Some comments on 'Fair and Transparent Blockchain based Tendering Framework' paper

I came across this paper on Hacker News yesterday and decided to have a look at it since it merges two of my interests: distributed ledgers and procurement. The paper by Hardwick, Akram and Markantonakis proposes a theoretical framework for a tendering system based on smart contracts, running on the Ethereum blockchain.

I cannot comment on some of the substance, particularly the security arguments presented, but keeping to the theoretical framework for now I have two comments on (i)mutability and the idea behind smart contracts to provide.

(I)mutability of a tender is not a feature, but a bug.

The authors approach the problem of public contract tendering from a vector broadly in the citizen participation/open governance/system integrity/trust scope. Nothing wrong with that, and it is refreshing to see new takes on existing ideas without the constraints imposed by the current mental models.

On p.4 the authors put forward as a security feature of their proposal:

"R1) The tendering Organisation cannot change the tender once it is placed on the blockchain. If due to some unforeseeable reasons they have to change it, then they have to create a new tender (smart contract) on the blockchain." 

Keeping legal considerations out of the way, I can understand the theoretical underpinnings of this proposal for immutability. However, it is very problematic on a practical basis: time and opportunity cost for everyone involved. Going back to square one every single time a minor error with the tender is detected or due to further information having been requested by the bidders is simply inefficient and disproportionate. If the objective is to ensure the security of the process and enable auditing ex post facto, this could be achieved by allowing changes to be made to the smart contract by the contracting organisation as long as all those changed states are tracked/timestamped as well. This would allow in my view to achieve the same objective but with lower transaction costs for the parties.

Smart contracts, not contracts

Next semester I will be teaching law and blockchain (also smart contracts) and this paper is a timely reminder how prose language can be tricky to interpret. What is described here as a smart contract (ie, the set of operations between launching a tender and awarding the contract) is perceived in legal terms not as a contract at all, but pre-contractual actions which may or not impose obligations on the parties (it varies from jurisdiction to jurisdiction) but not those of a contractual nature. The contract is the end result and usually it only involves two parties (the contracting body and the private party), not all participants in the procedure.

In essence as far as I can define smart contracts they are a set of scripts that run automatically in the same way they already exist in other areas that can lead to the formation of a contract (stock buying/selling orders at a pre-defined value come to mind). They are not (necessarily) by themselves a contract. Having said that, depending on the jurisdiction it is possible that smart contracts really are contracts assuming a) all the elements for contract formation are present (again, jurisdiction specific), or b) definition of what constitutes a contract changes in the future.

Where could this be used?

Coming back to the idea behind the paper - running public tenders on Ethereum blockchain - and where it could be used. My view about the use cases for blockchain in general is that it will be useful and used in scenarios where no other current technological alternative has been deployed or where trust issues are so profound that a centralised database would be more efficient but cannot be used due to lack of trust in the operators.

In both cases I cannot see countries which have already adopted centralised electronic procurement systems to jettison those in favour of a blockchain based system any time soon. Let's not forget the public sector tends to be a laggard in terms of technology and that even today electronic procurement is not mandatory in many countries (EU, I'm looking at you...) even though buying over the internet has been commonplace for more than 15 years. Small elements of what is proposed in the paper are being trialled in Aragon (Spain) but only as a mechanism to timestamp the delivery of bids and I have in the past called for a similar system to be created to gather contract feedback data.

I suspect the potential bulk of use cases will thus be in the developing world, especially those that do not currently have electronic procurement systems and where trust is a paramount issue. It is no surprise that mobile banking (on feature phones) took off in countries without strong bank branches penetration or even internet. And if banking can be done on low bandwidth phones, there is no reason why tendering could not follow a similar development path. Plus, on the long run piggy backing on a major blockchain like Ethereum may lead to a cheaper alternative than the set up and management of a centralised system.

Another potential scenario for use is for regime transitions, ie countries that have changed regimes and where the new one wants more transparency, quickly and where trust is - once more - an issue. Ukraine takes great pride (and rightly so) on developing and using ProZorro after the Maidan Revolution but the next Ukraine may find it easier and cheaper to achieve a similar result but without the need to deploy a centralised system.

Government risk assessment of Carillion published

The Public Accounts Select Committee has published a report into the risk assessments of Carillion in the run up to its failure. Here's a snippet:

"The Carillion assessments show that:

  • Although Carillion had been rated Amber owing to performance against contracts with the Ministry of Defence and Ministry of Justice, it was not until after Carillion issued a profit warning in July 2017 that Government downgraded Carillion to Red. It appears the Government was not aware of Carillion’s financial distress until this point.
  • In November 2017, officials recommended a provisional Black rating for Carillion. However, following representations from the company, the Cabinet Office did not confirm the designation. Carillion collapsed less than two months later."

On a very strange (but welcome) transparency note, even the assessments themselves were made public.

What it appears to me is that by November 2017, plans should have been privately put in motion to forestall a potential (though not certain yet) entrance into administration, ie how to handle ongoing contracts, securing access to sites, etc. That for me is much more important than knowing exactly when the rating moved from amber to red and then finally to black.

On a final note: who and when had access to these risk assessment reports, ie only the Cabinet Office or the wider public sector which could have been tendering contracts with Carillion as a bidder.

Carillion and the policy of re-pricing contracts

Somehow I missed this excellent blogpost by Peter Smith last week about the Public Administration and Constitutional Affairs Committee hearing on public sector outsourcing. The whole thing is worth reading, but here's an interesting bit:

"Asked about contracts that are in difficulties, “we have re-priced in some case” says Manzoni. He then backs off somewhat and says “we have to be careful with regulations”. Really? Tell us more, do explain where you have broken the law!  “Several I can think of where a re-pricing has taken place, where we have got it wrong”."

I do not fully agree with Peter's immediate conclusion of illegality. It may be that what is meant in this context is that the service delivery changed and as such the prices changed as well. This would be legal (within the limits provided for in the Regulations). Even a pure price change might be legal if it met the three criteria mentioned by Peter in his post and present in Article 72 of Directive 2014/24/EU:

(i) the need for modification has been brought about by circumstances which a diligent contracting authority could not foresee;
(ii) the modification does not alter the overall nature of the contract;
(iii) any increase in price is not higher than 50 % of the value of the original contract or framework agreement. Where several successive modifications are made, that limitation shall apply to the value of each modification. Such consecutive modifications shall not be aimed at circumventing this Directive;
 

The burden of proof for the conditions to be met remains with the contracting authority, so in this case evidence would have to be provided that a diligent contracting authority could not foresee the need to increase the price. An of course, the more times the repricing happens to any given contracting authority the less likely it is the test will be met. But who would put forward a complaint even it that was the case? 

In the bigger picture, this is yet another example of what I have been harping for years: the price of regulatory focus in the procedure has moved the pressure points (corruption/illegalities/violation of competition etc) to other areas of the system, namely contract performance and pre-tender launch. 

It is also evidence of the winner's curse at play, but we have known that for ages.

On the importance of designing public contracts well

Very interesting piece on Wired about how Barcelona is dealing with smart city surveillance, even if I do not buy the whole political worldview.* On the procurement side, this bit at the start caught my eye:

“Now we have a big contract with Vodafone, and every month Vodafone has to give machine readable data to city hall. Before, that didn’t happen. They just took all the data and used it for their own benefit”

I will take this at face value, but even so it shows the importance of understanding where value (and risk) lies. By giving Vodafone free reign on using the data generated in that contract the City Council was effectively paying them twice for the same service: first, in cash. Then, in data Vodafone could use as well for its own purposes. That the current City Council understands that the value generated by its contract is valuable (and also a key reason why incumbents usually have a built in advantage IMHO) is a welcome development.

In general I am in favour of more, not less transparency even though it is not exactly risk free in some markets due to the collusion opportunity it offers. But my experience in public procurement tells me that more detailed data provided to tenderers helps them reduce uncertainty and provide more detailed bids based on that data (it just so happens it might as well help collusion).

There is another important point to think about here as well and that is the potential State aid implications. If usage data has value for the incumbent and it is already being paid to deliver the contract then it is arguable the intrinsic data value goes beyond the market rate and that might constitute a case of implicit (?) State Aid. 

The fact the data is controlled by the City Council and (hopefully) made available to tenderers in the following tender allows to level the ground between the incumbents and challengers, negates part of their inbuilt advantage and the value the data has for the first.

*The idea behind Barcelona as a smart city predates 2015 and the current preoccupation with data ownership as well. 

Carillion, Capita and the obsession with lowest price contracts

In the wake of Carillion's implosion, we are coming to see the internal workings of the UK Government in a light that might be surprising or unexpected for those looking from the afar. The most recent piece of information comes in today's Telegraph and is connected to what award criteria are used. Mostly, lowest price even in large outsourcing contracts.

The Public Contracts Regulation 67(1) establishes - correctly - the principle that contracts need to be tendered in accordance with the most economic advantageous tender. 3 years after the Regulations came into force, lowest price or price only contracts should be a thing of the past. But they are not, why?

First, as mentioned in the Telegraph's piece, there is a huge pressure on budgets and that means the pressure is passed on to the private sector via price only contracts. If a large percentage of a pool of contracting authorities operating in a market all have the same approach, then margins of economic operators are indeed squeezed. By itself that is not a problem and is part and parcel on the economic world. No company likes competition, so take with a grain of salt the tears claiming contract prices in the public sector are too low. Having said that...  

The winner's curse exists really is a thing in public procurement. If only one contractor can win and the lowest price is the award criteria, there is a huuuuuuge pressure to win the contract at any cost - and try and make the difference up during the contract. In effect, quite often the prices presented to win the contract are not sustainable, ie, will not cover costs and allow for a profit to be made. Have too many of those, a little bit of a head wind and the positive cashflow won't be enough to keep the ship from keeling over. In effect, this is roughly what happened to Carillion (and may be happening to Capita as well).

In consequence, I would argue there are a lot more tenders that are abnormally low than those that are formally checked for that condition. In other words, there are plenty of apparently normally priced tenders which are effectively abnormally low depending on the financial circumstances of the tenderer and eventually other contracts the economic operator has already won or will be winning in the contract. In a world where the majority of winning tenders are abnormally low, when looked in context they will all look, well, normal.

That is only part of the story though.

Second, a longer term problem looms: lack of capacity in the public sector to deal with tender complexity. Lowest price tenders are easier to assess/compare and the corresponding decision to justify. It is no surprise they remain very popular in the UK (and elsewhere too), making irrelevant the default MEAT rule in both the Directive 2014/24/EU and the Public Contracts Regulations 2015.

This brings me to the final point: the UK pushed for significant changes to be introduced in Directive 2014/24/EU, which then led to the creation of the competitive procedure with negotiation and the innovation partnership amid other measures that I classify as being "for the 1%" of contracting authorities.

What Carillion's demise is showing is that not even the "1% of contracting authorities" have the chops to do the 'advanced' basics well (moving from lower price to MEAT) let alone deal with all those new toys included in the Directive. For years I have clamoured that what we need is to support contracting authorities in doing the bread and butter well. That means doing the actual work of training, supporting, upskilling and rewarding those at the coal face. To date I have seen zero investment from the UK Government on this (publishing guidance doesn't count...)

But that makes for less compelling marketing case than the new toys. Plus, it costs lots of money. Up front and for uncertain or diffuse benefits (ie, improving tenders, reducing risk and avoiding the next Carillion). For now, it is important to cut those budgets a little more though.

In the meanwhile, lowest price contracts remain the rule and not the exception.

Commission publishes guidance on procurement of innovation

The European Commission has just published earlier today a lengthy guidance document on procurement of innovation. It is welcome since procurement of innovation is the kind of approach (policy? idea?) that is useful mostly for the top 1% of procurers and even then, just some of the time. As such, guidance is required to make it easier for it to be deployed. 

Here's the blurb:

"The 2014 modernised public procurement directives 2 adjusted the public procurement framework to the needs of public buyers and economic operators arising from technological developments, economic trends and increased societal focus on sustainable public spending.

Public procurement rules are no longer only concerned with “how to buy” – they provide scope for incentives on “what to buy”, without prescribing them. The objective of spending taxpayers’ money well is gaining new dimensions, beyond merely satisfying the primary needs of public entities. With each public purchase, the public opinion is rightly interested to know whether the procured solution is not only formally compliant, but also whether it brings the best added value in terms of quality, cost-efficiency, environmental and social impact and whether it brings opportunities for the suppliers’ market."

The more we try to achieve with procurement the more complex it becomes. Remember when the next cycle of complaints about procurement complexity comes about.

Brexit and public procurement: new working paper

Myself and Albert have just made available on SSRN a new working paper on Brexit and public procurement, focused mostly on the transition agreement. As usual, we welcome comments and criticism.

Here's the abstract:

On 29 March 2017, the UK notified its intention of leaving the EU. This activated the two-year disconnection period foreseen in Article 50 TEU, thus resulting in a default Brexit at the end of March 2019. The firming up of a draft agreement on a transition period to run until 31 December 2020 can now provide a longer timescale for the Brexit disconnection, as well as some clarity on the process of disentanglement of the UK’s and EU’s legal systems. The draft transition agreement of 19 March 2018 provides explicit rules on public procurement bound to regulate ‘internal’ procurement trade between the UK and the EU for a period of over 15 months. However, the uncertainty concerning the future EU-UK relationship remains, and the draft agreement does not provide any indication on the likely legal architecture for future EU-UK trade, including through public procurement. The draft agreement has thus not suppressed the risk of a ‘cliff-edge’ disconnection post-Brexit, but rather solely deferred it. The transition is currently not into an alternative system of procurement regulation, but rather into the void. There have also been very limited developments concerning the UK’s and EU’s repositioning within the World Trade Organisation Government Procurement Agreement (WTO GPA), which creates additional legal uncertainty from the perspective of ‘external’ trade in procurement markets due to the absence of a ‘WTO rules’ default applicable to public procurement.

Against the backdrop of this legal uncertainty, this paper critically assesses the implications for public procurement of the March 2018 draft transition agreement. In particular, the paper identifies three shortcomings that would have required explicit regulation: first, the (maybe inadvertent) exclusion from the scope of coverage of the of the draft transition agreement of procurement carried out by the EU Institutions themselves; second, the continued enforcement of the rules on contract modification and termination; and third, the interaction between procurement and other rules. The paper also and flags up some of the areas for future EU-UK collaboration that require further attention. The paper then goes on to revisit the continued uncertainty concerning the EU’s and UK’s position within the WTO GPA. It concludes that it is in both the UK’s and the EU’s interest to reach a future EU-UK FTA that ensures continued collaboration and crystallises current compliance with EU rules, and to build on it to reach a jointly negotiated solution vis-a-vis the rest of WTO GPA parties.

De La Rue drops challenge to passport contract

Can't really say I am surprised by De La Rue's decision, but the motives are a joy to read:

"We've done our homework, we've taken legal advice, we've looked at, frankly, the likelihood of overturning the decision and the sensible thing for us to do is to refocus our efforts elsewhere and to move forward."

and

"Following four weeks of intense consideration and clear legal advice, we have taken the decision not to challenge the award of the UK passport contract."

Seriously, was that no evident already two weeks ago? Or was it all an outburst to be seen doing something?

Bonus points for burying the news of the profit warning with the announcement of dropping the challenge. It will be interesting to see if the "profit warning should lead to lost contracts" brigade which sprung after Carillion's demise will be calling for their pound of flesh of De La Rue now.   

Companies don't like competition and public procurement is no different

I remember - naively - thinking competition law made no sense conceptually. Surely, the idea of having a market and economic operators inside it was to enable competition for the best to win. So, why do we need competition law and by extension, public procurement rules?

The CEO of Liberty Steel provided this week with a nugget on my own naivety:

"The chief executive of Liberty Steel has called on the UK government to change public sector procurement rules, which he said fail to adequately support British manufacturers against European competitors.

Jon Bolton, who is in charge of Liberty’s Dalzell steel plant in Motherwell, fears UK public contracts are going overseas because the guidelines for steel procurement are too rigid.

Bolton said: “Guidelines for many public sector contracts are failing to properly take into account the regional economic benefit of our bids." "

Translation: we are not competitive but we are local. Give us the contracts because we are based in the UK.

And let's not forget that i) the UK is still inside the EU ii) Liberty Steel is worried with EU competitors, and not Chinese ones.

On cancer

I'm one of the lucky ones. 15 years ago I made it through. The experience  changed me profoundly, partly for the better and at a not insignificant cost. It is not something I mention publicly these days as its relative importance declines as time marches on, but my feelings about it are still best summarised by this verse in Pearl Jam's Alive:

Is something wrong, she said
Well of course there is
You're still alive, she said
Oh, and do I deserve to be
Is that the question?
And if so...if so...who answers...who answers

I still don't know the answer, but at least I had the chance to reflect (and change). As I said, I'm one of the lucky ones. Others, aren't.

A few months ago a former team mate from my years at Nottingham died in his early thirties. When I was handball club president he was one of our Erasmus student players. He subsequently came back to Nottingham afterwars for further study and work although we lost contact after I moved to Bangor. But I will still remember him as a great teamplayer. An all round great kid. One of my *kids*. It hurt. It stang. Even though we had not been in touch for a good while. He'll always be a 21 year old kid in my mind.

Yesterday it was one of my colleagues, one of the nicest people I ever worked with. This time around there was plenty of warning for those able to read the signals. A few days ago I knew her time was up. I just *knew* it. Still, it doesn't make it any easier to digest. It hurts. It stings.

Tonight I will celebrate Dora's life as I did with William's: hugging my 2 year old daughter and having a nice glass of wine, while being grateful for the time spent together and her words of wisdom. 

In the meanwhile, Offspring's Gone Away is playing in repeat and I will be making a donation to Cancer Research UK.

Timely reminder that EU public procurement remedies are still in force in the UK

Building upon two week's ago decision to award the first post-Brexit UK passports to an Franco-Dutch (Dutch-French?) company, it seems De La Rue is initiating proceedings to get the award decision reviewed.

This is yet another timely reminder EU law is still applicable in the UK since the Public Contracts (Amendment) Regulations 2009 tranpose Directive 2007/66/EC.

As for the grounds from De La Rue, based on the public reports, it seems they are either keeping their powder dry or do not have much to argue. Making generic comments such as the award price was below their cost price does not indicate any wrongdoing - only that they were not competitive enough. Even if there is an abnormally low bid, all the Home Office needs to do is investigate it and is under no obligation to exclude Gemalto.

This all reminds me of a tender I was once involved on the public side with a former colleague as legal adviser for one of the tenderers. After the result was announced he retorted to a common friend "How do I set aside the other 4 bids? Thanks for screwing my weekend!"

PS: I love De La Rue's assertion their new price is lower than that of the old contract, begging the question if they suddenly became very efficient or if they have been extracting rent since 2009. And let's not forget what 3M who lost the contract back then had to say.

PS2: As for the logic of tendering 10/11 year bog standard supply contracts, it defies me still especially with the assertion by De La Rue they were cheaper this time around than in 2009.

Public procurement is a meaty, tricky law business.

Thanks to Joelle Grogan who is running the excellent TrickyLaw series for covering public procurement and allowing me to take part!

Timely reminder public procurement rules still apply in the UK

It seems Gemalto, a French company has won the contract to produce the UK passports post-Brexit. FT has the scoop:


"Gemalto, a security company based in Paris, is expected to win a tender process ahead of the UK’s De La Rue, one person briefed on the decision said. De La Rue currently holds the contract for producing UK passports, worth £490m over 10 years.

Both the Sun and Daily Telegraph newspapers reported the news on Wednesday evening. Bill Cash, a pro-Brexit MP, said the decision was “incongruous to say the least” and “symbolically completely wrong”.

“The irony is unreal,” said Eloise Todd, chief executive of Best for Britain, the anti-Brexit campaign group.

The Home Office said the procurement process was ongoing, adding: “We do not require passports to be manufactured in the UK. A proportion of blank passport books are currently manufactured overseas, and there are no security or operational reasons why this would not continue.” "

While the UK is inside the EU (transition included) EU public procurement rules and general principles remain applicable. And there's no irony in that.

Updated Draft Agreement on the UK's withdrawal from the EU [Public Procurement]

The Commission published on March 19th a revised Draft Agreement on the UK's withdrawal from the EU, conveniently colour coded green, yellow and white to denote different levels of agreement between the parties. Green means the text has been agreed but is still subject to technical legal revision, yellow that the policy objective has been agreed upon but drafting changes are still required and white that no agreement has been reached yet.

As regards public procurement (Arts 71 to 74 of the Draft Agreement), the situation is as follows:

Article 71 - Green

Article 72 - All green except paragraph 2.

Article 73 - Yellow

Article 74 - Green

It seems that in what regards to public procurement, progress is being made in reaching an agreement. No major changes are visible to any of the articles in comparison with the original draft from a few weeks ago. As I said in the meanwhile, I find it odd that EU procurement rules will apply only until the procurement procedure is finalised, but not to the contract performance, thus meaning Articles 70 to 73 of Directive 2014/24/EU won't be applicable. Unfortunately, the draft remains unchanged in this point and the parties have accepted it (Draft Agreement Article 72(1) and (4)).

As for Article 72(2) where no agreement has been reached, I am puzzled as for the reasons why. Since Article 72(1) establishes the application of secondary rules to ongoing public procurement procedures, paragraph 2 only re-iterates the applicability of the principle of non-discrimination to the same set of procedures. That is the logical contextual reading of Articles 72(1) and 71 (which includes the definition of relevant rules). Another reading, however, would allow the extension of the principle of non-discrimination to contracts not covered by Article 71, that is contracts not-covered by the Directives: ie, those today subject only to the (horrible) certain cross-border interest. As I said, my guess is that those have been excluded from the scope of application of the Withdrawal Agreement via Article 71, but perhaps the definition of this scope is where the parties are yet to reach an agreement.

The only area where only policy agreement has been achieved is Article 73 pertaining to the Remedies Directives (Directives 89/665/EEC and 92/13/EEC). This can be understood in the negotiation context of the UK not wanting to be subject to the jurisdiction of the Court of Justice. This is, however, speculation on my part. 

Social audits flawed as a way of driving sustainable change

Thought provoking piece on The Guardian from an Oxfam manager about social audits as means to drive change in supply chains:

"The ethical audit industry is estimated to be worth $80 million dollars a year. The World Bank recently calculated that parallel, or duplicate, audits in the Vietnamese garment industry had added $50 to the cost of each worker per year. In terms of "lean manufacturing", audits could be seen as a form of waste, adding cost but not real value."

Funny how social/ethical audits do not seem to work for NGOs but somehow they will be great in procurement as I have seen mentioned time and time again at conferences? 

As I argued in my paper about the growth of external compliance in procurement (of which sustainable procurement is a key example), it is important to follow the money and the interests behind such proposals. I am yet to see their proponents having an honest debate about the costs and downsides of their proposals.

Procurement is complex, more cumbersome than needed, but not inane.

CityMapper which ran a on-demand bus service in London for a while had this to say about public procurement:

"It’s hard for the public sector to buy good software

Government entities need to utilise complex and bureaucratic procurement systems. These are won by companies with project managers and sales persons who are willing to deal with inane procurement processes, rather than product or technology companies that have the capability to do the best job."

It is true that there is plenty of scope for improvement on public procurement practices (transaction and opportunity costs I'm looking at you) and that economic operators without a track record have the deck stacked against them. But a system less transparent or 'inane' would be even worse for a small company to deal with. Such small company would not even know an opportunity exists and if it did, why should the public buyer listen to you when it can simply do a deal with the IBM of that particular field?

In fact that what already happens for contracts below EU-thresholds. There are barely any procurement rules and contracting authorities mostly do as they please (if they prefer to jack up the transaction costs, that is their problem - not that they need to follow "complex and bureaucratic systems"). Also, EU procurement rules on utilities (like transport) are a lot more flexible than people give them credit for.

Less transparency in a procurement system increases the risk of corruption too.

How would that be a less 'inane' system?

PS: There are plenty of cities in the UK where transport systems are open to competition (Nottingham is a good example) and do not rely on public procurement at all, but I digress.

 

After Carillion, Government looks into partially changing its procurement practice

Cabinet Office minister David Lidington has told the Liaison Committee of the House of Commons the following:

“We in government have started to look at lessons in terms of how we go about contracting with companies, [and consider] whether we want to revisit the question of seeking best value for money by getting large contractors in to manage wide ranging, complex projects.

[...]

If a government department were to decide that they wanted to let smaller companies bid for a number of different contacts, that would mean more in-house resource and expertise in the procurement and management”.

I, for one, welcome the (partial) recognition that perhaps more in-house resource for procurement and contract management is not a bad idea overall. But I have not forgotten the multiple instances where Government officials had bragged how "efficient" (ie, cheap) procurement was done in the UK in comparison with other Member States.

Picking up pennies in front of the steamroller as they say.

The problem with Lidington's view is not that larger contracts are bad in themselves (or worse than a multitude of smaller contracts), is that *especially* those monoliths need more resource for procurement and management.

But bearing in mind the approach of delivering Brexit on a shoe string, that is really not going to happen.