12 Oct 2010
Speech by Rosalie Langley Judd, Manager of Governance Policy, FSA
at the Financial Stability Institute Seminar on Corporate Governance Reforms
Good morning and thank you so much for inviting me to speak at this conference. I am delighted to be here, as it gives me a golden opportunity to learn the latest thinking on corporate governance from all of you here.
I have for some years been responsible for the UK’s policy on the regulation of individuals in regulated firms – our approved persons regime. Very recently I broadened that particular responsibility by taking on leadership for the FSA on governance policy more generally. As a result I was privileged to come in at the very end of the Basel Corporate Governance Task Force work revising the principles for enhancing corporate governance. So I can unashamedly admit I’ll be taking nuggets back from all of you here to consider incorporating into the UK approach!
We had excellent talks yesterday on the links between failures in corporate governance and the crisis. Against that backdrop I will simply explain our corporate governance framework and the changes we have made following the financial crisis, both in our rules and guidance and in how we implement them. And knowing that I shall be followed by two excellent speakers on remuneration I will avoid getting into their space.
For my part it is a particularly appropriate time to be sharing what we’ve been doing in the UK with you, because we’ve just published our policy statement and revised rules and guidance following Sir David Walker’s Review of Corporate Governance and our own consultation at the beginning of this year.
To put our work into context, many of you will know that in the UK we have a regime for approving individuals in the firms we regulate which predates the inception of the FSA. The approved persons regime applies to those holding certain functions in most of the businesses we regulate, including deposit taking, insurance, investment and home finance firms.
The regime is our way of ensuring that only individuals who are fit and proper can carry out specified functions – known as controlled functions - in the UK financial services industry. This is consistent with the idea that authorisation and approval processes are the first step in risk-based regulation. Simply put, prevention is better than cure.
In general terms, the regime is limited to those who:
- exert significant influence on the firm’s regulated activities;
- deal with its customers; or
- deal with the property of its customers.
The aim of the regime is to strike a balance between relying on those who manage the firm’s affairs to employ suitable staff, without intervention from the FSA, and seeking to ensure the firm’s key employment decisions are not contrary to the interests of customers and end-beneficiaries and are consistent with the statutory objectives we have.
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Our fit and proper test has three parts:
- honesty, integrity and reputation;
- competence and capability; and
- financial soundness.
In looking at honesty, integrity and reputation and at financial soundness, we ask a series of questions about past history, including past bankruptcy and the existence of criminal records. And, of course, we do our own checks. We emphasise the importance above all of openness with us. Each case is judged on its merits: the fact that a past regulatory offence or a criminal conviction may not in itself make someone unsuitable, but failure to disclose information to us accurately almost certainly does.
Historically, our approach to judging competence and capability was less developed on the basis that this was an issue we considered, but more a matter for the firm. I will cover later how we have been developing our approach to assessing competence after the crisis.
Once the FSA has approved an individual, the individual must remain fit and proper to carry out his function and must observe the standards of conduct set out in the Statements of Principle and Code of Practice for Approved Persons. Failure to do so runs the risk of discipline by us. The enforcement tools we have available have recently been increased to include suspension and restrictions as well as fines, withdrawal of approval or - the ultimate sanction - prohibition.
There are seven Statements of Principle, three of which apply only to those carrying out a Significant Influence Function (or SIF for short). An approved person performing a SIF:
- must take reasonable steps to ensure that the business of the firm for which he is responsible in his controlled function is organised so that it can be controlled effectively;
- must exercise due skill, care and diligence in managing the business of the firm for which he is responsible in his controlled function; and
- must take reasonable steps to ensure that the business of the firm for which he is responsible in his controlled function complies with the relevant requirements and standards of the regulatory system.
You may also know that, at the firm level, we have for a number of years used our Advanced, Risk-Responsive, Operating frameWork - or ARROW - and then the ARROW 2 model. This is designed to identify the main risks to our statutory objectives as they arise, and to help us plan how to address these risks in line with our regulatory approach. One of the risk elements of ARROW – and one to which we give double weighting – is governance, management and culture.
The outcome we have looked for on control culture is for the board and management to set the right ‘tone’ in terms of control – projecting the overall attitude, awareness and actions of the firm. This will include the integrity and ethical values of staff, the participation of directors in board meetings and sub-committees and management’s operating style and philosophy.
Governance can be described as board oversight of management activities and management oversight of staff activities in line with management requirements. Appropriate governance includes the policies, procedures, and practices established to help ensure staff and personnel carry out board and management decisions. These activities help ensure the board stays informed and aware, and therefore are able to challenge; also, that management can actively manage and control risk.
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I have just described our main tools when the collapse of Northern Rock led to a radical rethink in our supervisory approach and process. This led to our supervision enhancement programme and a commitment to increased focus on the competence of firms’ senior management.
There was also a recognition that the profile of prudential risk management and business analysis in the FSA should be enhanced and the linkages between risk identification and supervisory action strengthened.
There was no change, though, in our underlying regulatory philosophy. Two of the fundamental pillars of that philosophy are:
- Our regulatory approach remains grounded in the principle in our legislation that the primary responsibility for the management of a financial institution rests with its board and executive management. So, our revised supervisory framework is designed to be proactive in seeking to ensure that the board and executive of firms discharge their responsibilities.
- We continue to use and improve our current ARROW 2 framework and operate an outcome-based philosophy.
As we have examined and responded to the crisis we have learned more about what went wrong at firms. In governance terms, we have seen issues in several areas. For example:
- where boards did not sufficiently challenge the executive or understand their business models adequately;
- where boards needed a better understanding of higher risk activities and products; and
- where boards did not receive appropriate management information to be able to carry out their important oversight role.
So, boards needed better understanding, to challenge more robustly and to seek and receive better information. For all of these things, we have to make sure we have the right people on boards, with the right mix of skills, asking the right questions.
As we have the power to vet the individuals in these key positions, we realised there was more we should be doing to ensure they were up to the job and that, once in the job, they were doing their job effectively.
So, what changes did we make in our approach to corporate governance as a result of the crisis? First let’s consider the regulatory framework.
In our Consultation Paper published in January 2010 and called Effective corporate governance (Significant influence controlled functions and the Walker review), we brought together two strands of work – the intensification of the approved persons regime, and our contribution to the implementation of the Walker Review’s recommendations, particularly on risk governance.
The paper launched a number of proposals to strengthen the regulatory framework supporting our activities. It also explained how we have developed our processes for assessing the fitness and propriety of candidates for SIF roles.
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One of the key proposals in our Consultation Paper was to introduce a number of new, more specific, controlled functions within the approved persons regime.
Within the controlled functions, the SIFs capture many important roles under some broad headings, so currently one individual can carry out a number of roles under just one controlled function. These underlying roles are essential to effective governance. We believed our current regime was not detailed enough to allow us to segregate and capture specific key roles within governance structures.
Let me give you an example. A person approved as a director could move within a firm, from being, say, the marketing director to the finance director without further approval by us.
We believed this needed to change, and so we consulted on introducing a number of new, more specific, controlled functions that capture the key roles in organisations. These are roles such as:
- chairman;
- senior independent director;
- chairman of the risk, audit, and remuneration committees; and
- at the level below the Board, the financer, risk and internal audit functions.
And we consulted on making our policy more comprehensive with regard to bringing into the regime those in a parent company, including those based overseas, who exert a significant influence on the regulated firm.
In line with Sir David Walker’s recommendations, we also proposed two key pieces of guidance on risk governance. The first was that firms, particularly FTSE 100 listed banks and insurers, should consider establishing a board risk committee – if they do not already have one - to support their oversight of risk and risk strategy. This would not be for smaller firms: it might well be that in a straightforward business, risk matters can still be accommodated adequately in board agendas. But we agree with The Walker Review that risk issues demand depth of attention and for many firms that will necessitate a dedicated forum.
We also proposed encouraging firms to appoint a Chief Risk Officer or CRO. This would be a senior executive with primary accountability to the board on the quality of enterprise-wide risk management. He would be the key link between the board and the business. We would expect a core skill to be the ability to translate what is at times a highly technical and often detailed day-to-day reporting of risk into high-level information for the board to understand and interpret at a strategic level.
At the end of last month we published the revisions to our rules and guidance which will come into effect from 1 May 2011. They are available from our website: the reference is Effective Corporate Governance – Significant influence controlled functions and the Walker Review.1
The changes we made included:
- bringing in this new framework of classification of controlled functions;
- widening the parent entity SIF as I’ve described;
- extending the significant management function (CF29) to UK branches of incoming EEA banks accepting retail deposits;
- guidance detailing our expectations of the role played by NEDs, such as the level of time commitment required; and
- the guidance I’ve described on board risk committees and on CROs.
The feedback to our proposals was generally supportive, although we were asked for more guidance in some areas. The area which caused the greatest angst to firms was the parent SIFs, because of concern as to who would be covered. As I expect this will be the part of our regime of most interest to you, let me explain what it does and does not cover.
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In July 2009 we made rules requiring those individuals based in a parent entity whose decisions are regularly taken into account by the governing body of the UK firm to apply for approval. The reason for the change was because the regime at that time only brought within its scope individuals in matrix management structures where there had been a significant delegation of authority for management decisions by the governing body of the authorised firm. It did not necessarily reflect the increasing significant influence exerted on an authorised firm by individuals based in parent entities to which the authorised firm is accountable.
Last year we focused on overseas parents outside the EEA and on unregulated UK parents. This year we have slightly extended the regime to make sure firms of all types of corporate status are covered and to include regulated UK parents. In addition, we have also recognised that firms need further guidance in this area, so our latest rulebook changes include answers to a number of frequently asked questions to assist firms in deciding who needs approval in the parent entity.
The test set out in our rules last year and which I’ve described above has not changed. The test looks at whether the governing body as a whole takes into account the actions or decisions of the individual in the parent entity, not whether individual members of the governing body have reporting lines to him.
It is not the job title held by a person within the parent entity that will determine whether they fall within the scope of the regime, but rather the function exercised.
There also needs to be an arrangement in place permitting the performance of the role by the person concerned. It is important to remember, though, that formal delegation is not the only form of ‘arrangement’, since an arrangement can arise by conduct, custom and practice.
Broadly speaking, there are two main situations where the parent entity SIF may apply:
- where the individual is formally included in the firm’s reporting lines and decision-making structures; and
- where the individual has a direct but informal influence on the firm’s governing body that is sufficiently strong that his decisions or actions are regularly taken into account by the governing body.
If the firms’ governing body has sufficient discretion on how it applies and responds to directions or proposals coming from group committees or individuals based in parent entities, the influence is unlikely to be significant and therefore approval would not be required.
So, these are targeted proposals designed to bring within our regime only those individuals in the parent entity whose decisions or actions are regularly taken into account by the governing body of the UK firm. We are encouraging firms to speak to their supervisors if they are still unsure whether anyone in the parent entity needs approval.
In a separate consultation exercise, we have also proposed creating a new controlled function with specific responsibility for client money and assets. We believe a senior individual within the firm should have responsibility for oversight and protection of client assets and client money. However, this won’t be a one size fits all regime – firms with small client asset holdings can simply allocate this responsibility to their existing compliance officer without requiring further approval. But firms with larger holdings will need to appoint a senior individual to this new controlled function role.
All in all, our expectation is that these measures will mean that firms will give proper consideration to governance and risk issues at the highest level in their businesses.
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So how did we respond at a practical level in our approval of those applying for SIF roles?
Well, you may recall my saying earlier that, historically, we had placed less focus on the competence and capability part of the fit and proper test. Our response to the crisis – as part of our enhanced supervision for individuals - was to incorporate an in-depth interview into our process for assessing the competence and capability of SIF candidates for key roles.
This was not to ignore the principle that the primary responsibility for the management of a financial institution rests with its board and executive management. Rather, it recognises that, as that weight of responsibility rests on the senior management, then it is particularly important that they are fully up to the job. And the changes I’ve just described to our rules and guidance give further tools to our SIF team to help ensure this is the case by making assessments based on the particular role applied for.
Since October 2008, we have interviewed just over 660 applicants for approved persons roles, 36% of which have been in the last six months. We have conducted more interviews since April this year because we are now conducting them not only for firms which present a high risk in terms of impact and probability to our objectives, but also for firms which present a medium low risk, and also for some low impact banks where we think it necessary.
For the composition of the governing body, we focus both on the competencies and capability of the candidate for approval as well as taking a view on his role in relation to the wider composition of the governing body. Such an approach will, we believe, help to allay any concerns that our focus on experience and qualifications could increase the conformity and homogeneity of individuals at the top of the UK financial services industry, and the risk that levels of challenge and alternative points of view are reduced as a result.
The decision to interview is fundamentally risk-based. We will actively consider the need to interview candidates applying for any of the following roles in larger, more complex or risky firms: chairman, chief executive, senior independent director, finance director and chief finance officer, risk director and chief risk officer and NEDs whose responsibilities include chair of audit, risk or remuneration committees.
However, we may decide to interview any candidate applying to perform a SIF role in circumstances where we have concerns about the candidate’s fitness and propriety, or concerns about the applicant firm. We will consider what we know about the firm, the significance of the role in that firm, and what we already know – or feel we don’t know – about the candidate. The fact that a candidate is based overseas will not deter us from asking for an interview if our risk assessment shows he or she should be called.
In certain cases we may also decide to meet separately with appropriate representatives from the firm. These could be the chairman of the nomination committee, for example. We would do this if we wanted to gain additional insight into the due diligence the firm has undertaken on the candidate concerned.
There are four stages to go through.
Stage 1 – The firm’s application
It is the firm that remains responsible for making the application to us for approval of a candidate. A key part of that responsibility is the need for firms to assess the fitness and propriety of candidates thoroughly before proposing them for an approved person role.
We continue to find that many firms fail to conduct adequate due diligence on their candidates or make sensible judgments on their suitability, resulting in delays and more intensive investigations on our part. That is why we sent a letter to CEOs in October 2009, setting out our expectations. This can also be found on our website.
For the avoidance of doubt, what we mean by firms conducting ‘due diligence’ is an assessment of the candidate’s competence and capability to perform the role and not just obtaining references and carrying out credit checks.
One of the main ways firms can help make the approval process work more smoothly is by submitting applications in good time: we will not even set the date for an interview until we have received a completed and signed application form, and completed our initial pre-interview checks and assessment.
And firms know that gone are the days when they can phone us to say they wish to appoint a new chairman or CEO - expecting us to nod them through as approved within two days ready for an announcement.
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Stage 2 – Our assessment of the application
We check applications against the same three criteria that I mentioned earlier. As part of our ‘baseline’ assessment of any candidate, we will determine whether or not the candidate is or has ever been an approved person and check for any existing negative indicators or concerns. Where a firm is large enough to have its own supervisor or team of supervisors we will consult with them to understand any concerns they may have and seek their views on any issues we identify. We will also carry out other checks, such as credit checks. If necessary, we will make enquiries with other regulators, for example where a candidate is or was based overseas.
The type of information that helps us to make our approval decision includes details of:
- the responsibilities the role involves and the competencies it requires;
- the recruitment, referencing, interview and appointment processes;
- the due diligence undertaken by the firm to ensure the candidate is fit and proper; and
- the firm’s rationale for concluding the candidate is fit and proper to perform the role in question.
This information should include an assessment of the competence of the candidate and information about any action to be taken post-appointment to address any developmental gaps or training needs that have been identified.
At the core of this process, the onus lies with the firm to do proper due diligence on their candidates, and to show us that their chosen appointee is fit and proper for the role. Failure to assess competence thoroughly will tell us a lot about the quality of the firm’s own recruitment processes. Persistent failures to provide robust information in support of applications are likely to lead to us taking a closer supervisory look at the firm.
We will provide - where necessary and where we are legally permitted to do so – information to firms at the short list stage about the potential fitness and propriety of their candidates. In some circumstances, such as where an appointment is sensitive or urgent, or a candidate’s background is opaque or complex, firms may ask us at an early stage to carry out certain standard due diligence checks on one or more candidates.
The purpose would be to identify whether there are any adverse indicators in information sources that the firm would not have access to (such as checks with overseas regulators). These checks, which would focus on issues of probity, would not replace the general checks that we expect firms to undertake in the course of their own due diligence.
Where firms can demonstrate they have undertaken appropriate due diligence this may remove the need for us to conduct an interview.
Stage 3 – The interview
We recognise that many of the individuals we need to see are very senior and experienced in their field and, not unreasonably, expect to be evaluated by their peers. We have therefore taken on a group of similarly experienced and highly-regarded senior advisors to support us in such interviews. They are Sir Dominic Cadbury, Baroness Hogg, Lord Marshall and Sir David Scholey.
In selecting interview panel members, we are careful to avoid conflicts of interest. We select from a range of advisers and senior advisers appropriate to the candidate and nature of the role being applied for. We will not include on the panel anyone who has or may be seen to have a conflict of interest. We are also mindful to minimise delays in the approval process through having to wait on the availability of individuals to sit as panel members.
For those candidates we call for interview it is potentially a two-stage process. The first interview is an unrecorded, but minuted, interview with the candidate, followed, if necessary, by a second, recorded interview.
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In the interview itself, we cover a range of issues – these include the candidate’s competence, assessed against criteria such as market knowledge, risk management and control, and governance and oversight. We also look for evidence of the right behaviours – such as openness and cooperativeness with us – and we look for key soft skills relevant to a role, such as the skills needed to lead and direct a board committee.
We have identified the following key competencies for SIF roles:
- market knowledge: here we are looking for awareness and understanding of the wider business, economic and market environment in which the firm operates;
- business strategy and model: we want to see awareness and understanding of the firm’s business strategy and model appropriate to the role;
- risk management and control: the successful candidate needs the ability to identify, assess, monitor, control and mitigate risks to the firm. Also, an awareness and understanding of the main risks facing the firm and the role the individual plays in managing them;
- financial analysis and control: the candidate needs the ability to interpret the firm’s financial information, identify key issues based on this information and to put in place appropriate controls and measures;
- governance, oversight and controls: here we are looking for the ability to assess the effectiveness of the firm’s arrangements to deliver effective governance, oversight and controls in the business and, if necessary, oversee changes in these areas; and
- regulatory framework and requirements: the candidate needs to have awareness and understanding of the regulatory framework in which the firm operates, and the regulatory requirements and expectations relevant to the SIF role.
We don’t apply a one-size fits all approach to this assessment – our expectations for each candidate will vary according to a range of factors, such as our view of the firm, the balance of the board or team that the individual is joining, and so on. Nor do we assess the competence of every candidate for SIF approval against each of these criteria. To do so would be disproportionate and resource-intensive.
We do, though, expect the firm to provide sufficient evidence that they have themselves considered these matters in their recruitment processes. Some firms are starting to provide their assessment of the individual against our six competencies, to identify gaps in his or her knowledge and to prepare a learning and development plan to rectify these gaps. We welcome this.
We also recognise that in some circumstances, the level of competence required for an individual will depend on the balance of the team in which they are going to operate. This is particularly relevant when looking at the knowledge, skills and experience of a firm’s board as a whole.
As an example, we would generally expect NEDs to have a good level of market knowledge appropriate to the business of the firm concerned. However, there may be cases where an individual lacking such knowledge would otherwise be an excellent candidate for a firm. In those circumstances we will expect the firm to assess the impact of this in the context of the board as a whole, and be able to demonstrate that there will be enough industry knowledge across all the NEDs for the board to meet its collective responsibilities; and that they have prepared a structured development plan to bring the candidate concerned up to speed in a timely way.
Where we are interviewing someone with many years of experience in that sector, then exploring the candidate’s level of market knowledge during the interview is likely to assume a much lower priority than other important topics.
Other non-technical skills may also be relevant. We would expect a NED candidate seeking approval for the additional role of audit committee chair to be a highly authoritative individual, capable of challenging the executive effectively and marshalling the diverse skills and contributions of the committee members. While these are not skills tied to financial services, they are pivotal in delivering effective governance and therefore relevant to the individual’s capability to perform that role.
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In addition to assessing candidates against these competencies, we may also explore the candidate’s motivation for accepting the role, their capacity to perform the role in view of other commitments and their own due diligence on the firm and the position before they accepted the role.
The wide-ranging content of the interview reflects our desire to use it not only as an assessment tool, but also as a means of ensuring that candidates for key SIF roles have a clear understanding of our objectives and expectations and of their responsibilities. The interview also allows us to alert the candidate to areas where we consider they need further development in order to meet and maintain our standards of fitness for approval.
Where we identify any gaps in competence, behaviours or non-technical skills, we will look for evidence that the individual recognises such gaps, understands their importance and is capable and willing to address them.
We have heard two concerns. One is that it is taking longer to hire, which may lead to some senior candidates going outside the UK financial services industry. Here the steps I have already outlined under the application and assessment stages - which both firms and we can do to make the process as efficient as possible - make a big difference.
The other concern is that otherwise strong candidates may be deterred from putting themselves through this process. This is certainly not our intention and we’re not seeing evidence of this in practice. What we are seeing is an improvement in the quality of applications being made to us by firms, and this is absolutely our objective.
We have calculated the interview process costs firms around an additional £1,850 and us just over £1,000 per candidate. However, the cost has not been raised as an issue with us.
We believe the interview is a valuable tool for raising the standards of governance and control in firms. For the first 18 months the rate of firm’s withdrawing their candidate ran at 7.5%. Since April this year this has increased to 10%, with the majority being for reasons of competency. We believe this increase is due to our getting more skilled at assessing a candidate’s competence at interview, together with a greater focus on consistency and on helping supervisors to set their risk appetite for SIF holders.
Many candidates have fed back to us that they found the interview process to be helpful and constructive. Topics discussed have regularly led to positive follow-up action in the firm, initiated by the new approved person.
Stage 4 – Once approved, ongoing review
Once approved, the performance and competence of persons performing SIFs will be reviewed as part of ARROW assessments.
Part of our ongoing assessment of a board’s effectiveness and how individual approved persons are performing can include the board appraisals. We believe these are valuable tools for the boards to use and encourage them to share these with us.
Where we have serious concerns about the corporate governance of a firm, we can conduct an in-depth governance assessment of the firm, using our increased risk resources following the crisis. And we can instigate a formal statutory report to provide an independent review of the firm.
Putting all this into the wider UK context, corporate governance for companies generally in the UK is the remit of the Financial Reporting Council. The FRC, like us, has responded to the financial crisis and The Walker Review by examining the recommendations it makes on corporate governance. This has led to a thorough review of its standards, which have now been reissued as the Corporate Governance Code and the UK Stewardship Code. We believe these will help company boards become more effective and more accountable to their shareholders.
It is clear to us that the financial crisis exposed significant shortcomings in the governance and risk management across numerous firms. And although poor governance was only one of many factors that contributed to the financial crisis, it was an important one.
So, just as we are taking action on a range of fronts in our response to the crisis – from capital and liquidity, right through to asking questions about the very nature of our financial system – we are also addressing issues around governance and the culture within firms.
What do we mean when we talk about ‘culture’ in our industry? To quote from the revised Basel Principles:
‘A demonstrated corporate culture that supports and provides appropriate norms and incentives for professional and responsible behaviour is an essential foundation of good governance’”
Similarly, when we use the term we are referring to firms having the right culture for their business model – the right ethical framework – to facilitate the right decisions and judgments.
In his speech on ‘Can culture be regulated’ at a Conference on Values and Trust in the City of London earlier this month, Hector Sants encouraged boards to have a structured process for reviewing their firm’s culture, identifying its drivers and the behaviours and outcomes it delivers.
We have been thinking about three specific questions in relation to culture:
- Should the regulator seek to regulate culture at all?
- If the answer is yes, are the judgments needed too difficult to make?
- Then, thirdly, even if you believe the regulator should and could judge culture, what are the tools to use if we were to facilitate or enforce the adoption of these judgments?
We would be very interested to hear of any work that others here are doing around culture.
And to sum up, our governance work is within our overall programme to improve our regulation, and is part of our more intensive supervisory approach. We now have a much greater focus on making our own judgments, for example, about individuals performing key roles and the sustainability of business models of firms. We will and have intervened where we have concerns. We cannot simply rely on monitoring systems and controls or assuming that firms’ senior management are necessarily always best placed to make these judgments alone.
And so our emphasis now is on supervising governance in action – and that means evaluating the outcomes of the processes and structures firms have put in place and greater scrutiny of individuals before they are in positions of influence, and once they are in place.
We know that we won’t remove all risk from the system, but nor would we want to. We want to make sure that regulated firms are well-run, recognise the risks they face and put in place appropriate strategies, systems and controls.
All of this work aims to respond to the lessons we have learned from the financial crisis and to make our regulation more effective to reduce the risk of the same problems happening again.
Going forward we shall be working to ensure that our approach to governance is both sufficiently strategic and coherent, and that it reflects the latest EU and international guidelines. And, following Hector Sants’ recent speeches on the subject, we shall be developing further our thinking on culture and the regulator’s role.
Many thanks for your attention this morning.
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1 PS10/15: Effective Corporate Governance – Significant influence controlled functions and the Walker Review (24 September 2010).
