Fair Work Ombudsman v Bikaner India (WA) Pty Ltd (no 2)
[2023] FedCFamC2G 211
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 2)
Fair Work Ombudsman v Bikaner India (WA) Pty Ltd (no 2) [2023] FedCFamC2G 211
File number(s): SYG 1182 of 2019 Judgment of: JUDGE HUMPHREYS Date of judgment: 22 March 2023 Catchwords: INDUSTRIAL LAW – Fair Work Act – Restaurant Industry Award 2010 – penalty hearing – 16 contraventions – significant contraventions. Legislation: Fair Work Act 2009 (Cth) ss 44, 45, 323, 325, 340, 535, 536, 546, 550, 557
Fair Work Regulations 2009 (Cth)
Workers’ Compensation and Assistance Act 1981 (WA)
Cases cited: Australian Building and Construction Commissioner v Pattinson [2022] HCA 13
Australian Ophthalmic Supplies Pty Ltd v McAlary‑Smith (2008) 165 FCR 560
Canturi v Sita Coaches Pty Ltd (2002) 116 FCR 276
Fair Work Ombudsman v Bikaner India (WA) Pty Ltd [2023] FedCFamC2G 20
Fair Work Ombudsman v Lohr [2018] FCA 5
Fair Work Ombudsman v Nobrace Centre Pty Ltd (in Liquidation) [2019] FCCA 2979
Fair Work Ombudsman v NSH North Pty Ltd t/as New Shanghai Charlestown [2017] FCA 1301
Fair Work Ombudsman v Taj Palace Tandoori Indian Restaurant Pty Ltd & Anor [2012] FMCA 258
Mason v Harrington Corporation Pty Ltd [2007] FMCA 7
Mornington Inn Pty Ltd v Jordan (2008) 168 FCR 383
Seven Network (Operations) Pty Ltd v Communications, Electrical, Electronic, Energy Information, Postal Plumbing and Allied Services Union of Australia (CEPU) (2001) 110 IR 372
Division: Division 2 General Federal Law Number of paragraphs: 35 Date of last submission/s: 15 February 2023 Date of hearing: In chambers Place: Parramatta Solicitor for the Applicant: Ms Alamyar Solicitor for the Respondents: No submissions filed on behalf of the Respondent. ORDERS
SYG 1182 of 2019 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)
BETWEEN: FAIR WORK OMBUDSMAN
Applicant
AND: BIKANER INDIA (WA) PTY LTD (ACN 158 171 156)
First Respondent
SUSHIL KUMAR
Second Respondent
order made by:
JUDGE HUMPHREYS
DATE OF ORDER:
22 March 2023
THE COURT ORDERS THAT:
1.Pursuant to s 546(1) of the Fair Work Act 2009 (Cth) (“the Act”), within 21 days of this order, the Second Respondent a pecuniary penalty of $58,950.00 to the Commonwealth for the Second Respondent’s involvement, pursuant to s 550 of the Act, in the contraventions of the First Respondent, as declared at order 1 of the orders of Judge Humphreys dated 24 January 2023.
2.The Applicant has liberty to apply on seven days’ notice in the event that order 1 above is not complied with.
Note: The form of the order is subject to the entry in the Court’s records.
Note: The Court may vary or set aside a judgment or order to remedy minor typographical or grammatical errors (r 17.05(2)(g) Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 17.05 Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth).
REASONS FOR JUDGMENT
JUDGE HUMPRHEYS
INTRODUCTION
This judgment concerns the consideration of the appropriate penalty to be imposed on the second respondent Mr Sushil Kumar, following the Court’s finding that he committed 16 contraventions of the Fair Work Act 2009 (Cth) (“the Act”) in Fair Work Ombudsman v Bikaner India (WA) Pty Ltd [2023] FedCFamC2G 20.
The Court found that Mr Kumar contravened the following provisions of the Act:
a) section 45 of the Act and clause 20.1 of the Restaurant Industry Award 2010 (“Award”), by failing to pay to Mr Hasan the required minimum rate of pay;
b) section 45 of the Act and clause 34.1 of the Award, by failing to pay to Mr Hasan the required public holiday penalty rates;
c) sections 44(1) and 116 of the Act, by failing to pay Mr Hasan for work not performed on a public holiday;
d) section 45 of the Act and clause 34.2(a)(i) of the Award, by failing to pay to Mr Hasan the required evening penalty rates;
e) section 45 of the Act and clause 33.1 of the Award, by failing to pay to Mr Hasan the required overtime rates;
f) section 45 of the Act and clause 33.2 of the Award, by failing to pay to Mr Hasan the required Saturday overtime rates;
g) section 45 of the Act and clause 33.2 of the Award, by failing to pay to Mr Hasan the required Sunday overtime rates;
h) section 45 of the Act and clause 31.2(e) of the Award, by failing to provide Mr Hasan with eight full days off;
i) section 45 of the Act and clause 27.2 of the Award, by failing to pay to Mr Hasan either weekly or fortnightly;
j) section 45 of the Act and clause 30.2(a) of the Award, by failing to pay to Mr Hasan his superannuation payments;
k) section 325(1) of the Act, by requiring Mr Hasan to pay back to the First Respondent an amount from his wages each pay;
l) section 323(1)(a) of the Act, by failing to pay Mr Hasan any wages for the periods 21 December 2015 to 9 February 2016 and 3 April 2016 to 10 June 2016;
m) sections 44(1) and 90(2) of the Act, by failing to pay Mr Hasan his annual leave entitlements upon termination of his employment;
n) section 535(1) of the Act, by failing to make and keep records in respect of Mr Hasan prescribed by regulations 3.32(e), 3.32(f), 3.33(1), 3.33(3), 3.34, and 3.36 of the Fair Work Regulations 2009 (Cth);
o) section 536(1) of the Act, by failing to issue payslips to Mr Hasan within one working day of payment; and
p) section 340(1) of the Act, by taking adverse action against Mr Hasan by dismissing him, because Mr Hasan exercised his workplace right to make a claim for compensation under the Workers’ Compensation and Assistance Act 1981 (WA).
Following delivery of the liability judgment, the matter was listed for a directions hearing to prepare the matter for penalty hearing, however there was no appearance by or on behalf of Mr Kumar. The Courts notes that Mr Kumar’s legal representatives withdrew from the matter shortly after the liability judgment was handed down, however no Notice of Address for Service or any other document has been filed by Mr Kumar since. Due to the default of Mr Kumar, at the request of the applicant the Court has dealt with the issue of penalty in Chambers on the papers.
SERIOUS CONTRAVENTIONS AND MAXIMUM PENALTIES
The Court notes that the applicant’s position is that the number and nature of the contraventions are objectively serious. Pursuant to s 539 of the Act, the maximum penalty that the Court can impose for serious breaches of ss 535 and 536 of the Act is $5,400.00, and $10,800.00 for breaches of ss 44, 45, 323, 325 and 340 of the Act. Accordingly, the maximum penalty available for the 16 breaches amounts to $162,000.00. The Court notes that the applicant has sought to separate the contraventions of s 535 of the Act which would result in three additional contraventions being applied than what was found in the Court’s previous judgment. The Total maximum suggested by the applicant is $178,300.00.
THE LAW IN RELATION TO THE CONSIDERATION OF PENALTIES UNDER THE ACT
The Court has a broad discretion as to penalty. In Australian Building and Construction Commissioner v Pattinson [2022] HCA 13 at [71], it was stated that the Court should fix a penalty ‘it considers fairly and reasonably to be appropriate to protect the public interest from future contraventions of the Act’. Further, at [10] and [12], the High Court stated that the penalty must not exceed what is ‘reasonably necessary to achieve the purpose of s 546 of the Act, the deterrence of future contraventions of a like kind by the contravener and others’.
In Fair Work Ombudsman v NSH North Pty Ltd t/as New Shanghai Charlestown [2017] FCA 1301 (“NSH North Pty Ltd”) Bromwich J summarised how the discretion is to be approached at [36], as follows:
1. Identify the separate contraventions, with each breach of each obligation being a separate contravention, and each breach of a term of the Award being a separate contravention.
2. Consider whether each separate contravention should be dealt with independently or with some degree of aggregation for those contraventions arising out of a course of conduct, noting that s 557 of the Act provides that two or more contraventions of a given civil remedy provision are to be taken to be a single contravention if committed by the same person and arising out of a course of conduct by that person.
3. Consider whether there should be further adjustment to ensure that, to the extent of any overlap between groups of separate aggregated contraventions, there is no double penalty imposed, and that the penalty is an appropriate response to what each respondent did.
4. Consider the appropriate penalty in respect of each final individual group of contraventions, taken in isolation.
5. Consider the overall penalties arrived at, including by reference to those which may be proposed by the FWO (as permitted by Commonwealth v Director, Fair Work Building Industry Inspectorate [2015] HCA 46; 258 CLR 482 (CFMEU Civil Penalties Case) at [64]) and what is proposed by the respondents, and apply the totality principle, to ensure that the penalties for each respondent are appropriate and proportionate to the conduct viewed as a whole, making such adjustments as are necessary: (see; Kelly v Fitzpatrick [2007] FCA 1080; 166 IR 14 at [30]; Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith [2008] FCAFC 8; 165 FCR 560 at [23]. [71] and [102]).
The purpose of a civil penalty is primarily, if not wholly, is promoting the public interest in compliance with the laws that have been contravened, and it does not engage principles of retribution or rehabilitation: (see; Fair Work Ombudsman v Nobrace Centre Pty Ltd (in Liquidation) [2019] FCCA 2979 (“NoBrace”) per Kelly J at [65]. As these principles of retribution or rehabilitation are not involved in the determination of a civil penalty, this intensifies the focus of a civil penalty determination on issues of specific and general deterrence: (see; Nobrace at [66]).
The Act does not set out any mandatory criteria, inclusive or exclusive, that the Court must consider when determining whether to impose a penalty or the amount of any penalty: (see; Canturi v Sita Coaches Pty Ltd (2002) 116 FCR 276 at [88]). The choice of penalty must be guided by the “individual circumstances of a case, not by a line-by-line comparison with another case”: (see; Australian Ophthalmic Supplies Pty Ltd v McAlary‑Smith (2008) 165 FCR 560 at [12]). The process is an intuitive one by the Court and not an application of a scientific process: (see; Mornington Inn Pty Ltd v Jordan (2008) 168 FCR 383 at [60]‑[63]).
In Mason v Harrington Corporation Pty Ltd [2007] FMCA 7 (“Mason v Harrington”), Mobray FCM set out what is a now well accepted set of factors relevant in assessing a pecuniary penalty. They are as follows:
a) the nature and extent of the conduct which led to the breaches;
b) the circumstances in which the conduct took place;
c) the nature and extent of any loss sustained as a result of the breaches;
d) whether there has been similar previous conduct by the Respondents;
e) whether the breaches were properly distinct or arose out of one course of conduct;
f) the size of the business enterprise involved;
g) whether or not the breaches were deliberate;
h) whether senior management was involved in the breaches;
i) whether the party committing the breach had exhibited contrition;
j) whether the party committing the breach had taken corrective action;
k) whether the party committing the breach had cooperated with enforcement authorities;
l) the need to ensure compliance with minimum standards by provision of an effective means for the investigation and enforcement of employee entitlements; and
m) The need for specific and general deterrence.
Merkel J in Seven Network (Operations) Pty Ltd v Communications, Electrical, Electronic, Energy Information, Postal Plumbing and Allied Services Union of Australia (CEPU) (2001) 110 IR 372 set out some guiding considerations for the Court at [374]:
[374] Matters to be taken into account in determining the appropriate penalty include the cost of the contravention, deterrence, the flagrancy and deliberateness of the breach, the offender’s past record of behaviour and any contrition displayed by the offender.
EVIDENCE
The Fair Work Ombudsman (“FWO”) relied upon two Affidavits of Ms Girach and one Affidavit of Mr Hasan. Ms Girach was the Fair Work Inspector allocated to investigate the complaint of Mr Hasan (“the complainant”), an employee of the first respondent. Mr Hasan’s complaints are recorded in his Affidavit of 10 December 2020. Ms Girach’s Affidavit of 10 December 2020 provides an account of the investigation and the materials received by the Fair Work Ombudsman in relation to the complaints raised. Her Affidavit of 14 February 2023 provides the results to various searches relevant to these proceedings and to the issue of penalty.
THE FAIR WORK OMBUDSMAN’S SUBMISSIONS
The FWO submitted that s 557 of the Act provides that two or more contraventions of the same civil remedy provision of the Act will be treated as a single contravention where those contraventions were committed by the same person and in the same course of conduct. However, this does not apply to contraventions across different civil remedy provisions at s 557(2) of the Act. Each clause in the National Employment Standards or award must also be treated separately for the purpose of s 557. It was submitted that the fact that an employer contravened the Act by paying a flat rate does not justify aggregating contraventions of separate clauses: (see; Fair Work Ombudsman v Lohr [2018] FCA 5 at [33]-[34]).
The FWO submitted that Mr Kumar is entitled to the benefit of s 557(1) of the Act with respect to repeated contraventions of the obligations under the Award or the Act.
It was submitted that the contraventions of s 535(1) of the Act could be divided into three categories, namely failure to make and keep:
a) employee records for Mr Hasan specifying his commencement date and the Australian Business Number of the employer, as prescribed by regulation 3.32(e) and (f) of the Migration Regulations 1994 (Cth) (“the Regulations”);
b) records of Mr Hasan’s actual rate of remuneration, gross and net amounts paid, any deductions made, and any separately identifiable entitlement, as prescribed by regulation 3.31(1) and (3) of the Regulations;
c) records of Mr Hasan’s overtime hours worked as prescribed by regulation 3.34 of the Regulations; and
d) records of Mr Hasan’s leave entitlements as prescribed by regulation 3.36 of the Regulations.
It was submitted that these categories should be treated as separate breaches as there was no evidence to suggest that the above contraventions came as the result of a single decision of Mr Kumar.
The FWO submitted that the Court should consider applying the common law principle of course of conduct to ensure that Mr Kumar does not get penalised twice for the same conduct. However, it was submitted that there should not no further grouping of the contraventions as each arises from separate and distinct obligations and doing so would give insufficient weight to their separate legal character.
In relation to the nature and circumstances of the contraventions it was submitted that they occurred over a ten-month period. Despite only affecting one employee, the number and nature of these contraventions are objectively serious. The record keeping and pay slip contraventions made it difficult for the complainant to enforce his entitlements and the underpayments were significant. Mr Kumar was involved with the administration of the business at all times, had actual knowledge of the Award and the business affairs of the business at all relevant times, was knowingly involved in the relevant decision of the business, and personally received cash back from the complainant.
The FWO submitted that Mr Kumar’s deliberate conduct lead to the contraventions. Mr Kumar is an experienced company director, had actual knowledge of the relevant provisions of the Award and the Act. Mr Kumar also conceded at the previous hearing that he was aware of the unlawfulness of failing to comply with the relevant obligations owed to employees. Mr Kumar bears the onus of proof to present evidence demonstrating that the contraventions arose out of inadvertence or accident, of which none has been adduced. It was submitted that deliberateness is heightened in relation to the adverse action as Mr Kumar developed a false scheme to terminate the complainant with erroneous termination letters. Similar attempts were made with the production of retrospective pay slips. The FWO drew the Courts attention to evidence that Mr Kumar has had a number of previous interactions with the FWO and was on notice of similar employer obligations.
It was submitted by the FWO that the complainant fell within a vulnerable class of person, being a subclass 457 visa migrant worker who was highly dependent on their employer nominator. This relationship between employee, and nominator and employer reflects a power imbalance that was exploited by Mr Kumar.
The complainant was underpaid a significant sum of money in the amount of $38,822.68, of which none has been paid. This is despite the Court’s previous orders requiring this amount to be repaid by 21 February 2023. The complainant’s Affidavit explains the effect of these underpayments with him experiencing difficulty supporting himself, his wife and three year old daughter in relation to their costs of living. The contraventions have also occasioned a public loss by undermining the statutory objective of the Act.
The contraventions deprived the complainant the benefit of the minimum safety net provided by the Fair Work legislation. They reflect Mr Kumar’s prioritisation of his and his business’ own interest at the expense of the complainant’s. It was submitted that inadequate record keeping undermines the enforcement of workplace laws and, consequently, the effectiveness of the statutory safety net for employees. The failure to issue payslips may significantly disempower employees and create a structure which breaches of industrial laws can easily be perpetrated: (see; Fair Work Ombudsman v Taj Palace Tandoori Indian Restaurant Pty Ltd & Anor [2012] FMCA 258 at [67]).
The FWO submitted that, as at the date of their submissions on 14 February 2023, there was no evidence of corrective action or contrition from Mr Kumar and as such, no discount on penalty is warranted. Mr Kumar continued to deny his liability throughout the matter and was found to not be a witness of truth, maintaining a false narrative throughout the proceeding.
It was submitted that no evidence has been put forward to date in relation to Mr Kumar’s current financial position.
The FWO presented data collected from the Fair Work Ombudsman’s Strategic Research, Analysis and Reporting Team which displays the dispute rate for the café and restaurant industry as ‘high’ and the number one industry as a proportion of total disputes lodged with the Fair Work Ombudsman. As such, general deterrence is of particular importance. There is also the need for general deterrence in respect of employers of foreign national and visa holders, as well as contraventions in respect of record keeping given the impact it has on workplace compliance.
Although Mr Kumar is not currently the director of any company, it was submitted that he has been a director of at least one company at all times between 1994 and 2020. He is currently not the director of a company due to being the subject of a Notice of Disqualification from managing corporations for three years, due to expire in September 2023. It was submitted that there is a real possibility that Mr Kumar may seek to manage businesses, operate restaurants, and employ staff in the future. A sufficient penalty should be imposed to ensure that he will seek to avoid the risk of subjection to future penalties.
Based on consideration on the above factors, the FWO submitted that appropriate range for penalties is $44,000.00 to $56,000.00, after applying a 25% reduction according to the principle of totality.
THE RESPONDENT’S SUBMISIONS
The Court notes that no submissions had been filed on behalf of the second respondent Mr Kumar and as noted above, did not appear at a directions hearing on 10 March 2023. The Court is given what consideration it can based on the material that has before it to the respondent’s circumstances as applicable to the termination of penalty.
CONSIDERATION
The Court has adopted the approach described by Bromwich J in NSH North shore Pty Ltd. Each of the breaches is set out below in tabular form. This includes the maximum penalty payable for each breach. Whilst it has been submitted that each of the breaches should attract a separate penalty, the Court does not exceed to this submission. The Court is of the view that the breaches under ss 45 and 44 of the Act should be dealt with in an aggregated manner rather than as separate breaches. Each of the other matters can be properly regarded as separate matters which require the imposition of a separate penalty. Using this basis, the maximum penalty is payable are $64,800.00. However, in aggregating the breaches under s 45 of the Act, given the significant number of breaches, a much greater penalty needs to be imposed that might otherwise be the case.
In terms of the set of factors relevant in assessing a pecuniary penalty, the Court finds as follows:
a. The conduct which led to the breaches was highly organised, planned and deliberate. The conduct extended over a 10 month period and involved both deception on the part of Mr Kumar in relation to the entitlements of the complainant as well is a significant failure to abide by minimum standards of remuneration applicable under the relevant award. The underpayments were aggravated by the wrongful action of Mr Kumar to purport to terminate unlawfully the applicant that having made a workers compensation claim.
b. The complainant was a vulnerable person who was recruited from overseas to fill the position of cook within Mr Kumar’s restaurant. The exploitation of such persons is a matter of the utmost seriousness and deserving of not only public condemnation but the imposition of significant penalties.
c. The complainant over a relatively short period of time was underpaid an amount of approximately $39,000.00, none of which is been paid following the orders of this Court in the previous judgement. This is a significantly aggravating factor noting the complainant was left without any income in a foreign country in circumstances where Mr Kumar reported his unlawful termination to relevant migration authorities which caused further distress to the applicant in circumstances where he was unable to support himself his wife and child. Workers in these circumstances require strong support by the courts in terms of the imposition of penalties so it becomes clear that those who seek to exploit vulnerable fine workers bought here on temporary work permits, will not be tolerated and that any financial advantage that might be gained will be more than offset by the imposition a pecuniary penalties.
d. The Court is aware that the applicant has had previous interaction with the Fair Work Ombudsman in relation to underpayments and other breaches but these have been resolved without the necessity to litigation. The fact that Mr Kumar went on to commit a large number of serious contraventions is again a matter of some significant aggravation.
e. The Court is taken account of whether not all the breaches were distinct and is found that the underpayments arose out of a single course of action.
f. No evidence has been provided as to the size of the business enterprise involved. Other than material provided during the course of the hearing that indicated that the business was part owned by Mr Kumar and employed the applicant along with three identified other persons together with some wait staff.
g. The Court is satisfied that the breaches were planned deliberate and continuing.
h. Mr Kumar, as the director of the business was the senior manager and was directly involved in each of the contraventions.
i. Mr Kumar has not exhibited one iota of remorse or contrition. His actions have been aggravated by what the Court has found to be a deliberate attempt to mislead both the Fair Work Ombudsman and the Court through a false narrative supported by fabricated documents, including payslips that were produced after an investigation commenced by the Fair Work Ombudsman together with fabricated termination notices which purported to terminate the complainant at an earlier date that in fact occurred.
j. Mr Kumar has taken no corrective action and again, this is a significantly aggravating circumstance.
k. There has been some cooperation with the Fair Work Ombudsman in that some records were made available. Mr Kumar did attend for an interview. However, as against this, he has consistently maintained a false narrative, and has required the Fair Work Ombudsman to be put to proof in relation to each of the contraventions pleaded.
l. In this case, the Court takes great account of the need to ensure compliance with minimum standards for the payment of employees through an effective means for the investigation and enforcement of employee entitlements. The lack of cooperation and false denials of liability are aggravating circumstances of this case
m. The Court notes the high degree of complaints in relation to the café and restaurant industry and that there was a need for strong general deterrence. In the current case, noting the degree of deliberateness, planning and deception committed by Mr Kumar, the need for specific deterrence is at the very high-end of the available considerations when assessing appropriate penalties.
The Court is of the view given the seriousness of the conduct of Mr Kumar that a penalty of 90% of the maximum for all breaches is appropriate with one exception. That exception is the breach under s 325(1) of the Act in requiring the complainant to pay back some of his wages. This was explained to the complainant as being ‘a condition of his visa’. This type of conduct must fall into the most serious of categories and calls for a penalty that clearly indicates the Court’s disapproval of this contravention and is necessary to protect the public interest from future contraventions. The Court is of the view that a penalty of 95% of the maximum available is appropriate.
The Court has considered the submission that any penalties should be reduced by an amount of 25% on the basis of totality. Given the lack of any contrition or corrective action by Mr Kumar, along with his absence from the proceedings post the liability judgement, the Court is of the view that no reduction on the basis of totality is appropriate. In arriving at these penalties, the Court has considered the total penalty as proposed by the FWO and has ensured that the penalties are appropriately apportioned to the conduct as a whole.
In all the circumstances, the Court imposes the following penalties:
Contravention Recommended Penalty Imposed Penalty s 44 of the Act (2 breaches) $3,240-$5,400 $9,750 s 45 of the Act (9 breaches) $31,860-$41,040 $9,750 s 323(1) of the Act (1 breach) $0-$0 $9,750 s 325(1) of the Act (1 breach) $7,560-$8,640 $10,250 s 340(1) of the Act (1 breach) $7,560-$8,640 $9,750 s 535(1) of the Act (1 breach) $4,590-$6,480 $4,850 s 536 of the Act (1) (1 breach) $3,780-$4.320 $4,850 Subtotal $58,590-$74,520 - Total After Reduction $44,000-$56,000 $58,950 CONCLUSION
The penalties imposed are to be paid within 21 days of the date of this judgement and are to be paid to the applicant in accordance with the relevant provisions of the Act.
The Court notes that its role is restricted by the Act to the imposition of pecuniary penalties only. Whether the penalties will ever be paid by Mr Kumar is a moot point.
The conduct, as found by the Court, of Mr Kumar in a planned and deliberate exploitation of a vulnerable foreign worker in Australia, on a temporary work visa, calls into question the adequacy of the available penalties for what amounts to, in this case flagrant wage theft. It may well be that the time has come for this issue to be reconsidered by the executive.
I certify that the preceding thirty-five (35) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Humphreys. Deputy Associate:
Dated: 22 March 2023
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