UK: The Job Retention Scheme - Pensions & Benefits Issues (Video)

Ian Chapman-Curry: Hello and welcome to this webinar brought to you by the Pensions and Combined HR Solutions team at Gowling WLG. I am Ian Chapman-Curry, a Legal Director in the Pensions team and I am joined today by Richard Lee, Partner in the CHRS team. Hello Richard.

Richard Lee: Hi Ian, morning everyone.

Ian: So today, we are going to be looking at the pensions and employee benefits aspects of the current COVID-19 crisis and, in particular, the Government's Coronavirus Job Retention Scheme and what it means for pensions.

Just before we get into that - and to put this into a bit of scale as to why this is an issue that is causing so much interest and attention across the UK business community - I had a look this morning on the tracking of the number of cases being done by John Hopkins University. At nine o'clock this morning (2 April 2020) there were 938,373 confirmed cases, so just shy of 1,000,000 cases across the world. Sadly, that has brought a total number of deaths of 47,273.

On a more positive note, 194,405 people have so far recovered.

So, it is definitely a case of business, but definitely not business as usual, and there are just a couple of indicators to demonstrate that. Some of you will be familiar with the purchasing manager's composite index where groups of purchasing managers across manufacturing and service sectors say whether they are confident of placing more or fewer orders in the forthcoming month. Any sign above 50 is a sign of growth, anything less than 50 indicates contraction.

In January, at the beginning of the year after the December General Election, the economy showed signs of improving with a score of 52.7. That grew to be stronger in February with a score of 53 and then slumped in March down to 37.6, so demonstrating some real concerns for the UK economy; andnon the investment side we will take the FTSE 250 as a benchmark, a useful indicator of the health of the UK PLC. We can see that it reached a peak just before the crisis of just over 22,000 points and then slumped to 12,000 points before recovering slightly, but nowhere near enough to make up those differences.

So, we can see why some of those indicators are as they are. The Government has issued perhaps the clearest and most comprehensive message to the public seen since the Second World War: to stay home, to safe the NHS and to save lives.

Whole swathes of the UK economy have been closed. All retail (other than essentials), restaurants, pubs, hotels - the whole range that you can see up there. Other sectors are profoundly effected as well. So the obvious ones, transportation and aviation, leisure and tourism, but also ones like construction; whole building sites across the UK are no longer working on construction. It is having an impact across the board.

So we are going to go to the meat of this session, we are looking at furlough job retention. We will be looking at questions that come in and aiming to answer as many as we can at the end of the webinar. We have got a wide range of people on the call: we have got people who are pension purists, people who are trustees, HR managers and people who focus at this more from a pure employment point of view. So a whole wide range of views possible there.

If you put your question with your name, if you do not use the anonymous tab, then even if we do not get to your question in the time that we have, we will pick it up and get someone from the team to get in touch. We are also going to put together a composite Q&A document of common questions and our responses to those afterwards, together with a recording of this session if that is useful for you.

So, over to Richard. Furloughing job retention, what does it mean? How does it work?

Richard: Thanks very much Ian and to reiterate that we understand just how difficult this is at the moment for everybody and we hope that you are all staying safe and well.

So furlough leave, the informal name for the job retention scheme. You will have noticed, or many of you will have noticed that British Airways announced yesterday that they were putting 36,000 of their employees onto furlough leave, which is approximately 80% of their UK-based employees.

Some of you might have been on our employment webinar on Monday but, as Ian has mentioned, we have a range of people on this webinar so we are going to just build up piece by piece. It is extremely important that everyone understands the basics of the job retention scheme (JRS), or furlough leave.

So this is a temporary scheme only, open to all UK employers for at least three months, the Government's current position and it is possible for employers to put employees on furlough leave with effect from 1 March.

Employers can claim up to 80% of furloughed employees' usual wage costs, plus the associated employer NICS and, importantly for our purposes today, minimum automatic enrolment employer pension contributions on that wage; and I emphasise in there the minimum automatic enrolment employer pension contributions.

So that is the very basic position.

The next slide will take us into a bit more of an explanation. So what does it mean and how do employers get their money back?

So the important point to remember is that this is what applies to employees, it does not cover self-employed (there are separate initiatives to deal with that) but it does cover zero hours employees.

This is the basic position at the moment and many of you will understand that this changes currently on a daily, if not hourly, basis, but the Government's aim is to have these payments up and running in time for April payrolls. So that is the current timeline for Her Majesty's Government in setting up all of the new systems to deal with these payments and essentially we are talking about a new relationship for employers who apply to furlough their staff. They will have a new relationship with Her Majesty's Government (it does not exist in that way at the moment) but the employment relationship stays the same.

That is an important point that we all need to understand. The employment relationship stays the same.

So, just looking at a little bit more detail on furloughing and what it consists of. You can get more details through our link which is available below and through the Government link.

There is a risk at the moment with information overload and particularly for those of us who work in the pensions, employment, HR and benefits industry because we are having to keep up with all of the different streams of developments.

So we will now just step into the headlines for pensions and benefits, before we come back to Ian for more pensions specific developments.

So furloughing or JRS. Can we take advantage of this scheme as an employer? Yes, you can, provided you employed these employees with effect from 28 February. So they have to be on your PAYE on 28 February and you can apply for those employees to be on this scheme with effect from 1 March.

What does it mean? Well it means that your employees, who you place or who agree to go on furlough leave, remain as employees but their pay, and potentially their benefits, are adjusted. So they remain in employment and there is no change in their employment status, which again we will come back to. It is an important theme for benefits.

Can you just tell employees they are furloughed? No, you cannot. In the same way, you could not simply say we are cutting your pay by 50% from tomorrow.

So none of these new provisions - and there is no new law yet, we are all working on guidance - or things change the way in which employees need to be dealt with in this situation.

So there will need to be a negotiation process, an agreement process, to put in place furlough agreements and some of you will already have been looking at those and in fact may well have already agreed some, if you are unions or a collective workforce, but you cannot simply tell employees they are furloughed from next week..

Now what about the money that Her Majesty's Government is not reimbursing? Do you have to make up the difference to 100% because you will only be reimbursed for 80%? No you do not, that is an entirely commercial decision for each employer to make.

Next and this is an interesting question. Can we furlough people part-time? That does not mean we are not asking can we furlough part-time people. The question is can we furlough people part-time? So can you furlough someone for 50% of their time? No you cannot. That is the answer. You cannot furlough people part-time, you can furlough part-time people.

Can employees on furlough work for anyone else? Yes, they can work for other employers. This is an employer specific scheme, so provided that they are entirely separate jobs, separate employers, they can continue to work for other employers.

So those are the key basics of this regime and those are the issues. We will keep coming back to them when we are looking at the pensions and benefits aspects.

Ian: Sorry to butt in Richard, one of the things that just made me wonder is if you have a serious reduction in the amount of work that means that you would like to furlough a percentage of your people, is that permitted or does that fall foul of furloughing people part-time? And are there any issues with doing that?

Richard: So you can furlough in and furlough out. It is quite a common question in terms of planning and preparation, for example. Can we furlough one group for two weeks and then furlough another group for a few weeks, because in that way we avoid any issues between those groups? Those who are being paid for not doing work and those who are still having to carry out their work. So, that type of furlough is permitted. What you cannot do is split individuals down the middle and put them on half furlough leave. But, for these purposes they are either working or they are not working and that is the basic position.

Now just before we go back to Ian and some more pensions aspects in-depth, I just wanted to start you thinking about this scheme of other benefits. It is similar in terms of the considerations for pensions benefits though, whether or not your arrangement is through an occupational scheme or separate standalone insured scheme. It is going to be crucial, as it will be for pensions, to check the scheme rules in relation to definitions of earnings, wages, salary, basic pay and to check exactly what they would or would not cover in terms of furlough pay. And in terms of insured arrangements, check what the policy documents cover in terms of the definitions, the single definition and exactly which benefit is insured for these purposes and which level of claim will be insured for these purposes.

So that is again another common theme within our system we will all need to go through. Thanks Ian.

Ian: So headlines for employers. Is furlough leave covered by the absence rule?

Richard: That is important again as an analysis. You need to establish how employees are going to be treated for these purposes and we have already seen some absence rules, which allow employers to dictate exactly how the members are treated for benefit purposes during absence. It is a unilateral power in some cases.

So, is there anything in your absence rules that needs to be checked in terms of furloughing employees?

As I have mentioned on the death in service benefits, insured benefits, how are contributions and pensions paid defined?

We will keep coming back to this point; it is absolutely crucial. What is the basis for the contributions which will pay during a period of furlough leave and is the employer seeking contractual agreement to any changes. Where there are contractual promises of certain contribution rates, for example, then consultation, negotiation will need to be carried out. So, as well as the pensions side analysis, there is the employment contract union side analysis to go through, because again (just to remind you) you cannot simply notify employees that you are putting them on furlough leave because that is not provided for within the current legal regime.

And then, finally of course, when you have reached agreement and you have got clarity on the position on furlough, you need to make sure that on the administration side with the trustees that that has been accurately reflected through the furlough leave period.

So just looking at some more detailed elements of this - and we are getting a lot of questions on this - I am going to roll with these (questions) as I am going. A lot of these questions will be picked up by the slides that we are already covering, so I will carry on now on this piece and keep sending your questions in.

So there is the potential mismatch between the amount which an employer can be reimbursed for and normal pension contributions; and again it is a commercial decision for employers to decide the level at which they are going to continue to make contributions, or to allow earnings to continue during this period.

The Regulator has been clear, The Pensions Regulator has been clear that employer duties under the Pensions Act 2008 - which, for those of you who are not aware, is the Act which covers the automatic enrolment provision - those will all apply as normal; at least for the moment. So it will not be possible, for the moment, for employers to reduce contribution levels below the automatic enrolment minimum contribution rates.

So if you are proposing to reduce rates, which are above these minimums, you will still need to apply the minimum automatic enrolment contribution rates.

And the consultation provision, as I have mentioned previously, pensions consultation on statutory listed changes, which would normally include things like closure of a scheme to accrual, which employers may still be considering, those that still have defined benefit schemes, for example. Also reductions to percentage rates of employment contributions would require a minimum 60-day consultation.

Some of you may be thinking 'well that timeline is just not going to work' and that might be very true. It is possible to apply to the Regulator for a waiver and failing to go through the full 60-day process does not annul the changes, but you should be aware that the Regulator could levy a fine of up to £50,000 per employer.

And finally, employment contracts, which I have mentioned before. Do not forget about them. When introducing furlough provisions you need to have reviewed the actual position so that your collective bodies and your employees are fully engaged when agreeing variations, if that is necessary.

So, I think that is the end of that first section. Over to Ian.

Ian: Yes, so thanks for noting the point about The Pensions Regulator. I am just going to bring everyone up to speed with what The Pensions Regulator has been saying, as recently as information published on Friday.

It is worth pointing out that this is an incredibly interesting subject to so many people. I have personally not been on a webinar with as many people. I think if this was a lecture theatre, I would be decidedly less relaxed about presenting to the number of people and also getting a huge number of questions. So thank you for those. We will be dealing with as many of those as we can and like I said, we will be answering them both offline and in a composite Q&A document for you.

So, let us focus on what The Pensions Regulator has said. First of all, it has had some key messages.

The Pensions Regulator has emphasised that benefits need to be paid. At the moment, things are scary enough for the elderly, they do not need to have the worry that pensions are not going to be paid.  So, that is number one in the list.

Number two, and this is a sad reflection but in times of crisis there will always be some people who will try and make some money out of the confusion, The Pensions Regulator is emphasising the risk of scams; especially when you have individuals who may need to get hold of money as a result of losing jobs, losing income and the potential there for scams is quite high.

The Pensions Regulator has also emphasised that employers need to continue contributing, but we will come onto a slight caveat to that with its latest guidance in a moment.

On the defined contribution money purchase side, The Pensions Regulator says that savers need support to make good decisions in these challenging circumstances and, if you just remember the graph of the FTSE 250 a moment ago, this is an indication of just how challenging the circumstances are. So communications and messages that can be given to people to try and focus on the long-term and not make rash decisions on their DC pension savings.

And finally, The Pensions Regulator is aware that there may be some administrative breaches that occur and that they will be adopting a proportionate and fair approach to any action that they take in relation to those. So, you know, it cannot suspend the statutory regimes, but it can adopt a degree of flexibility.

So, The Pensions Regulator then goes into more detail on each of the areas of what it expects from trustees. One of its main focuses has been around business continuity and some of the trustee attendees on this call will be familiar with having to put in place risk management measures as a board of trustees and business continuity is an important element of that.

Business continuity means looking at people like your third party service providers and making sure that they are able to continue to function, even if they are having to work remotely. But it is also things like how trustees can continue to take decisions and stay in charge of the pension scheme while they are no longer at the moment able to potentially meet in person.

Another key message is on prioritisation. As we mentioned just before, The Pensions Regulator wants trustees to prioritise the payment of pensions and there are a whole series of things that have higher priority, according to The Pensions Regulator (TPR), than some other things; so prioritising retirement, prioritising death in service payments. It might be that the scheme is undergoing certain large projects. It might be sensible for those to be paused while the trustees make sure that those priority tasks can be fulfilled.

Corporate distress? The Pensions Regulator is alive to the issues, especially in certain sectors where perhaps previously with strong looking employers, employers with strong financial employer covenants, suddenly look like their business models have been upended. TPR encourages trustees to get in touch if they think that there is a risk of insolvency or if indeed insolvency is more than a risk, if that is actually going ahead.

Scams we covered briefly, but just to mention that what The Pensions Regulator would like trustees to do is:

• to look at scam smart;
• is to signpost effectively people to the money and pensions service;
• to treat transfer requests with perhaps even a higher degree of caution than it usually would; and just be alive to the risk of scams at the moment; and
• ensure that all of the proper communications and literature (the old style, you know the scorpion style leaflets) has been sent out to members at the right times.

And then on administration - and this is connected to business continuity and prioritisation - ensuring that the administrators, whether that is in-house or third party, are able to continue to administer the scheme. A lot of that comes down to business continuity and making sure that the priority areas are focused on. And then finally, around employers, a message for employers that The Pensions Regulator understands the pressures that are on all employers in the UK economy (and some in particular sectors under unbearable pressures), but to be mindful of the duties that are still owed and to talk to The Pensions Regulator where possible.

Some other impacts of the Coronavirus on The Pensions Regulator has been a postponement of various things like the regulatory initiatives, consultations on changes to the Code of Practice, like the revised DB funding Code of Practice and the long-term TPR strategy launch being postponed. Those are all still going to come back when we get to business as usual but, obviously, no one knows when business as usual will be.

All of these materials, together with information that I am about to come on, is available at a single home page on The Pensions Regulator webpage, which you can visit at tinyurl.com/tprcovid.

So moving on to the next slide, a bit of breaking news. I mean this is pensions, this happened on Friday so as far as we are concerned this is breaking news. We do not operate as a 24 hr news cycle in the way that some areas do, but this is still pretty novel.

The Pensions Regulator published three pieces of guidance; one for trustees focusing on scheme funding and investment; one for employers looking at scheme funding in particular, and then on the DC side looking at investment and transfer values.

Probably the most interesting, certainly the longest of these, is the guidance for trustees on scheme funding and investment and it just puts a lot more detail on the parameters around things like employers asking for a suspension or a reduction in deficit repair contributions; the things trustees need to take into account, if they are considering those sorts of things. Also looking at whether the schemes' risk portfolio, its investment range, remains appropriate, getting advice from investment advisers to look at those aspects and also thinking about whether there has been a material shift in the strength of the employer covenant, such that it might require the trustees to think about taking some action in terms of trying to increase the level of security that is in place.

OK, so that is just bringing you up to speed with where TPR is. Going back to the TPR homepage, worth checking what they issue, they are putting out new stuff certainly on a weekly basis, if not more frequently, so we will keep you up to speed on developments but you can also have a look at that.

And now we are going to go into some of the questions that we have had from all of you.

Just a quick point. There were some initial issues with the sound, for some of you, there is a mixture of issues going on here, obviously we are all operating our IT systems from home and there can be some issues with the speed of broadband which then impacts on this; and it might also be that that is the case at your end as well. So, we are doing everything we can to make sure that you get a clear sound signal. Hopefully, the recording will be fine so, if there are any parts you need to go over, that will be available and there is a Q&A document that will also be available. And if there is anything you would like us to cover, just drop it in one of the questions and we will pick up the phone and go over things.

So, let's focus on the job retention scheme in detail and look at some of these questions.

So the first one Richard, what happens to member status on furlough?

Richard: Thanks Ian, actually just before I dive into this one, just to pick up some of the recurring themes on the Q&As that people are sending in.

Yes, £2,500 a month is still the current cap. There has not been any change to that.

Yes,three weeks is the minimum that furlough leave can apply for.

And number three, sick pay. So sick pay is separate to furlough leave, you cannot be on both at the same time. If you are on sick pay currently you would then go onto furlough pay, they cannot cross over each other.

So, those two or three were just cropping up with a lot of frequency.

Also, salary sacrifice is very popular, and we will come onto that as part of these Q&As.

So member status, I have touched on this, very important to check what rules say when an employer is furloughing their members because we have certainly seen rules already - absence rules, eligibility rules - which would mean there is a change from active to deferred status.

And again, to remind you of the basic positions. There is not a change in the employment status for furlough, but you do need to check your scheme rules because of the importance and in particular in DB, prime benefit world, of triggering section 75 debts, of calculating benefits, in particular at the moment, in relation to early retirement and redundancy benefits.

So, the actual employment status of a furloughed employee does not change, but you do need to check the member status.

Ian: OK what about carrying out consultation during a lockdown?

Richard: Yes thanks Ian. What about it? Well, this has cropped up a lot already. If you are already in a 60-day consultation, for example, then you are absolutely fine to continue and if you are about to launch, which many of you may well be, then that is also acceptable. The key point is that all of the effected members and their representatives have got full and proper access to IT systems and member comms to allow a full and proper consultation, as would be usual.

On the employment side, for those more in the HR side of things on this webinar, generally that is the same for employment terms and variation in terms of changes, potential dismissal of engagements. So those consultation processes, be they 30 or 45-days on collective cases, are still acceptable. There is one minor wrinkle around dismissals and redundancies in terms of individual meetings, but it is possible for an exceptional circumstances application to be made.

So yes, you can carry on consulting during lockdown.

Ian: Right, I am almost nervous to ask this question because whenever you combine TUPE, the Transfer of Undertakings (Protection of Employment) with any subject it gets complicated and I have a feeling this is not going to be an exception.

So what happens to furloughed employees and scheme members who are on a TUPE transfer?

Richard: Yes, thanks Ian, and yes, well, how long have you got? You are not just nervous, because you rehearsed about ten minutes before the webinar started.

So let's move to a basic analysis. It is important any employees who are on an employer's payroll at 28 February can be placed on furlough leave and that can only be effective on 1 March at the earliest. That is important for TUPE.

Second point, again furloughed employees remain employees, OK, of the transferor at the point of transfer, as long as they have not left the business and we consider that they will be assigned to the transfer. So those of you who work on the employment HR side will be used to this, just identifying who is actually going to transfer, the organised group of employees, or if there had been a service provider change. So they will transfer. They are the employees who are transferring to the receiving employer.

Furloughed employees will be assigned to the transfer because, as part of the grant application of that scheme, employers have to confirm that the employees will return to the business. So, that is crucial because otherwise they would not necessarily be assigned to the transfer.

That is the first two points. It just starts to get a little bit more tricky from here.

So, this is difficult. It is not currently clear whether a receiving employer - so a transferring employer will not - whether they will receive funding for employees on furlough leave. In other words, if employees on furlough leave happen to TUPE transfer to you on 15 March, as a receiving employer, it does not as things stand clearly appear that you will be able to receive or continue to receive funding for those furloughed employees, basically because you did not employee them on 28 February.

The immediate thought around this is, how any employer is going to take a number of furloughed employees when they will not be funded. So, at present, that seems to indicate that employers might then have to look at redundancies, for example.

My understanding is that this is a point that is still being questioned with the Government, but at present - and if anyone does have information on that, very happy to listen to you or just send us in a note - that is a difficult area at the moment.

And then four, I suppose back to the world as we used to know it, so the usual TUPE transfers in terms of pensions and also the additional regulations we put on the slide, the TEP Regulations, so the pension protection provisions. So TUPE clearly does not apply to benefits which are old age, invalidity or ill health. So, they will only apply to transfer early retirement, redundancy benefits, for example; otherwise known as Beckmann and Martin benefits. But they would transfer, for example, contractual entitlements to a certain level of contribution into a GPP, for example.

You then have to analyse at the TUPE transfer the impact of the TEP provisions so, to the extent that transferring employees are active members in occupational schemes, then the receiving employer has to make a minimum provision after transfer. That is the usual position, ignoring furlough leave.

Clearly then you add in furlough leave and you have to analyse the earnings basis for benefit calculations. So defined benefit actives or furlough employees becomes a third but which is the final salary, which would be the calculation basis that needs consideration.

And finally, as if we all needed a fifth point on TUPE, there could be redundancies clearly in the current environment after furloughing comes to an end. So employers will need to be considering the scheme provisions on redundancy benefits over employment benefits, which generally clearly are enhanced and expensive, and also again managing the section 75 risk because there is so much going on in terms of employees at the moment, it would be fairly easy to accidentally trigger a section 75 debt and if employees are moving between normal employment to furloughing and to redundancy, for example. So somebody within your organisations needs to carefully manage this movement of active members.

And finally, just to mention as I flagged earlier, Beckmann and Martin benefits, which are those benefits which are pensions benefits that do transfer on TUPE and relate to, broadly speaking, early retirement benefits and redundancy benefits.

So, hopefully, that has picked up some of the TUPE interactions with furlough but do send in more questions if you have them.

Ian: I think, yes, onto the next one.

So salary sacrifice; and I have already had my own personal question about a gym membership on salary sacrifice answered by you Richard, so thanks for that. But for everyone else, how does salary sacrifice interact with the scheme? So for example, will the reimbursement of 80% of salary be on the basis of the pre-sacrifice or the post-sacrifice salary?

Richard: So as we have laid out, we are looking at the amount which an employee is entitled to, so looking at the reimbursement based on the post-sacrifice salary. Employees agree to salary sacrifice based on a percentage deduction usually, or sometimes a flat rate amount so £50 per a week, £100 per week, even in the pensions world. Some employers will give employees a choice.

Now again, moving onto the contractual side, and depending on what other flex arrangements employers might have in place, there may be a need to vary these salary sacrifice arrangements because if employees are dropping in their level of pay but the salary sacrifice amounts stay the same, whether that be £100 or £500 for example a month, then that would seem to be a disproportionate increase in the level of the sacrifice compared to the pay.

So, that is the first point on salary sacrifice.

Ian: So another couple of questions, what about salary sacrifice pension contributions? Should gross pay be reduced for any salary sacrifice benefits including pensions?

Richard: Yes, so the amount of gross pay is the amount payable after salary sacrifice. Sorry, I was enjoying the little Q&A session.

Ian: I was just going to say what can the employer claim on salary sacrifice pension contributions as a normal pension contribution.

Richard: So we have touched on this previously, HMRC is only paying auto-enrolment employer contributions on qualifying earnings so those are the band earnings, up to the statutory minimum of 3%. So, the qualifying earnings would be in the lower threshold and the upper threshold.

Ian: OK. And we've got one final question on salary sacrifice, and one rogue question that will actually be dealt with on the next slide; it wasn't about salary sacrifice. So the salary sacrifice one, should employers use the post or pre-salary sacrifice amount in their claim to HMRC?

Richard: Yes, so, sorry I've just seen another salary sacrifice question coming in actually.

So, the salary on which they are basing the claim to HMRC. Employers, as we have put on the slide, should use the lower post-salary sacrifice amount because that is the amount of salary to which employees are legally entitled.

Ian: OK. And so, as if by magic and repeated, a question specifically about trustees and furlough. So obviously a lot of trustees, either individual trustees or directors of trustee companies, who are also employees of the sponsor. What happens about those trustees who have been furloughed from their employment?

Richard: So we do think it is acceptable for furloughed trustees, be they on the member or employer side, to continue with their trustee role, and this is basically because it is entirely separate from their employment role and because they are not usually paid for a trustee role. So, it simply would not fall within the regime and they could continue to do their role.

There are some tweaks obviously around who pays them if they are paid, if the scheme pays or if the employer pays. But our view is that trustees who have been furloughed can continue to carry out their trustee duties and they are going to be very sought after at this difficult time, is our experience.

Ian: Yes. So one final question, we are just at time, and I think we will run over just by a couple of minutes if you bear with us.

Uninsured benefits, on life assurance and permanent health insurance. How will life insurance work? So if someone dies while they are on furlough leave, what will the insurer pay out? Presumably the question being is it the 80% or the 100%?

Richard: Yes again so as we touched on previously, go to the definitions, wherever they sit within the documents, and including the policy documents to see what is covered. We think that insurers are looking closely at their own contracts to establish exactly what they have permitted to pay in these types of circumstances and also, I am sure, some of you on this call have already been involved in discussions about force majeure in contracts. In other words, whether actually current circumstances could allow for a fulfilment of commercial contracts.

So I think that sort of finishes off those, that set of Q&As. Clearly, we have now had over nearly 70 questions coming in.

We unfortunately do not have the time to answer all of those now but we certainly will be doing so, and do continue to send them in.

Ian: It is quite remarkable because sometimes we have done webinars where we have to plant questions, but we have certainly not had to do that here. So what we are going to do is make sure that, if you have left your name and we can contact you, we will be able to get in contact with you and,for everyone who is on the call as well as having a recording of the webinar, we will be able to put together some of the more common themes of the Q&As. And if you cannot wait until then, we do have a range of material that you might find useful.

There is a very detailed employment insight, so this is from our Employment team, which is available to read. The webinar that they put out earlier in the week will also soon be available as a recording.

Read our pensions insight, which focuses on The Pension Regulator's approach in a bit more detail.

We also have a trustee checklist which is quite a handy high-level set of things for trustees to think about, given that there are so many things to think about. It can be quite useful to have those set out as a checklist.

And then finally, from across the firm, we have experts who have put their thoughts together in a COVID‑19 guide. It covers some fantastic stuff, so we have done pensions, employee benefits and employment today but if you are thinking about contracts, force majeure, other areas, banking and insurance, then please do go and download and share that guide.

So, that is all from me and Richard. Just before we do say goodbye, I would just like to make one plug.

We have just launched a new regular pensions podcast called The Month in Pensions, so if any of you are wanting more audio entertainment in the pensions world, and you have not got completely tired of my voice, then if you search in your usual podcast provider for The Month in Pensions you will be able to download the March edition and subscribe to get up-to-date with what is happening in pensions in under half an hour; which is not a bad deal as far as I am concerned.

So thanks everyone for joining us, thank you Richard for your time.

Richard: Thank you Ian.

Ian: Thank you for all the questions, like we say we will be getting back on all of those and so from both of us, and from the Pensions team at Gowling WLG, thanks for joining us and goodbye.

Richard: Thank you.

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