Mr Alistair Carmichael
MP for Orkney and Shetland · Liberal Democrat · United Kingdom
“I do not know whether this is something I still need to declare, Mr Speaker, but I visited the Falkland Islands in 2003 as a guest of the Falkland Islands Government. They have never invited me back.”
“I remind the House of my entry in the Register of Members’ Financial Interests and also that my wife is a practising veterinary surgeon. What is happening was predictable because it was predicted. The Government were warned by the National Audit Office in June last year that they were unprepared for outbreaks of this sort.”
“The Minister is surely aware that there is no route to net zero that does not go through oil and gas hydrocarbons, and that not exploiting resources on the UK continental shelf leaves us reliant on imports, which also has carbon consequences that must be taken into account.”
“The transition to clean energy could be an opportunity to build a different model that would, to use the First Secretary of State’s own words, end “overly centralised decision making and over-privatisation”.”
“I welcome what the Prime Minister just said about strengthening farming. If he is serious about this, one of the first things he can do is ensure that our farmers do not have to compete with imported food that is produced to lower standards than we expect.”
“Q4. Like others, I have always respected the Prime Minister as somebody who was in politics because he wanted to give service to his country, and he has earned our gratitude for that. In my constituency, those who volunteer as coastguard rescue officers also do so from a wish to give service to their community.”
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“For that reason, I thought that the direction in which the Minister moved was absolutely sensible. I am afraid that I do not take the same view on the position in Scotland. Including Scotland in the Bill would leave unresolved issues, and the Bill would therefore leave Scottish postmasters in a poorer position than those in the rest of the country.”
“I thank the hon. Member for Motherwell and Wishaw (Marion Fellows) for organising the briefing for us today. I attended it; I think there was only one sub-postmaster and one solicitor present at the time, but it was useful to hear from them. I pay tribute, as I have done before, to her for the work that she has done. I suppose it is a consequence of the motion before the House that we have emphasised its procedural aspects more heavily than the outcomes, but the House today needs to focus on the best possible outcomes for sub-postmasters. If there had been insistence on the Northern Ireland Assembly drawing up legislation, that would have required a 12-week minimum statutory consultation period, and that would have produced a worse outcome for sub-postmasters in Northern Ireland.”
“The presence of corroboration is an important part of Scots law, and the Lord Advocate is right to highlight that. As she has raised these issues, I believe that it is better for legislation to be made in the Scottish Parliament, where the equivalent to this stage would take place in a committee, and not in the Chamber, as is the case here; again, that is preferable.”
“As a result, it is reasonable to infer that, in cases that resulted in a conviction—whether by guilty plea or conviction after trial—other evidence was available that was capable of supporting the finding of guilt…As I have explained, not every Horizon case will involve a miscarriage of justice. In some cases, there was sufficient evidence to support a criminal conviction.” —[ Scottish Parliament Official Report , 16 January 2024; c. 22-27] That is the view and analysis of the Lord Advocate. Essentially, what she is saying—I have always believed that this is right—is that because of the way that the laws of evidence and procedure operate in Scotland, and in particular because of the need for corroboration, qualitative safeguards that bring better outcomes are available to people who are before the Scottish courts.”
“Will the hon. and learned Lady let me explain why I take that view? On 16 January, the Lord Advocate made the following observations, and I think that she is quite right: “The vast majority of the cases that may be affected by the issue were cases in which the accused pled guilty to the offence. Often, those pleas were tendered under legal representation. Although it is impossible to comment on every case, prosecutors do not mark cases to proceed in the absence of corroboration—they simply do not do that. Defence solicitors do not advise clients to plead guilty in the absence of corroboration. In cases that proceed to trial, the sheriffs do not convict in the absence of corroboration.”
“The hon. and learned Lady has said herself that this is a matter of opinion. I put great confidence in the opinion of Professor Chalmers, but I come to a different conclusion, because the route to conviction lay through civil servants employed by the Scottish Government— [Interruption.] As the hon. and learned Lady reminds us, almost three decades ago, I was one of them, so I understand perfectly how the system works, and I also understand that if I ever got it wrong—incredible though that suggestion may seem—the accountability for my mistake would be through the Lord Advocate.”
“I am intrigued to know what that final question about shutting down the Scottish Parliament is about, but it is open to the Scottish Parliament to deal with such matters through an emergency procedure. That would be sensible, and it would bring sub-postmasters across the whole United Kingdom to exactly the same place at the end of the day. That can be done in a matter of days, as I am sure the hon. Gentleman is aware. We have heard from others that the legislation is drafted and ready to go, so as a matter of politics, what is it that the Scottish National party does not want to admit?”
“The hon. Lady knows that I agree with her a lot more than either of us would ever admit, but on this matter, there is clearly a difference of opinion. The decision on whether the route to exoneration should be through the Scottish Parliament or through this place is a political choice.”
“I say gently to the hon. and learned Lady that the Scottish judiciary would never comment publicly because, in my experience, they have ways of making their views known. But she is right to point out that on this occasion, the Opposition spokesperson confused the office of the Lord Advocate with the judiciary. I would say to the hon. and learned Lady, however, that that in itself demonstrates to me the need for this matter to be dealt with where the expertise lies, which is the Scottish Parliament.”
“If my new clause had been selected for debate, I would probably not seek to press it. I am not in a position to do anything more, but I thank the Minister for his assurances on independence.”
“I will be back in Westminster Hall on Wednesday morning to deal with a case about the accountability of the Financial Conduct Authority, where it acted in respect of claims made by constituents of mine who had been the victims of a Ponzi scheme only because it was eventually forced into doing so by people who, as with the Post Office, were brave enough to take their case to court. Ultimately, they lost, but in the process of taking their case to court, they put the FCA in a position where there was no alternative but to pay out to all the victims through the financial services compensation scheme. The brave 95 people who took the legal action in the first place are left £2 million out of pocket. Everybody gets something because they were brave enough to stand up, but they are left to pay at the end of it.”
“We are here tonight because of a head of steam that was built up because of the nature of the Post Office as an institution, the standing of sub-postmasters in our communities, the sheer number of cases and the remarkable way in which the ITV programme caught the mood of the nation. What happened to sub-postmasters is different from what happens to people all the time only in one respect: the sheer scale of it. In my time as a Member of Parliament, I have come across so many examples of people with good, reasonable cases who were squeezed out of what they are entitled to because of the inequality of arms. Public bodies have deep pockets—the taxpayer is behind them every step of the way—to pay for the best legal representation and to stonewall in cases where people would otherwise have good justice.”
“I would say only that I hope that the Scottish Government can bring to the Scottish Parliament the legislation that has been prepared so that we can all come to the same place at the same time, because the important thing here—we have to come back to this time and again—is the outcome for the sub-postmasters themselves. For the Post Office as an institution, this is an important step in restoring its trust and its standing in the communities that we all represent. I leave the House with this final thought. There is a temptation to think that when the Bill passes and its provisions are implemented, somehow or other that is it—job done. I caution the House against that.”
“I am pleased to give this Bill my support and that of my party on Third Reading. It shows what is possible when the House comes together and works collegiately, as we have done. It must surely remain a concern to us all that it is necessary in the first place. I pay warm tribute to the Minister for how he has handled this matter, not just as a Minister but in his time before he came into office, as well as to the right hon. Member for North Durham (Mr Jones) and the hon. Member for Motherwell and Wishaw (Marion Fellows), although she is not in her place at the moment.”
“Member for Torbay said that our high seas have unique biodiversity, and he is absolutely right. Of course, we used to have lots of unique biodiversity; we did not have to look to the high seas and the oceans for it. On dry land, however, we have already seen the loss of so much of our critical biodiversity and I fear that it has probably gone forever. So this treaty is for all of us a second chance. Our oceans are the lungs of our planet and if we do not take the action necessary for the ratification of this treaty now, we risk treating the biodiversity of our high seas in the same way that we have treated the biodiversity on dry land, and we will all be poorer as a consequence.”
“The alarming thing I have found in recent years is that when I do a litter-pick on a beach and end up looking at it and thinking, “Well, this is absolutely pristine,” I then spend another 10 or 15 minutes carefully going over it and realise that even in that short time I can fill a carrier-bag with small pieces of plastic. As an islander both by birth and by choice, I see that all the time when walking around our coastlines. The blight of plastic pollution must be tackled. We made so much progress following “Blue Planet II” in 2017, but then along came the pandemic, the closedown and the necessary biosecurity measures. As a consequence, we have lost so much momentum. This treaty might be one opportunity to recoup some of the lost ground. The hon.”
“The truth of the matter is that, so often when it comes to what happens at sea, what happens is out of sight and out of mind, and things that happen on the high seas happen in a state of ignorance, because we simply do not know what goes on there. That is not just in environmental areas: if we consider the labour standards and rates of pay on many deep-water fleets, we will see a similar situation. For me personally, one of the most important aspects of the treaty is the duty that it gives to parties to assess the environmental impacts of things such as plastics. The growth of plastic pollution has been a blight on our shores for decades.”
“Of course, what happens on the high seas may be outwith the jurisdiction of our territorial waters and our exclusive economic zone out to 200 miles, but it is still nevertheless important for the inshore waters on which we rely in my constituency in particular, so we see this as an important opportunity for us. This is also an important opportunity for Britain to continue the leading role we have taken so far. The target of getting 60 countries to ratify the treaty is an important one, and when only four countries have currently ratified it, for Britain to step up to the plate and give early ratification would make a significant difference.”
“It is a pleasure to serve with you in the Chair, Ms Vaz. I congratulate the hon. Member for Torbay (Kevin Foster) most warmly on securing time for the debate. I hesitate to predict anything in politics these days, but I have more than a strong suspicion that this may be one of those occasions when we are all in violent agreement with each other. In order that everybody may have the opportunity to say what they have to say, I will try to keep my remarks suitably brief. I am quite happy to acknowledge the leading role the Government have taken in the past 10 years that has brought us to the agreement of this treaty. The target of a 30% protected area for the high seas is a significant one. It will not be easy to achieve, but it is an important goal that we should aspire to.”
“Like my hon. Friend, I have had correspondence with the Government on this issue. The sheep farmer example is a very good one. That sheep farmer will have income, possibly in the autumn from the sale of the sheep, possibly from a basic payment, and possibly from something like the less favoured area support scheme. There might be a small wool cheque at some time in the late summer or early autumn, but apart from that, that is all the income, which then has to be spread and harvested throughout the rest of the year. That is the reality for the sheep farmers to which my hon. Friend refers, and it shows the virtual impossibility of shoehorning that into a universal credit scheme that looks at things on a monthly basis.”
“I am sure we can all play a role in ensuring that this transitional relief and the importance of returning the form are understood—doubtless, the NFU and others will do that, too. The difficulty I have, however, is that even at the end of that transitional period, I do not see what in the farming business model will have changed. There will still be self-employed people with income coming in significant sums, but at small points in the year. At the end of the transition, we will still be where we are today—that will not change. If there is going to be change, it must come from the UC system.”
“On a point of order, Mrs Murray. It was remiss of me while intervening in the debate not to remind the House of my entry in the Register of Members’ Financial Interests. I hope you will allow me to do so now for the record.”
“That, in turn, allows for a greater payload to be launched for the same fuel efficiency, turning many of the disadvantages with which we have struggled for so long into advantages. Because of where we are, there are natural opportunities for security and safety that would not necessarily be found closer to other larger centres of population.”
“We have seen that quite remarkable progression in recent times as a consequence of a lot of hard work by the Shetland spaceport, and I pay particular tribute to Frank Strang and his colleagues for getting it to this point. It is now licensed by the Civil Aviation Authority, and we were delighted that it got a commitment of £10 million from the Government in the Budget. Indeed, such is the nature of the achievement that the Shetland spaceport is now even getting some interest from the Scottish Government—something else that must be welcomed. If you look at the right map, Mrs Murray—by which I mean a map that has Shetland on it, and not just parked somewhere in the Moray Firth in a box—you will see that Shetland, and Unst in particular, sits at the highest latitude point in the United Kingdom, and indeed one of the highest in Europe.”
“It is a pleasure to serve with you in the Chair, Mrs Murray. I pay warm tribute to the hon. Member for Wyre Forest (Mark Garnier) for securing this debate and for the work he does in the sector. We have spoken about the strategic significance of the space industry for the United Kingdom as a whole. Everything he said in that respect was absolutely correct, but the words in his peroration—about ensuring that we maximise the opportunities that will come from the industry—were particularly pertinent. For my constituency, that goes beyond the high-level opportunities that the hon. Gentleman identified. There are a number of specific local opportunities for Shetland, as we host on Unst—the most northerly of all the Shetland Islands—the Shetland spaceport at SaxaVord.”
“That is the sort of opportunity that we as a community should be entitled to exploit and to expect co-operation on, and support from, Government and elsewhere. We are putting a lot of ourselves into this industry. This industry has great significance strategically for the United Kingdom, as well as economically and militarily, and in just about every other way imaginable. When the Minister replies, I hope he will acknowledge the significance of the contribution that Shetland stands to make to the rest of the United Kingdom, and that there is an understanding that, if we are to step up to the plate for the benefit of the rest of the United Kingdom, then the rest of the United Kingdom should acknowledge that responsibility.”
“It has to be said, though, that the coming of a spaceport to Unst will be transformative for the community. One project that the community is keen to proceed with—and which is deserving of some support from the Scottish Government and the United Kingdom Government—would be to replace our inter-island ferries with fixed-links tunnels going from mainland Shetland to Yell, and Yell to Unst. It is a case that stands well in its own right. It is not an easy thing. To see the opportunities that come from the construction of tunnels, look no further than to our neighbours to the north-west, in Faroe Islands. That is the sort of thing that should be Shetland’s price for playing host to the space industry.”
“SaxaVord spaceport has a science, technology, engineering and maths initiative that already has collaborative research and development projects under way with academic institutions, including the University of Alaska, the University of Strathclyde and the University of Edinburgh—I suspect that Edinburgh probably has the least welcoming environment, in terms of temperature, of those three. SaxaVord also has an outreach programme for local Shetland schools and colleges, generating future technical skills in the area and ensuring a sustainable spaceflight ecosystem in Shetland and the wider United Kingdom. For us as a community, keeping young people in our community or giving them opportunities to come back when they have been away and had their education is critical. We see this as an opportunity.”
“I remember going to a meeting of the local community in the Baltasound Hall and the feeling of absolute desolation at that point, because RAF Saxa Vord had become such a massive part of the local economy of Unst. That was to go virtually overnight, and it was a struggle to find something to replace it. We welcome the coming of the space industry to Shetland, but we welcome it on our own terms and—as we did with the offshore oil and gas industry—we want to maximise for ourselves the opportunities that it can bring to our communities. Some of this is already starting to emerge.”
“I am delighted that my hon. Friend understands that it was a privilege to visit Shetland. She is absolutely right about that. What I am coming on to say fits well with that, because there are lessons for Shetland to learn from its engagement with the space industry and from how we have successfully engaged with the North sea oil and gas industry for the past 40-odd years. The history of Saxa Vord, even in my time, has not always been a happy one. Back in the day, it was an RAF radar station waiting for the Russian bear in the cold war to come screaming over the polar ice cap. With the end of the Soviet Union and the fall of the Berlin wall, it was felt that that sort of presence was not necessary. That may have been somewhat premature. I remember, as a Member of Parliament, when the RAF announced its drawdown from Saxa Vord in 2005.”
“The hon. Gentleman is making an important point. Inevitably in a competitive process, that kind of rivalry can emerge, but the real rivalry is between the UK space industry and the space industry elsewhere in Europe and the world. There must surely be a role for horizontal launch in Cornwall and for vertical launch in Shetland, and also at the Sutherland space site.”
“The hon. Member makes a compelling case. On the question of regional and local variations, in my community, we expect young people to go away for further and higher education due to the limited provision within the community. I encourage that, because I always say to young people, “Orkney and Shetland will still be here when you are ready to come back.” They go away, they meet people from other parts of the world, they fall in love and they want to bring them back. That enriches our communities in so many different ways, quite apart from the economic and social contribution. Does that aspect—the human aspect—for communities such as ours not really deserve be given better consideration by the Government?”
“The hon. Lady is making a very important point. Whether or not there is the case for a spousal visa—income connection—in principle is one matter, but does she not highlight the difficulty that we now have? This area of policy has become so complex, and there are so many exceptions and different rules applying to different people, that if we are going to have a scheme of this sort we need to pare it right back to the start and design it to meet people’s needs rather than some political purpose, which I fear is where we have got to here.”
“2. To ask the hon. Member for Luton South, representing the Speaker’s Committee on the Electoral Commission, what recent discussions the committee has had with the Electoral Commission on the integrity of election processes.”
“I congratulate the hon. Lady on her newly acquired responsibilities in this area. I am sure she brings the same diligence and independence of mind that her father brought to matters in this House for many years. We will be well served by her. Spotlight on Corruption wrote to the National Crime Agency in December last year highlighting the dangers of UK elections being exposed to dirty money and foreign influence. The commission no longer has powers to raise prosecutions, but it can investigate. Will the hon. Lady use her offices to bring the Electoral Commission’s attention to the Spotlight on Corruption report and see what assessment it makes of it?”
“I am interested to develop my hon. Friend’s thought about the Financial Conduct Authority. If I am able, I will speak at greater length about it later in the debate. It administers the Financial Services Compensation Scheme, which is a fund set up by levies on financial services companies themselves. It is the maladministration of the FCA or a lack of proper regulation that often leads to these claims being brought. Essentially, the people paying for the scheme have to do so because of the incompetence of the FCA.”
“Let us not lose sight of the fact that Alistair Greig was able to do what he did only because the Financial Services Authority and the Financial Compensation Authority were poor at doing the job that this House charged them to do. I invited various people to the screening of “King of the Swindlers” last night. I invited the legal team, including the solicitor who acted for the victims. I will be happy to introduce her to the right hon. Member for North Durham, because she is a sterling example of what good people in the legal profession can do, as a member of what I would still regard as a caring profession.”
“The legal action pursued by the 95 victims who had the determination, courage and stubbornness to pursue it did serve a purpose: eventually all the victims were allowed compensation from the Financial Services Compensation Scheme. That of course comes with an £85,000 cap, so my constituent who had lost £130,000 was immediately £45,000 down. However, those 95 victims of Alistair Greig who supported the legal action and made the compensation for everybody possible are left with a legal fees bill of £1.9 million; they are having to pay some £30,000 each, although the exact number varies. So my constituent started with £130,000, came down to £85,000, and is left with something in the region of £50,000.”
“However, it missed the opportunity not once, not twice, but three times to stop what he was doing. As a consequence, the number of victims ran to hundreds. Those who lost out were all small business people who had worked hard, saving £100 here and £1,000 or £1,500 there. They put all that money together and trusted it to Alistair Greig, usually on the recommendation of friends, family and others, because that is how business is often done in such communities. These people did not make that money by flipping properties or coming up with a great wheeze in the City; it was all hard won. Eventually, in desperation, they raised a legal action against Sense Network Ltd, the company that stood above Greig in the financial food chain, but they lost twice: in the first instance, and at appeal.”
“They were all people who had lived and worked as builders, tradesmen or shopkeepers, saving a bit here and there. They put their money into this Ponzi scheme and lost out. The constituent who first brought this to my attention lost out to the tune of £130,000, and his mother lost £37,000. Alistair Greig was responsible for his fraud, but he was able to carry it out as a consequence of the serial ineptitude and incompetence of the Financial Services Authority, later the Financial Conduct Authority. A journalist, Dale Haslam of Aberdeen’s Evening Express , who has done tremendous work exposing what went on, pointed out to me last night that if the FSA had got it right the first time Greig’s wrongdoing was brought to its attention, he would have been stopped after only one victim.”
“That is what I wish to draw the House’s attention to today. Last night, I was fortunate to host a showing upstairs of a BBC documentary entitled “King of the Swindlers”, and the parallels with the Post Office Horizon scheme and its victims are there for all to see. There were only a couple of hundred victims of the “King of the Swindlers”, whereas, as we know, thousands of sub-postmasters were affected by Horizon. The “King of the Swindlers” concerned a Ponzi scheme perpetrated by a financial adviser in the north-east of Scotland, Alistair Greig. He was eventually convicted of fraud and sentenced to 14 years’ imprisonment, which was later reduced to 10 on appeal. The victims came from everywhere from Shetland in the north, down through Orkney, along the highland east coast and the Moray coast, through Aberdeen and down into Angus.”
“Everybody believed before the Braer that the sum put into the IOPC fund could never be reached, but of course the Braer maxed out the fund. By the time the asbestos roof claimants came along, there was no money left to pay the compensation. However, money was left to defend a court action, which is what happened when my constituents raised one. I have never understood the judgment in the case, but my constituents lost and, as a consequence, were left having to carry their own losses. I am certain that had there been more money in that fund at the start, their losses would have been met. So, yes, this is about the imbalance of power, but it is also about the culture of the organisation concerned. An understanding is required on the part of these bodies, be they corporate or public, of the purpose for which they are there.”
“As I have been listening to this debate, I have been reflecting on the fact that not long after I was first elected to this House in 2001, one of the first pieces of casework in which I became involved related to 36 residents in the south end of Shetland whose asbestos roofs had all failed following the grounding of the Braer, off the south end of Shetland, some 10 years earlier. The casual observer might think it common sense that those roofs had worked perfectly functionally for decades and then suddenly, after a tanker full of Gullfaks crude was dumped on top of them, things started to go wrong. The problem was that they did not go wrong immediately; it took time for their failure to become apparent. As a consequence, those people were at the tail end of those who were claiming from the International Oil Pollution Compensation Funds.”
“It is a pleasure to follow the right hon. Member for North Durham (Mr Jones). I do so with a small measure of trepidation, as a recovering lawyer; it is 23 years since I left legal practice, so it gives me a certain perspective. He is right to say that we are talking about the imbalance of power between the big corporates, Government bodies and public bodies, and the individual private citizen. Beyond that, the real problem is about culture, because nothing in nature or law says that a big corporate, public regulator or public body has to treat people badly; that is the choice of the people who make up those bodies. That problem is not new.”
“They could walk out of the room at the end of the night, and I would be able to ask no more of them, but they were not even prepared to do that. I thought I would be up against some really slick types, but I have rarely come across two more nervous-sounding individuals.”
“We are not going to come.” Foolishly, the FCA gave me time to reply, and I had a telephone conversation on Friday night, as I left Shetland on a ferry to go to Orkney, with Chris Wilford, the head of public affairs, and Mark Francis, the director of enforcement and market oversight. Apparently, that is a proper job title; I thought it was some sort of ironic term, but that is what is in his contract. The response was, “Of course we are accountable, but we don’t like being accountable to you. This was an informal process.” All I was asking was for them to come along, sit in room and watch a documentary, along with the people who had lost their life savings to this man, and explain the decision that they had taken. That was all they had to do.”
“I do not disagree with that. I saw enough of that in my time in practice. The right hon. Gentleman knows of my experience with the historical shortfall scheme, and of going into hand-to-hand combat with the lawyers who were instructed by the Post Office. In that case, we were able to make progress for my constituent. A local solicitor, Anne Robertson, a sole practitioner operating in Orkney, took on one of the three biggest firms in London and left them running for cover. The victims were left with a £1.9 million legal fee because the inadequacy of the regulators left them with no option but to do what they did. We invited the regulators to the showing last night. I invited them in the middle of March; they replied last week in a letter, saying, “No, sorry. We have nothing to add.”
“It is paid for by companies in the financial services sector, which are regulated, so they pay for the regulation, and for the failure of that regulation. This is something that the Government seriously need to look at soon. In the meantime, if the FCA wants to do anything to persuade me or anybody else in this House that I am wrong about the culture within that organisation, it can put the final sum of £1.9 million in a cheque to the 95 claimants who were the victims of Alistair Greig and Midas Financial Solutions.”
“This is an organisation where the chief executive is paid £455,000 a year. Some of the commentary on the culture in the FCA is pretty damning. In one anonymous online report, a former colleague described the CEO as “a very high IQ, but not as much EQ”— emotional quotient. As we know, culture comes from the top of an organisation downwards. Unite, the union that represents many FCA workers, talks about the “toxic” environment for staff representatives, who have been given “minimal information” by their bosses. Again, this comes down to culture. How the FCA treats its staff reads across to how it treats people like my constituents, who find themselves in need of its services. We set up the FCA for a reason, and the FSCS for another reason. The FSCS was only supposed to be there in case the FCA failed in any way.”
“Her remarkable strength of character is in contrast to that of people like the chief executive of the FCA who, despite the very well-funded taxpayer salary that they get, simply lack the decency and moral courage to sit down in a room with their victims. That is why I think that the question of culture is at the root of the issue. Since I became interested in the last few days in the detail of what was going on in the FCA, I have found very little to offer me comfort. Apparently, the FCA said that 60 of its staff were earning salaries below the £29,500 per year set by the Joseph Rowntree Foundation as the minimum amount that people need to earn to reach an acceptable standard of living. It is a possibility that the FCA will establish its own hardship fund in 2024, if there is enough demand among staff.”