Transport Workers' Union of Australia v CleanAway Operations Pty Ltd
[2020] FWC 6212
•19 NOVEMBER 2020
| [2020] FWC 6212 |
| FAIR WORK COMMISSION |
DECISION |
Fair Work Act 2009
s.437—Protected action
Transport Workers’ Union of Australia
v
CleanAway Operations Pty Ltd
(B2020/664)
COMMISSIONER BISSETT | MELBOURNE, 19 NOVEMBER 2020 |
Proposed protected action ballot of employees of CleanAway Operations Pty Ltd – whether TWU genuinely trying to reach an agreement considered – application refused.
[1] The Transport Workers’ Union of Australia (TWU) has made an application to the Fair Work Commission (the Commission) for a protected action ballot order (PABO) pursuant to s.437 of the Fair Work Act 2009 (FW Act). The application is made in relation to employees to be covered by the proposed agreement for whom the TWU is a bargaining representative. The current agreement which covers the employees is the Cleanaway Cardinia and Greater Melbourne Municipal Enterprise Agreement 2016.
[2] Cleanaway Operations Pty Ltd (Cleanaway or the Respondent) opposes the grant of the order as it says that the TWU is not genuinely trying to reach an agreement.
[3] Beyond this issue the Respondent agrees that the application has been made in accordance with the FW Act and it has no issue with the questions to be included in the proposed ballot.
RELEVANT LEGISLATION
[4] Section 443(1) of the FW Act states:
When the FWC must make a protected action ballot order
(1) The FWC must make a protected action ballot order in relation to a proposed enterprise agreement if:
(a) an application has been made under section 437; and
(b) the FWC is satisfied that each applicant has been, and is, genuinely trying to reach an agreement with the employer of the employees who are to be balloted.
[5] The application has been made under s.437 of the FW Act. It falls therefore to determine if the TWU “has been, and is, genuinely trying to reach an agreement” with the Respondent.
EVIDENCE
[6] Evidence in these proceedings was given by Mr Anthony Goddard for the TWU and Mr Shane Burbidge for the Respondent.
Anthony Goddard
[7] Mr Goddard gave evidence that he is the TWU Organiser responsible for servicing members of the Respondent. This includes representing members in bargaining.
[8] Mr Goddard said that he had attended 10 bargaining meetings with the Respondent from January to October 2020. A log of claims from the TWU had been provided to the Respondent and the Respondent had provided its log of claims to the TWU.
[9] Mr Goddard gave evidence that at the bargaining meeting of 4 March 2020, in an attempt to progress the bargaining, TWU representatives advised management that if the pay rise was palatable the remainder of the Respondent’s offer would be accepted.
[10] Mr Goddard said that the TWU claims were articulated but bargaining meetings only went for between one and two hours so often there was not much time. He said however that the TWU had sought to engage in meaningful negotiations by seeking to determine the rationale behind the Respondent’s claims. He said the TWU did cancel one bargaining meeting due to the unavailability of its representatives.
[11] Mr Goddard agreed that the TWU suspended bargaining following an incident at the bargaining meeting of 14 October 2020. The following day the TWU distributed an update to members which reported on the conduct of representatives of the Respondent in the meeting of 14 October 2020 and advised that “with your support, the TWU will be lodging a Protected Action Ballot (PAB).”
[12] Mr Goddard agreed that on 21 October 2020 the TWU wrote to Cleanaway and advised that the TWU had “made the reasonable decision to pause further Enterprise Agreement bargaining meetings pending the outcome of your investigation of Cleanaway management’s behaviour” in the meeting of 14 October 2020. Mr Goddard also said that, as far as he could read the letter, it was a withdrawal from bargaining with Cleanaway by the TWU in Victoria. Mr Goddard said that this withdrawal from bargaining was not to punish Cleanaway but was for the safety of TWU officials.
[13] Mr Goddard said he was aware of a reply letter from Cleanaway dated 22 October 2020. He agreed that the steps for the continuation of bargaining set out in that letter provided a potentially safe environment in which bargaining could occur.
[14] Mr Goddard denied any knowledge of the TWU Facebook page.
Shane Burbidge
[15] Mr Burbidge gave evidence in relation to the bargaining meetings and progress of bargaining with the TWU. He agreed with the number of bargaining meetings held and said that one and a half hours was allocated to each meeting although sometimes the meetings went for two hours.
[16] Mr Burbidge said that the TWU had not gone into the detail of its claims beyond wages although did agree that the wage increase was the major issue.
[17] Mr Burbidge said that the detail of the claims was not clearly articulated until Mr Mem Suleyman, TWU Chief of Staff, attended the meeting of 23 September 2020.
[18] Mr Burbidge gave evidence that:
• The TWU did not question or engage with the Respondent on the Respondent’s log of claims tabled at the first bargaining meeting;
• The TWU did not table its log of claims until the third bargaining meeting although did discuss its desired pay increase before then;
• The TWU avoided discussing the detail of its claims in bargaining but rather talked at a high level. Because of this the Respondent had difficulty considering and responding to the TWU claims but did provide some concessions to the TWU conditional on the TWU providing more detailed information;
• At the bargaining meeting on 4 March the TWU again refused to articulate the detail of its claims;
• The TWU initially refused to participate in bargaining by video although on 22 July 2020 agreed to do so. However, at this meeting all the TWU wanted to discuss was the wage increase;
• On 6 August 2020 the TWU rejected in totality the Respondent’s log of claims without providing any considered feedback;
• At the meeting of 23 September 2020 attended by Mr Suleyman the TWU articulated in detail their log of claims and Mr Suleyman agreed to provide wording that might satisfy the claims and provide a basis for discussion at the following meeting. The wording was subsequently provided by the TWU.
[19] Mr Burbidge agreed that, at the meeting of 26 February 2020 the TWU indicated that if the pay rise was palatable the rest of the (Respondent’s) claims would be accepted. He said however that the parties were at loggerheads over wages with no apparent resolution.
[20] Mr Burbidge agreed that an email sent to him by Mr Goddard on 21 October 2020 did not say that the TWU would not bargain with Cleanaway although considered this was the TWU’s intent when the email was considered in conjunction with the TWU letter of 21 October 2020.
[21] Mr Burbidge said that, following the incident on 14 October 2020, the Respondent was prepared to withdraw Mr Schulze from the Respondent’s bargaining team for a short period of time (Mr Schulze having been involved in the incident). He said that the Respondent had other senior managers who could be involved and that if they had to appease the TWU to continue bargaining they would.
[22] Whilst Mr Burbidge acknowledged that the TWU may have been considering a protected action ballot application in July 2020 he said that he considered this ballot application to be in response to the incident of 14 October 2020 intended to punish the Respondent for the incident.
Further evidence
[23] At the conclusion of the hearing I questioned the parties as to whether the TWU had responded to the Respondent’s letter of 22 October 2020 where the Respondent set out what appeared to be an approach to bargaining agreed between the TWU and the Respondent. Both parties agreed that a response had been sent by the TWU. I requested that a copy of the email be provided to the Commission and indicated that, on review, I would seek further information from the parties if I considered that correspondence relevant. The parties subsequently made submissions as to whether I should have regard to the email, whether I should take evidence from Mr Suleyman with respect to the email and what, if any weight I might otherwise give to the email.
[24] I considered that it was not necessary to take evidence from Mr Suleyman with respect to the email – its existence and that it had been sent and received is not in dispute.
[25] While the Respondent suggested the email should be accorded little or no weight I have decided to take it into account. The Commission does have the power to inform itself in a manner as it considers appropriate.1 Having given the parties an opportunity to make submissions on the email I consider it reasonable to take the email and the submissions of the parties into account. The content of that email materially bears on the matters I am required to consider. In this respect it is unclear why the TWU did not provide it with its submissions and evidence, knowing full well at that time the case the Respondent (having filed first) intended to put to the Commission.
[26] The email response of the TWU was sent by Mr Suleyman on 30 October 2020 and said, in part:
Nevertheless, the TWU is willing to schedule meetings to recommence negotiations pending the approval of Delegates who were subjected to the behaviour on the said days from the business. For our part, we have been willing participants in enterprise agreement discussions for some time, we have clearly articulated this to your representatives.
Your team should correspond with myself directly to schedule appropriate times for the meetings for the Casey, Cardinia and Boroondara negotiations. Please note, I am on personal leave from the week commencing 02/11/2020 until the week commencing 16/11/2020. However, subject to no mitigating personal circumstances, you can nominate a time during my leave period for these discussions should Cleanaway feel the urgency to hold the discussions through this period. As for all other enterprise agreements that have been paused, TWU Organiser, Anthony Goddard can now be contacted as the main point of reference.
Moving forward and before proposed meetings commence, we request a short meeting with yourself to discuss agreed rules around the negotiations such as report back meetings to workers. We note numerous requests have been made for joint report back sessions with the business, to date, the requests have been ignored and Mr. Goddard has subsequently experienced difficulty accessing workers to give report backs at the site. Should negotiations recommence, we would need commitments on basic protocols like those listed in your letter…
[27] The import of the email is that, in relation to the proposed agreement subject to this application for a PABO, Mr Suleyman was the main point of contact. His absence on leave meant little could occur in relation to those negotiations until he returned after 16 November 2020.
LEGAL PRINCIPLES
[28] The Commission must be satisfied that the TWU, in this case has been, and is, genuinely trying to reach an agreement. The onus is on the TWU to demonstrate that this is so.
[29] The expression “genuinely trying to reach an agreement” in s.443(1)(b) is to be given its ordinary meaning.2
[30] In Total Marine Services v MUA3 the Full Bench said:
[32] We agree that it is not appropriate or possible to establish rigid rules for the required point of negotiations that must be reached. All the relevant circumstances must be assessed to establish whether the applicant has met the test or not. This will frequently involve considering the extent of progress in negotiations and the steps taken in order to try and reach an agreement. At the very least one would normally expect the applicant to be able to demonstrate that it has clearly articulated the major items it is seeking for inclusion in the agreement, and to have provided a considered response to any demands made by the other side. Premature applications, where sufficient steps have not been taken to satisfy the test that the applicant has genuinely tried to reach an agreement, cannot be granted.
[31] It is necessary, in reaching a conclusion, to have regard to all of the relevant circumstances.4
[32] In JJ Richards & Sons v TWU5 the majority of the Full Bench said:
[58] The expression “genuinely trying” in s.443(1)(b) is, clearly enough, concerned with the genuineness of the “trying”, the efforts, to reach the stated goal, namely an enterprise agreement that meets the requirements of the FW Act. It is directed at the authenticity of the applicant’s efforts to reach that goal. The genuineness or authenticity of an applicant’s efforts to reach that goal will turn on its motivation - the intention, object or purpose.
…
[63] In circumstances where an applicant for a protected ballot order calls (acceptable) evidence that their intention, object or purpose is to reach an enterprise agreement under the FW Act a finding that the applicant was not “genuinely trying to reach an [enterprise] agreement” within the meaning of s.443(1)(b) will necessarily involve accepting evidence establishing that the applicant had some other, extraneous purpose in seeking the ballot. Indeed, when there is evidence from an applicant for a protected action ballot order that they have been and are “genuinely trying to reach an [enterprise] agreement” under the FW Act, it is difficult to conceive of circumstances where it could properly be found they were not, unless there is cross-examination or other evidence establishing that the applicant in truth has some other, extraneous intention, object or purpose or is seeking something other than an enterprise agreement under the FW Act. For example, the evidence may demonstrate that the applicant is pursuing an agreement that it knows or ought reasonably knows would not be an enterprise agreement within the meaning of the FW Act because it contains non-permitted matters contrary to s.172(1) or that the true motivation is to apply pressure in pursuit of political or environmental goals or simply to punish the employer for some perceived wrong doing.
SUBMISSIONS
[33] The TWU submitted that it has been and remains prepared to bargain with the Respondent. It submitted that the application before the Commission is not revenge or in response to the incident of 14 October 2020 and that that incident is being dealt with separately.
[34] The TWU said that it initially prepared a PABO application in July 2020 but did not proceed with it at that time.
[35] The TWU submitted that, considered objectively, it has complied with the good faith bargaining requirements and has been and is genuinely trying to reach an agreement.
[36] The TWU said, of the Suleyman email of 30 October 2020, that it is explicit in stating the TWU is willing to recommence negotiations:
• The TWU is willing to schedule meetings;
• The TWU is willing to participate in meetings;
• Mr Suleyman indicates that he is the contact person for arranging meetings and is available, while on leave, for that purpose;
• The author is willing to discuss rules for the conduct of meetings.
[37] The Respondent submitted that the evidence demonstrates that the TWU officials took the incident of 14 October 2020 “personally” and that the application now before the Commission for a PABO is in revenge or retribution for that incident. Whilst it acknowledged that the TWU had done work internally in relation to a PABO application in July 2020 it submitted that there is no evidence they intended to do more at that stage. In this respect it submitted that the PABO application has some other intention than the achievement of an enterprise agreement.
[38] The Respondent submitted that at the meeting of 23 September 2020 the TWU was prepared to engage in detailed discussions with respect to its log of claims and had provided, for the purpose of furthering the negotiations, some draft clauses that it said would satisfy its claims. Because of the incident of 14 October 2020 and the subsequent withdrawal by the TWU from further negotiations, these proposals have not been subject to any further exchange between the parties. In this respect the Respondent said that the application is premature. Except for the incident on 14 October 2020 it would be expected that the parties would have proceeded further with bargaining. Instead, it submitted that the TWU has stopped bargaining and made the current application.
[39] The Respondent further submitted that on 16 October 2020 Mr Suleyman agreed with Mr Edwards of the Respondent on a framework within which bargaining could proceed following the incident of 14 October 2020. Despite this agreement the TWU reneged on the commitment to bargain and made the current application.
[40] With respect to the Suleyman email of 30 October 2020 the Respondent said that the email was an attempt by the TWU to provide a defensive position to the Respondent’s objection to the PABO application. Further, the Respondent submitted that the email is not evidence of a commitment to commence bargaining but rather a consideration of commencing bargaining but only if a number of conditions are satisfied, including matters over which the Respondent has no control including the views of the TWU delegates involved in bargaining.
[41] For all of these reasons the Respondent said the TWU is not genuinely trying to reach an agreement. The application should therefore fail.
CONSIDERATION
Bargaining until 14 October 2020
[42] The TWU gave evidence that it had engaged in 10 bargaining meetings with the Respondent prior to the incident on 14 October 2020 (although I would observe that the number of bargaining meetings is not determinative as to whether a party is genuinely trying to reach an agreement). I note its complaint however that the bargaining meetings were short.
[43] It is apparent from the evidence that the Respondent tabled its log of claims at the first bargaining meeting on 14 January 20206 (the first bargaining meeting) and the TWU tabled its log of claims at the meeting of 19 February 20207 (the fourth meeting). At the fifth meeting on 26 February 20208 the Respondent provided some response to the TWU’s log of claims and it was at this meeting that the TWU indicated that if the pay increase was adequate that would, in effect, settle the matter. The pay increase sought by the TWU was 20-24%. The only further documentary evidence of the bargaining meetings are the minutes of the meeting of 4 March 20209 where the Respondent provided further response to the TWU’s log of claims.
[44] Whilst Mr Goddard gave evidence that the minutes of the bargaining meeting of 19 February 202010 demonstrate that the TWU was attempting to “ascertain the rationale behind the employer’s position” those minutes do not demonstrate this.
[45] The material before the Commission indicates very little progress in bargaining for the number of meetings held up until 23 September 2020. The evidence does, however, support a finding that, at this meeting, the TWU claims were clearly articulated and it was agreed that proposed clauses would be provided by the TWU to the Respondent. Mr Goddard agreed that this had occurred. This drafting by the TWU was to allow the Respondent to provide detailed and considered feedback on the claims of the TWU at the meeting scheduled for 14 October 2020.
[46] A determination of whether a party is genuinely trying to reach an agreement is to be determined objectively based on the facts and circumstances before the Commission.
[47] Whilst there had been some exchange of logs of claims and views in January and February 2020, the evidence before me does not allow me to conclude that any real attempt was being made by the TWU to genuinely reach an agreement in the period up until 23 September 2020. Whilst Mr Goddard said that there has been no movement by the Respondent with respect to wages the evidence does not allow me to conclude that the TWU has considered the Respondent’s position on wages or responded such that I could conclude it was genuinely trying to reach an agreement.
[48] To say that an agreement on wages will resolve all matters is not indicative of genuinely trying to reach an agreement in circumstances where the TWU had provided a log of 18 claims, none of which were sought to be progressed. For all of the negotiations prior to 23 September 2020 there is little evidence to support any real or genuine attempts to reach an agreement.
[49] The evidence does support a conclusion that at the meeting on 23 September 2020 the TWU did articulate their claims and provided proposed wording to the Respondent that would enable genuine negotiations on the various claims to proceed. However, one successful meeting prior to the making of the application for a protected action ballot does not necessarily allow me to conclude that the TWU has been genuinely trying to reach an agreement.
The meeting of 14 October 2020
[50] The bargaining meeting of 14 October 2020 was intended to consider the proposals put forward by the TWU following the meeting of 23 September 2020.
[51] This meeting however was abandoned after no more than 15 minutes following apparent inappropriate conduct by Mr Schulze, a member of the Respondent’s bargaining team. This conduct was apparently motivated by a report from the Financial Review newspaper that was circulating in the workplace. Mr Schulze did not give evidence in these proceedings so what caused his reaction or what he hoped to achieve is not known. It does not seem to be disputed however that his action was not in relation to matters on the bargaining agenda.
[52] On the limited evidence before me about the incident on 14 October 2020 Mr Schulze’s conduct appears to have been inappropriate. In those circumstances the TWU cannot be blamed for ending the meeting and seeking some undertakings from the Respondent in relation to future conduct of negotiations.
[53] The incident of 14 October 2020 however needs to be separated from the process of bargaining.
At the time of making the application
[54] The application for a PABO was signed by the Branch Secretary of the TWU on 20 October 2020, the day before the TWU wrote to the Respondent and advised it was pausing any further enterprise bargaining. The application was lodged with the Commission on 28 October 2020 – six days after the TWU had received a response from the Respondent with respect to its letter and two days before Mr Suleyman responded to the letter from the Respondent of 22 October 2020.
[55] Clearly, at the time of making the application, the TWU was not genuinely trying to reach an agreement as it had advised the Respondent it had placed a “pause” on that activity. This was despite the apparent arrangement entered into between the TWU and the Respondent on 16 October 2020 for the future conduct of negotiations.
[56] The evidence before the Commission does not support a conclusion that the TWU was genuinely trying to reach an agreement at the time the application was made on 28 October 2020.
[57] Whilst it might be possible to conclude that the TWU is now seeking to re-enter negotiations by virtue of Mr Suleyman’s email of 30 October 2020 there has only been one meeting in this re-invigorated attempt and that was on 23 September 2020, prior to the pause in negotiations.
[58] For this reason, I cannot conclude, that at the time of making the application and at the time of hearing the application the TWU is genuinely trying to reach an agreement.
What was the reason for the application?
[59] The Respondent submitted that if the motivation of the application is for some ulterior purpose – for example to put pressure on the Respondent for some reason other than reaching an enterprise agreement, then the TWU could not satisfy the requirement that it is genuinely trying to reach an agreement.
[60] There was nothing that happened in a bargaining sense at the meeting of 14 October 2020 that would allow me to conclude that the PABO application of the TWU was made in circumstances where the TWU is genuinely trying to reach an agreement.
[61] The negotiations, having not progressed up until 23 September 2020, appear to have been re-set in that meeting. Further negotiations around articulated claims and draft wording was intended to occur on 14 October 2020. However, this effective re-set of bargaining was disrupted by the conduct of Mr Schulze not related to matters on the bargaining agenda. This incident is the only thing that occurred in the meeting of 14 October 2020. No bargaining for an agreement occurred.
[62] Given the apparently positive progress on 23 September 2020 and the provision of proposed wording of clauses by the TWU on 25 and 29 September 2020, that no more bargaining occurred before the application was made supports a finding that the application of a PABO was in response to the incident of 14 October 2020 and not in relation to bargaining. This supports a finding that the application was made for some purpose other than supporting a bargained agreement which does not support a conclusion that the TWU is genuinely trying to reach an agreement.
[63] I accept that a proposed PABO application was drawn up by the TWU in July 2020. That, however, does not go to the motivation of making the application in October 2020. The obligation on the Commission is to determine if the applicant for a PABO is genuinely trying to reach an agreement at the time the application is made. The motivation of the TWU in July 2020 does not bear testament to its motivation today.
Further bargaining
[64] There was some confusion with respect to whether the TWU intended to participate in further bargaining.
[65] In its letter of 21 October 202011 the TWU said that, in light of the incident of 14 October 2020, it had decided to “pause” further enterprise bargaining with the Respondent “pending the outcome” of investigations into management conduct at the meeting. This pause apparently applied to all negotiations for enterprise agreements with Cleanaway. In its reply letter of 22 October 202012 the Respondent said it was disappointed that the TWU had decided to stop participation in bargaining, particularly as Mr Edwards and Mr Suleyman had agreed to conditions on 16 October 2020 under which bargaining could occur.
[66] The Suleyman email of 30 October 2020 is the only indicator of future bargaining. As indicated above I have decided that regard should be had to it as it bears on the matter before me. There is no evidence of any meetings occurring or having been set up ready to occur on Mr Suleyman’s return – some cause of this, of course, sits with the Respondent who has not responded to the email. However, I am satisfied that the email established a number of caveats on any future meetings – meetings were “pending the approval of Delegates”; there would need to be a (preliminary) meeting to “to discuss agreed rules around the negotiations such as report back meetings”; “should” negotiations occur the TWU “would need commitments on basic protocols like those listed in your letter” and a TWU Delegate would need to be returned to site “without further stress”.
[67] I do not suggest that these are not legitimate claims or concerns of the TWU but, in the context of having paused bargaining they are put as conditions to be met if bargaining is to resume. I would observe in addition that the reference to some agreement to protocols such as those outlines in the Respondent’s letter (of 22 October 2020) seems strange when those protocols appear, by that letter, to have been agreed to by the Respondent and Mr Suleyman on 16 October 2020.
[68] For these reasons I accept the submissions of the Respondent that the email was a defensive strategy by the TWU to support its claim that it had been genuinely trying to reach an agreement.
[69] Even if I did accept it as evidence that the TWU was willing to recommence negotiations it is not indicative of an intent to genuinely try to reach an agreement, although I accept that meeting is a necessary step.
CONCLUSION
[70] The requirement of s.443(1)(b) of the FW Act is that the applicant for a PABO “has been, and is, genuinely trying to reach an agreement.”
[71] Such an assessment can only be made on the basis of the evidence before the Commission at the time of hearing the application.
[72] For a positive assessment to be made both conditions must be met – the TWU must have been genuinely trying to reach an agreement and must, currently, be trying to do so.
[73] It is also necessary that there be no other purpose in the proposed industrial action.
[74] The TWU may have been trying to reach an agreement in January and February 2020 and perhaps in March of 2020 but the evidence does not allow me to conclude that this effort extended from March through to September 2020. For this reason, I am not satisfied that the TWU have been genuinely trying to reach an agreement. I have reached this conclusion because of a lack of temporal connection between past efforts and the time of this application. The gap in the evidence of efforts from March to one meeting in September 2020 is too great.
[75] I am also not satisfied that the TWU is currently genuinely trying to reach an agreement. It has had one meeting with the Respondent (in September 2020) where some valid attempts appear to have been made to get negotiations on track. However, at that point the TWU paused negotiations and, at the time the application for a PABO was signed and lodged with the Commission, no further attempts had been made. To the extent I might accept that the TWU has now altered its position with respect to an apparent willingness to meet with the Respondent regarding this agreement I am not satisfied that it is adequate to meet the requirements of s.443(1)(b) that it has, and is, genuinely trying to reach an agreement.
[76] Further, I am not satisfied that the application of the TWU is not for some purpose other than reaching agreement. The timing of the application following the disrupted meeting of 14 October 2020 strongly supports a conclusion that the application was in relation to that incident and not for bargaining.
[77] For these reasons the application for a protected action ballot is refused.
COMMISSIONER
Appearances:
Mr J. Cooney appearing for the Applicant
Mr S. Edwards appearing for the Respondent
Hearing details:
2020.
Melbourne by video.
November 11
Printed by authority of the Commonwealth Government Printer
<PR724701>
1 Section 590(1) of the FW Act.
2 John Holland Pty ltd v AFMEPKIU {2010] FWAFB 526 at [38].
3 [2009] FWAFB 368.
4 Total marine Services Pty Ltd v MUA[2009] FWAFB 368 at [31].
5 [2010] FWAFB 9963.
6 Exhibit TWU1, attachment AG-3.
7 Exhibit TWU1, attachment AG-4.
8 Exhibit TWU1, attachment AG-5.
9 Exhibit TWU1, attachment AG-6.
10 Exhibit TWU1, attachment AG-4.
11 Exhibit Cleanaway1, annexure SB-3.
12 Exhibit Cleanaway1, annexure SB-4.
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