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Inspection on 24/10/07 for Moorlands Care Home

Also see our care home review for Moorlands Care Home for more information

This inspection was carried out on 24th October 2007.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

The inspector made no statutory requirements on the home as a result of this inspection and there were no outstanding actions from the previous inspection report.

What follows are excerpts from this inspection report. For more information read the full report on the next tab.

What the care home does well

Moorlands provide a number of alternatives at meal times, and the menu is also in the form of pictures to help those who may have difficulty reading decide what they would like for lunch. There is a very pleasant private sitting area outside for residents, and there is good information available about the home for prospective residents.

What has improved since the last inspection?

All of the statutory requirements and good practice recommendations made at the last key inspection have been met.

What the care home could do better:

As a result of this key inspection visit one statutory requirement has been made relating to resident`s care planes being reviewed regularly. In addition seven good practice recommendations have been made, which relate to: Care plans being reviewed on a monthly basis, recording resident`s wishes in relation to their funeral arrangements, amending the complaints procedure to include contact details for Social Services, putting a net curtain up at a window in the downstairs bathroom for added privacy, reviewing smoking policy and practice in the light of the new legislation, holding regular monthly resident`s meetings and having formal supervision sessions for staff a minimum of six times a year.

CARE HOMES FOR OLDER PEOPLE Moorlands Care Home 104 Church Lane Brinsley Nottinghamshire NG16 5AB Lead Inspector Rob Cooper Unannounced Inspection 24th October 2007 10:20 X10015.doc Version 1.40 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Older People. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Moorlands Care Home Address 104 Church Lane Brinsley Nottinghamshire NG16 5AB Telephone number Fax number Email address Provider Web address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 01773 781381 managermoorlands@regalcarehomes.com www.regalcarehomes.com Regal Care Homes Ltd Position Vacant Care Home 40 Category(ies) of Dementia - over 65 years of age (10), Old age, registration, with number not falling within any other category (40) of places Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: 1. Regal Care Homes Limited is registered to provide personal care with nursing for service users of both sexes at Moorlands Care Home whose primary needs fall within the following categories :Old Age, not falling in any other category (OP) 10 2. 3. Dementia, over 65 years DE(E) 10 No one under the age of 65 years may be admitted to Moorlands Care Home The maximum number of service users to be accommodated at Moorlands Care Home is 40 11th August 2006 Date of last inspection Brief Description of the Service: Moorlands is a care home providing personal and nursing care for 40 older people and 4 beds are available to care for people with a terminal illness. The home is run by a company called Regal Care who are based in Kent, who purchased the home in August 2005. The home is located in the village of Brinsley close to shops, pubs, the post office and other amenities. The home was opened in 1986 and consists of an extended domestic dwelling. 32 of the home’s bedrooms are single, and all of the bedrooms have en-suite facilities. Bedrooms are located on 2 floors and there is a passenger and stair lift. The home has a large well-laid garden that is well maintained and easily accessible. There is car parking available for 20 cars Fees: £290 - £561 dependent on the individual’s needs assessment and funding arrangements. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was an unannounced visit as part of the key inspection process – so that no one at Moorlands knew that the inspection visit was going to take place. The visit took approximately four hours through the middle of the day, with one inspectors present. The method used to carry out this key inspection visit was to send out an Annual Quality Assurance Assessment (known as an AQAA) for Moorlands to self assess their service. This had been returned, and helped to inform this inspection process. This was followed with a visit to Moorlands, where a method called case tracking was used; this involved identifying four residents and looking at their individual files and making a judgement about the quality of care they are receiving, and if their needs are being met. This was done by a partial tour of Moorlands, looking at the activities on offer, and talking to two residents, and two members of staff about the quality of the service, and their experiences of living and working at Moorlands. Currently Moorlands does not have a registered manager in post, as a new manager has recently been appointed, but has yet to take up their position. As a result Moorlands deputy manager provided much of the information during this key inspection visit. On the day of this inspection there were thirty-one residents in residence. Prospective residents can obtain information about Moorlands direct from the care home, and this would include seeing previous inspection reports prepared by the Commission for Social Care Inspection, or further information can be obtained from their website at: www.regalcarehomes.com What the service does well: Moorlands provide a number of alternatives at meal times, and the menu is also in the form of pictures to help those who may have difficulty reading decide what they would like for lunch. There is a very pleasant private sitting area outside for residents, and there is good information available about the home for prospective residents. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 6 What has improved since the last inspection? What they could do better: Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. The summary of this inspection report can be made available in other formats on request. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–6) Health and Personal Care (Standards 7-11) Daily Life and Social Activities (Standards 12-15) Complaints and Protection (Standards 16-18) Environment (Standards 19-26) Staffing (Standards 27-30) Management and Administration (Standards 31-38) Scoring of Outcomes Statutory Requirements Identified During the Inspection Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 8 Choice of Home The intended outcomes for Standards 1 – 6 are: 1. 2. 3. 4. 5. 6. Prospective service users have the information they need to make an informed choice about where to live. Each service user has a written contract/ statement of terms and conditions with the home. No service user moves into the home without having had his/her needs assessed and been assured that these will be met. Service users and their representatives know that the home they enter will meet their needs. Prospective service users and their relatives and friends have an opportunity to visit and assess the quality, facilities and suitability of the home. Service users assessed and referred solely for intermediate care are helped to maximise their independence and return home. The Commission considers Standards 3 and 6 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 12&3 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. Prospective residents at Moorlands had sufficient information before they moved in to make an informed choice about where to live. Currently residents are well informed about the services Moorlands offers Moorlands do not offer intermediate care. EVIDENCE: Both the statement of purpose and service user guide for Moorlands were seen. Both documents contained all of the information, which Care Homes Regulations say that they should. Both documents were written in an easy to understand style, and had been reviewed and updated within the last year. Regal care homes do have a web site, which contains further information and photographs of Moorlands, although this is currently being updated. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 9 Four residents files were seen as part of the case tracking process, and each file contained either a contract or a statement of terms and conditions within the home. Each of the four files seen contained an assessment of need, which had been completed in-house, prior to the resident moving in to Moorlands. There was clear evidence that the resident’s care needs had been based upon the assessments. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 10 Health and Personal Care The intended outcomes for Standards 7 – 11 are: 7. 8. 9. 10. 11. The service user’s health, personal and social care needs are set out in an individual plan of care. Service users’ health care needs are fully met. Service users, where appropriate, are responsible for their own medication, and are protected by the home’s policies and procedures for dealing with medicines. Service users feel they are treated with respect and their right to privacy is upheld. Service users are assured that at the time of their death, staff will treat them and their family with care, sensitivity and respect. The Commission considers Standards 7, 8, 9 and 10 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 7 8 9 10 & 11 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. The residents have their health and personal care well managed, supported and recorded by the staff at Moorlands. EVIDENCE: The resident’s files contained a good selection of care plans and risk assessments aimed at meeting their needs. However there was no evidence that care plans or risk assessments were being reviewed regularly. National Minimum Standards recommend that care plans and risk assessments are reviewed on a monthly basis to ensure that the resident’s changing needs are still being met. All of the files that were seen contained care plans related to resident’s health care needs, and these were clear and detailed, with risk assessments for bed rails where needed, signed by the resident or their relative. Two residents were asked about seeing their doctor, and all said that they had a local doctor Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 11 who either came to see them at the home (arranged through the staff) or they visited the surgery – depending on their particular need, although a doctor does usually visit them at Moorlands. Alliance Pharmacy provides Moorlands with their medication. An inspection of the storage, and booking in and out procedures showed that medication is handled safely and there is a clear audit trail for medication from the point of ordering to administration and/or disposal. Administration records were inspected and found to be complete. The lunchtime medication round was partially observed, and there were no concerns seen in the administration procedures. No resident at Moorlands currently self-medicates. During the course of the inspection visit a number of staff to resident interactions were observed. These were seen to be polite and respectful, and staff were observed knocking on resident’s doors before entering. Two residents were spoken with during the inspection, and each one said that they thought the staff treated them well. One saying: “The staff are very nice” while a second when asked if the staff were kind said: “Yes they are, they are marvellous.” Each of the four resident’s files contained a one-line space on the admission sheet for recording the resident’s last wishes/ funeral arrangements. Two were left blank, a third said: “not said” while the fourth file had the whole sheet missing. It is strongly recommended that resident’s wishes at the time of their death are discussed and recorded, preferably within a care plan which details who is to be contacted, and the exact funeral arrangements. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 12 Daily Life and Social Activities The intended outcomes for Standards 12 - 15 are: 12. 13. 14. 15. Service users find the lifestyle experienced in the home matches their expectations and preferences, and satisfies their social, cultural, religious and recreational interests and needs. Service users maintain contact with family/ friends/ representatives and the local community as they wish. Service users are helped to exercise choice and control over their lives. Service users receive a wholesome appealing balanced diet in pleasing surroundings at times convenient to them. The Commission considers all of the above key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 12 13 14 & 15 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. Residents at Moorlands have a lifestyle that reflects their cultural, social and religious interests, and needs. EVIDENCE: A programme of activities was seen, and evidence that different activities are organised. Two residents were asked about activities: One said “There’s usually something happening”, while the other said: “I don’t get involved, as I stay here in my room, but I think that there are activities organised, and someone comes in to chat to me.” Moorlands employ an activity co-ordinator who arranges activities for the residents, and ensures that there is a programme of activities in place. Moorlands have open visiting times, and both residents who were spoken with said that their families came to see them, and the staff always made them welcome. A newsletter had been produced in July 2007, which was aimed at keeping relatives informed about events at Moorlands, and staff said that another issue should be produced soon. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 13 There are a number of good signs around Moorlands to help point residents and visitors in the right direction. Many of the residents at Moorlands have high dependency needs or some degree of dementia, however staff were seen asking residents, and helping them in positive ways, to help with their choice and decision making. One resident who was asked, who had high physical needs, said that: “the staff always ask me what I want, and they try to help me with making choices.” Observation of the lunchtime meal showed that the quantities and quality of the food were very good. Two residents when asked said that the food was: “Very good, very nice” and “I do enjoy it (the food) here.” The menu showed a good variety and selection of food available, and all of the records relating to food storage and preparation evidenced that there was good and safe practice within the kitchen. The menu is available in a pictorial form, which is very good practice for those residents who may be unable to read or understand the written word, and there was a very good variety of choice around meals for residents, with several different options to cater for differing needs and tastes. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 14 Complaints and Protection The intended outcomes for Standards 16 - 18 are: 16. 17. 18. Service users and their relatives and friends are confident that their complaints will be listened to, taken seriously and acted upon. Service users’ legal rights are protected. Service users are protected from abuse. The Commission considers Standards 16 and 18 the key standards to be. JUDGEMENT – we looked at outcomes for the following standard(s): 16 & 18 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. Residents at Moorlands are safe, and their complaints are taken seriously and dealt with. EVIDENCE: Moorlands have received twenty complaints since the last key inspection in August 2006. A review of these complaints showed that they had been dealt with in line with Moorland’s complaints procedure. Two residents were asked about making complaints; both said they had not felt the need, but knew how to, and who to complain to. The complaints procedure was seen, and needs to be amended to direct complainants to Social Services rather than the Commission for Social Care Inspection, if they are not satisfied with Moorland’s response to their complaint. A review of staff training records showed that twenty-four of the staff team were had attended a safeguarding adults training course during the past year, with the most recent course held this month. This training is aimed at raising staff awareness of abuse, and informing them of the correct procedures to follow should they encounter abusive practice. The principal is that through raising the issues, residents are offered greater protection against abusive practice. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 15 Environment The intended outcomes for Standards 19 – 26 are: 19. 20. 21. 22. 23. 24. 25. 26. Service users live in a safe, well-maintained environment. Service users have access to safe and comfortable indoor and outdoor communal facilities. Service users have sufficient and suitable lavatories and washing facilities. Service users have the specialist equipment they require to maximise their independence. Service users’ own rooms suit their needs. Service users live in safe, comfortable bedrooms with their own possessions around them. Service users live in safe, comfortable surroundings. The home is clean, pleasant and hygienic. The Commission considers Standards 19 and 26 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 19 & 26 Quality in this outcome area is adequate; this judgement has been made using available evidence including a visit to this service. Residents at Moorlands live in a safe, clean and comfortable home, with their personal possessions around them. EVIDENCE: A partial tour of Moorlands showed it to be comfortable and well maintained. Two residents were asked about the building, each resident said they had a comfortable bedroom, and that they liked living there. An internal window from the downstairs bathroom has opaque glass, but it is still possible to see through, the addition of a net curtain or some other form of additional screening would improve the privacy and dignity of residents using that particular bathroom. Outside there is a pleasant garden area with a secure private lawned seating area. In the light of the new smoking legislation Moorlands should consider their smoking policies and arrangements. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 16 Staff were seen cleaning in various areas of Moorlands during the inspection visit, and the building was found to be clean. Two residents were asked about the cleanliness, and both said that they were quite happy, and that they thought the staff worked hard to keep the home clean and tidy. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 17 Staffing The intended outcomes for Standards 27 – 30 are: 27. 28. 29. 30. Service users’ needs are met by the numbers and skill mix of staff. Service users are in safe hands at all times. Service users are supported and protected by the home’s recruitment policy and practices. Staff are trained and competent to do their jobs. The Commission consider all the above are key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 27 28 29 & 30 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. Staff at Moorlands have been recruited professionally, and are competent and trained to do their jobs. EVIDENCE: A review of the staffing rota and staffing levels at Moorlands showed that there were enough staff currently employed to meet the resident’s needs. Two residents were asked about staffing levels, and both said that they thought there were enough staff, as did three members of staff who were also asked. The care industry considers National Vocational Qualifications (NVQ) to level II in care to be the basic qualification for staff working in residential care. A review of the training records showed that currently there are six staff members with NVQ qualifications, a further five are currently studying for their NVQ level III. In addition Moorlands employs seven qualified nurses. It is recommended that a minimum 50 of the care team are NVQ qualified as a minimum, and the staff team at Moorlands are currently working towards this figure. Four staff files were seen, and these contained all of the information that would show that staff had been recruited in a safe manner – in that applicants had to fill out an application form, provide two written references and undergo a Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 18 Criminal Records Bureau check. A review of the documentation showed that there were no issues raised in the recruitment process, and that it was possible to prove the process had worked to protect residents. Discussions with two staff members about their recruitment evidenced that they had undergone preemployment checks, and had not started working until those checks had been completed. A review of the staff training records showed that Moorlands does have a training plan for its staff, and that there are staff training courses planned for the coming months. The records showed that staff were receiving the skills training to be able to do their jobs, and discussions with two members of staff supported this view, and provided evidence of the different training courses staff had attended, including training in the mandatory areas – fire, food hygiene etc. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 19 Management and Administration The intended outcomes for Standards 31 – 38 are: 31. 32. 33. 34. 35. 36. 37. 38. Service users live in a home which is run and managed by a person who is fit to be in charge, of good character and able to discharge his or her responsibilities fully. Service users benefit from the ethos, leadership and management approach of the home. The home is run in the best interests of service users. Service users are safeguarded by the accounting and financial procedures of the home. Service users’ financial interests are safeguarded. Staff are appropriately supervised. Service users’ rights and best interests are safeguarded by the home’s record keeping, policies and procedures. The health, safety and welfare of service users and staff are promoted and protected. The Commission considers Standards 31, 33, 35 and 38 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): 31 33 35 36 & 38 Quality in this outcome area is good; this judgement has been made using available evidence including a visit to this service. Moorlands is a safe, well-managed care home with good systems for ensuring its quality in place. EVIDENCE: A new manager has recently been recruited by Moorlands, and is due to take up her post shortly. The new manager will be supported by regal care homes to complete and submit her application to the Commission for Social Care Inspection to be the new registered manager. Moorlands has a quality assurance system, which relies on questionnaires being filled in by residents and visitors. Copies of the questionnaire were seen together with evidence that the questionnaires had been evaluated, and an Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 20 action plan produced. Staff are also given a questionnaire around motivation, with a view to improving the quality of care, and staff support. Resident’s meetings have taken place in the past, but have slipped recently due to the managerial changes taking place. Staff anticipate they will resume regularly in the near future. Moorlands have a ‘small cash needs’ system for resident’s personal finances. The records for four residents were checked, and no errors were found. Receipts were in place to evidence expenditure and all cash totals tallied. Two residents were asked about the staff ‘looking after’ their money, and both said they could get it when they wanted. Moorlands operate a supervision system, with staff having formal supervision with a senior member of staff. Records relating to the staff’s formal supervision were seen and these indicated that staff members were not having supervision regularly – National Minimum Standards recommend a minimum of six times a year. Two staff members were spoken with about formal supervision and said that they were having formal supervision sessions although they were a “little bit hit and miss” with regard to how often. All of the staff said that the acting manager was very approachable, and that they felt well supported within their jobs. Many different health & safety records were seen, including the fire safety records – weekly tests, emergency lighting tests and extinguisher maintenance records, and the Control of Substances Hazardous to Health (COSHH) records, all were found to be correct and up-to-date, which evidenced that the residents and the staff are living and working in a safe environment. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 21 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Older People have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME Standard No Score 1 2 3 4 5 6 ENVIRONMENT Standard No Score 19 20 21 22 23 24 25 26 3 3 3 X X N/A HEALTH AND PERSONAL CARE Standard No Score 7 2 8 3 9 3 10 3 11 2 DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 3 15 4 COMPLAINTS AND PROTECTION Standard No Score 16 2 17 X 18 3 2 X X X X X X 3 STAFFING Standard No Score 27 3 28 3 29 3 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 X 2 X 3 2 X 3 Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 22 Are there any outstanding requirements from the last inspection? No STATUTORY REQUIREMENTS This section sets out the actions, which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard OP7 Regulation Requirement Timescale for action 31/12/07 Regulation Resident’s care plans and risk 15 (2) b assessments must be reviewed regularly to ensure that the plans continue to meet resident’s needs. RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. 2. Refer to Standard OP7 OP11 Good Practice Recommendations Resident’s care plans and risk assessments should be reviewed on a monthly basis. Resident’s wishes at the time of their death should be recorded within their file, preferably within a specific care plan with sufficient detail to direct staff when the time arrives. The complaints procedure should be amended to direct complainants to Social Services rather than the Commission for Social Care Inspection, should they not be satisfied with Moorland’s response to their complaint. A net curtain or other form of screening to the internal window in the downstairs bathroom should be put in place to increase the privacy and dignity of residents using that DS0000065350.V351892.R01.S.doc Version 5.2 Page 23 3. OP16 4. OP19 Moorlands Care Home 5. 6. 7. OP19 OP33 OP36 bathroom. The new smoking legislation means that Moorlands should review its policies and practice with regard to smoking for residents and staff. Resident’s meetings should be held on a regular basis, ideally monthly. Formal staff supervision sessions should be arranged for all staff a minimum of six times a year. Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 24 Commission for Social Care Inspection Derbyshire Area Office Cardinal Square Nottingham Road Derby DE1 3QT National Enquiry Line: Telephone: 0845 015 0120 or 0191 233 3323 Textphone: 0845 015 2255 or 0191 233 3588 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Moorlands Care Home DS0000065350.V351892.R01.S.doc Version 5.2 Page 25 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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