Running a contractor business has never been tougher. Every day, members tell us they’re facing:
Cash flow pressure that never seems to ease.
Difficulty finding — and keeping — good people.
Ever-tightening compliance and more onerous contracts.
Long hours, constant stress, and no clear way out.
In this latest intervention, FIS has worked with business consultant Dave Drimmie to develop a practical, hands-on programme designed to free business owners from firefighting and help them create systems that can help them escape the firefighting stage and start to scale their business.
The FIS Freedom Programme is initially upen to 12 contractors for a pilot programme. The programme is fully funded and will comprise of:
12 guided sessions (1–1.5 hrs each).
Business owner involved in the first 2 sessions.
Then your team works with us to document and digitise the core systems that run your business.
Government funding covers the pilot phase costs — so this first intake is fully supported.
The programme sets out to deliver:
Financial clarity – take control of cash flow and profitability.
Repeatable systems – extract what’s in your head and build processes that scale.
Empowered employees – attract, train, and keep five-star team members.
Elevation – win high-value clients at higher margins.
Deliver seamlessly – streamline projects, reduce errors, and improve profit.
Optimise – harness digital tools and AI to save hours every week.
Make saleable – create a valuable asset that isn’t dependent on you.
But with only 12 places available, you’ll need to act fast. Applications close 9pm, Sunday 28th September 2025 (due to funding constraints, this is a hard stop deadline for this pilot).
On 1st July 2025 Build UK published Version 5 of the Common Assessment Standard (CAS). Significantly the Building Safety section, introduced in 2024, will now become mandatory for all FIS Members undertaking regulated design or building work (not just Higher Risk Buildings).
Principal Contractors are advising that Specialist Contractors in their supply chain should have successfully completed the Building Safety section by 1 October 2025.
What does this mean to FIS Members?
If your company is already CAS certified through one of the recognised Pre Qualification Questionnaire (PQQ) providers (e.g CHAS, Constructionline, Achilles etc), you will need to complete the new mandatory Building Safety question set as part of the updated overall question set the next time you renew or go through the certification process with a Recognised Assessment Body.
The Common Assessment Standard continues to gain traction across public and private sector clients as a key tool to demonstrate organisational capability and compliance under the Building Safety Act. Certification is required only once via any of the Recognised Assessment Bodies, and businesses are encouraged to review their current accreditations to avoid duplication and reduce unnecessary bureaucracy in pre-qualification.
FIS has (since Version 5 was published) been invited to join the working group that sets the standards so members are encouraged to feed any concerns or observations around the existing questions to jamesparlour@thefis.org.
FIS also hosts a mirror group that is, as well as reviewing and feeding into the assessment criteria, helping create resources and guidance to support members in completing this section including an Integrated Management Standard, a Template Building Safety Policy and a range of resources and guidance designed to help complete key questions.
The Common Assessment Standard is being used by a growing number of organisations across the industry to demonstrate that members of their supply chains have the organisational capability to fulfil their duties under the Building Safety Act. Pagabo and Structure Tone are the latest to specify it, and a full list is on the Build UK website.
Companies that have the Common Assessment Standard from any one of the Recognised Assessment Bodies do not need to obtain certification from any others. Instead, they can agree to share their data at no cost with the other Recognised Assessment Bodies so it is visible to more Contractors and Clients. Don’t duplicate: anyone wishing to see a reduction in the bureaucracy of pre-qualification should be sharing their data rather than getting the Common Assessment Standard from multiple Recognised Assessment Bodies. Giving permission to share your data is quick and simple and will help businesses across the supply chain to save time and money and win work.
If you have been certified through the Common Assessment Standard are being asked to use a specific PQQ procedure, FIS has prepared some specific wording to send to the company requesting and a whistle blowing process to help ensure that companies are not required to hold multiple accreditations.
Build UK has updated its payment performance table to include data on the value of invoices paid within 60 days for the first time. Following the introduction of new reporting requirements from 1 January 2025, large companies are now required to report on both the value and number of invoices paid within 0 – 30, 31 – 60 and over 60 days to provide even greater transparency for the supply chain around payment performance.
Information on the value of invoices paid within 60 days is currently available in the Build UK table for 16 out of 21 tier one Contractor members that are required to report. The full set of results will be available in May 2026 when the remainder have submitted their first reports.
On average, Build UK tier one Contractor members paid 97% of invoices within 60 days by value compared to 96% by number, which highlights consistency of payment performance within 60 days whether measured by value or number of invoices.
In terms of payment performance it remains a concern that on average 16% of invoices are not paid on time and particularly concerning to see three house builders topping the league for percentage of invoices not paid within terms (Countryside Property – 53%, Vistry – 47% and Crest Nicholson – 39%). Due to the way that companies are required to report on the value of invoices not paid within the agreed terms, Build UK is not able to include this data in its table at this stage, but report that they are in discussion with the Department for Business and Trade about what can be done to collect and present this data in a meaningful way. In the meantime, businesses in the supply chain can check data by linking through to the detailed reports provided on the Government Website.
Commenting on the numbers, FIS CEO Iain McIlwee stated:
“We don’t have a full set of data yet and whilst it is positive that value and volume of invoices paid over 60 days does seem to align closely, the devil remains in the detail. It is a concern that close to a quarter of companies on the list are paying over 20% of their invoices outside of terms. Delve further and it gets worse. Two national house builders top the table in terms of not paying invoices within the agreed period, averaging half their invoices being paid outside of terms. Withheld payments from just these two businesses (categorised late and disputed) equates to an eye watering amount – in excess of £0.5 billion. This for me is scandalous. This isn’t free credit, it comes at a premium, it impacts viability, productivity and the ability of the supply chain to invest. This behaviour is at the root of the construction challenge, beyond the business argument it places a huge burden on a beleaguered supply chain, it isn’t just crippling the industry, it is destroying lives.”
The Government has also laid draft legislation to require companies to include their payment results in their Directors’ reports from 1 January 2026 and is consulting on further measures to improve payment practices as part of its Small Business Plan. FIS is urging members to attend a webinar hosted on the 9th September with the Department for Business and Trade that is supporting the consultation process.
Construction News has today reported that a group of specialist contractors working for ISG have formally threatened the Ministry of Justice with legal action following payments not being forthcoming for works completed and certified undertaken as part of prison construction at the time ISG entered administration.
These contractors and a wider group have been supported throughout by FIS who held a town hall meeting for impacted businesses in November last year when it became apparent that specialist contractors in the community were not going to get the protection expected from the Project Bank Accounts. There were 17 contractors involved in this first meeting and the group ballooned to 40 from across the construction sector that have been directly impacted. FIS introduced Hill Dickinson to the conversation and they have been advising the group since. On 11 August, Hill Dickinson, sent a pre-action letter to the department on behalf of six of these firms, demanding payment of unpaid money that was expected in August last year – the month before ISG’s collapse.
Commenting on the case, FIS CEO Iain McIlwee stated:
“We remain very concerned about how the supply chain of ISG have been treated and what we perceive to be a failing in the protection that should have been afforded through the administration of Project Bank Accounts. Specialist Contractors did an honest days work and for no fault of their own find themselves again carrying the can for others. We have tried to use all channels available to us to secure payment for this group of SMEs and are grateful to Hill Dickinson and Len Bunton for their advice throughout the process and to Lord Aberdare for championing the cause of these contractors in Government by raising key questions formally through the house.
Finishes and Interiors Sector will continue to do all we can to try to get some justice for these contractors and to ensure that lessons are not just learned, but changes are made.”.
Hill Dickinson partner Kate Kenneally, who is working on the case, said: “As the ultimate client and a party to the PBA Trust Deed, the MoJ is contractually obliged to ensure these payments are made. The failure to do so constitutes a breach of both the PBA and the associated contractual framework.”
Government has backed up commitments to tackling the scourge of late payments and retention in the construction sector by seeking views on a package of proposed legislative measures. The package of new measures is claimed to be the most significant attempt to address late, long and disputed business to business (B2B) payments in over 25 years.
The consultation recognises that late payment impacts 1.5 billion businesses and ultimately costs the UK economy almost £11 billion per year and closes down 38 UK businesses every day. Commenting on the launch of this consultation on 30th July, the Prime Minister, Kier Starmer stated:
“From builders and electricians to freelance designers and manufacturers—too many hardworking people are being forced to spend precious hours chasing payments instead of doing what they do best – growing their businesses.
“It’s unfair, it’s exhausting, and it’s holding Britain back. So, our message is clear: it’s time to pay up.
“Through our Small Business Plan, we’re not only tackling the scourge of late payments once and for all, but we’re giving small business owners the backing and stability they need for their business to thrive, driving growth across the country through our Plan for Change.”
The consultation proposes the following package of legislative measures:
Policy
Description
1. Audit committees and board-level scrutiny of large company payment practices
In September 2024, the government reaffirmed commitments to legislate on audit committees and other board level responsibilities to improve payment practices. The government believes further positive change could be achieved by increasing discussion and scrutiny of large companies’ payment practices at board level.We would welcome views on how government could best achieve this in the future with proportionate regulatory burden. For example:
A. Ensuring audit committees or company boards, where companies have them, provide commentary and make recommendations regarding payment performance to company directors before the data is submitted to government and included in the director’s report. This would include data provided as part of the Reporting on Payment Practices and Performance Regulations 2017, and any interest on late payment liabilities.
B. Ensuring the Small Business Commissioner writes to audit committees and company boards, where companies have them, when i) undertaking payment performance reporting assurance and ii) when investigating any other matter relating to a companies’ payment practices.
We would welcome views on these ideas, including the likely positive effects, costs, or any unintended negative consequences. We would also welcome other additional ideas to encourage greater discussion of payment practices at board level.
2. Maximum payment terms
The policy will amend The Late Payment of Commercial Debts (Interest) Act 1998, removing the exemption that allows businesses to agree to payment terms longer than 60 days if considered not ‘grossly unfair’. This will effectively limit payment terms between UK businesses to 60 days. Subject to further consultation, this policy may subsequently reduce this limit from 60 days to 45 days after 5 years.
3. A deadline for disputing invoices
The policy will amend The Late Payment of Commercial Debts (Interest) Act 1998, introducing a 30-day invoice verification period. Businesses who wish to raise a dispute will need to do so within 30 days of receiving an invoice, otherwise they will be liable to pay the invoice in full within the agreed payment terms, alongside any statutory interest or debt recovery costs if the invoice is paid late.
4. Mandatory statutory interest
The policy will amend The Late Payment of Commercial Debts (Interest) Act 1998, making the statutory interest rate payable on late payments mandatory. This will remove the ability to negotiate compensation rates lower than the statutory rate. This will increase existing financial incentives to pay invoices on time.
5. Additional reporting on statutory interest
The policy will amend The Reporting on Payment Practices and Performance Regulations 2017 to include additional reporting requirements around statutory interest liabilities. This will further increase transparency around poor B2B payment behaviour and informs other policies that aim to improve the utilisation and payment of statutory interest.
6. Financial penalties for persistent late payers
The policy will introduce new legislation, which gives the SBC powers to issue financial to businesses who persistently pay their suppliers late. The policy will use payment behaviour data submitted by businesses under The Reporting on Payment Practices and Performance Regulations (2017) to identify and issue financial penalties to persistently late-paying businesses, with penalties based on businesses’ unpaid statutory interest liability.
7. Additional powers for the SBC, including assurance of payment reporting data
The policy will amend The Enterprise Act 2016 to give additional powers to the SBC. The additional powers would improve the SBC’s ability to conduct investigations into poor B2B payment behaviour (beyond its current complaints scheme), allow it to provide legally binding arbitration in disputes, and impose financial penalties or make arbitration awards after an investigation or arbitration process.The policy will also enable the SBC to investigate the accuracy of the payment reporting data that large businesses provide under The Reporting on Payment Practices and Performance Regulations 2017. This will improve the quality of reporting data and support the reporting regulations original objectives of improving transparency around B2B payment behaviour.
8. Use of retention clauses in construction contracts
The policy will amend Part 2 of the Housing Grants, Construction and Regeneration Act (1996), to either prohibit the use of retentions or to introduce requirements to protect retention funds deducted and withheld from insolvency and late or non-payment.
Commenting on the consultation FIS CEO Iain McIlwee stated.
“This is a very welcome piece of work to get our teeth into over the summer, but on the surface is a very good set of measures and encouragingly consistent with the asks in our Blueprint for Better Construction. Greater scrutiny and tougher sanctions are needed. Point 8 really jumps off the page when we think about reform in the context of construction. Mismanagement of Retention remains a contentious and concerning problem that undermines trust, liquidity and with it the wider improvements in culture, investment and productivity that we need to see in construction.
FIS, along with a chorus of associations across construction, has long advocated for reform, but we have seen little action, just roadmaps and bluster. Tackling this in the Construction Act is the only way we will realistically see change. Our position remains that the Act should be amended to ensure retentions are automatically released at a defined date. They should not require additional applications from contractors or relate to dates that are not explicit to the completion of their works and events beyond their control. Additionally, the UK should seek to replicate the recent developments in New Zealand where it has been legislated that retentions are held in trust. When Collateral Warranties are implemented, retentions should be immediately and automatically returned.”
The consultation will run from 31 July 2025 to 23 October 2025. We are encouraging businesses to have their say. You can respond directly, but please feed in your views to FIS so that they can incorporate your views into their collective response. Please email any comments to iainmcilwee@thefis.org
Listen to our webinar discussing the above proposals
Hear directly from representatives of the Department of Business and Trade on the proposed measures, how they will be introduced and raise any questions as part of their information gathering ahead of the consultation closing on the 23rd October.
Growing concerns and legal challenges around acoustic performance claims led FIS in 2018 to take positive action and launch an acoustic verification scheme that covered glazed and demountable partitions and acoustic walls. The scheme reviews test data through a third-party verification process (carried out by independent acoustic engineers), performs a series of checks to verify information is accurate and genuine against marketing claims.
Verified Products can be marketed with the FIS Acoustic Verified Certificate and listed as Acoustic Verified on NBS to provide reassurance to specifiers and users. FIS members are poised to add a number of new product lines to the scheme and, as the verification cost is based on batch pricing, FIS is opening up the next round of verifications to all members to ensure that we can offer best value in bringing products into the scheme.
The scheme, developed through the relevant FIS Working Groups, established standard methodology for how tests should be conducted and reported. This means products can be effectively compared and the potential for inaccurate or misleading information from undermining project integrity and responsible manufacturers is limited. In 2024, for similar reasons, the scheme was extended to cover the validation of claims for acoustic pods. Larger meeting room pods are marketed as flexible solutions to provide acoustic privacy. However, ISO 23351-1:2020 states that the pod should not occupy more than 5% of the volume of reverberation test chamber. For most test chambers, this limits the maximum pod size to 11m3, leaving this emerging sector to use inconsistent parameters when making marketing claims.
The classification certificates will indicate to an acoustician that there is deep, verified data behind the classification allowing the acoustician to have a reliable dataset to use within their assessments.
If you are interested in bringing your products into the scheme or adding to your range of already verified products, please email info@thefis.org and we’ll get details of next steps out to you. Any questions call the FIS on 0121 707 0077.
For more details on how you can specify with confidence with the FIS Acoustic Verification Scheme, click here.
Yesterday Government announced a consultation that could see procurement law impemented that would effectively force all public contracting authorities to exclude firms that fail to meet the recognised payment standards.
On launching the consultation Georgia Gould MP OBE, Parliamentary Secretary for the Cabinet Office stated:
By strategically leveraging our annual public procurement spend, we can protect our supply chains, open up new opportunities for local small businesses and social enterprises, create good local jobs, and deliver greater value for taxpayers.
How reforms could work.
The Procurement Act 2023 (the ‘Act’) has already been implemented and reforms the rules that govern the £385billion spent through public procurement every year. In line with the manifesto, the Government intends to use the Act to create a simpler and more transparent regime for public sector procurement that delivers better value for money, drives economic growth, and safeguards national interests. This consultation looks to take the Act further by:
Supporting small businesses and social enterprises
Requiring large contracting authorities with spend over £100m p.a. to publish their own 3-year target for direct spend with SMEs and VCSEs and report against it annually, as well as extending spend reporting requirements.
Requiring contracting authorities to exclude suppliers from bidding on major contracts (+£5m) if they cannot demonstrate prompt payment of invoices to their supply chains.
Clarifying in primary legislation where it may be appropriate to award contracts for certain services delivered to vulnerable citizens without full competitive procedure, so that decisions can be driven by the needs of the individuals and vulnerable groups.
Supporting national capability
Requiring contracting authorities to make a standard assessment before procuring a major contract (+£5m) in order to test whether service delivery should be inhouse or outsourced.
Supporting local jobs and skills:
Requiring contracting authorities to set at least one award criteria in major procurements (+£5m) which relates to the quality of the supplier’s contribution to jobs, opportunities or skills. Contracting authorities would need to apply a minimum weighting of 10% of the scores available, to social value award criteria.
Requiring contracting authorities to set at least one social value KPI relating to jobs, opportunities or skills in major contracts (+£5m) and report on delivery performance against this KPI in the contract performance notice.
Requiring contracting authorities to use standard social value criteria and metrics selected from a streamlined list (to be co-designed with the public sector and suppliers) in their procurement of public contracts.
Allowing contracting authorities to specify the area in which the social value is to be delivered by choosing between the location of a contracting authority’s area of responsibility, the location where the contract will be performed, or the location where the supplier is based.
Based on the feedback on these proposals and when parliamentary time allows, the Government intends to introduce legislation to amend the Act. As part of this process the government will also look to introduce minor technical amendments to the Act under this legislation.
FIS will respond to the consultation formally, but Iain McIlwee, CEO of Finishes and Interiors Sector welcomed the consultation:
“For too long we’ve had a wishy washy approach to driving better payment through the supply chain with veiled threats of sanctions that “could” be applied. The rhetoric has not been matched by action and the reality is that we have seen little benefit to Government paying faster finding it’s way into the supply chain. It finally looks like this is being addressed and the changes set down here should start to add some teeth to the intent.
We will spend some time going through and looking for any loopholes that this leaves and respond formally, but initial inspection suggests it is a good start. Beyond these reforms we hope to see further activity around Late Payment rules and pushing those outside of the Public Sector to address payment fairness and retention moving forward. The payment culture has been a cancer at the core of our industry without addressing it, any improvement in investment in people or productivity will be limited. If we want to get Britain Building, we need to get money flowing.”
Please send any comments directly to iainmcilwee@thefis.org to support FIS response, but we also encourage members to respond directly to the consultation via the link above.
Finishes and Interiors Sector (FIS) was invited this week to attend a Round Table hosted by the New Hospitals Programme along with other national trade bodies to understand how we can maximise opportunities presented by programme for members. The discussion introduced the NHP Plan for Implementation as set down by the Rt Hon Wes Streeting MP, Secretary of State for Health and Social Care. The Plan aims to be a thorough, realistic and costed timetable for delivery ensuring the programme is on the soundest possible footing for delivery of our new hospitals. NHP will be backed by up to £15bn of investment for each five-year spending period, averaging £3bn a year by 2030 to be confirmed at regular Spending Reviews.
The discussion focussed on existing supply chain delivery challenges and how this varies regionally, understanding issues such as labour availability, alignment with other major projects and how we can work more collaboratively to support the programme.
Commenting on the meeting, FIS CEO, Iain McIlwee stated:
“This was a good, open and frank discussion and we got into some of the nitty-gritty of procurement, contracting, where and how modern methods construction can be adopted and workforce availability. Ultimately there is a massive opportunity for the sector and it is encouraging that the team at NHP are engaging early and keen to work with the supply chain and help us in addressing some of the challenges.”
More information on the programme is available within the NHP Supplier Guide. FIS has committed to working closely with the NHP and our membership to support the development and delivery of this plan.
The FIS Wage Rate Survey 2025 (data gathered in the first quarter of the year) revealed that, across the trades, FIS members have continued to experience increases in wage rates averaging around 7% in key trade occupations (the full index is available to contributors only).
Commenting on the data FIS CEO Iain McIlwee stated:
“The data underpins that the supply chain continues to be hit by inflationary pressures with an annual increase of 7% in 2025 piling on top of double digit inflation in 2024. If we look at what this means in real terms, for some trade areas rates are now (cumulatively) 75% higher than when we started to gather data in 2020. If we compare this to the wider economy, construction wages continue to outstrip the national average which was below 6% in 2025 and 2025. This is putting real pressure on specialist contractors. Comments gathered as part of the research raised concerns linking this inflation to shortages in key trade areas. If the market does start to improve in 2025 and 2026 there are very real concerns that the skills are simply not going to be there to meet demand. To address this, it is vital that recent Government announcements about investment in skills don’t just get lost in long term strategy, but are invested in supporting employers now in training and developing their workforce.”
The survey also points to changes in the structure of the workforce, which continues to trend away from direct employment, which has fallen from 26% in 2021 to 23% in 2025.
FIS also gathered data on Payment Trends, with around 20% suggesting that payment payment practices have worsened in the past 12 months and less than 5% reporting improvements.
FIS responds to review of the existing national curriculum and statutory assessment system in England. The consultation was launched by the new Government to explore how the the curriculum can evolve to more appropriately balance ambition, excellence, relevance, flexibility and inclusivity for all children and young people.
Specifically it was looking at how the educational system can provide::
an excellent foundation in core subjects of reading, writing and maths
a broader curriculum, with improved access to music, art, sport and drama, as well as vocational subjects
a curriculum that ensures children and young people leave compulsory education ready for life and ready for work
a curriculum that reflects the issues and diversities of our society, ensuring all children and young people are represented
an assessment system that captures:
the strengths of every child and young person
the breadth of the curriculum
In their response FIS raised concerns about the disjointed approach to qualification, the failure to embed a core understanding of careers and key vocational requirements within the existing curriculum.
Two new training courses have been added this week to the FIS e-Learning Hub. The courses aim to support members in managing individual competence associated with key package areas.
The first course is the Firestopping of service penetrations: Best Practice. The aim of this course is to assist in the design, specification and installation of building services penetrations to ensure fire compartmentation is maintained, five leading not-for-profit organisations have been involved in the development of the Guide on which this course is based. The aim of the course is to encourage early consideration of firestopping design in order to avoid problems at a later stage in construction. It is not an installation course but guidance to a good practice approach. The training is broken down to provide information on actions that should be carried out during each of the stages, one to seven, as defined in the RIBA Plan of Work.
The second course is a new interactive Pre-Construction Guide to Drylining. The course has been pulled together from decades of experience and focuses on the lead-up to commencing installation works. It highlights how to check bids and tenders for compliance, understand time requirements and site conditions, and ensure the design information is sufficient and fit for purpose.
Both courses are available freely to FIS members and CPD certificates will be issued on completion.
Speaking on the launch of these courses at the AGM on 7 November, FIS President Ian Strangward said:
“The bank of knowledge which FIS has built is impressive – we now need to make sure that we are not just a font of knowledge, but a modern information provider. It is not good enough to just have information available, we must work smarter to ensure it is used – getting to the right people in the right way. Our e-Learning Hub is going to be key. The first course we put up “an Introduction to the Building Safety Act” has been a great start, several hundred people have already completed the course and feedback has been very positive. In these next courses, “Firestopping of service penetrations: Best Practice” and particularly, our “Pre-construction guide to drylining” you will see progress in the quality of delivery. Now we have a process, you will be seeing a regular flow of new courses targeting vital interventions, job titles and knowledge gaps”
The Fire Wall Labelling campaign launched in 2023 has had a refresh this month with a new web area established to help promote the campaign. The fire wall labelling initiative aims to help identify fire walls and provide instant guidance on what to do when passing cables and pipes through the compartment.
Last year Finishes and Interior Sector (FIS), Association for Specialist Fire Protection (ASFP), and Gypsum Products Development Association (GPDA) joined forces to create this free to use labelling scheme that warns of the dangers of passing cables and pipes through compartment walls (Fire Walls).
The Fire Wall label is a simple and visual way of ensuring that those that could undermine the fire integrity of a wall to realise that it isn’t just a wall, but it is a Fire Wall. The label provides instant guidance via a QR code on what to do when considering whether and how to pass cables and pipes through compartment walls. It runs through a simple STOP, THINK, PLAN, CHECK and RECORD process and provides links to best practice guidance that will help ensure that safety is not undermined.
New requirements in the Building Regulations identify the need for businesses to demonstrate organisational capability. On a basic level, this means businesses will need to evidence how they check people are competent and ensure they are supported by effective process controls that support consistent delivery. This is not really a significant change as businesses have always had a legal requirement to ensure all reasonably foreseeable risks are effectively managed, but it does mean clients and Building Control officers will be showing more interest in your processes and management systems and will have more tools at their disposal to enforce where a business or individual fails to hit the required standards.
To support our community, the FIS Integrated Management Standard (IMS) has been relaunched as part of a newly developed Organisational Capability Toolkit. This toolkit will help members implement tried and proven methods of streamlining their company for the benefit of their business and its stakeholders. The toolkit will help to link and contextualise the wealth of information that FIS members have available to support compliant business management and how they can use their membership to support claims of organisational capability.
This IMS sits as a central resource to help align and control resources. It provides a framework for implementing risk management systems (supported by the FIS Product, Process, People Quality Framework) that will help organisations to meet statutory and legislative requirements.
On relaunching the standard at the FIS Conference and AGM in November, FIS CEO Iain McIlwee stated:
“This standard was developed originally to support the FIS vetting process, but really comes into its own in this new environment. It is clear in our work with members that many construction firms have great processes in place, but there can be a real disjoin between these processes. Across the sector we see design, procurement, contracts and legal, and construction processes that should complement and support each other, however they often clash, cause confusion and conflict and ultimately undermine delivery. This toolkit is a great opportunity to start to look collectively at how we can not just hit the baseline of compliance, but help to raise standards, promote professional businesses and support the Responsible No”.
FIS CEO, Iain McIlwee explores the importance of the word “No” in construction.
The procurement research FIS published in February 2023 coined the expression the “Responsible No”
“No” is a tiny word, one syllable, but at times, the hardest to say. If we say “No” to a clause in a contract, there always seems to be another firm willing to say “Yes”. If we raise too many issues, or qualify too much in our tender response, we may well lose the job. It is easy to talk about “No”, but in a tight, price-sensitive market, with mouths to feed…
The problem is that if we don’t exercise the option of “No”, if we don’t clarify, qualify and draw the line we take responsibility for issues outside of our control, assume responsibility for compliance and sign up to damages and delays that we can’t cover. Even if we avoid the worst of the financial hit, how often do we find ourselves staring at a detail on a construction site, scratching our heads and working it out on the fly – “the site fix”?
Regulation is driving change, common sense demands it
Changes to The Building Act 1984 carried through as part of the Building Safety Act changes, mean that we are liable for that detail for 10 years from a Building Control enforcement perspective and if it impacts fire or structural safety, it could be a 15-year plus liability (with prison sentences if it can be proved we were negligent).
As a sector we pride ourselves on our ability to get the job done, to adapt the design and make it work, but duties in the Building Regulations are now clearer and more onerous. The regulatory environment has changed, a heart full of hope and a tube of mastic isn’t enough.
On higher risk projects we’ve got major and notifiable changes – strict change control processes that should be in place. On all jobs, the building control officer is under greater pressure to ensure evidence is provided – they want to see (or photos of) as-built details backed by evidence of performance and competence.
The principal designer needs to start signing the job off on completion too, it is all about evidence, quality control and information management. If the principal designer won’t support or Building Control won’t sign-off, works stops and with it the flow of monies, I refer you back to the cost of delays mentioned above.
Design liability and elements thereof are being pushed deeper into the supply chain leading to confusion around accountability for design elements. Beyond the intended free-standing additions to the construction contract template, the norm has become to add complex schedules of amendment pertaining to design and programme responsibility. The potential for this to cause confusion around risk and contingent risk, impact insurability and create gaps in insurance cover for specific elements (particularly interface details and fixings) is a real concern. The impact is that businesses, buildings and projects may be uninsured or have significantly less cover than clients currently believe is the case.
Can we fix it?
The old days of “Bob the Builder, can we fix it?” and a rousing chorus of “Yes… we can” is changing. The retort now needs to be more like: “Not necessarily Bob, certainly not until Sarah the supervisor has checked with Alan the architect who has reviewed against the design, clarified with Edna the engineer and Mike the M&E designer, and ensured Quinn the quantity surveyor is aware. We also need to consider if we need to advise Barry the building control officer and he may need to liaise to Bertha the building safety regulator and Ivor the Insurer before … We can!”
This is a cultural change that we need to filter through our supervision protocols, into our Tool Box talks, and embed in our daily processes. But it isn’t just a site thing. Len Bunton always reminds me that dispute resolution begins and most problems could be solved before we sign the contract. There is always risk in construction, but with new potential for delays and new liabilities, we must understand these risks, cap them appropriately and insure them effectively.
Yes, but…
This need for risk awareness is the reason that we have introduced an FIS Contract Review Service. We know that 41% of our members never seek legal advice (scarily only 17% never start on site without a contract in hand!). This subsidised service is about helping members understand the risks and how to push back. It is also about FIS isolating unreasonable requests and pushing back as a collective. Getting your contracts reviewed routinely would be a good New Year’s Resolution. The “Responsible No” is a big ask, but sometimes we do need to say No, it shouldn’t be a flat No, but No, my insurance wouldn’t cover that, No we are not competent to Design that or simply No that is more risk that we can reasonably be expected to take on.
Remember compliance is changing clients have duties along with designers and contractors and good compliant projects supported by a resiliant and professional supply chain are essential. The truth is that we don’t need to say No to everything, but if more of us call out the unreasonable demands, we can start to say Yes to the work, but No to irresponsible asks – maybe we can make 2024 the year of the Confident, well Reasoned “Yes, but…”.
As FIS have explored the competence and capability with our community, the importance of deploying “No” has been repeatedly raised. Ultimately competence and capability require you to know your limits and ensure that all reasonably foreseeable business risks can be effectively managed and addressed.
If we don’t clarify, qualify and draw the line we take responsibility for issues outside of our control, assume responsibility for compliance and sign up to damages and delays that we can’t cover.
The FIS is focussed on Empowering the Responsble No and has launched a campaign to support this.
The Construction Leadership Council (CLC) has published a hard hitting statement calling a halt on the ongoing practice within the construction sector, of industry-approved forms of contract being amended by clients and their solicitors to introduce terms that are onerous and/or difficult to insure. This statement has been issued and is the conclusion to ongoing work through CLC Professional Indemnity Insurance Working Group.
The Construction Leadership Council (CLC), as part of the Building Safety Workstream, established a Working Group to focus on Professional Indemnity Insurance. The key objective of the group was to understand and look to address concerns over the cost, availability and limitations in insurance cover for all parts of the supply chain, from principal designer and contractor through to consultants and specialist contractors. As part this work the PII Taskforce supported an International Underwriting Association event on 31st January 2024 entitled “Competence in the Construction Sector”. The event reviewed new regulatory requirements in the Building Safety Act. Speakers were drawn from the construction, governmental, regulatory, legal and insurance sectors with particular focus on competence requirements and how they may help to reduce risk in the construction process. Wider inference of the Building Safety Act and what can be learned from recent court cases was also covered.
An open panel debate followed looking at the implications on the insurance process. It was recognised within these discussions that, whilst the work on competence is encouraging and should help to reduce risks moving forwards and hence availability of cover. Concerns were raised over design liability being pushed deeper into the supply chain leading to confusion around accountability for design elements. It was noted in discussion that heavily amended contracts add to confusion around risk and contingent risk, impact insurability and potentially create gaps in insurance cover for specific elements (for example, interface details and fixings).
Following exchange between the Insurance Sector and representatives of the CLC confirmed that there is a need to highlight this risk. The key assertion in the statement is that “standard form building and engineering contracts and professional services contracts issued by contract-producing bodies, should be used by clients with no amendments, except where necessary in the context of project-specific risks and relationships. The CLC believes that onerous amendments make contracts unviable, reduce competition, increase risk and lead to unnecessary legal costs required to review legal liabilities created by the amendments”.
Introducing the statement Samantha Peat, Chair of the CLC PII Working Group said:
“A sensible approach will simplify risk allocation, give clarity to the project team and their PII providers, and address the concerns for which the CLC PII Working Group was originally formed, namely, to address concerns about cost and efficacy of Professional Indemnity Insurance in Construction. It will also support the focus on accountability, competence and the need for better information management called for by Dame Judith Hackitt and enshrined within the Building Safety Act and the wider reform of the Building Regulations.”
FIS CEO Iain McIlwee responded:
“This is a massive statement from the Construction Leadership Council – we have to stop this routine amendment of the standard contracts.
This statement echoes the long held concerns of the FIS Community and I would like to personally thank Samantha Peat and colleagues in this Working Group for the amount of time that has gone in to establishing the forum and drawing the right people together to have the open and pragmatic discussion with the insurance industry that has resulted in this clear an unambiguous statement.
We have a legislative process that focusses on duty and a contractual process that focusses on passing the buck – this is bound to create tension. Boundaries need to be reset or we are left with impossible problems, uninsured elements and ultimately the potential for stranded assets and uninsured buildings. T
his is Leadership and we applaud the CLC and supporting representatives from the Insurance Sector for taking a strong line. The statement in itself will not change the world, but what we do with it can. For me the clear message here empowers the Responsible No by starting to spotlight the Irresponsible Ask. Contract amends are at the heart of the cultural concerns in construction – change is inevitable and has I believe been catalysed today”
Through the FIS Responsible No Campaign, the organisation is offering subsidised contract reviews and asking members to report (particularly public sector) contracts that are subject to heavy amends and also provide details of Irresponsible Contractual Clauses so that FIS can address behaviours directly with the client. You can find out more about the FIS Responsible No Campaign here.
FIS has, since it’s outset supported the introduction of the Common Assessment Standard. This new approach was launched in 2019 by Build UK and the Civil Engineering Contractors Association following concerns that the proliferation of suppliers and duplication of effort and support associated with pre-qualification schemes. Through it’s introduction, the claim was that this approach will help the industry to £1bn by eradicating duplicate fees and inefficiencies.
The overall impact, whilst positive (over 22,000 companies now have the accreditation and a growing number of companies have formally adopted use) has not met the ambition and for this reason FIS is adding a Common Assessment call to action to the Responsible No campaign. Underpinning why this is important FIS CEO, Iain McIlwee stated:
“The Responsible No isn’t about digging our heels in, but starting to identify and address behaviours and processes that are barriers to better. This is a clear example of that. The waste here in fees and time is obvious, we have collectively agreed as an industry a better approach and implemented a new standard to do this. We all need to do our bit in helping to raise awareness and normalise this new approach. The reality is we can’t blame people for not doing stuff they may not know about or understand – this is all about helping to identify and explain why something is an Irresponsible Ask.
This is a particularly important time for this intervention with the use of PQQs being linked to new requirements for Organisational Capability enshrined in the Building Regulations and the potential for further proliferation as businesses look for angles to make more money rather than support a collective effort.”
To support this effort, FIS have prepared new guidance on the Common Assessment Standard for members and also a template email to recommend adoption on projects where a particular Pre Qualification scheme is listed as required. Where there is continued resistance to adoption, FIS has also set up a whistleblowing process to enable members to help FIS identify any resistance so that this can be understood and hopefully addressed moving forward.
Finally FIS is asking members to help take stock of where we are now at in terms of impact of the Common Assessment Standard by completing the FIS Pre Qualification Impact Survey here. Information will be used to support this collective effort and to help deliver change.
In a recent residential property tribunal, the roof terrace at Smoke House and Curing House in Hackney Wick, East London was deemed by the tribunal to be a seventh storey bringing it in scope of the definition of a higher-risk building under the Building Safety Act.
The case was brought by a group of leaseholders against the landlord (Monier Road Limited) to ensure remediation work was completed.
The tribunal agreed that Smoke House and Curing House should be classed as higher-risk “for the purposes of Part 4 of the Building Safety Act”:
“In our view, it should be registered with the Building Safety Regulator and have a Principal Accountable person appointed. This is not for the Tribunal to specify under the terms of a Remediation Order, but it is considered essential that this building (both Smoke House and Curing House) are managed under the Higher-risk Building regime. The remedial works should be carried out with an application to the Building Safety Regulator as Local Authorities and Building Control Approvers (previously known as Approved Inspectors) are not permitted to work on Higher-risk buildings.”
It is important to note the Tribunal itself acknowledged it was not within its jurisdiction to formally determine whether the building being considered was a higher-risk building. Until stated otherwise, the sector and regulatory bodies should continue to refer to existing government guidance.
The government announce the introduction of tougher measures to tackle late payments to small businesses.
Secretary of State Minister Jonathan Reynolds has set down his commitment to:
foster a strong payment culture in the UK by bringing the payment performance and behaviour of large companies more clearly into focus.
The Minister confirmed intent to lay secondary legislation “in this parliamentary session” to make it a requirement for large companies to extend information requirements about their payment performance in their Annual Reports. Changes will include the additional requirement to report on value of invoices outstanding and, for construction firms, their practices, policies and performance with respect to retention clauses in any qualifying construction contracts with suppliers. The measures are intended to increase transparency around the payment practices of large businesses and bring them into focus for boards and investors.
The Minister also confirmed that Government will be launching a new supercharged Fair Payment Code to be overseen by the Small Business Commissioner (a voluntary code of best practice for companies committed to fair and fast payments that can be set as a procurement requirement). This will replace the existing Prompt Payment Code, with a clearer and more measurable set of ambitious commitments and will be a further lever to improve the UK’s business payment culture by shining a light on the best performers.
The Department for Business and Trade will also be launching a public consultation “within months” on additional legislative measures to address late payments and long payment terms to ensure improvements in payment times, especially for small businesses and the self-employed.
The Small Business Commissioner, Liz Barclay, said:
I am delighted to announce a new Fair Payment Code will be launched this autumn. The new code will reward businesses that treat their suppliers fairly and pay them quickly. It will also include an ambitious new Gold Award which aims to make 30-day payments the new standard for which businesses can aim.
We need sustainable, resilient businesses at all levels of the supply chains, to achieve the growth the economy needs. That means paying everyone from the largest supplier to the sole trader quicker, so they have the confidence to invest, improve productivity and grow. Fair payment terms and on time payments are the key.
Responding to the announcements FIS CEO, Iain McIlwee said:
The measures on reporting are welcome and mirror the work we supported with the last Government and recently wrote to the Construction Minister (Sarah Jones) to ensure that they did not get lost in the change. The reality is that better measurement will help to isolate the problem, but further consultation and action is required to solve it. We can’t wait for the data to tell us what we already know. The problems the Minister is looking to address are hiding in plain sight.- we only need to look to the spate of recent insolvencies and particularly the devastation caused by the failure of ISG to see the ultimate impact.
We also welcome the changes to the Prompt Payment Code. FIS has worked closely with Liz Barclay and found her to be a powerful advocate for the SME and we will be doing all we can to support Liz in this work and ensuring that the Prompt Payment Code is front and centre on all Public Sector Jobs and principals starts to resonate with Responsible Clients in the private sector too.
FIS will be drawing on the Manifesto already issued to the Construction Minister as the mainstay of our response. Key recommendations included in this document are:
NEAR TERM LEVERS (which have been addressed in above):
More robust enforcement of the duty to report legislation: Improvements to the Payment Practices and Performance (Amendment) Regulations announced in Autumn 2023 are positive, but
need to be backed by effective enforcement. To date there has been no enforcement of the duty to report, and the Prompt Payment Code has not been backed with sufficient resources to deliver the intended changes. The Office of the Small Business Commissioner needs more authority and resource to support effective enforcement.
LONGER TERM LEVERS Reform of the Construction Act is required
The process surrounding application, due dates and pay less notices needs to be simplified to ensure that they cannot be abused. Drawing on international comparisons, the Irish Construction Contracts Act provides for a 30-day payment period from the date at which the payment claim is submitted. This is far simpler than the ‘due date’ referenced in the UK Construction Act, which relies on supplementary information in the contract that can be distorted. There is also less room within the Irish legislation to extend payment terms in a subcontract agreement.
The Construction Act should be amended to ensure retentions are automatically released at the defined date. They should not require additional applications from contractors or relate to dates that are not explicitly related to the completion of their works.
Equally, retention money should be held in trust; it cannot be forgotten that Carillion wiped out £700m of retentions held against the supply chain. Consideration should be given to replicating the recent developments in New Zealand where it has been legislated that retentions are held in trust.
Where Collateral Warranties are held, retentions should be immediately and automatically returned.
The process and cost of adjudication also needs to be considered. Costs will be eased by greater clarity in the Act on payments and better use of standard contracts. Adjudication decisions should be binding to
help avoid costly legal costs/
Make interest on late payment compulsary New EU regulations require compulsory interest payments to be automatically applied to late payment and accrued until payment of the debt. This makes non payment a liability as opposed to an enforcement right that an embattled supply chain is disinclined to impose.
If you have any views on payment reform that you feel should be reflected in FIS Lobbying work, please email iainmcilwee@thefis.org
Conducted in the run up to Fire Door Safety Week, a survey of 2,000 adults found that despite an 18% increase in fires across NHS trusts—averaging nearly four fires daily—52% of people still consider hospitals the safest due to their fire prevention measures.[1]
The survey, conducted as part of this year’s Fire Door Safety Week campaign (organised by the British Woodworking Federation), which runs from 23rd – 27th September, focuses on the theme ‘A False Sense of Safety’. The campaign aims to bridge the gap between perceived safety and actual fire risk, encouraging the public to engage in fire safety awareness and report any fire door issues, regardless of location or the assumption that fire safety is someone else’s responsibility.
When asked about fire safety in other buildings, 36% of respondents considered schools to be as safe as hospitals and 26% felt the same about care homes. This contrasts with recent reports from the East Sussex Fire and Rescue Service where two care home directors were fined nearly £125,000 for multiple fire safety violations, which included defective fire doors and a lack of detection equipment and alarms, across four premises.[2]
Helen Hewitt, CEO of the British Woodworking Federation (BWF) that manages and funds Fire Door Safety Week, said, “Our latest research shows that people often have a greater sense of fire safety in buildings like schools and hospitals. Regardless of where you are, it is crucial to be aware of fire safety measures, such as emergency exits and fire doors, because the risk of fire is present in any building.”
When considering building safety, emergency exits were cited as the most important factor in feeling safe by 75% of respondents, followed closely by visible fire safety measures, including alarms and fire doors (70%). Additionally, 46% of respondents said they always or often notice fire doors in the buildings they visit. Regarding the buildings where respondents believed fire doors are well-maintained, 47% felt that fire doors in public buildings, such as hospitals and cafes, are properly maintained.
The survey also found that 29% of people would not report a fire door issue because they would not know who to contact, despite 74% saying they would report a door that appeared damaged. Concerningly, this is a decline from last year’s campaign, ‘Recognise it, Report it’, where 86% said they would report a faulty or propped-open fire door. For unresolved fire safety concerns, 43% would escalate the issue to the Health and Safety Executive, while 5% would not escalate it at all, and 14% did not know who they would escalate it to.
Helen added, “Fire doors are crucial in preventing the spread of fire and smoke. It’s encouraging that more people are noticing fire doors in the buildings they visit, but there’s still work to be done to ensure people feel confident in spotting and reporting fire door issues. Knowing who to report these problems to is key—start with the premises manager or owner, and escalate unresolved issues as needed. With the correct information, we can all contribute to maintaining fire safety.”
Fire doors require expert maintenance to remain effective. However, 29% of respondents would trust management and 27% would trust the building owner to handle fire door issues, while 13% would trust a handyman and 19% a caretaker. For fire doors to function correctly, they must be installed and maintained by a competent, trained professional.
Gavin Tomlinson, Protection and Business Safety Scrutiny Committee Chair of the National Fire Chiefs Council (NFCC), said: “Fire doors are an essential feature in most buildings, helping to protect both occupants and responding firefighters in the event of a fire. When well-fitted and properly maintained, fire doors provide vital protection against the spread of fire within buildings. While legislation requires those responsible for fire safety to have arrangements for testing and maintaining fire safety measures, people should feel safe in the buildings they visit or work in, and they should feel empowered to report faults and raise concerns, particularly those related to fire doors.”
Discussing the ongoing importance of Fire Door Safety Week, Helen Hewitt commented: “This campaign raises awareness of the critical role fire doors play in saving lives. The support we receive each year from individuals and businesses helps us spread this important message.”
For more information and an amazing set of fire door safety resources visit:
www.firedoorsafetyweek.co.uk
On Fire Door Safety Week 2024, FIS launched the Walls as a System document which has been developed by a collaboration of trade bodies and technical experts and looks at the design and build of wall systems, including integration of doors. To download a copy of the guide click here.
The government has, this week, unveiled new measures to support small businesses and the self-employed by tackling “the scourge of late payments”. New legislation being brought in the coming weeks will require all large businesses to include payment reporting in their annual reports – putting the onus on them to provide clarity in their annual reports about how they treat small firms. This will mean company boards and international investors will be able to see how firms are operating. Enforcement will also be stepped up on the existing late payment performance reporting regulations which require large companies to report their payment performance twice yearly.
The announcement by Business Secretary John Reynolds also sets down an intention to consult on tough new laws which will hold larger firms to account and get cash flowing back into businesses – this is seen as key to supporting growth.
How are requirements changing?
Under current laws, responsible directors at non-compliant companies who don’t report their payment practices could face criminal prosecutions including potentially unlimited fines and criminal records.
A new Fair Payment Code will replace the old Prompt Payment Code, and will be open to signatories this autumn. Businesses will need to prove they have met good payment standards before being awarded official code status.
This will be designed to push businesses to pay faster more often, to be awarded either gold, silver or bronze status. The Code will also shine a light on those responsible businesses doing the right thing by their suppliers and small firms.
It comes as part of our wider work to support SMEs to help go for growth with reform to business rates, getting more small firms exporting and our new industrial strategy.
A consultation which will be launched in the coming months, which will also consider a range of further policy measures that could help address poor payment practices. These new proposals, subject to consultation, will be bought forward on audit and audit committees, in order to help rebuild small businesses’ trust that they will be paid on time and to deliver on Labour’s manifesto commitment to tackle late payments.
Prime Minister Keir Starmer said:
We’re determined to back small businesses by unlocking their barriers to growth, and stamping out late payments is at the heart of this.
We know how important it is for business owners to have the peace of mind and certainty around their cashflow to keep their businesses alive. Late payments cost businesses tens of thousands of pounds and is one of the biggest reasons businesses collapse.
After years of delay, we’re bringing forward measures that small businesses have long been calling for to tackle late payments once and for all.
Business Secretary Jonathan Reynolds said:
Late payments are simply unacceptable and this government is determined to level the playing field for small business. When the cashflow runs dry, small firms go under which is why we need to hold larger business to account with their payment practices and foster an environment that supports growth and jobs.
Slashing trade barriers, reforming business rates, getting more SMEs exporting – this government is committed to small firms. We know there’s a lot more to be done, but today we are calling time on late payers once and for all.
New research published by the Department for Business and Trade has found payment problems multiply the further down the supply chain you go. With delays to payments increasing with each business along a supply chain, this results in smaller businesses generally experiencing more issues with late invoices than larger firms.
These new findings underpin the need to move quickly to crack down on late payments. The research also found that there was a clear imbalance between big and small firms, and that administrative errors are a major factor in creating slow payments with 24% of firms saying that invoices being incorrectly handled added to delays.
The government will work closely with industry to discuss what further measures can be considered to crack down on late payments while ensuring we strike the right balance and avoid excessive burdens on businesses.
The Small Business Commissioner, Liz Barclay, said:
I am delighted to announce a new Fair Payment Code will be launched this autumn. The new code will reward businesses that treat their suppliers fairly and pay them quickly. It will also include an ambitious new Gold Award which aims to make 30-day payments the new standard for which businesses can aim.
We need sustainable, resilient businesses at all levels of the supply chains, to achieve the growth the economy needs. That means paying everyone from the largest supplier to the sole trader quicker, so they have the confidence to invest, improve productivity and grow. Fair payment terms and on time payments are the key.
FIS Reaction
FIS has welcomed the announcements. The organisation had already been in touch to express concern that legislation due to be laid before Parliament before the snap election was called in June had been delayed. In their letter to Construcion Minister Sarah JOnes MP, FIS made the following statement:
<in construction> Large firms help enable projects, but it is the supply chain of SMEs who will need to find and invest in the 66% growth in the workforce we will need to deliver the homes that Labour is expecting. These SMEs find themselves at the mercy of inept and at times immoral procurement practices, contractual processes that leave them picking up the full risk of mistakes and omissions by others and credit and payment terms that make it almost impossible to plan and invest effectively as businesses.
SMEs are constantly paid late with appalling credit terms that often see them exposed to 90 days + of cost on a job before they receive a penny. With little protection available from insurance, this is offset by trade and charge card credit on materials. These SMEs have no protection from upstream failure and a raft of these in recent months has rocked our supply chain. Tracking payment practices (value not volume) is not enough (we need to look at how the supply chain is protected with bonds and project bank accounts), but a worsening payment trend can give the supply chain vital warning of a looming failure.”.
In her response, the Minister provided some reassurance that the new Government do understand the severity of the situation.
The Government is committed to creating a better business environment for small businesses. This includes taking action on late payments, to ensure small businesses and the self-employed are paid on time, and to increase transparency in relation to payment performance. Whilst the draft Statutory Instrument introduced earlier this year had to be withdrawn, the Government is fully aware of the importance of these changes to the payment reporting requirements to subcontractors in the construction sector. Therefore, it intends to reintroduce this legislation at the earliest opportunity. The legislation is now expected to be re-laid before Parliament in 2024, enabling commencement in 2025.
You can see a full copy of the Minister’s letter (in which she also expresses gratitude for the proposals set down in FIS Manifesto) here here.
