In Equitable Life Assurance Society v Bowley [2003] EWHC 2263 (Comm) at [41], Langley J suggested that ‘a company may reasonably, at the least, look to NEDs for independence of judgment and supervision of the executive management’ (emphasis added). Companies do not appoint NEDs without good reason; they are usually chosen for their specific expertise, experience or business connections. NEDs who provide these services can expect to be paid reasonably well for their contributions, but of course this means that they may become financially dependent on the company to a greater or lesser extent. Is it realistic to expect NEDs to be ‘independent’, and to supervise executive management? Equally, is it realistic to expect companies to appoint and pay fees to individuals who have little to offer apart from independence and a policing role?