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Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching

  • To: "Angie Graves" <angie@xxxxxxxxxxxx>, "Aikman-Scalese, Anne" <AAikman@xxxxxxxxxx>
  • Subject: Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching
  • From: "WUKnoben" <wolf-ulrich.knoben@xxxxxxxxxxx>
  • Date: Tue, 17 Mar 2015 15:36:23 +0100

I do agree that the council might be the right entity to following-up . 
Although I think in doing this the council has to refer again to the SGs/Cs to 
bring their respective rules (if there are any) into a coordinated form.

FYI here is an excerpt of the ISPCP constituency Operating Procedures: 

<<...
Applicants will be asked to declare whether the entity is a member of another 
GNSO constituency or will participate in ICANN policy formulation in ways other 
than their ISPCP membership.

Applicants representing entities which do participate elsewhere are required to 
demonstrate that their ISPCP membership will be divisionally oriented meaning 
that separate individuals will represent those divisions in ICANN affairs, and 
that the entity will only represent ISP and Connectivity Providers perspectives 
within the ISPCP.

In the interest of transparency, members are required to provide information to 
the secretariat whenever there are any material changes to their status or that 
of their organisation. 

...>>

This looks more or less like a code of conduct with criteria to be talked about 
on a case by case. 

Best regards

Wolf-Ulrich



From: Angie Graves 
Sent: Tuesday, March 17, 2015 1:13 AM
To: Aikman-Scalese, Anne 
Cc: Mary Wong ; mailto:gnso-improvem-impl-sc@xxxxxxxxx ; Ron Andruff 
Subject: Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching

Dear all, 

If 6.1.2(j) is mentioned in the response to Martin, the mention should be in 
the context of acknowledgement that 6.1.2(j) is the source of the loophole that 
Martin discovered.

Also, as refresher, here is an excerpt from Martin's email to the SCI:
"The point in question is in relation to the ability for a member of multiple 
SGs and Cs to regularly switch their voting rights between these groups in a 
tactical manner, so as to apply votes for elections/decisions where they may 
have concerns with lack of representation within a specific group, at a 
specific time. Whilst they may only vote in one of the SGs or Cs, there is no 
restriction as to when and how frequently they may switch their voting power 
between these groups.  This could be too flexible and potentially allow the 
system to be exploited."



Regarding raising this to the GNSO Council, mention of 6.1.2(j) by the SCI 
should be accompanied by mention of 6.2.6(d), as they are composed of identical 
language: "No legal or natural person should be a voting member of more than 
one Group."

Regards,

Angie



On Mon, Mar 16, 2015 at 7:47 PM, Aikman-Scalese, Anne <AAikman@xxxxxxxxxx> 
wrote:

  Mary,

  Our  response to Martin should definitely include a reference to GNSO 
Operating Procedure 6.1.2(j) and Martin can take this up with the BC.  We 
should not omit a relevant GNSO Operating Procedure when responding to this 
question.

  Thank you,

  Anne




       Anne E. Aikman-Scalese, Of Counsel
       
        Lewis Roca Rothgerber LLP | 
       
        One South Church Avenue Suite 700 | Tucson, Arizona 85701-1611
       
        (T) 520.629.4428 | (F) 520.879.4725
       
        AAikman@xxxxxxxxxx | www.LRRLaw.com
       
       
       




       
       



  From: owner-gnso-improvem-impl-sc@xxxxxxxxx 
[mailto:owner-gnso-improvem-impl-sc@xxxxxxxxx] On Behalf Of Mary Wong
  Sent: Monday, March 16, 2015 4:26 PM
  Cc: <gnso-improvem-impl-sc@xxxxxxxxx>; Ron Andruff


  Subject: Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching


  Thanks for the detailed feedback, Greg.  I will amend the note to reflect 
your suggestions, including to take up the matter with the Council directly 
rather than with individual SG/Cs. 



  On the question of whether the BC’s question raises the broader question of 
the effectiveness of Section 6.1.2(j), this may be something the SCI can 
include in its review plan should the Council choose not to refer the topic to 
the SCI at this time. As such, while we may not include it in the note to the 
BC, the SCI can certainly add it to its list of potential topics for 
further/future review at the appropriate time. 



  Thanks and cheers

  Mary



  Mary Wong

  Senior Policy Director

  Internet Corporation for Assigned Names & Numbers (ICANN)

  Telephone: +1 603 574 4892

  Email: mary.wong@xxxxxxxxx









  From: Greg Shatan <gregshatanipc@xxxxxxxxx>
  Date: Monday, March 16, 2015 at 17:07
  To: Mary Wong <mary.wong@xxxxxxxxx>
  Cc: "<gnso-improvem-impl-sc@xxxxxxxxx>" <gnso-improvem-impl-sc@xxxxxxxxx>, 
Ron Andruff <randruff@xxxxxxxxxxxxxxx>
  Subject: Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching



    I am not entirely in agreement with the note or its underlying premises. 



    I do agree that this is not an SCI issue in the sense that we cannot 
generate our own issues, and that our issues can only come from the Council or 
from a "group chartered by the Council."  The Business Constituency is neither, 
since it is chartered by ICANN.



    However,I believe this is an issue relating to the effectiveness and 
functioning of the GNSO Operating Procedures, and specifically, Section 
6.1.2(j), which states that"No legal or natural person should be a voting 
member of more than one Group."  The BC is questioning whether this Section of 
the GNSO Operating Procedures is effective as currently drafted, given the 
increasing number of stakeholders eligible to join multiple SGs.  The GNSO 
Operating Procedures are maintained by the GNSO Council.  Therefore, this seems 
to me to be an issue that is within the remit of the Council and which the 
Council could the refer to the SCI after appropriate deliberations.  I think it 
goes too far to say that this is outside the Council's purview because each 
SG/C is responsible for its own charter.  As you acknowledge later on in the 
note, the Charters are subject to a number of principles in the GNSO Operating 
Procedures.  To the extent that this relates to one of those principles (and it 
does) this is appropriate for the Council to take up.



    Furthermore, the Council, which meets regularly, would seem to be a better 
forum for shepherding this issue, as opposed to the leaderships of the SG/C's, 
which do not meet regularly.  If the leaderships did meet and decide that  a 
common rule for all GNSO SG/C needed to be adopted to guard against 
vote-switching, the natural method for creating and adopting such a rule would 
be for the GNSO Council (and by extension, the SCI) to amend GNSO Operating 
Procedures Section 6.1.2(j).  Sending this issue through the SG/C leaderships 
would just delay consideration.



    It seems to me that, at the very least, we should include in this letter 
(or email) as one of the suggestions that the BC bring this up before the 
Council.  We should also not simply say we are unable to take up the issue.  We 
should say that we are unable to take up the issue unless it is referred to us 
by the Council.



    I am also not particularly enthusiastic about suggesting that the BC 
consult with other SG/C's on a piecemeal basis.  This is the kind of problem 
that cries out for a GNSO-wide solution, so that there are consistent rules and 
results, and we don't have certain SG/C's that are friendly to "vote-switchers" 
and others that are not.  In any event, I don't think this should be premised 
in any way on whether other SG/C's are undergoing a charter review.  This issue 
is timely because this is an increasingly realistic problem, not because an 
SG/C is revising its charter.



    Overall, I just think this should be more neutral in terms of the options, 
and include the Council (and a review of 6.1.2(j)) as one of those options.  If 
the BC chooses to consult with leaderships, that should be fine.  If the BC 
chooses to take that route, that should be fine, too.



    Greg



    On Mon, Mar 16, 2015 at 4:11 PM, Mary Wong <mary.wong@xxxxxxxxx> wrote:

    Hello everyone,



    Since we have received no objections from anyone, and both Amr and Angie 
agreed that the SCI should proceed with a reply to Martin Sutton as sketched 
out by Angie and me, we have drafted the following email that Anne as SCI chair 
can send if it meets the purpose. Since we thought it would make sense to keep 
the note brief, we thought that sending it in the form of an email rather than 
as a separate letter would work too.



    On Amr’s question about SG/C charter revisions, our understanding is that 
each SG/C – in the current GNSO structure – is obliged to include procedures 
for amending their charters therein. However, under the previous structure, and 
more specifically in the transitional period to the current structure with four 
new SGs largely supplanting the old Constituency structure, each SG Charter had 
to be submitted to and approved by the ICANN Board. This took place between 
July 2009 and June 2011. Similarly, each existing Constituency had to be 
renewed and reconfirmed by the Board – this took place in early 2009.



    Our suggested draft text for a reply to Martin follows below.





    Dear Martin,



    Thank you for reaching out to me and the GNSO’s Standing Committee on 
Improvements Implementation (SCI) on 26 February 2015. The SCI has discussed 
the question that the Business Constituency (BC) raised concerning the 
possibility of vote-switching across different GNSO groups, and while we agree 
that this situation is not currently addressed by the GNSO’s rules or 
procedures, we have also concluded that this specific issue lies outside the 
remit of the SCI. 



    The SCI was chartered by the GNSO Council to review and assess the 
effectiveness and functioning of the GNSO Operating Procedures and Working 
Group Guidelines. As such, questions relating to Stakeholder Group/Constituency 
(SG/C) operations are beyond the scope of our charter, for the simple reason 
that the ICANN’s bottom-up community structure is based on each SG/C defining 
its own governance rules. The drafting, scoping, adoption, review and amendment 
of each group’s charter is therefore a matter for that group’s internal 
deliberations and decision, with a light oversight exercised by the ICANN Board 
which (under the current Bylaws) retains the discretion to prescribe periodic 
reviews of each group’s charter (see Article X, Section 5.3 of the ICANN 
Bylaws).



    Although the SCI is unable to take up consideration of the issue raised by 
the BC, we recognize the potential problem that this could cause were it to 
happen and would therefore like to offer a few options for your and the BC’s 
consideration. As the question arose during the BC's discussion of a revision 
of its Charter, it may be helpful for the BC - as part of its internal 
deliberations and process - to determine whether to seek external input and 
also how suggestions for mitigation received can assist in its decision as to 
the best way to proceed. For instance, BC leadership could reach out to other 
SG/C leaders to see if a common GNSO position can be developed around the 
issue. While we do not ourselves know if other SG/Cs are going to be reviewing 
their charters at this time, we note that each SG/C charter is supposed to 
specify the process for charter amendment. It may therefore turn out to be 
timely for the BC to raise this issue within the broader GNSO community.



    In this regard, it may be helpful to note that the GNSO Operating 
Procedures prescribe that SG/C rules be based on common general principles that 
ensure representativeness, openness, transparency and accountability. 
Specifically, while groups are not required to maintain identical rules, their 
participation principles should be objective, standardized and clear (see 
Section 6.1.1 and generally Section 6 of the GNSO Operating Procedures). In 
line therefore with the concept of community–based bottom–up governance, if a 
substantial part of the GNSO community were to agree on a need to solve the 
potential voting problem, this could result in the development of a GNSO norm 
or principle that could, if appropriate, be added to the GNSO Operating 
Procedures.



    Additionally, given the ongoing structural review of the GNSO, the BC may 
also wish to consider bringing up the issue with the GNSO Working Party that is 
coordinating this effort on the community’s behalf, perhaps through the BC 
representatives on the group. We understand also that the initial report of the 
independent examiner will be published for public comment in mid-2015, so there 
will be additional opportunities for public comments that can include 
suggestions for further structural improvements to the GNSO as well. 



    I hope that these suggestions from the SCI will be useful to the BC. Should 
you or the BC have any additional questions concerning the functioning of the 
GNSO Operating Procedures and Working Group Guidelines, please do not hesitate 
to contact me. The SCI will be pleased to support the community’s efforts to 
better understand and improve these rules and processes.



    With best regards,



    Anne Aikman-Scalese

    2015 Chair, SCI 









    From: Amr Elsadr <aelsadr@xxxxxxxxxxx>
    Date: Tuesday, March 10, 2015 at 06:43
    To: Mary Wong <mary.wong@xxxxxxxxx>
    Cc: "<gnso-improvem-impl-sc@xxxxxxxxx>" <gnso-improvem-impl-sc@xxxxxxxxx>, 
Ron Andruff <randruff@xxxxxxxxxxxxxxx>
    Subject: Re: [gnso-improvem-impl-sc] Re: Request to the SCI - Vote switching



      Hi,



      I haven’t commented on this thread, mainly because I thought the 
discussion was headed in an agreeable direction.



      I think Martin has raised an interesting point, and hope this issue 
doesn’t become a problem in the near or distant future. However, as noted by 
others, I don’t see this as an SCI issue. Since this isn’t a policy issue, I 
honestly don’t see this as something necessarily being within the scope of the 
GNSO Council either. Having said that, I don’t think it would be harmful for 
the council to discuss the issue. Ideally, this would have been picked up 
during the GNSO review, but should be individually tackled by the GNSO’s SGs/Cs.



      Isn’t the Board SIC involved in the process of SG/C charter revisions as 
well? I tried searching for a process description, but couldn’t find one. May 
be helpful to reference that in any response we send Martin, if that is indeed 
the case. I seem to remember them being involved in the NCSG charter revision.



      Thanks.



      Amr



      On Mar 9, 2015, at 9:11 PM, Mary Wong <mary.wong@xxxxxxxxx> wrote:





      Dear Angie and everyone,



      Thanks very much for the thoughtful comments – I think we are both saying 
very similar things! Essentially, the BC (like all other GNSO SG/Cs) defines 
its own charter and scope, which is one reason why (as well as more general 
reasons having to do with the fundamental community consensus-based bottom-up 
ICANN structure) staff suggested that this is an issue best determined by the 
BC itself. This can include all the considerations mentioned by Angie, and the 
BC may also decide it wishes to discuss the question with other GNSO SG/Cs. As 
we also noted, to the extent that a substantial or discrete part the GNSO 
community then believes a more uniform or coherent approach is needed, either 
the BC or another GNSO SG/C can bring it up as part of the ongoing GNSO Review 
- a point that was noted by Avri as something that can be done through each 
SG/C’s representatives on the GNSO Working Party, including the BC's. 



      Anne has requested that staff draft a response to Martin and the BC, 
which we propose to do along these lines. Although we do not think this is 
necessarily the type of matter that the SCI Charter was intended to cover, 
nonetheless it may be helpful to see if this is a shared SCI view. Please reply 
therefore if you have an objection to the proposed approach. If none is 
received by 23:59 UTC on Wednesday 11 March, we will proceed as noted herein.



      Thanks and cheers

      Mary



      Mary Wong

      Senior Policy Director

      Internet Corporation for Assigned Names & Numbers (ICANN)

      Telephone: +1 603 574 4892

      Email: mary.wong@xxxxxxxxx







      From: Angie Graves <angie@xxxxxxxxxxxx>
      Date: Monday, March 9, 2015 at 11:52
      To: Anne <AAikman@xxxxxxxxxx>, Mary Wong <mary.wong@xxxxxxxxx>, 
"<gnso-improvem-impl-sc@xxxxxxxxx>" <gnso-improvem-impl-sc@xxxxxxxxx>
      Cc: Julie Hedlund <julie.hedlund@xxxxxxxxx>, Ron Andruff 
<randruff@xxxxxxxxxxxxxxx>
      Subject: Fwd: Request to the SCI - Vote switching



        Dear Anne, Mary and SCI,



        I am writing to share my thoughts with the SCI as a member of both the 
BC and the SCI.  If any of my thoughts expressed below conflict with Mary 
Wong's pending response, I defer to her.



        I am inclined to think that I am speaking for more than just myself 
when I say that the SCI recognizes, too, the importance of this issue Martin 
has raised, and that we would like to be able to provide answers and resolution 
to the potential for abuse of voting rights.



        Unfortunately, the SCI's charter directs us to consider GNSO Council 
processes and procedures and Working Group guidelines that have been identified 
either by the GNSO Council or a group chartered by the GNSO Council as needing 
discussion (e.g. a WG).  As the Business Constituency is one of the 
Constituencies within the Commercial Stakeholder Group (CSG) referred to in 
Article X.5 of the ICANN bylaws, and as the BC's charter review is not at the 
request of the GNSO Council, Martin's request lies outside of the SCI's scope.



        I am available to talk about this issue with Martin and/or with the BC 
Charter Review Drafting Team, and maybe determine together the optimal way 
forward.  My suggestion is for the SCI to recommend that Martin raise this 
issue first inside the BC following the Drafting Team's completion of its first 
order of business--the charter review.  In seeking BC consensus on  the issue, 
requests for outside review will be thoroughly considered by the constituency, 
ideas for mitigation will be collected, and the best path forward with the 
issue will be determined and agreed upon by the BC membership.



        Thoughts?



        Thank you,



        Angie











        ---------- Forwarded message ----------
        From: <martinsutton@xxxxxxxx>
        Date: Mon, Mar 9, 2015 at 5:26 AM
        Subject: RE: Request to the SCI - Vote switching
        To: "Aikman-Scalese, Anne" <AAikman@xxxxxxxxxx>
        Cc: Angie Graves <angie@xxxxxxxxxxxx>, 
"<gnso-improvem-impl-sc@xxxxxxxxx>" <gnso-improvem-impl-sc@xxxxxxxxx>, Julie 
Hedlund <julie.hedlund@xxxxxxxxx>, Mary Wong <mary.wong@xxxxxxxxx>, Ron Andruff 
<randruff@xxxxxxxxxxxxxxx>


        Dear Anne, 

        Thank you for your helpful response and suggestion - all noted.

        Kind regards,

        Martin 
        Martin C SUTTON 
        Manager, Group Fraud Risk & Intelligence 
        Global Security & Fraud Risk
        Level 8,1 Canada Square,Canary Wharf,London,E14 5AB,United Kingdom

              __________________________________________________________________

                    
                    Phone
                   +44 (0)207 991 8074
                   
                    Mobile
                   +44 (0)777 4556680
                   
                    Email
                   martinsutton@xxxxxxxx
                   
                    Website
                   www.hsbc.com
                   



              __________________________________________________________________
              Protect our environment - please only print this if you have to!
             






        From:        "Aikman-Scalese, Anne" <AAikman@xxxxxxxxxx>
        To:        Martin C SUTTON/HGHQ/HSBC@HSBC
        Cc:        'Mary Wong' <mary.wong@xxxxxxxxx>, Julie Hedlund 
<julie.hedlund@xxxxxxxxx>, "<gnso-improvem-impl-sc@xxxxxxxxx>"        
<gnso-improvem-impl-sc@xxxxxxxxx>, 'Ron Andruff' <randruff@xxxxxxxxxxxxxxx>, 
'Angie Graves' <angie@xxxxxxxxxxxx>
        Date:        07/03/2015 22:20
        Subject:        RE: Request to the SCI - Vote switching


------------------------------------------------------------------------




        Martin, 
        Although SCI has not met, there has been some discussion on the list 
regarding your request on behalf of the BC Charter subteam.  
          
        Staff (Mary Wong) is drafting a response to your request for SCI and 
will be circulating that response to SCI members for purposes of developing a 
consensus on the recommended approach for BC in this fact situation.  At 
present we have  no calls scheduled.  If SCI members are not in agreement with 
the approach described in the draft response that staff is preparing, we will 
likely need to schedule a call to discuss in more detail than achieved to date 
on the list.  In this regard, you may want to alert and brief the BC members of 
SCI as to this particular issue since, to my knowledge, neither one of the BC 
SCI appointees has commented in the discussion of this matter on the SCI list.
        Thank you, 
        Anne 
          
          
          
          
         



              <ATT00001.gif> 
             Anne E. Aikman-Scalese, Of Counsel
             
              Lewis Roca Rothgerber LLP |
             
              One South Church Avenue Suite 700 | Tucson, Arizona 85701-1611
             
              (T) 520.629.4428 | (F) 520.879.4725
             
              AAikman@xxxxxxxxxx | www.LRRLaw.com
             
             
             


         



             
             


          
        From: martinsutton@xxxxxxxx [mailto:martinsutton@xxxxxxxx] 
        Sent: Friday, March 06, 2015 9:17 AM
        To: Aikman-Scalese, Anne
        Subject: Re: Request to the SCI - Vote switching 
          
        Dear Anne, 

        As a follow-up, could you please let me know when the SCI is next due 
to meet/discuss the item raised below?  I just want to manage expectations with 
the BC Charter group, so an indicative time would be helpful. 

        Kind regards,

        Martin 
        Martin C SUTTON 
        Manager, Group Fraud Risk & Intelligence 
        Global Security & Fraud Risk
        Level 8,1 Canada Square,Canary Wharf,London,E14 5AB,United Kingdom



              __________________________________________________________________



                    
                    Phone
                   +44 (0)207 991 8074
                   
                    Mobile
                   +44 (0)777 4556680
                   
                    Email
                   martinsutton@xxxxxxxx
                   
                    Website
                   www.hsbc.com
                   




              __________________________________________________________________
              Protect our environment - please only print this if you have to!
             







        From:        Martin C SUTTON/HGHQ/HSBC
        To:        "Anne Aikman-Scalese" <AAikman@xxxxxxxxxx>
        Date:        26/02/2015 23:21
        Subject:        Re: Request to the SCI - Vote switching




------------------------------------------------------------------------





        Thank you Anne, much appreciated. 

        Martin Sutton
        Manager, Group Fraud Risk and Intelligence
        Ph:  ++44 (0)20 7991 8074
        Mob:  ++44 (0)777 4556680
        Sent from my BlackBerry

        *********************************

        HSBC Holdings plc
        Registered Office: 1 Canada Square, London E14 5AB, United Kingdom
        Registered in England number 617987

        *********************************




------------------------------------------------------------------------

          From: "Aikman-Scalese, Anne" [AAikman@xxxxxxxxxx]
        Sent: 26/02/2015 20:31 GMT
        To: Martin C SUTTON
        Subject: RE: Request to the SCI - Vote switching


        Thanks Martin. I will bring this before SCI.
        Anne 
         



              <ATT00002.gif> 
             Anne E. Aikman-Scalese, Of Counsel
             
              Lewis Roca Rothgerber LLP |
             
              One South Church Avenue Suite 700 | Tucson, Arizona 85701-1611
             
              (T) 520.629.4428 | (F) 520.879.4725
             
              AAikman@xxxxxxxxxx | www.LRRLaw.com
             
             
             


         



             
             


         
        From: martinsutton@xxxxxxxx [mailto:martinsutton@xxxxxxxx] 
        Sent: Thursday, February 26, 2015 12:30 PM
        To: Aikman-Scalese, Anne
        Subject: Request to the SCI - Vote switching
         
        Dear Anne, 

        I am a member of the Business Constituency and currently working with 
the BC Charter Review team.  During our recent discussions, we identified a 
potential issue that may affect GNSO Stakeholder Groups (SGs) and 
Constituencies (Cs) which may warrant the attention of the SCI, which I 
understand you currently chair.

        With the introduction of New gTLDs, an increasing number of 
organisations now meet the criteria of membership within multiple groups, even 
across the contracting and non-contracting parties divide.  The point in 
question is in relation to the ability for a member of multiple SGs and Cs to 
regularly switch their voting rights between these groups in a tactical manner, 
so as to apply votes for elections/decisions where they may have concerns with 
lack of representation within a specific group, at a specific time. Whilst they 
may only vote in one of the SGs or Cs, there is no restriction as to when and 
how frequently they may switch their voting power between these groups.  This 
could be too flexible and potentially allow the system to be exploited.

        I am pleased to say that there is no evidence that this is occurring 
but as new members continue to increase, it seems sensible to consider 
preventative measures be put in place to protect the GNSO for the future.  As 
an example, a multi-member organisation could be obliged to commit  holding 
it's voting rights within one group for a minimum term of 12 months before 
switching to another group.  Of course, this would need to be uniform across 
all of the SGs and Cs, hence, we think it is appropriate to raise this issue 
with the SCI for consideration.

        I would be happy to discuss further and interested to know if you feel 
this would be appropriate and worthwhile for the SCI to assess.

        Kind regards,

        Martin 
        Martin C SUTTON 
        Manager, Group Fraud Risk & Intelligence 
        Global Security & Fraud Risk
        Level 8,1 Canada Square,Canary Wharf,London,E14 5AB,United Kingdom



              __________________________________________________________________





                    
                    Phone
                   +44 (0)207 991 8074
                   
                    Mobile
                   +44 (0)777 4556680
                   
                    Email
                   martinsutton@xxxxxxxx
                   
                    Website
                   www.hsbc.com
                   




              __________________________________________________________________
              Protect our environment - please only print this if you have to!


             


         


          


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