Justice 1 Committee, 05 Jun 2001

Meeting date: Tuesday, June 5, 2001

Official Report 211KB pdf

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Regulation of the Legal Profession Inquiry

We are taking evidence today from Linda Costelloe Baker, who is the Scottish legal services ombudsman, and Anne Millan, who is a complaints investigator. Does Linda Costelloe Baker wish to make any opening remarks?

No, convener, I do not.

Thank you. First, I shall ask you a fairly general question. What would you say is the most important element of your work? Has it changed since the office was first established?

This month is a rather important anniversary because the position of ombudsman came into being 10 years ago. The most important element of the work is the same now as it was then: the perception of the ombudsman's independence from the legal professions. That was important to complainants 10 years ago and remains so now.

As the committee may know, the Law Reform (Miscellaneous Provisions) (Scotland) Act 1990 states that I cannot be a lawyer. I have never worked in the legal professions, which means that people can be assured of my independence.

We share something, in that I am not a lawyer either.

The service was presumably set up in response to pressure from the public, who felt that they needed such a body. Has the service successfully addressed whatever public concern caused the ombudsman's office to be set up?

In part. The ombudsman's post grew out of the lay observer's post rather than being a fresh and new idea. In 10 years, the ombudsman has been quite effective in improving the way in which the legal professions deal with complaints. To that extent, the post has been a success—changes would not have happened without pressure from the public and my predecessors. However, the public are still concerned that they do not have a formal right of appeal to the ombudsman. I cannot overturn decisions that have been made by the professional bodies and I cannot make decisions about what should happen; I can make only recommendations.

Is your work entirely concerned with individual complaints that come to your office or are there other elements?

It is mostly concerned with complaints that come to the office. Between 300 and 400 people contact the office every year. A relatively small proportion of them are people whom I can actively help by preparing an ombudsman's opinion. Many of the people who contact the office do so with a wide range of complaints about bodies in the legal and justice world that are outside my remit, such as judges, sheriffs, procurators fiscal and the police. We get a few general consumer complaints—for some reason, I am thought to have magic powers in relation to public transport and I get quite a lot of complaints asking me to put the buses right. There is a serious side to that: it shows how important the concept of the ombudsman is to consumers; they perceive an ombudsman as someone who can put things right.

I can prepare a formal opinion on only about 120 complaints a year—those that are about the way in which one of the legal services professional bodies has handled a complaint against a lawyer. Of the complaints that I cannot deal with, the largest proportion are direct complaints about a lawyer. I have to refer those to the professional body.

Other than your dealings with the professional bodies, the discipline tribunal and others in relation to individual cases, do you have general meetings to highlight problems that arise in certain areas?

I have quarterly meetings with the Law Society of Scotland—with the director of the client relations office, the deputy director and the convener of the client care committee. They are relatively formal meetings with an agenda at which we discuss issues of mutual interest. The Law Society might want to discuss changes to how it deals with complaints or difficulties that it is having in its office and I might raise general issues that have arisen from the complaints that I have received. Similarly, I have about three meetings a year with the dean of the Faculty of Advocates. I have also had two meetings with the Scottish Conveyancing and Executry Services Board on general policy issues and general practice.

This may be difficult for you to answer, as you have not been in post for 10 years, but do you think that the general approach of the legal profession has changed as a result of the existence of the ombudsman?

Undoubtedly. I would like to think that it has changed as a result of the work of my predecessor; I am fairly certain that it has. In his final annual report, which was published last year, my immediate predecessor, Gerry Watson, highlighted the areas in which significant change had been effected during his six years in office.

For example, in 1994 and 1997, Mr Watson recommended that the Law Society establish a telephone helpline so that people could access the Law Society easily for advice on how to make a complaint. The Law Society rejected that recommendation in 1994 and 1997, but the helpline came into being in September 1999. It has received more than 7,000 calls a year and is enormously effective. I have met the qualified solicitor who answers the phone and I am very impressed by the service. It uses a lo-call number, so anyone in Scotland can ring it for the price of a local phone call. Very few of the phone calls—only about a third of them—concern complaints, but the helpline would not have been set up if the ombudsman had not told the Law Society that it needed to be more accessible, so that people could contact it more easily.

Do the figures in the annual report reflect changes in the work that is carried out by the ombudsman and in the demand on the ombudsman?

There is no trend. Over the 10 years, the number of complaints has gone up and down and up again. The average is 120 complaints a year that are within the ombudsman's remit to investigate. Over the past 12 months, there have been 117 complaints.

Bang on target. You have spoken about complaints coming to your office. What does your office consist of? What resources do you have to do the job?

At the moment, there are just two of us. I am employed as ombudsman part time—four days a week—and I have two full-time complaints investigators, of whom Anne Millan is one. The other complaints investigator left earlier in the year and his replacement will not start until next week, so we have had only half our staff complement for five months. I also have an office secretary who works four part-days a week. We are quite a small team.

Is not having a legal background a disadvantage?

No. The ombudsman is the only truly independent person in the whole complaints process. If I lost that independence, I would lose a lot of the confidence that consumers have in the ombudsman. I am reasonably familiar with law and the legal process from things that I have done previously in my professional life, but it is important that the ombudsman is not a lawyer.

Do your complaints investigators have legal expertise?

One has; one has not. Anne Millan's background is in citizens advice bureaux, but the other complaints investigator has a legal background. The balance is good.

The annual report provides information on turnaround times. What is your opinion of the turnaround times?

They were very bad, but they are fine now. The turnaround time increased over two or three years. Because our office is small, it became difficult to put things right once the waiting list began to grow.

Until 1999, there was only one complaints investigator—the second was appointed that year. When I took up appointment in the middle of last year, I made it an absolute priority for the first six months to focus on doing something about the turnaround times. That was extremely hard work, but the commitment I gave to everyone who was waiting was that we would complete an opinion on their complaint by the end of the year. Over five months, we got the waiting time down to six months. To illustrate the current position, the opinion that I put in the post at the end of last week had been made to me 11 weeks before. I think that is reasonable. My aim now is that the turnaround time should vary between three and 13 weeks, depending on the complexity of the case.

The majority of cases used to take more than a year to clear up. Given the fact that a lot of the original complaints were about the length of time that it took lawyers to clear things up, I suspect that that delay confirmed the complainants' problem with the legal position. You are saying that that state of affairs has improved and that turnaround times have been cut by quite a few months—even nine months.

We have taken a year out of the waiting time.

Has the fact that you have been a person short for five months affected that? It must have done.

It made it very difficult, but we were determined to provide a good service.

Can you say why it took five months to recruit a new member of staff?

We have some administrative links with the Scottish Executive justice department, which provides some services. Given that I am a statutory post holder, there have been real efforts on both sides to ensure that there is clear, blue water between us. One of the services that the Executive provides is help with recruitment. I ought to be tactful about this, but I perhaps will not be able to be.

I think that we would rather just have the truth.

The Scottish Executive's personnel division is used to dealing with the recruitment of a large number of people, perhaps once a year; it is not used to the fact that a small office that loses half its staff needs a rather more urgent approach. It has been difficult.

Is the new person now in post?

They will start on Monday.

I declare that my husband is a solicitor and a former member of the council of the Law Society of Scotland.

On statistics, a percentage-based breakdown of the nature of the criticisms of the Law Society that were handled by the ombudsman over the past four years has been provided. Those criticisms include inadequate consideration, delay and administrative failing, inadequate investigation and inadequate explanation. Will you expand on those, so that we can tease out the difference between, for example, inadequate consideration and inadequate investigation? What types of situation might fall into those categories? Are the same criticisms reflected in the complaints about other professional bodies that are handled by the ombudsman?

Inadequate investigation applies to cases in which the Law Society had not gathered enough evidence. I cannot and should not discuss individual complaints, but I can give examples that will illustrate the differences in general terms, which would be more useful.

One complaint involved another institution. The solicitor's file included very little evidence, and my view was that the Law Society—it was a Law Society complaint—could have and should have obtained information from that other institution, which would have filled the gaps in the solicitor's file. That recommendation was accepted. I would classify such criticisms as inadequate investigation.

Inadequate consideration refers to cases in which the Law Society's reporter, committee or council—since January last year, all complaints have had to go to the council—has not properly studied and considered the complaint that has been made. That is a fairly common reason for saying that a matter needs to be reconsidered.

It is rather too easy for the complainant's original complaint to get lost as it wends its way through some lengthy and rather complex processes.

A particular difficulty applies to complaints that are made to any of the three legal services professional bodies, because their complaints systems are based on disciplinary measures and not on dealing with complaints. The complaint made in commonsense, ordinary English has to be broken up and translated into a list of alleged disciplinary failings. Members can probably imagine that complaints can get lost in the gap. If the complaint made by the client does not survive the process and the committee and the council do not examine the complaint that was made, we would classify that as inadequate consideration and we would say, "Go back and look at the complaint that was originally made."

Are you saying that, if it were not possible to translate a complaint into a sort of disciplinary jargon, that complaint would be disregarded?

It can be. Over the past year, I have noticed that an increasing proportion of complaints that come to my office are cases that the Law Society has refused to investigate. In its annual report this year or last year, the Law Society said that it could not investigate more than 1,100 of the complaints that it had received. If the Law Society refuses to investigate, the person can complain to the ombudsman. I look to see whether, in the circumstances, the Law Society's decision was fair and reasonable.

Does the Law Society give a reason why it will not investigate?

Yes.

What sorts of reasons are given?

If someone makes a complaint about a sheriff who happened to have been a solicitor, the Law Society will not investigate a complaint about him or her. If someone makes a complaint about a chairman of a tribunal who happens to be a solicitor, the Law Society will not investigate the way in which he acted as chairman of the tribunal. Both those reasons are fair and reasonable. The cases that cause more concern are complaints about someone else's solicitor, as the Law Society is reluctant to investigate those cases.

Sorry, did you say someone else's solicitor?

Yes. In a divorce, if someone is not happy with the way in which their ex-partner's solicitor is conducting matters, the Law Society will in general not take that on as a complaint. If someone complains about the advice or professional judgment of their solicitor or advocate, the professional bodies—the Faculty of Advocates' procedure is the same as the Law Society's—will say that that is not something that they can second-guess and they will not accept the complaint.

Thank you. That was very interesting.

Does that mean that a large proportion of the advice and assistance work for which lawyers receive legal aid cannot be the subject of a complaint?

Yes.

The convener's question covered part of my next question, which is about the detailed reasons why cases handled by the ombudsman are deemed to be ineligible for investigation. Those reasons are listed as: "Outwith remit"; "Law Society/Faculty not involved"; "Law Society/Faculty not finished"; "Time-barred"; "No identifiable concern"; "Withdrawn/deceased"; and "Legislative bar".

You talked about cases that were "Outwith remit" when you said that you cannot deal with indirect complaints or the decisions of sheriffs or judges. Are other areas outwith the ombudsman's remit? I am also interested in time-barred cases. What is the length of the time bar?

It is six months—the person has to make a complaint to the ombudsman within six months of receiving the decision from the professional body. The time bar was set in the 1993 general directions to the ombudsman by the then secretary of state. That is being reviewed as part of an internal policy and practice review. We are actively considering whether, in my next annual report in a year's time, we should recommend a reduction in that period. We think that there are strong arguments for doing that.

It is hard for people to get their act together in such a short period.

I would make it shorter. However, before I make a recommendation, I would like people to let me know what they think.

Complaints to the ombudsman are unusual in having a firm starting point. A letter from the professional body is issued giving the decision and notifying people that they can complain to the ombudsman. Because there is such a clear starting point, a period of less than six months might be appropriate.

How long does the Law Society or the Faculty of Advocates have to finish dealing with a complaint before you intervene?

I can intervene while a professional body is still investigating on two grounds: if I think the investigation is taking too long or if I think my investigation is justified. The second is a catch-all provision, but I have to explain my reasoning.

We are now up to date and our turnaround time is pretty good, so I am more able than I was to take on complaints where the professional body is still investigating. If someone writes to me to say that one of the professional bodies is taking too long to deal with a complaint—recently I was informed that a body had taken three months to reply to a letter—I can deal with that without issuing a formal opinion. I can write to the professional body to say that Mr Morgan has expressed concerns to me in a letter and to ask them to respond to those concerns. That usually works.

Your report tells us how long you take to deal with a case once you have started to investigate it. Do you have any idea how long the Law Society takes to deal with cases?

I have been in post for 11 months and considered around 180 cases. The longest investigation that I have come across involved just less than four years of almost continuous investigation. If either the complainant or the solicitor initiates a legal action relating to the complaint, the Law Society stops its investigation until that has been completed. The four-year investigation to which I refer did not involve concurrent legal action, although it was an extreme case.

We have a good computer-based information system on complaints, which was introduced a year ago. One piece of information that we note is the amount of time that the professional body takes to deal with a complaint. The last two opinions that I filed related to investigations that took 122 and 121 weeks to conclude. Both involved the Law Society. That is not atypical. We would be surprised if a case were dealt with in less than a year.

I assume that you think the professional bodies take too long to complete their investigations.

Yes.

What sort of target would you set them?

A reasonable complaint investigation should take no longer than six months. At the moment, because the Law Society cannot delegate its powers and complaints have to be dealt with in committee, I would be prepared to allow another couple of months as a temporary measure.

Investigations can involve consideration of the same information time and again, with letters being cross-copied to the complainant and the solicitor concerned for further comment. That is a damaging process. Although it is my responsibility to examine the process from the complainant's point of view—and we try to step into their shoes—I also think that it is damaging for the profession. The complaints procedures of the Faculty of Advocates do not take as long, but it is not fair for a solicitor to have an investigation hanging over them for one, two or three years. The Law Society has a responsibility to solicitors as well as to complainants. It is unhealthy for investigations to go on for so long.

On the process by which the ombudsman seeks to resolve complaints, are there differences in practice, depending upon which professional body is involved?

No. Practice is similar across the board. Recently, we have tried to be more open and accessible to complainants. We want to give the feeling that we have an open door. If anyone wants to see us as part of their complaint investigation, they are very welcome to come. We have to tread a fairly careful line and not make it look as though they must come to see us, because we cannot pay expenses and we should not make people from the Western Isles, for example, feel that they are disadvantaged because they cannot visit us. However, we will talk by telephone and we will telephone back so that we meet the cost of the bill. As far as possible, we will deal with any queries and let people know that they are welcome to contact us.

When we accept a complaint for investigation, we send for the professional body's file. There is no difficulty in securing a file quickly, although there used to be a number of years ago. The typical Faculty of Advocates file is about half an inch thick and the typical Law Society file is about two inches thick. Occasionally, the file is bigger and there is a crate of associated files. We examine anything sent by the complainant. That can arrive in cardboard boxes or suitcases or it can be one letter in an envelope.

We go through the complaint investigation step by step in considerable detail. I do not know whether any member of the committee has seen an opinion provided by a constituent? It specifies the date on which the complainant wrote to the professional body and what they said. We summarise their letter and what and when the case manager replied. We summarise almost every piece of correspondence and report in the file.

When we have finished that stage, we consider the complaint that was made to the ombudsman. That is useful because it means that we can focus on the points that matter to the complainant. We then assess the adequacy of the complaint investigation under two headings. Under one heading, we consider how the complaint was managed. Were letters replied to promptly, for example? Were concerns addressed? Did the complainant get a response to those concerns? Were there avoidable delays in the process? Did everything happen as it should have done? That is a management assessment.

Under the second heading, we consider whether the complaints, as made and agreed, survived the process. Were they properly considered? Were they considered at each stage of the investigation? Were full and adequate reasons given for the recommendations and decisions that were made?

My opinions and recommendations are the shortest and final part of the report. The size of the whole report is typically between 20 and 30 pages, with 1.5 line spacing so that it is easy to read.

We have considered methodology because the process is time-consuming and detailed, particularly if a backlog has built up. We have considered whether it is possible to summarise and shorten some things. From an analysis of letters of thanks, we decided not to do so. The letters of thanks have a theme. They thank us for the care, attention and detail, for helping people to understand, for showing that we read everything and for following arguments. That is so important to people that it is worth showing how we have worked rather than simply producing the answer.

I agree. People want to ensure that their case has been fully considered and that must be shown.

You also publicise cases. I presume that you do so if you feel that your recommendations have not been followed. Can you give examples of circumstances in which you would do so?

Yes. Somebody complained to the Law Society. The Law Society refused to investigate the complaint on the ground that, under the Solicitors (Scotland) Act 1980, the person did not have an interest to complain. The person then complained to me that they thought that that decision was unfair and inappropriate. I agreed with the complainant. In my opinion, the complainant had an interest to complain and there were matters that the Law Society is required by law to investigate. The Law Society refused to do so.

That was a particularly serious refusal to follow an ombudsman's recommendation. I notified the Law Society that I intended to publicise the refusal and sent it a draft copy of the announcement that was going to be put in the four principal Scottish newspapers. With 48 hours to go, the Law Society said that it would make further inquiries and, with a little more pressure from me, has now started a formal investigation.

Is that the one and only time that you have threatened to publicise a case?

There is another case at the moment. The final decision has not yet been made.

Do you think that publicising a case is a way of getting the Law Society to change its mind?

In the case that I mentioned, I felt strongly about the complaint and believed that it should be investigated. On other occasions when the Law Society has refused to accept a recommendation, the cases have not been as black and white as that.

We assess recommendations for compensation against the amount of avoidable delay or mismanagement. Sometimes, the Law Society does not accept my view of that and there can be some negotiation. The Law Society or the Faculty of Advocates might pay part of the compensation but not all of it. In those circumstances, I would not normally publicise the refusal. The refusal is not sufficiently important, as it does not mean that an entire recommendation has been overturned.

So publicising a refusal is a strategy of last resort.

Yes, I think so. The potential publicity clearly matters. It is the only sanction that I have; it is the only thing that I can do. Everything else has to be a recommendation. As it is the only sanction that I have, it has to be managed carefully.

The relationship with the professional bodies also has to be managed carefully because it is based on persuasion, convincing arguments and sound work. I have to be bomb-proof in my opinions, because I can only make recommendations. Those recommendations have to be soundly made and well supported by arguments. That is a good discipline.

You also have power to refer solicitors to the Scottish solicitors discipline tribunal. Has that power been used and, if so, how often, not just over your tenure, but since the office was set up?

As far as I am aware, it has never been used. We have examined the power as a fundamental part of the policy and practice review. I think that we have identified some circumstances in which it might be appropriate to use that power, but in many ways it does not sit comfortably. My understanding is that anyone can refer a case to the Scottish solicitors discipline tribunal; but it is included as one of the ombudsman's powers.

I would have concerns about using the power at the moment because of some implications under the European convention on human rights. If it was used at the end of a long complaints investigation by the Law Society, there might have been a prosecution before the tribunal. I would then have some concerns about whether it would be ECHR-compliant for someone to reprosecute. The fact that the power has not been tested means that the difficulties have not been brought to light.

Is it also the fact that, by their nature, complaints would often not be susceptible to discipline anyway—if, for example, the complaint is about advice or judgment?

The principal type of complaint that can go to the discipline tribunal is one about an individual solicitor's conduct. Probably about a quarter of the complaints that we receive are about conduct rather than service. Complaints about service are dealt with entirely within the Law Society.

There are circumstances in which we could refer a case to the discipline tribunal, such as one involving a solicitor acting where they had a conflict of interest. If the Law Society had not identified the conflict of interest and we had, and if the Law Society refused to reopen the case, that might lead to a chain of events in which I might consider it appropriate to make the referral. We have examined that. As far as I know, such a referral has not been made in the 10 years of our existence.

Looking at the previous annual report, we see that three recommendations were made to the Faculty of Advocates. One was that correspondence should be exchanged. That was rejected because the

"present system does not require any change".

The second recommendation was:

"Complaints should be determined by Committee with lay membership."

That was rejected because

"members have confidence in … the Office of the Dean and would not readily accept involvement of other members".

The third recommendation was:

"Complaints should be determined by Committee with not less than 2 lay members."

That recommendation was made in 1996. The response was that a wide-ranging review was being undertaken.

Out of three recommendations, two were rejected and one was kicked into the long grass. The response seems almost arrogant; the faculty seems to indicate that it believes that its procedures are fine and that there is no point in telling it that it is wrong. Is that the feeling you get when you make recommendations to the Faculty of Advocates?

We deal with very few complaints about the Faculty of Advocates. It gets about 20 complaints a year.

Why is that?

There are three reasons. First, compared with solicitors, there are relatively few advocates: there are 8,500 solicitors in Scotland and 400 advocates. Secondly, advocates' contact with a client is over a much shorter period than solicitors' contact with a client. Thirdly, the advocate works directly to the solicitor, so the relationship is between the solicitor and the advocate rather than directly between the advocate and the client. That removes one of the possibilities for complaints to be made.

Having said that—and I hope that the dean of the Faculty of Advocates will not mind my quoting him—at a meeting that I had with the dean at the end of last year, I asked him straightforwardly where the ombudsman fits in to the Faculty of Advocates' complaints procedures. After some thought, his reply was that I help him to understand the points of view of clients and members of the public. There has been a realisation that clients and members of the public might see things differently from a close-knit professional body such as the faculty.

I have suggested that, as part of the initial response to a complaint, the faculty should provide an information sheet to explain who deals with the complaint, the time scale and the process. That has been readily accepted. The more fundamental changes to which the convener referred are in the pipeline, but it is a slow process.

For clarification, does the advocate act directly for the client? Does he have a contractual or pseudo-contractual relationship with the client, or is his relationship with the solicitor?

Remember that I cannot be a lawyer, so this should not be interpreted as legal advice or opinion. The advocate certainly has a duty of care to the client, but the contract—in terms of who pays—is, I think, with the contracting solicitor. Is that right?

It is a difficult matter of interpretation. It could be said that, because in the end the client pays the advocate via the solicitor, there is a sub-contract with the client. It is a rather fudged area of case law. It is under review and decisions are being reconsidered.

Who is reviewing it?

The Faculty of Advocates.

Can a solicitor complain to you about an advocate?

Yes.

Has that happened?

An advocate has complained about a solicitor, so it has happened the other way round. The complaint was not directly about the legal practitioner, but about the way that the body dealt with a complaint. Therefore, a solicitor who complained about an advocate to the Faculty of Advocates and was unhappy with the way in which the faculty responded would be entitled to complain to me.

Our inquiry is into regulation of the legal profession which, excepting you, is characterised as self-regulation. My question is general—do you think that self-regulation is the best method of regulation?

It is important to recognise that complaint handling is only a small part of regulation and self-regulation. However, it is the public face and the bit that matters to the public and to clients. It is also the bit that it is my job to do something about. I will talk about complaint handling, rather than regulation, because broader regulation is outwith my remit.

Improvements have taken place in the past 10 years, but I am concerned that some fundamental issues that were around 10 years ago are still around today. A complaints system that is based on disciplinary sanctions by a professional body has problems. Consumers are concerned about a process that is so in-house.

I will make a broad statement about whether I have confidence in self-regulation. Self-regulation is fine, in principle, as long as consumers are confident that it works. I have doubts about whether legal services consumers are satisfied with the present regime.

On a wider trade and professional basis, a move is being made nationally to increase the amount of self-regulation. The Cabinet Office's better regulation task force makes strong recommendations that self-regulation is the best way forward. I identify two broad areas where self-regulation must be treated with care. One is the police and the other is the legal professions. I will explain why.

In any other trade or profession, if someone has a problem, a dispute, or alleges that poor service has been provided, they can approach a lawyer who will act on their behalf and on their side. That person will feel supported by the law and legal argument. If someone has concerns about the legal service that they have received, there is no escape from legal services, legal culture, courts and the law. People feel that the same independence and impartiality does not exist and that lawyers are not totally on their side. Self-regulation maybe is the right move, but for legal services complaints, extra measures are required to win consumer confidence.

Are you saying that it is a matter of public perception rather than reality?

It can be. No matter how good investigations are, people can feel that a lawyer will not act against a lawyer; if they go to court to take legal action, the judge will be a lawyer. Many people are concerned that legislation is made by Parliaments, many members of which are lawyers. The lack of faith goes deep—not with everyone, but with many people.

Have you discussed with the Executive the research report that the central research unit of the Executive published last year? Is that an on-going matter?

The discussions were principally with my predecessor, because the report was published before I took up my appointment, but I know that we focused on some of the consumer concerns that were raised. We removed the waiting list, because that was a concern, and we improved the amount of information and the way in which we give people information. We hope that we give information in a plain English, frequently-asked-questions style, which people find easier to absorb. We dealt with the two problems that were identified with my office. The other cause for concern was the limits on the ombudsman's remit.

Indeed.

That is more your concern than mine.

Yes, and it would have to be addressed either by the profession giving way or through legislation.

Because we moved office in December and we are about to have a new website, we have not wanted to reprint the leaflets, so we have produced a rather inelegant temporary leaflet, copies of which I will leave for members. Within a month or so it should look more professional, although the content will be the same.

Unless committee members have any more questions, I thank you for your evidence. It has been a very helpful start.

Thank you. As I said to the clerk, my annual report is due for publication at the beginning of July. All MSPs will receive copies of it. If members would like to ask me any questions on the report once it is published, I would be pleased to accept an invitation to come back.