Harris Hagan

16Feb

Chambers Global 2024 Legal Rankings

16th February 2024 Harris Hagan 206

Harris Hagan continues to have four lawyers individually ranked for Chambers & Partners’ Global Market Leaders Rankings (Gaming & Gambling).

We are proud to have the quality of our work in the gambling industry recognised by the prestigious legal directories and will always strive for the highest standards for our valued clients.

John Hagan (Band 1) has been praised as a “leading practitioner” for gaming and gambling matters and recognised for often assisting with “high-value international transactions”.

Bahar Alaeddini (Band 2) has been recognised for her “specific expertise” with global gaming and gambling matters, including her frequent work on regulatory and licensing matters.

Julian Harris has been recognised with the esteemed position of Senior Statesperson and commended for his “wealth of experience” regularly assisting clients with licence reviews and compliance investigations. Commentary has praised Julian as “very switched on.”

Last, but certainly not least, Hilary Stewart-Jones also continues to occupy the position of Senior Statesperson and has been recognised as a “noted figure” in the industry. Commentary has emphasised her status as “very well connected and very knowledgeable for the UK market.”

02Feb

International Association of Gaming Advisors and Gaming Regulators European Forum Workshop: Manipulation of sports contests

2nd February 2024 Harris Hagan 204

The International Association of Gaming Advisors (“IAGA”) and Gaming Regulators European Forum (“GREF”) are delighted to be host a workshop on critical issues surrounding the manipulation of sports competitions at the London Marriott Hotel Canary Wharf at 4pm on Monday 5 February 2024. The workshop will present a unique opportunity to hear from international experts on sports betting integrity and gambling regulation across two sessions and an interlude.

The workshop will consist of the following sessions:

16:00 – International Olympic Committee lecture: the Prevention of the Manipulation of Competitions

The lecture will include:

An introduction to the Olympic Movement Unit on the Prevention of the Manipulation of Competitions (“OM Unit PMC”) by Friedrich Martens (Head of the OM Unit PMC);
A review of the betting-related provisions in the Council of Europe Convention on the Manipulation of Sport Competitions (“Macolin Convention”) by Nicolas Saydé (Head of the Macolin Secretariat, Council of Europe Sport Division); and
A review of the Olympic Movement Rules related to betting and the OM Unit’s work with betting entities by Evangelos Alexandrakis and Aiden Young (OM Unit PMC).

16:45 – Joint comments from GREF and IAGA

Following the lecture, there will be a welcome to the workshop and introductory comments from:

GREF Chairperson Isabelle Falque-Pierrotin (the Autorité nationale des jeux, French regulator); and
IAGA former President and Trustee John Hagan (Managing Partner, Harris Hagan).

17:00 – Panel discussion: Working together to protect international sporting events and gambling integrity

With numerous major sporting events occurring in Europe in 2024, the roundtable will discuss a number of critical priorities for event organisers, including sports betting integrity, match-fixing, gambling advertising and sponsorship, ethics and regulatory compliance.

Moderated by John Hagan, the panel will comprise:

Dieter Braekeveld (Integrity in Sports Training Officer at INTERPOL);
Atle Hamar (Director General of the Norwegian Gambling and Foundation Authority);
Friedrich Martens (Head of OM Unit PMC);
Tim Miller (Executive Director of the British Gambling Commission); and
Nicolas Saydé (Head of the Macolin Secretariat, Council of Europe Sport Division).

Harris Hagan is proud to continue its long association with IAGA, which includes Julian Harris and John Hagan serving as President in 2013 and 2019/2020, respectively, and Bahar Alaeddini serving as General Counsel and member of the Programme Committee. We therefore strongly recommend this workshop to readers not least for the excellent quality of the content and networking opportunities with the high-calibre speakers and panellists.

Please contact us if you would like to know more about IAGA’s work, membership and/or the workshop. We very much hope that you can join us there!

31Jan

White Paper Series: What’s next?

31st January 2024 Harris Hagan 220

In our last blog, we looked back at the last nine months. In this blog, we look forward at what lies ahead in 2024.

Open consultations

In the words of the previous Gambling Minister, Paul Scully MP, and as previously blogged by us, “ the industry to stay engaged as policies are refined, finalised, and implemented.” We continue to urge the industry to heed that imperative during 2024 and beyond, including on the following forthcoming deadlines:

21 February 2024 – GC Autumn Consultation (on proposed changes to the LCCP and RTS) closes.
15 March 2024 – GC December Consultation (on proposed changes related to financial penalties and financial key event reporting) closes.

The consultation phase is critical, with both Government and the Gambling Commission remaining under immense pressure to listen. We remain happy to assist clients with their responses where that would be helpful, as we did in the last once in a generation opportunity in 2005!

Closed consultations and forthcoming responses

We await responses (including implementation timeframes) on the following consultations:

DCMS Land-Based Consultation (closed on 4 October 2023)
DCMS Stake Consultation (closed on 4 October 2023)
GC Summer Consultation (closed on 18 October 2023)
DCMS Levy Consultation (closed on 14 December 2023)

What else is on the horizon?

February to March 2024 – Likely publication of Gambling Commission’s new three-year corporate strategy

March 2024 – Gambling Commission conference on illegal gambling

1 April 2024 – LCCP GAMSTOP and suicide reporting requirements come into force

TBC: Although the following items are expected, the timing is currently unknown:

DCMS consultation on Gambling Commission fees
Expected introduction of the statutory gambling levy
Establishment of a gambling ombudsman
Official launch of the Gambling Commission’s Gambling Survey of Great Britain
Extension of Gambling Commission powers to tackle illegal gambling (“when Parliamentary time allows”) Government review of the horserace betting levy
Government consultation on bringing remote gambling into a single tax structure

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31Jan

White Paper Series: 9 months in – where are we?

31st January 2024 Harris Hagan 236

It is now nearly nine months since the publication of the White Paper on 27 April 2023, which was nearly 30 months in the making. Following its publication, the Gambling Commission was quick to manage expectations by saying that the implementation of the White Paper “will likely take a number of years to fully complete”. So, where are we after 9 months? In this blog, and following the format of the White Paper, we look back at the progress made by the Department for Digital, Culture, Media & Sport (“DCMS”), the Gambling Commission and the industry.

Chapter 1: Online protections – players and products

26 July 2023 – Two consultations were published by the Gambling Commission and DCMS to implement proposals to improve online protections in the White Paper:

a Gambling Commission consultation (the “GC Summer Consultation”), which included proposals to reduce the speed and intensity of online products, while making them fairer and increasing consumer understanding about game play and introduce new obligations on operators to conduct financial vulnerability checks and financial risk assessments to understand if a customer’s gambling is likely to be harmful in the context of their financial circumstances. The GC Summer Consultation also included proposals to extend personal management licence (“PML”) requirements so more individuals within a licensee would be required to hold a PML.
a DCMS consultation on maximum stake limits for online slots (the “DCMS Stake Consultation”).

4 October 2023 – The DCMS Stake Consultation closed (extended from 20 September 2023 following the publication of incorrect problem gambling rates). At the time of writing, we await the response.

18 October 2023 – The GC Summer Consultation closed. At the time of writing, we await the response.

29 November 2023 – The Gambling Commission launched a further consultation (the “GC Autumn Consultation”), includes proposals to ensure that tools are available (such as deposit limits) to make it easier for consumers to manage their gambling and increase transparency for consumers if their funds are held by licensees that offer no protection in the event of insolvency. This consultation remains open until 21 February 2024.

Want to read more?

Read more in the following Harris Hagan blogs:

Chapter 2: Marketing and advertising

19 June 2023 – The Gambling Commission published a new hub for operators engaging with third parties.

25 July 2023 – As part of wider work by Government on online advertising and consumer protection, DCMS published its consultation response to the Online Advertising Programme.

26 July 2023 – The GC Summer Consultation was published, which included proposals to improve consumer choice on direct marketing by giving consumers more control over the direct gambling marketing they wish to receive.

5 September 2023 – The Betting & Gaming Council published the seventh edition of the Industry Group for Responsible Gambling Code for Socially Responsible Advertising (the “IGRG Code”), which notably:

extended safer gambling messaging requirements to 20% of advertising space across online and broadcast media (previously, this commitment only applied to television and radio); and
extended the 25+ rule to all digital media platforms, including those which operate age verification processes.

Throughout 2023, the Advertising Standards Authority (“ASA”) has also been making full use of artificial intelligence through its Active Ad Monitoring system in order to review and regulate online advertising. Since August 2023, there have been at least seven rulings on gambling adverts, which the ASA states have formed:

“part of a wider piece of work banning gambling ads which, under strengthened rules, are prohibited from being likely to be of strong appeal to under-18s.”

18 October 2023 – The GC Summer Consultation closed. At the time of writing, we await the response.

29 November 2023 – The GC Autumn Consultation was published and included proposals to ensure free bets and bonuses are more socially responsible and do not encourage harmful or excessive gambling. This consultation remains open until 21 February 2024.

1 December 2023 – The IGRG Code came into force.

Want to read more?

Read more in the following Harris Hagan blogs:

Chapter 3: The Gambling Commission’s powers and resources

23 May 2023 – The Gambling Commission published Evidence Gaps & Priorities, a document outlining current evidence gaps and the Gambling Commission’s approach to address these over the next three years.

26 July 2023 – The GC Summer Consultation was published and included proposals to change the composition and decision-making processes of the Gambling Commission’s regulatory panels. Note that this change was not proposed in the White Paper.

17 October 2023 – DCMS published its consultation on the statutory gambling levy (the “DCMS Levy Consultation”), which set out proposals for the structure, distribution and governance of the statutory levy for gambling operators.

18 October 2023 – The GC Summer Consultation closed. At the time of writing, we await the response.

23 October 2023 – The Gambling Commission called licensees to participate in a user research programme aimed at sharpening the dataset received through regulatory returns.

22 November 2023 – The Government published the Autumn Statement 2023, which included proposals to change the structure of remote gambling taxation.

23 November 2023 – The Gambling Commission published its first ‘experimental’ statistics from the Gambling Survey of Great Britain, which will become the data source for the Gambling Commission’s official adult gambling participation and problem gambling prevalence statistics in 2024.

29 November 2023 – The GC Autumn Consultation was published and included proposed changes to the LCCP to increase the frequency of regulatory returns and standardise reporting periods across the industry and remove the current voluntary system for funding research, prevention and treatment, once the statutory gambling levy is in force.

14 December 2023 – The DCMS Levy Consultation closed. At the time of writing, we await the response.

15 December 2023 – Although not specifically proposed in the White Paper, the Gambling Commission published a further 2023 consultation on 15 December 2023 (the “GC December Consultation”), which included proposals to update its Statement of Principles for Determining Financial Penalties to make changes to the criteria for imposing a financial penalty and the methodology for determining the amount of the penalty and add new key reporting requirements to the LCCP.

21 February 2024 – GC Autumn Consultation closes.

15 March 2024 – GC December Consultation closes.

Want to read more?

Read more in the following Harris Hagan blogs:

Chapter 4: Dispute resolution and consumer redress

The process for the appointment of a gambling ombudsman was timetabled to commence in Spring/Summer 2023. Government expects the ombudsman to be accepting complaints within a year of the publication of the White Paper. We are not aware of any public updates in this area since the White Paper was published.

Want to read more?

Read more in the following Harris Hagan blog:

Gambling Ombudsman – a new approach to consumer redress

Chapter 5: Children and young adults

18 July 2023 – The Gambling Commission clarified its approach to vulnerability and its expectations of licensees, ahead of the publication of its updated customer interaction guidance for remote gambling licensees, which was issued on 23 August 2023.

31 October 2023 – The customer interaction guidance came into effect.

Want to read more?

Read more in the following Harris Hagan blog:

Gambling Commission publishes new remote customer interaction guidance

Chapter 6: Land-based gambling

26 July 2023 – DCMS published a consultation (the “DCMS Land-Based Consultation”), which included proposals to relax casino rules relating to table/machine ratios, improve age verification measures, introduce cashless payments on gaming machines and increase licensing authority fees.

4 October 2023 – The DCMS Land-Based Consultation closed. At the time of writing, we await the response.

Want to read more?

Read more in the following Harris Hagan blogs:

Want to hear more?

Please sign up to our blog to receive insight and commentary on the implementation of the White Paper during 2024, as well as other relevant industry news.

21Dec

DCMS Committee on gambling regulation publishes its report

21st December 2023 Harris Hagan 219

The Department for Culture, Media and Sport (“DCMS”) Committee on gambling regulation, appointed by the House of Commons, has today published its report with its conclusions and recommendations to Government.

The inquiry launched in December 2022, at a time when there was considerable uncertainty about the status of the Gambling White Paper. The original terms of reference were as follows:

What is the scale of gambling-related harm in the UK?
What should the key priorities be in the gambling White Paper?
How broadly should the term ‘gambling’ be drawn?
Is it possible for a regulator to stay abreast of innovation in the online sphere?
What additional problems arise when online gambling companies are based outside UK jurisdiction?

After the publication of the White Paper, on 27 April 2023, the terms of reference were broadened to include:

What are the most welcome proposals in the Gambling White Paper?
Are there any significant gaps in the Government’s reforms?
What are the potential barriers to the Government and Gambling Commission delivering the White Paper’s main measure by summer 2024, the Government’s stated aim?

Culture Media and Sport, Chair, Dame Caroline Dinenage MP, said:

“While gambling regulation should not overly impinge on the freedom to enjoy what is a problem-free pastime for the majority, more should be done to shield both children and people who have experienced problem gambling from what often seems like a bombardment of advertising branding at football and other sporting events. The Government needs to go further than the proposals in the White Paper and work with sports governing bodies on cutting the sheer volume of betting adverts people are being exposed to.”

The Committee received more than 160 submissions and held four oral evidence sessions.

Main conclusions and recommendations:

Implementation of the Gambling White Paper

The Government must set out a detailed timetable for the delivery of the White Paper’s proposals, with the Committee concerned that there was no mention of gambling legislation in the King’s Speech.
The Government and Gambling Commission should set out how they will address the growing trend of unlicensed gambling sites targeting the self-excluded. The Gambling Commission must also continue to work to improve its knowledge of the black market and its ability to monitor the number of British consumers gambling with illegal operators.

Online gambling protections

The Committee supports the principle of financial risk checks, but they must be minimally intrusive with customers’ financial data properly protected. There should be a pilot of the new system before the checks are fully implemented.
Stake limits for online slots should match those for electronic gaming machines in land-based venues and not exceed £5. Online deposit limits should be set by default and require customers to opt out rather than opt in.

Children and young adults

The Government should review the case for banning children’s access to social casino games, which are often playable on smartphones and simulate gambling activities and products.
The Committee supports the proposed enhanced online gambling protections for young adults aged 18-24, namely triggering a financial risk check at a lower monetary loss threshold and limiting the stake for online slots to £2. The Government, Gambling Commission, and gambling operators must ensure these measures do not unintentionally lead to more adults in this age group giving a higher age at account-creation.

Gambling advertising

There is an urgent need to better understand the effects of gambling advertising on the risk of harm. The evidence for a link between advertising and gambling harm currently appears much stronger than evidence indicating there is a risk of displacement to the black market if gambling advertising were restricted. The Government must commission research on the link between gambling advertising and the risk of gambling harm, including specifically for women and children.
The Government should have taken a more precautionary approach to gambling advertising in general – particularly to minimise children’s exposure. While a complete ban on gambling advertising would not be appropriate, there is still scope for further regulation beyond that proposed by the Government.
The Government should work with the Premier League and the governing bodies of other sports to ensure that the gambling sponsorship code of conduct contains provision to reduce the volume of gambling adverts in stadia. A higher proportion of gambling advertising in stadia should be dedicated to safer gambling messaging. The Government must require sports governing bodies to publish the code without further undue delay.

Land-based gambling

Customers who prefer to pay on electronic gaming machines using cash should continue to be able to do so on all machines following any introduction of cashless payments.
The Government must ensure that the new settlement arising from the review of the Horserace Betting Levy mitigates the impact of the White Paper’s reforms on the racing industry and ensuring British racing’s future.

Gambling research, prevention and treatment

The Committee supports the proposed structure and governance of the new statutory levy to be imposed on operators in the industry to fund gambling research, prevention and treatment. The Government must ensure that service providers currently operating via the voluntary funding system are adequately supported in the transition to a statutory levy. There should be a new national strategy for reducing gambling harms.

A Gambling Ombudsman

The scope of the new gambling ombudsman should include all disputes between gambling operators and their customers, not only those relating to social responsibility failings.

Government has two months to respond.

Please get in touch if you would like discuss any of the proposals in the White Paper or would like any assistance preparing a response to the Gambling Commission’s current open consultations: the Autumn consultation, which includes proposals relating to incentives, customer-led tools, customer funds protection and regulatory returns reporting (closing 21 February 2024) and the December consultation on proposals relating to financial penalties and financial key event reporting (currently closing 15 March 2024).

18Dec

Bahar Alaeddini named in the top 10 Most Influential Women

18th December 2023 Harris Hagan 215

We are very proud to announce that Partner, Bahar Alaeddini, has been recognised in the top 10 Most Influential Women of 2023 by iGamingBusiness.

The award, now in its sixth year, highlights the outstanding contributions made by women who have not only excelled in their roles, but have also made a difference by influencing change within their workplaces and across the wider industry. This honour recognises Bahar’s continued exceptional impact on the gambling industry since joining Harris Hagan in 2012, and reflects the ethos and diversity of the firm, with 50% of both our partners and lawyers being female.

Bahar advises many of the world’s largest online and land-based gambling companies, regulators, financial institutions, and private equity firms on gambling law and regulation. Bahar is at the forefront of thought leadership in the gambling sector, sharing her extensive experience and insight by authoring many articles on a wide range of topics, including acting as the editor of the Chambers Global Practice Guide on Gaming Law. Bahar was named earlier this year as an Emerging Leader of Gaming 40 under 40 and is General Counsel of the International Association of Gaming Advisors and top-ranked in Chambers UK and The Legal 500.

01Dec

White Paper Series: Gambling Commission launches Autumn 2023 consultation

1st December 2023 Harris Hagan 232

On 29 November 2023, the Gambling Commission launched its Autumn 2023 consultation (the “Autumn Consultation”). It is the Gambling Commission’s second consultation addressing its commitments within the White Paper, following the Summer 2023 consultation.

The Autumn Consultation sets out five proposed changes to the Licence Conditions and Codes of Practice (“LCCP”) and Remote Gambling and Software Technical Standards (“RTS”), several of which were foreshadowed in the Gambling Commission’s Advice to Government in April 2023. These include:

Socially responsible incentives

The Gambling Commission wants to make changes to ensure that incentives such as free bets and bonuses are constructed in a socially responsible manner and do not encourage excessive or harmful gambling. Proposals include banning or limiting (to a maximum of 1, 5 or 10 times) the use of wagering requirements in promotional offers and banning the mixing of product types (e.g. betting, bingo, casino and lotteries) within incentives for new and existing customers, as well as updating social responsibility code provision 5.1 of the LCCP to make it explicit that incentives should be constructed in a manner that does not lead to excessive or harmful gambling.

Customer-led tools

The proposals include amendments to the RTS to ensure customers can seamlessly use pre-commitment tools (such as deposit limits) to maintain awareness and control over their gambling. The Gambling Commission is also seeking stakeholder views on: (a) minimising friction in the customer journey when they choose to use customer-led tools; and (b) cross-operator deposit limits, the prospect of which is sure to be a key area of focus in industry responses.

Improved transparency on customer funds in the event of insolvency

The Gambling Commission is seeking to improve the transparency of operators who have a ‘not protected’ rating (under the Gambling Commission’s rating system) in relation to customer funds. It proposes an addition to the LCCP, to require licensees to remind customers, no more than once every 6 months, that their funds are not protected in the event of insolvency throughout the customer relationship.

Changes to the frequency of regulatory returns

As we previously discussed, the Gambling Commission is proposing to amend the LCCP to require all regulatory returns be submitted on a quarterly basis.

Notably, the Gambling Commission states it will continue to engage with industry on the “final specification of fields for reporting” outside of the consultation process. We understand that this will be conducted through the Gambling Commission’s User research programme shortly, which we explained in a recent blog.

Removing obsolete Gambling Commission requirements due to the Government’s upcoming statutory levy (LCCP RET list)

Running alongside the Government’s consultation on the statutory levy, the Autumn Consultation proposes to remove the current requirement to make an annual financial contribution to fund research, prevention and treatment (“RET”) from the LCCP, once the statutory levy is introduced or at the beginning of the financial year in which the levy is introduced.

For further information about the statutory levy (and the Government consultation), please see our recent blog.

Other industry updates

The Gambling Commission explains that it is currently analysing the responses to its Summer 2023 consultation, which closed on 18 October 2023, and will release “one or more responses” to that consultation in 2024. It will also be launching another consultation on two “business as usual” matters shortly. This will include proposals addressing the clarity and transparency of the Gambling Commission’s calculation of financial penalties as well as licensees’ reporting of financial key events.

Next steps

The Autumn Consultation will be open for 12 weeks, closing on 21 February 2024. Responses can be submitted online, or by post to the Gambling Commission’s Policy Team.

We strongly encourage all licensees and stakeholders to review and respond to the Autumn Consultation. Please get in touch with us if you would like to discuss this matter further or require our assistance preparing responses.

29Nov

Chambers Gaming Law 2023 Global Practice Guide

29th November 2023 Harris Hagan 217

We are pleased to announce that Bahar Alaeddini has reprised her role as Contributing Editor to the Chambers Global Practice Guide for Gaming Law 2023, and Jessica Wilson has again contributed as a co-author. The latest edition of the Gaming Law 2023 guide is now live and describes the licensing and regulatory regimes in 35 jurisdictions, including many of the major global jurisdictions.

In a year that saw a number of significant developments and regulatory updates in the UK and abroad, Gaming Law 2023 is a helpful guide to lawyers, gambling businesses and others in the industry. It provides the latest legal information on a range of topics, including: land-based and online gambling; B2C and B2B licences; application requirements; affiliates; white labels; responsible gambling; AML legislation; restrictions on advertising; acquisitions and changes of control; trends in social gaming, esports, fantasy sports and blockchain; and taxation.

Harris Hagan contributed to the following parts of the publication:

Key trends are covered by jurisdiction under the Trends and Developments section, and the practice guide also provides users with the opportunity to perform jurisdiction comparisons using the Compare locations tool.

Please use the above links to review our contributions and use the practice guide.

27Nov

The Legal 500 Country Comparative Guide 2023 – Gambling Law

27th November 2023 Harris Hagan 193

In its second year of publication, Partner Bahar Alaeddini and Associate Francesca-Burnett Hall have jointly contributed to the UK chapter of The Legal 500: Gambling Law Comparative Guide 2^nd Edition (the “Guide”), with Bahar once again acting as contributing editor.

UK-Chapter Download

The publication – which this year spans 19 jurisdictions – gives readers an overview of gambling law, regulatory and licensing requirements in various jurisdictions and the UK, on matters including:

key gambling legislation and the legal definition of gambling;
types of gambling licences available, with a headline of the application procedures;
prohibited gambling products;
information on gambling advertising and marketing affiliates;
penalties for unlawful gambling;
anti-money laundering and safer gambling requirements;
shareholder reporting and approval thresholds; and
the regulator’s enforcement and sanction powers.

Of particular interest in this year’s edition of the Guide are the key regulatory developments and proposals for reform expected over the next 12-24 months, including those set out in the White Paper, which we outline in the UK chapter.

You can read the Guide and compare jurisdictions here.

19Oct

Harris Hagan retains Band 1 ranking in Chambers and Partners

19th October 2023 Harris Hagan 231

We are delighted to announce that Harris Hagan is ranked in Band 1 of Chambers and Partners UK 2024 for Gaming for the 20^th consecutive year.

“The team at Harris Hagan is comprised of experts in their field and is very accomplished at handling the complex landscape of gambling regulation in the UK.”

Partners John Hagan and Bahar Alaeddini continue to be recognised in Band 1. Consultants Julian Harris and Hilary Stewart Jones are ranked as Senior Statespeople. Senior Associates David Whyte and Gemma Boore, together with Associate Francesca Burnett-Hall, continue to be recognised as Associates to Watch. Together they constitute 7 of the 27 gaming lawyers recognised in the directory, befitting our status as a leading specialist gambling law firm. We were also invited by Chambers to write the introduction to the practice area.

We received many positive testimonials, including:

“The lawyers at Harris Hagan are top legal specialists in the remote gaming industry and have been able to assist with all our requests, with the ability to adapt to our business and commercial expectations.”

“John is the go-to person for reliable, practical and sensible advice. He has vast experience across the gambling sector and is able to draw on this to support our business.”

“Bahar is a master at solving complex issues and has an encyclopaedic knowledge of gaming laws and regulations.”

“David is very responsive and knows the industry, regulations and landscape well.”

“Gemma is very easy to deal with as well as very proficient in every aspect of her work.”

“Francesca is always available and very diligent.”

In view of the sensitive nature of much of our work, it is our long-held policy not to name clients in directories, but you know who you are, and we thank you for your continuing instructions and for helping us achieve these impressive rankings.

Harris Hagan

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