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2025-08-31-accounts

REGISTERED CHARITY NUMBER: 283337

Report of the Trustees and

Unaudited Financial Statements for the Year Ended 31 August 2025

for

The Charles Wallace Pakistan Trust

Thornton Springer LLP Chartered Accountants 67 Westow Street London SE19 3RW

The Charles Wallace Pakistan Trust

Contents of the Financial Statements for the Year Ended 31 August 2025

Page
Report of the Trustees 1 to 5
Independent Examiner's Report 6
Statement of Financial Activities 7
Balance Sheet 8
Notes to the Financial Statements 9 to 13
Detailed Statement of Financial Activities 14

The Charles Wallace Pakistan Trust

Report of the Trustees

for the Year Ended 31 August 2025

The trustees present their report with the financial statements of the charity for the year ended 31 August 2025. The trustees have adopted the provisions of Accounting and Reporting by Charities: Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) (effective 1 January 2019).

OBJECTIVES AND ACTIVITIES

Objectives and activities

Under the Declaration of Trust, the Trustees are empowered to use all or any of the capital or income of the fund for the provision of financial assistance for either:

a. Men and women of Pakistani nationality who are domiciled and normally resident in Pakistan to enable them to travel to the United Kingdom to follow a course of study, research or other educational pursuit, or

b. Any charitable educational institution in the United Kingdom serving persons of Pakistani nationality domiciled and normally resident in Pakistan.

In the event of the Trust failing, the Trustees are empowered to use funds for charitable purposes generally.

Public benefit

The Trusties have complied with their duty to have regard to the Charity commission's published guidance on the public benefit requirements. The public benefit of the charity's activities are outlined under objectives and activities above.

Page 1

The Charles Wallace Pakistan Trust

Report of the Trustees

for the Year Ended 31 August 2025

ACHIEVEMENTS AND PERFORMANCE Charitable activities Grant funded activity in 2024-25

Individual beneficiaries and sums expended are all listed on page 15 of this report.

Open Visiting Fellowships

In July 2024, the Secretary and the Chair visited Pakistan and took part in four rounds of interviews in Islamabad and Lahore, during which 15 candidates were awarded fellowships. All 15 of them took up their awards during 24-25 The maximum period of these awards is two months in the UK. To stretch the budget, in an appropriate way, conversations are had with all candidates about the time they need in the UK to gain optimal benefit from this professional opportunity. In the end none of the beneficiaries was granted more than a six week stay. The grant holders were welcomed by a wide selection of UK institutions. Interesting to see Cardiff features three times on the list. Perhaps this reflects the long term Welsh strategy to build multi-sectoral relations with Pakistan.

In June 2025 four rounds of interviews took place, this time on-line, to select the Open Fellows who will travel to the UK in 25-26. The process was smooth, despite dependence on technology. Again 15 were selected, and again there is a good spread of UK receiving institutions.

Reserved Visiting Fellowships

During the year two Reserved Fellows took up their places in the UK with the agreed partner institutions for this year. In 25-26 two other institutions will be the hosting partners.

The award holder at Nottingham University, Dr Asma Faiz, researched nationalism and populism among the British Pakistani diaspora.

At Edinburgh University, the Institute of Advanced Studies of the Humanities in partnership with the Centre for South Asian Studies, the award holder, Dr Suneela Ahmad, developed a postdoc research funding proposal. She seeks to extend understanding of indigenous communities through the idea of water based belonging, specifically looking at two communities in Sindh.

Doctoral Bursaries

Four Doctoral students from Pakistan were awarded grants of £1,000 towards the end of their studies. The trust continues to believe that these grants, modest though they are, have a positive impact on the capacity of the beneficiaries to bring their doctoral studies to a successful conclusion.

Responding to pressures on the annual budget trustees agreed to half the total budget for doctoral bursaries, to £5k annually, from 25-26. Applications will be considered just once in the year, at the May board meeting.

Visiting Artists

Gasworks Arts Centre :

Saadia Batool, was selected and funded toward the end of 23-24, and was still on her residency in London into the start of this reporting year. Saadia developed a series of paintings that further explored the history, archives and collective memories of the Hazara community. She engaged with migrant Hazara families in the UK and engaged with a wide range of international artists.

Faheem Abbas was welcomed by Gasworks in July 2025. Through his work, which includes sculpture, painting, drawing and writing, he explores historical and imagined symbols and how different meanings can be reached depending on time, place and power structures. He particularly enjoyed access to the many museums of London to enrich his creativity.

The Rangoonwala Foundation continues to cover half of the cost of the three-month residency. And Gasworks, continues to provide challenge and support to all of its international artists.

Page 2

The Charles Wallace Pakistan Trust

Report of the Trustees

for the Year Ended 31 August 2025

King's Foundation School of Traditional Arts :

Abu Hanzla, was selected to attend the King's Foundation School in September 2024 and remained for the 3 month semester. He found the time professionally enriching but a little tough socially, as his chosen accommodation was outside London.

In September Mahnoor Tiwana took up her place at the School where she is well settled. Two female candidates were considered, each had a strong style and some entrepreneurial flair. Mahnoor's work shows a deep interest in a broad range of traditional arts and the adaptation of technique to modern expression.

Theatre Residency

With the strong support of one of the Trustees, a new initiative in the arts was put in place this year. The first theatre residency was launched. The Arts Council of Pakistan, in Karachi, was the Pakistani partner and two UK partners helped to build the programme in the UK: The People's Palace Projects, Queen Mary's University of London and Battersea Arts Centre.

The first beneficiary, Syed Qasim Shah, came with experience in both directing and acting in Pakistan. He lived in Battersea Arts centre and experienced a wide ranging programme in London covering many aspects of theatre in the commercial and subsidised sectors including, production, direction, writing and performance. During his time in the UK he was also able to work on a new piece of writing which he hoped to have the opportunity to direct on his return to Pakistan.

British Museum:

The credit balance on the Charles Wallace account with the British Museum (£3,190) was carried over to 2024-25 since the museum did not select a Pakistani curator in the summer of 2024. The museum is actively seeking a suitable curator to attend the British Museum's International Training Programme in 2026.

EXTERNAL FACTORS

There has been a significant reduction in bilateral aid to Pakistan from several sources, most significantly from the UK and the USA. UK aid to Pakistan has dropped by c. 35% in the last 5 years. This inevitably means that the small levels of support available for professional development, from Trusts and Foundations such as Charles Wallace, are of even more value.

Partnership with the British Council Pakistan

The current three year agreement with the British Council will expire at the end of March 2026. The Council's staff team manage the recruitment of the Open Fellows, as well as the pre-departure arrangements for most of the Trust's visitors to the UK. They carry out this work with great commitment and efficiency. This was particularly evident when they successfully arranged all the interviews for the Open Fellows digitally. Further they provide thoughtful guidance and reliable help in the visa application process. This is commented upon by beneficiaries.

The British Council's current country director, James Hampson, speaks well of the Trust's work. The Secretary will make a visit to Pakistan in February 2026. At that time a new three year agreement will be under discussion.

In the past year the Trust contributed a total of £4,700 toward the Council's annual overheads including a component to cover its staff costs during the annual fellowship recruitment round. It may be a challenge to keep this charge at this modest level in the forthcoming negotiations.

Page 3

The Charles Wallace Pakistan Trust

Report of the Trustees

for the Year Ended 31 August 2025

FINANCIAL REVIEW

Financial position

This was the forty-third year of operation of the Trust, and as at 31 August, 2025, the financial summary of the year was as follows:

2024-25 2023-24 2022-23
Value of investments 1,924,626 1,844,829 1749,666
Total income 51,980 51,122 45,579
Portfolio management 11,279 11,001 10,646
British Council Levy 4,700 4,700 4,700
Admin expenses 5,559 7,031 6,872
Admin as % of activity 7.92% 8.40% 6.20%
Invest. fees as % of income: 21.90% 21.52% 23.44%

The accounts for 2024-25 accompany this report.

SUMMARY

Overall 2024-2025 has been a good year for the Charles Wallace Trust. The scale of activity is necessarily constrained by the overall size of the investments. Small amounts go a long way to support the development of purposeful, professional opportunities for mid-career Pakistanis; and their visits to the UK, be it to universities, research institutes or arts organisations certainly enrich those bodies.

INVESTMENT PERFORMANCE

The portfolio delivered a reasonable +8.3% to the end of September 2025 against a peer group return of 7.8% and return objective (CPI+3%) of 6.9%. Equity markets have staged a strong recovery post April's sell-off following President Trump's Liberation Day announcement. The US has recovered well following fears of tariff-induced inflation and slower economic growth. The technology sector has recovered extremely strongly with AI related stocks posting significant stock price returns. While we recognise and are exposed to a number of the key technology names (Alphabet, Nvidia, Microsoft) we are cognisant of the cyclical nature of recent financing deals bordering on the classic vendor-financing which plagued companies pre-dot com bubble. It is our belief that we are more likely at the beginning of a technology super cycle than the end, however it is unlikely to be one-way traffic and markets may well benefit from a short pause for breath in the form of a pull-back or even correction which we would view as heathy. Fixed income has had a relatively unremarkable year with low single digit returns whereas diversifying assets such as gold, in which we have a good position, was up an astonishing +40%. We are looking to take profits at these levels.

STRUCTURE, GOVERNANCE AND MANAGEMENT Governing document

The charity is controlled by its governing document, a deed of trust and constitutes an unincorporated charity.

The Charles Wallace Pakistan Trust was set up by means of a Declaration of Trust dated 24 June, 1981, amended by a Deed of Variation dated 28 February, 2002, and by a further Deed of Variation dated 12 June, 2017, and is registered with the Charity Commissioners as Charity Number 283337.

Organisational structure

The operations of the Trust are governed by a Board of Trustees, consisting of a Chair, up to six Trustees, and a Secretary. In 2016-17, the British Council resigned as a Corporate Trustee, and revised Trust Deeds were approved to accommodate this change. The Chair, the Secretary, and new Trustees are appointed by the Trustees. Although designated a Corporate Trustee, in recent years the Pakistan High Commission has chosen not to be represented on the Board.

REFERENCE AND ADMINISTRATIVE DETAILS Registered Charity number

283337

Page 4

The Charles Wallace Pakistan Trust

Report of the Trustees

for the Year Ended 31 August 2025

Principal address

The Old Manor House Cholesbury Lane Cholesbury Buckinghamshire HP23 6ND

Trustees

Mr Peter Elborn OBE Professor Sarah Ansari Dr Nada Raza Dr Shehla Zaidi Professor Adnan Qadir Khan Ms Ann Rosemary Arnott OBE Professor Faisal Devji Mr Tim Butchard

Secretary

Rebecca H E Walton CMG

Website www.wallace-trusts.org.uk

Independent Examiner

Thornton Springer LLP Chartered Accountants 67 Westow Street London SE19 3RW

Bankers

CAF BANK LTD 25, King's Hill Avenue King's Hill West Malling Kent ME19 4JQ

Investments

Rathbones Incorporating Investec Wealth & Investment 30 Gresham Street London EC2V 7QN

Approved by order of the board of trustees on ............................................. and signed on its behalf by:

........................................................................ Mr Peter Elborn OBE - Trustee

Page 5

Independent Examiner's Report to the Trustees of The Charles Wallace Pakistan Trust

Independent examiner's report to the trustees of The Charles Wallace Pakistan Trust

I report to the charity trustees on my examination of the accounts of The Charles Wallace Pakistan Trust (the Trust) for the year ended 31 August 2025.

Responsibilities and basis of report

As the charity trustees of the Trust you are responsible for the preparation of the accounts in accordance with the requirements of the Charities Act 2011 ('the Act').

I report in respect of my examination of the Trust's accounts carried out under Section 145 of the Act and in carrying out my examination I have followed all applicable Directions given by the Charity Commission under Section 145(5)(b) of the Act.

Independent examiner's statement

I have completed my examination. I confirm that no material matters have come to my attention in connection with the examination giving me cause to believe that in any material respect:

  1. accounting records were not kept in respect of the Trust as required by Section 130 of the Act; or

  2. the accounts do not accord with those records; or

  3. the accounts do not comply with the applicable requirements concerning the form and content of accounts set out in the Charities (Accounts and Reports) Regulations 2008 other than any requirement that the accounts give a true and fair view which is not a matter considered as part of an independent examination.

I have no concerns and have come across no other matters in connection with the examination to which attention should be drawn in this report in order to enable a proper understanding of the accounts to be reached.

S B Ison FCCA

Thornton Springer LLP Chartered Accountants 67 Westow Street London SE19 3RW

Date: .............................................

Page 6

The Charles Wallace Pakistan Trust

Statement of Financial Activities for the Year Ended 31 August 2025

Notes
INCOME AND ENDOWMENTS FROM
Investment income
2
EXPENDITURE ON
Raising funds
3
Charitable activities
Doctoral bursaries
Reserved visiting fellowships
Open visiting fellowships
Visiting artists
Other
Total
Net gains on investments
NET INCOME
RECONCILIATION OF FUNDS
Total funds brought forward
TOTAL FUNDS CARRIED FORWARD
31.8.25
Unrestricted
funds
£
51,980
11,279
4,000
8,936
41,004
16,276
10,379
91,874
96,040
56,146
1,900,667
1,956,813
31.8.24
Total
funds
£
51,123
11,001
11,999
12,077
47,563
12,044
11,732
106,416
172,619
117,326
1,783,341
1,900,667

The notes form part of these financial statements

Page 7

The Charles Wallace Pakistan Trust

Balance Sheet

31 August 2025

Notes
FIXED ASSETS
Investments
6
CURRENT ASSETS
Debtors
7
Cash at bank
8
CREDITORS
Amounts falling due within one year
9
NET CURRENT ASSETS
TOTAL ASSETS LESS CURRENT
LIABILITIES
NET ASSETS
FUNDS
10
Unrestricted funds
TOTAL FUNDS
31.8.25
Unrestricted
funds
£
1,924,626
3,190
44,169
47,359
(15,172)
32,187
1,956,813
1,956,813
1,956,813
1,956,813
31.8.24
Total
funds
£
1,844,829
3,190
54,088
57,278
(1,440)
55,838
1,900,667
1,900,667
1,900,667
1,900,667

The financial statements were approved by the Board of Trustees and authorised for issue on ............................................. and were signed on its behalf by:

............................................. Mr Peter Elborn OBE - Trustee

The notes form part of these financial statements

Page 8

The Charles Wallace Pakistan Trust

for the Year Ended 31 August 2025

Notes to the Financial Statements

1. ACCOUNTING POLICIES

Basis of preparing the financial statements

The financial statements of the charity, which is a public benefit entity under FRS 102, have been prepared in accordance with the Charities SORP (FRS 102) 'Accounting and Reporting by Charities: Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) (effective 1 January 2019)', Financial Reporting Standard 102 'The Financial Reporting Standard applicable in the UK and Republic of Ireland' and the Charities Act 2011. The financial statements have been prepared under the historical cost convention, with the exception of investments which are included at market value, as modified by the revaluation of certain assets.

Income

All income is recognised in the Statement of Financial Activities once the charity has entitlement to the funds, it is probable that the income will be received and the amount can be measured reliably.

Expenditure

Liabilities are recognised as expenditure as soon as there is a legal or constructive obligation committing the charity to that expenditure, it is probable that a transfer of economic benefits will be required in settlement and the amount of the obligation can be measured reliably. Expenditure is accounted for on an accruals basis and has been classified under headings that aggregate all cost related to the category. Where costs cannot be directly attributed to particular headings they have been allocated to activities on a basis consistent with the use of resources.

Grants offered subject to conditions which have not been met at the year end date are noted as a commitment but not accrued as expenditure.

Taxation

The charity is exempt from tax on its charitable activities.

Fund accounting

Unrestricted funds can be used in accordance with the charitable objectives at the discretion of the trustees.

Restricted funds can only be used for particular restricted purposes within the objects of the charity. Restrictions arise when specified by the donor or when funds are raised for particular restricted purposes.

Further explanation of the nature and purpose of each fund is included in the notes to the financial statements.

2. INVESTMENT INCOME

INVESTMENT INCOME
31.8.25 31.8.24
£ £
Deposit account interest 39 52
Interest 443 494
Curr asset inv income 51,498 50,577
51,980 51,123

continued...

Page 9

The Charles Wallace Pakistan Trust

Notes to the Financial Statements - continued

for the Year Ended 31 August 2025

3. RAISING FUNDS

Investment management costs

Investment management costs
31.8.25 31.8.24
£ £
Portfolio management 11,279 11,001

4. TRUSTEES' REMUNERATION AND BENEFITS

There were no trustees' remuneration or other benefits for the year ended 31 August 2025 nor for the year ended 31 August 2024.

Trustees' expenses

There were no trustees' expenses paid for the year ended 31 August 2025 nor for the year ended 31 August 2024.

5. COMPARATIVES FOR THE STATEMENT OF FINANCIAL ACTIVITIES

INCOME AND ENDOWMENTS FROM
Investment income
EXPENDITURE ON
Raising funds
Charitable activities
Doctoral bursaries
Reserved visiting fellowships
Open visiting fellowships
Visiting artists
Other
Total
Net gains on investments
NET INCOME
RECONCILIATION OF FUNDS
Total funds brought forward
TOTAL FUNDS CARRIED FORWARD
Unrestricted
funds
£
51,123
11,001
11,999
12,077
47,563
12,044
11,732
106,416
172,619
117,326
1,783,341
1,900,667

continued...

Page 10

The Charles Wallace Pakistan Trust

Notes to the Financial Statements - continued for the Year Ended 31 August 2025

6. FIXED ASSET INVESTMENTS

MARKET VALUE
At 1 September 2024
Additions
Disposals
Revaluations
At 31 August 2025
NET BOOK VALUE
At 31 August 2025
At 31 August 2024
There were no investment assets outside the UK.
Cost or valuation at 31 August 2025 is represented by:
Valuation in 2025
Cost
7.
DEBTORS: AMOUNTS FALLING DUE AFTER MORE THAN ONE YEAR
Other debtors
8.
CASH AT BANK
Bank account
Cash at brokers
Total
31.8.25
£
3,190
31.8.25
Total
funds
£
38,589
5,580
44,169
Listed
investments
£
1,844,829
134,701
(164,359)
109,455
1,924,626
1,924,626
1,844,829
Listed
investments
£
350,401
1,574,225
1,924,626
31.8.24
£
3,190
31.8.24
Total
funds
£
413
53,675
54,088

continued...

Page 11

The Charles Wallace Pakistan Trust

Notes to the Financial Statements - continued for the Year Ended 31 August 2025

9. CREDITORS: AMOUNTS FALLING DUE WITHIN ONE YEAR

Other creditors
10.
MOVEMENT IN FUNDS
Unrestricted funds
General fund
Capital
TOTAL FUNDS
Net movement in funds, included in the above are as follows:
Incoming
resources
£
Unrestricted funds
General fund
51,980
TOTAL FUNDS
51,980
Comparatives for movement in funds
Unrestricted funds
General fund
Capital
TOTAL FUNDS
At 1.9.24
£
8,980
1,891,687
1,900,667
1,900,667
Resources
expended
£
(91,874)
(91,874)
At 1.9.23
£
(108,346)
1,891,687
1,783,341
1,783,341
31.8.25
£
15,172
Net
movement
in funds
£
56,146
-
56,146
56,146
Gains and
losses
£
96,040
96,040
Net
movement
in funds
£
117,326
-
117,326
117,326
31.8.24
£
1,440
At
31.8.25
£
65,126
1,891,687
1,956,813
1,956,813
Movement
in funds
£
56,146
56,146
At
31.8.24
£
8,980
1,891,687
1,900,667
1,900,667

continued...

Page 12

The Charles Wallace Pakistan Trust

Notes to the Financial Statements - continued for the Year Ended 31 August 2025

10. MOVEMENT IN FUNDS - continued

Comparative net movement in funds, included in the above are as follows:

Unrestricted funds
General fund
TOTAL FUNDS
Incoming
resources
£
51,123
51,123
Resources
expended
£
(106,416)
(106,416)
Gains and
Movement
losses
in funds
£
£
172,619
117,326
172,619
117,326

A current year 12 months and prior year 12 months combined position is as follows:

Unrestricted funds
General fund
Capital
TOTAL FUNDS
At 1.9.23
£
(108,346)
1,891,687
1,783,341
1,783,341
Net
movement
in funds
£
173,472
-
173,472
173,472
At
31.8.25
£
65,126
1,891,687
1,956,813
1,956,813

A current year 12 months and prior year 12 months combined net movement in funds, included in the above are as follows:

Unrestricted funds Incoming
Resources
Gains and
resources
expended
losses
£
£
£
Movement
in funds
£
General fund 103,103
(198,290)
268,659
173,472
TOTAL FUNDS 103,103
(198,290)
268,659
173,472

11. RELATED PARTY DISCLOSURES

There were no related party transactions for the year ended 31 August 2025.

Page 13

The Charles Wallace Pakistan Trust

Detailed Statement of Financial Activities for the Year Ended 31 August 2025

Detailed Statement of Financial Activities
for the Year Ended 31 August 2025
31.8.25 31.8.24
£ £
INCOME AND ENDOWMENTS
Investment income
Deposit account interest 39 52
Interest 443 494
Curr asset inv income 51,498 50,577
51,980 51,123
Total incoming resources 51,980 51,123
EXPENDITURE
Investment management costs
Portfolio management 11,279 11,001
Charitable activities
Grants to individuals 70,216 83,683
Support costs
Management
British Council Levy 4,700 4,700
Secretary's Honorarium 2,760 2,750
Secretary's fixed overheads 504 504
Secretary's visit to Pakistan - 1,363
IT Costs 126 500
Sundries 507 395
Trustees meetings 41 -
Finance 8,638 10,212
Bank charges 61 80
Governance costs
Accountancy and legal fees 1,680 1,440
Total resources expended 91,874 106,416
Net expenditure before gains and losses (39,894) (55,293)
Realised recognised gains and losses
Realised gains/(losses) on fixed asset investments (13,415) (36,956)
Net expenditure (53,309) (92,249)

This page does not form part of the statutory financial statements

Page 14

The Charles WAllte PAkistn Trust Notes To The Fith#lltial St*temtnts- Contillued For the Ytar Ended 31 Au ust 2025 IliDIVIDUAL BENEFICIARIES AND SUMS EXPENDED Name Mll.- Sub'ect UK I lost Institution No. of wks Cost Dr Haroon Ahmed Dr Md Assit'Farooq Dr Mujiaba Hassan Dr Nadeein Sheikh Dr Ncclum Almas Prot'Saadia.Idlccb Ms Sania RaLII' Dr Shthid AIIL Urnar Far(K)q Dr Hira ￿]U￿a￿d￿8 Dr Iran Arnin Mr Mdlik Md Ar%ldll M% Meher Jaffri Dr Md Elisan Muzhur Ms Swiiya Mansour ZLN)noiic Diseases C'ardift'Llniv. Coronars. Htart Distase Co￿et7[rY UniN'. Hydrology & C limaie Glasgow Unl￿. Decarbon-isaiion Teesside Univ. English Liicraturc York Univ. MLdical Microbiologi London Sch HN'gicnc ILSHTMI H)PLrlLnsion Brisiol UniN. CanLLr RLsLarch Glasgom Univ. PhoiogtaphylFilm Making Avani-garde Films Londort Epidemiolvg) LanLa%ter [Jni￿. Mc)leLU1￿ Viwlugy Blizzard In%tilute Qu M ljniv. ufL()ndon Ener¥}. & EnN'ir()nment Tlieatre DireLtii)n EnNir(Intnenlal P()Ilution Int¢mationul RelatlOllS ?,868 2.067 3,668 2,067 2,868 2,067 3,668 3,668 2,468 3,668 3,668 ¥iJ Cardiff I Injv. CK)Id4niith4 Ci?Ilege Qu M IliiiTr. of L' 4.459 4.477 8.936 Vi51tin Arts Abu Hanzla Sl'ed Qasim Shah Triangle aris trust Gasworks paJmLni 10 Baiicrsca Aris CcnirL tor accommodation + cssLniial ¥xtcnsion Sch￿1 of Traditional Ans Theairt Residencs. 6.086 3.305 4.725 2.160 16.276 Doetorgl BursAries £1 OIKb eith Faiima seerai PhD in English and Ajntrican SILidies Unibersit). of Manchesier lJsatna J￿￿￿1 PIID in EcoiiomiLs UniTrersiiTr of Manchesttr FJreelia Akhtar PhD in Blisiness and Managemtni Queen Mar). Universii>' of London Naitna RiZw￿l PhD in lite and health Sciences Unii'trsiiy of Roehampton 4.000 Grand Total Aetivi 70.216 Page 15