Legal Watch: Health & Safety August 2014 Issue: 003
Introduction Where to now for health and safety in the light of the amendment to the Health & Safety at Work Act brought about by section 69 of the Enterprise and Reform Act in October 2013? It is still too early to analyse the full effects of this clause and whether it has stopped the march of the “health and safety gone mad” brigade. Health and safety remains of critical importance to any business – ensuring that there is a responsible approach to safe working practices. Nevertheless, there is a lingering concern that health and safety requirements have been transposed from the work environment to volunteer activity and there is perhaps a real question mark as to what extent health and safety laws apply/should apply to activities undertaken in the spare time, or voluntarily.
In This Issue: • Introduction • Health & Safety at Work Act over 40 years • Greenwoods and Plexus Law successes • Round-up of cases dealt with • Round-up of other developments • Round-up of significant fines over the last three months • The combining of the resources of Plexus and Greenwoods’ Health and Safety teams
Health & Safety at Work Act over 40 years The Health and Safety at Work etc. Act 1974 – 40 years on
HSWA also created the Health and Safety Executive
This is a summary of an article previously published in the
merged in 2008. The HSE continues to enforce HSWA and
Solicitors Journal.
its regulations. The HSE issues Codes of Practice, which
At aged 40 the Health and Safety at Work etc. Act 1974
provide industry guidance on compliance with specific
(HSWA) remains the cornerstone of UK health and safety
regulations and compiles statistics recording, amongst
regulation, despite the rapid development of new industries
other things, the number of fatalities, injuries and dangerous
and spectacular advances in technology.
occurrences reported by duty holders annually.
Historically, health and safety regulation in Britain had
HSWA has been the subject of significant legal argument in
been prescriptive and industry-specific. Inconsistencies
the Higher Courts, hardly surprising considering its broad,
developed, there was no requirement for employee
goal-based approach and a non-prescriptive model of
participation and some industries escaped regulation
regulation.
altogether. By the 1960s, the need for a new approach to
The general duties imposed upon employers are not
tackle fundamental issues of workplace safety had been
strict. They are qualified by a reasonable practicability test
recognised by trade unions and government.
determined by factors, including the nature and extent of
HSWA provides general principles for the management of
the risk. Once the prosecution has established, beyond
health and safety at work. Its provisions and the duties it
a reasonable doubt, that an employee or non-employee
creates for employers and others are less prescriptive than
has been exposed to risk, the burden of proof shifts to the
preceding legislation. They are more goal-based, adopting
defendant to establish that, on the balance of probability, it
principles of self-regulation by industry.
has taken all reasonably practical steps to control that risk
Employers must ensure, so far as is reasonably practicable, the health and safety of employees and others, including the general public, who may be affected by work being carried out. The provisions are widely drafted and capture employers throughout industry and commerce. HSWA also enables the creation of further regulations dealing with specific areas of work and risk. This has become the principal means for compliance with the European Health and Safety Framework Directive 89/391 EEC. The Framework Directive resulted in the creation of the so-called “six pack” of regulations, which impose strict duties upon employers concerning the use and maintenance of work equipment, manual handling and the assessment of risks associated with work.
(HSE) and the Health and Safety Commission, to oversee and enforce health and safety in the UK. These bodies
(section 40). In Davies v HSE 2002, the Court of Appeal held that the requirement to prove all reasonably practical steps had been taken and the reversal of the burden of proof were compliant with ECHR Article 6(2) and did not interfere with the presumption of innocence. The Court of Appeal noted that the reverse burden applied to regulatory offences and not criminal offences punishable by imprisonment. The European Commission challenged the reasonable practicability qualification, arguing it was not compatible with its Framework Directive, which allows member states to incorporate a defence where an occurrence was due to unusual and unforeseen circumstances beyond the control of an employer. The European Court of Justice found that the provisions of HSWA and, specifically, the reasonable practicability qualification did comply with the directive (Commission v UK 2007 – Case C127/05).
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Today government is focussed on deregulation and reducing burdens upon business. Following several reports, including those of Lord Young and Professor Löfsted, and the
Leisure and the Health & Safety At Work, etc Act 1974
launch of its own red tape challenge, the government has
The Health & Safety Executive has recently launched a
committed to streamlining the health and safety framework.
campaign to highlight the extent to which health & safety law
Nonetheless, HSWA has escaped serious censure and is
applies to volunteer organisations, such as sports clubs and
still considered fit for purpose. Its underlying principle, that
other similar unincorporated associations. This includes a
those who create risks from work activity are best placed
section of the HSE website dedicated to health and safety in
to protect employees and the public, is still considered
leisure activities. It does not provide information on activities
relevant.
covered by The Adventure Activities Licensing Authority
HSWA has been used to prosecute duty holders in circumstances probably originally unforeseen by parliament. Increasingly it is used to prosecute following accidents that occur outside traditional workplaces involving the general public. The HSE now investigates and prosecutes those supplying and operating leisure activities to the public in the event of accidents.
but it is otherwise wide ranging and includes swimming, organised sporting activities, leisure centres, countryside visits, children’s play and motorised leisure pursuits, as well as adventurous, thrill-seeking activities like bungee jumping. The site makes it clear that while health and safety law does not, generally, impose duties upon someone who is not an employer, self-employed or an employee, anyone (including volunteers) with control of non-domestic premises like a
The police and emergency services are also coming under
school or community hall has legal responsibilities to make
increasing scrutiny. The Metropolitan Police was prosecuted
the premises and any equipment or substances provided
for health and safety offences under section 3 following the
for their use there, safe, so far as is ‘reasonably practicable’.
shooting of John Charles De Menezes in 2005. The Greater
However, in our view it is not as simple as that and it may
Manchester Police, through its Chief Constable, is currently
depend on whether there is any work activity taking place
being prosecuted for the same offence following the
and the extent of the club’s undertaking.
shooting of Anthony Grainger in 2012. Both prosecutions were brought by the CPS rather than the HSE, a further departure from longstanding practice.
As a number of recent cases have shown, the courts are drawing a clear distinction between unsafe premises and equipment; potentially dangerous activity where there is a
The very generality of HSWA’s provisions and its non-
degree of organisation and compulsion to participate; and
prescriptive nature have allowed it to remain relevant today
those cases where the injured party uses safe premises or
despite a very different social and working landscape from
equipment on an entirely voluntary basis.
that in 1974. There is no reason why it should not remain the mainstay of health and safety regulation for the foreseeable future. For further details contact: Peter James
Cases where the premises or equipment are inherently unsafe speak for themselves but the other two concepts can best be illustrated. In Uren (2013) the claimant was taking part in a ‘fun day’ organised by the RAF. The court found that a competent
E: peter.james@plexuslaw.co.uk
risk assessment would have concluded that a game, which
T: 0844 245 5319
involved competitors getting in and out of a shallow pool, carried a risk of serious injury which could not be justified in the light of the social value of the game. The organisers should have banned head-first entry to the pool which would
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have prevented the claimant’s injury. Crucially however, the
genuine and informed choice or lacked capacity. In the
claim was pursued against the claimant’s employer and
absence of some particular assumption of responsibility,
therefore there was a work connection.
where the victim was of full age and capacity, was not under
In Wilson (2013) the failure of an instructor at an adventure activity centre properly to explain or demonstrate the technique for negotiating part of an obstacle course, as required by the centre’s own risk assessment procedure and instructor training notes, constituted a breach of duty of care which was causative of an accident suffered by the claimant. The claimant was a scout leader who no doubt felt that he should set an example to his troop by attempting the course. However, in Risk (2013), Cockbill (2013) and Grimes (2011) where the claimants were all injured as the result of diving into a swimming pool or paddling pools, it was found that their acts had been entirely voluntary and the hosts of the events they were attending had no liability. The pools as such were entirely safe and the claimants were under no pressure or compulsion to act as they did.
the protective wing of an occupier with control over what he might do, and had a genuine and informed choice, the occupier had no duty to protect him from an obvious risk which he created himself. Tomlinson v Congleton BC (2003) was cited. By acting as he did, the claimant had created an obvious and serious risk which would not otherwise have existed. Whether he would have responded to advice or warnings from the defendant and regardless of whether there was adequate supervision, he did exercise a genuine and informed choice at the critical moment. Assumption of responsibility required an examination of the responsibility which the defendant did in fact assume, not what it should have assumed. Knowledge of the risk was irrelevant to that issue, although it would become a relevant consideration in relation to the issue of breach. The claimant fell a long way short of establishing the necessary ingredients of an assumption of responsibility. What would be required
Plexus Law represented the defendant in Risk. At an annual
was evidence of the very matters he denied: namely,
event run by the student union on the defendant’s land, the
affirmative steps by the defendant to ensure that proper risk
21-year-old claimant had run and dived head-first into a
assessments were taken and all relevant control measures
small inflatable pool. He seriously injured his neck and was
enforced; or, at the very least, affirmative statements and
now tetraplegic.
representations by the defendant that those specific steps
He submitted that the defendant owed a duty of care to
would be taken. Moreover, in such a case an element of
take appropriate steps to prevent him from injuring himself,
reliance by the claimant was a pre-requisite of a duty of
which arose as a result of (1) the particular circumstances
care arising on that suggested basis and here reliance was
and the relationship between a college and its students; (2)
singularly lacking. In the absence of any indication that the
alternatively, the defendant’s assumption of responsibility
defendant would safeguard the students in any respect, still
in the particular circumstances, including knowledge of the
less from their own actions in the face of obvious risks, it
risks it had acquired from previous years.
should not be found to have assumed responsibility for the
Dismissing the claim, the High Court judge held that although the defendant accepted it owed the claimant a
very matters which the law would otherwise have said lay within the claimant’s personal sphere.
general duty of care under S2(2) Occupiers’ Liability Act
Plexus Law was successful also in Lu v The Royal Russell
1957, the question was whether it owed a particular duty
Preparatory School Trust (2013). On 30th September 2011
to protect him from the risk he had taken. The issue was
the claimant, a Chinese pupil at the defendant’s school,
not as to the existence of a duty but its particular scope. A
was undertaking her third trampolining lesson under the
duty to protect against obvious risks or self-inflicted harm
supervision of a PE teacher when she over rotated whilst
existed only in cases in which the potential victim had no
trying to complete a back drop as a result of which her knee impacted with her face causing serious injury to her vision
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considered likely to be permanent. The claimant claimed
basis that the evidence did not support the prosecution’s
the trampolining lessons were poorly structured and
case that the accident was caused by its breach of duty and
inadequately supervised. This was denied and the case was
that the nature of the accident was proof of the existence of
defended at a liability only trial in the Central London County
a risk attributable to the system of work. The judge found
Court where the trial judge dismissed the claim and ordered
that there was a case to answer based on the existence of
the claimant and her litigation friend to pay the defendant’s
risk arising from the unguarded use of the machine.
costs.
The defendant appealed submitting that the judge erred in
Cases such as these may, in the future, be affected by the
rejecting the submission of no case to answer as there was
provisions of the Social Action Responsibility and Heroism
no evidence of a breach of duty by it and the judge used the
Bill, should it become law. In particular, the courts will be
wrong test. It argued that a risk would only materialise if an
directed to ‘have regard to whether the alleged negligence
employee did something very foolish, which this employee
or breach of statutory duty occurred when the person was
accepted he did, and that was not sufficient.
acting for the benefit of society or any of its members’. If so ‘the court must have regard to whether the person, in carrying out the activity in the course of which the alleged negligence or breach of statutory duty occurred, demonstrated a generally responsible approach towards protecting the safety or other interests of others.’
Rejecting the appeal, the Court of Appeal held that for the case to go to the jury, the prosecution had only to adduce some evidence of exposure to risk. Once that was established the onus shifted to the defendant to show on the balance of probabilities that it did all that was reasonably practicable to ensure that its employee was not exposed
The latest guidance from the HSE is not helpful and
to such risk. The prosecution did not have to prove that
continues to blur the lines between when a volunteer club
a particular accident was foreseeable. Causation was not
may be caught by the HSWA and when it may not. Sadly it
an element of an offence under S2(1) Health and Safety at
is not as simple as saying the Act will apply to certain clubs
Work, etc Act 1974. The creation of a material risk by the
but not others. In truth it could depend on the facts of each
carelessness, including gross carelessness, of an employee
case.
remained a material risk for the purpose of the offence. The defendant’s employees had been exposed to a clear,
Polyflor Ltd v HSE (2014) EWCA Crim 1522 The appellant/defendant’s employee had been injured when his arm had been caught in machinery while he was checking it. The machinery normally ran with guards attached but, when it became blocked, the employee obtained a permit to work to run the machine without guards. Permission was given and the employee put a spanner in the belt to find the
obvious and material risk to their health and safety by the removal of guards on the machinery so that a maintenance operation could be performed while the machine was still in operation. Such an activity was permitted by the defendant under a permit to work system such that there was in place a system whereby employees were exposed to a clear risk. That was sufficient for the evidential threshold to be met.
point where the belt was rubbing. The spanner got caught in the machinery, he could not let go of it in time and he broke his arm. A similar accident had occurred at the defendant’s premises four years earlier. The jury heard evidence from the employee who accepted that he had been foolish. An expert for the prosecution gave evidence that “if someone’s going to do something stupid, you cannot stop them”. The defendant made a submission of no case to answer on the 06
Greenwoods and Plexus Law successes Health & Safety Executive v X. The prosecution arose out of an accident on 11 September 2012. The victim was a special needs pupil at a school
court also had in mind, no doubt, the charitable status of the defendant and any fine would directly impact on the valuable services that it provides to the children in it care.
opened by our client (a charity) just six days previously. Our
Although a conditional discharge is almost unheard of in
client had contracted for all the doors on the new premises
health and safety cases, it is important to keep all options
to be fitted with hinge guards but the victim trapped his
under review, gauge the “mood” of the sentencing tribunal
left index finger in an unguarded hinge and suffered an
and be prepared to be bold in the right case.
amputation. Despite the fact that there were no guards on the school’s previous premises, no similar accident had occurred. Our client pleaded guilty to breach of S3 of the HSWA. In its plea in mitigation it accepted that an aggravating factor was the impact of the injury on the young victim, for which a claim for compensation had already been made. In mitigation the court was asked to take into account how recently the school had opened and the fact that steps had been taken to design out the very risk that had occurred. However, the building contractors had failed to complete the works on time, so that the school had become operational immediately the works were completed and they and the supervising architect had failed to ensure that all guards were fitted as stipulated in the building plans. Following the accident senior figures involved with the school had immediately become involved and had ensured that remedial works were carried out. Credit was also claimed for the prompt guilty please; the charity’s lack of previous convictions and the impact on its finances of any financial penalty. The outcome was a conditional discharge for our client. In essence although our client was in breach of the Act the court accepted the mitigation that this was a case in which a responsible dutyholder had been badly let down by its specialist advisers/contractors and therefore this was reflected in the sentence of conditional discharge. The
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Round-up of cases dealt with HSE v HMT and another We were instructed on behalf of HMT who were prosecuted by the HSE under Section 3(1) of the Health & Safety at Work etc Act 1974 following the death of an elderly resident who suffered from dementia whilst in their care. Whilst building works were being undertaken at the care home the elderly resident wandered into one of the rooms into which the works were being undertaken. A fire door had been removed and left leant against a wall. Unfortunately the resident pulled it on top of her and sustained a broken hip. She died a month later. A guilty plea was entered at the first opportunity but submissions to the magistrates for the matter to remain in the Magistrates’ Court failed and the matter was referred to the Crown Court for sentence. Ultimately a fine of £20,000 was imposed after detailed written submissions had been made in mitigation.
HSE v JM We acted for the defendant who was prosecuted under Section 3(1)(a) of the Management of Health & Safety at Work Regulations 1999 for failing to make a suitable and sufficient assessment of the risks to the health and safety of his employees and under Regulation 17(1) of the Workplace (Health, Safety & Welfare) Regulations 1992 in failing to organise the workplace in such a way that pedestrians and vehicles could circuit in a safe manner. The prosecution was brought following the death of one of the defendant’s employees when he was struck by a vehicle in the defendant’s yard. A fine of £20,000 was imposed in respect of each offence. The magistrates retained jurisdiction.
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Round-up of other developments There are a number of ongoing consultations but the most relevant to health and safety generally relates to proposals to exempt self-employed persons from S3(2) HASWA except those undertaking activities on a prescribed list. The proposal stems from a recommendation made by Professor LĂśfstedt in his report ‘Reclaiming health and safety for all: an independent review of health and safety legislation.’
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Round-up of significant fines over the last three months May 2014 Stonyhurst College Breach/Circumstances: A historic private school in Clitheroe
Plea: Guilty. Sentence: Fined £110,000 and ordered to pay £16,620 in costs.
has been fined £100,000 over health and safety failings after
Refresco Gerber UK Ltd
one of its stonemasons developed a potentially fatal lung
Breach/Circumstances: An international smoothie and fruit
disease.
juice company has been sentenced for safety failings after
Stonyhurst pleaded guilty to a breach of the Health and
an engineer was killed by falling pipework during work to
Safety at Work etc Act 1974 by failing to ensure the health
decommission a former factory in South Wales.
and safety of its employees.
Refresco Gerber UK Ltd pleaded guilty to a breach of
Plea: Guilty.
Section 2(1) of the Health and Safety at Work &c. Act 1974.
Sentence: Fined £100,000 and ordered to pay £31,547.78 in
Plea: Guilty.
prosecution costs.
Sentence: Fined £80,000 and ordered to pay £75,000 costs.
Angus Group Ltd , Scotland
AAK UK Ltd
Breach/Circumstances: A specialist asbestos removal
Breach/Circumstances: A sauces manufacturer has been
company has been fined after it exposed workers to
fined £140,000 after a forklift truck driver was killed at a
dangerous fibres during demolition of a former school
factory in Runcorn.
building.
Michael Moran was using his forklift truck to load a lorry
Angus Group Ltd was found guilty of eight breaches of the
trailer outside the factory on the Astmoor Industrial Estate
Control of Asbestos Regulations 2006.
on 18 April 2011 when another lorry reversed into the side
Sentence: Fined a total of £109,000 and ordered to pay a
of his vehicle. The forklift overturned, killing him instantly.
further £42,100 in costs.
Company pleaded guilty to a breach of the Health and
Habitat Construction LLP Breach/Circumstances: A Southwark construction company has been ordered to pay more than £126,000 in fines and costs after a worker was left paralysed from the waist down
Safety at Work etc Act 1974. Plea: Guilty. Sentence: Fined £140,000 and ordered to pay £22,657 in prosecution costs.
when he fell eight metres from an unguarded window space into a basement. Habitat Construction LLP pleaded guilty to breaching Section 2(1) of the Health and Safety at Work etc Act 1974.
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Kemble Air Services Ltd Breach/Circumstances: Kemble Air Services Ltd, the operator of Cotswold Airfield, has been fined for safety
April 2014 Castlebeck Care (Teesdale) Ltd
failings after an experienced fire-fighter was killed while
Breach/Circumstances: Care provider Castlebeck Care
moving a pressurised gas cylinder. Mr Mills was attempting
(Teesdale) Ltd has been fined £100,000 after a patient died
to move a large freestanding cylinder weighing 65kg when
while being restrained using an unauthorised technique at a
the gas in the cylinder discharged very rapidly. This caused
Nottinghamshire mental health hospital.
the cylinder to spin round violently striking Mr Mills on his head and body leaving him with fatal injuries. Kemble Air Services Ltd, of Cotswold Airfield, Kemble Nr Cirencester was found guilty of two breaches of Regulation 3(1) of the management of Health and Safety at Work Regulations 1999. Sentence: Fined £75,000 and ordered to pay £98,000 in costs.
T Lea Sherwin Ltd Breach/Circumstances: A farming company in Middlewich has been fined £50,000 after a father-of-one suffered fatal injuries when a 1.5 tonne concrete panel fell on him. The court was told the firm failed to carry out a proper assessment of the risks, or to make sure a safe system of
Castlebeck Care (Teesdale) Ltd, now in administration was found guilty of breaching Sections 2(1) and 3(1) of the Health and Safety at Work etc Act 1974. Sentence: Fined £100,000.
Mid Staffordshire NHS Foundation Trust Breach/Circumstances: A vulnerable diabetic patient died because a hospital trust failed to implement basic handover procedures and ensure essential record-keeping, a court has heard. Mid Staffordshire NHS Foundation Trust was prosecuted by HSE and pleaded guilty to an offence under the Health and Safety at Work etc Act at Stafford Crown Court. Plea: Guilty.
work was in place. As they lifted the panel, which was six
Sentence: Fined £200,000 and ordered to pay £27,049
by one metres in diameter, the bolts attached to the lifting
costs.
chains snapped and the panel fell onto Mr Bennett. T Lea Sherwin Ltd, pleaded guilty to a breach of the Health and Safety at Work etc Act 1974 on 12 May 2014. Plea: Guilty.
March 2014 Gaspack Services Ltd Breach/Circumstances: A worker filling gas cylinders had
Sentence: Fined £50,000 and ordered to pay £28,585 in
his leg severed below the knee when a faulty cylinder he was
prosecution costs.
filling exploded at Guardian Gas Ltd, Brynmenyn Industrial Estate, Bridgend. HSE’s investigation found the failed cylinder was one of a batch of cylinders which Guardian Gas had sent to Gaspack, a certified cylinder inspection body, for inspection, testing and certification to prove their safety for a further 10 years. The cylinders had been returned to Guardian Gas certified as safe to use.
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Gaspack Services Ltd of Gellihirion Industrial Estate, Pontypridd, pleaded guilty to a breach of Section 3(1) of the Health and Safety at Work Act 1974.
Faraday Court in Fulwood Breach/Circumstances: A Preston-based building firm has
Plea: Guilty
been fined £130,000 over the death of a worker outside a
Sentence: Fined £30,000 and ordered to pay £60,000 in costs.
cinema in Ashton-on-Ribble. The Health and Safety Executive (HSE) prosecuted EMC Contracts Ltd after father-of-one Carl Green was struck by
Roberts-Gordon Europe Ltd Breach/Circumstances:
EMC Contracts Ltd
A
Wednesbury-based
a reversing van in a paved area outside the entrance to the heating,
ventilation and air conditioning manufacturer has been fined £150,000 after a worker was crushed to death while working in its warehouse. Ronald Meese, 58, of Bilston, a production supervisor for Roberts-Gordon Europe Ltd, had been stacking threemetre-long metal tubes in the warehouse in Darlaston Road, Wednesbury, when the incident happened on 27 July 2011. With the aid of a forklift truck, he had created several stacks, but as he left his cab to set down timber pieces for the next bundle of tubes to rest on, one of the stacks, weighing a tonne, collapsed onto him. Paramedics were called but Mr
Odeon Cinema on 27 July 2010. The 45-year-old painter from Chorley had been working on a project to fit out a new coffee shop in the cinema when the incident happened. He died from his injuries on the way to hospital. EMC Contracts Ltd, which has been put into voluntary liquidation, was found guilty of two breaches of the Health and Safety at Work etc Act 1974. The company, of Faraday Court in Fulwood, was fined. Sentence: Faraday fined £130,000 and ordered to pay £52,790 in prosecution costs.
Meese was pronounced dead at the scene. Roberts-Gordon Europe Ltd, of Kings Hill Business Park pleaded guilty to breaching Section 2(1) of the Health and Safety at Work etc Act 1974. Plea: Guilty. Sentence: Fined £200,000 and ordered to pay £27,049 costs.
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The combining of the resources of Plexus and Greenwoods’ Health and Safety teams The two firms’ health and safety teams are now working in close partnership, bringing together immense experience in serious injury and fatal accidents across a wide range of activities from care homes and schools to construction sites and railways; from garden centres to chemicals companies; and from food hygiene to environmental pollution. We have provided guidance and representation at inquests and in criminal proceedings in the most complex and high-profile cases.
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The information and opinions contained in this document are not intended to be a comprehensive study, nor to provide legal advice, and should not be relied on or treated as a substitute for specific advice concerning individual situations. This document speaks as of its date and does not reflect any changes in law or practice after that date. Plexus Law and Greenwoods Solicitors are trading names of Parabis Law LLP, a Limited Liability Partnership incorporated in England & Wales. Reg No: OC315763. Registered office: 8 Bedford Park, Croydon, Surrey CR0 2AP. Parabis Law LLP is authorised and regulated by the SRA.