Ethics, Rules of Conduct and Professionalism L3 Flashcards
Role and significance of RICS and its functions –
- Globally recognised professional body to have a positive change on the built and natural environments.
- Global standards, leading professional progression and data & insight.
- Provides confident markets, better buildings to live and work and positive social impact.
What is RICS? Purpose. Motto. Founded. Countries. Members.
- Royal Institute of Chartered Surveyors.
- Leading global professional body for Land, Construction, Infrastructure and Real Estate .
- Represent individual and firm members and protect clients.
- Est modus in rebus (“There is measure in all things”).
- Founded 1868.
- 146 Countries.
- 118k Members.
Lionheart;
- Charitable foundation setup by RICS
- Supports members faced with challenging times
Matrics –
- Network within RICS supporting and developing young professional members
Royal Charter
- Awarded in 1881 by Queen Victoria.
- RICS required to promote and regulate the profession whilst protecting clients.
- Changes to profession must be ratified by the UK government via the Privy Council.
RICS Headquarters
Parliament Square, London
Why become MRICS –
- Professional credibility by becoming chartered with the most prestigious surveying organisation in the world.
- Provide assurance to clients that their best interests are fundamental to the organisation
What are the RICS Professional & Ethical Standards – (reflection on you, your firm and RICS)
- RISTR
- Respect
- Integrity; Be honest, don’t show bias or act with conflicts of interest
- Service; Advise and communicate openly (fees, scope of services, extent of expertise)
- Trust; Promote the profession positively
- Responsibility; Be accountable, be diligent, question if not right
How do you maintain professional standards?
- Training / CPD – Keep up to date with latest information
- Comply with RICS rules of conduct and guidance notes
How might a firm create an ethical environment?
- Confidential procedures for whistle blowing
- Provide access to relevant information to promote best practice (e.g. Contracts and associated guidance docs)
- Provide regular training to advise on industry changes
RICS Decision tree –
- Guidance on how to act if uncertain on an ethical situation
- e.g. Legal?
- Sufficient facts?
- Complies with rules of conduct?
- Ok if scenario is made public (Internet)
Key Ethical areas
- Gifts, bribes and hospitality
- Discrimination
- Conflicts of interest
- Money laundering
- Confidential information
How do the RICS ensure standards and quality are maintained by members? What are they?
- Rule of Conduct -ESSCCCI
- Ethics
- Service
- Solvency
- Competence
- Co-operation
- CPD
- Information (confidentiality)
Ethical Behaviour
- Act with Integrity
- Avoid conflicts of interests
Competence (Rule of Conduct Members)
- Due skill and care e.g. Checking a scale
- Diligence (comply with technical standards e.g. Quantification approach using NRM2)
Service (Rule of Conduct Members)
- Respond in a timely manner
- Uphold professional standards (Use of latest guidance e.g. NRM1)
- Be clear on extent of expertise (QS - cost advice only e.g. not an expert on planning or structures)
CPD – (Rule of Conduct Members)
- Undertake at least the minimum 20 hours of CPD and submit to RICS
- Keep up to date with industry updates and relevant legislation
- Example of recent change relevant to QS / Construction
Solvency –
- Manage personal and professional finances
- Failure to manage business finances could detrimentally impact on client through sudden loss of service
Information to RICS –
- Submit information to RICS in a timely manner (CPD deadline end of Jan)
Co-operation –
- Co-operate as required with the RICS
- e.g. If client is dissatisfied then you should engage with any info required by RICS / other parties to resolve the issue
Rules of Conduct for Firms:
General (SC)
1. Service
2. Communicate
Conduct of Business (PCCCCSI)
3. Professional Behaviour
4. Competence
5. CPD
6. Complaints
7. Clients’ money
8. Service
9. Indemnity
Admin (DAASIC)
10. Designations
11. Arrangements to cover incapacity or death
12. Advertising
13. Solvency
14. Information
15. Cooperation
Why do the RICS have Rules of Conduct?
- Consistency of service
- maintain standards,
- protect clients,
- framework for advice
What would you do if you attended an event where MRICS colleagues were behaving inappropriately?
- I would remind that that they had a duty to comply with the RICS rules of conduct.
- Could detrimentally impact clients perception of company as well as the RICS.
- Potential loss of chartership status if actions warrant it. e.g. Discrimination, criminal activity
- Report if continued despite advice
RICS Bye-Laws -
- Rules adopted for governance of the members and its regulation
- e.g. Every member shall comply with the Rules of conduct
Conduct befitting of a chartered surveyor –
- Comply with rules of conduct
- Disclose those in breach,
- Declare criminal convictions
Registration of firm
- At least 1 principal member is RICS accredited.
- Details of PI
- Complaints procedure
- Training
- Registered at Companies house
- Locum
Complaints
Expression of dissatisfaction requiring resolution/acknowledgement
- Stage 1; Client formalises complaint in writing.
- Company acknowledges in 7 days
- Company respond within 28 and notify PI.
- Stage 2; Independent review if unable to resolve
Conflicts of Interest –
- Party (Arcadis acting for both Developer and Contractor)
- Own (Development that could detrimentally impact on your house i.e. potential to compromise your impartiality)
- Information Conflicts
Approach to Conflicts:
1. Identify
2. Clearly communicate
3. Highlight potential issue
4. Offer to step down
5. Client/ all parties written instruction if wish to proceed regardless
Gifts / Bribery –
- Do not accept if could be perceived to impact impartiality.
- Hospitality acceptable (sport, dinner, travel expense).
- Accepting gifts; Value? Who for? Proportionate? Timing (tender award)?
- Could declining offend? – Bribery is a criminal offence.
Bribery Act 2010 - Who is liable? Result of conviction? Levels of seniority accountable
- Bribing, being bribed, failure to prevent bribery
- 10 year prison, unlimited fine, director disqualification.
- All levels of seniority are liable for prosecution under the act
Arcadis Bribery Policy –
- As Bribery Act 2010. Not tolerated and employees should report any suspected activity
Price Fixing Monopoly (Construction) -
- Contractors collude in response to tender returns to artificially increase prices.
e.g. Actual Tender price circa £1m
Tenders 2 & 3 submit £1.3 & 1.4
Tender 1 submits £1.2
Modern Slavery
- Bonded labour; Where someone has borrowed money and is unable to pay it and is subsequently made to work to repay the money.
- Human trafficking; people exploited to work through threat, force or fraud.
PII – Why required? Covers what? Basis of indemnity cover?
- Professional Indemnity Insurance against a claim following negligence or failure of duty of care.
- Covers legal defence and compensation.
- Indemnity level based on previous years turnover.
Indemnity –
Why required?
- Assurance for client against negligence and protection/cover for RICS member
- Cover member against loss
RICS PI Insurance requirements:
- Each and every basis (i.e. claimants aren’t subject to an annual claim limit)
- Minimum levels of cover
- Run off cover (cover should the company be wound down)
Min. Indemnity
- £0- £100k = £250k
- £100-200k = £500k
- £200k+ = £1m Limit of indemnity
- Circa 2.5-5x Turnover
Run Off Cover
– Insurance against member retirement or firm ceasing to trade.
- Claims usually in line with limitations period of contract i.e. 6 (hand) or 12 (deed) years post completion
Babb vs Merett;
- Babb (surveyor & employee) undertook valuation for Merrett
- Survey later found to be negligent.
- Company no longer existed with no run off cover in place.
- Court ruled Babb could be pursued for losses personally given the lack if run off cover to protect the client (Marett)
Aggregate -
- £1m over a year.
- If a claim has been agreed at £1m another party can’t pursue any loss until the following year
Each & every -
- £1m can be sought by every claim made.
- e.g. 3x £1m claims could be brought in one year
How best to avoid claims:
- Advise within specialism (e.g. Structural aspects, planning, etc)
- Use RICS guidelines / follow best practice
- Keep records
Cost Plan Error - Example not QS fault vs lack of care / skill
- Must be proven to have acted with a lack of reasonable skill and care
- Market conditions changing would not constitute an error as this is somethings outside of their control
- Not checking a scale resulting in gross mismeasurement could constitute a claim
Friend asks you to complete a cost plan
- Still liable for claims so approach should be the same as in a professional context
General Insurance requirements of a firm
- Professional Indemnity cover (current and sufficient)
- Public liability - Covers injury or death to public, also covers loss or damage to 3rd parties
- Employer liability - Required by all firms employing staff, Pays out if employee is injured or ill
- Locum cover
- Run off cover
Client Account –
- Clearly denoted as a client account with name.
- Clear records e.g £10k received by X Client on 1 Jan 23 for z services
- Locum access - Third party access should director become incapacitated
What are the Principles of better regulation?
PACTT:
- Proportionality
- Accountability
- Consistency
- Targeting
- Transparency
Proportionality –
- Regulators should only intervene when necessary.
- e.g. Negotiation is the first ADR approach whereby parties should seek to resolve the issue prior to incurring time and costs by involving 3rd parties
Accountability –
- Regulators must justify their decisions and be subject to public scrutiny.
Consistency –
- Common fair approach to regulation.
Targeting (Principles of better regulation)
- Focus on the problem and minimise side effects.
Transparency – Principles of better regulation
- Openly communicate regulations clearly
Disciplinary Procedures
- Receipt of info
- Investigate
- Head of Regulation; Realistic prospect
- HoR concludes if no prospect
- Commence
- Decision
- Appeal
Issues that warrant RICS Disciplinary action
- Failure to use complaints procedure
- Conflict of interest e.g. Acting in interests of opposing party
- Misuse of clients money
- Allegation of a criminal offence
- Failure to comply with rules of conduct
- CHECK APPLICABLE AS SHOULD BE PROVEN IN COURT- Negligence e.g inaccurate measurement, not challenging inflated/illegitimate contractor variation/claim
Trigger of disciplinary proceeding
- Complaint / allegation to RICS
- Information received by RICS
Consequences of guilty determination
- Fixed penalty
- Expulsion from RICS (lose chartered status)
Grounds for expulsion directly by RICS
- Failure to pay membership fees
- Failure to maintain PI
- Failure to undertake CPD
Limitations of RICS (disciplinary context)
- Discipline a non member
- Pay compensation (redress scheme)
- Determine negligence (determined in court/legal system)
Continued Professional Development (CPD) –
- Ensure you are aware of latest industry developments.
- 20 hours PA (10 formal).
- Maintain professional & ethical standards.
- Formal = structured/course/technical author.
- Informal = Self-managed private study.
- Networking not classed as CPD.
- CPD recorded annually (31 Jan) via RICS website.
What sort of CPD have you done
- Inhouse training.
- RICS training.
- Personal reading.
- Examples TBC
Future/ongoing CPD selection
– Industry changes (Construction / QS) TBC
- Prevalent/hot topics e.g. Sustainability, Grenfell
- Requirements for future projects different to existing projects. e.g. Data centres (New Client)
Current RICS Structure
- Privy Council
- Governing Council
2.1 Regulatory Board - Sub Boards
3.1 Audit
3.2 Nominations
3.3 Admin
3.4 Leadership
3.5 Management Board
3.5.1 Finance
3.5.2 World Regional
3.5.3 Remuneration
Privy Council
- Grants and awards Royal Charter on behalf of the UK government
- Approve changes to the BYE LAWS
Governing Council
- Direct the RICS strategy (Increase membership, increase revenue e.g. Training, maintain standards)
- Management of royal charter obligations (Promote and regulate profession whilst protecting clients)
What is the Regulatory Board (RICS Structure)?
- Reports solely to the governing council on its activities
- Manages RICS regulation
- Chaired by non member to demonstrate independence
Management Board
- Day to day performance and delivery of the business plan set by the Governing Council
Presidential Team
- Elected by governing council.
- Provide leadership of issues facing the organisation
- Ann Gray 1 January 2023
President
President Elect ??
- Ann Gray; 1 January 2023
- ??
RICS Professional Groups
- 19 disciplines under 3 categories;
- Land, Property & Construction
Land –
- Rural
- Geomatics
– Environment - Minerals and Waste Management
- Planning and Development
Property (RICS categories)
- Valuation
- Commercial Property
- Facilities Management
- Residential
- Arts and Antiques
- Management Consultancy
- Property Finance and Investment
- Valuation of Businesses and Intangible Assets
Construction (RICS Categories)
- Quantity Surveying
- Building Surveying
- Project Management
- Infrastructure
- Capital allowances
Current RICS Issues – Initiatives -
TBC
Locums
- Covers long term illness & death etc.
- RICS member, Solicitor or Accountant are suitable Locums.
- Agreement; nature, confidentiality, conflict of interest, fee, ending, PI.
- Locum may need to oversee the sale of the business.
RICS Documents & status’
- International Standard (Mandatory Principles (MUST)) e.g. TBC
- Professional Statement (Mandatory rules (MUST)) e.g. TBC
- Code of Practice (Recommended good practice) e.g. TBC
- Guidance Note (Good practice SHOULD) – e.g. Contract Practice, Interim Valuations
- Information Paper (Good practice) – Insight (Information only) - Economic Report (Information only)
What is the purpose of guidance notes and should you follow them?
- Outline best practice and guidance how to approach elements of work.
- In a professional negligence claim the guidance note approach will be utilised to determine if a surveyor has acted competently
RICS Black Book
- Suite of guidance notes e.g. Interim valuations, valuing change, contract practice etc
Money Laundering
- Client; Secretive (identity or source of funds)
- Intermediary only
- Criminal association
- Overly knowledgeable on money laundering.
Parties; High-risk countries
- Connected without business reason
- Unusual transactions; fund Source; Large amounts of cash
- Unexplained third-party payments
Transaction Features (money laundering)
- Loss making
- Unnecessarily complex
- Unusual.
Money Laundering 2017
- Prevent exchange of money obtained from criminal activity.
- Identify customers
- Keep records
- Report suspicious behaviour
Guidance for firms (money laundering)
- Written ML policy
- Systems to implement guidance
- Provide training
- Keep reports of suspicion confidential
- Identify beneficial owner of potential transaction
- Notify senior person / ML officer to ensure compliance
Client paying in Cash (ML protocol)
- If the fees paid in cash are over £12k the government laundering department must be informed
GDPR
- General Data Protection Regulations
- Companies must establish processes to ensure compliance.
- Individuals have the right for their info to be deleted.
- Company penalty of 4% annual revenue.
- Report data breach within 72 hours.
- Right to be informed of what will happen to info.
- Right to access data. Can adjust and erase info.
FRICS
- Fellow
- Demonstrate intent to further the profession
- Act for the benefit of a third party
- Promote the profession.
- 4 categories in which the 17 characteristics are grouped within are: Champion – Expert – Influencer - Role model
FRICS Eligibility is assessed on characteristics, such as:
- Service to RICS (e.g. APC assessor)
- Gained a distinguished higher education qualification
- Leadership demonstrated by operating at a senior level within an organisation
- An individual who has developed an engaged a good reputation with Clients or secured high profile engagements
Mandatory Professional Statements - Conflicts of Interest
- Ensure the client receives the best possible advice and is not impacted by a conflict of interest e.g. Arcadis advising both Developer and Contractor
- Even if both parties accepted the position it would likely be perceived as lacking integrity
- Bring disrepute the profession / RICS
Common law -
- Common law is law that is derived from judicial decisions (case law) instead of from statutes.
- Their may not be an explicit statute but following case law a position may be established.
Construction and Technology Court
- Handle disputes about buildings, engineering and surveying.
- Cases that are heard include: claims about services provided by engineers, architects, surveyors and other professionals in this sector
- Claims about local authority duties relating to land and buildings environmental claims (e.g. pollution) claims resulting from fires challenges to decisions of arbitrators in construction and engineering disputes.
Conflict of interest
- Anything that impedes an individual or firms ability to act impartiality
- e.g. Arcadis acting for both Developer and Contractor
- Even if parties agree to appointment despite potential conflict if the appointment could be perceived as not being impartial then it should be avoided
Types of conflicts of interest
- Party e.g. Acting for a developer and the contractor i.e. one impacts on the other
- Own interest e.g. Development may impact the value of your home which could impact on your ability to act impartially
- Confidential information – e.g. Acting for two parties with are competing i.e. two developers interested in the same land. It may be difficult to stop information inadvertently go from one party to the other
Identifying a conflict of interest –
- I haven’t experienced a conflict of interest, but I appreciate that should one become apparent then I should disclose this to a client prior to providing a service.
- E.g. the fund monitor may also represent Arcadis.
Process for dealing with a conflict of interest
1: Inform Parties of issue
2: Offer to stand down
3: Obtain written confirmation that you can/can’t act
Still possible to proceed with potential conflict of interest?
- If all parties agree that it is possible to act impartially the clients approval should be sought in writing for informed consent and the arrangement should be clearly outlined.
- e.g. QS and fund monitor both Arcadis but surveyors based in different offices and respective information is confirmed as not being accessible by the other.
- Consideration should be given to perception of instruction e.g. If it is perceived to not be impartial it may have to be declined even if parties have agreed
Informed consent –
- RICS member has identified potential conflict of interest to all parties but said parties have given consent to proceed on the basis that advise can still be provided in the best interests of the respective clients.
- Consider perception of impartiality
What would you do if you were asked to work on a development that may detrimentally impact on the value of your home –
- If I was opposed to the development and
- thought that this could impact my impartiality
- I would decline the opportunity and
- aid in finding someone else who could help.
Transparency in professional fees
- Be transparent with clients in the fee for the professional service being provided.
- The client should understand the service they have agreed to pay for and there should be no hidden payments.
- Appointments should make clear anything that constitute additional payment or expressly not be included within the service
- e.g. life cycle costing or VAT advice
Checking a terms of an appointment document for compliance with RICS rules
- Attend meetings
- Monthly cost reports
- Advise client of required decisions for instructions
- Feasibility budget
- Cost plan development
- Tendering/Procurement
- Interim valuations
- Cost variation
- Contract matters e.g. L&E
Handling gifts and hospitality -
- Gifts & hospitality should not be accepted or offered if they are likely to compromise you or your firm’s impartiality or integrity
- or if it gives the impression of doing so as gifts are associated with bribery.
- Offers should be gratefully declined by being open and transparent about potential perception.
Money Laundering example. How would you respond and what would you do?
- Client requests that you make payment to the contractor on their behalf. - I would politely advise that we would not be able to do this.
- I would also report to a director /money laundering offer.
Complying with RICS’ CPD policy for members -
- All members must undertake a minimum of 20 hours CPD (10 hours must be formal).
Checking your employer’s compliance with RICS rules for firms
PSCCCI
- Professional
- Service
- Competence
- CPD
- Complaints
- Clients money
- Indemnity
Dealing with a conflict of interest L3
- During the latter stages of Final Account negotiations on the UPS scheme one of the Main Contractors involved in the negotiation
- asked if would like to attend a social event and dinner.
- Due to the pivotal timing of the invitation, I politely declined explaining Arcadis’ policy of accepting gifts.
Providing advice within your expertise / contractual authority L3
Whitwell – Client asked about Party Wall issue – I understood principles but advised it would be appropriate to liaise with a party wall surveyor.
Dealing with a complaint
Not done but understand process;
- Stage 1; review by senior member of firm
(7 days acknowledge – 21 days respond)
- Stage 2; Referred to redress scheme
CHP information can be requested as indicated in Arcadis’ terms of appointment
- Line Manager (7 days) 21 days to advise on outcome
- If unable to resolve escalated to Tom Mckenzie (Senior Director).
- If unable to resolve issue is directed to redress scheme.
- Arcadis have 14 days to present information.
- Redress scheme have 21 days to respond.
Handling client’s money
- Separate client account.
- Clear record of transaction; date, who from, what for
Importance of clear process for dealing with client money
- 3rd party can identify origin of funds;
- Insolvency (either party)
- Death of sole practitioner,
Left over client money –
- Find owner
- Hold for 6 years
- Donate to charity
Setting up professional indemnity insurance –
- Duty to hold adequate insurance to protect client.
- Each and every basis e.g. not impacted by other claims. If other claims had exhausted limit in the period.
- Cover based on preceding year turnover up to £100k= £250k turnover - £200k = £500k turnover over £200k+= £1m.
- Run off cover in the event the business is wound up to allow a client to bring action within the limitation period.
Registration of a firm with RICS.
- At least 1 principal member is RICS accredited.
- Provide PI
- Complaints
- training
- Register with Companies house
- Locum in event director becomes incapacitated
What are the Rules of Conduct?
- Honesty and integrity - not act with conflict of interest, comply with bribery act
- Professional competence - specialist knowledge, CPD
- Diligent service - Understand client requirements, be clear on scope, deadlines
- Respect - promote inclusivity
- Act in Public interest - Instil confidence in profession
Can you give me an example of when you have provided good client care?
What ethical standard would that example fall into?
Whitwell Party Wall - Service. Advising within expertise
Why do you think a firm would want to be regulated?
Benefits from public/clients being assured that they are accountable for delivering a quality service.
Public confidence maximises business
If a firm wished to be regulated, how would they go about this?
At least 1 principal member is RICS
PI
Complaints
Run off cover
Locum
What are the rules around the use of the RICS logo?
Must display on its business literature to denote that it is regulated by RICS.
If you were in a meeting with a Client and were asked a question you did not know the answer to, how would you handle this?
I would advise that I wasn’t sure but that I would check with a colleague and come back to confirm
If you found yourself in a situation where there was a potential conflict of interest, what would you do?
Confirm conflict to parties
Assess whether I could act impartially
Confirm with parties if they were happy to proceed
What is the purpose of the international standards and professional statements?
Do the international standards and professional statements have to be abided by or are they for guidance?
International Standard (Mandatory Principles (MUST))
Professional Statement (Mandatory rules (MUST))
Code of Practice (Recommended good practice)
Guidance Note (Good practice SHOULD) Information Paper (Good practice)
Insight (Information only)
Economic Report (Information only)
What would happen if a member didn’t follow any of the guidance notes?
In the event of a claim being brought against a firm not complying with guidance notes will weaken their defence.
Are you aware of what the Black Book and Red Books are?
The Black Books set out guidance from RICS on how work should be approached
Once qualified, how are you going to maintain your membership and what are your obligations? Also firm reqs
Members
1. CPD
2. Cooperate
3. Information provision
Firms
1. Complaints
2. PI
3. Run Off Cover
4. Cooperate
5. Information Provision
6. Display RICS
7. Reporting reqs for reg. of Firms
How are the disciplinary proceedings handled?
What is the role of the Head of Regulation?
If you were found guilty of committing “low level” breaches, what could happen as a result of this?
What are some of the penalties that can be levied for more serious breaches?
What is the purpose of the appeal panel?
In what circumstances might a member receive a Consent Order?
If a member didn’t complete their CDP requirements for a year, what kind of disciplinary would they likely receive?
Potentially in weeks’ time you will be chartered and in a months’ time you decide to set up your own business. There’s no one else in the business other than yourself, how would a complaints handling procedure be handled then?
If a complainant wasn’t satisfied with the outcome of review, how would this be addressed?
Are you aware of any Independent redress mechanisms?
Other than your own firm, who should you notify if a complaint is made against you?
How would a Client of yours find out about your firms complaints handling procedure?
How do you protect yourself against claims of negligence?
Why would a firm require professional indemnity and who does it protect?
If you were to identify the level of PI required as a business, how is this determined?
If you set up as a new business with no trading history, how would you determine this?
If a company ceases to trade, what happens to PI at that point?
Is run off cover indefinite or is there a limit?
If you were in a social environment and a friend came up to you and asked for some professional advice, what is your response to that?
What would you do if a contractor offered to take you to the Champions League final?
If you weren’t involved in a project with a Contractor and they sent you a bottle of wine at Christmas, would you accept it?
Where do you record all gifts that are received?
What is your company’s policy on receiving gifts?
What legislation is in place to govern this?
Can you tell me a bit more about the Bribery Act?
What are the six principles of the Bribery Act?
What is a bribe described as?
What should you do when handling client’s money?
What is the Client’s Money Protection Scheme run by the RICS?
If a Client went on holiday for 6 months and asked you to manage the project payments, how would you deal with this?
How often should the bank reconciliation be checked on the account?
How would you handle cash payments?
Are you aware of any RICS guidance on the handling of Client’s money?
How many signatories are typically required when withdrawing or processing Client’s money?
What four key requirements are there for lifelong learning?
How many hours of formal hours is a chartered member expected to undertake each year?
How often should the RICS global professional and ethical standards be reviewed?
Can you give me some examples of what would count as informal CPD?
When is the deadline for submitting your CPD for the year on to the RICS website?
If a member fails to log their annual CPD hours on time, what may happen?
What compliance do the RICS enforce when setting up your own firm?
If you were a sole practitioner and you resulted in taking serious illness of death, who would then manage your business?
What are some of the statutory compliance you would need to abide by when setting up your own firm?
What is the level of PI required for all new businesses?
If you weren’t a regulated firm by the RICS, do you have to adhere to their rules of conduct?
If someone came up to you for professional advice but you didn’t have the capabilities or expertise, how would you handle this?
Is there anywhere you would direct them to seek the required advice?
When shutting down a practice, what must you ensure is in place?
