Full Tilt Transport Pty Ltd (Migration)

[2023] AATA 171

Full Tilt Transport Pty Ltd (Migration) [2023] AATA 171 (1 February 2023)

DECISION RECORD

DIVISION:Migration & Refugee Division

APPLICANT:  Full Tilt Transport Pty Ltd

REPRESENTATIVE:  Ms Rui Guo (MARN: 1790263)

CASE NUMBER:  1916375

HOME AFFAIRS REFERENCE(S):          BCC2018/924445

MEMBER:De-Anne Kelly

DATE:1 February 2023

PLACE OF DECISION:  Brisbane

DECISION:The Tribunal affirms the decision under review to refuse the nomination.

Statement made on 01 February 2023 at 1:22pm

CATCHWORDS

MIGRATION – approval of a nomination – Direct Entry nomination stream – position of Fleet Manager – genuine need for the employment – contracted work to commence 3 months after visa grant – business founder planning to retire – duties of the position – position unfilled for lengthy period – position responsible for employees on greater salaries – decision under review affirmed           

LEGISLATION

Migration Act 1958, ss 359, 360
Migration Regulations 1994, rr 5.19, 5.37

STATEMENT OF DECISION AND REASONS

APPLICATION FOR REVIEW

1. This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 6 June 2019 to reject the applicant’s application for approval of the nomination of a position in Australia under reg 5.19 of the Migration Regulations 1994 (Cth) (the Regulations).

2. The applicant applied for approval on 26 February 2018. The requirements for the approval of the nomination of a position in Australia are found in reg 5.19 of the Regulations which contains two alternative streams: a Temporary Residence Transition nomination stream (reg 5.19(3)) and a Direct Entry nomination stream (reg 5.19(4)). If the application is made in accordance with reg 5.19(2) and meets the requirements of either stream, then the application must be approved. If any of the requirements are not met then the application must be refused: reg 5.19(5).

3. In this case, the applicant has applied for approval of a nomination, seeking to satisfy the criteria in the Direct Entry nomination stream.

4. The delegate refused the application on the basis the applicant’s nomination did not satisfy reg 5.19(4)(h)(ii)(B) of the Regulations because the application did not identify a genuine need for the nominator to employ a paid employee to work in the position under the nominators direct control. This was based in part on the fact the nominee was apparently genuinely needed but the employment contract showed he was not to commence work until 3 months after the visa was granted and the delegate found “Such a vague commitment to the commencement of employment does not correspond with the businesses claims of need for the position.”

5. The applicant appeared before the Tribunal on 27 January 2023 to give evidence and present arguments. Originally this was to be a joint hearing of the review into two employer nomination refusals by the same applicant with the other case an employer nomination lodged on 5 February 2018 for a Marketing Manager on $72,000 per annum but the nominee for that position Ms Yingyan Tan had never taken up the position and when contacted by the agent (a different agent) it was found she did not wish to fill the position, so the review application was withdrawn.

6. The applicant was represented in relation to the review by Ms Rui Gao.

7. For the following reasons, the Tribunal has decided to affirm the decision under review to refuse the nomination.

   Procedural matters.

   Section 359AA of the Act

8. At the commencement of the hearing, the Tribunal explained that it may put information to the applicant, under s.359AA of the Act, that would be the reason, or a part of the reason, for affirming the decision that is under review and that it would explain why this information was relevant to the decision and how it may be relied upon in reaching a decision. The Tribunal also advised that the applicant would be given an opportunity to respond to this information in one of two ways: they could request an adjournment and the hearing could be stopped for 15 or 20 minutes or whatever period of time they wished, and they could seek advice from the registered migration agent and then they could respond in the hearing or they could respond directly in the hearing. Under s.360 of the Migration Act 1958 (Cth.) the Tribunal must invite the applicant to a hearing to give evidence and present arguments relating to issues arising in relation to the review and this affords the applicant the opportunity to canvas information before the Tribunal.

9. It does not oblige the Tribunal to send a s.359(2) letter with a request for documents nor does it oblige the Tribunal to provide time post-hearing for the filing of documents.  It is clear from the Invitation to Attend Hearing that the applicant is expected to file relevant material at least seven (7) days prior to the hearing date. The Tribunal would permit an applicant to file documents after a hearing only where it is clear those documents could not be obtained prior to the hearing; where a new matter has been raised by the Tribunal that the applicant may not have reasonably been aware of or similar circumstances that would necessitate it to allow post hearing filing on the basis of procedural fairness or natural justice. The applicant did not put forward any matters that would enliven concerns regarding procedural fairness or natural justice. As such, the Tribunal did not allow the applicant with a formal opportunity to file post-hearing submissions or evidence.

10. Section 359AA provides as follows:

    (a)   The Tribunal may orally give to the applicant clear particulars of any information that the Tribunal considers would be the reason, or a part of the reason, for affirming the decision that is under review; and

    (b)   if the Tribunal does so—the Tribunal must:

    (i)ensure, as far as is reasonably practicable, that the applicant understands why the information is relevant to the review, and the consequences of the information being relied on in affirming the decision that is under review; and

    (ii) orally invite the applicant to comment on or respond to the information; and

    (iii) advise the applicant that he or she may seek additional time to comment on or respond to the information; and

    (iv) if the applicant seeks additional time to comment on or respond to the information—adjourn the review, if the Tribunal considers that the applicant reasonably needs additional time to comment on or respond to the information.

    CONSIDERATION OF CLAIMS AND EVIDENCE

11. The issue in this case is whether the applicant meets the requirements for approval of the nomination under the Direct Entry nomination stream set out in reg 5.19(4), which is extracted in the attachment to this decision. For the nomination to be approved, all the requirements must be met.

12. On 26 February 2018, the applicant lodged a Regional Sponsored Migration Scheme employer nomination visa subclass 187 in the Direct Entry Stream for the position of Fleet Manager on $65,000 per annum to be employed at Bakers Creek QLD 4740 in favour of Mr Zhichao DU.

13. Mr Craig Graham the director and founder of the business represented the applicant and advised the business was started in 2006 and now turns over some $4million a year with a profit of some $500,000 and has some 13 trucks, utes and pilot vehicles with 20 staff employed. Mr Graham is forthright and has built a very successful business and now wishes to retire at some time and spend time with his family. The financial figures are shown below, and it is noted that while revenue has grown the profitability has declined however the business is still a strong and profitable enterprise.

Year	2021	2020	2019	2018	2017
Sales	4,237,368	3,910,740	4,147,250	3,253,849
Wages	1,537,179	1,218,918	1,358,527	1,005,116
Expenses	3,914,831	3,438,495	3,420,700	2,757,791
Profit	322,536	372,244	726,550	496,058

Tasks of the position, genuine need for the position and training requirements reg 5.19(4)(h)

1. Regulation 5.19(4)(h) contains a number of alternative requirements. These are set out in detail in the attachment to the decision but can be briefly summarised as requiring either that:

   ·the tasks to be performed in the position will be performed in Australia and correspond to those of an occupation specified by the Minister in a legislative instrument, the occupation is applicable to the proposed employee in accordance with any specifications made in that instrument, there is a genuine need for the nominee to be employed as a paid employee in the position, and certain specified training requirements are met; or

   ·the position and nominator’s business is located in regional Australia, there is a genuine need for the nominee to be employed as a paid employee in the position under the nominator’s direct control, the position cannot be filled by a locally resident Australian citizen or permanent resident, the tasks of the position correspond to those of an occupation specified in the relevant legislative instrument, the occupation is applicable to the proposed employee in accordance with the specification of the occupation, and that a regional certifying body has advised the Minister about certain matters relating to the position.

   Genuine need for the position – reg. 5.19(4)(h)(ii)(B)

2. This was the original reason the delegate refused the application.

3. The director Mr Graham gave an update of the organisation of the business as below and  the salaries paid to the various staff based on a 38-hour working week.

   Managing director – Mr Craig Graham is the only shareholder and takes drawings from the business rather than a salary.

   General Manager – Ms Sheila Gibson. $90,000

   Fleet Manager – the nominee above the Truck drivers. $65,000

   The truck drivers are paid $45/hour for casual work, $40/ hour for rigid and ute drivers paid $30/hour. Salaries range from $79,040 to $59,280.

   Workshop Manager – Mr Les Jones $140,000

   Administration – Ms Christie Cook $ 28/hr or $55,328.

4. Ms Sheila Gibson it was noted had been the administration clerk in the previous organisation chart. Mr Graham was fulsome in his praise of his General Manager Ms Gibson as everyone answers to her and if there is something she can’t handle then it comes to Mr Graham. She is their “go to person “. “She bleeds Full Tilt…She is wonderful, recommend her to anybody but give her to nobody”.

5. Mr Jones is the workshop manager and very skilled and ensures that the trucks are road worthy and on the road making money.

6. Mr Graham advised that they advertised the position on 24 November 2017 but have not re-advertised it since. The candidates who applied were unsuitable. It seemed that a third party arranged the recruitment of the nominee although it was not clear as to who this was. Mr Graham had never nominated someone before, and he said he was unfamiliar with the process involved. The third party” Jack” had made the arrangements and that when the nominee was ready, he would come onboard.

7. There were a number of job descriptions submitted for this application and the Tribunal took Mr Graham through each task as below in the latest version and he confirmed “yep” to each task so the Tribunal takes this as the appropriate job description for the nominated position.

   Essential Job Functions – latest appropriate description

   ·Responsible for the records of maintenance of the fleet including the equipment to ensure vehicles are in good condition.

   ·Managing the bookings and planning the schedule to maintain maximum availability of fleet.

   ·Maintain clean and tidy workplace.

   ·Ensure all goods are stored and transported in condition that will maintain their quality.

   ·Keeping all vehicles and equipment clean and tidy and presentable.

   ·Assist Workshop Manager when requested.

   ·Assist Office Management when requested.

   ·Learning operation of transport company.

   ·Ensure personal safety and safety of others is a priority at all times.

   ·Comply with company policies and procedures at all times.

8. It was noted that an earlier version of the job description as below was much more comprehensive and appears to indicate that the tasks have been considerably simplified.

   Main Duties and Responsibilities

   • Organizing the purchasing and selling of vehicles to ensure the vehicles adequate and up to date
   • In charge of the maintenance of the fleet including the equipment and fuel usage to
   make sure our vehicles are in good condition
   • Managing the bookings and planning the schedule to maintain maximum availability of
   the fleet
   • Liaising with our clients and offering advice to them about suitable transportation type
   and hire rates for our vehicles
   • Ensure that the goods are stored and transported in condition that will maintain their
   quality
   • Ensure all of the crew understand the safety management system and work efficiently to meet the requirements of our clients
   • Coordinating activities in terms of goods arriving, loading and unloading from other
   transportation to ensure the scheduled time delivery.
   Handling complains and coordinates (sic) between the drivers.

9. It was put to Mr Graham that the salary for a Fleet Manager on Payscale ranges from $51,000 to $116,000 per annum and that the salary for the nominee is at the low end of that scale being $65,000 now $68,000 per annum. This is significant in an organisation that turns over some $4million per annum with some 13 trucks and drivers to manage and is fundamental for the profitability of the company. Mr Graham advised that everyone has to start somewhere.

10. It was noted that the first task of the nominee when he commenced employment with the company in September 2022 was to obtain a Forklift licence on 22 September 2022 and Mr Graham advised that it is necessary for anyone working in the transport sector to have a forklift licence to load and unload trucks as required.

11. The nominee joined the applicant from his payslips on 29 September 2022 although the employment contract 1 September 2022 showed the commencement date as 29 August 2022 although this could be a typographical error. The Tribunal asked Mr Graham who had been filling this vacant position in the almost five years since it was advertised in November 2017, and he advised that he had filled the position. Mr Graham agreed “it was a long time ago”.

12. The Tribunal put to Mr Graham under s359AA of the Act that from the nominee’s resume on Form 80 dated 20 February 2018 and uploaded for the visa application he was working “from November 2017 until now” for Royal MU Wines International Trading as Logistics Manager in South Australia although it also shows him residing for that time in Sydney NSW. Regardless, the nominee had work rights and was residing in Australia and the Tribunal asked Mr Graham why the nominee did not start work immediately for Full Tilt Transport since there was no impediment to him doing so.

13. Mr Graham replied “ahm that is a question I can’t answer, I don’t know. I was still providing information so the solicitor Jack, is that his name Daniel.” “The solicitor Jack that’s kept asking for information which I provided over and over so that’s all I know, and I just provided the information and when he was ready to come on board, I was advised then he came on board”.

14. The Tribunal put to Mr Graham he needed to demonstrate a genuine need to fill this position, but it had instead been filled for almost five years by Mr Graham himself in addition to all his other responsibilities at a time when his nominee had work rights and had been working in South Australia. If he had a genuine need and the nominee could not come and work until his visa was granted, according to the original employment contract then Mr Graham could have sought to fill this position and would have advertised it again. Mr Graham agreed that he had not advertised it again. The Tribunal said he could have telephoned the nominee and said he signed an employment contract, and the nominee was needed here as this was a big responsible position, Mr Graham had built the company, was a busy man and needed the nominee here working for him. However, none of that happened and the nominee did not start work until some four months ago in September 2022.

15. If the Tribunal gave consideration to this information, it may reasonably draw the conclusion that there was not a genuine need for the nominator to employ the person identified under subparagraph (a)(ii), as a paid employee, to work in the position under the nominator’s direct control since the nominee had work rights but the position remained unfilled by him for nearly five years and Mr Graham had filled the position himself therefore it may not satisfy reg 5.19(4)(h)(ii)(B) and this may be part or all of the reason to affirm the decision to refuse the employer nomination.

16. Mr Graham chose to respond in the hearing and said that he thought originally it did take a long time and then COVID came and everything slowed down and during this time he did receive a phone call from the Department of Immigration and he said he may not go ahead with it (the nomination) but then business picked up and he wants to retire and have this fellow on board to take over this position and spend more time with the family and he was mystified as to why it took so long. He thought it was a long process for legal reasons. He wants a “fresh person that doesn’t have influence from other companies and doesn’t steal my work” and this is a good opportunity.

17. He was invited to make some closing statements and said that he is grateful to have John (Mr Du) on board and hopes he is able to stay with them. He became aware that Mr Du was coming to work for him because he was rung through” Jack’s” office.

18. Macquarie Online dictionary has the following definitions.

    Genuine - being truly such; real; authentic.

    Need - a case or instance in which some necessity or want exists; a requirement; urgent want, as of something requisite

19. It is clear that a genuine need is a real urgent necessity or want rather than something which is merely desirable.

20. The Tribunal gives weight to Mr Graham’s statement that he is grateful the nominee is on board, and he is desirous of his staying because he wants to retire in the future and spend more time with his family but gives more weight to the fact that the position remained unfilled from November 2017 until September 2022 or nearly five years when the nominee was in Australia with work rights and working for another business.

21. If there was a real urgent necessity or genuine need for the nominator to employ the person identified under subparagraph (a)(ii), as a paid employee, to work in the position of Fleet Manager under the nominator’s direct control then reasonably Mr Graham would have asked why there was a protracted delay in the nominee commencing employment but he accepted the advice he had been given and although it is acknowledged that he has not nominated someone before and was unfamiliar with the process, if there was an real urgent need the nominator would have pressed harder or advertised again to fill the position but he did none of these things but waited nearly 5 years until “Jack’s office” telephoned him and said the nominee he was coming to start work. It seems that the genuine need being addressed here is the need of the nominee rather than the nominator.

22. The Tribunal gives weight to the fact that the original employment contract 30 January 2018 stated that the nominee would not be commencing work until three months after the visa was granted and although Mr Graham was unfamiliar with the employer nomination process, he has been willing to accept a delay in the nominee starting work and has not questioned this in the almost five years hence.

23. It is acknowledged that Mr Graham said COVID – 19 lessened the necessity to fill the position however it does not explain the almost five years the position was allowed to remain vacant without action on the nominators part to fill it either with the nominee or by advertising for someone else. The Tribunal gives weight to the fact that the Department telephoned Mr Graham during this time, and he was inclined to say he did not want to go ahead with the nomination and although he did not withdraw the nomination, it indicates a degree of ambivalence towards the nominee as a paid employee in the position of Fleet Manager.

1. The Tribunal gives some limited weight to the statement by Mr Graham that everyone needs to start somewhere to explain the fact that the position is being remunerated at $68,000 or the lowest end of the Payscale salary range of $51,000 to $116,000 for a Fleet Manager however it gives more weight that this reasonably demonstrates a degree of ambivalence about the genuine need for the full-time position of Fleet Manager. This is re-enforced by the fact that the nominated position although allegedly a managerial position is paid considerably less than the General Manager, the Workshop Manager and the full-time truck drivers.  It seems implausible that some truck drivers are paid considerably more than the manager they are meant to be reporting to. There is also the concern that although the nominated position of Fleet Manager is allegedly a full-time position and is on the same organisation level in the company hierarchy chart as the Workshop Manager and the Administrator, two of the tasks of the position are to assist the Workshop Manager and Office Manager/Administrator which would suggest that there is not a genuine need for the considerable tasks and responsibilities of a full time Fleet Manager.

2. Taking all  the above into account the Tribunal cannot be satisfied there is a genuine need for the nominator to employ the person identified under subparagraph (a)(ii),(the nominee) as a paid employee, to work in the position of Fleet Manager under the nominator’s direct control because the nominator agreed in the original employment contract that the nominee would not commence work for three months after the grant of the visa; the Managing director Mr Graham filled the position for nearly five years when the nominee had work rights and resided in Australia working for someone else; the nominees pay is lower than some of the truck drivers that report to him and is at the low end of the pay range for such a senior position and is considerably less than the other two managers who are his peers on the organisation chart and the managing director has never sought to expedite the filling of the position by pressuring the nominee or advertising for someone else.

3. Accordingly, the requirements of reg 5.19(4)(h)(ii)(B) and reg 5.19(4)(h) are net met.

4. For the above reasons the Tribunal is not satisfied that the applicant meets the requirements of reg 5.19(4). The applicant has not sought to satisfy the criteria in Temporary Residence Transition Nomination stream, and as such has not met the requirements in reg 5.19(3). Accordingly, the nomination of the position cannot be approved. Therefore, the Tribunal must affirm the decision under review.

   DECISION

5. The Tribunal affirms the decision under review to refuse the nomination.

   De-Anne Kelly
   Member

   
   

   ATTACHMENT - Extracts from the Migration Regulations 1994

   5.19Approval of nominated positions (employer nomination)

   …

   (2)The application must:

   (a)be made in accordance with approved form 1395…; and

   (aa) include a written certification by the nominator stating whether or not the nominator has engaged in conduct, in relation to the nomination, that constitutes a contravention of subsection 245AR(1) of the Act; and

   (b)be accompanied by the fee mentioned in regulation 5.37.

   …

   Direct Entry nomination

   (4)The Minister must, in writing, approve a nomination if:

   (a)the application for approval:

   (i)       is made in accordance with subregulation (2); and

   (ii)      identifies a need for the nominator to employ an identified person, as  a paid employee, to work in the position under the nominator’s direct control; and

   (b)the nominator:

   (i)       is actively and lawfully operating a business in Australia; and

   (ii)      directly operates the business; and

   (c)for a nominator whose business activities include activities relating to the hiring of labour to other unrelated businesses — the position is within the business activities of the nominator and not for hire to other unrelated businesses; and

   (d)both of the following apply:

   (i)       the employee will be employed on a full-time basis in the position for at least 2 years;

   (ii)      the terms and conditions of the employee’s employment will not include an express exclusion of the possibility of extending the period of employment; and

   (e)the terms and conditions of employment applicable to the position will be no less favourable than the terms and conditions that:

   (i)       are provided; or

   (ii)      would be provided;

   to an Australian citizen or an Australian permanent resident for performing equivalent work in the same workplace at the same location; and

   (f)either:

   (i)       there is no adverse information known to Immigration about the nominator or a person associated with the nominator; or

   (ii)      it is reasonable to disregard any adverse information known to Immigration about the nominator or a person associated with the nominator; and

   (g)the nominator has a satisfactory record of compliance with the laws of the Commonwealth, and of each State or Territory in which the applicant operates a business and employs employees in the business, relating to workplace relations; and

   (h)either:

   (i)       all of the following apply:

   (A)the tasks to be performed in the position will be performed in Australia and correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;

   (AA)there is a genuine need for the nominator to employ the person identified under subparagraph (a)(ii), as a paid employee, to work in the position under the nominator’s direct control;

   (AAA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;

   (B)either:

   (I)the nominator’s business has operated for at least 12 months, and the nominator meets the requirements for the training of Australian citizens and Australian permanent residents that are specified by the Minister in an instrument in writing for this sub-sub-subparagraph; or

   (II)the nominator’s business has operated for less than 12 months, and the nominator has an auditable plan for meeting the requirements specified in the instrument mentioned in sub-sub-subparagraph (I); or

   (ii)      all of the following apply:

   (A)the position is located in regional Australia;

   (B)there is a genuine need for the nominator to employ the person identified under subparagraph (a)(ii), as a paid employee, to work in the position under the nominator’s direct control;

   (C)the position cannot be filled by an Australian citizen or an Australian permanent resident who is living in the same local area as that place;

   (D)the tasks to be performed in the position correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;

   (DA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;

   (E)the business operated by the nominator is located at that place;

   (F)a body that is:

   (I)specified by the Minister in an instrument in writing for this sub-subparagraph; and

   (II)located in the same State or Territory as the location of the position;

   has advised the Minister about the matters mentioned in paragraph (e) and sub-subparagraphs (B) and (C).

   Case Number – 1916375 – Full Tilt Transport Pty Ltd

   Documents including the following were provided with the original application.

   1)Acknowledgement of employer nomination 27 February 2018.

   2)Online application for employer nomination 26 February 2018.

   3)BAS statement FY 2017.

   4)Employment contract 30 January 2018 for Fleet Manager ANZSCO 149411 on $65,000 per annum to commence employment to commence employment three months after grant of 187 visa.

   Main Duties and Responsibilities
   • Organizing the purchasing and selling of vehicles to ensure the vehicles adequate and up
   to date
   • In charge of the maintenance of the fleet including the equipment and fuel usage to
   make sure our vehicles are in good condition
   • Managing the bookings and planning the schedule to maintain maximum availability of
   the fleet
   • Liaising with our clients and offering advice to them about suitable transportation type
   and hire rates for our vehicles Number: 1916375eated on 03/11/2022 10:59:03
   • Ensure that the goods are stored and transported in condition that will maintain their
   quality
   • Ensure all of the crew understand the safety management system and work efficiently to
   meet the requirements of our clients
   • Coordinating activities in terms of goods arriving, loading and unloading from other
   transportation to ensure the scheduled time delivery
   Handling complains and coordinates between the drivers.

   5)Financial statement FY 2017.

   6)ABN and ASIC registration.

   7)Seek.com advertisement 24 November 2017.

   8)Organisation chart showing 39 employees – all Australian citizens.

   Managing director – Craig Graham.

   General Manager – Richard Sandham.

   Fleet Manager – the nominee above the Truck drivers

   Workshop Manager – Brandon Graham.

   Administration – Ms Gibson.

   9)Regional Certifying body approval 8 February 2018.

   Documents including the following were submitted after the review application was lodged.

   10)BAS statements FY 2018 & FY 2019.

   11)Notification of refusal of employer nomination including Notice of Decision.

   12)Job description same as that above.

   13)Financial statements FY 2018.

   14)Advertisement created 2017.

   15)Extract from promotional material regarding the business.

   16)Tax invoices and similar from the applicant to customers FY 2020 evidencing operation.

   17)Customer invoice report and vehicle registrations.

   18)Financial statements FY 2020 and FY 2021.

   19)BAS statements FY 2021 and FY 2022.

   20)Letter of engagement 1 September 2022 for start date 29 August 2022 on $68,000 per annum.

   Essential Job Functions

   ·Responsible for the records of maintenance of the fleet including the equipment to ensure vehicles are in good condition.

   ·Managing the bookings and planning the schedule to maintain maximum availability of fleet.

   ·Maintain clean and tidy workplace.

   ·Ensure all goods are stored and transported in condition that will maintain their quality.

   ·Keeping all vehicles and equipment clean and tidy and presentable.

   ·Assist workshop Manager when requested.

   ·Assist Office Management when requested.

   ·Learning operation of transport company.

   ·Ensure personal safety and safety of others is a priority at all times.

   ·Comply with company policies and procedures at all times.

   21)Payslips for the nominee from 29 September 2022 to 21 December 2022 for classification Fleet Manager.

   22) High Risk Work (HRW) – Candidate assessment summary by Queensland Government as competent for Licence Class LF – Forklift Truck, issued 21 September 2022 to the nominee Zhichao Du. Candidate is assessed as not yet competent for one or more assessment types for the HRW licence class and has not completed all required assessment types for the HRW licence class.