Extension of the Approved Persons Rules

The Financial Services Authority (FSA) has extended the Approved Persons Rules beyond the directors of firms to include those "exercising significant influence". Firms have to apply for approval for such persons before 6th February 2010.

The LGPS Investment Regulations - out with the old, in with the new

The new LGPS Investment Regulations came into force on 1 January 2010. The Regulations replace a whole raft of existing statutory instruments dating back to 1998 and also introduce several new requirements which warrant attention.

Getting tough on tendering. The impact of the new Remedies Directive

A radical overhaul of the remedies available under the existing public procurement regime came into force yesterday in the form of the Public Contracts (Amendments) Regulations 2009 (SI2009/2992) which implement the Remedies Directive.

To move or not to move that is the question - is it better to change a location and make a reasonable adjustment than make no change in location at all?

A worker has a disability. There are various adjustments you could make, all of them "reasonable". It would be preferable, as the employer, in terms of cost and business impact to do all of this at another location.

Court hands down judgment on key issues under the Consumer Credit Act 1974: Carey v HSBC

The case dealt with two matters concerning requests for copies of credit card agreements pursuant to section 78 of the Consumer Credit Act 1974 (Act) and the consequences of non-compliance with that provision.

Employment Law 2009 review/2010 preview: Part 2

In Part 2 of our year review/preview we look forward to the anticipated judicial and legislative trends for employment law in 2010.

Admitted Body Status - where are we now?

Shortly before the Christmas break, the Department for Communities and Local Government (CLG) issued updated guidance relating to the operation of the Admitted Body Status (ABS) framework within the Local Government Pension Scheme (LGPS).

Perpetuities and Accumulations Act 2009

The Perpetuities and Accumulations Act 2009 will come fully into force on 6 April 2010 by virtue of a commencement order announced in Parliament last week.

Lord Justice Jackson publishes final report on civil litigation costs

Lord Justice Jackson's Civil Litigation Costs Review makes a number of important recommendations which, if implemented, could result in significant changes to civil procedure.

Property update - January 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

Before you charge in - part 1. Commercial agents - the essentials and what happens upon termination

In this alert, Wragge & Co's dispute resolution experts set out some of the essential terms of commercial agents' contracts in the European Economic Area (EEA), focusing particularly upon the UK.

Banking update: report and review on recent cases and issues

A review of civil litigation costs, the need to make enquiries of occupiers, restitution, bankruptcy over security and a consultation on mortgagee's power of sale.

Is rent payable as an expense of administration?

The High Court's decision in Goldacre (Offices) Limited v Nortel Networks UK Limited (in administration) provides welcome confirmation that rent for premises used for the benefit of creditors must be paid as an expense of the administration.

What lies beneath

Sky proves fraud against EDS

The long-awaited judgment of Mr Justice Ramsey in the case of BSkyB Limited (Sky) v  Electronic Data Systems Limited (EDS) was handed down yesterday with EDS, now owned by Hewlett Packard, found liable for deceit, misrepresentation and breach of contract.

Alternative Investment Fund Managers Directive - update

In May 2009 Wragge & Co's Funds team reported on the EC's draft proposal for a directive on Alternative Investment Fund Managers (the Commission's Proposal).

Dr Reddy v Eli Lilly: the Court of Appeal consigns the old UK legal test for the validity of selection patents to history and looks to Europe for the answer

Dr Reddy's challenge to the validity of Eli Lilly's patent for Olanzapine has failed in the Court of Appeal.

Terms to be imposed into supplier:retailer grocery contracts

On 4 February 2010 the Groceries (Supply Chain Practices Market Investigation) Order 2009 (the Order) comes into effect.

Words, words, words: the use of general words to incorporate arbitration provisions

In Habas Sinai VE Tibbi Gazlar Isthisal Endustri A.S. v Sometal S.A.L., Mr Justice Christopher Clarke considered whether the use of general words of incorporation were capable of incorporating an arbitration clause into the parties' agreement.

Public equity financing: a new era?

2008 and 2009 were notoriously lean years for public listings in the UK. However, 2010 could bring a new era of popularity for initial public offerings (IPOs) as companies look for alternatives to the continuing challenging debt market.

Reporting under POCA - the need for a human process and clear audit trail

The decision of the Court of Appeal in Shah & another v HSBC Private Bank (UK) Ltd will give lenders some cause for concern.

Feathering the NEST egg - the final shape of workplace pension reform

Costly changes are coming which will affect employers and pension schemes.

'Fit notes' to be introduced from 6 April

The demise of the sick note as we have known it for more than 60 years is nigh! The existing sick note will be replaced with a new Statement of Fitness for Work, the so-called 'fit note'.

Not so fine! £500,000 fine for corporate manslaughter and £100,000 fine for health and safety offences causing death.

Fines of seldom less than £500,000 and £100,000 respectively will be handed out to organisations guilty of corporate manslaughter and health and safety offences causing death under the Sentencing Guidelines Council's guidelines published on 10 February.

Upstream without a paddle

The Court of Appeal has found in Eli Lilly and Company v Human Genome Sciences Inc that HGS' patent for a protein called by HGS "Neutrokine-a", antibodies to it and the polynucleotide sequence encoding for it was invalid for lack of industrial application.

Property Update - February 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

Dilution of vodka prevented by High Court

In the Diageo North America, Inc r v Intercontinental Brands case the owners of the famous 'Smirnoff' brand of vodka have succeeded in establishing extended passing off against InterContinental Brands in respect of its Vodkat alcoholic beverage.

Before you charge in - part 2. Governing law and jurisdiction - how to save yourself a headache at the outset

Any contract of substance, and certainly one with an international element, should contain both a governing law and a jurisdiction clause. Consider the following tips on what to think about when drafting these clauses.

Defined Contribution - focus on investment governance

Although nine years have passed since the Myners' Principles were first introduced, concerns remain about investment governance in pensions.

Purdah - public bodies in the pre-election period

With the next general election looming, Wragge & Co's Public Law and Regulation team considers the implications for decision-making by central and local government and other public authorities.

Two contracts, two clauses - what happens?

On 12 February 2010, the English Commercial Court handed down a helpful judgment in Norscot Rig Management PVT Limited -v- Essar Oilfields Services Limited.

Banking update: report and review on recent cases and issues

Obtaining information despite stay of enforcement, the need to act in good faith, recoverability of costs in small claims, penalty for destroying documents and a consultation on orders for sale for Consumer Credit Act debts.

An end to the AGA Saga?

The High Court has ruled on one of the most fiercely debated questions arising out of the Landlord and Tenant (Covenants) Act 1995.

Consultation on supermarket regulator

The Groceries (Supply Chain Practices Market Investigation) Order 2009 (GSCOP) came into effect on 4 February 2010. The Order requires certain supermarkets to have written terms with the majority of their suppliers of goods for resale in place.

Premium and Standard Listings: the two-tier UK Listing Regime

Companies looking at a stock market quotation now have a wider choice of listing category to consider as the Official List, the London Stock Exchange's main market for listed securities, now has two tiers: a premium and a standard listing.

Local authorities: the new generators?

It is widely acknowledged that the UK Government's targets for tackling climate change are incredibly challenging. It is also universally accepted that local authorities will have a key role to play in efforts to tackle climate change.

The innocent purchaser v the innocent finance company: who gets better title?

Nemo dat quod non habet or, as they say in English, no one can pass better title to goods than they possess. But there are exceptions to this principle of English law.

Reproduction of Opel logo on imitation toy cars does not infringe trade mark rights

The ECJ's ruling in the Opel v Autec toy cars case in January 2007 was a landmark in European trade mark law. The case is always referred to whenever the question of whether "trade mark use" is required to establish trade mark infringement arises.

What do you do when you haven't got time to consult?

Real life and legal obligations - not always a happy mixture. In real life things don't go to plan - customers change their minds and demand changes in your work plan. Suddenly you don't need as many people or for as long as you expected.

FIT and RHI: new acronyms to conjure with

As if energy, and renewable energy incentive schemes in particular, wasn't complicated enough already, two new schemes (and their obligatory acronyms) are due to be introduced in the next year or so.

Through the Looking Glass: make sure your liability clause means what you want it to mean

"When I use a word," Humpty Dumpty said in a rather scornful tone, "it means just what I choose it to mean, neither more nor less" (Lewis Carroll, Alice, Through the Looking Glass).

Rights of residency of child's primary carer

The European Court of Justice has handed down two key decisions regarding the rights of residency for primary carers of children in education.

Former directors who set up in competition: the first post-Companies Act 2006 case comes to light

A transcript has just been released of a company law case decided last year: Thermascan Limited v Norman.

Property Update - March 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

Tricky trade mark issues - toy shapes and trading names

In the Cipriani SRL & Ors v Cipriani (Grosvenor Street) Ltd & Others case, the English Court of Appeal has provided guidance on what is required for a business located elsewhere to have goodwill in England which is sufficient enough to base a passing off action on.

Before you charge in - part 3. Entire agreement clauses - how effective are they?

When negotiating a contract, should you be including an entire agreement clause? If so, how do you make sure it does what you want it to?

'Round up' on the scope of DNA patents - Monsanto Technology LLC v Cefetra BV and Others

A leading edge patent law hot potato is patents for DNA sequences. It appears that the protection offered by such patents in the EU may be more restrictive than many anticipated.

A Budget for Recovery?

The Budget 2010 was billed as "Securing the Recovery", but is perhaps better branded as a "Budget for First-Time Buyers".

Banking update: report and review on recent cases and issues

A defendant making a "claimant" part 36 offer, considerations of an unfair relationship, payment starts time running again and good reason required for failure to attend trial.

A 'Green' Budget, but is it green enough?

A new Green Investment Bank aimed at funding low carbon transport and energy schemes, such as nuclear power stations and wind farms, has been trailed in the press for a few weeks now. And it has appeared in Alistair Darling's pre-election Budget.

Consultative Decision Making & Delayed Take Off - R (on the application of Hillingdon Borough and others) v Secretary of State for Transport

On 26 March the High Court gave judgment in the case of R (on the application of Hillingdon Borough and others v Secretary of State for Transport) - a judicial review of the Government's decision to continue its support for the construction of a third runway at Heathrow Airport.

Debt on employer evolves again

Following last Autumn's consultation on draft regulations which would prevent a Pensions Act 1995 section 75 debt being triggered in two new sets of circumstances, final regulations have been laid and are due to come into effect on 6 April.

Online vetting - reputations on the line?

In a Microsoft-commissioned survey, 47% of UK recruiters and HR professionals stated that they look for online reputational data to vet candidates. And, 41% had rejected candidates based on information found online.

Limiting the spread of contamination... and its legal consequences

Most people are aware that it's a criminal offence to cause or knowingly permit pollution to occur. But it's not just a prosecution by the Environment Agency that companies need to be concerned about.

Compulsory prompt payment - of subbies!

From 25 March 2010, all government departments, agencies, non-departmental public bodies (and the bodies over which they have direct control) will be required to include a contract condition requiring their contractors to pay their subcontractors within 30 days.

Take action - Trade marks can be infringed by a competitor's internet keyword use (but Google claims a victory anyway).

The European Court of Justice (ECJ) has given judgment in four cases concerning alleged trade mark infringement via Google's adwords internet advertising service.

The Bribery Bill

Major changes to UK law governing bribery are afoot. A draft bill is expected to receive Royal Assent before the next general election, with general offences coming into force in June 2010.

Changes to Tier 1 and Tier 2 of the PBS - effective as of 6 April 2010

The UK Border agency has introduced a number of technical changes effective today to the Points-Based System (PBS) that affect all those involved in employer/employee relationships under Tiers 1 and 2.

Purdah - Changes to general election guidance

The announcement of the general election on 6th April 2010 marked the start of the purdah period and the publication of the new Cabinet Office General Election 2010 Guidance.

On the hook: how contractors may be liable for defects up to 15 years from completion of the works

How long can a contractor be on the hook for defective works under a building contract?

Energy Act receives Royal Assent

The Government has met its ambitious legislative timetable, as one of the final actions taken by the current Parliament during the "wash-up" period was to pass the Energy Bill, which received Royal Assent on 8 April 2010.

Civil Service Compensation Scheme - changes introduced on 1 April 2010

The Civil Service Compensation Scheme (CSCS) is a statutory scheme that provides compensation to certain civil servants who leave office through compulsory or voluntary redundancy.

Property Update - April 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

Theseus, George Washington's axe and patents for a caged bottle - could you make it up?

Floyd J decision in Schütz (UK) Ltd v Werit UK Ltd & Another.

Goodbye Tolent clause, hello Scheme

Since 2000, clauses requiring the referring party in an adjudication to pay all the legal and expert costs of both parties, plus the costs of the adjudicator, have been held not to offend the Housing Grants, Construction and Regeneration Act 1996 (HGCRA).

Agency workers and pensions: there's no escaping 2012 Workplace Pension Reform!

The Agency Workers Regulations 2010 (the Regulations) are due to come into force in October 2011. This is the Government's way of achieving "flexisecurity" for agency workers.

Homelessness decisions: minded to find or not?

Local housing authorities face considerable difficulties when deciding whether to send a "minded to find" letter pursuant to regulation 8(2) of the Allocation of Housing and Homelessness (Review Procedures) Regulations 1999/71.

Fund management fees and carried interest

It has always been important when structuring a fund to ensure that the fund manager is adequately incentivised to obtain the best returns for investors.

Before you charge in - part 4. Limitation - is the clock ticking?

The question of limitation is relevant to all legal disputes. If the rules on limitation are not followed, a party who has suffered a wrong at the hands of another may be time-barred from seeking a remedy.

Banking update: report and review on recent cases and issues

An order for sale and Convention considerations, undue influence, implied withdrawal of a Part 36 offer and reasonableness of after the event insurance premiums.

Liability of issuers in connection with published information – an extension of the regime

Issuers of securities admitted to trading on regulated markets are liable for fraudulent misstatements in periodic disclosures to the market. They are also liable for any dishonest concealment of a material fact in such publications.

Settlement and litigation costs: when refusing to talk doesn't pay

A successful party which fails to enter into settlement negotiations following an offer to settle may be deprived of a substantial proportion of its costs.

The limits of fairness in public law - the Sharon Shoesmith case

Sharon Shoesmith was Director of Children and Young People's Services (the DCS) for Haringey Borough Council during the short life of Peter Connelly (Baby P). The judgement concerning her termination of employment contains important legal analysis of the concept of "fairness".

The Late Payment of Commercial Debts Act - what constitutes "substantial"?

Many contracts contain provisions which allow the supplier of goods or services to charge interest if they are not paid in time - a right which in the current economic climate might be getting more attention than usual.

General election manifestos and supermarket regulation - a 'blow' for democracy?

Last week, the Labour Party, Conservatives and the Liberal Democrats rolled out their manifestos ahead of the general election on 6 May 2010.

Each manifesto alludes to the GSCOP which came into force on 4 February 2010 through The Groceries (Supply Chain Practices) Market Investigation Order 2009.

Construction fatal accidents: directors beware?

Directors of construction companies should take note that the current Government has accepted several recommendations in Rita Donaghy's report, "One Death is too Many", on construction fatalities.

Who is in charge this morning?

With Britain waking up to the reality of a hung parliament, Wragge & Co's public law experts consider the legal implications and likely outcomes of the election result.

Common sense interpretation of Part 36 offers

In any litigation, considering offers of settlement is crucial. If you make an offer under part 36 of the Civil Procedure Rules and your opponent does not accept it but then fails to obtain a more (or equally) advantageous outcome at trial, you are likely to be awarded your costs.

Property update - May 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

Goodbye Tolent clause, hello Scheme

For the last ten years construction contracts providing for one party to pay not only its own costs but also the other side's costs in an adjudication (whatever the outcome) have been accepted in the construction industry.

Successful challenge - Public and Commercial Services Union (PCS) obtains judgment that changes to the Civil Service Compensation Scheme (CSCS) are unlawful

The PCS (a trade union representing large numbers of civil servants) has successfully challenged the legality of certain changes made to the CSCS. The changes to the CSCS will now be set aside and sent back to the decision makers to be remade in light of the court's findings.

Utility companies and environmental information - pulling the plug

Until recently, most utility companies believed that they had a legal duty to make a range of environmental information available to the public. The Information Commissioner said that this was the effect of the Environmental Information Regulations 2004.

Competition law and land agreements: as safe as houses?

Are your land agreements facing an uncertain future?

Before you charge in - part 5. When and how to challenge public procurement contracts

When you bid for a public contract, what can you do if the rules have been breached? 

Banking update: report and review on recent cases and issues

What constitutes actual occupation, no claim against Court Services for failure to register bankruptcy petition, getting the name of the parties correct and clear reasoning required for court's decision.

Court of Appeal reluctantly applied the ECJ's guidance in L'Oreal v Bellure

The Court of Appeal has today handed down its long-awaited decision in L'Oreal v Bellure. The decision implements the responses given by the European Court of Justice (ECJ) (as it then was) in June 2009 to questions referred to it by the Court of Appeal.

Contrasting approaches

The general election produced a hung Parliament, with the prospect of politicians having to work together despite contrasting policies.

Local authority litigation update

With cuts to public spending high on the current political agenda, the focus on litigation issues for local authority in-house lawyers increases too.

Workplace pension reform: the devil in the detail

From 2012 all employers will have to enrol all eligible workers into a pension scheme. For the first time employer contributions will be mandatory.

Tort strikes back: subcontractors' liability for pure economic loss

Can a subcontractor or supplier employed to carry out works or supply goods to a contractor in relation to a construction project, owe a duty of care and be liable for the damage caused to the building by its defective works to anyone other than its employer?

Tomlin schedule not variable

In the case of Community Care North East v Durham County Council, Ramsey J held that the court did not have the power to vary terms within a schedule to a Tomlin Order.

Failure to settle can have significant costs consequences

Failure to make settlement offers or negotiate with an opponent at an appropriate time in the proceedings can lead to the defaulting party being penalised in costs.

Company law and corporate governance

Following a review of corporate governance by the Financial Reporting Council a new corporate governance code, 'the UK Corporate Governance Code' (previously the Combined Code), has been published.

High earners and pensions

High earners need to consider carefully their pension arrangements. This is because Mr Darling, when he was Chancellor of the Exchequer under the last administration, paved the way for the introduction of a new charge on pension contributions.

Before you charge in - part 6. Dispute resolution clauses – one size does not fit all

In this the sixth part of our 'before you charge in' series, we set out the broad features of the main dispute resolution methods and the situations in which they may be appropriate.

The Equality Act 2010 – 10 things you need to know

The long awaited Equality Act 2010 received Royal Assent on 8 April 2010. The primary aim of the Act is to consolidate and harmonise the existing equality legislation. However, it will also introduce some significant new provisions.

Property update - June 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

£4.3 million compensation for an 'unfair' dismissal

The Court of Appeal decision in Edwards v Chesterfield Royal Hospital NHS Trust will be of particular concern for employers with contractual disciplinary and grievance procedures – most notably the NHS and other public sector employers.

'Overspent, not overtaxed' - the Emergency Budget

George Osborne delivered his first fiscal statement as Chancellor of the Exchequer in today's Emergency Budget. As with all emergencies, we saw the flashing blue lights of tax-raising headlines and triage to deal with the wreckage of the structural deficit in the British economy.

Banking update: report and review on recent cases and issues

Wragge & Co's Banking and Finance experts bring you the latest on the cases and issues affecting the lending industry.

The Coalition Government's first Budget - high earners and pensions: an update

Mr Osborne delivered his first budget amid much speculation as to precisely what he would do with regard to various issues in the pensions arena, particularly the restriction of tax relief on pension contributions for "high earners".

'Henry' gets a clean win in the High Court

Numatic was successful in its claim of passing off against Qualtex in respect of Qualtex's vacuum cleaners which mimicked the basic Henry model shape and black bowler hat lid but not its surface decoration (smiley face and red colour ways).

US Supreme court hedges its bets and fails to deliver clarity in business methods case

The US Supreme Court gave judgment on Monday 28 June 2010  in the long awaited Re Bilski case concerning the patentability of business methods.

Publish or be damned - failure to comply with announcement obligations can be a costly oversight

Photo–me International is the latest in a growing list of companies to be fined by the City watchdog, the Financial Services Authority, for late disclosure of inside information.

UK cap on migrant workers entering the UK

The number of workers entering the UK from outside Europe will be controlled by a new limit the Home Secretary, Theresa May, announced on 28 of June 2010.

Court of Appeal brings some clarity to part 36

Part 36 offers are one of the most important tactical steps which parties (claimant or defendant) can take during a dispute. They provide a means of putting pressure on an opponent to settle a case or face potential costs and interest consequences.

The bark becomes a bite: first contribution notice issued

The Pensions Regulator has issued its first contribution notice (CN).

Conditions precedent: when clear drafting can save you time and money

A condition precedent is a clause in a contract that provides that the contract, or certain obligations in the contract, will only be enforceable if and when certain conditions are met.

A tax cloud hanging over Luxembourg real estate funds invested in France

The concept of partnership as defined in French tax law is currently changing. This is prompting fears with regards to the evolution of the taxation on capital gains on the disposal of shares in a partnership whose assets consist mainly of real estate.

The Companies Act 2006 and directors' duties

We should remind ourselves that being a company director is a wonderful thing for the person who is a company director.

The scope of DNA patents - ECJ's decision in Monsanto v Cefetra

The Court of Justice of the European Union (CJEU) handed down its decision on the scope of protection to be afforded to DNA sequence patents. 

Medeva's SPC applications: the Court of Appeal refers questions to the ECJ

There has been a dispute concerning whether Medeva BV was entitled to obtain supplementary protection certificates for its whooping cough vaccine.

Cash in the static?

Picture the scenario. A company is adversely affected by the implementation of government policy, but it is not possible in law to challenge the policy decision. And, it would not be helpful in practice to reverse it. What happens? Can an alternative case for financial compensation be created?

Global enterprise signals global financial support direction

We've only just witnessed the Pensions Regulator's first contribution notice. Now we're looking at its second financial support direction (FSD) exercise (the last time it issued any FSDs was in 2008 in respect of two Sea Containers pension schemes).

Ambush marketing – did it all kick off in South Africa?

So, the World Cup is almost over. Spain or the Netherlands will be the victors on the pitch, but who has triumphed in marketing terms? The official sponsors, which have paid many millions for the privilege? Or, the companies seeking to develop an unofficial connection by ambush marketing?

I want my postage back! Delivery Charge refunds under Distance Selling Regulations

The Distance Selling Regulations have been in force for almost 10 years now, but some thorny issues keep coming up. And whether or not retailers are required to refund delivery charges appears to be one of them, following an investigation carried out by the BBC.

The Health White Paper - A revolution for the better?

On Monday 12 July 2010 the new Coalition Government published its first White Paper on Health.

Personal Information Online: new Code of Practice published by the ICO

The Information Commissioner's Office (ICO) released a new Code of Practice on 8 July 2010 entitled "Personal Information Online".

Goodbye RPI?

The Government has announced that from 2011 (by reference to 30 September 2010) it plans to use the consumer prices index (CPI) rather than the retail prices index (RPI) for statutory revaluation of deferred pensions and statutory pension increases on pensions in payment.

Banking update: report and review on recent cases and issues

The meaning of charge for credit, enforcing charging orders, abuse of process considerations, tracing claims and the Financial Service Authority's responsible lending consultation; Wragge & Co's Banking and Finance experts bring you the latest on the cases and issues affecting the lending industry.

Before you charge in - part 7. Confidentiality agreements - are they worth the paper they are written on?

Obligations of confidence arise because of the relationships between parties (e.g. between MI5 and a field operative), or because of the circumstances of disclosure (e.g. an inventor revealing the secret designs of a new product to an investor or two parties collaborating in a joint venture).

The importance of compliance after Buncefield

There doesn't have to be a fatal accident for a large fine to be imposed on an organisation for breaches of duty relating to health, safety and environmental law.

Property update - July/August 2010

Wragge & Co's real estate experts bring you the latest property law issues. Read their comment on these issues and take note of any action points that will help you and your organisation.

IP update - from life-saving drugs to luxury scents

The Patents Court has considered Yeda Research Development Ltd's appeal from the Comptroller who refused to grant it Supplementary Protection Certificates (SPCs) in respect of its combination treatment for tumours.