Setting

Paul Marshall, Strategic Director Children and Education Directorate Services, Manchester City Council Tom Hinchcliffe, Deputy Place Lead, Manchester Heath and Care Commissioning Kate Green, Greater Manchester Deputy Mayor Stephen Watson, QPM , Chief Constable, Greater Manchester Police Thomas Lang, Youth Justice Head of Service, Manchester City Council Beate Wagner, Independent Scrutineer, Manchester Safeguarding Partnership

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Dear Manchester Local Safeguarding Partnership

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Joint targeted area inspection of Manchester

This letter summarises the findings of the joint targeted area inspection (JTAI) of the multi-agency response to serious youth violence in Manchester.

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Joint targeted area inspection of Manchester

This inspection took place from 9 to 13 October 2023. It was carried out by inspectors from Ofsted, the Care Quality Commission (CQC), His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) and His Majesty’s Inspectorate of Probation (HMIP).

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Context

The findings in the report evaluate the effectiveness of the multi-agency response to children aged 10 and over who are at risk of or affected by serious youth violence and/or criminal exploitation. Even where the report does not specifically refer to this group of children, all findings relate to this scope.

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Context

The inspectorates recognise the complexities for agencies in intervening to address serious youth violence when risk and harm occur outside of the family home. As a consequence, risk assessment and decision-making have a number of complexities and challenges. A multi-agency inspection of this area of practice is more likely to highlight some of the significant challenges to partnerships in improving practice. We anticipate that each of the JTAIs of this area of practice that are being carried out will identify learning for all agencies and will contribute to the debate about what ‘good practice’ looks like in relation to the multi-agency response to serious youth violence. In a significant proportion of cases seen by inspectors, children had also experienced other forms of abuse, which reflects the complexity of the needs and risks for children.

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Headline findings

Effective and mature partnership arrangements between agencies are supporting a coordinated and comprehensive muti-agency response to serious youth violence. A strong learning culture enables the partnership to identify when improvements are needed and to work together to address these. There is a well-understood strategy in place and much purposeful activity that is reducing risks to children. While the strategic intent is well established, in a number of areas, agreed interventions and actions are not fully embedded. For example, the commitment to child-centred policing has not yet been fully realised.

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Headline findings

There is an increasingly strong focus on prevention and early intervention to tackle serious youth violence in Manchester. There are a significant number of innovative interventions and projects which are making a positive difference for children. Though individual evaluation processes are in place for these interventions and projects, the partnership recognises that there is no overarching approach to monitoring and evaluation in place to understand how well these initiatives work together as part of a system to tackle serious youth violence.

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Headline findings

For children with high levels of risk and need, the complex safeguarding hub (CSH) promotes and supports an effective multi-agency response. There is a really strong commitment to relationship-based practice from professionals across the partnership which is enabling good engagement with children. Areas of practice that need to be improved include developing, reviewing and implementing effective multi-agency plans, accurate recording and information-sharing.

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What needs to improve?

◼ How effectively the arrangements for the monitoring and evaluation of serious youth violence support the partnership in implementing its strategy. ◼ How well the strong strategic intent to address the disproportionate impact of serious youth violence and criminal exploitation on children from some ethnic backgrounds and those with special educational needs and/or disabilities (SEND) has been translated into positive change for children. ◼ The specificity and thoroughness of plans, and how effectively they are implemented, reviewed and developed so that children get the right help at the right time. ◼ How consistently professionals look beyond the needs of an individual child, for whose safety or welfare there may be concerns, and consider risks to the wider group of children, such as brothers, sisters and peers associated with that child. ◼ The consistency with which key information is recorded and shared between

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What needs to improve?

partners to enable effective decision-making. ◼ The awareness of professionals about the range of services that are on offer to support the emotional well-being and mental health of children at risk from serious youth violence or criminal exploitation, as well as waiting times to receive therapeutic treatment as part of the core child and adolescent mental health services (CAMHS).

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Strengths

◼ Robust multi-agency arrangements with clear accountabilities and a well- understood strategy are leading to many children receiving a range of effective responses to address serious youth violence. ◼ A significant number of innovative approaches and interventions developed and managed by the partnership are making a positive difference to children’s lives. ◼ A culture of professional challenge and shared learning is helping to enable improvements in practice and in the impact of services. ◼ The views and aspirations of children are generally well understood. Professionals are developing a progressively more accurate, shared understanding of children’s lives and of the effect on them of experiencing serious violence and exploitation. ◼ A consistently strong approach to building relationships with children is supporting effective interventions to reduce risk. ◼ Most partner agencies have a good understanding of the range of risks from

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Strengths

serious youth violence and criminal exploitation faced by children, and this enables them to offer a range of appropriate support aimed at reducing risks. ◼ An effective approach is in place for prevention and early intervention, and to support the engagement of schools. There is an increasingly good mentoring offer that is making a positive difference for children. ◼ The CSH delivers strong multi-agency working that, overall, provides effective expertise, advice, help and intervention for children at significant risk of serious youth violence and exploitation.

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Main findings

Strong strategic arrangements are ensuring that partner agencies are clear about their roles and accountabilities, and this is helping the partnership to work effectively. The partnership has a shared commitment and drive for continuous improvement. The priority given to the response to serious youth violence is enabling an ever-improving multi-agency response. There is a culture of learning and challenge, which enables the partnership to identify where improvements are needed and to work together to address these. While strategic intent is strong, a number of developments, interventions and projects are not fully embedded.

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Main findings

The work of partner agencies to tackle serious youth violence within the Manchester local authority area is supported by the Greater Manchester Violence Reduction Unit. Partner agencies recognise the areas and levels of deprivation in Manchester and the consequent challenges. Manchester is the 7th most deprived local authority in England. Twenty per cent of its areas are among the most deprived 5% in England. Forty-six per cent of pupils in Manchester are eligible for pupil premium, compared with 28% for England overall.

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Main findings

The partnership is maintaining a largely stable workforce. Staff report feeling valued and are supported well. This stability is a key factor in how the relationship-based approach is making a positive difference for children. Staff morale is generally high. There is a good training offer, although the take-up of this remains inconsistent.

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Main findings

The partnership has a strong commitment to enabling children to receive a trauma- informed response from frontline staff, and this approach is becoming more embedded in practice. This is evident in the effective approach of professionals in considering and understanding the difficult and complex abuse which is a feature of the lives of many of the children reviewed during the inspection. Across the partnership, there is a general recognition that serious youth violence and child criminal exploitation are safeguarding and child protection issues. Although this underpins the strategic developments, this is not always communicated as consistently and explicitly as it could be to all frontline staff and projects, which means it is not always fully translated into practice.

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Main findings

The Community Safety Partnership (CSP) has developed a serious violence board that is working collaboratively with Manchester Safeguarding Partnership (MSP) to ensure that there is an effective focus on children affected by serious youth violence.

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Main findings

The partnership is delivering a broad range of effective interventions. This includes an increasing focus on prevention and early intervention. The partnership recognises the challenge of different short-term funding arrangements and are responding to this by working to coordinate the range of projects available to children and their families. For example, Engage is a project that is becoming more embedded and brings together a number of interventions and projects to meet children’s needs at an early stage.

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Main findings

Agencies have recognised that they need to further strengthen how effectively they intervene with those children most vulnerable to serious youth violence and exploitation. One of the ways this is going to be addressed is through the commissioning of a programme which will focus on working with children who have been involved with the Youth Justice Service for a prolonged period. In addition, the CSH has increased the number of children who they are working with who are at risk of serious youth violence.

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Main findings

The MSP’s focus on serious youth violence and exploitation is well supported through the complex safeguarding subgroup. The MSP has clarity about its role and has acted as a ‘critical friend’ challenging and influencing the work of the CSP, helping to ensure that children are central to the work. For example, the learning and challenge through the MSP enable an improved understanding of the impact of frontline practice and the identification of areas for development.

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Main findings

There is more to do in relation to the partnership’s role in monitoring the impact of the work being undertaken about serious youth violence. Although individual projects are evaluated, there is not yet a more overarching approach to evaluation. The partnership has recognised this and is working to improve data and intelligence so there can be a more holistic understanding and more effective monitoring of serious youth violence. The partnership’s strong commitment to address the disproportionate impact of child criminal exploitation and serious youth violence on children from some ethnic backgrounds and those with SEND has not yet been realised.

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Main findings

The Greater Manchester Violence Reduction Unit (VRU) works collaboratively with, and offers effective support to, the Manchester partnership in improving the response to serious youth violence. The VRU has identified where it can support the partnership to deliver interventions and develop strategy more effectively, including through delivering proactive public awareness campaigns to reduce serious youth violence.

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Main findings

Working with its partners, Greater Manchester police lead a number of initiatives that respond to child criminal exploitation and serious youth violence. The police chair fortnightly partnership meetings, sharing information and intelligence, and deliver a coordinated approach in order to meet children’s needs and address risks, while also considering criminal justice approaches, as well as other diversionary outcomes. Partners work well together to understand all aspects of serious youth violence and develop effective local strategies, to avoid the unnecessary criminalisation of children.

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Main findings

The important role of the community and voluntary sector in addressing serious youth violence is well understood in Manchester, and most organisations report feeling valued as partners. They are listened to and are enabled to inform and challenge practice. This means they feel part of a culture that is about ‘everyone doing the right thing for the child’.

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Main findings

The partnership’s commitment and investment in the community-led initiatives approach is positive. However, the potential of these approaches to support the partnership’s strategic aims is not always maximised due to a lack of consistently sufficient governance, and support and training for those who work in these initiatives. In Manchester, 61% of children are from ethnic minority groups. The partnership has a good understanding of the diverse needs of the communities in Manchester. Active engagement with communities is helping to ensure that their views and concerns about serious youth violence are progressively well understood. The partnership has taken some important steps to seek the views of children. For example, a self- evaluation process was carried out in a reflective conversation with 26 children who were known to the youth justice service and affected by serious violence. This focused on their experiences of health, education, police and youth justice services.

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Main findings

There has also been engagement with children through the annual safeguarding conferences. While such individual initiatives are positive, there is no current ongoing programme of engagement with children to inform practice and strategic development more systematically.

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Main findings

Although not rolled out across all schools or embedded in practice, partners are developing a process to introduce more effective information exchange between the police and education providers in relation to children at risk of serious youth violence. This is a positive initiative, although its impact is necessarily limited at this stage.

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Main findings

When children are referred to the Advice and guidance Service (AGS) as a result of concerns about serious youth violence or exploitation, the social workers contact the CSH for advice and consultation, which is supporting effective decision-making about next steps. Initial safety planning is generally completed well with the parents to address immediate risks to children.

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Main findings

When children meet the criteria for a service from the CSH, they are allocated a worker immediately so that their risks can be assessed promptly. Children benefit from very regular visits from practitioners who see them frequently. For many children, these visits and the interventions undertaken are making a positive difference. However, the full impact of this work is not always evident. The purpose and aims of the work are not always explicit in recording and in sessions with children.

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Main findings

Risk assessments are detailed and thorough and are updated at least every six months or when children’s circumstances change. This enables an effective understanding of risks to children. Although children’s views are recorded as part of the risk assessment, these are brief and do not always bring alive the child’s voice or lived experiences in a collaborative way. This can limit children’s investment in the direct work and clarity about their experiences and understanding of risk.

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Main findings

District social workers make appropriate referrals to CSH when children’s risks of serious youth violence or criminal exploitation are identified. Just under half the children referred to the CSH are not accepted for allocation and assessment. For those children who do not meet the criteria, clear recommendations are made by the CSH for follow-up work, such as mapping, direct work, and referrals to other services. The criteria and rationale for not undertaking a CSH assessment are not always clear and some of the decision-making is inconsistent with children’s level of risk. For some children, the follow-up work is not completed by the allocated social worker in the district team. This means some children do not get the support or intervention required to address their risks.

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Main findings

When incidents happen out of hours, the Emergency Duty Service (EDS) responds promptly to assess children’s needs and risks, to liaise with other agencies such as police and health practitioners, and to provide any necessary immediate support, before handing over to daytime services. Child protection strategy meetings are held when appropriate with the police and health practitioners to agree immediate safety planning.

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Main findings

For children who are arrested and held in police custody, police contact EDS for a discussion about the need for, and availability of, a suitable specialist placement that meets the criteria set out in the Police and Criminal Evidence Act (PACE). Police and local authority staff sometimes disagree about the need for a PACE placement. When local authority staff think a PACE placement is appropriate for a child, police do not always agree. In these situations, the police make the final decision. Children’s access to such placements is also limited due to a lack of availability. This means there are a few children who remain in custody overnight inappropriately.

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Main findings

For children with more serious or complex risks of extra-familial harm, including from serious violence and criminal exploitation, district social work teams use the My Safety Plan process to plan interventions and monitor progress. Through three- monthly conferences chaired by child protection chairs, this process ensures that for these children there is close oversight and monitoring of work with them and their progress. Children’s plans are also reviewed at monthly multi-agency meetings that are well attended by relevant professionals and families, ensuring robust monitoring. Although My Safety Plans are a positive development, there is not a consistency of understanding about which is the right plan to use: a child in need, child protection or My Safety Plan for children at risk of serious youth violence. This lack of clarity risks not always getting the best benefit from different planning processes.

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Main findings

Children and their families benefit from the tenacity of professionals in building and maintaining relationships. This leads to good engagement with children and their families. When plans and interventions are complex, often involving multiple agencies, professionals work well together, ensuring that children and their families do not need to work with too great a number of different professionals. Instead, children and their families are able to work with those professionals who are best placed to work with them. These professionals have positive relationships and coordinate and deliver services on behalf of the wider partnership. For a small number of children, there is a focus on relationship-building over a long period of time, but there is little evidence of positive change being achieved as quickly as children need. Children’s plans are not always specific, comprehensive or responsive to changing

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Main findings

need, and this limits how effectively they can be used to monitor the completion of agreed actions and the progress that children are making. Good working relationships between agencies, a shared commitment to getting it right for children and generally stable staff groups across all agencies mitigate this weakness in plans. However, this does mean that progress is not always timely for all children. The number of different plans for some individual children does not result in all agencies having a clearly understood set of actions. Children’s education, health and care (EHC) plans are not consistently taken into account in the planning and intervention for children who are at risk of serious youth violence and criminal exploitation.

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Main findings

The risks of criminal exploitation and serious youth violence to brothers and sisters and peers associated with the individual child subject to statutory intervention are not always identified. Key information is not consistently recorded or shared between partners for these children. This means that for these children, risks are not always identified as early as they could be. There is also a missed opportunity to fully involve other agencies, such as primary care services.

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Main findings

Health practitioner capacity within the AGS, CSH and school nursing is insufficient. Leaders are aware of the capacity issues, and commissioning meetings are taking place to increase capacity. At the time of the inspection, this means health assessments and the analysis of children’s needs are not always completed in a timely manner or by an appropriate health professional, and so the full level of the risk posed to children may not always be sufficiently understood.

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Main findings

Girls are underrepresented in referrals to the CSH, in relation to known levels of need. This underrepresentation is particularly true of girls who are black or of mixed heritage. The partnership is aware of this and has begun work aimed at understanding the causes of this underrepresentation and improving the identification of girls who are at risk.

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Main findings

Youth Justice staff undertake holistic assessments of risk, safety and well-being. Health panels now take place routinely for all children. The meetings are attended by an educational psychologist, the drug and alcohol service and other health professionals. Case planning forums support the timely exchange of information, assisting youth justice staff in their assessment of the risk and vulnerability of children affected by serious youth violence and child criminal exploitation. Staff are tenacious and a creative approach is promoted by the management team and embraced by staff. There is access to mentors from a variety of services, and this is especially valuable in providing ongoing help when a child’s intervention ends.

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Main findings

Out of Court Disposal processes allow agencies to work together to identify children who are at risk of, or affected by, serious youth violence, including children who are exploited. Partners work together to intervene at the earliest opportunity to provide the appropriate help to children and, where possible, divert them from the criminal justice system. Children have access to range of targeted interventions to meet their needs and are supported to engage with services. The North West Ambulance Service has committed to strategic involvement with the VRU and has been progressive in developing a lead on serious youth violence, while also undertaking joint work with partner agencies. This has shown a positive impact through the work of the Safe Street model, where the ambulance service, police, Metrolink and schools work together to deliver training and awareness work to children about exploring street safety and the impact of serious youth violence.

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Main findings

Children receive a high standard of coordinated care when attending the emergency trauma departments. A multi-agency approach is taken to the immediate management and planning of the next stage of care for children. The trauma centres work closely with the police to manage the safety of children. This is enabling the care and safety of children to be well managed by the agencies.

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Main findings

Children accessing the drug and alcohol service receive good child-centred support from staff who place an emphasis on developing trusted relationships. Risk assessments are comprehensive and include markers for serious youth violence. Links between drug and alcohol services for adults and children are helping to ensure that children needing help due to parental substance misuse are identified and supported.

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Main findings

Children benefit from the Oasis Navigator service, which supports them to process their experience and consider ongoing help to reduce risks of serious youth violence. The service provides sensitive support to families and an effective advocacy approach for children.

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Main findings

Speech and language support is strong, and most schools, including alternative provision, have provided focused training for teaching staff. This is helping to ensure that speech and language needs are identified, and early intervention and targeted support are provided, at an early stage.

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Main findings

CAMHS is offering an increasingly community-based approach, for example through offering emotional health and well-being support to children via its hubs and in schools and alternative education provision. This provides positive help and engagement with children presenting at the lower end of disruptive behaviour. Professionals are not sufficiently clear about the services that are on offer to support children’s emotional and mental health. Professionals do not consistently receive updates from CAMHS regarding referrals received, plans for care or outcomes from interventions. As a consequence, children do not always receive the right help at the right time.

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Main findings

Many children at risk of serious youth violence and criminal exploitation who have emerging mental health needs, have social communication needs and/or are neurodiverse wait too long to receive the CAMHS core offer of therapeutic treatment. The impact of this delay is not mitigated by a targeted approach to the needs of children on the waiting list. Criminal investigations of serious youth violence and criminal exploitation are well supervised and managed by the police. Investigators appropriately consider the impact of criminalisation in cases involving children and their wider safeguarding needs. Outcomes are appropriate and Crown Prosecution Service advice is sought when relevant to ensure that correct decisions are reached. Police referrals are routinely submitted when children’s needs are assessed. These referrals often capture their vulnerabilities well and are shared in a timely way.

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Main findings

The local agencies, in partnership with the VRU, have developed an approach through ‘Engage panels’ to identifying children at an earlier stage who may be at risk of serious violence but are not involved with statutory services. This is to enable children to get support and intervention at the right time. A wide range of services attend the panels to provide help for these children across the three districts in Manchester. Children can be referred from a number of different agencies. The police make appropriate and timely referrals to the Engage panel. However, when the referral is made by other agencies, it is not always clear from police systems that a child had been referred to Engage or the outcome of the panel. This does not support the police in decision-making for children. Children who are referred to Engage have an offer of help from a range of services.

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Main findings

Schools and other education providers receive good training and guidance related to serious youth violence and to the criminal exploitation of children. This enables school staff to recognise when children might be at risk of serious youth violence. Schools are aware of the range of agencies who can provide help for these children. Schools communicate effectively with these agencies to access this support when necessary.

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Main findings

There are clear procedures for the sharing of important information when children transfer from primary school to secondary school, or to alternative provision. This information is typically used well, for example, to ensure the continuity of support for vulnerable children.

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Main findings

For some children at risk of serious youth violence and criminal exploitation, attendance at school is not given sufficient priority, including at the time of the critical transition point at age 16.

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Main findings

Children at risk of serious youth violence are increasingly provided with mentors in some schools. Those who attend alternative provision receive additional effective support. Education and awareness-raising in relation to knife crime and being safe in their communities have taken place across primary schools.

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Main findings

A good range of innovative projects are being developed in Manchester. For example, Manchester Early Help Service has developed a partnership with an organisation that works in Black and ethnic communities to protect and safeguard children from abuse, modern slavery and exploitation, and to support parents whose children are at risk of criminal exploitation and serious youth violence. The development was in response to the overrepresentation of Black and mixed-heritage boys affected by serious youth violence. The service provides early help and parenting support, including one-to-one and group work and awareness-raising. This is having a positive impact for children and their parents.

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Practice study: highly effective practice

Professionals from a range of agencies worked well together to understand why a young teenage child, Child A, was routinely carrying a knife. The combination of the information-sharing and assessment and good engagement with Child A by a range of agencies revealed that the child was frightened of some of the older children who lived in their area. Child A felt that they had no one to help keep them safe. The neglect Child A had experienced was a significant factor. The family live in overcrowded conditions and Child A didn’t feel that there was space for them at home. After being chased by some older children, Child A became so worried about being in the community that in order to avoid those older children, their attendance at school reduced. Child A said they were carrying a knife to keep safe.

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Practice study: highly effective practice

Professionals’ shared understanding of this, and of the range of help available to children and families, enabled them to agree what was needed to improve their situation, and they are working together with Child A and their family to improve the child’s safety. The relationship the child has developed with workers has helped them to understand that they are valued. Work has started to improve the child’s relationship with their mum and is helping her to understand how Child A is feeling and the important role she has in making her child feel loved and safe. Child A has moved to a new education provision. The education provision is providing the child with a safe space to go to every day, and their attendance has improved. Child A’s mum is being helped to apply to move to a new house with more space for the family. As Child A is vulnerable to exploitation, work is being done to help the child to recognise risks, and to ensure that support is in place to

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Practice study: highly effective practice

help to keep them safe. As a result of the carefully planned and coordinated work, this child’s life is more stable, they have structure, and they have people to talk to and to support them. Child A is making friends and knows that if they are scared or worried, that there are a range of people to help them. Significantly, Child A has made the decision to no longer carry a knife, and this is keeping them and others safer.

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Practice study: area for improvement

When critical information is not shared, and assessments are completed in isolation, professionals are not able to help children effectively. This was the case for Child B, who was attacked and violently assaulted by a group of other children. Agencies did not know all of the factors that may have led to his assault, and, as a result, they were not in a position to take all the actions they could have to reduce the risk of harm for Child B. There had been minimal communication with primary care and CAMHS by children’s services, which meant that not all professionals were aware of the risks and what support was being provided. Opportunities for professionals to understand wider risk and need had been missed. Incidents had been seen in isolation without sufficient consideration of the child’s history, their family and community, and so contextual risks were not fully understood. The lack of a comprehensive and dynamic assessment and

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Practice study: area for improvement

plan means that the child has not accessed the right help at the right time.

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Practice study: area for improvement

The risks to Child B’s sibling of child exploitation and serious youth violence were not identified, shared or acted on fully with all relevant partners. Child B is struggling to access school and their EHC plan is not central to meeting their needs so that they can access education.

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Practice study: area for improvement

Having shared information, professionals are now better able to work together to provide Child B with more effective multi-agency support.

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Places and Spaces: highly effective practice

The Youth Zone’s provision in the north of the city delivers a range of effective interventions to children and families. There is good communication and information-sharing between the services, both operationally and strategically, and shared visions and aims. They have a good understanding, and a collective management, of children’s risks within the local community and work well together to find ways to increase safety. There is a shared aim to prevent and reduce serious youth violence through engagement with children both in and out of the centre, and by building intelligence to identify potential incidents such as planned fights and county line runners. This leads to preventative action that safeguards children.

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Places and Spaces: highly effective practice

Safeguarding is viewed as a collective community responsibility, and awareness- raising takes place across the community, including with transport providers, supermarket security staff and takeaways, as well as across a range of small grassroots charities and groups. The youth zone has a full-time designated safeguarding lead, a risk register and effective behaviour plans for any children considered to present a risk to others within the centre.

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Places and Spaces: highly effective practice

The youth centre reaches a broad range of children. The partnership recognises that those children who do not access the service are harder to reach and are more likely to be at greater risk. Outreach support is flexible in terms of the localities it is provided to, and this helps to identify hotspots and respond creatively. However, there is no youth outreach after 8pm at night, which is a recognised gap.

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Places and Spaces: highly effective practice

Children’s views and feedback help to shape services. Their views are gathered through a variety of activities, such as focus groups, outreach workers, and a youth voice video that has been shared with professionals.

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Places and Spaces: highly effective practice

The impact of this is that children report feeling safer in parks and open spaces when the detached youth workers are around and when using public transport at night. Children feel hopeful due to opportunities provided in the youth zone and through social action. They also report feeling respected and supported due to the trauma-informed practice model and the tenacity of youth workers building trusted relationships with children over time.

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Next steps

We have determined that Manchester local authority is the principal authority and should prepare a written statement of proposed action responding to the findings outlined in this letter. This should be a multi-agency response involving the individuals and agencies that this report is addressed to. The response should set out the actions for the partnership and, when appropriate, individual agencies. The local safeguarding partners should oversee implementation of the action plan through their local multi-agency safeguarding arrangements.

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Next steps

Manchester local authority should send the written statement of action to ProtectionOfChildren@ofsted.gov.uk by 9 March 2024. This statement will inform the lines of enquiry at any future joint or single-agency activity by the inspectorates.

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