Martin Wrigley MP: speeches

Speeches

• 3 Jul 2025 · NHS 10-Year Plan · Hansard source

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  Having secured a Westminster Hall debate on the issue, I am delighted to hear the Secretary of State reconfirm that the Carr-Hill formula will be revised and changed. I am also delighted with the ambition of the new plan, and I think it is very good in an awful lot of ways. Will the Secretary of State remember that GP surgeries are businesses? To correctly plan, they need confirmation and positive indications of where their funding will go over a multi-year period. If that is always in the front of his head, then all will go well. I have scanned the plan and read about the new choice charter, the Care Quality Commission and the National Quality Board. However, I am concerned that the ICBs are becoming more powerful and unaccountable to local neighbourhoods. The regulators are good and will keep them systemically accountable, but we are missing Healthwatch. I am disturbed that Healthwatch has been cancelled as the patient advocate, giving the patient’s voice in local areas. Will the Secretary of State reassure us that there will be some way of getting individual advocacy, as well as regulation?

• 3 Jul 2025 · Phone Theft · Hansard source

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  On that very topic, the Science, Innovation and Technology Committee had an inquiry where we put this to Apple and Google. It turns out that phones that are reported stolen in this country go on something called the GSMA blacklist, which stops the hardware from working and the phones cannot be reused in this country. The police says that most stolen phones go abroad to networks that do not use that blacklist. I put it to Apple and Google that they could use this blacklist. They said yes they could, but no they did not want to. Does the hon. Member agree that these companies should enable that blacklist, which would—in my humble opinion—effectively stop the theft of phones on the streets of London?

• 3 Jul 2025 · Women’s State Pension Age: Financial Redress · Hansard source

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  I congratulate the hon. Member for Salford (Rebecca Long Bailey) on securing this debate, and I thank her for her work. Does my hon. Friend agree that this is about trust in Government and a betrayal of trust for all of us who stood there with placards saying, “I support the WASPI women”? They should be following that up.

• 2 Jul 2025 · Draft Waste Electrical and Electronic Equipment (Amendment, etc.) Regulations 2025 · Hansard source

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  It is a pleasure to serve under your chairmanship, Mr Stringer, and I thank the Minister for bringing forward these regulations. The Liberal Democrats, too, think they are a good thing, and we will be supporting the instrument. It is nice to see the scourge of abandoning vapes—both disposable and non-disposable—in the community finally being tackled. Before I continue, I draw the Committee’s attention to my entry in the Register of Members’ Financial Interests and my continuing membership of Teignbridge district council. I will ask a couple of questions. Although I would really like to see the extension of the extended producer responsibility, and the particularly important balancing of the online responsibility to bring online traders in line with high street shops, in the interests of fairness, can the Minister give me an assurance that money for the costs of the disposal of vapes will be passed on to those authorities that are doing it, such as district councils? Disposing of vapes in those areas has been of particular trouble for the local councils. I was delighted to hear the Minister talk about environmental responsibility being a fundamental part of business. That is absolutely why I bring my private Member’s Bill forward on Friday, which looks to change the director’s duties to include balancing the interests of shareholders, employees and the environment. I would be delighted to discuss that with the Minister if it might help her in her mission. Without wishing to detain the Committee any further, the Liberal Democrats thoroughly approve of this instrument, and will be supporting it.

• 26 Jun 2025 · BBC World Service Funding · Hansard source

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  It is a pleasure to serve under your chairmanship, Sir Jeremy. I congratulate the hon. Member for Bury St Edmunds and Stowmarket (Peter Prinsley) on securing this timely and important debate. I must say it is a delight to see such unanimity of purpose across the Chamber. Clearly, there is a real will here to support the BBC World Service, which since 1932 has been Britain’s voice to the world. Today it reaches, as we have heard, an estimated 400 million people across some 59 countries, broadcasting in English and 42 other languages on TV, radio and digital. In today’s uncertain world, the BBC World Service is essential, in not only reaching out to people across the world, but, as we heard from many, building British soft power. It also protects and defends UK citizens wherever they are. Just this week, I spoke to a colleague who currently has constituents stuck in Tehran, and that struck a note with me. As a teenager, I was in Tehran at the start of the Iranian revolution; my father was the naval attaché in the British embassy. I remember evenings when the revolutionary guard would practise shooting stray dogs in the empty lot next to our house, and the power cuts, when people could be heard shouting from the rooftops, and all the time we listened to the BBC World Service to learn what was going on—it was an essential lifeline. However today, this vital institution is under threat, and has faced cut after cut in its budget, recently losing another £6 million. Since the domestic BBC took over funding for the World Service, the organisation has lost much of its autonomy, which has led to merged functions with centralised BBC productions in some cases. Language services were outsourced to local regions, which has exposed them to pressure from local Governments. Indeed, the Azerbaijani Government recently suspended BBC operations. Compounded by cuts to overseas development aid, this has put UK soft power in a precarious position. In 2025, the UK fell from second to third in the global soft power index, having been leapfrogged by China. As both China and Russia pour billions into their international media organisations, the BBC World Service is unable to compete at the same level. We cannot keep undermining the BBC World Service, as the Conservatives did with their assault on the BBC. That hollowing out leaves a clear and dangerous information gap in the global media landscape. China and Russia are pouring billions into their soft power initiatives, all too eager to fill that gap with disinformation and propaganda. They clearly see the value in it—and so should we. The BBC World Service is essential in building and maintaining British soft power and influence, and it requires proper funding. There is a desperate need for unbiased, impartial and fact-based reporting in today’s global information ecosystem. The World Service must now rise again to meet its historic aim: to inform people around the world with clarity, accuracy and integrity—to be a torch shining a light on truth globally. If we are to preserve the UK’s world-leading global image, standing tall on the world stage, we must revitalise the BBC World Service and invest properly in its upkeep. The Liberal Democrats believe that Britain must stand as a strong voice on the world stage. We must invest an additional £100 million of Foreign Office funds in the World Service. That would help to restore its global reach and give it the certainty of consistent funding to secure its long-term stability. We need action now. Will the Government commit today to reversing those damaging cuts? Will they guarantee the extra £100 million needed to restore the BBC World Service to its rightful place as Britain’s premier soft power tool? Will they ensure that short-term savings will not undermine our long-term global influence? The world is watching; Britain’s voice must not be silenced. The time for half-measures is over.

• 26 Jun 2025 · Topical Questions · Hansard source

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  The Dawlish sea wall collapsed in 2014, causing a devastating loss to the south-west’s economy of about £1.2 billion. It was not the break in the sea wall that closed the railway for eight weeks; it was the collapse of the cliffs. Will the Minister prioritise the project to secure those cliffs, which is yet to be carried out, or will she meet me? Perhaps she could even visit Dawlish to see how important this fix is going to be.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  I beg to move, That this House has considered GP funding in the South West. It is a pleasure to serve under your chairship, Dame Siobhain. GPs are the front door of the NHS. They diagnose and treat illness, prevent disease and provide vital mental health support. As Lord Darzi once observed, general practice displays “the best financial discipline” in the NHS family while constantly innovating to keep patients out of hospital. However, GP funding is complex, obscure and insufficient. The bottom line is that the amount of money GPs receive is insufficient to deliver the obligations they carry. That is a view held by every single one of the 28 practice managers I met in and around my district, who tell me the situation is unfunded, unsustainable and unsafe. GP funding is broadly based on two elements: a so-called global sum for core service costs, and additional quality and outcomes framework payments. The global sum starts with a payment per patient per year of £121.79—that is less than we might pay for our dog to go to the vet for an annual check-up, or about a third of the cost of servicing a Renault Megane. It is no wonder that practice managers spend their evenings juggling spreadsheets simply to keep the lights on. It gets worse. That paltry sum is then modified by something known as the Carr-Hill formula. Carr-Hill was designed for a different era. It weighs patient numbers and postcodes but underrates deprivation, multimorbidity and today’s population health priorities. The consequences are stark and deliver what is known as the inverse care law. In my constituency, the Buckland surgery looks after some 4,000 patients on its list but is effectively funded for 3,200.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  Practice managers tell me that that has already happened and they are less funded now than they were last year. On the changing numbers, each GP was supporting 1,800 patients in 2019 and is supporting 2,400 today, but safe care is often estimated to be closer to 1,400 per GP. So we are overloading GPs with patients. Practices make heroic use of pharmacists, physios and nurse practitioners, but the arithmetic does not add up. Meanwhile, the other part of their funding, the quality and outcomes framework scheme, has faced changes that have negatively impacted primary care. This meant that, nationally, £298 million was redistributed from the QOF into the global sum—we can see how bizarre this funding set-up gets; the names are just weird—and into cardiovascular disease prevention funding. Another £100 million of funding was repurposed but does not put extra capacity into the system. Rather than providing new money to support GPs, this felt to practice managers that the Government had been rearranging the deckchairs.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  The hon. Member is absolutely right: we have to consider these things. I have spent many hours persuading my local hospital trusts and the integrated care board to talk to the local authorities and work in the cycles of the local plan, so that they get their requirements into that plan. All too often they say, “A new housing development has just been built. We need a new GP practice with it,” and that is too late. The cycles do not add up. The system is broken, and we need to change that. The Buckland surgery is underfunded by some 800 patients every year. It is part of the Templer primary care network, in which 2,500 patients are effectively treated for nothing. This means that the Buckland practice faces an annual shortfall of approximately £84,000—money that would cover another GP. If we then look at the changing number of patients per GP, in 2019 each GP was supporting 1,800 patients, compared with around 2,400 today.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  I am not quite sure what to say now that the Minister has actually said that my prime ask will be delivered. That is fantastic, and shows the emphasis of these debates. I thank colleagues from across the House for their contributions. We all agree on the importance of GPs and the need to fix their funding. It is vital to recognise the many good things that GPs and GP practices have been doing in what have been difficult circumstances for a good number of years. It has been delightful to hear that MPs have been interacting with their local GP practices to understand the problems with the funding formula. Delighted as I am to hear the Minister announce changes to the Carr-Hill formula, GP funding is still complex. I tried to show how complex it is by focusing on just on two of its elements, but we have heard from other hon. Members that the extra funds are even more complex. The fact that the 7% increase is eaten up by the 6% increase in wages, NICs and so on shows that it is not simple. I thank the Minister for being here—

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  My hon. Friend is absolutely right. I commend him on obtaining a ministerial visit to his hospital in North Devon. North Devon district hospital is fantastic and we need to ensure that it gets the investment it needs—just so long as we can get some south Devon patients there as well. In Teignmouth, the previous four practices have merged into one, mostly due to not being able to find new partners. In Newton Abbot, one practice was on the verge of handing back its patient list due to not being able to replace retiring partners. We have not even talked about specific issues facing some of these surgeries, such as the unbreakable lease on a building that is not fit for use as a GP surgery, where the only possible course of action they could see was to declare themselves bankrupt. As doctors, that ends their careers. And yet, these practices are doing amazing things. The Kingsteignton medical practice, partnering with the charity Kingscare, has created a model that is delivering for patients. Just think what could be done with a better funding model. Buckland surgery would like to link with the local school to tackle adverse childhood experiences before they turn into permanent ill health, providing better family support—much as it has already done with its links to a number of local support services through the Buckland hub. Prior to the election, the now Health Secretary often quoted that a GP visit cost £40, whereas an A&E visit cost £400. I am not sure I agree with the absolute numbers, but the principle is fine: it is 10 times more expensive to put somebody through A&E than it is to put them through a GP. If we talk to Devon integrated care board on GP resilience and prevention, the evidence is crystal clear: prevention saves money. And yet, as Torbay and South Devon NHS foundation trust remains in NHS operational framework 4—we might perhaps equate it to “unsatisfactory” if it was a school—because of historical deficits, it is tasked with huge efficiency savings and is understandably risk-averse. Community services that once propped up primary and secondary care—the stroke recovery group, Devon Carers hospital service, the Torbay and Devon dementia adviser service—have vanished as funding evaporates. Closing gaps in prevention only widens cracks elsewhere. It is not getting better. To sum up, the funding formula is broken. It delivers the inverse care law that the availability of good healthcare tends to be inversely proportional to the need for it within a population. We need to fix it. I am asking the Government today to: end the Carr-Hill formula, and make deprivation, rurality and workload properly weighted; invest in core general practice, not just peripheral schemes, so that partnerships remain viable; protect prevention budgets in the next spending round, as it is cheaper to keep people well than to rescue them later; support premises and digital infrastructure so that online access enhances rather than overwhelms safe care; and publish a workforce plan that retains experienced GPs, accelerates training and makes partnership an attractive career again.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  All those things help, along with things like bringing back nurses’ bursaries. On rearranging the deckchairs, it is no wonder that practice managers described this year’s settlement as unfunded, unsustainable and unsafe.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  I have never been interrupted by a Minister before—I would be delighted.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  I thank the Minister for the intervention. I am not quite sure what the protocol is; I do not think that that has ever happened. This is a most fantastic debate. Capital investment in GP practices and buildings is welcome, but we have heard from across the Chamber that we need more. The problems with ICBs and the difficulties with trusts that are in NHS oversight framework segment 4 still impact GPs and how their funding works. I will push my luck, because the Minister has been very generous with his time and very patient with us all: will he meet me and some practice managers to talk about the complexities of managing the practices with such a level of complication in funding, and to see whether the Government can identify further ways of making it easier to run these businesses, so that they can get on with delivering what they are there to deliver: healthcare for the greatest number of people with the maximum possible benefit? That would be helpful. I thank all hon. Members for their contributions.

• 25 Jun 2025 · GP Funding: South-west England · Hansard source

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  I thank the hon. Gentleman for that intervention, but sadly, I must disagree. That is not what practice managers are telling me. Their costs have gone up so much that all of the increase has been swallowed up, and they are not sure they can keep the lights on. They are really struggling. I have partners in GP practices who are paying themselves less than the minimum wage, which is not sustainable. Patient demand has also increased post pandemic, and continued cuts have seen the removal of many services and social care that have supported what GPs do. On top of the cuts to Sure Start and a 40% drop in health visitors since 2015, carers already stretched thin face the prospect of losing personal independence payment support, which will inevitably rebound on general practice—the first line of defence. That is not to mention long covid and pandemic backlogs. All of those drive more people to want to see their GP. The cost of living crisis is compounding multimorbidity, where the most vulnerable in society with chronic illnesses are further pressured. And then, we get the new requirement to run the appointment schedule from 8 am to 6 pm, filling every single slot. From October, practices must hold digital front doors, open all day, for non-urgent requests. With 100% booked appointments, there is no spare capacity for the person who falls in the care home or for the child who needs attention after school. Partners in the Albany surgery in Newton Abbot warn me that an unlimited invitation will flood a service that simply cannot be limitless. This is unsafe—unfunded, unsustainable and unsafe. Talented doctors are leaving. The partnership model, still the cheapest and most community-rooted option, is no longer attractive when partners shoulder unlimited liability for premises, pensions and payroll, yet cannot guarantee safe staffing levels. The Royal College of GPs reports a 25% fall in GP partners over the past decade. The chair, Professor Kamila Hawthorne, put it bluntly: “It makes no sense that trained GPs cannot find sustainable posts while patients wait weeks for appointments.”

• 18 Jun 2025 · HS2 Reset · Hansard source

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  I thank the Secretary of State for the actions that she has taken today. They were clearly necessary, and it sounds like we are on a better track. However, HS2 provides little or nothing for rail users in the south-west, other than ongoing delays during the construction and operation of Old Oak Common. Will the Secretary of State consider funding, or prioritising the funding for, the critical final phase of the Dawlish rail resilience work that will help businesses and rail users in Devon and Cornwall—and perhaps even in Swindon?

• 11 Jun 2025 · NHS Funding: South-west · Hansard source

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  It is a pleasure to serve under your chairship, Dr Huq, and I congratulate my hon. Friend the Member for Torbay (Steve Darling) on securing the debate. GP funding is in crisis. I have met representatives of individual practices in my Newton Abbot constituency, as well as the 28 practice managers from around the district. They all have a funding crisis. The recent GP settlement was described to me as unsafe, unsustainable and unfunded. GP funding is complex, but in essence it has two parts: the global sum and the quality outcomes framework. The global sum is meant to cover basic costs, including salaries, facilities, and so on, and the QOF extra services, but it does not cover any of it. Practice managers across south Devon have told me that the global sum is £121.79 per patient per year. That works out as less than paying to take a dog to the vet for an annual check-up, or about a third of the cost of servicing a modest car, such as a Renault Megane. That sum is also then modified by the Carr-Hill formula, which, perversely, can reduce the sum in areas of deprivation. The Royal College of General Practitioners wrote in an open letter to Government last year that this formula is no longer fit for purpose and has contributed to the widening health inequalities across the country. Practices in the areas of greatest deprivation have patients with more complex needs, yet they do not receive proportional funding to address those needs. For example, Buckland surgery in my constituency has 4,000 patients, but the Carr-Hill formula reduces the funding to the equivalent for 3,200 patients. Practice managers are juggling numbers to make things work. Some surgeries are short of a full-time GP; just imagine the impact that has on patients. No wonder it is difficult to get an appointment. That is unsafe. The Government have said that from October GPs must offer an open access service; that means that all available slots are booked, so emergency appointments cannot be seen. That is not sustainable.

• 11 Jun 2025 · British Coal Staff Superannuation Scheme · Hansard source

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  This is a new topic to me personally. I was contacted by a constituent whose late husband, a good friend of mine, Michael Green, worked for British Coal at the time. He too was passionate that this money should be returned to the miners. Does the Minister agree that we need to get on with this and get this to happen as quickly as possible?

• 9 Jun 2025 · Planning and Infrastructure Bill · Hansard source

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  Does my hon. Friend agree that we saw in the recent Westminster Hall debate that the standard method for calculating the number of homes not only does not reduce prices, but inevitably ratchets them up and increases them?

• 9 Jun 2025 · Planning and Infrastructure Bill · Hansard source

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  Does the hon. Gentleman agree with the Liberal Democrats that, given the unreliability of section 106 agreements and developers living up to them, as he demonstrated, the best way to get affordable homes for his constituents and mine is through an increased amount of social housing delivered by the local council?

• 13 May 2025 · Local Housing Need Assessment Reform · Hansard source

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  It is a pleasure to serve under your chairship, Mrs Hobhouse. I congratulate my hon. Friend the Member for Horsham (John Milne) on securing this debate, and hon. Members from across the House on their excellent contributions. I draw attention to my entry in the Register of Members’ Financial Interests; I am still a sitting councillor at Teignbridge district council. The Liberal Democrats support housing targets, but believe we need to win the case for that housing within the communities we represent, and that enforcing them from Whitehall without community consent will continue to fail to deliver the homes we need. Homes must be built to meet local need and not be driven simply by developers seeking the highest profits. Development has brilliant potential for providing a wealth of opportunities to rural communities, but that can be realised only by genuinely involving those communities in the decisions that affect them. That means the right houses in the right places. The Liberal Democrats welcome the Government’s decision to make housing a priority, given the desperate number of people denied the basic right to a safe and warm home. The Conservatives’ poor commitment to house building has left 8.5 million people in England with unmet housing need. The Conservatives let developers get away with building housing to poor standards, and without GP practices, schools and community infrastructure, which are badly needed. They also let them off the hook for leaving land for housing unbuilt and new homes empty. We believe everyone has a right to a safe and secure home, but without more support for councils, more people will be left without access to quality and affordable housing. The previous Conservative Government forced councils to do more and more with less and less, plunging many into financial crisis. Although we have welcomed this Government’s commitment to our call for multi-year funding settlements, with additional pressure on councils to accept national insurance contribution changes, it is essential that they are funded robustly to achieve those aims. We have been disappointed by the Government’s reluctance to commit to a target for social house building. In addition to an overall target for new homes, the Liberal Democrats would target 150,000 new social homes to tackle the housing shortage and homelessness crisis. We are committed to ensuring that house building does not come at the expense of our environment. The Government should not be either delivering house building or protecting our environment; they can and must do both. We welcomed the Government’s recent announcement that they are adopting the Liberal Democrat policy and wording mandating all homes to be built with solar panels, in a solar rooftop revolution. We also welcome the measures in the Renters’ Rights Bill to ban no-fault evictions and create a national register of licensed landlords. We believe that these steps are crucial to overcoming the housing crisis. Liberal Democrats have long called for leasehold reform to make house ownership fairer and more accessible—we have been campaigning against leasehold since Lloyd George introduced the people’s Budget. On the specifics of the standard method, I agree with my hon. Friend the Member for Horsham, who pointed out that it does not and cannot work—as did the right hon. Member for, I believe, the Isle of Wight.

• 13 May 2025 · Local Housing Need Assessment Reform · Hansard source

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  I thank my hon. Friend for securing this valuable debate. Does he agree that, as well as causing the issues he described, incremental building contributes to problems with the sewerage systems? If a developer builds 50 houses here, 50 houses there and 50 houses elsewhere, and each one is considered on its own merit, it does not warrant an upgrade to the sewerage systems, so the water companies do not upgrade, systems become overloaded and we start getting sewage in the water.

• 13 May 2025 · Local Housing Need Assessment Reform · Hansard source

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  My apologies to the right hon. Member. Since 2018, when the Conservative Government introduced the so-called standard method, which was supposed to calculate housing need, the country has suffered from a top-down, dysfunctional system that fails to prioritise the importance of affordability or the infrastructure necessary to support new development. The constant tinkering, with the introduction and subsequent withdrawal of various failed algorithms, has led to the near paralysis of our planning system. That came on top of the central Government’s starving local planning authorities of the resources they need to function, and the lack of direction as a result of no fewer than 13 changes of Conservative Housing Minister in the nine years from 2015. It is illiberal, and contrary to the interests of a community-led planning system, to remove options for how to assess housing need from local communities. Although the standard method of assessing housing need is likely to be followed by most authorities, councils with the resources and ability to assess housing need in ways more suited to their areas should be permitted to do so. All housing need assessments are, in any event, subject to the same scrutiny by the Government’s inspectors. In the district of Teignbridge, in which my Newton Abbot constituency sits, the average house price in 2019 was just under 11 times the average income. After a substantial increase in housing targets due to the standard method calculations, that ratio is going up, and the average house price is now over 11 times the average income. Housing developers build homes only as fast as they can sell them and at the price they need to protect their profit and viability, given the often extortionate prices they have paid for the land. Asking them, via the flawed standard method, to build more to reduce the price is much like asking the owner of a gold mine to increase extraction to a level that reduces the price of gold. It will not happen. A big part of the solution is to build more council homes, and I am proud to have overseen the resumption of council house building at Teignbridge for the first time in 30 years. I urge the Government to help more councils build more council homes to help more people.

• 6 May 2025 · Parking Regulation · Hansard source

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  It is a pleasure to serve under your chairmanship, Mr Efford. I congratulate the hon. Member for Derby South (Baggy Shanker) on leading this debate, which has been a collaborative effort and is beautifully well attended. Many private parking companies aim to make their record-making profits from the demands they issue via penalty charge notices, not being satisfied with their advertised parking fees. There is no incentive for them to operate fairly, to make PCN rules straightforward or clear, or to run a genuine appeals process. This model has worked on intimidation and threats, with the companies knowing that a fair proportion of people will be intimidated into paying. The process rapidly escalates into debt collection threats and solicitors’ letters. This cycle of threatening letters, which are often referred to as threatograms, tends to continue regardless of appeals or evidenced facts. The companies will point to their own independent appeals processes; however, such processes are neither independent nor fair. In fact, they are run by the trade associations: the British Parking Association and the International Parking Community. These organisations are directly funded and directed by the private parking companies, the biggest of which are owned by US private equity groups. For too long, this industry has been allowed to set its own rules and mark its own homework, always at the expense of the motorist, and the RAC and AA agree. There is a legitimate need for parking management to prevent abuse, but costs and tactics are out of proportion to any legitimate aims. Primary legislation already exists to create a truly independent regulator. We urge the Minister to progress the consultation on the existing draft code of conduct and set up the new regulator that is clearly necessary. These private parking companies are out of control, causing misery for far too many motorists. It has to stop.

• 6 May 2025 · Parking Regulation · Hansard source

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  I hear stories of places like Cornwall council being so strapped for money that they are considering sub-letting all their parking spaces to independent private parking companies, which will run them for nothing other than the fines they will take from tourists visiting Cornwall and residents. Does the Minister agree that this issue is urgent? I do not hear urgency in his timescales. I repeat the request for a specific timescale for introducing a code of conduct.