It’s probably a legacy from my days as a member of the “accountants’ union”, but I’ve always had a respect for the worker bees in Tower Hamlets council’s over-stretched finance department. They do a difficult job in very tricky circumstances and they have to deal with all manner of politics from members and senior officers.
But they probably won’t thank me for highlighting this piece of legislation that may well add to their workload.
Under the Audit Commission Act, every council must for a four week period throw open its books for public inspection. It’s a fabulous piece of legislation that pre-dates the Coalition’s equally excellent transparency agenda. But curiously enough you won’t find any feature about it in the £1.5m pages of East End Life.
Tower Hamlets council, like most other authorities, aren’t that keen for people to know about. However, they are required by law to place a public notice in a local paper advertising the dates when the inspection takes place in a particular year. This year’s advert, for the financial period April 2013 to March 2014, was placed in the back pages of East End Life on June 9…nine pages after that week’s restaurant review, for which a council worker was handed £40 for a nice meal.
Here’s the advert:
Under this legislation, anyone can ask to see the details of any transaction during the financial year in question. This includes seeing copies of any contract, purchase order or invoice or other supporting documents.
So, if you were so inclined you could ask to see all transactions made for restaurant reviews in East End Life during 2013/14. You could ask for a list of all payments made for these reviews and view all invoices submitted by external contributors or expense claims submitted by staff.
Some issues might still be subject to confidentiality clauses. For example, you won’t be able to ask for individuals’ salaries. You can ask for all salaries in a particular area but you won’t see names attached to them. The Data Protection Act still applies.
However, this legislation allows for far more transparency than the both the Freedom of Information Act and the lists of payments to suppliers that councils must now publicise. So it gives us all a chance to have a look under those redacting pens.
For example, you’ll remember from this post here that when I asked under the FoI Act recently for the invoices submitted by the Champollion PR agency for its work combatting the Panorama programme, the council sent me this:
Under the Audit Commission Act, those black pen marks will have to be removed.
The Act is a potential gold mine of information, but you only have until July 28 to submit questions and follow ups. If you ask for information before then, the council must answer it even if that answer comes after July 28. However, the earlier you ask the questions the better.
And a plea (for the sake of the accountants), be wise and judicious in what you ask for. Fishing expeditions are of course allowed but try to narrow your searches and questions. Think about what you want. For example, you might want to see a summary of all expenses submitted by officers and councillors for “entertaining” (councillors rarely submit such claims by the way). From that summary you might want to drill down into something by asking for copies of receipts for a particular meal. Which restaurant, what did they eat and who did they entertain?
You might want to ask for copies of invoices submitted by a particular consultant or contractor.
It might be a good idea to discuss on this blog what you or someone else might ask. Let’s co-ordinate questions.
For my side, I’ve submitted an early batch of questions on Champollion, the lawyers Taylor Wessing and East End Life’s accounts. I’ve also asked for copies of invoices for Mayor Lutfur Rahman’s chauffeured Mercedes in the period.
And I’ve also asked for any payments made to The Society of the Golden Keys during the year. What’s that, you ask? In March 2012 (I saw this some time ago, but had forgotten about it), the council’s communications department paid the Society £800 for membership fees. I was told it was on behalf of Takki Sulaiman, the £100,000 a year head of communications. I was told he attended dinners/events with the society.
Here’s more about the Society, which is a membership group for hotel concierges in Britain.
The Society of the Golden Keys in Great Britain is thriving. With strict conditions of membership requiring proof of professional relationships with guests and work colleagues, approximately three hundred and thirty concierges in Great Britain now proudly wear the symbol of their status: the Golden Keys lapel pin. Each is revered for his or her professional gravitas, integrity, local knowledge and impeccable recommendations. The Society encourages friendship and camaraderie and the members meet formally each month. The Ladies’ Night Dinner and Dance and the Anniversary Cocktail Party are the social highlights of the year for many of the leading figures in the hospitality industry, as well there are many other events which the society of the Golden Keys help to promote.
Could one ask a list of all grants and other funding to individuals (no associations or companies)?
Yes but I think they’re already publicly available.
Asking for Champollion details is a good idea. Can we also ask for details of how much was paid by external organisations to advertise in EEL (I’ll bet that a lot of the stuff from East London Mosque and affiliated organisations get adverts buckshee, or at least heavily reduced.)
I’m trying to think of likely areas of fraud that can only be delved into via this method, and my imagination is running a bit dry. Given the ‘Golden Keys’ link (which looks to me like an excuse for Sulaiman to be winded and dined at someone else’s expense) then would it be possible to ask for details of membership of other ‘hospitality organisations’ that councillors have?
Could you get a view of the list of the grants to various organisations – i.e. the spreadsheet that they have refused to divulge thus far?
How do you make requests anyway? It looks like we need to turn up in person at the address given. Would we be allowed to take copies of things that we look at?
Tim.
Use the email in the link provided. Will update the post for that.
It’s not really about fraud; it’s very unlikely you’ll detect that. It’s more about appropriate spending.
Eg think of parking wardens and THEOs. What money is spent on them besides salaries? Uniforms, kit etc.
Think of receptions held by the mayor etc. Who did the catering? Ask for their invoices and what food was provided.
Good ideas there Ted, thanks. That sort of thinking is why you are a journalist and I’m not!
Tim.
Why are we paying for Sulamain, not a concierge or hospitality professional, to belong to this Golden Keys Concierge organisation? Surely there is someone withinTHBC who is more qualified?
Or is Sulamain a jumped up concierge and not fit for his currently highly paid role?
How much does each dinner he attends cost LBTH council taxpayers?
Also, are we paying for him to attend the 62nd congress in Mendoza, Argentinia, April 2015? If so,how much of LBTH council taxpayers’ money is being squandered?
http://www.thegoldenkeys.co.uk/
Takki Sulaiman would not qualify for membership according to the conditions on the Golden Keys Concierge organisation’s website.
Good point! Subscription is 70GBP London members and 60GBP out of town members. What does the 800GBP relate to?
£800 is corporate membership.
Nothing I can see on their website about corporate membership at £800.
Download the pdf New Associates Application form, from the Associate Membership link in the Membership tab at the top of the Home page. The fee is quoted on the form.
Gotcha! An Associate Member – £800. Still a strange expenditure, IMHO.
Very strange, particularly as neither Sulaiman nor the Council qualify for membership.
I am astonished that you, Ted, accepted a LBTH invoice which didn’t show any money.
https://trialbyjeory.files.wordpress.com/2014/06/panorama-champollin-invoices3.jpg&h=1024
That sort of cover-up is utterly unacceptable. Did you appeal against the exhibiting of the de facto BLANK invoice ???
Curious Cat
I knew I’d get it this way. Time wasters
I’m curious as to whether or not East End Life qualifies as a public newspaper within the definition of the Act.
It’s usual for all Councils to also place an advertisement in the local recognised commercial public newspaper as well as any local in-house amateur effort which might exist.
How about an email to the Director of the Tower Hamlets Audit, PWC and Eric Pickles asking what qualifies as a suitable newspaper?
The reason I ask is the only thing I would count as an appropriate newspaper is one that had its circulation validated via e.g. an ABC audit http://www.abc.org.uk/ The thing about East End Life is that all too often in the past one has seen copies dumped in various parts of the borough
The intent behind the Act is that the announcement should be prominent. I’d therefore expect to see BOTH
* a news release and
* a link to the information about it on the Council’s website.
Especially for a Council which was maintaining it had nothing to hide despite the fact it’s currently undergoing a separate audit of its expenditure and processes.
I’ve not looked at the website yet – I wonder what I will find?
Many local newspapers (and more) – i.e. paid for weeklies – no longer use ABC and indeed ABC also now hide their figures (unless you subscribe).
An interesting service for details of local newspaper circulation is provided by JICREG (a newspaper industry body). The report for TH shows that the circulation of the ELA is now less than 10K (9,354) although with a very unusual feature that more than 50% of the bigger AIR readership (includes digital) are aged 0-34. (Also 2 people in TH buy the Brentwood Gazette – who are they!) ttp://jiab.jicreg.co.uk/standardreports/report.cfm?NoHeader=1&geogtype=post74&SID=5960641921&UID=-1
There is no doubt that East End Life is the biggest TH specific media outlet so the notice is best here although I think it should also be publicised more as is suggested.
Incidentally one of the many good points that councils whose newspapers Pickles is or has shut down make is that they as they are obliged to produce public notices in newspapers (such as this one about the accounts). So when they no longer have a paper, they will again be gouged by the paid-fors. These charge well over the odds to put ‘Public Notices’ in their weekly paper and which fewer and fewer read and with most of them being pensioners. A clear example of councils being obliged to subsidise a business.
Local Government Lawyer quotes from the regulations in this article http://www.localgovernmentlawyer.co.uk/index.php?option=com_content&view=article&id=6388%3Agovernment-requires-councils-to-publicise-right-to-inspect-accounts&catid=59%3Agovernance-a-risk-articles&Itemid=27
“The revised Accounts and Audit (England) Regulations 2011 now include the following notification requirements:
the period during which the accounts and other documents will be available for inspection
the place at which, and the hours during which, they will be so available
the name and address of the auditor
the right to make objections at audit; and
the date appointed for the exercise of rights of electors.
As soon as reasonably possible after conclusion of an audit, a larger relevant body must give notice by advertisement and on its website stating that the audit has been concluded and that the statement of accounts is available for inspection by local government electors and including:
a statement of the rights conferred on local government electors
the address at which and the hours during which those rights may be exercised; and
details of where the statement of accounts can be found on the body’s website
Communities and Local Government Secretary Eric Pickles said: “An open Government is vital for good democracy and that’s why councils have to open their ledgers to the public – everyone has a right to know how their taxes are spent.
“But it’s not enough to just publish them quietly, armchair auditors and local journalists need to know exactly where to find that information and these new changes will make sure they are not just out in the open but under the spotlight too.””
Below you can find links to the official Audit Commission publications about inspecting accounts and making formal objections (and what that needs to include)
The first is the most accessible and I’d certainly recommend people have a good read of this if they want to follow through with an inspection of documents and a formal objection.
Council accounts: a guide to your rights (PDF document) – http://www.audit-commission.gov.uk/wp-content/uploads/2008/04/Council-accounts-Know-your-rights-July-20132.pdf
Council accounts – Your rights: Notice of an objection (PDF document)
Click to access objectionform2.pdf
Does this cover accounts and reciepts by Tower Hamlets Homes too?
Good question. I’m fairly sure it must do but we ought to check. If so, there are all manner of invoices that I’d like to examine…
I think you’ll find it’s a separate entity with its own auditors
Tower Hamlets Homes is a trading name of Tower Hamlets Homes Limited, a not for profit company limited by guarantee controlled by the London Borough of Tower Hamlets. Registered in England 06249790. VAT Registration No 912 4819 30. Registered Office: Jack Dash House, 2 Lawn House Close, Marsh Wall, London E14 9YQ.
It’s worth asking the auditors whether or not it’s included within the audit. I suspect that you’ll find only the transactions between it and the council are included.
THH not registered with Charities Commission – interesting!
Not really – THH is not a charity, but is a company limited by guarantee. THH is wholly owned by LBTH and its accounts are incorporated into LBTH although it has to submit its own to Companies House.
How do you go about asking questions? Can I email them and get an email response back, i.e. with invoices attached?
I’m keen to see all the invoices sent between Captive Minds and LBTH and what maintenance they do and charge for consistently?
All the invoices from the bengali TV and newspapers for adverts.
How much money was transferred from one department to the communications team to run projects like the one in brick lane that had the celebrity and entertainers turn up.
I’m keen to know the costs of the legal and PR firm they hired to project the mayor.
And how much money do they have to be hiring two more press officers when everyone else is making cuts. I would like to see more services that help me rather than staff who sugar coat more stories in east end life!
You can walk into mulberry place and just ask within the given time frame.
You’re going to have to be a lot more precise than that. Fishing expeditions almost always tend to be rejected with a request to be much more precise.
You also:
1) don’t get answers to questions – you only get to review documents and ask questions
2) have to go and inspect the prime documents i.e. invoices, orders, etc at the Town Hall – once you have identified precisely what you want to see. They don’t do an email service.
If I had a question to be asked, it would be on the lines of –
How much officer time (and so money) has been spent in response to dealing spurious scare stories promoted by Jeory, Gilligan et al that were then exaggerated to extremis by idiots e.g. ‘Council, I want an enquiry into why I was intimidated when I went to vote!!!’ (i.e. some bloke suggested to them that they should vote for Lutfur as they passed him on the street by the polling station. And that bloke was Asian. And he was wearing a Muslim prayer cap!!!!!!) Or, as I exclusively raised, based on the completely false claim (carried by Gilligan and others) ‘that a Polling station was on traffic island in the middle 4-lane (to discourage voters)’ https://twitter.com/Southpawpunch/status/473019041230385152
I think it is good that TH council is scrutinised and some of their actions are deplorable (e.g. kicking Jeory out of a meeting) but it is also deplorable that the political actions of Pickles in demanding enquiries are reported by those who wish to scrutinise them as though these are the decisions of a neutral person.
Pickles will get several bites of the cherry – he can demand an enquiry and he can then criticise TH’s spending (in part on stuff he is behind) such as these enquiries!
And then there is the loss of revenue to LBTH that misreporting causes e.g. from some supposedly intelligent women at my work who tell me that they will never go to TH (e.g. Brick Lane) because they ‘just know’ it ‘is full of hordes of young Asian men who would cart off blondes like them’ (I’d really love that to happen and them to be dumped in Limehouse Cut).
All of this derived from their reading of Gilligan in the Telegraph and their own bigotry – no less than a modern repeat of the Limehouse/Chinatown/Opium Den hysteria of 100 year ago and which was the setting for ‘Fu Manchu’.
So when you pore over the money TH may have spent on PR, maybe spend a moment considering why they need to do so such (e.g. to reach those stupid surbanites), your part in increasing that workload as well as perhaps your complete unoriginality in painting this part of London as a den of foreign intrigue. The original here wasn’t Sax Rohmer in 1913 but dates back to at least 61AD when Boudicca marched her army into London (from Essex, naturally) to burn the alien hordes.
Did you exclusively visit that polling station on the day?
I went there. It was in a ridiculous location. It doesn’t even have a recognisable address.
Why wasn’t there a polling station in Canary Wharf itself, eg by the Tube station or in the Idea Store?
Well, wherever it was, that had nothing to do with the mayor.
The polling stations were allocated by the Returning Officer after inviting submissions from all groups and members on the Council.
Would be very interesting to see what the different parties suggested for that.
as oldford1
and also the discussion (“Would be very interesting to see what the different parties suggested for that.”)
Representations received about polling places in Canary Wharf (General Purposes Committee – 18/12/13):
LBTH Conservative Group made the following comments (paraphrased):-
‘want East Wintergarden instead. If not, want Skillsmatch Centre at Heron Quay’. Returning Officer reply: “East Wintergarden not proposed as polling place on cost grounds.”
Tower Hamlets Labour Party and LBTH Labour Group made the following comments:- “We agree with the proposed polling places for this ward.”
Councillor Maium Miah (THF) made the following comments: includes: “…Please place on record my strong support for the retention of these three proposals.”
and then Andrew Gilligan in Daily Telegraph, 24/5/14:
“One (polling station), in the not very pro-Rahman territory of Canary Wharf, was placed on a traffic island, at the bottom of a ramp, in the middle of a busy four-lane road!”
I haven’t even been to that polling station but I can read maps and use Google Streetview..
1. It is not “in the middle of a busy four-lane road!”, 2. any ‘ramp’ will be of no relevance to those walking to a polling station. 3. It is not, in any sense on a “traffic island”.
LB Newham or LB Sutton (residence of the blondes) don’t have to deal with this sort of misreporting. Think of that when you consider what they spend on PR.
Why don’t you go and visit it on a Thursday and see for yourself? You’ll see it is very busy and not exactly close to voters, or accessible. The candidates I spoke to there on the day also thought it ridiculous.
To be fair I suspect the reason it was there was that it’s right next door to where the previous polling station was in the car park of the City Pride pub (it’s my polling station) which is now to be a huge new development which was initially rejected by the planning committee then mysteriously waived through despite huge local objection, loss of light concerns etc.
Now that’s worth looking in to.
Don’t blame your female colleagues. LBTH is a place to be avoided as a woman.
Just last week friend was verbally abused on a bus to Bow by teenage LBTH male residents for being a bad Muslim and not covering her hair. They said she was Egyptian, Fact is she’s half Carribean/British and not a Muslim.
My niece, 14, was ogled and looked upon lasciviously as we walked along Whitechapel High St. Her crime having strawberry blonde hair and a good (well covered neck to foot and wrist) figure!
Rohmer returns. From ‘Dope’ by Sax Rohmer, 1919.
“(on her way to Limehouse) Rita hitherto had never seen the East End on a Saturday night, and the spectacle afforded by these busy marts, lighted by naphtha flames, in whose smoky glare Jews and Jewesses, Poles, Swedes, Easterns, dagoes, and halfcastes moved feverishly, was a fascinating one. She thought how utterly alien they were, the men and women of a world unknown to that society upon whose borders she dwelled; she wondered how they lived, where they lived, why they lived.”
@Southpawpunch
That was nearly 100 years ago and look how we, as a society, have progressed for the better.
1872 – Secret Ballot Act
1900 – Labour Party formed
1911 – National Insurance
1918 – Fisher Education Act: English secondary education up to 14 yo.
1928 – Universal male suffrage and some women aged 30 and over.
1928 – Universal suffrage women over 21 years old.
1944 – Education act: split primary & secondary education
1948 – National Health Service founded; National Insurance amended
1962 – 1965 Vatican II
1965 – Race Relations Act
1965 – Comprehensive schools
1967 – Universal suffrage everyone aged 18 and over.
1967 – Sexual Offences Act ; gay rights for consenting adults aged 21 yo and over
1970 – Equal Pay Act
1974 – Health & Safety etc…
1975 – Sex Discrimination Act
1976 – Race Relations Act
1988 – National curriculum
2003 – Sexual Offences Act: equal rights 16 yo and over
2010 – Equality Act
So those “Jews and Jewesses, Poles, Swedes, Easterns, dagoes, and halfcastes” of 1919 and their offspring would’ve and did benefit from the progressive changes to our society. From 1918 all men over 21 could vote and from 1928 so could all women. With the benefit of free education, better healthcare, housing etc.., the majority benefited greatly and moved out and upwards.
What we are seeing, in the East End, is a return to pre-1950s where some boys/men think they can dictate to women what to wear, what to do and how to vote; note voting has always been secret since 1872.
Working women gave up their head scarves as a uniform in the 1960s as women’s lib took hold and Vatican II heralded the end of compulsory headgear (for women) in church; British men never wore/wear headgear indoors be it a church, a library, a public meeting, a pub or someone’s home.
Also, many women, of all ages, classes and colour, fought for equality in law, in pay and to be treated as equal human beings. The age of the “cat calling builder” vanished many decades ago; a good knee to the groin or a timely slap put paid to that in many cases.
Sadly, some people in LBTH society hanker for and are trying to enforce a past era.
The woman I say while voting did not seem to be getting a good deal!
I wonder how many women oppressed by muslim men in the East End would secretly welcome a law forbidding full-face veil, something that other countries (France and Belgium) and towns across Europe (in Spain and Italy for example) have done.
Not for the value of the law in itself but for the sign that it would send that this country and this society is not closing an eye on their oppression, while British society has evolved (at least in some areas) and women have reached better levels of freedom and parity (although British society is far from being perfect in that regard).
Banning full face veil or any other law against muslim beliefs and habits would be no doubt consider racist, but even in acts which might seem racist, there can be something good. Like a an encouragement to muslim women wanting to emancipate from male domination.
marco rossi
Since it is now accepted by Europe that France’s niqab ban is legal, other countries such as Belgium, Barcelona (not all of Spain), The Netherlands, parts of Italy, Denmark, Russia, parts of Switzerland are aiming or have implemented their own bans. Britain must surely follow suit or end up with a humongous fine for non-compliance with Europe. After all, we slavishly impose all other European directives.
I see Southpawpunch is very keen on the elimination of public accountability.
Along with elections, we also have a very strong tradition in the UK of being able to ask questions of public officials and of being able to hold them to account for their actions. It’s not an aspect which is as widely publicised as elections but it’s an equally important part of the democratic process.
The process may be far from perfect – but the process still exists.
The particular aspect which is the topic of this post is one which is grossly under-used – mainly because quite a few politicians would rather you didn’t know about it.
Those Councils which are open, transparent and accountable – and promote the notion that the community is entitled to ask them questions – give the “opening of the Accounts” process much more publicity.
This “rapid response team” seems rather interesting – perhaps we could ask for information in relation to its spending to say third sector organisations as well as spending to private companies??
Good to see the anti-Lutfur brigade gamefully employed and kept busy in looking at what the Mayor had for dinner, what kind of loo roll he uses and the colour of his stool etc etc.
While you do that, the Mayor will carry on with his job in serving and delivering for the residents of Tower Hamlets.
Keep it up guys !!
All the residents of tower hamlets?
hey, since the mayor seems to be too busy in all his work to notice it, have you notice the level of rubbish the borough is drawing in especially in certain areas like Whitechapel, Stepney Green, Bethnal Green etc?
Any chance that the mayor might get distracted for a second or two to do something about it? And by something I don’t mean just cleaning behind the disgusting pigs who litter (individuals and companies alike), but maybe starting a campaign of fines for those who litter? Any chance he might be distracted from showering muslim charities with monies and cleaning up the streets?
But I am wondering if you might perhaps have no perception of “rubbish” when you walk around. Maybe you yourself are one of those people eating fried chicken and chips and discarding those disgusting red carton boxes on the streets? Are you one of those beer drinking fiends who will discard cans on the pavement when 5 mt away there is a rubbish bin? are you one of those junkies discarding their needles in the park?
see, it’s all relative, you think the mayor is at work, I think he is robbing me with the most expensive council tax and the worst service in the UK
Interesting that the pro-Lutfur poodles are the ones who never examine the detail.
“i didn’t vote for the current mayor”
How much money is being spent on street cleaning?
Which areas of the borough and how frequently are they cleaned?
Who lives there and what is their connection to LBTH Council?
Who has the contract?
Any conflicts of interest?
Is it value for money?
How much money has been collected from bulk rubbish collection (which used to be free 3 times a year, I think)?
How much is spent on business rubbish uplift?
How frequent?
Who has the contract?
Any conflicts of interest?
Is it value for money?
How much is spent on THEOs (who should be issuing fines for littering)? Which areas do they cover?
How much have they raised in fines?
Your question is unlikely to be answered as it is too high level and too imprecise.
The best approach is to always focus on one specific area of expenditure or income and then ask a very precise question.
It’s maybe worth pointing out that questions need to focus on facts – that can be evidenced through an audit trail of documentary evidence – rather than opinions which require a judgement to be made.
However having raised matters of fact, this might well prompt auditors to ponder subsequently on value for money.
The issue for auditors is essentially:
* is expenditure legal?
* is expenditure appropriately authorised?
* does expenditure and income fail the test of “reasonable and rational”?
An auditor is only going to question decisions about expenditure – and related actions – if they are either:
* unlawful
* not properly authorised according to the Council’s Standing Orders, Financial Regulations and delegated powers of responsibility
An unlawful item of account is where records demonstrate that the Council’s spending or income is such that it
* had no right to spend or receive;
* spent Council money or received money without powers to do so;
* took from, or added to, the wrong fund or account; or
* spent on something that they had the power to spend on, but the decision to spend the money was unreasonable or irrational.
For example “I want to know how much money was spent on providing different types of transport for the Mayor (e.g. public transport; taxis, leased vehicles)? Please provide all documentary evidence relating to such expenditure.” is an OK question.
“Is it OK for the Mayor’s use of a Mercedes to get about the borough and do his laundry?” is marginal.
The question needs to be more precise. For example it might address:
* whether the use of a Mercedes was both unreasonable and irrational
* whether it was always used for appropriate council business
* if used for non-Council business, what percentage of time / journeys were declared as non-Council related and
* whether the Mayor had made a tax declaration with respect to usage of the Mercedes
* whether the Mayor had reimbursed the Council and/or paid tax on any usage relating to non-Council business and/or domestic purposes
If minded to do so, I’d also ask for the annual declaration by the Councillors that all their expenses were incurred on Council business (This is a form that all officers and all Councillors have to sign each year for tax purposes).
I’d also ask for the documented records of each Councillor’s work base used for determining eligibility to claim travel expenses in the system for recording and validating a Councillor’s eligibility to claim travel expenses.
I’d then ask for all the expense claims for specific Councillors with high levels of expense claims
Those familiar with the system relating to taxation of expenses claimed for travel will know where I’d going with this one………
These sorts of queries are very important so that we could all learn, for example, that Takki Sulaiman might be a concierge.
I heard he was playing the Artful Dodger in Oliver!
I will be occupying and taking all D(DUEL MOD) Nan does loyalties, as well as swearing as efficiently as possible. Strength and Honor.
George