Lloyds Banking Group Submission
National Assembly for Wales Legislation Committee No. 5
Proposed Legislative Competence (Welsh Language) Order 2009
Introduction
1.1 The Lloyds Banking Group welcomes the opportunity to submit evidence to the Welsh Assembly Legislation Committee No. 5 on the proposed Legislative Competence (Welsh Language) Order 2009.
1.2 The Lloyds Banking Group is one of the UK’s largest providers of financial services with branches of Lloyds TSB and Halifax across Wales.
Executive Summary
2.1 We welcome proposals to confer power on the National Assembly for Wales to legislate on the promotion and use of the Welsh language, but do not support a legal obligation requiring certain private companies to provide information bilingually.
2.2 Our experience based on the feedback we have received from customers does not suggest that there is significant consumer demand for the provision of bilingual information. We estimate that the costs of implementing these proposals would be substantial and would, therefore, be disproportionate to the consumer benefit.
Current arrangements for the provision of bilingual information
3. 1Lloyds Banking Group has worked closely with the Welsh Language Board.
3.2 We currently provide the following services in Welsh:
A Welsh language call centre (hours of availability 9.00 -17.30 Monday - Friday).
External and internal branch signage.
Choice of Welsh/English on ATMs (cash machines).
Welsh speaking branch staff identified by their name badges.
Cheque and paying in books.
Selected marketing material including customer leaflets and posters.
3.3 We are pleased to provide bilingual services to our customers in Wales, however, the usage of these services is low. The Committee may be interested to know that as far as our Welsh speaking contact centre is concerned, during January and February this year, the contact centre received an average of less than 200 calls each month. This is a tiny fraction (less than 0.01 per cent) of all calls made to our contact centres.
3.4 By comparison, our Polish speaking contact centre receives, on average, 15,000 calls per month.
The draft proposals
4.1 We are concerned that the ambiguity in the current drafting of clause 3 (e) ("persons providing services to the public who receive public money amounting to £200,000 or more in a financial year”) may bring certain banks, but not others into scope of the Order. The same may apply to other sectors and this risks putting some private companies at a competitive disadvantage to others.
4.2 We also consider that the Order, as currently drafted, could apply to any Welsh business borrowing more than £200,000 under, for instance, Government support schemes. Again, this may disadvantage these companies competitively through significant compliance costs. Similarly, any business or organisation (such as a charity) that has received Government or Welsh Assembly grants may also be covered.
Conclusion
5.1 We do not believe that there is sufficient consumer demand to support the case for a legal requirement on private companies to provide information bilingually in Wales.
5.2 The services that the Lloyds Banking Group currently provides to its customers in Wales on a voluntary basis exceed the demand from its customers.
5.3 We would encourage the Committee to re-draft clause 3 (e) to remove the current ambiguity and to ensure that private organisations, including those in receipt of 'public money’, are out of scope of the legislation.
15 May, 2009
