Deputyship Matters - December 24 : simplebooklet.com

We have nearly made it to the end of 2024 – it has been an extremely busy year and lifecertainly doesn’t seem to be slowing down any time soon where all things Court ofProtection are concerned.The Judgment in PW2 is awaited from Her Honour Judge Hilder. I think it’s safe to say theCourt has made its position on conflicts of interest very clear following decisions in bothACC and PW1. It will however be interesting to see how that is applied to clients withexisting arrangements in place both in terms of any compensation due to P and alsoconcerning the ongoing appointment of the Deputy and investment manager. Richard Dew ofTen Old Square has very kindly agreed to provide another webinar for our members once thePW2 judgment has been handed down – more information to follow in due course. The PDFwill also be working closely with the OPG in respect of guidance it will produce on thisissue.The recent decision in Lumb v NHS Humber and North Yorkshire ICB [2024] is also provingto be very challenging when it comes to the management of personal health budgets, directpayments etc. The implications for financial deputies are likely to be considerable especiallygiven many deputies will also act as employer for the carers. The PDF will be working withFay Collinson and liaising with the OPG to hopefully produce some further guidance on this.It would also appear several members have been facing challenges in respect of thetreatment of a PPO when it comes to means tested benefits and statutory funding. This is anissue we will be considering further with a view to providing our members with somesupport.Of course, the committee continues to engage with all stakeholders on issues as they arise.If there is anything you consider we should be supporting with then please let us knowadmin@deputiesforum.co.ukI am pleased to say we already have some members who have started their accreditationjourney on either the foundation or intermediate modules. It will be good to see thosemembers achieve their accreditation status in the coming months. The advanced module iscurrently in development and will be launched in 2025.2025 will be packed with 3 conferences, more webinars and podcasts and no doubt evenmore Court decisions to keep us on our toes.We hope you are all able to enjoy the festive period. See you in the New Year.PDF CHAIR 2024Stacey BryantFROM THE CHAIRDecember 2024

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Statutory wills are often used when a person is mentally incapacitated or when anexisting will is deemed invalid. In these cases, the court creates a statutory will thatreflects what the testator likely would have intended. Probate researchers bringinvaluable expertise to the process by accurately tracing beneficiaries and constructingdetailed family trees, which helps streamline the application, reduce risks, and ensureproper estate distribution.The Importance of a Family TreeA thorough family tree is critical in statutory will applications. When no valid will exists,the court relies on the family structure to determine inheritance. Probate researchersensure that not only immediate family—such as children, parents, and siblings—but alsomore distant relatives, like cousins and nieces, are identified and considered.Researchers are particularly skilled at uncovering estranged or unknown relatives,especially in complex family situations where the testator may have had multiplerelationships or lost contact with family members over time. A detailed family tree helpsreduce the risk of missing potential heirs, preventing delays or disputes during estateadministration.Tracing & Locating BeneficiariesOnce the family tree is established, the next step is tracing and locating beneficiaries.Statutory will applications require that all potential heirs be notified, which can bechallenging if beneficiaries have moved, changed names, or lost touch over the years.Probate researchers use specialized databases, public records, and genealogicalresources to track down hard-to-find heirs, including those who may have relocatedabroad. Their expertise ensures that all beneficiaries are properly served, reducing therisk of delays or legal challenges during the estate administration process.

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Risk Mitigation & Due DiligenceThe key value of a probate researcher lies in minimizing risk and ensuring accuracy. Incorrect orincomplete beneficiary information can result in costly delays and disputes. Researchers verifyrelationships, confirm legal entitlements, and ensure that all rightful heirs are identified. Thisaccelerates the process and gives solicitors and executors confidence that the statutory willreflects the testator’s likely intentions.In cases with more complex family dynamics—such as estranged relationships or non-traditional families—a carefully researched family tree clarifies inheritance rights and ensuresno beneficiary is unintentionally overlooked.Practical Tips for ProfessionalsStart Early1. Begin researching the family tree as soon as possible. Identifying heirs early helps resolveissues before they cause delays.2.Review Prior Documents3. Previous wills and legal documents may clarify the testator’s family structure or intentions,especially in contested cases.4.Verify Claims5. Ensure that all beneficiaries have a legitimate claim to the estate. Researchers can confirmrelationships through birth records and other documentation.6.Maintain Communication7. Keep executors and solicitors informed of progress. Communicate early about anychallenges, such as difficulty locating heirs, to keep the process on track.8.ConclusionProbate researchers are essential to statutory will applications. By creating accurate familytrees, locating beneficiaries, and ensuring due diligence, they minimize risks and help avoidpotential disputes. By following these practical tips, you can ensure a smooth and efficientstatutory will process that reflects the testator’s likely wishes and ensures proper estatemanagement.For further information contact Sam Kimber sam@pro-gen-research.co.uk

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2025 will mark the 100th anniversary of the Law of Property Act 1925 (“the LPA 2025”). The Actwas designed to simplify the complex and often confusing land law system in England andWales. Before its enactment, land law was described by Oliver Cromwell as a "tortious andungodly jumble". The LPA 1925 is still very much alive in property law practice today.For the Property and Affairs Deputy, the key is in the name. A Deputy will inevitably need someunderstanding of the laws of our land to be able to help our clients to manage their affairs. Most of us will have of course experienced a sale or purchase at some point or perhaps evenworked in a property team. It is still important to keep updated on property matters so I have highlighted a few recurrentissues that apply in practice:Orders with a general authority clauseThere have been recent discussions on this issue both at the CUG and on the forum. Some olderProperty and Affairsl Orders can be silent on specific authority to purchase or sell property.Such Orders may provide a “general authority clause” allowing the Deputy to deal with P’sproperty. If the general authority clause was inserted at the time of making an Order, it waslikely the intention of the court to allow the purchase of a property by the Deputy, however thisis not always a given. The Land Registry may interpret that same clause quite differently uponregistration of your client’s property. If the Land Registry decides to reject the Order as notbeing the correct authority to purchase by the Deputy then it will mean a retrospectiveapplication to the Court whilst also protecting the client’s priority on the Land Registry titlewhilst they are not officially owners. Purchase of Property for a minor under a Trust Going back to the LPA 2025, S1(6) states that a minor cannot hold legal title to any estate ofland. General practice therefore is that we appoint trustees to “hold” the legal title for ourminor clients. In Deputyship cases, the Trustee is most likely to also be the Deputy andtherefore additional Court authority is required to act as Trustee (as it is not within a Deputy’sgeneral powers to act as Trustee).

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The requirement for two trustees to hold legal title is primarily derived from S34(2) Law ofProperty Act 1925. This ensures that there is a check and balance in the management of theproperty, preventing any potential misuse of power by a single trustee.One question that often confuses conveyancers, the Land Registry and Deputies is: Is a TrustCorporation classed as one or two trustees? I have had mixed advice on this over the yearsfrom various conveyancers and land registry representatives. Some consider that if a TrustCorporation acts as Deputy for P, then the Trust is one entity/represents one person only andtherefore can only act as one of the Trustees. Consequently, another single trustee wouldneed to be appointed as co- trustee (for example a solicitor of the firm or a parent) in additionto the Trust Corporation Deputy. Others consider that two Directors of the Trust Company can individually be appointed to actas Trustee and therefore sign the TR1 and Contract for purchase in their individual capacitybut appointed as two Trustees. Good practice would be to ask the Court to clarify the positionin any Order for sale so that there is no question when it gets to Land Registry registration.A Declaration of Trust would be required alongside this process to explain the situation andusually in accordance with any Directions in the Order. Declarations of Trust will also usuallyneed to be filed with the OPG following completion of any purchase. Don’t forget to advisethe OPG once P turns 18 and the trust is discharged. On that point, the Court was recently asked whether authority is needed to transfer a legaltitle back to P once P turns 18. Again, this is another conflict point between the Court andconveyancers in practice. Some consider that court authority is needed because there couldbe a clause in the general Order restricting “disposition of property” and technically a TR1would be required to transfer the legal title from the Trustees to P which is classed as adisposition. The Court’s view is that this is a matter for the Trustees to deal with upon Pturning 18 and the court would not necessarily be required to provide specific consent. TheLand Registry may of course disagree.100 years on and we still have questions!

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It’s hard to believe that it’s nearly the fifth anniversary of the landmark case of Re ACC(and others) [2020] EWCOP9, published in February 2020. Since then, Deputies havesignificantly adjusted their practices to better address conflicts of interest.It is now very much the norm that Deputy’s think twice before instructing their own firm,in the spirit of the PDF and our collaboration as members Re ACC has also meant that wecan talk with ease with other law firms that offer similar services to ensure we find theright legal advisors for our clients.Naturally, there can be a fine balance between matters where a Deputy will know it willnot be cost efficient to obtain three quotes but we have learnt the best practice to dealwith this now whilst being aware that the OPG will require a best interests noteexplaining why three quotes were not proportionate to the magnitude of the issue itselfand there is a clear reason why it is in P’s best interests . Sometimes the cost of trying toexplain the facts of the instruction to three separate solicitors in order to produce a quoteis an inefficient use of a fee earners time and compared to the cost of the quote itselfwould be disproportionate to do. Since Re ACC we have recently seen few other judgements being handed down by SeniorJudge Hilder proving that the Court is still very alive to the issues of conflict. In the caseof re PW [2024] EWCOP16 the court looked at the financial conflict of interest when aDeputy appoints an in house or connected fund manager to manage the financialportfolios for clients and it was clearly held that appointing connecting parties to manageP’s fund is a clear breach of the Deputy’s fiduciary duty. The Court is there to protect thevulnerable but also our profession and how we are viewed by the outside world looking in.

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In the more recent case of Lumb v NHS Humber and North Yorkshire ICB & Anor [2024] EWCOP57 (T2) (11 October 2024) Re ACC principles ripple through this case law in particular the pointabout the general authority of a Deputy and what is classed as a property and affairs decision incontrast to a health and welfare one. The case held that management of direct payments of apersonal health budget as ‘representative’ in line with the NHS (Direct Payment) Regulations2013 does not fall within the authority of a property and financial affairs Deputy. A separatecourt application will be required if a P&F Deputy wishes to continue to manage payments forP. The case of Re ACC has certainly “opened the floodgates” to new points of law concerningdecisions made by a Deputy and how that can be viewed as a “conflict of interest”. It has alsoincreased scrutiny on any decision that doesn’t sit within the general power of a Deputy. Itcertainly means that as Deputy we are thinking harder about every decision we make, perhaps areason why cost draftsmen and the SCCO have seen such significant increases in our Bills ofcosts. But that is another PDF discussion for another day…!In the event that you need a refresh on the steps to take when thinking through a Re ACCscenario , please see the below flow chart prepared by Alexander Wright, former Chair of thePDF

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When P is joined as a party in property and affairs applications in the Court of Protection,the Official Solicitor is very often appointed to act as P’s litigation friend. The majority ofthese cases are statutory will and statutory gifting applications, and the Official Solicitor’soffice is involved in several hundred of such matters each year. There are certain issueswhich are commonly overlooked in the preparation of these applications, and which can (andoften do) cause avoidable delay and complications in the proceedings. In this context, theOfficial Solicitor would particularly highlight the following issues that applicants shouldfocus on when preparing their statutory will and gifting applications:Provide up to date and complete information regarding P’s finances – this shouldinclude valuations of their assets and any outstanding liabilities, and also schedulesdetailing their annual income and annual expenditure. If any material changes to P’sfinances are expected in the foreseeable future, details of these should also be provided. Provide good quality decision specific capacity evidence. The capacity assessment in astatutory will application should address P’s testamentary capacity. In a giftingapplication it should address P’s capacity to make the proposed gift.Also ensure that thecorrect ‘relevant information’ is identified in section 5.1 of the COP3 – this will varydepending upon the relevant legal test applicable to the decision to which theapplication relates. Ensure the necessary respondents (as detailed in paragraph 9 of practice direction 9E)are correctly identified and served. Be aware that service will only be dispensed with inexceptional circumstances, and be familiar with the relevant case law on this issue - ReAB [2013] EWCOP B39, Re D [2016] EWCOP 35, BH v JH [2024] EWCOP 12, and BH v JH(Costs application) [2024] EWCOP 9Property & Affairs Applications - Common IssuesJohn Howard, Lawyer, Property & Affairs OSPTwww.deputiesforum.co.uk

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www.deputiesforum.co.ukRecognise the need for litigation friends for respondents other than P who lack capacity toconduct the proceedings (whether by reason of them being minors, or being adults wholack litigation capacity), and take steps as soon as possible to identity suitable individualsto act as litigation friend for them. Ensure the applicant’s supporting evidence focuses on the factors in section 4 MCA 2005 –in particular, P’s past and present wishes and feelings, the beliefs and values which wouldbe likely to influence their decision, and any other factors P would be likely to consider ifthey were able to.Urgent applications – if seeking to have a matter expedited (e.g. due to concerns regardingP’s life expectancy), ensure that clear independent evidence as to why the matter requiresurgent attention is provided - Bagguley v E [2019] EWCOP 49, at [44] – “…where anapplication is brought before the Court of Protection, on what is said to be 'an urgentbasis', evidence of urgency must be presented which is both clear and cogent. This is to beregarded as a professional obligation on all the professionals involved but mostparticularly on the lawyers who bring the application.”

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Court of Protection practitioners are by now used to working with a slow legal process, which isas much a fact of life as potholes, heavy traffic and delayed trains. It should not be like this andwe know that judges and court staff work hard to clear the backlog, which by its nature, cannever be cleared. Each month the Court receives another thousand applications for a financialdeputy. Each one involves a unique set of personal circumstances where a person’s autonomousrights are handed over to another. And yet time is not on their side when a straightforwardapplication to appoint a deputy takes around six months to complete. A person who needs adeputy is someone who clearly cannot manage and needs assistance. Often that person is elderlyand in the last stages of life. Care needs to be provided and paid for, bills need to be paid, aproperty need to be protected or repaired. It can be an anxious and unsettling time for anyoneinvolved. Even where the need for deputy has been identified, there is going to be a great deal of work todo even before the application is made. Practice Direction 9H requires the applicant to notify theperson who lacks capacity and other notifiable persons before the application is made. Medicalevidence needs to be obtained and other information needs to be collated. Often that informationis out of date or partial. The Court statistics measure time from the date of the application to thedate a final order is issued, the applicant’s clock will start earlier. It also carries on for longer, orstarts again, as even when the order is issued, there are new delays to contend with dealing withbanks, and financial and other institutions. The reality is that practitioners need to adapt and dothe best they can in challenging circumstances. While we can press for improvements where wecan, and there will be times when some things do improve, we also need to use our own skillsand expertise to best effect. I have collated ten practical suggestions, some of which may workfor some cases. They may also prompt feedback, which also introduces a new overarchingsuggestion. We are all experiencing the same issues and for our mutual benefit and the benefit ofthe clients we look after, have an interest in offering refinements where we can. www.deputiesforum.co.uk1. Manage expectations Before an application is made, it is important to let the client or other parties you are dealingwith know that it is likely to be a long process. If clients, relatives, creditors, and care providersknow that the process is a slow one, they will not blame the solicitor when there is no deputy inplace after a month or two. Coping with DelaysMartin Terrell, Partner Warners Law, PDF Director

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www.deputiesforum.co.uk2. Get as much accurate information as possibleIt is good practice to provide the Court with as much information as possible. We shouldalways bear in mind that the Court knows nothing of the case, it relies on us to know whetherthe estate is a large or small one, what the properties are worth and who owns them. We needto provide evidence of the lack of capacity and the persons to be notified. The better theinformation provided up front, the more likely the Court will not delay the process expectingmore information or providing an incomplete order. 3. Don’t wait for too much information – be prepared to follow upThe Court’s timeframe for appointing a deputy only begins when it receives an application, sothe sooner the application is made, the less time is lost. A great deal of time can be spenttrying to prepare a perfect application, when information may be limited. It may not bepossible to obtain up to date evidence of assets and liabilities; it may not be possible to traceclose relatives or to establish whether a stay in a care home is temporary or permanent. Thereis a dilemma here between waiting for perfect evidence to start the process. Given the lengthof the process, it is better – even at the risk of creating more effort and delay in future – tomake the application sooner rather than later, and explain to the Court what more evidencewill be needed later on. An application can always be made on a COP9 to amend an order(within 21 days of issue) if the order is incomplete because more evidence has come to lightduring the application process. A further consideration is that once the application has been made, the applicant is lessexposed to risk. There is a remedy for costs if there is an objection or P dies before the deputyis appointed. Creditors may also be reassured knowing that an application has been made. 4. Don’t make mistakesIt goes without saying that any delays that take place should not be attributable to the us. Itcannot help the efficiency of the Court if applications are incomplete and need to be returned.With the best efforts in the best firms, mistakes are easy to make. Examples (unattributed toanyone in particular, of course) include:Omitting one or more of the application formsFailing to sign and date formsForm COP3 failing to specify a medical diagnosis or addressing the capacity tests of theMental Capacity ActFailing to name three persons who need to be notified of the application or failing toexplain why certain persons have not been notified Leaving too long a gap between notices (see PD9H para 13)

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www.deputiesforum.co.uk5. Be precise about what you want and support with evidenceFewer and fewer cases seem to be straightforward, where all that is required is ‘only’ theappointment of a deputy. Specific authority may be needed, to deal with particular issues of thecase, which need to be explained in the application. For example:To sell a property – if it is clear that the property is no longer needed, then is there a DOLSauthorisation which will provide evidence of this? is the property specified in a Will? If it isnot a main residence, are there Capital Gains Tax considerations?To administer an interest in an estateTo obtain possession of a Will or other personal possessions from a third partyTo instruct the deputy’s firm where the deputy is a solicitor to carry out a particular item ofwork. If you are asking for specific authority it is important to be clear about what is needed andexplain, with evidence why it is needed. 6. Don’t provide more information than you need toWhile it is important to anticipate the extent of the authority required, there is no point askingfor authority that is not needed at this time. It is tempting to provide the Court with as muchinformation as possible about a case, to anticipate every eventuality, but this can also lead tofurther delay. There is no point asking for authority to sell a property if P is still living in theproperty. Be clear and specify whether a further order will be needed in the foreseeable future, inwhich case the order appointing the deputy may provide authority to restore the application (byway of COP9 and with no new fee payable). If this cannot be anticipated, then a final order canbe made and a new application made in the future (with a COP1 and an application fee). 7. Use interim orders Not every application can wait several months for a deputy to be appointed. The applicant mayhave incomplete evidence or urgent action needs to be taken before a deputy can be appointed.Without express authority, an applicant may not be able to gain access to property or inspect andretain personal papers or place personal effects in storage. A great deal can be done with a shortinterim order which the Court may make – if provided with sufficient evidence – in a matter ofweeks. This might include authority to:Investigate and report, so that banks and financial institutions are required to disclosefinancial information (a third party given such an order is then placed on notice of the lack ofcapacity and will stop sending correspondence and financial demands without furtherauthority)

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www.deputiesforum.co.uk8.Be prepared to act in P’s best interestsSometimes it is not possible to wait for an order when urgent steps need to be taken. Limitedbut necessary steps can be taken, to protect a person’s estate. While it is preferable to havecourt authority before acting, an applicant would not be criticized if taking reasonable steps tochange locks, turn off a water supply, remove waste from a kitchen, or board up a property atrisk. Costs incurred can be approved by the Court if and expenses incurred would be protected bysection 7 Mental Capacity Act 2005 which provides a right to reimbursement where ‘necessarygoods or services are supplied to a person who lacks capacity.’ Any such actions should only becarried out where there is evidence of lack of capacity, and best interests are carefullyconsidered. For instance, can P be consulted on the matter? Are there any relatives or closefriends involved? In any event, steps taken should be as limited as possible, pending expresscourt authority.A local authority may be prepared to assist with a financial contribution for care once anapplication has been made. The fact that the application has been made provides somereassurance that P’s affairs are being dealt with and there will be a means of managing anydebts incurred.Gain access to inspect and secure the property and contentsObtain release of funds from a bank account to cover care costs or property expenses (thecourt will generally allow funds to be released to the applicant’s firm to cover care costs oressential property expenses)Redirect post (for security and to obtain evidence of a person’s financial affairs)Require a local authority or hospital to disclose a DOLS authorisationRequire another firm to disclose the contents of P’s WillThere is a very helpful precedent (B1) for clauses to use in an interim order provided inLexisNexis’ Court of Protection Practice.9.Use the DWPThe Department for Work and Pensions will designate a person as appointee to deal with thebenefits of someone who cannot manage their own affairs ‘because they’re mentally incapable orseverely disabled.’ An application for an appointment to act can be made without there being adeputy in place, and can be quite straightforward as well as efficient, if supported by suitablemedical evidence (in practice, a copy of form COP3 will be accepted). Once the appointment hasbeen made, the appointee can administer a state pension and any benefits, including attendanceallowance, which can be used to meet personal expense and care costs.

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www.deputiesforum.co.uk10.Shout when you need to shoutThe court process is a slow one, but will assist – or can assist – in an emergency. It goes withoutsaying that we need to be selective when pressing for a matter to be expedited. More work isneeded to push one application to the front of a queue, which will in turn delay otherapplications. Experience does suggest that where an application is presented carefully, withattention to the urgent steps that need to be taken, and consideration of the risk to P’s estate ifthe steps are not taken compared to any prejudice that may result if they are taken, the court willtry to assist. There will though be cases that are lost in the process, that disappear into a black hole. Emails tochase (the headings should be as succinct as possible and quote the court reference) are the firststep. Telephone calls require a great deal of patience.As a last resort, the red button behind theglass panel, a polite email to the court manager has proved effective.

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Following the recent Court of Protectionjudgments in Knight v Barnsley NHSFoundation Trust [2024] EWCOP 59 and Lumbv NHS Humber and North Yorkshire ICB [2024]EWCOP 57, and the recent webinar presentedby Fay Collinson we take a look at some ofthe queries that have arisen on the forumregarding statutory funding, and the likelyoutcomes of these decisions. One query (Professional Deputies Forum), which was raised before the recentcase regarding Peter’s undertakings, asked for a precedent for a Peter’sundertaking as they have been asked to sign one. The query notes that they havenot been asked to sign such a document for some time. The query has been answered with reference to the 2021 case of Martin v Salfordand the most recent case where Her Honor Judge Hilder in her concludingremarks within the judgment stated “When I asked counsel before me theyconfirmed that, to the best of their knowledge, orders with a Peter’s undertakingare no longer being made. I welcome that development.” It would be interesting to understand how often deputies are in fact being askedto consider signing such undertakings and what impact this has had if theyrefused to do so. Are you signed up to receive notifications of new posts in the Forum?This is managed from within your Profile (Settings) and from theindividual Forum threads where you can subscribe to a thread if it is ofparticular interest to you without the need to commentForum Round-Up - Pick of the PostsCharlotte Fletcher, Hugh James, Committee Member

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An arguably more significant case for deputies is the Lumb case regarding themanagement of PHB budgets by a property and financial affairs deputy. This casewill have very far reaching effects for deputies and a query on the forum askswhether deputies are now refusing to manage these budgets, and what steps arebeing taken to deal with it on a practical basis. The answers to this query raise a number of further questions about how it willwork where the deputy is employer if they are unable to manage the fundingneeded to pay the wages, whether it also applies to local authority directpayments (and the conclusion appears to be that it does) and what steps nowneed to be undertaken. It is clear that further guidance is needed, and this is something that the PDF islooking to put together. At the current time, the answers indicate that manydeputies are adopting a “watching with interest” approach, continuing withcurrent arrangements but not entering into new arrangements. This is also adifficult position, however, particularly for clients who may need the financialsupport to start quickly after what is often a long and drawn out battle to secureit in the first place. Linked to both of these points is the position with Periodical Payment Orders(“PPOs”) and the different approaches of local authorities as to whether theseshould be considered as “income” as opposed to capital for the purposes of meanstesting. This has been raised by the PDF on the forum to ascertain the experiences thatmembers have of this and what the outcomes have been. It appears from the answers that this is being raised more regularly by localauthorities and difficulties challenging their views are increasing. This couldclearly have significant financial implications for many of our clients (particularlythose whose claim settled for less than full liability), as well as the use of PPOs insettlement of litigation generally moving forwards. This is an issue that the PDF are interested in considering further to decide whataction may be appropriate to take. If you do have any cases where this has been anissue, please do contact us.

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Monday05MarLondonWearing your Employer HatAn employment seminar for DeputiesThe programme will include: Agency vs Directly Employed carers. Acting as an Employer. Statutory Funding & Safeguarding. Employment Disciplinaries& Settlement Agreements. Managing FamilyDynamics. GDPR/CCTV/Privacy/Confidentiality forP/Families/Carers - Your Responsibilities. And muchmore....0930 to1630 Book nowMonday15MayLondonAssociates ConferenceLearning, Developing, NetworkingA one day conference purely for AssociateMembers of the PDF that has beendesigned to be as accessible and asbeneficial as possible.0930 to 1530Book nowForthcoming EventsMonday18SeptThe PDF Conference 2025SAVE THE DATEThe NECTickets on sale January 20252025

Deputyship Matters - December 24

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