Can a practice principal really be liable for an associate dentist's criminal behaviour?

Can a practice principal really be liable for an associate dentist's criminal behaviour?

The question posed to the court was whether an employer can be vicariously liable for sexual assaults perpetrated by an independent doctor?

Between 1968 and 1984 Dr Bates was engaged by Barclays Bank to carry out medical examinations on potential and existing employees of the bank. Barclays at that time were undergoing a positive drive to recruit women into the bank and as a result a number of the individuals assessed by Dr Bates were women, some as young as 16.

Accusations against Dr Bates

The employees would go to Dr Bates’ home, where he had created a purpose-built treatment room. He would see the patients on their own with no chaperone present. They were required to undress to their underwear. The allegations against him included inappropriate breast examinations and digital vaginal or anal contact. Following the examination, Dr Bates would send a pro-forma document setting out the details of the examination to the bank. If the report was satisfactory the individual would be offered employment.

Dr Bates died in 2009, however in 2013 a police investigation was carried out which concluded that had he been alive, there would have been sufficient evidence against him to warrant a criminal prosecution.

Barclays’ vicarious liability

In 2016, 126 claimants sought damages against Barclays Bank in relation to the sexual assaults they had suffered. They claimed that the bank utilised the services of Dr Bates in the role of medical examiner in order to satisfy themselves that the person was fit to work for the bank and to confirm that they would be suitable for the life assurance policies in place.

In July 2017, the Hon Mrs Justice Davies ruled that, yes, the bank was vicariously liable for the actions of its self-employed contractor. The reasons she gave were as follows:

A two-stage test must be considered to determine whether or not a vicarious liability exists:

  1. Is the relevant relationship one of employment or “akin to employment”?
  2. If so, was the tort sufficiently closely connected with that employment or quasi employment?

When is a relationship “akin to employment”?

When the following criteria are satisfied:

– The employer is more likely to have the means to compensate the victim than the employee and can be expected to have insured against that liability;

– The tort (act) will have been committed as a result of activity being taken by the employee on behalf of the employer;

– The employee’s activity is likely to be part of the business activity of the employer;

– The employer, by employing the employee to carry on the activity will have created the risk of the tort committed by the employee;

– The employee will, to a greater or lesser degree, have been under the control of the employer.


The bank argued that Dr Bates was an independent contractor, and that he bore personal liability for the acts. Had the claim been made much earlier his personal estate would have been able to settle the claims.


However, to determine whether the relationship was “akin to employment” the judge applied the five criteria set out above:

– The judge concluded that whilst Dr Bates would have had indemnity insurance, that insurance would not have covered him for cases of sexual assault; his estate was distributed many years earlier.

– Employment was conditional upon the bank being satisfied on the basis of the medical examinations that the applicant was medically suitable for service. Dr Bates was the chosen doctor of the bank and he used their stationery.

– The purpose of the examination was to enable the bank to be satisfied that a potential member of staff would, health wise, be an effective member of the workforce. This was an intrinsic part of the business activity of the bank.

– The bank directed the employee where to go and gave no freedom of choice. They directed the doctor to undergo an examination, including a chest measurement! Many of the claimants, who were as young as 15 and 16 saw the doctor alone in his room and were asked to remove their clothing. The judge concluded that the bank created the risk of the tort (sexual assault) taking place.

– The fact that Dr Bates organised his own diary and carried out other medical activities did not negate the argument that he was under the control of the bank at the relevant time. The fact that the assessment took place at his home rather than the bank made no difference to this conclusion.


Tort closely connected with the employment

When considering stage 2, she concluded that the sexual assaults occurred during the course of a medical examination which the bank required the applicants to undertake for the purposes of securing employment. Dr Bates was trusted to do the work and placed him in a position to deal with the employees. This gave him the opportunity to abuse his position. The abuse was inextricably interwoven with the carrying out of his duties.

Would a practice principal be vicariously liable for the tortious acts of their Associates?

In short, the answer is yes. Whilst many associate dentists prefer to maintain their self-employed status for tax purposes (the Tooth Counsel has blogged on worker v self employed status on a number of occasions) the relationship that they have with the practice is almost entirely “akin to employment”. It is now common practice for associate dentists to appear to members of the public to be an integral part of their dental practice, bookings are made and diaries organised by the practice, patients and referring dentists are introduced to the associate via the practice, uniforms are often worn and the practice systems and stationery utilised. If an associate dentist commits an actionable tort against a patient or other member of staff whilst engaged by the practice, then the practice itself would be liable.

Whilst the principal of the “independent contractor defence” remains intact, this judgement sees the court extending the scope of vicarious liability significantly. Whilst the facts of the above case are extremely unlikely to arise in today’s society, particularly in a dental setting where nurses are present at all times when a dentist is seeing a patient, it is a valuable lesson to reinforce the view that the employers should not be complacent about the potential for poor behaviour by their independent contractors and the liability that may follow.

If you have any questions about this blog, or require advice and assistance in relation to your liabilities within the work place please feel free to email Julia Furley on This email address is being protected from spambots. You need JavaScript enabled to view it., or call us on 020 7388 1658.

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Stephen Henderson

Unusual circumstances

Great summary of a curious case. The claimants came after the bank because it has deep pockets and the doctor is dead and his affa... Read More
Tuesday, 03 October 2017 07:22
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Evil Genius - a guide to not being sued.

A guide to not being sued

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Goodman Grant win award at Liverpool Law Society Legal Awards

Goodman Grant win award at Liverpool Law Society Legal Awards



And the winner is…


The Goodman Grant team is delighted to announce that they have recently won at the prestigious Liverpool Law Society Legal Awards.


At a black-tie awards ceremony held at the Rum Warehouse in Liverpool, the Goodman Grant team were awarded the Best Niche Law Firm Award, for their work in the dental sector – a fantastic accolade that demonstrates the commitment Goodman Grant has to providing dentists with expert legal support.


Ray Goodman, joint managing director at Goodman Grant Solicitors, says of the firm’s win: “This award shows the amount of hard work and devotion the Goodman Grant team puts into helping each and every one of our dental clients and it is an honour to have this recognised by the Liverpool Law Society.”


Goodman Grant are renowned for providing a wide range of specialist legal services to the dental profession, from employment contracts and disputes, to CQC applications, due diligence and all aspects of practice sales and acquisition.


To find out more, contact the expert team at Goodman Grant today.


For more information, visit the Goodman Grant website at or call us on:

Leeds office: 0113 834 3705

London office: 0203 114 2133

Liverpool office: 0151 707 0090

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Provide the best service, to everyone - Nicola Lomas Goodman Grant Lawyers for Dentists

Provide the best service, to everyone

A Tesco store recently made the headlines when an employee posted on Facebook about how the company had gone above and beyond contractual obligation to provide her with the facilities to breastfeed her new baby in comfort and privacy.

The feature truly highlighted how important it is to offer support to new mothers at this important stage of parenthood and Tesco has been rightly praised for its efforts. Unfortunately, however, there are just as many cases that show the opposite – from mothers who have been asked to leave restaurants or other public spaces or who have been shamed into thinking that breastfeeding in public is taboo.

Of course, breastfeeding is protected by law – from as far back as the Sex Discrimination Act of 1975 which stipulates that breastfeeding mothers should not be harassed or discriminated against in any situation. This has been reinforced more recently in the Equality Act, 2010 which clarifies that a business must not treat any woman who is breastfeeding unfavourably. Indeed, employers must be aware of these stipulations, since they are required, by law, to provide adequate facilities for breastfeeding mothers.

Dental professionals must be particularly considerate of this. In many dental surgeries, space is a rare commodity, so ensuring that there is enough room for a breastfeeding mother – either employee or patient – to rest may be more difficult. The allocated space must be comfortable, private and be large enough to allow the individual to lie down.

Other than the requirements to regularly risk-assess the working environment, however, there is no legal requirement to conduct a specific separate risk assessment for a breastfeeding individual – but a prudent employer may wish to do so, to best provide an environment which is safe and comfortable.

Employers are not required to provide specific areas in which breastfeeding or expressing can take place, nor do they need to provide paid breaks for this purpose. But they must be aware that sometimes the staff room or the waiting room will be inadequate and the toilet facilities are simply inappropriate to breastfeed. Importantly, they must remember that under the Equality Act they cannot provide a service on different terms; meaning you cannot ask a breastfeeding mother to sit somewhere different than your usual waiting room unless there is a safety concern – so it is better overall to make provisions for a comfortable area which meets the specific legislative requirements to avoid any complications or potential dispute.

Not only will this be in keeping with current laws, it will be an effective way to show your support for new mothers – and this can be a particularly powerful tool. Whether it’s online or in person, new mothers will certainly discuss different service environments – your dental practice included – and if you are providing a comfortable, caring environment for them and their babies, they will most likely tell their friends about it. As a way of attracting new patients, new mothers may be a positive place to start.

In this regard, providing appropriate areas for breastfeeding mothers is simply the start – there is a myriad of other opportunities for you to take to strengthen the relationship between your business and new parents. Providing information can be another powerful way of doing so. For example, did you know that is has been show that breastfeeding a child will significantly reduce the risk of dental caries, malocclusion and fluorosis – it is also suggested that breastfeeding will promote optimal jaw and tooth development.[1]

There is also a helpline available in the UK to check the suitability of certain drugs for breastfeeding mothers; Drugs in Breastmilk helpline is contactable through 0844 412 4665 and is an effective way of staying up-to-date on behalf of your patients.

Similarly, it is worth making it clear that mothers are exempt from patient charges under the NHS whilst they are pregnant and throughout the first year of their child’s life.

Taking these steps is a great way of providing an excellent service to everyone – offering effective information as well as a comfortable, appropriate environment for breastfeeding patients and employees will certainly attract positive comments, just as Tesco enjoyed recently.

Goodman Grant Solicitors are the lawyers for dentists in the UK. With nationwide offices and an expert team, they understand the specific issues that dental professionals are beset with on a daily basis. If you need assistance with any of the legal aspects of running a dental business – from how to best cater to breastfeeding mothers to incorporation or employment contracts and tribunals – they can help. As both NASDAL and ASPD members, they know precisely what dental professionals need to run an effective business and will assist in a positive, friendly manner.

Do not risk alienating breastfeeding mothers – make sure you take the right steps to ensure you accommodate their needs just as you would any other.


Nicola Lomas Goodman Grant Lawyers for Dentists

For more information call Nicola Lomas on 0151 707 0090 or email This email address is being protected from spambots. You need JavaScript enabled to view it.

[1] LA Leche League GB leaflet: Harry Torney, BDS (QUB), M DENT SC (TCD)


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Protect yourself and your staff - Goodman Grant Lawyers for dentists

Protect yourself and your staff - Goodman Grant Lawyers

On average, there are approximately 6,000 employment tribunals being presented each month in this country. In dentistry, we see a large volume of cases in which practice principals have failed to issue their staff with proper employment contracts. Despite the fact that the provision of such contracts has been a statutory requirement since 1978, there are still many practices that fail to do so – why this should be the case is hard to determine, but it is indicative of an attitude that fails to recognise the importance of the staff. 


Failing to provide employment contracts to any member of your team is not only a breach of statutory requirement, it can also leave practice owners vulnerable should there be dispute with a member of staff. For example, without an employment contract, there is no clear procedure for staff holidays, sick pay, overtime of discipline.


It is also quite likely that if a tribunal comes across a case where an employer has not provided a contract, they are likely to sympathise with the employee’s position. Thus, the lack of a contract can actually jeopardise the chances of successfully defending against such proceedings.


But by including a clause in an employment contract, that defines the procedures that will be followed in all aspects of work within your practice, you will be suitably protected.


To reinforce this, it is also prudent to supply a comprehensive staff handbook. This must be bespoke to your dental practice and will expand upon the terms detailed in the employment contract, focussing on specific circumstances that may be unique to you and your team. Of course, it must be regularly updated to reflect new legislation and practice changes, and it is absolutely vital to include a thorough introduction to the handbook in any staff inductions.


Ultimately there are two reasons to invest yourself in a comprehensive handbook like this. Firstly, you will be able to significantly reduce the chances of becoming embroiled in a dispute and being taken to a tribunal. The second is that your business will come across as professional, serious, fair and competent.


Of course, these precautions are not guaranteed to stop all staff misconduct, but they do provide an efficient safety-net to fall back on if matters turn nasty. What’s more, it will promote staff happiness, because they will feel protected and valued – and, of course, happy staff should equal happy patients.


John Grant of Goodman Grant Lawyers for Dentists - a NASDAL member

For more information call John Grant on 0113 834 3705 or email This email address is being protected from spambots. You need JavaScript enabled to view it.



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Specialist Lists and the GDC Review

Specialist Lists and the GDC Review


The GDC specialist lists were established in 1998; the most recent, Special Care Dentistry, being added in 2008. The UK has more recognised areas of specialism than any other European country.  There are currently 4261 registered specialists across the 13 disciplines. The GDC are not obliged to have specialist lists, but are empowered to do so by various pieces of European and domestic legislation and regulation. If they wanted to dispose of the lists it would not require legislative change, but would need a compelling policy reason and would require a significant amount of regulatory change.

There is no comprehensive data about the total number of patients treated by Specialists each year; although there were 2.7 million outpatient appointments within dental speciality clinics and a further 320,000 consultant episodes in 2012/13 according to NHS data. This of course does not account for private patients.

The GDC recently undertook a review of the way in which the specialist lists are regulated. The aim was to determine what the benefit of regulation was when it comes to patient protection and whether the lists did in fact help patients make a more informed choice about their dental treatment.

The first phase of the review began in January 2014; whereby information was obtained from both the public (with a representative sample of 500 adults) and the profession regarding their experiences (there were 68 responses from the profession, including 25 from individual specialists and 5 from GDPs).



The most common way to obtain entry onto a specialist list is to undertake a recognised training programme. Approximately 500 students per year attempt this route. Alternatively, candidates can seek to illustrate equivalence in “knowledge and experience gained through academic or research work”; commonly known as mediated entry.

European registrants with qualifications in Oral Surgery or Orthodontics are automatically recognised.

In 2011 there were 175 additions to the list, in 2012 245 and in 2013 231.


Only a registered specialist can use the title. This is also true for the use of the “ist”; endodontist, periodontist etc. It is not permissible to use the phrase “specialising in” if you are not registered on a specialist list. The only permissible terms are “special interest in”, “experienced in” and “practice limited to”. Using an incorrect term can lead to professional disciplinary proceedings and/or a conviction and fine.


The cost of registering on a specialist list are relatively low; just £345 for initial registration and £72 per year thereafter.  

The GDC have calculated that the cost of regulating the specialist lists in 2014 was £339,000, which income is forecast to exceed by 6%. There does not appear to be any comparison with earlier years, and as such it is not known whether this is a constant figure. However, this cost also includes the cost of the review so is likely to be much higher than previous years.

Conclusions of the Review

Does specialist regulation bring any benefits in terms of patient and public protection?

The reality is that public awareness of the specialisms is extremely low; shockingly more than half of those surveyed did not know ANY specialism existed. Only 1% was aware of periodontists and restorative specialist, only 2% of prosthodontics and only 3% of endodontists. The highest recognised term was “cosmetic dentist” at 22%, closely followed by orthodontist at 19%. Worryingly 10% believed implantologist to be a recognised speciality. However, most people felt that it was important that specialists were properly regulated. Unfortunately, only a third of those questioned had even heard of the GDC (and this was when prompted!).

It is useful for specialists and practice owners to bear in mind that when choosing a specialist most of those who did recognise specialisms relied on their dentist’s referral rather than their own research. What is abundantly clear is that dental specialists are not effectively marketing their existence, and by implication their value.  

Of those in the profession who responded, the general view was that regulation should not be decreased and that deregulation risked those not properly qualified attempting procedures outside their capability. However others pointed out the lack of evidence that regulation does in fact improve patient care. Concern was raised re the lack of regulation of specialists post-entry. At present CPD requirements are the same for both GDPs and Specialists.

Is regulation proportionate to the risks posed by dentists providing complex treatments?

Perhaps understandably specialists were more supportive of the lists than GDPs. Some respondents felt that the fees charged were disproportionate. However this is surprising bearing in mind the amount of administration required in certain cases. £345 may seem a lot for someone who has been awarded the CCST, but is a small reflection of the cost of mediated entrance. It is curious that a more diverse fee structure has not been recommended and that practitioners are not being asked to fund appeal hearings, particularly if unsuccessful.

Many respondents questioned the need for the number of specialist lists. However the review concluded that they were necessary due to the number of complex procedures undertaken.

Are the specialist lists the appropriate mechanism for helping patients make more informed choices about care seen as falling outside the remit of a GDP?

74% of patients who had visited a Specialist had been referred by their GPD. Only 4% of those questioned said that they would check the details of their Specialist with a regulator. Although the majority responded that it was important that the information was there if they did want to check.

GDPs and Specialists generally agreed that the lists do assist in making appropriate referrals.

In reality although specialist lists are available on the GDC website, the public a) doesn’t know about the GDC website and b) doesn’t understand the terminology used and significance of qualifications recorded. It would appear that it is the GDC who are failing in the provision of information to patients.

Should the GDC be the body to regulate the specialities?  

It was generally agreed that the GDC are the appropriate body to regulate, however it was pointed out the GDC was reliant on the Royal Colleges to provide guidance on the skills, knowledge and behaviour of specialists. Nor does it quality assure specialist training or have a separate revalidation process in place.

The review made for possible proposals for the future:

1.       Strengthen the GDC’s approach to regulation. The GDC are developing a “work programme” to achieve this and intends to give a clearer definition as to the meaning of specialist, ensuring the lists are correct, “tightening up” mediated access or removing this route entirely, quality assuring specialist training and providing information to patients.

It appears that the only rational for proposing the removal of mediated entry is to reduce costs. Surely a fairer and more sensible approach would be to charge applicants appropriately.

2.       Explore alternative models of regulation:

If the Council is of the view that the current regulation does not offer significant benefits to either the public or patients; is not proportionate; or that resources could be more properly focussed on key regulatory functions; then there would be no further policy changes and instead possible alternatives to statutory regulation would be explored. This could include investigating the possibility of removing all specialist lists save Oral Surgery and Orthodontics:

3.       Continue to regulate the Specialties, but not make any significant policy changes. Although it is still suggested that the mediated entry route would be reduced.

4.       Further analysis of the evidence of improved patient outcomes.

Overall the review has uncovered the alarming lack of understanding by the public regarding Dental Specialists and the Lists. However, on a more positive note, appears to suggest that those within the profession believe that the lists are both necessary and helpful. Of the proposals, only one thing is clear that dentists can expect an attack on the mediated entry route over the coming years; although there seems little justification for this save on costs grounds.



**Blog image from Creative Commons

***This blog has been written for Rumpole of the Surgery by Julia Furley of JFH Law

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Andrew Shelley

Missed the point

The GDC, as usual, have missed the point. Other dentists refer to specialists and the specialist lists help them choose the approp... Read More
Monday, 21 September 2015 19:00
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Visit Ward Hadaway at the Nasdal Stand I175

Visit Ward Hadaway at the Nasdal Stand I175

Ward Hadaway is a top 100 law firm with offices in Newcastle, Leeds and Manchester. Its healthcare team is nationally recognized with leading legal experts supported by a substantial team of sector specialists.

Led by Damien Charlton and Alison Oliver, our healthcare practices team provides a range of specialist legal services for dental practitioners, including:

  • sales and purchases of NHS, private and mixed practices
  • preparation of associate agreements
  • incorporation of practices
  • advising on dental law and regulations
  • preparation of partnership and expenses sharing arrangements
  • employment law
  • property matters
  • dispute resolution

We look forward to seeing you at the NASDAL stand I175 at the BDIA Conference.

Damien Charlton is an experienced commercial lawyer who has been advising businesses on company and commercial matters for over 15 years. He is a member of NASDAL.

This email address is being protected from spambots. You need JavaScript enabled to view it.

t: 0191 204 4265


Alison Oliver is an Associate Solicitor in Ward Hadaway's Commercial Department. She works almost exclusively with healthcare sector clients, and has been advising dental and medical practitioners for the last 10 years.

This email address is being protected from spambots. You need JavaScript enabled to view it.

t: 0191 204 4240

Alison will be speaking on dental partnership and expense sharing agreements at the Conference – look out for details at the NASDAL stand.


What our clients say:

"We have recently completed the sale of our two large dental practices to a national corporate through Alison Oliver. The nature of the practices meant that there was a lot to consider, but Ward Hadaway provided an excellent service throughout and took a lot of the pressure off us as sellers. They clearly have a lot of experience and knowledge in selling dental practices, and were able to anticipate and prevent potential pitfalls. The sale completed smoothly on time, largely due to the close personal attention given by Alison Oliver throughout. Any queries were replied to immediately, and I could not fault anything in the whole process from our solicitor’s point of view."

Paul Blaylock, Former Dental Practice Owner

"We cannot recommend Ward Hadaway more highly....All [members of the team] completed their various roles calmly and efficiently, being the friendly contact at the end of a phone or e-mail almost immediately whenever we needed help and advice. I would not hesitate to recommend them to any other dentist who is contemplating the sale, or indeed purchase, of a dental practice."

Paul Winfield, Former Dental Practice Owner

What the legal directories say:

Committed to building long-term relationships with clients rather than just looking at immediate revenue opportunities.

Legal 500

Clients note that "the firm has an excellent cross-section of lawyers, the resources to cope with tight timescales and is excellent value for money – we trust it to come up with the goods on any legal matter".

Chambers Legal Directory


NASDAL can be found on stand I175 at the BDIA Dental Showcase

NASDAL is an association of specialist dental accountants and lawyers all of whom have a deep expert, technical understanding of the key issues and challenges facing the dental profession.  Members regularly produce guidance and benchmarked data so that they can provide clients with cutting edge advice on complex issues.


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Agreeing with Associates - John Grant

John Grant of Goodman Grant Solicitors

John Grant Director from Goodman Grant Solicitors discusses the importance of bespoke written associate agreements.

If you were to study the legal test into whether someone is an employee or self-employed, you might quickly conclude that most dental associates are employees. The dental profession has quite frankly always enjoyed what can only be called a special dispensation from the Inland Revenue. In other words, the Revenue have not, as yet, challenged dental associates’ self-employed status. Although there is little sign of this changing at present, that is not to say it never will and it is certainly better to do what one can to protect oneself – not only against the Revenue, but also against claims of unfair dismissal by former associates

If there is no written associate agreement and a practice principle decided to terminate an associate’s contract, that associate could seek legal advice and if it was deemed that they were an employee, they could pursue a claim for unfair dismissal. This could then culminate into a sizeable compensation sum.

In addition, not only are there the risks of compensation claims, there are also tax implications. If the Inland Revenue were to pursue the case, it would be entitled to ask the principle to pay all tax that the associate should have paid as an employee over their entire period of employment. This is regardless of any tax the associate may have already paid.

Consider the criteria of the legal multiple test that is used to determine if someone is an employee or self-employed:

Personal service – does the servant have to perform the service personally or can someone else carry it out

In most associate’s agreements, the right to appoint a locum is provided – however in the vast majority of cases, it is limited and may only apply if the associate were away ill and even then, the appointment of a locum is usually subject to the practice owner’s approval.

Mutuality of Obligation- An obligation to do the work and an obligation to be paid for it.

The overall reality of a dental practice is that the principle or owner does introduce patients. Whilst many associate agreements state there is no obligation, the reality is that such an obligation does exist – otherwise principals would quickly find associates giving notice to leave the practice. When the work is complete, there is the obligation to pay the associate.

Control – how much control does the employer exercise over how the servant carries out their job?

Not only are there controls imposed by CQC, the NHS and the GDC, but in addition many written agreements stipulate that associates must comply with the practice policies and procedures – even to the extent of requiring associates to participate in practice appraisals.

Similarly, most large dental corporates go into great detail within associate contracts to explain exactly how the individual should perform the work, which I would submit is entirely contrary to the notion of associates being self employed. If they are required to attend team meetings and have to attend out of hours emergencies, this too suggests a degree of control that is most commonly found in an employee/employer relationship.

John Grant of Goodman Grant Lawyers for Dentists - a Past Chairman of ASPD

For more information call John Grant on 0113 834 3705 or email This email address is being protected from spambots. You need JavaScript enabled to view it.


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Professional Services for Dentists

PFM Dental and Patient Plan Direct, proud sponsors of GDPUK, have come together to create a new blog area on GDPUK: Professional Services for Dentists

The area will provide expert opinion and advice in key areas relating to professional services within dentistry including:  Practice valuations, Business management and operations, Financial, Accountancy and Legal. Guest bloggers are experts in their field with one thing in common – they all work exclusively with dentists. The blog represents an excellent all-you-need-to-know source to keep you ahead of the field in non-clinical matters.

PFM Dental are one of the leading specialists providers to dentists within the UK providing: a dental sales agency, practice valuations, independent financial advice and chartered accountancy services.

Patient Plan Direct is the fastest growing, most cost effective and flexible plan provider in the market - Experts in plan launches and plan transfers.


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