Mr Martin Karaba v Itero Australia Pty Ltd
[2023] FWC 1754
•15 AUGUST 2023
| [2023] FWC 1754 |
| FAIR WORK COMMISSION |
| DECISION |
Fair Work Act 2009
s.365 - Application to deal with contraventions involving dismissal
Mr Martin Karaba
v
Itero Australia Pty Ltd
(C2022/8342)
| DEPUTY PRESIDENT BINET | PERTH, 15 AUGUST 2023 |
Application to deal with contraventions involving dismissal.
On 15 December 2022, Mr Martin Karaba (Mr Karaba) filed an application (Application) pursuant to section 365 of Fair Work Act 2009 (Cth) (FW Act) with the Fair Work Commission (FWC) alleging that Itero Australia Pty Ltd (Itero) contravened the general protection provisions of the FW Act by dismissing him from his employment because of his race.
On 3 January 2023, Itero filed a Form F8A – Response to General Protections Application alleging Mr Karaba was not dismissed by Itero (Jurisdictional Objection).
In Coles Supply Chain Pty Ltd v Milford [1] (Coles Decision) the Full Court of the Federal Court held that where a respondent submits that the applicant to a section 365 application was not dismissed, as is the case here, the FWC must first determine whether the person was dismissed.
Directions for the filing of materials in advance of the Hearing were issued to the parties on 7 March 2023 (Directions)
Permission to be represented
The Directions invited the parties to make submissions as to whether the FWC should grant permission to the parties to be represented. A determination of this issue is necessary to ensure that the manner in which any hearing is conducted is fair and just.
Itero sought permission to be represented at the Hearing.
Having considered the submissions of the parties, leave was granted to Itero to be represented, pursuant to section 596(2)(a) of the FW Act, on the grounds that it would enable the matter to be dealt with more efficiently taking into account the complexity of the matter.
At the Hearing, Mr Karaba represented himself and Mr Dirk Branford (Mr Branford), a lawyer from Pragma Lawyers represented Itero.
Evidence
In accordance with the Directions, Mr Karaba filed a witness statement setting out his evidence in chief.[2] Mr Karaba gave further evidence in chief at the Hearing and was cross examined by Mr Branford.
In accordance with the Directions, Itero filed a witness statement setting out the evidence in chief of the following witnesses:
a.Mr Patrick McCormack (Mr McCormack)[3] – Mr McCormack is the founder and Director of Itero.
b.Mr Lawrence Tufnell (Mr Tufnell)[4] – Mr Tufnell is the Operations Manager.
c.Ms Jenny McGillemhaoil (Ms McGillemhaoil)[5] – Ms McGillemhaoil is the Operations Coordinator.
The Itero witnesses gave further evidence in chief at the Hearing and were cross examined by Mr Karaba.
The parties jointly prepared and filed a digital court book containing the evidence and submissions of the parties (DCB). The DCB was admitted at the Hearing as an exhibit and marked Exhibit DCB-1.
Mr Karaba filed additional written submissions on 20 March 2023 and on 3 May 2023. Itero filed additional written submissions.
In reaching my decision, I have considered all the submissions made, and the evidence tendered, by the parties even if not expressly referred to in these reasons for decision.
Background
Itero is a rope access provider, specialising in projects that require work to be conducted at heights. Itero’s work includes maintenance, construction and the shutdown of major construction and oil and gas projects and infrastructure.
Due to the level of risk involved in providing rope-access services at height, there are strict safety regulations that must be complied with at all times by Itero and its employees. Employees must work in strict alignment with the International Rope Access Trade Association (IRATA) standards, the International Code of Practice for Rope Access Work (ICOP), health and safety legislation, site safety policies and procedures and Itero policies and procedures. A breach of safety protocols can result in serious injury or fatality to the individual or their colleagues.[6]
Itero’s work is project based.[7] It is therefore common for Itero’s employees to work across a range of projects and sectors for relatively short periods of time. These projects can range from a few months to 2 weeks or less in relation to any one project.[8]
One such project is Fortescue Mining’s Iron Bridge Project in the Pilbara region of Western Australia. Itero has been engaged by Fortescue’s contractor Monadelphous Engineering Associates Pty Limited to perform work at Iron Bridge pursuant to a commercial contract dated 13 October 2022 (Monadelphous Contract).[9]
Clause 10 of the Monadelphous Contract relevantly provides that:[10]
“10.2 The Company’s Representative may direct the Contractor to remove from the Site within such time as the Company’s Representative directs, any person employed or engaged in connection with Work under the Contract who, in the Company’s Representative’s opinion (acting reasonably),misconducts him or herself, is incompetent or negligent, carries out work in an unsafe manner or fails to comply with any direction issued by the Company’s Representative.”
Due to the level of risk involved with working at heights, there are strict safety rules which apply at the Iron Bridge Project. Itero employees are made aware of the safety requirements of Itero and its clients through site specific inductions and review of the Safe Work Method Statements (SWMS) and relevant risk assessments. The relevant SWMS and risk assessments are reviewed and signed by all Itero employees prior to commencement of any work.[11]
Mr Karaba commenced employment on a casual basis as a Rope Access Level 1 Operator (Tier 2) with Itero on 14 September 2022 pursuant to a contract of employment dated 7 September 2022 (Employment Contract).[12]
The Employment Contract relevantly provides that:
a.The principle conditions of Mr Karaba’s employment are set out in the Itero Australia Enterprise Agreement 2021. – Recital D.[13]
b.Mr Karaba is employed on a casual basis and his employment will be terminable on 1 hour’s notice – Recital B,[14] Clause 22.[15]
c.Mr Karaba will be primarily based at the Ironbridge Site – Item 10 and 11 of Schedule One.[16]
d.Itero may direct Mr Karaba to perform his duties from time to time at any location – Clause 3.2[17] With one week’s notice this may include regional or interstate locations – Clause 12(v).[18]
e.Itero may terminate Mr Karaba’s employment if any licence, qualifications, clearances or cards are suspended, cancelled or revoked- clause 25.[19]
Mr McCormack says that the reference to the Itero Australia Enterprise Agreement in the Employment Contract is in fact a reference to the Melchor Access Enterprise Agreement 2021. Melchor is the business name under which Itero previously operated.[20]
In addition, the Employment Contract also contains the following clause:[21]
“5.1 Location
(a) The Employee will be primarily based at the Ironbridge Site, If the employee chooses to work in CBD operations, a letter of offer with relevant rates will be issued under terms of contract below (5.1 (b) (d) *note these terms are only relevant for Perth Metro based works.
(b) Due to the nature of the Employer’s business the Employee may be required to work at various locations throughout Australia or to travel on Employer business both nationally and internationally. The Employee agrees to work at such locations as the Employee is directed to attend from time to time.
(c) The Employee agrees that all costs associated with travel and parking within the Perth Metropolitan Area are the responsibility of the Employee. Should travel occur outside this area, the Employee may be entitled to reimbursement when approved by the Operations Manager.
(d) The Employer reserves the right to transfer the Employee’s employment to another place of work on notice to, and following consultation with, the Employee.”
It is relevant to note that the Contract of Employment provides for two rates of remuneration – one described as an ‘Ironbridge Away Rate’ and one described as ‘Perth Rate’.[22]
Mr McCormack says that Employment contract terms are intended to reflect the commercial reality that the work the business undertakes is project based and therefore requires frequent location changes. [23]
Mr McCormack and Mr Tufnell say that over the course of his employment, Mr Karaba proved to be a competent but difficult employee. According to both men, while Mr Karaba had a good work ethic, there were concerns raised by his supervisors about his attitude and refusal to follow directions on site and work in a safe manner.[24]
On 1 November 2022, Mr Karaba allegedly breached safety rules by working on ropes without a IRATA Level 3 supervisor present. The IRATA International Code of Practice requires an IRATA Level 3 supervisor to be present constantly when ropes work is carried out) (Alleged Breach).[25] Mr Karaba says that his supervisor left the worksite without his knowledge in order to create a ground for dismissing Mr Karaba because of his cultural background.[26]
The Incident was reported to Mr Tufnell by Mr Brock Mackay, Itero Supervisor. Mr Karaba was stood down from height duties while Mr Tufnell made further inquiries in relation to Mr Karaba’s work performance.[27]
Mr Tufnell conducted an investigation into the Alleged Breach (Investigation). Mr Tufnell obtained witness statements from Mr Karaba and the two witnesses present at the time of the Alleged Breach, obtained a copy of the incident report and reviewed the relevant job hazard assessment. Mr Tufnell also sought feedback from Mr Karaba’s supervisors. [28]
On 2 November 2022, Mr Tufnell received emails from both Mr Seth Price, Project Supervisor Monadelphous and from Mr Lloyd Harrop, Itero IRATA Level 3 Safety Supervisor (Mr Harrop) each containing a list of concerns about unsafe behaviour allegedly engaged in by Mr Karaba.[29]
On 3 November 2023, Mr Karaba prepared a witness statement regarding his recollections of the Alleged Breach which he provided to Monadelphous.[30] The same day incident reports were prepared by Mr Harrop and Mr Larry Llubit a Level One Rope Technician who were both witnesses to the Alleged Breach.[31]
On 3 November 2022, Mr Tufnell received an email from Mr Michael O’Sullivan, Health and Safety Advisor at Monadelphous (Mr O’Sullivan), with the subject line “Non-Compliance to rescue/work team requirements.” In this email Mr O’Sullivan informed Itero that he had recently become aware that Mr Karaba had breached site safety rules on 1 November 2022 by working on ropes without a IRATA Level 3 supervisor present and that the incident should have been reported to Monadelphous and to Fortescue.[32]
On 3 November 2022 Mr Tufnell responded to Mr O’Sullivan to explain the investigation he had conducted and reporting that:[33]
“As for the risk assessments, it is strictly stated in the JHA that at no point is any rope access works to be undertaken unless authorised by a Level 3 who is in attendance. I have asked the team to have a conversation regarding this onsite and reiterate the importance of following all IRATA rules and Regulations. As it stands, this incident in my eyes is a breach of the risk assessment and industry best practice, I feel it can bemanaged if Martin is receptive to the advice and counselling, we wish to provide however as of Tomorrow he will be taken offsite and need to attend a meeting in the office to discuss these issues. I have also attached a formal report given by Martin which highlights the incident from his point of view.”
Mr O’Sullivan conducted his own investigation of the Incident and completed an Incident Report on behalf of Monadelphous and Fortescue. The Incident Report found that the Alleged Breach was substantiated and constituted a breach of site safety procedures by Mr Karaba.[34]
On 4 November 2022, Mr O’Sullivan called Mr Tufnell and discussed the removal of Mr Karaba’s site access from the Iron Bridge site pursuant to clause 10.2 of Monadelphous Contract.[35] Mr Tufnell indicated to Mr O’Sullivan that Itero intended to meet with Mr Karaba to discuss the findings of the investigation and moving Mr Karaba to a different site where he could be more closely supervised.[36]
A copy of the Incident Report was forwarded by Mr O’Sullivan to Mr Tufnell on 4 November 2022. Mr O’Sullivan requested that Mr Tufnell provide evidence that the remediation steps had been taken by Itero in relation to the finding that Mr Karaba had breached site safety regulations.[37]
Mr Karaba was removed from the Iron Bridge Site, Mr Tufnell and Mr McCormack then discussed where to place Mr Karaba given his access had been removed from the Iron Bridge Site and decided to move him to another site where he would receive closer supervision, training and mentoring. [38]
On 7 November 2022, Mr Tufnell and Mr McCormack met with Mr Karaba at Itero’s head office in Perth to discuss the findings of the investigation and Mr Karaba’s options moving forward. Mr McCormack and Mr Tufnell say that during this meeting that Mr Karaba was informed that Monadelphous would be unlikely to let him return to their site given the Alleged Breach had been substantiated.
Mr McCormack and Mr Tufnell say that Mr Karaba was offered work on one of Itero’s Perth based sites, the CBH Metro Grain Centre site (CBH Site).[39] The CBH Site has more Itero supervisors on it who could coach and mentor new or inexperienced workers. The CBH Site is also closer to the Itero head office and is regularly visited by the Itero management team who also assist in technical support and coaching. [40]
Both Mr McCormack and Mr Tufnell are adamant that at no stage during this meeting did they mention or threaten to terminate Mr Karaba’s employment. In contrast, they both say that they reassured Mr Karaba that he could work on the CBH Site where he would get supervision and further training. [41]
All three Itero witnesses say that at the conclusion of the meeting, Mr Karaba, Mr Tufnell and Mr McCormack went to Ms McGillemhaoil’s office to organise Mr Karaba’s transfer to the CBH Site. Ms McGillemhaoil is responsible for coordinating staff changes and issuing letters clarifying changes in employment rosters or conditions. [42]
The three Itero witnesses say that while discussing the arrangements for the CBH Site, Mr Karaba said words to the effect of “don’t worry, I have some other work lined up.” Ms McGillemhaoil did not therefore proceed with arrangements to transfer Mr Karaba to the CBH Site. Mr Tufnell and Ms McGillemhaoil both say that they told Mr Karaba to contact them as soon as he was available to work for Itero again.[43]
For example, Mr Tufnell’s recollections of the meeting are as follows:[44]
During this meeting, Mr McCormack and I informed the Applicant that Monadelphous had requested that Itero not return him to the Iron Bridge Site. We discussed the possibility of the Applicant working on other Itero sites. During the course of the discussion, we discussed the CBH Site and how the Applicant would receive good supervision and mentoring on that site. At no stage during this meeting was termination of employment mentioned. In fact, Mr McCormack and I reassured the Applicant that Itero still had work for him despite the Incident and Monadelphous’ decision regarding his presence on the Iron Bridge Site. Following this meeting, Mr McCormack, the Applicant and I went to Jenny McGillemhaoil’s office to make arrangements to move the Applicant to the CBH site. Ms McGillemhaoil is Itero’s Operations Co-Ordinator. While discussing these arrangements, the Applicant said words to the effect of “nah I have some other stuff lined up.” I understood this to mean that the Applicant had accepted work with another company and did not want to work with Itero on the CBH Site.
It is not uncommon for casual employees to move between working for various companies. It is widely how the Rope Access industry operates. I believe that the Applicant began looking for, and was successful in obtaining, alternative employment once he was informed about the Investigation. I mentioned to the Applicant that he should call me if he wanted work with Itero in the future. I then walked the applicant out and shook his hand and requested again that he should call me when he is available for work with Itero. To this the Applicant responded to the effect that he had “other shutdown work available” and that his preference was to work FIFO.”
Ms Gillemhaoil’s recollections of the events of 7 November 2022 are as follows:[45]
“I sent a meeting invite to the Applicant and Mr. Tufnell on 2 November 2022, to organise a meeting in the ltero Office on 7 November 2022 at 10.30am. Both Mr McCormack and Mr Tufnell attended the meeting with the Applicant on 7 November 2022.
15. While I did not attend this meeting, I was made aware of what was discussed by Mr McCormack when he came out of the meeting room.
16. Following this meeting, Mr McCormack, Mr Tufnell and the Applicant came to my office to discuss the Applicant's next shifts, which were to be at a different site in Perth.
17. During this exchange, Mr McCormack and Mr Tufnell told me that Monadelphous had requested that the Applicant not return to the Iron Bridge Site.
18. Consequently, they requested that I organise an induction and shifts for the Applicant at the CBH Metro Grain Centre in Forrestfield, Perth.
19. However, the Applicant didn't seem to be keen in taking up the offer and he said he had some other commitments.
20. I understood this to mean he had obtained alternative work and would not be keen to go to CBH Metro Grain Centre in Forrestfield, Perth. So, I told him to let me know when he's ready to work again.
21. In my experience, it is common in the Ropes Access industry for casual employees to frequently move to different companies based on what Ropes Access work is available on different sites.
22. It was my understanding that the Applicant wasn't interested to return to work with ltero since there was no contact made after 7 November 2022 that I was aware of.”
Mr Karaba insists that the only matter discussed at the 7 November 2022 meeting was the investigation into the Alleged Breach. He says that he was told he would be suspended until the investigation by Monadelphous was complete. He denies having any discussions with any of the Itero witnesses regarding transferring to the CBH site.[46]
On 8 November 2022, Mr Tufnell sent an email to Mr O’Sullivan in which he reported the outcome of the 7 November 2022 meeting with Mr Karaba as follows:[47]
“As it stands we have brought Martin into the office for a meeting, it was established with him that the safety approach by himself was not acceptable and as a result has been taken off the project, we are going to offer him a position on one of our industrial sites where he will be mentored by one of our primary supervisors to train him up to a standard of safety performance that is expected by ITERO and all our clients. He has been removed from the project but not terminated from ITERO. I am not sure if he is going to accept the offer however we have had a very constructive meeting with him and explained the approach a level 1 IRATA technician should take when working in a high-risk environment. As for onsite the team have had an amendment added to the SWMS which has been discussed in a toolbox, this is based on your constructive feedback regarding the additional items.”
Mr Tufnell did not hear from Mr Karaba between 8 November 2022 and 19 November 2022 and presumed that Mr Karaba had taken up the other work that he had mentioned at the 7 November 2022 meeting. On 19 November 2022, Mr Karaba sent an email to Mr Tufnell requesting further details about the Fortescue investigation.
On 24 November 2022, Mr Tufnell sent an email to Mr Karaba attaching correspondence from the Investigation and confirming that Itero had not terminated his employment.[48]
“Hi Martin,
See attached and below all correspondence regarding this matter. As stated during the meeting it is not Itero terminating employment as we are happy to put you on other projects, it is Monadelphous and FMG that can’t have you back onsite.”
Mr Karaba asserts that his supervisor orchestrated his dismissal because of his cultural background.
Consideration
The Application was made pursuant to section 365 of the FW Act. Section 365 of the FW Act provides that:
“365 Application for the FWC to deal with a dismissal dispute
If:
(a) a person has been dismissed; and
(b) the person, or an industrial association that is entitled to represent the industrial interests of the person, alleges that the person was dismissed in contravention of this Part;
the person, or the industrial association, may apply to the FWC for the FWC to deal with the dispute.”
The term ‘dismissed’ is defined in section 12 of the FW Act by reference to section 386. The term ‘dismissed’ is defined at section 386 of the FW Act as follows:
“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.
(2) However, a person has not been dismissed if:
(a)the person was employed under a contract of employment for a specified period of time, for a specified task, or for the duration of a specified season, and the employment has terminated at the end of the period, on completion of the task, or at the end of the season; or
(b)the person was an employee:
(i)to whom a training arrangement applied; and
(ii)whose employment was for a specified period of time or was, for any reason, limited to the duration of the training arrangement; and the employment has terminated at the end of the training arrangement; or
(c)the person was demoted in employment but:
(i)the demotion does not involve a significant reduction in his or her remuneration or duties; and
(ii)he or she remains employed with the employer that effected the demotion.
(3) Subsection (2) does not apply to a person employed under a contract of a kind referred to in paragraph (2)(a) if a substantial purpose of the employment of the person under a contract of that kind is, or was at the time of the person’s employment, to avoid the employer’s obligations under this Part.”
While section 386 is found in Part 3-2 - Unfair Dismissal of the FW Act the definition of ‘dismissed’ contained in section 386 of the FW Act has been applied by the Courts to section 365 general protections matters and I have adopted that approach in this Application.
Mr Karaba asserts that his supervisor orchestrated his dismissal because of Mr Karaba’s cultural background.
Itero say that:
a.it was directed to remove Mr Karaba from the Iron Bridge Site;
b.Itero did not dismiss Mr Karaba to the contrary it confirmed orally and writing that Mr Karaba’s employment was not being terminated;
c.Mr McCormack and Mr Tufnell offered Mr Karaba employment at another site;
d.Consistent with his status as a casual employee Mr Karaba elected to decline work at the other site;
e.Mr Karaba remains on their books’.
Mr Karaba insists that the only matter discussed at the 7 November 2022 meeting was the investigation into the Alleged Breach. He says that he was told he would be suspended until the investigation by Monadelphous was complete. He denies having any discussions with any of the Itero witnesses regarding transferring to the CBH site or any other work location. He cites the lack of a written offer as evidence that no such offer was made.[49]
I accept that evidence of the Itero witnesses that Mr Karaba was offered employment at the CBH Site on 7 November 2022 and that it reinforced that he was not being dismissed for the following reasons:
a.The written testimony of the Itero witnesses corresponded with their oral testimony at Hearing without appearing rehearsed or artificial.
b.The evidence of each of the Itero witnesses was consistent with the evidence of each of the other Itero witnesses with sufficient differences to suggest that no collusion occurred.
c.The demeanour of the Itero witnesses in the witness box was consistent with them giving truthful evidence.
d.The evidence is that the Monadelphous Investigation had been completed before 7 November 2022. This is consistent with the evidence of Mr McCormack and Mr Tufnell that they told Mr Karaba the outcome of the investigation at the meeting and consequently the requirement for him to be relocated to another site. It is inconsistent with Mr Karaba’s version of events that the Investigation had not been completed by this time and that he was told he would be informed of the outcome at some later point in time.
e.It is consistent with the contemporaneous email of 3 November from Mr Tufnell to Mr O’Sullivan where he indicated that he believed that incident could be dealt with by advice and counselling rather than disciplinary action.
f.It is consistent with the contemporaneous email of 8 November 2022 in which Mr Tufnell reported to Mr O’Sullivan that Itero had met with Mr Karaba and offered him work on a different site where he could be appropriately mentored.
g.It is consistent with the contemporaneous email of 24 November 2022 in which Mr Tufnell confirmed that Mr Karaba had not been dismissed and had been offered work at different location.
h.It is consistent with the provisions of the Employment Contract which provide for the transfer of employees from site to site.
It is consistent with industry practise for Rope Access Technicians to be employed for short term engagements.
Mr Karaba asserts that because he was not offered a written contract for work at the CBH site this is evidence that such an offer was not in fact made. The lack of a written contract for the CBH work is unsurprising given that Mr Karaba indicated that he did not wish to take up the offer of the work and I am not satisfied that it suggests that such an offer was not made.
Notwithstanding his arguments to the contrary, I am satisfied that the work at the CBH Site could have been performed under the terms of the Employment Contract without the need for a new contract. While imperfectly drafted arguable the Employment Contract provide Itero with the contractual capacity to direct Mr Karaba to perform work at another location including CBH. In any event an offer of employment was made in writing by Itero on the 24 November 2022 by way of the email sent by Mr Tufnell to Mr Karaba.
Mr Karaba’s assertion that his supervisor fabricated events to cause his dismissal because of Mr Karaba’s cultural background is not supported by any evidence. In the 3 November 2022 from Mr Tufnell to Mr O’Sullivan Itero proposed that the incident could be dealt with adequately with counselling without requiring Mr Karaba’s exclusion from the Iron bridge Site or disciplinary action. Further more in the same email Mr Tufnell forwarded Mr Karaba’s report of the incident.
Mr O’Sullivan conducted his own investigation into the Allegations and reached the conclusion that Mr Karaba had committed a safety breach. Had Itero wished to dismiss Mr Karaba it could have relied on Mr O’Sullivan’s findings or its own investigation into the safety breach. Alternatively, Itero could have relied on the concerns reported by Mr Karaba’s supervisors about his attitude at work. Both the Employment Contract and the Agreement both contemplate Itero providing only an hour’s notice to lawfully terminate Mr Karaba’s employment. Instead the evidence reveals that Itero took multiple steps to continue Mr Karaba’s employment including by reconfirming in the 24 November 2022 email that his employment had not been terminated.
Mr Karaba also asserts that he resigned from his employment with Itero and was forced to do so because of the conduct of Itero. On the evidence before me it appears that Mr Karaba is endeavouring retrospectively to recharacterize what occurred in order to create a legal basis for his claim. It would appear what occurred on 7 November 2022 is more accurately characterised as Mr Karaba choosing of his own volition not to accept an offer of a future casual engagement (as was his right as a casual employee) because he had other (presumably more lucrative) employment opportunities available to him. There is no contemporaneous evidence that he declined the offer of work at CBH because he viewed it as constituting a dismissal from his employment.
I therefore uphold the Jurisdictional Objection and dismiss the Application.
An Order[50] to this effect will issue with this decision.
DEPUTY PRESIDENT
Appearances:
Mr Karaba, for the Applicant.
Mr Branford, for the Respondent.
Hearing details:
2023
PERTH
20 JULY
[1] [2020] FCAFC 152.
[2] Digital Court Book (DCB) 552-554.
[3] Ibid 70-171.
[4] Ibid 172-204.
[5] Ibid 205-207.
[6] Ibid 71, 172.
[7] Ibid 70.
[8] Ibid 70.
[9] Ibid 33.
[10] Ibid 41.
[11] Ibid 172-173.
[12] Ibid 15- 32.
[13] Ibid 18.
[14] Ibid 18.
[15] Ibid.
[16] Ibid 53.
[17] Ibid 19.
[18] Ibid 23.
[19] Ibid 30.
[20] Ibid 70.
[21] Ibid 19-20.
[22] Ibid 21.
[23] Ibid 70-71.
[24] Ibid 173.
[25] Ibid 72, 122.
[26] Ibid 539.
[27] Ibid 177-178, 173, 553.
[28] Ibid 72, 174, 187-188, 184-186.
[29] Ibid 173-174, 177-181.
[30] Ibid 184-186.
[31] Ibid 530-531, 542.
[32] Ibid 72, 122, 182-183.
[33] Ibid 187-188.
[34] Ibid 124-132, 191-199, 187.
[35] Ibid 174.
[36] Ibid 174.
[37] Ibid 187.
[38] Ibid 174, 73.
[39] Ibid 174, 73.
[40] Ibid 174, 73.
[41] Ibid 174, 73.
[42] Ibid 174, 73, 206.
[43] Ibid 175, 206.
[44] Ibid 175.
[45] Ibid 206.
[46] Ibid 543-545.
[47] Ibid 200.
[48] Ibid 175, 203.
[49] Ibid 544-545.
[50] PR765207.
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