Scottish Honey Bee Health Strategy Steering Group - November 2019

Minutes of the meeting of the Scottish Honey Bee Health Strategy Steering Group on 14 November 2019 at 11am

Attendees and apologies




Nick Ambrose

Scottish Government

Branch Head, Animal Health & Welfare (Chair)

Luis Molero

Scottish Government

Lead Bee Inspector

Jackie Quigley

Scottish Government


Sarah Gallagher

Scottish Government


Fiona Highet

Scottish Government (SASA)

Senior Entomologist 

Graeme Sharpe


Apiculture Specialist

Alan Riach

Scottish Beekeepers Association


Bron Wright

Scottish Beekeepers Association

Past President

Gavin Ramsay

Scottish Beekeepers Association

Bee Health Convener

Helen Nelson

Scottish Beekeepers Association


Margaret Ginman

Bee Farmers Association

General Secretary

Murray McGregor

Bee Farmers Association

Past chairman

Margaret Thomas

Bee Farmers Association


Julian Parker

National Bee Unit (NBU), APHA

Acting Head of National Bee Unit

Angus MacAskill

Scottish Government

Bee Inspector (Observer)

Karen MacKenzie

Scottish Government





Phil MacAnespie

Scottish Beekeepers Association

Vice President

Belinda Philipson


Defra Plant and Bee Health Evidence & Analysis

Nigel Semmence

National Bee Unit

Contingency Planning and Science Officer

Sandra Gray

National Bee Unit

National Bee Inspector

Items and actions

Item 1: Welcome and apologies

Nick extended a warm welcome to everyone, in particular to those attending for the first time. Apologies as above

Item 2: Previous meeting minutes (9th meeting 15 November 2018)

The minutes from the previous meeting were agreed.

Item 3: SASA Report

Entomology team has six members of staff, this includes Fiona Highet, Mairi Carnegie and Hanna Gizycka who are involved in ‘bee work’.

There have been 22 varroa test requests this season. 62 colonies tested. A further 13 samples were tested for unexplained colony loss.

SASA have received 144 foulbrood samples (407 colonies tested)  from the bee Inspectors (60), certified bee farmers (72) and self-reporting beekeepers (12) who could not be checked by the inspectors.

Braula fly is still present in Orkney. Braula is a wingless fly that lives within honey bee colonies and minimally impacts on the bees. NHM is interested in current UK status as varroa treatment has eradicated braula from most of mainland Britain.  

There have been training workshops for the bee Inspectors, bee farmers.  The SG and SASA had a presence at the Royal Highland Show in the honey tent. Fiona has also been involved in talks with schools, Roslin Institute and some evening talks to local associations.

Fiona was also involved in the recruitment of the new lead bee inspector.

R &D projects - Fiona and Graeme Sharpe (SRUC) are still doing research with Luke Woodford from St Andrews University on the Isle of Arran.

EFB Subclinical Project

Asian hornet – education and updates

Item 4: BHIT report

Luis gave a report about what has been happening since he joined on the 5 August 2019.

There have been a few changes this year.  Steve Sunderland, John Smith and Jim Anderson have all retired.  This means that we have a limited number of staff.  We have one part-time and three full-time bee inspectors.  We do have one on maternity leave but we are unsure if they will be coming back to help on bees when they return to work.

We are hoping for a well-resourced and trained team for next season.  We are recruiting for new bee inspectors for next season.  We are still in the early days but we have until March to get the right people.  Training will begin in May, Graeme Sharpe (SRUC) and SASA will all be involved.

Bee health strategy is coming to an end in June.  We need to work with the BHIP to review this.

We also need to review the EFB control plan for the bee farmers. 

Contingency plans?

There are 2,390 beekeepers in Scotland who are on BeeBase.  That is 3,416 apiaries and 14,888 colonies.  We have inspected 417 colonies, 58 beekeepers.  There were193 colonies infected with EFB this season.  That was a total of 61 apiaries, eight beekeepers where affected (four commercial and four hobby).  There were also 10 cases of AFB in Scotland.  A total of five apiaries where affected but on one beekeeper. 

Luis Molero, Gordon Mackay and Claire Gill were hosted by the State of Jersey for four days on which they learnt about the AH control activities carried out on the island, including track, tracing and removal of nests. The time was very valuable and illuminating in terms of the resource required to deal with AH and the cooperation with and between beekeepers.

Item 5 – Scottish Beekeepers Association report

Board of trustee and advisors

In addition to 17 Trustees and two advisors, one covering IT and one insurance, the SBA has a development officer, who is self-employed, supplying services on a sub-contract, part-time basis.


Michelle Berry’s current main role is to develop an online Bee Academy for the SBA website where beekeepers can extend their knowledge at their own pace. Michelle is currently investigating sources of funding for this task. She is also editing the Scottish Beekeeper magazine on a temporary basis due to the editor having had twins.


The Information and Communications Technology team continue to add relevant content to the SBA website. It is a valuable information resource for beekeepers and lay members of the public can be used easily and quickly to order shop items, apply for membership and apply for SBA exams and workshops. All education syllabuses and module past papers are available in the members pages.

SBA membership

Membership is at about 1,770 as last year including the 43 affiliated local beekeeping associations (ABAs). It is believed that there are about 2,500 beekeepers in Scotland. Beekeepers can be members of an ABA without being a member of the SBA, or vice versa. The SBA offers a discount rate for first-time members (£20). Most first-time members come from ABA beginner classes.

SBA Subscription fee

The individual and ABA membership fee stays the same this year at £35 (£20 for ABAs under 50 members)

Affiliated beekeeping associations (ABAs)

There are 43 ABAs. Virtually all local associations are now affiliated to the SBA and also some beekeeping groups who are part of wider community groups, such as Tarland

Members’ meetings

An AGM, and members and delegates forum have been held during the year. The main change was a constitution change (AGM) to restrict trustee post duration to nine years. Members raised concerns at the Nov delegates and members meetingabout the large numbers of bee and queen imports specifically of non-black (Amm) bees. The trustees advised that EU rules prevented import restrictions with ref to Dr Ambrose’s letter of 2014 clarifying this point. Questions were asked about whether species conservation projects could overrule EU free trade rules. The SBA president stated that the European court had ruled that this was only possible if all beekeepers in a defined boundary area (island or EU country) agreed and referenced the Danish Laeso island case (which failed due to some beekeepers on the island wanting to maintain the freedom to import any type of bee).

Luis Molero gave an interesting talk at the delegates and members meeting outlining his journey towards becoming the SG lead inspector and his ambitions for better disease control in Scotland.

Honey bee health

After a mild winter, the bees built up fairly quickly in spring and were able to take advantage of early crops such as canola (OSR 00). Health up to that point (June) was generally good. The June gap was particularly severe this year, with feeding necessary, and this stressed the bees leading to diseases such as chalk brood and sac brood appearing in July. The bees recovered somewhat by end of July and, in spite of wet weather, harvested lime and late summer flower honey. Again, in spite of wet weather, the heather yielded well in most places.

Notifiable diseases

Generally the foulbroods seem under control and we thank the bee farmers and the Scottish bee inspectors for continuing to monitor and control outbreaks.  Members continue to express concern when large numbers of colonies appear in their areas for the canola (OSR) flows, but as far as is known, spill-over of disease from bee farming into the hobby sector seems to be minimal.

Chronic bee paralysis virus: this seemed less prevalent in the hobby sector than in 2017.

Asian hornet and small hive beetle: monitoring is continuing for these pests.

Restocking options in Scotland

Work is still progressing from the queen rearing project sponsored by the SG and carried out by Gavin Ramsay. Several ABAs are now rearing queens and producing nucleus colonies for beginners, and efforts are being made to expand those activities.

SBA Education

A full education programme has again run throughout 2019 and next year’s program is being planned.


Practical exams: uptake remains encouraging. 50 SBA Basic Beekeeping Certificates (BB) were awarded. In addition there were two intermediate practical, two apiarian (advanced practicals), and two expert bee masters. Seven members applied for and received the SBA Beekeeper Trainer Certificate. The increase in intermediate and apiarian practical candidates is particularly gratifying as they are the people who will become mentors and teachers in the future. This is greatly aided by the Moray Beekeepers Association 'Healthy BEES' two-day workshops, seven of which were run throughout Scotland last year. These courses are heavily subsidised by the Scottish Rural Development Programme Knowledge Transfer and Innovation Fund and supported by the SBA. The program is funded for three years and tutored by Tony Harris NDB and Ann Chicott, both SBA expert bee masters.

Modular exams: 68 candidates gained module certificates in Nov 2018/Mar 2019 and 11 candidates reached the level of Intermediate Module Certificate (four modules) and seven Advanced Module Certificate (all seven modules passed).

Exam fees

All fees stay the same for next year: Junior beekeeper £5, BB £20 , Modules £23 and the more senior exams £35

International Meeting of Young Beekeepers 2018

The IMYB was held in Slovakia (Banska Bystrica) from 3 to 9 July 2019. The SBA sent three young beekeepers who excelled in representing Scotland with Martin Leahy of Tarland gaining the individual trophy (Best Young Beekeeper – out of 79 entrants). The Scottish team did very well in the individual country award (seventh out of 29 entrant countries) and the Scottish entrants also were well placed in the International teams being present in the teams that came second, third and sixth .Thanks to all who supported the project. Next year the meeting is in Slovenia 29 June to 1 July and Bron Wright is confident of again getting a full team of three young people recruited. The Royal Highland Society of Scotland agreed to donate £1,800 a year for three years to support the preparation and travel costs associated with the IMYB, and the Scottish Government and bee farmers have also been generous in their support. All support is very much appreciated.

Courses and workshops

Workshops were held in microscopy (preparation for the exam in 2020). Skep making, honey–preparing the bees and processing honey, wax workshop and two train the trainers (TtT) courses in Nov. These TtT courses are valuable in helping experienced beekeepers to pass on their knowledge. The TtT courses were subsidised by the SG via the Bee Health Strategy Group and it is hoped that the SG can continue to support the courses. Two very successful bee health days were run by the Scottish Government.

SQA Level 5 beekeeping courses

The University of the Highlands and Islands (UHI), in association with Inverness Beekeepers Association and the Scottish Beekeepers Association, has developed a Scottish Qualification Authority (SQA) approved course in beekeeping. This is a National Progression Awards (NPA) course covering three areas – the basics of beekeeping theory; the identification and use of associated equipment; and understanding the subduing and manipulation of colonies of bees.

It will be awarded at Scottish Credit and Qualification Framework (SCQF) Level 5 (about old O level/standard grade -ABRs estimation) The course is designed to be run in conjunction with local beekeeping associations in order to cover the hands-on part of beekeeping. It has been based on the SBA Basic Beekeeping Syllabus BB) and should, in conjunction with local beekeeping association practical coaching, take students to the point where they could sit their BB exam. Several schools are planning to run these courses.

SBA Autumn Convention

A very successful convention weekend was held in Aberdeen in the Hallmark Hotel at Dyce airport. Talks were given by Tony Harris-Moray (Maximising the Honey Harvest and Going to the Heather) and Dara Kilmartin-Dublin (Colony Nutrition and The Amazing World of Bee Vision).

Lecture tour, 30 Sep – 4 Oct

Irene Power of Ireland gave four insightful and enjoyable talks at five venues around Scotland. Subjects covered were Spring/Summer Management to Maximise the Honey Crop, Are you Ready for Winter, Efficient Beekeeping for the busy beekeeper and Easy Nucs.

Promotion of beekeeping

Engagement between the SBA and the public is recognised as vital and much time is spent by trustees and our development officer on attending agricultural shows, food festivals, community and schools’ groups, The Royal Highland Education Trust (RHET) have now included beekeeping in their open farm days program and the SBA and ABAs have been supporting these days, where schoolchildren are shown where their food originates. The beekeeping tent at these events is always very popular. The seven video clips for children which can be accessed on the SBA website at Learn/Bee basics are still proving popular.

SBA Moir Library

Several favourable international responses have been received regarding the digitised back copies of the Scottish Beekeeper (back to the first copy, published in 1924) and also regarding the material on the SBA website.

SBA-supported research

Varroa research: a study ‘to create an off host culture system for the parasitic mite varroa destructor’, continues at the University of Aberdeen, part funded by the SBA.

2016 COLOSS CSI pollen project: The project continues with the volunteer beekeepers now working on pollen analysis.


The SBA has been represented at meetings including, CONBA-UK, SG Bee Health and Education, National Diploma of Beekeeping (NDB), UK National Honey Show, Royal Highland Show, Scottish National Honey Show (Dundee Food and Flower Festival), Scottish Smallholders’ Festival and Women in Agriculture.       

Item 6 - Bee Farmers Association report (supplied from Margaret Ginman)

“Firstly, I would like to thank you all round this table for the positive and constructive working relationship with the BFA. It shows much can be achieved by working together and listening to each other.

Much of the work of the BFA this year has been taken up with concerns about agriculture policy post Brexit. We have spent a lot of time studying proposals and feeding in to consultations at all levels of government.

We have also worked with all countries of the UK regarding their national pollinator strategies. After all bees know no boundaries. The BFA is actually the only UK-wide honey bee organisation.

The BFA addressed the problem of the ageing profile of bee farmers with the introduction of our Rowse / BFA apprenticeship scheme. Our original target was to attract 30 youngsters into the profession. We hope to get to that 30 next year - no mean achievement for a small organisation of just 456 members. Our first six graduated this year and we have four more who have completed the course and are awaiting their results. Our first apprentice in Scotland started this year though Scotland has played a part in giving others who have attended the scheme the benefit of their knowledge.

Our youngsters are awarded the Wax Chandlers Diploma for Excellence in Bee Farming.

The BFA is extending the use of its apprentice units to roll out adult training across the UK.

Also looking forward the BFA is happy to be working with you to bring world-famous queen breeder Keld Brandstrup over from Denmark to speak alongside our chairman Ged Marshall in Perth in March. Keld worked with Brother Adam for two years and managed to obtain breeding stock from Buckfast Abbey. The BFA took a group of 20 bee farmers over to visit Keld in the spring.

Winter losses - the heaviest in recent years for some - undoubtedly had an impact on honey harvests this year. However, the picture of the honey harvest across the UK is one of the most varied for year - some reporting bumper crops and others disastrous low crops. Interestingly, I attended the EU Honey Working Party on Tuesday and this huge variation is mirrored across Europe. I have typed up a brief comment from each country on this issue and am happy to distribute it. I will give you some examples though.  (Please see Annex A)

Scottish Harvest – bees have had conditional issues due to spring appearing earlier this year.  Some places in Scotland had a poor spring harvest due to the weather.  The ground was really dry in the east of the country which didn’t do well for the crops.  Summer was very hot and the heather started early as well.  If people had their bees up at the heather in July they seemed to do well, however if they were there in August the heather was gone.  It has been an average year for honey yield.  Also the cluster size going into winter seems to be very high.”

Item 7 – SRUC Report (supplied by Graeme Sharpe)

“Outputs of the advisory activity AA119 Bee Health.  Delivers education, training, advice and knowledge transfer to beekeepers in Scotland.  The total budget to deliver this is £82,000 and my role is to manage the advisory activity.  I am located in Auchencruive, Ayr which has an education apiary, honey house and training rooms.  The key outputs of the Advisory activity are evening talks/workshops which include:

  • swarm control and prevention
  • hive and apiary hygiene
  • observing the colony
  • spring and summer management
  • varroa management
  • queen rearing principles and methods
  • disease recognition and
  • my method of beekeeping

The talks are done all over the country.  I have had done talks in Skye in the Northwest to Dumfries in the Southwest and all the bits in between.

Bee health days in Tarland and Dumfries this year. Great team work with Scottish Government, SASA, SBA and local beekeepers.

I also ran three swarm control prevention days (May, June and July) this year.  This includes:

  • preparation of swarming
  • factors effecting swarming
  • queen cell recognition
  • swarm prevention methods
  • swarm control methods
  • making up a nuc
  • good husbandry practice

I went to the Isle of Arran with Luke (St Andrews University student doing placement at SASA) to check the bees there.

Also helped with the bee farmers and BHIT training day.  This is to help bee Inspectors and bee farmers recognise the signs of disease within the colony.  They learn about biosecurity, the biology of the disease, treatment options including the destruction of colonies, shook swarm and economics.  They also view live samples and have an assessment at the end.

Farm Advisory Service (FAS) programme will be held in Perth on 7 March 2019.  These training days are for bee farmers wishing to launch or re-launch their business or bee keepers looking to make the move into professional bee farming.  They will cover the practical issues affecting bee farming on a larger scale, as well as information on setting up a business, marketing and branding products, keeping accurate accounts, running a business and writing a business plan.”

Item 8 – NBU/APHA/BHAF report

NBU has been undergoing a reorganisation for the future ways of working.

The review of the 10-year programme probably won’t happen until next year.

The annual hive count is currently live.

50 part-time inspectors for the coming year but currently have vacancies for one regional bee inspector (RBI) and seven seasonal bee inspectors (SBIs).

There is a small R&D team for the Asian hornet.  This is the third year of live outbreaks of the Asian hornet.  Most of the confirmed sightings have initially been from beekeepers or local people to the area.

To date there have been 13 confirmed sightings in England and six nests have been destroyed.  Nine of these sightings have occurred in 2018: an individual hornet in Lancashire (April) and Hull, three in Cornwall, two in Hampshire, one in Surrey (all September) and the latest in Kent (October).

There is also the Asian hornet app which is encouraging people to record species to contribute to the database.

Imports - there has been an increase in imports of 17% for honey bee consignments and 26% for queens, This requires more inspections. One consignment was illegally imported from Sicily. DEFRA position if this is to occur again in future the consignment would be destroyed under the TARP regulations.

Date of next meeting


Annexe A

BFA Report Nov 2019 on EU Honey Market Situation

There are 17.5 million beehives in the EU producing more than 209,000 tonnes of honey in 2018. Europe is only 60 per cent self-sufficient in honey, and imports are needed to meet consumption demands.

But dig deeply into the figures and you will realise the EU market situation is “alarming”, says chairman of the EU Working Party on Honey Etienne Brunneau. He went on to say the situation is so worrying that if nothing is done “bee farming as we know it will die out. The market will be left to the amateurs,” he said.  

Spain and Romania have the highest shares of beehives, 17 per cent and 11 per cent respectively. Germany and Poland have the highest shares of beekeepers, 20 per cent and 11 per cent respectively.

Romania, Spain and Germany are the biggest honey producers.

Europeans are huge consumers of honey too.

In the UK alone, honey outsells jam with more than 50 per cent of households consuming nearly eight kilos a year.

At world level, the EU is the biggest importer of honey (42.1 per cent). That honey is mainly coming from China, which produced 543,000 tonnes in 2017.

The EU average unit value for imported honey has decreased since 2016 and - when excluding New Zealand - was at 1.92 €/kg in 2019.

Mr Brunneau says this is having a disastrous effect on locally produced honey.

He explained that many EU countries like Belgium import huge qualities, blend and package it and re-export it to other EU countries.

Many at the Honey Working Party meeting in Brussels on November 6 felt that the crisis could only by corrected by restructuring the bee industry. Others felt that better labelling about the source of honey was the answer.

In an attempt to protect local producers, Portugal, Spain and France have prepared new national legislation on labelling of origin of blended honey. They have notified the commission that they want to bring in these new labels as soon as possible. Now they have to wait for an answer from the commission before proceeding with adoption.

Mr Brunneau highlighted that the prices of honey have collapsed at world level (-7.6 per cent.). He said this a clear sign of the deterioration of the honey market situation. 

He used several graphs and charts to illustrate the poor returns for producers, with production costs outweighing margins in many countries.

Mr Brunneau focused on the main markets for intra-EU trade:  Bulgaria, Hungary, Romania, Spain and Germany. In Bulgaria, Hungary and Romania, there is a huge volatility of prices and exports. When the prices of honey go down, the exports increase and when the prices of honey go up, trade decreases. In Spain, there was the same tendency, butthe prices now are in a continuous descending trend - as low as 2 euros per kilo.  “However, when data from these countries are compiled together, the prices looked stable,” Mr Brunneau said. This was masking the problem.

When it comes to the average production costs of production compared to the price of multi-floral honey in bulk at wholesalers, 12 countries had a negative margin in 2018 and three had a margin closed to zero.

Lithuania has written a letter to the commission saying it has nearly 9,000 beekeepers producing some 4,000 tonnes and they fear their industry will go bankrupt because the price has fallen to 1.8 euros per kilo which is unsustainable.

Mr Brunneau said urgent measures are needed to remedy to this alarming market situation - such as origin labelling showing where all the honey has come from in a blend, traceability, a new coordinated control plan with member states targeting imports of consignments of more than 20 tonnes of honey from third countries.

He talked of the use of the “most effective detection techniques” such as NMR (nuclear magnetic resonance), setting up of a European reference laboratory, adoption of EU legal definition of beehive products, a multi-country promotion programme on European honey aimed at the internal market and the creation of the European honey market observatory.

The representative from the commission answered that the commission has proposed a 70 per cent increase in the Apiculture Programme to start in 2020.

But the problem lies in the fact that overall the EU is only 60 per cent self-sufficient in honey with Spain being 90 per cent self-sufficient but the UK only 14 per cent. Germany, France, Italy and the UK are all huge importers of honey together with USA and Japan.

We need to import honey to meet consumer demand. Indeed, in the UK we consume more than 30,000 tons. Honey now outsells jam as a preferred spread on toast.

The main supplier of imported honey into the EU generally is China - accounting for nearly 40 per cent of honey imports. 20 per cent comes from the Ukraine.

This means the EU honey trade balance is negative.

The EU figures, released on November 6, show the number of beehives throughout the Euro area has risen by 5.5 per cent to 17,577,000. The largest number of hives is still in Spain - up 3.2 per cent to 2,961,000, with Romania second but showing a huge 15.3 per cent increase to 1,849,000. Hungary is down a small number but Denmark is down a whopping 14.9 per cent from 141,000 to 120,000.

UK is also down 1.2 per cent from 247,000 in 2017 to 244,000 in 2018.

The total number of beekeepers across the whole of the EU is predicted to go up 7.6 per cent to 652,305 by 2022 with the UK showing an increase from 37,888 to 40,275. The biggest increase in the number of beekeepers is in Germany up 9.7 per cent from 116,000 in 2017 to a predicted 127,259 by 2022.

However, if you look at the evolution of the number of beekeepers since 2014 you will notice that the figures for the UK and Romania stand out because they go down in 2017. This would appear to be due to more robust counting systems being introduced.

The average number of hives per beekeeper in 2018 makes interesting reading.

Across the whole of the EU it is 21. This ranges from the UK with an average of six to 147 in Greece and 103 in Spain.

 When it comes to honey production the UK apparently had one of its best years in recent times with 6,600 tonnes. Romania tops the chart with 30,900 tonnes. Spain is not quoted in the chart but if you look back to 2017 you will see production is around 30,000 tonnes.

UK estimated average yield per honey has soared in UK from 10kg in 2017 to 34 in 2018. Finland tops this chart with 47kg per hive. Spain is down to just 10kg per hive. The average across the whole zone is 22 kg - a small increase on 2017.

The UK is second when it comes to share of imports from Third Countries - up from 31,757 tons in 2013 to 45,099 tons in 2018.

Now to costs - the EU average value for Chinese imported honey is down 11.5 per cent from 1.47 euros per kg to 1.30 euros per kg. New Zealand honey by contrast is still going up from 23.36 euros per kg to 23.54 euros per kg. But the biggest price increase is for imported honey from Serbia up 22.2 per cent from 3.06 euros per kg to 3.74 euros per kg.

UK home prices for multi-floral honey at site of production went down slightly in 2018 to 14.5 euro per kg. These compare favourably with the EU average of 6.46 euros per kg. The best price for honey is in Eire at 19.25 euros per kg and the worst price in Romania (who produced the most) at 2.25 euros per kg.

The UK tops the chart with its price for multi floral honey in bulk at wholesalers. The EU average is 3.79 euros per kg. In the UK we get 10 euro - very slightly down from 10.04 euros per kg in 2017.

The raw data for the charts and graphs used by Mr Brunneau can be found, with difficulty, at the Food, Farming and Fisheries section of the European Commission website.

EU Apiculture Programme from 2020

The Honey Working Party gave information about the next apiculture programme from 2020 to 2022. As mentioned above, there is a proposed increase of 70 per cent with budget approval so far of 40 million euros. All member states have proposed programmes in place and requests for money already exceed 50 million euros.

Measures under which requests can be made are:

  • technical assistance:  27 member states (MS) have put in claims under this measure
  • combatting beehive invaders:  28 MS
  • rationalisation of transhumance: 19 MS
  • analysis of apiculture products: 20 MS
  • restocking of hives: 22 MS
  • applied research: 18 MS
  • market monitoring: 14 MS
  • product improvement: 17 MS


Margaret Ginman

General Secretary

Bee Farmers Association

November 2019


Bees Health Improvement Partnership (BHIP)
c/o Scottish Government
Saughton House
EH11 3XD

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