House of Commons - The Equality Bill: how disability equality fits within a single Equality Act

The Equality Bill: how disability equality fits within a single Equality Act - Work and Pensions Committee Contents

5 The public sector equality duty

Extending the public sector equality duties

199. The Government report A Framework for a Fairer Future signals the Government's intent to introduce an integrated equality duty (covering race, sex, disability, sexual orientation, religion or belief and age) on all public authorities. DWP states that the Government is keen to retain the successful features of the disability, race and gender equality duties on public authorities and to extend those benefits to the other protected strands:

"The substance of the proposed single public sector equality duty will be broadly similar to the existing duties. The new duty will require public authorities to have due regard to the need to eliminate unlawful discrimination and harassment, promote equality of opportunity [...] Public Authorities will also be required to promote good community relations in respect of all their functions and for all protected grounds (with the exception of age, regarding pupils in schools)."[245]

200. The Department reports that more than 80% of the respondents to the Discrimination Law Review consultation favoured integrating the three existing duties into one duty, and 90% favoured extending the duty. It states that clear statutory guidance from the Equality and Human Rights Commission (EHRC) should help public authorities to implement the new duty in an effective and proportionate way.[246] Mr Sandbach of Citizens Advice (CAB) stressed that "One of the important messages, the powerful message of an integrated Equality Duty is that you cannot just cherry-pick equality and you cannot cherry-pick this group or that group."[247]

201. A number of submissions argued that, if a single duty is effectively implemented with proper steps taken to (a) engage effectively with disabled people (staff, service users, local communities) and (b) it is effectively monitored and reviewed, then it need not be a weaker option.[248] The Discrimination Law Association added "the duty to have due regard to the need to take steps to take account of disabled people's disabilities, even where that involves treating them more favourably […] has been particularly effective in reinforcing the reach of the reasonable adjustment duty, and in promoting substantive, as opposed to formal, equality."[249]

202. However, most submissions also expressed fear that the single duty might dilute the attention that is given to disability or that the specifics of disability discrimination might be lost sight of. Mr Purton of the TUC argued that: "in the legitimate rush to harmonise, to iron out the differences between the different equality statutes, which we support, they should not lose sight of the specificity of disability and the fact that you have to treat disabled people more than equally in order to achieve an equal outcome much of the time."[250]

203. Ms Casserley of the Discrimination Law Association explained that it: "It would not mean that you had a duty that was exactly the same for everyone but I think that is the important aspect, that that concept of more favourable treatment is retained in the context of disability. It may not look as though it is completely harmonising but it is particularly important that it is retained in the context of disability."[251] Mr Lamb of the Disability Charities Consortium agreed: "We need to see that very clearly expressed within the wording of the general duty that there does need to be required more favourable treatment in relation to disabled people within whatever the new duty is."[252]

204. Others criticised that the extension of the public sector equality duty does not go far enough. Ms Holzhausen of Carers UK said: "We warmly welcome the extension as well but of course we would welcome it even more if it included carers."[253] Carers UK argue that "we do not believe that the single equality duty could be either inclusive or effective without addressing the discrimination, harassment and inequalities that are faced by such a significant and growing part of the population as carers."[254] It added that "a public duty to promote equality in public services would be the single most effective way of providing recognition for carers, which as our surveys have shown is one of the top concerns of carers."[255]

205. However, the CBI argues that lessons should be learned from the existing duties before the new single duty is introduced. CBI members believe that the current duties place too great a focus on processes - such as recruitment targets and audits - at the expense of value for money outcomes. "Such a situation merely creates compliance rather than commitment. As the Equalities Review recognised, there is little evidence that the public sector duty on race, for example, has been effective in improving outcomes."[256]

206. The Minister, Maria Eagle, acknowledged that: "Of the existing public sector duties across the three strands so far to promote equality two of them are very recent, only coming in in 2005 and 2006, disability and gender. The race duty is older. They have all had slightly different approaches. In the past particularly I think the race duty has been a bit too much of a tick-box. […] With the new legislation we are looking to get away from tick-box paper arrangements to a process which will promote this kind of culture change."[257] Mr Harrop of Age Concern and Help the Aged argued that: "the experience of the three existing equality duties is fantastically helpful and we should aim to bring the best."[258]

207. The Disability Equality Duty (DED) came into force on 4 December 2006, and since then the Office for Disability Issues (ODI) has undertaken a range of activities to ensure that the duty is implemented effectively. Ipsos MORI was commissioned to carry out an audit of compliance with the Disability Equality Duty in January 2007. The final report revealed that 72% of public authorities covered by the audit were found to have published a Disability Equality Scheme (DES), and at least 54% of all authorities covered in the audit had published a DES that contained evidence that the authority had involved disabled people in its production. By the summer very few authorities did not have a scheme in place.[259] Mr Crowther of the EHRC said:

"focussing on the disability duty and the key benefits we think that has brought, there is little doubt that it has changed the profile and the approach towards disability across many public authorities. I do not think that has been uniform; we are aware there are some public authorities that have taken a real lead on this, there are some that merely do what they have to and there are some that are not doing enough at all. Of course, we have to address all three of those situations in an appropriate way."[260]

208. Research by the Disability Rights Commission shows that where authorities had complied with the Disability Equality Duty this had a very positive impact on public sector bodies' performance and culture. Organizations in particular reported that the involvement of disabled people in developing the Disability Equality Scheme had very positive consequences. It was felt to have helped to create better public services, enabling organizations to become more customer-focused, particularly in terms of recognising the diversity of the communities with which they engage.[261]

209. Schneider Ross's study of the implementation of the three public sector equality duties echoes the conclusions of the DRC regarding the potential of the duties, and the particular strength of the Disability Equality Duty. This study found positive outcomes had been delivered by the duties, with equality issues being accorded higher priority and increasingly mainstreamed. Based on an analysis of the reports of public authorities regarding their implementation of the equality duties Schneider Ross found that progress on disability was only slightly less than on race. The researchers described this as 'striking' given that the disability duty had only been recently introduced at the time of the research, whereas the race duty had been in force for more than six years. Indeed on one aspect disability scored higher than race: 72% of respondents said that involvement of disabled people contributed to successful implementation of the DED.[262]

210. A recent study by the EHRC consisted of interviews with equality practitioners from a range of sectors and confirmed that the specific duties were a lever for change within their organisations. Some acknowledged that, in some cases, implementing the specific duties might be perceived as a bureaucratic means towards compliance. However, the vast majority were clear that implementing the specific duties had been fundamental in improving services to local people.[263]

211. In addition to the requirement relating to the schemes, certain Secretaries of State are also required to publish a report, the first one published on 1 December 2008, on progress toward equality in their policy sector and proposals for co-ordination of future work by relevant public authorities. The EHRC states that the requirement for Secretaries of State to report and to address shortcomings appears to have driven improvements in data collection and analysis, and may help to strengthen co-ordinated activity across different departments in the future.[264] Mr Crowther argued that

"From the evidence that has been produced […] there is no doubt that greater priority is being given to disability issues by public authorities and in particular a shift in the perception of disability as being an add-on issue to one of being the core business of what public authorities do: improved perceptions of an increasing respect for disabled colleagues in the workplace and a better understanding of people's support needs; the greater involvement of people with hidden impairments; improvements in the quantity and quality of data that public bodies have to be able to make informed decisions rather than assumptions about what disabled people want."[265]

212. Mr Congdon of the Disability Charities Consortium emphasised that "We must bear in mind that disability equality schemes only came in in December 2006 so it is quite early days and the message to all of them is that if you are going to prove beyond doubt that you are giving disabled people a fair deal in terms of the services you provide, the move towards equal outcomes, you need to do things: you need to have a proper plan; you need to know what is going on. […] We have certainly found it a very powerful lever by saying, 'What are you doing to ensure you are getting equality of outcomes for people with disabilities?'"[266]

213. We welcome the Government's intention to introduce an integrated equality duty (covering race, sex, disability, sexual orientation, religion or belief and age) on all public authorities. We also recommend that in line with our recommendation on a separate equality strand for carers, this duty should be extended to cover carers.

214. We strongly believe that any attempt to harmonise the public sector duties should not dilute the attention that is given to disability discrimination. We recommend that the key elements of the Disability Equality Duty, particularly the requirement of more favourable treatment, need to be preserved.

Improving focus on outcomes

EQUALITY SCHEMES

215. Mr Crowther of the EHRC, amongst others, said: "To date there has perhaps been too much of a focus simply on whether or not a public authority has a scheme and not on the substance of that scheme."[267] Mr Congdon of the Disability Charities Consortium added that: "Schemes are important but what is more important than the piece of paper which says there is a scheme is what we are actually going to do. What are we actually going to do to change how we deliver our public services to ensure we get equality of outcome?"[268]

216. The EHRC suggests that there are key aspects of the current specific duties where the principles underlying the duties ought to be developed or extended to drive improvements in outcomes. These include:

"A duty to publish objectives and priorities for action, and to implement them and report against progress;
Involvement and effective consultation;
Equality Impact Assessments (EIAs). The EHRC believes the principles underlying the purpose of EIAs need to be re-stated in particular:
- An emphasis on outcomes and action
- Focusing on evidence and data sources
- Emphasising the need to build EIAs into mainstream policy development
- Underlining that EIAs should be sharp and focused appraisals of existing and potential impacts
- Emphasising the role of involvement in policy making
- Stressing the importance of using the process to identify opportunities to improve policies as well as for risk management;

Reporting Requirements on progress;
Inspection and Regulation. The EHRC calls for the introduction of a specific duty on inspection and regulatory bodies to inspect relevant public authorities for their performance on equality;
Duties on Secretaries of State: The EHRC would also like to see the Single Equality Duty develop the principles that underpin the current Secretary of State reporting duty (Disability Equality Duty)."[269]

217. Well designed equality schemes can be a useful tool for public authorities to assess their progress in equality outcomes. However, we have heard concerns that currently they are not as effective as they could be and merely represent a tick box exercise. If they are to be more than just a tick-box exercise they must focus more on outcomes than the scheme process itself. We recommend that equality schemes should include a combination of prioritisation and action planning. We endorse the set of tools for public authorities, proposed by the Equality and Human Rights Commission, to help design equality schemes to achieve greater equality outcomes.

COMPLIANCE AND ENFORCEMENT

218. The TUC argued that effective enforcement of the duty is essential: "Evidence suggests that important progress has been made by public bodies that have taken seriously their obligations under the existing DED, although not all bodies fall within that description, which is why effective compliance and enforcement activities are essential."[270] Mr Lamb of the Disability Charities Consortium added that: "at schools they are not actually complying with their disability equality duties and the production of disability equality plans in terms of the planning duty that is required of schools, but you could make exactly the same comment about other public authorities and the way they are delivering those. I think we need to look at the compliance regime."[271]

219. If a public authority does not comply with the duty to give due regard to disability equality it can be challenged by means of a claim to the High Court for judicial review. A claim for judicial review may be made by a person or a group of people with an interest in the matter, or by the EHRC. However, only the EHRC can take compliance action with regards a failure to comply with the duty to produce and implement Disability Equality Schemes.

220. In practice individuals or groups are likely to find it very difficult to challenge public authority decisions. Ecas, an Edinburgh-based disability charity for example, reports difficulties in enforcing the DED, saying that it had wished to challenge a decision of the City of Edinburgh Council to cut funding for an equality forum on grounds that this was done without statutory due regard for the impact on disabled people. However, it had concluded: "The only means of privately enforcing the DED is judicial review - even after instructing senior counsel, we have found this to be unworkable in practice."[272]

221. Ecas reported that the council had refused to release information on its Equality Impact Assessment and Ecas then took out an Freedom of Information request. By the time the evidence was made available, the judicial review time limit had expired. Ecas called for:

a) "a specific duty, on the part of public authorities, to publish full information about initial screening and equality impact assessments undertaken;

b) "further specific duties allowing the public and organisations to be provided with documentary evidence that decision-makers (e.g. councillors) were informed of the predicted impact of their decision within a specified timescale (e.g. 10 working days) of the request being received;

c) "stronger mechanisms to require and enable the EHRC to enforce compliance with public authority equality schemes."[273]

^222.The TUC adds to this the concern that the EHRC lacks resources to fulfil its role efficiently: "There are concerns, however, that the EHRC has not properly followed up on some of the earlier work done by the previous Commissions. The single duty will make even more demands on the EHRC and so it must be provided with sufficient resources to lead on this work and to form effective partnerships with other bodies to promote compliance and enforcement."[274]

223. Mr Lamb of the Disability Charities Consortium argued that: "there are issues on the compliance side about how far the Equality Commission in general can police this massive number of public bodies so we want to look at mechanisms that look both at self-analysis and reporting mechanisms."[275] Mr Crowther of the EHRC stated that: "inspectorates and regulatory bodies should have specific duties to monitor compliance with these duties. That is a kind of step further than I think what the Government is currently proposing which is resting on an assumption that the fact that they have the duties would be enough. […] I think there are 44,000 public bodies in Britain and clearly the process of understanding and knowing what is going on and influencing them is not something the Commission can do on its own."[276] However, the Minister, Maria Eagle, disagreed:

"I do not necessarily accept that. Obviously, they have their views but they have £70million a year and 500-plus staff. You can do quite a lot of enforcement with that in my view. […] I know that there are some discussions between themselves and the inspectorates about whether or not the inspectorates and various bits of the public sector should be inspecting against equality, and I know that there are discussions and meetings going on between the Commission and those inspectorates, but most of the inspectorates are a lot smaller than the Commission and have fewer resources. To the extent that they can work together, fine, but the obligation is with the Commission."[277]

224. We would like to see the single duty in the public sector working well and achieving its equality objectives. To succeed, it needs improved monitoring and enforcement mechanisms. Enforcement can not rely on private enforcement by judicial review alone. We were told of procedural obstacles to this process which we call on the Department to examine.

225. We call for a specific duty, on the part of public authorities, to publish full information about initial screening and equality impact assessments undertaken. This would improve transparency and allow for effective assessment of the implementation and quality of the schemes. We strongly believe that public sector equality duties lack credibility if the Government doesn't address these concerns.

226. We also call on the Government to conduct thorough research into the quality of equality schemes in the public sector, the effectiveness of their implementation, the administrative burden they impose and particularly the impact of this process on equality outcomes.

PROCUREMENT

227. The public sector spends around £175 billion every year purchasing goods and services from the private sector, involving 30% of British companies. DWP states that public sector procurement can therefore be a potentially powerful lever to drive progress on equality. It states that under the existing public sector equality duties, public bodies are already required, in carrying out their procurement activities, to have due regard to the need to eliminate unlawful discrimination and to promote race, disability and gender equality.[278] The Minister, Maria Eagle, said that the "use of our purchasing power through public procurement will be a powerful lever."[279]

228. Cloisters state that experience under the Race Relations Act demonstrates that more is needed generally to ensure that public authorities, especially central government departments, fully comply with their positive duty to promote equality. They highlight the lack of evidence that public authorities do take their race equality duty into account in the procurement process, despite comprehensive guidance prepared by the Commission for Racial Equality.[280]

229. The CBI argues that procurement can be an effective lever to promote social objectives, but says that clarity about the requirements placed on contractors is essential: "The requirements need to strike a balance between 'making the public pound work harder' and impinging on the private sector business process: to do this", and added: "the requirements need to be related to contract delivery not procedures."[281] The Employer Forum on Age states: "Provided that appropriate indicators of diversity performance are adopted (and that these are not narrowly or prescriptively restricted to, for example, the gender pay gap), we believe that substantial change in the private sector will flow from an increased focus on equality and diversity in public sector procurement from private sector suppliers."[282]

230. Ms Scott-Parker of the Employers' Forum on Disability said: "I see four distinctly different categories of activity under this. One is how does Government put its money in by way of social enterprise - organisations that employ people primarily with disabilities or other disadvantaged groups. […] Secondly, on the equality front, how do you determine whether or not your supplier does share your values? […] Third, I mentioned earlier requiring the suppliers to prove they are disability-competent would I think drive change in a much more powerful way. Prove to us that the services you deliver enable people with disabilities. […] The fourth one we have not talked about is disabled entrepreneurs."[283]

231. The TUC cites a number of examples of good practice on equality and public procurement in some parts of the UK. The Northern Ireland Equality Commission and the Central Procurement Directorate have jointly published guidance on equality and procurement, with a number of good practice examples; West Midlands Local Authorities have developed the West Midlands Common Standard, a common set of questions that can be used at the pre-qualification stage to get contractors to demonstrate that they comply with non-discrimination requirements in employment legislation; GLA has adopted a Responsible Procurement policy; Unison's local government branch in Newcastle has reached an agreement with Newcastle City Council permitting them to review tender documents and interview contract bidders about level of service and proposed terms and conditions.[284]

232. However, the Federation of Small Businesses (FSB) believes that using procurement as a way of improving disability outcomes in the private sector is not a practical measure for small firms.[285] Mr Willman of the FSB argued that: "Small businesses are discriminated against very heavily in the procurement process because the public sector workers do not understand the smaller units of the micro-business. You do not have policies because it is not a written procedure."[286] The British Chamber of Commerce agree that "In these tough economic times, the government's priority should be to make the tendering process for public sector contracts easier for small businesses. The Glover Review recognised that it is already difficult for small firms to access the £160billion of public sector contracts that are on offer each year. There is a danger that these measures will make it even more difficult for small firms to access these contracts."[287]

233. We believe that procurement can be an effective lever to promote equality objectives, but clarity about the requirements placed on contractors is essential. We agree with the CBI that these requirements should be related to contract delivery not procedures. This approach would ensure that smaller firms stand an equal chance in meeting the requirements, as it would benefit most those that can deliver the required outcomes, rather than those with the most administrative resources.

234. A number of submissions recommend that the new legislation should make it explicit that the equality duty is exercised in relation to procurement.[288] The Disability Charities Consortium states: "A specific duty around public procurement would send out a clear and unequivocal message that public authorities can be held accountable if they have not taken steps to ensure that contracted services or publicly funded services are compliant with disability equality."[289] This goes further than the Government's proposals which outline a light-touch approach through encouraging greater transparency and improving use of purchase power.

235. Age Concern and Help the Aged argue that: "whilst we would welcome: 'clearer, consistent and practical guidance on the legal and policy framework and the ways in which equality can be factored into the various stages of the procurement process, together with case studies and examples of good practice', we do not think that this alone will be enough."[290] Mr Harwood of the Public Interest Research Unit emphasised that: "unless the definition of functions of a public nature is made clear in the Equality Act, there is a danger that as more and more public functions are contracted out the equality duties will become of ever diminishing practical significance."[291]

236. The Minister, Maria Eagle, stressed that contracted out services are covered by the public sector duties: "To the extent that they are carrying out public functions they will [be covered] in the same way as the public sector."[292] However, the Discrimination Law Association emphasised that:

"Applying statutory equality duties to public authorities using the definition of 'public authority' contained in s.6 of the HRA 1998 will not necessarily bring a private or voluntary sector body fully within the reach of the statutory equality duties as such duties will apply to bodies that are not 'pure' public authorities ('hybrid authorities') only when they are carrying out 'functions of a public nature' and only in respect of such functions."[293]

237. The confusion that currently surrounds the definition of 'public functions' within the Human Rights Act 1998 demonstrates the need for clarity within the legislation on this issue. Mr Harwood of Public Interest Research Unit argued that "there needs to be a definition in the Act, such as along the lines of the Joint Committee on Human Rights' definition in their inquiry into the meaning of public authority, to make clear to people such as the contractors that they are subject to that duty."[294] The Discrimination Law Association added that "This appears to be necessary to overcome the hesitation by public authorities, which, in turn, is based in part on the extremely cautious approach of the Office of Government Commerce (OGC) […] to recognise procurement as a 'function' of public authorities."[295]

238. A number of submissions confirmed that OGC guidance has tended to emphasise the constraints of EU Procurement law rather than positively stating what can be achieved on equality through procurement.[296] Ms Casserley of the Discrimination Law Association said that: "because of the guidance that is sometimes put out and because of the European Directive on procurement there is a fear that if people use procurement to promote equality they will fall foul of European legislation in some way and actually that is not the case, you can be a lot more proactive about procurement."[297] Mr Purton of the TUC agreed: "The guidance that has been issued is extremely conservative in its interpretation of the law and seems to have been designed in the past to deter public sector organisations from procuring their supplies and services from organisations employing disabled people. I am very, very pleased to say that seems to be changing."[298]

239. DWP states that as part of OGC's procurement policy and standards framework the Government recently set out how social issues can be addressed through public sector purchasing: "The OGC publication Buy and make a difference, provides practical advice on this, with good-practice. The OGC will be publishing a similar guide specifically on addressing equality issues in procurement, including clarification of what the existing public sector equality duties mean for public procurement."[299]

240. As more and more public functions are contracted out to private and third sector organisations, there is a concern that the equality duties will become of ever diminishing practical significance. We believe that there is a need for clarification in the forthcoming Bill that private and third sector organisations carrying out public functions need to fulfil the same requirements as public sector organisations in terms of promoting equality and equality outcomes. Any person or body acting on behalf of a public body should be deemed to be exercising a public function. We also recommend that the Bill should make it explicit that the equality duty must be exercised in relation to procurement.

A duty on the private sector?

241. The TUC argues that there have been some welcome advances in understanding and commitment among some larger private sector employers of the DDA, but the single largest impediment to the employment of disabled people remains employer discrimination, especially where the issue is mental health. The TUC states that "The current light-touch regime has not brought about a significant increase in the employment of disabled people; advice is readily available for those good practice organisations that are willing to heed it."[300]

242. However, DWP states that the Government does not think that an equality duty on the private sector is appropriate.[301] The CBI argues that there is little evidence that the extension of the duty to the private sector would be effective.[302] Ms Scott-Parker of the Employers' Forum on Disability agreed: "For me, it is too early in the sense that we still do not have the evidence in the public sector. […] We certainly have some members who feel that their systems are sophisticated enough. They would accept it. We have others saying, 'But does it work?' Fundamentally, that is the question."[303] Ms Williams of the CBI added: "I agree with that. It is too early. […] If it can be effective, we need to make sure and be confident it works in the public sector before committing the private sector to the same requirements."[304]

243. Age Concern and Help the Aged recognise that placing a statutory equality duty on the private sector may cause difficulties, but believe that it should be maintained as an option if a voluntary standard proves ineffective.[305] They highlight the fact that the private sector provides approximately 80% of all employment opportunities in the UK.[306]

244. The TUC argue that an equality duty for the private and voluntary sectors would not have to exactly mirror the public sector duties. It could be phased in, for example, applying to large private sector organisations initially and just to the employment function, rather than the goods and service delivery functions.[307] The Public and Commercial Services Union agrees: "Although it might require a difference of approach, based on size and scale of operations, in principle we see no reason why private sector employers are any less able than those in the public sector to develop similar approaches to equality and to document these."[308]

245. DWP states that the Government's ambition is to bring about cultural change to tackle discrimination in the private sector. It refers to case study evidence from research that shows that the most important factor cited by employers and service providers making adjustments for disabled people was that 'it was the right thing to do'.[309]DWP states it has adopted a two-pronged approach through the Employ ability initiative, challenging employer attitudes (targeting SMEs on an area basis) and developing an employer-led strategy to encourage employer ownership and leadership of this agenda.[310] The Government also announced its plans to develop, in partnership with EHRC, an equality 'Kite Mark'. This will recognise employers who are transparent about reporting their progress on equality.

246. The National AIDS Trust recognises the development of this kite mark as a positive step, but are concerned that as this is a voluntary scheme, those employers who have the worst record on equality issues will not need to take any further steps.[311] The FSB also have concerns that a 'Kite Mark' for employers would automatically work against small firms who do not have the HR expertise or resources to put into acquiring it.[312]

247. Citizen Advice states that there are a wide-range of tools, which fall short of the statutory duty approach, including fiscal incentives such as tax credits for 'good' diversity employers. Such measures have been used to encourage employers to invest in workforce development and management and could be used to bring greater compliance with equality and discrimination legislation, and broader public policy goals. They say that a key option for consideration is the role of market regulators. The Equality Bill should include a statutory role for EHRC in working with regulators, and introduce equality and fairness indicators as part of their regulatory criteria and functions (the model of co-regulation).[313]

248. We note the Government's stated intention not to extend the duty on the public sector to the private sector. We have to build on the experience with the current duties first to make them work better in the public sector before extending them to the private sector. However, we believe that a duty on the private sector should be maintained as an option if a voluntary standard proves ineffective. We recommend that the Government keeps its policy under review, while considering the outcomes of its assessment of the impact of the public sector equality duty.

245 Ev 200 Back

246 Ev 201 Back

247 Q 90 Back

248 Ev 87 [TUC], Ev 60 [National AIDS Trust], Ev 93 [Disability Charities Consortium], Ev 128 [RNID], Ev 173 [Terrence Higgins Trust], Ev 176 [Trade Union Disability Alliance] Back

249 Ev 169 Back

250 Q 90 Back

251 Q 24 Back

252 Q 21 Back

253 Q 57 Back

254 Ev 134 Back

255 Ev 135 Back

256 Ev 214 Back