PP 5/20

Artificial intelligence and intellectual property: call for views –Response of the IP Federation
Founded in 1920 in the UK, the IP Federation represents IP intensive companies who are extensively involved in business activity in the UK and internationally across a range of industries. Our membership includes companies
that invest billions in developing and using AI technologies to build thesolutions of tomorrow. In developing and using these technologies our members appreciate the importance of creating the right incentives to build, use
and share AI technology. In particular, our members recognise the critical role
artificial intelligence (AI) will play in innovation, driving breakthroughs acrossthe diverse industry sectors of our membership including healthcare,manufacturing, cybersecurity and the automotive industry. Details of the
IP Federation membership are given at the end of this paper.
On 7 September 2020, the Intellectual Property Office published a call forviews posing a number of questions on how we think the IP framework currently relates to AI and the future of AI and IP policy. The call for views has
five sections covering patents, copyright and related rights, designs, trade
marks and trade secrets.
The IP Federation is pleased to submit this response to the IPO’s call for viewson artificial intelligence and intellectual property. We applaud the IPO’s
diligent efforts to assess the impact that AI has on IP as well as the impactthat IP might have on AI. In this response, we have answered questions set
out in two sections: i) the copyright and related rights section; and ii) thepatents section. We would be very willing to take part in additional dialogue
on this topic, across all five sections of the consultation and we very muchappreciate the opportunity to make this response.
Copyright and Related Rights
1. Do you agree with the above description of how AI may use copyrightworks and databases, when infringement takes place and which exceptions apply? Are there other technical and legal aspects that need
to be considered?
The description provided by the IPO provides some helpful examples of
how AI may use copyright works. These illustrative examples should not
be considered exhaustive. AI is an area of technology which is rapidly
developing. As such, a description of how AI can use copyright works willcontinue to develop and change.
AI may use copyright works for activities such as training, validation,
classification and diagnosis. During such activities, processes may involvethe use of a copyright work which may include storing the work, or part of
the work within the AI system. For example AI may be trained on copyrightworks which are stored. Copyright works may also be used during theRegistered Office 60 Gray’s Inn Road, London WC1X 8LU
Email: admin@ipfederation.com | Tel: 020 7242 3923 | Web: www.ipfederation.com
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analysis stage for example, to implement privacy persevering technologies. AI developers may also need to make such copyright works available, for example to provide transparency on how the AI was trained, ordemonstrate the efficacy of AI implemented techniques.
In examining copyright infringement, the description states that “copyright is infringed when someone uses a substantial part of a copyright workwithout the copyright owner’s permission.” We do not agree with thisstatement. Copyright can only be infringed when certain restricted acts
are performed. It is also important to recognize that the idea \ expression
dichotomy in UK copyright law requires that ideas, facts, and unprotected
elements of copyrighted works are accessible to those studying, observing
and interacting with a work, just as copyright has never prohibited someone from reading a book and understanding its content. AI and otherautomated means of observing and understanding works should also be
afforded effective access to unprotected elements of works.
As such the IP Federation supports a broad text and data mining copyrightexception that permits the use of copyright works for lawfully accessed
works. The ability for rightsholders to control usage contractually where
the work is confidential information or know-how etc (unpublished work)
will continue to exist. The rightsholder should be entitled to opt its works
out of the copyright exception for text and data mining (TDM) for commercial purposes, provided that it is required to do so in an appropriatemanner, including requiring the use of machine readable steps.
The description states: “Like a human, an AI may also infringe copyrightby generating copies of the song externally, performing it, distributing
it, or communicating it to the public.” We do not agree the statementthat “like a human, AI may also infringe copyright” this statement has
been interpreted to mean, AI may be used in a manner that infringes
copyright. The assessment should depend on whether the song performed,
distributed or communicated to the public is a copy or adaptation of a
copyright work under current case law.
It may be difficult to apply infringement analysis to other copies that are“stored within the AI brain” as these copies may not be accessible. Some
members are concerned that restricting such acts that relate to thefunctioning of the AI system, rather than the output that is generated may
have the effect of driving the development of AI outside the UK.
The exceptions to copyright and database rights that are listed in thedescription do not include the full list of exceptions that may apply tocopyright infringement, for example in limited circumstances, such as theRembrandt project example provided, the parody exception may apply(Section 30A of the UK Copyright, Designs and Patents Act (CDPA)).
We acknowledge that the TDM exception under UK law is only available
for non-commercial research purposes. This limitation is an inherently
grey area, as it is unclear what would qualify as non-commercial. The IP
Federation would like to see the UK adopt a broad copyright exception
similar to the TDM exception in the EU Copyright Directive. By not
implementing the EU Copyright Directive, the UK is at risk of driving AI

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development outside the UK. It should be noted that countries implementing a fair use doctrine such as the US and Singapore are able tomore easily accommodate rapid developments in technology whilebalancing the interest of copyright owners.
2. Is there a need for greater clarity about who is liable when an AI
infringes copyright?
This question will be interpreted as who is liable for copyright infringement when AI is used to perform acts that infringe copyright.
An infringer of copyright is strictly liable under tort law. That a legal person performs an infringing act through the agency of an AI does not affecttheir liability.
Performance of an infringing act may occur while the AI is being trained,
in this case the person with control could be the person training the AI. If
the AI generates a work that infringes copyright, then the person with
control could be whoever has made the necessary arrangements that have
led the AI to generate the work. It should be appreciated, however, thatsuch an assessment of who has control over the act of infringement iscomplicated and will depend on the facts of the particular case. It shouldbe also be noted that AI systems may behave unpredictably or without
direct human control (sometimes referred to as behaving autonomously),
therefore it may be difficult to identify the person who has control over
the AI system.
IP Federation members hope to see the case law develop to further clarify
how the law is applied in this area and do not believe any legislativechange is necessary at this stage.
3. Is there a need to clarify existing exceptions, to create new ones, orto promote licensing, in order to support the use of copyright works
by AI systems? Please provide any evidence to justify this.
By not implementing the EU Copyright Directive, the UK is left with thecurrent UK copyright rules which provide for a limited exception to text
and data mining (TDM) “for the sole purpose of research for a non-commercial purpose”, leaving out a wide array of entities using TDM (including
machine learning) techniques to develop breakthrough innovations. This
could leave the UK at a significant disadvantage to the EU and threaten
the UK’s ambition to become a powerhouse in artificial intelligence (AI).
A “new tech arms race” has emerged among many of the world’s leading
economies where many of these economies have implemented broader
TDM copyright exceptions than Europe and are able, under certain circumstances, to make use of fair dealing/fair use provisions. Our members
therefore strongly believe that there is a need to create a new exception
for text and data mining. Further details of the IP Federation’s position on
TDM are set out in our policy papers PP 4/20, PP 3/20 and PP 4/19.
The rapidly evolving nature of AI highlights the need to consider further
exceptions that may be required where it may be necessary to provide a
copy of a copyright work as an output of an AI system, such as activities
that are in the public interest and do not impact the commercial interest

Page 4 of 12of the copyright owner. It should be noted that countries implementing afair use doctrine such as the US and Singapore are able to more easily
accommodate rapid developments in technology while balancing theinterest of copyright owners.
Under the Open Data Directive EU Member States will transpose into
national law by 17 July 2021, the Directive’s mandate to make publicsector data “re-usable for commercial and non-commercial purposes,”.
The UK government would benefit the AI industry in the UK if it were to
make UK public sector data available to the same extent, while safeguarding privacy.
Depending on the data and use scenario, data sharing agreements can becomplex and take months to draft and negotiate. To help alleviate thisburden, the UK government could support the creation and use of model
data sharing agreements. Model agreements can help reduce the “frictions” that today deter organizations from sharing data.
4. Is there a need to provide additional protection for copyright or database owners whose works are used by AI systems? Please provide
any evidence to justify this.
AI innovation requires access to large data sets. Additional protection for
copyright or database owners may further limit access to data and stifle
the application and development of AI in the UK. In 2018 the European
Commission conducted an evaluation of the EU Database directive. In thisevaluation the Commission found that while the directive’s limited scope
facilitates its implementation, the sui generis right should not be extended
broadly to the data economy.
As set out in the European Commission’s IP Action plan, the EU will be
conducting a review of the Database Directive, pointing out that the
Directive could be revisited to facilitate data access and use. The IP
Federation urges the UK government not to impose stricter restrictions on
the access and use of data than the EU, particularly in light of any further
efforts by the EU to liberalise access to data which may result from thereview of the Directive.
5. Should content generated by artificial intelligence be eligible for protection by copyright or related rights?
Our members note that some jurisdictions including New Zealand andSouth Africa allow protection of copyright in software where AI tools wereused to build the software. Under Section 9(3) CDPA, copyright may be
conferred to a person who makes the arrangements necessary forthe creation of computer-generated work. There is some debate as towhether this rule applies to copyright in software because the Software
Directive requires human intellectual creation to be eligible for copyright protection.
The IP Federation considers that there is a need for an economic and moral
debate to assess the consequences of conferring intellectual property
protection to content generated by artificial intelligence. If machines
were allowed to create material protected by intellectual property rights

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then it is likely that intellectual property rights, would accrue exponentially to organisations that are able to develop AI solutions the fastest.
This is compounded by unequal access to data that is used to train AI. This
would create an unequal playing field for businesses who do not haveaccess to similar training data. Our intellectual property system isavailable to protect the intellectual creation of any human equally. This
paradigm would no longer hold true if the intellectual property system isdeveloped to afford protection to content generated by machines. It isalso possible that attributing copyright to machines may disincentivise
human creativity. AI does not require incentives such as copyrightprotection to generate work.
6. If so, what form should this protection take, who should benefit fromit, and how long should it last?
No response
7. Do other issues need to be considered in relation to content
produced by AI systems?
No response
8. Does copyright provide adequate protection for software which
implements artificial intelligence?
Copyright alone does not provide adequate protection for software asfunctionality is not protected by copyright. Consequently, a functional
equivalent can be independently created by someone else without
infringement of the copyright in the original software. Moreover, copyrightmay not subsist is some aspects of the software if ‘created’ by the AI.
However, the patent system is available to protect functionality implemented by software.
9. Does copyright or copyright licensing create any unreasonableobstacles to the use of AI software?
Restricting the use of the TDM exception for non-commercial purposescreates unreasonable restrictions on commercial organisations wanting to
implement and develop TDM solutions. Use of copyright works may berequired to ensure that a copy of a work is not output among the results,
or used to validate privacy persevering techniques. There may also be aneed to make copyright works available to provide transparency on how
the AI was trained. Using copyright to prevent such activities may beconsidered unreasonable. Broadening the TDM exception to allow forcommercial use would help remove unreasonable restrictions. Countries
implementing a fair use exception may be in a better position to prevent
copyright from creating unreasonable obstacles.
We urge the UK Government to carefully consider the steps our European
neighbours and other countries are taking to allow organisations todevelop and implement AI. Organisations are likely to choose to conduct
their R&D in countries that do not impose unreasonable obstacles todeveloping and applying AI solutions.

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Patents
The consultation is explicit that speculation of concepts of AI superintelligence(so-called “strong AI”) is not occasioned. We agree that this is appropriate
because there is no evidence to suggest that strong AI will be forthcoming in
the foreseeable future.
Inventions in the field of AI arise in three main respects:
I. Inventions created in the furtherance of the field of AI, such as developments and improvements to existing AI techniques or new AI techniquesthat advance the technical field.
II. Inventions involving the application of AI to address a problem in atechnical field, such as speech synthesis, image recognition, or network
intrusion detection.
III. Inventions including novel ideas discovered with the assistance of AI, suchas novel outputs of a trained machine learning algorithm applied to drug
discovery, engineering problems, optimisation challenges and the like.
The IP Federation believes all such inventions should be susceptible to patent
protection where the criteria for patentability, including novelty and inventive
step, are satisfied.
The specific questions raised in respect of patents in the consultation are
addressed in turn below.
1. What role can/does the patent system play in encouraging thedevelopment and use of AI technologies?
The IP Federation supports the government’s goal of making the UK a
global centre for AI and data-driven innovation by increasing uptake of AI
for the benefit of everyone in the UK. Innovators depend on patents toprotect and commercialise their innovations in the field of AI. In particular, patents incentivise investment in research and development (R&D) byprotecting inventions as a property right while at the same time publishingthe details of inventions for the wider good.
Without patents the incentive to innovate is diminished, protection for
inventions is reduced to trade secrets, and knowledge sharing is curtailed.
Furthermore, the opportunity to commercialise innovations can be affected as ideas fall available for anyone to use, even those arising as the
product of considerable research investment.
The IP Federation therefore believes the patent system has an essential
role to play in incentivising investment in AI R&D to secure the UK’s place
as a world-leading innovative economy.
2. Can current AI systems devise inventions? Particularly:a) to what extent is AI a tool for human inventors to use?
b) could the AI developer, the user of the AI, or the person who constructs the datasets on which AI is trained, claim inventorship?
AI is one tool in the research and development toolkit. When applied to a
problem domain, AI can assist in the discovery of novel ideas. Any such

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discovery is always made with the assistance of, under the guidance of, orbased on the contributions of a human.
As a tool, AI does not devise inventions. AI serves as essentially an alternative mechanism for programming, instructing or configuring a conventional computer system. Whereas it is not feasible to program a computerin the conventional manner to recognize all styles of handwriting, or tocorrectly interpret all types of speech, AI algorithms including machinelearning algorithms can be trained in a supervised manner to perform suchtasks. Such training is an application of mathematics. Similarly, programming a computer to analyse large unlabelled data sets to identify latentfeatures, novel classifications and using such new insights in new practicalapplications is equally an application of mathematics with AI operating as atool. Even bio-inspired techniques such as evolutionary algorithms operatingon the basis of goals or fitness functions to optimise a real-world or logicaldesign are applications of conventional computer science in clever andbeneficial new ways, even where stochastic methods are involved.
The current and foreseeable state of the art in AI and related fields does
not involve algorithms devising inventions. Nonetheless, patent applications
have been filed where the applicants consider they are unable to identify ahuman inventor. This raises the question: what is an inventor? This question
may require clarification to ensure an appropriate inventor can be
identified in all cases, even where AI is used. Otherwise inventions for whichapplicants believe they cannot identify a human inventor cannot be subject
to patent applications which require the designation of a human inventor.
As outlined above, we believe a human is always involved in the work of anAI, whether as programmer of the AI, configuring the AI, operating the AI,
supervising the AI, defining objectives for the AI, selecting input data (suchas training data) for the AI or recognising applications of the output of theAI. Where an invention is devised with the assistance of AI the appropriate
person(s) involved in the devising of that invention should be identifiable as
the inventor(s). We recommend a broad dialogue involving all stakeholders
on how clarification on this identification of an inventor can be achieved,
and note inspiration may be taken from the CDPA in respect of computer
generated works. Further inspiration may also be taken from case law
relevant to the patentability of discoveries.
c) are there situations when a human inventor cannot be identified?
As outlined above, the IP Federation considers that all inventions devisedwith the assistance of AI involve human inventors, though the current legal
framework may make it difficult for applicants to properly identify thosehuman inventors. Accordingly, a clarification may be required to ensure ahuman inventor can always be identified.
3. Should patent law allow AI to be identified as the sole or joint
inventor?
The IP Federation considers that the answer to this question is no. The
purpose of identifying an inventor in a patent application is twofold: 1) toenable the right of attribution provided in, inter alia, Article 4ter Paris
Convention; and 2) to determine ownership of resulting property deriving

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from the right to apply for a patent. In respect of ideas discovered by AI,
both purposes are irrelevant: there is no right of attribution for a computer
system such as AI; and there can be no proprietary ownership by AI. It
follows that an AI tool cannot be an inventor at least because: the law does
not permit it to be; and the principal purpose of determining inventorshipis to determine ownership, and the law does not (and should not) permit
AI systems to own property.
4. If AI cannot be credited as inventor, will this discourage future inventions being protected by patents? Would this impact on innovation
developed using AI? Would there be an impact if inventions were
kept confidential rather than made public through the patent system?
The IP Federation considers there is no need to, or purpose for, designating
an AI as inventor for patent application and there is no disincentive fromprecluding such designation. On the contrary, permitting designation of AI
as inventor introduces considerable uncertainty as to the right to file apatent application and ownership of resulting patents. An AI involved inassisting in the discovery of new ideas may exist in multiple capacities atthe same time including in relation to: its owner; its lessee or tenant, suchas in a cloud-computing context; its user or operator; a person responsible
for or contributing to its configuration; a person recognising the value andcontribution of its output; and others. Seeking to untangle these
relationships from a property-ownership perspective is much lessstraightforward than seeking to recognise the persons involved in thedevising of an invention. The IP Federation therefore believes theappropriate approach is to prioritise clarifying the human inventors involved
in devising an invention.
5. Is there a moral case for recognizing AI as an inventor in a patent?
The IP Federation believes there is no moral reason for recognising AI as aninventor. The purpose of designation of inventor is outlined in response toquestion 3 and this does not warrant extension.
6. If AI was named as sole or joint inventor of a patented invention, who
or what should be entitled to own the patent?
An AI should never be named as an inventor for a patent because AI does
not devise inventions (see the response to question 2). A human inventor
should always be listed at least because all new ideas discovered by AI
involve a human inventor. The identification of a particular human inventor
can be aided by clarification of the requirements for inventorship.
Ownership is suitably defined on the basis of inventorship as currently
provided in the UK Patents Act.
7. Does current law or practice cause problems for the grant of patents
for AI inventions in the UK?
Considering inventions across the following three categories:
I.

Inventions created in the furtherance of the field of AI: suchinventions can fall-foul of the excluded subject matter provisions
codified in Section 1(2) UK Patents Act and Article 52(1) European

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Patent Convention. In particular, improvements to AI algorithms andtechniques without specific practical application can be excluded asmathematical methods or computer programs as such. The IP Federation is generally comfortable with the interpretation of these provisions in the UK Patents Act and European Patent Convention, thoughnotes that inconsistencies can arise in the examination of patentapplications between the UK Intellectual Property Office (UK IPO) andthe European Patent Office (EPO) due to differing methods of applying
the exclusions. Additionally, we recognise that developments in AI
techniques constitute valuable contributions to the state of the art
and their protection by patent without requiring recitation of a
specific application would fairly reflect that contribution.
II.

Inventions involving the application of AI to address a problem in atechnical field: the application of AI to particular problem domains
is normally readily protected by patent.

III.

Inventions including novel ideas discovered with the assistance of
AI: it is in the use of AI to assist in the discovery of new ideas thatsome patent applicants struggle to identify a human contribution
sufficient, in their view, to warrant designation of an inventor. Suchinventions should not be excluded from patent protection for only
such reasons and the clarification in respect of the human contribution to the devising of an invention described above is warranted.

8. Could there be patentability issues in the future as AI technology
develops?
The current and currently foreseeable state of the art in AI and its applications do not lead us to anticipate significant patentability issues going
forward, noting that changes to the patent system are most preferably
made on the basis of a factual evidence-base without recourse tophilosophical discourse which may not reflect the technical reality.
9. How difficult do the list of excluded categories in UK law make it tosecure patent protection for AI inventions? Where should be the line
be drawn here to best stimulate innovation?
Refer to the response to Question 7 above. The current approach to interpreting the excluded categories at the UK IPO and EPO are reasonable
though some inconsistencies arise between the two. The outcome awaitedin the currently pending referral to the EPO Enlarged Board of Appeal in
G 1/19 may have an impact on the patentability of some AI inventions. If
this is the case then further dialogue on the nature and scope of the
exclusions will be required.
10. Do restrictions on the availability of patent rights cause problems for
ethical oversight of AI inventions?
The IP Federation considers the answer to this question is no. Ethical oversight of AI includes questions of transparency, explainability and bias. While
the IP Federation recognises the importance of these issues, we believe it
is not appropriate for them to be addressed through IP provisions such as
patent law and practice. Regulatory requirements to assure the social

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acceptability of AI should be considered separate to the patent system.
While it is noted that patent applications must disclose an invention in amanner that is sufficiently clear and complete for it to be understood, thisrequirement serves to ensure the sufficiency of disclosure of an invention
in an application. Such disclosure need not extend to disclosure for the
purpose of full transparency of an AI algorithm, or full explainability of an
AI technique. Indeed, in some cases, a patent application for an invention
devised with the assistance of AI may be directed to the output of the AI,
in which case there may be no need to disclose the AI mechanism itself inorder to sufficiently disclose the output itself. Accordingly, patent law is
not an appropriate or effective home for these regulatory issues.
11. Does the requirement for a patent to provide sufficient detail to allow
a skilled person to perform an invention pose problems for AI
inventions?
The IP Federation considers the answer to this question is no. The disclosureof inventions including applications of AI or devised with the assistance of
AI is no different to the disclosure of other computer implemented inventions. Methods, algorithms and flowcharts can be used to disclose themethodology of an AI invention. There is unlikely to be a need to disclose
training data or trained weights for machine learning algorithms or the likesince inventions arise in the methodologies employed. Where novel outputs
are discovered with the assistance of AI such as novel physical objects, novelcompositions and the like, disclosure of the output is sufficient. It is notnecessary to disclose how the output was discovered to sufficiently disclose
the output itself.
12. In the future could there be reasons for the law to provide sufficientdetail of an AI invention for societal reasons that go beyond thecurrent purposes of patent law?
The IP Federation considers the answer to this question is no for the reasons
given above in response to question 10.
13. Does or will AI challenge the level of inventive step required to obtaina patent? If yes, can this challenge be accommodated by current
patent law?
The IP Federation considers that AI does not challenge the level of inventive
step required to obtain a patent. A new idea discovered with the assistanceof AI is suitably assessed for inventive step applying the standard defined inpatent law on the basis of prevailing case law. Properly applied, this standard recognises how, for an invention in a patent application, any potential
for a person skilled in the art to have recourse to AI as a tool is recognised
based on both the state of the art and the common general knowledge ofthe person. It is to be expected that the potential to have recourse to AI
may be low in fields of endeavour where the state of the art indicates a
low-level or absence of application of AI. It is also to be expected that thepotential to have recourse to AI may increase as indications of such arefound in the state of the art and/or become part of the common generalknowledge of the notional skilled person.

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14. Should we extend the concept of “the person skilled in the art” to“the machine trained in the art”?
The IP Federation considers the answer to this question is no. An extension
to the legal fiction of a person skilled in the art to include a machine
trained in the art would serve only to expand the fictional capability ofthe person skilled in the art to have recourse to trained machines (i.e. AI).
This expansion is unnecessary. A determination of whether a notional
skilled person may or may not have recourse to AI is part of an analysis ofinventive step for an invention and is a question to be addressed in thecontext of the invention, the relevant state of the art and the common
general knowledge of the skilled person. It is not necessary to specificallycodify any particular tool or technique into the common general knowledgeof the skilled person, and doing so renders the legal fiction inappropriate
in cases where a skilled person specifically would not have recourse to AI.
15. Who is liable when AI infringes a patent, particularly when this action
could not have been predicted by a human?
This question will be interpreted as who is liable for patent infringement
when AI is used to perform acts that infringe patent rights. An infringer ofa patent is strictly liable under tort law. That a legal person performs aninfringing act through the agency of an AI does not affect their liability.
16. Could there be problems proving patent infringement by AI? If yes,
can you estimate the size and the impacts of the problem?
Proving infringement of patents is not always straightforward, and inrespect of software inventions it can be particularly challenging. Infringement involving the operation of an AI is no different. The challenge canleave some patents seemingly unenforceable for being undiscoverable inuse by infringers. The challenge is tempered by high quality professional
services engaged in the selection of appropriate inventions for patenting,and in suitable patent claim drafting.
IP Federation
4 December 2020

IP Federation members 2020
The IP Federation represents the views of UK industry in both IPR policy and practicematters within the EU, the UK and internationally. Its membership comprises theinnovative and influential companies listed below. The CBI, although not a member,is represented on the Federation Council, and the Council is supported by a numberof leading law firms which attend its meetings as observers. It is listed on the joint
Transparency Register of the European Parliament and the Commission with identity
No. 83549331760-12.
AGCO Ltd
Airbus
Arm Ltd
AstraZeneca plc
BAE Systems plc
BP p.l.c.
British Telecommunications plc
British-American Tobacco Co Ltd
BTG plc
Canon Europe Ltd.
Caterpillar U.K. Ltd
Cummins Ltd.
Dyson Technology Ltd
Eisai Europe Limited
Eli Lilly & Co Ltd
Ericsson Limited
Ford of Europe
GE Healthcare
GKN Automotive Limited
GlaxoSmithKline plc
Hitachi Europe Ltd
HP Inc UK Limited
IBM UK Ltd
Johnson Matthey PLC
Juul Labs UK Holdco Ltd
Merck Sharp & Dohme (UK) Ltd
Microsoft Limited
Nokia Technologies (UK) Limited
NEC Europe
Ocado Group plc
Pfizer Ltd
Philips Electronics UK Ltd
Pilkington Group Ltd
Procter & Gamble Ltd
Reckitt Benckiser Group plc
Renishaw plc
Rolls-Royce plc
Shell International Ltd
Siemens plc
Smith & Nephew
Syngenta Ltd
UCB Pharma plc
Unilever plc
Vectura Limited
Vodafone Group