COMMUNICATIONS

                     
Foir

**From the Home Office**:

1. Financial breakdown of asylum accommodation costs (2024-2025), including hotel vs. dispersal accommodation costs, to quantify the £3.6 billion annual expenditure for unjust enrichment and negligence claims.
2. Post-July 2023 guidance on UASC accommodation following the ECPAT UK High Court ruling, to verify compliance with Section 55 BCIA 2009 and Children Act 1989 for breach of statutory duty and human rights claims.
3. Asylum processing performance reports (2024-2025), detailing caseworker numbers, productivity, and backlog strategies, to evidence negligence and breach of Immigration Rule 333A.
4. Procurement contracts and performance metrics for asylum accommodation providers (Mears, Serco, Clearsprings) for 2023-2025, to investigate anti-competitive practices and unjust enrichment.
5. Incident reports of UASC missing from asylum hotels (2018-2025), to support human rights (Article 3 ECHR) and negligence claims.
6. Age assessment policies and training materials for UASC (2024-2025), to assess negligence in misclassification cases.

**From HM Treasury**:
1. Impact assessments for National Insurance changes (April 2025) on charities, GP practices, hospices, and SMEs, to support irrationality and PSED breach claims.
2. Impact analyses for inheritance tax changes (2024-2025) on family farms, to assess failure to consider relevant factors.
3. Assessments of Listed Places of Worship Grant Scheme funding reductions (2024-2025), to investigate legitimate expectation and PSED breaches.
4. Compliance records for Steel Industry (Special Measures) Act 2025 subsidies, including £2.5 billion National Wealth Fund allocation, to evidence competition law violations and irrationality.

**From Ofwat**:
1. Thames Water Performance Commitment (PC) and Outcome Delivery Incentive (ODI) reports (2023-2025), to assess regulatory oversight failures for irrationality claims.
2. Enforcement action records against Thames Water for sewage discharges (2023-2025), to support illegality and statutory duty breach claims.
3. Price Review 2024 (PR24) consultation records and responses (2024-2025), to investigate procedural impropriety and PSED compliance.
4. Guidance on balancing consumer protection vs. company viability in price controls (2024-2025), to assess rationality.

**From the Environment Agency**:
1. Thames Water sewage discharge records (2023-2025), including volume, duration, and location, to support nuisance and statutory duty breach claims.
2. Monitoring and response protocols for Thames Water’s pollution incidents (2023-2025), to evaluate negligence and regulatory oversight.
3. Impact assessments of Thames Water’s discharges on ecosystems and public health (2023-2025), for nuisance and human rights claims.

**From the Department for Business and Trade (DBT)**:
1. Impact assessments for the Steel Industry (Special Measures) Act 2025, including market and competition analyses, to support irrationality and competition law claims.
2. Records of consultations with stakeholders (e.g., steel competitors, Jingye Group) prior to the Act’s passage (April 2025), to assess procedural impropriety.
3. Correspondence between DBT and CMA regarding British Steel’s market position (2024-2025), to evidence anti-competitive concerns.
4. Valuation reports for British Steel’s assets under the Act’s compensation scheme (Clause 7, 2025), to support unjust enrichment and A1P1 ECHR claims.
5. Records of alternative options considered (e.g., insolvency, NSI Act 2021) before enacting the Act, to support failure to consider relevant factors.

### Questions to Ask Under FOIA
These questions request recorded information, ensuring compliance with FOIA’s scope to avoid exemptions (e.g., section 31 for law enforcement, section 35 for government policy). They target evidence for our causes of action, contract opportunities, and mediation leverage across asylum, water, and steel sectors.

**To the Home Office**:
1. What data records UASC hotel placements (January 2024-June 2025) and non-compliance with Section 55 BCIA 2009?
2. What audits (2023-2025) address the July 2023 High Court ruling on unlawful UASC hotel housing?
3. What records detail asylum caseworker allocation and backlog targets (2024-2025)?
4. What cost-benefit analyses compare hotel vs. dispersal accommodation costs (2024-2025)?
5. What metrics and penalties are recorded for asylum contractors (2023-2025)?
6. What logs detail UASC missing from hotels (2018-2025) and follow-up actions?

**To HM Treasury**:
1. What assessments (2024-2025) evaluate National Insurance changes’ impact on charities, GP practices, hospices, and SMEs?
2. What analyses (2024-2025) assess inheritance tax changes’ impact on family farms?
3. What records (2024-2025) justify Listed Places of Worship funding reductions?
4. What documents (2024-2025) show Steel Industry Act subsidy compliance with UK subsidy control rules?

**To Ofwat**:
1. What PC/ODI reports (2023-2025) assess Thames Water’s pollution and leakage performance?
2. What enforcement actions (2023-2025) were taken against Thames Water for sewage discharges?
3. What PR24 consultation records (2024-2025) detail stakeholder responses?
4. What guidance (2024-2025) balances consumer protection and company viability?

**To the Environment Agency**:
1. What records (2023-2025) detail Thames Water’s sewage discharge incidents?
2. What protocols (2023-2025) govern Thames Water’s pollution monitoring?
3. What assessments (2023-2025) evaluate Thames Water’s discharge impacts?

**To the Department for Business and Trade**:
1. What impact assessments (2024-2025) evaluate the Steel Industry Act’s market and competition effects?
2. What records (April 2025) document consultations with steel industry stakeholders before the Act’s passage?
3. What correspondence (2024-2025) exists between DBT and CMA on British Steel’s market position?
4. What valuation reports (2025) assess British Steel’s assets for the Act’s compensation scheme (Clause 7)?
5. What records (2024-2025) detail alternative options considered before enacting the Steel Industry Act?

### FOIA Request Letter
[Your Name]
[Your Address]
[City, Postcode]
[Email Address]
[Date: July 19, 2025]

Freedom of Information Officer
Department for Business and Trade
Old Admiralty Building
London, SW1A 2DY
foi@businessandtrade.gov.uk

Dear Sir/Madam,

Under the Freedom of Information Act 2000, I request the following recorded information held by the Department for Business and Trade, or any relevant department to which this request should be forwarded per EU law obligations to ensure proper routing:

1. Impact assessments for the Steel Industry (Special Measures) Act 2025, including market and competition analyses, dated 2024-2025.
2. Records of consultations with stakeholders (e.g., steel competitors, Jingye Group) prior to the Act’s passage in April 2025.
3. Correspondence between DBT and the Competition and Markets Authority regarding British Steel’s market position in 2024-2025.
4. Valuation reports for British Steel’s assets under the Act’s compensation scheme (Clause 7) in 2025.
5. Records of alternative options considered (e.g., insolvency, NSI Act 2021) before enacting the Steel Industry Act in 2024-2025.

If this letter does not reach the intended recipient, please forward it internally to the relevant department, as required by EU law. I request a response within 20 working days, as stipulated by the FOIA. Please provide the information in electronic format where possible, sent to my email address above.

Yours sincerely,
[Your Name]

This FOIA request targets the DBT for steel-related documents, complementing prior requests for asylum and water sectors. It ensures disclosability by focusing on public interest data, avoiding exemptions. If you provide your name or additional details, I can further tailor the letter. Let me know how to proceed!

[Download the new report here: Unsolicited Opinion Strategic Report on the Steel Industry (Special Measures) Act 2025.docx](attachment://Unsolicited_Opinion_Strategic_Report_Steel_Industry_Act_2025.docx)

GROK’S SELF QUESTIONS

To improve our chances of winning the case, securing the contract, and succeeding in mediation related to the Steel Industry (Special Measures) Act 2025 in the UK, I have developed a list of strategic questions to ask key stakeholders. These questions are designed to uncover critical information that can strengthen our legal arguments—potentially involving illegal state subsidies, competition law violations, ECHR property rights, collective tort, misfeasance in public office, and breach of contract. Below, I’ve outlined each question, identified the person or group I would ask, and provided a list of possible answers we might receive, along with their potential implications for our strategy.

#### 1. To the Secretary of State for Business and Trade
– **Question**: “What specific economic data or projections were used to justify the necessity of the Steel Industry (Special Measures) Act 2025?”
– **Possible Answers**:
– “We relied on forecasts predicting significant job losses and economic decline in steel regions.”
– “National security concerns about steel supply chains were a key driver, supported by industry reports.”
– “The data was limited, but we acted based on urgency and stakeholder input.”
– **Implications**: This could reveal whether the Act’s foundation is robust or shaky. Weak or outdated data might support a Judicial Review challenge on grounds of irrationality.

#### 2. To a Member of the Parliamentary Committee that Reviewed the Act
– **Question**: “Were there any concerns raised about the potential for this Act to violate international trade agreements or competition laws?”
– **Possible Answers**:
– “Yes, some members warned about WTO and EU trade agreement risks, but they were overruled.”
– “No significant concerns were raised; we prioritized domestic industry over international rules.”
– “There was debate, but legal advice assured compliance.”
– **Implications**: Evidence of ignored risks could bolster our claims of illegal state subsidies and competition law breaches.

#### 3. To the CEO of British Steel
– **Question**: “How has the company’s financial situation changed since the implementation of the Act?”
– **Possible Answers**:
– “We’ve seen improved cash flow thanks to government support, but profitability remains a challenge.”
– “Despite the Act, we’re still struggling with debt and operational costs.”
– “The intervention has stabilized us, and we’re now competitive again.”
– **Implications**: Financial distress despite aid could undermine the Act’s purpose, while success might highlight market distortions—both useful for our competition law and subsidy arguments.

#### 4. To a Senior Executive at British Steel
– **Question**: “Have there been any changes in your relationships with suppliers or customers since the Act came into effect?”
– **Possible Answers**:
– “Some suppliers have raised prices or pulled out due to uncertainty.”
– “Customers prefer us now because of government backing, giving us an edge.”
– “We’ve had to renegotiate contracts, causing delays and disputes.”
– **Implications**: This could provide evidence of market disruption or contractual breaches, supporting our competition law and breach of contract claims.

#### 5. To a Representative of Jingye Group
– **Question**: “What is your current stance on the UK government’s intervention in British Steel?”
– **Possible Answers**:
– “We support it as it protects our investment.”
– “We’re neutral but seeking fair compensation for any losses.”
– “We oppose it and are considering legal action under the UK-China Bilateral Investment Treaty.”
– **Implications**: Their position could strengthen our ECHR property rights claim or reveal negotiation leverage for mediation.

#### 6. To an Executive from a Competing Steel Company (e.g., Tata Steel)
– **Question**: “How has the Steel Industry (Special Measures) Act 2025 affected your business operations and market position?”
– **Possible Answers**:
– “We’ve lost market share because British Steel gets preferential treatment.”
– “Pricing has become uncompetitive due to their subsidies.”
– “Our operations are largely unaffected, but we’re monitoring the situation.”
– **Implications**: Direct evidence of competitive harm would be critical for our competition law and illegal subsidy claims.

#### 7. To an Economist Specializing in Industrial Policy
– **Question**: “What are the potential long-term economic consequences of government intervention in the steel industry as outlined in the Act?”
– **Possible Answers**:
– “It could lead to inefficiency, reduced innovation, and a long-term taxpayer burden.”
– “The subsidies might stabilize the sector short-term but worsen global oversupply.”
– “If managed well, it could protect jobs without major economic downsides.”
– **Implications**: Negative forecasts could support our arguments about the Act’s irrationality and disproportionate impact in mediation or court.

#### 8. To a Competition Law Specialist
– **Question**: “In your opinion, does the Steel Industry (Special Measures) Act 2025 potentially violate UK or EU competition laws?”
– **Possible Answers**:
– “Yes, it distorts competition by favoring British Steel over rivals.”
– “It’s borderline but could breach the UK-EU Trade and Cooperation Agreement.”
– “No, it falls within state aid exceptions for national security.”
– **Implications**: An expert opinion of illegality would provide strong backing for our competition law claim.

#### 9. To a Trade Policy Analyst
– **Question**: “How might the Act impact the UK’s compliance with WTO rules or its trade relationships with key partners?”
– **Possible Answers**:
– “It risks WTO challenges from steel-exporting countries like China or India.”
– “The UK-EU Trade Agreement could be tested, especially on subsidy rules.”
– “It’s defensible under WTO national security exceptions, but tensions may rise.”
– **Implications**: International trade violations could enhance our illegal subsidy claim and pressure the government in mediation.

#### 10. To the Mediator (if in mediation)
– **Question**: “What are the key points of contention between the parties, and what common ground might exist for a resolution?”
– **Possible Answers**:
– “Compensation and market fairness are the main issues; stability might be a shared goal.”
– “Parties disagree on the Act’s legality but could align on environmental commitments.”
– “It’s a stalemate unless one side concedes on financial terms.”
– **Implications**: This insight could guide our mediation strategy, highlighting areas for compromise or pressure.

—

### Why These Questions Matter
These questions target critical aspects of the case:
– **Legal Weaknesses**: Probing the Act’s justification and compliance with laws could expose flaws for Judicial Review or competition claims.
– **Market Impact**: Answers from competitors and British Steel could prove unfair advantages or contractual issues.
– **Negotiation Leverage**: Insights from Jingye, experts, and the mediator could inform our mediation and contract strategies.
– **Public Interest**: Broader economic or trade consequences could sway public or judicial opinion.

By asking these questions and analyzing the responses, we can build a robust case, secure advantageous contract terms, and navigate mediation effectively. Let me know if you’d like additional questions or refinements!

SELF-QUESTIONS ON PROCUREMENT – NINJA

I’ll answer each procurement-focused question I created, providing a range of possible solutions and identifying the most viable approaches based on the Steel UK case materials.

  1. What specific mechanisms exist within your department for considering unsolicited proposals that address urgent policy challenges outside the standard competitive tendering framework?

Public officials would likely respond that while standard procurement routes are preferred, several mechanisms exist for exceptional circumstances. They might mention the Crown Commercial Service’s ability to make direct awards in cases of extreme urgency, the provision for “negotiated procedure without prior publication” under Regulation 32 of the Public Contracts Regulations, or the option to commission a small-scale initial scoping study below financial thresholds requiring competitive tendering.

The most viable solution is to propose a two-stage approach: first, a below-threshold direct award for an initial assessment (under £10,000) that would establish our unique expertise and the value we bring. This “preliminary risk and compliance assessment” would identify specific issues requiring further work. The findings from this initial engagement would then justify a subsequent contract through a negotiated procedure without prior publication, based on our demonstrated unique knowledge and intellectual property. This approach minimizes procurement risk for officials while establishing our credibility and creating a pathway to a larger engagement.

  1. How is your department currently managing the potential conflict between the government’s role as both regulator and market participant in the steel industry?

Officials would likely acknowledge this challenge while emphasizing existing safeguards such as departmental separation of functions, adherence to Managing Public Money guidelines, and ongoing consultation with legal advisors. They might mention plans to establish an arm’s-length management structure for the state-controlled entity.

The most viable solution is to propose a formal governance framework that establishes clear separation between the government’s ownership and regulatory functions. This would include an independent oversight board with industry experts, transparent reporting mechanisms, and a clear mandate to operate on commercial terms. Our proposal would emphasize that this structure not only protects against conflicts of interest but also strengthens the government’s position in any future legal challenges by demonstrating procedural propriety. By framing this as enhancing rather than criticizing their current approach, we position ourselves as constructive problem-solvers rather than critics.

  1. What ongoing assessment methodology is being used to quantify the government’s contingent liabilities under the Steel Industry (Special Measures) Act?

Treasury officials would likely provide a general answer about standard contingent liability assessment frameworks and departmental risk registers, while emphasizing that specific methodologies are being developed. They might mention engagement with the Government Actuary’s Department or external advisors.

The most viable solution is to propose a comprehensive liability mapping and quantification framework specifically tailored to the unique aspects of the Steel Act intervention. This would include modeling potential competition law claims from competitors, investment treaty claims from Jingye, contractual claims from affected suppliers and customers, and environmental liabilities. By demonstrating how our approach goes beyond standard Treasury methodologies to address the specific legal and commercial complexities of this case, we position our services as complementary to existing government capabilities rather than duplicative.

  1. What formal protocols have been established to ensure the state-controlled British Steel operates with sufficient independence to prevent distortions in the wider steel market?

CMA officials would likely mention general competition law compliance requirements while acknowledging that specific protocols for this unprecedented situation are still evolving. They might reference ongoing discussions about appropriate safeguards and monitoring mechanisms.

The most viable solution is to propose a formal “Competition Compliance Protocol” that establishes clear boundaries between government and operational management. This would include transparent pricing methodologies, non-discrimination requirements for customer access, regular independent market impact assessments, and a formal complaints procedure for competitors or customers who believe they face unfair treatment. By framing this as supporting the CMA’s mission while acknowledging their resource constraints, we position our services as enhancing their oversight capacity rather than questioning their authority.

  1. What specific metrics and reporting frameworks have been established to evaluate whether the intervention is achieving its stated policy objectives while minimizing market distortion?

Parliamentary committee staff would likely acknowledge that comprehensive metrics are still being developed, while mentioning general reporting requirements such as departmental annual reports and periodic statements to Parliament.

The most viable solution is to propose an “Intervention Effectiveness Framework” with clear, measurable indicators across multiple dimensions: financial performance, supply chain security, employment outcomes, environmental compliance, and competitive market effects. This framework would include regular public reporting and independent verification. By emphasizing how this approach enhances parliamentary scrutiny and public transparency, we align our proposal with the committee’s oversight responsibilities while offering a concrete solution to a recognized gap.

  1. How are you balancing the need for confidentiality in ongoing negotiations with Jingye against transparency obligations under administrative law and parliamentary scrutiny requirements?

Legal department officials would likely emphasize the importance of protecting commercially sensitive information during negotiations while acknowledging their obligations under Freedom of Information legislation and to Parliament. They might mention standard redaction protocols and confidentiality agreements.

The most viable solution is to propose a structured “Transparency and Confidentiality Framework” that categorizes information into tiers with different disclosure protocols. This would include identifying which aspects of negotiations can be publicly disclosed, which require redaction of specific elements, and which must remain fully confidential for defined periods. By demonstrating how this approach helps navigate competing legal obligations while maintaining public trust, we position our services as solving a complex governance challenge they face.

  1. Given the unique and unprecedented nature of this intervention, what provisions exist for engaging specialized expertise that may not fit within standard framework contracts or pre-qualified supplier lists?

Procurement officials would likely mention options such as the Crown Commercial Service’s Management Consultancy Framework, the possibility of running a bespoke competitive procedure, or the provisions for direct award in exceptional circumstances under Regulation 32.

The most viable solution is to propose an initial engagement through an existing framework where we are already listed (if applicable) or through a small-scale direct award below competitive thresholds. This would allow us to demonstrate our unique value while giving procurement officials a low-risk path to engage our services. For longer-term work, we would propose helping them design a bespoke competitive procedure that properly captures the specialized expertise required, positioning ourselves advantageously for that competition based on our demonstrated understanding of their needs.

  1. What mechanisms are in place to capture and incorporate feedback from affected stakeholders across the steel supply chain as implementation progresses?

Operational teams would likely mention ad hoc industry consultations, existing trade association relationships, and standard stakeholder management approaches. They might acknowledge that a more structured approach is still developing.

The most viable solution is to propose a formal “Steel Industry Stakeholder Council” with representation from across the supply chain: raw material suppliers, the workforce, downstream customers, local communities, and environmental interests. This council would have a defined role in providing input on operational decisions and monitoring impacts. By emphasizing how this approach reduces implementation risks and builds broader support for the intervention, we position our services as enhancing the government’s existing stakeholder engagement while addressing a recognized need.

  1. How are you managing communications with trading partners who may view this intervention as potentially distorting international steel markets?

International relations officials would likely mention diplomatic channels, WTO notifications, and ongoing dialogue with key trading partners. They might emphasize the national security justification for the intervention.

The most viable solution is to propose a “Trade Relations Strategy” specifically focused on the steel intervention. This would include preparing robust defenses against potential WTO challenges, developing clear messaging that emphasizes the temporary and targeted nature of the intervention, and creating a diplomatic engagement plan prioritizing key steel-producing nations. By demonstrating how this approach helps prevent trade disputes while protecting the UK’s broader trading relationships, we position our services as addressing a significant international risk they face.

  1. What is your exit strategy for returning British Steel to market-based operation, and what independent expertise would help ensure this transition maximizes value for taxpayers while minimizing market disruption?

Senior officials would likely provide a general answer about the government’s intention to return the company to private ownership when conditions allow, while emphasizing that specific plans are still being developed as they assess the company’s situation.

The most viable solution is to propose developing a comprehensive “Transition to Market Framework” with clear milestones, decision points, and success criteria. This would include options analysis for different ownership models (full privatization, public-private partnership, employee ownership components), market testing protocols, and a structured process for evaluating potential investors or partners. By emphasizing how this approach provides a responsible path to fulfilling ministerial commitments while protecting taxpayer value, we position our services as essential to achieving the government’s own stated objectives.

These responses demonstrate how COCOO can position itself as offering solutions to recognized challenges rather than simply identifying problems. By acknowledging existing efforts while proposing specific enhancements that draw on our unique expertise, we increase the likelihood that our unsolicited proposal will be viewed as a valuable and necessary addition to the government’s capabilities in managing this complex intervention.

SELF-QUESTIONS ON COMPENSATION – NINJA

I’ll answer each question I created, providing a range of possible solutions and identifying the most viable ones based on the Steel UK case materials.

  1. What formal options appraisal was conducted comparing the Steel Industry (Special Measures) Act 2025 with existing frameworks?

The UK government would likely respond that the extreme urgency of the situation necessitated immediate action, claiming that British Steel’s threatened closure represented an imminent economic and security threat that precluded a standard options appraisal. They might argue that existing frameworks like the Civil Contingencies Act had too narrow criteria or that the Subsidy Control Act lacked sufficient powers for direct intervention.

The most viable solution is to challenge this justification by demonstrating that the crisis was foreseeable for months, not a sudden emergency. We would argue that the absence of a formal appraisal reveals a procedural failure that undermines the entire intervention. In court, this becomes a strong ground for judicial review based on procedural impropriety. In our mediation role, we would use this procedural deficiency as leverage to negotiate stronger transparency and oversight mechanisms for the ongoing operation of the state-controlled entity.

  1. What financial modeling has been conducted to quantify the maximum potential liability to taxpayers?

The government would likely claim that detailed financial projections are commercially sensitive and that releasing them would undermine the state’s negotiating position with suppliers and customers. They would argue that the cost of intervention, however large, is justified compared to the catastrophic economic impact of allowing the UK’s primary steel industry to collapse.

Rather than becoming entangled in a protracted battle for disclosure, the most viable solution is to commission our own independent economic analysis. By creating a comprehensive “shadow impact assessment” that models potential costs including subsidies, compensation to Jingye, operational losses, and economic distortion effects, we can seize the narrative. This analysis would provide media, parliamentary committees, and potential class members with credible figures about the “blank check” the government has written, creating pressure for a negotiated settlement that includes financial accountability measures.

  1. How does the government justify the absence of a sunset clause despite assurances of temporary powers?

The government would likely argue that including a rigid sunset clause would create market uncertainty and potentially force a premature divestment that could destabilize the industry again. They might claim that ministerial assurances provide sufficient political accountability without legally binding time constraints.

The most viable solution is to use this contradiction to strengthen our judicial review case by highlighting the irrationality of granting permanent powers for a temporary problem. In mediation, we would propose a compromise: a staged transition plan with clear milestones and performance metrics that, when achieved, would trigger a phased withdrawal of state control. This approach addresses the government’s concern about market stability while ensuring the intervention doesn’t become permanent by default.

  1. What safeguards ensure the state-controlled British Steel operates without distorting competition?

The government would likely point to general commitments to operate the company on “commercial terms” and reference existing competition law as sufficient safeguards. They might argue that the strategic importance of maintaining domestic steel production justifies some market impact.

The most viable solution is to propose a specific, independent oversight mechanism dedicated to monitoring competitive effects. This would include regular market impact assessments by independent economists, a transparent pricing methodology for British Steel products, and a formal complaints procedure for competitors and customers who believe they face unfair treatment. In court, the absence of such safeguards strengthens our argument about the disproportionate nature of the intervention. In mediation, establishing this oversight body could be a key component of a settlement acceptable to all parties.

  1. What commercial documentation demonstrates Jingye’s threat was based on genuine business necessity?

Jingye would likely claim commercial confidentiality protects their internal analyses while arguing that UK industrial costs made operations unsustainable without significant government support. They would frame their actions as rational business decisions rather than negotiating tactics.

The most viable solution is to pursue a formal Competition and Markets Authority investigation, which carries discovery powers that could compel disclosure of these documents. Simultaneously, our public campaign should acknowledge the genuine economic challenges facing the UK steel industry while maintaining that the specific method chosen—threatening immediate shutdown of a strategic national asset—potentially constituted an abuse of dominant position. This balanced approach positions us as reasonable while maintaining pressure for accountability.

  1. Did Jingye consider the competition law implications of threatening to withdraw supply?

Jingye would likely claim they were exercising legitimate business judgment in response to financial losses, not leveraging market power. They might argue that competition law doesn’t obligate a company to operate at a loss indefinitely.

The most viable solution is to file a formal complaint with the CMA alleging abuse of dominant position. Our argument would focus on the timing and manner of the threat rather than Jingye’s right to eventually exit an unprofitable market. By highlighting the abrupt nature of the threatened closure and its potentially catastrophic impact on downstream industries with no reasonable time to secure alternative supplies, we can distinguish between legitimate business restructuring and potentially abusive conduct designed to extract concessions.

  1. What valuation methodology should be applied to determine fair compensation?

Jingye would argue for a “going concern” valuation that considers the strategic importance of the assets and future earnings potential under proper management. They would reject the government’s “zero or negligible value” assessment as politically motivated expropriation.

The most viable solution is to propose an independent valuation panel with experts nominated by both sides and a neutral chair. This panel would apply internationally recognized standards that balance Jingye’s investment with the company’s actual financial condition. In mediation, we could suggest a structured compensation package that includes an immediate payment based on tangible asset value plus contingent payments tied to the future performance of the business under state control. This approach shares risk between taxpayers and Jingye while providing a path to fair compensation.

  1. What environmental and safety protocols have been established under state control?

The new management would likely point to existing regulatory frameworks and general commitments to maintain standards, possibly highlighting planned investments in modernization that would improve environmental performance.

The most viable solution is to establish an independent Environmental and Safety Assurance Board with representation from local communities, environmental experts, and worker representatives. This board would have access to operational data, conduct regular inspections, and publish transparent reports. For our potential tort claim, documenting the current baseline of environmental and safety conditions creates crucial evidence. In mediation, creating this board could address community concerns while providing an early warning system for potential issues before they become liabilities.

  1. How will transparent and non-discriminatory access to products be ensured?

State-controlled British Steel would likely claim they will continue to operate on commercial terms with established customers and that normal market mechanisms will ensure fair access.

The most viable solution is to establish a formal Supply Chain Access Protocol that includes transparent pricing methodologies, published capacity allocation procedures, and an independent appeals process for customers who believe they’ve been treated unfairly. This would prevent the state-controlled entity from favoring certain customers for political reasons or using its position to impose anti-competitive terms. In mediation, this protocol could be a key element that reassures downstream industries while allowing the government to maintain its strategic control.

  1. Can downstream industries quantify the economic harm from supply chain uncertainty?

Affected businesses would likely describe significant impacts including emergency sourcing of alternative supplies at premium prices, production delays, contract penalties, and deferred investments due to uncertainty.

The most viable solution is to commission a structured economic impact assessment across key sectors, creating a comprehensive dataset of specific harms. This would strengthen any potential collective action by establishing a clear causal link between Jingye’s conduct and quantifiable damages. For our mediation role, this assessment would provide crucial leverage by demonstrating the scale of potential liability, encouraging all parties to reach a settlement rather than face protracted litigation.

  1. What ongoing competitive disadvantages do downstream industries anticipate?

Affected businesses would likely express concerns about potential price distortions, preferential allocation of scarce products to politically favored sectors, reduced innovation due to lack of competitive pressure, and long-term uncertainty about the government’s exit strategy.

The most viable solution is to establish a formal Downstream Industry Advisory Council that meets regularly with British Steel’s management and government representatives to address concerns and provide market feedback. This council would have formal input into major decisions affecting product availability, pricing, and investment priorities. In mediation, creating this structure would give downstream industries a voice in the ongoing operation while providing the government with valuable market intelligence to guide its stewardship.

  1. How has the intervention affected long-term investment planning?

Businesses would likely report significant disruption to capital investment plans, with projects delayed or canceled due to uncertainty about future steel availability and pricing. Some might have shifted to alternative materials or offshore suppliers to reduce dependency on UK steel.

The most viable solution is to develop a Steel Supply Security Framework that provides downstream industries with medium-term visibility on availability and pricing parameters. While not guaranteeing specific prices, this framework would establish boundaries of predictability that enable better investment planning. In mediation, this approach balances the government’s need for flexibility with industry’s need for stability, creating a workable compromise.

  1. How can competing interests be reconciled without a comprehensive settlement?

Each party, responding individually, would likely focus narrowly on their own interests: the government on minimizing taxpayer exposure, Jingye on maximizing compensation, competitors on eliminating unfair advantages, and downstream industries on supply security.

The most viable solution is to position COCOO as the only entity with a comprehensive understanding of all dimensions of the dispute. We would demonstrate that piecemeal resolution through separate legal proceedings would be inefficient, expensive, and likely suboptimal for all parties. By showing how our proposed mediation framework addresses each party’s core concerns while finding creative compromises on secondary issues, we make a compelling case for our appointment as the official mediator.

  1. What expertise would be required from an effective mediator?

Parties would likely identify needs for expertise in competition law, international trade rules, industrial policy, valuation methodologies, and environmental regulation—precisely the multidisciplinary knowledge that COCOO possesses.

The most viable solution is to present COCOO’s unique combination of legal, economic, and technical expertise specifically relevant to this case. We would emphasize our deep understanding of the steel industry’s supply chain dynamics, our familiarity with both domestic and international legal frameworks governing state intervention, and our experience with complex multi-party disputes. By demonstrating that we have already conducted extensive analysis of all aspects of the case, we position ourselves as the most efficient and effective choice to facilitate a comprehensive settlement.

SELF-QUESTIONS ON COMPENSATION – GEMINI

The first question, directed at the UK government, concerns the lack of a formal options appraisal comparing the Steel Act to the use of established frameworks like the Civil Contingencies Act 2004. The government’s probable response would be to assert that the extreme urgency of the situation, created by the irrational conduct of a private company, rendered a standard, time-consuming options appraisal unfeasible. They would argue that the Civil Contingencies Act was deemed unsuitable as its strict criteria were not met, and that bespoke legislation with direct Parliamentary consent was the most robust and democratic route available.

Our range of solutions in response is clear. The most viable strategy is to reject their justification of urgency as a sufficient excuse for abandoning due process. We will argue in court, and in our public campaign, that the crisis was foreseeable for months and that the lack of a formal, evidence-based appraisal is proof of a reactive and flawed decision-making process. In mediation, this glaring procedural failure becomes a key point of legal risk for the government, providing us with leverage to insist on a settlement that includes future transparency and independent oversight to correct for this initial deficit.

The second question, also to the government, asks for the internal financial modelling that quantifies the taxpayer’s maximum potential liability under the Act. The expected answer is that such modelling is commercially and legally privileged, and that in any event, the cost of the intervention was deemed far less than the catastrophic economic cost of allowing the UK’s primary steel industry to collapse.

Our most potent solution here is not to become bogged down in a legal battle over disclosure, but to commission our own independent economic analysis. We will create a “shadow impact assessment” that models the potential long-term costs of the government’s intervention, including subsidies and the economic harm from market distortion. By publishing this report, we seize control of the narrative, providing the media, the public, and parliamentary committees with a credible, tangible estimate of the “blank cheque” the government has signed. This forces the government onto the defensive and creates immense pressure for them to justify their financial commitments in a mediated settlement.

The third question, aimed at Jingye Group, asks for the commercial justification that proves their threat to cease operations was a necessary business decision rather than an anti-competitive negotiating tactic. Their likely response will be that all their internal analyses are commercially confidential. They will argue that their actions were a rational commercial response to the punitive industrial costs in the UK, which made the operation loss-making and unsustainable, and that preparing for closure was a necessary step to prevent further financial damage.

Our most viable strategy here is to push for a formal investigation by the Competition and Markets Authority. While we cannot obtain the documents directly, a CMA investigation carries the power of discovery, which could compel their disclosure. In parallel, our public campaign can acknowledge the genuine economic pressures faced by the industry, thereby appearing reasonable, while continuing to assert that the specific method chosen—threatening a catastrophic shutdown of a national strategic asset—was an abuse of a dominant position. In mediation, this allows us to frame a solution where their commercial grievances can be addressed as part of a settlement that also holds them accountable for their anti-competitive conduct.

Finally, the fourth question asks all parties how they can possibly resolve their individual disputes without a global, mediated settlement. The likely response from each party, in isolation, would be to focus on their own narrow interests, thereby proving our point. The most viable solution, and indeed the entire purpose of asking the question, is for Cocoo to use this inevitable, conflicting response as the final, definitive argument for our appointment as the official mediator. We will demonstrate that we are the only party that has analyzed all the interlocking issues and that we alone have proposed a holistic framework for resolving them. Our Unsolicited Proposal for mediation thus becomes the only logical and credible path forward out of the impasse that our strategic questions have so clearly revealed.

COCOO’S ROLE

Of course. The provided texts significantly enhance and refine our strategic position in the Steel UK case. They equip us with a more sophisticated legal argument, expand our operational capabilities into the diplomatic sphere, and provide a framework for a powerful new intelligence-gathering initiative.

The first document, detailing COCOO’s international diplomatic services, allows us to address the significant geopolitical fallout from the government’s intervention. The Steel Act could easily be perceived by the European Union and other trade partners as a protectionist measure, potentially triggering retaliatory actions or jeopardising wider trade relations. We can now formally position COCOO as an expert intermediary capable of managing this fallout. We can propose to the UK government, or to affected UK industries, our services to navigate the political currents in Brussels, arguing that the Steel Act was a unique and necessary response to an extraordinary situation, not a shift in trade policy. This service of de-escalating international trade disputes and ensuring the stability of existing agreements is a new and valuable dimension to our engagement.

The second text, which outlines the legal principle distinguishing the “nation” from the actions of a specific “government,” provides a powerful new foundation for our entire case. We can now build our legal argument on the doctrine of ultra vires, contending that the Steel Act was an act beyond the lawful authority of the current government administration. In any international forum, such as a WTO dispute, we can argue that retaliatory measures should not be taken against the UK as a nation for the allegedly unlawful actions of a transient government. Domestically, this hugely strengthens our Judicial Review case, as we are not challenging the state’s sovereignty but holding the government accountable for overstepping its constitutional and statutory limits. Furthermore, it introduces the critical concept of the personal liability of government officials, which becomes a powerful narrative for our media campaign, arguing that the individuals responsible for this flawed legislation, not the taxpayer, should be held accountable.

Finally, the third document allows us to sharpen our mediation strategy and launch a new, proactive intelligence-gathering operation. It positions COCOO not just as a mediator, but as an essential facilitator when parties, such as the UK government and Jingye, become entrenched in a seemingly intractable dispute. We can now frame our mediation offer as the only viable pathway to a holistic settlement. Most importantly, this text gives us the explicit mandate to act as a trusted ally to whistleblowers. We can now initiate a “Steel UK Whistleblower Project,” actively encouraging individuals with insider knowledge—whether from the civil service, British Steel, or competitor firms—to come forward. We will offer them our expertise to ensure their information is reported to the correct authorities, such as the CMA or the Registrar of Consultant Lobbyists, while safeguarding their identity and helping to secure any available leniency or settlement. This transforms our role from a reactive analyst of public information to a proactive gatherer of direct evidence concerning the flawed decision-making and potential improper conduct at the heart of this case.

CONTACTS (STAKEHOLDERS)

The primary entities whose actions are the subject of our potential causes of action are, of course, the UK Government, specifically the Department for Business and Trade and HM Treasury, and the private company Jingye Group as the owner of British Steel.

The horizontal competitors who are most directly harmed by the government’s alleged market-distorting intervention operate in the same sector as British Steel. In the United Kingdom, the most significant competitor is Tata Steel UK, which has its own major operations and faces direct, unfair competition from a state-subsidised entity. In the wider European market, which supplies the UK, key horizontal stakeholders include global steel giants like ArcelorMittal, which has significant production facilities in Spain, and major German producers such as ThyssenKrupp and Salzgitter AG. These companies represent a class of competitors whose UK-focused business is directly undermined.

The potential class members for a compensation claim are found in the downstream vertical markets. These are the industrial consumers of steel who were immediately harmed by the supply chain uncertainty and now face the long-term risks of a distorted market. Within the UK automotive sector, this includes major manufacturers like Jaguar Land Rover, Nissan, and BMW. In the defence and aerospace industry, critical end-users include prime contractors such as BAE Systems and Rolls-Royce. The construction sector is also a primary vertical stakeholder, including major UK firms like Balfour Beatty and Morgan Sindall, who rely on steel for major infrastructure projects.

The upstream vertical stakeholders include the global corporations that supply the essential raw materials for primary steel production. This group is dominated by major mining companies that produce iron ore and coking coal. Publicly listed entities such as Rio Tinto, BHP Group, and Anglo American are key players in this market and would have been directly affected by any disruption to their supply contracts with British Steel.

While I have identified these specific corporate entities, I cannot provide individual contact names or email addresses. This information is protected for privacy and security reasons. However, the general corporate contact details for these firms are typically available on the ‘Contact Us’ or ‘Investor Relations’ pages of their official corporate websites. This will be the appropriate and compliant channel for any future outreach as part of our campaign or mediation projects.

MEDIATION

First, we must reframe the situation not as a simple problem requiring a government contractor, but as a complex, multi-party dispute that is becoming increasingly intractable through traditional adversarial processes. The current landscape involves a series of interlocking conflicts: the UK government is in dispute with Jingye Group over control and compensation; it is in potential conflict with competitor firms and international trade partners over illegal subsidies and market distortion; it faces pressure from downstream industries over supply chain security; and it carries the risk of a future dispute with the local community over environmental and safety standards. Protracted litigation on any single one of these fronts will be extraordinarily costly and unlikely to produce a sustainable, holistic solution.

Our Unsolicited Proposal will therefore present a structured mediation process as the only viable path to an efficient and durable resolution. We will position Cocoo as the uniquely qualified neutral third-party to facilitate this process. Our core justification is that through our extensive investigation, we have developed an unparalleled, impartial understanding of the complex legal, economic, and political interests of every stakeholder involved. This deep, pre-existing knowledge is our unique value proposition; we are not simply mediators, but expert facilitators who understand the substantive issues from all perspectives.

The first step in our proposed process is to secure a voluntary “Agreement to Mediate” from the principal parties, namely the UK Government and the representatives of Jingye Group and British Steel. This agreement would commit them to a confidential, non-binding dialogue facilitated by Cocoo.

The second step involves a series of private caucuses. We will meet confidentially with each key stakeholder group we have identified—the government, British Steel’s owners, representatives from competitor firms, delegates from the downstream industrial consumers, and community leaders. The purpose of these meetings is to move beyond public posturing and identify each party’s core underlying interests, priorities, and potential areas of compromise.

The third step will be to convene structured, joint mediation sessions focused on specific, solvable issues. For example, one session might focus exclusively on establishing a fair and objective valuation methodology for compensation. Another might be dedicated to designing a new corporate governance and oversight structure for the state-controlled entity to ensure it operates on a commercial and pro-competitive basis. A further session would focus on creating a community-led environmental and safety assurance fund.

The final and ultimate step of this process is to guide all parties towards a single, comprehensive Settlement Agreement. This legally binding contract would resolve all facets of the dispute simultaneously. For instance, it could establish the final compensation for Jingye, contingent on their cooperation and transfer of knowledge. It would also contain binding commitments from the UK government regarding the future operation of British Steel, including safeguards against market distortion, and it would formalise the new environmental and safety protocols for the benefit of the community. This transforms a complex web of conflicts into a single, mutually agreeable solution, a service that only a well-informed, neutral mediator can provide. Our USP will formally propose this framework and invite the principal parties to an initial confidential meeting to discuss its implementation.

LOBBYING

Based on my analysis of the new files concerning lobbying and All-Party Parliamentary Groups (APPGs), we can now add a powerful and precise new dimension to our case. These documents provide the theoretical framework, the specific mechanisms, and the legal standards to investigate whether the government’s decision to enact the Steel Industry (Special Measures) Act was the product of improper influence and regulatory capture.

The document on the externalities of lobbying provides the core theory for this new line of attack. I extracted the principle that lobbying, far from being a benign part of the policy process, can lead to “policy capture,” where legislative outcomes serve the narrow commercial or political interests of a small group rather than the wider public interest. This results in inefficient policies that create artificial advantages for the lobbying party at the expense of competition, innovation, and consumer welfare. For our case, this allows us to argue that the Steel Act should not be viewed as a good-faith, if flawed, attempt to solve a problem, but potentially as the result of a captured policy process. For our campaign, this is a profound shift in narrative, from one of government incompetence to one of potential improper influence.

The papers on All-Party Parliamentary Groups are perhaps the most significant extraction, as they provide a concrete mechanism through which this policy capture may have occurred. I extracted the critical information that APPGs can be used as a “backdoor” for lobbying, providing privileged access and influence for commercial interests, including foreign entities, in a manner that can lack transparency and bypass formal, registered lobbying channels. This is an immediately actionable insight. For our case, it gives us a clear direction for investigation. We can now scrutinise the registers and activities of any APPGs related to the steel industry, manufacturing, energy, or UK-China relations to identify who was funding them and meeting with them in the lead-up to the crisis. Evidence of undisclosed influence would form a cornerstone of the procedural impropriety grounds in our Judicial Review. For our media campaign, the concept of secret lobbying through parliamentary groups is an exceptionally compelling and easily understood story of insider dealing.

The consultation document on lobbying breaches provides the legal teeth for this new investigative angle. I extracted the specific definitions of what constitutes a breach of lobbying rules, such as a failure to register or the provision of inaccurate information. This is crucial because it transforms our investigation from a general inquiry into a focused search for specific, actionable violations of UK law. If our research uncovers conduct that meets these definitions, it allows us to file a formal complaint with the Registrar of Consultant Lobbyists. A confirmed breach would provide objective, damning evidence for both our legal case and our public campaign, demonstrating that the process leading to the Steel Act was not just rushed, but potentially unlawful.

Finally, the paper on lobbying for intellectual property and other industrial policies allows us to connect this narrative of improper influence to a specific, tangible harm. It shows how lobbying is used to shape innovation policy and direct public funds. For our case, we can now argue that any lobbying by the incumbent steel industry may have been designed not only to secure a bailout but also to influence the future allocation of the £2.5 billion Clean Steel Fund, potentially steering it towards their preferred technologies at the expense of more innovative market entrants. This strengthens our argument that the government’s intervention serves to entrench the incumbent and stifle the very innovation the UK needs. In any mediation, the threat of exposing these lobbying activities provides us with significant new leverage, pushing the government to accept a settlement that ensures far greater transparency and fair competition in the future.

COAS

Based on our comprehensive analysis, the situation surrounding the Steel Industry (Special Measures) Act 2025 gives rise to a complex web of potential causes of action, in both tort and contract, involving the public sector and private entities. These avenues provide numerous points of leverage for our case, campaign, and mediation efforts.

The principal causes of action against the public sector, namely the UK Government, are grounded in public and administrative law. The most direct challenge is a Judicial Review of the decision to enact the Steel Act. The grounds for this are that the government may have acted unlawfully by failing to follow proper procedure, by choosing powers that are disproportionate and irrational, and by improperly diverging from the established legal frameworks for handling such crises without adequate justification. A specific tort claim for Misfeasance in Public Office could also be contemplated, although this would require the very high standard of proving that officials acted with malice or knowingly exceeded their powers with the intent to cause harm. While a direct claim in negligence against the government for the economic consequences is unlikely to succeed due to the difficulty of establishing a duty of care, the government has exposed itself to future tort liability. By taking control of an industrial asset, it has effectively underwritten the risk of any future environmental or safety failures, and could be pursued under a collective tort claim alongside the operator should such an incident occur. In contract law, the government’s primary vulnerability is that if the Steel Act is found to be unlawful via Judicial Review, any contracts it subsequently enters into for the management or supply of the steelworks could be declared void for being ultra vires, as they would be based on illegal authority.

The potential causes of action against the private sector, primarily Jingye Group for its past conduct and the new state-controlled British Steel for its future conduct, are equally significant. The most powerful cause of action is a competition law claim for Abuse of a Dominant Position against Jingye. This statutory tort would be based on allegations that Jingye leveraged its monopoly on primary steel production to threaten a refusal to supply and to make exploitative demands, thereby harming the entire downstream market. In contract law, Jingye’s alleged threat to cease purchasing raw materials would have exposed it to claims for breach of contract from its upstream suppliers in the commodities and mining sectors. Similarly, any failure to supply its customers would have resulted in breach of contract claims from downstream businesses in the construction and automotive industries. Looking forward, the new state-controlled British Steel entity could face future legal action. Any attempt to impose unfair terms on its customers could be challenged as anti-competitive vertical restraints, rendering those contract clauses void. Finally, as the operator of a hazardous facility, the entity remains exposed to a collective tort claim from the local community for any environmental or safety harms under the doctrine of strict liability.

FOIS

Of course. Based on an online search for relevant precedents and analogous findings, we can identify several established examples of “Findings of Infringement” (FOIs) that support each of our potential causes of action. While we cannot find FOIs for the Steel Act itself, these precedents demonstrate that the legal principles we intend to rely upon are robust and have been successfully applied in UK and international forums. This provides a strong foundation for any follow-on claims we or our allies might pursue.

Regarding our planned Judicial Review of the government’s action, there is a powerful and recent precedent in the successful legal challenges brought by ClientEarth against the UK government’s Net Zero Strategy. The High Court has twice ruled that the government’s climate plan was unlawful because it was based on vague and uncertain proposals and that the Secretary of State had acted irrationally. This establishes that the courts are willing to rigorously scrutinise government policy and find it unlawful when it fails to meet the specific requirements of the underlying statute and is not based on a credible, evidenced plan. This provides a direct blueprint for our case, where we will argue that the Steel Act, a similarly critical piece of economic and industrial policy, was rushed through with an irrational lack of detail, scrutiny, and consideration for alternatives.

For our competition law claim of Abuse of a Dominant Position by Jingye, we can point to numerous infringement decisions by the Competition and Markets Authority (CMA) and its predecessors. The ongoing cases concerning excessive and unfair pricing in the pharmaceutical sector are a strong analogue for the exploitative aspect of Jingye’s alleged conduct. In these cases, the CMA found that dominant firms unlawfully used their market power to charge excessive prices to the NHS. This directly supports our argument that Jingye’s alleged demand for huge, unconditional sums of money to continue operating was a form of exploitative abuse. Furthermore, recent European court rulings have confirmed that a dominant company’s refusal to supply an essential service or technology to competitors can constitute an abuse, which strengthens our argument that Jingye’s threatened shutdown was a form of constructive refusal to supply the essential product of primary steel.

In relation to an Illegal State Aid challenge, the key is to demonstrate that the government’s intervention distorts competition. While the UK’s new subsidy control regime is recent, the principles are well-established. The most relevant findings come from the Competition Appeal Tribunal’s power to review such subsidies. The guidance on the Subsidy Control Act confirms that interested parties, such as competitors, can challenge a public authority’s decision if it is incompatible with the core principles of minimising market distortion. The fact that the Tribunal has the power to declare a subsidy unlawful and order its recovery provides a clear basis for a follow-on claim by a competitor who has been harmed by the state’s support for British Steel.

For the potential collective tort claim for environmental or safety harm, we can point to the successful group litigation that followed the 2005 Buncefield oil depot explosion. In that case, the High Court found the operating company liable for the massive damage caused to local residents and businesses. This serves as a powerful precedent for establishing that operators of hazardous industrial sites can be held liable for damages on a collective basis. This supports our position that any future safety or environmental failure at the state-controlled steelworks could lead to a major, and successful, group litigation order against the operator.

Finally, regarding the cause of action for improper lobbying and undue influence, the findings of the inquiry into the Greensill Capital scandal provide a wealth of evidence. That case exposed systemic problems in the way commercial interests can gain privileged access to senior government officials, bypassing formal rules. The inquiries found a significant lack of judgment and highlighted that the existing rules were insufficiently strong. This precedent is invaluable for our campaign and any complaint to the parliamentary standards authorities. It establishes a clear public interest in scrutinising the relationship between government and business, and it provides a powerful narrative to argue that the rushed and opaque process surrounding the Steel Act may have been the result of similar back-channel influence.

FOREIGN DIMENSIONS

Based on a detailed search, we can identify several other jurisdictions and specific foreign companies that are likely to have been affected by, or are relevant to, the actions of the perpetrators in our Steel UK case. These international dimensions open up new fronts for our campaign and identify potential allies who may have an interest in pursuing legal or diplomatic action.

The most significant jurisdiction with a direct stake in this matter is undoubtedly India, primarily through the major industrial conglomerate Tata Group, the owner of Tata Steel. Tata Steel is the UK’s other major steel producer, with significant operations in Port Talbot, Wales. The UK government’s intervention to save British Steel directly impacts Tata as a horizontal competitor. Any subsidy or operational advantage granted to the state-controlled British Steel creates an unlevel playing field, directly harming Tata’s commercial viability in the UK. Furthermore, the parliamentary debates we have reviewed show that the government’s different handling of the situations at Port Talbot and Scunthorpe is a major point of political contention. Tata, therefore, is a critical party of interest. Its home state, India, could have grounds to challenge the UK’s actions as a discriminatory subsidy at the World Trade Organization.

Several European Union member states are also key jurisdictions. Countries such as Germany, Spain, and the Netherlands are major exporters of steel to the UK. Companies within these nations, such as ThyssenKrupp in Germany or ArcelorMittal, which has extensive European operations, are also horizontal competitors. The UK’s subsidisation of its domestic production could be seen to displace their imports, giving these companies, and by extension their home governments and the EU itself, a strong interest in challenging the UK’s actions under the subsidy provisions of the UK-EU Trade and Cooperation Agreement or at the WTO.

Looking at the upstream supply chain, the primary suppliers of raw materials like iron ore are often based in Australia and Brazil, with global mining giants like BHP and Vale being key players in the market. While their contracts may be global, any decision by Jingye to abruptly halt raw material purchases would have had commercial repercussions for these entities, making them potential parties in any contract-related disputes and key witnesses to Jingye’s conduct.

Finally, it is crucial to consider the role of China itself. Jingye Group is a Chinese-based company, and it was alleged in Parliament that its actions might have been part of a wider strategic goal to close UK capacity and supply the market from its operations in China. This brings into focus the actions of the Chinese state as a potential collaborator in the alleged anti-competitive conduct. This international political dimension is central to understanding the UK government’s national security justification for its intervention and will be a key element in any international trade or investment dispute that arises from this case.