Professional July/August 2021

Professional July/August 2021

Official publication of The Chartered Institute of Payroll Professionals PROFESSI NAL in Payroll, Pensions & Reward Issue 72 July/August 2021

Payroll: in-house v as a service

The language of payroll Roots, signposts

Solving payroll recruitment headaches Ways andmeans

Farewell to the EYU Directions

CIPP UPDATE POLICY HUB PERSONAL DEVELOPMENT

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Editor’s comment

Nothing stays the same forever, and the same applies to being editor of this magazine. I am gradually retiring while

of the magazine, the first I edited. So, if my maths is correct, by end of 2021 I will have edited 130 issues and many supplements. It has been a privilege and a source of joy to edit them.

supporting CIPP’s Lora Murphy transition into the role (see page 10 for a brief outline). If all goes to plan, it is envisaged that the December/January issue of the magazine will be my last as editor. I can still vividly remember working on the February 2009 issue

Mike Nicholas MCIPP ([email protected]) Editor

Chair’s message

The feature discussion topic for this issue is payroll provision, in-house

with in-house expertise. Payroll provided as a service can appear the easier option, which removes some of the employment law complexities and can initially be the most cost-effective option, until add-on costs start to increase for additional reports or bespoke requirements to meet the changing business needs. A popular way for companies to determine the route they will take is to map all the options – including arguments for and against, together with associated costs to calculate the cost per payslip – and understand those that best serve the business’s interests. For payroll: in-house v as a service, there is no easy answer, and for many employers trying to find the right solution can be a recurring cycle every three or five years. Whichever option is chosen, it is essential employees are paid accurately and on time and that companies meet all the legal obligations surrounding PAYE etc.

versus as a service. It is a consideration for all businesses both large and small. The business world sees one-man bands processing their own payrolls using the free

tools provided by HMRC; others will purchase tools on the market aimed specifically at small employers; but many small businesses will use the services of their accountant. Mid-size companies too big to use HMRC’s free tool are faced with options such as employing a payroll professional to process payroll in-house, use their accountants, or a payroll bureau. Large employers will process payroll in-house or use a varying level of managed services provided by payroll bureau. Whichever size business, various issues are considered with the main one usually being cost. Others involve people, as it is not as simple as employing a person or team to process the payroll. Companies will look for specific skills, knowledge and fit, which then need to be maintained to avoid fines and penalties for non- compliance. However, this option does then provide the company

Liz Lay MSc FCIPPdip FHEA ACIPD ([email protected]) Chair, CIPP

So, as we enter our summer season, let us also hope the gloomy weather of April and May has well passed us by and I can testify, as I live in Cornwall, that the ‘staycation’ is well and truly in vogue! I have over the last year (well, sixteen months, CEO’s message

when employers recruit staff in the pensions and payroll arena. Since my early days in the profession, I have personally benefitted from them, and through various employments ensured that my payroll and pension teams have used them in their career road map. Today, my role is in ensuring no pension or payroll professional sits at a desk (either in the office or at home!) without having the necessary education to do their role professionally. Great testament is also due to past and present pension and payroll professionals in their roles as subject matter experts, tutors, mentors, moderators, invigilators and the like who have brought together all their skills in writing and delivering content that comes from years of experience in the professions. I continue to offer my grateful thanks to those 100+ tutors and trainers who ensure our material is relevant and fit for purpose so that we continue to be seen as key workers in the organisations we represent. Keep safe and well.

now), reflected (just like many other organisations, large and small have done) on how we have all adapted our way of working. In both the payroll and pensions arena where generally the thought of ‘working from home’ was something never entertained and yet overnight we turned that on its head. Truly a testament to the professionalism of all in our industry. What has been really gratifying during this pandemic has been the uptake of education, training and membership from you and many new members as they (and their employers) have recognised the contribution of payroll and pension professionals in keeping the UK paid. It’s encouraging to see the Payroll Technician Certificate, Certificate in Pensions Administration and the Foundation Degree in both Payroll Management and Pensions Administration and Management go from strength to strength. These qualifications are becoming the gold standard requirement

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

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| Professional in Payroll, Pensions and Reward |

Issue 72 | July / August 2021

in Payroll, Pensions & Reward PROFESSI NAL

Also available online at professionalmag.co.uk

Contents

July / August 2021

THIS ISSUE’S FEATURE TOPIC PAYROLL: IN-HOUSE V AS A SERVICE

40 Payroll: in-house v as a service by Jerome Smail

Features

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15

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Solving payroll recruitment headaches by Claire Younger

Embracing organisational agility by Mark Judd

Refurbishment of the CIPP’s Foundation Degrees by Stuart Laverick

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18

19

Freeports and employer NICs by the CIPP policy team

Farewell to the EYU by Lora Murphy

The future of P11D reporting by Tim Bridgett

| Professional in Payroll, Pensions and Reward | July / August 2021 | Issue 72 2

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Editor Mike Nicholas 0121 712 1000 | [email protected] Advertising Daniel Cull 0121 712 1021 | [email protected] Design James Bartlett and Nicole Davis [email protected] Printing Warwick Printing Company Ltd

Impact of Brexit on social security contributions by the CIPP policy and research team

The language of payroll by the CIPP policy team

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Employees at risk of breaching the LTA by Jonathan Watts-Lay

Gender pay gap reporting by Samantha Johnson

Chief executive officer Ken Pullar FCIPP CIPP board of directors Jason Davenport MCIPP MIoD Louise Gray ChMCIPPdip

FCA acts to reduce pension costs by Henry Tapper 29 NMW guidance for sleep-in workers by Danny Done 32

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Stuart Hall MCIPPdip Helen Higson ACIPP Dianne Hoodless MSc ChFCIPP FHEA Liz Lay MSc FCIPPdip FHEA ACIPD Jeremy Montgomery BA(Hons) FCIPP

Looking for an old pension? by Ian Neale and Gareth Stears

Carole Pearson MCIPP Katie Sharpe MCIPPdip

Cliff Vidgeon BA(Hons) CMA ACG ChFCIPP Clare Warrington MSc FCIPPdip AFHEA

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Useful contacts

Furlough notice pay, isolation dismissal,

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]

discrimination by Nicola Mullineux

How to develop and maintain employee trust through reliable payroll by Simon Parsons 36

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Payroll maturity: how does your organisation measure up? by Nick Clarke

Regulars

01 Editor’s comment, and

17 Compliance 26 Reward 34 Industry news

0121 712 1013 cipp.org.uk @CIPP_UK

Chair’s andCEO’smessage

04 CIPPupdate

Events, news and developments

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.

05 My CIPP

Policy hub: On your behalf, Advisory; Spotlight on…

36 Technology 43 Wordsearch 48 Confessions of a payroll manager

10 Movers and shakers 11 Personal development BePayroll, Diary of a student 16 Payroll news

Full issue including additional online content available at professionalmag.co.uk

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| Professional in Payroll, Pensions and Reward |

Issue 72 | July / August 2021

CIPP update

2021 Annual Excellence Awards – deadline 31 July THE WINDOW remains open for nominations for the CIPP’s 2021 Annual Excellence Awards – but the 31 July deadline will soon arrive! Don’t miss your opportunity to nominate your colleagues, peers or team, and don’t forget the four new award categories: ● Best Coronavirus Crisis Response ● The Bright Beginnings Award If you would like to attend, ensure you book your place soon, as these sessions are in high demand. More information can be found here: www.cipp.org.uk/events/events-calendar.html. BeKnowledgeable Summer Sessions ALONG WITH summer came the relaunch of the series of CIPP’s BeKnowledgeable webinars. The first session in the series took place on June 22; hosted by CIPP policy and research officer Gemma Mullis ACIPP, it provided information on the topic of payrolling benefits in kind. The second in the series, scheduled for 13 July, will be hosted by CIPP policy lead Sam Johnson LLB(Hons) MCIPPdip, and will provide CIPP members with the opportunity to learn more about the rules for salary sacrifice and optional remuneration arrangements. The last in the series, which will be delivered on 18 August, discusses termination payments, and will be hosted by Lora Murphy ACIPP, CIPP’s content editor. Delegates will be able to submit any questions they may have in a session at the end of each webinar.

National Payroll Week – now open for bookings NATIONAL PAYROLL Week – which runs from 6 to 10 September – is almost here! The week is packed with online events and sessions that are free to attend. You are now able to book your place on these sessions at www.cipp.org.uk/events/npw-landing.html. The digital National Payroll Week pack can help payroll professionals continue the celebrations. Last year saw the most successful National Payroll Week to date, with over 5,500 packs downloaded and engagement rates soaring to an all-time high. Let’s build on the success of 2020 and ensure that payroll professionals continue to be at the forefront of their industries. Payroll professionals should celebrate their own achievements, along with those of their colleagues for the outstanding performances of payroll teams up and down the country in the past year. You can request your NPW 2021 pack now, which will be ready to download from the start of August, by visiting www.cipp.org.uk/events/npw-landing.html. Congratulations to the newly accredited PAS organisations THE CIPP’s Payroll Assurance Scheme (PAS) is designed to test the strength of your payroll in relation to its processes, compliance with legislation and guidance and to investigate any associated people skills and development opportunities. One of the most important duties of any payroll department centres around ensuring effective business continuity plans are in place. Given the events of the last year, extra congratulations must be given to all the organisations that have achieved this accreditation and will have successfully implemented these plans. Special congratulations to our recently accredited organisations: ● Bishop Fleming Payroll Solutions Ltd ● Cantium Business Solutions ● Crown Prosecution Service ● Driving & Vehicle Standards Agency ● NES Fircroft Group 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, but assessments are taking place virtually, in line with current government guidelines. To find out how the Payroll Assurance Scheme can benefit your organisation, email [email protected] .

● The Spotlight Award ● The Luminary Award

To find out more and to make your nominations before 31 July, visit www.cipp.org.uk/events/annual-excellence-awards.html.

The CIPP and climate change CLIMATE CHANGE is one of the greatest challenges our generation is facing and the CIPP is committed to leading the payroll profession in becoming more sustainable. We have made a commitment to being a net zero organisation by 2035 which forms part of our environmental, social and corporate governance in putting forth climate commitments and setting targets. We will also encourage our members and suppliers to reduce their emissions to create a more sustainable future. We will be sharing further information about our commitment to becoming a net zero organisation on our website, through social media channels and in Professional magazine as we progress our targets. Foundation Degree autumn enrolments ENROLMENTS FOR both the Foundation Degree in Payroll Management and the Foundation Degree in Pensions Administration and Management are now open. Visit our qualifications page – https://www.cipp.org.uk/training- and-education/study.html – to find out more and to take the next step in your payroll career. The deadline for enrolment is 1 October, but if you are applying for a student loan to fund your studies the deadline is 20 August.

| Professional in Payroll, Pensions and Reward | July / August 2021 | Issue 72 4

Policy hub

On your behalf

Policy team update

The CIPP’s policy and research team provide an update on developments.

A s the BeConnected National focus shifted to the continuation of the BeKnowledgeable webinars. These online presentations offer a high-level overview of topical areas that create operational challenges for payroll professionals. In 2021, the policy team have covered the subjects of: off-payroll working; national minimum wage; and holiday pay. Recordings of the sessions are still available; please contact the CIPP events team to get access. Forums drew to a close at the end of May 2021, the policy team’s Looking to the immediate future and beyond, the team have worked closely with the CIPP events team developing the content for National Payroll Week, taking place in September 2021, and for the Annual Conference which will be held the following month, in October 2021. These are some exciting opportunities to learn, collaborate and celebrate the profession, so please take the time to join the celebrations. The Queen’s speech In just ten minutes, the Queen’s speech was delivered on 11 May 2021 at the House of Commons. The ceremony was more scaled-back than is the tradition, as a result of the coronavirus and social distancing restrictions. The key areas of focus in the speech were: the environment; ‘levelling up’; education; housing; security; and the armed forces. The speech introduced the Skills and Post-16 Education Bill, which has been designed to transform post-16 education and training. Its aim is to make skills training more readily available to support people to get into work. The Bill also includes the lifetime skills guarantee, which will work to ensure that everyone, irrespective of their background or where they live, will be able to gain the skills required to progress in work at any point in their lives. In the speech, the Queen said that:

parental bereavement leave and statutory parental bereavement pay. In addition, there is also a helpful flowchart relating to the coronavirus job retention scheme and the change to eligibility criteria for claim periods between May 2021 and September 2021. Within the policy hub, there are a variety of webcasts, and we aim to publish a new one each month. The webcasts are particularly beneficial for those individuals who are auditory learners. Following on from the publication of several documents on ‘Tax Day’ there has been a significant focus on consultations and calls for evidence. Members can locate the CIPP’s previous formal responses to government consultations within the policy hub. The responses that the CIPP submits incorporate the views of members. What policy can do for you The policy team carries out research into issues that are impacting payroll professionals. We really appreciate views, opinions and feedback from members and encourage you to get in touch about payroll policies that are working well, or those that are not. You can contact the team at [email protected] . Additionally, if there is anything you feel that the team should be discussing, please contact us at the same address. There are various ways in which you can get involved and have your say. The list below is not exhaustive but provides examples of the platforms you can use to share your ideas and shape the future of payroll policy: ● consultation roundtable thinktank meetings ● events – add your opinions into the Q&A chat boxes, or share your comments when face-to-face events resume ● respond to the CIPP’s Quick Polls which are hosted on the News Online page ● respond to surveys produced by the policy team. n

“Eight new Freeports will create hubs for trade and help regenerate communities”, and that “[m]easures will be introduced to provide National Insurance contribution relief for employers of veterans.” The National Insurance Contributions Bill (http://ow.ly/UwY630rIH3z), provides National Insurance contributions relief for employers of veterans (available from 6 April 2021) and for employers in Freeports (proposed from 6 April 2022). It also works to strengthen the existing powers that HM Revenue & Customs has to act decisively in situations where it is aware of, or suspects, that avoidance schemes are being operated. ...works to strengthen the existing powers that HM Revenue & Customs has to act... Helpful resources The CIPP’s website is a great resource for payroll professionals, and the policy team wanted to highlight the wealth of information that is available. Members have access to enhanced features and can make use of a variety of different tools, including factsheets and webcasts. The factsheets are intended to provide a high-level overview of some of the processes that payroll teams are responsible for and can be printed for use as a handy reference tool, a training aid, or as an appendix to departmental standard operating procedures. The factsheets are updated on a regular basis, and the topics covered at the time of writing are as follows: redundancy; termination payments; statutory sick pay; statutory maternity pay; optional remuneration arrangements; payrolling of benefits; coronavirus sick pay rebate scheme;

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| Professional in Payroll, Pensions and Reward |

Issue 72 | July / August 2021

MY CIPP

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

Q: Can a National Insurance number (NINo) issued in the Isle of Man be used to process an employee on a UK payroll? A: Guidance in HM Revenue & Customs' (HMRC's) National Insurance Manual (see NIM39620, https://bit.ly/3wHvsXN) confirms that the Isle of Man and the UK have historically operated similar National Insurance contributions (NICs) and social security schemes. This has allowed the operation of one National Insurance account for a person who has lived or worked in both territories. The territory in which the taxpayer resides normally holds and maintains the account. Employees with an Isle of Man NINo, which begins with letters ‘MA’, can use it in the UK. Similarly, customers with a UK NINo can use it in the Isle of Man. A person with a NINo starting ‘MA’ arriving in the UK from the Isle of Man, will need to contact the Isle of Man tax office to ensure their NINo is activated in the UK and accessible to HMRC. Q: Can an employer arrange gym membership for their employees through a salary sacrifice arrangement? A: There are limits to the benefits that retain their tax and NICs advantages. These were introduced in April 2017 and are termed as optional remuneration arrangements (OpRA). The arrangements mean that where an employee chooses to receive a benefit as opposed to an amount of cash pay, the taxable value of the benefit is taxed at whichever is the higher of: ● the amount of cash foregone, or ● the taxable value of the benefit under normal benefit in kind rules. The values are then reported via the P11D return, as the employee is liable to tax and the employer is required to pay

A: Regulations include a duty on employers to provide a statement of benefits to every employee who has received payrolled benefits at any point during a tax year. The information must be provided before 1 June, following the end of the tax year. This includes employees who have been employed for only part of the year, so yes this does apply to an employee who leaves the business mid- year. There is no prescribed format for these statements, so they could be on paper or online. The information could be included on payslips throughout the year or in an annual statement of benefits, for example. Q: We have produced our P11D returns for tax year 2020/21 and submitted them to HMRC. Included are P11D returns for employees who left our employment prior to the start of this tax year. Are we required to issue them with a statement of the content of their P11D return? A: Whilst this isn’t mandatory, it would be good practice to send the ex-employees a copy of the content (typically a copy of the P11D). This is because former employees can request a statement from a former employer at any time, up to three years after the end of the tax year. (See regulation 94 of the Income Tax (Pay As You Earn) Regulations 2003, https:// bit.ly/3vKFyXG.) Q. An employer wishes to create a contract of employment whereby employees are provided with a set payment for the completion of a task. However, the employer is struggling to understand how to calculate holiday pay for them. Are there any methods that should be considered?

class 1A NICs on the amount. Under the OpRA rules, a gym membership is not an exempt benefit that retains salary sacrifice advantages. See EIM44131 in HMRC’s Employment Income Manual (https://bit.ly/3vgl5d0), and guidance on OpRA here: https://bit. ly/3ffin1H. Q: An employer is currently looking into setting up an annual leave buy scheme for its employees. Should a deduction be taken from gross or net pay? A: If an employer contractually agrees to reduce an employee’s salary in exchange for a benefit, it will be regarded as a salary sacrifice arrangement. Reducing an employee’s gross pay may affect their NMW rate, so checks will be required to ensure they do not fall below the NMW. HMRC advise that holiday purchase can be a salary sacrifice arrangement which is not caught by the OpRA rules as it is an intangible benefit. Q: Are diesel vehicles that are registered as Euro 6AP subject to the income tax exemption of the 4% supplement? A: Cars that meet the Euro 6d standard will have a Euro status of the car displayed in their V5 Registration document and will be shown with: Euro 6AJ, Euro 6AK, Euro 6AL, Euro 6AM, Euro 6AN, Euro 6 AO, Euro 6AP, Euro 6AQ, Euro 6AR. Therefore, diesel vehicles that are registered as Euro 6AP are exempt from the 4% supplement. Q: If an employer payrolls benefits, do they still need to provide a statement of benefits for employees who leave the business in the middle of the tax year?

| Professional in Payroll, Pensions and Reward | July / August 2021 | Issue 72 6

O N L I N E L E A R N I N G

Policy hub

Case law continually produces changes to employees’ statutory holiday leave and pay entitlement, which are covered in this informative course, along with the various types of leave and the calculation of pay. Holiday pay and leave

A: The Working Time Regulations 1998 refer to sections 221–224 of the Employment Rights Act 1996 for the calculation of a week’s pay for the purpose of annual leave. Essentially, a week’s pay is the contractual remuneration due to an employee for working their normal working hours in a week. If a worker has no contracted normal working hours, then the holiday pay calculation is based on pay received during the pay reference period. (The number of hours worked is not relevant.) The reference period for calculating pay ends on or before the calculation date (the day the absence begins) and goes back 52 weeks. If the employee receives no pay in one of those weeks, that week is disregarded, and the reference period extends back an extra week, up to a maximum of 104 weeks from the end date. Unlike other calculations, a week is not excluded if pay is received but no work is done (such as a week of holiday pay). Q: An employee’s fixed term contract is due to end fifteen weeks into her ordinary maternity leave period. Does the contract end or should we put it on hold whilst she is on leave? Also, would we pay her the full 39 weeks of statutory maternity pay (SMP), even though her contract will finish at fifteen weeks into her leave? A: If the employee satisfies all the criteria to be entitled to SMP than the employer must pay 39 weeks of SMP. The SMP due can either be paid as a lump sum when her contract ends (although this is less beneficial to the employee due to NICs implications) or keep her on the payroll, purely as a means to pay the balance of SMP. The employee would no longer accrue holiday pay or have any further employment rights as the contract has ended. Once the 39 weeks of SMP have been paid form P45 can be issued to her. Q: An employee who commenced employment in October 2019 has been provided with relocation expenses as a benefit. It is now April 2021, and the employee wishes to submit a final claim for removal expenses incurred in the last tax year. Is this allowed?

A: Whether the employer reimburses these expenses is one issue, which is a contractual matter for the employee and employer. The second issue is the treatment (e.g. tax exemption) of the amount reimbursed. To qualify for the tax and NICs exemption, a removal expense must be both incurred and reimbursed by the end of the tax year following the one in which the employee starts the new employment. So, the expense would need to have been reimbursed before 6 April 2021 to be allowable for the exemption. HMRC’s Employment Income Manual (see EIM03104, https://bit.ly/2T9VfsV) states that “To qualify for exemption, the removal expenses must be incurred, or the removal benefits provided before the last day of the year of assessment following the one in which the employee starts the new job. This day is known as the limitation day (section 247, ITEPA)”. However, in specific circumstances the time limit can be extended, as set out in EIM03105. If the expense fails the statutory conditions, it becomes a non-qualifying cost. Where the employer reimburses a non-qualifying cost, the amount is counted as earnings and, therefore, added to the employee’s other earnings through the payroll with PAYE income tax and class 1 NICs deducted/paid (https://bit. ly/3486sN0). n

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| Professional in Payroll, Pensions and Reward |

Issue 72 | July / August 2021

MY CIPP

Spotlight on...

are News Online articles, at least three a day, presenting on webinars, attending consultation meetings, and putting together extended articles for publications such as the CIPP’s magazine, Professional . What type of skills does a policy teammember need? They need to be adaptable, as things are constantly evolving and changing in the payroll sphere. I think we also need to be quite resilient characters due to this and be prepared for whatever comes our way. A good analytical and technical mind is a must, as we have to interpret complex, wordy legislation and put it into practice, and real life situations. What’s themost interesting fact you have ever heard about payroll? In 1966, the Beatles released the song Taxman to protest against the 95% supertax they were paying.

Management. Although it is very enjoyable, juggling studying with being a single mum and a full-time job does sometimes have its challenges. Was there amoment in your career/life that made you want to enter a career in payroll? From the moment I started my first payroll related job, I wanted to pursue a career in payroll. When given extra responsibility for the more complex and less administrative tasks in that role, I decided this was definitely something I wanted to do more of. Howdo you feel when you know you havemade a positive difference to someone through your advice? It is genuinely one of the best feelings in the world. I know from my time working in operational payroll that when you are uncertain about an element of processing payroll it can make you feel panicky and doubt your own knowledge. So, to be the voice that reassures someone that what they are doing is correct is amazing. What has been your biggest sense of achievement since joining the CIPP policy team? I really enjoyed being involved in and pleased with the outcome of the Future of Payroll survey. This gave me a chance to see what payroll professionals think will happen over the course of the next few years for the profession, and to analyse both qualitative and quantitative >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

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