“Automotive, Food, Metals, Engineering, Printing and Kindred Industries Union” known as the Australian Manufacturing Workers' Union (AMWU) v OS ACPM Pty Ltd T/A BHP Operations Services
[2022] FWC 2850
•28 OCTOBER 2022
| [2022] FWC 2850 |
| FAIR WORK COMMISSION |
| DECISION |
Fair Work Act 2009
s.437—Protected action
“Automotive, Food, Metals, Engineering, Printing and Kindred Industries Union” known as the Australian Manufacturing Workers’ Union (AMWU)
v
OS ACPM Pty Ltd T/A BHP Operations Services
(B2022/1581)
| DEPUTY PRESIDENT DEAN | CANBERRA, 28 OCTOBER 2022 |
Proposed protected action ballot of employees of OS ACPM Pty Ltd T/A BHP Operations Services.
The “Automotive, Food, Metals, Engineering, Printing and Kindred Industries Union” known as the Australian Manufacturing Workers’ Union (AMWU) (Union) has made an application for a protected action ballot order (PABO) pursuant to s. 437 of the Fair Work Act 2009 in relation to certain employees of OS ACPM Pty Ltd T/A BHP Operations Services (Respondent).
The Respondent did not oppose the making of the PABO, however it opposed the appointment of IRIQ Pty Ltd (IRIQ) as the protected action ballot agent (the ballot agent).
As correctly identified by the Union, in the event the Commission does not decide that IRIQ is to be the ballot agent, then the Commission must appoint the AEC as the ballot agent. Irrespective, the Commission must otherwise make the PABO.
A conference conducted on 25 October 2022 failed to resolve the disputed issue. The conference followed extensive submissions and other material filed by both parties. A hearing was subsequently scheduled for 4.15pm on 26 October, however both parties filed additional written submissions and witness statements earlier that day and were content for the matter to be determined on the papers as no persons providing witness statements were required for cross examination.
Amended application
An amended application was filed on 25 October 2022 seeking to correct the references to ‘IRIQ Law Pty Ltd’ (named in the application to be the proposed ballot agent) to ‘IRIQ Pty Ltd’, in addition to some other minor amendments. The Union requested that the Commission allow these amendments pursuant to s.586 of Act. The amendments were sought in response to an objection made by the Respondent that IRIQ Law Pty Ltd had been deregistered in September 2017, despite a number of PABOs having been subsequently made by the Commission appointing this entity as a ballot agent under s.444 of the Act.
I am satisfied that it is appropriate to accept the amended application and make the corrections sought. As will be obvious, the Commission cannot appoint an entity that does not exist as a ballot agent.
Appointment of protected action ballot agent
Section 444(1) of the Act provides that the Commission may decide that a person other than the AEC is to be the ballot agent for a ballot if:
(a)the person is specified in the application for the protected action ballot order as the person the applicant wishes to be the protected action ballot agent; and
(b) the FWC is satisfied that:
(i)the person is a fit and proper person to conduct the ballot; and
(ii)any other requirements prescribed by the regulations are met.
Regulation 3.11 of the Fair Work Regulations 2009 (the Regulation) provides that:
3.11 FWC may decide on ballot agent other than the Australian Electoral Commission—requirements for protected action ballot agent
(1)For subparagraph 444(1)(b)(ii) of the Act, this regulation sets out requirements that the FWC must be satisfied have been met before a person other than the Australian Electoral Commission becomes the protected action ballot agent for a protected action ballot.
Note: The person must also be a fit and proper person to conduct the ballot.
(2)The person must be capable of ensuring the secrecy and security of votes cast in the ballot.
(3)The person must be capable of ensuring that the ballot will be fair and democratic.
(4) The person must be capable of conducting the ballot expeditiously.
(5) The person must have agreed to be a protected action ballot agent.
(6)The person must be bound to comply with the Privacy Act 1988 in respect to the handling of information relating to the protected action ballot.
(7)If the person is an industrial association or a body corporate, the FWC must be satisfied that:
(a)each individual who will carry out the functions of the protected action ballot agent for the industrial association or body corporate is a fit and proper person to conduct the ballot; and
(b)the requirements in subregulations (2) to (6) are met for the individual.
As it is not in dispute that IRIQ is a body corporate, the Commission must be satisfied that each individual who will carry out the functions of the ballot agent for the body corporate is a fit and proper person to conduct the ballot.
It is also not in dispute that a decision under s.444 of the Act to appoint a ballot agent other than the AEC is a discretionary decision.
Having made the amendments to the application sought by the Union, I am satisfied that s.444(1)(a) has been met in that the person specified in the application is the person the applicant wishes to be the ballot agent.
The remaining issues to be determined, then, is whether:
a. the ballot agent is a fit and proper person,
b. the requirements of the Regulation are met, and
c. whether to exercise my discretion to appoint IRIQ as the ballot agent.
The case for the Respondent
The Respondent’s final submissions were as follows:
“7.In respect of section 444(1)(b), the Commission must be satisfied that IRIQ Pty Ltd is a fit and proper person to conduct the ballot.
8.The AMWU asserts, at paragraph 21 of its submissions, that IRIQ is a fit and proper person to conduct the ballot. It is apparent that the AMWU contends that support for that proposition is in paragraphs 16 to 18 of the Statement of Mr Dobson.
9.At paragraph 17 of his statement Mr Dobson asserts that IRIQ Pty Ltd has been appointed the ballot agent in respect of ballots conducted of the workforces of BHP Coal Pty Ltd, DMH Plant Services, Territory Power and Water, ALS Industrial, Queensland Alumina Limited, Komatsu Australia, Opal Packaging Australia, G&S Engineering Services and Lincoln Electric Company.
10.That evidence however, is not correct. A search of the Fair Work Commission's website indicates that, to the extent orders could be located, the ballot agent in respect of the above matters was IRIQ Law Pty Ltd. As reflected in Attachment A to these submissions (ASIC extract), IRIQ Law Pty Ltd was, at each of the relevant times, de-registered.
11.Further, a search of the Fair Work Commission's website does not reveal any matters in which IRIQ Pty Ltd has been appointed as a protected action ballot agent.
12.It is apparent from paragraph 10 that in reliance on material put before the Commission, the Commission has appointed an entity that does not exist as a protected action ballot agent. That is a most unfortunate circumstance, and serves to demonstrate the importance of accurate material being put before the Commission. Reliance on the number of ballots that have actually been conducted, but based on incorrect material, and on the face of the orders by the wrong entity, in the Respondent's submission supports the view that the Commission cannot be satisfied that IRIQ is fit and proper to conduct the important functions of a protected action ballot agent.
13.Contrary to the AMWU's submissions at paragraph 22, it is not for the Respondent to identify a reason why IRIQ is not fit and proper, it is for the AMWU to satisfy the Commission that it is.
14.Having regard to the above, the Commission cannot be satisfied that IRIQ is a fit and proper person to conduct the protected action ballot.
Regulation 3.11
15.The Commission must also be satisfied that each of the requirements in Regulation 3.11 is satisfied.
16.The Respondent does not dispute that the Commission can be satisfied of the matters in sub - regulations (2) to (6) of Regulation 3.11
17.Regulation 3.11(7) however is not satisfied.
18.Regulation 3.11(7) prescribes further requirements about which the Commission must be satisfied if the proposed ballot agent is an industrial association or a body corporate. Those matters apply in addition to the pre-requisites in regulations 3.11(2) to (6).
19.Regulation 3.11(7) provides that where the proposed ballot agent is a body corporate, the FWC must be satisfied that each individual who will carry out the functions of the protected action ballot agent is a fit and proper person to conduct the ballot and the requirements in regulations 3.11(2) to (6) are met.
20.In the Statement of Mr Devjee dated 25 October 2022 and the Statement of Mr Dobson dated 25 October 2022, they both assert that Mr Devjee ‘is the only employee of IRIQ who will carry out the functions of the protected action ballot agent’. The reference to Mr Devjee being the only ‘employee’ is telling. What neither Mr Devjee or Mr Dobson say is that Mr Devjee is the only person who will carry out the functions of the protected action ballot agent. In those circumstances the Commission cannot be satisfied that Mr Devjee is the only ‘individual’ who will carry out the functions of the protected action ballot agent. The absence of satisfactory evidence that Mr Devjee is the only individual who will carry out the functions, and that each of the requirements in regulations 3.11(2) to (6) are satisfied in respect of Mr Devjee is a basis to refuse the application to appoint IRIQ as the ballot agent (see National Tertiary Education Industry Union v Curtin University[2022] FWC 2514 at [50] (NTEU)).
21.Even if the Commission is satisfied that Mr Devjee is the only individual who will carry out the functions of the protected action ballot agent, the Commission cannot be satisfied that Mr Devjee personally is bound to comply with the Privacy Act 1988 (as required by regulation 3.11(6)).
22.The AMWU asserts at paragraph 38 of its submissions that because Mr Devjee is an employee of IRIQ, and IRIQ is obliged to comply with the Privacy Act when carrying out the ballot, the Privacy Act applies to him. To that end the AMWU relies on section 6E(1B) of the Privacy Act.
23.That proposition cannot be accepted. Section 6E(1B) provides that the Privacy Act applies to a ‘small business operator’ where the small business operator is carrying out the functions of a protected action ballot agent. The ‘small business operator’ is IRIQ. It is obliged to comply with the Privacy Act when carrying out a protected action ballot; Mr Devjee is not. Further, it should be noted that ‘small business operators’ are not otherwise required to comply with the Privacy Act (other than in certain narrow circumstances identified in section 6D(4), none of which are relevant here).
24.The effect of the AMWU's submission is that any individual working for an ‘organisation’ that is subject to the Privacy Act is themselves bound to comply with the Privacy Act. That is not so. The Privacy Act only applies to ‘individuals’ where the individual is an ‘organisation’ ( e.g. a sole trader carrying on a business with an annual turnover in excess of $3 million), or for example, where an individual carries on a small business (as a sole trader), and in that capacity is a protected action ballot agent. That is not the position here.
25.Further, in respect of the evidence concerning the application of the Privacy Act to Mr Devjee:
(a) At paragraph 17 of his statement, Mr Devjee says that IRIQ is a small business operator bound to comply with the Privacy Act when conducting a protected action ballot. That is correct, but says nothing in respect of the application of the Privacy Act to Mr Devjee personally.
(b) Other than as described above, Mr Devjee does not make any reference to the Privacy Act in his statement. For example, he does not provide any evidence of his understanding of the requirements of the Privacy Act or how he intends to discharge those requirements when conducting the protected action ballot.
(c) At paragraph 3 of his statutory declaration, Mr Devjee asserts, that because IRIQ is a ‘small business operator’, he is also a small business operator ‘by extension’. That is incorrect for the reasons given above.
(d) At paragraph 14 of his statement, Mr Dobson says IRIQ takes its obligations under the Privacy Act very seriously. Again, this says nothing about the application of those obligations to Mr Devjee. The statement at paragraph 13 that Mr Devjee has extensive experience complying with the Privacy Act should be given no weight in circumstances where that ‘extensive experience’ is not identified and Mr Devjee himself gives no evidence of any such experience or, as outlined above, his understanding of the Privacy Act. Mr Dobson has had an opportunity to put on evidence about the steps IRIQ will take to comply with the Privacy Act, and the steps it will take to ensure Mr Devjee complies. He has not done so.
26.For those reasons, the Commission cannot be satisfied that Mr Devjee is required to comply with the Privacy Act and the requirements in Regulation 3.11(7) and (6) are not satisfied. To that end, it ought to be borne in mind that the Commission must reach the requisite state of satisfaction on the basis of some reasonably probative evidence.” (footnotes and citations omitted)
The case for the Union
In reply, the Union made the following submissions:
“1.In the material filed by the Respondent, no positive case is put against the appointment of IRIQ Pty Ltd as a ballot agent.
2.No issue is taken by the Respondent with the manner in which the ballot is to be conducted or the means by which this is to occur.
3.The Applicant’s evidence is uncontested.
4.No evidence has been adduced to counter any of the evidence lodged by the Applicant (despite the Respondent being afforded many opportunities to do so).
5.Rather, the Respondent’s objections are technical objections principally of form and not substance.
6.Moreover, many have now been addressed. The Respondent now appears to accept that:
(a) IRIQ Pty Ltd meets the requirements of the FW Regulations;
(b) Mr Devjee is a fit and proper person.
7.All that remains in contention, is:
(a) whether IRIQ Pty Ltd is a fit and proper person, only on the discrete issue of Mr Dobson’s evidence in respect of the title of the entity referred to in previous decisions of the Commission;
(b) whether reg. 3.11(7) is satisfied in respect of Mr Devjee, in respect of:
(i)whether Mr Devjee is the only individual who will carry out the functions of the protected action ballot agent; and,
(ii)whether Mr Devjee is bound by the Privacy Act.
(c) whether the Commission should otherwise exercise its discretion to appoint IRIQ Pty Ltd.
8.We address each matter in turn.
IRIQ Pty Ltd is a fit and proper person
9.The only basis on which the Respondent claims that IRIQ Pty Ltd is not a fit and proper person is, in essence, that where Mr Dobson gives evidence that IRIQ Pty Ltd has previously acted as a protected action ballot agent, that the relevant ballot agent was IRIQ Law Pty Ltd and that his evidence is ‘not correct’ [8 – 10].
10.The Respondent’s contentions do not provide any adequate basis to conclude that IRIQ Pty Ltd is not a fit and proper person to conduct the ballot.
11.First, the Respondent by requesting that the matter be determined on the papers has expressly elected not to cross-examine Mr Dobson in respect of his evidence.
12.If the Respondent wished to assert that Mr Dobson was somehow not credible or deliberately giving untrue evidence, such a proposition should be put to a witness. It has opted not to do so.
13.Mr Dobson gives evidence that it is IRIQ Pty Ltd who has conducted these ballots in accordance with the relevant orders issued by the Commission.
14.Mr Devjee is an employee of that entity.
15.A review of those decisions make clear that it is Mr Devjee who is expressly referred to as the employee providing a statutory declaration on behalf of the ballot agent in those matters (see, for example, [2022] FWC 2617 and [2022] FWC 2729).
16.In those matters, it is plain that the person proposed in the application was IRIQ Law Pty Ltd.
17.The correct naming of the ballot agent in the application is, naturally, the responsibility of the applicant in each application (and not the ballot agent).
18.In this matter, there was a regrettable error in the application in listing the title of the entity conducting the balloting made by the Applicant which was corrected on being made aware of its error. (footnote omitted)
19.There was no error on the part of IRIQ Pty Ltd which did not misidentify itself in the statutory declaration submitted to the Commission.
20.It will not be lost on the Commission that, with one exception, in the matters where IRIQ Law Pty Ltd has been appointed as the protected action ballot agent it is the present Applicant who has made the application (the sole exception involved the CEPU in [2022] FWC 2617, a decision which is in near identical terms to [2022] FWC 2617). We also observe that in the matter of Australian Manufacturing Workers' Union (AMWU) v G & S Engineering Services Pty Ltd [2021] FWC 3909, directions were expressly issued that ‘IRIQ Pty Ltd T/A IRIQ Law’ conduct the ballot – see PR731372.
21.Third, the unchallenged evidence of Mr Dobson is that IRIQ Pty Ltd:
(a) is wholly independent of the Applicant and the Respondent in these proceedings;
(b) it derives no interest, financial or otherwise, in the outcome of any ballot or election we conduct and we are paid regardless of the outcome;
(c) has never been the subject of any complaint, sanction or penalty, in respect of any contravention of workplace, privacy or corporations’ laws (or any other laws);
(d) has never been sued;
(e) has conducted ballots in accordance with the relevant orders issued by the Commission and any other directions made by the Commission;
(f) an independent advisor has never been appointed previously where IRIQ Pty Ltd has conducted ballots in the past.
22.Each of these matters should fortify the Commission in a conclusion that IRIQ Pty Ltd is a fit and proper person and the objection ought not be upheld on this basis.
Mr Devjee only person to carry out ballot
23.The submission at paragraph [20], that the Commission cannot be satisfied that Mr Devjee is the only ‘individual’ who will carry out the functions of the protected action ballot agent, because the statements of Mr Devjee and Dobson state that he is the only ‘employee’ who will carry out the functions, is pure speculation.
24.Again, if the Respondent wished to make such a submission, the proposition that the witnesses deliberately omitted any reference to others being involved in the process ought to have been put to them. The Respondent has deliberately elected not to do so.
25.The submission is also incorrect. At paragraph [23] of Mr Dobson’s statement he expressly states:
“Mr Devjee was authorised by IRIQ Pty Ltd to make the statutory declaration and statement already filed in this proceeding, on behalf of IRIQ Pty Ltd as to the company’s suitability to act as ballot agent and his own suitability as the individual who will carry out the functions of the protected action ballot agent for the body corporate. [Our emphasis)]”
26.This ground cannot be upheld and the Commission can be satisfied that it is Mr Devjee alone who will be carrying out the functions of the ballot agent on behalf of IRIQ Pty Ltd.
Mr Devjee bound to comply with the Privacy Act
27.It is not disputed that IRIQ Pty Ltd is bound by the Privacy Act.
28.The contention that Mr Devjee is not bound by the Privacy Act, is incorrect.
29.Section 6E(1B) of the Privacy Act, provides that:
“… if a small business operator is the protected action ballot agent for a protected action ballot conducted under Part 3‑3 of the Fair Work Act 2009, this Act applies, with the prescribed modifications (if any), in relation to the activities carried on by the small business operator for the purpose of, or in connection with, the conduct of the protected action ballot, as if the small business operator were an organisation.”
30.Mr Devjee’s activities performing the functions of ballot agent are taken on behalf of IRIQ Pty Ltd as its employee and with its express authority (as is apparent from the material filed with the Commission).
31.A company has no physical existence and can only act through its employees and agents.
32.So much is reflected in provisions of the Privacy Act which have the effect that:
(a) conduct engaged in by Mr Devjee on behalf of IRIQ Pty Ltd as an employee within the scope of his actual or apparent authority is taken for the purposes of a prosecution for an offence against the Privacy Act or proceedings for a civil penalty order under the Regulatory Powers Act (as it applies in relation to the civil penalty provisions of the Privacy Act), to have been engaged in also by the body corporate unless the body corporate establishes that the body corporate took reasonable precautions and exercised due diligence to avoid the conduct (s. 99A(2) of the Privacy Act);
(b) where it is necessary to establish the state of mind of IRIQ Pty Ltd in respect of particular conduct, it is sufficient to show that the conduct was engaged in by Mr Devjee as an employee within the scope of his actual or apparent authority and that he had that state of mind (s. 99A(1) of the Privacy Act).
33.In performing the functions of ballot agent on behalf of IRIQ Pty Ltd, Mr Devjee is thereby bound by the Privacy Act and, his conduct is taken to be that of IRIQ Pty Ltd where it is engaged in as an employee within the scope of his actual or apparent authority.
34.The import of the Respondent’s submission is that no employee of a business could perform the functions of a protected ballot agent. Such a conclusion would undermine a number of prior decisions of the Commission (not least those involving Mr Devjee). This type of absurd outcome, plainly was not intended by the framers of reg. 3.11 of the FW Regulations.
35.Finally, the Respondent’s characterisation of the Applicant’s evidence as to IRIQ Pty Ltd’s and Mr Devjee’s commitments to observe their obligations under the Privacy Act [25(d)] are unwarranted. The material lodged by Mr Dobson and Devjee both expressly refer to their obligations under the Privacy Act (and commit to them). There is adequate material before the Commission to conclude they will observe their obligations.
Commission should exercise its discretion to appoint IRIQ Pty Ltd
36.Again, the Respondent has advanced no positive case, founded on evidence, as to why the Commission ought not exercise its discretion to appoint IRIQ Pty Ltd as a ballot agent.
37.We have addressed above the purported (single) alleged inaccuracy in respect of the evidence of Mr Dobson. This proposition has not been put to the witness in cross - examination and is a mere submission. Nothing in these decisions or the material filed by the Applicant would lead the Commission to conclude that IRIQ Pty Ltd was anything other than a fit and proper person to conduct a ballot.
38.Mere ‘residual concerns’ about whether the Privacy Act applies are no basis not to exercise the discretion. The Commission is either satisfied the requirements of the FW Regulations are met or it is not. If it is not, then it does need to make a discretionary discretion.
39.Finally, the FW Act allows an applicant to nominate another ballot agent, other than the AEC.
40.Cogent and compelling reasons have been expressed for this. The Commission can comfortably exercise its discretion to appoint IRIQ Pty Ltd as the ballot agent, having regard to the dispersed nature of the Respondent’s workforce and the efficiencies in the manner the ballot is to be conducted (none of the evidence in respect of this is challenged).
41.The Applicant submits that on the evidence before you and in the absence of any countervailing evidence, IRIQ Pty Ltd is a suitable ballot agent to appoint.
42.Whether you decide to appoint IRIQ Pty Ltd or not, we submit, there is no basis not to make the order.
43.Finally, for clarity, paragraph 42(d) of the AMWU’s outline of submissions filed 26 October 2022 was included in error and is not relied upon.”
Consideration
Particularly in cases where PABO applications are not contested, the Commission relies heavily on accurate information being provided to it, both in the application itself and in the statutory declaration filed in support of such application. The Commission should be able to rely on applicant unions to provide accurate information.
What has become clear through the evidence and submissions filed in this matter is that the Commission was misled in the previous applications relied on by the Union in making orders nominating a ballot agent that did not exist. The consequence that arguably flows from an invalid ballot (given the ballot agent does not exist), is that any industrial action subsequently taken by employees would not be protected, leaving such employees exposed to the consequences of taking unprotected industrial action.
As the Respondent correctly submitted, it is not for the Respondent to dissuade the Commission that the requirements of section 444 have not been met. The onus lies solely with the Union to satisfy the Commission as to these matters.
Here, the Respondent identified the deficiencies with the application immediately on being asked by the Commission to respond to the application, however it took four attempts by the Union (in the form of further evidence and submissions) to adequately respond to the matters raised.
To the extent these matters have not already been dealt with this in this decision, I find the following:
a. I do not accept the Respondent’s objections are “technical objections principally of form and not substance”. The requirement for the Commission to be satisfied as to the requirements of s.444 and the Regulation are not trivial matters to be taken lightly.
b. While I agree that “IRIQ did not misidentify itself in a statutory declaration submitted to the Commission”, in my view there remains an obligation on the proposed ballot agent, upon receipt of the Order issued by the Commission, to ensure that the entity the Commission has appointed as ballot agent is in fact the entity that undertakes the ballot in accordance with the requirements. This weighs against a finding that IRIQ is a fit and proper person to be appointed a ballot agent.
c. I am satisfied that if IRIQ is appointed the ballot agent, Mr Devjee will be the individual who will carry out the functions of the ballot agent on behalf of IRIQ, based on the evidence of Mr Dobson[1]. As the evidence confirms he will be “the individual”, and so I am satisfied it will be Mr Devjeee alone who will carry out these functions.
d. I agree with the Unions submissions as to the application of the Privacy Act to Mr Devjee. For the reasons contended by the Union, I accept he is bound by it when performing the functions of the ballot agent taken on behalf of IRIQ. I agree with the Union that if the Respondent were correct in its interpretation, it would have the effect that no employee of a business could perform the functions of a ballot agent, which I accept is not the intention of the legislation.
e. On the basis of the material before me, including the declaration of Kegan Scherf of AMWU made on 14 October 2022 setting out the steps taken by them in bargaining with the Respondent and that they have been, and are, genuinely trying to reach agreement with the Respondent, I am satisfied that there is a notification time in relation to the proposed agreement and that the requirements in s.443(1) of the Act have been met.
While it has been a difficult decision given the persuasive arguments put by the Respondent, I am satisfied, having weighed all the evidence, that IRIQ is capable of being appointed as the ballot agent. This is primarily based on the uncontested evidence of Mr Dobson and Mr Devjee as to each of the matters required to be satisfied which are set out in the Regulation. The decision has been difficult because IRIQ have clearly undertaken ballots in relation to other PABO applications where IRIQ Law Pty Ltd was the nominated ballot agent, and when IRIQ must have been aware that that entity did not exist. Likewise, it is concerning that the Union continued to rely on PABOs made by the Commission in other applications where IRIQ Law Pty Ltd was appointed as a ballot agent, simply characterising it as a “regrettable error”, to support the making of a PABO in this application.
On balance, having weighed all the evidence, I am satisfied that IRIQ has demonstrated it is a fit and proper person to conduct the ballot.
The final question then is whether the Commission should exercise its discretion to appoint IRIQ as the ballot agent. Based on the evidence of Mr Scherf, I am satisfied such discretion should be exercised. I accept an electronic ballot will be more convenient and accessible for employees than a paper ballot undertaken by the AEC, particularly where access to a paper ballot may be difficult given the geographic location of employees including where their rosters may require them to remain away from their homes for extended periods of time.
Conclusion
The PABO is made in the terms set out in PR747145.
DEPUTY PRESIDENT
[1] See paragraph 23 of Statement of Dean Dobson.
Printed by authority of the Commonwealth Government Printer
<PR747144>
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