Document:Project Proposal Integrity Initiative 2017-18
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PROJECT PROPOSAL FORM
For projects over £80k
To be completed by the Post
Project Title
INTEGRITY INITIATIVE
Which Programme is the funding being sought from - Insert fund name Russian Language Strategic Communication Programme
Project Code - To be added once the Project has been approved and the code is provided by the Programme Team
TBC
Is the Project ODA eligible Yes/No
ODA Codes - To be added by Post using guidance in Annex 2 and 3 of “OECD’s ODA Reporting Guidance”. Input Sector Code Channel of Delivery Code
Part A: To be completed by the Project Implementer
Project Title INTEGRITY INITIATIVE
Purpose This must be NO MORE than one sentence, clearly setting out the “change” to be delivered
- To counter Russian disinformation and malign influence in Europe by: expanding the knowledge base; harnessing existing expertise, and; establishing a network of networks of experts, opinion formers and policy makers, to educate national audiences in the threat and to help build national capacities to counter it.
Context and Need for the Project. In no more than 200 words, provide the background to the issue this project will change, what the expected final Outcome will be, and (where applicable) why the UK should fund this project
- Russian open sources say that Russia is at war with the West. The existence of democracy poses a threat to their dictatorial system. Undermining and ultimately destroying Western democratic institutions is Russia’s way of neutralising this “threat”. To this end, Russia is currently employing all forms of power, led by malign influence and disinformation. Russia’s diplomats, media, Information Troops, hackers and troll armies attack individuals, subvert institutions and create mistrust of democratic processes. Incontrovertible evidence of Russian interference is obscured by barrages of lies.
- Whilst this is better publicised since the US Elections, the dangers of Russia’s offensive is acknowledged only in a few capitals and its scale and nature understood only by the expert international community. In some countries there is no awareness at all, or the issue is denied. To change this situation our project will build a network of networks across Europe, organising local teams to counter Russian influence and disinformation in their own societies and challenging the Kremlin’s narrative within Russia itself. Developing a concerted response will not happen spontaneously. It needs leadership. Our Institute has the proven expertise and experience and it is appropriate for the UK to provide this leadership, especially post-Brexit.
Short Project Summary In no more than 200 words explain what the project plans to achieve and how (setting out how the Outputs will deliver the Purpose/Objective, and how the activities will deliver each relevant Output), and what difference will it make on the ground over the next few years? This question will be looked at again during any Evaluation of this project, and when an Impact Report is done. The success of the project will largely be judged on what is said here
To expand our long-term programme so that, over the next two years, at-risk European countries can better understand and counter Russia’s policy of malign influence and disinformation.
To be achieved by:
- Expanding our network of specialists, journalists, academics and political actors across Europe, empowering them to educate their publics and policy elites
- Sponsoring, including via the Free University of Brussels (thereby enhancing academic respectability of the topic), advanced research, publications, workshops, educational courses, mentoring, lectures
- Expanding the impact of the Integrity Initiative website, dissemination and Twitter/social media accounts, and increasing the reporting of the issue in mainstream and specialist press
- Engaging UK and other national political and military establishments, improving their ability to counter Russian disinformation and other weapons of hybrid warfare strategy
- Engaging the Lithuanian Stratcom and Ukrainian SF teams to teach their unique insight into Russian techniques
- Strengthening external organisations’ capabilities, including: NATO Parliamentary Assembly; Atlantic Treaty Association; Interallied Confederation of Reserve Officers; Baltic Defence College; HQ NATO Public Diplomacy; EU Stratcom team
- Engaging Russian and Russian-speaking audiences to challenge Moscow’s narratives
- Adapting our approach as Russia responds to our successful counter moves
- Applying lessons of the programme more widely, e.g. to countering Daesh influence in Muslim communities
Cost
What is the TOTAL cost of the Project Please detail the cost to the FCO and, if relevant the cost to co-funders If relevant, please provide costs for future Financial years. Please note, the cannot guarantee funding for future years Project funds are paid quarterly in arrears.
FY 17/18 £ [est.] 582,635
Cost to FCO £480,635
Cost to Co-funders £ 102,000
Co-Funding
Has funding for this project been sought from other donors (EU, DfID, other countries), Private institutions or the host government?
If Yes, please provide details including source and amount. If No, why not, and were options for doing so explored?
Funding from HQ NATO Public Diplomacy, £12,000 for each inaugural workshop
Funding from partner institutions £5,000 for each inaugural workshop
Funding from NATO HQ for educational video films – free provision of camera team
Funding from Lithuanian MOD to provide free all costs for their stratcom team for a monthly trip to support a new hub/cluster creation and to educate cluster leaders and key people in Vilnius in infowar techniques
Timing
Planned start date:
01 07 2017
Planned completion date:
31 03 2018
PLEASE ATTACH A FULL ACTIVITY BASED BUDGET (in Excel). Proposals without an activity based budget will not be considered The Activity Based Budget must match the activities and timings set out below
Will the Implementing Partner be sub-contracting any other agencies to carry out elements of the project activities? If Yes, please provide details
Good procurement procedures must be followed – please refer to Annex C of the FCO Grant Contract
No
Implementing Agency
Name; Address; Telephone Numbers; Email; Website
The Institute for Statecraft
2 Temple Place
London WC2R 3BD
07974 019 212
www.statecraft.org.uk
Country or countries covered
- Southern and Western European countries and Baltic States, UK, USA, Canada
Have you bid for funding from the FCO in the past three years?
Please provide details of any bids made and/or projects implemented
- 2014 Ukraine capacity building. Unsuccessful bid
- 2015 El Salvador Human Rights and reduction of gang violence. Successful bid.
- 2016 El Salvador Rule of Law and prison reform. Successful bid.
Project Plan
Based on the information provided in the Summary, use the table below to set out the Purpose, Outputs and Activities to be delivered. Give the Indicator(s) for the Purpose and each Output, along with the Baseline information, what the target to be reached is, and when it will be delivered by, along with milestones (checkpoints) at which progress will be measured.
This will allow you to monitor and measure progress throughout the Project, and provide clear evidence of the Project’s success
Indicator = what will be measured (eg the number of people who will be trained; the increase in positive perceptions of an issue)
Baseline = the current status (eg no training exists; current perceptions are x% positive)
Sources = where will the information on the baseline data and targets come from (eg data from research carried out by the implementer; open source data)
Milestones = the key points at which progress will be tracked (can be specific dates/events or the regular quarterly reports – but provide indicative dates for the latter)
Target = what the project will deliver (eg 100 people trained; 50% increase in positive perceptions)
Date = the date by which it will be delivered
Purpose: To counter Russian disinformation and malign influence in Europe by: expanding the knowledge base; harnessing existing expertise, and; establishing a network of networks of experts, opinion formers and policy makers, to educate national audiences in the threat and to help build national capacities to counter it. Indicator(s) Baseline Sources Milestones Target & Date
Establishment of a further 6 national clusters (Hub + network); increased awareness and understanding of the threat posed by Russian influence and disinformation; strengthened capability to respond to that threat
Current networks are passive and limited to experts. There is little spin off from the expert international community’s understanding to national political leaderships.
There is now a solid information base, but expert groups work in stovepipes and there is no overall impetus to collaborate, so the effort does not achieve critical mass
Once collaboration is established under a leadership which focuses on a goal, measurable impact should be seen within 2 months
New national clusters can be set up at a rate of about one per month. Most countries will see significant changes in perceptions within 2 months. In countries where there is a serious problem (eg Greece) evidence will be in the form of seriously increased debate Output 1: Creating or improving the structural mechanisms for tracking, analysing and responding to Russian malign influence and disinformation
Indicator(s) Baseline Sources Milestones Target & Date
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1. Setting up a cluster (Hub plus network of experts, journalists, political players) in each country
2. Setting up a Brussels-based research network to encourage key and at-risk European countries, US and Canada to establish in a major national think tank a process or programme for studying infowar
3. Engage with national MFAs, MOIs, Min Educs to encourage them to set up centres for the study of disinformation etc
4. Employing principally UK and Lithuanian models, engage with Allied Armed Forces to establish units within Spain: Cluster established as proof of concept. Netherlands, inaugural meeting set for 22 June; France, for 24th June. Norway, Germany, Lithuania, Greece, Cluster in process of setting up. Serbia, Italy, Cluster in process of exploratory discussion
Think tanks engaged; first exploratory meeting held on 26 Apl 2017. Meeting in US tentatively scheduled for Sept 2017
Successfully accomplished in France (MFA CAPS) and Norway (MOD). Currently exploring with Germany (Chancellor’s Office)
Lithuanian stratcom team successfully teamed with UK 77 Bde. Successful engagement with Spanish cluster formation in Jan
All data researched by the Institute
Data researched by the Institute and VUB IES
All data researched by the Institute
All data researched by the Institute and 77Bde
Progress will be reported on a monthly basis and the programme amended according to developing circumstances, driven by the pace of international events.
Progress will be reported on a monthly basis
Progress will be reported on a monthly basis and the programme amended according to developing circumstances, driven by the pace of international events.
Progress will be reported on a monthly basis and the programme amended according to developing circumstances, driven by the pace of Each Cluster will consist of a small admin hub (1-3 pers), plus a network of 10-20 active members serving to disseminate material to 100= key individuals and institutions.
12 Institutes have agreed to participate, of which 6 attended the first meeting. Some 20 institutes across Europe should be engaged by Mar 2018
Progress will be tied to the establishment of national clusters. We expect 5-6 MFA/MODs to spark by Mar 2018 Ditto
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their ranks to track, analyse and respond to Russian disinformation and influence
5. Engaging with and using the influence networks of existing international or national allied institutions as agreed, viz: NATO HQ; NATO Stratcom unit, Riga; NPA; RFA; CIOR; ATA; Baltdefcol.
2017. Lithuanian team committed to supporting development of our programme.
ATA engagement agreed; Institute membership of ATA agreed pending formal ATA approval. Exploration of modalities ongoing with RFA & CIOR. NATO
PD support to our programme agreed in principle. NPA and Baltdefcol under discussion.
All data researched by the Institute and ATA to date. Other data should be provided by each organisation
international events.
Progress will be reported on a monthly basis and the programme amended according to developing circumstances, driven by the pace of international events.
It is difficult to calculate numbers at this stage. There is a potential to reach many thousands of individuals. But much will depend on how the institutions take up the distribution of material.
Activities linked to Output 1
Output 2: Commissioning in-depth research and conducting analyses of significant events
Indicator(s) Baseline Sources Milestones Target & Date
1. Completion of in-depth study of Russian influence and disinformation within a specific country: vulnerabilities; issues specific to the country in question; trends.
2. Evaluation study comparing the differences in the way
Germany study completed. Short French study completed. Swedish study satisfactorily undertaken by third party outside this programme. Partial Netherlands study completed.
Background work to this study partially completed
All data researched by the Institute
All data researched by the Institute
Completion of each study report
Completion of the study report
Written report for widespread dissemination; date determined by the programme of each cluster. Italy study has been commissioned but with no completion date yet agreed.
Written report for widespread dissemination; Sept 2017
V. 160104 9 Russia approaches each country (variations in Russian tactics) and why; implications for the response.
3. Tracking Russian attention given to key events: national elections or referenda; international meetings (Summits, G7 etc); troop deployments (eg to Baltic States); unforeseen or surprise events.
4. Preparing a lexicon of terminology for the subject area
5. Preparing a manual of best practice, combining available experience and expertise with new experiences.
6. Preparing a study of attitudes in Russia and of Russian speaking communities in Baltic States, Germany, other
Work for each event needs to be done on an ongoing basis
Not yet begun
Partially completed
Not yet begun
All data researched by the Institute
All data researched by the Institute
All data researched by the Institute or collated from other studies
All data researched by the Institute
Each date will be determined by the event and the cluster programme when agreed
Completion of the lexicon/ report
Completion of the manual/ report
Progress will be reported on a monthly basis and the programme amended according to developing circumstances, driven by the pace of local/
Written report for widespread dissemination, private and public briefings, and/or social media distribution
Written report for widespread dissemination; date TBD
Written report for widespread dissemination; date TBD
Engagement of focus groups of Russian citizens meeting in third countries in summer/autumn 2017 and early 2018
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countries as relevant
7. Devising and undertaking work to determine the relevance of the Russia work to learning how to counter Daesh and others.
In depth study ongoing, will be maintained and expanded
All data researched by the Institute
international events.
Progress will be reported on a monthly basis and the programme amended according to developing circumstances
Engagement of key leaders in target local communities to explore the setting up of a programme. First meetings planed for summer 2017
Activities linked to Output 2
Output 3: Dissemination of knowledge
Indicator(s)
Baseline
Sources
Milestones
Target & Date
1. Publication schedule of in depth studies, policy briefs, textbooks
2. Translation of publications into English or the local language, plus into Russian
The publications will complement existing work
There is an immense need for work in local languages so as to be accessible to local leaderships and journalists who do not speak English. There is an even greater need for work in Russian, to
All material will be produced by the Institute
We will translate both original material produced by the Institute and also selected other material for which permission to translate can be obtained
Completion of each publication. Progress reporting on a monthly basis Completion of each publication. Progress reporting on a monthly basis Written report for widespread dissemination; date TBD Written report for widespread dissemination; date TBD
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3. Preparation of a course on discernment for schoolchildren
4. Preparation of a course on information literacy for University-level students
5. Preparation of a video distance learning course on disinformation and malign influence
6. Formalization of a process of dissemination by targeted emails and hard copy of papers and studies produced by the Institute or from other trusted sources.
7. Formalisation of a process of social media dissemination of
inform Russian citizens, reinforce the democratic opposition, and reach Russian speaking populations of W 7 C European states
Some experience exists, on the basis of which we are developing a course framework
Some examples exist, on the model of which we are developing a course framework
No such programmes exist
This process exists but needs formalizing and amplifying
This process exists but needs formalizing and amplifying
We are working in partnership with Tallinn Technical University and Chester University UK
Our programme will reflect best practice drawn from existing models and tailored to identified specific needs
We are working in partnership with HQ NATO
We will (re-) distribute our own material and good work done by others We will (re-) distribute our own material and good work done by others Progress reporting on a monthly basis Progress reporting on a monthly basis Progress reporting on a monthly basis The process will be tightly monitored with feedback and progress reporting on a monthly basis The process will be tightly monitored with feedback and progress reporting on a monthly The development and implementation of a pilot project for trialling in schools in NW England in autumn 2017 The development and implementation of a pilot project for trialling in VUB in autumn 2017 The development of a pilot video for trialling in Universities in autumn 2017 To ensure effectiveness distribution will be according to carefully drawn-up lists, varying between a handful of people and several hundreds of recipients. Tweeting and retweeting has the potential to reach thousands
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relevant key points, studies etc generated either by the Institute or by a third party.
8. Delivery of presentations and briefings to official, military, and economic (eg City) audiences
9. Devising and implementing counter measures, both general and specific to each country
10. Introduce Information warfare and political (hybrid) warfare modules in the curriculum of relevant VUB IES Masters’ programmes
IfS staff currently deliver 6-8 such presentations weekly to a variety of audiences. These are well received and need to be expanded in number
Very little work has been done in open source on this area and much more is needed.
No such modules exist but market research shows a significant interest in them
All material will be produced by the Institute All material will be produced by the Institute All material will be produced by the Institute/ VUB basis Progress reporting and feedback on a monthly basis Progress reporting and feedback on a monthly basis Progress reporting and feedback on a monthly basis We are currently reaching c1-200 people monthly. This figure can be increased considerably Target for this work is to produce tested material by autumn 2017 Target for this work is to produce tested material by autumn 2017
V. 160104 13 Activities linked to Output 3 Sustainability How will the project ensure benefits are sustained once the project funding ends? The programme is proposed to run until March 2019, to ensure that the clusters established in each country have sufficient time to take root, find funding, and demonstrate their effectiveness. Funding for year 2018-9 will be sought from a variety of sources. The programme will create a critical mass of individuals from across society (think tanks, academia, politics, the media, government and the military) whose work will be mutually reinforcing. Creating the network of networks will also give each national group good international access. Together, these conditions plus the growing awareness within governments of the need for this work should guarantee the continuity of the work under various auspices and in various forms. Monitoring Please note that the Grant Contract specifies the need for (at least) quarterly reporting on progress and finances As the programme is working in a highly volatile international environment, it will likely need to adapt constantly to remain fit for purpose. Consequently, monthly contact with the FCO is requested for reporting and guidance.
V. 160104 14 Risks What are the key risks in implementing this project and how are you going to manage them Add more lines as required Larger/higher value projects will require a full Risk Management Strategy. You should consider whether one is needed for this project. You should also think here about when risks should be escalated Risk Impact Low/ Medium/ High Like-lihood L/M/H Management How will the risk be managed and monitored, what are the mitigating actions, and who is the risk owner Escalation Point At what stage will the management of this risk need to be escalated A malicious court case brought on a pretext by an individual or law company engaged by a stooge of the Russian government with the aim of harassing key individuals and disrupting the programme. Medium/high Low/medium Constant management attention to detail to prevent inadvertent statements in publications. Review of all potential contentious material by the Institute’s legal experts. Taking out a libel insurance policy covering this risk. The risk owner is the Institute On receipt of information that a writ may be issued. Insurance will be taken out pre-emptively A DDOS attack is carried out against the Institute servers; participants in the programme are hacked or trolled; the websites are tampered with and content of material altered, security is breached internally. medium medium The maintenance of good IT firewalls and cyber hygiene procedures. Good management procedures to reduce internal malicious breaches of IT security and encourage instant reporting of mistakes and anomalies. Regular technical checks. The risk owner is the Institute On receipt of evidence of a breach; lowering of technical performance; sudden departure of a staff member Adverse publicity generated by Russia or by supporters of Russia in target countries, or by political and interest groups affected by the work of the programme, aimed at discrediting the programme or its participants, or to create political embarrassment medium Low/medium Education of all participants in the programme to ensure understanding of the risk. Care taken in public statements, interview, conferences. Counselling of victims in event of a problem. Cultivating good relationships with journalists to provide support and counter attack. The risk owners are the Institute and participating individuals Unexpected, unwarranted or aggressive media interest, or the appearance of articles and reports. Stakeholders Who are the people or groups with an interest in this project and who will be affected by it and/or can influence its success either positively or negatively? How will you manage your Stakeholders Interest L/M/H Influence L/M/H Engagement / Communications plan (How to engage, how often and who by/who to) Owner All participants in the national clusters High High Regular contact needs to be maintained with all participants as well as with cluster leaders to ensure enthusiasm, All staff
V. 160104 15 engagement with them Add more lines as required Larger/higher value projects will require a full Stakeholder Engagement & Communications Strategy. You should consider whether one is needed for this project. check competence, and keep up morale. A programme staff member will be engaged for this specific function, but all team members must be engaged in the process. To be effective, the network must be actively maintained and grown. A passive network will be unable to engage with and defeat the threat, and will ultimately disintegrate. Officials in national governments and international institutions. medium high Officials have a limited time availability and are often overworked. Adverse publicity or an admin problem can be disproportionately upsetting. Attention to their requirements and sensitivity to their vulnerabilities need to be borne in mind by all in the programme. All participants Programme funders high high Funders are entitled to expect both efficiency and effectiveness in the carrying out of the programme. Regular reporting and good communications will ensure the funders are satisfied and can have immediate impact should something worry them. Institute staff Our targets high high Our work will annoy a lot of people, who may therefore try to disrupt it. This problem cannot be avoided, but may be reduced by avoiding unnecessarily abusive or provocative action. Steady, effective education of our policy makers and opinion formers will widen the support base and be more effective than shrill, high profile events with no follow through. Good political support achieved by carefully building good All participants
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relations is very valuable in event od confrontation occurring
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Beneficiary Groups
Describe the level of participation of beneficiary group(s) in planning the project
Does the plan reflect the wishes/needs of the beneficiaries
[Beneficiaries are those organisations, groups or individuals who are benefitting from the change that the project will deliver]
The beneficiaries will include Western policymakers and national governments across Europe, as well as the populations of these countries who would be affected by Russian disinformation, destabilisation and malign influence.
Other direct beneficiaries will be those effective institutions working in this area which this programme will actively support and whose work we will disseminate and publicise.
Also benefitting will be genuine media outlets whose reputation is undermined by Russian state propaganda outlets such as RT and Sputnik, masquerading as media sources.
Most of all, the Western system of democratic values will benefit for being protected against attack by those powers who would seek to overturn our system and all it stands for.
Signature of Implementing Agency Lead Contact
Chris N Donnelly
Date
27 04 2017
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Part B: To be completed by Post
What Programme Objectives does this project help meet
Programme
Country Business Plan
Prosperity Fund only: Intermediate outcome from the PF Theory of Change
How will this project help to deliver that Objective
Contact name and details at Post
In addition to the “need for the Project” set out above, what benefit will the Project deliver for the UK?
Please note that if the Project is ODA eligible the primary purpose of the Project must be the development of the host country.
How have lessons learned from previous similar projects been taken into consideration in the development of this idea
What consideration has been given to an exit strategy to ensure that the project does not create dependence? Please provide details
Evaluation
Will this project be evaluated?
Projects over £500,000 must be evaluated, and this should happen within 6-12 months of the Project Completion Report being submitted to London
For Projects between £100,000 and £500,000 please highlight to the Programme Team if you think it would be useful for this Project to be evaluated.
Yes / No:
When:
Yes / No: Please ensure that a decision is made with the Programme Team and the evaluation is added to the evaluation plan. Funding for Project Evaluations will have to come from the Programme budget
The Implementer
Provide details of any previous work with the Implementing Agency, and relevant background information on financial,
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reputational, organisational etc issues
Cross Cutting Issues
What additional impact will the project have on issues such as the environment, diversity and human rights?
Please note both positive and negative possible impacts
For ODA projects: Are you satisfied that the proposed activity is likely to contribute to a reduction in poverty?
Yes / No. Please explain briefly how.
For ODA projects: Are you satisfied that the proposed activity will promote gender equality? If this is not possible, are you satisfied it will not contribute to further gender inequality?
Yes / No. Please include examples where possible.
Human rights (HR) assessment
For projects in the security and justice sectors: Have you completed an assessment under the Overseas Security & Justice Assistance Guidance?
Yes / No
Please summarise the results including the key risks and mitigation measures and overall rating
For other projects: Do you consider that there is a serious risk that the assistance might directly or significantly contribute to a violation of human rights and/or IHL?
If YES what is the risk:
CHECKLIST
Consultancy Value Programme
Are consultants being used in the delivery of this Project? If yes, please ensure that you check the requirements within the CVP on Corporate Procurement Group’s Sharepoint site
Yes/No
Marketing & Advertising Freeze
Will elements of the Project include Marketing or Advertising products and services that are externally procured i.e. will incur cost to FCO. If yes, refer to the guidance on the Comms & Engagement Sharepoint site and complete the necessary clearance forms
Yes/No
TV & Film Production
Is the project producing any television programmes or films (including documentaries)? If yes, you must seek approval from the relevant junior minister’s private office.
Yes/No
Advance Payments
Will the implementer require payments in advance? If Yes, please complete the Advance Payment request Form (Programme Office’s Sharepoint site) as early as possible. Please note, advance payments will ONLY be made where there is a clear justification
Yes/No
Open competition
Has the project been part of an open Bidding Round or Tender process? If not you should refer to your programme team in the first instance to make sure you comply with competition requirements.
Yes/No
Gifting
Will any of the goods procured during the project become the property of the implementer or beneficiary? If Yes, please consult the Gifting & Granting Guidance (Programme Office’s Sharepoint site). Please note, goods purchased during a project will usually remain the property of HMG and will need to be disposed of in accordance with guidance
Yes/No
Contract
There must be a signed contract in place between FCO and the implementer, prior to any activities commencing. Please ensure that the
V. 161210 20 implementer is aware of the content of the Contract well in advance of having to sign. Please refer to guidance on Grant Contracts (Programme Office’s Sharepoint site). If the project is being implemented by a commercial organisation/ business, please see CPG’s Sharepoint site for guidance on Commercial Contracts. Due Diligence Reasonable checks must be made on the potential implementing organisation prior to initiating the project and your findings recorded (see Programme Office Sharepoint site). Please confirm that checks will be / have been carried out. Can this project be referred to publicly, or are there sensitivities that would preclude publicity. If public, please provide an unclassified form of words describing the project, which can be used in briefing materials. Comments from policy lead either geographical or thematic Does the project have your support? Date of Post Programme Board at which the bid was approved Comments from Post Programme Board [Note: All bids must be appraised by the Post Programme Board] Include here, information on why the Project was approved, plus any conditions that were attached. Signature of Board Chair Date Comments from London Programme Board (if applicable) Date Useful links: Programme Office: http://ubs.sharepoint.fco.gov.uk/sites/ops/OU/SPF_Office/default.aspx Corporate Procurement: http://ubs.sharepoint.fco.gov.uk/sites/finance/procurement/default.aspx Comms & Engagement: http://restricted.sharepoint.fco.gov.uk/sites/comms/default.aspx
