PR961315

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AUSTRALIAN INDUSTRIAL RELATIONS COMMISSION

Workplace Relations Act 1996
s.45 appeal against decision PR957250
issued by Deputy President Hamilton on 27 April 2005

Australian Municipal, Administrative, Clerical and Services Union
(C2005/2699)

s.170LW application for settlement of dispute (certification of agreement)

Australian Municipal, Administrative, Clerical and Services Union

and

Australian Taxation Office and another
(C2005/1888)

Commonwealth employment

   

VICE PRESIDENT ROSS

 

SENIOR DEPUTY PRESIDENT ACTON

 

COMMISSIONER MANSFIELD

MELBOURNE, 11 AUGUST 2005

Appeal – whether dispute was a dispute over the application of the agreement – jurisdictional fact – issue turned on whether a particular clause gave rise to a binding obligation – error warranting correction on appeal – leave granted – appeal upheld – decision quashed.

DECISION

Introduction

[1] The Australian Taxation Office (the ATO), the Australian Municipal, Administrative, Clerical and Services Union (ASU), the CPSU, the Community and Public Sector Union (CPSU) and the Media, Entertainment and Arts Alliance are all party to the ATO (General Employees) Agreement 20041 (the ATO Agreement). The ATO Agreement was certified pursuant to Part VIB of the Workplace Relations Act 1996 (Cth) (the WR Act).

[2] On 16 February 2005 the ASU lodged a notification (C2005/1888) of an alleged dispute arising under the ATO Agreement. The notification is in the following terms:

[3] In essence the ASU sought to invoke the dispute settlement clause in the ATO Agreement in relation to notices of suspected breach of the APS Code of Conduct that were issued to three of its members employed by the ATO.

[4] In each case the ASU complains that the ATO’s delegate did not discuss the report of a suspected breach with the employee before issuing the notice of suspected breach to the employee. It complains that the delegate’s conduct shows bias and a lack of independence. It seeks the appointment of a new delegate, and a direction that the new delegate consider afresh the action under clause 1.13 of the Misconduct Procedures that is appropriate.2

[5] The ASU seeks a determination by the Commission under clause 141.5 that the following steps are necessary to achieve the ATO’s compliance with the Misconduct Procedures. The determination sought is as follows:

[6] The dispute settlement procedure is set out in clause 141.5 of the ATO Agreement, in the following terms:

[7] Clause 118 of the ATO Agreement states:

[8]
The background to clause 118 is dealt with in the uncontested evidence of Mr Jeffrey Lapidos. We deal with Mr Lapidos’s evidence later.

[9] It is also relevant to note that s.15(1) of the Public Service Act 1999 (Cth) requires an Agency head to establish procedures for determining whether an APS employee in the Agency has breached the code of conduct. The code of conduct is set out in s.13 of that Act. These procedures “must comply with basic procedural requirements set out in Commissioner’s Directions”.5

[10] The basic procedural requirements for determining breaches of the Code of Conduct appear in chapter 5 of the Public Service Commissioner’s Directions 19996. In accordance with s.15(3) of Public Service Act 1999 (Cth) and the Commissioner’s Directions, the ATO has established “Managing Misconduct - ATO Procedures for Determining Suspected Breaches of the APS Code of Conduct” (the Misconduct Procedures).

[11] The Misconduct Procedures contain the following provisions.

[12] Following a conference on 28 February 2005, the ATO confirmed that its position was that the Commission did not have jurisdiction to hear and determine the application pursuant to clause 141. The ASU disagreed. Directions for a preliminary jurisdictional hearing were issued by consent and the parties, including the intervener - the CPSU, were required to file submissions. The matter was heard on 11 and 12 April 2005.

[13] In the proceedings at first instance the ASU contended that clause 1.12 of the Misconduct Procedures requires the ATO’s delegates to discuss a report of a suspected breach of the APS Code of Conduct with an affected employee before issuing a notice of suspected breach to the employee. It argued that the ATO’s delegates had not done so, and had therefore failed to properly apply the Misconduct Procedures. It argued that a failure to properly apply the Misconduct Procedures gave rise to a dispute involving a matter set out in subparagraph 3(b) of Step 3 of clause 141.5 of the ATO Agreement because it involves the question of whether or not the ATO has complied with the procedural obligation, employee entitlement or condition in clause 118.8

[14] The ATO submitted that the dispute was only about the proper application of the Misconduct Procedures. It argued that clause 118 does not create an obligation distinct from, or additional to, the obligation created by the Misconduct Procedures and that the ATO’s obligation to comply with the Misconduct Procedures arises out of s.15 of the Public Service Act 1999 (Cth), not clause 118 of the ATO Agreement. On this basis it is said that there was no dispute over the application of the ATO Agreement, and no question as to whether the ATO has complied with clause 118.

The decision subject to appeal

[15] The critical question in the proceedings at first instance was whether clause 118 of the ATO Agreement “creates an obligation, enforceable as a clause of the ATO Agreement, to properly apply the ATO Misconduct Procedures”9.

[16] In the decision subject to appeal the Deputy President concluded that, although on the language of the clause alone it probably could be interpreted either way, “the stronger argument is that it is declaratory alone and creates no obligations.”10 In particular his Honour found that clause 118 did not establish “any procedural obligation, employee entitlement or condition under the Agreement”11 within the meaning of the dispute settlement clause in the ATO Agreement. The Deputy President sets out six reasons for his conclusion.

[17] At paragraphs 53 to 56 of the decision subject to appeal the Deputy President said:

[18] Two further aspects of the decision subject to appeal are relevant.

[19] The first is that the Deputy President distinguished the decision of the Full Bench in SDA v Big W Discount Department Stores19 (the Big W decision). In the Big W decision the Full Bench found that a clause in the following terms created a binding obligation:

[20] The Deputy President dealt with the Big W decision at paragraphs 24 and 25 of the decision subject to appeal:

[21] The second aspect of the decision of note is that the Deputy President supported his conclusion with respect to the meaning of clause 118 by reference to a series of cases dealing with letters of comfort.21 We return to this issue later in our decision.

Submissions on appeal

[22] The Appellant contends that the Deputy President erred in concluding that the Commission did not have jurisdiction pursuant to clause 141 of the ATO Agreement to determine the dispute referred to it by the ASU. In particular it is said that the Deputy President erred in concluding that clause 118 did not impose a “procedural obligation” on the ATO within the meaning of clause 141.5 of the ATO Agreement and in concluding that the opening three lines of clause 118 only constituted a prefatory or explanatory statement on the part of the ATO.

[23] The Appellant submits that the words of clause 118 are plain english words. A commitment to “ensure” that something happens is, prima facie, indicative of making a binding promise. They are words of obligation so that an allegation by a party to the ATO Agreement of a failure by the person who made the commitment to meet the commitment gives rise to a dispute about the application of the agreement.

[24] Three particular points are advanced by the Appellant in respect of the reasons given by the Deputy President.

[25] Firstly, it is submitted that the Deputy President erred in failing to follow the Big W decision.

[26] As set out at paragraphs 24 and 25 of his decision, the Deputy President distinguished the Big W decision in two ways. Firstly, it was said that in the clause in the Big W decision there was a mutual commitment. This mutuality was said to be “consistent with it being a binding obligation between [the parties] that this commitment be implemented”. The ASU argues that it is difficult to see why this is so. Many provisions in certified agreements will be binding notwithstanding that only one party to the agreement is required to comply with the provisions. The requirements to pay wages to employees or to obey lawful directions of the employer are but two obvious examples. It is submitted that mutuality cannot be the hallmark of a binding obligation. In any event, it is submitted that it is far from clear what commitment the union was making in clause 2.6 of the Big W agreement as State occupational health and safety legislation does not impose duties on unions.

[27] The other point of distinction relied upon by his Honour was that the facts in the Big W decision were less complex than those arising in the present case “given that State legislation can be overridden by federal award provisions”. The ASU submits that this is not the case in relation to occupational health and safety laws and refers to s.170LZ(2)(a) of the WR Act.

[28] In reply the ATO submits that the Deputy President did not err in distinguishing the Big W decision. In Big W the Full Bench found that clause 2.6 of the relevant certified agreement imposed obligations that were additional to those required by State occupational health and safety legislation.22 A dispute about whether Big W was required to provide anti-fatigue matting was not merely a dispute about whether it was complying with its obligations under State legislation, but rather was a dispute about what the agreement required.

[29] It is argued that in contrast to the position in the Big W decision, clause 118 of the ATO Agreement does not impose obligations additional to the Misconduct Procedures. Indeed, it imposes no obligations at all, but merely records the ATO’s pre-existing obligations and its intention to comply with them. For this reason, the ATO submits that the present case can be distinguished from the Big W decision.

[30] In the alternative, the ATO submits that the Big W decision is clearly wrong and should not be followed. In this context it is said that a Full Bench of the Commission is not bound by, and may depart from, a decision of another Full Bench if it is satisfied that the earlier decision is clearly wrong.23

[31] It is submitted that the conclusion of the Full Bench in the Big W decision, that clause 2.6(a) of the relevant certified agreement imposed obligations additional to those in State legislation, is unsupported by reasoning. The Full Bench says only that clause 2.6(a) has the effect for which the appellant contends.24 It had earlier recorded the appellant’s contention “that clause 2.6(a) involved a commitment to achieve and maintain healthy and safe working conditions in all Big W workplaces and specified the means by which this ought to occur; ‘by abiding by all relevant Occupational Health and Safety legislation’”.25

[32] The ATO submits that this passage does not describe any obligation further to that arising out of the State legislation. A commitment to abide by State legislation is not an assumption of a new obligation or an obligation additional to that in the State legislation.

[33] In reply to the ATO’s submissions the ASU contends that the Full Bench in the Big W decision found that clause 2.6(a) of the agreement there under consideration imposed an “additional obligation” in the sense that a breach of state occupational health and safety law could be prosecuted under the WR Act. The obligation was additional in the sense that, rather than being limited to criminal enforcement by an inspector appointed under the Occupational Health and Safety Act 1985 (Vic),26 the obligations could be enforced both in the Commission as a dispute under the agreement and, perhaps, in the Federal Court pursuant to s.178 of the WR Act.27

[34] The ASU submits that the reasoning in the Big W decision is “refreshingly simple” and is clearly indistinguishable from the present case. Far from being “clearly wrong” as the Respondent submits, it is clearly correct. It is said that the Big W decision represents good law. It is not distinguishable from the present case and ought to have been followed.

[35] The ASU also submits that in assessing the Big W decision, the current Full Bench should adopt the “cautious approach” described in Cetin v Ripon Pty Ltd.28 The circumstances in which the Full Bench there departed from an earlier Full Bench decision were quite unusual and the present case bears no resemblance to those circumstances.

[36] Secondly, the Appellant challenges his Honour’s reliance on a series of cases dealing with letters of comfort.

[37] The Deputy President concluded that the opening line of clause 118 “simply expresses the ATO’s intention to comply with and carry out obligations established by the Public Service Act.” His Honour went on to say that the clause was “something of a letter of comfort given to the ASU and CPSU because of the concerns about application of the Agreement that they raised during negotiations”.29

[38] The reference to letters of comfort was a reference to a line of cases concerning contractual negotiations that are cited at paragraphs 29 to 35 of the Deputy President’s reasons. The Appellant submits that these cases are of little assistance to the Commission in the present matter. The circumstances in which letters of comfort are provided in the course of contractual negotiations is explained by Cheshire and Fifoot, in their book Law of Contract, as follows:

[39] The learned authors give as an example the case of Commonwealth Bank of Australia v TLI Management Pty Ltd31 (TLI Management), a case cited by the Deputy President. The ASU contends that in circumstances where a binding commitment has been sought and refused, it is far from surprising that courts have refused to bind the provider of the letter of comfort to its contents as a contractual promise.

[40] But it is argued that the facts of the present case are clearly distinguishable from those in TLI Management. In this context the ASU relies on Mr Lapidos’s evidence that, after promulgation of the ATO’s Misconduct Procedures on 1 January 2001, the ASU “became concerned that the Misconduct Procedures were not being properly implemented”32. The point was pressed during negotiations for the ATO (General Employees) Agreement 2002 between the parties and clause 118 was the result. The clause was replicated in the current ATO Agreement. It is submitted that there is no suggestion on the evidence that the ATO was unprepared to provide a binding commitment but instead offered a ‘letter of comfort’ as a compromise. In the circumstances it is said that it is highly unlikely that the parties would have mutually agreed that a non-binding commitment, which could not even be enforced in the Commission under clause 141, would meet the ASU’s concerns.

[41] In reply the Respondent submits that it is “abundantly clear” from his decision that the Deputy President did not consider that clause 118 was a letter of comfort. Rather it is said that he only referred to letters of comfort by way of an analogy and his construction of clause 118 was based on other considerations.

[42] The third and final aspect of the Deputy President’s reasons that is challenged by the Appellant relates to the proposition that the Misconduct Procedures are already highly regulated. The Appellant contends that there is no statutory obligation on the ATO to comply with the Misconduct Procedures, whether under either s.15 of the Public Service Act 1999 or elsewhere. It is submitted that the only relevant obligations imposed on the ATO by s.15 are to:

[43] Section 4 of the Public Service Act 1999 (Cth) provides that the ATO may not be prosecuted if it fails to comply with that Act. The ASU contends that what the Public Service Act 1999 (Cth) regulates is employee compliance with the code of conduct.

[44] The Appellant submits that in those circumstances it should come as no surprise that the parties would have agreed to the mechanism in clauses 141 and 118 of the ATO Agreement that enables some limited enforcement of the Misconduct Procedures. In the absence of those provisions, the Misconduct Procedures would be applied at the whim of the ATO.

[45] In relation to the concern raised by his Honour at paragraphs 50 and 51 about potential conflict between the Public Service Act 1999 (Cth) and the WR Act failed to have regard to s.8 of the Public Service Act 1999 (Cth), which provides that the Public Service Act 1999 (Cth) has effect “subject to the Workplace Relations Act 1996”. Further, any conflict that does exist can be considered in the second stage of the matter as anticipated at paragraph 11 of his Honour’s reasons for decision.

[46] The Respondent relies on the reasons given by the Deputy President for finding that clause 118 does not establish a procedural obligation, employee entitlement or condition, within the meaning of subparagraph 3(b) of Step 3 in clause 141.5 of the ATO Agreement. There is no dispute over the application of the ATO Agreement involving a matter in subparagraph 3(b), and the Commission is not empowered by Step 3 to do anything. The appeal should be dismissed.

Consideration

[47] This is an appeal pursuant to s.45(1)(g) of the WR Act. To succeed the Appellant must show that the Deputy President erred in refusing or failing to exercise jurisdiction. The issue for determination is whether the Deputy President erred in concluding that the Commission did not have jurisdiction pursuant to clause 141 of the ATO Agreement to determine the alleged dispute notified by the ASU.

[48] Clause 141.5 of the ATO Agreement empowers the Commission to “settle disputes over the application of [the] Agreement”. Whether the alleged dispute is a dispute “over the application of [the] Agreement” requires the determination of a jurisdictional fact.

[49] In Corporation of the City of Enfield v Developmental Assessment Commission the joint judgment of Gleeson CJ, Gaudron, Gummow, Kirby and Hayne JJ described the term “jurisdictional fact” in these terms:

[50] Similarly in Re CFMEU - Termination of Bargaining Periods, Lee and Madgwick JJ said:

[51] In dealing with an appeal from the determination of a jurisdictional fact a Full Bench of the Commission is concerned with whether the member at first instance reached the right conclusion. It is not concerned simply with whether the decision of the single member was reasonably open to him or her.35 As Gummow J pointed out in Minister for Immigration and Multicultural Affairs v Eshetu,36 a court or tribunal cannot give itself jurisdiction by erroneously deciding that a jurisdictional fact exists.

[52] In determining whether the alleged dispute notified by the ASU is a dispute “over the application of [the] Agreement” that expression should not be narrowly construed. In this context we agree with the observation of the Full Bench in Shop, Distributive and Allied Employees Association v Big W Discount Department Stores that:

[53] The determination of jurisdictional fact in this case turns on whether clause 118 of the ATO Agreement “creates an obligation, enforceable as a clause of the ATO Agreement, to properly apply the ATO Misconduct Procedures”.

[54] We make two general observations relevant to the proper construction of clause 118.

[55] The first is that the accepted approach to interpreting an industrial instrument was explained by Madgwick J in Kucks v CSR Ltd38:

[56] This approach was approved by a Full Court of the Federal Court in Ansett Australia Ltd v Australian Licensed Aircraft Engineers’ Association39, and was recently cited by two Judges of the High Court of Australia in Amcor Ltd v Construction, Forestry, Mining and Energy Union40.

[57] The industrial context in which an agreement is negotiated is relevant to determining the mutual intention of the parties to the agreement. As we have noted, the background to clause 118 was dealt with in the uncontested evidence of Mr Jeffrey Lapidos in the proceedings at first instance. At paragraphs 2 and 3 of his witness statement Mr Lapidos says:

[58] The second general observation is that the legislative context within which the ATO Agreement sits is also relevant. As Kirby J observed in Amcor Limited v CFMEU:

[59] The legislative context suggests that certified agreements give rise to binding obligations. While a certified agreement is in operation it prevails over an award or order of the Commission to the extent of any inconsistency with the award or order (s.170LY). Similarly, a certified agreement prevails over terms and conditions of employment specified in a State law, State award or State employment agreement to the extent of any inconsistency (s.170LZ). Where an organisation or person bound by a certified agreement breaches a term of the agreement a penalty may be imposed by the Court (s.178).

[60] We now turn to that part of clause 118 which is in issue.

[61] Relevantly, clause 118 of the ATO Agreement provides:

[62] It seems to us that in the context of this matter the expression “committed to ensuring” evinces an intention to create an obligation, enforceable as a clause of the ATO Agreement, to properly apply the Misconduct Procedures. As the Deputy President pointed out in the decision subject to appeal, one of the meanings of the word ‘commit’ is to “bind by pledge or assurance”. We also note that the word “ensuring” is a derivative of the word ‘ensure’, which means, among other things, “to pledge one’s faith to a person for the execution of a promise”.43 Hence, adopting the ordinary meaning of the words in the expression “committed to ensuring” suggests a binding obligation. The context within which the ATO Agreement was negotiated and the legislative context in which it sits also support that conclusion.

[63] We have considered the reasons advanced by his Honour for reaching the contrary conclusion but, with respect to him, we do not find them persuasive. We now turn to briefly deal with his Honour’s reasons, which are summarised at paragraph 16 of this decision.

[64] As to his Honour’s first reason, the fact that the commitment in clause 118 is expressed by the ATO alone and not as a mutually agreed term is of little weight. The Misconduct Procedure does not impose any obligation on the ASU. Hence, as conceded by counsel for the ATO, one would not expect the clause to say that the ASU is committed to complying with a procedure that does not impose any obligations upon it.44 In support of his conclusion the Deputy President also advances the proposition that there is “some degree of vagueness” about a legal obligation to “properly apply” an existing obligatory procedure. With respect to him, we do not agree. We see no “degree of vagueness” about an obligation to properly comply with a misconduct procedure.

[65] The second reason given is that the ATO’s Misconduct Procedures are enforceable by other means and hence it was unnecessary for them to be given force by the ATO Agreement. We accept that this is so, but it does not follow that the availability of alternative remedies means that the parties agreed that clause 118 would have no legal effect.

[66] The fifth and sixth reasons given by his Honour also make reference to the issue of “dual regulation”. We do not find these points persuasive.

[67] The existence of alternative means of enforcing compliance with the Misconduct Procedure does not of itself lead one to conclude that clause 118 was not intended to give rise to an enforceable obligation. Parties to agreements often confer a power of private arbitration upon the Commission in respect of disputes over the application of the agreement. Such a power is conferred despite the availability of an alternative remedy, namely enforcement in a court pursuant to s.178 of the WR Act.

[68] We acknowledge that there are other means available to the ASU to ensure that the ATO properly applies its Misconduct Procedures. But we also accept the Appellant’s contention that the alternative remedies available are costly and time-consuming when compared to proceedings in the Commission. The scope of the remedies available to the Commission may also be broader.

[69] Nor do we find his Honour’s third and fourth reasons persuasive. We acknowledge that the context in which clause 118 appears is a relevant consideration, but in our view that context does not compel the conclusion reached by his Honour.

[70] In this regard we note that in other parts of the ATO Agreement different language is used in circumstances where the provision is intended to be aspirational or prefatory, as opposed to an intention to give rise to a binding obligation. For example clause 120.1 states:

[71] Unlike clause 118 there is no reference in this provision to any commitment to ensuring a particular outcome.

[72] We conclude by briefly referring to that aspect of his Honour’s decision that deals with “letters of comfort”. We note at the outset that this point was not raised by any of the parties before his Honour, nor was it relied on by the ATO on appeal.45 For our own part, and contrary to his Honour’s view, we see no sound basis for regarding the opening sentence of clause 118 as “something of a letter of comfort given to the ASU”.46 We accept the submission advanced by the Appellant in this regard.47

[73] We are satisfied that the Deputy President erred in concluding that the Commission did not have jurisdiction pursuant to clause 141 of the ATO Agreement to determine the dispute notified by the ASU. We grant leave to appeal, uphold the appeal and quash his Honour’s decision.

[74] The dispute notification is remitted to the Deputy President for hearing and determination.

BY THE COMMISSION:

VICE PRESIDENT

Appearances:

P. Rozen, of Counsel for the Australian Municipal, Administrative, Clerical and Services Union.

R. Crow, of Counsel for the Australian Taxation Office.

Hearing details:

2005.
Melbourne:
July 19.

1 AG835215 PR948752.

2 Exhibit ATO6 in the proceedings at first instance, Appeal Book at tab PQ; exhibit ASU3 in the proceedings at first instance, Appeal Book at tab G at paragraph 7.

3 Names omitted as unnecessary at this stage of the proceedings.

4 Statement Detailing Determination, Appeal Book at tab C.

5 Exhibit ATO2 in the proceedings at first instance, s.15(3)(a) of the Public Service Act 1999.

6 Exhibit ATO2 in the proceedings at first instance, Appeal Book at tab L.

7 Exhibit ATO3 in the proceedings at first instance, Appeal Book at tab M.

8 Respondent’s written submissions in the proceedings at first instance, Appeal Book, tab F at paragraph 9.

9 PR957250 at paragraphs 43; see also exhibit R1 at paragraph 37.

10 PR957250 at paragraph 43.

11 PR957250 at paragraph 54.

12 PR957250 at paragraphs 43 – 45.

13 PR957250 at paragraph 46.

14 PR957250 at paragraph 48.

15 PR957250 at paragraph 49.

16 PR957250 at paragraph 50.

17 PR957250 at paragraphs 51 – 52.

18 Witness statement of Jeffrey Lapidos at paragraph 3.

19 PR924554, 12 November 2002 per Watson SDP, Kaufman SDP and Foggo C.

20 PR924554 at paragraphs 24 – 25.

21 See generally paragraphs 29 – 35 of his Honour’s decision.

22 See the Big W decision at paragraphs 28 – 29.

23 Cetin v Ripon Pty. Ltd. (2003) 127 IR 205 at paragraphs 48 – 50.

24 Big W decision at paragraph 29.

25 Big W decision at paragraph 13.

26 See s. 48.

27 See Big W decision at 28. The Appellant contends that this aspect of the decision was clearly obiter dictum.

28 (2003) 127 IR 205 at 214 (paragraphs 48 – 50).

29 PR957250 at paragraph 53.

30 Cheshire and Fifoot, Law of Contract (7th Australian edition), p. 193 (emphasis added).

31 [1990] VR 510.

32 Witness statement of Jeff Lapidos at paragraph 3.

33 (2000) 199 CLR 135 at 148.

34 (2002) 113 IR 241 at paragraph 53.

35 Pawel v Australian Industrial Relations Commission (1999) 97 IR 392 per Branson and Marshall JJ at paragraph 16.

36 (1999) 162 ALR 577 at paragraph 127. Also see R v Judges of the Federal Court of Australia; Ex parte WA National Football League (Inc) (1979) 143 CLR 190 at 214.

37 PR924554 at paragraph 23. Also see ASU v Qantas, Print T0301, 7 September 2000 per Munro J, Polites SDP and Cribb C.

38 (1996) 66 IR 182 at 184.

39 [2003] FCAFC 209.

40 [2005] HCA 10 at paragraph 96 per Kirby J and at paragraphs 145 – 146 per Callinan J.

41 Exhibit ASU3 of the proceedings at first instance at paragraphs 2 – 3.

42 [2005] HCA 10 at paragraph 64; also see paragraph 13 per Gleeson CJ and McHugh CJ; paragraphs 41 – 49 per Gummow, Hayne and Heydon JJ.

43 The Oxford Dictionary (1978) Volume III at p.205.

44 Transcript at PNs 218 – 221.

45 Transcript at PNs 235 – 245.

46 PR957250 at paragraph 53.

47 See paragraphs 36 to 41of this decision.

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