Fair Work Ombudsman v The Old Cop Shop Eatery Pty Ltd
[2020] FCCA 1884
•10 July 2020
1FEDERAL CIRCUIT COURT OF AUSTRALIA
| FAIR WORK OMBUDSMAN v THE OLD COP SHOP EATERY PTY LTD | [2020] FCCA 1884 |
| Catchwords: INDUSTRIAL LAW – Penalties – respondent not participating in proceedings – failure to comply with a compliance notice – single breach – no admissions, no contrition, no rectification. |
| Legislation: Fair Work Act 2009, ss.546, 716 Federal Circuit Court Rules 2001, r.16.05 |
| Other: Restaurant Industry Award 2010 |
| Cases cited: Australian Building and Construction Commissioner v Construction, Forestry, Mining and Energy Union (CFMEU) (2018) 262 CLR 157; (2018) 351 ALR 190; (2018) 92 ALJR 219; (2018) 273 IR 211; [2018] HCA 3 Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith (2008) 165 FCR 560; (2008) 246 ALR 35; [2008] FCAFC 8 Commonwealth of Australia v Director, Fair Work Building Industry Inspectorate (2015) 258 CLR 482; (2015) 90 ALJR 113; (2015) 255 IR 87; (2015) 326 ALR 476; [2015] HCA 46 Community and Public Sector Union (CPSU) v Telstra Corporation Limited (2001) 108 IR 228; [2001] FCA 1364 Fair Work Ombudsman v Bedington [2012] FMCA 1133 Fair Work Ombudsman v NSH North Pty Ltd t/as New Shanghai Charlestown (2017) 275 IR 148; [2017] FCA 1301 Kelly v Fitzpatrick (2007) 166 IR 14; [2007] FCA 1080 Mason v Harrington Corporation Pty Ltd [2007] FMCA 7 Mornington Inn Pty Ltd v Jordan (2008) 168 FCR 383; (2008) 247 ALR 714; (2008) 171 IR 455; [2008] FCAFC 70 Plancor Pty Ltd v Liquor, Hospitality and Miscellaneous Union (2008) 171 FCR 357; (2008) 177 IR 243; [2008] FCAFC 170 Ponzio v B & P Caelli Constructions Pty Ltd (2007) 158 FCR 543; (2007) 162 IR 444; [2007] FCAFC 65 Rajagopalan v BM Sydney Building Materials Pty Ltd [2007] FMCA 1412 |
| Applicant: | FAIR WORK OMBUDSMAN |
| Respondent: | THE OLD COP SHOP EATERY PTY LTD ACN 613 061 644 |
| File number: | MLG 4602 of 2019 |
| Judgment of: | Judge Riley |
| Hearing date: | 29 May 2020 |
| Date of last submission: | 29 May 2020 |
| Delivered at: | Melbourne |
| Delivered on: | 10 July 2020 |
REPRESENTATION
| Advocate for the applicant: | Matthew Gallus |
| Solicitors for the applicant: | Office of the Fair Work Ombudsman |
| Advocate for the respondent | No appearance |
| Solicitors for the respondent: | None |
ORDERS
Within 28 days, pursuant to section 546(1) of the Fair Work Act2009, the respondent pay a pecuniary penalty of $22,050 to the Commonwealth for the contravention of s.716(5) of the Fair Work Act 2009 by failing to comply with the compliance notice dated 25 October 2019 and issued by the applicant to the respondent.
NOTATION
(A)Pursuant to r.16.05(2)(a) of the Federal Circuit Court Rules 2001, the court may vary or set aside a judgment or order made in the absence of a party.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT MELBOURNE |
MLG4602 of 2019
| FAIR WORK OMBUDSMAN |
Applicant
And
| THE OLD COP SHOP EATERY PTY LTD ACN 613 061 644 |
Respondent
REASONS FOR JUDGMENT
Introduction
This matter concerns the penalties to be imposed for a contravention of the Fair Work Act 2009 (“the Act”). The respondent has not participated in this proceeding, although the court was satisfied that it has been properly served.
On 20 April 2020, the court gave default judgment against the respondent, and made declarations and orders as follows:
THE COURT DECLARES THAT:
3.Upon admissions that the respondent is taken to have made by reason of its default, a declaration be made that the respondent contravened s.716(5) of the Fair Work Act 2009 by failing to comply with a compliance notice issued on 25 October 2019 (“the compliance notice”).
THE COURT ORDERS THAT:
4.Pursuant to s.545(1) of the Fair Work Act 2009, the respondent take the steps that were required by the compliance notice within 28 days by:
a.calculating the outstanding entitlements, including superannuation contributions, it was required to pay Mike Taylor (“the employee”) in respect of the period from 7 April 2019 to 12 June 2019;
b.paying the outstanding entitlements (other than superannuation contributions) it was required to pay the employee pursuant to the compliance notice to the Commonwealth Consolidated Revenue Fund (on behalf of the employee);
c.paying superannuation (including interest calculated at the rate of 5.25% per annum from 23 December 2019 to 31 December 2019 and at the rate of 4.75% per annum from 1 January 2020 to 20 April 2020) into the employee’s nominated superannuation fund on the outstanding entitlements referred to in paragraph 4(a) (as required by clause 30.2 of the Restaurant Award); and
d.preparing and producing to the applicant, a schedule outlining its calculation of the outstanding entitlements it was required to pay the employee, and providing proof that the outstanding entitlements were rectified as set out in paragraphs 4(b) and 4(c).
5.Pursuant to s.547(2) of the Fair Work Act 2009, the respondent pay interest (interest calculated at the rate of 5.25% per annum from 23 December 2019 to 31 December 2019 and at the rate of 4.75% per annum from 1 January 2020 to 20 April 2020) on the amounts owed to the employee pursuant to paragraph 4(a) (other than on superannuation contributions) to the Commonwealth Consolidated Revenue Fund within 28 days.
6.The applicant distribute to the employee the amounts paid pursuant to orders 4 and 5 within 60 days of the payment being made, or in the event that the employee cannot be located within this timeframe, these amounts be retained by the Commonwealth of Australia pursuant to s.559 of the Fair Work Act 2009.
In essence, the respondent breached s.716(5) of the Act by failing to comply with a compliance notice issued by the applicant on 25 October 2019.
In her outline of submissions filed on 1 May 2020, the applicant proposed that the court impose aggregate penalties in the range of $22,050 to $23,625.
Legislation
The applicant is empowered to issue compliance notices under s.716 of the Act. That section provided as follows:
Application of this section
(1)This section applies if an inspector reasonably believes that a person has contravened one or more of the following:
(a)a provision of the National Employment Standards;
(b)a term of a modern award;
(c)a term of an enterprise agreement;
(d)a term of a workplace determination;
(e)a term of a national minimum wage order;
(f)a term of an equal remuneration order;
(g)a provision of Part 6-4C (which deals with the Coronavirus economic response);
(h)a jobkeeper enabling direction (within the meaning of Part 6-4C);
(i)a provision of an agreement authorised by Part 6-4C.
Giving a notice
(2)The inspector may, except as provided by subsection (4), give the person a notice requiring the person to do either or both of the following within such reasonable time as is specified in the notice:
(a)take specified action to remedy the direct effects of the contravention referred to in subsection (1);
(b)produce reasonable evidence of the person's compliance with the notice.
(3)The notice must also:
(a)set out the name of the person to whom the notice is given; and
(b)set out the name of the inspector who gave the notice; and
(c)set out brief details of the contravention; and
(d)explain that a failure to comply with the notice may contravene a civil remedy provision; and
(e)explain that the person may apply to the Federal Court, the Federal Circuit Court or an eligible State or Territory Court for a review of the notice on either or both of the following grounds:
(i) the person has not committed a contravention set out in the notice;
(ii) the notice does not comply with subsection (2) or this subsection; and
(f)set out any other matters prescribed by the regulations.
Relationship with enforceable undertakings
(4)An inspector must not give a person a notice in relation to a contravention if:
(a)the person has given an undertaking under section 715 in relation to the contravention; and
(b)the undertaking has not been withdrawn.
Relationship with civil remedy provisions
(4A)An inspector must not apply for an order under Division 2 of Part 4-1 in relation to a contravention of a civil remedy provision by a person if:
(a)the inspector has given the person a notice in relation to the contravention; and
(b)either of the following subparagraphs applies:
(i)the notice has not been withdrawn, and the person has complied with the notice;
(ii)the person has made an application under section 717 in relation to the notice that has not been completely dealt with.
Note:A person other than an inspector who is otherwise entitled to apply for an order in relation to the contravention may do so.
(4B)A person who complies with a notice in relation to a contravention of a civil remedy provision is not taken:
(a)to have admitted to contravening the provision; or
(b)to have been found to have contravened the provision.
Person must not fail to comply with notice
(5)A person must not fail to comply with a notice given under this section.
Note:This subsection is a civil remedy provision (see Part 4-1).
(6)Subsection (5) does not apply if the person has a reasonable excuse.
The hearing on 29 May 2020
The matter was listed for penalty hearing on 29 May 2020. The hearing proceeded by Microsoft Teams, due to the COVID-19 pandemic. The applicant was represented but the respondent did not appear, although it had been given proper notice of the hearing.
Material relied upon
At the hearing on 29 May 2020, the applicant relied on:
a)the application and statement of claim dated 23 December 2019;
b)the affidavit affirmed by Kathleen Davies on 17 April 2020; and
c)the affidavit of Senior Fair Work Inspector Sarah Eloise Allen affirmed on 29 April 2020.
Background facts
The applicant set out the background facts of the matter in her outline of submissions filed on 1 May 2020 as follows:
2.The Compliance Notice was served at the Company’s registered office by Fair Work Inspector John O’Leary (FWI O’Leary) after he determined that the Company had underpaid a former employee, Mike Taylor, for a period of approximately two months. The Compliance Notice required the Company to calculate Mr Taylor’s minimum entitlements, rectify any underpayments by paying him those amounts and provide evidence of such payment to the FWO within seven days of payment being made.
3.The Company failed to comply with the Compliance Notice.2
2 Affidavit of Sarah Eloise Allen affirmed 29 April 2020 (Allen Affidavit) at [9]-[11].
…
6.The Company operates a restaurant located at 160 Bell Street, Coburg in Victoria.3
3 Allen Affidavit at [7].
7.On or around July 2019, the FWO commenced an investigation into the Company after receiving a request for assistance from Mr Taylor alleging underpayment of minimum entitlements.4
4 Allen Affidavit at [6]-[7].
8.On 25 October 2019, FWI O’Leary gave the Compliance Notice to the Company after conducting an investigation and forming a belief that the Company had contravened provisions of the Restaurant Industry Award 2010 (Restaurant Award) relating to minimum wages, casual loading and Sunday and public holiday penalty rates.5
9.The Compliance Notice required the Company to:
(a)take specified action by 29 November 2019 to remedy the direct effects of the contraventions by:
(i) identifying the hours worked by and amounts paid to Mr Taylor from 7 April 2019 to 12 June 2019; and
(ii) calculating and paying any outstanding amounts owing to Mr Taylor, and the superannuation payable in respect of Mr Taylor, in respect of the outstanding amounts; and
(b)produce reasonable evidence of the Company’s compliance with the Compliance Notice to the FWO, by producing a copy of the schedule of calculations and evidence of having paid the amounts owed to Mr Taylor, within seven days of payment being made.6
10.The Company did not take the action specified in the Compliance Notice by 29 November 2019 or at all, or provide evidence to the FWO of calculations or payments to Mr Taylor within seven days of payment or at all.
5 Allen Affidavit at [8].
6 Allen Affidavit at [8].
Approach to determining penalty
As s.716 of the Act is a civil remedy provision, the court may impose a penalty pursuant to s.546 of the Act.
Bromwich J summarised the proper approach to determining penalty in cases such as this in Fair Work Ombudsman v NSH North Pty Ltd t/as New Shanghai Charlestown (2017) 275 IR 148; [2017] FCA 1301 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 FW 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].
In the present case, steps two and three are not relevant, because there was only one contravention.
A convenient checklist of the factors that the court might consider in determining penalty include the matters that were identified by Mowbray FM in Mason v Harrington Corporation Pty Ltd [2007] FMCA 7 at [26]-[59] and adopted by Tracey J in Kelly v Fitzpatrick (2007) 166 IR 14; [2007] FCA 1080 at [14]. That list is as follows, (with paragraph letters inserted):
(a)The nature and extent of the conduct which led to the breaches.
(b)The circumstances in which that conduct took place.
(c)The nature and extent of any loss or damage sustained as a result of the breaches.
(d)Whether there had been similar previous conduct by the respondent.
(e)Whether the breaches were properly distinct or arose out of the 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 the enforcement authorities.
(l)The need to ensure compliance with minimum standards by provision of an effective means for investigation and enforcement of employee entitlements.
(m)The need for specific and general deterrence.
The court must, of course, be mindful of the caution expressed by Buchanan J in Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith (2008) 165 FCR 560; (2008) 246 ALR 35; [2008] FCAFC 8 at [91] as follows:
Check lists of this kind can be useful providing they do not become transformed into a rigid catalogue of matters for attention. At the end of the day the task of the Court is to fix a penalty which pays appropriate regard to the circumstances in which the contraventions have occurred and the need to sustain public confidence in the statutory regime which imposes the obligations. There is no suggestion in the present case that the learned magistrate made any relevant error in her identification of the matters which she should consider in fixing penalties.
The court will consider the circumstances of the case under the various headings suggested by Mowbray FM, and then consider whether any other matters are relevant.
There was no cross examination of any witness, so I accept all of the affidavit evidence.
Step 1: identifying the breaches
As stated above, the respondent breached s.716(5) of the Act by failing to comply with a compliance notice issued by the applicant on 25 October 2019.
Step 2: single course of conduct
As there was only one breach, this step is not relevant.
Step 3: grouped breaches
As there was only one breach, this step is not relevant.
Step 4: the appropriate penalty for the breaches
a. the nature and extent of the conduct which led to the breach
The nature and extent of the conduct which led to the breach was a failure to comply with a compliance notice that required the respondent to:
a)calculate the correct amount of wages that was payable to Mr Taylor;
b)rectify any underpayments; and
c)provide proof of payment to the applicant.
The respondent failed to fulfil any of those requirements.
b. the circumstances in which that conduct took place
The circumstances in which the conduct took place were that the respondent failed to comply with its basic obligations under the Restaurant Industry Award 2010, even after the matter was brought to the respondent’s attention by the regulator. The applicant formed the belief that the respondent had contravened provisions of the award relating to minimum pay, casual loading and Sunday and public holiday penalty rates in respect of Mr Taylor. Mr Taylor was 21 years old at the relevant time, and, as such, a vulnerable worker.
c. the nature and extent of any loss or damage sustained
It appears that the precise extent of the loss or damage sustained by Mr Taylor has not been ascertained by the applicant.
d. whether there had been similar previous conduct
The applicant conceded that the respondent had not been the subject of any previous court proceedings brought by the applicant for the contravention of workplace laws.
e. whether the breaches arose out of the one course of conduct
This point has already been addressed.
f. the size of the business enterprise involved
There is no evidence before the court as to the size of the respondent’s business. In any event, it is well-established that even small businesses are obliged to comply with workplace laws.
For example, Tracey J said in Kelly v Fitzpatrick (2007) 166 IR 14; [2007] FCA 1080 at [28]:
No less than large corporate employers, small businesses have an obligation to meet minimum employment standards and their employees, rightly, have an expectation that this will occur. When it does not it will, normally, be necessary to mark the failure by imposing an appropriate monetary sanction. Such a sanction “must be imposed at a meaningful level” (citation omitted)
Similarly, in Rajagopalan v BM Sydney Building Materials Pty Ltd [2007] FMCA 1412, the court said at [27]:
Employers must not be left under the impression that because of their size or financial difficulty that they are able to breach an award. Obligations by employers for adherence to industrial instruments arise regardless of their size. Such a factor should be of limited relevance to the Court’s consideration of penalty. …
g. whether or not the breach was deliberate
The respondent did not advance any evidence to the effect that the breach was not deliberate. It is difficult to see how the breach could have been anything other than deliberate, in circumstances where the respondent was clearly informed by the regulator of the requirements, which were spelt out in a compliance notice.
h. whether senior management was involved in the breaches
The applicant did not address this issue. However, I note from a company search that the respondent has only one director but two shareholders. The sole director has 48 shares and a corporate entity has 72 shares. In these circumstances, it is unclear whether senior management was involved in the breach.
contrition, corrective action and co-operation with the authorities
The respondent has not demonstrated any contrition, corrective action or co-operation with the authorities.
j. the need to ensure compliance with minimum standards
The respondent in this case appears to have breached Mr Taylor’s minimum entitlements.
k. the need for specific and general deterrence
In Commonwealth of Australia v Director, Fair Work Building Industry Inspectorate (2015) 258 CLR 482; (2015) 326 ALR 476; (2015) 90 ALJR 113; (2015) 255 IR 87; [2015] HCA 46, French CJ, Kiefel, Bell, Nettle and Gordon JJ said at [55]:
No less importantly, whereas criminal penalties import notions of retribution and rehabilitation, the purpose of a civil penalty, as French J explained in Trade Practices Commission v CSR Ltd, is primarily if not wholly protective in promoting the public interest in compliance:
“Punishment for breaches of the criminal law traditionally involves three elements: deterrence, both general and individual, retribution and rehabilitation. Neither retribution nor rehabilitation, within the sense of the Old and New Testament moralities that imbue much of our criminal law, have any part to play in economic regulation of the kind contemplated by Pt IV [of the Trade Practices Act]. ... The principal, and I think probably the only, object of the penalties imposed by s 76 is to attempt to put a price on contravention that is sufficiently high to deter repetition by the contravenor and by others who might be tempted to contravene the Act.”
(footnotes omitted)
Similarly, in Australian Building and Construction Commissioner v Construction, Forestry, Mining and Energy Union (CFMEU) (2018) 262 CLR 157; (2018) 351 ALR 190; (2018) 92 ALJR 219; (2018) 273 IR 211; [2018] HCA 3, Keane, Nettle and Gordon JJ said at [116]:
As has been observed, the principal object of an order that a person pay a pecuniary penalty under s 546 is deterrence: specific deterrence of the contravener and, by his or her example, general deterrence of other would-be contraveners. According to orthodox sentencing conceptions as they apply to the imposition of civil pecuniary penalties, specific deterrence inheres in the sting or burden which the penalty imposes on the contravener. Other things being equal, it is assumed that the greater the sting or burden of the penalty, the more likely it will be that the contravener will seek to avoid the risk of subjection to further penalties and thus the more likely it will be that the contravener is deterred from further contraventions; likewise, the more potent will be the example that the penalty sets for other would-be contraveners and therefore the greater the penalty's general deterrent effect. Conversely, the less the sting or burden that a penalty imposes on a contravener, the less likely it will be that the contravener is deterred from further contraventions and the less the general deterrent effect of the penalty. Ultimately, if a penalty is devoid of sting or burden, it may not have much, if any, specific or general deterrent effect, and so it will be unlikely, or at least less likely, to achieve the specific and general deterrent effects that are the raison d'être of its imposition.
(footnotes omitted)
In relation to specific deterrence, Gray J observed in Plancor Pty Ltd v Liquor, Hospitality and Miscellaneous Union (2008) 171 FCR 357; (2008) 177 IR 243; [2008] FCAFC 170 at [37] that:
… Specific deterrence focuses on the party on whom the penalty is to be imposed and the likelihood of that party being involved in a similar breach in the future. Much will depend on the attitude expressed by that party as to things like remorse and steps taken to ensure that no future breach will occur. …
In relation to general deterrence, Lander J noted in Ponzio v B & P Caelli Constructions Pty Ltd (2007) 158 FCR 543; (2007) 162 IR 444; [2007] FCAFC 65 at [93]:
… In regard to general deterrence, it is assumed that an appropriate penalty will act as a deterrent to others who might be likely to offend. The penalty therefore should be of a kind that it would be likely to act as a deterrent in preventing similar contraventions by like minded persons or organisations. If the penalty does not demonstrate an appropriate assessment of the seriousness of the offending, the penalty will not operate to deter others from contravening the section. However, the penalty should not be such as to crush the person upon whom the penalty is imposed or used to make that person a scapegoat. In some cases, general deterrence will be the paramount factor in fixing the penalty…(citations omitted)
Similarly, in Community and Public Sector Union (CSPU) v Telstra Corporation Limited (2001) 108 IR 228; [2001] FCA 1364, Finkelstein J said at [9]:
… even if there be no need for specific deterrence, there will be occasions when general deterrence must take priority, and in that case a penalty should be imposed to mark the law's disapproval of the conduct in question, and to act as a warning to others not to engage in similar conduct …. (citation omitted)
Specific deterrence is a significant factor in this case, where the respondent has shown no contrition and taken no corrective action.
General deterrence is also a significant factor in this case, given that the restaurant industry is notorious for underpayments to staff.
Other issues relating to penalty
In Mornington Inn Pty Ltd v Jordan (2008) 168 FCR 383; (2008) 247 ALR 714; (2008) 171 IR 455; [2008] FCAFC 70, Stone and Buchanan JJ held at [75]:
A conventional consideration in assessing a discount in a criminal case for a plea of guilty is the stage in the proceedings at which the plea is entered. Normally, the maximum discount for this factor, sometimes thought to be 25%, is reserved for a plea made at the first reasonable opportunity …
In Fair Work Ombudsman v Bedington [2012] FMCA 1133 Jarrett FM held at [87]:
The cases indicate that a discount on the penalty to be imposed is appropriate where there has been co-operation and admissions early in the course of an investigation or soon after the commencement of proceedings. Such discounts range as high as 30% in some cases. …
As there were no admissions in this case, there is no occasion to give a discount for admissions.
Step 4: the appropriate penalty
The maximum penalty for a corporation, such as the respondent, is $31,500 for a single breach.
The applicant’s submissions filed on 1 May 2020 suggested that an appropriate penalty would be in the range of $22,050 to $23,625.
By my calculation, the suggested penalty is 70% to 75% of the maximum penalty.
In my view, a penalty of 70% of the maximum is appropriate in this case. That is primarily because:
a)the conduct was deliberate;
b)there were no admissions;
c)there was no contrition;
d)there was no co-operation with the authorities;
e)there was no rectification;
f)the compliance notice concerned non-compliance with minimum requirements; and
g)the worker involved was young and vulnerable.
Step 5: the totality principle
In relation to the check that is required by the totality principle, I consider that a penalty of $22,050 is appropriate for the contravening conduct engaged in by the respondent.
There will be an order accordingly.
Liberty to apply
The applicant has also sought liberty to apply, but did not explain why. In the circumstances, I am not inclined to give liberty to apply. If the order needs to be enforced, it can be done in the usual way.
Rule 16.05 notation
As the respondent did not appear at the final hearing, it is appropriate to make the usual notation under r.16.05(2)(a) of the Federal Circuit Court Rules 2001. That rule allows the court to vary or set aside a judgment or order made in the absence of a party.
I certify that the preceding forty-nine (49) paragraphs are a true copy of the reasons for judgment of Judge Riley
Associate:
Date: 10 July 2020
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