Scrutiny of Acts and Regulations Committee
Abalone - Taking Stock, Information Paper,
Review of the Fisheries (Abalone) Regulations 1996
December 1996
Table of Contents
Chairman's
Foreward
Introduction
The
Industry
The
Regulations
Meetings
and Visits
Additional
Submissions
Conclusions Appendices
1 - Regulations
2 - Regulatory Impact Statement
3 - Buckmaster RIS Submission
4 - VAPA - RIS Submission
5 - VADA - RIS Submission
6 - VAPA - SARC Submisison (1)
7 - VADA - SARC Submission (2)
8 - Academic Paper
9 - Newspaper Articles
The Fisheries (Abalone) Regulations were made by the Governor
in Council on 1 April, 1996. They came into operation on that day. Their
objective was to replace all previous regulation of the abalone industry
with a set of regulations which managed and controlled the abalone fishery
from the point of its taking in Victoria to the point of sale or export.
The Regulations do this primarily by introducing an "abalone audit
trail".
Before the Regulations were made, a Regulatory Impact Statement
had been prepared and circulated to explore questions of the cost and
benefit of regulating the abalone trade in Victoria. Consultation over
the Regulations had also taken place with major players. As a result of
the RIS, certain amendments were made to the draft Regulations that were
circulated with the RIS.
However, even after the Regulations were made, the Committee
received submissions from divers and processors in the central zone who
expressed their objections to aspects of the Regulations.
In the usual scrutiny which the Subordinate Legislation
Subcommittee undertakes of all regulations made under Acts of the Victorian
Parliament, there were one or two aspects which the Committee wished to
explore further. This Information Paper is a result of this examination.
It aims to better inform all readers of the nature of the abalone industry
and of the regulation of the trade which now applies in Victoria.
I am thankful for the co-operation which we received from
the Department of Natural Resources and the Environment, and for the interest
shown in the Regulations by the Victorian Abalone Divers Association and
Victorian Abalone Processors Association which first highlighted their
concerns with the new Regulations.
The Committee is empowered to move motions of disallowance
of Regulations where it has formed the view that the Regulations are in
breach of the Subordinate Legislation Act 1994. In the case of
the Fisheries (Abalone) Regulations 1996, the Committee will not move
such a motion. The Paper which you are about to read provides a range
of information about abalone and canvasses technical questions about the
Regulations.
I acknowledge with thanks the participation in this project
of my colleagues on the Subordinate Legislation Subcommittee: the Honourable
Maree Luckins, MLC, the Honourable Peter Katsambanis, MLC, the Honourable
Don Nardella, MLC and Ms Mary Gillett, MP. I am also grateful for the
assistance rendered by the Chairman of the Full Committee of the Scrutiny
of Acts and Regulations, Mr Peter Ryan, MP .
Finally, my thanks are extended to the staff of the Committee.
In particular, I would mention Tanya Coleman, Legal Researcher and Rhonda
MacMahon. Assistant Executive Officer. Other members of staff also played
their respective roles in bringing this document to fruition. They are
Helen Mason, Executive Officer; Stephen Robertson, who was Acting Assistant
Executive Officer during the early days of preparation of the Paper; Dominique
Saunders, Legal Researcher and Richard Kings, Office Manager.
Murray H. Thompson, MP
Chairman
Subordinate Legislation Subcommittee
FISHERIES (ABALONE) REGULATIONS 1996
The Committee has examined the Fisheries (Abalone) Regulations
1996. These Regulations are reproduced as Appendix 1 to this Information
Paper.
The Committee has resolved not to recommend that the Parliament
disallow the Fisheries (Abalone) Regulations either in whole or in part.
It will not recommend that the Parliament amend the Regulations in any
particular way. It notes that amending Regulations to parts of the Regulations
are planned with anticipated improvement to the administration of the
Regulations.
The Committee recommends this Information Paper to Members
of Parliament and to the public generally as an example of the
nature of the work the Committee performs with respect to the scrutiny
of Regulations made under Acts of the Parliament of Victoria.
The Committee meets in Subcommittee to examine regulations
(also called subordinate legislation) made under principal Acts. Its recommendations
form the basis of this document, and have been adopted by the Scrutiny
of Acts and Regulations Committee (SARC) in Full Committee.
Abalone is a marine snail that is greatly appreciated as
a food in Asia. The most abundant species found in Victorian waters is
the blacklip abalone. These are found in reef areas from the low-tide
zone to depths of about 30 metres. As adult abalone do not move far ,
divers are restricted to a known 121 square kilometres (approximately)
of inshore reef area. This area supports the abalone populations which
are exploited by the Victorian commercial fishery. Some suggest that Victoria
is responsible for as much as 10-14% of the world production of abalone.
Appendix One to the Regulatory Impact Statement (RIS) describes
abalone biology in this way:
Growth rates differ from site to site according to environmental
factors such as water flow and food availability. Abalone from sheltered
waters grow more slowly than those from exposed reef areas where higher
water exchange provides more food in the form of drifting seaweed. First
maturity is normally at four years of age, and breeding takes place annually.
Juvenile abalone settle locally in response to stimuli provided by grazing
of adults.
The biology of abalone makes them particularly vulnerable
to over exploitation and illegal fishing. Failure in the breeding and
juvenile settlement cycle is a common feature of overfished abalone fisheries
throughout the world. Once depleted, abalone stocks do not generally recover
quickly. (RIS p. 34)
The RIS is reproduced as Appendix 2 to this Information
Paper. The RIS accompanied the making of the Fisheries (Abalone) Regulations
1996.
The formula for the cost of an annual licence fee for a
diver is set out in section 15(1)(d) of the Fisheries Act 1968 and
for 1996-1997 is $46,334.20. The cost of the business of abalone diving
(ie the annual licence fee plus the on-going value of the business) was
revealed by bidding at a recent public auction as in excess of $3,000,000.
One abalone can be described loosely as worth a $10 dollar
note. This is because the beach price for standard processor abalone is
$25 per kilogram which is about 3 abalone. With the right market connections,
a diver could get $30 per kilogram for live abalone. The live trade, although
prized, is less than 10% of the total legal Victorian catch.
While it is hard to accurately put a figure on it, it seems
that illegal abalone can be bought for $5 each (rather than $10). This
cheaper price includes the risk of detection which a seller or purchaser
runs.
Victorian waters are divided into three zones - western,
central and eastern zone. A Total Allowable Catch (TAC) is set for each
of the zones. Within that TAC there is an individual quota for each licensee
(diver) of 20 tonnes in the eastern and western zones and 20.58 tonnes
in the central zone. The individual quota can normally be reached in less
than 70 days of diving, although weather conditions vary from zone to
zone which may extend that period. The central zone includes Port Philip
Bay where the smaller abalone favoured for the live trade market may be
caught. The small size of these abalone also impact on the number of days'
fishing required to reach the individual quota. Divers may also purchase
extra quota throughout the year which would increase their fishing days
- and their profit - but when the new year starts, each diver who pays
the abalone licence fee is granted the same quota.
All licence holders are subject to steep penalties, including
forfeiture of quotas and loss of licence as appropriate, for non-compliance
with licence conditions or overfishing or being found with abalone for
which there is no corresponding abalone docket or for other breaches of
the Regulations currently under examination (see, for example, Part III
of the Fisheries Act 1968 as well as Part 5 of the Fisheries (Abalone)
Regulations 1996).
There are three types of personal licences issued under
the Fisheries Act 1968 with respect to abalone. These are the licence
to take abalone for sale also called an abalone licence (for a diver);
the abalone processor's licence (to process abalone for sale) and the
abalone storer's licence (to store abalone) (see section 13(1) of the
Fisheries Act). Methods of calculating the relevant fee are set out in
section 15 of the Fisheries Act.
The Fisheries Act, and the Regulations made under it, fall
within the Department of Natural Resources and the Environment (DNRE).
When the RIS was being prepared, the Department was known as the Department
of Conservation and Natural Resources (DCNR).
It is not within the Committee's role to examine the questions
of policy behind Regulations. Rather, the Committee considers issues raised
by section 21(1) of the Subordinate Legislation Act 1994. These
include whether the statutory rule:
(h) is inconsistent with principles of justice and fairness;
(j) has been prepared in contravention of any of the provisions
of this Act or of the guidelines with respect to the statutory rule and
the contravention is of a substantial or material nature; or
(k) is likely to result in administration and compliance
costs which outweigh the likely benefits sought to be achieved by the
statutory rule.
The Committee has considered reporting to the Parliament
on the basis of section 21(1)(h), (j) and (k) of the Subordinate Legislation
Act.
The Committee considers that provisions which impose extremely
narrow time limits may be inconsistent with principles of justice and
fairness (s.21(1)(h)). Amendments to the Regulations extending certain
time limits are foreshadowed, and the Committee is inclined not to report
given these imminent changes.
The Committee has evaluated concerns that the Regulatory
Impact Statement does not simply and fully explain why regulation is required
in this area and that, accordingly, the Regulations may be in contravention
of section 10(1) of the Subordinate Legislation Act and Parts 3 or 4 of
the Premier's Guidelines made under section 26 of the Act. Reporting to
the Parliament on this basis is possible under section 21(1)(j) of the
Subordinate Legislation Act. After a full examination of the many issues
raised, the Committee has chosen not to report under this principle.
Finally, a number of submissions were made on the RIS and
to the Committee in relation to compliance costs but, while the precise
volume of illegal activity cannot be ascertained, the Committee took the
view that the likely benefits sought to be achieved are in excess of the
alleged high compliance costs. Thus, reporting under section 21(1)(k)
of the Subordinate Legislation Act is not appropriate.
The Committee is aware of the economic importance of the
industry to Victoria as well as the importance of maintaining a sustainable
abalone fishery.
The commercial fishery in Victoria has been a limited entry
fishery since 1968. (see sections 13A to 13D of the Fisheries Act). These
restrictions have meant that only holders of an abalone licence can take
abalone for sale in Victoria. There are particular provisions relating
to small non-commercial or recreational abalone taking as developed in
Part 2 of the Regulations. Management of the processing sector is also
seen as important because of its link to valuable export markets.
The Regulations establish a new framework for the management
and control of the abalone fishery in Victoria. The framework comprises
several features. These include the requirement that abalone taken by
licensed divers be landed in sealed bins, as well as the introduction
of an abalone transfer certificate scheme. Certain existing provisions
are enhanced. Each of these components has been instituted with the aim
of supporting the audit trail scheme to ensure better the sustainability
of the abalone fishery.
Some of the new provisions impose very strict and brief
time limits by which certain actions must be taken. For example, with
respect to the taking and landing of abalone, Part B of the relevant abalone
docket must be completed by divers within 30 minutes of landing (reg.
17(1)(l)). Within 15 minutes after the time of an abalone processor receiving
abalone, if Part B of the duplicate and triplicate copies of the abalone
docket has not been completed, the processor must notify the Secretary
(reg. 20(1)(e)). Regulation 21(2)(a) requires a consignment of abalone
without a docket to be weighed and notified and recorded within 30 minutes.
The penalty for failure to comply with a condition (such as these are)
is 10 penalty units as well as possible cancellation of the licence (section
17 (2) of the Fisheries Act). The question arises as to why there is such
a hurry. The RIS explains these provisions but does not offer reasons
for the urgency. The urgency is in marked contrast to the more relaxed
requirement to notify the Secretary within 72 hours if the telephone number
of the fax machine is changed (reg. 23(1)(b)(iii)).
The RIS describes the impact of these Regulations on divers
with regard to time constraints in a manner which highlights some of the
advantages of the scheme. For example, with respect to divers:
There is a reduction in the number of dockets to be completed
annually from 365 to approximately 70 assuming each landing is sent to
one processor or interstate destination. Divers will no longer be limited
to selling to one processor each day and will also be able to sell directly
interstate. This will allow divers to maximise their marketing opportunities.
(p.16 RIS)
With respect to processors, the RIS states:
Processors will be required to comply with completion of
paperwork and have available a phone and fax service when receiving abalone
at their premises. Staff will need to be trained to ensure that legal
provisions are complied with. There will be some costs in terms of staff
duties, phone and fax costs and possible short time delays between receipt
of abalone and commencement of processing. (p.17 RIS)
The DNRE has accommodated one of the time issues raised
by processors in submissions on the RIS. This concerned the requirement
in the Regulations circulated with the RIS that the weighing and documentation
of interstate abalone comply with the 30 minute time limit. The Regulations
were amended prior to making so that there is no obligation to comply
with the strict 30 minute deadline if the licensed abalone processor has
obtained the Secretary's approval in writing for an extension of time
to comply. This accommodation illustrates the DNRE's willingness to amend
where it is persuaded that change is appropriate.
Such brief time limits, could have been considered reportable
by the Committee on the basis of being inconsistent with principles of
fairness under section 21(1)(h) of the Subordinate Legislation Act. Changes
are expected in due course with respect to time restrictions applicable
to processor requirements. These planned amendments indicate Departmental
openness to supportable complaints.
Section 10 of the Subordinate Legislation Act spells out
what a RIS must include. In this list is:
(a) a statement of the objectives of the proposed statutory
rule;
(c) a statement of other practicable means of achieving
those objectives;
(d) an assessment of the costs and benefits of the proposed
statutory rule and of any other practicable means of achieving the same
objectives; and
(f) any other matters specified by the guidelines.
It may be that the Fisheries (Abalone) Regulations do not
comply with section 21(1)(j) of the Subordinate Legislation Act because
the regulations have been prepared in contravention of the statutory requirements
for RISs.
On a perfunctory reading of the RIS, it appears that there
is an unsubstantiated premise that there is illegal diving for and processing
of abalone and that regulation to prevent such activity is essential.
The RIS contains assertions such as the following:
The rise in value of abalone has led to increased levels
of illegal fishing by poachers who are conducting increasingly sophisticated
illegal operations. (RIS p. 8)
It is estimated that Australia wide there is more than 700
tonnes of abalone exported annually which cannot be accounted for by combined
legal production in abalone producing States. The annual value of the
Victorian component of this illegal trade is proportionately estimated
at $10 to $12 million.(RIS p. 9)
There is no specific source for these assertions other than
a reference to the National Compliance Committee of the Standing committee
for Fisheries and Aquaculture which has identified illegal fish sales
as a national problem. (RIS p. 27)
Portland Ocean Trading Pty Ltd expresses its dismay at the
allegations in the RIS this way:
We wish to express our dismay at the continued use of a
figure of 700 tonnes of illegal abalone per year. Our company researched
the matter of reconciling the export figures and production figures. We
found out from D.P.I. that not only has such an exercise not been done
but that the database is so corrupted by sloppy recording that it is impossible
to draw any conclusion at all. Yet this assertion, about the 700 tonnes,
is still in the public arena and amplified by the media.
The uncritical repetition of unsubstantiated and totally
impossible figures by some Government officials, divers and enforcement
officers not only transcend the normal bounds of self interested exaggeration
but threatens the status of a valuable Australian fishery (in) the international
market Not to mention poisoning relationships between the D.C.N.R. and
stakeholders.
This company is appalled at the continued assertions regarding
large scale evasion and finds it hard to operate in such an atmosphere.
(submission on the RIS dated 6 March, 1996)
Both diving groups and processors resent the implication
of the RIS that there is large scale illegal activity and that the regulations
need to be in place to limit this.
For example, one writer discusses the RIS in this way (Appendix
3):
My first impression was of a document very heavy on allegations
and very light on evidence. Further and more careful scrutiny did little
to change that initial reaction, but instead raised in my mind the very
serious question of accountability for the claims made.
I could find very little evidence of any rigorous analysis
regarding risk assessment, economics, or presumed effects of management
actions, harvesting etc.) on abalone populations. This lack of reasoned
argument is most disturbing in a formal public document...
I suggest that most readers of the RIS will be left with
an impression of an enforcement-driven document, characterised by an array
of unsubstantiated assertions and a distinct lack of compelling evidence
to support them.
The DNRE response to this writer was that the RIS was approved
by the Office of Regulation Reform who certified that the cost benefit
analysis was adequate.
The objectives of the Regulations relate to proper and serious
matters such as ensuring the sustainable use of Victoria's abalone resources
(reg. 1 (a)) but the RIS appears to be drawn on a wider canvas of illegal
activity. Indeed, the new measures in the Regulations together with the
strengthened former provisions are said "to increase the likelihood
that illegally caught abalone will be detected when it is laundered into
the export chain" (RIS p. 5).
Statements such as this give the Regulations an aura of
achievement beyond what it is that the Regulations actually attempt to
do. The regulations establish a reasonably onerous scheme under which
those who benefit from the licensing regimen pay a price of compliance
with rules covering method of presenting the catch etc. Illegal poaching
is not controlled by the Regulations except tangentially by means of the
paper trail.
The RIS gives the impression that the Regulations control
the illegal abalone trade. While the audit trail increases the difficulty
for illegally caught abalone to find a market, there is still a range
of illegal activity not ameliorated by the Regulations. For example, illegal
abalone from Victoria is sold (either dried or in long-life packets) to
Asian visitors to Australia from car boots outside theme parks on the
Gold Coast of Queensland and also in Cairns. The value of a single car
boot of abalone sold in this way could be as much as $40,000.
This focus of the RIS was seen by most respondents to the
RIS as a slur on the abalone trade, and was one to which the Department
of Conservation and Natural Resources responded by asking those troubled
by the claim to present material disproving it. For example, in a letter
from the Department to the Chairman of the Victorian Abalone Processors
Association (4 January, 1996) the Acting Manager of Victorian Fisheries
writes:
If you have information to suggest that the national estimate
of 700 tonnes of illegal trade in abalone is incorrect, we would welcome
your advice and are prepared to submit any information that you can provide
for the consideration of the Compliance Committee.
Arguably, such a responsibility should not lie on divers
and processors but rather the overcoming of illegal activity should have
been explored and presented as a regulatory objective, with reasons for
eliminating illegal activity clearly formulated and defined (see p. 3404,
G 51 22 December 1994 - the Premier's guidelines).
It should be noted, however, that the letter mentioned above
of 4 January, 1996 continues:
The correspondence from VAPA indicates that offence has
been taken by some processors in relation to allegations of possible involvement
by processors in illegal activities. The Department has not intended to
offend any processor. It is a fact, however, that a number of processors
have been successfully prosecuted in recent times. Furthermore, a number
of Departmental staff are concerned that shortcomings in current regulations
may have contributed to a number of instances where the law was insufficiently
robust to allow prosecutions to proceed against suspected offences. The
intent of the proposed regulations is to improve the law to ensure that
legislative intent can be realised.
In the DCNR's summary of the Submissions on the RIS, the
DCNR asserts in response to suggestions of a slur against the abalone
industry found in the RIS from VAPA, VADA, Buckmaster and Portland Ocean
Trading Pty Ltd that:
A large percentage of the Department's Special Investigations
Group investigations involve abalone offences where licensed processors
are involved in handling poached abalone. Organised crime can be defined
as conspiracy by groups of individuals engaged in take, possession and
sale of abalone to subvert the regulatory framework in an organised manner.
Large scale organised illegal fish harvesting and selling have been detected
and successfully prosecuted. Five Victorian licensed processors have been
taken to court on abalone and related fraud offences, and found guilty.
Two cases are pending and two further investigations are ongoing.
The Committee has often stated that a RIS need not be an
economic or philosophical treatise but rather present simply and fully
the reasons why regulation is required in the area. It may be argued that
the RIS fails in this regard because it does not properly convey the reason
why regulation of this activity is sought.
Evidence in support of why the new audit trail approach
is regarded favourably could include prosecution statistics, confirmed
reports of illegal practices, or newspaper or other media accounts of
unlawful practices. The Committee could expect to see that the nature
and extent of the problem of illegal fishing by poachers would be documented
in greater detail than is present in the RIS. It is not sufficient to
declare that the objectives of the Regulations are to provide a consolidated
framework for the management and control of the Victorian abalone fishery
and then to premise much of the regulatory apparatus on a proportional
estimate of the Victorian component of illegal trade within Australia.
Such failure could amount to the statutory rule having been
prepared in contravention of a provision of the Act. Under section 21(1)(j)
of the Act the Scrutiny Committee could report this to a House of the
Parliament. The Committee has examined the issues raised and presents
this discussion of those concerns so that DNRE and other Departments will
be conscious of the importance of accurately reflecting in an RIS the
objective of proposed Regulations.
Except for the matters raised above, the RIS appears to
comply with section 10 of the Subordinate Legislation Act.
During the RIS process not all those who made submissions
on the Fisheries (Abalone) Regulations opposed the Regulations. It would
seem that the abalone industry is quite strongly divided.
There is a response from one amateur abalone fishing group
which expresses concerns that there continues to be a restriction on the
taking of Greenlip abalone. In reply, the Department suggests that these
issues will be further addressed in the Draft Abalone Management Plan
which was issued in May, 1996. Some respondents have urged that the appropriate
time for the making of these regulations was after the making of
the Abalone Management Plan.
As mentioned at the outset, it is not for the Committee
to examine questions of policy such as timing. The Committee observes
that it received a copy of the Draft Abalone Management Plan and that
aspects of control of the abalone fishery appears to be under review.
Smaller processors have expressed satisfaction with the
Regulations. One even supplied information not given in the RIS of a scheme
which breaches the intent if not the letter of the former regulations
- but the loophole, the Department advises, cannot be closed. (see Submission
from Pacific Prime Pty Ltd and DCNR reply found at Appendix 4).
The Victorian Abalone Divers Association Inc (VADA) and
the Victorian Abalone Processors Association Inc (VAPA) object strongly
to the new Regulations and to a perceived haste in implementation and
lack of consultation (see paras 14 and 15 below).
The Department strongly believes that it has done all it
could be expected to do in the consultation and RIS process. It has offered
to do almost whatever would make it easier for the participants to comply
with the Regulations. However, apart from the acceptance of written approvals
given by the Secretary under regulation 32 there has been little response
to the Department's offer.
In the earlier consultation phase, it seemed as if all parties
were satisfied with the approach taken and Departmental officers were
surprised to receive RIS replies expressing dissatisfaction. It notes
that the 3 major processors (whose correspondence is referred to below)
are not members of VAPA and that they are satisfied with the Regulations.
The Department recalls meetings where high compliance costs were alleged
by processors who could not detail the amounts claimed.
The Committee received copies of letters from the Abalone
Fishermen's Co operative Ltd in Mallacoota, the Western Abalone Divers
Association of Warrnambool and the Victorian Fishing Industry Federation
Inc centred in Melbourne. These groups are quite happy with the Regulations
and the consultative process which led to their introduction. Their correspondence
was with the Minister and confirmed their support for the Fisheries (Abalone)
Regulations.
The Western Abalone Divers Association writes:
....we believe that it is important for our industry (to)
be demonstrably honest at all levels. The new Regulations ensure this
and in the future, will enable abalone divers to avoid any of the suspicion
that seems to have appeared in recent years. (3 May, 1996)
The Abalone Fishermen's Co-operative writes:
Our purpose in writing to (the Minister) is to express
our support and satisfaction with the above regulations which were developed
after wide ranging and extensive consultation with all sectors of the
abalone industry in Victoria. In fact the consultation process extended
over approximately two years and representatives from our organisation
were extensively involved in the development and consultation process
from both the catching and processing perspectives.
As with any regulatory regime there are costs involved,
but in our view the costs of compliance have been minimised and we believe
the costs will prove to be far outweighed by the benefits accruing from
a healthier and more productive and accountable industry at all levels.
(3 May, 1996)
The RIS presents the costs and benefits of the Regulations
and details the costs in Appendices 2 to 4 to the Statement. The Office
of Regulation Reform has certified that the assessment appears adequate
for the purposes of section 10(3) of the Subordinate Legislation Act.
However, respondents to the RIS dispute the purported benefits
and outcomes. One suggests that there is "very little evidence of
any rigorous analysis regarding risk assessment, economics or presumed
effects (of management actions, harvesting etc.) on abalone populations"
(see letter 4 March 1996, in Appendix 3). VAPA contends that the statements
of impacts on processors are inaccurate and misleading, particularly regarding
costs and duplication of existing paperwork (see Submission on RIS from
the Victorian Abalone Processors Association Inc in Appendix 5).
Some divers also complain of the cost of compliance with
bin tagging and docket completion required by the Regulations. However,
as the industry is very profitable, and the resource itself has both natural
and financial value to Victoria, the costs of compliance may be seen as
proportionately small.
In the letter referred to in Paragraph 8 above, the Abalone
Fishermen's Co-operative makes just this point. The Chairman of the Co-operative
goes on to say:
In this regard I must note that our organisation and member
divers have already expended funds and developed systems to ensure compliance
with the regulations and would be extremely concerned if that investment
is wasted.(3 May, 1996)
The question of administrative costs outweighing likely
benefits is one on which the Scrutiny Committee could have reported to
the Parliament under section 21(1)(k) of the Subordinate Legislation Act.
However, the Committee believes that on balance the administrative costs
are not excessive to divers or processors.
CONTINUE browsing ABALONE
- TAKING STOCK INFORMATION PAPER
Scrutiny
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