Share Invitation 2022
Community-Owned Renewable Energy
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The energy crisis is never far from people's lips. But the solution - using less gas - seems beyond
the intellectual reach of most commentators. Well, here at BEC, we beg to differ. As well as
being carbon positive, renewable energy is cheap - just ask any of our host solar sites who save
hundreds of thousands of pounds on their electriciy bills each year.
Climate change, too, demands we take this kind of action, and I'm pleased to say that BEC is
now building more solar PV sites, detailed in this document, to add to the 80 we've built over
the last twelve years.
So this is our latest share offering, and a chance for you to get involved. By buying shares in BEC
you get an equal voice in how BEC is managed, help develop a local, affordable energy supply,
and ensure the benefits of locally-based renewables are retained locally.
And, crucially, you help us take action on climate change - our new systems will save 400 tons
of carbon each year.
Financially, this share offer is a first for BEC - a solar PV system without the financial base of
Feed in Tariffs. This means the risk profile of any investment you make is different to our previous share offers, and you should consider
our updated risks section accordingly. Having said that, investments in BEC join a 'pot' of existing shareholdings, so all the
solar PV we've built to date do have feed in tariffs; and for me this is a key aspect of BEC's stability - our broad-based portfolio decreases
the risk of any one solar PV system underperforming, or being overly reliant on one revenue stream or other.
At the last count BEC has more than 600 investors, and it's an inspiration to have so many people as part of what we are doing. You
can join them by becoming a member of Brighton Energy Coop and adding your voice to the community energy revolution that's
building in Brighton - and beyond.
This offer of shares is not regulated by the Financial Services and Markets Act 2000 or subsidiary regulations. The money
you pay for your shares is not safeguarded by any depositor protection scheme or dispute resolution scheme. The Society,
unlike banks and building societies, is not subject to prudential supervision by the Financial Conduct Authority, nor has it
been approved by an ‘approved person’ under section 21 of the above act.
Chairman’s Introduction
SHARE OFFER SUMMARY
Will Cottrell
Chairman
Brighton Energy Coop
Projected Interest Rate: 5%/ 3.5%*
Minimum investment: £300
Maximum investment: £100,000
Fundraise target: £482,050
*First Interest payment (yearly thereafter): April 2024. First two years’ interest is
expected to be 5%; 3.5% thereafter
Share offer closes: 28/2/2023
System Size:578kWp
OUR NEW PROJECT
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Panels: 1410*410W Mono Inverters: 23* Solaredge 25kW
578kW of new community-owned solar at Rathfinny Wine Estate
Our new solar partner is Rathfinny Wine Estate, a tranquil oasis on the South
Downs just north of Seaford. Rathfinney is a family-owned vineyard, founded
in 2010, and will join the growing collection of solar wineries in Sussex.
BEC plans to install 578kWp of solar at Rathfinney in November 2022, our
biggest system to date. The solar system will have 1410 panels, 23 SolarEdge
inverters and will be installed by our long-term installation partner GenFit.
The money will be spent on the installation of solar panels at Rathfinny,
scaffolding, and a project development fee for the Brighton Energy Coop
team.
BEC’s History
2012/13
£18,000 raised from ten Brighton investors to develop the
concept. 77 people later invest an additional £236,000 and
BEC installs its first three solar installations.
2014
A further £411,000 of solar assets added to BEC’s
renewables portfolio. Turnover is nearly £35,000 and BEC
makes an operating profit of just over £7,000. By the end of
the financial year 215 people are BEC members.
2015
Fifty people join and we are visited by two energy ministers!
We raise a further £68,000 for a new solar array at
Shoreham Port; turnover passes £64,000 and our operating
profits rose to £23,000.
2016
Six large solar arrays built - costing £573,000 - including our
first school; membership passes the 400 mark and total
funds raised top £1,300,000. Turnover increases to nearly
£82,000, with an operating profit of £25,000 we pay our first
interest payment to members: £32,000.
2017
Additional solar PV built with the University of Brighton. 77
people join and £230,000 is invested; interest payment this
year is £33,000, based on a turnover of £135,000 and an
operating profit of £39,000.
2018
Several commercial arrays built and a further £272,000
raised. Membership passes 500 and we pay out £58,000 of
interest. At £194,000 our turnover is nearly ten times that of
five years ago.
2019
The rollout of our solar Schools project. BEC qualifies as a
Brighton and Hove City Council-approved contractor and
we install on 12 schools, raising more than £1 million along
the way. Membership is now over 600 people.
2020/22
Now with a capital value of £3.5M, BEC takes on three new
staff members, and concentrates on embedding our new
projects. Interest payments of more than £150,000.
JOIN BEC AND
HELP US BUILD
MORE SOLAR
By buying shares you join Brighton Energy Coop you help us
raise the money to finance the development,
marketing and capital costs of our our new projects.
All new solar PV projects are assessed by the BEC team to
ensure they are suitable to deliver a return sufficient to cover
operations, maintenance, capital repayment costs and i
nterest. If these projects do not materialise we will return
members' monies, only issuing share certificates and investing
capital in solar arrays that meet our investment criteria.
Who Can Invest?
Anyone over 16, and also from companies and organisations.
Anyone buying shares on behalf of an organisation or a group
of people must specify a person over 16 to act as their
nominee and be listed in the share register on behalf of that
group. You may purchase up to £100,000 of shares, the
minimum being £300. Each share is worth £1.
Share Withdrawals
Shares are issued in tranches and in chronological order. Each
tranche of shares is issued a share class - generally a share
class represents the solar PV systems this investment has
gone to fund. We make no distinction between share classes
for the priority of withdrawals. Note that BEC may undertake
money-laundering checks as required by law.
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Interest Rate
As a Community Benefit Society (CBS), we set an interest rate
that is, in our view, sufficient to obtain the necessary funds to
raise the money to build new solar projects. Legally, CBSs are
meant to direct their efforts to fullfil their objectives, rather
than benefit shareholders .
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Through our school-based solar systems, BEC saves schools
thousands of pounds on their electricity bills each year. And
via our Community Fund we work together optimising energy
usage & teaching kids about clean energy.
For the past four years we've been focussing on engaging
local school children. Today we work with national charity
Energy Sparks to deliver curriculum materials at appropriate
levels to the kids, and provide a £300 grant to each of BEC’s
13 Solar Schools, to help onboard teachers to these materi-
als.
To facilitate all this, BEC forged a new relationship between
Brighton & Hove City Council’s Energy Team and Energy
Sparks, so that all Brighton & Hove schools could participate,
whether they have a free BEC solar system or not. We held a
skills-share meeting with fellow community energy group,
BHESCo, to ensure that their solar schools could get on
board at the start.
BEC allocates 2% of our total turnover to our Community
Fund.
OUR WORK IN THE COMMUNITY
n June 2021 we surveyed of our 600+ members, and asked why
they had joined Brighton Energy Coop. The results were
illuminating. We found the main factors that movtivated people
to join BEC were:
⦁ “to take action to tackle climate change” - 99% of respondents
thought this was either “very important” or “important”
⦁ “to make my money align with my principles” - 92% similarly
thought this was “very important” or “important”
⦁ “to help provide funds for good causes” – 69% also thought
this was “very important” or “important”
⦁ “to contribute to something that benefits the local area” –
66% said this was “very important” or “important”
⦁ “Getting an attractive return on my investment“ was
considered “important” or “very important” by 55% of our
members
We also found 64% of BEC members live in Brighton or Sussex,
while 25% said that they had no connection with the area. 62%
said Brighton Energy Co-op was the first community energy
group they have been involved in. Of those who had joined
other community
energy groups, these included: Bath and West CE, BHESCO, Low
Carbon Hub (Oxford), OVESCO, Repower Balcombe, Stockport
Hydro, Thrive, Energy4All and Triodos Crowdfunding.
62% of respondents were over 50. In terms of income, 52% had
an annual personal income level of £25,000 or less, and 23%
had an income of £50,000 or more.
Who Joins BEC?
MEET THE BEC TEAM
Chairman & founder
Will Cottrell
BEC’s other founder, Will has been
Chairman since 2010. He was
Community Energy Fund-raiser of the
year 2014, won the Environment award
at 2015’s PEA awards and has authored
several pieces on developing community energy schemes.
Will oversaw the development and fund-raising of BEC's £1
million schools project in 2019 and is part of Coops UK community
energy mentoring programme.
Secretary & founder
Damian Tow
As BEC's co-founder, Damian brings a
sharp scrutiny to the operation. With
his emphasis on financial, legal and
regulatory aspects, he has 14 years’
experience as a project manager at
Cable & Wireless, BT and was also a director of a small software
company. . Having originally read Business Studies at Hull
University, Damian completed a Masters in Leadership for
Sustainable Development at Forum for the Future in 2009.
Project Development
Matt Brown
Matt joined BEC in 2013 as head of new
project development. Since then he’s
overseen the development of BEC’s
new solar systems. He helps BEC take a
positive and pro-active approach to
developing our renewable portfolio and is committed to the
developing greater community ownership of renewable energy
generation.
Project Development
David Owers
David joined the BEC in 2021 to assist
with developing new projects. He has
enjoyed careers as an energy engineer,
entrepreneur and general manager in
the medical devices industry before
moving to Brighton in 2011, working as a Directorate Manager at
the main NHS hospital trust.
Director Peter Davis
Peter joined the BEC Board in April
2017 after retiring as Development Director
of Shoreham Port. Previously, he
was Head of Planning at Adur Council
and before that he worked in various
economic regeneration roles in the
Midlands. He is a Member of the Royal
Town Planning Institute and a Fellow of the Institute of Economic
Development.
Director Sue Paskins
Sue is a qualified accountant and
served as a Green Party Councillor in
Brighton & Hove from 2003-7. She
owned and ran a number of successful
businesses and has worked in accountancy
for various commercial organisations,
culminating at First Leisure PLC where she was Group
Management Accountant. More recently she – along with husband
Mick – own and run a series of successful boutique hotels.
Director Gerard Sauer
Gerard joined BEC as a Non-Executive
Director in December 2017, focussing
on the technical issues of PV assets.
Lately concentrating on post FIT strategy,
He started in the Renewable Energy
Industry in 1992, and has been
involved in fuel cell cars and boats, static generators, large scale
solar plants, and continental wind projects.
Director Stuart Condie
Stuart joined BEC’s Board at the end of
2019 having previously been chairman
at Shoreham Port 2015-17. His working
life has mostly been in transport, but
he's also chaired two pension funds,
and been a Non-Executive Director of
Heathrow Express. His areas of expertise include finance, commercial
contracts, and compliance issues.
ERDF Solar Grants
Svenja Czubayko
Svenja joined in BEC in 2021 and
oversees our ERDF Solar Grant Scheme.
She is a Elmhurst-accredited Energy
Assessor and qualified in Permaculture
Design in 2016. She has a special interst in smart building design
and sustainable technologies, previously working as Programme
Manager for the Sustainable Business Partnership and BHESCO.
Communications &
Community Fund
Atlanta Cook
Atlanta joined BEC in November 2020,
to oversee our communications and
Community Fund. As a longtime eco
educator, campaigner, event organiser and fund-raiser, she
brings a wealth of knowledge to our table. Atlanta is a Co-founding
Trustee & Secretary of eco education charity Beacon Hub
Brighton CIO, a Regional Rep for Surfers Against Sewage and
runs her own marine environment consultancy.
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FINANCIAL DETAILS
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Solar at Rathfinny Wine Estate
Note the figures given iare provisional. There remain several key risks around our assumptions, so it's important to read the
risk factors below.
DISCLOSURE
None of the Directors of BEC have, for at least the past five years,
received any convictions (for any fraudulent offence or
otherwise), or been involved in any bankruptcies or
receiverships, or received any public recrimination or sanction
by a statutory or regulatory authority or designated professional
body, or been disqualified from any function by any court.
Conflicts of interest
The rules of BEC include provisions relating to potential conflicts
of interest; related party activities are disclosed and dealt with
according to the rules.
Remuneration
None of the directors are paid for their role as Directors but BEC
pays remuneration to Will and Damian for providing
administrative support to BEC. Similarly BEC pays Will, Damian
and others for project development services. We cost these
services at a market rate similar to that which has been paid by
comparable organisations. The directors are elected each year
at our AGM.
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Revenue
Revenue assumptions are based on where our solar electricity
gets used. If it is sold to the site, revenue is determined by our
power purchase agreement, which is fairly predictable as it's
fixed in BEC's lease with the site and inflation-linked.  The
remainder of electricity is exported to the grid, and revenue here
is based on a preliminary offer from Octopus energy for 27p per
Kwh for the first 30 months. At that point revenue projections for
export are based on our assumptions of where the export
market will be; the BEC Board has judged that 7p to be a
reasonable forecast of the export price we will receive after our
30-month contract with Octopus expires.
Outgoings
The greatest costs are interest and capital repayments to
members. Our projections are based on the assumption that
capital is returned to members as the asset is gradually
written off over the 25-year life of the project. Other costs include
maintenance (annual checks, repairs, and replacement of
generating equipment), insurance, and a contribution to the
running costs of BEC. For more information about the latter refer
our annual accounts which are available on our website.
Other Assumptions
• We intend to return all the shareholdings in our new systems
over 25 years
• Soar PV performance degrades at 1% pa. This is a normal
degradation rate for solar PV and consistent with our operating
experience.
• Retail Price Index (RPI) – 2.5%. This is based on the experience
of recent years, but is obviously at odds with inflation over the
last 12 months. However, since our major costs (share interest
and capital payback) do not fluctuate with inflation, while our
major revenues (historic Feed in Tariffs, electricity sales) are
index linked, inflation rates above 2.5% would
benefit BEC's financial position.
• Interest payments to members are targeted to be 3.5%. This is
based on a projection of profit and reserves generated by the
new systems at the time we aim to pay interest. At this time the
Board will review performance and determine what rate of
interest is affordable.
The Board expects 3.5% to be paid annually for the life of the
project but this is not guaranteed. There may be periods when
we don’t generate sufficent income to pay this interest due to
sites not using all the electricity we generate or other factors.
• Administration costs and running costs are estimates, again
based on Brighton Energy Coop's experience.
• Generation projections are not based on numbers from
installers - they are based on the production efficiency of our
existing systems, and our in-house understanding of how solar
operates in the Sussex environment.
Financial Assumptions
Brighton Energy Co-op is the trading name of Brighton Energy
Limited, a Community Benefit Society (CBS) formed in 2010. As a
CBS, Brighton Energy Co-op is democratically owned. Each
member has one vote, regardless of the amount invested. Unlike
a limited company, which is designed to benefit shareholders, a
CBS is designed to benefit the wider community.
BEC is bound by its Rules, and the Directors serve in accordance
with those Rules. BEC's day-to-day operations are overseen by
the Board which also bears ultimate accountability to BEC
members for ensuring financial probity and achievement of the
organisation's objectives.
As a CBS, Brighton Energy Ltd complies with the requirements of
the Cooperatives and Community Benefit Societies Act 2014 and
is registered with and regulated by the Financial Conduct
Authority. BEC shares are not traded.
We have been trading since 2010: Our revenue comes from Feed
in Tariffs, and electriciy sales - to our host sites and to the grid.
Our administration costs come from running the organisation,
maintaining our solar systems and depreciation.
At the end of March 2021 BEC had issued 3,123,633 shares, each
valued at £1. Our most recently-published financial performance
is shown to the left. As you can see, our we generated a surplus
of £162,490. We then made an interest payment of £96,577, generating
a total surplus for the year of £65,913.
See our full Accounts at www.brightonenergy.org.uk/documents
About BEC
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RISKS
All investments and commercial activities carry risk. By buying
shares you should weigh up financial risk and reward as you
would with any other investment opportunity. You should read
this document in full, including this section on risks and if you
are in any doubt please contact us or consult someone with financial
experience before joining.
Not Securing sites
The viability of a project depends on obtaining a lease agreement
with our host sites to host our solar panels. Without a
lease we are unable to proceed. It's therefore a risk that the
money we spend on developing a project prior to lease signing
(including planning permission and grid approval) may be spent
without a result.
Mitigation
Our financial projections make provision for project development
costs.
Raising Insufficient funds
It's possible that once under way the required capital cannot be
raised
Mitigation
We are confident our fund-raising targets are realistic. Since 2021
we've been running a pledge scheme where those interested in
joining BEC or adding to their existing membership can pledge
new investment. To date more than 200 people have pledge
more than 1 million pounds. If fundraising targets are not met,
however, then we will refund shareholder capital for this class of
share.
Variance in the value of various revenue streams
Historically Feed in Tariffs have provided the bulk of the BEC's
revenue. As time has progressed, sales to host sites and electricity
exported to the grid have became more important. More recently,
increasing export rates have increased their value within
BEC's revenue stack.
Mitigation
The directors keep a close eye on market conditions and attempt
to gain the long term contracts to alleviate market fluctu-
ation
Sites may change hands.
Things change. Businesses go bust, or get sold, and so the hosts
of solar panels may change.
Mitigation
Within our lease agreement it's specificed that any new tenant
to a building must either buy the system or continue the agreement
with BEC. To further ameliorate this risk, BEC aims to partner
with the widest range of organisations as possible, so that
even if a building falls vacant then a new occupier will soon pay
us for electricity.
General investment risks
BEC shares will not be transferrable or recognised on a stock exchange,
but they will be buyable back by BEC. They will never increase
in value above their nominal value of 1 pound each, but
could fall in the event that BEC becomes financially unsustain-
able.
Risks associated with the financial assumptions
Our new systems are not backed by FITs. This means that financially
they are less stable than before, as revenue is reliant purely
upon market mechanisms: electricity sales to sites and exports
to the national grid.
The former is RPI linked, but RPI and cost increases are unpredictable.
Energy prices may fluctuate and in an irregular fashion.
Revenue may be ahead of projections in the short term but fall
back later, or vice versa.
Mitigation
We model the financial performance of future solar systems
using our in-house modelling tool. This has successfully delivered
accurate forecasts for the past 10 years of solar projects,
despite changing market conditions.
Revenue for our new projects also goes into a 'pot' with revenue
from FIT-backed systems, and so the risk of building a small percentage
of new projects without FITs is somewhat offset by our
legacy projects.
The BEC board will always review actual revenue and developing
trends before making annual payments of interest or allocating
funds to our community fund.
Risks specific to BEC
Solar kit may fail. Weather events may damage solar equipment
and natural degradation may reduce system performance.
Mitigation
Warranties and insurance will be in place in the event of mechanical
breakdown of the equipment. The risk of complete mechanical
failure and subsequent loss of revenue is mitigated by
the use of multiple inverters and our systems are regularly monitored
and serviced by our maintenance teams to minimise supply
interruptions.
Renewable Energy Industry Risks
Government policy towards renewable energy may change, although
there has been no sign of a change in commitment to
Feed in Tariffs.
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MEMBERSHIP INFORMATION
Investing for Children
Parents and grandparents can invest in for their children and
grandchildren. Interest earned will be paid to the beneficiary
named by the investor in their membership application. Shares
owned this way are exempt from inheritance tax when passed
on.
Share Withdrawals
Shares for this latest share offer are withdrawable up to a maximum
of 4% per annum of share capital in issue at the end of the
financial year. Within this ceiling, individual requests to withdraw
will be at the discretion of the Board. The Board may resolve at
any time to require any proportion of its share capital to be withdrawn,
in which case it shall treat as agreed to be withdrawn on
behalf of every member (and not some only) that proportion of
the shares held by them (with such rounding to the nearest
whole number of that Proportion which is a fraction as the
Board may determine). All members are deemed to give any
consents required to the withdrawal of their shares in this man-
ner.
The scope for being able to withdraw shares in the future will be
dependent upon the Society developing a successful business
and hence cash flows to pay out share withdrawals or contingent
on the Society raising additional capital for the purpose of
paying out share withdrawals. In the case of joint investments,
all investors concerned must agree to a withdrawal.
Shares will be repaid at the original price (subject to comments
hereafter).
The Directors of the Society have the right to change the withdrawal
facility, or to suspend withdrawals.
Similarly the Directors have the right to write down the value of
shares, if the liabilities of the Society (and its share capital)
should exceed the value of its assets. Members who then withdraw
their shares will only
receive the written down value of their shares.
The value of your shares may fall and their value will not exceed
the £1 per share. Although shares are withdrawable, you may
not be able to withdraw the full price you pay for them if BEC
does not have funds available at the time you want to withdraw
your shares. In some circumstances, the Directors may be compelled
to write down the value of your shares. Should you then
wish to withdraw your shares, you should expect to receive only
their written down value.
Returns to Members
The Society will pay only a sufficient rate of interest on money
paid for its shares and may in any one year pay no interest at all.
A sufficient rate is determined by the Directors as the rate necessary
to obtain and retain the capital required to carry out the
Objects of the Society as set out within its Rules.
Voting
Each member has one vote regardless of the size and value of
their shareholding. Members are kept informed of developments
through the Brighton Energy Co-op website, by e-mails
where the member so wishes, by occasional newsletters, annual
reports and Annual General Meetings.
Legal Information
This document is issued by Brighton Energy Limited, registered
number 31107 R, as a Community Benefit Society incorporated
in England and Wales on the 10 November 2010 under the Industrial
and Provident Societies Act 1965.
This offer of shares is not regulated by the Financial Services and
Markets Act 2000 or subsidiary regulations. The money you pay
for your shares is not safeguarded by any depositor protection
scheme or dispute resolution scheme. The Society, unlike banks
and building societies, is not subject to prudential supervision
by the Financial Conduct Authority, nor has it been approved by
an ‘approved person’ under section 21 of the above act.
This document does not constitute a prospectus within the
meaning of the Prospectus Regulations 2005.  These regulations
do not apply because there is a specific exemption for community
benefit societies that conduct their business for the benefit
of the community.
As a member and shareholder of the Society you own the Society.
If the Society is unable to meet its debts and other liabilities,
you will lose the whole amount held in shares. This may make it
inappropriate as a place to invest savings.
Your investment in your share account receives interest but does
not enjoy any capital growth. It is primarily for the purpose of
supporting the society rather than making an investment. As a
Society, the maximum return offered to investors will always be
limited.
Nomination option
In the event of the death of a member, the repaid value of the
shares will normally be added to the estate for probate purposes.
You may elect to nominate a recipient for the value of the
shares (but only up to the amount set out in law) and thus
(under current legislation) remove the value of the shares (up to
the amount set out in law) from your estate for probate purposes
i.e. the shares may pass to the nominee outside the Will of
the deceased). The nominated property will nevertheless form
part of the deceased’s estate for Inheritance Tax Purposes, unless
the estate is an excepted estate.
Documents
The Rules of Brighton Energy Limited, application form, latest financial
statements and financial projections are available on
our website: see www.brightonenergy.org.uk/documents.
Dissolution
In the event of the society’s being dissolved, after paying creditors
any remaining surplus would then go to paying back initial
investments on a pro rata basis, plus any interest due. Should
there be any surplus after this point, it will be distributed to
other organisations in Brighton and Hove with similar objectives,
as chosen by the members.
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Inheritance Tax Relief
BEC Shares would generally be expected to attract Business
Property Relief at rates of up to 100% for IHT purposes, provided
the shares have been held for at least 2 years.
Under-subscription
If this share offer is under-subscribed then we will fund the installation
from our existing cashflow, and extend the share offer
period.
Over-Subscription
Subject to the directors’ discretion we plan to close the share
offer once the maximum fund-raising target is reached. Capital is
to be sourced purely through the offer of shares; there are no
grant or loans planned as part of the fund-raising process.
Subject to your consent, BEC may hold your personal data.
You may have:
* downloaded a PDF from our website, or
* expressed an interest in some other way in obtaining information
about our current share offer, or
* previously given your contact details to BEC as an investing
member, or
* previously given your contact details to BEC as an expression
of interest in receiving future information about investment op-
portunities.
BEC will therefore hold your name and contact details:
* to communicate with you about this share offer
* to communicate with you about your membership of BEC (for
example issuing invites to general meetings, or providing information
about your investment)
* to communicate with you about future share offers
* to communicate with you about the plans activities and successes
of the business
In addition if you are an investing member, BEC will hold bank
details for each member for the purposes of making annual payments
of interest or repayments of capital.
You may withdraw your consent to your data being held by BEC.
You may amend your consent as to what data is held by BEC
and which of the above matters BEC may use your data in connection
with. However, if you are an investing member, you
should note that we need to hold your personal data and bank
details in order to manage your membership and investment. if
you have any queries about this share offer, or if you wish to
pledge money or request shares, please contact us via our online
contact form as this incorporates a statement regarding
your personal data in response to which you may give, withhold,
or qualify your consent.
If you are considering becoming an investor, or are just interest
in learning more about BEC please note that if we do not receive
a record of your consent, we will be unable to continue to hold
your contact details after May 2018 and therefore unable to give
you information about future share offers or BEC activities after
that date.
Brighton Energy Limited company number 31107 registered as a Community Benefit Society at 47 Montpelier Road, Brighton, East Sussex
BN1 3BA
DATA PROTECTION