post

COVID-19 IMMIGRATION LAW UPDATE AS AT 29TH APRIL

Measures taken to fight the spread of COVID-19 have affected almost every aspect of life both in the UK and internationally. The UK immigration system is not immune from these measures, in particular given the wide travel restrictions and lockdown.

The Home Office has a dedicated section of its website for immigration issues related to COVID-19. This article is a brief summary, as at 29 April 2020, of a few of the key changes and concessions to immigration law and practice as a result of the coronavirus. The Home Office’s approach to immigration issues arising from the pandemic is, however, changing and being updated on an almost daily basis and we recommend that anyone seeking guidance please do contact us or check the Home Office website for the up to date position.

Tier 2 and Tier 5 Sponsors

The Home Office’s current position is that sponsors should, where possible, try to comply with the sponsor duties set out in the Sponsor Guidance. However, a sponsor that cannot comply due to the pandemic, but is taking a reasonable and pragmatic approach, should not be penalised.

The Home Office has issued COVID-19 guidance for organisations that sponsor overseas workers under Tiers 2 and 5 of the Points Based System. It promises not to take any enforcement action against anyone who continues to sponsor employees despite absences due to COVID-19 (the guidance also covers Tier 4 students).

  • Reporting Obligations

Ordinarily, sponsors are required to report a change in the workplace of an employee and any absences over 4 weeks. The Home Office has relaxed these reporting requirements. In light of the fact that most employees are now working from home, there is no need to report this as a change in work location. There is also no requirement to report any employee absences that have been the result of the consequences of the COVID-19 outbreak. Sponsors will also not be required to withdraw sponsorship for employees where any absence extends beyond 4 weeks and is unpaid. Sponsors should, however, continue to report other changes, for example if a sponsored employee is working out of another office abroad. Sponsors should also ensure that they continue to be able to monitor attendance at work as part of their other ongoing reporting and monitoring duties. Sponsors will need to report any termination of a sponsored worker’s employment as normal. This will, of course, also have immigration implications for individual employees.

  • Reduction in pay – Furlough arrangements:

Sponsors are now also permitted to cut the pay of sponsored employees to 80% of salary, or £2,500 a month (whichever is lower). Any changes must be part of a company-wide policy to avoid redundancies in which all workers are treated the same. This concession applies regardless of the SOC code minimum salary. The reduction is permitted as a temporary measure, and, once the furlough arrangement has ended, the salary must return to the previous rate in accordance with the Certificate of Sponsorship. Sponsors must report all salary changes to the Home Office. 

  • Certificates of Sponsorship (CoS) – Validity and Delay in Start dates

A Restricted CoS must be assigned within three months. Once assigned, it must be used within three months. If either of the three month deadlines is missed, the CoS will become invalid and a new CoS will be required. However, if the CoS became invalid because the employee was unable to travel due to the COVID-19 pandemic, it may still be accepted by the Home Office. Applications will be considered on a case-by-case basis.

  • Employees with pending in-country Tier 2 or 5 visa applications

Sponsors may allow employees to start work before their visa application has been decided provided that (i) a CoS has been assigned, (ii) their application was submitted in-time before their current visa expired and (iii) the role they are employed in is the same as the one on their CoS.  

Reporting responsibilities for an employee start from the date the CoS was assigned, not from the date that their application is granted. Any changes that will impact the eventual consideration of the migrant’s visa application should be updated on the CoS, as normal. If the employee’s application is eventually rejected as invalid or refused, their employment must be terminated.

Visa applications and extensions

  • Migrants in the UK with a visa expiring between 24 January 2020 and 31 May 2020 will have their visa extended to 31 May 2020 if they cannot leave the UK because of travel restrictions or self-isolation related to COVID-19. The extension is not automatic and needs to be requested from the Home Office via an online form. 
  • Migrants applying to stay in the UK long-term can apply from the UK to switch to a long-term UK visa until 31 May 2020. This applies where migrants would usually need to apply for a visa from their home country. For example, a visitor could apply from the UK to switch to a Tier 2 or family visa. The concession is limited to migrants whose visa is due to expire by 31 May 2020.
  • UK Visa and Citizenship Application Centres run by SOPRA STERIA in the UK are temporarily closed. If your visa is due to expire, you should submit an extension of leave application online in the normal way before the date of expiry of your visa in order to protect your position and to prevent becoming an overstayer. Priority and super-priority processing is not currently available. Your application will not be processed until the biometric centres have re-opened and you have been able to attend a biometric appointment. Your supporting documents can, however, be uploaded in the meantime on the SOPRA STERIA website.
  • For migrants wishing to apply for a visa from outside the UK, Visa Application Centres are also closed. Migrants can submit their online applications as normal although the processing will be delayed until the Visa Application Centres re-open and they can attend a biometric appointment.
  • If you have already secured entry clearance to the UK but cannot use it before it expires, you can request a replacement visa with revised validity dates free of charge until the end of this year. Please note that this does not include visit visas.  As the visa application centres abroad are closed, the replacement visa will not be issued until the centres re-open.
  • In addition, applicants with an endorsement in the Global Talent, Start-up and Innovator categories may still be eligible for a visa even if the endorsement has expired. They are encouraged to apply as planned and the Home Office will consider all applications on a case by case basis.

Conclusion

Parliament has made very clear that no one should have a negative outcome through the immigration system due to a circumstance that was beyond their control. Reality does not, however, always reflect political pronouncements or aspirations. So far, Home Office staff have shown themselves willing to be flexible in some areas. However, it is very important to check the position on a case by case basis and to keep abreast of the guidance as it is published.

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She can assist both corporate and individual clients with any immigration, nationality or asylum matter and possesses a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters. Alice has substantial experience of challenging UK Home Office decisions, regularly representing clients in appeals at both the First-Tier and Upper Tribunal and also by way of Judicial Review applications in both the Upper Tribunal and UK High Court.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental  sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way.

For more information or assistance with a particular query, please in the first instance contact Adam Mikula on 020 7947 5354 or by email on adm@prospectlaw.co.uk.

For a PDF of this blog click here

post

BREXIT: AN UPDATE ON THE EU SETTLEMENT SCHEME

Despite Brexit feeling like an ever-receding dream (or fast approaching nightmare depending on your political perspective), the EU Settlement Scheme is up and running and applies to all EU citizens and their family members currently living in the UK. The deadline for EU citizens and their family members to apply to the Scheme is 31 December 2020 if the UK leaves the EU without a deal, or 30 June 2021 if the UK leaves with a deal.

EU citizens and their family members who, at any point before the deadline, have been continuously resident in the UK for five years are eligible to apply for “settled status” enabling them to remain living in the UK indefinitely. EU citizens and their family members who arrive before the deadline, but who have not yet been continuously resident here for five years, are eligible to apply for “pre-settled status”, enabling them to remain living in the UK until they have reached the five-year threshold. They can then also apply for settled status.

Some of the key features and ‘benefits’ of the Scheme are as follows:

  • Pre-settled status and settled status are granted primarily on the basis of a simple test of residence in the UK. There is no requirement for the EU national to be “qualified” which, under the previous EEA regulations, meant working or a student or self-sufficient with private health insurance. This is good news for the many non-EU nationals who, under the previous rules, could not have applied for leave to remain in the UK solely on the basis of their relationship with their EU family member where that EU family member was not “qualified”;
  • Compared to other UK visa application routes, the Scheme is relatively user friendly and, in our experience so far, caseworkers do seek to grant status rather than refuse it (which is as promised when the Scheme was introduced);
  • The application process is online and normally no original documents need to be submitted to the Home Office. If they do need to be submitted, they are normally returned very quickly;
  • Decisions are currently being made within a couple of days or at most within a month;
  • The EU Settlement Resolution Centre has a telephone number which works and a person on the end of the telephone with whom an applicant can discuss an application in detail and seek advice;
  • Applications under the Scheme are free.

However, the government has been criticised for many aspects of the scheme, including the following:

  • Calls to the EU Settlement Resolution Centre, whilst helpful, are not free – this undermines the goodwill extended to EU citizens through the scrapping of the application fee;
  • Why does the application deadline in a no deal scenario need to be sooner than if the UK leaves the EU with a deal? A no deal scenario in October would leave EU citizens with only 14 months within which to regularise their status;
  • Under the current provisions of the Scheme, a right of appeal following an unsuccessful application under the Scheme will only be available in the event that the UK leaves the EU with a deal – we see no good reason why such a right should not be available in the event that the UK leaves without a deal as well;
  • There is no clarity as to what will happen to EU citizens and their family members currently resident in the UK who fail to confirm their immigration status through the Scheme before the deadline. In giving evidence to a recent parliamentary committee, the Home Secretary himself appeared unsure what their status and rights would be;
  • It is also unclear whether the Home Office would automatically contact or pass on information to any agency, Government department or individual (such as an employer or landlord) following an applicant’s unsuccessful application to the Scheme;
  • Failing to confirm in primary legislation the right of EU citizens, resident in the UK at the time of its exit from the EU, to remain in the UK. No-one should be left without rights because they have not made an application under the Scheme;
  • Failing to provide all EU citizens who successfully apply to the Scheme with hard copy written confirmation of their status; applicants currently only receive electronic confirmation.

Despite its shortcomings, given the fact that applications under the Scheme are free and decided quickly, we recommend that EU nationals and their family members do make an application under the Scheme as soon as possible. This might give some reassurance in the uncertain political climate. Please do not hesitate to contact us if you have any questions at all regarding your status under the Scheme, or the status of someone you know. We would be delighted to assist you with your application should one be required.   

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She can assist both corporate and individual clients with any immigration, nationality or asylum matter and possesses a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters. Alice has substantial experience of challenging UK Home Office decisions, regularly representing clients in appeals at both the First-Tier and Upper Tribunal and also by way of Judicial Review applications in both the Upper Tribunal and UK High Court.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental  sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way. The above is only a very brief summary of some of the principal changes the Home Office has announced. Please contact us for further detail, or if we can assist you in connection with any of the applications mentioned in this article.

For more information or assistance with a particular query, please in the first instance contact Adam Mikula on 020 7947 5354 or by email on adm@prospectlaw.co.uk.

post

INVESTORS AND ENTREPRENEURS: AN UPDATE ON THE TIER 1 VISA ROUTE

The Home Office published a detailed statement of changes to the Immigration Rules on 7th March, in which they confirmed that the Tier 1 (Graduate Entrepreneur) and the Tier 1 (Entrepreneur) route are to be replaced by “Start-up” and “Innovator” visas.

These changes also clarify details of their significant reforms to the Tier 1 (Investor) requirements.

Click here to read the Home Office’s detailed statement of changes

Start-up and Innovator Visas

On 29 March 2019, the Tier 1 (Entrepreneur) route will close and the Tier 1 (Innovator) route will open in its place. The required investment for this route has decreased from £200,000 to £50,000.

On 6 July 2019 the Tier 1 (Graduate Entrepreneur) route will close and the Tier 1 (Start-up) route will open in its place. This visa is for those starting a new business for the first time in the UK. Applicants will no longer need to be graduates and will not need to have secured any initial funding.

For both these routes, however, applicants will now need to be endorsed by trusted organisations in the UK, such as “business accelerators, seed competitions and government agencies, as well as higher education providers”. The endorsing body will be obligated to judge the applicant’s business plan, to assess if their business is “innovative, viable and scalable”. Successful applicants will need to stay in contact with those endorsing bodies regularly and will require further endorsement when applying for extensions to their visas. These will require them to prove they have made significant achievements in line with their business plan. A higher level of English will also be required.

Applications for Indefinite Leave to Remain will also require a further endorsement letter.  In order to receive this endorsement, the applicant will have to satisfy several requirements, including evidence to showing that they have successful businesses employing numerous people or generating significant revenues.

Tier 1 (Investor)

There will be significant changes to the Tier 1 (Investor) route from 29 March 2019. These primarily affect the types of permitted investment and the source of an investor’s funds.

Permitted Investments

Applicants will no longer be able to invest their money in UK government bonds. Instead, they will have to invest in active and trading UK companies. The rules on routing investment funds via “intermediary vehicles” will also become stricter, and will include a requirement that such vehicles be regulated by the Financial Conduct Authority. The definition of “active and trading” companies is also being tightened.

Source of Funds

The period for which funds must be held prior to applying for an investor visa will be increased from 90 days to two years. However, this requirement can be circumvented (as is possible under the current rules), if you can provide mandatory evidence of the source of your funds. Furthermore, the requirement to open a UK bank account before applying for an investor visa will also be tightened, to make explicit that the bank must carry out all required due diligence checks and confirm that these have been done.

Please note that there are transitional arrangements in place for those on existing Entrepreneur and Investor visas.

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She can assist both corporate and individual clients with any immigration, nationality or asylum matter and possesses a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters. Alice has substantial experience of challenging UK Home Office decisions, regularly representing clients in appeals at both the First-Tier and Upper Tribunal and also by way of Judicial Review applications in both the Upper Tribunal and UK High Court.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental  sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way. The above is only a very brief summary of some of the principal changes the Home Office has announced. Please contact us for further detail, or if we can assist you in connection with any of the applications mentioned in this article.

For more information or assistance with a particular query, please in the first instance contact Adam Mikula on 020 7947 5354 or by email on adm@prospectlaw.co.uk.

For a PDF of this blog click here

post

POST-BREXIT IMMIGRATION UPDATE –WHITE PAPER PUBLISHED

The UK government published a White Paper yesterday setting out its plans for post-Brexit immigration, which are expected to be brought into force from 1 January 2021.

The long awaited White Paper (WP) is the official approval by the government of the recommendations made by the Migration Advisory Committee in September 2018.

Click here to view the full white paper.

Post-Brexit Immigration

The White Paper proposes a single, skills-based immigration system, focused on talent and expertise rather than nationality. Essentially the proposal is to continue with our existing points based immigration system but to bring EU nationals within it.

It includes the following positive changes:

  • Removing the quota on Tier 2 General visas: The WP proposes to remove the cap on these visas which is currently set at 20,700 per year.
  • Removing resident labour market test: The WP proposes to abolish the requirement for employers to complete a Resident Labour Market Test (RLMT) before sponsoring a foreign worker for a Tier 2 General Visa. Currently, employers are required to advertise a vacancy for 28 days to confirm that no British or EEA nationals are suitable for the role.
  • New short-term visa for low-skilled workers: The WP proposes to create a new visa category for low-skilled workers, allowing initial visas up to 12 months that will not require employer sponsorship. The 12 month visa will provide the right to work, but people arriving on this route will not be able to bring family members with them or take benefits nor will they accrue rights to settle in the UK. They will also have a 12-month cooling off period once their visa expires.
  • No visa for EU visitors: The WP proposes that EU nationals would be able to enter the United Kingdom for short-term trips as tourists or business visitors without a visa.
  • Consultation on salary threshold: The WP confirms that UK authorities will launch a public consultation on the current minimum salary requirement of £30,000 for Tier 2 (General) Visa applications.
  • There are also proposals for improved border security checks and an Electronic Travel Authorisation (ETA) Scheme including allowing citizens from Australia, Canada, Japan, New Zealand, USA, Singapore and South Korea to use e-gates to pass through the border on arrival, alongside EU and UK citizens.

The proposed changes would partly address a number of concerns expressed by businesses over the past months, including the anticipated drain of low-skilled EU workers after Brexit. It would also hopefully make the system much quicker given the removal of the Tier 2 quota and the RLMT. Conversely, the government admits that these proposals could reduce the UK workforce by between 200,000 and 400,000 EEA nationals over the first 5 years meaning that GDP would be between 0.4 and 0.9% lower than it otherwise would have been in 2025.

This new immigration system will be implemented in a phased approach from 2021 following an extensive 12-month programme of engagement with businesses, stakeholders and the public by the Home Office. The proposals may of course change depending on any future trade deal struck with the EU.

EU Citizens already living in the UK

It is important to note that the White Paper outlined above is about the UK’s future post-Brexit migration system and does not affect EU citizens already living in the UK, who will be able to (and will need to) apply for “settled status” in order to stay legally after Brexit.

In summary under the terms of the proposed Settlement Scheme:

  • EU citizens and their family members who, by 31 December 2020, have been continuously resident in the UK for five years will be eligible for “settled status” enabling them to stay indefinitely;
  • EU citizens and their family members who arrive by 31 December 2020, but will not yet have been continuously resident here for five years, will be eligible for “pre-settled status”, enabling them to stay until they have reached the five-year threshold. They can then also apply for settled status;
  • EU citizens and their family members with settled status or pre-settled status will have the same access as they currently do to healthcare, pensions and other benefits in the UK;
  • Close family members living overseas will still be able to join an EU citizen resident in the UK at any time after 2020, where the relationship existed on 31 December 2020 and continues to exist when the person wishes to come to the UK. Future children are also protected; and
  • Settled status will only be lost after 5 years’ absence from the UK.

No Deal

If we leave the EU on 29 March 2019 with no deal, the protections on offer to EU citizens will be diluted as follows. See the Department for Exiting the EU’s no-deal paper on citizens’ rights published on 6 December 2018 for further detail:

  • The Settlement Scheme will only apply to EU citizens who arrive before 29 March 2019 rather than as currently planned for EU citizens arriving up to the end of 2020.
  • There will be a shorter deadline for applications, of 31 December 2020, rather than 30 June 2021.
  • There will be no right of appeal to an immigration judge to challenge a refusal of settlement under the scheme.
  • There would be a cut-off point of 29 March 2022 for family members of EU citizens with settled status to join them in the UK.

There is so far no clarity on the status of EU nationals arriving in the UK between 30 March 2019 and 1 January 2021 in the event of no-deal.

On the plus side in a no-deal scenario, the Home Office says that the Settlement Scheme would still be generous and user-friendly, with case-workers “looking to grant status, not for reasons to refuse”. The Home Office are not always known for being generous and user friendly so this would be a welcome development.

Please note that if you are an EU national and have already been living in the UK for several years, you may already have acquired a permanent or other right of residence under existing EU regulations. Given that the UK is still for the moment a full member of the EU and depending on your personal situation, it might be a good idea to regularise your situation now to ensure minimal disruption over the next few years.

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She can assist both corporate and individual clients with any immigration, nationality or asylum matter and possesses a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters. Alice has substantial experience of challenging UK Home Office decisions, regularly representing clients in appeals at both the First-Tier and Upper Tribunal and also by way of Judicial Review applications in both the Upper Tribunal and UK High Court.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way.

For more information or assistance with a particular query, please in the first instance contact Adam Mikula on 020 7947 5354 or by email on adm@prospectlaw.co.uk.

For a PDF of this blog click here

post

HOME OFFICE ANNOUNCES A U-TURN ON SUSPENSION OF TIER 1 (INVESTOR) ROUTE

Further to our report last week that the Tier 1 (Investor) Visa scheme was to be suspended, the Home Office has now confirmed that applications under this category can still be submitted.

This immigration route will, however, be reformed in the spring due to concerns about its use for money laundering purposes. Whilst full details of the proposed reforms are not yet available, the Home Office clearly intend to make the rules tougher and will most likely insist on applicants’ financial and business interests being assessed by independent auditors.

If you are a potential investor that is considering this immigration route, it might be advisable to submit your application as soon as possible, whilst the current rules remain in place.

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She has specialised in immigration since 2003, is accredited as a Senior Caseworker at Level 2 and a Supervisor under the Law Society’s Immigration accreditation scheme. Alice can assist both corporate and individual clients with any immigration, nationality or asylum matter. She has a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters.

If you require any advice on these changes or other possible visa routes into the UK, please contact Alice Boyle on +44 (0)7775 902 935 or ajb@prospectlaw.co.uk.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way.

For a PDF of this blog click here

Click here to read our previous article on this topic

post

HOME OFFICE ANNOUNCES SUSPENSION OF TIER 1 (INVESTOR) VISAS

The Tier 1 (Investor) immigration route will be suspended until further notice from midnight on Friday 7 December, the Home Office announced last night.

These “golden” visas are granted to applicants who are able to show that they have at least £2 million to invest in the UK economy, and have proved very popular with wealthy overseas investors and high net worth individuals. Depending on the amount of money an applicant has to invest, they provide a relatively quick route to settlement and British citizenship.

The scheme will re-open for applications at some point in 2019, with major changes to the rules such as the removal of government bonds from the list of acceptable investments. Instead, applicants will need to invest in active and trading UK companies, and they will also be required to provide comprehensive audits of their financial and business interests.

These changes have come about after a government review of the visa as part of a crackdown on money laundering in the UK.  Immigration minister Caroline Nokes said:

The UK will always be open to legitimate and genuine investors who are committed to helping our economy and businesses grow. However, I have been clear that we will not tolerate people who do not play by the rules and seek to abuse the system….

That is why I am bringing forward these new measures which will make sure that only genuine investors, who intend to support UK businesses, can benefit from our immigration system.”

A statement of changes to the Immigration Rules is due to be laid before Parliament later today.

About the Author

Alice Boyle is a solicitor with extensive experience in all areas of immigration law. She has specialised in immigration since 2003, is accredited as a Senior Caseworker at Level 2 and a Supervisor under the Law Society’s Immigration accreditation scheme. Alice can assist both corporate and individual clients with any immigration, nationality or asylum matter. She has a sound understanding of Tier 1 Investors, Tier 1 Entrepreneurs and Tier 2 matters.

If you require any advice on these changes or other possible visa routes into the UK, please contact Alice Boyle on +44 (0)7775 902 935 or ajb@prospectlaw.co.uk.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

This article is not intended to constitute legal or other professional advice and it should not be relied on in any way.

For a PDF of this blog click here