Collision in the Sea of Marmara: Civil and Criminal Liability in Maritime Casualties
Taking the ship casualty off Silivri as its point of departure, this article examines the provisions governing collision, the scope of liability in damages, the operation of the criminal investigation, the administrative casualty investigation and the steps that must be taken in the first days following a casualty.
“In a maritime casualty the criminal investigation, the administrative safety investigation and the claims for damages proceed on three separate and independent tracks; yet all three draw on the same pool of evidence.”
On 2 September 2026, at around 03.00, some 18 nautical miles south of Silivri, a collision occurred between two Turkish-flagged merchant vessels. Following the collision between ALSU, a 90-metre vessel sailing in ballast from Kocaeli to Aliağa, and Tuğberk İmamoğlu, which was carrying coiled steel and rebar from İskenderun to Karadeniz Ereğli, Tuğberk İmamoğlu sank within approximately eleven minutes and contact with her ten-member crew was lost. The wreck was located on the fourth day after the casualty at a depth of 720 metres; search and rescue operations are continuing.
In the investigation conducted by the Silivri Chief Public Prosecutor's Office, the master and the third officer of ALSU were remanded in custody, while four seafarers were released under judicial control. According to publicly available information, the preliminary expert report identifies a chain of omissions on the part of both vessels; Tuğberk İmamoğlu's sailing with her automatic identification system switched off and her turn to starboard in the last half mile, contrary to the agreement reached by radio, are characterised as the element that physically initiated the collision, while the bridge arrangement aboard ALSU is characterised as the root cause. These characterisations belong to a preliminary report, and none of them has been conclusively established by a judicial authority.
To whom fault belongs, and in what proportion, will be determined by the courts. This article does not sit in judgment on the specific incident; it seeks to set out, to the extent the facts of the case permit, which rules govern a casualty of this kind under Turkish law, how liability is apportioned between the parties, how the criminal process operates and which steps must be taken in the first days after the casualty. The names and personal details of the persons subject to proceedings are not disclosed. The factual information is compiled from sources in the public domain as at the date of publication and may change as the investigation progresses. The presumption of innocence is reserved.
Collision and the Fault Regime
Under Turkish law a collision between ships is termed a “çatma” and is governed by a special regime set out in Articles 1286 to 1297 of the Turkish Commercial Code No. 6102 (TCC), modelled on the Brussels Convention of 1910. For this regime to apply it suffices that the craft involved are ships within the meaning of the Code, and under Article 1286(2) TCC damage caused by a faulty manoeuvre without physical contact is subject to the same regime. These provisions govern only the relationship in damages; the criminal investigation and the administrative inquiry are conducted on separate tracks.
The regime is fault-based. Article 1287 TCC provides for three distinct situations: where the collision is caused by an unforeseeable event or by force majeure, or where its cause cannot be established, each party bears its own loss. Accordingly, a finding that the weather conditions on the night of the casualty were ordinary weakens only the force majeure defence; the possibility of an unforeseeable event arising from an engine or steering failure, and the possibility that the cause of the collision cannot be established at all, remain matters requiring separate assessment.
Where the collision is caused by the fault of the owner or the crew of one ship, the owner of that ship is liable for the damage (Article 1288 TCC). In practice fault is attributed to both ships in the great majority of collisions, and the Code draws a distinction at this point: in respect of damage to ships and cargo each owner is liable only in proportion to its own fault (Article 1289 TCC), whereas in respect of loss arising from death and personal injury the owners at fault are jointly and severally liable towards the injured party, and the owner that pays may have recourse against the other in proportion to the latter's fault (Article 1290 TCC).
Two rules complete the regime. The first is that there is no statutory presumption of fault in collision; the ship that sank cannot be presumed innocent, nor the ship that manoeuvred presumed at fault, and fault must be proved by evidence (Article 1294 TCC). The second is that no formal requirement such as a prior notice is a precondition to bringing an action (Article 1293 TCC).
Legal note — How is the Sea of Marmara characterised in law?
The Sea of Marmara is, in its entirety, Turkish internal waters; it is neither territorial sea nor high seas. Even had foreign-flagged ships been involved, the casualty would have been heard before the Turkish courts in both its criminal and its civil dimensions. The freedom of passage deriving from the Montreux Convention does not have the effect of exempting a ship from Turkish navigation rules or from Turkish jurisdiction.
The Facts of the Case: What Is Known and What the Courts Will Decide
- ALSU · Kocaeli → Aliağa · alteration of 5° to port, then 9° to port
- VHF: “Alsu, alter to port” ×2 — “Understood”
- Tuğberk İmamoğlu · İskenderun → Karadeniz Ereğli · automatic identification system off
- Last 0.5 mile: turn to starboard; port bow → starboard bow, at approximately 500 m
- Fig. 01 — Schematic, not to scale, per the statements and the preliminary expert report
According to publicly available information, the statements of the two officers in custody indicate that the master was resting, that the vessel was under the command of the third officer, who had joined the ship a month earlier and had seven months' experience, and that there was no lookout on the bridge. According to the same information, the other vessel twice requested by radio that ALSU alter course to port; ALSU altered first five and then nine degrees to port; at a distance of approximately 500 metres the other vessel turned to starboard and struck ALSU's starboard bow with her port bow. The officers state that they were unable to see the other vessel's automatic identification system signal on the electronic chart display and information system, that they tracked the vessel by radar alone, and that they received no warning from the coastal vessel traffic service.
It is reported that the preliminary expert report likewise finds that the system in question was switched off and that the turn to starboard was contrary to the radio agreement, treating these as the triggering element and the single-officer, lookout-less watch aboard ALSU as the root cause. According to the report, had the master and a lookout been on the bridge, the manoeuvre could have been detected at a distance of 1.5 to 1.8 miles rather than half a mile, and the collision could have been avoided by stopping the engines or going astern. None of these assessments constitutes a final finding. Indeed, Article 67(3) of the Code of Criminal Procedure No. 5271 provides in mandatory terms that an expert may not, in the report or in oral explanations, engage in the legal characterisation and evaluation reserved to the judge.
The legal significance of the facts may be set out as follows. For vessels on reciprocal courses the rule is that both ships alter course to starboard (International Regulations for Preventing Collisions at Sea, Rule 14); although a different arrangement may be agreed by radio, alterations of five and nine degrees made when the vessels had closed to a distance of 500 metres do not possess the character of the “early, substantial and readily apparent” action required by Rule 8. Under Rule 5 every vessel is obliged at all times to maintain a proper lookout by sight and hearing as well as by all available means appropriate in the prevailing circumstances, so as to make a full appraisal of the situation and of the risk of collision. Under Rule 7 the risk of collision is to be determined using all available means, radar included, and assumptions may not be made on the basis of scanty information.
A last-moment turn contrary to what had been agreed by radio constitutes an element to be weighed against that vessel in the assessment of fault. Under the rule that there is no presumption, however, this circumstance does not of itself dispose of the allegations concerning the bridge arrangement aboard the other vessel. Whether both circumstances in fact occurred, and their legal characterisation, will be determined at the conclusion of the proceedings. It is anticipated that the dispute will most likely be resolved within the framework of the joint-fault regime, through a debate on the apportionment of fault conducted along the axis of triggering fault and root cause. For the families of the deceased the outcome does not change: the whole of the loss arising from the deaths of ten seafarers may be claimed from any of the owners found to be at fault, even if their own employer is also found at fault (Article 1290 TCC).
The Persons Liable: Owner, Master, Insurer and the Limitation Ceiling
- Claimant · the relatives and the cargo interest
- Owner · strict liability (Article 1062 TCC · LLMC ceiling, Articles 1328 et seq.)
- P&I insurer · direct action (Article 1478 TCC)
- Fig. 02 — Liability map, schematic
The owner
The registered owner who operates the ship on the water for the purpose of gain, and any person who operates a ship not belonging to him in his own name, has the status of owner, or “donatan” (Article 1061 TCC). The owner is the primary defendant in the action for damages and is held liable for the fault of the crew even in the absence of any fault of his own and without the possibility of adducing exculpatory evidence (Article 1062 TCC). For this reason, before an action is brought, the identity of the person actually operating the vessel must be established from the ship's registry records and the safety management documentation.
The master and the crew
The master is bound to act as a prudent master would (Articles 1088 and 1089 TCC). The master and the officers may also be held personally liable under the provisions on tort (Article 49 of the Turkish Code of Obligations, TCO). The presence of a lookout alongside the officer of the watch during the night watch is required by Section A-VIII/2 of the Code of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, and the sole-lookout exception permitted for the daytime watch is not provided for at night. Accordingly, the view that the posting of a lookout lies within the master's discretion is not consistent with that standard.
The insurer
In Türkiye, liability insurance is compulsory for ships of 300 gross tons and above. The injured party may bring a claim directly against the insurer, limited to the sum insured (Article 1478 TCC). Since it is debated whether an insurer may invoke the “pay to be paid” rule against an injured party under compulsory insurance, it is advisable to plan the claim together with the action to be brought against the owner and the negotiation of a letter of undertaking.
Limitation of liability
The owner discharges the liability arising from a collision within a ceiling calculated by reference to tonnage and expressed in special drawing rights. Articles 1328 et seq. TCC apply directly the Convention on Limitation of Liability for Maritime Claims of 1976 and its Protocol of 1996. A separate and higher limit is provided for claims in respect of loss of life. The master and the crew also benefit from the right to limit. That right is lost only where the personal intentional or reckless conduct of the owner is proved; the gross fault of a crew member is not in itself regarded as sufficient, and in practice the test applied is knowledge at company level. Whether an inexperienced officer keeping the night watch alone and without a lookout was a choice made on a single night or the ordinary operating pattern of the vessel is precisely the subject of that debate.
Legal note — Would the outcome differ if one of the ships had flown a foreign flag?
There would be no material difference as regards damages. Turkish law applies to a collision occurring in Turkish internal waters as the law of the place where the act was committed (Article 34 of the Act on Private International Law and Procedure No. 5718, PIL Act); the Turkish courts have jurisdiction, and the limitation regime operates in the same way. The real difference arises at the stage of enforcement: unless an order for the arrest of the ship is obtained and a letter of undertaking secured while the ship is in a Turkish port, the process turns into an application for enforcement abroad.
The Scope of Compensation and the Families of the Missing Crew
Heads of loss recoverable on death
In the event of death, funeral expenses, medical expenses and losses arising from the reduction or loss of working capacity where death did not occur immediately, and the losses suffered by persons deprived of the support of the deceased, may be the subject of compensation (Article 53 TCO). In addition, non-pecuniary damages may be claimed by the close relatives (Article 56 TCO). Loss-of-support damages are calculated by means of an actuarial report on the basis of the deceased's income, probable working life and life expectancy and the shares of support, with seafarers' voyage bonuses and foreign-voyage earnings also included in the calculation. Where there is more than one person liable, the provisions on joint and several liability apply (Article 61 TCO; for collision, Article 1290 TCC).
Social security
A seafarer has the status of an employee under the Maritime Labour Act. A casualty occurring while the vessel is under way constitutes an occupational accident within the meaning of Article 13 of Law No. 5510 and must be reported to the Social Security Institution within three working days. The Institution grants a survivors' pension to the entitled persons and pays a funeral allowance; it then has recourse for the initial capitalised value of the pension against the employer and against the owner of the other vessel, in proportion to their fault. The amount covered by the Institution is deducted from the loss-of-support damages.
The presumption of death in respect of the missing crew
A person who disappears in circumstances in which death must be regarded as certain is deemed to have died even if the body has not been found (Article 31 of the Turkish Civil Code, TCivC). In that event the death is entered in the civil register on the order of the highest local administrative authority, and interested parties may also apply to the court for a declaration (Article 44 TCivC). A ship sinking within eleven minutes, a wreck at a depth of 720 metres and life-saving appliances found empty constitute the typical factual basis for that presumption; consequently, as a rule there is no need to resort to the declaration of absence (Article 32 TCivC), which requires a waiting period of at least one year. The entry of the death in the register is a precondition for the opening of the succession, the granting of a pension and the bringing of an action for damages.
Legal note — What is the position as to social security protection where the ship flies a foreign flag?
The Maritime Labour Act applies only to Turkish-flagged ships. An employment contract concluded aboard a foreign-flagged ship is governed by the law of the place where the employee habitually carries out his work (Article 27(2) PIL Act), and in the case of a ship that place is in practice taken to be the flag state. The first paragraph of the same Article, which permitted a choice of law, was annulled by the decision of the Constitutional Court published in the Official Gazette of 10 March 2025, the annulment taking effect on 10 September 2025. A Turkish seafarer who contracts directly with a foreign owner is not regarded as compulsorily insured in Türkiye; protection is provided through a Turkish crew management company, a flag state with which a social security agreement is in force, or voluntary insurance. In the absence of these, no Institution pension and no right of recourse arise; the families turn to the liability insurance cover, to the security provided under the Maritime Labour Convention where the flag state is a party to it, and to any fixed compensation provided for in a collective agreement.
Criminal Liability
The offence and negligence
A collision resulting in death is assessed under the offence of negligent homicide. Where more than one person has been killed, the applicable provision is Article 85(2) of the Turkish Penal Code No. 5237 (TPC), which provides for a term of imprisonment of two to fifteen years. Negligence, in the words of Article 22(2) of the same Code, is the commission of an act without foreseeing the result specified in the statutory definition of the offence, by reason of a breach of the duty of care and attention. In the maritime context the content of that duty is supplied by the International Regulations for Preventing Collisions at Sea, watchkeeping standards and national navigation rules. Where the result was foreseen but not intended, conscious negligence is present and the sentence is increased by one third to one half (Article 22(3) TPC).
The offence of dangerous navigation (Article 179(2) TPC, as amended by Law No. 7550) is, where the result of death occurs, absorbed into the result offence under the rule of concurrence of offences (Article 44 TPC). The alcohol and blood tests carried out after the casualty are of significance for the assessment of conscious negligence. In negligent offences each person is liable only for his own fault (Article 22(5) TPC); the liability of company managers arises only where a specific breach of the duty of care attributable to them is proved to be causally connected with the result of death.
Jurisdiction, investigation and protective measures
Turkish law applies to offences committed in Turkish internal waters and aboard Turkish-flagged ships (Article 8 TPC), and venue lies with the court of the place where the offence was committed (Article 12 of the Code of Criminal Procedure, CCP). The relatives of the deceased have the right, during the investigation phase, to request the collection of evidence and to examine the file and obtain copies of documents through their counsel (Article 234(1)(a) CCP); during the trial phase they may join the public prosecution as intervening parties (Article 237 CCP). Pre-trial detention may be ordered only where concrete evidence demonstrating strong suspicion of the offence, a ground for detention enumerated in the law and proportionality are all present (Article 100 CCP). Judicial control is the alternative to detention (Article 109 CCP), and in the present case that course was followed in respect of four seafarers. During the investigation phase the continuation of detention is reviewed ex officio at intervals of no more than thirty days, and the suspect may request a review at any time (Article 108 CCP).
The conduct of the criminal investigation is not dependent on the recovery of a body. In criminal proceedings the fact of death may be proved by any lawful evidence, and the entry of the death in the civil register is not a precondition of the investigation. Negligent homicide is not an offence subject to complaint; it is investigated ex officio, and the trial is conducted before the assize court.
The relationship between the criminal and the civil proceedings
The criminal judge's assessment of fault and a judgment of acquittal do not bind the civil judge (Article 74 TCO). By contrast, findings of material fact contained in a final criminal judgment are, in settled practice, regarded as binding on the civil judge. The expert report prepared during the investigation phase is, for both judges, merely one item of evidence, and, as noted above, the expert has no authority to make legal characterisations (Article 67(3) CCP).
Legal note — Does the master who was resting in his cabin incur criminal liability?
Resting at night is ordinary and does not in itself constitute fault. Since criminal liability is personal, the error of the officer at the helm cannot be imputed to the master (Article 20(1) TPC), and where several persons have acted negligently each is liable for his own fault (Article 22(5) TPC). The master's liability concerns the manner in which the watch was organised: leaving an inexperienced officer alone at night without a lookout, and failing to include in the night orders an instruction to call the master in case of doubt, constitute a separate breach of the duty of care, and where a causal link with the result of death is established the charge extends to the master as well. In investigations of this kind, the charge directed against the master typically concentrates on precisely this point, namely whether the duty of supervision and oversight was discharged.
Procedure: Competent Court, Evidence, Security and Time Limits
Subject-matter jurisdiction and venue
An action for damages arising from a collision is an absolute commercial action and is heard by the commercial court of first instance (Articles 4 and 5 TCC). In Istanbul there is a commercial court of first instance designated to hear disputes relating to maritime commerce. Although the court of general jurisdiction is the court of the defendant's domicile (Article 6 of the Code of Civil Procedure, CCivP), in the case of tort the courts of the place where the act was committed, of the place where the damage occurred and of the injured party's domicile also have jurisdiction (Article 16 CCivP). An action for damages arising from an occupational accident brought by the deceased seafarer's dependants against his own employer falls within the jurisdiction of the labour court.
Mandatory mediation as a precondition to suit
In respect of claims for receivables and damages whose subject matter is the payment of a sum of money, an application to a mediator before the action is brought is prescribed as a precondition to suit (Article 5/A TCC). An action brought without a prior application to a mediator is dismissed on procedural grounds for want of a precondition to suit. An action for damages arising from an occupational accident brought against the seafarer's own employer is excluded from the scope of this requirement.
Sea protest and preservation of evidence
The master is entitled to have a sea protest recorded by the court even where the ship has been lost, and is bound to do so where so requested (Article 1098 TCC). An application for the preservation of evidence before the action is brought is made to the commercial court of first instance of the place where the collision occurred; the master or representative of the other ship is notified of the proceedings, and the report does not apportion fault (Article 1292 TCC). The general regime governing the preservation of evidence is set out in Articles 400 and 401 CCivP. Records seized by the public prosecutor's office are accessible through counsel (Article 153 CCP).
Arrest of the ship
Claims in respect of loss of life and property arising from a collision are maritime claims and permit an application for the arrest of the ship at fault (Articles 1352 and 1353 TCC). Such claims also give rise to a maritime lien ranking ahead of mortgages (Articles 1320 et seq. TCC). An order for arrest is sought from the court of the place where the ship is located, and in the case of Turkish-flagged ships the court of the place of registry also has jurisdiction. In practice the arrest is lifted against a letter of undertaking issued by the liability insurer.
Limitation periods
Claims arising from a collision are subject to a limitation period of two years from the day of the casualty, and recourse claims between owners to a limitation period of one year from the date of payment (Article 1297 TCC). It is debated whether the provision on the extended criminal limitation period (Article 72 TCO) applies to this special period; the prudent course is to bring the action before 2 September 2028.
- 0–24 hours · assistance · notification · voyage data recorder
- 3 working days · occupational accident report to the Social Security Institution
- 30 days · review of detention (Article 108 CCP)
- 1 year · recourse between owners
- 2 years · limitation period for collision claims
- Fig. 03 — Time limits
Legal note — What would the outcome have been had the collision occurred on the high seas?
Criminal jurisdiction would, under Article 97 of the United Nations Convention on the Law of the Sea, have belonged exclusively to the flag state and to the state of which the offender is a national; since both ships were Turkish-flagged, the outcome would again have been the jurisdiction of the Turkish courts (Article 8(2)(b) TPC). As regards damages, the criterion of the law of the place where the act was committed would be inoperative; where the ships fly the same flag the law of the flag state applies, and where they fly different flags the law of the forum or the law with which the case is most closely connected applies.
Steps to Be Taken in the First Days Following a Casualty
The steps to be taken in the first days are set out below, arranged according to the parties to the casualty.
A · For the owner and the ship operator
- The master's obligation to render assistance to the other ship and to communicate the name, port of registry and route of his own ship must be discharged (Article 1295 TCC). Under the third paragraph of that Article the owner is not liable for the master's breach of this obligation alone. The duty of assistance provided for in the Law No. 4922 on the Protection of Life and Property at Sea must additionally be borne in mind; the Main Search and Rescue Coordination Centre, the harbour master's office and the coast guard must be contacted immediately.
- The evidence must be frozen. The voyage data recorder's record must be preserved; the logbooks, the passage plan, the watch and rest-hour records and the radar, electronic chart, automatic identification system and radio records must be kept unaltered. Interference with these records gives rise to a suspicion of tampering with evidence and may constitute a ground for detention.
- The protection and indemnity club and the hull insurer must be notified immediately. Defence counsel must be appointed before the seafarers' statements are taken (Articles 147 and 149 CCP), and separate counsel must be appointed where there is a possibility of a conflict of interests.
- A sea protest must be recorded without delay (Article 1098 TCC) and an application for the preservation of evidence made (Article 1292 TCC). Preparations must be made for a letter of undertaking against arrest and for a limitation fund; the occupational accident report must be submitted to the Social Security Institution within three working days.
B · For the families of the missing or deceased seafarers
- Access to the investigation file must be obtained through counsel (Articles 234 and 153 CCP); the statements, the expert report and the navigation records must be followed.
- Once the search operations have ended, the entry of the death in the civil register on the order of the local administrative authority must be secured (Articles 31 and 44 TCivC). The employer's report to the Social Security Institution must be followed up, and applications for the survivors' pension and the funeral allowance must be made.
- Claims for loss of support and non-pecuniary damages must be advanced against both owners on the basis of joint and several liability. Although a direct claim against the insurer is available (Article 1478 TCC), the debate concerning the “pay to be paid” rule must be borne in mind. An application for mediation must be made before the action is brought; the arrest of the ship must be sought while she is in a Turkish port; the two-year limitation period must be monitored and an application to join the criminal proceedings must be made.
C · For cargo interests and other third parties
- The cargo insurer must be notified immediately. Claims founded on the contract of carriage against the party's own carrier and claims founded on the collision provisions against the owner of the other ship must be identified separately; an application for mediation must be made before the action is brought; the arrest of the other ship must be sought. Although collision claims are subject to a two-year limitation period, a claim against the party's own carrier arising from the contract of carriage is subject to a shorter period.
Conclusion and Assessment
““There is no presumption of fault in collision. Fault is proved by the records preserved in the first hours of the casualty; those records decide compensation, criminal liability and the owner's right to limit.””
In maritime casualties the criminal investigation conducted by the public prosecutor, the safety investigation conducted by the administration and the injured parties' claims for damages proceed in parallel. Although their legal bases, purposes and standards of proof differ, the navigation records, logbooks, watch schedules and first statements constitute the common material of all three. The purpose of the administrative safety investigation is not to establish fault or liability but to draw lessons for the prevention of similar casualties; its findings therefore do not take the place of the civil and criminal proceedings. The preservation of evidence in the first hours following the casualty directly affects both the correct determination of fault and the owner's right to limit liability.
As regards the casualty off Silivri, the investigation is continuing and fault will be determined by the courts. The applicable legal framework, however, is settled. Collision liability is fault-based; in respect of loss of life the owners at fault are jointly and severally liable to the families of the deceased; the owner, although liable for the fault of the crew even in the absence of any fault of his own, may limit his liability within the framework of the international conventions; and criminal liability is assessed individually, on the basis of each seafarer's own fault and under the provisions on negligence. For shipping companies the conclusion to be drawn is operational before it is legal: compliance with the rules on watchkeeping, lookout and rest hours is a legal necessity that directly determines the owner's right to limit and the criminal exposure of the crew.
Legislation Cited
Turkish Commercial Code No. 6102, Articles 4, 5/A, 1061–1062, 1088–1089, 1098, 1188, 1286–1297, 1320 et seq., 1328 et seq., 1352–1354, 1478 · Turkish Code of Obligations No. 6098, Articles 49, 53, 56, 61, 72, 74 · Turkish Penal Code No. 5237, Articles 8, 20, 22, 44, 73, 85, 179 · Code of Criminal Procedure No. 5271, Articles 12, 67, 100, 108, 109, 147, 149, 153, 234, 237 · Code of Civil Procedure No. 6100, Articles 6, 16, 400–401 · Turkish Civil Code No. 4721, Articles 31, 32, 44 · Act on Private International Law and Procedure No. 5718, Articles 27, 34 · Law No. 5510, Article 13 · Law No. 4922 on the Protection of Life and Property at Sea · Law No. 5235, Article 12 · Convention on Limitation of Liability for Maritime Claims of 1976 and its Protocol of 1996 · International Regulations for Preventing Collisions at Sea, Rules 5, 7, 8 and 14 · Code of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, A-VIII/2 · United Nations Convention on the Law of the Sea, Article 97
This article has been prepared for general information purposes only and does not constitute legal advice. The information concerning the incident is based on sources in the public domain as at the date of publication, and the presumption of innocence is reserved. Neither the author nor Devin Law & IP represents any of the parties to the incident referred to in this article, acts on instructions from any party or has access to the investigation file. This article does not create an attorney-client relationship and contains no undertaking as to its updating. 15 September 2026.
