Autumn Newsletter now available

By in Newsletter


Professions Together Autumn Newsletter 2017


This is an Interim Newsletter to fill the gap between the end of the former UKIPG Web-Site and the formal launch of the new one for Professions Together. As the Secretary no longer has access to the Content Management System or automatic E-mailer, as previously, it is being sent from his own e-mail account.  (Change)

We have done an extensive ‘clean up’ of the membership database and e-mails, hoping to eliminate the ‘undeliverables’ (usually caused by individuals moving to new jobs).  If you are moving, or have been forwarded this by a colleague and would like to be on the circulation, please-mail your request directly to the Secretary at

Please note that with the change of Chairman, office services can no longer be provided by the Registrar of the Science Council.  The new Postal Address is ‘PT UKIPG, PO Box 1099, AYLESBURY HP22 9QH’. Please correspond by email to Fiona Hellowell (Chairman) at  or Peter Swindlehurst (Secretary) at

Current Work

It is important that we do not get too ‘bogged down’ in the administration of internal change. There is still a lot going on elsewhere. BREXIT still dominates, but there is also activity in HE, Technical and Vocational Education, Apprenticeships (especially at the ‘higher’ levels), Professional Regulation and Corporate Governance, and Professional Ethics. 

International, European and BREXIT

The Background to Brexit Negotiations

Before the 8th of June Election, the European Union (Notification of Withdrawal) Bill had received Royal assent on 15th March and was by then an Act of Parliament. It allowed the Prime Minister to invoke Article 50 of the Treaty on the European Union on 29th March. The aims, priorities and intentions of the previous Government, had been outlined in the Prime Minister’s 6th February Statement, and detailed in the White Paper CM9417 ‘The United Kingdom’s exit from and new partnership with the European Union’. In this plot, professional and business services seemed to have been given a low priority.

Whilst the CM9417 White Paper made a start, it also highlighted some tricky issues, such as the UK/Republic of Ireland border emerging as an external border of the EU, the need to replace EU Single Market Rules with WTO Rules, the need to absorb the ‘aquis’ of EU law into UK Law etc, and to safeguard the position of those who had moved from other EU Member States to UK and vice versa). Whilst there was ‘a show’ of listening and learning, little notice was taken of evidence provided by those who had worked in this field, as well as that gathered in the earlier ‘Balance of Competences’ work.

We know that many Europe-wide organisations are recognised by the EU but are not founded in the Treaties and so not intrinsically part of the EU. In earlier Newsletters, we focussed on the obvious ones (to us in the professions), such as the European Higher Education Area and the possibilities for Horizon 2020. A major issue has been, and still is, the need to give confidence to those working in key jobs in the UK, and to potential HE students and researchers. On 21st April, DfE and BEIS formally guaranteed funding (at home country rates) for EU HE students enrolling in 2018/2019, even though their courses would extend beyond Brexit.

What was later addressed was the process of transition, as so much UK law is based, either entirely or to some extent, on extant EU law (Regulations, implemented Directives, or ECJ Case Law) –   the sum of which is known as the ‘aquis’. And, of course, while all the discussion and negotiation is going on, the ‘aquis’ continues to exist and to develop.  The policy of HMG was that all of the ‘aquis’ will be incorporated into UK law by a single Act of Parliament, the day that the UK finally ceased to be a member of the EU.  Prior to the Election, the discussion was on what was described as ‘The Great Repeal Bill’, and the issues were was addressed by the DExEU White Paper of 30th March Cm 9446 ‘Legislating for the UK’s Withdrawal from the EU’.   Since then, we have got a new Parliament and Government, a Queen’s Speech, and a whole series of position papers.. The three opening paragraphs of the Queen’s Speech simply said:

My government’s priority is to secure the best possible deal as the country leaves the European Union. My ministers are committed to working with Parliament, the devolved administrations, business and others to build the widest possible consensus on the country’s future outside the European Union.

A bill will be introduced to repeal the European Communities Act and provide certainty for individuals and businesses. This will be complemented by legislation to ensure that the United Kingdom makes a success of Brexit, establishing new national policies on immigration, international sanctions, nuclear safeguards, agriculture, and fisheries.

My government will seek to maintain a deep and special partnership with European allies and to forge new trading relationships across the globe. New bills on trade and customs will help to implement an independent trade policy, and support will be given to help British businesses export to markets around the world”.

Brexit Developments and Negotiations

We can see the inevitable fragility of the current government leading to a lack of legal certainty and hence business confidence. However, quite early in the process, there were two major Ministerial Speeches, and a published policy statement on ‘Safeguarding the position of EU citizens in the UK and UK nationals living in the EU’. These were highlighted, and transcripts provided, in the previous Newsletter

  • In opening the Queens Speech Debate, Rt Hon David Davies, the Secretary of State for DExEU, gave a major speech on ‘Brexit and Foreign Affairs’. The speech had four sub-headings ‘New and Deep Relationship with EU’, ‘Leaving Single Market and Customs Union’, a ‘Repeal Bill’, and ‘Other EU Related Legislation’ – things like ‘trade, customs, immigration, international sanctions, nuclear safeguards, agriculture, and fisheries’. Its tone is very much ‘press on as before’.
  • On 5th July, Rt Hon David Lidington, the Lord Chancellor, gave a detailed and thoughtful speech to HM Judges at a Mansion House Dinner. David Lidington had spent 5 years as Minister for Europe in the FCO, and had dealt with the ‘Balance of Competences’ work, so focused much of his speech on some, albeit specialised, Brexit issues. This section of the speech reaffirms the intention to absorb the ‘aquis’ of EU law into UK law, and to leave the jurisdiction of the ECJ.

Since those early days for this Government, formal Negotiations began with the First Round on 19th June, with the Third Round being completed on 31st August. There is a suggestion that the start of the 4th round might be delayed. Summaries of what happened, and copies of the position papers and other official documentation on ‘the Article 50 process and our negotiations for a new partnership with the European Union’ can be found on the Article 50 ‘’ website .  The main headings of this material (in the order listed) are:  Position Papers, Future Partnership Papers, White Papers, Announcements, Speeches and Statements, Terms of Reference, The Negotiating Team, Meetings Agenda, and Technical Notes and background. The SofS reported to Parliament on the work done in the July and August Rounds on 5th September and this is recorded on the ‘Art 50 Gov.UK’ website.

A topic of primary interest to Professions Together will be that of Citizens Rights, as this covers both residence and rights to practice a profession.  On 26th June, the UK Government set out a position paper on this subject (one of those mentioned in the Art 50 ‘collection’ above).   It is, of course, a negotiating pitch and not the final agreement. It is far too complex and risky for your Newsletter writer to attempt to summarise. However, the negotiating team staff for this topic have done so in a tabular form, summarising both EU and UK positions and highlighting points of agreement and otherwise. The comparison document relating to this topic can be accessed at: .  [The RPQ stuff starts at page 12] If you wish to see if you – or your members / Registrants or staff – have any direct contact with senior members of the team, the list can be found at:

Migration Advisory Committee

There are a number of official advisory bodies to Government, one such being the Migration Advisory Committee.  On 27th July, the Home Office commissioned the Migration Advisory Committee (MAC) to report on the impact on the UK labour market of the UK’s exit from the European Union and how the UK’s immigration system should be aligned with a modern industrial strategy.  To implement this commission, the MAC issued a Call for Evidence on 4th August, with a return date of 27th October. See: .  It is expected that the majority of PSRB, especially those with an international perspective, will be compiling their evidence by now, either for themselves or in collaboration with relevant professional or trade associations. But this is a reminder, in case it has been missed. While on the subject of MAC, we might also note that on 24th August, the MAC was commissioned to ‘to assess the impact of international students in the UK’.  The Chairman of MAC said that they would soon be issuing a Call for Evidence on that topic, so be prepared.

Intellectual Property Office

Not to be outdone of this topic, the Intellectual Property Office said that there was much speculation on the future of many intellectual property laws following decision that the UK should leave the EU.  It has, therefore, produced a guide which looks to offer factual information on the future of the UK’s IP regime. It emphasises that the UK will remain one of the best places in the world to obtain and protect intellectual property.  The guide is at:

International Trade

Obviously, whilst still a member of the EU and subject to the Treaties, the UK trades internationally through EU Trade Agreements. The most recent one is CETA between EU and Canada.  De facto, the putative TTIP (Transatlantic Trade and Investment Partnership) did not come to fruition following the US presidential Election. Almost all of the issues relating to things like customs union, non-tariff barriers, ‘rules of origin’, and ‘technical barriers’, now being raised in the EU/UK exit negotiations, had already been rehearsed in the fifteen rounds of TTIP ending last year. It will be recalled that by far the most contentious area was the ISDS (Inter State Dispute Settlement System) proposal. After many protests, in March 2014 the EU Commission launched a formal consultation on ISDS and received a record-breaking 150,000 responses – and more from UK than from anywhere else. As every such agreement has some ‘dispute settlement system’, any between the UK and EU would presumably also have to have one to resolve any disputes which would previously have been settled by the ECJ on the firmly rules-based European Law. For a flavour of the issues raised by the TTIP ISDS consultation – and therefore likely to re-emerge in any EU27/UK agreement – see the Consultation Summary Report:  (13 Jan 2015).

To get a Department of International Trade overview of the potential for International Trade, see the Speech by the Rt Hon Liam Fox, SofS at DfIT at the first meeting of the UK-US Trade and Investment Group on 24th July at the American Enterprise Institute. There was a similar one a few days later in Mexico City.

Implementing EU Legislation

The fundamental planning assumption is that UK plays a full part in developing and implementing EU law prior to Exit, and that all EU law becomes UK national law on the day after Exit. That is the purpose of The European Union (Withdrawal) Bill which received its Second Reading in the Commons on 11th September. This means that we need to be involved in new EU legislation, and so the implementation of the Directive 2016/1148 on the Security of Networks and Information Systems and on the implementation of the General Data Protection Regulation.  See Consultations from DCMS of 7th and 8th of August.

UK Professions Together

The UKIPG / Professions Together recognised that this is a major area of work and interest for the UK professions and their regulatory and representative bodies, and for the sectors of business, industry or services in which they operate. Our International and European Forum, under the leadership of Katy Turff of the Engineering Council, is focused on this issue.  There has been much sharing of policy developments and advisory papers prepared for Government. There was a very well attended Forum at the Engineering Council in December 2016. This work will now need to be refocused while there might be a window of opportunity to catch the various government departments and lobbyists in a perhaps more ‘listening mode’!   It is planned to hold another Forum at the Engineering Council on the 7th or 8th of December.  Katy would like to hear from those UKIPG/PT representatives involved in this work, with offers to present, suggestions for external speakers, and particularly your general or specialist contacts at DExEU and your sponsor Departments (eg DH, DCLG). It might be useful to see if your profession has any useful relationships with key figures at DExEU (See: .  There is also some interest among our Irish colleagues in the IIPA in joining us for discussion.  Peter S has the contacts.


Recognising that UK is still an EU Member State at least until March 2019, that many EU citizens work in UK professions, and that after departure all of the needs of both UK and EU professionals will remain, the UKIPG / Professions Together has remained a member of the European inter-professional group known as CEPLIS. CEPLIS is a good source of intelligence on what the EU Institutions are planning and implementing, and of the experiences of the professional associations and regulators in the wider Europe. There are some residual issues relating to RPQ (especially those parts subject to later ‘implementing acts’), on the ‘Services Package’ (especially as it relates to ‘professional services’ and healthcare) and ongoing involvement with Horizon 2020 projects.  There is limited interest within the new (ie current) Commission in the full implementation of the revised RPQ Directive, and in the earlier focus on entrepreneurship and support for SMEs. (Both ‘old hat’ to the ‘new’ Commission!).  The joint initiative of CEPLIS and the Malta Federation of Professional Associations (MFPA), to seek Horizon 2020 funding of a Centre of Excellence for Professional Ethics, suffered a setback. UKIPG / PT did have the opportunity to be updated at the 2017 General Assembly, and Seminar of the Permanent Committee, hosted by our Maltese colleagues in June.  See also CEPLIS on

CEPLIS hosted a breakfast meeting on the 5th of September at the European Parliament in Brussels for the members of the SME Intergroup to discuss the Proportionality Test and other issues of the Services Package regarding the Liberal Professions.  A Report on the discussion can be found at: Two key speakers were Martin Frohn, responsible for the RPQ work at the Commission, and Andreas Schwab MEP and IMCO coordinator (EPP), the Rapporteur on the proposal for a Directive on a Proportionality Test before adoption of new regulation of the professions.

Whilst on the subject of ‘proportionality’ and the need for regulation, representatives are asked to note the Commission Conference ‘’Professional Services: How does regulation matter?’’ to be held on Thursday 9th November 2017, at the Thon Hotel EU, in Brussels, and in the framework of the Single Market Forum 2017/2018. This conference will focus on the lessons learned from the mutual evaluation of regulated professions (2014-2016). It will also examine the objectives of, and recent findings resulting from the Services Package adopted in January 2017. To start the debate, international experts, academic researchers, representatives from the European Parliament, the European Commission and the European Economic and Social Committee, as well as social partners, will take part. [On ‘academic input’, note that of Queen Mary, University of London is a primary Commission contractor]  Register at

The next CEPLIS General Assembly is scheduled for 30th November in Rome. The usual Permanent Committee Seminar will be replaced by an event arranged and hosted by our Italian ‘Professions Together’ colleagues in Confprofessioni, and in collaboration with the Economic and Social Committee.  PT needs to decide on how best to continue with representation at CEPLIS while ever it is an ‘Observer Member’.

Contacts. Please keep Katie Turff ( / 0203 206 0578) and the compiler of this Newsletter (, advised of your interests and share your thoughts and developments on all things International and European.

Education and Training


As Education and Training are less affected by the EU Treaties, the Government Departments concerned have been able to get on with their ‘normal’ work. The Higher Education and Research Bill 2016-17 and the Technical and Further Education Bill 2016-17 both received Royal Assent on 27th April 2017. The broad proposals of both pieces of legislation were set out in the April Newsletter.  Whilst there were lots of amendments ‘ping-ponged’ between the Houses, the essential intent of both Bills was enacted.

Higher Education and TEF.

The major HE event of the weeks prior to the issue of the previous Newsletter in July was the publication of the first set of Teaching Excellence Framework (TEF) results. Arising indirectly from the Review of Quality Assessment in Higher Education, the TEF is in some ways a balancing pressure for ‘Teaching’ against the well-established REF for ‘Research’.  In principle, entry into the TEF system was voluntary and without sanctions.  However, many HEIs sought to enter at the start to gain experience, as it was expected some form of pressure to partake would come later.

The use of the word ‘excellence’ implied that TEF was seeking something over and above that which was expected of any HEI meeting the requirements of the Quality Code.  Therefore, there would be no OFSTED/CQC type ‘inadequate’ or ‘requires improvement’ ratings. The TEF measures teaching excellence in three key areas:

  • Teaching quality– teaching that stimulates and challenges students, and maximises their engagement with their studies.
  • Learning environment– the effectiveness of resources and activities (such as libraries, laboratories and work experience) which support learning and improve retention, progression and attainment.
  • Student outcomes– the extent to which all students, in particular those from disadvantaged backgrounds, achieve their educational and professional goals.

The TEF assessment metrics take account of differences in students, entry qualifications and subjects studied, and so allow the assessors to judge teaching excellence and outcomes for the specific students taught at the university or college. In comparing results, one must compare approximate like with like. There are many other comparison sites which attempt to rate HEIs on an ‘absolute’ scale.  The ratings are labelled ‘Gold’, ‘Silver’ and ‘Bronze’, with a quarter Gold and Bronze and half Silver. Details of the TEF Scheme, and the Assessment Outcome for the HEIs which took part in this round, are available from HEFCE.


The Office for Students

The Office for Students is a new public body established under the Higher Education and Research Act 2017.  It is intended to become operational on 1st April 2018. The OfS will be the regulator for the Higher Education sector and is meant to put the student interest at its heart. It is also meant to be innovative in its approach to student participation, success and employability. Once fully operational in April 2018, the OfS will replace the Higher Education Funding Council for England (HEFCE) and the Office for Fair Access (OFFA). The Chairman is Sir Michael Barber, and the newly appointed Chief Executive is Nicola Dandridge who is moving to the OfS from being Chief Executive of Universities UK.  Some of the current HEFCE Board will also transfer to the OfS.  Note that, because education is a devolved matter in the UK, the OfS applies only to HE in England; the Welsh, Scottish and Northern Irish Administrations have their own arrangements.

QAA and the PSRB Forum

In contrast to what was said about OfS above, the Quality Assurance Agency for Higher Education (QAA) is a UK-wide body, which also has broad HE interests beyond the UK, both in Transnational HE and in consultancy and contract work. It is essentially a collaborative membership body, although with its own identity, governance and management.  Much of its quality assurance work is done in support of HEFCE, and presumably of OfS in the future.

An important collaboration, with several years of history now, is the PSRB Forum; part of the QAA’s work on ‘stakeholder engagement’. The term ‘PSRB’ means ‘Professional and Statutory Regulatory Bodies’, principally in the context of education, but now expanded to cover skills and apprenticeships. QAA has worked in partnership with UKIPG over many years and intends to continue to do so with ‘Professions Together’, although organisational changes at QAA have meant a sequence of personnel changes. The Forum usually involves representatives from HEIs and sector bodies, HESA etc. Events are organised jointly, and QAA provides the logistics and event booking system

The next PSRB Forum, which acts as an ‘education special interest group’ in Professions Together, is being planned for 6th November at a London venue. There was a meeting of minds between QAA and PT on topical agenda issues. These are likely to include TEF, External QA of Degree and Higher Apprenticeships, a possible increase in external-to-EU HE, and the project work by HESA and the HEA (some current work with some sample PSRBs).  Full details will be published soon by both QAA and Professions Together.


On Apprenticeships, most of the policy developments have morphed into procedures and practices. The Levy system has started, Providers are on the Register, the Institute for Apprenticeships is getting organised to take over the Approvals, Assessment and Quality Assurance etc, before getting into Technical Education next year. OFSTED has made clear its inspection policy, based on the Common Inspection Framework. Recent news in the public domain indicates that OFSTED is already finding poor and incorrect practice, grading some major providers as ‘Unsatisfactory’ across the Inspection Framework, and finding misuse of ‘apprenticeship’ for programmes for non-employed trainees.

The newly combined Education and Skills Funding Agency is developing ways of supporting the non-Levy sector provision ). However, it soon became clear that something has gone wrong with the initial approach: .

While all this is going on, the HE Sector is working out the pros and cons of being a ‘normal’ apprenticeship provider or offering an ‘integrated degree apprenticeship’. See Catherine Boyd’s article on this in WonkHE With the introduction of the ‘Standards’ Apprenticeship scheme, there was an initial emphasis on a unified system for all providers, but gradually the realities of the way the different sectors operate, including the ‘battles’ to enshrine certain principles such as ‘institutional autonomy’ in the HE and Research Act, have led to divergence, and the option for at least some HEIs of being  providers of an ‘integrated degree apprenticeship’.

One aspect of the ‘Standards’ Apprenticeships is the External End Point Assessment, to be conducted by Approved Assessment Providers.  This process is to be subject to External Quality Assurance, which could be provided by one of an employer-led group, a professional body, Ofqual, or – where these options were not appropriate – by the Institute for Apprenticeships. However, the Institute opted to contract out the fourth option to Open Awards, for it to deliver External Quality Assurance (EQA) of apprenticeship end-point-assessment on the Institute’s behalf in 2017-18. Open Awards is described as an Awarding Organisation approved by Ofqual, and an Access Validating Agency approved by the Quality Assurance Agency for Higher Education (QAA).  Professions Together  would welcome news of member organisations, which have become End Point Assessment Providers as ‘professional bodies’ under the options given above. Please contact the writer of this Newsletter ( so that we can arrange to share lessons and effective practice.

Education Forums

The Inter Professional CPD Forum (qv) has been an exemplar over many years for the sort of self-sustaining special interest groups that the UKIPG/PT membership values.  They provide a challenge to received wisdom and historic ‘good practice’ as the environment changes, develop mutual support between colleagues in other bodies, and provide opportunities for networking at a cost very much less than commercial conferences and training events. The International and European Forum is another variant of this model.

In education, we have also benefitted from our partnership working with QAA in the Professional and Statutory Regulatory Bodies (PSRB) Forum – mentioned above –  over the last decade.  Fiona Hellowell initiated a more general Professions Together Education Forum. One such Forum was hosted by CIPD in December and a PSRB Forum was held in March.  We now need to get our heads around the new Education Acts, Apprenticeships  and Technical & Further Education.  Please indicate interest to Fiona Hellowell (Chairman) or Peter Swindlehurst (Secretary) at

Inter Professional CPD Forum

The Inter Professional CPD Forum exists within the framework of the UK Inter Professional Group / Professions Together, but additionally provides opportunities for other organisations to become Forum members (eg providers of CPD development programmes and CPD management software systems). The next Forum will be hosted by the Institute of Chartered Secretaries and Administrators (ICSA) on 16th October at Saffron House, 6-10 Kirby Street, London EC1N 8TS.  Timings are as usual; gather for lunch and chat from 1230 and the Forum business will run from 1330 to 1630. As well as a presentation by the hosts, the meeting will hear from other Forum members. Chris Senior, the Forum Administrator, will welcome any offers of a presentation related to your professional area, or any generally relevant topic for discussion. There may also be a looser session in which representatives from those members who have not presented for a while can give short introductions.  The Forum last met on 22nd May and was kindly hosted by the IET.

Professional Regulation, Ethics and Corporate Governance

Please contact Sandra Ison at ARB or Tina Russell at CIPD to indicate any interest in these general areas.

Financial Ethics and the IDEA Centre Research – Events

The UKIPG / Professions Together has a long history of collaboration with the Inter Disciplinary Ethics Applied Centre at the University of Leeds.  In the last Newsletter, we noted the IDEA Centre’s research, commissioned by the Banking Standards Board, into the role of professional bodies in raising levels of ethical behaviour and technical competence within the banking and building society sector. The IDEA Centre held six Professional Ethics Network events, co-badged with a professional body and led by Professor Chris Megone and Jim Baxter and focused on the Professions and Ethics in Finance.  Following discussion at CEPLIS with Professor Benoit Rihoux of University of Louven, who is leading a ‘European Centre of Excellence’ project related to ‘CPD and Professional Ethics’, it could be useful to connect the two projects. The outcome of this work might just tip the balance in favour of H2020 funding in a second bid.

The IDEA Professional Ethics Network is hosting a free to attend seminar on Thursday 28th September at 1800 – 2100 (including supper) on ethical trading relating to supply chains. See .

Corporate Governance

On 29th August, DEIS published a Government Response to its Green Paper Consultation on Corporate Governance. See:                                                The broad headings of the review were Executive Pay, Strengthening the employee, customer and wider stakeholder voice, Corporate Governance in large privately-held businesses, Other Issues (around monitoring and enforcement), and Boardroom Diversity.  In ‘Other Issues’, there are several references to the Financial Reporting Council, the oversight regulator for the finance professions. The FRC’s Mission is:

Regulations and Professional Input

Following the Grenfell fire, there was comment that one possible contributing factor was the perceived reduced level of professional monitoring and enforcement by construction industry professionals in modern construction practice, possibly introduced under a ‘better regulation’ or ‘lighter touch regulation’ approach’ (eg roles of Supervising Architects, Building Control Officers, Clerks of Woks, Fire Safety Specialists, Site Engineers etc). There were also concerns about the wording of the Regulations themselves.  In response, the DCLG announce on 30th August an Independent Review of Building Regulations and Fire Safety.  Is your profession in any way involved? See:

Legal Regulation

The Legal Services Board, the oversight regulator for the legal professions, has been undertaking research into the experiences of consumers in vulnerable circumstances when they use legal services. Focusing specifically on people with dementia and mental health problems (and their carers), the research set out to explore their experiences of accessing legal services and to identify what can be done to improve accessibility, service experience and outcomes.  Some of the issues raised may be equally relevant to other providers of professional services across the spectrum of PT Membership. For a summary of findings, see:

Professional Standards Authority for Health and Social Care.  The PSA has published a report of a study entitled ‘A Typology of Dishonesty – Illustrations from the fitness to practise database’.  The paper proposed a typology of six kinds of dishonest act that can apply across professions.  See:—illustrations-using-the-fitness-to-practise-database.pdf?sfvrsn=6

UKIPG / Professions Together

Due to a change in employment, Ali Orr stood down as Chairman on 18th May at the start of the Leadership Group Meeting.  The Group invited Fiona Hellowell, formerly of ICSA and HEA, to be Interim Chairman. She agreed to do so until the end of 2017 to allow PT to seek nominations and appoint a new Chairman from 2018. Please start thinking, asking and suggesting now.

Thanks to all UKIPG / Professions Together representatives who have organised payment of their organisation’s annual subscription.

The new Postal Address for Professions Together – the UK Inter Professional Group is ‘PT UKIPG PO Box 1099, AYLESBURY HP22 9QH’