Muhammad Tayyab

Investment and Portfolio Management Final Project Submitted by: Muhammad Tayyab -) Submitted to: Mr. Syed Mubashir Ali Shah Quaid-i-Azam School of Management Sciences, Quaid-i-Azam University, Islamabad Page 1 of 24 Central Depository Company Central Depository company is a Pakistani central securities depository which deals with different services which includes debt, equity, and other financial instruments. It was founded in 1993 and is based in Karachi, Pakistan. They also have offices at Lahore and Islamabad. CDC is regulated by Securities and exchange commission of Pakistan. This company is basically responsible for maintaining and operating the depository system. The depository system solely takes care of electronic settlement of shares on the stock exchange of Pakistan. This facility allows client to transfer shares and securities from one-person account to another through electronically avoiding the inconvenience of hand to hand transfer. This company has done great work and got the image of infrastructure backbone and the ultimate custodian of the Pakistan Capital Market. According to the Companies Act, 2017, CDC holds the status of Public Interest Company and Large Sized Company since it holds the assets of public as guardian capacity. CDC is ISO/IEC 27001:2013 certified for Information Security Management and ISO/IEC 22301:2012 certified for its Business Continuity Management Program. It is also an approved employer by ACCA, ICAP, ICAEW and CIMA. CDC is a member of Asia-Pacific Central Securities Depository Group (ACG), which is an international organization facilitating the exchange of information, promoting mutual assistance among member securities depositories and clearing organizations in the Asia Pacific region. Vision Page 2 of 24 To be a world-class institution providing innovative and reliable services primarily to the capital and financial markets, stimulating business growth and maximizing benefits for all stakeholders. Mission Provide secure, reliable, and innovative solutions that systematically reduce risk, enable transparency, and bring efficiencies to Financial and Capital Markets. To be the centre of excellence by continuously employing state of the art technology and best talent in the country while maintaining good corporate governance. Ensure to provide employees with an environment of professional and personal growth and to society, we firmly believe in giving back to the community. Core Values These are the core values which are strictly followed to make this entity work effectively and efficiently. 1. Reliability  Reliable and trustworthy for our every stakeholder.  No compromise on integrity and security of information. 2. Integrity  Fair, honest and transparency in all our dealings.  Take responsibility for our actions.  Endeavor to perform to the finest of our capacities. 3. Transparency Page 3 of 24  Approaches and methods are clearly characterized, well communicated, and connected similarly to all.  Make adequate disclosure of company information.  Strong adherences to the best practices of Corporate Governance. 4. Teamwork  Build strong relationships within and across functions.  Share ideas and best practices and value diversity.  Communicate candidly and on an ongoing basis within team. Sponsors and Share holders S. No Shareholders Total No. of Shares % of Held Shareholding 1 Pakistan Stock Exchange Limited 79,616,000 39.81 2 MCB Bank Limited 30,000,000 15.00 3 Habib Bank Limited 22,692,000 11.35 4 LSE Financial Services Limited 20,000,000 10.00 5 National Investment Trust Limited 12,692,000 6.35 6 Industrial Development Bank Limited 10,000,000 5.00 7 Pak Company 10,000,000 5.00 China Investment Limited Page 4 of 24 S. No 8 Shareholders Crescent Steel and Allied Products Total No. of Shares % of Held Shareholding 5,500,000 2.75 5,000,000 2.50 Limited 9 ISE Towers REIT Management Company Limited 10 Allied Bank Limited 2,000,000 1.00 11 IGI Investments (Private) Limited 1,299,996 0.65 12 Innovative Investment Bank Limited 1,000,000 0.50 13 Crescent 200,000 0.10 4 – 200,000,000 100 % Standard Business Management (Pvt) Limited 14 Others * TOTAL CDC Services: The main operation of the CDS was to take care of the functions carried out in Pakistan capital Market regarding financial instruments. But with the passage of time the use and efficiency of the technology increased rapidly in other markets and industries so to meet the hour of the need this company started diversified services beyond the traditional depository domain. Page 5 of 24 Investor Account Services  This service was started in 1999  In this service corporate and retail investor can open and maintain custody directly with CDC. 1. Trustee and Custodial Services  It was started in 2002  Serves as a Trustee to Open-end and Closed-end Mutual Funds and Voluntary Pension Schemes. 2. CDC Share Registrar Services Limited (Wholly owned subsidiary of CDC)  It was launched in 2008.  This service includes providing share issuing companies state of the art facilities of registrar and transfer agents, including customer dealing on behalf of the companies. 3. IT Minds Limited (Wholly owned subsidiary of CDC)  Launched in 2009  This includes providing business process outsourcing (BPO) services which include provision of back office accounting functions to the Mutual Fund industry. 4. Centralized Information Sharing Solution for Insurance Industry (CISSII)  Launched in 2014  Offers online data sharing arrangement for the insurance industry. 5. E-Services Page 6 of 24  Launched in 2017  A customer convenience initiative by CDC, in the form of a web portal offering the following free-of-cost facilities:  Centralized e IPO System: This involves the Applications for subscription of shares offered to public can be made electronically and payments can be made by Internet and Mobile banking, ATMs etc., avoiding the hassle of physical submission of IPO application and visiting the bank.  E-Dividend Repository: Provides investors consolidated data of all their cash benefits due and credited by issuers, and in case their dividends have not been credited, the reason for non-disbursement of dividend will also be available. Statistics Information Facts Number of Share 149.59 billion Value of Shares PKR 4.19 Trillion Total Number of Subaccounts 250,185 Number of Securities 938 Number of Retail Investor 57,285 Total Number of Shares in Investor Account 88.81 Billion Page 7 of 24 Percentage of shares in CDS with respect to share Capital 76.49% Total Number of Mutual Funds and Pension funds PKR 878 Billion Total Net Assets in Custody with trustee and Custodial Services 207 Total Number of Securities under Transfer agent Services 202 Legal Frame of Work Central Depository Company of Pakistan Limited was formed under Central Depositories Act 1997 which was passed on June 10, 1997. Subsequently, Central Depository Company of Pakistan Limited Regulations were developed and approved by the Securities and Exchange Commission of Pakistan. Relevant Legislation:  Central Depositories Act, 1997  Central Depository Company of Pakistan Limited Regulations  Central Depositories (Licensing & Operations) Regulations, 2016  CDC Regulations in Urdu Language Securities Act 2015:  Securities Act 2015 PSX Rule Book:  PSX Rule Book Page 8 of 24 NCCPL Regulations:  NCCPL Regulations Companies Act 2017:  The Companies Act, 2017 SECP Roles for CDC SECP Laws  NTN Number:-  License to act as Central Depository granted by SECP under Securities Act, 2015 dated-.  Certificate of Registration to Act as Trustee granted by SECP under Non-Banking Finance Companies and Notified Entities Regulations, 2008 dated December 19, 2017. Statutory Auditors:  F. Ferguson & Co.  CDC Share Registrar Services Limited Internal Engagement CDC is an active member of the following regional and international groups:  Asia-Pacific Central Securities Depository Group (ACG)  ACG logo for international engagement CDC is a member of ACG, which is an international organization facilitating the exchange of information, promoting mutual assistance among member securities depositories and clearing organizations in the Asia Pacific region. Page 9 of 24 Established in 1997, ACG is a regional platform of 34 depositories and clearing organizations from 23 member countries. Today, ACG represents Asia on various international platforms such as World Forum of CSDs (WFC), International Securities Services Association (ISSA), Association of Global Custodians (AGC) and the Committee on Payment and Settlement Systems of the International Organization of Securities Commissions (CPSS-IOSCO). In 2013, Mr. Muhammad Hanif Jakhura, CEO-CDC was elected as the Executive Committee Chairman of ACG for the term of-. By virtue of this election, CDC was elected as the ACG Secretariat for the term of-. CDC has also introduced the “Risk and Recovery Management Task Force” in ACG whose objective is to promote Risk Management culture among ACG members and to develop an effective Risk Management Framework. CDC was elected as the convener of the same. CDC hosted ACG’s 10th Annual General Meeting in 2006 in Karachi, Pakistan, which was attended by around 60 delegates from 18 regional countries. Association of National Numbering Agencies (ANNA) CDC, along with the depositories around the world, serves as a member to the Association of National Numbering Agencies (ANNA). It is the global representative of numbering agencies operating around the world where member companies regulate identification of local securities for trading locally and internationally. The service bureau at ANNA receives daily reports and updates from member and partner numbering agencies around the world. It serves as the centre point of information dissemination and collection of securities data since 2001. Page 10 of 24 For the last two decades, CDC serves as the sole National Numbering Agency (NNA) issuing ISINs (International Securities Identification Numbers) to standardize identification of local securities of trading and settlement in the country and abroad. The purpose of NNA is to receive information regarding registration from issuers of securities and financial instruments such as shares, bonds and derivatives directly, and then to issue codes that uniquely identify these instruments. This code is called International Security Identification Number (ISIN), coined under ISO 6166 that identifies fungible and non-fungible securities from one another. As of June 2018, CDC has assigned 2,265 ISINs. The badge of global association representing Pakistan at ANNA is one of CDC’s many achievements as it continues to maintain its leading position in the country. Collaborating with ANNA allows CDC to continue its journey of progress and innovation while continuously building state-of-the art mechanisms, products and services that are pivotal to Capital Market development. Memorandums of Understanding (MoUs) CDC has signed a number of Memorandums of Understanding (MoUs) with other depositories to gain benefits of cross-border cooperation, explore avenues of mutual assistance and enhance coordination. These MoUs entail cooperation in the areas of technology exchange, operational processes, mechanism for cross-border listing of securities, and exchange of information. These include the following prestigious depositories:  Abu Dhabi Securities Market (ADSM)  China’s Securities Depository & Clearing Corporation (SD&C)  Depository Trust & Clearing Corporation (DTCC), U.S.A.  Dubai Financial Market (DFM)  Indonesia Clearing & Guarantee Corporation (KPEI) Page 11 of 24  Japan Securities Depository Centre (JASDEC)  Korean Securities Depository (KSD)  MKK Turkey  Taiwan Depository & Clearing Corporation (TDCC)  Thailand Securities Depository (TSD)  Maldives Securities Depository (MSD) Capital Market Development Since its inception, CDC has been taking initiatives for the creation of an efficiently functional marketplace and making a remarkable difference to how it operates. From ensuring the smooth functioning of the market with steadfast operations to constant scrutiny of risk management processes and the resulting upgrades, the routine protocol practices and contingency planning rehearsals, to continuous investor awareness efforts, CDC has been the leading force in Capital Market development. We have focused primarily on empowering the people, safekeeping their assets and investments and secondarily on the improvement of mechanisms and processes. National Clearing and Settlement System (NCSS) Formulated by the CDC management, National Clearing Company operates the National Clearing and Settlement System (NCSS), another capital market infrastructure mechanism, providing settlement and clearing facilitates to all three exchanges for trades in eligible securities. Clearing and settlement are among the most important aspects in the operation of the securities business. It is the process of reporting, matching, correcting securities transactions and the ultimate delivery or receipt of net balances. Page 12 of 24 Formerly managed by the CDC management, NCCPL is registered as a separate legal entity and now independently manages the National Clearing and Settlement System (NCSS). Automation of Security Transfer Mechanism A core contribution that CDC has made is the automation of security transfer mechanism. The project, implemented as a collaboration between NCCPL and CDC, was launched in 2008 with the objective of ensuring that all movements associated with security transfer are done efficiently while reducing downtime and further mitigating any risks or possible data theft. CDC Security Transfer Mechanism was designed to speed up settlement via the Partner’s Main Account. The automation allowed for restricted use of Main Account where transactions were only to be viewed in exceptional circumstances and permitting the process of settlement to be directly reflected on the accounts of the investors, thereby limiting manual entries. The first Balance Order, executed by adopting the automated process, was launched on December 27, 2010, marking significant improvements in the settlement of securities transactions. This complex, interconnected project was weaved and assessed with detail and successfully delivered by both teams working at NCCPL and CDC. Induction of National Savings Bonds (NSB’s) in CDC CDC takes pride in serving as the custodian of multiple instruments traded in the Pakistan Capital Market. In line with its vision of digitizing and de-materializing instruments for consequent improvement of operational efficiency and elimination of risk of loss & damage, CDC has launched the National Savings Bonds (NSB’s) in book entry form as part of its system. All variants of NSB’s are available in maturities of three, five and ten years, with 12.50%, 12.55% and 12.60% return rates, respectively. The induction of NSBs in Central Depository System (CDS) has made their handling more convenient and secure for investors, as it has Page 13 of 24 eliminated their risk of loss and damage of physical certificates. This facility has further removed the inconvenience of delivering physical documents to multiple parties, significantly improving efficiency, and reducing cost of managing these certificates in physical form. An investment in an NSB can be made through subscription, with registration under the name of the investor with Central Depository Company (CDC). Considering there was no limitation of size, a minimum, uncapped offer of Rs. 20,000 has been placed as subscription. It is obligatory for investors to open an Investor Account/Sub Account that would permit them to hold their securities in book-entry form. These bonds can be bought by individuals as well as through mutual funds, gratuity, pension, provident fund or trust, excluding body corporate and banks. It will then become listed on all the stock exchange. Foreign residents living abroad can make their investment by payments remitted through official banking channels. Implementation of Maximum Limit on Asset under Custody Asset under custody implies the aggregate worth of all securities maintained with the Broker Participant, exclusive of instruments maintained in the House Account and those that are in blocked form. Under a joint initiative undertaken by CDC and Securities and Exchange Commission of Pakistan (SECP), a security protocol has been embedded to restrict the number of securities held by Trading Rights Entitlement Certificate (TREC Holder) Participants (Brokers). “Limit on Assets under Custody” prescribes a limit to the extent of which a TREC holder (Broker) may have custody of securities under their control. As per the regulations coined by SECP, the Maximum Custody Limit is 25 times the Capital Adequacy level. The adequacy level has been pre-defined and is applicable to all TREC holders to maintain compliance. CDC Page 14 of 24 has also devised a set of periodic actions which will be taken against a TREC holders in case of non-compliance of these procedures. Centralized e-IPO System In its dedication to cater to its customers right down to the singular level, CDC has introduced a Centralized e-IPO System (CES) which enables investors to submit their online subscription applications for securities offered via the Initial Public Offering (IPO). The service is readily accessible to the public and aids the process of payment through various banking channels of 1Link member banks such as such as internet banking, Automated Teller Machines, mobile banking and Over the Counter. E-Dividend To speed up receiving dividends given by companies, CDC has introduced its e-Dividend Repository which will help investors receive their payments directly into their accounts as well as assist them in tracking their dividends. This repository has been designed as a web-based portal with global accessibility and provides the investors with a holistic overview of their earnings. Additionally, it identifies reasons of non-disbursement in case payments have not been made. Furthermore, to help investor file their tax returns, it issues certificates which summarize areas such as dividend rates, net dividend paid, tax and zakat deductions etc. The service is offered free of cost and requires a simple registration with the CDC eService portal which will allow the investor to avail this service. E-LOR (electronic Letter of Rights) Another initiative undertaken by CDC in its endeavour of capital market transformation through digitization is the Electronic Letter of Rights (e-LOR) launched in 2015. The e-LOR can be availed by the investors through CDC Web Access portal by subscribing to Online Transactions and allows investors submit online Transaction Orders for right subscription. Page 15 of 24 After the requisite payment by the investor against the right shares subscribed, they will be automatically transferred into his account on the due date. Revamping of the Capital Gain Tax (CGT) regime CDC has worked closely with the National Clearing Company of Pakistan (NCCPL) on the Computation and Revamping of the Capital Gain Tax (CGT) regime. CDC collaborates with NCCPL for the provision of CGT data which is calculated under the First In First Out (FIFO) Method. NCCPL receives the data to derive, accumulate and deposit the CGT earned to the national treasury on behalf of all capital market investors. It is noteworthy that all transactions and trades reflected on trade platforms and the transfer of securities through free delivery in the Central Depository System (CDS) are covered under CGT Regime. All capital gains arising on redemption of units of open-ended mutual funds and on trading of future commodity contacts at Pakistan Mercantile Exchange (“PMEX”) are included in CGT Regime of NCCPL, from July 1, 2016. Margin Trading/ Financing CDC has also rendered its support in improving and transforming the processes adopted in Margin Financing (MF) and Margin Trading (MT). Account Holders that are deemed Trading Financers by NCCPL can request CDC to open their MF account, while Account Holders that are deemed Eligible Financers by NCCPL can request CDC to open their MT account. Free Float Free Float is the remainder of total shares in the market subtracted by treasury stocks and shares held by institutions and are traded publicly. Companies are obliged to fulfil the free float requirement to be able to trade in the stock market. CDC has also contributed greatly to enhance the paradigm of free float in the Pakistan Capital Market. All reports and data are maintained Page 16 of 24 in the Central Depository System (CDS) and then disseminated to the issuers and Pakistan Stock Exchange (PSX). Caps on Bank’s Sponsor Holding To reduce the occurrence of money laundering and theft, PSX, NCCPL, CDC and the SECP have jointly developed a centralized portal where UIN of investors with more than 2% of shares of any listed banking companies will reflect and be uploaded on a daily basis by CDC. NCCPL identifies the unsettled transactions of the determined UINs in this portal to understand and identify the true holding of an investor. Investment Road Shows and Awareness Programs With a vision for wide scale development of the Pakistani Capital Market and to educate investors throughout Pakistan, Central Depository Company launched a series of Investment Road Shows in 2005. These target-driven events transformed into a platform for the capital market leaders and executives to meet and interact with the investors and stakeholders. The road shows have become a channel in educating the investors about the workings of Pakistan Capital Market & investment opportunities and clearing misconceptions about associated risks. The core objective of Central Depository Company through these programs is to provide comprehensive knowledge about Central Depository System, Account Maintenance and Value-Added Services that help in managing and maintaining CDS accounts effectively. It also apprises the audience about their role and responsibilities as an investor. Other than Karachi, Lahore and Islamabad, where Investor Awareness Programs are more frequently arranged, CDC has organized Investment Road Shows in several other cities of Pakistan including Hyderabad, Sukkur, Dahari, Gujranwala, Multan, Sialkot, Faisalabad, Quetta, Rawalpindi, Islamabad, Abbottabad, Muzaffarabad, Mirpur Azad Kashmir and Peshawar. Page 17 of 24 Similarly, CDC regularly conducts Awareness Programs for colleges and universities across the country to help educate their students about Pakistan Capital Market and the investment and job opportunities offered by it. Capital Market Days Apart from covering several local cities in Pakistan, CDC has taken the road shows to Abu Dhabi and Dubai in 2006 and held similar events in London (in collaboration with London Stock Exchange) and in New York (in collaboration with Citibank and The Bank of New York Mellon) in July 2007. These events by the name of Capital Market Days have played a key role in foreign-investor relationship development by enabling face-to-face dialogue between corporate entities and fund managers/institutional investors. Corporate Social Responsibility Corporate social responsibility (CSR) is a self-regulating business model that helps a company be socially accountable—to itself, its stakeholders, and the public, the purpose of corporate social responsibility is to give back to the community, take part in philanthropic causes, and provide positive social value. Businesses are increasingly turning to CSR to make a difference and build a positive brand around their company. Corporate Social Responsibility is an integral part of CDC’s culture. Being the sole depository of the country, the organization has realized its national and moral obligations with a strong sense of responsibility. Our approach towards community is not limited to financial support but is also a vital element of employee engagement. Our philanthropic outreach program includes the following areas:  Education  Health Care Page 18 of 24  Employable Skill Development  Special Children and;  Orphanage Our approach varies i.e. directly or through NGOs of repute. Every year we contribute 2.5 percent of profit before tax towards corporate philanthropic activities. While supporting wide range of initiatives as detailed above, we believe in playing our role in strengthening the basic fabric of our society by contributing towards projects of fundamental nature. Since inception, CDC has sponsored many projects among which sponsorship for construction of a TCF owned school and a Cancer Consulting Clinic owned by The Indus Hospital are two major contributions. With such like engagements, our aim is to support the ailing society by uplifting the health and education to deserving individuals of the society CDC Access to its customers: CDC Access is a customer focused service package which gives investors the benefit of accessing vital account information with ease and convenience at anytime from anywhere. This package currently comprises of two services that come under the umbrellas of Account Information and Online Transactions. The Account Information Portfolio comprises of the following channels: IVR: IVR is a round-the-clock Interactive Voice Response system supported by a state-of-the-art call centre, toll free number- (CDCPL) and dedicated customer support staff. Web enables: Investor Account holders to access their account information through www.cdcaccess.com.pk Page 19 of 24 Mobile App: Mobile App enables Investor Account holders to access their account information & corporate actions and perform online transactions through their mobile phones. SMS: gives an added level of convenience to investors by providing them their account information on their mobile screens. E-Statement: provides Sub-Account Holders and Investor Account Holders their Account Balance Statements on their registered email address on either monthly or quarterly frequency. E-Alert: provides free-of-cost alert messages on real time basis about important account related transactions in the email inbox of Sub-Account Holders and Investor Account Holders. Mandatory Subscription of either SMS or e-Alert Subscription of either SMS or e-Alert is mandatory for both Investor Account and Sub-Account. The Online Transactions service allows Investor Account Holders to initiate Portfolio Transfers directly through the CDC Access web portal https://www.cdcaccess.com.pk on real time without any paperwork or manual effort. Your CDC Relationship Number: To register for availing CDC access Account Information Portfolio, you would be required to fill in your CDC Relationship Number in the Investor Account Opening Form. Your CDC Relationship Number is the combination of Investor Account Services (IAS) ID and your account number. Page 20 of 24 Description: CDC Generation of T-PIN: Call at- After selecting the language preference, press 1 for self service. Enter your 12-digit CDC – Relationship Number (which is a combination of IAS ID and your Investor Account Number) Generate your 4-digit T-Pin. Activation of CDC access Services: Investor Account Holders can conveniently subscribe to CDC access services (both Account Information and Online Transactions) while filling the Investor Account Opening Form. SubAccount Holders can subscribe to the CDC access – Account Information services while filling the Sub-Account Opening Form Information Security Information Security is one of the key drivers in CDC’s business model to ensure reliable and smooth services to our clients. CDC has an established Information Security Management System (ISMS) through which threats / vulnerabilities are monitored and addressed timely to mitigate risks. All businesses accepted of ISO/IEC CDC are 27001:2013 certified standard, against globally demonstrating our commitment and focus to safeguard the information critical to the functioning of Pakistan Capital Market. Moreover, it ensures that our Page 21 of 24 clients’ assets are well protected in line with internationally recognized current best practices of the information age. Security is embedded into all functions of the company such as IT, Finance, Legal, Operations, Marketing, Product Development, HR, Administration and Internal Audit. This cross-functional implementation provides best value to the quality of service. Business Continuity Program CDC holds a unique privilege to be among very few organizations across the globe, few international depositories and the very first organization in Pakistan to achieve ISO/IEC 22301:2012 for its Business Continuity Program. CDC has a fully functional BCM Committee headed by the CEO and is comprised of top management that reviews and upgrades the policies and takes necessary actions as and when required. BCM is designed to bridge potential gaps between people, locations and technology that could threaten the smooth execution pf CDC’s business operations. BCP at CDC is benchmarked with the best practices taken from across the globe. Some of these major aspects include: Crisis Management Planning To deal with any unforeseen incident, the Organization has a crisis management plan in place, which prepares it to respond and recover from any adverse event. The plan is chalked out to Page 22 of 24 minimize impact of the incident and provide guidance to employees on how to respond in such circumstances. Security and safety guidelines are also provided to visitors to be followed in case of emergency. Floor plans, emergency signs and critical contact numbers are placed on all floors. Safety equipment such as smoke detectors, fire extinguishers etc. are also available at appropriate locations. CDC House is a completely non-smoking premises. The building is equipped with public addressing system that provides directions to employees in the event of an emergency. Recovery of Critical Business Processes Business Continuity at CDC is designed to respond to any business disruption by resuming critical functions from an alternate site within a defined timeframe. CDC understands that extended delay in revival of its critical business processes may create operational difficulty for its clients that are associated with the company in different capacities. Communication in Crisis The effectiveness of CDC’s Business Continuity Program extensively depends on the ability of its members to communicate with each other to coordinate activities, share information and implement appropriate strategies. The communication about the incident is passed to vital staff using the call tree. Resilient IT Infrastructure A resilient IT infrastructure is the most critical component in the overall resiliency and business continuity planning of any organization. At CDC, we achieve data resilience via replication among 3 geographically dispersed data centres to avoid single point of failure. The arrangement ensures high availability, business continuity and disaster recovery at a zero data loss. Page 23 of 24 Welfare of Staff CDC understands that people are its most critical asset, and organizational success cannot be achieved without them. The Organization enforces emergency procedures and exercises them at regular intervals to safeguard its employees against any uncertain situation. In addition, to fully equip its employees to cope with emergency situations, CDC arranges safety and security trainings like First Aid and Fire Fighting from professional bodies. Page 24 of 24