Professional February 2021

Professional February 2021

Official publication of The Chartered Institute of Payroll Professionals PROFESSI NAL Issue 67 February 2021 in Payroll, Pensions & Reward

Remote working and payroll software in the cloud

Employer-provided seasonal flu jabs Treatments Payroll saved from pension misery Solutions Starting your own business Stimulants

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On pages 37–42 are several articles on remote working and payroll software in the cloud. Will these become the enduring ‘new normal’ ways of working? See pages 20–21 for a reminder of the

how some previously displaced individuals have successfully set up a new business. Might some readers want to act similarly? Best wishes – and bring on vaccination!

imminent introduction of the postponed off-payroll working rules. Has the pandemic reduced the impact on employers? A continuing effect of the pandemic is job losses. This issue has the first two in a series of articles (pages 10, 11, 13) on

Mike Nicholas MCIPP ([email protected]) Editor

I hope this finds each of you safe and well and adjusted to the new ways of working. The main theme for this edition is remote working and payroll software in the cloud, so I will touch on both. With focus on safety and flexibility, the Chair’s message

a level of over-communication, so that everyone remains engaged. New team members, whether new to the industry or just new to the team, must be fully supported to feel engaged and part of the team and I would always encourage social time, so the coffee- break chats are not lost. As for the cloud and accessing payroll software anywhere, anytime, the pandemic has certainly brought that type of strategy and capability to the fore as all businesses review their digital transformation strategy and consider whether or not they can truly work remotely in an efficient manner. I hope you find the articles contained in this edition of interest and of benefit to you, and please do drop me a line if you want to discuss anything contained in more detail

movement towards remote working and a continued approach to this initiative, pose several questions. What may have been considered as a short-term drive to support the health of the nation, has become a longer-term strategy. Adjusting to this and deciding if it can truly work for you is almost exclusively a personal choice, as it has to take into account an individual’s home life, whether they can work safely and confidentially in that environment, and not just whether there is a choice involved. If the answer is ‘yes’, then managing your working day and commitments becomes much more disciplined to ensure it does not stray into personal time. Also managing teams remotely requires a greater focus on a variety of communication styles and

Jason Davenport MCIPP MIoD ([email protected]) Chair, CIPP

Let’s hope that 2021 is much better year than last year. Writing this just prior to Christmas, it’s been perturbing to see an increase in the tiers/ levels in many parts of the UK. I’m sure that many of us, back in March 2020, never imagined we’d still be in the throes of this pandemic. It is to CEO’s message

and appeals committee, led by our independent chair, Helen Fairfoul, who, with various board colleagues, met and interviewed all candidates as part of our governance process. The successful candidates who will stand for election will be announced at our AGM on 31 March (currently planned online through MS Teams, but watch this space)(see page 17). You will notice this date is a change from our usual AGM date in December, which has arisen due to the change in the CIPP’s financial year some three years ago. This change put considerable pressure on timeously completing the year end processes, and yet adhering to the Charter in which the AGM had to be held in the same year. The Charter changes recently agreed by the membership has allowed us to move the AGM into the following year, easing the pressure on the year end accounting process and allowing more measured time for applications for board positions by the membership. Remember to use your vote! All that remains is to wish you all a safe but successful and prosperous 2021!

be hoped that the release of vaccines, slowly but surely, will move us to some degree of normality – but who knows what ‘normality’ will look like going forward. And just as we see a glimmer of light at the end of that particular tunnel, we have to contend with the small matter of what Brexit looks like. Just a year ago the notion that whole payroll teams and departments decamping home en masse would have been unthinkable, for various operational and governance reasons. But we did it – and were acknowledged by government as key workers in ensuring the UK continued to be paid. It’s an intention of the CIPP to hold more roundtables and the like on the very topic of what the ‘future payroll professional will look like’ and how the pandemic has influenced and shaped the future of payroll. We will seek contributions across all of our membership levels on this topic. February sees the election opening for two new directors to the CIPP board. As usual we had a large number of members putting themselves forward for election. I’ve been grateful for the support of the nominations

Ken Pullar FCIPP ([email protected]) Chief executive officer, CIPP

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| Professional in Payroll, Pensions and Reward |

Issue 67 | February 2021

in Payroll, Pensions & Reward PROFESSI NAL

Also available online at payrollpensionsandreward.org.uk

Contents

February 2021

THIS ISSUE’S FEATURE TOPIC REMOTEWORKING AND PAYROLL SOFTWARE IN THE CLOUD

39 Remote working

and payroll software in the cloud

by Jerome Smail

Features

10

13

19

CJRS and the importance of compliance by CIPP’s policy and research team

Starting your own business by Jo Marshall

Starting your own business by Jason Davenport

22

28

20

Preparing for off-payroll working by Lora Murphy

Employer-provided seasonal flu jabs by Beverley Gibbs

GMP equalisation by Gareth Stears and Dave King

| Professional in Payroll, Pensions and Reward | February 2021 | Issue 67 2

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Chief executive officer Ken Pullar FCIPP CIPP board of directors Jason Davenport MCIPP MIoD Stuart Hall MCIPPdip Dianne Hoodless MSc ChFCIPP FHEA Editor Mike Nicholas 0121 712 1000 | [email protected] Advertising Vickie Graham 07775 564 352 | [email protected] Design James Bartlett, Nicole Davis and Sam Parkes [email protected] Printing Warwick Printing Company Ltd

Failure to return to work, whistleblowing events, age

Payroll saved from pension misery by Henry Tapper

discrimination by Nicola Mullineux

32

35

Payroll saved from pension misery Gender pay gap reporting 2021 by Danny Done Passionate about payroll automation by Maria Mason

37 Henry Tapper, chief executive officer of AgeWage , outlines radical proposals and the CIPP’s key role 38

Liz Lay MSc FCIPPdip Carole Pearson MCIPP Katie Sharpe ACIPPdip

Finance’s reliance on legacy systems by TimWakeford

Cliff Vidgeon BA (Hons) FCIPP CMA ACIS Clare Warrington MSc FCIPPdip AFHEA

Payroll in 2021 and beyond by Simon Parsons

Useful contacts

42

Education [email protected] 0121 712 1023 Events [email protected] 0121 712 1013 General enquiries [email protected] 0121 712 1000 Marketing and sales [email protected] 0121 712 1033 Membership [email protected] 0121 712 1073 Training [email protected]

I’m a payroller, get me out of here! by Jennifer Morrell

Regulars

01 Editor’s comment, and Chair’s andCEO’smessage 05 CIPPupdate, We’ve got mail Events, news and developments 06 My CIPP Policy hub: On your behalf, Advisory 10 Personal development Starting your own business, A week in the life of, BePayroll, Diary of a student

19 Compliance 24 Payroll news 27 Rewardnews 28 Reward 35 Technology

0121 712 1063 cipp.org.uk @CIPP_UK

Articles Please support this magazine so that it can continue to be a part of your membership package. Trademarks The CIPP logo, the initials ‘CIPP’ and the words ‘Professional in Payroll, Pensions and Reward’ and ‘CIPP Consult’ are trademarks of the Chartered Institute of Payroll Professionals. Copyright: The Chartered Institute of Payroll Professionals 2021. The Chartered Institute of Payroll Professionals, Goldfinger House, 245 Cranmore Boulevard, Shirley, Solihull, West Midlands, B90 4ZL. Switchboard 0121 712 1000 Copyright This magazine is published by The Chartered Institute of Payroll Professionals in whom the copyright is vested. All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or any means, electronic, mechanical, photocopying, recording or otherwise, without the prior written permission of the publisher. The views expressed in this publication are not necessarily those of the CIPP or the editor. The information and comment contained in this publication are given in good faith, their accuracy or completeness cannot be guaranteed.

44 Industry news 47 Wordsearch 52 Confessions of a payroll manager

16 Movers and shakers 17 Charity news 18 COVID-19 news

Full issue including additional online content available at payrollpensionsandreward.org.uk

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| Professional in Payroll, Pensions and Reward |

Issue 67 | February 2021

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CIPP update

Congratulations to the newly accredited PAS organisations

WELCOME TO the February edition. We hope January went well for you all, and that you are settling into the new routine for 2021. If you or your business are thinking of changing software provider, then our 2021 Software Directory will be included in the March issue. This supplement enables you to review and compare products at a glance, a great tool to help with your forward planning. Looking back to the end of 2020, the last activities the CIPP held before the Christmas break were two Chartered members’ events during December. One was held on 2 December and the other on 9 December. These events were scheduled as a replacement to the usual Chartered dinners held throughout the year. They were extremely well-attended and lively events and were a great opportunity to network with others in the industry; something we did not have much opportunity to do in 2020. We kick off 2021 with our new and re-branded members only ‘BeKnowledgeable’ webinar events. The first was held on 19 January and focussed on off-payroll working (also sometimes simply referred to as ‘IR35’), as we help to prepare the industry for the introduction of the reforms into the private sector. The second will be held on 10 February and will focus on the national minimum wage. The new BeKnowledgeable webinar sessions, which will be hosted by our policy team officers, Gemma Mullis and Lora Murphy, are designed to help CIPP members be at the top of their game. Keep your eyes on our website, emails and our News Online service for details of more BeKnowledgeable webinars coming up throughout the year.

i

i

THE CIPP’s Payroll Assurance Scheme (PAS) is designed to test your payroll processes in relation to payroll processing, compliance and the people skills and development opportunities.

One of the most important elements is ensuring business continuity plans are in place and effective should they be required. Given recent events, congratulations to all organisations that have achieved this accreditation and will have been able to put those plans into action. Special congratulations to our recently accredited organisations: ● Trident Trust Marine Services ● University Hospitals Birmingham NHS Foundation Trust Ken Pullar, CIPP chief executive officer, said: “Never has it been more important for businesses to have good payroll processes, knowledge and skills that enable them to implement new government legislation and guidance quickly. Congratulations to those organisations that have recently demonstrated just that.” The Payroll Assurance Scheme is still operating, with assessments currently operating virtually. To find out how the Payroll Assurance Scheme can benefit your organisation, email [email protected] .

Aggregation of earnings

Memories of Norman Green I was sorry to hear of the death of my friend and former colleague Norman Green. I used to represent HM Revenue & Customs, formerly Inland Revenue, at payroll conferences from the late 1980s through to 1995, when I took early retirement. I met Norman through your conferences and through his work with the British Computer Society. In my role as group leader of the Employer Group on PAYE Operational Policy I valued highly the chance to work with Norman. His constructive criticism worked even-handedly with support if he felt that the departmental representative was in danger of getting an unreasonably rough time! class 1 National Insurance contributions (NICs) and hence the monthly earnings period was used. Monthly employment tended in the main to be full-time, and the nursing bank work was thus non- pensionable, being classed as ‘overtime’ for NHS Pension Scheme purposes, so being not contracted-out employ ent. Occasionally I did come across examples of weekly and monthly contracted-out employments which gave rise to the problem described in the article. Norman and I shared a friendship and personal interest in interesting cars, and it is on that account that I particularly recall the BPMA’s autumn conference of 1994, held at my beloved National Motorcycle Museum. I had addressed the conference during the afternoon and sat down with him over a cup of tea. He knew of my plan to buy a Morgan Plus 8, knew that I had not actually ever driven a V8 car, and insisted that he and I take a little trip in his Reliant Scimitar, before each setting off for home. I didn’t need to be asked twice! I bought my Morgan 22 years ago, still own her, and often think of that afternoon when setting off round Worcestershire lanes. I am sad to realise that last year’s exchange of Christmas cards was to be the end of a chapter. I shall think of you, Norman, when our postman begins this year’s deliveries. My kind regards go to any who may vaguely remember me from those halcyon days. A solution to this, which HM Revenue & Customs were quite happy with at the time, was to pay the bank work on a monthly basis but provide an advance of the bank nurse work. The bank work pay was reduced by an amount representing the tax and NICs due. A specified number of the bank weeks would then be automatically transferred within the payroll to be processed with the monthly pay and the amount advanced recovered. Not sure whether the advance pay method would be allowed now under real time information, since it is a ‘regular’ payment – well, as regular as ‘as and when work’ can be. Surprised somewhat both that it hasn’t cropped up before and that it wasn’t anticipated when the abolition of contracting-out was first mooted. Unusual for the payroll industry not to have picked up on this. Whether it’s because aggregation is a mainly public sector problem, and perhaps limited mainly to the NHS, although I’ve no evidence of this. David Toye Pages 20 and 21 of issue 66 (December 2020 – January 2021) of Professional magazine featured an article on this payroll processing problem, prompting the following welcome communication. The use of the weekly earnings period looks like an unexpected consequence of the abolition of contracting- out. This is because contracted-out employment took precedence over not-contracted-out employment for

Vince Ashall MSc FCIPP

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| Professional in Payroll, Pensions and Reward |

Issue 67 | February 2021

MY CIPP

On your behalf

Policy team update

The CIPP’s policy and research teamprovide an update on developments

T he CIPP’s policy team are always striving both to raise the profile of the payroll profession and to educate members and non-members in relation to both current payroll policies and those on the horizon as and when proposed by the government. In order to facilitate this, the team attend a number of meetings, and respond to consultations published by various government bodies. The tail-end of 2020 saw much activity in that space, and the team were involved with several meetings to discuss both current and potential future policies that are impacting, and will impact, the work of payroll professionals.

that has employees working in the EU or European Economic Area (EEA). The same applies if their employer seconds or posts UK employees to work temporarily in an EU or EEA country. Avoiding pension scams The Pensions Regulator (‘the Regulator’) runs a number of campaigns to alert individuals saving for their future to the types of pension scams currently in operation. Unfortunately, the number of scam schemes has increased significantly throughout the pandemic, as unscrupulous criminals attempt to prey on the most vulnerable in such uncertain and turbulent times. What the Regulator is reporting is that it is seeing an increase in savers wishing to transfer their pension due to the instability of their employer or the broader financial markets. The resounding message to savers is to be cautious and vigilant, particularly of scammers who attempt to lure them to what is known as ‘safe havens’. Where savers are enquiring about transferring their pension, the advice is to direct them to the Financial Conduct Authority’s (FCA’s) ScamSmart page (http:// ow.ly/8hin30rp8ox) which offers detailed guidance and gives particular emphasis to pension scams that are in place as a result of the impact of Covid-19. Key pieces of advice for savers are as follows: ● Reject unexpected offers – Where there is an offer of an investment

opportunity that was completely unexpected, it is highly likely that either this relates to a high-risk investment or it is a scam. The scams can come through a variety of communication methods with cold-calls often used; however, a scam could arrive in the form of an email, by

post, or be advertised online. ● Be wary of warning signs –

Unexpected contact, time pressure, social proof, unrealistic returns, false authority, and flattery, are all cited as warning signs of pension scams. ● Check if a firm is FCA-authorised – The majority of financial services firms must be authorised by the FCA, and if they aren’t any pension offers are likely to be scams. Individuals can access the Financial Services Register (http://ow.ly/ RBUr30rp8pW) to establish whether a firm or individual is either authorised or registered. ● Ensure the contact is not from a ‘clone firm’ – This is a frequently used scamming method, in which the scammer company poses as a genuine firm. Use the contact details provided on the FCA’s Register, and not the details provided by the firm. A firm’s details should also be checked with directory enquires or Companies House (http://ow.ly/M7qa30rp8q6) to ensure that they match. ● Check the FCA warning list – Savers should utilise the FCA Warning List (http:// ow.ly/b6iP30rp8qq) to check the risks of a potential investment. There is a reminder, however, that even if a firm is not included on the list, it could potentially still be operating a scam. ● Get impartial advice – Savers are advised to consider seeking financial advice or guidance, prior to investing. The Money

Expat Forum The Expat Forum brings together

professionals who deal with the payment and treatment of expatriates, living and working outside of the UK, and also of those who come from abroad to work within the UK. At the forefront of everyone’s mind is what is going to happen in terms of reciprocal social security agreements between the UK and countries in the European Union (EU). At the time of writing, no formal agreements have been confirmed with EU countries, with the exception of Ireland; Switzerland and the UK have also confirmed that they have made an agreement. Payroll professionals must await further guidance on how to proceed if they process the payroll for a UK employer

...no formal agreements have been confirmed with EU countries, with the exception of Ireland...

| Professional in Payroll, Pensions and Reward | February 2021 | Issue 67 6

Policy hub

One hour skills boosting courses New one hour e-learning courses for only £75 +VAT

Advice Service provides information on investing and how to source a financial adviser (http://ow.ly/1RCn30rp8qF). ● Report any suspicions – Individuals suspicious of a firm, and believe they are operating a pension scam, should contact the FCA’s Consumer Helpline or use its reporting form (http://ow.ly/3Ezz30rp8tX). ● Be wary of future scams – Those who have already fallen victim to scams are more likely to be targeted again, either by the same fraudsters or by other criminals who have purchased the person’s details. ...employers can claim for 80% of employee wages for the remainder of the duration of the CJRS... Construction Industry Forum The policy team recently attended the inaugural meeting of the Construction Industry Forum, a stakeholder group recently established which includes members from the tax, accounting and construction industries. The CIPP will attend this forum to provide the payroll industry’s perspective, with particular focus on how the construction industry scheme offsets interact with real time information and pay as you earn (PAYE) functions. Student loan consultation group During the recent consultation group updates were given on the implementation of the Plan 4 student loan which will be in place from 6 April 2021. This plan will relate to those who took out a Scottish student loan while they were studying. Those who are on either Plan 1 or Plan 2 to whom this relates will, from 6 April 2021, be moved onto the new Plan 4. It has been confirmed that notification to move these employees will be sent at the same time as the usual SL1 student loan start notices in early March 2021. Employers will not get start and stop notices for affected employees but will be advised to ‘swap’ the current plan of an employee to Plan 4. Employers need to ensure that this change is actioned, as not doing so will mean the employee is overpaying their student loan. This does

not just relate to employees in Scotland, but across the whole of the UK. If the request to ‘swap’ is not actioned, via PAYE real time information, employers will be sent a notification from the generic notification service (GNS). The policy team advice is not to ignore any GNS message, and to action any notification sent, especially around student loans, to ensure that the deductions are correct to each employee’s circumstance. Further extension to the CJRS Ordinarily, when there is a major update to the workings of the coronavirus job retention scheme (CJRS), or indeed, any of the measures relating to support for businesses and individuals through the outbreak of coronavirus, an announcement is made in the Houses of Parliament. On Thursday 17 December 2020, however, the chancellor of the Exchequer tweeted about an additional month-long extension to the CJRS, thereby signifying the importance of social media and highlighting the many ways in which payroll professionals should keep up to date with important developments. What this means is that, as opposed to closing on 31 March 2021, the CJRS will now close on 30 April 2021. Initially, it was advised that the level of government support through the scheme would be 80% for November 2020– January 2021, and that there would be an assessment of the ongoing impact of the pandemic closer to the time in order to establish the amount provided by the government for February and March 2021. It is now confirmed that employers can claim for 80% of employee wages for the remainder of the duration of the CJRS, until the end of April 2021. The Budget date was also announced and will be delivered on 3 March 2021. By extending the length of the scheme by an additional month, this gives more than 45 days for employers to make business decisions following on from the announcements made in the Budget. In situations where businesses are required to make more than 100 redundancies, the consultation period must commence at least 45 days before any dismissals take effect, so the rationale behind timescales is apparent. At the time of writing, additional guidance on the extension to the scheme had not been published. n

One CPD point per course

Calculating income tax

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For more information or to enrol: Visit: www.cipp.org.uk Email [email protected]

Call: 0121 712 1044 Live chat with us

cipp.org.uk @CIPP_UK

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| Professional in Payroll, Pensions and Reward |

Issue 67 | February 2021

MY CIPP

The CIPP's Advisory Service team provides answers to popular questions

Q: Do expenses form part of attachable pay for the purpose of calculating deductions under an attachment of earnings order? A: Payments the employer makes to reimburse expenses the employee incurs in the employment are not within the definition of attachable pay for attachment of earnings orders. If you are unsure whether a particular item is within scope you could contact the originator of the order to seek confirmation. Q: An employee who is being made redundant this month had purchased a bicycle under the cycle-to-work scheme. The salary reduction was first due to occur this month. Are we able to deduct anything more under salary sacrifice? A : Unfortunately, you are not able to make any deductions through salary sacrifice. You should refer to the terms of the agreement reached between the employee and the employer to establish what happens if, amongst other things, the employee ceased employment during the loan period. Such a relevant provision might, for example, require return of the cycle and/or permit a deduction from the employee’s net pay. If the cycle is less than five years old and ownership is transferred to the employee, a taxable benefit arises based upon the cycle’s age at the date of transfer, its original cost and the acceptable disposal value percentage. The employer would pay class 1A National Insurance contributions (NICs) on this amount. For reference purposes, see pages EIM21664–EIM21668 in HM Revenue & Customs’ (HMRC’s) Employment Income Manual (https://bit.ly/3gmAsd2). Q: An employee would like to buy their employer-provided laptop from the business. Is there a reportable benefit?

A: As the company owns the laptop, which the employee is purchasing, there would be a transfer of an asset and therefore a taxable benefit arising under section 206 of the Income Tax (Earnings and Pensions) Act 2003. The taxable benefit would be reported in the P11D return at section A. The cost of the benefit would be the market value of the asset at the time of transfer less any amount made good by the employee. Even if the amount made good reduces the taxable benefit to zero, this will still need to be reported in the P11D. Q: A third party customer wishes to pay a cash bonus to a client’s employees for their hard work during the coronavirus pandemic. Is this taxable? A: Yes, this will attract both PAYE (pay as you earn) income tax and class 1 NICs; however, the collection of this isn’t as straightforward as normal. When an award is given to an employee from a third party, it is classed as a third-party award. As this award is being given in cash, the following must be applied. The third party must process the value of the award for PAYE tax purposes, which mean obtaining details from each employee being given the award. The third party would then process the payment via their payroll for tax purposes only, with many grossing this up so that the employee receives the full cash amount. The employer must then be notified of the cash amount gifted and the tax associated and paid on the cash given. The employer then adds this to their employee’s PAYE record as a class 1 NICs liability only, thus both the employee and employer paying class 1 NICs on the value. Guidance on third party awards is available here: https://bit.ly/2K1OC84 and here: https://bit.ly/3mvjIlx.

Q: An employee has received a temporary National Insurance number (NINo) due to the Coronavirus pandemic. Should we operate this in the payroll system? A: You would not use the temporary NINo in the payroll system as they are not accepted by the Quality Standard. If, when submitting a full payment submission (FPS) for the employee, the employer does not know their NINo, the NINo field should be left blank but the employee’s date of birth and gender entered in the appropriate items. See page NIM39110 of HMRC’s National Insurance Manual (https://bit.ly/3qCvRbJ) for guidance. Q: How many keeping in touch days are parents entitled to during statutory shared parental leave (SShPL)? A: For the purpose of whether a parent is considered to be ‘working’ which would affect payment of statutory shared parental pay and continuation of entitlement to SShPL, a parent can undertake work on twenty SPLIT (shared parental leave in touch) days. Q: Why is there a fluctuation of 20p in an employee’s tax deduction this month? A: The fluctuation is due to the rounding in the taxable pay amount (e.g. after deducting the tax free pay), as the calculation of the tax is based on whole pounds. When working out income tax cumulatively under pay as you earn, eventually the previously ignored pence make a whole pound and then 20% of this is 20p, which is where the difference comes from. Q: When submitting a P46(Car) return for an employee who is giving up a cash allowance and taking a company car, do I show the annual value of the

| Professional in Payroll, Pensions and Reward | February 2021 | Issue 67 8

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allowance given up or the list price of the car (depending on which is more)? A: The P46(Car) return asks for all the relevant information and also if the employee is giving up/foregoing ‘cash’ to be in receipt of the car and the value. The value entered would be the annual amount the employee would have received if they had not chosen the car, but this may be prorated if the employee is in receipt for only part of the year as illustrated by the following example: Sue has decided that she would like to give up £5,000 of her salary for a company car that she will receive in June. The value of cash foregone would be calculated as: £5,000 ÷ 12 × 10 = £4,166.67 (June to March = 10 months for the calculation). Q: We employ seasonal workers who remain ‘dormant’ for many months and usually do not return to work. When should we remove them from the payroll? A: There is no guidance on when you should remove dormant employees. HMRC, however, will assume an employee has left the employment if they are not paid after a three-month period. It is recommended to have >Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56

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