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No-one in Swaffham slept that night. Police and immigration officials moved from house to house, flushing out the ‘illegal’ ones. Some were taken from their beds, some detained at work, others let go because there weren’t enough vans. By dawn the choppers had landed, the immigration officials had left and the police had done their job. A story dissolved, never to be told, never to be printed, never to be aired. How lives change overnight!

‘The inflow is mainly from the Eastern European countries and they use “waiting area” countries like Ukraine and Russia for easy access to the West,’ says Professor Marko Bojcun, Director of the Ukraine Centre at London Metropolitan University, who has spent the last couple of years researching the east-west migration path from the former Soviet Union to Western Europe.

These are the people ‘Fortress Europe’ loves to hate, the ones the United States labels as ‘aliens’, Middle Britain sees as asylum seekers taking ‘our jobs and benefits’, and the developed world christens ‘illegal immigrants’.

My life as an illegal worker started last summer when I rang Peter, a notorious gang master in Swaffham, Norfolk, eastern England. He has command over more than 200 illegal Eastern Europeans. All I needed to do to cross the threshold into this uncharted nether world was to go there.

Peter hides out in a pub most of the time, where he occasionally also does his business. I get an intimidating reception from the people inside the pub, but quite the opposite from Peter himself. Valencia, who is Polish, guides me to my pre-arranged accommodation: 53 Station Street, a ratinfested edifice and an eyesore for the locals. Scores of dirty working boots and raincoats litter the hallway. Four or five beds to a room, bare concrete floors, the stench of urine and greasy kitchen sinks, oily cooker and corroded utensils, rusty gas pipes and soiled floors.

Many workers already occupy the place I will be calling home for the next three months. I get a bemused look from them–a single coloured skin in a stronghold of East Europeans and Russians.

Next morning in the wee hours I find myself beside a road waiting for a van to take me to the workplace. National Insurance and work permits are not an issue. Peter hasn’t even asked me for my surname. Standing on the street this cold foggy morning I feel like an illegal Mexican waiting to be hired for a day’s labour in San Diego. A van screeches to a halt. The driver pops out his head and asks me if I am Pranav. An eerie silence fills the van when I hop in. A Nepali is a surprise. No-one speaks a word to me.

The Manor Farm Ducklings Company employs a huge number of illegal workers. Today another greenhorn (me) has arrived. Flora, an administrative assistant, guides me to a room where I will slave for the next 13 hours, lifting 15-kilogram packages of Marks and Spencer ducks, stacking them in a truck. She introduces me to Marian, a Polish man who started earlier in the day. Language stands as a wall between us.

Barely two hours into the job my vision blurs, my arms ache and my legs won’t hold me up any longer. I lose consciousness and collapse inside the truck. A minute or two later I find myself held by Marian. He has dragged me further into the truck to avoid the CCTV cameras that glare at us from every corner of the factory. He gives me the thumbs up and goes back to work–at twice the speed, to compensate for the time he has lost with me. We haven’t exchanged a word yet, but I have discovered a humane bond and my idea of ‘illegal East Europeans’ is transformed. In the darkness of the cold truck, against the agonizing body ache, I weep silently–a Nepali let loose in the lowlands of England.

After 14 days of 14-hours-a-day slavery at Manor Farm Ducklings, and the total loss of my self-confidence, I get paid–a little yellow envelope containing my recompense for gutting a duck every three seconds. They have subtracted $56 a week for National Insurance contributions, $56 for a bed like a trench and $6 for the white-van ride to and from work. And then there is Peter’s $48 ’security deduction’. My wage is $136. It’s a rip-off.

Peter, one of the gang tycoons of Norfolk, is not a nice guy. If driving across rhubarb fields in a Range Rover while abusing workers at the top of his voice is all it takes for this ex-Londoner to do his job, so be it. After all, he says, when his workers do the midnight runner ‘it doesn’t mean a damn thing’–new recruits will fill the gap within hours.

No-one is allowed to break his rigid rules. He segregates us on the basis of race alone. A handful of English welfare fraudsters work for him. They travel in a different van, work comfortable seven-hour shifts and get holiday and sick pay. Sycophantic Carl, Peter’s right-hand man, makes sure the rules are properly implemented.

The day starts as early as five in the morning. It takes an hour-long van ride to reach the fields. The long summer days of June are a windfall for gang masters like Peter and Carl: a battalion of illegal workers, a gang of mean supervisors and vast fields of rhubarb to be harvested. You slave for 16 hours a day bent double, five minutes for lunch if you are lucky, abuse and threats of deportation in between.

I leave East Anglia the minute I have achieved what I set out to do, never to look back again at the modern-day equivalent of medieval slavery. For thousands of others it’s not that easy. With their economies back home in the doldrums there is no respite for them. Vultures like Peter and wage-slave factories like The Produce Connection and Manor Farm Ducklings stretch from the Scottish Highlands to the Midland plains and the Eastern lowlands, feasting on the vulnerability of the immigrants, the ones Fortress Europe loves to hate.

Police and immigration authorities turn a blind eye to the disorder they help to create. Every few months they launch a PR stunt, raid a factory, arrest a few immigrants, take them through Swaffham market square with sirens blaring. The locals cool down, politicians stop grousing for a while. The gang masters start their scavenging all over again.

How do they get away with it? Well, illegal workers fill the chronic shortage of labour in agriculture and manufacturing. The state provides them with nothing. They work for a pittance. They pay taxes like everyone else. They contribute to the economy. They help to make this part of England one of the richest in the country. Dead to the world in a cluster of caravans in the shadows of an open shed, waiting on street corners at dawn to be taken away in vans; humble, hard-working people cheated by fate and foxy folks. Lives lost in the lowlands.

I received a call from a business systems analyst one afternoon. He said: “We’re in negotiations with a prospective new technology vendor. But the process is going too easily. The vendor is conceding every single negotiating point. Could you review the financial information on the company?” I retrieved the company’s statements from the Internet. The company was losing money, it was insolvent, and its accountants had just issued a “going concern” qualification. I called the systems analyst and conveyed these facts. “Is that bad?” he asked. I again tried stating the information in financial terms. I ended up telling him: “If we pulled up to the company’s headquarters tomorrow, I wouldn’t be surprised to see the lights out and the doors locked.”

Several years ago, vendor due diligence primarily involved conducting background checks, nailing down operational requirements, and negotiating contract language. While evaluating an armored-car company or check-printing vendor once seemed arduous, today’s technology risk managers face such nettlesome questions as these:

* If the bank’s primary telecommunications company declares bankruptcy today, will the phones ring tomorrow?

* If the Web-hosting vendor cuts back on customer support personnel, will the bank’s Web site be down for hours rather than minutes?

* How would the bank know if its transactions-processing vendor were sold to management of questionable character?

Even if a vendor is in poor shape, there may still be compelling business reasons to stay put rather than seek alternative solutions. Shifting front Crafty Crocodile Software to Big Boa Constrictor Systems can take a bite out of your budget as you leave your old vendor and squeeze your resources while installing a new one. Like the man who journeyed the world searching for romance only to return home and fall in love with the girl next door, sometimes the best course of action may be to sit and do nothing.

Indeed, many robust and cutting-edge solutions come from vendors who lack a long track record or have weak financial statements. As one vendor recently lamented:

“I am sorry to hear that your bank has decided not to take advantage of our revolutionary new product. I think that it is a grave mistake to eliminate a vendor from consideration based on a due-diligence process that appears to be unduly focused on number crunching as opposed to seeking opportunity for your bank to gain a competitive advantage.”

Although a less formidable technology vendor may require a smaller contract with a closer maturity date, a stronger vendor may merit a larger, longer-term contract. Moreover, some vendors have capitalized on their financial and operational strength: “Sign a three-year deal rather than an annually renewable contract and save $500,000!”

Evaluating a vendor’s risk profile is troublesome because not all of the risks are financial. National banks are old hands at providing the Office of the Comptroller of the Currency with many indications of direct credit risk to borrowers (risk ratings, repayment histories, independent credit reviews, etc.), but they may be less experienced when it comes to evaluating third parties. In addition to credit risk, the OCC asks banks to consider strategic, reputation, compliance, transaction, and other risks, (1)

While encouraging national banks to use technology in a safe and sound manner, the OCC has stepped up its third-party risk assessment. Recently caught short, one national bank had to devote extensive manpower and financial resources to vendor review. As fate would have it, the solution involved the help of a new database from a technology vendor.

Ironically, while financial institutions are increasingly relying on technology, they also are migrating to progressively more outsourced solutions. As a result, banks are delegating control of the very functions that are becoming more important to their success! Just because the henhouse now has a digital gate doesn’t make the farmer any less responsible when the fox swipes the automatic opener.
eveloping an Effective Vendor Evaluation Solution

What’s needed is a consistent means of identifying, prioritizing, and administering technology vendor risk. Vendors representing higher risk should be tracked more closely. And the solution should be dynamic. An effective vendor risk management system will:

* Rely on teamwork from various functional areas of the bank.

* Determine materiality of the vendor risk.

* Guide evaluation of a vendor’s track record.

* Incorporate financial analysis of the proposed vendor.

* Obtain proper legal review of vendor contracts.

* Integrate existing vendors into the system.

* Establish guidelines for tracking vendors over time.

The Teamwork Solution

Technology solutions are now so pervasive that they require input from throughout the institution. Traditionally, evaluation of new bank products and services included input from audit, compliance, security, privacy, and marketing. Clearly, the best approach to evaluating vendor risk has always been multidisciplinary. But in addition to these traditional areas, technology vendor risk analysis also depends heavily on technology, business systems, operations, finance, and legal review.

* Conduct an analysis of the vendor’s business franchise. How long has the company been in business? Who are the vendor’s main competitors? What is the company’s market share?

* Check the vendor’s business reputation, complaints, and litigation. Does a reference and background check with the vendor’s existing customers indicate any problems?

* Review qualifications, backgrounds, and the reputation of the vendor’s management.

* Establish the vendor’s internal controls, audit, business resumption, continuity, recovery, and contingency plans. Review the vendor’s insurance coverage.

* Review the vendor’s experience in implementing and supporting the proposed product or service. Are there other similar-sized financial institutions as customers?

* Look at the significance of the bank’s contract to the vendor. Does the proposed contract represent a large par of the vendor’s revenues or income?

* Determine whether the vendor has any key subcontractors or enabling counterparties. If the proposed contract is large or material, conduct a check on these additional entities as well.

* Look at the service and support commitment. Does the vendor dedicate a sufficient level of resources to meet the ongoing needs of the bank?

* Evaluate research and development expenditures. Is the vendor’s current research-and development budget large enough to keep the bank’s technology current?

While answering many of the preceding questions is most important before entering a vendor relationship, the bank should revisit this checklist annually for more material contracts. Outsourced technology arrangements should clearly receive the highest level of regular scrutiny. However, as mentioned above, these vendors are generally very strong and the regular review can be conducted in a relatively short time.

Financial Evaluation

What would you think about a vendor who said the following?

By declaring bankruptcy, the company is in the process of reorganizing its finances. The news media will speculate to no end about whether or not we will survive. Regardless of what the financial press and our competitors say, the company has a proud past and we believe that it has a bright future. The company’s new management is in the process of addressing key constituencies, including our employees, supplier’s and customers….

One of the biggest risks in technology vendor relationships is financial stability. Several years ago, it seemed that a telecommunications carrier declared bankruptcy every day. Sometimes, in particularly volatile areas of technology, it seems tough to identify even one vendor with financial staying power.

* Review recent pronouncements front the company’s management. Has the company had any recent earnings warnings? Does it seem that the company has provided any surprises related to its accounting procedures? One of the biggest areas of adverse surprises was revenue recognition. Are sales being converted to cash or are receivable balances rising?

* If publicly traded bond ratings are available, obtain them from Moody’s, Standard & Poor’s, and Fitch. Generally, a senior unsecured debt rating is preferable for a vendor analysis, since the vendor contract usually has no preferential terms or security. Pull a D&B or other commercial credit report on the proposed vendor.

* Update research on the industry.

* Analyze the vendor’s most recent financial statements. What are the vendor’s income statement and cash flow trends? How consistent has the company’s operating performance been in the past?

* Review the company’s balance sheet. Some technology vendors build fortress-style balance sheets to offset the volatility inherent in their industries. Does it appear that the company has enough financial staying power for the length of the contract?

* Evaluate the vendor’s forward commitments. Often, technology vendors have a healthy slug of deferred revenues or maintenance liabilities. Does the company appear to have the operating consistency and liquidity to meet its upcoming commitments?

A company in financial distress is not one to be avoided altogether. However, in attempting to right the ship, the management of a beleaguered vendor often takes steps that have adverse consequences for the bank. If the vendor significantly cuts its staff, the bank faces the risk of a more prolonged disruption in service than is desirable. The bank also faces the possibility that resolving even routine customer service matters will take longer and require more manpower. Often a company in trouble will greatly reduce capital expenditures, resulting in the risk that a competitor could develop better technology.

A company reorganizing in bankruptcy may ironically have better service quality than before: If service quality slips, the company becomes a candidate for liquidation. Nevertheless, a vendor in bankruptcy poses significantly increased risks: Even a company that successfully reorganizes may shed assets or reorient its service delivery.

For these reasons, in cases of financial distress, it is often appropriate to consider substitute vendors. At the very least, once a vendor in financial distress is identified, it is imperative that the bank develops a financial tracking system and an operational contingency plan.

Legal Review

The importance of proper legal review cannot be emphasized enough. Generally, the bank will have an established review system for all contracts, based on various criteria, including dollar size. The last pace of change in technology may warrant legal review if the term of the contract exceeds a relatively short length of time. In addition, certain criteria that raise materiality also increase legal risk.

Rome wasn’t destroyed in a day. It didn’t come crashing down in tremendous chunks of marble. No, it decayed.

Which brings us to the Buccaneers. They remain capable of beating any team in the league at any site. Their pass rush is world class. The resourcefulness that won them a championship last January remains evident.

But as was the case with Rome, decay is all around.

The Bucs haven’t had the muscle to back up their heart, blowing fourth-quarter leads in two of their five losses, including one to the Panthers, their most bitter rival, last Sunday. They also had a late meltdown against the Colts and could have defeated Carolina in Week 2 by kicking an extra point. It was blocked, and the Bucs lost in overtime.

The Bucs have been run on by every opponent that has committed to the rushing game, with the exception of the Panthers on Sunday. Going into Week 10, 16 defenses had held their opponents to a better average gain per rush than the Bucs, who had allowed 4.1 yards. Last season, only two teams were better in this category than Tampa Bay, which held opponents to 3.8 yards per carry.

It’s no mystery why the Bucs’ defense has been slightly out of sync. Gone from last year are strongside linebacker Al Singleton and free safety Dexter Jackson. Significant players who have missed blocks of time with injuries include linebacker Shelton Quarles, strong safety John Lynch, backup safety Jermaine Phillips and cornerback Brian Kelly. The Bucs subsequently have been lining up players who otherwise would be saloon doormen or insurance salesmen. Dwight Smith was forced to start at four different positions in four games.

“Kelly was a big loss because he was their cover corner,” Panthers receiver Muhsin Muhammad said after lake Delhomme passed for 277 yards against the Bucs. “He was in all their coverage schemes and allowed them to do a lot of different things coveragewise. In their scheme, they didn’t rely on Ronde (Barber) to cover a lot. Now he’s got to cover. Now they’re limited.”

Without ideal personnel, the Bucs were forced to rely on Lynch in man-to-man coverage on the Panthers’ game-winning drive. Lynch was trying to cover Muhammad when he made a 22-yard catch to the Tampa Bay 5.

At times, the secondary tackling has been inefficient. I counted five missed tackles by defensive backs in the open field Sunday. There have been games in which tackles Warren Sapp and Anthony McFarland have been driven back, allowing running backs to get past them before linebackers could reach their gaps. And when the Bucs have had to play from behind, opposing offenses have gone big and created mismatches against Tampa’s smallish front.

The “new car” smell is long gone from the bus that Sapp is driving. The Bucs have played their “Tampa 2,” or cover 2 defense so well, that virtually everyone in the NFL has copied it. That hasn’t helped the Bucs because offenses have become much more familiar with it. “We’ve seen it so much that we feel we have an idea of what to do against it,” one NFC head coach says.

The Bucs’ running game actually is better than it was a year ago because Michael Pittman has improved and coach Jon Gruden has gotten more mileage, or at least yardage, out of a nice package of misdirection plays.

But there are issues with the passing game, despite the numbers the Bucs have put up. The Bucs’ blocking always has had holes, and injuries have made those holes wider. Right tackle Kenyatta Walker has been forced to play left tackle, and he committed two personal fouls and one unsportsmanlike conduct penalty against Carolina (a fourth penalty, for holding, was declined). “He’s garbage, he’s horrible,” said Carolina defensive tackle Kris Jenkins, who still was spitting fire after the game.

Last year, many of the Bucs’ big plays in the passing game came against the blitz. This year, opponents aren’t blitzing the Bucs as much because they don’t have to. Defenses are able to get to quarterback Brad Johnson with four men. He even was sacked by a three-man rush against San Francisco. “If you can cover at all, you can beat their offensive line with four,” says one defensive coordinator.

Offensive linemen who can’t keep pass rushers away from the quarterback and receivers who struggle to get open are a dangerous combination, like a ventilation system that’s sucking smoke into a room in which the windows and doors are locked.

Aside from Keenan McCardell, who has played very well, the Bucs’ receivers have been heard more than seen. Keyshawn Johnson actually has had a couple of decent games recently, but three coaches and two personnel men used the same two words when asked about him: “Can’t run.” At 31, “he’s a step slower,” one personnel man says. Before Sunday, Johnson averaged 2.7 yards after the catch, which ranked 160th among receivers with at least 10 receptions, according to STATS Inc.

Quarterback Brad Johnson has done a nice job of making the most out of the situation. But he has had to come off his receivers and check down frequently. That explains why 39 percent of the Bucs’ passes have been caught by running backs, compared with 32 percent a year ago.

Alone, none of these problems is insurmountable. And we should point out the Bucs had some problems at this point a year ago.

But decay is growing, and opportunity is shrinking.

Simply put, comparing auto insurance company quotes online can save you money. While many people find it easier to stay with the same company for years – especially when their auto, home and life insurance policies are with that same company, the truth is that you are probably paying too much. Everyone shops around for the best deal when purchasing a car; why not do the same with the insurance that protects that car?

Shopping on-line. Many insurers now offer instant rate quotes on-line, such as Allstate, e-surance.com and Amica. Others, like Progressive, even provide their rates and the estimated rates of their competitors. Take advantage of these company’s websites or you can visit a comparative on-line services, such as our on-line quote tool for free insurance quotes which provides multiple quotes from carriers who write insurance in your area. These on-line tools are extremely easy to use and generally only take a few minutes. They are well worth the effort if you can save money on your next policy.

Services. Getting a lower rate is only part of the equation. It is important to look at what services the insurer provides. For example, many insurers, such as Geico, have add-on features such as emergency road service available for a nominal charge (Geico charges $12 per year/per car). Others, like Progressive, have 30,000 independent agencies throughout the U.S., so you can deal with a “live” person instead of trading e-mails and phone calls. Allstate now offers programs on accident forgiveness (this helps keeps rates from going up because of an accident) and deductible rewards (gives an immediate $100 off collision coverage deductible and an additional $100 off for each year of accident free driving – up to a $500 total. These are just a few examples; the key is to make a list of what’s important to you and make sure you are getting the coverage you desire.

Crucial times for comparison. Comparing auto insurance companies is especially important when you’ve moved as location directly affects your premiums. It is also important to compare auto insurance companies when circumstances in your life have changed, such as retirement, marriage, adding a teenager to your policy, adding another vehicle, whether the amount you drive has changed or if you’ve purchased a new vehicle. Changed circumstances cause insurers to re-evaluate their risk – and since all insurers use different methods to evaluate that risk, your current provider may not always be as competitive in quoting your new situation believing that you will not take the initiative to shop around.

Late premium payments can, and might, result in policy cancellation – even if you are only one day late! The truth is, unlike homeowners policies which generally allow for a “30 day grace period” to make premium payments, most insurers can cancel auto policies immediately for lack of payment if allowed by state law. Check the law in your state to see what grace periods are allowed. The National Association of Insurance Commissioner’s (NAIC) website (http://www.naic.org/state_web_map.htm) provides links to state insurance departments. Look under consumer information to see whether your state provides a grace period.

But will they? The good news is that most insurers won’t cancel your policy for non-payment if it is a one-time occurrence because they want your business. However, if you are chronically late, your insurer may take advantage of your non-payment and cancel your policy – especially if you’ve become a bad risk. It is also important to realize that many insurers may require you to pay your entire term balance before reinstating your coverage if you’ve passed the cancellation date on your policy.

Avoid bad credit scores! Being cancelled for non-payment of premiums may also earn you a bad credit score and cost you more on future policies with other insurers. Most insurers use credit scores (your overall credit history) to assess their risk. The lower your credit score, the more you will pay for insurance. If you don’t have the money to pay your premium, contact your insurer immediately and see if you can work out a payment schedule. A bad credit score will follow you from insurer to insurer and could leave you without insurance altogether!

Take advantage of new resources. Many insurers, such as Geico and State Farm, now allow for online payments that can be automatically deducted from your checking and savings accounts. If you are a chronic late payer, take advantage of these new resources to avoid bad credit scores.