Annual Report

2012

30 March 2012

2

Contents

Guernsey International Business Association (GIBA) 3

GIBA Corporate Tax Working Party 5

Guernsey Finance 6

GIBA Technical Committee 7

Education & Training 8

Association of Guernsey Banks (AGB) 9

Guernsey Investment Fund Association (GIFA) 10

Guernsey International Insurance Association (GIIA) 10

Guernsey Association of Trustees (GAT) 11

Guernsey Investment Management and Stockbrokers Association (GIMSA) 12

Commercial Bar Association (CBA) 13

Guernsey Society for Chartered and Certified Accountants (GSCCA) 13

3

Guernsey International Business Association (GIBA)

WELCOME to the 2012 Annual Report of GIBA. This year we are breaking with tradition and issuing a written summary of our work in 2011, leaving the addresses at the General Meeting to focus on the agenda for 2012.

I would like to start by paying tribute to my predecessor, Paul Meader. Paul served the GIBA council with distinction for 6 years to the end of 2011. It is only through the prism of direct personal experience that one can appreciate the tremendous commitment and strong leadership that Paul provided as Chairman and I would like to take this opportunity to thank Paul for his service on behalf of GIBA, its member associations and the wider business community.

I would also like to thank the various council members who have served during 2012. GIBA is an effective vehicle for industry but its effectiveness is highly dependent upon the commitment and work of the council members. I have been very grateful of their various contributions and support over the past year. In particular I should like to mention the following people, not all of whom are members of the council but whose work has been important to industry.

Tony Mancini has led the GIBA tax committee throughout the review of the Crown Dependencies’ corporation tax regimes. In so doing Tony and his team have ensured a consistent message is delivered to those responsible for this on behalf of Guernsey. I am now confident that we will reach a satisfactory resolution of this matter during 2012.

Peter Mills has been our C&E board member. As such Peter has been highly instrumental in informing and engaging in policy debates on a wide range of topics significant to industry within C&E. His diligence and effectiveness in this role has been exemplary and as he stands down from it I would like to pay tribute to him and acknowledge the debt of gratitude owed to him by us all for the considerable personal commitment of time and energy that Peter continues to make.

Peter has agreed to step up as Deputy Chairman, to which position he was recently elected by the Council. He also leads the GIBA technical committee which will doubtless continue to be extremely busy in the future, and has joined me on the PR team.

Peter, you truly are a glutton for punishment and we thank you for it.

Finally I would like to thank Mark Oliphant of Guernsey Finance for his enormous support on the administration and running of the council, Ken Gibbs for his contribution to the Training Strategy Group, Gerry Morrissey for his work as Trustee of the GTA and Jim Gilligan for his work as Chairman of Guernsey Finance. If there are any that I have forgotten to thank it is not through lack of appreciation but lack of short term memory!

4

During 2011 GIBA has considered and acted on many things and I do not propose to give a detailed account of all of them. However, a run through on the potted highlights is I think appropriate.

The major issues that have run throughout the year, and in some cases into the future, include Ombudsman, FATCA and the AIFM. I am sure you are all familiar with the issues involved.

In addition we have contributed to States consultations on: Population Control, Image Rights, Guernsey Finance funding, States Strategic Plan, States Training Strategy, Foundations, States Members remuneration, corporation tax, TIEAs and DTAs, Guernsey Economic Review, Guernsey’s international rating, Fiscal Policy Panel, aviation, Supplementary Benefit Review among others.

We have also contributed to GFSC consultations on: Corporate Governance Code, GFSC Review, regulatory fees, Solvency II and others.

We are represented on the following boards and committees: C&E board, GF Board, GTA, EU Engagement Committee, FSG, and meet regularly with: GFSC executive, FEPG, Guernsey Finance executive, again among others. We continue to meet annually with: Chief Minister, Minister for T&R, Minister for C&E, GFSC Commissioners, States Strategic Plan Committee

Issues for the year ahead will include: Single European Payments Area, QROPS, FATCA and RDR. However, of most immediate and pressing concern is the election on 18th April and the ongoing GFSC review. The top priorities for Council over the next 12 months will be:

To establish new relationships and understanding with the new States and the ministers they elect;

To work with the GFSC towards a regulatory environment fit for the modern world;

To continue to support Guernsey Finance in their promotional work;

To continue to support the States and those involved in developing and implementing Guernsey’s new Training Strategy; and

To continue to provide leadership, support and a unified voice to industry on the issues of the day as they arise.

Of absolutely critical importance over the next year will be to work with the States and the GFSC on developing a new effective framework for the future development of policy and strategy, both economic and regulatory, to ensure Guernsey’s continuing success as an Independent Finance Centre. This will certainly be at the top of our priorities and I particularly look forward to hearing from Cees Schrauwers, Chairman of the Commissioners at the GFSC, and Jarrod Cowley-Grimmond, Director of the Finance Group of C&E, at the meeting to hear their views on this topic.

This will certainly be a busy year!

Dominic Wheatley

Chairman, GIBA

5

GIBA Corporate Tax Working Party

THERE has been much less progress in finalising the review of the corporate tax regime than most people in industry would have hoped. This lack of progress has been caused by developments outside the island over which Government has no control.

The Technical Working Party (mostly consisting of senior officers at States Income Tax) has been continuing its research into alternative tax regimes to Zero-10. This research has included regular consultation with the Tax Professionals Panel, a panel of senior tax practitioners from the larger accountancy firms and a number of senior corporate lawyers.

In addition, the States approved changes to the exempt funds regime in September. The exempt company regime, which now only applies to investment funds, was introduced in 1989 and has been largely unchanged since then. It has always been clear the exempt funds regime would be unaffected by the wider tax review. The proposed changes were intended to make the regime more appropriate for the modern funds market and to provide further certainty to the funds industry over the tax treatment of all collective investment schemes.

However, wider events have prevented the conclusion on the overall review.

In November 2010, Policy Council had announced that it intended to publish proposals for a new tax regime in the middle of 2011. However, subsequently in February, the tax regimes of Jersey and the Isle of Man were reviewed by the EU Code of Conduct Group on Business Taxation. Since the outcome of this review would be directly relevant to Guernsey it was decided to delay any publication of any proposals until after the EU Code of Conduct review was complete.

The initial review by the EU in February on Jersey and the Isle of Man was that their regimes had “unacceptable” features that did not comply with the Code of Conduct on Business Taxation principles. The features, in particular, which were under review, were the rules that attribute company profits to local shareholders but not to non-residents. These were those islands’ equivalents of Guernsey’s deemed distribution provisions. The islands’ response to this was to announce the abolition of the offending measures. Following this, the regimes were reviewed again by the EU Code of Conduct Group in September and following that review, it was announced that the Jersey and Isle of Man regimes were now compliant regimes. This was ratified by ECOFIN on 30th November 2011.

At the start of the review process in late 2009, the States had been led to believe that the States Resolution in October 2009 on its intended review of the corporate tax regime had satisfied that Code Group that the island’s regime would not be subject to formal review. In October 2011, HM Treasury informed the government that a formal review by the Code Group would in fact take place. This review is still ongoing and the outcome is awaited. Whilst Guernsey’s regime has features that, at first sight, have similarities to the Jersey and Isle of Man attribution rules that had been ruled non-compliant, it is felt that the deemed distribution provisions are sufficiently different to make the outcome of the review uncertain.

In addition, a review of Gibraltar’s new territorial regime was undertaken by the EU Code of Conduct Group in October. The outcome of this review has not yet been published.

6

Whilst there is clearly still much uncertainty until the Code Group delivers its formal assessment, subject to that outcome, it would seem reasonable to make some assumptions on the likely final outcome of the review. It now seems likely that the basic framework of Zero-10 will preserved, at least in the medium term. There may be some changes required to the treatment of local shareholders and this may have an impact on income tax revenues. However, whatever the response to this potential impact, Policy Council has repeated stressed its commitment to and the fundamental importance to the finance industry that the “zero tax” product is retained.

Tony Mancini

Chairman, GIBA Corporate Tax Working Party

Guernsey Finance

During the last year Guernsey Finance has been operating in a global environment with an economic recovery that is weak but there has been some increased confidence in the markets. However, the good news is that Guernsey’s finance industry continues to prove its resilience and is performing more strongly than many of our competitors. I am glad to say that Guernsey Finance has very much been able to play its part in working together with our industry and Government stakeholders to ensure this continued success.

Some of the highlights from 2011 include: The appointment in March of Fiona Le Poidevin as Technical Director and Deputy Chief Executive; The Guernsey Funds Forum in May, which was attended by 380 delegates; The first fact-finding delegation to Russia (Moscow) in May; Guernsey companies receiving approval to list on the Hong Kong Stock Exchange (HKEx); Chief Executive, Peter Niven, attending the inaugural STEP Lat-Am conference in November; Further growth in the value of media coverage generated annually by Guernsey Finance, which now stands at some 170% of our funding; A 30% increase in the number of unique visitors to the Guernsey Finance website during 2011 compared to 2010.

2011 began with recruitment for the new position of Technical Director and Deputy Chief Executive, following the Board’s recognition that Guernsey Finance both needed greater industry expertise in-house and a plan of succession for the future. We were delighted to be able to appoint Fiona, who brought with her an invaluable breadth and depth of knowledge from her ‘big four’ audit and tax work in London and Guernsey. Since joining, she has been particularly instrumental in enabling Guernsey Finance to launch fresh initiatives in nascent products, such as cleantech and thus far untapped jurisdictions like Russia. Indeed, 2011 was a year of building and extending our strategy of maintaining and indeed, enhancing our presence in well-established markets while also looking to raise our profile within niches such as film finance and cleantech and increase awareness of the Guernsey brand within the ‘emerging’ markets. Overall, during 2011, Guernsey Finance delivered an even busier programme of activity with enhanced service levels.

Jim Gilligan

Chairman, Guernsey Finance

7

GIBA Technical Committee

DURING 2011/12 GIBA has been more active than ever on technical matters.

Paul Meader was actively involved with the States of Guernsey on EU matters and Jon Heaume was co-ordinating issues relating to FATCA. Further, every GIBA Council meeting involved running through an ever more increasing list of international technical projects and consultations from the States of Guernsey or the Guernsey Financial Services Commission. For example: Ombudsman, AIFM Directive, Dodd Frank, Code of Corporate Governance, Solvency II, Aircraft Registry, Image Rights and Foundations.

Your Council decided that the best way of handling so many topics was to create a technical committee, with matters of importance escalated to the Council as required. I was elected chair of the committee and John Clacy the deputy chair. Each association has one representation on the committee and representatives from Guernsey Finance and Commerce and Employment Financial Sector Development Unit attend. The committee members are: Peter Mills (Chair); John Clacy (Deputy Chair); Andy Veron (AGB); Sam Shires (Commercial Bar); Alasdair McLaren (GAT); Neale Jehan (GIFA); David Riley (GIIA); Richard Bellis (GIMSA); Nickie Paul (GSCCA); Tina Torode (Secretary). Representative from Guernsey Finance: Fiona Le Poidevin. Representative from Commerce & Employment: Jarrod Cowley-Grimmond.

The main aim of the committee is to identify key technical areas that affect more than one industry sector and determine how best to evaluate and take forward those technical areas on behalf of the industry. It is important to note that this committee works along aside the existing technical committees, but is able to facilitate co-ordination of those pan-association topics. Having representatives from Guernsey Finance and the Government in attendance is very important to facilitate effective two way communication directly with those bodies.

The committee has met three times since its establishment and assessed over forty technical topics. Of those the committee has monitored eleven key topics, including Solvency II, Code of Corporate Governance and the UK Bribery Act. The committee is currently involved with four topics; FATCA, RDR, CFC review in the UK and QROPS. With regard to FATCA the committee has recommended that the FATCA working group is re-established and Tony Mancini has offered to chair this group. We are awaiting more information from the GFSC on RDR and once available we will evaluate the input needed from the industry and work with the Commission to ensure that the end result is something that fits the type of business that we undertake in Guernsey. Regarding the CFC review and QROPS we are watching the developments, but hopefully by the time that you read this the States of Guernsey will have approved the new Income Tax Legislation relating to QROPS.

My thanks go to all the committee members and to the secretary, Tina Torode, for their involvement so far. Although it looks as though 2012 will be at least as busy as 2011 and we will continue to meet quarterly during the course of the year.

Peter Mills,

Chairman, GIBA Technical Committee

8

Education & Training

GIBA has had representation on the Boards of G.T.A. University Centre, the Guernsey College of Further Education and the Guernsey Adult Literacy Project for many years. In addition, GIBA had Trustee representation on the GTA and GALP.

During 2011 the GTA University Centre underwent a period of significant change. At the beginning of the year Professor Richard Conder retired as Chief Executive, funding from the GFSC was due to cease at the end of 2012 and some confidence had been lost in the GTA due to media coverage over the previous twelve months. Additionally, the GTA was facing a budget deficit of around £160000.

Thus, for 2011, the GTA Board set itself four key objectives:

1. To build and sustain key relationships with stakeholders 2. To provide stability for customers, staff and suppliers 3. To cuts costs and secure funding for 2012 and beyond 4. To develop a strategic plan.

By the end of 2011 the GTA had forged stronger working relationships with all the professional bodies, the College of FE, private training providers and most importantly secured its links with the universities. By removing itself from the media the GTA developed the mantra of ‘business as usual’ and worked particularly hard to reassure customers that the GTA was here to stay and in October 2011 the GTA was able to recruit to all the key programmes with good numbers.

During the year costs were cut by around 20% and in October the States agreed to bridge the funding gap post 2012, which was a seminal moment in the life of the GTA as it was finally accepted as an integral part of education provision within Guernsey. A strategic plan setting very clear objectives as well as a Service Level Agreement between the GTA and Commerce and Employment were written and endorsed by the GTA Board, giving clear strategic focus for the next three years.

During 2012 the GTA will be offering the first ever fully taught on island full time BA (Hons) degree in business. This will represent a new departure for the GTA and offers students the opportunity to study towards a degree in two years. Currently the GTA has around 250 students studying part-time undergraduate/ postgraduate or equivalent qualifications and this number looks set to rise over the coming months. The GTA is looking to form partnerships with the Institute of Law in Jersey and continues to work closely with education providers from Highlands College, JIBS and other Jersey companies.

The GTA was involved with the development of the Skills Strategy document and is looking to play an important role in the implementation of this initiative. The GTA continues to work closely with industry to ensure that the qualifications offered meet the changing needs of Guernsey businesses and to this end the advisory groups are to be revamped to ensure that their remit dovetails with the strategy on the skills development and implementation.

9

GIBA was represented on (and I chaired) the Skills Strategy Development Group along with colleagues from Chamber, IOD and CGI representing all of industry. The Group first met in September 2010 and finished the Report in March 2012. It was the first time that all the key information had been gathered together in one document which was produced as an evidence pack to the final report.

The political stakeholders (C&E, SSD and Education) then received a presentation on the Report from the Chairman and Frontier Economics was also available to explain provenance of the evidence pack. The stakeholders then meet, firstly individually and then together, to agree a way forward. The next step is the implementation of the 35 recommendations of the Skills Strategy Development Group and a Chairman has been appointed. Three additional industry members are now being sought.

GIBA and the other members of G4 met with Dennis Mulkerin to have input into the Secondary Education Review. We were impressed with Mr. Mulkerrin’s ideas and support his Report.

Ken Gibbs

Director, GTA and Chairman, Skills Strategy Development Group

Association of Guernsey Banks (AGB)

AGB provides a forum for the discussion of matters of interest between its members and through its committee offers contact with the GFSC, Guernsey States, and other bodies as required. There are currently 35 licensed banks, the large majority of which are members of the AGB. AGB has responded to consultations including Corporate Governance, Skills Strategy, Financial Services Ombudsman, and Population, whilst it has monitored developments in respect of SEPA, FATCA, RDR and Vickers, and maintained constructive dialogue with the GFSC in respect of a number of regulatory developments.

AGB has continued to promote relevant training and development through its qualifications matrix, through subsidy of the Certificate and Diploma in Financial Studies and arranging for the introduction of a banking module in the Offshore Certificate delivered through the Guernsey Business School.

Looking forward, developments including Vickers and FATCA will increase the cost of doing business, whilst low interest rates will continue to depress revenues. AGB is conscious that the number of licensed banks is reducing and is concerned that Guernsey should continually strive to be business-friendly and an attractive place to do banking business.

John Robinson

Chairman, AGB

10

Guernsey Investment Fund Association (GIFA)

THE Fund sector has experienced challenging times, due to uncertainty in the world economy. However, the level of funds under administration in Guernsey rose during 2011.

Against this background GIFA, through its sub-committees, continues to represent the views of members. During the year it has engaged with the GFSC in the finalisation of the Guernsey Code of Corporate Governance and has contributed to the working party on the revision to the B Scheme Rules and to the GFSC project to implement electronic submission of information. The compliance sub-committee has also been active in seeking clarity on Anti Money Laundering rules. GIFA has also continued to monitor other regulatory developments including AIFMD and FATCA. GIFA engages regularly with the GFSC and individuals have supported GIBA in promotional activities.

Forthcoming matters include the revision to the Non-Guernsey Scheme Rules, the implementation of FATCA and representation on behalf of the open-ended fund sector which faces difficulties in trying to distribute funds, particularly in the UK. Following the success of last year’s event, the marketing sub-committee continues to work closely with Guernsey Finance and is currently focussing on the Fund Forum to be held in London in May.

Patrick Firth

Chairman, GIFA

Guernsey International Insurance Association (GIIA)

GIIA has been very active throughout 2011 and into 2012.

In April, GIIA responded to the Consultation on the Accounting Standards changes proposed for small and medium sized companies, which represents most captives in Guernsey. The GIIA response was endorsed by AIRMIC, the UK Risk Management Association. In June, GIIA supported Guernsey Finance hosting a sell-out Solvency II Masterclass at the London Stock Exchange featuring a panel of industry experts discussing the merits of Guernsey’s position regarding Solvency II Equivalence. In September, the UK Treasury issued its long awaited consultation on Controlled Foreign Companies, on which GIIA commented, and which appears to have resulted in some benefits for our industry. In November, the Solvency II equivalence debate was reignited by the EU, including a brief consideration of the viability of a bifurcated or “two tier” regime, however the Guernsey politicians decided at the end of January to maintain the status quo and remain outside of equivalence for the time being , much to the relief of industry.

Other areas of involvement from GIIA included the Population Consultation, the Financial Ombudsman Consultation and the E&Y Review of the GFSC.

Martin Le Pelley,

Chairman, GIIA

11

Guernsey Association of Trustees (GAT)

GAT has been active across a broad spectrum of issues throughout the last twelve months.

GIBA and FSG

GAT interacts closely with GIBA, FSG, GFSC, GF and the Guernsey Registry as well, of course, as its membership. Regular member luncheons provide an opportunity for members to meet and for an update on current affairs to be delivered in a succinct thirty minute round up, which has proved to be increasingly popular as a way for members to keep abreast of the multitude of issues under consideration at any one time. There is often close to 50% of the industry represented at our members’ luncheons. GAT also issues a monthly newsletter to all members, and maintains a website the scope of which is constantly being improved.

The GAT Chairman sits on GIBA Council, and also on Finance Sector Group. Both meet monthly. FSG is chaired by the Minister for C&E. In addition, the Finance Minister and the Chief Minister, the Director General of the GFSC and senior civil servants regularly attend. All industry sectors are represented at high level. This is the key forum between industry and government.

A huge range of subjects are continuously monitored including local and international issues, such as: Local politics; Zero-10; IMF Follow Up; E&Y review of the GFSC; FATCA; New FATF 40 Recommendations; European Savings Tax – Amendment Directive; Ombudsman – GAT has consistently campaigned for the Fiduciary sector to be excluded from the scope of the ombudsman’s duties; Population Controls; Induction courses for new politicians; The Guernsey Training Agency; TIEAs – monitoring and ensuring management processes are appropriate; Limited Liability Partnership laws; Foundations; Company Law amendments; Statutory Audit Directive – applied for equivalence; European Equivalence criteria for AML; Joint Jersey/Guernsey Brussels Office; Tax strategy review; States Strategic Plan and Financial Transformation Policy.

GFSC

There was a real break down of industry confidence in the Commission in the first quarter 2011 exacerbated by Divisional directors and key staff leaving. GAT participated in meetings with the Commissioners, which are now a regular event and which the GAT Chairman attends. With new Divisional director appointments, new blood on the panel of Commissioners, results of the E&Y Review filtering through and other reforms we are seeing much more cohesion and confidence beginning to return. GAT Committee has met twice in the last 12 months with the Fiduciary Division. Subjects monitored include: Code of Corporate Governance; site visits and interaction between Fiduciary Division and Licensees; Assets Under Trusteeship reporting; Annual Returns New format; s.21 Notifications; Likely to Benefit; QROPs

Other

GAT has met three times with the Registry in 2011 and assisted in bringing improvements including to the strike off process. GAT meets regularly with GF. Work covers arranging/attending conferences (Panama, Singapore, Geneva), China office/developments and Master Classes. GAT’s new Technical Committee will engage with the GIBA Technical Committee and address all matters of technical significance to fiduciaries

Jon Heaume, Immediate past Chairman, GAT

12

Guernsey Investment Managers and Stockbrokers Association (GIMSA)

IN THE face of the deteriorating European Sovereign debt situation, and with constant government and central bank intervention, the business environment remained difficult. Inertia, with regard to service providers, had been a relatively successful strategy during, and following, the earlier credit crunch fuelled market slump.

Anecdotal evidence suggests that breaking this inertia and winning new investment management business, particularly in the international arena, remains difficult. It is anticipated that this trend is unlikely to improve in the future particularly as onshore jurisdictions with their deeper talent pools, and financial resources, maintain and extend their dominance.

New investment and asset management firms have been attracted to the Island and we hope that we will be able to attract them to our Association in due course so that Guernsey can benefit from their international experiences and also to try and identify areas where we can improve from a jurisdictional perspective.

The primary issue for consideration over the past year by our Association has been the impending introduction of the outcomes of the Retail Distribution Review (“RDR”) in the UK on 1 January 2013. With the other Crown Dependencies having declared their intentions to implement the new requirements on 1 January 2014 we do not believe that there is any merit in regulatory arbitrage. We have met with the Commission, and they in turn have also consulted with our sector and the broader industry, and a working party has been formed. We believe that the existing regulations can be modified to accommodate the essence of the RDR and that no new legislation will be needed. It is highly probable that Guernsey will follow a similar path with regards to requirements and timelines as the other Crown Dependencies. We are currently waiting to engage with Government as this needs to be a policy decision.

We continue to work with the GTA, with particular focus on “gap fill” education associated with the RDR.

On the regulatory horizon there are European initiatives such as MiFID II and PRIPS which need to be examined and assessed as to how best to incorporate the spirit of the requirements whilst maintaining regulatory proportionality.

Richard Bellis,

Chairman, GIMSA

13

Commercial Bar Association (CBA) CBA was formed on 9 December 2010 with a mandate to represent those firms of Advocates with an established physical presence in the Bailiwick of Guernsey who advise on all elements of commercial law. The Commercial Bar promotes and advances the practice of commercial law in the Bailiwick of Guernsey. Some of the matters with which the Commercial Bar has dealt over the last twelve months include:

Consideration of the restructure of the Caen element of qualification as an Advocate in Guernsey. This would include, in particular, the use of lecturers and infrastructure from the Jersey based Channel Islands Institute of Law. Currently the cost to firms of putting candidates through the qualification process is excessive.

A Technical Committee was formed as a Sub-Committee of GIBA. A member of the Commercial Bar will sit on the committee such member to rotate yearly. Practitioners from the Commercial Bar will be invited to contribute their expertise from time to time as and when required.

Important points of legal interpretation, including, for example, the nature and treatment of dividends under Guernsey corporate law, were discussed and a consensus position formulated.

A Commercial Bar consensus as to how to treat various types of business in relation to anti-money laundering requirements was formed and this initiative was progressed further. This point was also raised with Bar Council. The working group is to formulate an agreed approach with the GFSC with view to resolving points of difference as between the Bar and the GFSC.

The provision of a member of the Commercial Bar to communicate with incoming deputies as to the importance of the finance industry for Guernsey, with particular emphasis on the importance of the legal and accountancy professions.

Endorsement of, inter alia, the Image Rights Report.

Continuing consultation with the GFSC and C&E in respect of new law and regulations.

The adoption of agreed practices and procedures in respect of, inter alia, schemes of arrangement applications to the Royal Court.

Barney Lee, Secretary, CBA

Guernsey Society of Chartered and Certified Accountants (GSCCA)

THE last year has seen some significant developments for Guernsey Accountants: the introduction of regulation for Guernsey Auditors of Market Traded Companies; the ongoing development of when and how to replace UK GAAP; the EU review of the Guernsey’s corporate tax regime and the modernisation of the Guernsey housing license system.

The GSCCA has been busy inputting into all of these processes to ensure the most favourable outcome for our members and Guernsey plc.

John Clacy,

President, GSCCA