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Personal InjuryLaw Review

WINTER/SPRING 2007Issue 002

It’s your faultEmployers pin the blame on workersPg 4

Mesothelioma claims in the spotlightThompsons looks at the alternativesPg 6

When working is bad for youA look at the Corporate Manslaughter BillPg 10

www.thompsons.law.co.uk

T H O M P S O N S S O L I C I T O R S L A B O U R & E U R O P E A N L AW R E V I E W

In the news

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In the news

T H O M P S O N S S O L I C I T O R S L A B O U R & E U R O P E A N L AW R E V I E W2

Prosecution service prosecuted

Controlling asbestos Slipping when gritting

The High Court has orderedthe Crown ProsecutionService to review its decisionnot to bring corporatemanslaughter charges againstthe employer of a teenagerkilled in his first week at work.

The Judge ruled that the CPS mustreconsider the evidence in the death of17-year-old Daniel Dennis who fellthrough a skylight while working forroofing company North Eastern Roofingin April 2003.

The decision, following a Judicial Reviewbrought by the GMB and ThompsonsSolicitors, is only the second time in legalhistory that the CPS has been brought tocourt in a workplace death case. Itexposes the lack of specialism and

proactivity in the CPS’s approach tocorporate manslaughter.

The Court concluded that the way theCPS interpreted the evidence and itsapparent lack of understanding of healthand safety law, should be looked at again.The Judge said it is “...seriously arguablethat a different decision might be madeonce account is taken of these matters”.

The employer was aware that Daniel hadhad no prior safety training, but sent himup scaffolding to access timber on theroof of a B&Q store in Cwmbran, Gwentduring a re-cladding project. He was notwearing a harness and the skylight areawas not fenced off.

The inquest jury took less than 10minutes to reach its unlawful killing

verdict, although the CPS had told theDennis family that gross negligencemanslaughter charges could not bebrought.

Representing the Dennis family, MickAntoniw, an expert in corporatemanslaughter and health and safety law atThompsons said:“This is a landmarkruling and we now expect the CPS toreview and overhaul the way theyconsider the evidence in cases involvingworkplace deaths.This case also exposesthe desperate need for the newcorporate manslaughter laws currentlybefore Parliament.” (See page 11)

If you or anyone you know has beeninvolved in a workplace accident, go towww.thompsons.law.co.uk for moreinformation.

The Control of AsbestosRegulations 2006 came intoforce on 13 November 2006.The revised regulationsstrengthen overall workerprotection by reducingexposure limits andintroducing mandatory trainingfor work with asbestos.

They also simplify the regulatory regimeand implement revisions to the EUAsbestos Worker Protection Directive.

The revised regulations introduce thefollowing changes:• single control limit of 0.1 fibres/cm3 of

air for work with all types of asbestos• specific mandatory training

requirements for anyone liable to beexposed to asbestos

• requirement to analyse theconcentration of asbestos in the airwith measurements in accordance withthe 1997 World Health Organisationrecommended method

• practical guidelines for thedetermination of “sporadic and lowintensity exposure” as required by theEU Directive

• replace three existing sets of AsbestosRegulations.

Most work with asbestos will still needto be undertaken by a licensedcontractor but any decision on whetherparticular work is licensable will now bedetermined by the risk.

To download the full text of theregulations, go to:www.opsi.gov.uk/si/si200627.htm

It’s that time of year whenthere’s a lot of snow and iceon roads and pavements.What happens whenemployees slip, fall and hurtthemselves at work?

Regulation 12 of the Management ofHealth and Safety at Work Regulationsrequires employers to ensure that the“surface of every traffic route in theworkplace” is suitable for the purpose forwhich it is used and their surfaces are notslippery or have no substance on themthat exposes employees to risk of slipping.

So if an employee slips on snow or ice,falls and hurts themselves as a result of afailure by the employer to grit, then theymay have a compensation claim. But whatabout the employee who slips and injuresthemself while doing the gritting?

In Ann Farrant -v- Essex CountyCouncil, the claimant successfully suedher employer for negligence when sheslipped on the ice she was gritting.

Mrs Farrant, a UNISON member, cameto Thompsons after she fractured herwrist when she slipped on the ice shewas gritting in a playground as part ofher duties as a school caretaker.

Thompsons took proceedings againstEssex County Council whose solicitorsfought the case to court.Thompsons saidthat Essex CC should have carried out arisk assessment and provided MrsFarrant with proper safety equipmentunder the Personal Protective EquipmentRegulations. Indeed, the council hadexpected her to carry out her own riskassessment and she wore her own bootsand Marigold gloves to do the job.

The Judge found in favour of Mrs Farrant.He said that, although it was a “commonsense” task, the whole point of riskassessments was to train an employee inhow to do the job safely and to providethem with safe equipment.

In this case, Mrs Farrant should havebeen trained to allow the ice to meltbefore she walked on it and should havebeen given proper non-slip boots.

Essex CC argued that, even if they wereat fault, Mrs Farrant should take some ofthe blame for the accident for not payingattention to the area she had salted.

The Judge said she was clearly treadingcarefully on the salt and that she was inno way responsible for her accident (seepage 4 for more details aboutcontributory negligence).

In a case where a meterreader slipped on leaves, theOccupiers Liability Act 1957,which states that occupiers ofland owe a duty of care tovisitors, and the WorkplaceRegulations 1992 applied.

In Bond -v- Derbyshire CountyCouncil, the claimant was visiting an oldpeople’s home (owned by the council) toread the meters. He had to go through afire exit to an outside meter.

It was a windy and wet day and heslipped on leaves in the outside corridorand fell, fracturing his elbow.

Mr Bond, a UNISONmember, was referred toThompsons.Along with theOccupiers Liability Act, we said that theWorkplace Regulations 1992 appliedbecause the building was his workplaceas, at the time, he was there to do a job.

The Workplace Regs require theemployer to ensure, among other things,that workplace floors are safe.

Thompsons successfully argued, underthe Occupiers Liability Act, that thedefendant should have at least warnedMr Bond that there were likely to bewet leaves outside the door, even if itcould not keep the area clear due tothe wind.

The Judgeagreed that the council

should have foreseenthat leaves would blow into the area andthat a verbal warning should have beengiven, or the area checked before allowingMr Bond to go through the door.

Derbyshire CC then argued that theWorkplace Regulations did not apply asMr Bond was not at his own workplace.

The Judge ruled that Regulation 2 of theregs applied to a working visitor to thepremises and therefore that the councilwas in breach for the same reasons asabove.The Judge found in Mr Bond’sfavour and decided that he was in no wayresponsible for his accident.

Slipping onleaves

T H O M P S O N S S O L I C I T O R S P E R S O N A L I N J U RY L AW R E V I E W

Contributory negligence

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Contributory negligence

T H O M P S O N S S O L I C I T O R S P E R S O N A L I N J U RY L AW R E V I E W4

It is an argument that defendants areincreasingly putting forward to avoidpaying full compensation. But this is oftenbased on a misunderstanding of the law,which says that courts should bereluctant to find blame against anemployee for a momentary lapse ofattention if the main cause of theaccident was a breach by the employer.

In a recent case that Thompsons pursuedon behalf of an Amicus member, theemployee was injured when the fork lifttruck he was driving collided with anothervehicle that had been wrongly left in apassage, forcing him to drive into a wall.

Although the member’s injury claim wasonly for around £3,500, the employer atfirst counter-claimed for £15,000 for thecost of the repairs to the wall, increasingthis to £18,000 when court proceedingswere issued.After pressure from theunion, the employer dropped the claim ofcontributory negligence.

This is just one example of howemployers (and their insurers) usecontributory negligence arguments todelay and deny personal injury claims.

But the case law is clear. In JohnSummers & Sons -v- Frost (1955) itwas held that where an accident was justthe type that legislation was designed toavoid, and where the workman wasinjured as a result of a momentary lapseof concentration (and not disobedienceor reckless disregard), then nocontributory negligence would be found.

And in Ryan -v- Manbre Sugars Ltd(1970) the Court of Appeal wasunanimous that pure inadvertence wasnot negligence and excusableinadvertence was not something that MrRyan should be blamed for.

Lord Justice Keene said in Cooper -v-Carillion plc (2003) that an employeecan have a legitimate expectation thattheir employer has complied with theirduties. If not, employees should not sharethe blame equally with them.

An approach that the Court of Appealconfirmed recently in Sylwester Dziennik-v- CTO Gesellschaft Fur Container-transport MBH and Co (2006). Itdecided that an electrical engineer had notbeen at fault and partly to blame for hisinjuries when he was badly burned whiletrying to replace a defective thermosensor.

Although the High Court found that thevessel did not operate in “as tight afashion” as it should have done inrelation to safety, it said Mr Dziennik was60 per cent to blame for not followinginstructions he had been shown duringan informal discussion in the smokingroom with the chief engineer.

However, the Court of Appeal disagreed.It said it was not clear how the Judge hadcome to his conclusions, given the “realdoubt” as to whether Mr Dziennik hadbeen shown how the job “should” bedone as opposed to just how it “could”be done.

Nor was it clear that Mr Dziennik hadbeen negligent when he failed to followthe informal procedure.This was onlyone way to do the job out of a possiblethree.

In Smith -v- S Notaro Ltd andGrafton Group plc (t/a Plumbase)(2006) the Court of Appeal held thatemployers must comply with their legalobligations, even if the employee wasmostly to blame for the accident.Thecourt said that the employer should havetrained Mr Smith in the risks of usingunsafe walkways, even though these were"largely a matter of common sense".

And irrespective of how much anemployee is to blame for the accident, theCourt of Appeal has said in Anderson-v- Newham College of FurtherEducation (2002) that workers cannotbe found to have contributed 100 percent to their own misfortune.

But if employees have contributed, thenthey must pay the price. In Badger -v-Ministry of Defence (2005), the HighCourt said that although asbestos waspartly to blame for his death, Mr Badgerhad contributed by continuing to smoke,despite being aware of the dangers.

So it is clear that, although employersoften try to put all the blame on theiremployees, the courts will not alwaysagree.Whatever the circumstances of theaccident, it’s best to get expert advicefrom Thompsons.

It’s yourfault

Contributory negligence iswhen defendants claim

that the victim waspartially responsible fortheir own injury, and ask

the Judge to split theblame between them and

the injured party

Irrespective ofhow much anemployee is toblame for theaccident, workerscannot be foundto havecontributed 100per cent to theirown misfortune


Compensation

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Compensation


The Department of Work and Pensionsrecently consulted with unions, law firmsand others on how the system ofhandling mesolthelioma claims could beimproved.Thompsons’ national head ofasbestos litigation Ian McFall examinesthe system and what needs to be done.

How mesothelioma sufferersget compensation

A mesothelioma sufferer can getcompensation in one or more of thefollowing ways:• DWP benefits [including Industrial

Injuries Disablement Benefit (IIDB),Disability Living Allowance (DLA) forCare (DLAC) and/or Mobility (DLAM)and Constant Attendance Allowance(CAA)]

• Payments under the PneumoconiosisWorkers Compensation Act 1979(PWCA)

• A civil claim for damages against one ormore of the companies responsible for

exposing them to asbestos negligentlyand/or in breach of a statutory duty.

But not all victims get compensation andsome may end up with none at all.

To be eligible for DWP benefits or apayment under the PWCA the asbestosexposure has to have occurred duringthe course of the applicant’semployment.

Anyone who contracts mesotheliomafrom para-occupational exposure – suchas the wives, children or evengrandchildren from a worker’s overalls –is automatically excluded.

Civil compensation

The outcome of a civil claim for damagesis just as unpredictable. It will depend onwhether the company responsible for theasbestos exposure still exists, whether ithas assets to meet the claim or whetherthe insurers on risk at the time ofexposure can be traced.

Thompsons estimate that between 10and 20 per cent of mesothelioma claimsfail because the company no longer existsand insurers cannot be traced.

The court system

The mesothelioma fast track procedure inthe Royal Courts of Justice (RCJ) deliversan effective system which results in analmost immediate judgment in theclaimant’s favour where it is clear thedefendant was in breach of duty.The

claimant also receives interim payments ofover £40,000 within weeks of startingproceedings and what is called a disposalhearing in a few months, which resolves anyoutstanding issues about assessing damages.

The vast majority of mesothelioma casespursued in the RCJ fast track proceduresettle without the need for a disposalhearing.With an average case lasting justa few months, most mesothelioma casescan be brought to a conclusion within aclaimant’s lifetime.

Not surprisingly, there are increasingdemands on the RCJ mesothelioma fasttrack procedure.The system is becomingoverloaded and needs more resources toenable more cases to be dealt with morequickly. Claimants would also benefitfrom having the system rolled out toregional courts.

A fund of last resort

Since the introduction in 1972 of theEmployers Liability (CompulsoryInsurance) Act 1969 employers have hadto hold liability insurance in respect ofemployees’ bodily injury and disease.Yetinsurers in many mesothelioma claimsoften cannot be traced.This is in no smallpart due to the insurance industry failingto keep adequate records.

An “insurance fund of last resort” wouldprovide for payment of compensation incases where the employer is insolvent andthe insurer cannot be traced. Paymentsshould be funded by a compulsory levy onthe insurance industry.

Mesothelioma claims in the spotlight

Make insurers refundPWCA payments

Payments made under the PWCA toclaimants who subsequently succeed inrecovering damages are deducted fromthe total compensation due from thedefendant company or their insurers.These are not refunded to the state, andare effectively a windfall for thewrongdoer or their insurer.

The compensator – the insurer – shouldbe responsible for refunding PWCApayments to the State in the same waythat it currently has to refund relevantDWP benefits to the CompensationRecovery Unit (CRU).

This would stop insurers receiving awindfall collateral benefit and would bean income stream to the state equivalentto the CRU recoveries.

Increase PWCA payments

Payments under the PWCA to claimantswho submit an application during theirlifetime currently range from £10,180(for a person aged 77 and over) to apayment of £65,531 (for someone aged37 and under).

These should be re-calibrated so that theminimum and maximum paymentscoincide with the bracket for an award ofgeneral damages for pain, suffering andloss of amenity in mesothelioma claimsas currently set out in the Judicial StudiesBoard Guidelines.These would work outat £47,850 to £74,300.

Improve eligibility for IIDB

The Industrial Injuries Disablement Benefit(presently limited to people who havecontracted the disease as a result ofasbestos exposure arising out of or duringthe course of earned employment), shouldbe relaxed to include para-occupationalexposure such as clothing andenvironmental exposure claims, which couldinclude living near an asbestos factory.

In many cases of para-occupationalexposure there is no prospect of pursuing asuccessful civil claim for damages eitherbecause the responsible company no longerexists and there is no available insurance, orthe court may not be prepared to find abreach of duty as in the recent Court ofAppeal decision inMaguire -v- HarlandandWolff [2005].

There are probably no more than 100para-occupational exposuremesothelioma cases each year.The cost ofproviding DWP benefits and a PWCApayment to those claimants who wouldotherwise have no entitlement to anycompensation would be relatively modest.

And it would remedy an injustice thatThompsons finds very hard to explain inany logical way to the wives, children andeven grandchildren who have developedmesothelioma because they were exposedto asbestos through no fault of their own.

Damages in Scotland

There is a big difference between theway in which damages for bereavement

are assessed in Scotland, as compared toEngland and Wales.There is no logicalexplanation for it.

In England and Wales a bereavementaward is fixed at £10,000 for deathsoccurring on or after 1 April 2002. Inmesothelioma cases it is normally payableonly to the spouse of the deceased.

In Scotland the equivalent award to abereaved spouse is currently in the orderof £28,000. Other family members suchas siblings and children each have theirown right to a payment of approximately£10,000.

That means that the compensation forbereavement for a family who can bring aclaim in Scotland will differ by tens ofthousands of pounds compared to afamily in England and Wales.

The Rights of Relatives to Damages(Mesothelioma) (Scotland) Bill will ensurethat relatives’ claims for damages are notextinguished by a person withmesothelioma settling their own claimwhilst still alive.A similar statutoryamendment should be introduced inEngland and Wales.

Alternatively the Civil Procedure Rulesshould be amended to allow a claimantwith mesothelioma to make anapplication for an interim payment byway of Part 8 proceedings if they choosenot to bring the claim to a full and finalsettlement during their lifetime, thereforepreserving the rights of others to pursuea claim of greater value after their death.

The current system for compensating mesothelioma victims is inherently unfair, with the outcome subject to a number of vagaries,including whether the victim was exposed to asbestos during the course of their employment or whether their exposure was fromthe contaminated clothing of a relative says Thompsons' national head of asbestos litigation Ian McFall

Ian McFall


Negligence

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Negligence


available, that W would have been aware(if only in general terms) that there wassome risk of contamination if he did notwear them and/or if he were to bring thegloves into contact with his skin.

As for exposure to the sun, the Judgeconcluded that this was a majorcontributory factor to his cancer. AlthoughW could not ever remember beingsunburnt, the judge thought it inconceivablethat he would not have been, given that hehad spent most of his time in the armyoutside, and much of it in hot climatesduring the 1970s and 1980s when therewas little awareness of sun protection.

By comparison, the risk of developingskin cancer from DU contamination was

no more than a few per cent. Nor wasthere any evidence to suggest that W hadan unusually thin skin which made him

particularly susceptible. He concluded,therefore, that UV radiation was “by farthe more probable explanation”.

Empty shellFor a claim of negligence to succeed against an employer,claimants have to be able to show (among other things) thattheir employer did (or did not do) something that caused theinjury or disease

A soldier who developed a skin cancer,which he said was caused by picking updepleted uranium, failed recently in hisclaim of negligence.The Judge concludedthat, on the balance of probabilities, itwas more likely to have been caused byover exposure to the sun.

The soldier asked Thompsons torepresent him, which we agreed to doeven though it would be a difficult caseto pursue.

Basic facts

W served in the Army for 15 years,including spells in Cyprus and Australia aswell as an armaments research operationin Kirkcudbright in Scotland, where heworked between 1984 and 1987.

This site contained a number of rangeswhere armaments, including depleteduranium (DU), were tested.When theDU rounds were fired, some fell on theground and had to be cleared by teamsof soldiers, including W.

When picking up the DU,W said thatalthough he wore a dosemeter, he wasnot issued with gloves and was not givenany instruction or training about workingwith such a hazardous substance.

He subsequently developed a cancer onthe side of his nose which he said wascaused by touching his skin with his hand

or finger, either of which could have beencontaminated by DU. His employer, theMoD, argued that it was caused byexposure to sunlight.

The arguments

W argued that:1. That because the skin on the side of

his nose was particularly thin, it wasmore easily contaminated than otherparts of his body

2. That his particular type of skin cancerwas less likely to be caused byexposure to the sun than other types

3. That the side of the nose was less likelyto be exposed to ultra violet (UV) raysfrom the sun than other parts

4. That he had a dark complexion andwas therefore less at risk ofdeveloping skin cancer from UVexposure

5. That during his time at Kirkcudbright,he suffered from short lived acuteinflammatory conditions of the throatand right eyelid which, in his expert’sopinion, could be attributed to DUcontamination

6. The fact that he was young wasrelevant

For its part, the MoD pushed the linkwith exposure to sunlight, arguing that:1. W worked out of doors for most of

his working life in all weathers,including sunlight

2. When he worked outside he wore aberet, which did not provide his facewith any protection from the sun; andsun protection was not as common asnow

3. When serving in Australia he wasstationed in areas where skin cancerwas very common

4. The experts agreed that, at the veryleast, sun exposure played a part inthe development of his skin cancer

5. The link between sun and skin cancerwas well documented

6. The doctors treating him thoughtsunlight was the likely cause

7. He suffered from a common cancer.

Conclusion

From the evidence, the Judge ascertainedthat, during the time he spent atKirkcudbright, there were very fewincidents that gave cause for concern inrelation to contamination. In any event,W had worked on a very occasionalbasis (no more than 15 times) on therange when DU rounds were fired. But arisk still existed (however low) and it wastherefore foreseeable that W could beinjured. But what caused his injury – was itcontamination or exposure to sunlight?

Although W could not remember wearinggloves, the Judge said that it was morelikely than not that he was issued withgloves along with a personal dosemeter.He concluded, from the evidence

Comment

This case was heard at the end of 2006 when depleted uranium was in the newsagain due to new allegations made by senior US scientist Dr Keith Baverstock ofa link between DU and cancer in Iraq. He claimed on the BBC that researchshowing the link was withheld by the World Health Organisation.

The MOD said in reponse that there was “no scientific or medical evidence” tolink depleted uranium use to sickness in Iraq.Thompsons has a long history ofpursuing cases such as this where establishment opinion is against us but bydoing so we have been able to raise important issues and contribute to a widerdebate and campaign.

T H O M P S O N S S O L I C I T O R S L A B O U R & E U R O P E A N L AW R E V I E W

Corporate manslaughter

11

Corporate manslaughter

T H O M P S O N S S O L I C I T O R S L A B O U R & E U R O P E A N L AW R E V I E W10

The UK is finally close to having a lawthat will make it possible to successfullyprosecute employers who kill workers asa result of their gross negligence.

Ten years ago the Labour Partycommitted itself to such a law, one thatwould hold employers and corporationsto account for public and workplacedeaths caused by gross negligence.

Disasters such as Piper Alpha andZeebrugge, Southall (left) and Hatfieldmade it tragically clear that the existinglaw was not working where largecorporations are involved.The numbersof workplace deaths each year caused bypreventable accidents were unacceptablyhigh, as they still are.

Attempts to charge individual companydirectors or senior managers of largecorporations with what is known in legalterms as gross negligence manslaughterfailed disastrously, usually with the chargeshaving to be dropped for lack of evidencelinking an individual with the offence.

Controlling mind

Employers and corporations were literallygetting away with murder because of thelegal requirement to show that anindividual senior manager, known as the“controlling mind” had caused the death.

The Corporate Manslaughter Bill createsa new law of " corporate manslaughter "and does not require a “controllingmind” to be identified.The new law isaimed at organisations and notindividuals. Its objective is to holdcompanies and in particular their seniormanagement to account for deaths atwork. It is, to a limited extent, the light atthe end of the tunnel for the tradeunions and victims and public interestgroups who have for so long campaignedfor such a law.

In terms of punishments, the Bill allowsfor unlimited fines and the possible useof “remedial orders”.

But unlimited fines on their own arelargely meaningless. Once a fine is paidthe punishment is done. It doesn’t deterfuture offences or instigate a change inculture so that future deaths or injuriesare less likely to occur.

Thompsons has worked closely with thetrade unions, Labour MPs and ministers toget the Bill amended to include alternativesto fines, including disqualification andimprisonment for company directors whoshould have a specific legal responsibilityfor health and safety.

While it is unlikely that the Governmentwill allow the Bill to be changed thatdramatically, there is a strong chance thatwhat is being called “corporateprobation” will be included as analternative or addition to fines.

Corporate probation would give thecourt the power to impose a supervisionorder on an employer that would compelthe company to review its safety

procedures and take measures thatwould result in a reduction in accidents.

The overriding objective of corporateprobation is to achieve a positive and longterm change to company safety culture.

Further penalties

Depending on the final drafting of theBill, Courts might also be able to orderthe company to pay compensation,publicise the offence, notify shareholders,register the offences against the names ofdirectors in the companies’ register andto impose whatever order is needed toget the company to change the way itbehaves. Failure to comply could lead tofurther penalties being imposed.

If corporate probation is included in thenew law, it will be among the most farreaching and innovative changes to healthand safety legislation in the UK.

Despite the Bill there still remains a glaringgap in health and safety legislation. Directorsof companies have no specific legalresponsibility for a company's health andsafety.The Bill exposes this weakness in thelaw and pressure is building from the tradesunions for a new law or amendments toexisting health and safety legislation tocreate specific legal responsibilities andobligations on company directors for acompany's safety performance.

Trades unions understand that untilcompany directors are made accountableattempts to change company safetycuture and save lives will be undermined.

In a society where we talk about rightsbalanced by responsibilities, if companiesare to take their health and safety dutiesseriously, responsibility for a company’ssafety policy and the implementation ofthat policy must be taken at boardroomlevel.

The Corporate Manslaughter and Homicide Bill received itsthird reading in the House of Commons in December. MickAntoniw, a Thompsons partner, explains what this will mean.

When workingis bad for you

Photo:Duncan

Phillips,Report

Digital

Mick Antoniw

As we go to print, the House of Lords has voted to extend the Bill to deaths in policecustody. This defeat for the government risks losing the Bill over one issue (asimportant as it is), when the Bill is essentially about holding companies to account fordeaths at work. This would be a travesty and a disaster for those families who havelost loved ones in workplace deaths and waited so long for a law to bring some justice.

PILR aims to give news and views on personal injury law developments as they affect trade unions and their members.

This publication is not intended as legal advice on particular cases

To receive regular copies of PILR email: [email protected]

Contributors to this edition:Mick Antoniw, Alison Clarke, Judith Gledhill, Ian McFall, Marion Voss

Editor: Jennie WalshDesign: www.rexclusive.co.ukPrint: www.dsigroup.com/talisman

Visit us at www.thompsons.law.co.ukEmail us at [email protected]

Thompsons is the largest specialised personal injury and employment rights law fi rm in the UK with an unrivalled network of offi ces and formidable resources.

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