Internal audit

report 2020/2021

Primary Care Finance

Berkshire West CCG
Final
February 2021

Click to launch
Executive summary Background and scope Current year findings Appendices

Contents

1. Executive summary 3

2. Background and scope 6

3. Current year findings 7

Appendices 12

Appendix A: Basis of our classifications 13

Appendix B: Terms of reference 15

Appendix C: Limitations and responsibilities 16

Distribution list

For action: Helen Clark (Director of Primary Care)

For information: Rebecca Clegg (Chief Finance Officer)

Stuart Ireland (Senior Finance Manager)
Sarah Wise (Primary Care Contracts Manager)
Audit Committee (Final Only)

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Executive summary (1 of 3)

Total number of findings: 4

Report classification

Medium Risk (8 point) Critical High Medium Low Advisory

Control design – – 2 2 –

Operating effectiveness – – – – –

Trend Total – – 2 2 –

Consistent with our previous

review of Primary Care Finance Summary of findings – Please see appendix A for the basis of our report classifications
Areas which relate to business as usual Primary Care Finance processes:

The last time we reviewed Primary Care Finance the

1. Delegated authorities for contract and discretionary payments Low
CCG was given full assurance on the NHSE Internal
Audit rating scale. Although this report is rated as
medium risk overall, the elements which relate to
business as usual Primary Care Finance processes 2. Timeliness of premises rent reviews Low
are low risk, which also equates to full assurance on
the NHSE scale.

This is also in line with the national average. Of the Areas relating to Covid-19 reimbursements which management requested to be included in the review:
22 CCGs which have received Internal Audit ratings
for Primary Care Finance, 73% have been given
1. Financial controls over Covid-19 reimbursement claims Medium
substantial assurance and 27% have been awarded
full assurance.

2. Covid-19 reimbursements outside of NHS guidance Medium

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Executive summary (2 of 3)
Summary of findings
This review was undertaken as part of the 2020/21 Internal Audit Plan agreed with the Audit Committee.

During our review we identified a number of examples of good practice relating to Primary Care Finance, including:
• The CCG has effective procedures for the reporting of delegated funds and the Primary Care Commissioning Committee has effective oversight over the use of these funds.
• The CCG has established policies and processes for the validation and approval of payments made to practices.
• We performed testing of 25 GP contract payments and a further 25 ‘discretionary payments’ (including rent reimbursements, locum cover for sickness and maternity, water rates and
DES participation payments) and note that segregation of duties was in place in all cases.
• We note that all contract and discretionary payments tested were accurately coded, in line with the National Chart of Accounts.

Our review identified two medium rated risk and two low risk rated findings as follows:

As part of this review, we have selected and tested Covid-19 reimbursements made to practices. We recognise Covid-19 was an emergency situation not just for the CCG, but also for the
NHS as a whole and during this time, the CCG’s focus and priority was to ensure resources were allocated to the necessary areas and without delay. This included ensuring claims for
reimbursement were processed quickly, which was in line with Sir Simon Steven’s letter to all GP practices, CCGs and Trusts in March 2020. We also note the response to Covid-19 was
made more challenging by a lack of detailed national guidance relating to reimbursements during this time.

Financial controls over Covid-19 reimbursement claims (Medium Risk)

• Between May - September 2020, the CCG had reimbursed practices just over £1m in Covid related expenses, including for personal protective equipment, cleaning and additional
staffing hours. As part of our testing of Covid reimbursements, we sampled 25 reimbursements amounting to £324k. These payments were included in the Primary Care Budget.
• Claims for Covid reimbursement were sent directly to the Finance department at the CCG and reviewed and approved by the Senior Finance Manager before being processed and
as such, segregation of duties between the person raising the payment and the person approving the payment was absent in this process. We also note that 15 payments were
included in payment schedules which exceeded the Senior Finance Manager’s delegated authority limit of £100k. These payments were for claims submitted between April and July.
Furthermore, although practices were instructed to retain all supporting evidence (including invoices, purchase orders and timesheets) for future audit purposes, they were not
required to provide this evidence at the time of submitting the claims for reimbursement. We also note 1 claim for £10k where the claim form was not signed or dated. In a further 2
claims for £50k and £46k, claim forms were not completed at all, although invoice breakdowns were provided by the practice.
• We understand that changes to the way in which Covid reimbursement claims are processed and approved have now been implemented by the CCG. Including, ensuring
segregation of duties is in place and additional layers of approval. We would also recommend that supporting evidence should be requested from practices when they submit a
reimbursement claim and this evidence should be agreed to the claim form.

Covid-19 reimbursements outside of NHS guidance (Medium Risk)

NHS Guidance:
• We recognise Covid-19 was an emergency situation for the CCG and the response was made more challenging by a lack of detailed national guidance relating to reimbursements
during this time. Detailed guidance did not become available until 4th August and was applied retrospectively, after claims for reimbursement had already been processed.
• Although we recognise that the guidance was issued late, we have assessed previous claims against the parameters set in the guidance in order to inform future reimbursement
decisions. From a review of 25 Covid-19 claims, we have identified £14k worth of expenses which were for items we wouldn’t normally expect to be reimbursed and were outside of
the parameters set in the NHS guidance. We note that since August 2020, the CCG has introduced a requirement so claims for items >£500 now need prior approval.

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Executive summary (3 of 3)
Summary of findings

Covid-19 reimbursements outside of NHS guidance (Medium Risk) – Continued

Covid assessment pods:
• Practices were able to claim reimbursement for ‘additional capacity from existing practice staff’, including hours that staff spent working in Covid assessment pods. Of the 25 claims
reviewed, we identified 2 claim forms from the same practice which claimed for all hours that staff on zero hour contracts worked in the assessment pods over a two month period,
resulting in all 903 hours being reimbursed. We recognise that the detailed NHS guidance did not become available until August 2020 and as such we recommend that for future
claims for staff on zero hour contracts, the reimbursable hours are separated from ‘normal capacity’ (i.e. the hours the staff members worked prior to the start of the pandemic), as
this represents the regular staffing costs that the practice should still incur.
• We also identified one instance where a practice claimed for the same hours in three different claim forms. This is because the hours were cumulatively recorded on each new form
and each claim was reimbursed in full and therefore led to a total overpayment of £7,445. Since we raised this issue to management, the full amount of the overpayment has been
recovered from the practice. We note that this was the only duplication we identified from testing performed.

Delegated authorities for contract and discretionary payments (Low Risk)

• We tested a sample of 25 GP contract payments and a further 25 discretionary payments, including rent reimbursements, locum cover for sickness and maternity, water rates and
DES participation payments and note that in all cases, adequate segregation of duties was in place between the individual raising the payment and individual approving the
payment. However, we note that the payment schedules were approved by the Senior Finance Manager and in excess of their delegated authority limit of £100k. We note that the
preparation, review and approval of the payment schedules are a routine monthly process. Furthermore, the Financial Procedures Handbook states that the Senior Finance
Manager has an approval limit of up to £10m for GP payment schedules and as such, the Scheme of Delegation should be amended to reflect this.

Timeliness of premises rent reviews (Low Risk)

• We tested a sample of 5 premises cost rent reimbursement agreements and note that in one case, the last rent review was conducted in April 2017 and had yet to be completed at
the time of fieldwork. According to the British Medical Association, rent reviews should be conducted at least every three years. Although we note that rent reviews are coordinated
and managed by the Commissioning and Support Unit and the CCGs involvement in these processes is usually limited, the CCG should be aware of the risk of more agreements
becoming out of date and the potential for a backlog of reviews needing to be undertaken, especially given the impact of Covid and the reduced capacity within the District Valuers
Office over this period.

We would like to take this opportunity to thank all CCG staff who assisted with this review.

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Background and scope

This review was undertaken as part of the 2020/2021 internal audit plan approved by the Audit Committee.

Background and audit objectives

On the 22 August 2018 NHS England published the Primary Medical Care Commissioning and Contracting: Internal Audit Framework for delegated Clinical Commissioning Groups.
As part of this there is a formal requirement for an annual audit of primary care provision that must cover the following four areas over the course of a three year cycle:
• Commissioning and Procurement of Services;
• Contract Oversight and Management Functions;
• Primary Care Finance; and
• Governance (common to each of the above areas).

It has been agreed with members of the Audit Committee and management that this year’s audit will focus on Primary Care Finance. Due to the increased risk resulting from Covid-
19, it has been agreed with management that we will also review a sample of reimbursements to practices for Covid-19 related expenses.

The Framework contains additional audit reporting requirements which need to be complied with. The audit’s overall risk rating (low, medium, high, and critical) must now be aligned
to one of four assurance levels used by NHS England:
• Full;
• Substantial;
• Limited;
• No assurance.

The Framework mandates that the Primary Care Commissioning Committee should have a lead role in discussing and agreeing the report prior to being presented to the Audit
Committee. Therefore, the final report will go to a meeting of the Primary Care Commissioning Committee. In addition to consideration by the Audit Committee the report’s overall
rating should be discussed at a Governing Body in public and the CCG must report the report’s overall rating, using one of the four assurance levels outlined above, to NHS England
within one month of the report being finalised.

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Current year findings (1 of 4)

Finding and root cause

1 Financial controls over

Covid-19 reimbursement
claims
Between May and September 2020, the CCG had reimbursed practices just over £1m in Covid related expenses, including for
personal protective equipment, cleaning and additional staffing hours. As part of our testing of Covid reimbursements, we
sampled 25 Covid reimbursements amounting to £324k. These payments were included within the Primary Care budget.

Claims for Covid reimbursement were sent directly to the Finance department at the CCG and reviewed and approved by the
Senior Finance Manager before being processed and as such, segregation of duties between the person raising the payment and
the person approving the payment was absent in this process. We also note that 15 payments were included in payment
schedules which exceeded the Senior Finance Manager’s delegated authority limit of £100k. These payments were for claims
Control design submitted between April and July. We note that guidance was issued instructing Commissioner’s to make ‘payments promptly’
and these financial controls were not applied in an effort to ensure claims for reimbursement were processed without delay.

Furthermore, although practices were instructed to retain all supporting evidence (including invoices, purchase orders and
timesheets) for future audit purposes, they were not required to provide this evidence at the time of submitting the claims for
Finding rating reimbursement and instead this was arrangement was on a ‘trust’ basis with the practices.

We also note 1 claim for £10k where the claim form was not signed or dated. In a further 2 claims for £50k and £46k, claim forms
Rating Medium were not completed at all, although invoice breakdowns were provided by the practice.

We understand that changes to the way in which Covid reimbursement claims are processed and approved have now been
implemented by the CCG. Including, ensuring segregation of duties is in place and additional layers of approval.

Implications

Financial controls, including segregation of duties, appropriate approval levels and inspecting supporting evidence ensures
payments are valid, appropriate and increases the likelihood of errors being detected and corrected on a timely basis.

Action plan

• Covid reimbursement payment schedules should be Responsible person/title: Stuart Ireland (Senior Finance
prepared by the Senior Finance Manager and then Manager)
reviewed and approved by the CFO.
• Supporting evidence should be requested from practices Target date: N/A – Actions already implemented
when they submit a reimbursement claim and this evidence
should be agreed to the claim form. Reference number: 20-21-PCC-01
PwC Internal audit report – 2020/2021
Executive summary Background and scope Current year findings Appendices

Current year findings (2 of 4)

Finding and root cause

2 Covid-19 reimbursements
outside of NHS guidance
NHS Guidance
We recognise Covid-19 was an emergency situation not just for the CCG, but also for the NHS as a whole and during this time,
the CCG’s focus and priority was to ensure resources were allocated to the necessary areas and without delay. This included
ensuring claims for reimbursement were processed quickly, which was in line with Sir Simon Steven’s letter to all GP practices,
CCGs and Trusts in March 2020. We also note the response to Covid-19 was made more challenging by a lack of detailed
national guidance relating to reimbursements during this time. Detailed guidance did not become available until 4th August and
was applied retrospectively, after claims for reimbursement had already been processed.
Control design Although we recognise that the guidance was issued late, we have assessed previous claims against the parameters set in the
guidance in order to inform future reimbursement decisions. Section 20 of the Covid-19 support fund for general practice (August
2020) states that 'reimbursement may be sought for net additional costs incurred as a result of Covid-19 requirements, including
the costs of minor physical adjustments to buildings (eg Perspex screens and barriers), additional cleaning materials, and
additional clinical equipment (eg pulse oximeters and thermometers)’.
Finding rating
From a review of 25 Covid-19 claims, we have identified £14k worth of expenses which were for items we wouldn’t normally
expect to be reimbursed and were outside of the parameters set in the NHS guidance. The NHS guidance also states that where
Rating Medium items being claimed for reimbursement are outside of the example expenses listed, the CCG should contact their region for
advice first, however, such consultations did not take place.

We note that since August 2020, the CCG has introduced a requirement so claims for items >£500 now need prior approval.

Covid assessment pods

Practices were able to claim reimbursement for ‘additional capacity from existing practice staff’, including hours that staff spent
working in Covid assessment pods. We note that this requirement did not apply to clinical leads. Of the 25 claims reviewed, we
identified 2 claim forms from the same practice which claimed for all hours that staff on zero hour contracts worked in the
assessment pods over a two month period, resulting in all 903 hours being reimbursed. We recognise that the detailed NHS
guidance did not become available until August 2020 and as such we recommend that for future claims for staff on zero hour
contracts, the reimbursable hours are separated from ‘normal capacity’ (i.e. the hours the staff members worked prior to the start
of the pandemic), as this represents the regular staffing costs that the practice should still incur.

We also identified one instance where a practice claimed for the same hours in three different claim forms. This is because the
hours were cumulatively recorded on each new form and each claim was reimbursed in full and therefore led to a total
overpayment of £7,445. Since we raised this issue to management, the full amount of the overpayment has been recovered from
the practice. We note that this was the only duplication we identified from testing performed.

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Current year findings (2 of 4)

Implications

2 Covid-19 reimbursements
outside of NHS guidance
Claims outside of the NHS guidance may not be appropriate, represent value for money or be justified. It may also not be
appropriate for the CCG to fully reimburse expenses which provide a significant residual benefit to the practice beyond any
response to Covid-19.

Action plan

• Now that the Government guidance is clear, future Responsible person/title: Rebecca Clegg (Chief Finance
reimbursements should be in line with this guidance. Officer)
Control design
Target date: March 2021

Reference number: 20-21-PCC-02

Finding rating

Rating Medium

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Current year findings (3 of 4)

Finding and root cause

3 Delegated authorities for

contract and discretionary
payments
We tested a sample of 25 GP contract payments and a further 25 discretionary payments, including rent reimbursements, locum
cover for sickness and maternity, water rates and DES participation payments and note that in all cases, adequate segregation of
duties was in place between the individual raising the payment and individual approving the payment.

However, we note that the payment schedules were approved by the Senior Finance Manager and in excess of their delegated
authority limit of £100k. We note that the preparation, review and approval of the payment schedules are a routine monthly
process. Furthermore, the Financial Procedures Handbook states that the Senior Finance Manager has an approval limit of up to
£10m for GP payment schedules and as such, the Scheme of Delegation should be amended to reflect this.
Control design
Implications

The Scheme of Delegation should be updated to ensure that this is accurately reflects routine processes and is consistent with
the Financial Procedures Handbook.
Finding rating
Action plan
Rating Low
• The Scheme of Delegation should be updated to reflect the Responsible person/title: Noreen Kanyangarara (Senior
approval limits for routine GP payment schedules. Finance Manager)

Target date: March 2021

Reference number: 20-21-PCC-03

PwC Internal audit report – 2020/2021

Executive summary Background and scope Current year findings Appendices

Current year findings (4 of 4)

Finding and root cause

4 Timeliness of premises rent

reviews
We tested a sample of 5 premises cost rent reimbursement agreements and note that in all cases, an outcome letter was issued
and the outcome was agreed by the practice.

However, for one of the agreements tested, the last rent review was conducted in April 2017 and had yet to be completed at the
time of fieldwork. According to the British Medical Association, rent reviews should be conducted at least every three years.
Although we note that rent reviews are coordinated and managed by the Commissioning and Support Unit and the CCGs
involvement in these processes is usually limited, the CCG should be aware of the risk of more agreements becoming out of date
and the potential for a backlog of reviews needing to be undertaken, especially given the impact of Covid and the reduced
Control design capacity within the District Valuers Office over this period.

Implications

If rent reviews are out of date, then current reimbursement arrangements may not reflect market values and practices may not be
Finding rating reimbursed the full amounts to which they are entitled. However, we note that adjustments to rent review amounts can be
retrospectively applied and paid.

Rating Low Action plan

• The CCG should continue to monitor the overall progress of Responsible person/title: Stuart Ireland (Senior Finance
rent reviews being conducted and intervene where Manager)
necessary i.e. if more rent reviews become out of date.
Target date: March 2021

Reference number: 20-21-PCC-04

PwC Internal audit report – 2020/2021

Appendix A: Basis of our classifications Appendix B: Terms of reference Appendix C: Limitations and
responsibilities

Appendices
Appendix A: Basis of our classifications Appendix B: Terms of reference Appendix C: Limitations and
responsibilities

Appendix A: Basis of our classifications

Individual finding ratings

A finding that could have a:
Critical
• Critical impact on operational performance resulting in inability to continue core activities permanently ; or
• Critical monetary or financial statement impact of greater than £1m; or
• Critical breach in laws and regulations that could result in material fines or consequences greater than £1m; or
• Critical impact on the reputation or brand of the CCGs which could threaten its future viability, e.g. high-profile political and media scrutiny, i.e. front-page headlines
in national press.

A finding that could have a:

High
• Significant impact on operational performance resulting in significant disruption to core activities; or
• Significant monetary or financial statement impact of between £500k and £1m; or
• Significant breach in laws and regulations resulting in significant fines and consequences between £500k to £1m; or
• Significant impact on the reputation or brand of the CCGs, resulting in unfavourable national media coverage.

A finding that could have a:

Medium
• Moderate impact on operational performance resulting in moderate disruption of core activities or significant disruption of discrete non-core activities over 1 day; or
• Moderate monetary or financial statement impact of between £10k to £500k; or
• Moderate breach in laws and regulations resulting in fines and consequences between £10k to £500k; or
• Moderate impact on the reputation or brand of the CCGs, resulting in limited unfavourable media coverage restricted to local media with a long-term reduction in
public confidence.

PwC Internal Audit Report

Appendix A: Basis of our classifications Appendix B: Terms of reference Appendix C: Limitations and
responsibilities

Appendix A: Basis of our classifications

Individual finding ratings

A finding that could have a:
Low
• Minor impact on the CCGs’ operational performance resulting in minor disruption of discrete non-core activities for less than 1 day; or
• Minor monetary or financial statement impact less than £10k; or
• Minor breach in laws and regulations with limited consequences less than £10k; or
• Minor impact on the reputation of the CCGs, resulting in limited unfavourable media coverage restricted to the local press with a short-term reduction in public
confidence.

A finding that does not have a risk impact but has been raised to highlight areas of inefficiencies or good practice.
Advisory

Report classifications
The report classification is determined by allocating points to each of the findings included in the report.

Findings rating Points Report classification Overall Risk Rating Points

Critical 40 points per finding ⬤ Low risk 6 points or less

High 10 points per finding Medium risk 7 – 15 points

Medium 3 points per finding High risk 16 – 39 points

Low 1 point per finding Critical risk 40 points and over

PwC Internal Audit Report

Appendix A: Basis of our classifications Appendix B: Terms of reference Appendix C: Limitations and
responsibilities

Appendix B: Terms of reference

Scope

We will review the design and operating effectiveness of key controls in place relating to the CCG’s management of primary care finance as set out below during the period 1 January to 30
September 2020. The sub-processes and related control objectives included in this review are:

Management and reporting of delegated funds

▪ Policies and procedures have been established for the forecasting, monitoring and reporting of delegated funds and the Primary Care Commissioning Committee has effective oversight over
the use of delegated funds.

Financial controls for the approval of payments to practices

▪ The CCG has established policies and processes for the validation and approval of payments made to practices.
▪ Payments made to practices are approved by persons with appropriate approval limits in line with the Scheme of Delegation.
▪ Adequate segregation of duties is in place between individuals raising and approving payments made to practices.

Compliance with coding guidance

▪ Transactions are accurately coded in line with NHSE coding guidance.

Approval of ‘discretionary’ payments

▪ Policies and procedures have been established for the validation and approval of discretionary payments.
▪ Discretionary payments are reviewed and approved by persons in line with the Scheme of Delegation.

Implementation of the Premises Cost Directions

▪ Applications for funding towards premises costs are processed in line with the Primary Medical Care Policy and Guidance Manual.
▪ Approval of applications is granted by the Primary Care Commissioning Committee and in line with the Scheme of Delegation.
▪ Signed agreements are in place between the CCG and practices for funding arrangements.
▪ Rent reimbursement agreements with practices are subject to financial review every three years and all other financial agreements are subject to financial review on an annual basis.

Reimbursement of Covid-19 expenses

▪ Reimbursement of Covid-19 expenses are supported by a claim form and relevant supporting documentation (e.g. purchase orders and invoices), reviewed and approved in line with the
Scheme of Delegation and in line with the guidance, where available.

PwC Internal Audit Report

Appendix A: Basis of our classifications Appendix B: Terms of reference
Appendix C: Limitations and responsibilities
Limitations inherent to the internal auditor’s work
We have undertaken the review of Primary Care Finance, subject to
the limitations outlined below:
Internal control
Internal control systems, no matter how well designed and operated,
are affected by inherent limitations. These include the possibility of
poor judgment in decision-making, human error, control processes
being deliberately circumvented by employees and others,
management overriding controls and the occurrence of unforeseeable
circumstances.
Future periods
Our assessment of controls is for the period 1 April 2020 to 31 July
2020 only. Historic evaluation of effectiveness is not relevant to future
periods due to the risk that:
• The design of controls may become inadequate because of
changes in operating environment, law, regulation or other
changes; or
• The degree of compliance with policies and procedures may
deteriorate.
PwC Internal Audit Report
Appendix C: Limitations and
responsibilities
Specific limitations identified as part of the internal
auditor’s work
Internal audit work was performed in accordance with PwC's Internal
Audit methodology which is aligned to the Public Sector Internal Audit
Standards. As a result, our work and deliverables are not designed or
intended to comply with the International Auditing and Assurance
Standards Committee (IAASB), International Framework for Assurance
Engagements (IFAE) and International Standard on Assurance
Engagements (ISAE) 3000.
The procedures performed were limited to information and controls
operated by the CCG, and we did not perform inquiry or review
documentation that are owned by external third parties..
Responsibilities of management and
internal auditors
It is management’s responsibility to develop and
maintain sound systems of risk management,
internal control and governance and for the
prevention and detection of irregularities and
fraud. Internal audit work should not be seen as
a substitute for management’s responsibilities
for the design and operation of these systems.
We endeavour to plan our work so that we have
a reasonable expectation of detecting
significant control weaknesses and, if detected,
we carry out additional work directed towards
identification of consequent fraud or other
irregularities. However, internal audit
procedures alone, even when carried out with
due professional care, do not guarantee that
fraud will be detected.
Accordingly, our examinations as internal
auditors should not be relied upon solely to
disclose fraud, defalcations or other
irregularities which may exist.
pwc.co.uk

In the event that, pursuant to a request which Berkshire West CCG has received under the Freedom of Information Act 2000 or the Environmental Information Regulations 2004 (as the same may be amended or re-enacted from time to
time) or any subordinate legislation made thereunder (collectively, the “Legislation”), Berkshire West CCG is required to disclose any information contained in this document, it will notify PwC promptly and will consult with PwC prior to
disclosing such document. Berkshire West CCG agrees to pay due regard to any representations which PwC may make in connection with such disclosure and to apply any relevant exemptions which may exist under the Legislation to such
report. If, following consultation with PwC, Berkshire West CCG discloses any this document or any part thereof, it shall ensure that any disclaimer which PwC has included or may subsequently wish to include in the information is
reproduced in full in any copies disclosed.

This document has been prepared only for Berkshire West CCG and solely for the purpose and on the terms agreed with Berkshire West CCG in our agreement dated 1 April 2014 (which novated from our contract of the same date with
Newbury and District CCG, North and West Reading CCG, South Reading CCG or Wokingham CCG on 1 April 2018). We accept no liability (including for negligence) to anyone else in connection with this document, and it may not be
provided to anyone else.

© 2020 PricewaterhouseCoopers LLP. All rights reserved. In this document, 'PwC' refers to the UK member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see
www.pwc.com/structure for further details.

190829-113606-JE-UK