IMPACT – HIGH

What is the change? The Migration Advisory Committee has published its final report detailing its study of EU/EEA workers in the UK. The report considers the total impact of EEA labour on life in the UK, including economic and social impacts on domestic wages, unemployment, prices, productivity, training, the provision of public services, public finances, community cohesion and well-being to provide a researched basis for migration policy.

The report makes key recommendations to the UK Government on regulating EEA workers after the UK leaves the European Union and the post-Brexit implementation period ends on 31 December 2020. Its recommendations are not binding, but the report suggests that the UK will move towards a single, unified immigration system for EEA and non-EEA nationals in which low-skilled migration is substantially cut, and the existing Points Based System Tier 2 routes for skilled workers are reformed for wider use.

Key recommendations:

The MAC report recognizes that “Free movement has the virtue of a low bureaucratic burden but at the price of losing control over both the level and type of immigration into the UK”. The MAC therefore recommends government policy should be to:

  1. Maintain visa-free travel from the EEA, but introduce restrictions on how EEA nationals settle and work in the UK prioritising higher skilled migration;
  2. Assume a single set of immigration rules for both EEA and non-EEA nationals;
  3. Resist demands for employer-led sector-based routes for low-skilled workers (other than seasonal agricultural workers), regional variations, or variation for Northern Ireland or the public sector;
  4. Maintain the existing Tier 2 (ICT) route; and
  5. Extend the scope of the existing Tier 2 (General) route to medium-skilled workers.

Specific Tier 2 (General) recommendations include:

  • Removing the cap/quota;
  • Reducing SOC skill level to include medium-skilled occupations;
  • Maintaining the salary threshold at £30,000;
  • Applying the Immigration Skills Charge to EEA nationals;
  • Abolishing the Resident Labour Market Test; and
  • Ensuring that the process for changing employers in the UK is straightforward.

Background: The MAC is an independent committee of experts that produces reports and recommendations to the UK Government to provide an objective evidence basis for migration policy. In July 2017, the Home Office commissioned the MAC to study current and future EEA migration patterns and the impacts of EEA workers on the domestic labour market, as well as to make recommendations on how to align the UK’s post-Brexit immigration system with modern economic goals. The committee conducted a Call for Evidence and published interim results of responses from business and other stakeholders in March. Those results indicated that businesses remain concerned about a future immigration system that limits their ability to access EEA labour.

Analysis & Comments:  The MAC research produced detailed evidence to support its findings on the impact of EEA migration on the UK, which are summarized below.

  • No or little labour market impact on the overall employment outcomes or wages for UK-born workers.
  • Positive impact on productivity and levels of innovation, and potentially positive impact on training (no negative impacts on training were found and no robust conclusions could be made regarding investment levels).
  • Migration from New Member States (NMS) and non-EEA countries has some impact on reduced prices of medium- and lower-skilled personal services and increased housing prices.
  • EEA migrants pay more in taxes than they receive in benefits.
  • The positive net contribution to the public finances is larger for EU13+ migrants than for NMS migrants, which supports a more selective approach to higher earning EEA migration.
  • Migration does not reduce the quality of health or social care, choice or attainment at school, average level of subjective well-being in the UK, or increase crime.
  • More attention could be paid to ensuring that extra public resources go to places of higher migration to better manage the consequences.

The report is lukewarm in its support of the move to a managed migration system for EEA nationals, recognizing “A managed migration system could benefit the resident population though there would be winners and losers and the size of the benefits are likely to be modest”. However, its proposed shift towards higher-skilled migration means that while the end of free movement will cut low-skilled EEA access to the UK from 2021, changes to the existing Tier 2 visa system (by removing the cap, widening the range of jobs permitted, and reducing bureaucracy as detailed above) should either maintain or widen access to the UK for medium-skilled workers. Many employers would welcome an improved and enlarged Tier 2 system, although arguments that employers made during the Call for Evidence for sector-based schemes to ease loss of lower-skilled workers in retail, hospitality, social care etc. or regional variations have not been accepted by the MAC.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? In a series of technical notes published last week, the UK government has set out the implications if the UK leaves the EU on Brexit Day (March 29, 2019) without reaching a withdrawal agreement, including to the rules governing travel and mobility.

What does the change mean? Employers and individuals should understand the default requirements and restrictions on mobility for UK and EU citizens in the event of a “no-deal” Brexit.

Key points:

  • Irish citizens in the UK and UK citizens in Ireland will continue to retain all rights they currently enjoy under the Common Travel Area rules, even in a no-deal Brexit. The Common Travel Area will be maintained between the UK and the Republic of Ireland, assuring the continued free movement of citizens of the UK and Ireland (as well as the Isle of Man and Channel Islands) to travel, work and settle in each other’s countries, and associated rights to healthcare, education and other social benefits.
  • Travelling to the EU with a UK passport  may be more difficult under “no deal,” as UK citizens will automatically become third-country nationals subject to immigration controls when traveling to EU countries. Additionally, when travelling to the 26-country Schengen region, UK passport holders will be subject to passports-validity rules and strict counting rules on durations of stay. Passports must have been issued within 10 years of the date of arrival in a Schengen country and must have at least three months of remaining validity beyond the intended departure date (or approximately six months of remaining validity beyond the arrival date). UK nationals would also be limited to stays within the Schengen region of 90 days in any rolling 180-day period.
  • The technical notes do not address the status of EU citizens (other than Irish citizens) regarding travel to the UK. The rights of EU citizens in the UK have already been protected within the UK Immigration Rules Appendix EU, setting up a two-year transition period during which free movement will be retained, and ensuring permanent residence for any EU citizen who arrives before 1 January 2021 at the point they achieve five years’ residence.  Following a “no deal” Brexit, it would require parliamentary approval to change these rules and would go against all government reassurances when launching the EU Settlement Scheme.

Analysis & Comments: While the UK government continues to work toward a comprehensive withdrawal agreement with EU negotiators, it recognizes that with Brexit just six months away and a complex legal process to ratify any agreement, a no-deal outcome remains a possibility. UK employers and business travellers should factor in additional time and processing if immigration controls are placed on travel within Europe post-Brexit. British citizens should consider renewing their passports now if they hold older, longer-validity passports (issued more than nine years and six months before the intended date of travel) or if they will expire within six months of intended travel to a Schengen country. British citizens planning travel to the Schengen region post-Brexit should familiarize themselves with the strict counting rules that would apply to them if there is no deal in place.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

The Migration Advisory Committee has proposed changing visa processes to make it easier to hire international students. The proposal was one of several recommendations included in a 117-page report issued this week.

Former Home Secretary Amber Rudd commissioned the MAC in 2017 to assess the impact of international students in the U.K. The commission subsequently issued a call for evidence and based its recommendations in part on the responses stakeholders provided. The MAC recommended that the government:

  1. Retain its policy of not placing a cap on the number of international students in the U.K.
  2. Work with the education sector to increase the number of international students.
  3. Continue to include international students in the net migration target.
  4. Retain its current policies on family dependent rights and student work rights.
  5. Widen the window for applying to switch from Tier 4 to Tier 2 visa, making it possible to apply for a Tier 2 visa as soon as a job offer is made.
  6. Increase the post-study leave period to six months for all master’s students, provided that this change is deemed appropriate after continued study.
  7. Incorporate the 12 months leave to remain for students who have completed their Ph.D. into their original visa duration.
  8. Grant Tier 4 students who meet at least Level 6 qualification a two-year period after the completion of their coursework, during which they may submit an out-of-country Tier 2 visa application under the current rules for switches from Tier 4 to Tier 2.

The MAC declined to endorse the idea of introducing a separate post-study visa program, saying it would drive up demand for short degrees in order to retain temporary working rights—a point that the committee’s chair, Professor Alan Manning, acknowledged would be disappointing to the education sector.

Analysis & Comments: While the MAC introduced changes that would ease the processes for obtaining a Tier 2 visa upon completing coursework, it stopped short of proposing a separate post-study visa program. It also recommended that international students continue to be counted in the government’s net migration statistics, a disappointment to the education sector at a time when officials are under pressure to reduce overall net migration. The government will review the MAC’s recommendations and will set out its position in response to the inquiry’s findings.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? UK Visas and Immigration is no longer accepting visa applications at the British Consulate in New York, which will cease operations Oct. 31.

What does the change mean? New visa applications in the U.S. will be mailed to VFS, the visa processing service that contracts with the U.K. government. Applicants will continue to attend biometrics appointments at VFS centers.

  • Implementation time frame: Ongoing.
  • Who is affected: Anyone seeking immigration services at the British Consulate in New York.
  • Impact on processing times: No significant impact. Processing times are expected to remain the same, though there may be short-term delays related to the change.
  • Next steps: UKVI will be rolling out changes globally to its visa services and will be seeking feedback from stakeholders.

Background: In June, UKVI announced that visa processing would end in New York, the former U.S. processing hub, in October. UKVI also unveiled numerous pilot programs as it moves toward digitalization and onshoring of visa processing. Among the other changes, electronic applications will be more widespread and processing will be centralized in Sheffield, England; compliance audits of employer sponsors will make greater use of technology and electronic communications between employers and the agency; and premium visa services will be unbundled to give applicants greater choice in selecting which enhanced services they are willing to pay for.

Analysis & Comments: Though UKVI has indicated that visa application processing times will remain the same, applicants in the U.S. applying for U.K. visas should be aware of the changes and plan for the possibility of delays. The British Consulate General in New York previously processed approximately 95 percent of all applications within posted processing times, but the transition to the Decision Making Center in Sheffield may have an impact on the turnaround times for new applications during the initial ramp-up period.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The U.K. will pilot a seasonal work permit program for farm workers next year.

What does the change mean? The pilot will provide up to 2,500 work permits per year to non-EU workers. The permits, which will be valid for up to six months, will be issued to help alleviate seasonal labor shortages. Officials will review the program at the end of two years to determine how best to settle on long-term solutions for labor needs in the farming industry.

  • Implementation time frame: The program will be implemented in spring 2019 and will run until Dec. 31, 2019.
  • Visas/permits affected: Seasonal work permits.
  • Who is affected: Fruit and vegetable farmers and non-EU farm workers.
  • Business impact: The seasonal work permits will help farmers meet labor needs during peak production times.
  • Next steps: Additional information, including whether the permits will be issued under the points-based system or as part of a separate scheme, is expected in the coming weeks and months.

Background: Home Secretary Sajid Javid and Environment Secretary Michael Gove announced the creation of the pilot program this week. Few details about how the program will be implemented are available at this point, but Gove said the pilot will “ease the workforce pressures faced by farmers during busy times of the year” and that officials “will review the pilot’s results as we look at how best to support the longer-term needs of industry outside the EU.”

BAL Analysis: The creation of the pilot program has received a muted response from U.K. farmers since the current shortfall of labor is said to be around 35,000 workers. That said, it is a sign that the U.K. is considering the needs of individual industries as it prepares to leave the European Union. BAL will continue to monitor the implementation of this program and will provide more information as it becomes available.

This alert has been provided by the BAL Global Practice and our network provider located in the United Kingdom.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The allocated quota for Tier 2 Restricted Certificates of Sponsorship has been exhausted for July. Requests from applicants with fewer than 41 points and with a salary below £41,000 per year were rejected. Employers will need to resubmit these requests in August.

What does the change mean? While the quota was exhausted for the eighth consecutive month, the points and salary cutoff was significantly lower than it was in May and June. This is likely a sign that demand for Tier 2 Restricted Certificates of Sponsorship is easing up, especially after the U.K.’s recent announcement that National Health Service doctors and nurses were removed from the quota.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Tier 2 (General).
  • Who is affected: Companies applying for Restricted Certificates of Sponsorship (RCoS) for non-EEA skilled migrants under the Tier 2 (General) category.
  • Impact on processing times: Rejected applications will need to be resubmitted in August, assuming that the resident market test remains valid.
  • Business impact: Companies sponsoring Tier 2 workers below the minimum salary level may need to delay work start dates. In some cases, employers may need to readvertise the positions.

Background: The annual quota for Tier 2 (General) visas is 20,700, allocated into monthly quotas with more visas allocated for the high-demand months of April through September. U.K. Visas and Immigration removed doctors and nurses from the quota in June, a move that appears to have already had a positive impact on the quota. The quota has been reached every month since December 2017; however, the points and salary cap dropped significantly compared with recent months. The points cutoff, for example, was 46 in April, 51 in May and 60 in June.

BAL Analysis: Pressure on Tier 2 quotas continues to pose challenges for employers recruiting non-EU workers. However, the removal of NHS doctors and nurses from the Tier 2 caps was met with approval from businesses and the backlog that built up over a period of months may be easing. BAL will follow matters in the U.K. to see if the drop this month becomes a long-term trend.

This alert has been provided by the BAL Global Practice and our network provider located in the United Kingdom.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

The United Kingdom has published a 98-page white paper that outlines the country’s vision for the U.K.’s post-Brexit relations with the European Union.

The white paper envisions a future where the U.K. and EU would negotiate visa-free travel arrangements, establish intra-corporate transfer agreements and promote student mobility, and where the U.K. would maintain its open border with Ireland. Prime Minister Theresa May said in an introduction to the white paper that the government was working to fulfill the mandate of voters while still maintaining a strong relationship with EU member states.

“Our proposal is comprehensive,” she wrote. “It is ambitious. And it strikes the balance we need – between rights and obligations. It would ensure that we leave the EU, without leaving Europe.”

The white paper is split into sections on economic relations, security partnership, EU-U.K. cooperation and institutional arrangements. Among other key provisions on immigration, the document said:

  • The U.K. would end freedom of movement with the EU after a transition period that would last through December 2020. The U.K. would “seek reciprocal mobility arrangements” with the EU, in line with agreements the country would reach with other close trading partners.
  • The U.K. would work to establish travel arrangements with the EU such that U.K. and EU nationals would be able to travel to each other’s countries for short-stay business or tourism without obtaining a visa. These arrangements would only permit paid work in “limited and clearly defined circumstances” in line with the U.K.’s current business visa policy.
  • The U.K. would work to establish similar reciprocal provisions for intra-corporate transfers, aiming to permit U.K. and EU-based companies to “train staff, move them between offices and plants and to deploy expertise where it is needed.” These arrangements would also be based on existing arrangements that the U.K. currently has with some non-EU countries.
  • The U.K. would prioritize mobility for students and young people to allow them to access “world leading universities and the cultural experiences” in the U.K. and EU.
  • The U.K. would maintain the Common Travel Area with Ireland, such that the border between the Republic of Ireland and the U.K. would remain open and that Irish nationals would enjoy a status in the U.K. that would be distinct from other EU nationals.
  • The U.K. would honor a previously reached agreement that the 3.5 million EU nationals in the U.K. and the 800,000 U.K. nationals in the EU will be able to “move, live and work on the same basis as now” through the end of the transition period.

BAL Analysis: The white paper is the U.K.’s most detailed indication to date of how the U.K. would like to shape its post-Brexit relations with the EU. Still, it is not clear how the politics will play out in the U.K., where May has come under sharp criticism from elements within her own party who favor a cleaner break with the EU, i.e., a “hard Brexit.” Nor is it clear how the EU will respond the U.K.’s proposals. Some of the proposals are still lacking in specifics, with the white paper saying “details of the UK’s future immigration system will be set out in due course.” BAL will continue following Brexit-related developments and will provide updates to clients as negotiations continue.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

Brexit secretary David Davis and foreign secretary Boris Johnson have resigned from the government in protest of Prime Minister Theresa May’s softer Brexit plan that would keep the United Kingdom in the European Union customs union and single market.

The resignations pose a threat to May’s already fragile government and could lead to a no-confidence vote to oust her from power. Labour Party leader Jeremy Corbyn said that May’s government “has no authority left and is incapable of delivering Brexit.” Those who oppose the U.K. leaving the EU have renewed calls for a second Brexit referendum.

On Friday, May met with her cabinet to agree on a Brexit plan that would create a free-trade zone between the U.K. and EU for goods and require the U.K. to follow EU regulations related to goods and agricultural products, but not services. The U.K. would also allow the EU Court of Justice to retain jurisdiction over some issues. There is no indication that the EU would accept the proposal, especially if the U.K. seeks free movement of goods while restricting the free movement of people.

By Sunday, Brexit Secretary David Davis resigned, saying that he did not support the plan and that May had given away “too much too easily” in Brexit negotiations. He was replaced Monday by former housing minister Dominic Raab. On Monday morning, Foreign Secretary Boris Johnson followed suit and resigned in a letter arguing that the proposal would not allow the U.K. to make its own laws, but would relegate the U.K. to the “status of a colony.” The Brexit “dream is dying, suffocated by needless self-doubt,” the letter says. Jeremy Hunt, former health secretary, was named to replace Johnson.

BAL Analysis: May’s proposal indicates that the government is leaning toward a softer break from the EU, but the loss of support of “hard Brexit” cabinet members who want a clean break from the EU could make it more difficult for the proposal to gain the support of pro-Brexit members of parliament. In the immediate term, the resignations could topple May’s government, which is held together with the support of Northern Ireland’s Democratic Unionist Party. A no-confidence motion requires 48 Tory signatures to trigger a vote in the House of Commons. May said she will contest such a motion.

This alert has been provided by the BAL Global Practice group. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Home Office has reversed a rule that took effect in January on calculating acceptable absences during the five-year qualifying period for permanent residence.

What does the change mean? The old calculation rule that is less strict will be reinstated for immigrants who entered the U.K. before Jan. 11 and will remain in effect for the next five years. Additional immigration rule changes due to come into effect on Friday can be found here.

  • Implementation time frame: July 6, 2018.  
  • Visas/permits affected: Indefinite Leave to Remain (ILR) applicants.
  • Who is affected: All U.K. employers and Tier 2 (General) skilled workers.
  • Business impact: The reinstatement of the prior rule makes it easier to calculate absences and avoid disqualifying absences due to business travel outside the U.K. during the five-year qualifying period.
  • Next steps: Companies are encouraged to make sure that Tier 2 (General) workers who intend to settle in the U.K. are aware of the residency requirements.

Background: Tier 2 (General) skilled worker migrants who have lived and worked in the U.K. for five continuous years are eligible to apply for indefinite leave to remain in the U.K. on a permanent basis. The Home Office requires not only a five-year visa, but proof that the migrant has been physically resident in the U.K. throughout the period as evidenced through a schedule of absences. Applicants are disqualified if they have been absent from the U.K. for more than 180 days during a 12-month period, but the immigration rules govern how the absences are calculated. Before Jan. 11, the calculation method looked at whether the applicant was outside the U.K. for more than 180 days during any of the separate five 12-month blocks preceding the application date. It was therefore straightforward to analyse absences and calculate the optimum time to submit the application to ensure that business travel did not undermine the 180-day rule. Since Jan. 11, a stricter rule was applied that counted 180-day absences in any 12-month period during the previous five years. Following lobbying from stakeholders, the pre-Jan. 11 rule has been reinstated for all migrants who entered the U.K. before that date, and that calculation method will be in effect for the next five years.

BAL Analysis: Employers and migrants applying for Indefinite Leave to Remain (permanent residence) should be reassured by the policy reversal that applications can be submitted on the same basis as originally anticipated. Any ILR applications made now and in the next five years will be processed under the old rules, which allow for some tactical timing of the filing. New arrivals to the U.K. should be aware that their ILR applications will ultimately need to meet the new rules of no aggregate absence of 180 days in any 12-month period within the five years. A schedule of absences from the U.K. should therefore be maintained continually, and applicants should seek advice from BAL if frequent business travel or extended single absences (personal or business) will take them over or close to the 180-day threshold.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

What is the change? The allocated quota for Tier 2 Restricted Certificates of Sponsorship (RCoS) has been exhausted for June, the seventh consecutive month the quota has been reached.

What does the change mean? Requests for Tier 2 (General) Certificates of Sponsorship earning points below the minimum 60 and a salary of less than £60,000 per year have been rejected for the month of June, and employers will need to resubmit them in July.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Tier 2 (General).
  • Who is affected: Companies applying for RCoS for non-EEA skilled migrants under the Tier 2 (General) category.
  • Impact on processing times: Rejected applications will need to be resubmitted in July, assuming that the resident market test remains valid.
  • Business impact: Companies sponsoring Tier 2 workers below the minimum salary level may need to delay work start dates and plan for continued pressure on quotas in the coming months as the backlog eases. As a result, employers may need to readvertise the positions.
  • Next steps: Employers should plan for delays to business schedules or plan alternative visa routes until removal of National Health Service doctors and nurses from the cap beginning in July eases the pressure in this route.

Background: The annual quota for Tier 2 (General) visas is 20,700, allocated into monthly quotas. In 2016, the monthly distribution was changed to provide higher quotas during the high-demand months of April through September and lower quotas in other months, thereby shifting pressure on months at the end of the fiscal year (December through March). The exhaustion of quotas at the end of the fiscal year, however, has carried over into the new fiscal year. When the monthly quota is reached, applications are ranked by points obtained, with more points earned for shortage occupations, higher salaries, and certain Ph.D.-level roles. The trend requiring ever higher salaries to be successful within the cap has continued this month, while employers wait for the impact of the removal of NHS doctors and nurses from the cap to be felt.

BAL Analysis: As BAL has reported, the pressure on Tier 2 quotas is a long-term trend that continues to pose challenges for employers recruiting non-EU workers in a tight labor market. The quotas have been exceeded every month since December 2017, and as the excess applications roll over to the next month, a backlog has developed. The Home Office announcement earlier this month to remove NHS doctors and nurses from the Tier 2 caps has been met with approval by business, but it is not yet in effect and will potentially take time to ease the backlog. Companies that recruit higher earners will continue to be more likely to have their applications approved. Employers should consider salary as the deciding factor in the approval of an RCoS request and they should plan for all applicants on lower salaries to be delayed and potentially disqualified until, and if, the system returns to pre-December 2017 levels of use. While applications do roll over each month, this is only automatic while the advertising remains valid (typically six months). A more detailed risk assessment should be conducted for all roles prior to advertising.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.