Sabapathy v Viveganantham (No 2)

[2024] FedCFamC2G 1032

FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA

(DIVISION 2)

Sabapathy v Viveganantham (No 2) [2024] FedCFamC2G 1032

File number(s):

MLG 1637 of 2022

Judgment of:

JUDGE MANSINI

Date of judgment:

15 October 2024

Catchwords:

INDUSTRIAL LAW – FAIR WORK – application by a refugee immigrant for relief in relation to various established contraventions of the minimum entitlements, regular payment and record-keeping obligations under the Fair Work Act 2009 (Cth) – compensation, interest and pecuniary penalties ordered.

Legislation:

Fair Work Act 2009 (Cth) ss. 12, 13, 14, 45, 323, 535, 545, 546, 547, 550

Fair Work Regulations 2009 (Cth) reg. 3.32, 3.33, 3.34

Cases cited:

Australian Building and Construction Commissioner v Pattinson (2022) 274 CLR 450

Australian Building and Construction Commissioner v Pattinson [2019] FCA 1654

Australian Competition and Consumer Commission v Reckitt Benckiser (Australia) Pty Ltd (2016) 340 ALR 25

Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith [2008] FCAFC 8

Commonwealth v Director, Fair Work Building Industry Inspectorate (2015) 258 CLR 482

Construction, Forestry, Maritime, Mining and Energy Union v Australian Building and Construction Commissioner (The Non-Indemnification Personal Payment Case) (2018) 264 FCR 155

Fair Work Ombudsman v Carers Portland Inc [2023] FedCFamC2G 620

Flight Centre Ltd v Australian Competition and Consumer Commission (No 2) (2018) 260 FCR 68

Markarian v The Queen (2005) 228 CLR 357

Trade Practices Commission v CSR Ltd [1990] FCA 521

Wong v The Queen (2001) 207 CLR 584

Division:

Division 2 General Federal Law

Number of paragraphs:

47

Date of hearing:

30 September 2024

Place:

Melbourne

Counsel for the Applicant:

Mr Merriman

Solicitor for the Applicant:

Holding Redlich

The Respondent:

Appearing in person

ORDERS

MLG 1637 of 2022

FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)

BETWEEN:

PRABAKARAN SABAPATHY

Applicant

AND:

SAJEEVAN VIVEGANANTHAM

Respondent

ORDER MADE BY:	JUDGE MANSINI
DATE OF ORDER:	15 OCTOBER 2024

THE COURT ORDERS THAT:

1.Within 120 days of these orders, the Respondent pay to the Applicant:

(a)$83,263.81 to the Applicant in compensation for loss suffered because of the Respondent’s contraventions of the Fair Work Act 2009 (Cth) (Act);

(b)$31,638.10 to the Applicant by way of interest on the amount that was required to be paid to the Applicant pursuant to the Act; and

(c)$50,400.00 being the total pecuniary penalties payable for the Respondent’s contraventions of the Act.

2.There be no order as to costs.

3.To the extent not resolved by the Court’s reasons in Sabapathy v Viveganantham [2024] FedCFam2G 666 and Sabapathy v Viveganantham (No 2) [2024] FedCFam2G 1032, the amended application filed 22 May 2023 is otherwise dismissed.

Note: The form of the order is subject to the entry in the Court’s records.

Note: The Court may vary or set aside a judgment or order to remedy minor typographical or grammatical errors (r 17.05(2)(g) Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 17.05 Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth).

REASONS FOR JUDGMENT

JUDGE MANSINI

IN SUMMARY

1. For the reasons delivered on 25 July 2024 this Court has determined that, in the course of operating his rubbish removal company, the Respondent employed a refugee immigrant and was involved in multiple contraventions of the minimum entitlement, regular payment and record-keeping obligations in the Fair Work Act 2009 (Cth) (Act).

2. Specifically it was determined that SK Removals Pty Ltd contravened ss.45, 323 and 535 of the Act and the Respondent was involved in those contraventions within the meaning of s.550(2).

3. These reasons address the remaining questions as to the appropriate relief (if any) to be ordered for the Respondent’s contraventions.

   APPLICATION FOR RELIEF

   Orders sought

4. The orders for relief sought by the Applicant were expressed in the following terms:

   1.Pursuant to s 545(1) of the Fair Work Act 2009 (Cth), the Respondent shall pay to the Applicant compensation in the amount of $104,079.76 within 28 days of the date of this order.

   2.Pursuant to s 547(2) of the Fair Work Act 2009 (Cth), the Respondent shall pay to the Applicant interest in the amount of $39,191.45 within 28 days of the date of this order.

   3.Pursuant to s 546(1) and 546(3)(c) of the Fair Work Act 2009 (Cth), the Respondent shall pay to the Applicant a pecuniary penalty in the amount of $100,800 in respect of its contraventions of ss 45, 323 and 535 of the Fair Work Act 2009 (Cth) within 28 days of the date of this order.

   4.There be no order as to costs.

   Procedural context

5. The lengthy procedural context to the application is traversed in the reasons of 25 July 2024.

6. Upon arriving at the findings as to contraventions, the Court considered that the Respondent be afforded further opportunity to consider, prepare and file written evidence and submissions as to the questions of what, if any, compensation and pecuniary penalty(ies) ought be imposed for the contraventions pursuant to ss.545 and 546 of the Act. The procedural orders made on that day provided that:

   THE COURT ORDERS THAT:

   1. The proceeding is listed for further hearing at 10.00am on 30 September 2024 in respect of the Applicant’s claims for compensation and pecuniary penalties pursuant to ss.545 and 546 of the Act.

   2. By 4.00pm on 19 August 2024, the Applicant is to file and serve an outline of submissions (including to clearly specify the form of orders sought) and any supporting affidavit(s).

   3. By 4.00pm on 11 September 2024, the Respondent is to file and serve an outline of submissions and any affidavit(s) in response.

   4. By 4.00pm on 25 September 2024, the Applicant file and serve any submissions and affidavits in reply.

   5. Any request that the Applicant’s claims for compensation and pecuniary penalties pursuant to ss.545 and 546 of the Act be determined on the papers (meaning, on whatever materials are before the Court and without need for a hearing) may be made, by consent of the other side, no later than 4.00pm on 25 September 2024.

   6. Liberty to apply.

   AND THE COURT NOTES THAT:

   A. In the event of any non-compliance with the Court’s orders or failure to attend the hearing, the Court may dismiss the application for relief on default or determine the application for relief on what is before the Court pursuant to rr.13.05 and/or 13.06 of the Federal Circuit and Family Court of Australia (Division 2) (General FederalLaw) Rules 2021 (Cth).

7. On 20 August 2024, the Applicant filed an outline of submissions and a supporting affidavit of Ms Fiorella Chiavetta Cruz deposed 19 August 2024, in respect of his claims for compensation and pecuniary penalties pursuant to ss.545 and 546 of the Act.

8. The Respondent did not file an outline of submissions and affidavits in reply by 4.00 pm on 11 September 2024 or at all. The Respondent did not request an adjournment or more time to comply with the program prior to the hearing on 30 September 2024.

9. At 10.00 am on 30 September 2024, the matter proceeded to hearing in relation to the questions of what (if any) compensation and pecuniary penalties were appropriate to order. Mr Merriman of Counsel appeared on behalf of the Applicant and the Respondent appeared in person. The Respondent was invited to make oral submissions to the Court at the hearing and referred to screenshots of bank transactions emailed to chambers on 3 April 2024 which are taken into account (with appropriate weight) in preparing these reasons. 

   Factual context

   Findings of fact

10. By the reasons of 25 July 2024, the Court accepted certain uncontentious facts and made findings of fact on the evidence. Relevant to the relief sought:

    (a)SK Removals Pty Ltd was, at all relevant times, a “constitutional corporation” and a “national system employer” as defined in ss.12 and 14 of the Act.

    (b)The Respondent was the sole director and officer of SK Removals Pty Ltd, with authority and responsibility for employment matters including the company’s compliance with workplace laws.

    (c)The Applicant was, at all relevant times, a “national system employee”: s.13 of the Act.

    (d)The Applicant was employed to work as a casual labourer for SK Removals Pty Ltd from on or around 7 January 2018 until he became injured and stopped work on or around 11 July 2018 (the Employment).

    (e)Throughout the Employment, the Waste Management Award 2010 (Award) applied to the Applicant’s employment, the relevant classification was that of Level 2 Labourer and therefore he was entitled to a casual hourly rate of $27.75 inclusive of a 25% casual loading (cl.14.4) and industry allowance (cl.20.6) (which increased to a casual hourly rate of $28.71 on 1 July 2018) plus applicable overtime, weekend and public holiday penalties. Specifically, during the Employment until 1 July 2018, the Applicant was entitled to the following overtime and penalty rates under cl.30, 31 and 32 of the Award:

    (i)$35.52 per hour for the first two hours of overtime worked Monday to Friday;

    (ii)$46.62 per hour after the first two hours of overtime worked Monday to Friday;

    (iii)$35.52 per hour for the first two hours of overtime worked on Saturday;

    (iv)$46.62 per hour after the first two hours of overtime worked on Saturday;

    (v)$46.62 per hour for overtime worked on Sunday; and

    (vi)$61.05 per hour for work on a public holiday.

    (f)SK Removals Pty Ltd failed to keep any records of employment as prescribed by the Fair Work Regulations 2009 (Cth) (Regulations).

    (g)The Applicant’s records from his personal notebook were as follows:

    (i)For the period 7 January to 28 February 2018, the Applicant recorded the start and finish times for his hours worked which entries he had completed on each occasion when he started and finished work. The hand written record reflected that during this period there was weekend work, early morning starts (sometimes as early as 4.00am, sometimes at 9.00am) and evening finishes (sometimes at 3.00pm, sometimes as late as 11.00pm); and

    (ii)For the period 29 February to 11 July 2018, following a discussion with the Respondent wherein the Applicant was told it was unnecessary to record his hours worked because he was going to be paid a daily rate, the Applicant had recorded only the days not worked. During this period, the Applicant’s evidence was that his hours increased and he often worked more than 12 hours per day on 5 days of each week plus maybe 7 or 8 hours on the other 2 days of each week, from 4.00am anywhere up to 11.00pm or 12.00am.

    (h)At all relevant times during the Employment and pursuant to cl.24.2 of the Award, the Applicant was entitled to be paid all earnings within 3 days of the end of the week in which those earnings accrued.

    (i)No payment was made to the Applicant in respect of wages or salary.

    (j)The Respondent made payments to the Applicant, which the Respondent said were to assist the Applicant’s family with the cost of living at home in Sri Lanka, as follows:

    (i)In or around June 2018, in the amount of $528.00 paid direct to the Applicant’s family in Sri Lanka;

    (ii)In or around July 2018, in the amount of $858.00 paid direct to the Applicant’s family in Sri Lanka;

    (iii)In or around August 2018, in the amount of $250.00 paid direct to the Applicant in cash; and

    (iv)In or around September 2018, in the amount of $300.00 paid direct to the Applicant in 3 instalments of $100.00.

    Findings of contravention

11. By the 25 July 2024 reasons, the Court made the following findings of contraventions of the Act:

    (a)In contravention of cl.14.4 (casual loading), 19.1 (minimum wages – adult rates), 20.6 (industry allowance), 24.2 (payment of wages), 30 (overtime), 31 (Saturday and Sunday work) and 32 (public holiday work) of the Award and therefore s.45 of the Act, SK Removals Pty Ltd failed to pay the Applicant wages totalling around $101,290.04 during the Employment.

    (b)At all material times, SK Removals Pty Ltd was required under the Award to contribute an amount equivalent to the superannuation guarantee charge rate at 9.5% to avoid a charge equivalent to any shortfall in superannuation contributions in respect of the Applicant’s earnings. And, at all material times, SK Removals Pty Ltd failed to make any superannuation payment in respect of the Applicant as to avoid liability for a superannuation guarantee charge under the relevant superannuation legislation and in contravention of cl.25.2 (employer contributions) of the Award and therefore s.45 of the Act, totalling around $2,789.72.

    (c)SK Removals Pty Ltd contravened s.323 of the Act by its wilful ignorance or failure to give genuine consideration to whether there was a payment obligation to the Applicant and/or the amounts due (and, otherwise, by deferring identification of what the amount to be paid was and, by that conduct, its failure to pay).

    (d)SK Removals Pty Ltd contravened s.535 of the Act by its failure, at all relevant times, to make and keep records of the kind prescribe by the Regulations specifically regs. 3.32, 3.33 and 3.34.

    WHETHER TO ORDER COMPENSATION

12. With regard to the reasons of 25 July 2024, the Applicant sought orders requiring the Respondent to pay the amount of $104,079.76 by way of compensation to the Applicant for the various established contraventions of s.45 of the Act, inclusive of superannuation on the wages amounts.

13. Section 545 confers a broad discretion on the Court to make any order that it considers appropriate if the Court is satisfied that a person has contravened a civil remedy provision. Without limiting that power, the statute expressly contemplates such order to include an award of compensation for loss that a person has suffered because of the contravention: s.545(2)(b), see also Fair Work Ombudsman v Carers Portland Inc [2023] FedCFamC2G 620.

14. As explained in the reasons of 25 July 2024, the requisite state of satisfaction exists. Relevantly, the Respondent was involved in multiple contraventions of s.45 of the Act by the failure or omission to pay the identified modern award entitlements (cl.14.4 (casual loading), 19.1 (minimum wages – adult rates), 20.6 (industry allowance), 24.2 (payment of wages), 25.2 (employer contributions), 30 (overtime), 31 (Saturday and Sunday work) and 32 (public holiday work) of the Award. The compensation order sought directly arises from those contraventions and it may be accepted that the Applicant’s loss was directly occasioned by the Respondent’s involvement in the contraventions of s.45.

15. The Respondent broadly disputed the Applicant’s calculations by submitting that the Applicant did not and could not have worked so many hours. Beyond screenshots of select bank statements which were said to show that the Respondent was not paid as much for the work performed as the Applicant claimed to be entitled to receive, the Respondent did not avail of the opportunities afforded to bring relevant evidence before the Court and, as such, the Applicant’s evidence in this regard (taken from his personal notebook) may be accepted on its face. However, the Applicant’s evidence was in part based on an estimate which was not able to be clarified on account of the company’s non-compliance with the record-keeping obligations in the Act. The Applicant submitted that his calculations incorporated a discount of 20% to allow for exigencies arising from the fact that the Applicant had not kept contemporaneous records of hours worked and had also deducted the amount of $1,936 which was agreed as paid for to the Applicant and his family in Sri Lanka. Nonetheless, in all of the circumstances and in the exercise of the Court’s discretion, I am minded to apply a further discount of 20% to account for the inherent uncertainty in the quantum of relief that arises because of the contraventions.

16. SK Removals Pty Ltd was the primary contravenor however, as sole director of SK Removals Pty Ltd and the only person with authority and responsibility to ensure the company’s compliance with workplace laws, it is appropriate that the Respondent be ordered to pay the compensation arising from the contraventions of s.45 of the Act.

17. For the above reasons, the Respondent will be ordered to pay compensation in the total amount of $83,263.81 ($104,079.76 less 20% or $20,815.95) for his contraventions of s.45 of the Act by involvement within the meaning of s.550(2) of the Act.

    INTEREST

18. The Applicant also sought payment of interest on the outstanding amounts, calculated at $39,191.45. The Applicant’s calculations in support of the amounts sought are extracted at Annexure A to these reasons.

19. Section 547 of the Act provides that, in making an order in relation to an amount that a person was required to pay to, or on behalf of, another person under the Act or a fair work instrument (other than a pecuniary penalty), the Court must on application include an amount of interest unless good cause is shown to the contrary. Further, in determining the amount of interest, the court must take into account the period between the day the relevant cause of action arose and the day the order is made.

20. In all of the circumstances and absent good cause to the contrary, it is appropriate to order interest on the compensation amount of $83,263.81. Adopting the guidance of the Federal Court of Australia’s practice note (“Interest on judgments”), pre-judgment interest will be ordered in the amount of $31,638.10.

    PECUNIARY PENALTIES

21. The Court’s power to impose pecuniary penalties in respect of the established contraventions resides in s.546(1) of the Act.

22. Section 546(1) permits the Court to impose a pecuniary penalty “that the court considers is appropriate if the court is satisfied that the person has contravened a civil remedy provision”. Each of ss.45, 323 and 535 of the Act are civil remedy provisions.

23. For the reasons delivered on 25 July 2024, that state of satisfaction exists. It falls to determine what level of penalty (if any) is appropriate as against the Respondent in light of the established contraventions.

24. The purpose of a civil penalty under the regime provided by the Act is primarily, if not wholly, protective in the promotion of the public interest in compliance with the provisions of the Act and in (general and specific) deterrence of further contraventions: Australian Building and Construction Commissioner v Pattinson (2022) 274 CLR 450 at [15]-[16] (Pattinson) citing the plurality in Commonwealth v Director, Fair Work Building Industry Inspectorate (2015) 258 CLR 482 and French J in Trade Practices Commission v CSR Ltd [1990] FCA 521 (CSR Ltd). An “appropriate” penalty being one that “strikes a reasonable balance between oppressive severity and the need for deterrence in a particular case”: Pattinson at [41].

25. The task of assessing what amount to impose involves the selection of a figure taking into account all factors relevant to the particular case: Wong v The Queen (2001) 207 CLR 584 at [75] (Gaudron, Gummow and Hayne JJ); Markarian v The Queen (2005) 228 CLR 357 at [37] (Gleeson CJ, Gummow, Hayne and Callinan JJ); Flight Centre Ltd v Australian Competition and Consumer Commission (No 2) (2018) 260 FCR 68 at [55] (Allsop CJ, Davies and Wigney JJ); Australian Competition and Consumer Commission v Reckitt Benckiser (Australia) Pty Ltd (2016) 340 ALR 25 at [44] (Jagot, Yates and Bromwicgh JJ) as cited by Snaden J at [26] in Australian Building and Construction Commissioner v Pattinson [2019] FCA 1654. The oft cited decision of French J in CSR Ltd at [42] listed those factors relevant to an overall assessment of penalty, restated by the Full Court in Construction, Forestry, Maritime, Mining and Energy Union v Australian Building and Construction Commissioner (The Non-Indemnification Personal Payment Case) (2018) 264 FCR 155 at [20]:

    ..the nature, character and seriousness of the conduct; the loss and damage caused; the circumstances in which the conduct took place; the size of the contravener and its degree of power; the deliberateness of the conduct and the time over which it occurred; the degree of involvement of senior officials or management; the culture of the organisation as to compliance or contravention; and, any co-operation with the regulator and contrition.

1. This is not an exhaustive list. Further, each case warrants an “idiosyncratic” approach and a careful analysis of all relevant circumstances - as was stated in Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith [2008] FCAFC 8 at [12] (Graham J):

   Penalties are not a matter of precedent. The choice of penalty must be dictated by the individual circumstances of a case, not by a line by line comparison with another case.

2. I turn to consider the application for pecuniary penalties in light of those well-established principles.

   Nature and deliberateness

3. The relevant conduct involves the Respondent’s involvement in the various contraventions of SK Removals Pty Ltd, incurred in the course of operating his rubbish removal company. Specifically, pursuant to the factual findings of 25 July 2024 as summarised above, the Respondent employed a refugee immigrant and has been determined to have been involved in a series of contraventions of the minimum entitlement, regular payment and record-keeping obligations in the Act. The contraventions arose because the Respondent did not regard Australia’s workplace laws as applicable to the work performed by the Applicant for his company.

4. The quantum of the underpayments which the Respondent as sole director was involved in accruing was found to total wages of around $101,290.04 plus superannuation of around $2,789.72.

5. Whilst some payments amounting to $1,936 were made to the Applicant and his family in Sri Lanka, and were deducted from the quantum of underpayments, the fact remains that the Respondent did not make those relatively modest payments as being for wages or work performed. The Respondent did not pay the Applicant for the work that he performed at all, nor did he keep records of work performed as he was required to do which has frustrated the early resolution of the matter.

6. There is no evidence of prior contraventions of the Act by the company or the Respondent. This is a relevant factor to take into account in assessing the appropriate penalty (if any) but does not reasonably excuse what are objectively serious and multiple contraventions of the Act.

7. In the present case, the Respondent has demonstrated an inexcusable ignorance of Australia’s workplace laws which applied to his engagement of the Applicant to work in his rubbish removal business regardless of any familial connection or friendship. Adopting the most beneficial view of the Respondent’s case, he has not sought to understand his obligations or that of SK Removals Pty Ltd and his involvement in the contraventions of SK Removals Pty Ltd was serious. Ignorance of Australia’s workplace laws is not of itself sufficient excuse for an employer to not familiarise itself with and/or to disregard the operation of these basic conditions of employment.

   Loss

8. There is no dispute that the Applicant has suffered loss occasioned by the various contraventions of the Act. Consideration of the loss suffered by the Applicant is addressed earlier in these reasons (in relation to the separate relief sought in terms of compensation).

9. These are all matters taken into account in assessing the penalty, including the conclusion that a separate award of compensation be made in the present case.

   Cooperation and contrition

10. This was not a case where the Respondent’s (at best - sporadic) cooperation was of any assistance as to warrant a discount on or adjustment of the penalty. Rather, the Respondent’s involvement in the proceedings resulted in numerous delays to the resolution of the matter which were not ultimately justified by the provision of evidence or materials.   

11. At the penalty hearing, the Respondent told the Court that he is sorry. This may be understood as an expression of contrition and perhaps regret about the breakdown of his relationship with the Applicant and that it has come to this. For his part, the Applicant took this to be a statement of the Respondent’s regret upon belated appreciation or realisation of the serious consequences for him.

12. These factors are relevant to an assessment of penalty.

    Size and financial resources

13. It was not contentious that SK Removals Pty Ltd was a small company which was since deregistered. At the penalty hearing, the Respondent told the Court that he continues to operate a rubbish removal business, now as a sole trader, and does not employ nor intend to employ any other person to work for him.

14. The Respondent also told the Court that he would be happy to pay $10,000 to $20,000 to the Applicant, but not for salary and did not want to pay any more. He said that he could make such payment within 2 months and did not otherwise describe his financial circumstances.

    Deterrence

15. There is a need in the present case for general deterrence, to emphasise the importance of the maintenance of effective minimum terms and conditions of employment and adherence to the provisions of industrial instruments.

16. There is also a need for specific deterrence especially where the Respondent continues to operate a business and could employ persons in the future.

    Resolution – penalties

17. It falls to determine what level of pecuniary penalty (if any) is appropriate as against the Respondent for his involvement in the contraventions of SK Removals Pty Ltd.

18. The multiple contraventions of each Award provision are properly characterised as a single course of conduct in each case. However, it remains that there are a total of 8 separate contraventions of s.45 on account of there being 8 separate award conditions which were not complied with, in addition to a contravention of s.323 and of s.535.

19. As an individual, the maximum penalty for each of the contraventions of ss.45, 323 and 535 of the Act is $12,600.

20. In weighing all of the relevant factors, I am satisfied that it is appropriate to impose pecuniary penalties on the Respondent as follows:

    (a)For each of the 8 contraventions of s.45, in the amount of $5,040 and totalling $40,320;

    (b)For the contravention of s.323, in the amount of $5,040; and

    (c)For the contravention of s.535, in the amount of $5,040,

    (totalling $50,400 in penalties).

21. In my view, the penalty arrived at in each case is a proportionate response to the respective contraventions and strikes a reasonable balance between oppressive severity and the need for deterrence in this particular case. It is appropriate that they be paid to the Applicant, within a longer timeframe of 120 days.

    CONCLUSION

22. For the above reasons, I will make orders for payment compensation, interest and the imposition of pecuniary penalties in the above specified amounts. There will be no order as to costs and the application will otherwise be dismissed.

I certify that the preceding forty-seven (47) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Mansini.

Associate:

Dated:       15 October 2024

ANNEXURE A

Start Date	End Date	Days	Rate*	Amount Per Day	Total
11/01/2018**	30/06/2018	171	5.5%	$15.6833	$2,681.84
01/07/2018	31/12/2018	184	5.5%	$15.6833	$2,885.72
01/01/2019	30/06/2019	181	5.5%	$15.6833	$2,838.67
01/07/2019	31/12/2019	184	5.25%	$14.9704	$2,754.55
01/01/2020	30/06/2020	182	4.75%	$13.5076	$2,458.39
01/07/2020	31/12/2020	184	4.25%	$12.0858	$2,223.78
01/01/2021	30/06/2021	181	4.1%	$11.6912	$2,116.10
01/07/2021	31/12/2021	184	4.1%	$11.6912	$2,151.17
01/01/2022	30/06/2022	181	4.1%	$11.6912	$2,116.10
01/07/2022	31/12/2022	184	4.85%	$13.8298	$2,544.68
01/01/2023	30/06/2023	181	7.1%	$20.2457	$3,664.46
01/07/2023	31/12/2023	184	8.1%	$23.0972	$4,249.88
01/01/2024	30/06/2024	182	8.35%	$23.7450	$4,321.59
01/07/2024	30/09/2024***	92	8.35%	$23.7450	$2,184.54
Total	2455	$39,191.45