Parliament Volume 3, Issue 3

Spring 2013

Lemasters Consulting Parliament

Parliament is a quarterly journal focusing on the deathcare profession.

Spring 2013

Spring 2013


Spring 2013


owners and employees alike focus on helping others and they let their day-to-day operations get away from them. Businesses must take care of those that work for them so that everyone feels like family and are treated fairly. With a good foundation and a happy family comes good service and business that comes to us.

This issue of Parliament looks at our own family dynamics and suggests some ways to handle situations that affect our business. Not only do we consider family members in the workplace, we also look at employees that we want to treat like family members. Also, I am sharing a case study that can show how families in business can be torn apart because of the business.

As always, I truly hope you enjoy Parliament, and welcome any comments, feedback, questions, or ideas for future issues.

Best Regards,

I continually think about what I can share and talk about when I sit down to write an issue of

Parliament. The last issue, for example, was about family—the families we serve every day in our profession. This issue is also about families—except it is about our own families and the ones we work with everyday. Too often, we work so hard helping others, that we don’t take the time to handle our own.

This month a very dear friend of mine—Jason Reed—passed away. He was only 39. In the wake of his death it made me stop and think about all the people he touched and how they will be affected by his untimely death. I recounted many memories and stories we shared over the years. It made me think about all he had done not only in his personal life, but also in his professional life as well. Again, he was not only family to his wife, parents, children, and siblings; he was also family to those he worked and dealt with everyday.

As a business, we have to take the time and not only serve the families that come to us in their time of need, we also need to take time and work with the families that work for and with us everyday. Too many times businesses,

Letter from the Publisher

•3

Spring 2013


Parliament is published quarterly.

Publisher: Poul LemastersArt Direction & Design: Doth Brands

Questions? [email protected] are free. Please visit lemastersconsulting.com to sign up.

© Copyright 2013 Lemasters Consulting and Poul Lemasters. All Rights Reserved.

About the Publisher

•4

ABOUT POUL LEMASTERS, ESQ.Poul Lemasters is the publisher of Parliament, a licensed attorney and a funeral director/embalmer. Poul is also an adjunct professor at the Cincinnati College of Mortuary Science. He is an active member of the International Cemetery Cremation Funeral Association where he advises on cremation concerns and FTC compliance to members. Poul is also active in various state funeral, crematory, and cemetery associations.

ABOUT LEMASTERS CONSULTINGLemasters Consulting is a company formed exclusively to serve the needs of the funeral profession, including funeral homes, funeral directors, cemeteries, cemeterians, crematories, and those working in the industry. Lemasters Consulting provides various services in: Government Compliance, Policy and Procedures, Risk Management, Litigation, Valuation, Market Analysis, Buy/Sell, Forms Management, and Next of Kin Disputes. www.lemastersconsulting.com

Contributing Author

Photo Page 17 by Will MerydithPhoto Page 18 by TinyFrogletPhoto Page 21 by Barbara EcksteinPhoto Page 22 by Tambako the JaguarPhoto Page 25 by Tambako the JaguarPhoto Page 26 by Dawn AshleyPhoto Page 29 by Joanna HansonPhoto Page 30 by Roland Tanglao

Volu

me

3, Is

sue

3

Photo Page 2 by John Van AttaPhoto Page 5 by RumpleteaserPhoto Page 6 by Atsuhiko TakagiPhoto Page 9 by Tambako the JaguarPhoto Page 10 by Dawn AshleyPhoto Page 13 by Barbara EcksteinPhoto Page 14 by hannahsmetana

ABOUT DONALD B. FERFOLIA, JR., J.D., CFSPDon is a fourth generation funeral director and an attorney involved with his family’s funeral firm in Cleveland, Ohio. The combination of law, funeral service, and family business experiences have provided Don with a unique skill set that enables him to assist clients in solving many different types of problems. He enjoys helping firms deal with the daily challenges of running a closely held business including regulatory compliance, proactively managing accounts receivable issues and succession planning. He can be contacted by telephone at 440-249-4655 or via email at [email protected].

Spring 2013


Spring 2013


Spring 2013


What a proud day. You’ve worked for years to build your business. Not only

has your business thrived and help you provide for your family—now your business can support your family by employing them. After all, your workplace is great. You have a great rapport with your employees—and they love you and your family. It’s a perfect plan; what could go wrong? Plenty! From hiring to firing there are a lot of pitfalls when it comes to hiring your own family in the workplace.

HIRINGIt all starts at day one. Employers are so nervous when it comes to hiring someone new. There’s the application, the interview, the reference checks, and the background checks. But then, when it’s family, it’s just, “Here you go, you start tomorrow.” With family, it’s critical to make sure you do everything just like they were another employee. Keep in mind, your family may turn against you and cause an issue, but think about how your other families may use it against you.

As an example, think about how and what amount you pay your family employee. Make sure that their wages match the level of experience, responsibility, and performance that the job demands. If your son is going to be a helper around the business and work random days/hours each week, then pay accordingly. Do not start paying him a $30,000 salary when the position does not demand it. If you do, you may be setting yourself up for a claim against another employee who says they deserve more.

Also, make sure that day one starts

off with very clear expectations and goals for their position with the firm. All too many times children of the owner do not know what is expected of them or do not know their role so it causes issues. Make it clear to the new employee and also to other employees. If it is not discussed it will be the 400 pound gorilla in the room—so just acknowledge it up front.

Lastly, consider some qualifications for family members to work in the family business. One common qualification when it comes to family businesses is making the incoming family members work outside the firm before working for the family. The job may be in the field or outside the field, the choice is yours, but it gives a level of credibility to their experience and value before starting a path with the family firm.

RESPONSIBILITIESAs mentioned briefly above, responsibilities of family employees are a critical issue. So many times family employees believe they are exempt from the day-to-day responsibilities that affect everyone in the workplace.

Consider the example of the wife of the owner who is the office assistant and comes to work everyday, but instead of the 8:30 AM start time—it’s a bit closer to 9:30 AM. On top of that, there are the extended lunches and the kids that are a priority over the business schedule. This may sound common and may not sound like a big deal—but it is a bad scenario in a workplace. Employees that are punished for late starts will have a claim and defense when there are others allowed to abuse or ignore the policy.

5 Issues When Your Family Members Work For You

•7

continued on page 8

Spring 2013


continued on page 11•8

Consider it another way. Now you have an employee that is abusing the same thing—late start, long lunch, not abiding by the schedule. You want to punish the employee but are limited because of your treatment of others. In fact, if you pursue the issue and possibly fire them for their actions they may have a claim of discrimination against you based on your nepotism. Holding all employees to their responsibilities is key to allowing you full authority to enforce your policies and procedures.

DECISIONSEveryone in the business has some level of decision-making authority. A common problem with families is when the limit and the ability to oversee the decisions is lost. Too many times family employees do not realize the authority—or the limit of their authority—when it comes to decisions. Abuse of the decision making process can range all the way from company paid lunches to buying a new vehicle, and lots in between.

Your niece has just started working in the business along with your daughter who has been there for a year. They are both young and new to the business, but both work hard in the eyes of their parents. As the weekend approaches your niece decides to change the schedule and before leaving lets everyone know that your daughter is on call this weekend now—not her. She leaves and when your daughter finds out she picks yet another person to be on call. Both your niece and your daughter have changed the schedule. Is this in either of their authorities and decision making abilities?

Continued...5 IssuesAgain clear roles and guidelines are critical in these situations. But, there must also be a framework for everyone to work within. For a family business it is important to go beyond the typical policies and procedures and have very detailed outlines of who can decide what, and how. One way to handle and avoid this is through an Advisory Board. An Advisory Board can be made up of family members, non-family members, friends, and independent advisors. The idea behind the Advisory Board is to help with certain decisions and to help guide the family with the business.

One struggle with a family business is growth. This growth includes changes to the business and changes to the structure. When the decision needs to be made on who gets a raise and for how much, it can become difficult when the brothers have to decide between each of their daughters. With the help of an Advisory Board the business can have them make those decisions, and keep the best interests of the business in the front and the emotional side of the family in the back.

COMPLAINTSAn employee steps into your office and says that your child has made unwanted advances on them and is sexually harassing them. You oversee both employees and now have to investigate the matter. This is a complex situation that puts you in a no-win situation.

Handling complaints when it comes to family employees is a tricky situation. Most businesses take a blind position on this and just hope it never happens.

Spring 2013


Spring 2013


Spring 2013


•11

Unfortunately when it does happen it will only be worse with no plan in place.

One tactic is to put a reporting policy and procedure in place when it comes to complaints about a family member. Many times, the family employee reports directly to another family member. Therefore, if there were a complaint against one family member, another family member would be in charge of settling the problem. Your policy and procedures manual should include a provision that would not allow this.

Instead, if an employee has a complaint against an employee, and that employee’s manger is a family member, then another supervisor must hear and settle the issue. It sounds simple, but few have the written policy and it can help avoid a lot of problems. Plus, it’s a little piece of mind for the employees to know that this isn’t all family against them and they have some protection.

FIRINGThere’s no easy way to handle this but if the time comes that this is a thought—then it probably means you should have already done it. Many family businesses have failed because the leaders failed to terminate family employees when they should have and instead let them become the new leaders and tear apart a good business.

Firing any employee starts the day you hire someone. This means that there are clear expectations about what their job is and needs to be in the future. All employees need to have objective yearly reviews where they are made

aware of their position as it stands and what the future holds for them. If your family employee is poor at management then they need to know it and understand that they may never run the business. Letting them just go and then one day saying that this isn’t working is bound to ruin a few lives. Communication is always key, and when it comes to family, it’s even more important. Make sure that other family members know how things are going so that there are never surprises.

When it is time to fire a family member, keep it as simple as possible. Again, this shouldn’t be a surprise. If it’s a surprise—then communication has failed and a better plan needs to be put in place. Anytime you fire an individual keep it simple and be direct. Do not apologize or try to make excuses. Also, a letter explaining the reasons is not always the best plan. A simple termination letter setting the date will suffice. Afterwards, depending on the relation, you may want to buy some flowers for Mom—after all, you just fired her son and you don’t want everyone hating you!

Seriously, family is wonderful and rewarding and if you have a business that can support you and your family—you should. After all, it’s a legacy and there is great joy in handing that legacy to the next generation. But be cautious and smart and make sure that as you go forward you lay a path that is clear and easy to follow so not only does your family enjoy the business—the business can enjoy them as well.

Continued...5 Issues

Spring 2013


•12

“It’s My Name, So I Will Use It Anyway I Want—Right?”A Case Analysis

continued on page 15

Think about this. Your name is perhaps the most identifying mark that people associate and

relate to you. Imagine if after years of working for the Smith Business, you—Tim Smith—decided to leave and were told you cannot use Smith as your business name. This may seem unbelievable, although the idea of families fighting over the use of their last name may be in and of itself unbelievable. Yet, the use of a surname is not an absolute guarantee and for business it can be a huge issue. This case involves a family dispute over the use of the family name Salerno. Rosario D. Salerno’s Sons Inc., dba Salerno Funeral Home v. Rosemary Salerno Butta aka Rosemary Salerno, 635 NE 2d 1339. The Plaintiffs, Salerno Funeral Home, sued Rosemary Salerno because she was advertising and promoting her own funeral home under “Rosemary Salerno—Funeral Director.” The Plaintiffs asked the Court to issue an injunction preventing Rosemary Salerno from advertising under her name. The trial court issued an injunction but allowed Ms. Salerno to advertise her funeral home under the name of “Butta-Salerno”, a former married name, so long as she included a disclaimer that she was not associated with Salerno’s Sons Funeral Home. Ms. Salerno appealed the decision and asked the Court to allow full use of her name because she had a right of use as to her own name.

The facts showed that Ms. Salerno began working at Salerno’s Sons Funeral Home in 1958 and became

a licensed funeral director in 1961. She worked full-time for the Funeral Home until 1972. During this time period, in 1968, Ms. Salerno married Andrew Butta and changed her name to Rosemary Salerno Butta. Then, in 1972, she divorced Mr. Butta and also stopped her full-time employment with Salerno’s Sons.

There are disputed facts over her involvement with Salerno’s Sons from 1972 until 1986. Ms. Salerno said she continued to work part-time, but both parties agree that in 1986 she did return to Salerno’s Sons full-time. She stayed there until 1992 when she left due to disputed reasons. It was at this time Ms. Salerno started her own funeral business. Shortly thereafter, in 1993, Salerno’s Sons filed for and were granted an injunction.

On appeal, Ms. Salerno made two arguments. The first argument was that the trial judge erred in issuing the injunction because there was no evidentiary hearing. Her second argument is that the injunction was too broad and that there was a “personal name rule” that gave her an absolute right to use her name in business.

As to the first argument, the Court set forth that in order to win a trademark infringement claim the party must show (1) the service mark is legally protected (2) someone is using a similar mark and (3) the use of the similar mark creates a “likelihood of confusion” by the public. In this case, the record showed that Salerno’s Sons

Spring 2013


Spring 2013


Spring 2013


Continued...It's My Name


•15

had registered the service mark to protect “Rosario D. Salerno Funeral Home,” “Salerno Funeral Home,” and “Salerno’s Galewood Chapel.” The Court found the name Salerno had legal protection. The Court also looked at the name being used by Ms. Salerno, and it was identical and therefore covered the similar mark requirement.

Lastly, the Court looked at the facts to see if there was a likelihood of confusion by the public. By Ms. Salerno’s own testimony she stated that she had received several phone calls at her phone number asking about services being held at the Salerno’s Sons Funeral Home. This alone supported the fact that the public was likely to be confused. Therefore, the Court did not hold an evidentiary hearing and on the facts found enough reason to issue the injunction. The Appeals Court agreed with this finding as well.

For the second argument, Ms. Salerno focused on her absolute right to use her name. She cited a ‘personal name rule’ that would allow this to be the case. However, the Appeals Court found no absolute right in the use of ones name. The Appeals Court cited various cases that used a balancing test to determine if a name could be used and to what extent. The Court stated “The ultimate aim is to frame an injunction that will avoid confusion in the marketplace, protect a prior company’s property interest in its name, and permit an individual to exploit his own identity and reputation in a legitimate manner.”

The Appeals Court looked at previous

cases where the person was sometimes allowed to use their own name—with restrictions—and other cases where the person was enjoined from using their name at all. The Court, in considering whether to allow or not, looked at the contribution of the person in developing the overall goodwill in the name to be used and also looking at whether the person seeking to use the name has developed their own goodwill as well.

In this case, Ms. Salerno did work for Salerno’s Sons for many years, but it is unclear from the record if she helped create the goodwill. Furthermore, there was a period of time in dispute as to whether she worked for the business at all. Lastly, there is no showing in the evidence as to her own goodwill in the business other than her license and involvement in the profession. The Court went on to state that depending on the outcome of these questions, Ms. Salerno may be allowed to use her name; may be allowed to use her name with certain limitations, such as a disclaimer; or she may not be allowed to use her name at all. The Court reversed the decision of the trial court and remanded it to determine these facts before setting the scope on the injunction.

As you read these facts you may think this would never happen to you or may simply be surprised on how drastic the outcome could be. Everyone thinks that families will ultimately prevail and solve their own problems, but many times family disputes are the toughest ones.

Spring 2013


When families work together, there will be issues. When times are good, take the time to discuss what can go wrong and have a plan to resolve it before it ever happens. Think of it this way: if you can’t agree on how to solve something when you are all friends—how do you solve a problem when you are all enemies? Make sure your own family has a plan that covers your business.

Continued...It's My Name

•16

Spring 2013


Spring 2013


Spring 2013


EMPLOYEE CONTRACTEmployee contracts are definitely two-sided. For every benefit to the employee there is a trade-off for the employer, and, likewise, for every benefit for the employer there is a trade-off for the employee. But, if an employee is worried about their position or longevity or an employer is worried about the employees’ seriousness or commitment, then an employee contract can be a perfect tool.

Understand that an employee contract changes the at-will hire/fire agreement. Under a true employee contract the employee is guaranteed a certain term of employment under a set of circumstances. Employee contracts can be written more generally to preserve the right to at-will employment, but the wording needs to be constructed carefully and the parties need to understand fully.

If you do chose to write an employee contract, keep it specific to the employee at hand and make sure that it sets forth: a description of the job/duties, the salary, a length of time in the contract, limits on competition during and after employment, specific grounds for termination, and a dispute resolution plan.

Employee contracts are not always the answer, but they are an option. More and more employers are using employee contracts not only as a method of inducing employees to a set term of employment, but also as a method of control. Employment contracts also help when it comes to

Family is great—but sometimes there are people in our lives (and businesses) that aren’t family—

but we wish they were. Wouldn’t it be great if our best employees were also our family so your business could be kept close? We may not be able control who our family is, but we can control how we treat our employees. Sometimes treating our best employees like they were family can go further than anything else we do.

Why do it? If you want someone to stay with your business and treat your business like it was theirs, then they need to believe the business is theirs. In today’s culture, employee retention and longevity result from employees wanting to stay; not because they believe they owe it to their employer. It used to be common for employees to stay at a job for years simply because they felt a duty of loyalty. Now, employees are not only looking, they are being sought after from other employers and asked to leave because it is better somewhere else. Key employees need to have some type of ownership so they just don’t feel like they are an owner, but rather they can see that they are an owner.

Of course, any employer may have reservations about giving any employee too much. Keep in mind that you don’t have to sell your business to make someone appreciate his or her benefits. Furthermore, benefits of ownership, or quasi-ownership, don’t always equate to money. There are plenty of ways to give without costing the employer and without limiting the employer from future changes.

3 Things To Do When You WISH Your Employees Were Your Family


Spring 2013


covenants not to compete and are useful when you are hiring someone in a position of trust or at a level where they could use your information against you at a later date.

PURCHASE PLANIt’s the ultimate story from a new business owner. The new owner shares their experience of how they were told if they work hard—then one day this could all be theirs. Years later, after thousands of hours and sweat equity—the previous owner gave them the keys to the business. It sounds wonderful, and it does happen. However the story many times starts the same, but the ending is much different.

Many employees are told that one day this can be theirs. If it’s truly a plan or an option, and as the owner you want it to happen, then put a plan in place. There are many options to help an employee become the new owner, but it typically takes time. Overall, if you have the person you want to own it, make them know it and help them so they stay in it for the long haul.

This article cannot address all the methods or structures for setting up a purchase plan, but know that there are many and each have pros and cons. There are plans, such as employee stock ownership plans (ESOP) for large businesses, and employee owned cooperatives for smaller businesses. There are also phantom stock options, performance bonuses, non-qualified deferred compensation plans, and sweat equity buy-outs—just to name a few.

The main thought here is to understand that if an employee buyout

is a thought, then put some teeth to it. An employee that understands not only will have the option to buy the business BUT also see a written plan on how it will happen. This will lead to longevity and (hopefully) a motivated employee. If anything, put a plan in writing so that the employee can see that the dream is real.

BENEFITSThere is a saying that the only thing better than owning your own business is being treated like you own a business. Everyone looks at the owner as having an unlimited expense account, a great car, and benefits that include a daily lunch at the country club. While owners understand that this may not actually be the case, there are definitely some perks to being the owner.

Based on that, why not share in some of the perks so that your key employee(s) get a sense of the ownership world. In the short-term, this may cost a little to the business but it can have long-term implications that may never be reached by a competitor thus guaranteeing retention and happy employees. Also, many benefits are less costly than raises but project a higher return.

So what do you offer? Of course a company car is always high on the list. Many times a business can use a second car for running errands, and what better benefit to an employee. However, if the car seems a bit much then think ‘car care’ instead. By offering things like gas, oil changes, and even car washes, an employee can still have a great car benefit without the actual company car.

Continued...3 Things


Spring 2013


Spring 2013


Spring 2013


Continued...3 ThingsAnother benefit appreciated at higher levels is an expense account. Obviously with some limits, but if it’s used properly and allowed to be used somewhat freely it can give the employee a sense of true ownership. Consider a monthly amount, or budget, and then don’t micro-manage. I have been out with employees that are with a crowd and unable to ‘buy’ the dinner for everyone even though it would be a good thing. Allowing them the freedom to do such things gives a sense of empowerment that money really doesn’t buy.

As a last thought, consider the little things that can add up to a lot for anyone. Things like cell service, laundry/dry cleaning service, continuing education/travel, or free lunch. Little benefits can lead to big returns. And all benefits do not have

•23

to be for everyone so long as your basis is non-discriminatory. Your key employees, who should be managers or some higher level, can receive certain perks that others do not receive. Not only does it reward those at this level, it can also provide an incentive to others to reach this level.

Overall—key employees are worth their weight in gold (or at today’s market price, at least silver). When you have a key employee that you want to stay they need to believe they have ownership. Ownership is one of the keys to retaining employees and having a smooth transition. Once an employee believes they have ownership, then they will commit to the business. It is hard to ask for an employee to commit when the employer doesn’t make a commitment on their part.

Spring 2013


late 1996 and early 1997, Secretary of Defense William Cohen testified that before he agreed to deploy troops in to a combat situation he would ask if there was a “So-called exit strategy.” He stated that “We know how to get in. How do we get out?” This same thought process can be applied to businesses as an owner plans for the future. When an owner takes over a firm or an entrepreneur founds a funeral home with the hope of providing help to families for generations, that same owner never gives much thought on how he or she can exit and allow the business to thrive and survive. It is vitally important to develop some sort of “exit strategy” because funeral directors know too well that life can take unexpected turns. Having a plan in place allows a funeral home owner to be confident that should he or she not be there, the firm can continue its service to the community.

As an owner, if you don’t think about anything regarding succession planning, please consider the following:

DETERMINE HOW YOUR BUSINESS IS HANDED DOWN TO THE NEXT GENERATIONThis sounds like a common sense statement, but the failure to complete a succession plan takes the decision making out of the previous owner’s hands. The decisions on how a business is transferred is left to outside forces such as federal tax law or state probate laws.

When one surveys advertising from family-owned funeral homes in almost any local

market in the United States, what is one common theme that is revealed? Multi-generational family ownership.

How many have seen taglines like “Our Family Serving Your Family for 4 Generations—Over 80 Years” or “For 3 generations our funeral home has been committed to helping families through difficult times”?

For those who own these family owned and operated businesses the question for the owner becomes, “How do I pass the business down to the younger generation?”

In times that have long since passed, the traditional model in funeral service was that one generation built the business and when the that generation “retired” the business was passed down to the oldest in the next generation. Most know that the real definition of “retire” was that the older generation never retired, but stopped working only when illness or death prevented them from serving families in the community they loved. Not only is this model of business succession not viable in today’s business environment, but it can cause major divisions in a family and in some instances can cause a family to lose a business because of arcane state laws or tax issues. How does one prevent this from happening?

During his confirmation hearing in

“Will 3 Generations Become 4?” Some Thoughts on Succession Planning


•24

By Donald B. Ferfolia

Spring 2013


Spring 2013


Spring 2013


•27

START EARLY It is never too early to start planning. Planning early not only can assist an owner, but can also help the succeeding generation. For example, a father wants to retire and sell the business to his daughter. The “problem” is that the business is valued at $10,000,000.00 (What a good problem to have!) Most likely, the daughter cannot write a check to her Dad for the value of the business. This can be averted by having some sort of buy-sell agreement in place that will allow the daughter to purchase the business over time. This accomplishes two goals—allowing the daughter to buy a successful business in manageable chunks and providing the father with consistent cash flow for a period of time.

PUT THE PLAN IN WRITINGA written plan serves at least two purposes. First and most importantly, a written plan is the only plan that truly documents an owner’s intent. The plan may take the form of a buy-sell agreement, it may be part of a will, or it may be part of a trust that was established to help move the business to succeeding generations. From a family relationship standpoint, a written plan brings objectivity into the process. If there is a dispute between family members, a written plan can take the emotion out of the dispute. A well-constructed plan can anticipate many disputes and it is the plan making the decision not the disputing family members.

REMEMBER, YOUR BUSINESS COMPRISES ONLY PART OF YOUR ESTATEBusiness owners are also husbands,

wives, mothers, and fathers. Most family members want to treat younger generations equally and that is an admirable goal. But treating family members equally does not mean splitting each asset in an estate equally. It is OK to transfer the business only to those who work in it. There are other assets that can be conveyed to other family members.

SEEK ADVICEIt is usually the funeral director who gives advice. The funeral director is not the one who seeks it out. By seeking advice from a trusted advisor (an attorney or accountant for example), the owner can potentially avoid pitfalls or traps that may cause problems for the next generation.

With some forethought, discussion and planning, the objective of keeping a family-owned funeral home in a family for many generations is a very reachable one. Although beginning the discussion is never easy because as people we don’t want to talk about an “exit strategy,” the result can be a smooth transition from generation to generation and the successful continuation of quality service to families in their time of need.

Continued...Succession Planning

Spring 2013


Spring 2013


•

In Memoriam

—Jason G. Reed—November 5, 1973–March 2, 2013

‡

Spring 2013


Spring 2013

Parliament Volume 3, Issue 3

Documents