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Have you implemented all the recommendations made by the Woolf Committee?

Following the publication of the Woolf Committee recommendations in May 2008, we undertook to act on all 23 of the Woolf recommendations within three years.
In accordance with recommendation 23 of the Report, we engaged an external independent expert - Ethical Leadership Group (ELG), a leading global compliance advisor which aims to help companies build and strengthen cultures of integrity – to conduct an independent assessment of our business conduct programme and assess our progress to date in meeting the Woolf Recommendations.
ELG’s report concludes that substantial progress has been made against the Woolf recommendations with well designed processes to ensure continuous improvement (see the ELG Findings). ELG identified some opportunities for improvement and these have been incorporated into the Group's on-going business conduct programme to ensure continuous improvement.
Deloitte LLP completed external assurance of our reported implementation programme in September 2011.