Maritime Union of Australia v Fremantle Ports

[2015] FWC 6865

[2015] FWC 6865

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009
s.739 - Application to deal with a dispute

Maritime Union of Australia
v
Fremantle Ports
(C2014/6650)

COMMISSIONER CLOGHAN PERTH, 20 OCTOBER 2015

Alleged dispute concerning cleaning duties.

[1] The Maritime Union of Australia (MUA or Applicant) has made application to the Fair Work Commission (Commission) to deal with a dispute in accordance with a dispute settlement procedure (DSP).

[2] The MUA is in dispute with Fremantle Ports (Fremantle Ports or Employer).

[3] The application is made pursuant to s.739 of the Fair Work Act 2009 (FW Act).

[4] The DSP is contained in the Fremantle Ports Bulk & General Stevedoring Enterprise Agreement 2012 (2012 Agreement).

[5] The application was the subject of conciliation but remained unresolved.

[6] At the hearing, the MUA was represented by Ms E Palmer, Industrial Officer and evidence was given on behalf of the MUA by Mr W Tracey, Deputy National Secretary and Mr J Cassar, Assistant Branch Secretary Western Australia.

[7] The Employer was represented by Mr M Vallence, Industrial Agent and evidence was given on behalf of Fremantle Ports by Mr M Pearce, Manager Bulk Business and Ms A Wiseman, Human Resources/Industrial Relations Advisor.

RELEVANT BACKGROUND

[8] The Port of Fremantle operates from two locations; the Inner Harbour at Fremantle and the Outer Harbour, south of Fremantle.

[9] In the Outer Harbour, the Employer operates a commercial bulk handling service at the Kwinana Bulk Terminal (KBT). The Employer utilises its employees in the servicing of contracts with users of the Outer Harbour Kwinana Bulk Jetty (KBJ).

[10] Thirteen full-time stevedoring employees are based at the KBT and undertake work related to the loading and unloading of vessels berthing at the KBT and KBJ. The stevedores are employed pursuant to the 2012 Agreement.

[11] The parties are in dispute with respect to what, when and where some aspects of cleaning duties are to be carried out, pursuant to the 2012 Agreement.

[12] The requirement to carry out cleaning duties primarily arises as a result of: spillage of bulk product from the conveyor belts during the loading and unloading process and residue left behind during the loading and unloading of vessels.

[13] The need to keep the wharf and various equipment clean at the KBT is for a number of reasons including: safety hazards; environmental reasons; environmental licencing requirements; dust control; reducing the amount of maintenance and ensuring optimum efficiency of equipment.

[14] The Employer asserts that cleaning can be safely undertaken when there are no vessels alongside the wharf, at appropriate times when there are stoppages in the loading/unloading process and during maintenance shutdowns. 1

[15] The Employer concedes that although there have been instances where stevedores have undertaken cleaning prior to a vessel coming alongside the wharf and when loading/unloading operations have been delayed, the employees have generally refused to undertake the work and have consistently refused to clean underneath the JC01 conveyor.

[16] Notwithstanding the above situation which has existed since the commencement of the 2012 Agreement on 13 February 2013, the Employer has not “forced the issue”. 2

[17] The Employer has now “forced the issue” and it is necessary, pursuant to the application, to determine answers to the following questions as agreed between the parties:

Is Fremantle Ports entitled, pursuant to the terms of the Fremantle Ports Bulk & General Stevedoring Enterprise Agreement 2012 to require Stevedoring employees covered by that Enterprise Agreement to:

• undertake cleaning duties prior to a vessel coming alongside and at times when an alongside vessel is not being loaded or unloaded (e.g. whilst waiting for product, due to breakdown or other delays in loading or unloading);



• whilst undertaking cleaning duties, clean up all product and not just the product left from the last vessel; and



• clean underneath the JC01 conveyor?

RELEVANT STATUTORY FRAMEWORK

[18] There is no dispute between the parties that the application has been properly filed and made in accordance with the DSP in Clause 25 of the 2012 Agreement.

DISPUTE

[19] The scope and timing of the cleaning duties for stevedores was the subject of “considerable controversy in bargaining for the 2012 Agreement”. 3 That controversy resulted in Schedule 1 which I have attached to this Decision. Conceptually, Schedule 1 relates to where, when, what and how cleaning is undertaken.

[20] Subject to one exception, the MUA assert that Schedule 1 is a restrictive covernance and is the “be-all and end-all” of cleaning duties for stevedores employed pursuant to the 2012 Agreement. 4

[21] Fremantle Ports while acknowledging Schedule 1, relies on other general provisions in the 2012 Agreement for the discretion to allocate cleaning duties consistent with a positive answer to the three questions for determination in paragraph [17]. The MUA is seeking a negative answer to all three questions.

RELEVANT PROVISIONS OF THE 2012 AGREEMENT

Clause 7: Definition

[22] Stevedoring includes:

“…

• General functions and duties such as the lashing and unlashing of containers, working in a ship’s hold, driving of motor vehicles including buses, marshalling, cleaning (per Schedule 1 to this Agreement) and…”

Clause 9: General Employment Arrangements

“The Employer may utilise permanent full-time…employees as required in any of the stevedoring operations. Employees shall be available for work consistent with this Agreement.

There shall be no restriction on the allocation of tasks provided for under this Agreement subject to…

Employees shall be recruited and used at the discretion of the Employer and shall be utilised in accordance with the Employer’s policies and procedures in an operational requirement. Nothing in this Agreement shall impede the process of ongoing change to continuously improve the viability, efficiency and productivity of stevedoring operations.

Job staffing and work practices shall be relevant to operations and aimed at international best practice benchmarking…”

Clause 13: Hours of Work

“13(a) …
13(b) …

13(c) Availability

Employees are to be able to undertake stevedoring work contained within this Agreement without restriction imposed by whether or not a ship is alongside a wharf or not.
…
In addition, employees must be available for cleaning duties per Schedule 1 of this Agreement from time to time.”

Clause 21: Continuity of Operations and Composition of Workforce

“The parties recognise and accept the requirement of the Employer to be able to guarantee delivery of services to its customers. The Employer shall have the discretion to determine the number and placement of employees to particular functions on an individual basis at the start of and throughout the course of any shift including…

“An employee shall perform such work as the Employer shall, from time to time, reasonably require…employees may also be required to perform unscheduled, incidental or unforeseen duties, including…cleaning duties per Schedule 1.” (my emphasis)

PREVIOUS OR RELATED INDUSTRIAL INSTRUMENTS

[23] Previous industrial instruments which have a relationship with the 2012 Agreement are considered below.

[24] The Fremantle Ports Bulk & General Stevedoring Enterprise Agreement 2005 (2005 Agreement) referred directly to cleaning in a very limited sense. The only reference is in subclause 7.3.1 which refers to the situation of “two cranes/three drivers” situation where the “Down driver” is “able to assist in productive work, which includes but is not limited to… general cleaning…”

[25] The 2005 Agreement applies to employees “performing functions within the Stevedoring Industry Award 1999” (1999 Award) in Grades 1 to 6 of the same award.

[26] The 1999 Award applies to “stevedoring employees engaged in stevedoring operations”.

[27] The 1999 Award sets out the definition of stevedoring operations at Clause 7. For relevant purposes, at paragraph 7(j), “General functions” includes: “general cleaning”, “cleaning and attendance to amenities areas and offices”, “cleaning and maintenance of containers”, “sorting, stacking, preparing or otherwise handling of loose goods and cargo”, “preparation and cleaning of ships’ holds”, “the handling of dunnage or ballast” and “general duties in connection with the loading and unloading of ships”. Put shortly, cleaning is a normal function of a stevedoring employee.

[28] The 1999 Award was replaced by the Stevedoring Industry Award 2010 (2010 Modern Award).

[29] The 2010 Modern Award does not include a definition of “stevedoring operations” in the same extensive way as in the 1999 Award. The reason for the lack of an extensive definition of “stevedoring operations” is, in my view, due to the fact that the 1999 Award applied to “stevedoring employees” engaged in “stevedoring operations”. However, the 2010 Modern Award covers employers engaged in the “stevedoring industry” and their employees in the listed classifications. It is not necessary to set out a description of each employee classification but to say that the “stevedoring industry” means, “the loading and unloading of cargo into or from a ship including transporting and storage at or adjacent to a wharf”.

[30] The 2010 Modern Award followed from the then Minister for Employment and Workplace Relations making a request pursuant to s.576C(1) of the Workplace Relations Act 1996, that the AIRC undertake award modernisation (Request).

[31] The Request, amongst other matters, set out the objectives of modern awards:

• to be simple to understand, easy to apply and reduce the regulatory burden on business; and



• must be economically sustainable and promote flexible modern work practices and the efficient and productive performance of work; and



• must be in a form that is appropriate for a fair and productive workplace relations system that promotes collective enterprise bargaining but does not provide for statutory individual employment agreements.

[32] Consequently, when the MUA gave evidence that the 2010 Modern Award, “does not provide for the performance of cleaning functions or include a definition of stevedoring operations”, this is not surprising. Further, it is not surprising that the 2010 Modern Award does not include, “any cleaning function” in what the MUA described as detailed, “classification descriptions”. 5

[33] If “modern” is defined as pertaining to the present, it would be remarkable if the Commission conformed to the past and adopted detailed descriptions of “General functions” in the 1999 Award, to such an extent, as cleaning of amenities areas in the 2010 Modern Award.

[34] The absence of detail in employee classifications in modern awards was a purposeful process and not intended to exclude or qualify the functions, in this case, of a stevedore. Cleaning had been a function of stevedores in previous industrial instruments. The 2010 Modern Award was not intended, or should be interpreted, as removing the cleaning function from the role and duties of a stevedore.

[35] To illustrate absence of detail in the transition from “stevedoring operations” in the 1999 Award, to the duties of a “stevedore employee grade 2” in the 2010 Modern Award, a multitude of duties and functions are reduced to the descriptor “other general duties”. Similarly, it is useful to compare the 1999 Award which had a long list of clerical functions in the duties of a stevedore, which is replaced in the 2010 Modern Award, with the following; “clerical tasks incidental to the performance of functions at this grade” and “other basic clerical tasks”.

[36] It would be wrong, in my view, to infer that a lack of reference to “cleaning functions” in the 2010 Modern Award to anything, more or less, than “it goes without saying” that stevedores are expected to carry out cleaning functions as part of their general duties.

[37] In summary, the lack of reference to cleaning functions in the 2010 Modern Award, is nothing more than, such duties are self-evident, incidental and consequential to employment as a stevedore.

INTERPRETATION OF ENTERPRISE AGREEMENTS

[38] The parties were in agreed that the Commission should interpret the 2012 Agreement consistent with the summary of principles set out in the Full Bench Decision in The Australasian Meat Industry Employees Union v Golden Cockerel Pty Ltd[2014] FWCFB 7447 at para [41]. I have done so.

IS THE EMPLOYER, PURSUANT TO THE 2012 AGREEMENT, ENTITLED TO REQUIRE STEVEDORES TO undertake cleaning duties prior to a vessel coming alongside and at times when an alongside vessel is not being loaded or unloaded (e.g. whilst waiting for product, due to breakdown or other delays in loading or unloading)?

[39] The MUA assert:

“other than those cleaning duties within the Schedule 1 that are specified to be performed “during operations”, stevedoring employees can only be required to perform cleaning duties, “immediately following the performance of stevedoring duties and immediately after completion of the vessel or in other specified circumstances…” 6 (my emphasis)

[40] In support of this assertion, the MUA rely upon two terms of the 2012 Agreement. The two terms are as follows.

[41] Firstly, a particular term of Schedule 1 reads:

“Cleaning will be undertaken in accordance with this Agreement, with resources, times, shifts allocated immediately after completion of the vessel.”

[42] Secondly, in Clause 7: Definitions, of the 2012 Agreement, a “Grey Day” means:

“a rostered day” which an employee, due to the hours that aren’t worked through idle time, (who are less than 48 hours ahead of the required annual hours on a year to date basis) can be required to attend for the performance of any operational stevedoring duties (including cleaning undertaken immediately following the performance of stevedoring duties) and training as required – but not for cleaning in isolation.”

[43] When considering whether the MUA’s assertion is based upon the terms of the 2012 Agreement, the commencing point is that cleaning is a normal part of a stevedore’s duties.

[44] From the commencing point that cleaning is a normal part of a stevedore’s duties, the question is whether those cleaning duties are restricted in the terms asserted by the MUA.

[45] In the first part of the term, “Cleaning will be undertaken in accordance with the Agreement”, the subject is “cleaning” and the condition is that the cleaning must be carried out in accordance with the 2012 Agreement.

[46] The word “with” denotes that “resources, times and shifts allocated”, which accompany the “cleaning”, are to be determined “immediately after completion of the vessel”.

[47] The subject of each part of the term in Schedule 1, deals with two separate and distinct matters. The two matters are “cleaning” and the “logistics” that go with that cleaning. The task of cleaning is conditional on the 2012 Agreement. The “logistics” of cleaning is conditional only in terms of timing - that is, immediately after completion of the vessel.

[48] The first part of the term in Schedule 1 is that “cleaning will be undertaken in accordance with the Agreement” is unambiguous and has a stand-alone meaning. It is a piece of information that is readily understood. Further, the MUA’s assertion that cleaning will be undertaken in accordance with the 2012 Agreement and that cleaning can only occur “immediately after completion of the vessel”, ignores the distinction between “cleaning” and the “logistics” associated with that cleaning. This distinction is important. To “mix” the distinction creates ambiguity and uncertainty, when none previously existed.

[49] In my view, it would be a distortion of the plain and ordinary meaning of the term to apply a link between the timing of the “logistics” of cleaning, with when that “cleaning” can be carried out.

[50] The “Arrangement” agreed between the parties in Schedule 1 sets out that cleaning is conditional on what is contained in the 2012 Agreement. The necessary “logistics” that go with that cleaning occur “immediately” after the loading or unloading of the vessel. This is presumably because the nature of the loading and unloading, determines the amount of cleaning required.

[51] The construction asserted by the MUA ignores the second part of the term in Schedule 1 and the “logistics” of cleaning and when those “logistics” are to be determined.

[52] Further, it is notable that the remainder of the “Arrangement” term is associated with the logistics of cleaning, in particular, the allocation of stevedores to the cleaning function.

[53] Notwithstanding the contention that Schedule 1 is intended to be the, “be all and end all” of cleaning in the 2012 Agreement, the MUA rely upon the definition of “Grey Day” in support of its assertion that stevedores can only be required to perform cleaning duties “immediately following the performance of stevedoring duties”.

[54] In support of its assertion that stevedores can only clean “immediately following the performance of stevedoring duties”, the MUA is taking a specific set of circumstances, that is, stevedores attending work on “Grey Days” – and applying those circumstances to all stevedores attending work, at all times. In my view, this is not a valid approach to the meaning and application of the 2012 Agreement.

[55] The plain and ordinary meaning of “Grey Days” is simply that, in certain circumstances an employee can be required to attend work and carry out cleaning duties following the performance of other stevedoring duties. However, the Employer is unable to require that employee to carry out cleaning duties in isolation to all other stevedoring duties.

[56] In summary, the words in “Grey Days” have a meaning within a context – “Grey Days”. In my view, to use the meaning of the words for all situations is to take the term out of context. To draw, in my view, a conclusion that all stevedores, at all times, are prohibited from carrying out cleaning duties until after other stevedoring duties have been carried out, is a misinterpretation and “out of context” meaning and application of the 2012 Agreement.

[57] Having set out that cleaning is part of a stevedore’s duties and that such duties are not restricted to immediately following the completion of a vessel, or after other stevedoring duties have been completed, it is necessary to determine whether, consistent with the question, are there any restrictions on cleaning prior to “a vessel coming alongside and at all times when an alongside vessel is not being loaded or unloaded”?

[58] Cleaning by stevedores, subject to the specific circumstances regarding “Grey Days”, is governed by the 2012 Agreement including Schedule 1.

[59] Pursuant to subclause 13(c) in Hours of Work, in the 2012 Agreement, stevedores, “are to be available to undertake stevedoring work contained within this Agreement without restriction imposed whether or not a ship is alongside a wharf or not”.

[60] Notwithstanding subclause 13(c) in the 2012 Agreement, it is still subject to the more specific provisions regarding Schedule 1. However, there is nothing in Schedule 1 which derogates from a stevedore being required to undertake cleaning duties whether or not a ship is alongside the wharf or not.

[61] For the above reasons, I determine the answer to the question posed by the parties is in the affirmative.

[62] I now turn to the second question for determination.

IS THE EMPLOYER, PURSUANT TO THE 2012 AGREEMENT, ENTITLED TO REQUIRE STEVEDORES TO whilst undertaking cleaning duties, clean up all product and not just the product left from the last vessel?

[63] The MUA assert that if it is correct that stevedores are only required to perform cleaning duties “immediately after completion of the vessel” or “immediately following the performance of stevedoring duties (subject to the various exceptions)”, employees “cannot be required to undertake cleaning duties prior to a vessel coming alongside and at times when an alongside vessel is not being loaded or unloaded” 7 (my emphasis).

[64] Put shortly, in all cases, cleaning is limited to the “last vessel” only. All other cleaning is excluded – including prior to a vessel being tied up at the wharf, or even alongside and not being loaded or unloaded.

[65] For the MUA, cleaning is essentially restricted to being undertaken during operations (loading and unloading) and only the product of the last vessel, loaded and unloaded.

[66] Should the MUA be wrong and that cleaning can only take place “immediately after completion of the vessel” or “immediately following the performance of stevedoring duties”, it follows that stevedores are not restricted to cleaning the product of the last vessel.

[67] For the reasons set out above in paragraphs [39] to [61], I am not satisfied that stevedores are restricted to cleaning duties only “immediately after completion of the vessel” or “immediately following the performance of other stevedoring duties”. Consequently, the answer to the question posed is in the affirmative.

[68] I now turn to the last question for determination.

IS THE EMPLOYER, PURSUANT TO THE 2012 AGREEMENT, ENTITLED TO REQUIRE STEVEDORES TO clean underneath the JC01 conveyor?

[69] Schedule 1 sets out the scope of cleaning duties.

[70] JC01 conveyor is referred to on three occasions in Part A of Schedule 1 of the 2012 Agreement. It is not disputed that there is no particular reference to “underneath” of JC01.

[71] The MUA assert that, in the absence of any mention of “underneath” JC01, I could find, on a proper interpretation of the 2012 Agreement, that stevedores are not required to clean underneath JC01 and that is the end of the matter. The only parts of JC01 that stevedores are required to clean are the feeder shoot from AL05, the transfer house and associated walk ways. If those were the only mention of JC01 in Schedule 1, I would agree. However, there is one further mention of JC01 to which I now turn to.

[72] Stevedores are required to clean the:

“wharf apron from KBB2 security gate (does not include cleaning on the south side of JC01) including bollards and platforms”.

[73] The MUA assert, and it is not in dispute, that stevedores are not required to clean the “south side” of JC01.

[74] As JC01 conveyor is the north/south dividing line, stevedores are required to clean north of JC01 on the wharf apron but not, according to the MUA, underneath the conveyor which is the dividing line.

[75] The MUA assert that, if the Employer considered underneath JC01 was part of the wharf apron north of its southern most point, why is it now explicitly seeking, as part of roster discussions, to have stevedores clean underneath JC01. There is force to this proposition and is considered later.

[76] I am satisfied that the words “wharf apron” have a plain and ordinary meaning. I am also satisfied that the exclusion provision on the “south side of JC01”, is ambiguous and uncertain.

[77] To assist in determining the meaning and application of the words “south side of JC01”, I consider it appropriate to consider the extrinsic written material provided in the course of bargaining for the 2012 Agreement.

[78] The MUA’s log of claims for the 2012 Agreement relevantly provides cleaning of :

“Wharf apron (does not include cleaning on the south side of JC01 or under JC01/JC03)”. 8

[79] The word “or”, in context, is used in its conjunctive sense.

[80] The Employer’s response to the claim is:

“Rejected – Fremantle Ports is seeking to avoid restrictions and is claiming that stevedoring personnel undertake any cleaning tasks and other duties that they are competent to perform as directed from time to time”. 9

[81] The Employer’s response is consistent with its log of claims which reads:

“Increased cleaning scope (extra cleaning, expanding 4th person duties and no shift or time restrictions on cleaning)”. 10

[82] On 10 December 2012, Mr Pearce forwarded to the MUA, following a meeting with two onsite MUA delegates, a draft “cleaning agreement” which reads:

“Wharf apron from KBB2 security gate (but does not include cleaning on the south side of JC01) including bollards and platforms” (my emphasis).

[83] The margin notation in the draft “cleaning agreement” highlights that the words “or under JC01/JC03) Transfer house” are “Deleted”. 11

[84] Mr Pearce met with the two onsite delegates in the days after 10 December 2012. However, the draft cleaning agreement set out by Mr Pearce remained unchanged as it relates to cleaning of the wharf apron. In short, the Employer rejected the MUA’s claim to exclude cleaning underneath JC01 and this was reflected in the draft “cleaning agreement” which eventually became Schedule 1.

[85] In summary, the extrinsic material associated with this issue demonstrates that the MUA’s original position to exclude cleaning underneath JC01 and the Employer’s rejection of such a proposal. The extrinsic material also demonstrates Fremantle Ports’ position on the issue was eventually realised in Schedule 1 of the 2012 Agreement.

[86] Should the MUA have disagreed with the inclusion of cleaning under JC01, the time to address that issue was at the time it received Mr Pearce’s email which sought the MUA’s review and feedback.

[87] The Employer’s rejection of the MUA’s claim to exclude cleaning underneath JC01 is unambiguous. The MUA cannot, in my view, now interpret the 2012 Agreement on this matter, as anything other than the Employer’s position to have cleaning underneath JC01 as part of a stevedores duties.

[88] I now turn to the MUA’s argument that if the Employer is certain that Schedule 1 provides for cleaning underneath JC01, why has it sought to include the issue in discussions regarding the new roster. I do not know the answer to such a question, except to agree with Ms Palmer, that it has probably done so, “to ensure that it was cleaned”. 12

[89] I do not consider it appropriate to speculate on why the Employer has not required stevedores to clean underneath JC01 or draw an adverse inference from the discussions regarding the roster. Ultimately, my role is to interpret the enterprise agreement, and where there is ambiguity or uncertainty, consider objectively, the surrounding evidence to assist in the interpretation of the 2012 Agreement.

[90] Finally, I am not persuaded that JC01 is some sort of “demilitarized zone” and excluded from the wharf apron. It would be unfitting to infer that the negotiators to the 2012 Agreement, adopted such an impractical approach to the wharf layout and that cleaning north of the conveyor is the starting point for the north side of the apron.

[91] As I understand Mr Tracey’s evidence, a subgroup of the bargaining group dealt with negotiations for conditions associated with cleaning. The subgroup of MUA delegates met with Mr Pearce. 13

[92] Mr Pearce gave evidence that cleaning has been an issue almost for as long as he has been employed by the Employer; that is, since 2008. The Employer primarily has to call on other parties (BSOs or contractors) to carry out cleaning duties while stevedores are on duty. 14

[93] Ms Palmer’s cross examination of Mr Pearce pressed home two particular points which the MUA wished to make. Firstly, that the delegates in the cleaning subgroup did not agree to the Employer’s desire to remove the cleaning restrictions in place. In my view, the totality of Mr Pearce’s evidence was that the MUA delegates did not “agree or disagree”. 15 Whether the MUA delegates agreed or disagreed, I am still left with the task of determining the meaning and application of the 2012 Agreement, including Schedule 1, as eventually agreed between the parties.

[94] Secondly, Ms Palmer put to Mr Pearce that, for example, if the Employer wanted to include cleaning underneath JC01, it could have expressly stated that in a term of Schedule 1. 16 Ms Palmer’s contention is true. However, such a proposition is equally true for the MUA that it could have included in the 2012 Agreement, a term which expressly excluded cleaning underneath JC01. Such arguments, while suggestive of how the 2012 Agreement could have been drafted, do not circumvent the necessity of the Commission having to determine the meaning and application of the words eventually agreed upon by the parties.

CONCLUSION

[95] For the reasons set out above, pursuant to subclause 25 (e) of the 2012 Agreement, I determine that the questions posed by the parties in paragraph [17] are answered in the affirmative.

COMMISSIONER

Appearances:

E Palmer on behalf of the MUA.

M Vallence on behalf of Fremantle Ports.

Hearing details:

2015:

Perth,

27 August.

 1   Exhibit R1 para 21

 2   Exhibit R1 para 25

 3   Transcript PN29

 4   Transcript PN497

 5   Exhibit A4 – para 7 and 8

 6   Exhibit A1 para 11

 7   Exhibit A1 – para 14

 8   Exhibit R5 (4)

 9   Exhibit R5 (5)

 10   Exhibit R5 (5)

 11   Exhibit R5 (6)

 12   Transcript PN550

 13   Transcript PN90

 14   Transcript PN320

 15   Transcript PN390

 16   Transcript PN384

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