29 July 2021
BTOverview In this edition
Post Furlough Pitfalls for Employers to Avoid
Post COVID Professional Indemnity Claims
HSE Enforcement Trends and COVID Compliance
Post Lockdown Changes to Corporate Insolvency
Event: RESOLVE - INSOLVENCY - NOW AND THE FUTURE
Do you wish to amend your title conditions?
“Free Britney”: Do Conservatorships exist in Scotland?
Announcement: Free Fertility Law Advice Service
BTO NEWS
www.bto.co.uk
Post Furlough Pitfalls for Employers to Avoid Douglas Strang outlines how to future proof businesses post pandemic.
The Coronavirus Job Retention Scheme (or the furlough scheme) has been a lifeline for a huge number of businesses throughout the COVID-19 pandemic. The scheme will end on 30 September 2021. This means that employers need to think now about the future of their businesses and whether any reshaping is required.
flexibility, an employer would need to obtain employees’ agreement to any changes being made. Furloughed workers may agree to return to work with a pay cut or reduced hours in the short term if it saves their jobs. There is also the option of using unpaid leave, or temporarily laying off staff (if permitted by the contract).
Furlough over Summer 2021 From 1 July 2021, the furlough scheme has become more expensive for employers. The Government is currently paying 70% of salaries with employers making up 10%.
Fire and Re Hire? A last resort for changing an employee’s terms of employment when a change cannot be agreed, is the dismissal and re hiring of employees. However, it is important that the employees are consulted on the changes and follow a fair dismissal procedure. The termination will be a dismissal in law and can therefore give rise to an unfair dismissal claim even if the employee accepts re-engagement on the new terms
In August and September, the Government is only paying 60% of wages with employers having to pay 20%. Issues for Employers The aim of the furlough scheme, since its introduction in Spring 2020, has been to protect jobs from redundancies caused by the effects of the COVID-19 pandemic. It has been successful in avoiding redundancies, but with the scheme ending, there is much for employers to consider. Employers must think carefully about their finances, their requirement for staff, and whether furloughed workers can resume work as before. Ultimately, employers may decide that redundancies or other changes are required. Redeployment and Changes to Roles The first port of call for any employers who are unable to bring the entire furloughed workforce back to work should be to look at alternatives to redundancy. Can the problem be addressed by changes to roles, working hours, or pay? Employers should consider whether employment contracts allow for changes to be made. Ideally, there would be a contractual flexibility clause allowing for a change to be made to an employee’s role or hours, but only rarely will this extend to being able to unilaterally cut pay. The wording of the clause will dictate the changes which can be made. Even if there is such a clause it is important for employers to consult with staff to ensure that any issues are fully raised and explored. When there is no contractual clause allowing for 1
The collective consultation rules are triggered when an employer proposes to dismiss and re hire 20+ employees in a 90 day period. It is imperative for firms to follow the rules; you may need to arrange for the election of employee representatives. Employers should also be aware of possible reputational harm, as there has been widespread criticism recently of the “firing and rehiring” on inferior terms, with calls for such a practice to be banned. Redundancy Some businesses will inevitably decide that redundancies must be made. Seeking volunteers may be a sensible first step. Employers need to tread carefully to make sure that due process is being followed for any compulsory redundancies. A fair dismissal process is mandatory (at least where employees have over 2 years’ service). The process should include individual consultation, proper selection pools, and objective selection criteria. BTO’s specialist Employment Team can assist employers in making tricky decisions about the future of their businesses and the lawful procedure to follow. This update contains general information only and does not constitute legal or other professional advice.
Douglas Strang dst@bto.co.uk / 0141 221 8012
Post-COVID Professional Indemnity Claims Rebecca O’Hear takes out her crystal ball to consider a few sectors expected to be affected by Professional Indemnity claims relating to COVID-19 adapted business procedures.
Although it is too early to determine the full impact that COVID-19 has had on claims, what follows is our best guess on a few sectors expected to be affected:
failure to deliver the level of work clients expect. Service issues may rapidly escalate to fee disputes, complaints and, inevitably, an increase in claims.
Surveyors and Valuers A suppressed housing demand, an emerging desire for gardens and private outdoor space, and buyers being able to raise more for new house funds during a time when they weren’t able to spend on anything else, have all led to a soar in house prices in the last 12 months. This was compounded even further in July 2020 when the government announced a stamp duty holiday.
Leaving interpersonal aspects to the side, physical barriers have had a particular impact on private client practitioners for whom face to face meetings are crucial in order to be able to take instructions, assess capacity and arrange the execution of documents such as wills. We have seen, and anticipate more, claims stemming from the sort of situation where a testator has been admitted to a care home or hospital, to which access is restricted, and has sadly passed away before testamentary instructions could be implemented.
Many believe that this landscape can’t last, with the Bank of England having previously suggested a 16% fall in house prices by the end of 2021. Surveyors are being challenged on property valuations considered as having been ‘down-valued’ in areas where recent sale data indicates that considerably higher prices are capable of being achieved. Conversely, however, they may also find themselves on the end of claims later brought by disgruntled homeowners who find themselves in negative equity following overzealous valuations prepared during an uncertain market. Home Reports now feature disclaimers advising that “property market activity has been impacted due to the current response to COVID-19. This has resulted in an unprecedented set of circumstances on which to make a valuation judgment”. However, will a short comment advising that less certainty can be attached to valuations be enough to stave off claims? Legal (and other) Professionals Firms may experience an increase in claims relating to inadequate or inaccurate advice as a result of remote dealings with both clients and employees. Communication is vital and face-to-face consultations provide an opportunity to ask questions and seek clarity on complex and nuanced legal points that emails don’t. This is even more of an issue for elderly clients who do not have access to emails or video conferencing applications. Trust is established through rapport, but this can be difficult to build through words on a screen. Partners are unlikely to have been able to supervise less experienced staff to the same degree as in the office. This may have led to missed deadlines and a 3
Finally, as professionals shift from home working to a more flexible model involving moving between home and office, the likelihood increases of claims stemming from data loss or data security breaches. For example, the phone or laptop being left on a train, or the memory stick being dropped in the rush to catch one. Education It has been widely reported that the move to online learning has led to an overall reduction in supervised teaching hours for many students. Additionally, students studying courses involving considerable practical elements have complained that zoom calls can never replicate the hands-on laboratory experience they signed up for. The problem is all the more acute in the case of students who are paying tuition fees or accommodation costs and may consider themselves entitled to greater accountability. In the immediate aftermath, schools, colleges and universities may face claims around the assessment of work and, in the case of colleges and universities, around the operation of admissions policies and procedures. Allegations of discrimination are likely to feature. They may be faced with value for money claims in respect of the tuition fees they have collected, despite being unable to offer a full teaching experience during the pandemic. They may also experience so called “failure to teach” claims arising further down the line, when ill equipped students are faced with difficulties when trying to secure graduate jobs. The above are but some of the issues which may arise... Rebecca O’Hear,roh@bto.co.uk / 0141 221 8012
HSE Enforcement Trends and COVID Compliance As many businesses return to the workplace, Vikki Watt considers Regulatory enforcement trends over the last fifteen months.
The HSE are continuing their steadfast role in ensuring that employers protect the health, safety and welfare of their employees, so far as reasonably practicable, as many workplaces make the transition to communal working areas and offices. The HSE are continuing their spot check visits across all sectors with an enhanced presence in sectors perceived to be higher risk; such as construction, manufacturing and the care sector, whilst seeking to maintain proportionality in their enforcement decisions and behaviours. The statistics and information published by the HSE to date show that over the past fifteen months, there has been a fairly steady increase in Regulatory enforcement. Although there have been no successful prosecutions as yet (which is understandable given the timing of matters), we can see trends in the nature of potential breaches occasioning the service of Improvement Notices, for example, (which is a tool the HSE will use to work with the duty-holder to seek to ensure compliance). The most commonly perceived breaches all centre around the general duties set out in the Health and Safety at Work etc Act 1974 and relate to failures to have in place suitable and sufficient hand hygiene procedures, social distancing measures and welfare facilities. Unsurprisingly perhaps, many of the early cases related to perceived deficiencies in transmission control procedures as workplaces sought to implement control measures to deal with the new risks. Crucially, there were also failures to produce appropriate COVID19 related risk assessments and to ensure staff were aware of the new infection control procedures which ought to have been in place. Interestingly, as we progress through this year, we are seeing slightly different risk profiles in the type of purported breaches in relation to which the HSE are serving Improvement Notices. It is perhaps human nature to want to have a long-awaited conversation with a colleague or friend out-with working hours, however, cautious employers should still seek to make it clear to employees what their expected procedures are for entering/exiting the workplace. Royal Mail Group Limited were served with an Improvement Notice in April 2021 for failing to assess, manage and control risks for employees doing just that. A number of 1
employees were congregating before and after their shifts without any social distancing measures being enforced. COVID-19 is not an industry or sector specific problem. Whilst some businesses might have higher risks, and therefore a more onerous task of mitigating those risks, COVID-19 does not discriminate based on job title. Furthermore, it is not just the responsibility of employers. Employees are also responsible for complying with appropriate control measures to keep themselves and others safe under the Health and Safety at Work etc Act 1974. Therefore, we all have a duty to act in line with our employer’s directions and public health guidance. Please contact us for further information on what you can do to protect your business and workers as you prepare for a return to the workplace and to ensure compliance with the latest rules during this time of transition for many. Vikki Watt vwa@bto.co.uk 0141 221 8012 Lucia Spadaro lsp@bto.co.uk 0141 221 8012
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Post Lockdown Changes to Corporate Insolvency As certain temporary protective measures afforded to business during the pandemic come to an end, corporate lawyer Alastair Dunn and litigator Angus Wood set out a brief summary of some key considerations.
The Corporate Insolvency and Governance Act 2020 (“the Act”) introduced a variety of temporary protective measures to allow businesses to withstand challenges created by the pandemic and to avoid insolvency proceedings. However, certain temporary measures are due to end in the coming months as government restrictions are gradually lifted. It is important for companies and directors to be aware of the changing provisions as well as the potential impact of proposed new legislation on investigating the conduct of directors of dissolved companies. Some key considerations: Winding up petitions The Act prevented creditors from enforcing statutory demands or winding up petitions on companies where their debts arose as a result of the pandemic. This aimed to allow businesses, which would otherwise be solvent, to survive the effects of the pandemic and continue to operate their businesses during and after lockdown. These protections, however, are due to be removed on 30 September 2021. From this date, creditors will be entitled to enforce statutory demands for payment and raise winding up petitions against companies, regardless of whether or not their debts are attributable to the pandemic. Moratorium The Act also introduced a 20-business day moratorium, whereby creditors are prohibited from pursuing legal action against a company without the permission of the Court. This was designed to provide businesses with “breathing space to explore rescue and restructuring options, free from creditor action”. Under the Act, companies remain eligible for a moratorium even where they have been subject to insolvency proceedings or have entered into a moratorium in the last 12 months, therefore ensuring eligibility for those suffering cashflow problems during multiple lockdown periods. This provision, however, is also due to end on 30 September 2021, meaning companies may only benefit from one moratorium per year thereafter. Further, the availability of the out of court application process for companies will be removed on the same date and shall be retained only for overseas companies. It is also important to be aware of the temporary provisions which have already ended in recent months. These include the protections for directors in terms of 3
their contributions to company assets under the wrongful trading provisions, the restriction on suppliers terminating goods and services contracts where the customer has entered insolvency proceedings and the extension of filing deadlines at Companies House. The Ratings (Coronavirus) and Directors Disqualification (Dissolved Companies) Bill In addition to the protective measures which are being withdrawn, the Government is shifting its focus from providing support, to investigating abuse of the support offered. The Government has highlighted the shear scale of the support offered – with almost £80bn of Government backed emergency loans issued – and HMRC has ramped up its rhetoric around investigations into abuse of the Job Retention Scheme, with a specific taskforce being set up to investigate incorrect and fraudulent claims. One concrete measure which has also been proposed is the Ratings (Coronavirus) and Directors Disqualification (Dissolved Companies). One of the aims of the Bill is to address concern surrounding the actions of directors in dissolving companies to avoid liability for the company’s debt. Under the current provisions, (Company Directors Disqualification Act 1986) neither the Secretary of State, nor the official receiver, can investigate former directors when a company is dissolved as opposed to liquidated. This Bill proposes to remove this prohibition, therefore making it easier to hold directors accountable for wrongful conduct when dissolving a company. It remains to be seen how effective this step will be as the dissolution of a company would still avoid the obligation of a liquidator to report to the Insolvency Service on directors’ conduct. However, if enacted, this Bill may discourage directors from failing to properly adhere to insolvency procedures and ensure greater accountability for the repayment of government loans. If any of these changes affect your business, get in touch with us to obtain specialist advice on corporate insolvency. Alastair Dunn akd@bto.co.uk / 0141 221 8012 Angus Wood arw@bto.co.uk / 0141 221 8012
Tuesday 5 October 2021
RES
LVE
14:00 - 17:15 including Q&A Virtual Classroom hosted by CLT Scotland Chaired by Grant Hunter, Partner
“RESOLVE - INSOLVENCY - NOW AND THE FUTURE” The fees below include a 20% discount for BTO’s contacts: £100 + VAT for CLT members (Discount code: DISC100) £200 + VAT for non-members (Discount code: DISC200)
TO BOOK: CLICK HERE and enter your discount code.
Life after Covid Support: Zombie Companies, Insolvency and the Claims which Follow What will happen in the insolvency world once the current protective measures and support packages are removed? Angus Wood will discuss the potential fallout from the withdrawal of the insolvency protections and unprecedented capital support provided to the UK economy. He will consider the drivers of insolvency and the claims which are likely to arise as part of the insolvency, including; unlawful dividends, unfair preference and gratuitous alienations. He will do so with a view to providing practical guidance for companies and directors faced with the prospect of insolvencies, and for creditors when considering prospective recoveries. Angus Wood, Insolvency Litigation Partner, BTO Solicitors LLP: arw@bto.co.uk / 0141 221 8012
Rocks, Hard Places and Directors’ Duties Alastair Dunn will consider recent case law developments in relation to directors’ duties and explore how the courts may regard difficult decisions taken by companies during the pandemic. While the UK government temporarily suspended the wrongful trading provisions for company directors to remove the threat of personal liability during the pandemic, the law relating to director’s duties and liabilities in the context of insolvency remained intact. This means that actions taken by directors during the pandemic could still attract liability for fraudulent trading, transacting while insolvent and granting preferences. Accordingly, the threat of director disqualification remains for actions taken during this unprecedented period with there being no relief for subsisting breaches of duties. Alastair will look at some of the difficult calls that directors have had to make and how these may be looked at after the event in the context of the balancing of their legal duties in circumstances that nobody could have predicted. Alastair Dunn, Corporate Partner, BTO Solicitors LLP: akd@bto.co.uk / 0141 221 8012
Dealing With Distressed Corporations and the Restructuring Options Available Based on over 30 years of experience in SME’s, Kenny Craig will provide a pragmatic view on the causes of financial difficulty, turnaround considerations, restructuring options available and how they work in practice. He will cover the issues faced by insolvent businesses and guide you through the restructuring and insolvency options available to directors and other stakeholders in the SME sector. Kenny will focus on many of the practical issues which affect the decision making process and which need to be addressed in order to secure a positive outcome for the future of the business and its stakeholders, as opposed to simply closing the doors. Kenny Craig, Insolvency Partner, Begbies Traynor: kenny.craig@btguk.com / 0141 222 2230
Do you wish to amend your title conditions? Jane Steel explores two ways in which Scottish property owners can amend their title conditions.
Many proprietors living in multi-tenanted developments in Scotland are subject to title conditions that impact what they can and cannot do to their properties. A “Community Burden” is the term used for a title condition that applies to multiple properties. While some of these burdens are conducive to the overall enjoyment of the development, especially when it comes to the maintenance of communal areas, others may be unnecessarily restrictive and simply outdated. There are two courses of action that are open to owners who wish to amend their title conditions: a minute of waiver, or an application to the Lands Tribunal for Scotland (“the Tribunal”). A minute of waiver must be signed by all or a majority of benefited proprietors (owners who are able to enforce the burden) in order to discharge or vary a title condition. In recognising that this may be rarely achievable in a development of any size, the alternative (and in some cases the more practical option) would be to make an application to the Tribunal. The 2003 Act provides a special mechanism for the variation of a community burden. Section 91 of the 2003 Act provides for such a variation to be made by an application to the Tribunal by at least one quarter of the unit owners. For example, if there are 40 properties in the development, only the owners of at least 10 properties are required to give their consent by signing the application in order for it to proceed to the Tribunal. The Tribunal will also take care of the administrative elements of the process i.e. serving notice on all the proprietors. At present, standard applications to the Tribunal cost £150 and are made on the Form TC 91(1)(a), which should be populated with as much information as possible. However, the Tribunal are active in their contact with the applicant(s), or their agents, for clarity if the application form is incomplete or unclear. When the Tribunal receives the application, they will send a copy of it to various parties, namely the benefited owners. Parties who receive this intimation are given at least 21 days to give a response (known as “representations”). Any representations made should be in the form of a written statement of facts and contentions that the party wishes to rely on.
In cases where representations opposing the application have been made, the case may go to a hearing. Nevertheless, the Tribunal may still grant the application if it is reasonable to do so after the consideration of a number of factors contained in Section 100 of the 2003 Act, for example, the purpose of the title condition and the extent to which the burden impedes the enjoyment of the burdened property. Where the Tribunal approves the application or if it is unopposed, it will grant an order for the burden to be discharged. In a time where the housing market has seen a significant increase in the demand for properties, this brief insight is a friendly reminder of the options available to those who are unhappy with and wish to change their title conditions. Jane Steel js@bto.co.uk / 0141 221 8012 222 2939
“Free Britney”: Do Conservatorships exist in Scotland? Charlotte Fleming and Sian Keddie discuss the legal concept of a Conservatorship, Scotland’s equivalent mechanism and steps that you can take to avoid the upset and distress experienced in Britney’s situation.
You may have noticed #FreeBritney trending on social media recently causing you to ask Google ‘Do Conservatorships exist in Scotland?’ What is a Conservatorship? Legally, a Conservatorship is a mechanism by which an individual is appointed by the Court to manage the affairs of an adult who lacks capacity to manage their own affairs. It is, therefore, similar to the mechanism used in Scotland – Guardianship. In both cases, the Court-appointed Conservator or Guardian has the ability to make decisions involving the adult’s financial affairs, as well as their health and medical decisions. This is a role that comes with an extraordinary amount of responsibility and discretion and so it is vital that the Conservator or Guardian is trustworthy and acts in the best interests of the vulnerable adult, including taking their wishes, where appropriate, into account. Could what is happening to Britney happen to me or my loved ones? You may be concerned to learn that in Scotland we have an equivalent mechanism to the United States’ Conservatorship – the issues affecting the Spears family may not be so remote after all. In Scotland, there are stringent rules which require to be complied with to obtain a Guardianship Order. For example, two medical reports must be obtained from registered medical practitioners which confirm that the adult lacks mental capacity to make their own decisions. The proposed Guardian will also require to obtain a ‘Bond of Caution’ - an insurance policy that protects against the appointed Guardian acting dishonestly. If the Guardian were to dishonestly take money from the adult in question, for example, this insurance policy would ensure that the adult is reimbursed. Once granted, the court will impose very strict timescales which means that most Guardianship arrangements will be subject to review every 2-5 years. During their tenure, the chosen Guardians are very closely monitored by the Office of the Public Guardian. In contrast, although the process for obtaining a Conservatorship in the USA varies from state to state, 3
the requirements appear less rigorous than those required by the Scottish courts for a Guardianship. Therefore, it is unlikely for Britney’s situation to occur to the same degree in Scotland. However, there are other problems associated with Scottish Guardianships, including the costs involved in such applications and the fact that applying to the Court in Scotland can be incredibly time-consuming. What can I do to avoid Britney scenario? Whilst Guardianships are closely monitored to protect against abuse of power or questions of integrity, you may be concerned at the prospect of the court appointing someone to manage your affairs on your behalf. Crucially, you may worry that the person appointed by the Court is not someone you would have appointed yourself, given the choice. Thankfully, you can arrange for a Power of Attorney to be prepared! You may think that putting a Power of Attorney in place is not something that requires thought until you are at least middle-aged. However, the ‘Free Britney’ saga demonstrates that matters of capacity can be relevant at any age and this is a cautionary tale! A Power of Attorney allows you to choose the individuals who will be responsible for managing your affairs if you lose the capacity to do so. You can – and should – think carefully about who you wish to appoint and be confident that they will make the correct decisions for your wellbeing. You can also leave additional guidance about the criteria you wish to be met before being deemed incapacitated, any spending preferences and what kind of decisions you would have made about medical care. In short, you can provide a great deal of guidance and this should give you confidence that your Attorneys can act in accordance with your wishes as far as possible. If you would like to discuss putting a Power of Attorney in place to ensure peace of mind, contact our Wills Estates and Succession Planning team. Charlotte Fleming cfl@bto.co.uk / 0141 221 8012 Sian Keddie ske@bto.co.uk / 0131 222 2939
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BTO is delighted to announce the launch of our free Fertility Law Advice Service for couples and individuals who are embarking on their fertility treatment journey.
What is the Fertility Law Advice Service?
How can I use this service?
This email advice service is designed to answer initial questions potential parents may have regarding the fertility treatment process. Free signposting and generic information about fertility law will be provided by our lawyers who have a genuine understanding of fertility law and the complicated landscape in which it operates.
For those wishing to take advantage of this free service, all initial enquiries can be submitted via email to a dedicated inbox at fertilitylaw@bto.co.uk or by completing our online Contact form. Our Fertility Law team’s specialist solicitors guarantee a response within 7 days or less.
Why has this advice service been created?
What if my enquiry is urgent and/or I require formal advice regarding my specific circumstances?
We recognise that being aware of the legal position may not be your top priority when starting your journey to becoming a parent. However, arming yourself early on with knowledge of your rights and the options available to you, can demystify the whole process. Our email advice service has been created to address this need and to help couples and individuals start off the fertility process on the right foot. We believe that everyone should be able to create the family that they desire and we support all modern families, no matter their make-up and circumstances, including surrogacy, assisted donor conception, adoption and LGBTQ+ couples. We also represent clients in international and cross border issues.
The Fertility Law team is offering a no-obligation initial Fertility Fixed Fee appointment (currently remotely). This is a meeting of up to 60 minutes @ £270 +VAT. Click here for full details of the package. Call 0131 222 2959 / 0141 225 4848. We look forward to guiding you through your fertility journey!
“(They did) a wonderful job… at a very difficult time in my life.” BTO Client 3
BTO NEWS New Accredited Specialist in Professional Negligence Lynne Cardow, a Partner in our band 1 ranked Professional Liability team, has been awarded specialist accreditation in professional negligence by The Law Society of Scotland. She is now one of only ten Scottish solicitors to hold this accreditation. A double achievement, Lynne has also become a Certified Specialist in Cyber Security. Lynne Cardow lca@bto.co.uk / 0141 225 5318
Certified Cyber Security Specialist Lynn Richmond, a Partner in BTO’s Data Protection team, has become a Certified Specialist in Cyber Security. As no business is immune to cyber risk and we have seen that the financial and reputational impacts of cybercrime, business interruption and data breaches can be immense, Lynn and Lynne Cardow considered it important to provide our clients with an even more robust service in this area. Lynn Richmond lyr@bto.co.uk / 0131 222 2934
Accredited Specialist in Family Law Morven Douglas, a Senior Associate in our Family Law team, has been re-accredited by the Law Society of Scotland as a Family Law Specialist for a further 5 years, having first received accreditation ten years ago. Morven Douglas mjd@bto.co.uk / 0141 221 8012
Donna Brennan Joins BTO’s Helensburgh Office as Legal Director Donna Brennan has been appointed as Legal Director in our BTO Raeburn Hope office, where she will manage the firm’s Wills Estates and Succession Planning team. Donna is a recognised expert in her field and a Registered Trust and Estate Practitioner. Donna Brennan dbr@bto.co.uk / 01436 671 221
Irene Henderson Promoted to Associate Irene Henderson has been promoted to Associate in our BTO Raeburn Hope office in Helensburgh where she deals with all aspects of residential conveyancing, including purchases, sales, transfers of title and re-mortgaging. Irene Henderson ihe@bto.co.uk / 01436 671 221
New Lettings Manager in Helensburgh BTO Raeburn Hope Office Mairi Walker has been appointed as Lettings Manager in our Helensburgh office. Mairi’s focus will be on delivering an individual service to the firm’s landlord and tenant clients, ensuring that they have an accessible, proactive property lettings and management service. Mairi Walker mmw@bto.co.uk / 01436 647 629
Whatever your legal needs, we are ideally placed to assist.
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BTO Solicitors LLP (SO305583): 48 St. Vincent Street Glasgow G2 5HS / 0141 221 8012 One Edinburgh Quay Edinburgh EH3 9QG / 0131 222 2939 77-81 Sinclair St, Helensburgh G84 8TG / 01436 671 221 Follow BTO on Twitter: @btosolicitors The material in this publication contains general information only and does not constitute legal or other professional advice.
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