National Union of Workers v Serco Global Services Pty Ltd

[2015] FWC 5250

[2015] FWC 5250

FAIR WORK COMMISSION

DECISION

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

National Union of Workers
v
Serco Global Services Pty Ltd
(C2015/3734)

COMMISSIONER ROE MELBOURNE, 4 AUGUST 2015

Resolution of dispute in accordance with the dispute resolution procedure of the Serco Global Services Burnie Employment Agreement 2013. Dispute concerning the requirements to be classified as a Customer Contact Specialist Level 3.

[1] The dispute concerns the requirements to be classified as a Customer Contact Specialist Level 3 under the Serco Global Services Burnie Employment Agreement 2013. Currently employees at the Burnie call centre, which is operated by Serco to provide services for the Australian Taxation Office (ATO), are classified at either Entry Level, Level 1 or Level 2 depending upon their experience, their training and the variety of work which they are capable of undertaking. No employees are currently classified at the highest level under the Agreement, Level 3. The NUW argues that 9 employees who are currently classified at Level 2 should be classified at Level 3. The 9 employees were not identified by name, apart from Mr Phillips. Essentially the NUW argues that employees who are currently classified at Level 2 who are trained and experienced in all relevant areas of the business and who now work in the Debt Early Intervention (DEI) area should be classified at Level 3. The dispute was not able to be resolved through conciliation. The parties agree, and I am satisfied, that the appropriate steps of the dispute settlement procedure have been followed, that the dispute is a dispute arising from the Agreement and that I am now required to resolve the dispute by arbitration.

[2] I have considered evidence presented by a number of employees and managers at both the Burnie and Box Hill sites about the work performed by the employees at the call centre under the ATO contract. The Box Hill site is covered by a different agreement. I accept that Serco is conducting work at the two sites under the same contract and they utilise the same technology, operational policy manuals and training format for the work at both sites. However, I am satisfied that the actual qualifications and experience of team members allocated to particular work varies between the sites. The actual level of supervision and the qualifications and experience of supervisors may also vary between the sites. As a result I am particularly interested in the evidence of what actually occurs at the Burnie site in resolving this dispute. Some of the evidence from Box Hill employees and managers has to be treated with caution given the differences between the two sites.

The classification requirements

[3] In approaching a dispute about classification the central focus is the actual words of the classification descriptors. The classification requirements are to be judged against what the employees are actually required to do and where appropriate their qualifications, competencies and experience. Often the way in which work is actually performed will differ from job descriptions, policies and procedures and management’s perception. Of course where employees act in a way which is contrary to specific direction or in a manner which is clearly not condoned, the tasks performed, or the skills exercised, will not be relevant to classification. Otherwise it is the actual tasks and skills held and used, or which may be required to be used, which are relevant to the determination of classification level.

[4] In some classification structures the definitions are such that employees will satisfy some factors from lower classification levels and some factors from higher classification levels and a best fit or substantial character approach is appropriate. In some agreements there are specific provisions about mixed functions or specific allowances which mean that a requirement to occasionally perform a task or a skill which might fall within a higher level classification level does not justify reclassification to that level. However, particularly where the Agreement encourages flexibility, productivity, career opportunities and/or team work the occasional requirement to utilise higher level skills or tasks is relevant to the determination of the appropriate classification level.

[5] The Agreement in this case provides under the Contract of Employment Clause that:

“On the job training will be limited only by operational requirements and an employee's ability and competency to perform the required duties. Therefore an employee is to be available to work as required on any work within his/her skill, competence and training and that each employee shall learn and acquire the skills and learn any skills as directed and shall provide instruction and/or training as appropriate to another employee as required.”

[6] I am satisfied that employees are required to multi-skill, develop new skills, and assist the development of other employees. There is no mixed functions clause in the Agreement and no skill based allowances.

[7] I am satisfied that skills or tasks which are required to be performed or utilised occasionally are relevant to the determination of the appropriate classification level.

[8] The classification requirements of the Agreement are as follows:

“14. JOB CLASSIFICATIONS

(a) Customer Contact Officer - Entry Level

An employee at this level is engaged in a course of training and development (other than a new apprenticeship) during the initial employment period to perform customer contact functions. An employee at this level would normally perform customer contact functions under close direct/immediate supervision. An employee would normally progress to the appropriate classification for their position after successful completion of their initial course of training and their 6 month qualifying period.


(b) Customer Contact Officer - Level 1

An employee at this level is engaged in high volume, inbound and/or outbound call and or information handling activities requiring basic customer interaction skills including associated straightforward processing working within clearly defined limits of authority and established company and client procedures which involves basic retrieval, reporting and data entry. Initial training is typically of relatively short duration between 1 to 10 days involving contact or transaction technologies, one or two core systems or a variety of systems and policy and procedures. An employee who holds a Certificate II in Telecommunications or equivalent could be classified at this level when employed to perform the functions of the role.

(c) Customer Contact Officer - Level 2

An employee at this level is engaged in high volume, inbound or outbound interactions which may include some outbound business to customer sales calls requiring a higher degree of customer interaction than Level 1 in order to resolve more complex issues. This level of employee works with more autonomy than Level 1 in order to resolve customer interactions. Initial training is typically between 10 to 20 days involving multiple systems. An employee who holds a Certificate III in Telecommunications or equivalent could be classified at this level when employed to perform the functions of the role.

(d) Customer Contact Specialist - Level 3

An employee at this level is engaged to perform a broad range of skilled applications in the provision of customer service and/or selling products or services and provide leadership and guidance to others in the application and planning of the skills. May include inbound and/or outbound, cold calling or processing complex information. Handles more complex products and services than level 2. Works under limited supervision with a high degree of autonomy. Typically longer duration contacts and more complex transactions. Initial training is typically over 20 days, handles contact or transaction technologies, multiple complex core systems within context of company client policies and procedures. An employee who holds a Certificate III in Telecommunications or equivalent could be classified at this level when employed to perform the functions of the role.”

[9] The team leaders are not covered by the Agreement. I am satisfied that the classifications are designed to cover the scope of work of customer contract officers below the level of team leader. The classification structure is hierarchical. The level descriptors are to be read as a whole in the context of the lower level descriptors.

[10] I am satisfied that the qualification requirements at each level are not mandatory. The reference to formal qualifications uses the words “could be classified at this level”. The reference to internal training uses the term “typically” a certain number of days. The number of days of internal training is indicative not determinative. At levels 1, 2 and 3 the expression “initial training is typically” is used. I am satisfied that considered in context the word “initial” is a reference to the fact that after having been classified at a particular level further training may be required or may be undertaken. I am satisfied that the number of days training specified at a level is the total amount of training and should not be read as additional training from the training requirement for the level immediately below. The total amount increases as follows:

● Entry Level – 6 month qualifying period and engaged in initial training.
● Level 1 – 1 to 10 days training.
● Level 2 – 10 to 20 days training.
● Level 3 – over 20 days training.

[11] I am satisfied that to be classified at Level 3 the following are the mandatory elements:

● Perform a broad range of skilled applications in the provision of customer service and/or selling products or services.
● Provide leadership and guidance to others in the application and planning of the skills.
● Handle more complex products and services than Level 2.
● Work under limited supervision.
● Work with a high degree of autonomy.

[12] The other elements of the descriptor are more indicative or typical and are aids to assessing whether or not the work required to be performed meets these requirements. So for example; in assessing complexity the duration of contacts and the complexity of transactions will be relevant. In assessing the range of applications and the level of the work the nature of the training will be relevant. The complexity of information and whether or not cold calling is involved will also be relevant.

[13] Serco suggested that the use of the word “specialist” in the heading for Level 3 suggests that the jump between Level 2 and Level 3 is large and that the classification is only available to a worker who is required to specialise in particular complex products or services. I am not satisfied that this is correct. The term specialist is also found in the award classifications for the level below team leader. In the Agreement, as in the Award, the worker at this level is employed to perform a broad range of skilled applications. There is no mandatory requirement to focus on longer duration contacts or more complex transactions. In fact the flavour of the classification descriptor is about the capacity to work across a broad range of services and applications not to specialise in any particular type of transaction or service. The word specialist is used more in the sense of experienced or expert worker. There is nothing in the descriptor or the Agreement which suggests that there is a bigger jump in requirements between Level 2 and Level 3 than there is between Level 1 and Level 2.

[14] The words autonomy and complexity have to be read in the context of the work which is covered by the Agreement. Contract call centre work tends to be highly process and policy driven. The work is closely monitored and assessed. Workers must closely follow scripts and procedures. The work under this Agreement is for the ATO. The ATO understandably:

● Carefully restricts the parameters for decisions which can be made by the call centre operators;
● Restricts the advice which can be given by the call centre operators;
● Demands a very high level of consistency in the way in which situations are handled; and
● Requires consistency and comprehensiveness in reporting of decisions and transactions.

[15] A natural consequence of the work organisation in call centres of this type is that escalation is available. Where it is mandatory to refer a matter to a higher level in specified circumstances this does affect the degree of autonomy, complexity and responsibility of the task. However, where escalation is simply available in cases where the worker is unsure or wants a second opinion I am satisfied that the existence of an escalation point does not necessarily undermine the level of autonomy, complexity or responsibility of the task.

[16] The concept of “selling products or services” also needs to be considered in the context of the work which is covered by the Agreement. The contract call centre workers do not sell products in the sense of receiving money. However, they are required to try to get taxpayers, both individual and business, to use particular ATO products and services. This includes “voice detector” and other on line services. I am satisfied that this is the selling of products and services within the context of this Agreement. I accept the evidence of Ms Fisher for Serco that it is not just DEI workers who are required to sell these other products and services. This is expected of those in a number of areas of the business.

[17] The relative level of autonomy and/or complexity required for each level of the classification structure is to be assessed within these constraints.

The range of work and DEI work in particular

[18] The ATO contract requires the customer contact officers to engage in a range of work:

● Individual work: this relates to queries from individual taxpayers about issues such as how to lodge their return and when they might expect advice about refunds. There are a number of specific functions associated with this and specific training modules for each of those functions.
● Business work: this relates to queries from businesses about completion of business activity statements, provisional tax, how to lodge returns and other aspects of completion of returns. There are a number of specific functions associated with this and specific training modules for each of those functions.
● Debt work: this is of two types:

• D01 work which is about the provision of information about debts owed to the taxation office and the processes associated with this including implementation of payment plans. There are specific training modules for this function.



• DEI work which is about payment plans for the repayment of debts owed to the taxation office. There are specific training modules for this function.

[19] Those who are competent in individual work are generally classified at Level 1. Those who are competent in a wide range of the individual and business functions are classified at Level 2. Those classified in individual, business and debt functions are also classified at Level 2.

[20] At the time the Agreement was made in 2013 some workers were engaged in D01 Debt work. The DEI work was introduced in April 2014 at the Burnie site. The claim for Level 3 classification relates to workers who are performing the DEI work and who are also trained and experienced in the individual, business and D01 work.

[21] Serco provided some evidence of what occurred during the negotiation process for the Agreement. I am not satisfied that the subjective views of Serco about that process are relevant to my determination of what are the classification requirements in the Agreement which was eventually reached.

[22] The way that the call centre operates is that if you are competent in individual, business, D01 and DEI work then you are expected to be able to deal with issues which arise in all or any of these areas. Sometimes a query in one area will also involve an issue in another area or require knowledge in another area. For example; a business activity statement issue and a debt issue. If the customer contact officer is trained and experienced in both areas they will deal with both. If they are not then the aspects that they are not trained in will be transferred to a different contact officer who is appropriately trained.

[23] The NUW did not argue that those engaged in individual, business and D01 work met the requirements to be classified at Level 3. The NUW did not argue that the D01 work met the requirement: “Handles more complex products and services than Level 2” and typically this would involve “longer duration contacts and more complex transactions”. Their argument was that the DEI work did meet this description and that the additional requirements for DEI work meant that the skills requirements in total justified classification at Level 3 including the broad range of work, the higher level of training and the provision of assistance and guidance to others.

[24] Where an employee who is trained in a particular area is unable to answer or deal with a matter in that particular area, for example; they are unfamiliar with the situation or the caller is particularly abusive or non-responsive then the employee can seek assistance from a floorwalker or a team leader. If the issue raised is outside the parameters of the customer contact officer’s authority or requires authorisation or referral or where ATO technical assistance is required then the matter can be referred to an ATO coach or an ATO officer remotely. Generally such situations for DEI work are referred to an ATO officer remotely whilst such situations for individual work are referred to an ATO coach present at the facility.

[25] A floorwalker is one of the customer contact officers who is experienced and is selected to spend some of their time circulating and providing assistance to other customer contact officers in dealing with queries within the scope of the matters in which they have been trained. This work does not currently affect the classification of the employee. Having a floorwalker means that someone is available to assist where the team leader is not present or available (on a meal break, in a meeting, attending to other duties or assisting other employees) or where the team leader does not have the training in a particular area (e.g. DEI work). Serco gave evidence that contact officers may volunteer to do floor walking or they may be asked to do it because their computer or other computers are “down’. 1 Serco gave evidence that contact officers are not forced to do floor walk work. Mr Phillips gave evidence that when there is a breakdown there is sometimes no choice. Serco gave evidence that they are now moving to a system where, based upon expressions of interest, employees are selected and then rostered to do floor walking.

[26] I am satisfied that, whether or not the floorwalk work is voluntary, it is required and the skills being used should be considered in determining the appropriate classification level.

[27] When the DEI work was introduced at Burnie in 2014 the more experienced, competent and multi-skilled employees were selected to be trained for the work. This group received three days of specific training to complement their already existing skills in individual, business and D01 work. In 2015 a second group were fast tracked to work on DEI. These workers did not all have training across the existing skills areas. Some were only trained in individual work and not business work. This training was 9 days and it covered some aspects of individual, business and debt work as well as the DEI specific work.

[28] Serco witnesses conceded that those who were in the second fast track group who did not have experience in business and D01 areas were unable to complete the work on a greater range of calls and had to refer more of these calls on to other areas. It was also conceded that these workers also required assistance from floorwalkers, team leaders and ATO contacts more often than the initial group of DEI workers.

[29] The customer contact officers performing DEI work operate within the following parameters:

● They can approve or disapprove debt repayment plans for up to $500,000 provided that the repayment period does not exceed 24 months.
● Approval outside these parameters involves getting sign off by an ATO officer.
● They will access information from the taxpayer about their income and expenses.
● They will assess capacity to pay.
● They will access and review the compliance history of the taxpayer and this may influence the decision to approve or not approve the repayment plan.
● If other issues relating to individual or business tax returns arise they are to be dealt with (if the customer contact officer has the training in that area).

[30] The parties agreed that initially there were a range of differences between the D01 work and the DEI work. Until recently there were occasions where a customer contact officer performing DEI work may alter matters which had been earlier considered by a customer contact officer doing D01 work. The parties agreed that in the last few months the processes for D01 work have been changed to make them closer to those of the DEI work. The scripts used for the D01 work and the DEI work are now the same. I accept that employees use much the same systems and methodology for the D01 and the DEI work.

[31] The DEI work involves both inbound and outbound calls and the use of multiple applications. D01 work involves use of the same applications but does not involve outbound calls. Reporting of the decisions made is required. A macro for the format of the reports is provided but the composition of the content is the responsibility of the contact officer.

Do those engaged in DEI work, who are also trained and experienced to perform work in individual, business and D01 areas, meet the requirements of Level 3?

[32] Mr Phillips, a customer contact officer who works in DEI at Burnie, gave evidence that there were more calls of a long duration and also more agitated and difficult callers in the DEI area than in the other areas. Mr Phillips has experience in all the relevant areas of the business. Mr Lowry for Serco gave evidence that the average call handling time for DEI work in June 2015 was 15.02 minutes compared to 14.95 minutes in D01 and 11.70 minutes in Business. Witnesses for Serco also suggested that individual taxpayers were more likely to get agitated than those in the DEI area.
[33] The evidence on both sides about the frequency of agitated callers is too subjective and generalised to be of much value. The evidence satisfies me that the calls in debt are generally longer than those in the other areas. The average duration is now similar between the two debt areas D01 and DEI, however, there is no data on the distribution of call times and so it is possible that Mr Phillips is correct and that there are a group of more complex longer calls in DEI. It is also possible that the recent changes to the D01 processes may have changed the duration of those calls. I am unable to draw a firm conclusion about call duration other than to find that calls in debt are generally longer than individual or business calls.

[34] I accept the evidence of Mr Phillips that he was expected to provide assistance and guidance to other workers in the DEI team who are less experienced or trained in a narrower range of areas. Ms Grieve gave evidence that she was in this later group and was, for a period of time, seated next to a more experienced and broadly trained employee for this purpose. Mr Phillips says that he is also approached by team leaders and floor walkers for advice.

[35] Ms Fisher for Serco gave evidence that DEI officers are not expected to provide advice to their peers and that support mechanisms are quite adequate through floorwalkers, team leaders, and ATO coaches. I prefer the evidence of Mr Phillips and Ms Grieve that adequately trained team leaders and floor walkers are not always available. This evidence is based upon direct experience of how things operate in practice. I also accept the evidence that a number of team leaders are not trained in DEI work. I accept the evidence of Ms Grieve that on occasion she has had to wait a considerable period of time for suitable assistance.

[36] Ms Jordan gave uncontested evidence that when she worked in DEI from May 2014 until February 2015 she was not required to provide leadership or guidance to her peers.

[37] In summary I am satisfied that:

● Mr Phillips provided assistance and guidance to other less experienced workers in the DEI team and he is also approached by team leaders and floor walkers for advice.
● Team leaders and floorwalkers who are trained in all relevant areas were not always available to the DEI team.
● Ms Grieve received assistance and guidance from co-workers with broader training and experience in the DEI team for a period of time.
● Ms Jordan was not required to provide leadership or guidance when she was working in the DEI team.

[38] I cannot assume that those who came through the fast track process will continue to require additional guidance and assistance from more experienced workers. Serco accepted that they will transfer more calls and require more assistance but it may be that this will come through the established processes of floorwalkers, team leaders and ATO coaches or officers in the future. Ms Grieve gave evidence that the practice of her being placed next to more experienced co-workers had not continued.

[39] I cannot assume that all DEI team members with the relevant broad training base provided leadership or guidance. The extent to which the provision of assistance and guidance extended beyond Mr Phillips is unclear.

[40] Mr Phillips gave evidence that his total training exceeded 20 days. Serco gave evidence that the additional training for DEI work for those who were already trained in other functions was three days. I consider it likely that an employee who has progressed through most individual and business functions and D01 function and then DEI function over a number of years will have completed a total of about 20 days training.

[41] Mr Phillips gave evidence that the type of analysis involved in reviewing a taxpayer’s history including their business activity, their debt compliance and their assets and income is more complex than the previous work he has done for Serco. Although there are steps to be followed and materials and escalation points available to assist, Mr Phillips is required to use his initiative in asking questions about financial history. Mr Phillips also says that the reports required from DEI decisions are more complex than those in other areas. Ms Grieve also gave evidence that the work in DEI is more complex than in other areas. Mr Brazier also said that the work is more complex. Ms Grieve gave evidence that there are fewer team leaders available with the necessary DEI expertise available to the DEI workers. The team leaders are generally able to assist those in the other areas. This means that DEI workers have to be more autonomous and that the experienced and broadly trained DEI workers provide assistance to others. Mr Phillips and Ms Grieve gave evidence that the ATO coaches provide support in whether or not to approve a payment plan but not in respect to other issues which arise in DEI.

[42] In areas other than DEI an issue can be escalated to non-phone related help (for example an ATO coach) whilst in DEI this is not available. The DEI consultant can get phone assistance from an ATO officer remotely. Serco witnesses gave evidence that this assistance was readily available when required.

[43] It is accepted that not all customer queries will be found in the available scripts and in many cases the employees are expected to use natural language and use the scripts as a guide and not the exact words.

[44] The witnesses for Serco gave evidence that the focus of DEI work is narrower than D01 work. The work in DEI is focused on the development and approval or otherwise of a debt payment plan. However, I am not satisfied that this narrowness significantly reduces the complexity of the work or the level of autonomy or initiative required in carrying out the work. This is particularly the case as DEI work involves outbound calls unlike D01 work. I am also satisfied that the DEI work should not be considered in isolation. If the DEI worker is trained in other areas including D01 then if a payment plan is not possible they may advise customers of the next steps which is work normally done in D01. They may also provide assistance in respect to other matters which are dealt with in individual or business. I am satisfied that for those who are appropriately trained the complexity of the DEI work includes the whole range of other work in the centre.

[45] I accept the evidence of the witnesses for Serco that recent changes to the D01 processes mean that the D01 work and the DEI work have become more aligned. Mr Lowry provided an analysis which showed that 85% of the tasks were common. The additional DEI tasks are now as follows: granting of additional time for provision of financial information or to lodge an outstanding document, advise pre-legal warnings and issuing of FAWL. 2 The training for DEI and D01 covers similar topics. Previously there were a number of areas of difference including financial information and capacity to pay which were not in the D01 package. However, the differences have now narrowed. The remaining differences are that DEI training covers superannuation guarantee charge overview and excess contributions tax overview and enterprise dialler introduction which are not included in D01 training.

[46] I am satisfied that since the changes to the procedures in D01, the work in DEI is no longer significantly more complex than the D01 work. I am not satisfied that the work in DEI is significantly more complex or requiring significantly more judgement or autonomy than the work in D01. This may have been the case during 2014 but the changes to D01 processes and materials mean that it is no longer the case.

[47] To justify a Level 3 classification I would need to be satisfied that those involved meet the requirement “Handles more complex products and services than Level 2” and typically this would involve “longer duration contacts and more complex transactions”. There is some evidence that work in the debt area generally, when DEI and D01 work is considered as a whole, is more complex than business and individual work. It appears that the call durations are longer, the information required to be processed is more complex and involves a greater number of variables, the level of judgement required is greater, and the reporting process requires more care and judgment. However, this is not the case which was run by the NUW. The evidence was not sufficient to enable me to reach a firm conclusion that those involved in the DEI work who are also experienced and trained in D01 and business and individual work are handling more complex products and services which typically involve longer duration contacts and more complex transactions. There was insufficient evidence about the level of complexity of the individual and business work at Level 2. The case focused on the differences between DEI and D01 work not on the difference between the debt work taken as a whole and other work.

[48] Taking the evidence as a whole it appears to me that the current practice whereby employees are reclassified to Level 2 when they are experienced and competent to work across the range of individual and business functions is consistent with the classification structure. An employee who is experienced, trained and competent in most individual, most business, D01 and DEI functions is:

● Engaged to perform a broad range of skilled applications in the provision of customer service and/or selling products or services.
● Engaged in both inbound and outbound calling and is processing complex information.
● Within a call centre context the employees work under limited supervision.
● There is additional training for those engaged in D01 and DEI functions on top of the training for individual and business functions. The total amount of training for a person who had progressively moved from individual functions to business functions and then to D01 function and then to DEI function over a number of years would be around 20 days.

[49] The elements are met because of the cumulative skills and training associated with the combination of individual, business, D01 and DEI functions.

[50] The three remaining mandatory elements of the Level 3 definition are:

● “Provide leadership and guidance to others in the application and planning of skills”.
● Works with a “high degree of autonomy”.
● “Handles more complex products and services than Level 2”.

[51] I am satisfied that those workers who are sufficiently expert to provide leadership and guidance to others will also be working with a sufficiently high degree of autonomy to meet the classification requirement. As discussed earlier the concept of autonomy means something different within a contract call centre environment where processes and procedures and escalation processes are more formal and rigid than in many other workplace environments. There is no doubt that Mr Phillips works with a higher degree of autonomy than his less trained and experienced colleagues. He will require assistance significantly less often and will transfer significantly fewer calls. Where the employee also is trusted to provide leadership and guidance to others that will be sufficient evidence of the necessary degree of autonomy.

[52] I accept that Mr Phillips meets the Level 3 requirement of providing leadership and guidance to others and also working with a high degree of autonomy. As discussed earlier the extent to which this applies to others is not clear. However, I am satisfied that those who are performing floorwalker duties from time to time are providing the necessary leadership and guidance to others. Serco are moving to a system whereby floorwalkers are selected following an expression of interest process.

[53] Therefore, if it was established that the debt work taken as a whole is more complex than the business and individual work, then those who had the full range of competencies across individual, business and debt work and who were also selected to work as floorwalkers from time to time may meet the requirements for Level 3. I have earlier explained why the evidence before me did not establish that the D01 and DEI functions taken together are more complex products and services than required of a Level 2 employee who is performing individual and business functions.

[54] The resolution of the dispute is my determination that the case has not been made for the reclassification of the employees concerned to Level 3.

COMMISSIONER

Appearances:

Ms A Grogan appeared for the Applicant.

Mr A Denton appeared for the Respondent.

Hearing details:

2015

Burnie

July 22

 1   Serco 2, at para 17.

 2   Statement of Hayden Lowry at para 20.

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