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Referral of Cases to CPS Headquarters (the Principal Legal Advisor, Private Office, Strategy & Policy Directorate and Press Office), Central Casework Divisions, the Chief Crown Prosecutors, or Area Complex Casework Units

Principle

Decisions on where cases are to be handled should be made quickly to avoid unnecessary delay.

Certain cases require special handling because of the type of case or the circumstances of the alleged offender.

There is a nationally agreed list of cases which are to be handled by Area Complex Casework Units and the London Complex Casework Centre. In addition, the work of the Central Casework Divisions, namely the Central Fraud Group, Special Crime and Counter-Terrorism Division, and Organised Crime Division have also been defined.

A reference to Chief Crown Prosecutor will be taken to mean 'Chief Crown Prosecutor or Deputy Chief Crown Prosecutor'.

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Guidance

Referral of Cases to Central Casework Divisions

Central Fraud Group (CFG)

Cases investigated by HMRC, fiscal fraud investigated by the police and HMRC. Cases of non-fiscal fraud where the alleged loss is in excess of £1M and which are complex or highly sensitive.

Please refer to Annex C for full details of the CFG referral criteria.

Special Crime and Counter Terrorism Division (SCCTD)

Counter Terrorism Unit

CPS Areas must refer the following cases to SCCTD: 

  • acts of terrorism or terrorist related offences; 
  • incitement to racial or religious hatred; 
  • official secrets act offences; 
  • violent extremism 
  • war crimes, crimes against humanity including torture and hostage taking.

Prosecutors need to be aware that: 

  • any act involving commission, preparation or instigation for a potential political, religious or ideological purpose; or 
  • possession of articles that might be useful to a terrorist;

could lead to the consideration of terrorist related offences.

In a few cases involving explosives, the possibility of a prosecution under the counter-terrorism legislation will arise. The Terrorism Acts 2000 and 2006 create a wide variety of offences, and most investigations are dealt with by specialist police units and referred directly to the Counter Terrorism Division. However, it is possible that prosecutors will be presented with cases where the legislation is applicable, for example where involvement with explosives is in some way linked to extremist political, religious or ideological activities which may include extreme right wing motivation.

Any case involving a possible charge under the terrorism legislation is referred immediately to the Special Crime and Counter Terrorism Division (SCCTD) and not dealt with by Area or CPS Direct prosecutors.

See the Legal Guidance chapter on Explosives for detailed guidance. [ADD LINK]

Special Crime Unit

CPS Areas must refer the following cases to SCCTD: 

  • 'Mercy' killings/encouraging or assisting suicide; 
  • Euthanasia offences; 
  • Disasters; 
  • Corporate manslaughter; 
  • Medical manslaughter;
  • Deaths in custody; 
  • Cases involving high profile people; 
  • CPS Employee Cases; 
  • SOCA Employee Cases;
    Serious public corruption connected to the Westminster environment, MPs/Peers, London Assembly, Royal Palaces and similar bodies (except cases submitted by SOCA); 
  • Election offences; 
  • Appeals to the Supreme Court; 
  • Appeals to the Administrative Court; 
  • Appeals to the Court of Appeal (for new appeals against final rulings lodged on or after 18 October 2010); 
  • Unduly lenient sentences; 
  • Non-European Arrest Warrant Import Extraditions to England and Wales (except SOCA, Terrorism, Official Secrets, War Crimes or Race/Religious Hatred cases);
Appeals Unit
  • Appeals to the Supreme Court;
  • Appeals to the Administrative Court;
  • Appeals to the Court of Appeal [for new appeals against final rulings lodged on or after 18 October 2010;
  • Unduly lenient sentences.
Extradition Unit
  • Non European Arrest Warrant Import Extraditions to England and Wales (except SOCA, Terrorism, Official Secrets, War Crimes or Race/Religious Hatred cases);
  • Extraditions to other jurisdictions.

Organised Crime Division (OCD)

This Division deals exclusively with cases submitted by the Serious Organised Crime Agency (SOCA) and the Child Exploitation and Online Protection Centre (CEOP). SOCA and CEOP cases must not be dealt with by Area Complex Casework Unit (or the Central Complex Casework Unit in London).

In addition, CPS Areas must refer all potential applications for the following to the Central Confiscation Unit of OCD: 

  • High Court Serious Crime Prevention Orders; 
  • civil asset recovery; 
  • pre-POCA High Court restraint and receivership work; and 
  • civil proceedings against the CPS.

Referral of Cases to Strategy and Policy Directorate

Strategy and Policy Directorate has a monitoring role in relation to cases identified at Annex B.

Referral of Cases to the Principal Legal Advisor

The following cases must be referred to the Principal Legal Advisor:

  • Cases involving the intentional or reckless sexual transmission of infection. Note: Referrals to the PLA must be through Heads of Complex Casework Units or Chief Crown Prosecutors.
  • Area and Complex Casework cases involving immunity from prosecution and undertakings as to the use of evidence (s 71, s 72 and s 74(2)(a) of the Serious Organised Crime and Police Act 2005. Note: cases falling under s 74(2)(b) and (c) must also be referred in certain circumstances. Refer to the legal guidance on Witness Immunities and Undertakings).
  • Applications for non-jury trials under s 44 of the Criminal Justice Act 2003.
  • Homicide cases where death occurs either (i) more than 3 years after an initial injury is sustained or (ii) after a person has previously been convicted of an offence committed in circumstances connected with the death. Refer to Homicide: Murder and Manslaughter elsewhere in the Legal Guidance.
  • Cases in which a charge of perverting the course of justice is being considered following retraction of a rape allegation. Refer to Public Justice Offences elsewhere in the Legal Guidance. Note: Referrals to the PLA must be through Chief Crown Prosecutors or Heads of the Complex Casework Units.
  • All private prosecution cases referred to the CPS for possible intervention.
  • All cases where police officers and fire-fighters who have carried out heroic acts during the course of their duty and in doing so may have breached section 7 of the Health and Safety at Work Act 1974 (the duty of all employees to take reasonable care at work). Refer to Heroic Acts by Police Officers and Firefighters elsewhere in the Legal Guidance.

From time to time, the Director requires the Principal Legal Advisor to be advised of certain types of cases for monitoring or other purposes. Those instructions should be followed and they are separate from the list of cases here that are required to be referred to the Principal Legal Advisor so that she may consider the case.

Referral of Cases to Private Office

  • Re-trial of serious offences - Part 10 Criminal Justice Act 2003.

Note: the personal consent of the DPP is required (or PLA where so authorised by the Director during the Director's absence).

In most, if not all cases, it is intended that the PLA will appear as Leading Counsel for the Crown. CPS Areas should therefore consult the PLA before considering the instruction to external counsel.

  • Jury Vetting - all requests for jury vetting must be referred to the Director.

Referral of Cases to Press Office

HQ Press Office must be advised of any case which may attract national media interest. If in doubt please contact Area Communications / Press Officer.

General

Annex A and Annex B bring together in table format the foregoing referral and notifcation requirements.

Referrals and Notifications to the CCPs or DCCPs

Cases to be referred for Actions and Case Handling Decisions

The following cases must be referred to the CCP or DCCPs: 

  • Murder
  • Conspiracy to commit murder
  • Attempted murder
  • Concealment of birth
  • Infanticide

Refer to Homicide: Murder and Manslaughter elsewhere in the Legal Guidance.

  • Riot
  • Any case involving the prosecution of a person with diplomatic immunity

Refer to Diplomatic Immunity and Diplomatic Premises elsewhere in the Legal Guidance.

  • Any offence by a solicitor representing a client
  • References by the Criminal Cases Review Commission to the Court of Appeal

Refer to Appeals from the Criminal Cases Review Commission elsewhere in the Legal Guidance, and also to Special Crime Division. 

  • Conspiracy, attempt, incitement or aiding and abetting any of the offences above;
  • A decision to intervene in a non CPS prosecution;

Refer to Private Prosecutions elsewhere in the Legal Guidance.

  • Reinstitution of proceedings

Refer to Re-institution of Proceedings elsewhere in the Legal Guidance. Note: The requirement for CCP authorisation is derived from an AG undertaking to Parliament and cannot be devolved to DCCP at present.

  • Re-trials for serious offences (Part 10, Criminal Justice Act 2003 - Double Jeopardy cases)

Refer to Retrial of Serious Offences elsewhere in the Legal Guidance.

Any case in which the prosecutor wishes to apply for consent to prefer a Voluntary Bill of Indictment. 

Refer to Voluntary Bills of Indictment elsewhere in the Legal Guidance.

  • PACE applications for personal records; trade / business material from a bank when s 7 Bankers' Books Evidence Act 1879 is not available; journalistic material;
  • Any case involving a fatal road traffic collision, including those where it is not proposed to proceed with an offence of causing death by dangerous or careless driving but where the driver was either: unfit to drive through drink or drugs; where the proportion of alcohol exceeded the prescribed limit; or where the driver failed without reasonable excuse to provide a specimen for analysis.

Refer to Road Traffic Offences Guidance on Prosecuting Cases of Bad Driving elsewhere in the Legal Guidance.

  • Appeals to the Court of Appeal.

Refer to Appeals to the Court of Appeal elsewhere in the Legal Guidance.

  • Cases involving allegations of criminal libel;
  • Motor manslaughter;
  • Cases involving applications to the Home Office for Resident Informant Status.

Refer to Covert Human Intelligence Sources elsewhere in the Legal Guidance.

  • Cases involving applications to the Attorney General for Nolle Prosequi.

Refer to Termination of Proceedings elsewhere in the Legal Guidance.

  • Cases or circumstances which may trigger a review of previously finalised cases.

Refer to Policy on Review of Previously Finalised Cases elsewhere in the Legal Guidance.

Cases to be notified to the CCPs or DCCP

The following cases must be notified to the CCP or DCCP: 

  • Cases involving any deaths which do not require referral to CCP or DCCP for actions and case handling decisions;
  • Cases that may raise national media interest;
  • Road traffic offences by members of the police, ambulance or fire services whilst on duty.

Refer to Allegations of Criminal Offences Against Police Officers and Other Persons Serving with the Police elsewhere in the Legal Guidance.

  • Where the judiciary directs that the papers are referred to the CPS for any reason.

See Judicial Comments elsewhere in the Legal Guidance.

  • Gaming betting and lottery offences;
  • Cases involving allegations of sexual offences committed abroad;
  • Cases in which a hypnotised witness is to be called to give evidence which will nearly always be in cases of unusual complexity and sensitivity.

Cases to be Notified to the CCPs, DCCPs or, in London, the Directors of Legal Services

The following cases must be notified to the CCP, DCCP or, in London, the Directors of Legal Services:

  • Cases involving any deaths which do not require referral to CCP or Directors of Legal Services for actions and case handling decisions;
  • Cases that may raise national media interest;
  • Road traffic offences by members of the police, ambulance or fire services whilst on duty.

Refer to Allegations of Criminal Offences Against Police Officers and Other Persons Serving with the Police elsewhere in the Legal Guidance.

  • Where the judiciary directs that the papers are referred to the CPS for any reason;

Refer to Judicial Comments elsewhere in the Legal Guidance.

  • Gaming betting and lottery offences;
  • Cases involving allegations of sexual offences committed abroad;
  • Cases in which a hypnotised witness is to be called to give evidence which will nearly always be in cases of unusual complexity and sensitivity.

Referral of Cases to the Area Complex Casework Unit

Complex casework to be dealt with in Area Complex Casework Units (CCU) will be mainly from Level 1 and Level 2 crimes with broadly defined characteristics of complexity that distinguish them from non-complex crime. The cases will normally bear one or more of the following characteristics: 

  • Substantial and complex fraud;
  • Large scale human trafficking;
  • Serious drug related offences involving substantial importation, manufacture or supply, particularly with an international dimension;
  • Major targeted local criminals in organised or international crime;
  • Serial sexual assault where there has been a protracted investigation;
  • Large scale child abuse, abduction or paedophile abuse cases involving multi generational abuse of several victims;
  • Major large scale public disorder offences of a political, racial or religious nature, or which cause particular local concern;
  • Complex / serious cases involving professional misconduct;
  • Hate related murders;High profile / multi victim / multi defendant;
  • All applications for a witness anonymity order;
  • All cases involving the negotiation of jurisdiction with the USA;
  • All cases in which the CPS Regional Asset Team Recovery lawyer has been involved in advising upon prosecution (Applicable Areas only. Currently: London, West Midlands, NE England, NW England and Wales (not North));
  • Cases investigated by a Counter Terrorism Unit which fall short of being terrorist offences and thus are not prosecuted by the Counter-Terrorism Division (Applicable Areas only. Currently: London, West Midlands, Greater Manchester and West Yorkshire).

There is a presumption that all cases in the Crown Court which are likely to last for 40 days or more and thus fall within the VHCC scheme will be dealt with by the CCU regardless of whether they have any of the above characteristics. This presumption can be overridden with the agreement of the Chief Crown Prosecutor if a VHCC case is considered to be suitable for handling by an Area operational unit.

In addition, cases may be referred to the CCU by agreement or at the direction of the Chief Crown Prosecutor and are likely to feature one or more of the following: 

  • Unusual legal or evidential issues (including RIPA);
  • Extensive confiscation issues;
  • Significant or multiple foreign enquires or liaison with foreign law enforcement agencies;
  • Protected witness;
  • Resident source;
  • Extensive undercover police operations / multiple use of sources.

Arrangements for CPS London

Separate arrangements apply to the London Complex Casework Centre (CCC). Prosecutors should refer any queries to the CCP London or the Head of the London CCC.

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Procedure

For most cases, there is no special form for either referral or notification. However, the Principal Legal Advisor has set out specific arrangements for the referral of cases for her consideration. For other referrals, sufficient information should be supplied to enable the CCP (DCCP in London) to make an informed decision as to who should handle the case.

For notification, a narrative report should be supplied for information, dealing particularly with the point giving rise to the need for notification.

The referral or notification should be through the normal line management channels.

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Annex A - Mandatory Referral of Cases by CPS Areas to HQ and Central Casework Divisions

Key

  • SCCTD - Special Crime and Counter-Terrorism Division
  • CFG - Central Fraud Group
  • ID - International Division
  • OCD - Organised Crime Division
  • PLA - Principal Legal Advisor

Allegations against the Police

Allegations against police officers concerning deaths in police custody or following police contact - SCCTD (Crime Unit)

Allegations against police officers of seriously corrupt activity - SCCTD (Crime Unit)

Crimes against humanity

War crimes, crimes against humanity including torture and hostage taking - SCCTD (Counter Terrorism Unit)

CPS related issues

Cases against CPS and SOCA employees - SCCTD (Crime Unit)

Civil proceedings against the CPS - OCD (Central Confiscation Unit)

All CPS official overseas visits require written authorisation - ID

Extradition and related matters

Extradition to other jurisdictions - SCCTD (Extradition Unit)

Non-European Arrest Warrant Import Extraditions to England and Wales (except SOCA, Terrorism, Official Secrets, War Crimes or Race / Religious Hatred cases) - SCCTD (Extradition Unit)

Fraud

Cases investigated by HMRC, fiscal fraud investigated by the police and HMRC. Cases of non-fiscal fraud where the alleged loss is in excess of £1M and which are complex or highly sensitive (Refer to CFG referral criteria for full detail) -  CFG

Hatred, extremism and reckless conduct

Cases involving the intentional or reckless sexual transmission of infection - PLA

Incitement to racial or religious hatred - SCCTD (Counter Terrorism Unit)

Violent extremism - SCCTD (Counter Terrorism Unit)

Homicide and death related cases

'Mercy' killings/encouraging or assisting suicide - SCCTD (Crime Unit)

Euthanasia - SCCTD (Crime Unit)

Corporate Manslaughter - SCCTD (Crime Unit)

Deaths in custody (See also Allegations against the Police) - SCCTD (Crime Unit)

Disasters - SCCTD (Crime Unit)

Medical Manslaughter - SCCTD (Crime Unit)

Homicide cases where death occurs either (1) more than 3 years after an initial injury is sustained or (2) after a person has previously been convicted of an offence committed in circumstances connected with the death (refer to Homicide elsewhere in the Legal Guidance) - PLA

Official Secrets

Official Secrets Act cases - SCCTD (Counter Terrorism Unit)

Proceedings in Higher Courts

Appeals to the Supreme Court - SSCTD (Appeals Unit)

Appeals to the Administrative court - SSCTDD (Appeals Unit)

Appeals to the Court of Appeal in respect of cases lodged on or after 18 October 2010 - SSCTD (Appeals Unit)

Potential applications for High Court Serious Crime Prevention Orders, Civil Asset Recovery; and pre-POCA High Court restraint and receivership work - OCD

Unduly lenient sentences - SSCTD (Appeals Unit)

Prosecution Related Issues

Area and Complex Casework cases involving immunity from prosecution and undertakings as to the use of evidence (section 71, section 72 and section 74(2)(a) of the Serious Organised Crime and Police Act 2005).  Note: cases falling under section 74(2)(b) and (c) must also be referred in certain circumstances - PLA

Pre-CPS (that is, pre-1986) cases referred by the Criminal Cases Review Commission - SCCTD (Crime Unit)

Jury Vetting Requests for jury vetting must be referred to the DPP - DPP/Private Office

Applications for non-jury trials under section 44 of the Criminal Justice Act 2003 - PLA

Cases in which a charge of perverting the course of justice is being considered following retraction of a rape allegation - PLA

All private prosecution cases referred to the CPS for possible intervention - PLA

Heroic Acts by Police Officers and Firefighters Section 7 HSWA 1974 - PLA

Public Life

Cases involving high profile people - SCCTD (Crime Unit)

Cases involving the disclosure of confidential information by public servants to journalists - SCCTD (Crime Unit)

Election offences - SCCTD (Crime Unit)

Serious Public Corruption connected to the Westminster environment, MPs/Peers, London Assembly, Royal Palaces and other similar bodies (except cases submitted by SOCA) - SCCTD (Crime Unit)

Bribery

Foreign bribery and associated offending - CFG

Other domestic bribery and corruption - CFG/SCCTD (Crime Unit)

Re-trial of serious offences

Re-Trial of Serious Offences Part 10 Criminal Justice Act 2003  - DPP

The personal consent of the DPP is required (or PLA where so authorised by the Director during the Directors absence).

In most if not all cases it is intended that the PLA will appear as Leading Counsel for the Crown. Please therefore refer to the PLA before considering the instruction of external counsel.

Terrorism

Acts of terrorism or terrorist related offences - SCCTD (Counter Terrorism Unit)

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Annex B - Monitoring of Casework: Notification of case details to Headquarters and Central Casework Divisions as per instructions

Procedural Failures

Custody time limit failure - DPP

Monitoring of Casework

Appeals against conviction and/or sentence to the Court of Appeal; Appeals by way of case stated; Judicial Review - CPS Appeals Units, SCD

Applications to the ECHR - Strategy and Policy Directorate (Helpdesk) - to discuss response and maintain central record

Cases which may attract media interest - Press Office

Cases which may trigger a review of previously finalised cases - Head of Strategy and Policy; Group Chair

Reasonable Chastisement Defence - all cases in which the defence of 'reasonable chastisement' has been raised and there is a decision to charge - Strategy and Policy Directorate

Third Party Costs Order for Serious Misconduct - Applications against the media - Strategy and Policy Directorate and Press Office

Violent or Domestic Extermism cases - Counter Terrorism Divison (VE or DE Co-ordinator)

Cases of Non Accidental Head Injury in which the defence seek to challenge 'the Triad' diagnosis by introducing bio mechanical evidence or by 'unified hypothesis' - Strategy and Policy Directorate

Annex C - Referral Criteria for the Central Fraud Group

Acceptance Criteria

Prosecuting Fraud within the CPS

The Guidelines apply to all fraud cases referred to the CPS from 1 September 2010.

1. The Central Fraud Group (CFG) has been established as a CPS Central Casework Division to provide a specialist prosecution and advisory service for complex, sensitive and high value fraud cases both in London and throughout England and Wales. The CFG will be a centre of excellence in the prosecution of fraud. It will undertake both fiscal fraud cases investigated by HMRC and non- fiscal fraud cases, primarily those investigated by the Police.

Fiscal fraud

2. The CFG will continue to handle all prosecution and pre-charge advisory work in cases of fiscal fraud investigated by HMRC, as set out in the Directive on Fiscal Fraud Prosecutions from the Chief Operating Officer dated 6 May 2010, along with cases of arms brokering and strategic exports investigated by HMRC. No additional criteria will be applied to determine whether a case is suitable for prosecution by the CFG.

3. The only exception to the above is that from 1 October 2010 CPS Direct will be responsible for providing HMRC with initial charging advice in respect of any urgent out-of-hours charging decisions.

Non-fiscal fraud

London - cases investigated by the City of London Economic Crime and Fraud Squad and the Metropolitan Police Economic and Specialist Crime Division (SCD 6): All cases must be referred initially to the CFG for consideration as to their suitability for prosecution by the Group.

4. England and Wales - cases investigated by Economic Crime Units or their equivalents in police forces outside City and SCD6 London:

Any case where the alleged intended provable loss exceeds £1M must be referred initially to the CFG for consideration as to suitability for prosecution by the Group unless the case is self-evidently straightforward to deal with.

Any case where it is considered that the criteria set out at paragraph 10 below apply, may be referred to CFG.

5. Given the complex nature of such investigations, all referrals should take place at an early stage of the investigation, as soon as the specialist advice of a fraud prosecutor would be of assistance. Many such cases involve issues relating to restraint or international enquiries, for example, which would benefit from the early involvement of a specialist prosecutor. 

Geographical split

6. All cases submitted to the CFG for prosecution and/or pre-charge advice by investigating authorities in areas including and North of the following: North Wales, West Mercia, Staffordshire, Derbyshire, Nottinghamshire and Lincolnshire should be referred to the Head of Central Fraud Group (North) at Sunlight House, Manchester:

Elizabeth Bailey
Head of Division
Central Fraud Group (North)
Sunlight House
Quay Street
Manchester
M60 3PS

Switchboard (Sunlight House) 0161 827 4700

7. All other investigating authorities (i.e.South Wales and south of the regional areas referred to above) should refer their cases to the Head of Central Fraud Group South (Non-Fiscal) at Rose Court, London:

Andrew Penhale
Head of Division
Central Fraud Group South (Non Fiscal)
Crown Prosecution Service, 6th Floor Rose Court,
2 Southwark Bridge, London SE1 9HS

Switchboard (Rose Court) 020 3357 0000

Case acceptance criteria in non-fiscal fraud cases

8. Once a case is referred to the CFG it will be registered and then considered against specific case acceptance criteria by the Heads of the Central Fraud Group North or South (Non-Fiscal) or their deputy. Provided there is sufficient detail included within the papers referred to the CFG, this assessment will take place within 10 working days of receipt by the Group.

9. The case acceptance criteria to be relied on by the CFG are as follows:

Suitable cases for the CFG will be cases of alleged fraud which are considered to be serious, complex and/or highly sensitive. This will include the following:

i) Cases where the alleged intended provable loss is in excess of £1 million;
ii) Difficult corruption cases especially concerning public bodies and officials;
iii) Cases where it is necessary to maintain public confidence in the impartiality of the reviewer;
iv) Substantial and significant fraud on government departments;
v) Frauds on the governments of other countries;
vi) Cases in which, because of widespread public concern, the Fraud Group may be expected to perform a co-ordinating and standard setting role;
vii) Difficult cases requiring specialised knowledge involving, for example, Stock Exchange practices, Regulatory bodies, Complex Banking issues, shipping law, onshore and offshore trusts, computer misuse in perpetrating the fraud;
viii) Complex and high value "Boiler Room" and "Ponzi" frauds;
ix) Significant and complex cases of money laundering in connection with fraudulent activity Cases of foreign bribery (where the investigation has not been conducted by the Serious Fraud Office [SFO]).

Please note that the above list is not exhaustive but is indicative of the type of cases that may fall within the criteria  

10. If a case is considered suitable for the CFG it will then be allocated to an appropriately experienced CFG lawyer.  If it is not considered to be suitable, it will be referred to the CCU of the CPS Area local to the investigating authority. When a case is referred on to an Area CCU, the CFG will inform the relevant police officer or Senior Investigating Officer of its decision and the person within the local CCU to whom the case has been referred. 

11. In all cases where pre-charge advice is sought under the Statutory Charging scheme the submissions by the Police will include a duly completed MG3 form and all other appropriate documentation.

12. In the event of any disagreement or dispute under the terms of these criteria then matters will be referred to the Director of the Fraud Group whose decision will be final.

Case Referrals by CPS Areas

13. Where a fraud case has been accepted for prosecution by a CPS Area and the Area, having regard to the case acceptance criteria in paragraph 9 (above), considers that the case may be suitable for prosecution by the CFG, it should refer the case as soon as possible to the appropriate office of the CFG for its geographical area. Provided there is sufficient detail included within the papers referred to the CFG, the assessment of the case by the Head of the Central Fraud Group North or South (non-fiscal) or their deputy will take place within 10 working days of receipt by the Group.

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