4th September 2019
Quick Links
HOUSING LAW NEWS & POLICY ISSUES
 

Overcrowding and children: report by Children’s Commissioner for England
On 21 August 2019 the Children’s Commissioner for England, Anne Longfield, published research which establishes that “while official statistics show 124,000 children in England living in temporary accommodation, this does not include the hidden homeless who are ‘sofa-surfing’, often in very cramped conditions”. New analysis conducted for the Children’s Commissioner estimates that in 2016/17 there were 92,000 children living in sofa-surfing families. The report, Bleak houses: Tackling the crisis of family homelessness in England, reveals that some children are living in converted shipping containers and office blocks, and B&Bs, in cramped conditions, often miles away from their schools. For the report, click here. For an article about the report’s findings, click here. For the response of Arch (the Association of Retained Council Housing), click here. For comment by Shelter, click here.

Overcrowding and children: report by National Housing Federation
On 22 August 2019 the National Housing Federation published a briefing stating that more than one in ten children in England are living in overcrowded homes. This comes to a total of around 1.3 million children from more than 600,000 families, who are stuck in overcrowded conditions because there is nowhere else for them to live. According to the NHF, overcrowding in England has now reached record levels, as around 96,000 more children are living in overcrowded homes compared to a decade ago. The NHF is calling on the Government to invest £12.8bn every year for the next decade in building new social homes, bringing spending levels back to those last seen in the early 1950s. For the briefing, click here. For a press release related to it, click here. For a comment by the Joseph Rowntree Foundation, click here.

Family left in overcrowded conditions for more than a decade: Ombudsman’s report
On 29 August 2019 the Local Government and Social Care Ombudsman reported that a Lancashire mother of three, who also took on the care of her two grandchildren, had to sleep on a mattress in her living room for more than 10 years because the county council did not deliver the support it had agreed to. The woman, who already had young children living with her in a small three-bedroomed terraced house, was promised an extension by Lancashire County Council as part of a care order granted in 2005. However, it was not till 2011 the council agreed a budget for the work. The project was beset by delay, and the cost of the proposed works increased significantly. By 2016 the proposed costs had increased by £50,000 and the council told the woman the extension would no longer be built.

The Ombudsman’s investigation also found the council delayed deciding whether to provide the family with a people-carrier type vehicle in response to the court order. It eventually paid for a vehicle in 2016. The Ombudsman has also criticised the council for not agreeing to pay for storage of some of the family’s belongings over a three-year period.

The council has now agreed to apologise to the woman, and pay her £24,000 to reflect the avoidable distress she and her family suffered living in overcrowded conditions for 10 years. It will also pay her £500 for the distress and uncertainty she suffered because of its failure to make a decision in line with the care order on funding for a people carrier. It will also reimburse all her storage costs for the period of December 2016 to January 2019.

For a report, click here. For the official report of the investigation, click on the link at the right top corner of that page.

Right to Buy reform needed: LGA
On 24 August 2019 the Local Government Association said that housebuilding efforts by councils risk being undermined without reform to the Right to Buy (RTB) scheme in the coming Spending Round. The LGA added that the latest figures show that councils in England directly built 2,560 homes in 2018/19: the highest since 1992/3 when they built 2,580 homes. The LGA’s Housing spokesperson, Cllr Judith Blake, said:

“[T]he number of new council homes being built is not able to keep pace with those sold under Right to Buy. Right to Buy continues to enable many families to achieve the dream of getting on the housing ladder and owning their own home, but it urgently needs reform. Current arrangements are restricting councils from being able to replace homes being sold under the scheme. This loss of social rented housing risks pushing more families into the private rented sector, driving up housing benefit spending and rents and exacerbating our homelessness crisis.”

For the LGA’s full statement, click here.

Anti-social behaviour and housing – England
The House of Commons Library has published two recent briefings in relation to anti-social behaviour and housing. They are:

  • Anti-social behaviour in social housing (England) – This briefing paper, published on 23 August 2019, provides an overview of the remedies available to social landlords to deal with tenants who exhibit anti-social behaviour. The paper focuses on England but some of the same legislation applies in Wales. Scotland and Northern Ireland operate under different legislative regimes. The Home Office updated guidance for frontline professionals dealing with ASB in August 2019. For the briefing, click here.
  • Anti-social neighbours living in private housing (England) – This briefing paper, published on 27 August 2019, outlines the legal position and potential remedies available where people find themselves living next door to tenants of private landlords or owner-occupiers who exhibit anti-social behaviour. The briefing focuses on the legal position in England. For the briefing, click here.

Local Housing Allowance
On 2 September 2019 Crisis called on the Government to restore the levels of Local Housing Allowance (LHA) so that they truly cover market rents. The charity said that such a policy would have the potential to prevent more than 6,000 households from being pushed into homelessness and also lift more than 35,000 children out of poverty in the next three years. Research, published as part of its Cover the Cost campaign, outlined the three-year cost and benefit analysis of a Government investment of £3.3 billion in LHA for immediate net benefits of £2.1 billion. More specifically, the charity is calling for £820 million in the next year as part of upcoming spending decisions. For the report, click here. For more details of the Cover the Cost campaign, click here. For a press release about the report, click here.

Right to Rent: private landlords' duty to carry out immigration status checks
On 27 August 2019 the House of Commons Library published a briefing paper providing an overview of Right to Rent checks which must be carried out by private landlords/agents in England. The checks were introduced by the Immigration Act 2014. Breaches may, in some circumstances, amount to a criminal offence after changes introduced by the Immigration Act 2016 in December 2016. The checks are controversial and have been subject to legal challenge. For the briefing, click here.

Universal Credit
On 29 August 2019 Shelter published a report finding that the inadequate levels of housing element of Universal Credit for private renters is being exacerbated by some of UC’s in-built design features. Most importantly, the five-week wait at the start of a UC claim means households can be left with very little or even no income for the whole period. Shelter says that the five-week wait must be abolished as a matter of urgency to avoid rent arrears and the risk of eviction and homelessness, and that the process of applying for an advance payments arrangement should be as straightforward and simple as possible. For the report, click here. For an accompanying report looking at the relationship between the Local Housing Allowance rates and private rents, click here.

Help to Buy mortgages
On 28 August 2019 the MHCLG announced that it has closed a loophole which has seen purchasers using the Help to Buy scheme facing difficulties if they wanted to take out a mortgage with a term of more than 25 years. Under the changes, which are taking effect immediately, people will have the freedom to reduce their monthly mortgage repayments by spreading their borrowing over a longer period. For the announcement, click here.

Shared ownership changes
On 28 August 2019 the MHCLG announced plans for a new national model for shared ownership by which people will be able to buy their home in 1 per cent increments. At present, they have to buy an increased share in 10 per cent chunks, which can be as much as £45,000 per time. The proposals are subject to consultation. For the announcement, click here. For details of the consultation, see Housing Law Consultations below.

Rural housing statistics
On 29 August 2019 the Department for Environment, Food and Rural Affairs published a raft of statistics relating to housing availability and affordability in rural and urban areas. The releases set out: additions to affordable housing stock; housing availability and affordability; net additions to housing stock; house building; and homelessness and temporary accommodation. To access all the statistical releases, click here.

Letting fees – Wales
The Renting Homes (Fees Etc.) (Wales) Act 2019, which came into force on 1 September 2019, makes it an offence to charge a tenant any payment that is not specified as a ‘permitted payment’ by the legislation. Letting agents and landlords are now only permitted to require a payment for rent, security deposits, holding deposits, a payment in default (when a tenant breaches a contract), and payments related to council tax, utilities, a television licence, or communication services. The law caps holding deposits paid to reserve a property before the signing of a rental contract to the equivalent of a week’s rent and creates provisions to ensure their prompt repayment. For the Act, click here. For an announcement by the Welsh Government, noting the commencement of the new regime, click here.

On 29 August 2019 the Welsh Government published an updated version of guidance explaining what landlords and letting agents can charge tenants from 1 September 2019; for the guidance, click here. On 30 August 2019 the Welsh Government published guidance on the legislation for tenants; for that guidance, click here and for a ‘quick guide’, click here.

Youth homelessness – Wales
On 21 August 2019 the Welsh Government announced 26 projects to tackle homelessness among young people. For details of some of the individual projects and funds awarded to each, click here.

Universal Credit landlord engagement newsletter
On 29 August 2019 the Department for Work and Pensions published the latest Universal Credit landlord engagement newsletter. It aims to provide up to date information to social and private landlords about Universal Credit. For the newsletter, click here.

‘Beds in sheds’: Oxford City Council takes action against rogue landlords
On 28 August 2019 Oxford City Council reported the action it has taken over the last 18 months against rogue landlords as part of its initiative to protect vulnerable tenants from potentially dangerous ‘beds in sheds’. The council began proactively targeting these structures in January 2018 following a grant of £274,942 from central government. Since then council inspectors have visited over 1,000 suspected beds in sheds, resulting in 21 being shut down and 31 enforcement notices being served. The team expect to visit another 400 suspected beds in sheds by the end of the year. For more details, click here.

Right to Buy proposals: Labour Party
On 2 September 2019 John McDonnell, the shadow Chancellor of the Exchequer, told the Financial Times that the Labour Party, if elected, would look to bring in a “right-to-buy” scheme to help private tenants buy their rented homes for a “reasonable” price. The Residential Landlords Association responded by saying that the plans, if implemented, “would kill off the private rented sector”. For details of the proposals, set out in an article in The Independent (the Financial Times website has a ‘paywall’), click here. For the RLA’s response, click here.
HOUSING LAWS IN THE PIPELINE
 

The UK Parliament returned from recess on 3 September 2019. The National Assembly for Wales rose on 19 July and is being recalled from recess on 5 September 2019.
Local Housing Authority Debt Bill
This Bill, which had its first reading in the House of Lords on 4 July 2017, seeks to replace the current regime of limits on local housing authorities’ debt with limits determined by the existing prudential regime for local authority borrowing for non-housing-related purposes. The second reading is yet to be scheduled. For the Bill as introduced, click here To follow progress of the Bill, click here

Homeless People (Current Accounts) Bill
This is a Private Member’s Bill introduced in the House of Commons by Peter Bone. The Bill is intended to require banks to provide current accounts for homeless people seeking work; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017. The second reading was due to take place on 1 February 2019 but Parliament did not sit on that day and the second reading will now take place on a date to be announced. To follow progress of the Bill, click here

Sublet Property (Offences) Bill
This is a Private Member’s Bill introduced in the House of Commons by Christopher Chope. It is intended to make the breach of certain rules relating to sub-letting rented accommodation a criminal offence; to make provision for criminal sanctions in respect of unauthorised sub-letting; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017 and was due to receive its second reading on 23 November 2018 but was not called. To follow progress of the Bill, click here

Mobile Homes and Park Homes Bill
This is a Private Member’s Bill introduced in the House of Commons, also by Christopher Chope. It is intended to require the use of published criteria to determine whether mobile homes and park homes are liable for council tax or non-domestic rates; to make provision in relation to the residential status of such homes; to amend the Mobile Home Acts; and for connected purposes. The Bill is being prepared for publication. The Bill received its first reading on 5 September 2017 and was due to receive its second reading on 23 November 2018 but was not called. To follow progress of the Bill, click here

Affordable Home Ownership Bill
This Bill was introduced to Parliament on Tuesday 24 October 2017, also by Christopher Chope, under the Ten Minute Rule and is a Private Member’s Bill. It was said by him to make provision for affordable home ownership; to require the inclusion of rent to buy homes in the definition of affordable housing; to make provision for a minimum proportion of new affordable housing to be available on affordable rent to buy terms; to provide relief from stamp duty when an affordable rent to buy home is purchased; and for connected purposes. The Bill was due to receive its second reading on 23 November 2018 but was not called. The Bill itself has not yet been published. To follow progress of the Bill, click here

Creditworthiness Assessment Bill
This Private Member’s Bill was introduced by Lord Buck and had its second reading in the House of Lords on 24 November 2017. The Bill would require certain matters (including rental payment history) to be taken into account when assessing a borrower’s creditworthiness. The Bill has completed all stages in the Lords. It received its first reading in the Commons on 12 September 2018. Second reading had been further postponed until 22 March 2019 but the Bill was not called. The Bill is now expected to have its second reading debate on a date to be announced. For the Bill as brought from the Lords, click here For progress of the Bill, click here

Private Landlords (Registration) Bill
This Bill was introduced to Parliament on 17 January 2018 under the Ten Minute Rule. The Bill seeks to require all private landlords in England to be registered. Second reading has been postponed to a date to be announced. For the Bill, as introduced, click here To read the debate on introduction of the Bill, click here To follow progress of the Bill, click here

Leasehold Reform Bill
This Bill, introduced to Parliament on 7 November 2017 under the Ten Minute Rule and sponsored by Justin Madders, makes provision about the regulation of the purchase of freehold by leaseholders; to introduce a system for establishing the maximum charge for such freehold; to make provision about the award of legal costs in leasehold property tribunal cases; and to establish a compensation scheme for cases where misleading particulars have led to certain leasehold agreements. Second reading has been postponed to a date to be announced. For the Bill as introduced, click here To follow progress of the Bill, click here

Homelessness (End of Life Care) Bill
This Bill, sponsored by Sir Edward Davey, was introduced to Parliament on 7 February 2018 under the Ten Minute Rule. It makes provision about end of life care and support for homeless people with terminal illnesses, including through the provision of housing for such people. Second reading has been further postponed and will now take place on a date to be announced. For the Bill as introduced, click here To follow progress of the Bill, click here

Housing and Planning (Local Decision-Making) Bill
This Private Member’s Bill seeks to remove powers of the Secretary of State in relation to the location of and planning permission for new housing developments; to give local authorities powers to establish requirements on such developments in their area, including requirements on the proportion of affordable and social housing. It received its first reading on 13 March 2018. Second reading has been postponed to a date to be announced. The Bill is being prepared for publication. To follow progress of the Bill, click here

Freehold Properties (Management Charges and Shared Facilities) Bill
This Private Members' Bill, sponsored by Helen Goodman, seeks to make provision for the regulation of fees charged by management companies to freeholders of residential properties; to make provision for self-management of shared facilities by such freeholders; and to require management companies to ensure shared facilities are of an adequate standard. It received its first reading on 14 November 2018. Second reading has been further postponed and is now expected to be on a date to be announced. The Bill is being prepared for publication. To follow progress of the Bill, click here

Fire Safety (Leasehold Properties) Bill
This Private Members' Bill, sponsored by Marsha De Cordova, would require freeholders of certain properties that have failed fire safety tests to carry out remedial work; to make provision for sanctions for such freeholders who fail to carry out such work; to ensure that leaseholders are not held liable for the costs of such work; and to make provision for a loan scheme to assist freeholders in carrying out such work. It received a first reading on 28 November 2018 and will have its second reading on a date to be announced. To follow progress of the Bill, click here.

Tenancy (Deposits and Arbitration) Bill
This Private Members' Bill, sponsored by Lloyd Russell-Moyle, would establish a single custodial tenancy deposit scheme; to provide for that scheme to invest deposits; to require interest on such investments to be used for the provision of tenant advocacy, tenant support and arbitration services; to establish a mandatory arbitration service for the resolution of disputes between landlords and tenants. The Bill received its first reading in the House of Commons on 13 March 2019. The second reading is scheduled to take place on a date to be announced. The Bill is being prepared for publication. To follow progress of the Bill, click here.

Freehold Properties (Management Charges) Bill
This Private Members' Bill, sponsored by Preet Kaur Gill, would require landlords to provide accounts of management charges payable under section 19 of the Leasehold Reform Act 1967 to freehold property owners. The Bill received its first reading in the House of Commons on 5 June 2019. The second reading is yet to be scheduled. The Bill is being prepared for publication. To follow progress of the Bill, click here.

Ground Rents (Leasehold Properties) Bill
This Private Members' Bill, sponsored by Eddie Hughes, would regulate ground rents charged on leasehold properties; make provision for a cap on ground rents; and make property developers liable for the legal costs of leaseholders seeking to vary certain ground rent contracts. The Bill received its first reading in the House of Commons on 25 June 2019. The second reading is yet to be scheduled. The Bill is being prepared for publication. To follow progress of the Bill, click here.

HOUSING CASES
 

Tenancy deposit reform: a call for evidence
This call for evidence seeks to understand the barriers tenants face providing a second deposit when moving from one tenancy to the next. It looks at what can be done to speed up the return of deposits to tenants at the end of the tenancy. It considers whether existing initiatives to address deposit affordability are meeting tenants’ needs and whether the market can offer improved products. It also explores innovative approaches that could be taken to help tenants move more easily, including allowing tenants to passport their deposit between tenancies.

The call for evidence, which closes on 5 September 2019, builds on the work of the Tenancy Deposit Protection Working Group, which has been looking at whether improvements can be made to deposit protection to the benefit of tenants and landlords. For the consultation document, click here.

Increasing the minimum notice period for a no fault eviction – Wales
The Welsh Government is consulting on:

  • extending the minimum notice period from two months to six months
  • increasing the period at the beginning of a contract during which a landlord cannot give notice from four months to six months
  • placing a six-month restriction on issuing a notice following the expiry of a previous notice
  • removing a landlord’s ability to end a fixed term standard contract (under section 186)
  • the use of break clauses in fixed term contracts.

The consultation will close on 5 September 2019. For the consultation document, click here.

Ending the Scandal: Labour’s new deal for leaseholders
The Labour Party has published plans to end leasehold ownership of houses and flats. It proposes five key changes:

  1. End the sale of new private leasehold houses with direct effect and the sale of private leasehold flats by the end of the party’s first term in Government.

  2. End ground rents for new leasehold homes, and cap ground rents for existing leaseholders at 0.1 per cent of the property value, up to a maximum of £250 a year.

  3. Set a simple formula for leaseholders to buy the freehold to their home, or commonhold in the case of a flat, capped at 1 per cent of the property value.

  4. Crack down on unfair fees and contract terms by publishing a reference list of reasonable charges, requiring transparency on service charges and giving leaseholders a right to challenge rip-off fees and conditions or poor performance from service companies.

  5. Give residents greater powers over the management of their homes, with new rights for flat owners to form residents associations and by simplifying the Right to Manage.
The document sets out a series of questions to which the party seeks responses by 30 September 2019. For the consultation document, click here.

Local authority housing statistics: proposed changes
This MHCLG consultation seeks views on the proposed discontinuing of the local authority housing statistics (LAHS) bulletin that is published in January every year and for its content to be published in other statistical bulletins throughout the year. The consultation closes on 9 September 2019. For the consultation document, click here.

A new deal for renting: resetting the balance of rights and responsibilities between landlords and tenants
On 15 April 2019, the government announced that it will put an end to so called ‘no-fault’ evictions by repealing section 21 of the Housing Act 1988. Under the new framework, a tenant cannot be evicted from their home without good reason. The government says that this will provide tenants with more stability, protecting them from having to make frequent moves at short notice, and enabling them to put down roots and plan for the future. The government also proposed to strengthen the section 8 eviction process, so landlords are able to regain their property should they wish to sell it or move into it themselves. This will provide a more secure legal framework and a more stable rental market for landlords to remain and invest in.

This consultation seeks views on how section 21 of the Housing Act 1988 has been used in the past, and the circumstances in which landlords should be able to regain possession once it has been abolished, including what changes may be necessary to the existing grounds for possession in Schedule 2 to the Housing Act 1988.

The government is also inviting views on the implications of removing the ability of landlords to grant assured shorthold tenancies in the future, how the processing of repossession orders through the courts could be improved, and whether the reforms should be extended to other types of landlords, most notably, to housing associations.

The consultation closes on 12 October 2019. For the consultation document, click here.

Rogue landlord database reform
​The database of rogue landlords and property agents was introduced in April 2018. The database is targeted at only the most serious and prolific criminals, who are convicted of the limited range of banning order offences. The database is currently an enforcement tool available to local authorities, except in certain circumstances where anonymised, aggregated data can be requested by the public.

In October 2018 the Prime Minister committed to opening up access to information on the database of rogue landlords and property agents to tenants. This consultation is seeking views on widening access to the database to allow tenants and prospective tenants access to the database. To ensure that the database is a useful tool for local authorities and tenants, we are also seeking views on expanding the scope of offences and infractions which could lead to entries on the database.

Annex A contains the current list of offences and infractions which lead to inclusion on the database. Annex B contains a list of proposed offences and infractions for inclusion on the database.

The consultation closes on 12 October 2019. For the consultation document and annexes, click here.

Mobile homes: a fit and proper person test for park home sites
In 2018, following a review of park homes legislation, the government gave a commitment to introduce a fit and proper person test for site licence holders and managers of park home sites in England, subject to a technical consultation. The purpose of the test is to improve the standards of park home site management. This consultation is intended to ensure that the regulations will support effective operation of the fit and proper person test in practice. The consultation closes on 17 September 2019. For the consultation document, click here.

Homelessness Reduction Act 2017: call for evidence
The Government regards the Homelessness Reduction Act as a key lever for reducing homelessness and helping to halve rough sleeping by 2022 and ending it altogether. This call for evidence seeks to gather evidence on:

  • the impact the Act has had and the outcomes that are being achieved;
  • how has the Act changed the approach of local housing authorities and their partners to tackling homelessness and supporting those in need;
  • the experience of people approaching their local housing authority for help;
  • how the implementation of the Act has been resourced, including the level of new burdens funding to assist this; and
  • what elements of the Act and processes are working well, and which might need adjustment.

The consultation closes on 15 October 2019. For the consultation document, click here.

New national model for shared ownership
The government is reviewing a new national model for shared ownership to make it easier for people to buy more of their own home, including allowing them to buy in 1 per cent increments.

The MHCLG is seeking views on:

  • making it easier to increase the share a person owns: allowing owners to purchase shares in much smaller increments
  • making it easier to sell the home: by giving the owner more control over the sales process
  • making it easier to get a mortgage: by ensuring there is one preferred national model for shared ownership.

The consultation closes on 29 September 2019. For the consultation document, click here.

Make Sure you Keep Up to Date with Housing Law Week

Don’t miss out on your weekly updates!
Sign up here now to ensure you receive your own free copy of Housing Law Week straight to your desktop each week.

HOUSING LAW ARTICLES & PUBLICATIONS
 

We need social housing, not warehouses, for homeless kids Daniel Lavelle Guardian 22 August 2019 – to read the article, click here

How can children thrive when they are squeezed into cramped homes? Barbara Ellen Guardian 25 August 2019 – to read the article, click here

In the county courts – succession, possession and warrants Giles Peaker Nearly Legal 26 August 2019 – to read the article, click here

Possession and licensing in Wales Giles Peaker Nearly Legal 26 August 2019 – to read the article, click here

As a sector, we must do better to help victims of domestic violence Callum Chomczuk CIH Blog 27 August 2019 – to read the article, click here

From the Frontline: the ongoing impact of welfare reform Tom Weekes Shelter Blog 29 August 2019 – to read the article, click here

Services charges and additional provisions John Murray Local Government Lawyer 29 August 2019 – to read the article, click here

The five-week wait is five weeks too long Steph Kleynhans Shelter Blog 30 August 2019 – to read the article, click here

No Help to Buy Alex McCallum Shelter Blog 2 September 2019 – to read the article, click here

Housing: recent developments Sam Madge-Wyld and Jan Luba QC Legal Action September 2019 – to read the article (subscription required), click here
HOUSING LAW DIARY
 

5 September 2019                                
National Assembly for Wales returns

5 September 2019                                
Closing date for submissions to the call for evidence in respect of tenancy deposit reform (see Housing Law Consultations)

5 September 2019                                
Closing date for submissions to the Welsh Government consultation on increasing the minimum notice period for a no fault eviction (see Housing Law Consultations)

9 September 2019                                
Closing date for submission to the consultation on proposed changes to local authority housing statistics (see Housing Law Consultations)

30 September 2019                              
Closing date for submissions to the Labour Party’s consultation on Labour’s new deal for leaseholders (see Housing Law Consultations)

Advertise your vacancy to Housing Law Week Readers

Send details of the vacancy and a link to the vacancy on your website to info@limelegal.co.uk
RECRUITMENT
 
Housing/Property Litigation Solicitor
TV Edwards LLP
Click here for details
 
 
Housing Lawyer
Shepherds Bush Housing Group
Click herefor details
 
 
Housing Options Officer
North Warwickshire Borough Council
Click herefor details
 
 
2 Solicitors
Osbournes Law
Click herefor details
 
 
Paralegal
Osbournes Law
Click here for details
 
 
Environmental Health Officer
Bath & North East Somerset Council
Click here for details and insert ‘housing’ in key words
 
 
Senior Housing Needs Officer
Brighton and Hove City Council
Click here for details
 
 
Homelessness Prevention Officer
Coventry City Council
Click here for details
 
 
Lime Legal Limited, Greengate House, 87 Pickwick Road, Corsham, Wiltshire, SN13 9B