Funding Council

Remit

The IWF Funding Council exists to fulfil the following roles:

1. to consider relevant policy issues affecting IWF in order to brief Board representatives with members’ views;
2. to contribute funds and ensure renewal of funds for the operation of IWF;
3. Advise on the annual IWF budget and setting of membership fees;
4. to select three industry members for the IWF board;
5. to advise on and approve the members’ code of practice.

Bylaws

The Council may make its own bylaws for conduct of its meetings or otherwise provided that such bylaws do not conflict with this constitution.

Membership

Any person or organisation may be a member of the IWF Funding Council except:

• national and local governments;
• political parties;
• law enforcement bodies;
• employees of IWF;
• any applicant under the following process.

Where two or more members of the Funding Council are members of the same group of companies (as defined in Section 53 of the Companies Act 1989), they shall be treated as a single member for all voting and in order to calculate voting rights their qualifying subscriptions will be aggregated. For all other purposes, they will be treated as individual companies.

The Secretariat, by giving 14 days notice in writing, will notify the Chair of the Funding Council of organisations that are new members of the IWF and who are applying to join the Funding Council. All applications shall be considered by the Funding Council at its earliest convenient meeting.

The applicant will not be accepted onto the Funding Council if, at the meeting at which the application is considered a majority vote against the new IWF member joining the Funding Council.

For the purposes of Funding Council business, applicants accepted as members will be designated as either a Full Member or an Associate Member.

A Full Member is defined (subject to the proviso below) as being:

(a)   Any provider of public electronic communications networks or services offering connectivity to the Internet; 

(b)   Any provider of content hosting services to the public; 

(c)   Any provider of an Information Society service that carries user-generated content; or

(d)   Any membership organisation that represents companies that fall within some or all of (a) to (c) above;

provided that any applicants who do not fall into categories (a), (b) or (c) above, or who in the sole discretion of the IWF only fall into any such category incidentally or on a secondary basis and are not from the internet industry, will not constitute Full Members. All Members who are not entitled to become Full Members may be elected as Associate Members. 

If there is a disagreement over the proper designation of a new member, the Chair of the Funding Council will appoint three people on the Funding Council to investigate the facts and resolve the matter.

Full Members are required to adhere to the Code of Practice for Notice and Takedown as applicable to the services they provide. 

In case a Member has their Membership of the IWF terminated for breach of the Code of Practice, their membership of the IWF Funding Council shall automatically terminate at the same time. 

Membership status 

• No contribution shall affect the status of a member until actual payment is received by IWF.
• All contributions shall be designated as "pending contributions" from the date of receipt until the end of the following calendar month, and as "current contributions" for the next 12 calendar months. The "qualifying contributions" of a member at any time is the greater of their total current contributions for the present month and those for the next month.
• The Chief Executive shall notify the Funding Council each meeting of the status of each member.

Funding and members’ subscriptions 

Membership subscriptions are set by the Board

Expenses

Travel and related expenses of members and their representatives will be the responsibility of that member.

Representatives

• A member of the Funding Council may appoint one representative to attend, speak and vote on its behalf at Funding Council meetings. However, with the consent of the Funding Council Chair, members may send additional representatives who will have “observer” status. Such observers will have no voting rights.
• The representatives of a member shall be treated as having the full authority of the member in matters to do with the Funding Council, and any communication received by the representatives shall be deemed to have been received by the member.
• It is also possible for a representative to represent more than one member. In such cases, the representative will carry the votes attributed to the members he or she represents.
• Where a representative represents more than one member, then one representative from any of these members may also attend members’ meetings without the Chair’s permission. The rules above for sending additional representatives will also apply.
• Members shall notify the names of representatives to the IWF. Members may change their representative at any time. In addition, a representative may appoint a substitute, but only as provided for by the bylaws; such a substitution is not a change of representative.

Meetings

• The Council will meet as often as is required to conduct its business. The Funding Council will usually meet between pre-arranged board meetings. If an additional Board meeting is required, for whatever reason, it will be the decision of the Chair of the Funding Council or deputy, to determine the requirement for an additional Funding Council meeting.
• Distribution of agendas, notes and papers will normally be by electronic means. The agenda should be distributed at least 14 days in advance of the meeting and state clearly what issues will require a vote at the meeting. If a vote is required, the relevant documentation and notice must be sent out 14 days in advance of the meeting. 
• The Chair can invite the Chief Executive and Secretariat of IWF to attend meetings unless the Council vote to exclude them for a specific meeting or topic.

Funding Council Officers

• Members will appoint a Funding Council Chair and Vice-Chair.
• Chair and Vice-Chair appointments will be for two-year periods, with no limit on the number of terms. Appointment will be made following an open vote via a show of hands at a members’ meeting unless a closed vote is requested by any member, in which case weighted voting will apply. Members will be notified of the candidates for appointment via the meeting agenda which will be issued 14 days in advance of the meeting.  Should the Chair or Vice-Chair stand down within any two-year period, an election for a replacement will take place at the next members’ meeting. The replacement’s term will last until the replaced position’s two-year term is up, at which point there will be another election for the following two year term.
• The Chair’s role will be to chair the members’ meetings and to represent the Funding Council at external IWF meetings whenever possible.
• The Vice-Chair’s role will be to support the Chair and to act as a substitute for the Chair’s duties when the Chair is not able to carry them out. The Vice-Chair will also be Acting-Chair should the Chair stand down mid-term, until a new Chair is voted in.

Removal of the Funding Council Chair and Vice Chair

• Representation can be made to the Funding Council Vice Chair for a vote of no confidence in the Funding Council Chair (or in the Case of the Vice Chair, to the Chair). Such representation should be supported by a second, separate representation.
• A vote will then be held at the next members’ meeting to determine whether the vote of no confidence succeeds. A 60% majority vote of all eligible votes will be required for the motion to succeed.

Voting

• Procedures for voting shall depend on the purpose of the vote. In all cases the votes held by a member shall be cast as a single block and not be split. 
• Formal voting at Funding Council meetings will be conducted via a show of hands unless a weighted vote is requested by any member or the Chair rules that such a vote is necessary.
• At the commencement of the meeting, all those holding proxy votes must be notified through the Chair and declared to the meeting.
• When a weighted vote is conducted the representative of each member organisation will have one vote for each complete £1,000 of that member's current contribution, subject to a minimum of one vote per member. The proportion of the total number of votes cast by any member shall be capped as follows:
• Internet industry associations: 20% (for the avoidance of doubt such associations will include LINX, ISPA and a body which is an Internet Registry, for example, Nominet)
• All other organisations, including aggregated votes as defined under the membership section above: 10%
• A quorum shall be five persons who are representatives of members and who represent at least 25% of all eligible (weighted) votes. Proxies held by the five persons will count towards the percentage of eligible votes. Except where stated otherwise in this Constitution a vote shall succeed if more than 50% of the votes cast (ignoring abstentions) are in favour.
• All members of Funding Council may vote on all matters unless provided for elsewhere in this document. 

Elections to the IWF Board of Trustees

• In this section, terms such as "members of the IWF Board" refer to those members nominated by the Funding Council and no others.
• Members' representatives are elected for a term of three years.  The term of office may be varied with the agreement of the Members, for example, in order to stagger terms and ensure continuity. A proposal to vary the term of office in this way shall be based on the recommendation of the Chair in consultation with the Members. The Council shall announce the date of the election at least 28 days in advance, and shall circulate the names of candidates at least 14 days in advance.
• Candidates must have attended at least two Funding Council meetings in the 12 months prior to the date the election is announced, and may nominate themselves without seconder providing that such nomination is received by IWF at least 21 days before the date of the election.
• Where a vacancy on the IWF board falls open, a bye-election shall be held not more than 90 days after the vacancy occurred.
• Should a board representative leave the member organisation they represent or change member organisation (i.e. change from representing one member to representing another), then that board position will become vacant and a bye-election must be held to appoint a replacement. In the latter instance, it will be possible for that person to stand for re-election.
• In circumstances where a board trustee is replaced, the time their replacement serves on the board will not count as a whole term. The replacement trustee will have to stand for election when the full two year term of the board trustee being replaced would have expired.
• The IWF Secretariat shall administer the election and publish to the Council (but not externally) a formal record of all ballots cast in elections and the process of counting the vote.
• The primary role of the Funding Council trustees is to represent the interests of Full Members who are commercially and operationally impacted by the IWF’s role as a self-regulatory body. For this reason, only Full Members may vote in these elections. 
• If an election is being held for more than one member of the IWF Board at the same time, it shall be held by Single Transferable Vote with each member casting a single ballot weighted by the number of votes held by that member.
• When an election is being held for a single IWF Board vacancy it shall be held by Alternative Vote with each member casting a single ballot weighted by the number of votes held by that member.

Uncontested elections

• If the number of candidates is equal to the number of places open, those candidates are elected unopposed and no ballot is held. If the number of candidates is less than the number of places open, the candidates are again elected unopposed and no ballot is held; the unfilled places are declared open and a bye-election is required.

Role of the Board Trustees

• Members’ representatives elected to the Board of the IWF are appointed to represent the policy of the Funding Council and to ensure the proper governance of the IWF.
• They also act as trustees to the charity. 

Removal of a Board representative

• Representation can be made to the Funding Council Chair for a vote of no confidence in any of the board representatives appointed by the Funding Council. Such representation should be supported by a second, separate representation.
• A vote will then be held at the next members’ meeting to determine whether the vote of no confidence succeeds. A 60% majority vote of all eligible votes will be required for the motion to succeed.

IWF policy proposals

• For the purposes of this section “policy” refers to both public policy matters (e.g.: legislative proposals emanating from Government) and matters of internal policy pertaining to the IWF (e.g.: deployment of the CAIC URL list).
• Funding Council trustees are responsible for representing the view of the Funding Council in Board discussion and votes on matters of policy.
• Funding Council may be invited to respond to a proposal drawn up by the Board. Funding Council may also make a proposal to the Board on a matter of IWF policy on its own initiative.
• Where a policy matter impacts primarily on the commercial and operational workings of Full Members, only those members shall vote on such matters. It shall be for the Funding Council Chair, in consultation with the Full Members concerned, whether a policy matter has such an impact.
• Funding Council shall make best efforts to conduct its deliberations in line with the process set out in the Annexes. If necessary, a decision may be taken to use the emergency procedure for urgent matters in line with the process set out in the Annex.
• The circulation and sharing of documents relating to policy matters is subject to confidentiality arrangements.   

Code of practice

• The Funding Council is responsible for the management of the IWF Code of Practice.
• The Funding Council shall review the Code of Practice periodically.  A review may be proposed by any Full Member and is subject to the approval of the Funding Council.
• The Code of Practice only applies to service providers which are capable of acting on a take down notice issued by the IWF. For this reason, voting on changes to the code arising from a review is limited to Full Members only.

Changes to the Constitution 

• A change to this Constitution shall only be made at a meeting of the Council. Draft wording for the change shall have been notified to all members of the Council, and also all members of the main Board of IWF, at least 28 days before the meeting. The Council shall consider any representations from these people before holding their vote.
• Only Full Members may vote on changes to the constitution. 
• At least 75% of votes cast on the final proposal must be in favour for it to succeed. The change takes place immediately after the vote has been held unless stated otherwise as part of the proposal.

Annex 1 – Consultation Processes 

Funding Council Process for considering Board proposals.

FC Code of Practice

Issued on 14th June 2018

1. Introduction

This Code of Practice (the Code) defines the 'Notice and Takedown Procedure’ which is applied to Full Members by the Internet Watch Foundation (IWF), as further specified below, by which such Full Members are requested to remove, or disable (or otherwise permanently disrupt) access to, potentially illegal content which is hosted on their networks or on Usenet Services they provide, and where such content is accessible in or from the UK.

References in this Code to “potentially illegal content” refers to (i) content within the remit of the IWF as at the date of issue of this Code, namely, child sexual abuse images hosted anywhere in the world that is accessible in or from the UK, including non-photographic child sexual abuse images hosted in the UK, and which is (ii) assessed by the IWF, in accordance with its rigorous standards and by reference to English law and guidelines applicable at the relevant date, to be reasonably capable of sustaining a criminal prosecution under English law.

As at the date of issue of this Code, the applicable law and guidelines by which the IWF assesses potentially illegal content include the following (all laws stated are laws of England and Wales unless stated otherwise):

• Protection of Children Act 1978
• Civic Government Act 1982 (Scotland)
• Criminal Justice Act 1988
• Sexual Offences Act 2003
• Police and Justice Act 2006
• Criminal Justice and Immigration Act 2008
• Coroners and Justice Act 2009
• EC Directive 2000/31/EC, as implemented in England and Wales by the Electronic Commerce (EC Directive) Regulations 2002 (concerning liability of internet service providers)
• Crown Prosecution Service guidelines on indecent photographs of children (available at https://www.cps.gov.uk/legal-guidance/indecent-images-children-iioc)
• The Sexual Offences Definitive Guidelines of the Sentencing Council of England and Wales (available at https://www.sentencingcouncil.org.uk/wp-content/uploads/Sexual-Offences-Definitive-Guideline-web5.pdf)

Breaches of the Code may ultimately lead to suspension or termination of the Member’s membership of the IWF.

2. Definitions 

A breach is defined as a material failure or non-compliance to comply with the Notice and Takedown Procedure.

Other terms used within the Code are consistent with those in the Electronic Commerce (E-Commerce) Directive 2000/31/EC.

3. Scope of the code

The Code governs Full Members of the IWF that host Internet content on their servers (wherever the servers are situated) which is accessible in or from the UK, or which provide Usenet services for their customers (either directly or under contractual arrangements with third parties). For these purposes, a “Full Member” means as defined in the Funding Council Constitution.  

Full Members to whom this Code applies cannot opt-out of the Code.

4. Obligations of Full Members under the Code

4.1 Contact Details

Full Members to whom the Code applies must provide the IWF with a nominated point of contact to which the IWF can serve Notices under the Notice and Takedown Procedure. This point of contact may be a nominated member of staff or a dedicated mailbox set up to receive such Notices and which is monitored by one or more members of staff. It is the responsibility of each Full Member to whom the Code applies to notify the IWF of any change to its point of contact for receipt of Notices.

4.2 Compliance with Notice and Takedown Procedure 

Upon receipt of a Notice from the IWF, the Full Member in question must act expeditiously in order to comply with the Notice and Takedown Procedure as set out in paragraph 5 below.  

Any Full Member to whom the Code applies, who disregards or otherwise fails to act expeditiously on a Notice from the IWF does so at its own risk, and will as a result be deemed to be in breach of the Code.

4.3 Newsgroups

Full Members to whom the Code applies, who provide a Usenet service to their customers, will ensure those services are cleaned and updated on a periodic basis in accordance with the IWF’s recommendations (Appendix 1). This includes Usenet services delivered under contractual arrangements with third parties.

5. Notice and Takedown Procedure

5.1  The IWF may instigate the Notice and Takedown Procedure upon discovering or being informed of any content which it regards as potentially illegal content, and which is hosted on networks of, or provided via Usenet Services of, a Full Member and where such content is accessible in or from the UK. The IWF may also, at its discretion, raise a particular instance of potentially illegal content.

5.2  The Notice and Takedown Procedure shall operate as follows. The IWF contacts the relevant Full Member by sending an email to the nominated point of contact, containing the header ‘IWF Notice & Takedown Request’ (or equivalent header), and providing sufficient information to enable the Full Member to identify the location of the potentially illegal content (referred to as the “Notified Content”.)  

5.3  If promptly requested by the Full Member (by telephone or email), the IWF shall provide any necessary clarification of the subject matter of the email, and may also have regard, in the sole discretion of the IWF, whether to accept any alternative measures or remedies proposed by the Full Member in relation to the Notified Content. If the IWF accepts alternative measures or remedies, then the Full Member undertakes to implement those measures or remedies within 5 working days of the IWF’s acceptance; subject to which the IWF shall retract the IWF Notice & Takedown Request email.

5.4   The IWF may voluntarily retract an IWF Notice & Takedown Request in its sole discretion at any time.

5.5  Subject to paragraphs 5.3 and 5.4 above, the Full Member in question shall promptly, and in any event within 5 working days of receipt of the email, respond that:

(a)  it has identified the Notified Content, and will promptly remove or disable access to the Notified Content; or
(b) it is prevented or restricted from removing or disabling access to the Notified Content due to the applicable laws of its home jurisdiction, but it will endeavour to disrupt access to or transmission of the Notified Content by lawful means; or
(c) the email is issued improperly because the Full Member in question does not host the Notified Content or provide Usenet Services in respect of the Notified Content (providing a full explanation to the IWF).

6. Amendment of the Code

The Code may be amended only by agreement of the Full Members of the Funding Council in accordance with the Funding Council Constitution, and with the agreement of the IWF Board.

7. Document History

Version	Date Published	Summary of Changes	Made by
2	14th June 2018	Extension of Code to cover international companies	FC

 

8. Adjudication Process (where no resolution is possible by discussion)

The adjudication process does not apply automatically. It applies, in connection with any breach or suspected breach of the Code by a Full Member, where no satisfactory resolution has been achieved within 30 days of commencement of discussions between the IWF and that Full Member (or within 30 days of the IWF attempting to open discussions). (See Appendix 2 for flowchart).

8.1 Notification

8.1.1 All notifications of a breach or suspected breach by a Full Member (hereafter the “Referred Member”) should be made to the IWF’s Deputy Chief Executive or, in their absence, the Chief Executive of the IWF.

8.1.2 Such notifications will typically be referred internally by an IWF hotline analyst who becomes aware of a suspected breach through the operation of the notice and take down process. An issue may also be flagged to the IWF by another Member or a third party. Formal notifications to the Full Member will not however occur until no resolution is achieved within 30 days of those discussions between the IWF and the Full Member (or within 30 days of the IWF attempting to open discussions).

8.1.3 Subject to paragraph 8.1.2, the IWF will notify the Referred Member of the suspected breach within 5 working days of the IWF becoming aware of the breach.

8.1.4 The IWF will maintain a confidential log of all suspected breaches that come to its attention.

8.2 Initial Inquiry

8.2.1 The Chief Executive of the IWF (footnote 1) will investigate a suspected breach and compile a report of initial findings. This report will outline the nature of the suspected breach, the salient facts and any mitigating circumstances.

8.2.2 On the basis of these initial findings the Referred Member may agree with the Chief Executive that the matter can be fully and satisfactorily resolved without further action.

8.2.3 If the matter cannot be fully and satisfactorily resolved with the Referred Member or requires further investigation and/or input from other parties, the Chief Executive may initiate a full inquiry.

8.2.4 The IWF will notify the Referred Member concerned if a full inquiry is initiated about them.

8.3 Full Inquiry

8.3.1 The full inquiry will normally be completed within 15 working days from the date of notification to the Referred Member (referred to in 8.2.4). In exceptional circumstances (eg if the matter being investigated is complex) the duration of the inquiry may be extended. A further period of a maximum of 7 working days may elapse between the completion of the full inquiry and the notification of any sanction to be applied.

8.3.2 The inquiry aims to determine whether a breach has occurred and, if it has occurred, the reasons for that breach. The inquiry will also seek to ascertain any mitigating actions taken by the Referred Member in relation to the breach and reasons why the Referred Member did not act on the notice in question. The inquiry will verify that the IWF has acted correctly and consistent with its agreed procedures.

8.3.3 All evidence collected as part of the inquiry will be recorded, auditable and disclosable to the Referred Member subject to the inquiry.

8.3.4 A representative(s) of the Referred Member and employees of the IWF will be invited to co-operate fully with the inquiry and provide written evidence and/or attend meetings in person.

8.3.5 If during the course of the inquiry, a dispute arises over the assessment of whether content is potentially illegal (as defined in the Code), external professional advice, including reference to law enforcement agencies, may be sought.

8.3.6 The IWF will produce a report on the suspected breach. The Chief Executive is responsible for ensuring that the inquiry has been conducted appropriately and that the conclusions reached in the report are consistent with the evidence considered in the full inquiry. The Chief Executive will approve the final report and send a copy to the Referred Member.

8.3.7 The Chief Executive may:

1. 1. Agree with the Referred Member that the original notice was inaccurate or inappropriate or contained manifest errors, and that the matter is
      closed without the Referred Member having to act on the notice;
   2. Agree with the Referred Member that the matter is closed and that the Referred Member will act on the original notice;
   3. Agree with the Referred Member to refer the matter to the relevant law enforcement agency;
   4. Refer the matter to the Breach Sub-Committee of the Board if the Referred Member will not comply with the original notice.

8.4  Referral to IWF Breach Sub Committee

8.4.1 It is anticipated that most failures of the process can be remedied quickly without the need for formal proceedings (outlined above). However, if a Referred Member is found to be in breach after a full inquiry, the Board (or relevant Sub- Committee) may decide to impose proportionate sanctions on a Referred Member in order to secure their compliance.

8.4.2  Referrals received by the IWF Board pursuant to 8.3.7 (d) will be delegated for consideration to a Breach Sub-Committee of the Board which will be an ad hoc committee rather than a standing committee.

8.4.3 Any Breach Sub-Committee of the Board will comprise at least three people, with a ratio of 2:1 being maintained in relation to independent/industry membership. The Chair will be an independent trustee. The industry representative must not be employed by the Referred Member.

8.4.4 The inquiry by the Breach Sub-Committee will normally be completed within 15 working days from the date of notification to the Referred Member (referred to in 8.3.7 (d)).

8.4.5 The Referred Member shall be entitled to meet with the Breach Sub-Committee in person or by teleconference, depending on the Referred Member’s preference, and present its response to the final report per 8.3.6. The Referred Member may be assisted by or represented by another person, including a legal advisor. The Referred Member shall also be entitled to submit written evidence.

8.4.6 Referred Members and employees of the IWF are expected to co-operate with any reasonable request from the Breach Sub-Committee to assist in obtaining evidence.

8.4.7 The Breach Sub-Committee will determine the facts and arrive at a decision and will then agree an appropriate sanction. The Breach Sub-Committee will consider the report from the Executive (referred to in 8.3.6) and may, if it considers appropriate, seek independent legal advice in respect of a case brought before it.

8.4.8 The IWF shall inform the Referred Member of the Breach Sub-Committee decision within ten business days of the decision being made and shall provide details of the Breach Sub-Committee reasoning and any proposed sanction. This reasoning can be used as grounds for an appeal.

8.4.9 For the avoidance of doubt, if the Breach Sub-Committee finds that there was no case to answer then no further action shall be taken and the Referred Member will be advised.

9. Sanctions and Remedies

9.1 If a Referred Member is found to be in breach after a full inquiry the Breach Sub-Committee may decide to impose sanctions on a Referred Member in order to secure their compliance.

9.2  Remedies and sanctions available to the Breach Sub-Committee for breaches are:

(a) Request a formal, written undertaking as to future compliance
(b) Issue of a warning or reprimand
(c) Report filed with relevant law enforcement authority
(d) Suspension from membership
(e) Termination of membership

9.3 If the Breach Sub-Committee levies either 9.2(d) or 9.2(e) in the list of remedies and sanctions then it may publish its adjudication on the IWF website. Other adjudications shall not be published.

9.4 When determining the level of any remedy or sanction the Breach Sub-Committee will consider a number of factors that will determine the most appropriate course of action. Recognising that each case is likely to have its own particular features, the factors which the Breach Sub-Committee may take into account include the following:

(a) Whether the breach was inadvertent, negligent reckless or knowingly an act of commission or omission
(b) Seriousness of the breach in terms of detriment to consumers or the wider public interest
(c) Repetition or regular breaches or flouting of the rules
(d) Mitigating actions taken by the Referred Member or mitigating circumstances
(e) Impact of the breach on the integrity of the IWF
(f) Degree of co-operation with the IWF by the Referred Member in connection with the identification and rectification of the breach
(g) Relevant precedent, although the IWF Board will not be bound by precedent

9.5 IWF can recover reasonably incurred marginal costs (footnote 2) of the process from the Referred Member concerned who is found to be in breach. These costs are limited to those reasonably incurred by third parties involved in the process

10. Appeal

10.1 A Referred Member may appeal against a decision of the Breach sub committee (footnote 3) that a breach has occurred and/or the sanction applied (per 8.4.8).

10.2 Notification of the intention to appeal must be made in writing to the Chair of the Breach Sub Committee within 10 working days of receipt of the outcome full inquiry of the Breach Sub-Committee and/or receipt of the notification to impose a sanction as per 8.4.8. If no notification is received the matter will be considered closed.

10.3 The Board will use its best endeavours to hear an appeal within 15 days of the receipt by the Board of a notification of an intention to appeal. Those Board members who formed the Breach Sub-Committee may not be part of the Board meeting that considers the appeal.

10.4 The following are able to make representation in writing, by teleconference or in person (the Referred Member is entitled to request a face to face meeting). The following are also able to give additional evidence to the Board. 

• • Chair of the delegated Board Breach Sub-Committee
  • Representatives of the Referred Member organisation
  • The Chief Executive of the IWF

10.5 The Board can take external professional advice, including legal and law enforcement authority advice.

10.6 The Board is required to report its decision to the Referred Member within 10 working days of the appeal having been determined. The Chief Executive of the IWF and, where relevant, other Board members will be advised of the decision also.

10.7 The Board decision made will be final and there will be no further appeal process.

Footnotes

#1 For the purpose of this document the Chief Executive could be a delegated member of the IWF Executive team.

#2 Additional, marginal costs over and above the usual staff resources such as Trustee attendance fees, research costs or external expert advice.

#3 As set out in paragraph 8.4.7.