A Scottish Government Consultation on Family Law - draft Impact Assessments

Potential reform of the minimum age of marriage and civil partnership- draft Equality Impact Assessment Record

Title of policy/ practice/ strategy/ legislation etc.

Potential reform of the minimum age of marriage and civil partnership

Minister: Minister for Victims and Community Safety

Teams involved in the EQIA

Family Law Policy Unit;

Justice Analytical Services;

National Records of Scotland (NRS);

Child Rights Reporting & Monitoring Unit;

Violence Against Women & Girls Policy Unit

Mainstreaming Unit

Directorate: Division: Team

Directorate for Justice: Civil Law and Legal System: Family Law Policy Unit

Is this new policy or revision to an existing policy?

Revision to an existing policy.

Screening

Policy Aim

The Scottish Government has announced that it will consult on whether it should introduce legislation to raise the minimum age of marriage and civil partnership from 16 to 18.

We will also consult on whether the existing forced marriage or forced civil partnership offence should be amended to criminalise any conduct for the purpose of causing a child (a person under 18) to enter into a marriage or civil partnership. (The law of forced marriage in England and Wales was changed in this way with effect from 27 February 2023.)

This potential extension of the forced marriage offence would be intended to capture behaviour which was not coercive in nature but had the purpose of causing a person under the minimum age of marriage and civil partnership to enter into such a relationship. This would include conduct such as initiating the arrangements, including inducing or persuading that person to take part or attempting to do so.

The current minimum age of marriage in Scotland was set at 16 in the Age of Marriage Act 1929. Before then a girl could marry at 12 and a boy at 14 without need for parental consent.

Section 1 of the Marriage (Scotland) Act 1977 states that:

• “No person domiciled in Scotland may marry before he attains the age of 16” and
• “A marriage solemnised in Scotland between persons either of whom is under the age of 16 shall be void.”

Domicile is a complex legal concept. In general terms, domicile is the country that a person treats as their permanent home and with which they have a substantial connection. Below the age of 16 a child living with his or her parents will generally share a domicile with their parents (known as a “domicile of dependence”).

Under section 86 of the Civil Partnership Act 2004, both parties must be at least 16 to be eligible to register a civil partnership.

In 2023, the UN Committee on the Rights of the Child’s Concluding observations on the combined 6th and 7th periodic reports of the United Kingdom of Great Britain and Northern Ireland recommended that the UK:

• “Prohibit all marriages of children under 18 years of age, without exception, in Scotland, Northern Ireland and all overseas territories and the Crown dependencies of Guernsey and the Isle of Man.”

Article 16(2) of the United Nations Convention on the Elimination of All Forms of Discrimination against Women provides:

• “The betrothal and the marriage of a child shall have no legal effect….”

This is a draft (pre-consultation) EQIA Record as we do not yet have a finalised policy. This draft EQIA Record is being published to support the consideration of the public consultation.

Before the Scottish Government decided to consult, officials met informally with a range of groups to gather views and evidence, including:

• AMINA- Muslim Women’s Resource Centre
• Article 12 in Scotland
• Association of Registrars of Scotland
• Caledonian Humanist Association
• The Church of Scotland
• Evangelical Alliance
• The Free Church of Scotland
• Hemat Gryffe Women’s Aid
• Humanist Society Scotland
• IKWRO Women’s Rights Organisation
• Independent Humanist Ceremonies
• JustRight Scotland
• Karma Nirvana
• Minority Ethnic Carers of People Project (Gypsy/Traveller Carer’s Project)
• Scottish Council of Jewish Communities
• Saheliya
• Scottish Women’s Aid
• The Scottish Association of Mosques
• Shakti Women’s Aid
• Sikhs in Scotland
• Together (Scottish Alliance for Children’s Rights)
• UNICEF UK
• The United Free Church of Scotland

Officials also met with:

• some members of the Scottish Youth Parliament
• some academics

We also spoke to Police Scotland and the Crown Office and Procurator Fiscal to inform them of our work in this area and to seek background information.

The Minister for Victims and Community Safety, Siobhian Brown MSP, met with Pauline Latham, then MP for Mid-Derbyshire, who promoted the Westminster legislation which changed the minimum age of marriage and civil partnership in England and Wales.

The Scottish Government has not decided whether to legislate. Based on the views of stakeholders in favour of reform, this could contribute to the following National Outcomes in the National Performance Framework:

• Children and Young People: We grow up lived, safe and respected, so that we realise our full potential
• Communities: We live in communities that are inclusive, empowered, resilient and safe
• Human Rights: We respect, protect and fulfil human rights and live free from discrimination
• Poverty: We tackle poverty by sharing opportunities, wealth and power more equally

Who will it affect?

Increasing the minimum age of marriage and civil partnership to 18 in Scotland would affect any 16- and 17-year-olds who wish to marry or enter a civil partnership.

If the minimum age of marriage and civil partnership was raised, local authority registrars and authorised religious or belief celebrants could not solemnise a marriage or register a civil partnership of a 16- or 17-year-old.

There might need to be changes to the IT and guidance provided by National Records of Scotland to local authority registrars in relation to the maintenance of the registers of marriages and civil partnerships. There might need to be changes to some forms and other information provided by registrars to the public in connection with the registration of a marriage or civil partnership.

If the existing forced marriage offence was extended as mentioned in paragraph 2 this would affect a number of groups and agencies, particularly Police Scotland and the Crown Office and Procurator Fiscal Service. Alleged perpetrators might be entitled to legal aid which is administered by the Scottish Legal Aid Board. If the penalty imposed on conviction under the extended element of the forced marriage offence involved imprisonment, this would affect the Scottish Prison Service.

It could also affect parents, wider family or others who tried to arrange, encourage or otherwise induce a person under the minimum age of marriage to marry or enter a purported civil partnership.

What might prevent the desired outcomes being achieved?

Increasing the minimum age of marriage and civil partnership to 18 in Scotland would require legislation in the Scottish Parliament.

Stage 1: Framing

Results of framing exercise

A variety of points were made at the internal Scottish Government framing exercise:

• The number of registered marriages involving under 18-year-olds is very low, but the evidence clearly indicates more girls under 18 marry than boys. It appears that marriage under 18 typically involves young women in mixed sex relationship with an older boy or man.
• Some stakeholders expressed concern that marrying at a young age can potentially increase the chance of experiencing domestic abuse.
• There needs to be a balancing act when considering the rights we afford children and the protections we need to put in place for them.
• It can be confusing for children to be allowed to do certain things but not others.
• We do not have evidence to explain why people under 18 choose to marry, however a lack of opportunities for young people in Scotland could lead them to choose to marry.
• While the number of 16- and 17-year-olds entering into a marriage or civil partnership is very low, increasing the age to 18 could be seen more as a symbolic act where Scotland would be aligning with the recommendations of the United Nations Committee on the Rights of the Child, and with other countries which have also fixed their minimum age of marriage at 18.
• Increasing the minimum age could be argued to increase safeguards for young people but such a change could also be seen as removing their right to marry or enter a civil partnership.
• Reaching a view on reform in this area is potentially cross-cutting. We currently permit 16- and 17-year-olds to exercise a range of other rights with or without additional protections.
• We will need to consult with more young people and are exploring the options to involve them in the consultation. We have previously sought their views at a Scottish Youth Parliament workshop.
• It has been suggested that one group that might be impacted by a change in the minimum age of marriage and civil partnership might be the Gypsy/Traveller community. This is anecdotal evidence as we do not have statistics in this area.
• Increasing the minimum age of marriage could have a positive effect on instances of forced marriage.
• A lot of pressure to get married could come from family members or the wider community.
• As this is a sensitive subject, we would seek views internally on how best to approach asking the right questions in the consultation.
• Some stakeholders have expressed views that more should be done to educate children on the rights that they have.
• A number of stakeholders we met expressed the initial view that there were other options for protecting children that might have more success than changing the forced marriage offence.

Extent/Level of EQIA required

There is clear statistical evidence that very few registered marriages involve a 16- or 17-year-old party and that the numbers have been steadily declining for some time. Consequently, it appears this potential change to legislation to increase the minimum age of marriage and civil partnership could be viewed more as a symbolic change. Nonetheless, it is important to consider any available evidence around groups or communities which might be more impacted by such a change. We are also considering other action, such as a change in the forced marriage offence which could affect marriage ceremonies without legal effect or purported civil partnership which involve a party under the minimum age of marriage and civil partnership in Scotland.

It has been suggested that raising the minimum age of marriage could have a positive impact for women and girls. In particular, the UN Committee on the Rights of the Child and the Committee on Eliminating Discrimination against Woman issued a joint General Recommendation which notes international evidence about the impacts of early or child marriage:

“Child marriage is often accompanied by early and frequent pregnancy and childbirth, resulting in higher-than-average maternal morbidity and mortality rates. Pregnancy-related deaths are the leading cause of mortality for girls between 15 and 19 years of age, whether married or unmarried, around the world. Infant mortality among the children of very young mothers is higher (sometimes as much as two times higher) than among those of older mothers. In cases of child and/or forced marriage, in particular where the husband is significantly older than the wife, and where girls have limited education, the girls generally have limited decision-making power in relation to their own lives. Child marriage also contributes to higher rates of school dropout, especially among girls, forced exclusion from school and an increased risk of domestic violence, in addition to limiting the enjoyment of the right to freedom of movement.”

It is not clear, given the low numbers of registered marriages and civil partnerships involving parties under 18, how harmful these relationships are in Scotland in terms of the harms referenced by the UN Committee’s summary of international evidence.

One point that could be brought up in consultation responses is, should the minimum age of marriage be increased, it would then not be aligned with the age of consent to sexual intercourse. That might raise concerns among some religious groups. Young people could also still enter a cohabiting relationship. The cross-cutting nature of a change to the minimum age of marriage and civil partnership suggests that the evidence around the impacts should be carefully considered as the Scottish Government progresses this work.

Stage 2: Data and evidence gathering, involvement and consultation

Age

Evidence gathered and strength/quality of evidence

We are doing a draft Children’s Rights and Wellbeing Impact Assessment (CRWIA) separately and will consider further evidence relating to those under 18 in that assessment.

In 2023 there were 21 instances of marriages in Scotland where one or both parties were 16 or 17.

This can be compared with 2013, when there were 50 recorded marriages where at least one party was under 18.

Between 2005 and 2023 there were 4 civil partnerships registered where one or both parties were 16 or 17.

The NRS data is high quality statistical data. It suggests that in practice very few young people would be impacted if legislation raised the minimum age of marriage and civil partnership to 18.

Source

NRS

Data gaps identified and action taken

N/A

Disability

Evidence gathered and strength/quality of evidence

We have no evidence about 16- and 17-year-olds with a disability who marry or enter a civil partnership.

Source

For evidence on those with the protected characteristic of disability see our Equality Evidence Finder see our Equality Evidence Finder at http://www.equalityevidence.scot/

Data gaps identified and action taken

We will consider consultation respondents’ views and evidence.

Sex

Evidence gathered and strength/quality of evidence

Data shows that more girls marry aged 16 or 17 than do boys of the same ages. We obtained data from NRS specifically on the sex of 16- and 17-year-olds marrying. In the ten-year period between 2013 and 2023, 247 girls aged 16 or 17 married compared with 59 boys of those ages.

The published data is about those aged 19 and under. The published NRS data in 2022, indicates that 61 females aged 19 or under were recorded as married in Scotland. In 2022, 31 males married in the same year.

The NRS data is high quality statistical evidence which indicates that a change in the minimum age of marriage would impact more for girls.

The evidence suggests that girls or young women under 18 who marry are entering mixed sex marriages with older boys or men. See the evidence under the protected characteristic of Sexual Orientation.

Source

NRS Statistics and Data: Vital Events: Section 7: marriages and Civil Partnerships at Table 7.01b

Data gaps identified and action taken

N/A

Pregnancy and maternity

Evidence gathered and strength/quality of evidence

There is published data on teenage pregnancies in Scotland, but this does not identify the marital status of the mother. (1)

NRS data shows that the number of live births in Scotland to a married mother under the age of 20 has reduced significantly, from 202 in the year 2000 to 24 in 2022. (2)

The NRS data is high quality statistical evidence. However, we already have evidence that the numbers of 16- and 17-year-olds who marry or enter a civil partnership is very low.

Source

(1)Public Health Scotland - Teenage Pregnancies Year of conception ending 31 December 2020

(2)NRS Statistics and Data: Vital Events: Births at Table 3.01b

Data gaps identified and action taken

N/A

Gender reassignment

Evidence gathered and strength/quality of evidence

We do not have evidence about the gender reassignment status of those who marry or enter a civil partnership

Under the Gender Recognition Act 2004 the minimum age for applicants to apply for a gender recognition certificate (GRC) is 18. Therefore a 16- or 17-year-old cannot apply for a GRC.

Source

For evidence on those with the protected characteristic of gender reassignment see the Scottish Government’s Equality Evidence Finder

Data gaps identified and action taken

We will consider consultation respondents’ views and evidence.

Sexual orientation

Evidence gathered and strength/quality of evidence

We do not have data about sexual orientation specific to 16- or 17-year-olds entering a marriage or civil partnership.

NRS data shows that in 2023 there were 18 mixed-sex civil partnerships registered where one party was under 25. The same year there were 5 same-sex civil partnerships registered with the same criteria. (1)

NRS has not published data on the age of individuals entering into same sex marriages. In 2023, there were 1,040 marriages of same sex couples. (2)

We are aware it has been suggested that there might be injustice for those in same-sex relationships arising from increasing the minimum age of marriage and civil partnership to 18. (3)

The NRS data is high quality statistical information but is not specific to 16- and 17-year-olds and does not cover marriages which are more numerous.

Source

(1)NRS Statistics and Data: Vital Events: Marriages and Civil Partnerships Tables at Table 7.11

(2)NRS Statistics and Data: Vital Events: Marriages and Civil Partnerships Tables at Table 7.02

(3)“Early marriage: any need for action?” Rob Clucas, Journal of the Law Society of Scotland, 13 November 2023.

Data gaps identified and action taken

N/A

Race

Evidence gathered and strength/quality of evidence

We do not have data about race or ethnicity of 16- or 17-year-olds entering a marriage or civil partnership.

NRS has published data on the country or birth and country of nationality for parties marrying in Scotland, and the country of birth for those registering a civil partnership in Scotland. (1)

It has been suggested that there could be adverse impacts for the Gypsy/Traveller community in Scotland because it may be more common to marry at 16 or 17 in that community. (2)

The evidence is that forced marriage is not limited to any one community in Scotland although it may be experienced predominantly in the South Asian community. (3)

Source

(1)NRS Statistics and Data: Vital Events: Marriages and Civil Partnerships Tables at Tables 7.08,7.09 and 7.12

(2)See for example “Inequalities experienced by Gypsy and Traveller communities: A review”, Equality and Human Rights Commission, 2006, at page 231

(3)Understanding Forced Marriage in Scotland, Scottish Government, 30 January 2017

Data gaps identified and action taken

We will consider consultation respondents’ views and evidence.

Religion or belief

Evidence gathered and strength/quality of evidence

We do not have evidence regarding the religion or belief of those who marry or register a civil partnership in Scotland.

There is data on the numbers of civil marriages, and marriages solemnised by religious or belief celebrants. (1)

Our analysis of data separately provided to us by NRS for marriages involving a 16- or 17-year-old in the period 2013-2023 (276 marriages) indicates that for Scotland as a whole:

73% (202) were conducted by a civil registrar

17% (47) were conducted by a celebrant from a Christian religious body or denomination

8% (22) were conducted by a celebrant from a Muslim religious body

the remaining 2% (5) were conducted by celebrants representing other religious bodies and some belief bodies.

Of the 17% (47) of ceremonies conducted by celebrants from a Chistian religious body or denomination, 12 celebrants were from the Roman Catholic Church, 10 from the River of Life Church, 9 were Ministers of deacons from the Church of Scotland and 9 celebrants from the Assemblies of God. (2)

This is based on high quality statistical information. It does not suggest that marriages involving a 16- or 17-year-old party are predominantly taking place in any particular religious or belief group.

Source

(1)NRS Statistics and Data: Vital Events: Marriages and Civil Partnerships at Tables 7.05, 7.06 and 7.07.

(2)NRS internal data provided to the Scottish Government.

Data gaps identified and action taken

We will consider consultation respondents’ views and evidence.

Marriage and civil partnership

Evidence gathered and strength/quality of evidence

In respect of this protected characteristic, we are required to comply with the first need of the public sector equality duty (the duty to eliminate discrimination, harassment, victimisation or other prohibited conduct) and only in respect of work. The proposed policies under consideration do not relate to work.

Source

N/A

Data gaps identified and action taken

N/A

Stage 3: Assessing the impacts and identifying opportunities to promote equality

Having considered the data and evidence you have gathered, this section requires you to consider the potential impacts – negative and positive – that your policy might have on each of the protected characteristics. It is important to remember the duty is also a positive one – that we must explore whether the policy offers the opportunity to promote equality and/or foster good relations.

Do you think that the policy impacts on people because of their age?

Eliminating unlawful discrimination, harassment and victimisation:

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation.

Advancing equality of opportunity:

Evidence shows that females are more likely to marry at a young age than males and some stakeholders believe increasing the minimum age of marriage will have a positive impact on 16- and 17-year-old girls and improve safeguarding.

Promoting good relations among and between different age groups:

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Do you think that the policy impacts disabled people?

Eliminating unlawful discrimination, harassment and victimisation

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation. We currently have no evidence relating to disabled 16- and 17-year-olds who marry or enter a civil partnership.

Advancing equality of opportunity

We currently have no evidence relating to disabled 16- and 17-year-olds who marry or enter a civil partnership.

Promoting good relations among and between disabled and non-disabled people

We currently have no evidence relating to disabled 16- and 17-year-olds who marry or enter a civil partnership. This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Do you think that the policy impacts on men and women in different ways?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation.

Advancing equality of opportunity

As mentioned previously, some stakeholders have suggested that increasing the minimum age of marriage would have a positive impact for women and girls and it is clear from the evidence that more girls aged 16 and 17 marry than boys of those ages.

Promoting good relations between men and women

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Do you think that the policy impacts on women because of pregnancy and maternity?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation.

Advancing equality of opportunity

While there are limited numbers of younger married mothers in Scotland, the UN Committee on the Rights of the Child’s international evidence suggests increasing the minimum age of marriage and civil partnership to 18 could potentially have a positive impact on teenage pregnancy rates and on health outcomes for both mother and child.

Promoting good relations

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding for 16- and 17-year-olds.

Do you think your policy impacts on people proposing to undergo, undergoing, or who have undergone a process for the purpose of reassigning their sex?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation.

Advancing equality of opportunity

We currently have no evidence relating to 16- and 17-year-olds with the protected characteristic of gender reassignment who marry or enter a civil partnership.

Promoting good relations

We currently have no evidence relating to 16- and 17-year-olds with the protected characteristic of gender reassignment who marry or enter a civil partnership. This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Do you think that the policy impacts on people because of their sexual orientation?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination, harassment and victimisation.

Advancing equality of opportunity

We have noted the suggestion that increasing the minimum age of marriage could be seen as negatively affecting same-sex couples. However, it has also been suggested to us by stakeholders that gay or lesbian people should be treated in the same way as heterosexual people.

Promoting good relations

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Do you think the policy impacts on people on the grounds of their race?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination.

Advancing equality of opportunity

There is anecdotal evidence that it might be more common for 16- and 17-year-old women from the Gypsy/Traveller community to marry than is the case for in other communities and that there could be adverse impacts for women who could not do so within their culture. We will consider the views of consultation respondents and any further evidence in determining next steps, including assessment of positive or negative impacts shown by the responses and evidence and any steps that can be taken to address concerns.

Promoting good race relations

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

It might be argued that increasing the minimum age of marriage and civil partnership could have a negative impact on relations with the Gypsy/Traveller community. We will consider the views of consultation respondents and any further evidence in determining next steps, as above.

Do you think the policy impacts on people because of their religion or belief?

Eliminating unlawful discrimination

We do not consider the current law or the potential policy to change it constitute unlawful discrimination.

Advancing equality of opportunity

Increasing the minimum age of marriage and civil partnership could create a perceived discrepancy as the age of consent would remain at 16. It has been suggested this would mean that some people of faith would have to abstain from sex until they are of age to marry. However, some groups we spoke to suggested that those of faith often have to abstain from certain legally permitted activities because they contravene their beliefs. To the extent that there may be religious or cultural marriage ceremonies taking place which are not legally valid here, either in Scotland or abroad involving children from Scotland, extending the forced marriage offence may deter parents and families from organising these ceremonies.

Promoting good relations

This potential policy is not about promoting good relations. Some stakeholders argue the proposed changes under consideration would improve safeguarding of 16- and 17-year-olds.

Stage 4: Decision making and monitoring

Identifying and establishing any required mitigating action

Have positive or negative impacts been identified for any of the equality groups?

There are potentially positive impacts for the protected characteristics of age and sex (particularly for women). Some stakeholders have suggested that there might be negative impacts for the protected characteristics of race and of sexual orientation. Some may argue that there may be a negative impact for some people of faith of raising the minimum age of marriage, if the age of consent to sexual intercourse remained 16.

Is the policy directly or indirectly discriminatory under the Equality Act 2010?

N/A

If the policy is indirectly discriminatory, how is it justified under the relevant legislation?

N/A

If not justified, what mitigating action will be undertaken?

N/A

Describing how Equality Impact analysis has shaped the policy making process

No direct changes have been made to this potential policy as a result of this draft EQIA Record which is intended to support a public consultation. However, the draft EQIA Record has highlighted the need to consider carefully any points raised by consultation respondents relating to the protected characteristics of sex (particularly in relation to women), race, sexual orientation, and religion and belief.

There are no direct implications for finance as a result of this draft EQIA Record. There would be costs in relation to implementing any changes in the law if after consultation, legislation proceeds. The potential costs of reform are considered in our draft Business and Regulatory Impact Assessment.

Monitoring and Review

At this stage, the Scottish Government has not decided to legislate. This draft EQIA Record is intended to support the public consultation. We will consider monitoring and review issues once the consultation responses are analysed and next steps are decided.

Stage 5: Authorisation of EQIA

Stage 5 will be completed and an updated EQIA published if, following analysis of the consultation responses, the Scottish Government takes forward legislation.

Please confirm that:

This Equality Impact Assessment has informed the development of this policy:

Yes

No

Opportunities to promote equality in respect of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation have been considered, i.e.:

• Eliminating unlawful discrimination, harassment, victimisation;
• Removing or minimising any barriers and/or disadvantages;
• Taking steps which assist with promoting equality and meeting people’s different needs;
• Encouraging participation (e.g. in public life)
• Fostering good relations, tackling prejudice and promoting understanding

Yes

No

If the Marriage and Civil Partnership protected characteristic applies to this policy, the Equality Impact Assessment has also assessed against the duty to eliminate unlawful discrimination, harassment and victimisation in respect of this protected characteristic:

Yes

No

Not applicable

Declaration

I am satisfied with the equality impact assessment that has been undertaken for reform of the minimum age of marriage and civil partnership and give my authorisation for the results of this assessment to be published on the Scottish Government’s website.

[This will be completed after this consultation and views have been obtained from consultees]

Name:

Position:

Authorisation date: