People following this thread might be interested to read a page on the DTI's web site that states: an "undertaking" means any entity which is engaged in economic activities. It does not have to be profit-making so long as the activity carried out is one which in principle has commercial competitors. Charities, universities, research institutions and voluntary entities may be caught within the meaning of "undertaking" if they carry out economic activities. The concept of "undertaking" embraces public sector as well as private sector entities. Now, the NHS "in principle" has commercial competitors in the form of private health-care providers, doesn't it? This would lend credence to an argument that the NHS *is* an undertaking, full stop. I have e-mailed the DTI asking for clarification of the above paragraph. Michael