Jessica Reinmuth v James Cook University
[2024] FWC 1968
•26 JULY 2024
| [2024] FWC 1968 |
| FAIR WORK COMMISSION |
| DECISION |
Fair Work Act 2009
s.365—General protections
Jessica Reinmuth
v
James Cook University
(C2024/3759)
| COMMISSIONER SIMPSON | BRISBANE, 26 JULY 2024 |
Application to deal with contraventions involving dismissal – Jurisdictional objection – Applicant resigned – Application dismissed.
On 6 June 2024, Jessica Reinmuth (Ms Reinmuth / the Applicant) applied to the Fair Work Commission (the Commission) under s.365 of the Fair Work Act 2009 (the Act) for an application to deal with a general protections dispute involving dismissal. The Respondent in the matter was named as James Cook University (the Respondent).
The Respondent raised a jurisdictional objection that the Applicant was not dismissed, and instead resigned voluntarily. Ms Reinmuth accepted that she had resigned from her employment but argued that she was coerced into doing so by the Respondent, such that she was dismissed within the meaning of s.386(1)(b) of the Act.
On 2 July 2024, I issued a Notice of Listing and Directions to the parties regarding the jurisdictional objection. A jurisdictional hearing was held on 23 July 2024.
Ms Reinmuth appeared with her partner Mr Tim Pipe, and Ms Belinda Pope appeared on behalf of the Respondent. Ms Reinmuth provided a witness statement which was admitted into evidence.
Background
Ms Reinmuth commenced employment with the Respondent on 9 September 2019 as an Assistant HR Administrator. As a result of the COVID-19 pandemic, in 2020 Ms Reinmuth and other staff of the Respondent worked from home on a temporary basis. In August 2020, staff started to return to the Respondent’s Townsville campus in a hybrid working approach.
At this time, the Respondent allowed Ms Reinmuth to continue to work from home as she was considered a vulnerable person due to her medical condition. Ms Reinmuth gradually returned to on-campus work from June 2022, and she resumed her previous arrangement on 6 April 2023. In this role, she and the other staff in the HR Administration team worked from home 2 days per week.
In July 2023, Ms Reinmuth submitted advice from her medical practitioner advising her to work from home, due to the physicality required of Ms Reinmuth in commuting to work, rather than the nature or physicality of the work itself. Despite this, the Respondent’s expectation was that Ms Reinmuth would continue to work on-campus 3 days per week.
Ms Reinmuth undertook an independent medical examination in January 2024 at the Respondent’s direction. The examination confirmed that the barrier to the Applicant’s return to campus was the travel required, noting that it took approximately 20 minutes for Ms Reinmuth to drive to campus, and she experienced uncomfortableness after approximately 10 minutes in a car.
In the months leading to Ms Reinmuth’s resignation, she was on a gradual return to work plan and was allowed to work from home 4 days per week. On 15 April 2024, Ms Reinmuth provided a medical certificate advising that she was unable to work on campus 1 day per week for a month. The Respondent sought further information in relation to this advice, and Ms Reinmuth’s medical practitioner stated that she experienced symptoms including fatigue, lethargy, reduced concentration, agitation and cognitive difficulties.
Based on this information, the Respondent informed Ms Reinmuth that it could not accommodate further suitable duties for her, due to safety concerns. Ms Reinmuth was informed that she required a medical clearance before she could return to work. She then commenced a period of sick leave on 23 April 2024.
On 30 April 2024, Ms Reinmuth emailed a resignation letter to Ms Amanda Parker, a HR Advisor of the Respondent.
Evidence and Submissions
The Respondent submitted that it did not terminate Ms Reinmuth’s employment and did not engage in any conduct, or course of conduct, that forced her to resign. Instead, the Respondent argued it acted reasonably in supporting Ms Reinmuth by allowing her to work according to the same hybrid working arrangement that applied to all other staff in the HR Administration team.
Ms Reinmuth said in her statement that she suffers from rheumatoid arthritis, and unless she has a flare up the condition does not generally impact her ability to perform her role, however excessive walking drives and exacerbates the pain she suffers, and she is able to manage her symptoms more successfully if she limits the physical demands placed on her body.
Ms Reinmuth said her initial employment was based full time on campus and as a result of the COVID-19 pandemic she commenced working from home full time from February 2020 as did her colleagues. Ms Reinmuth said hybrid working arrangements commenced in August 2020 and she remained working at home as she was identified as a vulnerable worker until June 2022 when she commenced a graduation to a hybrid working arrangement.
Ms Reinmuth said from July 2022 she worked from home two (2) days per week and worked on campus three (3) days per week. Ms Reinmuth said she took personal leave from 14 November 2022 to 21 December 2022 as a result of her symptoms worsening.
Ms Reinmuth said between January 2023 and June 2023 she attempted to resume the hybrid working arrangement of two (2) days at home and three (3) days at work, and during this period she was required to utilise personal leave and/or annual leave for the days she was unable to work on campus due to her medical condition.
Ms Reinmuth said in late June 2023 her symptoms flared and she was unable to attend work on campus for a period of time and the Respondent approved her to work from home on a full time basis.
Ms Reinmuth said on 8 September 2023 the Respondent requested further information from her general practitioner Dr Kaylene Girgenti, in relation to her medical conditions and ability to return to work on campus. Ms Reinmuth produced a copy of a letter from her medical practitioner to the Respondent dated 3 October 2023 detailing her medical conditions and supporting her request to continue working remotely for the next month until at least 1 November 2023.
Ms Reinmuth said in early November 2023 her Rheumatologist prescribed her new medication, and as a result her medical practitioner recommended that she continue to work remotely from home for a further period of 14 weeks to assess her response to the medication. Ms Reinmuth produced a copy of this letter dated 1 November 2023 from her medical practitioner to the Respondent. The medical certificate included the following:
“…This is to certify that on the 01.11.2023 I examined Miss Jessica Anne Reinmuth who in my opinion is suffering from a medical condition and will be unfit for Work in the workplace until a review following a trial of a new medication (see attached letter from the specialist), but will be suitable for work from home.
I anticipate that to adequately assess the response to the treatment – she would need to complete at least the initial 14 weeks as per the letter…”
Ms Reinmuth also provided a copy of a referral letter dated 27 October 2023 from her Rheumatologist for a treatment program over 14 weeks and depending on the response further treatment.
On 28 November the Respondent sent correspondence to Ms Reinmuth requiring her to attend an Independent Medical Examination (IME). The letter included the following:
“As you know, James Cook University has sought information over the past 18 months from your current treating medical practitioner to assist us to support your return to the workplace.
Unfortunately, the information provided to date is unclear and inconsistent, and we have no long-term health prognosis to effectively assess the level of risk associated with your medical conditions and your fitness for work.
Under Clause 51 of the James Cook University Enterprise Agreement 2022 (the Agreement), the University can require a Staff Member, whose capacity to perform the duties of their position is in doubt, to undergo a medical examination by a medical practitioner or an assessment by a suitably qualified allied health professional chosen by the University at the expense of the employer.
In the absence of clear and consistent health advice to date, I have determined to require you to undergo a medical examination in accordance with Clause 51 (a) of the Agreement. This letter serves to provide no less than 4 weeks’ notice that you are required to attend a medical examination as required in accordance with Clause 51(c) of the Agreement.
The medical examination will be undertaken by a doctor who is a Board-registered Occupational Physician. The University will cover the cost of the examination and all travel expenses incurred in attending the medical examination. In addition, you will be paid for your attendance….”
Ms Reinmuth said on 9 January 2024 she attended the IME. Ms Reinmuth said that she was verbally advised by the examiner that she was capable, and it was safe for her to continue working remotely from home. Ms Reinmuth said the examiner also recommended that she reduce her pain medication and she was told to increase movement in her lower body to assist in managing her medical condition.
Ms Reinmuth said between 21 February 2024 and 13 March 2024, she commenced a return to work program with the Respondent. Ms Reinmuth said she worked one (1) day per fortnight on campus and worked the remaining nine (9) days of each fortnight remotely at home. Ms Reinmuth produced a copy of a Work Capabilities Form on the Respondent’s letter head to be completed by the employee’s medical practitioner. The form was completed on 14 February 2024 by Dr Girgenti recommending Ms Reinmuth could work for one day a fortnight in the workplace to be reviewed on 13 March 2024.
Ms Reinmuth said that on 18 March 2024 she commenced a revised return to work program with the Respondent, increasing the days she worked on campus to one (1) day per week. Dr Girgenti completed the Work Capabilities Form on 11 March 2024 for this to occur, with a review date of 10 April 2024.
Ms Reinmuth said on 10 and 11 April 2024 she was unable to work for two (2) days and took personal leave. Ms Reinmuth produced a medical certificate from Dr Girgenti dated 15 April 2024 stating that Dr Girgenti examined Ms Reinmuth on 15 April 2024 and in her medical opinion Ms Reinmuth is suffering from a medical condition and will be:
“…unfit for Work from: 15/4/2024 to: 10/05/2024 inclusive.
She is able to continue working from home for this period. Should you require any further information, please do not hesitate to contact me…”
Ms Reinmuth said that it was always her intention to return to work on campus in a hybrid working arrangement similar to her colleagues, however at that point in time, the symptoms associated with her medical condition prevented her from doing that, although her general practitioner had determined that it was safe for her to continue working from home on a full-time basis.
Ms Reinmuth said on 15 April 2024 she resumed remotely working from home on a full time basis in accordance with the medical certificate.
Ms Reinmuth said on 16 April 2024 she attended a meeting with the Respondent and was informed by Ms Parker that she would have to take annual leave on 17 April 2024, being the day she was supposed to work on campus in accordance with her return to work suitable duties plan.
Ms Reinmuth said between 16 April 2024 and 20 April 2024, her general practitioner and the Respondent corresponded in relation to her medical condition and her suitability to continue work remotely. Ms Reinmuth produced copies of correspondence between her general practitioner and the Respondent.
On 16 April 2024, Dr Girgenti sent correspondence to Peta Millar, Injury Prevention and Management Advisor at the Work Health and Safety Services and Resources Division of the Respondent. I do not intend to repeat the contents of the letter in full, however the letter described Ms Reinmuth’s symptoms and described additional symptoms as a result of her medical treatment including agitation, dizziness, fatigue, irritation and cognitive difficulties.
On 19 April 2024 correspondence was sent to Dr Girgenti from the Respondent setting out the symptoms and side effects described by Dr Girgenti in the context of general work activities, heightening the likelihood of medical incidents or injuries. The Respondent’s correspondence referred to:
“…inherent risks associated with isolated working from home, especially given her medical condition and lack of immediate support, cannot be overlooked.
The University operates under a hybrid flexible working arrangement, which entails a requirement for employees to work from campus for a portion of their working hours. We believe that expecting Ms Reinmuth to fulfil this requirement by working on-site for one day per week is not unreasonable, considering the nature of her role and our commitment to maintaining operational efficiency.
You have referenced disabilities in the report, we have found no record of any modifications or adjustments requested by Ms Reinmuth’s that references a disability as a contributing factor to her working from home arrangement. If this factor is relevant, could you please detail how this impacts Ms. Reinmuth ability to her fulfil responsibilities at work?”
The 19 April correspondence from the Respondent also requested the following:
“What the university would like to understand is how Ms. Reinmuth, given her list of symptoms and medication side effects, can safely fulfil her job duties, irrespective of whether she is on campus or not, and without factoring in the commute to and from campus….”
On 20 April 2024 Dr Girgenti sent correspondence to Peta Millar at the Respondent that included the following:
“…
The Oxford Dictionary defines disability as:
1. A physical or mental condition that limits a person’s movements, senses or activities:
2. A disadvantage or handicap, especially one imposed or recognized by law:Jessica has a permanent diagnosis of inflammatory arthritis. As per previous correspondence in the past, we have requested closer parking due to her limited physical abilities, in addition to the ability/option to work from home and when on campus, take regular breaks when required. I believe these would all be considered as modifications or adjustments. I have previously on many occasions detailed how her pain, limited ROM and levels of fatigue impact her ability of fulfil her responsibilities at work when required to work on campus.
I am unable to comment on Jessica/s ongoing work performance – I believe that if there had been any concerns about her completion on of work based tasks or KPI’s, this would have been addressed by yourselves in the workplace. In my opinion, she is more then able to safely fulfil her jobs and duties regardless of her location. The requirement to compute to and from campus can at times put extra strain on her above an beyond what she details with on a day to day basis.
I hope this has assisted and would welcome any further correspondence should you require more detail.”
It was put to Ms Reinmuth that she had submitted that the Respondent failed to make reasonable temporary adjustments forcing her to resign, and she was asked what reasonable adjustments were not made given her capacity to work from home four days a week and one day at work on her Work Capabilities Form. Ms Reinmuth said on 23 April 2024 she was advised that her doctor’s medical advice that she could work from home, was not acceptable to the Respondent and could not be accommodated.
It was put to Ms Reinmuth that this was for a temporary period of time as a result of changes in her medical condition because of changes to her medication as described by her medical practitioner such as agitation, dizziness, fatigue, irritation and cognitive difficulty. Ms Reinmuth appeared to agree with this proposition.
Ms Reinmuth said on 22 April 2024 she had a discussion with the Respondent, and Peta Millar informed her that the Respondent required further information in relation to her symptoms. Ms Reinmuth said the Respondent requested a medical clearance from her general practitioner. This was why Ms Reinmuth was asked to take personal leave.
Ms Reinmuth provided email correspondence at 11:04am on 22 April 2024 from Peta Millar to herself which included the following:
“Thank you for taking the time to discuss your medical documentation with me today. As per our conversation, I have attached the information provided by your GP.
The report highlights that you experience symptoms such as fatigue, lethargy, malaise, and reduced concentration at times.
Additionally, that the reduction in pain medication have introduced further symptoms, including but not limited to agitation, dizziness, fatigue, irritation, and cognitive difficulties. Given our responsibility to prioritse your safety, particularly in the context of remote work where direct supervision and immediate assistance might be limited, it's imperative to address any health concerns or symptoms that could hinder your performance or compromise your safety.
Considering the severity of these symptoms and their potential impact on your safety in a work environment, the university has requested further clarification. In the absence of such clarification, we kindly request medical clearance confirming when the mentioned risks are no longer relevant…”
Later that day at 3:01pm Ms Reinmuth received a further email from Emma Pollock from the Respondent as follows:
“Hi Jess
I will set up a meetng for tomorrow morning with you, Amanda and I to discuss further.
I do however want to acknowledge that given the information provided by your GP, I have concerns around the request for ongoing remote working.
Additionally, I support the request from WHS regarding medical clearance confirming when the mentioned risks are no longer relevant, which would allow you to travel to campus to undertake a hybrid working model.
Regards
Em”
Ms Reinmuth said on 23 April 2024 she attended a Microsoft Teams meeting with Ms Pollard and Ms Parker of the Respondent. Ms Reinmuth said that Ms Pollard informed her that she was no longer permitted to work remotely from home until a medical clearance had been provided.
Ms Reinmuth said that as she was unable to attend campus or work remotely from home and she had exhausted her personal leave entitlements, she was required to utilise her annual leave entitlements until the Respondent received the requested clearance.
Ms Reinmuth said on 30 April 2024 she resigned from her employment with the Respondent. The resignation letter stated as follows:
“Hi Amanda,
I am writing this email to notify you that I am resigning from my position at JCU as HR Assistant. My last day employed with JCU is 28th May 2024.
Regards,
Jessica Reinmuth”
The following day, Ms Parker sent the following email in response:
“Hi Jess,
Apologies for not replying sooner, however this email went to my spam folder, so I didn’t see it until late last night.
We will be sorry to see you go but thank you for your contribution to the team over the past four and a half years.
Can you please let me know a convenient time that we can arrange to have your JCU equipment returned. Also please let me know if you would like to have a final lunch with the team. I’m sure they would love the opportunity to say goodbye also.
Thanks
Amanda”
Later that day, Ms Reinmuth provided a further medical certificate, stating that she was suffering from a medical condition and was unfit for work until 28 May 2024. Accordingly, she did not perform any work for the Respondent after the notification of her resignation on 30 April 2024, and the date the resignation took effect on 28 May 2024. Ms Reinmuth said she utilised her annual leave entitlements. Ms Reinmuth said that she felt that she had no other choice but to resign from her employment with the Respondent.
Ms Reinmuth said the Respondent refused to make reasonable adjustments for her to work remotely from home due to her medical condition.
Ms Reinmuth asserted that she requested to work remotely due to her medical condition for a period of time and the Respondent was aware that she intended to gradually increase the number of days spent working on campus once her symptoms improved. Ms Reinmuth asserted the Respondent refused the request and failed to make reasonable temporary adjustments with the deliberate and dominant purpose of forcing her to resign.
Ms Reinmuth asserted there was no genuine or operational safety reason why the Respondent required her to return to work on campus or provide a medical clearance to resume work including:
(a)the Applicant’s role did not require her to work on campus;
(b) the Applicant had worked remotely from home on full-time and/or hybrid working arrangement since the COVID-19 pandemic, with no adverse impacts on her performance or output or that of her team members;
(c) there was no genuine basis for the Applicant not being able to safely work from home and the Applicant’s general practitioner supported a work from home arrangement for the Applicant;
(d) the Respondent acted in an adverse manner in refusing to accept the advice of the Applicant’s general practitioner concerning the Applicant’s capacity to work from home and by requiring the Applicant to utilise annual leave entitlements until she was able to return to work on campus;
(e) three (3) colleagues of the Applicant in the same role work a hybrid working arrangement of three (3) days on campus and two (2) days from home; and
(f) as such, the Respondent is adept at accommodating remote working arrangements without any adverse impacts on organisational objectives.
Ms Reinmuth asserted that the decision of the Respondent had the effect of preventing her from performing her role and that the termination of her employment was the probable result of the employer’s decision such that she had no effective or real choice but to resign.
The Respondent submitted that Ms Reinmuth was not forced to resign from her employment, and the Respondent has not engaged in any conduct or course of conduct that would force Ms Reinmuth to resign.
It was put to Ms Reinmuth in oral evidence that the Respondent had never agreed for her to work from home on a full-time basis and that she was on a return to work arrangement for one day per week on campus with a transition, and she had never applied for an individual flexibility arrangement or a flexible working arrangement. Ms Reinmuth said she was never offered an individual flexibility arrangement and she was not aware that was an option.
It was put to Ms Reinmuth that these arrangements are available in the enterprise agreement, and this was outlined to all staff. Ms Reinmuth agreed she attended the training session about the enterprise agreement, but she did not think it was relevant to her situation. Ms Reinmuth agreed she did not seek advice about this.
Ms Reinmuth was asked whether she engaged in any discussions about escalating her concerns before resigning such as with the Director of Human Resources or anyone else, in order for the Respondent to respond to her concerns. Ms Reinmuth said she did not make contact with the Director of Human Resources as when she had in the past she had received “pushback” so she did not bother. Ms Reinmuth said she did not seek advice from anyone else as there was no one that could help her in her situation.
Ms Reinmuth said she believed she had a balance of approximately 50 hours of leave at the time she resigned. Ms Reinmuth initially thought all her leave was exhausted about two weeks prior to the end of her notice period. The resignation date was 30 April 2024, and the last day of employment was 28 May 2024. It was put by the Respondent that during the notice period Ms Reinmuth took three days paid sick leave and 13 days annual leave and one public holiday resulting in five days of unpaid leave. After checking, Ms Reinmuth subsequently advised that this was correct.
The Respondent submitted that at the time of her resignation Ms Reinmuth was on a graduated return to work plan and was supported to work from home four days per week, with the expectation to be on campus one day per week. The Respondent said it was committed to continuing to work with Ms Reinmuth and her treating medical practitioners to return her to work three days on campus, two days working from home as per her colleagues in the HR Administrative team.
The Respondent submitted that in July 2023, Ms Reinmuth's medical practitioner advised her to work from home due to difficulties in commuting, not the nature of her work. The practitioner noted that there was no medical reason preventing her from finding alternate ways to get to campus. The Respondent said it suggested ways to support her in working on campus three days a week during flare-ups, but it was ultimately her responsibility to make arrangements to be on campus. The Respondent said it continued to support her working from home based on medical advice for certain periods, while maintaining the expectation that she would transition back to working on campus three days per week.
The Respondent said that in January 2024, it required Ms Reinmuth to undergo an IME which confirmed that her difficulty in returning to campus stemmed from her ability to commute, as she lived about 20 minutes away and experienced discomfort after 10 minutes in the car.
The Respondent said at the time of her resignation, she was on a graduated return-to-work plan, supported to work from home four days a week, with the expectation of being on campus one day a week, however, on 15 April 2024, she provided a medical certificate advising that she could not work on campus for one day a week for a month, prompting the Rehabilitation team to seek further advice from her treating medical practitioner due to conflicting information with the IME.
The Respondent said on 16 April 2024, her treating medical practitioner detailed symptoms such as fatigue, lethargy, reduced concentration, and issues from weaning off long-term pain medication, including agitation and cognitive difficulties. Based on this information, the Respondent informed Ms Reinmuth that they could not accommodate further suitable duties due to safety concerns and required a medical clearance for her return to work.
The Respondent said Ms Reinmuth did not object to this requirement and subsequently took sick leave starting 23 April 2024 before resigning on the 30 April 2024. Following her resignation, Ms Reinmuth was offered a farewell lunch by her direct supervisor, which she declined, and her colleagues contributed to purchasing a farewell gift which the Respondent said was a customary practice upon separation when a staff member resigns their employment rather than being dismissed.
The Respondent submitted that it did not coerce Ms Reinmuth to resign, and the University has been reasonable both in supporting Ms Reinmuth to work from home following medical advice and in working to transition Ms Reinmuth to the same hybrid arrangement (three days on campus, two days working from home) as her colleagues in the HR Administrative team. The Respondent submitted that during this process, Ms Reinmuth chose to resign from her position.
Relevant legislation
Section 386(1) of the Act states:
“386 Meaning of dismissed
(1) A person has been dismissed if:
(a) the person’s employment with his or her employer has been terminated on the employer’s initiative; or
(b) the person has resigned from his or her employment, but was forced to do so because of conduct, or a course of conduct, engaged in by his or her employer.”
Consideration
Pursuant to section 386(1)(b) of the Act, a person is ‘dismissed’ where the conduct, or course of conduct of the employer forces the employee to resign, that is the employee has no real choice but to resign. There must be some action on the part of the employer which is either intended to bring the employment to an end or has the probable result of bringing the employment relationship to an end.
It is apparent that the position taken by the Respondent was that it wanted Ms Reinmuth to obtain a medical clearance in order to allow her to return to work, after it received specific advice from her general practitioner about the impact the symptoms of her condition, and side effects of the treatment that she had been receiving, was having on her. It seems reasonably clear the intention of the Respondent was for Ms Reinmuth to cease working, whether it be at home or on campus until her medical condition and or the side effects of treatment for the condition at that time, subsided, given it appears not in dispute that it was envisioned the side effects in particular would be for a temporary period of time.
The evidence does not support a conclusion that the Respondent’s actions were intended to bring the employment relationship to an end. The intention was to not expose Ms Reinmuth to potential risk of injury by requiring her to work at any location, for the specific period of time that she was suffering from the symptoms and side effects described in her general practitioner’s advice to the Respondent.
I am also not satisfied that the position adopted by the Respondent had the probable result of bringing the employment relationship to an end. The material before the Commission indicates the Respondent had been supportive of Ms Reinmuth and provided reasonable accommodation in relation to her non work-related medical condition, in attempting to work with her to attempt to slowly return her to working on a hybrid model of working at home and on campus in a graduated manner.
Ms Reinmuth’s initial role in 2019 was based on campus five (5) days per week. It does not appear to be unreasonable that the Respondent direct that a proportion of Ms Reinmuth’s role be performed on campus under the hybrid working arrangement of two days at home and three on campus for the purpose of collaboration, process improvement and team building. Ms Reinmuth has not provided evidence of any contractual right, or right described in an industrial instrument to work from home on a full-time basis.
Ms Reinmuth could have escalated the dispute about the Respondent’s decision to require a medical clearance on the basis of the medical advice provided by her general practitioner to a higher level of management within the University or brought a dispute under the dispute settling procedure in the enterprise agreement, or alternatively under the Respondent’s grievance procedure. Ms Reinmuth did not take this step and instead tendered a resignation on 30 April and subsequently a medical certificate advising she was not fit for work for the period of notice which ran out on 28 May 2024.
I am satisfied on the basis of the evidence that Ms Reinmuth’s resignation was a decision taken by her voluntarily. As the Applicant was not dismissed the Commission has no jurisdiction to deal with the matter any further and the General Protections application is dismissed. An order will be issued separately and concurrently with this decision to that effect.
COMMISSIONER
Appearances:
Ms Jessica Reinmuth on her own behalf assisted by Mr Tim Pipe.
Ms Belinda Pope for the Respondent.
Hearing details:
2024
By Microsoft Teams Video
23 July.
Printed by authority of the Commonwealth Government Printer
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