EY's Pay Perspective: 2016 Executive and Board Remuneration ...

EY Pay Perspective2016 Executive and Board Remuneration Report

1 EY Pay Perspective 2016 Executive and Board Remuneration Report |

EY is pleased to present the EY Pay Perspective: 2016 Executive Board and Remuneration Report, now in its 13th edition.

Over the last year we asked attendees to our non-executive director (NED) forums about their top executive remuneration concerns for 2015. Their collective view was clear:

1) How to align pay to performance.

2) How to align remuneration strategy to business strategy.

This view was shared by our clients in management roles. Therefore, we have focused our Pay Perspective report this year on our insights in these areas.

To provide context to the rst concern, we examine 2015 remuneration outcomes and analysis of the historical pay for performance relationship over a

ve year timeframe, to see whether there was any identi able link between pay and performance.

Then, as we look at remuneration strategy, we are seeing organisations adopting one of two approaches:

• Continued use of standardised structures and mechanics, within traditional remuneration models.

• An increasing number of companies considering adopting innovative, tailored remuneration strategies that re ect business goals and the speci c value drivers for individual companies.

There are a number of opportunities for companies in their approach to remuneration around the effectiveness of remuneration to drive desired outcomes and to also emphasise the right behaviours.

On the following pages you will nd more details of current and changing practices that we trust will help guide you in formulating your own remuneration design for 2016 and beyond1. We look forward to working with you in 2016.

Executive summary

1 Our analysis continues to be supported by EY’s Board and Executive Remuneration Database — the most comprehensive and reliable tool of its kind in Australia. The data in this report is based on the remuneration quantum and policy released by 31 December 2015 for the 100 largest listed companies in Australia as at 1 December 2015 (Top 100).

2 | EY Pay Perspective 2016 Executive and Board Remuneration Report

n uences on executive remuneration in 2015 3

Themes from 2015 5

Future executive remuneration challenges and opportunities 17

De nition of key terms

BUH Business Unit Head

Business plans / strategy / growth Measures such as New Business Acquisitions, Execution of Strategic Initiatives and Implementation of Key Growth Initiatives

Capital management / funding Measures such as Average Capital Employed, Liquidity and Core Funding Ratio

CEO Chief Executive Of cer

CFO Chief Financial Of cer

Lower 50 Listed companies in Australia ranked 50 to 100 as at 1 December 2015

LTI Long-term incentive

NED Non-executive director

No STI deferral An STI plan paid immediately following the end of the performance period

People / values / behaviour / culture Measures such as Employee Engagement, Employee Culture and Leadership Development

Pro t / earnings Measures such as Earnings before Interest and Tax, Pro t before Tax, Net Pro t after Tax and Earnings per Share

Return Measures such as Return on Equity, Return on Assets, Return on Capital

Safety / health / environment Measures such as Lost Time Injury Frequency Rate, Zero Harm and Environmental Sustainability

STI Short-term incentive

Top 50 Listed companies in Australia ranked 1 to 50 as at 1 December 2015

With STI deferral An STI plan paid in part immediately following the end of the performance period and in part after a further de ned time period

Contents

3 EY Pay Perspective 2016 Executive and Board Remuneration Report | 33 EY Pay Perspective 2016 Executive and Board Remuneration Report |

ue ces executive remu erati i


Effective executive remuneration design requires companies to

Focus on revenue growth, ef ciency and productivity gains. Cost-reduction initiatives, with some companies considering headcount reductions.

M A activity in Australia at pre-GFC levels, and predicted to continue through 2016.Businesses addressing change of control terms in long-term incentive (LTI) and deferred short-term incentive (STI) plans.

Increased cost of attracting offshore talent due to weaker dollar. Higher cost of importing talent leading to companies increasingly opting for short-to-medium term mobility arrangements and internal capability development.

Importance of clarity of messaging and commercial rationale for incentive pay structures and targets and how they link to strategy.Proxy advisor groups and institutional investors are converging on the importance of performance hurdles re ecting stretching targets and aligning performance periods to business cycles.New tax rules allowing for taxation of

options and rights at exercise instead of vesting, and extending the maximum deferral period to 15 years.

Efforts to improve alignment between remuneration policies and business strategy. Companies reviewing their entire remuneration structure and linking it to their strategy.

Executiveremuneration

“Buying”talentoverseas is moreexpensive

Board focus

Limitedregulatory change

Companiesare doing more with less

Shareholderand proxyadvisor group

remains strong

Uncertainand volatile economicenvironment

EY Pay Perspective 2016 Executive and Board Remuneration Report |

Themes rom

In FY15, remuneration outcomes continued to be generally re ective of company performance.

We saw only modest xed remuneration increases for “same incumbent” CEOs and executive roles. Total target remuneration increased slightly for CEOs, although more signi cantly for other executives ( ure ).

Across the market, median total target remuneration has increased for Top 100 companies’ executives, while there was no change in median xed remuneration ( ure ). This is largely due to new incumbents receiving lower xed remuneration than their predecessors (with median xed remuneration around 14% lower for new incumbent CEOs).

The increase in total target remuneration re ects that more companies are increasing incentive opportunities and focussing on using variable remuneration to reward performance, rather than considering performance outcomes in xed remuneration increases.

Figure 1: Fixed remuneration increases have remained modest for same incumbent CEOs and other executive roles, with total target remuneration increasing for executives

Element CEO CFO

Fixed remuneration 2.6% 3.2% 3.5%

Total remuneration 1.6% 7.3% 7.7%

Figure 2: Median total target remuneration has increased slightly for executives within the whole market

Variable remuneration

CEO

2014

5,768 6,222

1,877 2,169 2,124 2,251

2015 2014 2015 2014 2015

CFO BUH

7,000

6,000

($’000s)

5,000

4,000

3,000

2,000

1,000

0

Fixed remuneration


Awarded STI payments were just above target and generally increased slightly in FY15 compared to FY14 ( ure ).

Figure 3: Median actual STI payouts as a proportion of target STI were slightly above target levels

o e Year T pai as a percenta e o tar et

CEO 2015 107%

2014 104%

CFO 2015 105%

2014 107%

BUH 2015 104%

2014 102%

28%

33%

36%

36%

35%

30%

26%

31%

28%

25%

29%

17%

46%

36%

36%

39%

36%

54%

Top 50 companies

CEO

CFO

BU

HCE

OCF

OB

UH

36%

36%

45%

36%

48%

48%

26%

30%

29%

19%

24%

16%

38%

34%

26%

45%

28%

36%

Lower 50 companies

Average xed remuneration as a % of total remunerationAverage STI target as a % of total remunerationAverage LTI grant as a % of total remuneration

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

Remuneration mix shifted as

2015 saw some change in the remuneration mix ( xed remuneration vs STI vs LTI) for the Top 100. While there tended to be some uctuation in the remuneration mix, there was a broad shift towards a greater emphasis on LTI in 2015.

Figure 4: Target remuneration mix varied by both company size and remuneration structures

Remuneration mix continued to vary by company size and remuneration structure ( ure 4). Top 50 companies were more heavily weighted towards variable pay, and generally had a higher proportion of LTI in the remuneration mix than Lower 50 companies. Of all roles, CEOs had the smallest proportion of total remuneration delivered as xed remuneration.


Another way to look at remuneration mix is the proportion of remuneration opportunity in equity versus cash. There was a clear difference between the Top 50 and Lower 50 companies in 2015, which is broadly consistent with 2014.

48%

68%

56%

71%

56%

68%

52%

32%

44%

29%

44%

32%

Top 50 companies

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

57%

76%

64%

76%

65%

86%

43%

24%

36%

24%

35%

14%

Lower 50 companies

Average cash as a % of total remunerationAverage equity as a % of total remuneration

With STI deferral

No STI deferral

With STI deferral

No STI deferral

With STI deferral

No STI deferral

CEO

CFO

BU

HCE

OCF

OB

UH

Figure 5: Larger companies pay proportionately less cash and more equity

Companies with STI deferral offered a lower proportion of remuneration as cash to their executives than companies without STI deferral. Top 50 companies had proportionally lower cash opportunities than Lower 50 companies ( ure 5).


Boards, shareholders and proxy advisors in Australia and overseas expect that executive, and particularly CEO, remuneration outcomes re ect company performance.

We wanted to examine whether the data re ected that focus. We used publicly available data for the ASX 50 to test if that had been the case for CEO incentive outcomes over a ve-year period from 2011 to 2015. The results of our analysis supported our hypothesis.

Remuneration outcomes do re ect company performance. Further, the strength of this link has improved over the past ve years.

We were not trying to answer the question “do CEO incentive dollar

Instead, we asked “given the incentive

— which removed company size and industry variables from the analysis.

We looked at incentive outcomes paid to CEOs in cash or various forms of equity in each year, rather than the statutory / accounting value of remuneration disclosed (which is typically different to actual remuneration).

Our analysis measured:

1) The value of STI received as a percentage of the maximum opportunity for that year.

2) The value of LTI vested as a percentage of the maximum opportunity for each grant.

These incentive outcomes were then assessed relative to the company’s performance.

We analysed short-term and long-term company nancial performance using common metrics considered re ective of company performance:

• Short-term company performance: one-year total shareholder return (TSR) growth, one-year earnings per share (EPS) growth, and one-year operating pro t margin growth over each company’s nancial year.

• Long-term company performance: three-year TSR growth and three-year EPS compound annual growth to 2011, 2012, 2013, 2014 and 2015. Three year performance was measured, as most ASX100 companies use three year performance periods.

Based on the company performance outcomes, companies were divided into four company groups according to their quartiles (Top, High, Moderate and Low) for short-term and long-term performance.


We found that CEO incentive outcomes

Perc

enta

ge o

f max

imum

opp

ortu

nity

pai

d

Perc

enta

ge o

f max

imum

opp

ortu

nity

that

ves

ted

83% Top performing

STI LTI

61% High performing

37% Moderate performing34% Low performing

85% Top performing

68% High performing67% Moderate performing

57% Low performing

Figure 6: Average incentive outcomes (as a percentage of maximum) were highest for CEOs of top performing companies

The graphs below illustrate our ndings. The average STI and LTI incentive outcomes for each of the performance groups (Top, High, Moderate and Low performing companies) are shown below ( ure 6). Average incentive outcomes are presented as a percentage of maximum opportunity.

Our research showed a link between CEO incentive outcomes and company performance. Top performing companies paid their CEOs, on average, a higher proportion of their maximum STI and LTI than the High, Moderate and Low performing companies.


2014

Shares

38%

2015

CashRightsOther

37%

15%

8%

8%

8%

42% 48%

2014

2 years

2015

3 yearsBetween 2 and 3 years

Between 1 and 2 years1 yearLess than 1 year

46%

29%

56%16%

29%

19%

4%

2%

Figure 8: STI deferral of 2 years has increased for STI plans with single-point vesting

Figure 7: Shares and rights remain the most common STI deferral vehicles

There is no clear trend as to whether STI deferral periods are increasing or not, but we have seen change as companies altered their remuneration structures to match business needs. There was a small increase of 5% in companies using tranche vesting for STI deferrals (from 31% to 36%). Among companies with single-tranche deferrals, 10% more deferred a portion of their STI for two years in 2015 compared to 2014 ( ure 8).

Note: May add up to more than 100% due to companies operating more than one STI plan

circumstancesWhile the aggregate statistics paint a broadly unchanged picture for STI plans in 2015, our client experience is that many companies are revisiting their plans to re ect company speci c or industry wide circumstances.

Prevalence of STI deferral was broadly unchanged, with 73% of companies deferring a portion of STI. There was only a small change in the vehicle of choice for STI deferral; shares and rights remained the most common deferral vehicles ( ure 7). Deferrals into cash decreased in prevalence, with 8% deferring STI to cash, compared to 15% in the previous year.

Standard approaches to remuneration mix and incentive design can lead to ineffective remuneration structures, as there is not a “one size ts all” approach that will suit all companies’ circumstances. Consequently, companies are re-evaluating (or have re-evaluated) their remuneration structures.

Institutional investors and proxy advisors have supported bespoke remuneration structures that link to the business strategy, when there is a commercial rationale and clear communication. As long as investors and proxy advisors are informed of the reasons for the

introduction of tailored plans, the foundations have now been laid for more diverse — and t for purpose — practices in remuneration frameworks.

structure design2015 was a static year for changes to remuneration structures. Most companies made small, gradual changes rather than large, structural changes.

However, our work with clients paints a more interesting and insightful picture. Some companies are starting to undertake bigger changes — a clean

sheet of paper approach, with a view to aligning remuneration frameworks to the business strategy. Some companies have moved away from a traditional remuneration framework. Others are changing performance measures; for example introducing absolute performance measures with the rationale that it closely aligns executive remuneration outcomes to shareholder experience, or introducing measures aligning the LTI to a publicly stated strategic initiative to emphasize the importance of that initiative.


Pro t / earnings

88%

84%

Capital management / funding

37%

26%

Return

34%

38%

20152014

People / values / behaviour / culture

79%

66%

Business plans / strategy / growth

58%

68%

Safety / health / environment

52%

52%

Figure 10: Top three STI plan non- nancial performance measures

Figure 9: Top three STI plan nancial performance measures



Pro t / earnings are still the most prevalent nancial STI performance measure. The use of capital management / funding measures increased, while return measures decreased slightly ( ure 9).

The top three non- nancial performance measures remained unchanged for the third year in a row ( ure 10). Although not one of the most prevalent measures yet, we are seeing an increase in project speci c / milestone performance measures, with 26% of companies using them compared to 19% in 2014.

People, values, behaviours or culture is a predominant STI performance measure, used by 79% of the Top 100. This represents an increase from 2014, when these were used by 66% of companies

Minimal

Degree of change and common approaches

i ni cant

> Retain existing structures and performance measures

> Change pay mix> Add strategic performance

measure to performance hurdles> Tailor comparator groups for

relative performance requirements

> Combine remuneration elements

> Remove short-term or long-term components entirely


Figure 11: The range of LTI plan changes

Figure 12: Relative TSR and absolute EPS is the most common LTI performance measure combination

Relative TSR and absolute EPS 43%

Relative TSR and return measure 20%

Relative TSR with two separate comparator groups 15%

Relative TSR and another measure 15%

Absolute EPS and another measure 8%

As companies assess and adjust their LTI plans, we see a spectrum of approaches, ranging from maintaining a traditional vanilla LTI approach to unique approaches, depending on the outcomes of their reviews ( ure 11).

As in previous years, a majority of companies’ LTI plans use two measures (61%). There has been an increase in companies using three or more measures in their LTI plans in 2015, 18% compared to 12% in 2014.

There was more standardisation in the performance measures of choice among LTI plans with two performance measures. Of these, the most common combination was relative TSR and EPS growth, 43% in 2015 compared to 38% in 2014 ( ure 12). The increased prevalence is due partly to new entrants into the Top 100 companies using this combination, and partly to companies changing their performance measures.

Some companies are testing different performance measures; for example, introducing additional strategic or project-based measures in addition to existing measures. Of the 14 companies with three performance measures,

12 used relative TSR and EPS in their LTI plans. This mixed use of traditional and innovative metrics is in line with the results of client surveys we ran in 2015, which indicated companies are willing to try new approaches by introducing non-traditional measures, but are cautious against deviating too much from the market norm.

Two other approaches to performance benchmarks noted were the use of absolute TSR (rather than relative) as a performance measure and use of more tailored comparator groups, where possible, for relative TSR-based plans (rather than index constituents or general market matches).


2014

Performance rights

80%

2015

Share optionsPhantom / cashOther

83%

10%

11%

13%

17%

12%

12%

2014

Between 4 and 5 years

2015

5 years

4 years3 yearsLess than 3 years

76%

70%

17%23%

4%

3%

3%

1%3%

Figure 13: Performance rights remain the most common LTI vehicle

Figure 14: Limited change in LTI performance periods

2 EY analysed the weighted average time it takes for remuneration to be received by CEOs in the Top 100 companies. For example, if a CEO receives a target package consisting of 30% xed remuneration, 30% cash STI and 40% LTI vesting after 4 years, the weighted average reward timing is: Fixed remuneration (30% x 0.5 years) + STI (30% x 1.0 years) + LTI (40% x 4.0 years) = 2.05 years.

Note: May add up to more than 100% due to companies operating more than one LTI plan

Performance rights are still the

Performance rights remain the most prevalent LTI delivery vehicle, used in 80% of plans ( ure 13). There was a slight increase in the use of options, which replaced phantom or cash-based plans as the second most prevalent vehicle in 2015. Increased use of options was mainly due to new entrants into the Top 100, rather than a policy change by existing companies. However, our client interactions indicate an increased interest in providing a choice between options or rights as LTI plan vehicles in 2016.

There was an increase of 7% in companies that use tranche vesting for LTI plans in 2015 (from 12% to 19%). Among companies with single-tranche vesting, performance periods have remained virtually unchanged from 2014 ( ure 14). 70% of companies use three years as the LTI performance period. Although we have heard from some proxy advisors that four year performance periods are becoming the norm, this is not supported by the data, and less than a quarter of companies use a four year performance period.

The average time it takes for remuneration to be received by CEOs has risen from 1.75 years, following a decrease in the previous year. The average time a CEO needs to wait to realise the full value of rewards granted in a given year was 1.79 years in 2015. This small increase indicates that across the market companies are not making signi cant moves towards longer performance periods ( ure 15)2.

Figure 15: CEO median weighted average reward timing (years)

2013 2014 2015

1.87

1.75

1.79

Executive minimum shareholding requirements remained staticConsistent with 2014, 45% of companies disclosed a minimum shareholding requirement for executives ( ure 16).

Figure 16: No change in executive minimum shareholding requirements

2014 2015

43% 45%


The initial response to the introduction of the two-strike rule was for most companies, adopting remuneration structures that were common market practice. This conservative approach has started to change in the past two years, with companies questioning whether the standard, “vanilla” approaches can actually support business goals and be effective. NEDs, management, and shareholders (and their advisers) recognise the importance of aligning remuneration with business strategy.

In our conversations with NEDs, they highlighted concerns over negative market reactions as an impediment to making signi cant change. Of particular concern is the perceived potential impact on remuneration report voting and related “two-strike rule”.

There has been an increase in the percentage of companies receiving “no votes” in 2015 ( ure 17).

However, remuneration report voting outcomes do not seem to be related to changes in remuneration strategy and / or structures. Rather, the reasons for the strikes can generally be categorised into three main themes:

• Protest vote unrelated to remuneration: shareholder dissatisfaction with company performance, management, or Board.

• Perceived misaligned pay outcomes: excessive pay for executives, especially combined with poor performance.

• Poor external communication /engagement: Shareholders / proxy advisers not understanding incentive plan mechanics or the link between the remuneration framework and company strategy.

We are not aware of companies receiving a strike purely in protest against changes to remuneration strategy, or introducing innovative remuneration structures. This fact should provide some comfort to companies considering whether there is an opportunity to change their approach based on their speci c business requirements.

EY Pay Perspective 2016 Executive and Board Remuneration Report |

Figure 17: More companies received a “no vote” in 2015

0-10%0

10

20

30

40

50

60

70

80

90

10%—25%

“No vote” percentage

Perc

ent o

f com

pani

es

Avg 3%

Avg 2%

Avg 16%Avg 17%

Avg 47% Avg 37%

25%—100%

20152014

100


ctual total ees Represent actual fees paid to Chairs /NEDs including committee fees where applicable

Fee policy Represent the base fees for services on a company’s board, as set out in company policy and excludes additional fees paid for committees or other services

for options and rights (with the right structures around the plan rules), has contributed to this change by allowing tax-effective equity-based payments for NEDs. We expect the trend to continue in 2016.

NED fee pool increases slowed down in 2015 (4% at median) compared with 2014 (10% at the median). The increase in NED fee pool size has corresponded with similarly conservative increases in the fees paid to NEDs ( ures 19 an 20).

Figure 19: Actual fees paid to company directors in the Top 100

Figure 20: Policy target fees for company directors in the Top 100

2015 saw NED fee structures starting to change, with more companies introducing minimum shareholding requirements ( ure 18).

There has been a large increase in the number of companies implementing minimum shareholding requirements for NEDs. 2015 was the rst year that the majority (57%) of the Top 100 companies required their directors to have “skin in the game” by holding company shares. The Employee Share Scheme taxation policy changes, allowing deferral of taxes until exercise

Figure 18: Over half of Top 100 companies now have NED minimum shareholding requirements

2014 2015

48%

57%

208 218

NEDs Chairs

4404652015

2014

165 170

NEDs Chairs

470 476

Note: Actual fees for chairs appear lower than policy fees due to differences in sample size (as not all companies disclose policy fees).


Future executive remuneration challen es an opportunities


Focus on t or purpose Companies will continue to focus on their executive remuneration strategy and structures to ensure they are aligned with company strategy:

• More companies will introduce strategic measures and non-traditional remuneration approaches that are more aligned with the business strategy.

• Regular reviews and reassessment of executive remuneration structures will become the norm, focusing on alignment to the business and testing whether the approach is effective in supporting required behaviours and performance.

Executive remunerationmpact o economic environment

We expect to see some companies adapt their executive remuneration strategy to re ect challenging conditions through:

• Minimal xed remuneration increases and setting lower remuneration levels for new incumbents.

• Strengthening of the target-setting mechanism for STI metrics, to ensure affordability and improve the alignment between pay and performance.

• More use of minimum performance gateways to ensure affordability of STI payouts.

• Greater remuneration weighting on equity as opposed to cash.

We see remuneration challenges and opportunities for change in 2016 and beyond will be around the effectiveness of remuneration plans in not only supporting the required outcomes, but also the right behaviours for executives and the broader employee population:


Better communication o the relationship etween incentive outcomes an per ormance Companies will consider adapting the way their remuneration approach is communicated to internal and external stakeholders, focusing on clarity and simplicity of messages. More companies are now viewing their remuneration reports as communication and engagement platforms, which is a transition from a purely compliance-based view. Consistent with the themes explored earlier, simple articulation of the following generally underpin a strong communication-based approach:

• Why the company uses its executive remuneration approach and how the approach supports the business strategy.

• How remuneration outcomes re ect the business outcomes achieved.

Whole of organisationmpact o economic environment

We expect to see companies focus on how they effectively spend budgets that are likely to remain static or, in some cases, decrease:

• Companies will continue to provide minimal xed remuneration increases and increases will be more targeted to critical roles and talent.

• As budgets contract, there will be more stringent allocation of STI pools and more consideration of how pools are distributed to participants.

Focus on t or purpose We expect to see:

• Financial services companies responding to APRA and ASIC’s focus on the effectiveness of remuneration structures, and how remuneration structures in uence behaviours and culture.

• This will also impact companies outside nancial services; given most NEDs in nancial services sit on multiple boards, which likely include other industries.

• Remuneration Committees scrutinising the effectiveness of incentive plans not only in supporting the required outcomes but also the right behaviours.

Use o ata analytics In the past year we have seen signi cant interest in productivity and analytical tools related to people. We see people analytics and evidence-based decision making as key inputs into labour productivity in the future, and expect companies to increase investment in analytic tools to determine how to best spend reward budgets:

• Consideration of the total reward approach, including non-monetary bene ts to support employee engagement and wellbeing.

• Analysing wage structures and optimising costs associated with collective agreements that companies are about to negotiate, are in the process of negotiating or at the conclusion of a negotiation to articulate costs and bene ts.

| EY Pay Perspective 2016 Executive and Board Remuneration Report 2020

Institutional investors and proxy advisors are increasingly supporting tailored / bespoke remuneration structures, as long as the structures are communicated clearly and support the company strategy.

Ideal remuneration arrangements strike the right balance between strategic and tactical business goals, attract and retain the right talent to deliver these, and discourage excessive risk taking. At the same time, remuneration structures should not reward executives for failure, should be fair and valued by executives, and re ect performance both at the individual and company level.


Craig Whiteman Tel: +61 8 8417 1770 [email protected]

Tel: + 61 7 3011 3182 [email protected]

Tel: +61 3 9288 8212 [email protected]


Bruno Cecchini Tel: +61 3 9288 8423 [email protected]



Perth



Rohan Connors Tel: +61 2 9248 4318 [email protected]




Richard Kantor Tel: +61 2 9276 9052 [email protected]

David Werner Tel: +61 2 8295 6721 [email protected]


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© 2016 Ernst & Young, Australia. All Rights Reserved.

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This communication provides general information which is current at the time of production. The information contained in this communication does not constitute advice and should not be relied on as such. Professional advice should be sought prior to any action being taken in reliance on any of the information. Ernst & Young disclaims all responsibility and liability (including, without limitation, for any direct or indirect or consequential costs, loss or damage or loss of profits) arising from anything done or omitted to be done by any party in reliance, whether wholly or partially, on any of the information. Any party that relies on the information does so at its own risk. Liability limited by a scheme approved under Professional Standards Legislation.

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