On Thursday, the UK government approved the first stage of lockdown easing. “Step one” of the government’s lockdown easing schedule will formally begin on Monday when the legal “stay at home” gets superseded by “stay local” guidance. We also note that the emergency powers vested in the government by Coronavirus Act 2020 have rolled over by parliament until the end of September, with ministers publically voicing an expectation that the government will bring forward a proposal to again extend those powers before they expire.
“Step four” of the unlocking plan is due no earlier than 21st June. On this date we expect the Financial Conduct Authority’s instruction of 24th September 2020 to the UK financial sector to be superseded. Until then the instruction from our regulator remains:
“Firms should continue to follow Government advice on working from home until notified otherwise.”
Until then, we do retain an exemption from lockdown restrictions ONLY when it is ‘critically essential’ to meet with consumers who have an ‘urgent need’ for something which can not be adequately handled via video conference, telephone call or, which could reasonably be delayed until restrictions are removed.
Like many businesses, we’re spending a lot of time trying to anticipate the COVID impact over the next few years. Our policies will evolve; however, our current thought processes are:
We do not expect to return to pre-covid normality during the remainder of 2021 or through 2022. It seems clear that until the pandemic becomes endemic, in a globalised world, with so many who have not being vaccinated and none of the current vaccines offering guaranteed immunity, then COVID mutations are likely to be ‘troublesome’ for some time to come.
All of our team have voluntarily confirmed their personal commitment to receive COVID vaccinations when invited to do so. Our priorities are protecting our clients, our team and our families (many of whom are in the COVID higher risk groups) from the risk of infection as a result of our activities, and, pending guidance from our regulator and subject to the provisions of Disability Discrimination Act and the Equality Act, we are currently minded to not engage with any new client for physical meetings, who has not accepted their COVID vaccinations. However, we will be pleased to offer our online/telephone service to such persons.
As a business, we will accept the government’s offer for workplace lateral flow tests to ensure that any member of our team who needs to attend a future physical face-to-face meeting with a client can be tested prior to that meeting. For mutual protection, we are considering the appropriateness of requesting that clients also obtain a lateral flow test before such meetings.
We anticipate that for a few years there may be a ‘seasonality’ to physical face-to-face meetings, with these happening predominantly during the spring and summer, and much less so during the autumn and winter. Existing clients, particularly those with limited digital capabilities will be prioritised for physical face-to-face meetings. We are considering (subject to the Disability Discrimination Act and the Equality Act) to refuse our service to prospective new clients who will not commit to the use of video-conference meetings when necessary. Should we adopt this policy, it will not apply to existing clients.
For the foreseeable future, we will continue to encourage the use of video-conferencing for meetings. We are continuing to invest in tools to try and make working with us at a distance simpler for our clients. All physical face-to-face meetings will be subject to social distancing and the use of PPE such as masks and visors in accordance with our COVID-Secure policy and government guidelines.
Please don’t hesitate to contact us should you have any queries.
