Overriding
Interest
From Shariah To The Shard
As the Shard London Bridge climbs ever higher into the skyline, it is a reminder of the growing
importance of Islamic financing for global real estate investment and development. In the UK
and across the world, banks, funds and investors are using Shariah compliant techniques to
attract investment from those who require their business affairs to be conducted in accordance
with their religious principles.
In May 2011, the Bank of London and the Middle East launched its Light Industrial Building
Highlighting developments and
Fund, an Islamic compliant UK real estate fund which invests only in sustainable property
issues in the real estate industry
assets. The target close for the Fund is between £50m and £100m in equity, which will be
leveraged to create a portfolio of £200m. The target buildings are typically used for light
Summer 2011
In this issue:
From Shariah To The Shard.............. 1
Restrictive Covenants Ignore At Your Peril......................... 2
manufacturing, assembly, storage, warehousing and distribution activities.
Also in May, Gatehouse Bank, an Islamic compliant bank set up in the UK in October 2008,
completed the purchase of a £53m Rolls-Royce core manufacturing and logistics facility in
Scotland for one of its customers. This follows a series of other deals in the past year, including
student accommodation and office headquarters transactions.
Outside the UK, the Islamic compliant real estate market is making further inroads. In January
Transaction Focus............................ 4
2011, Gazprombank (an affiliate of the world’s largest gas producer and exporter, Gazprom)
Tenants’ Guarantors - Practical
and Barwa Real Estate Company of Qatar jointly announced the first closing of the Islamic
Implications of Recent Court of
compliant Barwa Gazprombank Real Estate Fund. Each party will seed the Fund with US$75m
Appeal Decision ............................ 5
and the Fund will invest in the construction of housing and commercial real estate in Russia.
Cases............................................ 6
Asia has always been prominent in Islamic finance through the efforts of Malaysia and
New Real Estate Team Additions....... 8
Indonesia. Now Singapore is a growing centre following the influence of the Monetary
London Office Move...................... 10
Authority of Singapore. Incentives include reduced taxes for Islamic transactions, waived stamp
Events and Announcements
at K&L Gates................................ 11
duties for real estate financing and a five per cent concessionary tax rate for Islamic financing.
The world’s largest listed Shariah compliant REIT was established in Singapore in November
2010 – the Sabana Shari’ah Compliant Industrial REIT. The REIT holds over 3 million square
feet of high-tech industrial, warehouse and logistics property in Singapore.
In order to retain Islamic compliance, a REIT or fund must abide by a number of rules including
the avoidance of interest on any gearing it undertakes. There are also restrictions on the type
of properties and tenants that Islamic investors can become involved with. The exclusions
include investing in properties for conventional banks or insurance companies or having them
as tenants; gambling and adult entertainment businesses; and real estate involved in the
production of forbidden products, such as pork and alcohol.
Given the globalisation of Islamic real estate financing and funds, K&L Gates is well positioned
K&L Gates LLP
One New Change
London EC4M 9AF
www.klgates.com
T: +44 (0)20 7648 9000
F: +44 (0)20 7648 9001
to assist given our global platform with 37 offices around the world - in Europe, Asia, the
Middle East and the US.
For more information, please contact Jonathan Lawrence (jonathan.lawrence@klgates.com),
a real estate finance partner in our London office and co-head of the firm’s Islamic Finance
and Investment group.
Restrictive Covenants Ignore At Your Peril
George Wimpey Bristol Ltd
and Gloucestershire Housing
Association Ltd [2011] UKUT
91 (LC)
2. that the continued existence of
release or variation with the party
the restriction would impede the
benefitting from the restrictive covenant
reasonable user of the land for public
2. take out indemnity insurance to protect
or private purposes or would, unless
modified, impede such user and either:
Overview
against the risk of a person with the
Applying to the Lands Tribunal is not only an
benefit of a restrictive covenant seeking
expensive and time consuming process, but
to enforce it - this is often done where
to the benefit of it any practical
also, as this profiled case shows, developers
the restrictive covenant is historic and
benefits of substantial value or
should not assume that inconvenient
the insurers are satisfied that the risk of
advantage; or
covenants can easily be removed by
enforcement is low
making such an application - particularly if
they have adopted a deliberate strategy of
forcing through the development by ignoring
the fact that the covenants exist. Developers
should ensure that their legal advisers
investigate whether restrictive covenants
apply, and how those restrictive covenants
can be satisfactorily dealt with, before
committing to a scheme.
Background law
A restrictive covenant affecting freehold
land consists of an agreement by deed that
one party will restrict the use of its land in
some way for the benefit of another’s land.
If land is burdened by a restrictive covenant
and the owner of that land wants to
develop in a way that is restricted by a
covenant, it may seek to deal with it in a
number of ways:
2
1. it may be possible to negotiate a
Overriding Interest
3. if agreement cannot be reached
(a) does not secure to persons entitled
(b) is contrary to the public interest,
and that money will be an
with the beneficiaries of a restrictive
adequate compensation for the
covenant, or if insurance is not
loss or disadvantage, if any, which
available, make an application to the
any such person will suffer from the
Lands Tribunal for the modification or
discharge or modification; or
discharge of a restrictive covenant
pursuant to section 84(1) of the Law of
Property Act 1925
3. that the persons entitled to the
benefit of the restrictive covenant
have agreed, either expressly or by
The Lands Tribunal may discharge or modify
implication, by their acts or omissions,
a restrictive covenant only where it is
to the same being discharged or
satisfied that one of the following grounds
modified; or
has been made out:
1. that due to changes in the character of
the property or the neighbourhood or
other circumstances which the Lands
Tribunal deem material, the restriction
is obsolete; or
4. that the proposed discharge or
modification will not injure the persons
entitled to the benefit of the restriction.
The facts
The grounds of objection to Wimpey
Tribunal found that “the extensive works
The restriction was imposed by a 1936
Homes’ application to have the restriction
which Wimpey Homes had carried out on
conveyance in which the purchaser
modified included: disturbance during
the application land were not an inadvertent
covenanted “for the benefit of the
construction work; risk of flooding; loss of
action resulting from the discovery of the
adjoining land with the vendor on the
natural habitat for wildlife; light pollution;
covenant at a late stage in the development
west and south side of the land hereby
increased crime; traffic congestion and
programme. Rather they were the result of
conveyed that no building shall be erected
noise; loss of privacy, views, openness
a deliberate strategy of forcing through the
on the piece of land to the west of the
and overall amenity; that the proposed
development on the restrictive land in the
line drawn on the said plan between the
modification would set a precedent for
face of many objections from those entitled
points marked A and B….”. The line A-B
further modifications of the restriction; and
to the benefit of the restriction, to the point
formed the eastern boundary of the freehold
loss of property value.
where they had so changed the appearance
land owned by Wimpey Homes (the
“application land”).
The Decision
The issue to be decided was whether
In 2006 detailed planning permission was
Wimpey Homes’ application should
granted to Wimpey Homes for 124 dwellings
succeed on the ground referred to at 2(a)
and the local authority approved details
above. The Tribunal decided that the
including the construction of 17 dwellings, 1
proposed use of the land for residential
triple garage and 6 double garages on the
and character of the application land that
the tribunal would be persuaded to allow
them to continue with the development.”
The Tribunal made it clear that it was not
inclined to reward parties who deliberately
flout their legal obligations in this way.
development was reasonable and that the
Reform
covenant did impede that reasonable use.
The Law Commission has been considering
However, the application failed because
reforming the law relating to restrictive
In May 2007 solicitors instructed by one
the Tribunal decided that the practical
covenants. They had previously suggested
of the objectors wrote to Wimpey Homes.
benefits of the restriction to the owners of
that, due to the expense of applying to
They drew attention to the restrictive
four particular properties belonging to the
the Lands Tribunal for the discharge or
covenant and asked the developer to
objectors were of substantial value and
modification of covenants, all restrictive
cease installing services in preparation for
advantage in that the development would
covenants should lapse 80 years after their
the construction of a housing development
have resulted in a reduction in property
creation but that an application could be
on the application land. Nevertheless,
values for those objectors. It was also found
made to the Lands Tribunal by a party who
Wimpey Homes continued with the work
that the restrictive covenant, by impeding
considered that the covenant was not in
and by the time building work ceased on
the proposed development, secured two
fact obsolete. However, this proposal was
the application land Wimpey Homes had
of the objectors practical benefits by
rejected by the Lord Chancellor. The Law
started construction on all of the proposed
allaying their reasonable concerns about
Commission is intending to publish a report
houses and garages.
intensified flooding and relatively high
setting out its latest recommendations for
density development and that those practical
reform and a draft Bill in 2011 so we must
benefits were a substantial advantage.
wait to see what alternative proposals are
As Wimpey Homes had not succeeded
put forward.
application land. Wimpey Homes then began
preparing to build.
In 2008 proceedings were commenced
against Wimpey Homes by a number
of objectors claiming the benefit of the
restriction and seeking an injunction to
restrain Wimpey Homes from building on
the application land. It was agreed that all
in establishing the ground relied upon,
the Tribunal had no power to modify the
Written by Lucinda Bayliss and
restriction and the application was refused.
Marianne Clark
of the objectors were entitled to the benefit
The Tribunal added that even if the ground
of the restriction. Wimpey Homes then
had been made out, it is unlikely that they
made an application to the Lands Tribunal to
would have exercised their discretion to
have the restrictive covenant modified.
modify the covenant. This is because the
Summer 2011
3
Transaction Focus
Action For Children
K&L Gates has recently advised leading
charity Action for Children on the sale of
its former headquarters in Highbury Park,
Islington, to developer Mount Anvil. The
deal, which completed at the end of April
2011, was conditional upon Mount Anvil
securing planning permission for residential
development of the site (which was secured
for 143 dwellings).
Action for Children Executive Director of
Finance Simon Bass said: “The Charity is
pleased that this transaction has completed.
The sale facilitated a move to a new
accommodation that is much more suited to
our future needs.”
4
Overriding Interest
K&L Gates London partner Piers Coleman
commented: “We have been proud to work
on this transaction and pleased with the
outcome for our client, bearing in mind the
great work the Charity does. Whilst the
climate for residential development prospects
remain challenging, it shows that transactions
can still happen however tough the market
and funding conditions.”
Piers Coleman and Sebastian Charles led on
real estate and planning issues, respectively,
supported by senior associate Lucinda Bayliss.
K/S Victoria Street v House of
Fraser (Stores Management)
Limited
Tenants’ Guarantors - Practical
Implications of Recent Court of
Appeal Decision
Summary
At the end of July the Court of Appeal
upheld the decision in the Good Harvest
case by confirming that repeat guarantors
are unlawful. The Good Harvest case
had caused much debate amongst the
property industry when the English Courts
decided that an existing guarantor could
not guarantee an incoming tenant by way
of AGA (Authorised Guarantee Agreement).
Although K/S Victoria upheld Good Harvest
in this respect, it also provided some
much awaited clarification on issues left
undecided by the Good Harvest Case. It is
the Court’s remarks about guarantees that
are of interest rather than their decision on
the very specific facts, and so we have not
referred to all the facts of K/S Victoria. We
do however refer to some of the practical
implications of the clarifications made in the
K/S Victoria Judgment.
Main issues considered by the Court
Sub - Guarantees
on the point, and they will be very
The Court considered that a sub-guarantee
persuasive. This is welcome news for the
may be included in the original guarantee
wording, or may be introduced by joining
the tenant’s guarantor into the AGA to give
the sub-guarantee. After the Good Harvest
company and not just a guarantor.
so the Court of Appeal in K/S Victoria has
provided welcome confirmation that the
tenant’s guarantor can validly guarantee that
tenant’s liability under an AGA.
Even though the point didn’t arise in Good
by the current tenant’s guarantor) for the
proposed assignee is always void. The
Court of Appeal preferred the interpretation
• Landlords should ideally require the
whether sub-guarantees would be valid,
Repeat Guarantees
looked at whether a guarantee (offered
came into force.
valuable company to be the tenant
Subsequent Assignees
of repeat guarantees in some detail and
rise to some doubt since the 1995 Act
decision there was much debate as to
of Appeal
The Court of Appeal did consider the issue
industry, clarifying a point that has given
• A guarantee will be void and the
landlord will be left without valid security
if he accepts any person who was the
guarantor of the immediately preceding
tenant as an assignee’s guarantor.
• If an assignment has already happened
Harvest, the Court went on to look at
and that assignment transferred a
whether the tenant’s guarantor could act as
guarantee from a former tenant to the
guarantor for subsequent assignees even if
assignee, a landlord cannot safely rely
it could not validly act as guarantor for the
upon the guarantee.
immediate assignee. It concluded that this
would be valid.
• The landlord can and should require
a guarantor to guarantee the tenant’s
of section 25(1) of the LTCA 1995 that can
Practical Implications
obligations in an AGA when he receives
be read as invalidating any guarantee given
The practical implications of the K/S Victoria
an application from the tenant to assign.
by the tenant’s guarantor of the obligations
Street Case are:
of the assignee.
• With correct drafting a tenant’s
• If alienation covenants permit intragroup assignments without consent then
these should be looked at and ideally
The court accepted that the parties’
guarantor can guarantee the tenant’s
commercial freedom would be limited and
obligations given in an authorised
it may also be commercially unrealistic,
guarantee agreement (AGA) when a
but still supported this interpretation. The
lease is being assigned. This has been
practical implications of this are that a
referred to as a GAGA. The comments
guarantee to the landlord in relation to a
tenant’s guarantor cannot offer itself as
of the Court of Appeal on GAGAs are
tenant, cannot provided a bank guarantee
guarantor for an assignee, as is often done
not binding on future courts as this issue
for the first assignee of that tenant.
on intra-group assignments. It also prevents
was not directly applicable to the facts
the same bank acting as guarantor for both
of K/S Victoria. However as it was the
tenant and assignee. This is even the case
Master of the Rolls, who provided the
where the parties are completely unrelated,
comments then considerable weight
but happen to bank with the same bank.
will be given to them in any future case
landlords should prohibit assignments
intra-group so as to retain control.
• A bank who has provided a bank
Summer 2011
5
Cases
Sale Contract
Disability Discrimination Act
A vendor appointed an estate agent to
An agreement for the sale of a
A tenancy obliged a tenant to decorate
sell its property initially on a sole agency
development site which was in part
and clean the interior of a residential
basis. Subsequently, a multiple agency
occupied by a third party tenant was
property as often as necessary to keep
basis was agreed and a second agent
subject to various conditions. One of the
it in reasonable order. The tenant was
was appointed. A buyer approached the
conditions was the obtaining of vacant
disabled, suffering from epileptic seizures
first agent and was shown around the
possession from the tenant and paying
and so was unable to decorate. The
property and made an offer for it. The
sums due to the tenant on the termination of
landlord, as a consequence, waived
offer was rejected. Thereafter, the buyer
its lease. If the conditions were not satisfied
its right to demand internal decorating.
inspected other properties but showed no
within five months of the completion date,
However, the tenant asserted that s24C
further interest in the vendor’s property.
then either party could terminate the
of the Disability Discrimination Act 1995
Three months later, the buyer’s interest in
contract, subject to the party terminating
obliged the landlord to go further and
the property revived. It approached the
not being in breach of its obligation. The
undertake repairs and decorations to the
second agent and subsequently purchased
vendor terminated the lease but allowed
property to a standard which would enable
the property. The vendor paid commission
the tenant to remain in occupation under
the tenant to “enjoy” the property. It was
to the second agent. The first agent also
a tenancy-at-will and postponed payment
held that the state of the property did not
claimed a fee on the basis that it had been
of the sums due under the lease. After
make it impossible or unreasonably difficult
the effective cause of the purchase by the
five months from the completion date,
for the tenant to enjoy the property within
buyer. It was held that, given the rejection
the purchaser served notice to terminate
the meaning of s24C. An assessment had
of the original offer by the buyer and the
the agreement and sought the return of
to be made as to whether the additional
period of three months before the buyer
its deposit. It was held that the vendor
services requested by the disabled tenant
revived its interest, the chain of causation
had failed to comply with its obligations
would enable him to live as would any
had been broken.
under the agreement and that the right to
other typical tenant in the property. In
terminate had properly arisen. Therefore,
the circumstances, the landlord was not
Comment: It was said that the courts
the agreement was at an end and the
obliged to repair or redecorate.
were anxious to avoid vendors who had
deposit was repayable.
Agency fees
multiple agents having to pay more than
one commission, though there was no legal
Comment: The vendor’s argument that
discrimination statutes were generally to
presumption either way.
the purchaser had waived its right to
be construed benevolently towards their
terminate failed because there had been no
intended beneficiaries but, nevertheless,
unequivocal waiver by the purchaser.
this tenant’s claim failed.
BDW Trading – v – JM Rowe (Investments), CA
Beedles – v – Guinness Northern Counties, CA
Glentree Estates – v – Holbeton, CA
6
Comment: The Court said that anti-
Overriding Interest
Option Agreement
An option agreement gave a developer
the right to acquire a site from a land
owner for the purpose of constructing a
residential development. The local authority
in the area generally required developers
to enter into Section 106 Agreements
to provide affordable housing. Thus, the
option agreement provided that the land
owner would bear financial contributions
in respect of any S106 Agreement, save
in respect of affordable housing. The
agreement further provided that the cost
of carrying out works complying with an
S106 Agreement were development costs
and thus deductable from the price payable
by the developer. A dispute arose as to
where the costs under a S106 Agreement
would fall. An expert appointed under
the agreement found that, as a matter of
construction, the land owner should bear
the costs of affordable housing. Land owner
argued that, despite that determination, the
intention had been that the developer bear
the costs and that the agreement should be
rectified. The Court held that, despite the
expert’s determination, it could still consider
the issue of construction prior to determining
the issue of rectification. It said that, on a
true construction, the burden of the cost of
affordable housing fell on the developer so
there was nothing to rectify. However, since
the land owner was bound by the expert’s
determination on the construction issue, it
was left without a remedy.
Comment: The Court said that, if it had
found that, as a matter of construction,
the developer was to bear the costs, it
would have been appropriate to rectify the
agreement.
Woodford Land– v – Persimmon Homes, ChD
Promissory Estoppel
Sale Contracts
A contract for sale was conditional
upon the completion of specific works of
renovation and conversion by the vendor.
The vendor failed to complete the required
Related parties involved in the ownership
work within the timescale set out in the
of an arcade business and property carried
contract and so the purchaser refused
out a demerger. One party (the landlord)
to complete. The vendor served formal
acquired the freehold of the property and
the other party (the tenant) the business
and a tenancy. The tenancy contained a
break clause which the tenant overlooked.
The tenant thought that it would be able
to conduct the business uninterrupted until
the end of the term. Subsequently, the
notice to complete and, thereafter, the
parties discussed a list of snagging items.
Subsequently, the vendor refused to carry
out further works. The purchaser therefore
sought to rescind the contract on the
basis that the vendor was in repudiatory
landlord wished to redevelop the property
breach. The vendor asserted that it had
and served a notice to operate the break
done all that it was contractually bound to
and notice under the Landlord and Tenant
do and claimed that it was the purchaser
Act 1954 to terminate the tenancy on
who was in repudiatory breach for failing
redevelopment grounds. The tenant sought
to complete. It was held that, on the
to oppose the landlord’s proposals on
evidence, the matters in the snagging list
a basis that it had been encouraged by
were material and sufficiently substantial
the landlord to believe that it would be
such that the purchaser was justified in
able to continue to use the property for
the remainder of the term and said that it
would not have paid the price it paid for
requiring their completion and that it was
the vendor who was in repudiatory breach.
the business otherwise. It was found that
Comment: It was said that, in this case,
no representation or assurances were given
the threshold of materiality below which a
by the landlord regarding the occupation
failure to remedy would not justify a refusal
of the property by the tenant. It was the
tenant’s mistake in overlooking the break
to complete was low.
clause of which mistake the landlord was
Phoenix Property Investors – v – Grange
not aware and no estoppel arose.
Securities, ChD
Comment: The tenant’s contentions
regarding the uneconomic cost of
redevelopment were also dismissed.
Crossco No. 4 – v – Jolan, ChD
Summer 2011
7
New Real Estate Team Additions:
Shanghai
K&L Gates is pleased to announce the arrival of partner Amy Sommers to our newly located Shanghai office.
In China’s growing economy, real estate occupies an increasingly important place. K&L Gates is delighted
to welcome lateral partner hire Amy Sommers, a long-time China resident who has recently joined our
Shanghai office with experience in this significant sector.
Amy Sommers
Amy is a fluent Mandarin speaker who has been involved in China for 20 years. As expected for a
seasoned foreign lawyer in China, Amy has wide experience in advising foreign companies expanding
to China and providing counsel on the operational issues as well as the regulatory framework.
Notwithstanding the economic reforms of the past three decades, real estate remains a heavily regulated
sector and Amy draws on her deep experience with PRC regulatory and policy issues in advising clients
on their PRC real estate investments.
Amy is a co-author of “Real Property Law in China: A Guide to Foreign Investment,” published earlier
this year by the American Bar Association. This work offers invaluable and practical guidance to dealing
with foreign investment in real property transactions in China. In addition to providing a framework for
understanding how real property transactions are commonly structured in China, it provides a general
understanding of the historical development of the real property system in China. Case studies are included
that explain how specific issues are handled in light of applicable rules; also included are various practical
tools, such as sample transaction documents, for understanding how real property transactions function in
this complex market.
Amy is a former chair of the Cross-Border Real Estate Committee of the American Bar Association Section
of International Law, and from 2008 through 2010, served as a chair of the Real Estate Committee of the
American Chamber of Commerce – Shanghai. The Expatriate Professional Women’s Society of Shanghai
awarded Amy its 2007 Businesswomen Award in the category of Professional Excellence for her work in
helping create stronger ties between the US legal profession and China’s growing profession.
8
Overriding Interest
New Real Estate Team Additions:
Paris
Edouard Vitry recently joined our Paris Office as a partner in its real estate investment, development and
finance practice. Edouard arrives at K&L Gates from Simmons & Simmons LLP, and is joined in his move by
counsel Joanna Klat and associate and Secretary of the Paris Bar Conference 2011 Benjamin Chouai.
An experienced commercial real estate lawyer, Edouard advises French and international clients such
Edouard Vitry
as real estate funds and companies, banks, and insurance companies on a broad range of real estate
matters. These include investments, financings and refinancings, construction, development, leasings, and
disputes. A Fellow of the Royal Institution of Chartered Surveyors (RICS), he chairs the Dispute Resolution
professional group of RICS France and is also the President of the Association des Juristes et Etudiants en
Droit Immobilier de Paris II Assas - Real Estate Lawyers Alumni Association.
Joanna Klat
In May, K&L Gates’ Paris office moved from its current location on the avenue Raymond Poincaré to a new
address at 116 Avenue des Champs Elysées.
Benjamin Chouai
Summer 2011
9
10
Overriding Interest
Events and Announcements
at K&L Gates
Real Estate Breakfast
Seminars in September
and CBRE). Paul McNamara, director
and head of research at Prupim, then
Real Estate Team of the Year
We will be hosting our annual real estate
focussed on the property investors
The K&L Gates real estate team were
breakfast seminars on the 20th and 27th
perspective, and interestingly mentioned
delighted to be shortlisted for “Real Estate
September. Further details are posted on our
a new United Nations paper, which
Team of the Year 2011” by UK Lawyer
website, www.klgates.com.
he is involved with, dealing with the
Magazine.
investors perspective. The presentations
discussion. The panel, made up of key
Competition -Where in the
World is OI?
industry professionals, discussed some
Send in a photo of OI in an exotic or not
On the 27th of May the K&L Gates Real
new developments for the ISPI Monitor
so exotic location for a chance to win
Estate Group, together with the Investment
(including the setting up of a new
a bottle of champagne. Entries should
Property Databank (“IPD”) and the
Sustainability Steering Committee (which
be emailed to any of the editors whose
Investment Property Forum (“IPF”) organised
Steven Cox and Bonny Hedderly of K&L
details appear on the back page of this
and hosted a seminar entitled “The Green
Gates will participate in)).
issue. Winners will be announced in our
The Green Agenda and
New Sustainability Initiatives
Seminar
were then followed by the panel
next issue.
Agenda and New Sustainability Initiatives”.
Steven Cox chaired the event and Sebastian
Attendance at the seminar was high
Charles participated on the panel.
(over 100 people) and there were lots
of questions from the floor. We also had
Steven and Sebastian, were joined by
a great attendance internally, including
outside speakers/panellists from the IPD
Edouard Vitry who came over from Paris
(Christina Cudworth), CBRE (Michael
to support the event. If any of our readers
Brodtman), Prupim (Paul McNamara),
would like a copy of the slides or have
Quintain (Louise Ellison) and Legal and
any questions about this event or our
General (Bill Hughes). The seminar took the
upcoming September seminars please do
form of a panel discussion which included
get in touch.
a presentation by Christina Cudworth,
Global Head of Sustainability at the IPD,
with a focus on the latest results of the
IPD’s UK Sustainability ISPI Monitor (which
K&L Gates sponsors together with the IPF
Summer 2011
11
For further information contact:
Steven Cox steven.cox@klgates.com Milton McIntosh milton.mcintosh@klgates.com T: +44 (0)20 7360 8259
Bonny Hedderly bonny.hedderly@klgates.com T: +44 (0)20 7360 8192
T: +44 (0)20 7360 8213
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