Watch the proceedings here.

Seven months ago I put proposals to the Minister for a new Enterprise and Investment Visa scheme, which he was already working on. Great to see it now being introduced. Details below.

24 January, 2012

The Minister for Justice, Equality & Defence, Mr. Alan Shatter, TD, today announced that he had secured Government approval for the introduction of two major new immigration initiatives aimed at  facilitating (non EEA) migrant entrepreneurs and investors who, in return for permission to reside in the State, are prepared to invest here for the purpose of saving or creating jobs.

The new initiatives will be known as;

§   The Immigrant Investor Programme
§   The Start-up Entrepreneur Programme

Announcing the programmes the Minister said “I am grateful for the support of my Cabinet colleagues in devising these important initiatives. All of us in our different Departments are committed to doing what we can to help Ireland’s economic recovery and this represents a further instalment in my Department’s efforts in this respect, following on from the Visa Waiver Programme introduced last year”.

The Immigrant Investor Programme:
Approved participants in the Investor Programmes and their immediate family members will be allowed enter the State on  multi-entry visas and to remain here for a defined period.  Ordinarily this will be for a period of 5 years – reviewable after 2 years.  The sort of investments envisaged will include a specially created low interest  Government Bond, capital investment in an Irish business – which may need it for the protection or creation of jobs, or in some cases the purchase of property – including that held by NAMA. Endowments in the cultural, sporting educational or health areas will also be considered.

The level and duration of financial commitment required from the Investor will depend on the nature of the investment but will generally range from €400,000 for endowment-related investments to €2 million in the new Immigrant Investor low-interest bearing Government Bond to be devised by NTMA in conjunction with the Immigration authorities. The funds in this Bond will be held by NTMA and, as is the case with other similar financial products, they will be available for the benefit of Ireland.

The level of investment in business entities where jobs are being created or saved will generally be  €1 million and the Department will be guided by and reliant upon the advice and expertise of IDA Ireland and Enterprise Ireland in assessing individual proposals.

The Start-up Entrepreneur Programme:
Turning to the Start-up Entrepreneur Programme, the Minister said “We need to do more to tap into the entrepreneurial potential that exists among migrants”. The Department of Justice has operated a business permission scheme for a number of years, but the conditions were considered to be too onerous.  The Minister continued, “Our existing business permission  lacked the sort of flexibility needed to attract start-ups.  We have been looking at this issue for a while and have had very useful input from State
Agencies and other Government Departments in drawing up the proposals”.

The Start-up Entrepreneur Programme provides that migrants with a good business idea in the innovation economy and funding of €70k can be given residency in this State for the purposes of developing their business (this compares with a previous minimum funding requirement of €300k).  No initial job creation targets will be set as it is recognised that such businesses can take some time to get off the ground.  Projects will be evaluated by an
Evaluation Committee with State Agencies playing a key role in “picking winners” or those who demonstrate a good idea or the potential to be a winner.

All applications for both programmes will be considered by an Evaluation Committee comprised of representatives of IDA Ireland, Enterprise Ireland, the following Government Departments; Finance;  Jobs, Enterprise and Innovation; Foreign Affairs and Trade; Health; other Government Departments as the need arises and the Minister’s own Department of Justice.  The input of the State Agencies and other Government Departments – bringing with them their economic expertise – will be crucial in deciding which applications are recommended for approval. Applicants must be of good character and be able to support themselves while in Ireland. Applicants will be required to attest to their bona fides on affidavit sworn here.  False, misleading or incomplete information submitted can lead to removal from the State as well as revocation of the immigration permissions.  An Annual Report will be published on the operation of the Programmes and they will also be reviewed to ensure that they continue to meet their objectives.  The Programmes offer no special access to Irish citizenship.  Beneficiaries will be subject to the same rules as other migrants in that regard – i.e. generally residence in the State for at least 5 years.

Minister Shatter stated “These two initiatives are about protecting existing jobs and creating new opportunities.  Ireland clearly needs investment and there is considerable potential out there.  However we don’t have the field to ourselves.  We are in competition with other countries who are already operating in this space”.  This was a reference to the existence of investor schemes in the US, UK, Canada, Australia and New Zealand amongst others.

Next Steps

Formal rules and official launch

The Minister indicated that he hoped to have the new schemes formally launched by mid March when the detailed rules governing the Programmes which are being worked upon by officials in the Department of Justice will be published. He said no new legislation is required as the pre-existing legislative powers of Ministerial discretion are sufficient to enable the programmes to operate in a flexible manner.

The Minister was not prepared to offer a projection as regards the likely uptake.  “I am not going to make any predictions on this”, he said.   “it would be unwise to do so in any case. We are in new territory so let’s wait and see. The relevant State Agencies fully support these initiatives; they are about jobs – whether creating new opportunities or saving existing jobs and my Department looks forward to working closely with them in a positive “Team Ireland” approach in operating these Programmes”

Minister Shatter concluded “Immigration systems are often associated with border control but that is only one part of the picture.  Immigration systems can assist in job creation and we need to think of migrants not just as workers but as people who can create employment  for others”.

ENDS

Notes for Editors

Immigration Scheme for Investors and Entrepreneurs

Background:

The current ‘business permission’ scheme for migrant investors, requires the applicant to have a minimum of €300,000 to invest in an Irish business project. The investment must create at least two full time jobs for EEA nationals in a new project or maintain employment levels in an existing business.  This scheme has been in place for some time and is largely inadequate for the purposes of (i) attracting high potential innovation start ups or for (ii) tapping into the potential pool of international investors.

To avail of the potential opportunities for attracting job creating investments into Ireland, the Government have approved two new immigration schemes.

Start-up Entrepreneur Programme:

This entrepreneurial start up scheme recognises the need to foster start-up enterprises in priority innovation sectors of the economy.  The existing business permission scheme is insufficient to support such business proposals and a more flexible approach has been developed in consultation with Enterprise Ireland, who have extensive experience of such schemes in other jurisdictions.

To qualify an applicant must –

§   Have some form of financial backing of not less that €75,000  through business angels, venture capital providers or a financial institution regulated by the Financial Regulator.  Personal funding transferred to the State or a grant from a relevant State agency would also be acceptable.

§   The business proposal must have a strong innovation component.

§   The applicant must not be a drain on public funds.

Immigrant Investor Programme

The investor scheme is designed to attract individuals with a successful background in business to invest in and relocate to the State.  A range of investment options are provided for with different thresholds applied depending on the nature of the investment;

§   A once off endowment of a minimum of €500,000 to a public project benefiting the arts, sports, health or education.

§   A minimum €1,000,000 investment in a low interest immigrant investor bond.  The investment is to be held for a minimum of five years. The details of the investment will be finalised with the National Treasury Management Agency in the coming weeks.  The bond will be offered exclusively to participants in this scheme and will not be tradable on any market.

§   A minimum €1,000,000 venture capital funding into an Irish business for a minimum of three years.  An investment into an Irish publicly quoted company could be considered but the investment level would have to be much higher.

§   A minimum €1,000,000 mixed investment in 50% property and 50% in Government securities.  Special consideration could be given to those purchasing property, in the State, which have been enforced by NAMA.  In such cases a single €1m investment in property might be sufficient.

Evaluation of Applications:

Applications will be on a prescribed form and will be accompanied by a fee to offset the administrative costs of the schemes.  Admission to both schemes will be subject to the approval of an Evaluation Committee composed of suitably qualified and experienced people from relevant State Agencies or elsewhere.

The Evaluation Committee will be formed from senior management representatives from the Departments of Justice and Equality, Finance, Foreign Affairs and Trade, Jobs, Enterprise & Innovation as well as Enterprise Ireland and the IDA.  A suitable qualified independent member will also be appointed.

The first order of business for the Committee will be the adoption of a code of practice for the operation of the schemes.  The code will be published and will articulate the integrity and transparency of the evaluation process.

All communication between the Committee and applicants for the schemes will be directed to the applicant or their nominated legal or financial representative.  No other third party or agency communications will be accepted or considered.

The Evaluation Committee will co-opt expertise from relevant Government Departments or State Agencies where the nature of the investment proposal requires such input.

Immigration Permissions:

Successful applicants will be granted a residence permission for two years which will be renewable thereafter provided the business is still operational and the applicant is earning a living without being a burden on the State.

No employment requirement will exist for the first two years and neither will the business be required to be profitable at renewal stage.

Family reunification will be permitted for spouse/partner and children provided that family needs are met from the resources of the entrepreneur/investor or other private means.  No access to State benefits will be permitted during this period.

Naturalisation options

The two schemes offer interested parties the potential for residence in the State and not Irish Citizenship.  Successful applicants will only be able to apply for naturalisation under the terms of the Irish Nationality and Citizenship Acts 1956-2004, in the same way and under the same conditions as all other non-Irish nationals.

Watch my speech here

Today we examined the Oireachtas Annual Report for 2010. To watch the proceedings click here, and to watch my contribution scroll to 01.05.33.

20.12.11

To whom it may concern,

I wish to make a submission to the Constituency Commission in respect of the constituency of Dublin South-East.

The Dublin area south of the River Liffey that falls under Dublin City Council jurisdiction is effectively divided between the Dáil constituencies of Dublin South-Central and Dublin South-East, 5-seat and 4-seat constituencies respectively. For historical, planning and practical reasons, I believe it to be sensible to consider both constituencies together for the purposes of any possible redrawing of constituency boundaries or changes in seat allocation.

As it stands, there are 25,355 people per TD in Dublin South Central and 25,791 people per TD in Dublin South-East. This means that there is a population of 126,775 in Dublin South-Central and 103,164 in Dublin South-East. In line with constitutional provisions, it is clear that both constituencies when taken together warrant 8 seats in total.

The Commission’s review presents an opportunity to better arrange these two constituencies and bring about greater balance. If a seat were lost from Dublin South Central, it would bring the total number of seats in each constituency to parity. This would also require the ‘transfer’ of territory from Dublin South Central to Dublin South East to balance the number of people represented by each seat. If Terenure A, Terenure B, Terenure C, Terenure D and Kimmage C (approx. 12,500 people in total) were transferred from Dublin South Central to Dublin South East, there would be an almost equal population in both constituencies of roughly 114,000.

Apart from this balancing of the two constituencies in terms of population and seats, there would also be a practical element to such realignment in that the Terenure area would no longer be divided between two electoral areas. For local residents and businesses alike, there can be tremendous confusion about which TD to contact or which official is responsible for the area.

If the above measure was implemented we would see the removal of an unnatural and problematic border through Terenure and the equal distribution of 4 seats apiece for both constituencies, across similar population sizes.

Yours Faithfully,

Eoghan Murphy TD

Irish mothers don’t raise entrepreneurs.

None of my friends were pushed that way. When we were coming out of college and moving down career paths, it was towards the safety of the professions that we were shepherded. So much so that if someone said they were ‘setting something up’ or starting a business, it really meant that they hadn’t quite figured things out yet. And it certainly didn’t get you girls. (And that was important too.)

Those that had that particular spirit, and ambition, as my brother did, left for London or elsewhere. The ones that didn’t leave got in to property, and got wiped out.

Irish mothers don’t raise entrepreneurs. But then try telling that to the thousand or so people who descended on the Royal Dublin Society in October for the Dublin Web Summit and F.ounders.

There they met people like the founders of LinkedIn and YouTube. Heard inspirational stories of success and failure from many gifted speakers. And most importantly, met each other, shared their own stories over a pint or two and talked about the various obstacles and opportunities to starting a tech business here in their native country. The average age was under 30, the future of this country.

There’s something happening here. All these people. All this ambition. Is it driven by necessity, the lack of jobs say, or is it driven by possibility, unrestricted and abundant in the digital age? Or is it cultural, a “cool” factor perhaps, brought on by a Hollywood makeover and some high profile tech nerds? (Don’t underestimate the influence that ‘Wall Street’ had on creating the banker generation).

Whatever it is, we have to help it.

Ok. But how?

The Chilean government has a programme to attract tech entrepreneurs to its shores called Start Up Chile. They want to convert Chile into the innovation hub of Latin America and to do this they’re offering foreigners 40 thousand dollars, equity free, a one year visa and access to the best social and capital networks in the country. They figure that if all these high potential people (1000 in all by 2014) relocate to Chile, even for year, it can only have a positive effect on the indigenous scene.

Many will probably leave. But some will stay. Yet it’s the wider cultural benefit over the five year period that the government is banking on. They’re going to flood their own nascent market of entrepreneurs in the hope of making it bigger and better. Changing their culture with help from abroad. It’s high risk, with no guaranteed returns and with outcomes that may be difficult to measure in any meaningful way. But it’s bold. And if it does work Chile has just secured its relevance and future in the new economy.

There may not be much point in debating the merits of this policy here because we simply don’t have that kind of money. But the idea, and the fact that the politicians and the bureaucrats actually got it to happen is pretty inspiring. We need to get this investment of foreign people (and their ideas and energy and ambition) in to the mix with our own talent.

Minister Bruton recently announced a new 10 million euro fund to attract overseas start-ups. This is going to be a great support for the sector no doubt. He’s talking mostly about targeting Irish people abroad, perhaps 20 to 30 start-ups, with Enterprise Ireland administering the scheme. Good idea, and now it’s actually happening.

It’s the Taoiseach’s ambition that Ireland will be the best small country in the world in which to do business by 2016. My ambition, and it’s a little less grand, is that we’ll be the best country in Europe in which to start a tech business by 2016. Here’s some ideas, together with Minister Bruton’s, that could help make it happen:

First you have to get rid of the barriers. So that any entrepreneur from anywhere can come here to get going. That means the right visa scheme. We have ‘business permission’ criteria in place but they’re behind the times. The government is currently preparing a new enterprise and investment scheme. Good. But we also have to make it easier for founders to bring people from abroad over to work with them. So we’ll need to do more here on the standard visa front too.

Another barrier is a lack of qualified software developers. This problem isn’t particular to Dublin, and while we should try and attract foreign developers here, we really need a good pool of domestic talent from which everyone can draw. So we need to get people thinking web development. And I don’t mean in school or in university. That’s really important too but we need these guys now. People are already discussing (and in a few cases implementing) programmes that convert unemployed engineers and architects in to digital developers. It’s a really exciting idea with lots of possibilities and the government needs to give it more attention.

With the barriers down we can try and make it easier for everyone to do what they do, and at the same time make it very attractive to do it here in Ireland. That means making it more acceptable. I’m talking here about bankruptcy laws and the acceptance of failure so that people can succeed. The government is saying three years as the “discharge” period for bankruptcy. It needs to be less, like in the States or the UK.

It also means making it cheaper. Start-up companies don’t care about corporation tax rates, but they do care about the costs of doing business. And given the mobility of a lot of these enterprises they can and will go where costs are less. Here’s where we get to be really creative.

We could start with the entrepreneurial tax credit as recommended by the previous government’s Innovation Task Force, which would give a rebate of tax paid on salaries for the first three years, for every five jobs created (and capped at 100k). We could take this a little further and start to target specific people, like abolishing employer’s PRSI for software developers. Or, more radically, do away with income tax altogether for the first year. We wouldn’t be losing money because it would never have been here in the first place. But the people will spend their salaries in the country, will pay VAT, will rent apartments, eat in restaurants etc. And the real benefit in the longer term could be far more significant than the “lost” tax take.

Ultimately though the government will have to put its money where its mouth it if it’s to get serious. What money? Well there is some money, we are taking in tens of billions each year. So this would be a question of priorities. Do we connect the two LUAS lines in Dublin City, or do we give the entire country the best broadband of anywhere in the world, ever? This isn’t to knock the necessity of the LUAS interconnector, but I think it’s easy to understand which investment is more important for the future of this country. (I think we should do both and cut somewhere else, but the question remains: where?)

And then we need to sell. Like Start Up Chile or Start Up America. Decide the brand, decide the package, and get it out there. Again, the Innovation Task Force was quite good on this. I believe we’re a special place already, but bringing in some of the measures above, as well as others, could really kick things off quite quickly. Just look what one man and a dedicated team have done with the Websummit/F.ounders series.

We want to support our young tech entrepreneurs. We want it to be easier for them to do what they do, and we want them to do it better. We want to help but without getting in the way or attaching too many strings. And always keeping in mind that you don’t have to incentivise a “go-getter” to go out and get, you just have to allow them to – they’ll figure the rest out for themselves. Including selling it to their mothers.

Watch today’s proceedings here.

Brian Hayes TD, Minister of State with special responsibility for the Office of Public Works (OPW) today announced detail of a programme of major capital works for 2012.

Speaking this afternoon, the Minister said, “I very much welcome the allocation by the Government of €45 million per annum for flood risk management and mitigation in the Infrastructure and Capital Investment Medium Term Exchequer Framework for the period 2012-2016.  The total allocation of €225 million for capital flood relief measures over the 5-year period of the framework is greater than the total spent on such measures in the past 10 years. This allocation is additional to the related current expenditure provision for maintenance by the OPW of completed arterial drainage schemes and collection of flood flow data, for which €17m has been provided in 2012.”

“At a time when difficult decisions have to be made in order to adhere to the current severe financial constraints, this very substantial allocation underlines the Government’s recognition of the serious personal and economic impact of flooding and the importance it attaches to addressing the problem,” the Minister said.

The Minister concluded, “My Office will continue to operate in 2012 the Minor Flood Mitigation and Coastal Erosion Works scheme under which local authorities can apply for funding for small scale measures to address localised flooding and erosion problems in their areas.

List of Schemes for 2012

Completion of current phases of major flood relief schemes at:

Clonmel,

Mallow

River Tolka

River Dodder

Mornington

Johnstown
Commence construction of the remaining phases of schemes at:

Fermoy

Ennis

Tullamore

Templemore.

Funding will also be provided by the OPW for schemes being undertaken by the relevant local authorities at:

Bray

Carlow (Phase 2)

Waterford (Phase 2)

River Wad (Dublin)

During 2012 the OPW will progress the planning and design of schemes at:

Enniscorthy,

Arklow

Bandon

Skibbereen

Ballymakeera

Raphoe

Crossmolina

Rivers Dunkellin and Clare

River Dodder (Phase 3)

Lower Lee

South Campshires (Dublin)

Eoghan speaking during Private Members Business, 8.12.2011

The Government’s amendment states that we “support efforts to secure an agreement at this week’s meeting of the European Council that fully protects Irish interests and that contributes to the restoration of stability in the Euro area.”

I might have added “and that also restores the founding principles and ideals of the European project”.

The democratic ideal behind the European Union is under threat. It is an ideal that is unique in the international system of states. Independent nations of different sizes and strengths have come together in cooperation. That cooperation is structured around the principle of equality amongst sovereigns – one Member, one vote.

The crisis in the Eurozone threatens all of this.

It threatens this, because if we do not save our currency and it breaks up it could very possibly break-up the EU and all that has been achieved before the Euro. No more equality on the continent between nations, no more common market.

At the very same time, the manner in which we attempt to save the Euro, also risks destroying the European project, as Member States and institutions seek to assert their will over others, undermining the democratic ideal and casting us back to the realpolitik of “the strong do what they will to survive, the weak do what they must”.

We have a good thing, a unique thing here in the European Union. We have a good thing, a unique thing here in the Euro currency.

If war is an extension of politics by other means, so too is economics, but at the other end of the spectrum. And with economics – the coal & steel community, the common market and then the Eurozone, people sought to make advances that war or politics could never make. But we may have taken economics too far, further than the people were willing to go.

It is clear now that we rushed with the Eurozone project, not putting in place the proper architecture for a properly functioning common currency, not heeding the many warnings from nobel prize winning economists and others that were given at the time.

We cannot go back to the past.

We stand here faced with a genuine dilemma.

• How to protect Irish interests – sovereignty and independence over our fiscal affairs;
• How to stabilise the Euro area – in a manner that is credible AND fair;
• And how to restore that fundamental principle of European Union – where no member is more equal than another.

This is the biggest decision that our government and our country will face in its lifetime. We must face in to it in a rational way. And in a calm way. A decision may not come tomorrow, but it will come. Everything will change and we must be ready for that.

The setting up of an Advisory Group is a significant development for NAMA and may just prove the ‘watershed’ moment that was anticipated following the Geoghegan review in October. But we can likely expect some friction with the NAMA board.

People will rightly focus on the tax, spend and cut elements of Michael Noonan’s speech today, but there was also some important information given about the future operation of the National Asset Management Agency (NAMA).

In October it came to light that Minister Noonan had authorised a review of NAMA’s operations and that he had asked Michael Geoghegan, former CEO of HSBC to do this. Following that review, a member of the NAMA board resigned, stating that significant changes to NAMA were on the way. The review was “a watershed in the life of Nama” he said and would result in “changes to the structure of the agency”. With no official information released, speculation in the media was rife.

The Geoghegan review had come as NAMA was completing its first phase: acquisition of its full loan portfolio of €31.7Bn. The second phase would see the Agency shifting its attention to focus fully on managing the assets in the portfolio with a view to realising the public’s ‘investment’. Before the Geoghegan review there had been much criticism, public and private, as to whether NAMA had the people or the expertise to handle this new phase successfully. Comments from the departing board member appeared to confirm that it did not.

At a meeting of the Public Accounts Committee (PAC) on the 26 October, I quizzed officials as to the outcome of the Geoghegan review, with the Chairman of the NAMA board, Frank Daly, not yielding too much. It was “confidential” he said. Mr Geoghegan had given a verbal briefing to the board of his review, with a number of suggested recommendations. He then gave the same to the Minister, but nothing was written down and no final report was prepared. This meant that either Mr Daly or the Minister would have to give it up.

While Mr Daly remained tight-lipped, the Minister indicated separately his intentions to make some of the recommendations from the review known at a later date. Meanwhile a second member of the nine person board resigned. It seemed certain that a significant change was coming.

And it has now come, with the announcement today that an Advisory Group (AG) to the Minister on NAMA’s operations is to be established. Its purpose will be to advise the Minister on “NAMA’s strategy and its capacity to deliver on that strategy through property disposal and the ongoing management of assets.” More specifically, the AG will:

• Help identify candidates for the NAMA board (and these candidates will have entrepreneurial and property skills);
• Make recommendations on strategies for attracting international capital to Ireland; and,
• Provide advice on lessons learned from asset management agencies in other countries.

NAMA will be directed to cooperate with the AG through the establishing Act of 2009. (So, no change to legislation, as was speculated, but a new order from the Minister under the Act.)

This is a significant development for NAMA. Why?

For one, it confirms that the board is lacking the required expertise for the discharge of its duties as it enters this new phase. That’s an important thing to understand, but it’s perhaps more important that action is being taken to change that fact. It is unlikely that this would have happened in the absence of the Geoghegan review. The Minister is to be congratulated on this.

Secondly, attracting international capital to Ireland is absolutely key if NAMA is to be successful – and there is much external interest. Establishing this as a priority of the AG means that now hopefully serious moves will be made in this direction. Use of the word ‘strategies’ for attracting that investment might point to possible portfolio arrangements, whereby less desirable assets would be packaged with more attractive ones. This is probably necessary for NAMA to successfully meet its obligations.

It was also announced by the Minister that there will be a reduction in the stamp duty rate for commercial properties from 6% to a flat rate of 2%. This should also be a big help to the Agency as it begins to move more Irish properties off its portfolio.

It will be interesting to see how the AG interacts with the Agency in practice and how ‘hands-on’ the Minister will choose to be on foot of its advice. Expect some friction. Chairman Frank Daly seemed to infer at the PAC that while there would be some changes following the Geoghegan review, even structural ones, these would not be significant. This doesn’t fit in my opinion with what the AG is being set up to do. And it certainly doesn’t chime with the comments of one of the resigning board members.

The size of the AG and the formality of its structure will be important considerations. A more fluid membership than the rigid structure of the traditional board system might be an advantage here. This new dimension to the Agency’s operation also provides an excellent opportunity for increasing transparency of the Agency’s activities. At the very least, if its advice was made public, we could measure NAMA’s operation against something.

This is an opportunity to bring more expertise and more focussed direction behind the NAMA project, and it is needed. With an estimated 20% drop in property values since the transfer price paid by NAMA, the possibility that the Agency might require some form of recapitalisation at a future date is very real. The very minimum that must be recovered is €31.7Bn over the next eight years. All relevant resources should be brought to bear.

***

Separately, the Minister also announced that legislation would not now be introduced to tackle upward only rent review clauses in existing leases. NAMA had previously anticipated that such legislation would reduce the value of its Irish portfolio by as much as 20%.

This will be a blow to many, but NAMA has advised the Minister that it will publish its policy guidance for dealing with tenants experiencing difficulties arising from upward only rent reviews. The guidance does allow for NAMA to approve rent reductions, it allows for the appointment of an independent valuation of market rent, and it allows tenants to approach NAMA directly where landlords are not being cooperative.

Of course it’s not what those experiencing genuine difficulties with their existing leases were looking for, but insofar as NAMA’s operation is concerned, the publishing of the policy guidance is a welcome measure. NAMA is nowhere near as transparent an organisation as it should be and anything that sheds light on how it conducts its business is a positive.