22 Feb 2017

ShippingBulletin - February 2017


In this issue:

Cargo claims - burden of proof

A cargo of bagged coffee beans was shipped from Columbia to Germany. The bills of lading were issued by the defendant carrier, CSAV and incorporated the Hague Rules. The carriage was on LCL/FCL terms. Before stuffing, the containers were lined with Kraft paper by the stevedores.

On discharge, the cargo was found to have suffered damage from condensation. The loss amounted to $62,500, some 2.6% of the total value of the consignments. Volcafe, the consignees, brought a cargo claim against the carriers.

At first instance, the judge (David Donaldson QC) allowed the claim. He held that the defendant had failed to displace the prima facie assumption of breach of Hague Rules article III, rule 2 ("carrier shall properly and carefully carry") and had failed to prove that it had a "sound system". Carriers appealed.

Held (Gloster and King LJJ and Mr Justice Flaux):

  1. The appeal was allowed; the carriers were not liable.

  2. At common law, and under the Hague Rules: the initial burden is on the claimant to demonstrate non-delivery or damage. It is then for the carrier to establish a prima facie defence based on an excepted peril (here, inherent vice, Article IV rule 2(m)). The burden then shifts back to the claimant to establish that the exception did not apply because of the carrier’s negligence.

  3. It was an error to proceed on the basis that the carrier could not rely on the inherent vice exception in the case of a “normal” cargo of coffee beans unless it could show that damage was inevitable. Inherent vice and inevitability of damage were not the same. The judge should have concluded that the defendant had made out a sustainable defence within article IV rule 2(m).

  4. He should then have considered whether the inherent vice exception was negatived where the defendant had not employed a sound system in the carriage of the goods (the claimants had the burden of proof).

  5. A sound system did not mean that the carrier was required to employ a system which would prevent damage. The judge imposed a standard beyond what the law required and discounted general industry practice. One of the signs of a sound system was that it was in accordance with general industry practice.

  6. Had the judge applied the law correctly, he would have concluded that the claimants had not established that the defendant’s system of lining the containers was not a sound system, and the inherent vice defence would have succeeded.

(Volcafe Ltd and others v Compania Sud Americana de Vapores SA (trading as 'CSAV') [2016] EWCA Civ 1103, [2017] 1 Lloyd's Rep 32)



No package limitation for bulk cargo under Hague Rules

A cargo of fishoil was carried on board the tanker AQASIA under a voyage charterparty on the London form. The charterparty incorporated Article IV of the Hague Rules (ie the defences).

It was common ground that the voyage charterparty evidenced the contract between the claimant and the defendant. The defendant was the disponent owner of the vessel, and the carrier under the charterparty.

The charterparty provided for the carriage of "2,000 tons of fishoil in bulk, 5% more or less". The freight was a lump sum of Nok 817,500. The bill of lading recorded the cargo as "Icelandic Fishoil in bulk – 2.056.926 kgs".

On arrival at the discharge port, 547,309 kg (547.309 mt) of the cargo was found to have been commingled with another cargo, and suffered damage. The defendant accepted in principle that it was liable for the damage but argued that it was entitled to limit its liability under Art IV, r 5 of the Hague Rules to £100 per mt of the cargo damaged (in total, £54,730.90). The quantum of the claim was USD367,836 (£299,160).

Art IV, r 5 of the Hague Rules states:

"… Neither the carrier nor the ship shall in any event be or become liable for any loss or damage to or in connection with goods in an amount exceeding 100£ per package or unit"

The Commercial Court was asked to consider the preliminary issue of whether the defendant was entitled to limit its liability to £54,730.90, in particular, whether Art IV, r 5 of the Hague Rules was capable in principle of applying to bulk cargo.

Held: (Sir Jeremy Cooke) 

  1. The defendant was not entitled to limit its liability.

  2. Looked at in context ("per package or unit"), the word "unit" was intended to refer to a physical item, not a unit of measurement. In Art III, r 3(b) "packages" were paired with "pieces" (meaning individual physical items of cargo) and quantity and weight were seen as different. If the word "unit" was apt to cover both "unpackaged physical items as units of shipment" and also "units of measurement in the case of bulk cargoes", this would create an obvious issue where the word had different meanings for different types of cargo.

  3. There was no English authority directly on the point, although there were judgments which proceeded on the assumption that "unit" referred to a physical item. The travaux préparatoires of the Hague Rules clearly supported the construction of unit being something akin to a package. Bulk cargo was not in mind in 1924, because the limitation figure was not relevant, given the low value of such cargoes.

  4. The drafting of the Visby amendments in 1968 strongly suggested that the draftsmen considered that a "unit" constituted a physical item rather than a freight unit.

  5. Considering all the above, the word "unit" in the Hague Rules can only mean a physical unit for shipment. It cannot mean a unit of measurement. (Nor can it mean a customary freight unit, as is the case in the United States.)

  6. In summary: where the Hague Rules apply to the carriage of a bulk cargo it is not possible for carriers to limit their liability under Art IV, r 5. Where the Hague-Visby Rules apply to the carriage of a bulk cargo, such limitation is possible.

(Vinnlustodin HF and another v Sea Tank Shipping AS (formerly known as TANK INVEST AS) [2016 EWHC 2514 (Comm), [2016] 2 Lloyd's Rep 510)




Ship finance loan - effect of assymmetric jurisdiction clause

Commerzbank made a number of loans to finance the building of ships. One loan was to Androniki Navigation Limited and another to Pauline Shipping. Both loans were guaranteed by Liquimar. The loan and guarantee documentation contained asymmetric jurisdiction agreements. These provided that either party could bring proceedings in the English courts, but that the bank also had the right to sue in any other court of competent jurisdiction.

Following events of default by the borrowers, the bank warned Liquimar and Pauline of its intention to commence proceedings in England. However, before the bank brought its claim in England, Liquimar and Pauline commenced proceedings against the bank in Greece.

In the Greek proceedings, Liquimar and Pauline sought orders that there was no liability to the bank under the guarantee and claimed damages from the Bank under Greek law for (amongst other things) reputational loss.

The bank subsequently commenced proceedings in England against Liquimar and Pauline. The claims included:

  • the amount outstanding under the loan;
  • a declaration of non-liability in respect of the claims made by Pauline and Liquimar; and
  • damages and/or an indemnity for breach of the jurisdiction clauses in the loan agreements and guarantees.

It was common ground that (apart from the claims for breach of the jurisdiction clauses) the claims in the London actions involved the same causes of action as the claims in the Greek actions. Liquimar and Pauline applied for a stay of the actions in England and to set aside the permission given to the bank to serve the proceedings out of the jurisdiction.

The issue was therefore whether the bank could proceed with its claim in England, in spite of the parallel proceedings in Greece. The answer turned on whether the asymmetric jurisdiction clause conferred exclusive jurisdiction on the English courts for the purposes of the Recast Regulation.

Liquimar and Pauline argued that the bank should not be allowed to proceed in England, and that the English Court should stay its proceedings pending the ruling of the Greek court. Their core argument was that the asymmetric jurisdiction clause was not an exclusive jurisdiction clause, and therefore the bank could not rely on the rule that the court named in an exclusive jurisdiction clause prevailed.

Held (Cranston J.):

  1. The judge refused the defendants' applications for a stay and declined to set aside service out of the jurisdiction. Accordingly, the bank could continue with its claim in England.

  2. The reference in the Recast Regulation to "an agreement [which] confers exclusive jurisdiction" included asymmetric jurisdiction clauses such as those in the present case:

    "where a clause confers exclusive jurisdiction on the court or courts of a Member State when one party sues, the clause will still be an exclusive jurisdiction clause for the purposes of [the Recast Regulation] even where, if the other party to the clause sues, the clause shows the parties to have agreed that jurisdiction is to be conferred differently, or allowed to engage differently."

  3. The conclusion that an asymmetric jurisdiction clause was exclusive was consistent with the aims of the Recast Regulation, which were to enhance the effectiveness of exclusive jurisdiction clauses and to avoid abusive tactics. The defendants had agreed to sue only in England, but instead had initiated proceedings in Greece. It would undermine the agreements of the parties and foster abusive tactics if the jurisdiction clauses in the present case were not to be treated as exclusive.

(Commerzbank AG v (1) Pauline Shipping (2) Liquimar Tankers Management Inc [2017] EWHC 161 (Comm))




Towcon - "light ballast condition" - repudiation

Regulus owned the tug "AHTS HARMONY 1" and entered into an agreement on TOWCON terms to tow the FPSO "IKDAM" (owned by Lundin) from Tunisia to Malaysia. It was an express term of the contract that the "IKDAM" would be provided in "light ballast condition". Regulus claimed that the FPSO was not provided in this condition and as a result, the voyage took longer than it would have done. They claimed delay payments at the contract rate and damages for the cost of additional fuel.

Lundin denied that the vessel was not in light ballast condition and claimed breach of an implied obligation to maintain an average speed of 4.5 knots. The towage contract came to an early end and Lundin engaged another tug to complete the journey.

Held (Phillips J.):

  1. Light ballast condition is where the vessel is carrying no more ballast than is necessary to ensure the stability for the voyage. Lundin was in breach of the contract, in that it failed to provide the "IKDAM" in light ballast condition. However, Regulus was unable to prove that the breach caused any delay in the towage, nor that it suffered any loss (some ballast was removed during the voyage and there was no increase in speed). Regulus was therefore not entitled to any delay payments under the contract.

  2. There was no collateral warranty or implied term that a particular speed was to be maintained during the tow. Lundin's claim therefore failed.

  3. Regulus gave an ineffective notice purporting to cancel the contract, which was a repudiation of the towage contract, which Lundin accepted. Lundin was entitled to damages for the cost of the replacement tow.

(Regulus Ship Services PTE Ltd v (1) Lundin Services BV (2) Ikdam Production SA [2016] EWHC 2674 (Comm))




Shipbuilding - engine failure - consequential loss

Star Polaris bought a vessel built by the yard, HHIC. The vessel was delivered in November 2011, but suffered a severe engine failure in June 2012. Star Polaris commenced arbitration, claiming that the engine failure was caused by HHIC's breaches of contract. They claimed compensation including:

  • cost of repairs to the vessel
  • towage, agency and survey fees, off-hire and off-hire bunkers caused by the engine failure
  • diminution in value of the vessel

The Tribunal held that there was a causative breach of the yard's warranty of quality but the chief engineer had also been negligent and that broke the chain of causation between the yard's negligence and the damage which would not have been suffered had the chief engineer not been negligent. The cost of repairing some of the damage was therefore recoverable from the yard (quantum to be determined). The other losses fell within a contractual exclusion clause for "consequential or special losses, damages or expenses" and so were not recoverable.

Star Polaris appealed. The issues were:

(i) Did the phrase "consequential or special losses, damages or expenses" in the contract mean losses, damages or expenses falling within the second limb of Hadley v Baxendale (ie, losses resulting from special circumstances known to the parties when they entered into the contract)? Or did it have a "cause and effect" meaning as held by the Tribunal?

(ii) does diminution of value constitute a consequential or special loss?

Held (Sir Jeremy Cooke):

  1. The appeal was dismissed.

  2. 'Consequential or special losses, damages or expenses' had a wider meaning than the second limb of Hadley v Baxendale. Looking at the positive obligations to repair, and the exclusion of all losses whatsoever arising after delivery, "consequential" had to mean that which follows as a consequence of the physical damage, namely financial loss other than that of the cost of repair.

  3. Reading the clause as a whole, the parties did not intend the yard's liability to extend beyond the obligation to remedy any defect by making repairs/replacements. The objective agreement was that financial loss consequent upon physical damage was excluded. Diminution in value did constitute a consequential or special loss and so was excluded.

(Star Polaris LLC v HHIC-PHIL INC [2016] EWHC 2941 (Comm))




Inter Club Agreement - clause 8(d) - meaning of 'act'

Claimant shipowners carried a cargo of soya bean meal from South America to Iran. The charterparty incorporated the terms of the Inter Club Agreement ("ICA"). When the vessel arrived at the discharge port, the defendant charterers ordered it to wait off the port for over 4 months because they had not been paid for the cargo. When the cargo was eventually discharged, it was discovered that some of it had overheated and was found to be lumpy and discoloured. The claim made against owners was settled for approx. €2.6 million and owners claimed that sum, plus hire of approx. US$1 million, from charterers.

The Tribunal found that owners had not failed to monitor the cargo and the damage had occurred because of the inherent nature of the cargo, together with the prolonged period at anchor. Charterers' decision to load that cargo and then have it wait for 4 months in the holds of the vessel was held to be an "act" falling within the final part of 8(d) of the Inter Club Agreement, and therefore charterers were liable for 100% of the damage.

Clause 8(d) provides that:

"(8) Cargo claims shall be apportioned as follows:
…(d) All other cargo claims whatsoever (including claims for delay to cargo):

50% Charterers
50% Owners
unless there is clear and irrefutable evidence that the claim arose out of the act or neglect of the one or the other (including their servants and sub-contractors) in which case that party shall then bear 100% of the claims

Charterers appealed.

Held (Teare J): 

  1. The appeal was dismissed.

  2. The meaning of 'act or neglect' must depend on its context and must be construed having regard to the language of the ICA as a whole. The relevant context is the ICA 1996 which seeks to apportion claims between owners and charterers in a broadly mechanical manner, with regard to the cause of the claim but not the terms which would usually govern the owner/charterer relationship. It is a factual question of what falls within a party's 'sphere of risk' as allocated by the ICA.

  3. 'Neglect' would require proof of fault because the ordinary meaning of neglect is a failure to do that which one ought to do.

  4. 'Act' should also bear its ordinary meaning which is that of any act, culpable or otherwise. This is consistent with the overall scheme of mechanical apportionment, irrespective of fault. 'Neglect' is an exception to the overall scheme. The juxtaposition of 'act' and 'neglect' was not sufficiently cogent to require 'act' to mean a fault of commission.

(Transgrain Shipping (Singapore) PTE Ltd v Yangtze Navigation (Hong Kong) Co Ltd, The MV "YANGTZE XING HUE" [2016] EWHC 3132 (Comm))




Refund guarantees - valid demand?

MUR entered into a joint operations agreement with Monaco Seatrade SAM in relation to the chartering and operation of a Handysize/Handymax bulk carrier. Pursuant to that agreement a demand guarantee was issued by the defendant bank, Compagnie Monegasque de Banque. MUR alleged that sums were unpaid under the joint operations agreement and made two demands under the guarantee.

The Bank denied liability and asserted that neither demand complied with the requirements of the guarantee. The first demand was not sent by registered post as required. The second demand allegedly did not have the requisite authorisation or authentication of the power of the person who signed the demand.

The guarantee provided that:

"upon written demand sent to the bank by way of registered mail to the above mentioned bank's address. Such demand must be signed by duly authorised legal representatives of MUR certifying in writing that the Charterer has defaulted in its obligation to make the Guaranteed payment concerned; that the amount claimed under this guarantee is due.

For the purpose of identifying the Legal authorised representatives, the Beneficiary shall provide to the Bank, together with the request for payment, certified copies of MUR's Extract of Registry and the passport of the signatory signing the request for payment; the request of payment should be authenticated as well as representative's powers of MUR by a notary and duly apostilled…"

Held (Cranston J.):

  1. The principle of strict compliance with the requirements for a demand (which applies to letters of credit), does not apply to demand guarantees.

  2. As a general rule, the terms for demanding payment under a demand guarantee should be clear and precise. If an instructing party requires the beneficiary to present certain documents, they should make that clear in the guarantee.

  3. The demand was signed by a duly authorised person and there was no requirement for an opinion under Dutch law as to the authority of the signatory. There was no doubt that the demand documents would be understood to be making a demand under the guarantee.

  4. There was inconsistency as to whether the demand should be signed by one or two representatives ("representatives…signatory"), but the number of signatories was not important; the signatory was authorised.

  5. The requirement for registered mail was not a condition precedent, it was directory. The first demand was sent by a number of different means including courier. There is no doubt that the demand was received and so was effective.

(MUR Joint Ventures BV v Compagnie Monegasque de Banque [2016] EWHC 3107 (Comm))




Delivery of cargo without bill of lading - LOI - agency

A cargo of iron ore was carried from Western Australia to China on the "ZAGORA". The cargo was sold by SCIT Trading to Xiamen. Xiamen then agreed to sell the cargo to Cheongfuli. Cheongfuli then agreed to sell the cargo to Shanxi Haixin. Under that contract Shanxi Haixin was to appoint the discharge agent.

SCIT Trading arranged the vessel for carriage of the cargo pursuant to a COA that it had in place with SCIT Services. SCIT Services concluded a voyage charterparty with Oldendorff Carriers. Oldendorff Carriers had a long term agreement with Oldendorff for the latter to supply tonnage to the former. Oldendorff entered into a time charter trip with head owners on back to back terms with the voyage charter. Shanxi Haixin nominated the discharge port agent as Sea Road.

The original bills of lading were not available at the discharge port, so LOIs were required. The cargo was to be discharged to the discharge port agent who would then deliver it to the receivers on presentation of the bills of lading. The LOI identified Xiamen as the party to whom delivery was to be made. The cargo was delivered in accordance with the instructions of someone identifying themselves as from Sea Road. Bank of China paid the purchase price but was not reimbursed so arrested the vessel. Oldendorff put up security to release the vessel from arrest.

The issue was whether the LOI was engaged where delivery was to the custody of Sea Road, not Xiamen. It was submitted that the discharge to Sea Road was as agent for owners or Oldendorff.

Held (Teare J.):

  1. The nomination of Sea Road as discharge port agent had been passed up the line of charterparties, therefore it is probable that Sea Road performed functions for all of the named entities in this case.

  2. The crucial question was whether Sea Road, in taking delivery of the cargo, was acting on behalf of owners/Oldendorff or Xiamen. The Master gave evidence that the Sea Road representative had stated that he was there to handle discharge on behalf of Xiamen. Xiamen had inserted its name in the LOI to ensure it retained possession of the cargo and so would not suffer loss. The evidence indicated that it was more likely than not that Xiamen intended Sea Road to take delivery of the cargo on Xiamen's behalf and Sea Road accepted this.

  3. It is unlikely that Sea Road would have been acting as owners' agent. Owners would not be interested in discharging the cargo into the possession of their own agent as this would not engage the LOI and protect them.

  4. The cargo was delivered to Xiamen through the agency of Sea Road and so the LOI was engaged. Oldendorff was therefore liable to indemnify owners in respect of the arrest of the vessel and any liability to the Bank of China. This took effect similarly down the line.

(Oldendorff GmbH & Co KG and others v Sea Powerful II Special Maritime Enterprises and others [2016] EWHC 3212 (Comm))




Insurance - liability policy - notification

Maccaferri hired out a staple gun to a building company. There was an accident involving this gun, as a result of which a man lost an eye. A claim was brought against Maccaferri and they were found liable. Maccaferri claimed against Zurich under their combined Public and Products Liability policy. A condition precedent to Zurich's liability was:

"The Insured shall give notice in writing to the Insurer as soon as possible after the occurrence of any event likely to give rise to a claim with full particulars thereof. The Insured shall also on receiving verbal or written notice of any claim intimate or send same or a copy thereof immediately to the Insurer and shall give all necessary information and assistance to enable the Insurer to deal with, settle or resist any claim as the Insurer may think fit…"

Maccafferi had notified Zurich when they were joined as Part 20 Defendants to the proceedings against the building company, nearly 2 years after the incident occurred. Maccaferri were aware at the time of the accident that an incident had occurred and that the gun was retained for testing, but there had been no suggestion that the gun was at fault.

The first instance judge found that Zurich was not able to rely on the notification clause to refuse liability.

Held (Black and Clarke LJJ):

  1. Appeal dismissed.

  2. The wording of the clause meant that there firstly had to be an event: something happening at a particular time in a particular place. That event needed to be "likely to give rise to a claim"; at least a 50% chance of giving rise to a claim.

  3. The clause in the policy had the potential effect of completely excluding liability in respect of an otherwise valid claim. Zurich therefore needed to ensure that clear wording was used. It had not done so and any ambiguity in the clause would therefore be construed in favour of Maccaferri.

  4. On the facts, although the gun was involved in the accident, there was only a possibility that the gun was at fault. There were a number of other possible faults too. Therefore the circumstances at the time of the incident were not such as would require Maccaferri to notify Zurich.

  5. There was no obligation on Maccaferri to carry out a rolling assessment as to whether a past event was likely to give rise to a claim (although clauses do exist which provide for this).

(Zurich Insurance PLC v Maccaferri Limited [2016] EWCA Civ 1302)




Sale contract - bank co-signing letters of indemnity

Euro-Asian Oil SA entered into contracts with Abilo (UK) Limited for the supply of 20,000 metric tonnes of ultra-sulphur diesel, with a purchase price of nearly US$ 16,000,000. The contracts provided for a letter of credit and for payments against presentation of either the original shipping documents or a letter of indemnity. Credit Suisse co-signed the letters of indemnity which were presented to Euro-Asian's bank under the letters of credit, in lieu of bills of lading.

When the cargo was not delivered, Euro-Asian claimed in contract, tort and unjust enrichment against Abilo under the sale contract and the letter of indemnity. It also claimed against Credit Suisse for breach of warranties under the letter of indemnity.

Held (Cranston J.):

  1. Abilo was found liable for the non-delivery of cargo under the sales contract and the breach of the warranties and undertaking in the letters of indemnity.

  2. Credit Suisse were also found liable for breach of the warranties and undertaking in the letters of indemnity.

  3. Credit Suisse had gone beyond the role of a letter of credit bank: in co-signing the letters of indemnity, it had assumed the same contractual responsibilities as Abilo in relation to the underlying contract of sale and exposed itself to liability in the event that Abilo did not make the delivery.

(Euro-Asian Oil SA (formerly Euro-Asian Oil AG) v Abilo (UK) Ltd and another [2016] EWHC 3340)




NOR - meaning of "within port limits"

The MV "ARUNDEL CASTLE" was chartered out on the basis of a fixture recap, clause 15 of which provided that:

"[Notice of readiness] to be tendered at both ends even by cable/telex/telefax on vessels arrival at load/disch ports within port limits. The [notice of readiness] not to be tendered before commencement of laydays."

It also incorporated Gencon 94, clause 6(c) of which provided that:

"If the loading/discharging berth is not available on the Vessel's arrival at or off the port of loading/discharging, the Vessel shall be entitled to give notice of readiness within ordinary office hours on arrival there … Laytime or time on demurrage shall then count as if she were in berth and in all respects ready for loading/discharging provided that the Master warrants that she is in fact ready in all respects.…"

When the vessel arrived at the load port, it was congested. The vessel could not proceed to berth and was directed to an anchorage by the port authority. Owners gave notice of readiness ("NOR"). A demurrage claim followed.

There was a dispute as to whether the NOR was valid. The Tribunal held that it was invalid because it was given when the vessel was outside port limits (as identified by reference to the relevant Admiralty chart). Owners appealed and argued that "port limits" included any area within which vessels are customarily asked to wait by the port authorities.

Held (Knowles J.):

  1. Owners' appeal was dismissed.

  2. Although the definition of "port" in the Laytime Definitions for Charterparties 2013 includes places outside the legal, fiscal or administrative area where vessels are ordered to wait for their turn, that definition cannot be used unless the parties have deliberately chosen it as their definition.

  3. The test for an arrived ship is that set out in The "JOANNA OLDENDORFF" [1973] 2 Lloyd's Rep 285: "before a ship can be treated as an arrived ship she must be within the port and at the immediate and effective disposition of the charterer and … her geographical position is of secondary importance. But for practical purposes it is so much easier to establish that, if the ship is at a usual waiting place within the port, it can generally be presumed that she is there fully at the charterers' disposal."

  4. The parties had provided little material to the arbitrators. Based on that material, the arbitrators were entitled to reach a conclusion of fact that the vessel was not within port limits, or at least that owners had not proved that she was.

  5. Having regard to the authorities, there was no basis for holding that "port limits" means geographical port limits as shown by an Admiralty Chart (although parties would be free to provide for that meaning in their agreements). However, it did not follow that the arbitrators were wrong to use the Admiralty chart as they did on the limited material put before them in this particular case.

(Navalmar UK Limited v Kale Maden Hammaddeler Sanayi VE Ticart AS, The MV "ARUNDEL CASTLE" [2017] EWHC 116 (Comm))




Tonnage limitation - new limits in force in UK

The UK has brought into force increased figures for the limit of shipowners' liability. The limits affected are the "general limits" in Art 6 of the LLMC 1996 (as previously amended by the 1996 Protocol). The figures were introduced by the IMO in June 2015 but required legislation to enter into force in the UK. This legislation has been passed and the new limits came into force on 30 November 2016. The new limits apply only to occurrences taking place on or after 30 November 2016.

The legislation also introduced an "ambulatory reference". This provision will allow for future increases to the limitation figures which are agreed at international level to be adopted in UK law without requiring amending legislation.





Joanne Champkins

Joanne Champkins
Senior knowledge development lawyer

T:  +44 20 7809 2623 M:  +44 7825 625 900 Email Joanne | Vcard Office:  London

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