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.13/10/2017 (25) 2785

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INQUIRY UNDER THE CHARITABLE FUNDRAISING ACT 1991

Public Hearing

Held at

Level 3, LPI Building

Queens Square

1 Prince Albert Road

Sydney, New South Wales

On Friday, 13 October 2017 at 10.00am

(Day 25)

BEFORE: The Public Inquirer,

The Hon. P A Bergin SC

Anthony Cheshire SC

Ms Jennifer Single

Mr Enzo Camporeale

.13/10/2017 (25) 2786 R G COLLINS (Mr Cheshire)


1 PUBLIC INQUIRER: Yes, Mr Cheshire.

2

3 MR CHESHIRE: Thank you, Madam Inquirer. I call

4 Robyn Collins.

5

6 PUBLIC INQUIRER: Yes, come into the witness box, please,

7 Ms Collins.

8

9 MR HERZFELD: Madam Inquirer, I should just announce my

10 appearance. My name is Herzfeld. I appear for WBI as

11 I did before, but I also appear for Ms Collins personally.

12

13 PUBLIC INQUIRER: Yes, I think leave has been granted to

14 you, Mr Herzfeld.

15

16 MR HERZFELD: It has, yes.

17

18 PUBLIC INQUIRER: Please take a seat, Ms Collins.

19

20 <ROBYN GAI COLLINS, sworn: [10.00am]

21

22 <EXAMINATION BY MR CHESHIRE:

23

24 MR CHESHIRE: Ms Collins, would you give the

25 Public Inquiry your full name, please?

26 A. Robyn Gai Collins.

27

28 Q. What is your professional address?

29 A. Level 7, 245 Castlereagh Street, Sydney.

30

31 Q. What is your current occupation?

32 A. I'm the General Manager of RSL WBI and RSL (NSW).

33

34 Q. You have, I think, prepared a statement in this matter

35 dated 9 October 2017; correct?

36 A. Yes.

37

38 Q. That statement has three volumes of exhibits to it;

39 correct?

40 A. Three?

41

42 PUBLIC INQUIRER: Q. Yes, it does.

43 A. Yes.

44

45 MR CHESHIRE: Madam Inquirer, I tender that statement with

46 the exhibits, which I think will be Exhibit 25,

47 volumes 1, 2 and 3.



1

2 EXHIBIT #25 STATEMENT OF MS ROBYN GAI COLLINS, TOGETHER

3 WITH EXHIBITS, VOLUMES 1, 2 AND 3

4

5 MR CHESHIRE: Q. Ms Collins, I think it is right that

6 you have been General Manager of WBI since 2012; is that

7 correct?

8 A. Yes.

9

10 Q. You have more recently become the General Manager of

11 RSL (NSW); correct?

12 A. Yes.

13

14 Q. When did you take up the position of General Manager

15 of RSL (NSW)?

16 A. I signed the contract on 15 August of this year.

17

18 Q. When did you commence in the position?

19 A. The contract was backdated until 1 August, but in

20 terms of handling matters, 15 August.

21

22 Q. Just to be clear, when you say the contract was

23 backdated to 1 August, does that mean that you were

24 performing, at least partly, the role of RSL (NSW) from

25 1 August?

26 A. I was learning about RSL (NSW), yes.

27

28 Q. As it were, a handover period, is that right, in those

29 two weeks between the 1st and the 15th?

30 A. I'm not sure what you mean by "handover".

31

32 Q. I'm just trying to work out, did you start work in the

33 role on 1 August for RSL (NSW)?

34 A. I don't - not fully, no.

35

36 Q. But partly?

37 A. Partly, in terms of learning. Would you like me to

38 explain?

39

40 PUBLIC INQUIRER: No, just wait for the next question.

41

42 MR CHESHIRE: Q. That's fine. When you commenced with

43 WBI in 2012, as I understand it, you understood that you

44 were going to be responsible for the overall management of

45 the whole of the WBI; is that correct?

46 A. Yes.

47



1 Q. In fact, that turned out not to be the case; correct?

2 A. Yes.

3

4 Q. As I understand it, WBI is, or at least was, made up

5 of at least two parts, one of which was DefenceCare;

6 correct?

7 A. It wasn't called DefenceCare then, it was called the

8 Defence Services Assistance Centre.

9

10 Q. That subsequently became DefenceCare; is that correct?

11 A. Yes.

12

13 Q. And that part of WBI provides a range of services to

14 current and former Defence personnel and their dependants;

15 is that right?

16 A. Yes.

17

18 Q. There is also another part of WBI, as I understand it,

19 which is known as RSL Active?

20 A. Now it is known as RSL Active, yes.

21

22 Q. It previously had a different name, but it performed

23 the same role; correct?

24 A. I'm not sure. I wasn't involved in that at that time.

25

26 Q. All right. Whatever it was known as, RSL Active, as I

27 understand it, encourages veterans and serving members of

28 the Defence Force to participate in various sporting

29 programs; correct?

30 A. Yes.

31

32 Q. Is that the entirety of WBI, being DefenceCare on the

33 one hand and RSL Active on the other?

34 A. Can I clarify? Is that the entirety of when I started

35 or now?

36

37 Q. Let's take when you started?

38 A. When I started, no, it wasn't the entirety of WBI.

39

40 Q. What was the extra bit when you started?

41 A. There was a national veterans affairs adviser who was

42 an employee of WBI whose role, I understand, was reporting

43 in some way part of RSL National.

44

45 Q. DefenceCare, RSL Active and that adviser, was that

46 then the entirety of WBI when you started?

47 A. As I understood it.



1

2 Q. As things are currently constituted, it is DefenceCare

3 and RSL Active without the adviser; is that right?

4 A. Yes.

5

6 Q. Am I right as well that DefenceCare, or what became

7 DefenceCare, provides two particular parts, one of which is

8 community support and one of which is what you've referred

9 to as claims and advocacy; is that correct?

10 A. Yes.

11

12 Q. And again, that's the entirety of DefenceCare; is that

13 correct?

14 A. Yes.

15

16 Q. When you commenced with WBI, as I understand it, it

17 became clear to you that, in fact, your role was limited to

18 the DefenceCare side; is that correct?

19 A. Yes.

20

21 Q. Am I right that you were, as you saw it, effectively,

22 excluded from the RSL Active side?

23 A. Yes.

24

25 Q. The finances of WBI as a whole, am I right, that also

26 you found yourself, effectively, excluded from those; is

27 that right?

28 A. Yes.

29

30 Q. Was any formal direction ever given to you to say to

31 you that you were limited to DefenceCare? Let me put it a

32 different way. Were you told, in effect, that you are only

33 to deal with DefenceCare or was it simply that's the way

34 that things developed?

35 A. Could I explain it a little bit? It is probably a

36 little bit the way things developed.

37

38 Q. All right. Did you at any stage raise with anybody

39 within WBI the fact that you weren't, as you saw it,

40 performing your role as General Manager of WBI?

41 A. Specifically in that way, raised that direct question?

42

43 Q. Yes.

44 A. I'm really having trouble recalling whether I actually

45 raised that direct question or whether it was more a series

46 of discussions.

47



1 Q. When you say a series of discussions, to whom did you

2 report?

3 A. The trustees.

4

5 Q. Was there anybody on the same level as you or was

6 everybody supposed to, as you understood it, report up to

7 you and you on to the Trustees?

8 A. Can I clarify? Before I walked in - do you mean was

9 it my understanding every one was reporting to me when

10 I walked in the door?

11

12 Q. When you walked in the door, was it your understanding

13 that everybody would report to you?

14 A. Yes.

15

16 Q. In fact, did that turn out to be the case?

17 A. No.

18

19 Q. So the RSL Active side, in respect of which you had,

20 you say, no involvement, did anybody report to you from

21 that side?

22 A. No.

23

24 Q. The financial side of the entirety of WBI, which

25 I think you said was effectively controlled by Ms Mulliner;

26 is that correct?

27 A. Yes.

28

29 Q. Did she report to you?

30 A. No.

31

32 Q. So, to your understanding, she reported to the

33 trustees; is that correct?

34 A. Yes.

35

36 Q. Not only in what you did day to day, but in your

37 reporting it was as if you were the general manager of

38 DefenceCare; correct?

39 A. Yes.

40

41 Q. You have, in your exhibit, prepared a number of

42 organisational charts; is that correct? Do you recall that

43 you have produced some organisational charts?

44 A. Produced them, yes. I didn't prepare them. Some of

45 them were - I found in records.

46

47 Q. All right. Perhaps you could be provided with



1 volume 1.

2 A. Thank you.

3

4 Q. Would you turn to tab 11. This is, I think, a chart

5 that predates your arrival; correct?

6 A. Yes.

7

8 Q. Would you turn to tab 12. I think, likewise, that

9 predates your arrival; is that right?

10 A. Yes.

11

12 Q. Tab 13, that's a more recent version because that

13 includes you; correct?

14 A. More recent than the previous one?

15

16 Q. Yes.

17 A. Yes.

18

19 Q. And as I understand it, you prepared this chart;

20 correct?

21 A. Yes.

22

23 Q. That's limited to DefenceCare rather than being a

24 chart of WBI; is that right?

25 A. Yes.

26

27 Q. Could we turn over to tab 14. As I understand it,

28 that the is current organisational chart that shows WBI;

29 correct?

30 A. Yes.

31

32 Q. When I say current, we have you in the middle as GM,

33 RSL (NSW); is that right?

34 A. And WBI, yes.

35

36 Q. So that's intending to show you covering both

37 positions; is that right?

38 A. Yes.

39

40 Q. I think, in your statement you talk about, as it were,

41 getting control back over the whole of WBI and that shows

42 that after that has occurred; correct?

43 A. Yes.

44

45 Q. You, I think, is it right, were described from time to

46 time as general manager of DefenceCare; correct?

47 A. Yes.



1

2 Q. Did you ever raise the issue of the fact you were

3 being described as something that you thought you weren't,

4 in that you thought you were general manager of WBI, but in

5 fact you were being treated as general manager of

6 DefenceCare?

7 A. Could you just ask that again, sorry? I just --

8

9 Q. As I understand it, you were described, from time to

10 time, as general manager of DefenceCare; correct?

11 A. Yes.

12

13 Q. How did you describe yourself? Did you describe

14 yourself in that way or as general manager of WBI?

15 A. General Manager DefenceCare.

16

17 Q. And that was because you saw that as being the role

18 that in fact you were carrying out; is that right?

19 A. Yes.

20

21 Q. So you did not describe yourself as General Manager of

22 WBI; is that correct?

23 A. No.

24

25 Q. That is correct, you didn't?

26 A. Sorry, I didn't. Yes, that's right, sorry.

27

28 Q. Even though your contract referred to you as

29 General Manager of WBI; is that right?

30 A. Yes.

31

32 Q. When you commenced with WBI, as I understand it, you

33 became aware of what were described as decompression trips;

34 is that correct?

35 A. Yes.

36

37 Q. Those decompression trips, were they on the side of

38 DefenceCare or on the side of RSL Active?

39 A. RSL Active.

40

41 Q. Those trips, I think, ceased after a time; is that

42 correct?

43 A. That's my understanding, yes.

44

45 Q. Did you have any role in raising issues about those

46 trips?

47 A. Any role?



1

2 Q. Did you raise any issues about those trips?

3 A. I raised one.

4

5

Q.

All right. Who did you raise that with?

6 A. If I recall, I think it was Mr Perrin.

7

8 Q. What did you understand Mr Perrin's position was?

9 A. Trustee and - a Trustee of WBI.

10

11 Q. What issue did you raise with Mr Perrin?

12 A. The fact that I was worried that there weren't

13 specialists going along with people who were severely ill

14 and that there had been reports in the ex-service community

15 at the time of a lack of specialist support during trips

16 where people were severely ill and had mental health

17 issues, and I asked if there were appropriate specialists

18 going along.

19

20 Q. So these trips, as I understand it, were for either

21 current service people, is that right, or veterans, or just

22 for veterans?

23 A. I'm not 100 per cent sure. Would you like my

24 recollection?

25

26 Q. Yes, what was your understanding?

27 A. My recollection was there were some current serving

28 and veterans.

29

30 Q. Who had psychological issues; is that right?

31 A. I don't know for sure but I think that was

32 what - that's my recollection of what was said.

33

34 Q. Where were they being taken on these trips, as you

35 understood it?

36 A. I only have recollection of one in Hellfire Pass.

37 I don't know the others, sorry.

38

39 Q. Your belief was that if people who were unwell were

40 taken there, they needed to have proper qualified support;

41 is that right?

42 A. That was my belief.

43

44 Q. Do you know whether your complaint or issue that you

45 raised had anything to do with them being ceased, those

46 trips?

47 A. I have no idea.



1

2 Q. It was a matter that was outside of DefenceCare;

3 correct?

4 A. Yes.

5

6 Q. It was outside the role that you were actually

7 carrying out; correct?

8 A. Yes.

9

10 Q. May we take it, then, that from time to time, even

11 though your role was limited to DefenceCare, that you did

12 raise issues across, for instance, RSL Active?

13 A. I'm just trying to recall if there were many other

14 occasions. I can't recall many other occasions, I'm sorry.

15

16 Q. Perhaps if I put it this way: you didn't consider

17 that you were forbidden from raising issues about

18 RSL Active, did you?

19 A. I'm not sure I ever thought about that in those ways,

20 in those terms.

21

22 Q. But you raised that issue because you thought it was

23 an important issue to raise within WBI; correct?

24

25 PUBLIC INQUIRER: I reject that question. Next question.

26

27 MR CHESHIRE: Q. Ms Mulliner, as I understand it, went

28 on sick leave in early 2016; is that correct?

29 A. I believe so, yes.

30

31 Q. And that's the time at which you started to take a

32 larger role within WBI; correct?

33 A. It was more the middle of the year. I became more

34 active and involved.

35

36 Q. Yes. That was because, as I understand it, you needed

37 to because Ms Mulliner was not there; correct?

38 A. I believed so.

39

40 Q. So that meant that you became more involved in the

41 financial side of the business; correct?

42 A. Yes.

43

44 Q. And part of that was also you became involved, then,

45 in the formal appeals that were being conducted by WBI;

46 correct?

47 A. Not early in the year. That was the middle of the



1 year.

2

3 Q. From early 2016, you started looking into more of the

4 financial side of WBI; correct?

5 A. Yes.

6

7 Q. And then in the middle of 2016, you formally became

8 involved with the formal appeals that WBI was conducting?

9 A. Yes.

10

11 Q. By "formal appeals", that's the Anzac Appeal and the

12 Poppy Day Appeal?

13 A. Yes.

14

15 Q. I think also around the same time you became involved

16 with RSL Active; correct?

17 A. Towards the end of the year.

18

19 Q. Towards the end of 2016?

20 A. Yes.

21

22 Q. And you formally assumed responsible for it; correct?

23 A. Yes.

24

25 Q. That meant, at least from that time, you really were

26 then performing the role of General Manager of WBI;

27 correct?

28 A. No. Mr Hodges, the National Veterans Affairs Adviser,

29 retired in January or February 2017, I believe.

30

31 Q. Did you take over anything from him or did his role

32 just stop?

33 A. I believe his role was reallocated by RSL National.

34

35 Q. So outside of WBI?

36 A. Yes.

37

38 Q. From late 2016, you had taken over DefenceCare,

39 effectively, as General Manager of DefenceCare and

40 General Manager of RSL Active; is that right?

41 A. Yes.

42

43 Q. With only the adviser left over, as it were, that you

44 had no responsibility for?

45 A. No, I had no responsibility for finance, IT, HR.

46 They were still outsourced to RSL (NSW).

47



1 Q. Finance - how was that then being performed in

2 Ms Mulliner's absence?

3 A. The finance manager was attending the trustees's

4 meetings and providing the information to the Trustees.

5

6 Q. That finance manager was the finance manager of

7 RSL (NSW); is that right?

8 A. Yes.

9

10 Q. Even at that time, then, did you consider that you

11 were performing the role of General Manager of even

12 DefenceCare?

13 A. At that time - it's difficult to answer with a yes or

14 no. I probably - could I answer with a --

15

16 Q. Yes.

17 A. I probably felt that I was starting to assume control

18 over more of WBI by the end of 2016, but I was aware that

19 the finance manager did not report to me.

20

21 Q. So the finance manager continued to report to the

22 Trustees; is that right?

23 A. In WBI, yes.

24

25 Q. So the RSL (NSW) finance manager was responsible for

26 the finances of WBI; correct?

27 A. Yes.

28

29 Q. And reported to the Trustees of WBI in that regard?

30 A. Yes.

31

32 Q. I think, as you became increasingly involved in the

33 financial side of WBI, you became concerned about some of

34 the things that you discovered; is that right?

35 A. Yes.

36

37 Q. There were matters in respect of donations that you

38 were concerned about; correct?

39 A. Yes.

40

41 Q. And about financial management generally; correct?

42 A. Yes.

43

44 Q. And I think you raised a number of these with

45 Mr Kolomeitz; is that right?

46 A. Yes.

47



1 Q. And at the time he was one of the Trustees?

2 A. Yes.

3

4 Q. The response that you received from Mr Kolomeitz, did

5 that appear to be helpful?

6 A. Yes.

7

8 Q. As matters went on, you were becoming more involved in

9 discovering more issues; is that right?

10 A. Yes.

11

12 Q. As you became more involved in those financial issues,

13 did you have a closer relationship with the finance

14 manager?

15

16 PUBLIC INQUIRER: Just let me understand. Closer than --

17

18 MR CHESHIRE: Q. I think you described the finance

19 manager reported to the Trustees, as I understand it?

20 A. Yes.

21

22 Q. You had been completely excluded from finance issues,

23 correct, up until this point?

24 A. Up until - yes.

25

26 Q. At this point, as you became more involved with the

27 financial side of WBI, did you start to have more

28 communications, more dealings with the finance manager?

29 A. Yes.

30

31 Q. You were aware that WBI prepared financial statements

32 each year?

33 A. Yes.

34

35 Q. To your understanding, was that done by the

36 finance manager or the finance manager's team?

37 A. I understood it was done by the CFO.

38

39 Q. Being the CFO of?

40 A. RSL (NSW).

41

42 Q. Being Ms Mulliner, as you understood it?

43 A. Yes.

44

45 Q. Then when Ms Mulliner was off on sick leave, did you

46 have an understanding he was preparing the financial

47 statements of WBI?



1 A. Do you mean the annual financial statements or the

2 monthly?

3

4 Q. Let's try the annual, first of all.

5 A. The annual, I presumed that would have been by

6 Mr Umrigar, but Ms Mulliner had already completed 2015 and

7 the - we were in the year 2016, so there was - we wouldn't

8 have expected the annual financial statements to have been

9 completed by Mr Umrigar until early 2017.

10

11 Q. Mr Umrigar was the finance manager for RSL (NSW);

12 correct?

13 A. Yes.

14

15 Q. The monthly reports that you mentioned, was that him

16 and his department that were preparing those?

17 A. Yes.

18

19 Q. When I say "his department", his department within

20 RSL (NSW)?

21 A. Yes.

22

23 Q. Did you have any involvement with the auditors of WBI?

24 A. At what stage?

25

26 Q. At any time?

27 A. The beginning of this year was the first time that

28 I recall a member of the audit team coming to see me.

29 It may have been about March or a bit later, so not quite

30 the beginning of this year, about some changes we wanted to

31 make to the funds in the balance sheet.

32

33 Q. When you say "the funds in the balance sheet", what do

34 you mean by that?

35 A. In the balance sheet of RSL WBI there were a number of

36 funds, a couple of which - one was called a hospital fund,

37 I believe, that didn't seem to have any transactions or

38 very limited transactions on them and I understand they had

39 been there for a number of years. In the course of getting

40 prepared for the 2016 audit, I asked some questions about

41 those funds and asked to see the files and then asked for

42 one of the members of my team to go back and put a

43 historical record together of transactions in those funds

44 and to see whether those funds were currently being used or

45 would be used in the future as to whether we should keep

46 them in the balance sheet.

47



1 Q. So did those funds appear to you to be dormant?

2 A. Yes.

3

4 Q. And what was the result of that?

5 A. The result of that was a recommendation was made to

6 the Trustees and the Trustees agreed that they were no

7 longer needed, they were dormant, and that we had,

8 I believe, passed that on to the audit or Mr Umrigar had

9 passed it on to the auditor and the auditor - one of the

10 auditors' team came and met with me to go through the files

11 and talk about the dormant funds.

12

13 Q. Were those funds wound up or did something happen to

14 them?

15 A. We were going to wind them up. The money had really

16 already been expended for the purpose it was intended, but

17 it must not have been taken out of the funds, but the audit

18 did not progress, so nothing has been done at the moment.

19

20 Q. I think you said that the time of that was the early

21 part of this year.

22 A. I'm trying to remember the month - possibly

23 March/April.

24

25 Q. With the exception of that, did you ever have any

26 dealings on any issue with anybody from Grant Thornton,

27 being the auditors of WBI?

28 A. Could I explain?

29

30 Q. Yes.

31 A. I had a vague recollection of attending a meeting in

32 early 2016 with the Trustees and I thought the auditor was

33 present, but when I met Ms Sheridan in June this year, it

34 was clear she did not recognise me, so I realised I was

35 mistaken and that meeting probably wasn't with the auditor.

36 And I was sitting in - I thought I was sitting in on a

37 meeting talking about the 2015 accounts that Ms Mulliner

38 had prepared, but I realised I was probably mistaken. So

39 the first time that I had dealings with the auditor would

40 have been meeting one of Ms Sheridan's team in earlier this

41 year, as I said, and then I met with Ms Sheridan in June of

42 2017.

43

44 PUBLIC INQUIRER: Q. Did you recognise Ms Sheridan?

45 A. The lady I recalled meeting I thought had a different

46 hair colour.

47



1 Q. So you did or you didn't recognise her?

2 A. I didn't - I'd seen her picture, I don't know whether

3 it was from that.

4

5 Q. I'm just asking you did you recognise her.

6 A. Not particularly.

7

8 PUBLIC INQUIRER: All right. Yes, Mr Cheshire. That's

9 all right.

10

11 MR CHESHIRE: Q. The meeting you had with her in June of

12 this year, what was the purpose of that?

13 A. To go and to see why the audit had stalled, what were

14 the problems associated with the stalling of the audit.

15

16 Q. When you say the stalling of the audit, it appeared to

17 you to have stalled on the side of the auditor; is that

18 right?

19 A. Yes.

20

21 Q. Were you given an explanation?

22 A. I found it difficult to understand the explanation.

23

24 Q. To the best of your recollection, what was the effect

25 of the explanation you received?

26 A. That more work needed to be done.

27

28 Q. About any particular issue?

29 A. I can't recall, I'm sorry.

30

31 Q. You're aware that WBI has admitted certain breaches in

32 respect of the Charitable Fundraising Act; correct?

33 A. Yes.

34

35 Q. And some breaches in relation to the presentation of

36 its financial statements; correct?

37 A. Yes.

38

39 Q. Did you have any discussion with Ms Sheridan about

40 those breaches, asking her how this could have happened?

41 A. In that particular meeting?

42

43 Q. In any meeting?

44 A. I think that might be the only meeting I've had with

45 her. I don't recall that.

46

47 Q. You didn't --



1 A. No, I don't think so.

2

3 Q. You didn't think to raise that with her?

4 A. At the time it wasn't the purpose of the meeting and,

5 no, I didn't think to raise that with her.

6

7 Q. I have asked you about communications with the

8 auditors and you've given evidence as to your meetings that

9 you had. Just to be clear, are there any other

10 communications that you've had with the auditor outside of

11 meetings?

12 A. A few phone calls and some emails, I think.

13

14 Q. To the best of your recollection, what was the subject

15 matter or the effect of those telephone calls?

16 A. Again, to try and move along with the audit.

17

18 Q. When were those telephone calls and emails?

19 A. Probably before - some of the telephone calls or

20 perhaps one of the telephone calls, I'm not sure now, was

21 before the meeting in June. There may have been more than

22 one around about that time, May, June, July this year.

23

24 Q. Am I right that, to the best of your recollection, you

25 did not have any dealings of any type with any of the audit

26 team prior to February-March of this year?

27 A. To the best of my recollection, yes.

28

29 Q. I asked you about the meeting in June, but am I right

30 that you have never raised with any of the audit team,

31 whether in writing or orally, the issue of the breaches of

32 the Charitable Fundraising Act?

33 A. I don't recall having done that.

34

35 Q. One of the issues that I think you became aware of at

36 an earlier time was the fact that WBI's objects were

37 limited to ex-servicemen rather than current servicemen;

38 correct?

39 A. Yes.

40

41 Q. And that continues to be the case under the rules of

42 WBI; correct?

43 A. Yes.

44

45 Q. I think you became aware of that soon after you

46 commenced in about 2012; correct?

47 A. Yes.



1

2 Q. I think it right that you have raised that issue from

3 time to time?

4 A. Yes.

5

6 Q. Your issue was that in the light of those limited

7 objects, it appeared that WBI was providing assistance to

8 people in breach of its objects; correct?

9 A. Yes.

10

11 Q. As I understand the position, it has continued to

12 provide assistance to current servicemen and their

13 dependants as well as ex; correct?

14 A. Yes.

15

16 Q. Therefore, at least to your understanding, WBI has

17 continued to be in breach of its objects from when you

18 started to the current day; correct?

19 A. Yes.

20

21 Q. You had raised that from time to time; correct?

22 A. Yes.

23

24 Q. But nothing seems to have been done; correct?

25 A. No, steps have been taken.

26

27 Q. When you say "steps have been taken", what steps have

28 been taken?

29 A. Do you want me to go back to outline them all?

30

31 Q. Let me put it this way: the objects have not been

32 amended; correct?

33 A. Not at the moment, no.

34

35 Q. And WBI has continued to provide for current service

36 people and their dependants; correct?

37 A. Yes.

38

39 Q. In terms of steps to resolve either of those two

40 matters, nothing has been done, at least, to date?

41 A. I think work has - sorry, I'm not sure of the answer.

42

43 PUBLIC INQUIRER: Q. You've already told me that you

44 have started work?

45 A. Yes, started work.

46

47 MR CHESHIRE: Q. What's the current position in that



1 regard?

2 A. The current position is the most recent advice was

3 that the objects of WBI could not be changed and that the

4 alternative was to set up a new legal entity which had

5 broader objects, and that WBI would engage the new legal

6 entities to deliver the services that related to its

7 objects, but that the new legal entity would have broader

8 objects that were more in line with what was needed in the

9 sector.

10

11 Q. Is that an option that you understand is going to be

12 pursued?

13 A. That's an option that the Trustees are considering at

14 the moment.

15

16 Q. To your understanding, has a decision been made as to

17 whether there is going to be a new entity set up along

18 those lines?

19 A. No, there's no decision yet.

20

21 Q. As things currently stand, WBI continues to provide

22 for current as well as ex-service people; correct?

23 A. Yes.

24

25 Q. And its objects continue to be limited to ex-service

26 people; correct?

27 A. Yes.

28

29 Q. One of the issues that you have drawn attention to is

30 the relationship between WBI and the various other RSL

31 entities, I think you refer to as RSL (NSW), LifeCare, the

32 sub-branches and the women's auxiliaries. You understand

33 that although they have a relationship, they are separate

34 legal entities; correct?

35 A. Yes.

36

37 Q. In your statement you talk about achieving some form

38 of separation. Is it your view that at least until

39 recently there has been a blurring of the lines between the

40 various of those entities?

41 A. Yes.

42

43 Q. So one of the things that you have been keen to

44 achieve is some form of further separation between the

45 various legal entities; correct?

46 A. Could I explain a little?

47



1 Q. Yes.

2 A. One of my goals has been to improve governance and if

3 that, as a result, leads to a separation, then that is what

4 needs to happen. So my goal really has been to improve

5 governance in WBI.

6

7 Q. When you say to "improve governance", as I understand

8 it, historically, one of the issues that appears to have

9 been the case is that WBI had its finances being

10 effectively run by RSL (NSW); correct?

11 A. Yes.

12

13 Q. And that's something that you would consider when they

14 are separate entities to be not good governance?

15 A. Could I answer that with an explanation?

16

17 Q. Yes.

18 A. I think if the service is appropriate and you're

19 getting the information that you need to make sound

20 decisions, it's not necessarily poor governance to

21 outsource a particular function. I think if you're not,

22 however, getting the sufficient information to be able to

23 make sound decisions for a legal entity and the information

24 you're being given and you can't change or you can't get

25 traction to change in the current outsource service

26 provider, then good governance is to change. Whether

27 that's to change to another service provider or to bring it

28 in-house, that's a decision that you could make, either

29 decision would be acceptable.

30

31 Q. But when you earlier referred to being excluded from

32 financial matters in relation to WBI, you would accept that

33 it would not be appropriate for the General Manager of

34 WBI to be excluded from financial matters; correct?

35 A. No, if you were the full General Manager of the

36 organisation.

37

38 Q. And whatever you call it, you would accept that even

39 if somebody else is carrying out the day-to-day management

40 of the financial records, the information has to flow back

41 in to WBI; correct?

42 A. Yes.

43

44 Q. And not simply go to the Trustees; correct?

45 A. No.

46

47 Q. You agree?



1 A. Yes.

2

3 Q. Whether you call yourself General Manager or anything

4 else, there has to be somebody within WBI who has knowledge

5 of everything that is going on financially; is that

6 correct?

7 A. I think it is advisable, yes.

8

9 Q. Well, isn't it essential?

10 A. Yes.

11

12 Q. And,indeed, to be in a position to supervise what is

13 going on financially; correct?

14 A. Yes.

15

16 Q. And to change it if necessary?

17 A. Yes.

18

19 Q. And that includes issues such as compliance issues;

20 correct?

21 A. Yes.

22

23 Q. For instance, in the context of this Inquiry, it is

24 not appropriate to outsource entirely issues of complying

25 with the Charitable Fundraising Act; correct?

26 A. Not appropriate, no. I agree, sorry. Yes. Sorry.

27

28 Q. In the context of the blurring of the lines between

29 the organisations, one of the issues that you have had

30 concern about is the use of WBI as what has been described,

31 I think, as I clearing house for donations to other

32 entities; correct?

33 A. I was concerned about that.

34

35 Q. That appeared to arise, at least in part, again out of

36 this blurring of the lines between the various entities; is

37 that right?

38 A. I don't know whether that's how it arose, I'm sorry,

39 I don't know.

40

41 Q. Have you taken steps, though, to prevent that

42 happening again?

43 A. Yes.

44

45 PUBLIC INQUIRER: Q. Have you discussed that with the

46 auditor?

47 A. I have not had much in the way of dealings with the



1 auditor at all this year, sorry.

2

3 Q. I am just asking you have you discussed removing the

4 clearing house phenomenon with the auditor?

5 A. Mr Umrigar may have --

6

7 Q. I'm just asking you --

8 A. No, personally, no, sorry.

9

10 PUBLIC INQUIRER: Yes. Thank you, Mr Cheshire.

11

12 MR CHESHIRE: Q. That's happened with other ventures,

13 correct - commercial ventures, film ventures?

14 A. What ventures, sorry?

15

16 Q. The use of WBI as, in effect, a clearing house for

17 donations; correct?

18 A. Could you repeat the whole question, sorry.

19

20 Q. You're aware that WBI has been used, as you call it,

21 as a transit place or a clearing house for donations to go

22 to a commercial film venture; correct?

23 A. No, I wasn't aware of that.

24

25 Q. You're not aware of that?

26 A. Not of - sorry of WBI - could you explain what you

27 mean by that? WBI used as a clearing - sorry.

28

29 Q. You were aware, were you not, that donations that were

30 intended to go to a particular venture went through WBI;

31 correct?

32

33 PUBLIC INQUIRER: You're sending mixed messages here. I'm

34 going to ask Mr Cheshire to write on a piece of paper the

35 name of the venture.

36

37 MR CHESHIRE: Q. Do you have volume 1 in front of you?

38 That may be the easiest way. If you have your statement at

39 the beginning, if you turn to paragraph 268. There's no

40 need to read it out, Ms Collins, but you see the reference

41 there? Ms Collins, do you see --

42 A. Yes.

43

44 Q. Does that refresh your memory?

45 A. I'm aware of the donations.

46

47 PUBLIC INQUIRER: Q. Just wait. You're just being asked



1 whether you see it, and I think you do?

2 A. Yes, I do.

3

4 Q. There's no need to refer to the actual production for

5 the moment, until Mr Cheshire invites you to do so.

6 A. Yes.

7

8 MR CHESHIRE: Q. You had a concern about that issue;

9 correct?

10 A. Yes.

11

12 Q. You had a concern about the moneys that was intended

13 for this venture but it was going through WBI; correct?

14 A. No, I did not know the moneys were going through WBI.

15 I was aware that WBI at one stage made a donation. I was

16 not aware that moneys from sub-branches went through WBI to

17 the venture.

18

19 Q. Were you aware that, in effect, WBI's fundraising

20 authority or charitable status was being used to facilitate

21 donations to this venture? If you look at paragraph 272,

22 do you see the reference there to the donation?

23 A. Yes. Yes, sorry, I didn't connect the question with

24 that, sorry.

25

26 Q. Yes. That was a concern that you had; correct?

27 A. Yes. Yes.

28

29 Q. To similar effect, I think, what you have described,

30 if you turn to paragraph 99, as transit payments to

31 LifeCare and the women's auxiliary; correct?

32 A. Yes.

33

34 Q. That, again, you had a concern about; correct?

35 A. Yes.

36

37 Q. If people wanted to donate to WBI, they should donate

38 to WBI; correct?

39 A. Yes.

40

41 Q. But if people wanted to donate, for instance, to

42 LifeCare or the women's auxiliaries they should do so,

43 correct?

44 A. Yes.

45

46 Q. So WBI should not be used as some form of transit hub

47 or clearing house; correct?



1 A. Yes.

2

3 Q. Have you put steps in train to ensure that those

4 matters do not happen?

5 A. Yes.

6

7 Q. What have you put in place?

8 A. I asked the Trustees whether we could resolve that any

9 donations sent to WBI that were intended for a different

10 organisation would be returned to the donor with

11 information on where to send the donation, so that it went

12 to their intended recipient.

13

14 Q. Do I understand it you thought that was just bad

15 practice for them to come through WBI; is that correct?

16 A. Yes.

17

18 Q. It wasn't a matter that you looked at from the

19 perspective of the Charitable Fundraising Act?

20 A. No.

21

22 Q. You also, I think, had a credit card that you used,

23 correct, that was provided for your use?

24 A. Yes.

25

26 Q. As you understood it, that was being paid by the

27 Hyde Park Inn; correct?

28 A. I'm not sure how to answer that. I'm not sure how to

29 answer that. Do you want me to explain what I understood?

30

31 Q. You understood, didn't you, that you weren't paying

32 the bill; correct?

33 A. No, I understood that WBI was reimbursing the

34 Hyde Park Inn.

35

36 Q. Yes, but in the first instance you understood that the

37 bill was being paid by the Hyde Park Inn; correct?

38 A. I found that out, yes.

39

40 Q. You understood that the Hyde Park Inn was part of the


42 A. Yes.

43

44 Q. Again, even if WBI was reimbursing, you formed the

45 view that that was not good practice; correct?

46 A. Yes.

47



1 Q. Did you do something to stop that?

2 A. I asked whether WBI could have its own credit cards.

3

4 Q. What happened with that?

5 A. I was told no, it couldn't.

6

7 Q. What is the situation today? Do they continue to be

8 paid, as you understand it, by the Hyde Park Inn?

9 A. As I understand it, yes, they do. We are trying to

10 change that.

11

12 Q. Is there any reason that you can see as to why WBI

13 cannot have its own credit cards?

14 A. No, I can't see any reason why it couldn't.

15

16 Q. In the context of the Hyde Park Inn, are you aware

17 that one of the issues that this Inquiry has looked as was

18 the resignation of Mr Rowe in November 2014?

19 A. Yes.

20

21 Q. And the issue of his expenses?

22 A. Yes.

23

24 Q. And one of the issues that has been raised is that his

25 son was living in an apartment provided for him at the

26 Hyde Park Inn?

27 A. Yes.

28

29 Q. As at that time, November 2014, were you working at

30 Anzac House?

31 A. Yes.

32

33 Q. The floor that you were working on, did it have

34 employees of RSL (NSW)?

35 A. Registry, one, and the communications, two. Two.

36

37 Q. Two people?

38 A. Yes.

39

40 Q. Was there interaction with the other floors within

41 Anzac House?

42 A. DefenceCare interaction?

43

44 Q. Did you have any interactions with people on other

45 floors in Anzac House?

46 A. Some. Limited.

47



1 Q. Do you remember any discussion about the reason for

2 Mr Rowe's departure?

3 A. No.

4

5 Q. Do you remember any discussion about Mr Rowe having

6 any problem with his expenses?

7 A. No.

8

9 Q. What was the first that you found out about there

10 being any issue with Mr Rowe's expenses?

11 A. The media, when it hit - when it was reported in the

12 media.

13

14 Q. At that time, did you have any discussions with

15 anybody within RSL (NSW) about that issue?

16 A. I can't recall specifics of anything possibly other

17 than a general "I am shocked" type of comment. Nothing

18 specific comes to mind, I'm sorry.

19

20 Q. You don't recall anybody saying to you, for instance,

21 something to the effect, "Well, everybody knew about his

22 expenses", or anything to that effect?

23 A. No, not that I can recall.

24

25 Q. I asked you earlier about what you described as the

26 formal appeals being the Anzac Day and Poppy Day appeals.

27 You were also involved in various other fundraising appeals

28 that were conducted by DefenceCare; correct?

29 A. Yes.

30

31 Q. Am I right that you did not look at those from the

32 point of view of the Charitable Fundraising Act?

33 A. Sorry?

34

35 Q. Those appeals, did you consider at the time they were

36 being carried out, whether WBI was in fact complying with

37 the Charitable Fundraising Act?

38 A. Did I consider it? I'm not sure how to answer that.

39

40 PUBLIC INQUIRER: Q. Did you think about the

41 Charitable Fundraising Act when you were doing the appeal?

42 A. Yes, we did.

43

44 Q. All right.

45 A. Yes, we did.

46

47 MR CHESHIRE: Q. When you commenced, am I right that



1 from at least 2012 onwards, you were aware that WBI was

2 engaged in fundraising?

3 A. Yes.

4

5 Q. You were aware, were you, that it had a charitable

6 fundraising authority?

7 A. Yes.

8

9 Q. But you were aware that, in fact, WBI was in breach of

10 its authority; correct?

11 A. No, I wasn't aware at that stage.

12

13 Q. You are now aware, are you?

14 A. I'm now aware, yes.

15

16 Q. It appears from that that even if you turned your mind

17 to the issue of whether WBI was complying with Charitable

18 Fundraising Act, you didn't get it right; correct?

19 A. Hard to answer yes/no. In hindsight, yes, we didn't

20 get it right, sorry.

21

22 Q. Do you think that's because, in fact, you did not give

23 sufficient consideration to the Act?

24 A. In hindsight - at the time, I thought we were giving

25 sufficient consideration to the Act and I thought we were

26 researching what we needed to do when people requested to

27 fundraise. At the time I had thought we were. I had no

28 oversight of the finances, so I was not aware of the lack

29 of compliance there. With hindsight, looking back, in its

30 totality, those were not compliant.

31

32 Q. If one takes the financial side, you are aware, aren't

33 you, that there are certain requirements as to how bank

34 accounts are to be kept?

35 A. Yes.

36

37 Q. If you knew that WBI was fundraising and you knew that

38 it had a fundraising authority, then you knew that that

39 obligation was there; correct?

40 A. Yes.

41

42 Q. In order to find out how the accounts were kept, you

43 would have needed either to have looked at that or to have

44 asked somebody; correct?

45 A. Yes.

46

47 PUBLIC INQUIRER: Mr Herzfeld, I presume there's a



1 section 41 application here?

2

3 MR HERZFELD: We haven't made any application yet.

4

5 PUBLIC INQUIRER: I understand that, that's why I'm

6 raising it.

7

8 MR HERZFELD: No, in relation to the statement.

9

10 PUBLIC INQUIRER: Do you want to make an application to

11 object?

12

13 MR HERZFELD: Would you just excuse me for one minute?

14

15 PUBLIC INQUIRER: Yes.

16

17 MR HERZFELD: No, we don't, not at this stage. I am

18 listening to the questions carefully.

19

20 PUBLIC INQUIRER: There has been admission, and I just

21 want you to be clear. I think I might take a short

22 adjournment. It is not a matter of any concern. Just step

23 down for a moment, Ms Collins. I just want there to be no

24 misunderstanding and I want to make sure that the benefits

25 of the legislation are looked at. I'll leave it with you,

26 Mr Herzfeld, and I'll return shortly.

27

28 MR HERZFELD: I appreciate the time.

29

30 PUBLIC INQUIRER: Thank you, no problem.

31

32 SHORT ADJOURNMENT

33

34 PUBLIC INQUIRER: Yes, thank you. Yes, Mr Herzfeld?

35

36 MR HERZFELD: Thank you for the time. With the benefit of

37 that time, we do on Ms Collins' behalf take an objection in

38 relation to the topic of compliance with the Charitable

39 Fundraising Act.

40

41 PUBLIC INQUIRER: Yes. While you're on your feet,

42 Mr Herzfeld, I'm also conscious of the statements that were

43 made in respect of the Trust operating in breach of Trust.

44

45 MR HERZFELD: Yes.

46

47 PUBLIC INQUIRER: It seems to me, perhaps if I may be able



1 to suggest to you, that you do make an objection generally

2 for the moment in respect of the aspects of the evidence.

3 I know that Ms Collins is not a Trustee, but the knowledge,

4 et cetera, in circumstances where I apprehend that nothing

5 has been done to approach the court for guidance or

6 corrections; is that right?

7

8 MR HERZFELD: Yes.

9

10 PUBLIC INQUIRER: I would like to hear about that in due

11 course because I now know, on the evidence, that there is a

12 problem. At the moment I'll note your general objection

13 and then you can provide a schedule in respect of any

14 questions and answers that you wish to be included in that

15 objection. Does that suit, Mr Herzfeld?

16

17 MR HERZFELD: It does. Obviously that topic is also

18 covered in the statement itself.

19

20 PUBLIC INQUIRER: It is.

21

22 MR HERZFELD: I'm not sure what --

23

24 PUBLIC INQUIRER: I will note your objection to the

25 contents of the statement as well.

26

27 MR HERZFELD: Yes, thank you.

28

29 PUBLIC INQUIRER: Thank you, Mr Herzfeld.

30

31 Q. Ms Collins, come back into the witness box, please.

32 Ms Collins, you've heard what I've said and you've heard

33 what has been said.

34 A. Yes.

35

36 Q. Let me just indicate to you that I have noted that you

37 object to answering any questions on the ground that they

38 may tend to expose you to prosecution for a criminal

39 offence or a civil penalty and that, in due course, your

40 counsel will provide a schedule to the Inquiry which will

41 be noting your objections. The effect of that objection is

42 that any answer that you give in respect of those questions

43 cannot be used against you in those proceedings to which

44 I've just referred. Do you understand that?

45 A. Yes.

46

47 Q. The only protection in this circumstance that is not



1 provided to you is that if you do not tell me the truth.

2 Do you understand that?

3 A. Yes.

4

5 PUBLIC INQUIRER: Yes, thank you. Yes, Mr Cheshire?

6

7 MR CHESHIRE: Thank you.

8

9 Q. Ms Collins, as I understand it, when you commenced

10 with WBI you were aware that DefenceCare, at least, was

11 fundraising; correct?

12 A. Yes.

13

14 Q. And you were aware that WBI had a fundraising

15 authority; correct?

16 A. Yes.

17

18 Q. That covered that fundraising?

19 A. Yes.

20

21 Q. And you were aware that the fundraising authority

22 imposed certain conditions; correct?

23 A. Yes.

24

25 Q. And you were aware that, likewise, the Charitable

26 Fundraising Act and the regulation imposed certain

27 obligations?

28 A. Yes.

29

30 Q. You are now aware that, in fact, WBI did not comply

31 with the Act, the regulation and its conditions; correct?

32 A. I'm now aware, yes.

33

34 Q. Yes. What I'm trying to explore with you is how that

35 happened, given that you knew you were fundraising and you

36 knew there were obligations. What I'm asking is is the

37 answer to that that you didn't make sufficient inquiries or

38 that you misunderstood the obligations or you left it to

39 somebody else, or something else?

40 A. I understood that the financial obligations and the

41 reporting obligations were outside of my control, were the

42 responsibility of the CFO and the Trustees, and

43 I understood my obligation to be to ensure that the small

44 fundraisers for DefenceCare met the requirements under the

45 Charitable Fundraising Act and the authority and the

46 regulations.

47



1 Q. Did you discuss those obligations with anybody else

2 within WBI?

3 A. Yes. The marketing and fundraising manager.

4

5 Q. Were they there when you started?

6 A. No. I recruited the first marketing and fundraising

7 manager in November 2012.

8

9 Q. And that was whom?

10 A. Xiong Luong.

11

12 Q. Sorry, you may need to spell that.

13 A. X-U-O-N-G, it's pronounced "Som", S-O-M, and Luong,

14 L-U-O-N-G.

15

16 Q. That person, I think, Mr Luong, was then succeeded by

17 Ms Rocchi; is that right?

18 A. That's correct.

19

20 Q. That is R-O-C-C-H-I; is that correct?

21 A. Yes.

22

23 Q. In fact, is Mr Luong's first name spelt X-U-O-N-G or

24 X-I-O-N-G?

25 A. X-I-O-N-G, sorry.

26

27 Q. You discussed those requirements with Mr Luong, but am

28 I right you didn't discuss them with the Trustees; correct?

29 A. Not specifically that I can recall.

30

31 Q. And you didn't discuss them with Ms Mulliner either;

32 correct?

33 A. No. We asked Ms Mulliner for a number of things on

34 occasion and to clarify points in relation to fundraising.

35 She was my - and Xiong - our first point of call for

36 questions.

37

38 Q. In terms of compliance with the Act, conditions and

39 the regulations, you never said anything to the effect to

40 Ms Mulliner, "Are we in fact complying with the Act?"

41 A. I don't recall specifically asking, "Are we complying

42 with the Act in terms of the finance?"

43

44 Q. What about with the day to day operation of the

45 appeals, what needed to be done on the non-financial side,

46 was that managed by Mr Luong?

47 A. These informal appeals?



1

2 Q. Well, anything that was not covered by the Anzac Day

3 Appeal and the Poppy Day Appeal?

4 A. Yes, initially, it was managed by Mr Luong.

5

6 Q. With issues such as keeping registers of collectors

7 and those sorts of matters, did you leave that to Mr Luong?

8 A. Yes.

9

10 Q. Did you ever have any discussions to ensure that he

11 was, in fact, ensuring that WBI was compliant?

12 A. Yes, we met weekly and we would discuss various small

13 fundraisers, and there would be times he would be looking

14 up the website and we would discuss issues associated with

15 fundraises. They were very small fundraises and most of

16 them were quite simple.

17

18 Q. When you say "issues", you refer to there, am I right,

19 to general issues rather than specifically being matters of

20 compliance?

21 A. They weren't necessarily just general issues. There

22 would be occasion we would be discussing issuing an

23 authority, whether something was a fundraising or not.

24 There were times when people would ring and it wasn't

25 fundraising or the idea didn't come to fruition. There

26 were a number of things we would discuss.

27

28 Q. What about if fundraising was to be carried out by way

29 of, say, collection buckets with collectors, did you turn

30 your mind to issues such as whether there needed to be a

31 register of collectors, a register of buckets, those sorts

32 of matters?

33 A. Yes, and sequential numbering and the issuing of ID

34 cards, how they were issued, yes.

35

36 Q. How did you ensure that there was compliance with

37 that?

38 A. By discussions with Mr Luong and Ms Rocchi as to what

39 we needed to issue, whether we needed to issue, the records

40 we needed to keep. Through the discussions.

41

42 Q. Did you have access to the bank accounts of WBI?

43 A. Not until October this year.

44

45 Q. Am I right, then, that you did not have online access

46 to those accounts?

47 A. No.



1

2 Q. To your understanding, did anybody within WBI have

3 access to the bank accounts of WBI?

4 A. It's my understanding that none of the employees did.

5 I did not know about the Trustees.

6

7 Q. When you were discussing with Mr Luong issues relating

8 to appeals, how did you understand that the money that came

9 in was going to be handled?

10 A. We understood that RSL (NSW) would handle that. At

11 one stage we asked what bank account WBI had and we were

12 given that information, but in terms of the financial side,

13 we understood that that would be managed and handled by

14 RSL (NSW).

15

16 Q. In effect, it wasn't just the management of the

17 financial records; as you understood it, RSL (NSW) was

18 managing the entire finances of WBI, is that correct?

19 A. That's correct, yes.

20

21 Q. Did you even know whether the money that came in from

22 fundraising was going to go into a WBI account or into an

23 RSL (NSW) account?

24 A. I could not see that. I could not confirm that.

25

26 Q. Did you have a view as to what was happening to it?

27 A. I felt it was going into the WBI account. I presumed

28 it was. We would occasionally see in the income statements

29 reference to particular donors that we were dealing with.

30 I had no evidence or anything to suggest that it wasn't.

31

32 Q. Am I right that you never had a discussion with

33 Ms Mulliner about what was happening to the money?

34 A. I can't recall a specific discussion with Ms Mulliner

35 about that.

36

37 Q. Do I take it also that you're not aware of Mr Luong

38 having had any discussions with Ms Mulliner about that?

39 A. I don't know. He may have.

40

41 Q. Do you accept that given your role within at least

42 DefenceCare that you were carrying out, that's a matter

43 that you ought to have had discussions with Ms Mulliner

44 about?

45 A. I believe I would have, had I thought at any stage

46 that there was a problem, but I had no evidence of any

47 problem or reason to do so.



1

2 Q. But in the context of compliance and the importance of

3 compliance, do you not accept that you ought to have had

4 some conversation with Ms Mulliner where you said to her,

5 "Can we just make sure we're compliant" or, "Are we

6 compliant?", or something to that effect?

7 A. It was never my role to do that. I understood that

8 quite clearly.

9

10 PUBLIC INQUIRER: Q. Never your role to do what?

11 A. To question Ms Mulliner. With hindsight, if I sit

12 here now, I would like to say that in better knowledge -

13 I didn't have that knowledge then. I had no - anything to

14 suggest - no evidence to suggest that there was anything

15 wrong that needed questioning at the time.

16

17 MR CHESHIRE: Q. You understood Ms Mulliner was in fact

18 employed by RSL (NSW); correct?

19 A. Yes.

20

21 Q. Even if you regarded the financial management as being

22 outscored, the issue of compliance by WBI was matter for

23 you; correct?

24 A. Not as I understood it, no.

25

26 Q. In relation to matters of compliance with the

27 Charitable Fundraising Act by WBI, who did you understand

28 at that time had that responsibility?

29 A. The Trustees.

30

31 Q. Yes. And presumably they were entitled to rely upon

32 their staff; correct?

33 A. Yes.

34

35 Q. Who then within the staff of WBI had responsibility

36 for compliance?

37 A. The charitable - can I just answer that by way of

38 explanation?

39

40 Q. Yes.

41 A. My understanding the Charitable Fundraising Act is

42 quite broad. I felt I had responsibility in the liaison

43 with people who wanted to do small fundraisers and the

44 responsibility - we took responsibility for things like

45 collection buckets, ID tags, talking to them and issuing

46 authorities. Once there were any financial transactions,

47 that was outside my area of responsibility.



1

2 PUBLIC INQUIRER: Q. When you say issuing authorities,

3 to what are you referring?

4 A. We occasionally issued an authority to fundraise.

5

6 Q. I see.

7 A. If someone asked us if they could fundraise on our

8 behalf. Most of the time when we spoke to people,

9 certainly in my discussions with Mr Luong and Ms Rocchi, it

10 often didn't turn into fundraising, but --

11

12 Q. Just on the authority to fundraise, I presume that was

13 in the form of a letter --

14 A. A letter.

15

16 Q. -- that you allowed them to present to the public as

17 your agent, effectively; is that right, or --

18 A. Yes. It would have been the occasional one.

19

20 Q. You allowed them to fundraise under WBI's fundraising

21 authority?

22 A. Yes, that's right.

23

24 PUBLIC INQUIRER: Yes, I understand that. Yes,

25 Mr Cheshire.

26

27 MR CHESHIRE: Q. Would you accept that irrespective of

28 the fact that the finance issues may have been outsourced

29 to RSL (NSW), somebody within WBI ought to have been given

30 the responsibility for ensuring compliance with all aspects

31 of the Charitable Fundraising Act?

32 A. That would have been a matter for the Trustees to

33 decide, yes.

34

35 Q. Am I right that you set up the website of WBI?

36 A. The DefenceCare website.

37

38 Q. You set that up, did you?

39 A. Yes.

40

41 Q. You then were aware, were you, that it had a donate

42 function on it?

43 A. Yes.

44

45 Q. Did you appreciate that that constituted fundraising?

46 A. Yes.

47



1 Q. Did you give any thought in the setting up of the

2 website, as to the way in which it would work, whether it

3 would be compliant with the Charitable Fundraising Act?

4 A. Yes.

5

6 Q. What did you understand would happen to the money when

7 a member of the public donated it?

8 A. The money would - there were two ways to donate.

9 One was automatically via the website which went through

10 to, I understand, an eWAY system, and that was looked after

11 by Ms Mulliner and the finance area, so the back-end of the

12 website. I understood that that payment gateway - the

13 money would go through the payment gateway and then would

14 be directed to the nominated WBI account that the finance

15 department provided to us. Then that money would be

16 accounted for in the finance system. There was an

17 automatic receipt issued if you donated online, but then

18 the finance area would also provide us with receipts and we

19 could write a thank you letter to the donor.

20

21 Q. With the money that came in, you mentioned an eWAY

22 platform. Did that mean that there was an external

23 provider or supplier that was involved in the process?

24 A. Yes.

25

26 Q. Did that provider take money out of the donation?

27 A. I'm sorry?

28

29 Q. How was that supplier or provider paid?

30 A. I don't know that. That was a matter for RSL (NSW)

31 finance.

32

33 Q. Am I right that when you set the process up, you knew

34 that the money would go somewhere, but you didn't know how

35 much would actually end up in the account; is that right?

36 A. I didn't have oversight of that, I'm sorry, no.

37

38 Q. Am I right that you did not give consideration as to

39 whether the full amount would go into a bank account before

40 expenses were taken out or whether, in fact, only an amount

41 would go into a bank account after expenses had been taken

42 out?

43 A. That was not something I had responsibility for, I'm

44 sorry.

45

46 Q. In setting up the website, did you give any

47 consideration to that issue?



1 A. Personally, no.

2

3 Q. Are you aware, at least now, the

4 Charitable Fundraising Act imposes certain requirements

5 about gross proceeds of fundraising going into bank

6 accounts?

7 A. Yes, I'm aware of that.

8

9 Q. You would see, would you not, at least now, in setting

10 up a website, that that's a matter you would need to give

11 consideration to, correct?

12 A. Yes, in the finance area absolutely I would give

13 consideration to.

14

15 Q. It appears that when you set up the website you did

16 not give consideration to the finance aspects and whether

17 they complied with the Charitable Fundraising Act; is that

18 right?

19 A. As I understood, it was not my responsibility to give

20 the consideration. The eWAY portion of the website was

21 handled by a company called Cornerstone and that was

22 handled - that part of the exercise was dealt with by

23 RSL (NSW) Finance.

24

25 PUBLIC INQUIRER: Q. You're just being asked now that

26 you know what you know, would you not give consideration to

27 that aspect of the requirements when you set up a website?

28 A. Yes.

29

30 PUBLIC INQUIRER: Yes, thank you. Yes, thank you,

31 Mr Cheshire?

32

33 MR CHESHIRE: Q. The website that you set up is a

34 website that's available throughout Australia; correct?

35 A. Yes.

36

37 Q. You are aware that the Charitable Fundraising Act is

38 an Act that applies in New South Wales; correct?

39 A. Yes.

40

41 Q. And, indeed, there are licensing requirements in some

42 of the other States and Territories in Australia; correct?

43 A. Yes.

44

45 Q. When you set up the website, did you give any

46 consideration as to whether that would mean that you would

47 need to have licences or authorities in any other State or



1 Territory?

2 A. Yes, we did. Over a period of time we started to

3 think about the impact of that.

4

5 Q. So that was after the website was set up; is that

6 right?

7 A. Yes, it was after.

8

9 PUBLIC INQUIRER: Q. When was that?

10 A. Sorry?

11

12 Q. When was that?

13 A. When was the website set up --

14

15 Q. No.

16 A. -- or when did we give consideration to it?

17

18 Q. Yes.

19 A. It wasn't long after the website was set up. I'm

20 trying to remember.

21

22 Q. Just pause there and think about it.

23 A. I think Mr Luong was still there, so it would have

24 been probably early 2013.

25

26 PUBLIC INQUIRER: Thank you.

27

28 MR CHESHIRE: Q. What was the result of that? Did you

29 then go and seek licences or authorities in other States

30 and Territories?

31 A. I asked Ms Mulliner about whether WBI had licences in

32 other States and Territories. She explained that the

33 organisation didn't, and I asked if I could get them and

34 she said yes.

35

36 Q. And so did you?

37 A. Yes.

38

39 Q. WBI currently has, as you understand it, authorities

40 or licences in all of the other States and Territories

41 insofar as they exist; is that right?

42 A. It needs to, yes.

43

44 PUBLIC INQUIRER: Q. Are they current?

45 A. Yes, they are.

46

47 Q. Are they being used for fundraising?



1 A. I'm not sure we get many donations from interstate.

2 The licences are current, but I can't recall many

3 donations. There would be some from interstate. So,

4 insofar as that, yes, they would be being used to

5 fundraise.

6

7 PUBLIC INQUIRER: Thank you.

8

9 MR CHESHIRE: Q. WBI is currently not fundraising in

10 New South Wales; correct?

11 A. That's right.

12

13 Q. Is WBI currently fundraising outside of New South

14 Wales?

15 A. Not that I know of, no.

16

17 Q. You're aware that there are other RSL entities in

18 other States and Territories in Australia; correct?

19 A. Yes.

20

21 Q. Such as State Branches of the RSL; correct?

22 A. Yes.

23

24 Q. Is there any agreement or understanding between the

25 various States and Territories as to where you will or

26 won't fundraise?

27 A. Not that I'm aware of. There may be.

28

29 Q. You mentioned the Anzac Day and the Poppy Day appeals

30 that are conducted by WBI. As I understand it, WBI

31 conducts those appeals in New South Wales; correct?

32 A. Yes.

33

34 Q. WBI does not go and do an Anzac Day Appeal or a Poppy

35 Day Appeal in Western Australia; correct?

36 A. No.

37

38 Q. Is that right?

39 A. No, that's right. Sorry, that's right.

40

41 Q. Is there anything that would stop it doing that?

42 A. We have a licence. No, I'm not sure there's anything

43 that would stop it. Legally, do you mean?

44

45 Q. Or in practice, is there any understanding or any

46 agreement between the various States and Territories?

47 A. Not that I know of. There's - not that I know of and



1 understand.

2

3 Q. You are aware, aren't you, that organisations from

4 other States fundraise in New South Wales?

5

6 PUBLIC INQUIRER: RSL organisations.

7

8 MR CHESHIRE: Q. RSL organisations.

9 A. Yes.

10

11 Q. You are aware, for instance, of what is called the Art

12 Fund; correct?

13

14 PUBLIC INQUIRER: The Art Union.

15

16 MR CHESHIRE: Q. I beg your pardon, the Art Union.

17 A. Yes.

18

19 Q. Which is part of the RSL Queensland?

20 A. Yes.

21

22 Q. You are aware that that fundraises in New South Wales?

23 A. Yes.

24

25 Q. Would it be right that, to your understanding, since

26 WBI has ceased fundraising, the Art Union has conducted

27 more fundraising in New South Wales?

28 A. I don't know, sorry.

29

30 Q. You're not aware of that?

31 A. No.

32

33 Q. Are you aware of any discussions between the various

34 States and Territories following WBI ceasing to fundraise

35 in New South Wales where somebody else has said, "Well,

36 we'll come in and take up the slack"?

37 A. No. No. I have had - would you like me to explain

38 discussions with RSL Victoria?

39

40 Q. Yes.

41 A. RSL Victoria normally coordinates the Poppy Appeal and

42 the Anzac Appeal nationally. We have indicated - I told

43 RSL Victoria that we are not fundraising and that - so, WBI

44 is not fundraising, and that means that the Poppy and the

45 Anzac Appeals can't be run in New South Wales under WBI's

46 fundraising authority. He had mentioned that RSL Victoria

47 were looking to getting a fundraising authority in



1 New South Wales, because I also mentioned to him I was

2 concerned about the Poppy Appeal website and the Anzac

3 Appeal website, as it did mention that donations - I'm not

4 sure it was clear, but there was a mention of WBI and

5 I explained that he needed to take that down.

6

7 Q. Am I right that RLS Victoria has an Anzac Day and

8 Poppy Day website; is that correct?

9 A. They do. I'm not sure it is up, though, at the

10 moment.

11

12 Q. Your concern was that somewhere on that website it

13 mentioned WBI and you were concerned that that was

14 misleading because WBI wasn't currently fundraising for

15 those appeals; is that right?

16 A. Yes.

17

18 Q. Poppy Day is coming up soon; correct?

19 A. Yes.

20

21 Q. To your understanding, is RSL Victoria looking to

22 carry out fundraising for Poppy Day in New South Wales?

23 A. No, it's my understanding they're not.

24

25 Q. What about any of the other States and Territories?

26 A. I don't know.

27

28 Q. You have no awareness of that at all?

29 A. No, whether they're fundraising in New South Wales, do

30 you mean?

31

32 Q. Yes. Is anybody intending to fundraise for Poppy Day

33 in New South Wales to your understanding?

34 A. I don't know.

35

36 Q. Although you did not have access to the financial

37 records of WBI, you would have seen, am I right, the

38 financial statements of WBI?

39 A. The audited financial statements?

40

41 Q. Yes.

42 A. The audited ones? At times, yes.

43

44 Q. Do you recall that there was a note in those financial

45 statements, at least prior to 2014, that WBI did not engage

46 in any fundraising appeals or activities?

47 A. I only found that out in preparation for the Inquiry



1 when I read the notes to those accounts.

2

3 Q. Your view now is that those statements were wrong;

4 correct?

5 A. Yes.

6

7 Q. You simply didn't notice that at the time?

8 A. I did not read the notes to the accounts for the prior

9 years to 2015 until I prepared for the Inquiry.

10

11 Q. Am I right that you don't recall any discussions with

12 anybody about the issue of whether WBI was or was not

13 fundraising?

14 A. Not that I was involved in.

15

16 Q. You mentioned Mr Luong was then succeeded by

17 Ms Rocchi?

18 A. Ms Rocchi.

19

20 Q. When did she take over?

21 A. Approximately early 2014.

22

23 Q. At that time, the Anzac Day and Poppy Day appeals were

24 not being carried out by WBI; is that right?

25 A. No, they weren't.

26

27 Q. Am I right that Mr Luong took over the appeals that

28 were being carried out at that time; correct?

29 A. Ms Rocchi - sorry?

30

31 Q. Mr Luong was responsible initially for all of the

32 appeals that were being carried out by WBI; correct?

33 A. By DefenceCare.

34

35 Q. By DefenceCare. Ms Rocchi then took over all of the

36 appeals that were carried out by DefenceCare; is that

37 right?

38 A. Yes.

39

40 Q. The Anzac Day Appeal and the Poppy Day Appeal, WBI

41 took over in 2014 or 2015; correct?

42 A. Mid-2014, I understand.

43

44 Q. Who then took over responsibility for those appeals

45 when WBI took them over?

46 A. I understand there was a campaign manager, Ms Palmer,

47 and an Appeals Committee.



1

2 Q. And the Appeals Committee was a committee of


4 A. I understand that. I've never seen documentation to

5 that effect.

6

7 Q. And you had no involvement with that committee;

8 correct?

9 A. No.

10

11 Q. Is that right?

12 A. Sorry, that's right. Sorry, yes.

13

14 Q. Ms Palmer - is that right?

15 A. Yes.

16

17 Q. Ms Palmer, was she employed by RSL (NSW)?

18 A. I didn't see her employment contract. I was of the

19 understanding she was employed by WBI.

20

21 Q. Did she report to you?

22 A. No.

23

24 Q. Who did she report to?

25 A. I understand it changed. My initial understanding was

26 Ms Mulliner or Mr Perrin, I'm not sure.

27

28 Q. Am I right, then, that when WBI took over the

29 Anzac Day Appeal and the Poppy Day Appeal, it appears that

30 they were treated differently to the other appeals that

31 DefenceCare was carrying out?

32 A. It appears that way.

33

34 Q. And to your understanding, the Poppy Day Appeal and

35 Anzac Day Appeal was that being carried out by DefenceCare

36 or WBI?

37 A. WBI, not DefenceCare.

38

39 Q. When you say by WBI, presumably not by RSL Active; is

40 that right?

41 A. No, not RSL Active.

42

43 Q. To your understanding, was the Poppy Day Appeal and

44 the Anzac Day Appeal really being carried out by RSL (NSW)

45 but in the name of WBI?

46 A. I don't have enough knowledge to answer that

47 correctly - to answer that with a "yes", I'm sorry.



1

2 Q. Is it right then effectively you had no involvement

3 with the Poppy Day Appeal and the Anzac Day Appeal until at

4 least earlier this year?

5 A. That's right, until - sorry, no, until August,

6 approximately August 2016.

7

8 Q. What happened then?

9 A. The Trustees asked me would I take over looking after

10 the appeals.

11

12 Q. When you say "the appeals", you mean those two

13 appeals; is that right?

14 A. Sorry, the Anzac Appeal and the Poppy Appeal.

15

16 Q. So DefenceCare had always had responsible for the

17 fundraising activities of WBI, excluding the Anzac Day

18 Appeal and the Poppy Day Appeal?

19 A. I was not aware of anything else other than the small

20 fundraises we ran on the website. However, I believe that

21 there were donations to RSL Active, and DefenceCare was not

22 involved in those.

23

24 MR CHESHIRE: Is that a convenient time?

25

26 PUBLIC INQUIRER: It is. We're going to take a short

27 break, if you'd like to leave the witness box, and I'll

28 resume at 10 to 12.

29

30 Yes, I will adjourn until then, thank you.

31

32 SHORT ADJOURNMENT

33

34 PUBLIC INQUIRER: Yes, thank you. Just before you come

35 back into the witness box, Mr Herzfeld, this matter of the

36 Trustees is worrying me.

37

38 MR HERZFELD: The objects?

39

40 PUBLIC INQUIRER: The breach.

41


43

44 PUBLIC INQUIRER: Are you able to say whether anything has

45 happened in respect of seeking either directions from the

46 court or notifying the court?

47



1 MR HERZFELD: All I can say is what is in the statement as

2 to the steps and what was considered and then what didn't

3 happen and then obviously there's then the --

4

5 PUBLIC INQUIRER: Has the court been approached?

6

7 MR HERZFELD: No. Would you just excuse me for a moment?

8

9 PUBLIC INQUIRER: Yes, of course.

10

11 MR HERZFELD: You will have seen in the statement that

12 there was contemplated applying to the court for a cy pres

13 scheme. I apprehend what you're asking me is a slightly

14 different question.

15

16 PUBLIC INQUIRER: Section 63.

17

18 MR HERZFELD: I understand that there has not been any

19 application to the court for advice.

20

21 PUBLIC INQUIRER: Or, alternatively, some remedial

22 situation for the Trustees presently. I don't know that

23 the actual provision of services outside the objects of the

24 trust is happening, and I'm not going to explore that with

25 you, but I'm just saying to you that it is concerning me

26 that I'm now aware that there is a probability, a high

27 probability that that is happening and, really, endorsing

28 steps to be taken very urgently in respect of that aspect.

29

30 MR HERZFELD: I understand. There is obviously some -

31 I think Ms Collins has already mentioned it - broader

32 process about what may happen to remedy that.

33

34 PUBLIC INQUIRER: It doesn't matter, Mr Herzfeld.

35

36 MR HERZFELD: My point is that it is not that it is just

37 being ignored, but I understand what you are putting to me.

38

39 PUBLIC INQUIRER: I'm saying that the Trustees appear to

40 be in breach of trust, as I sit here and as I've been told

41 today, and that is what I'm referring to. Having now been

42 given that evidence on oath, it does seem to me that

43 really, really urgent consideration should be given to

44 rectifying, either stopping the provision of the services

45 until it can be clear that there will be no breach by the

46 Trustees, or, alternatively, seeking some assistance from

47 the Supreme Court.



1

2 MR HERZFELD: I understand what has been put to me.

3

4 PUBLIC INQUIRER: Thank you. Come back into the witness

5 box, please. Yes, thank you, Ms Collins.

6

7 Yes, Mr Cheshire.

8

9 MR CHESHIRE: Thank you.

10

11 Q. Ms Collins, I asked you about the development of the

12 website. Who was involved in that process with you?

13 A. Mr Luong, and in terms of the payment gateway,

14 I believe we would have asked Ms Mulliner.

15

16 Q. You gave some evidence before morning tea about you

17 believing that somebody reported to Mr Perrin. Mr Perrin

18 was one of the Trustees of WBI; correct?

19 A. Yes.

20

21 Q. But he was also Chief Executive Officer of RSL (NSW)?

22 A. Yes.

23

24 Q. You've given evidence about how the financial side of

25 WBI was effectively outsourced to RSL (NSW)?

26 A. Yes.

27

28 Q. To your understanding, did Mr Perrin have any

29 involvement with WBI by virtue of his RSL (NSW) role?

30 A. I'm not sure I would know that.

31

32 PUBLIC INQUIRER: Q. Did he communicate with you as

33 Chief Executive Officer of RSL (NSW) from time to time or

34 not?

35 A. No, not really.

36

37 MR CHESHIRE: Q. What dealings did you have with the

38 Trustees in WBI?

39 A. I attended a monthly meeting of the Trust. There were

40 occasions - I was asked if I needed to see anyone during

41 the month about an urgent matter, that I should first

42 approach Mr Perrin because he was in the building. There

43 were occasional meetings with Mr Perrin. Then, if there

44 was something outside my delegation, I would often email

45 all three Trustees.

46

47 Q. Am I right that your first port of call was often



1 Mr Perrin because he was in the building; is that right?

2 A. They asked me to see Mr Perrin, yes, if I needed to

3 speak to a Trustee.

4

5 Q. Did that happen on a regular basis?

6 A. Not regular.

7

8 Q. How often, on average?

9 A. Two to three times a month, perhaps a little more.

10

11 Q. What sort of issues did you discuss with Mr Perrin?

12 A. He would approve my expenditure, credit card

13 expenditure. If I needed to ask matters to Defence and

14 other ex-service organisations, I was new to the sector,

15 I would ask Mr Perrin about that and how he - suggestions

16 for how I would approach, for example, other ex-service

17 organisations and Defence matters.

18

19 He would occasionally refer people to DefenceCare.

20 He would come and see me if he was alerted to someone who

21 was in trouble. That was reasonably regular. They would

22 have been the sorts of matters.

23

24 Q. Mr Perrin wasn't involved, for instance, in the

25 development of the website; is that right?

26 A. I gave the Trustees all the information about the

27 website, including the content. In terms of approval of

28 the website, yes, the detail of the development, no.

29

30 Q. Do you recall that you - I'm not sure whether you

31 still have it, but you had a footer below your emails that

32 you sent out?

33 A. Yes.

34

35 Q. And the footer referred to DefenceCare being a charity

36 providing welfare and pension services; correct?

37 A. Yes.

38

39 Q. For current and ex-serving Defence Force personnel and

40 their families; correct?

41 A. Yes.

42

43 Q. And also referring to donations over $2 being tax

44 deductible; correct?

45 A. Yes.

46

47 Q. And making a real difference; correct?



1 A. Yes.

2

3 Q. And then saying "Your support is appreciated";

4 correct?

5 A. Yes.

6

7 Q. Did it occur to you that the sending out of that email

8 invited people to donate to WBI?

9 A. Yes.

10

11 Q. And, therefore, did it occur to you that by sending

12 out that email, you, effectively, were engaging in

13 fundraising?

14 A. Yes.

15

16 Q. So you understood, did you, that that was part of

17 fundraising?

18 A. Yes.

19

20 Q. You considered, did you, the obligations of the

21 Charitable Fundraising Act in respect of donations that

22 might come in in response to your emails?

23 A. In terms of my responsibility, yes, my area of

24 responsibility, yes.

25

26 Q. The email that I just took you to referred to both

27 current and ex-servicemen; do you recall that?

28 A. Yes.

29

30 Q. It appears even though you were aware of the objects

31 being limited to ex-defence personnel, on your footer you

32 still included "current"; correct?

33 A. Yes. Could I explain?

34

35 Q. Yes.

36 A. When I raised the breach of the objects with the

37 Trustees in November 2012, I specifically asked -

38 I actually - sorry, I provided what I considered some

39 interim solutions while they sought to address the breach.

40 I suggested to them that we adopt these interim solutions

41 so that we were not in breach, because many of the current

42 serving people we were helping were actually on the way to

43 a medical discharge and the Trustees specifically told me

44 that I was not to implement those changes and that I was to

45 continue to operate as they had asked me to operate,

46 because the initial response they gave me was they were not

47 sure it was a breach.



1

2 Q. Did you discuss with anybody whether you should, in

3 fact, have the reference in your email footer to "current"

4 as well as "ex"?

5 A. I believe that was part of the instruction that they

6 gave me to continue to use "current". In fact, they

7 approved the brochure and the word "current".

8

9 Q. When you say "the brochure", do you mean a fundraising

10 brochure that is provided to the public?

11 A. A brochure about DefenceCare services. There actually

12 was only one small brochure. It did have a section on it

13 for donations, so, in my view it was fundraising, but it

14 also had information on the services.

15

16 Q. Is that a current brochure?

17 A. It has been changed slightly, but there is still a

18 brochure. We have now amended it and taken offer the

19 donation section because we are not fundraising.

20

21 Q. But that was only taken out recently during the course

22 of this Inquiry; is that right?

23 A. When we stopped fundraising.

24

25 Q. Putting that aside, that still refers to "current" as

26 well as "ex"?

27 A. Yes, it does.

28

29 Q. I think I'm right - one of the things that you looked

30 into in about August of last year was the appeals; correct?

31 A. Yes.

32

33 Q. There was a formal committee that was set up to do

34 that; is that correct?

35 A. Are you referring to the Operational Review Committee?

36

37 Q. If that's what it was called, then yes.

38 A. I recommended to the Trustees that we set up an

39 Operational Review Committee which was different to the

40 Appeals Committee that I understand ran before.

41

42 Q. As I recall your evidence, you weren't sure whether

43 the Appeals Committee was in fact part of WBI; correct?

44 A. I wasn't. I believe I was - I thought I was told it

45 was reported to State Council, but I did not see the

46 minutes, so I didn't see anything to show that, but I was

47 told that and I believed that at the time.



1

2 Q. Was the operational review committee then, as you saw

3 it, a way of getting these appeals back within WBI so that

4 there was no doubt about it?

5 A. No, it was more than that. That was one aspect that

6 bothered me. It was more than that. I had flagged, when

7 I first was asked to take over appeals, a number of

8 questions, early questions that bothered me, and I felt

9 that I didn't understand enough about appeals. They were

10 enough to flag concerns, but I wasn't aware enough about it

11 as to know how serious the concerns were. So my

12 recommendation, I think it was at the 30th or the 31st

13 August meeting, was that we should set up an Operational

14 Review Committee to truly understand how appeals operated

15 and investigate all aspects that may be of concern, but one

16 of those was governance, one of those things that I saw.

17

18 Q. In terms of the issues then that you had that led you

19 to recommend setting up this review, was one of those

20 issues that you were concerned there might well be breaches

21 of the Charitable Fundraising Act?

22 A. Yes.

23

24 Q. And also that there appeared to be no central system

25 by which all of the appeals were operated; is that right?

26 A. I'm not sure what you mean by "central system".

27

28 Q. If WBI or DefenceCare is running lots of appeals, they

29 should all be operated in a similar way?

30 A. Oh, yes, sorry, yes.

31

32 Q. And that appeared not to be the case; correct?

33 A. Yes.

34

35 Q. As the review was carried out, you became aware that

36 it appeared that there were issues of non-compliance;

37 correct?

38 A. Yes.

39

40 Q. One of those issues, I think, related to the

41 involvement of the sub-branches; correct?

42 A. Yes.

43

44 Q. To your understanding, the sub-branches were raising

45 money through the Anzac Day Appeal and the Poppy Day

46 Appeal; is that right?

47 A. Yes.



1

2 Q. When they were carrying out those appeals, were they

3 carried out, as you understood it, under their own

4 authority or using WBI's authority?

5 A. My view was it should have been under WBI's authority,

6 but that was one of the early issues that was of concern to

7 me, because there was seen to be a reliance on the

8 sub-branches charitable fundraising authority by virtue of

9 the way that the amount of money that was paid by the

10 sub-branches for the tokens, and I didn't understand why

11 that was the case.

12

13 Q. Why did you think it should be done under the WBI

14 authority?

15 A. I thought - well, the appeals were being run by WBI

16 and it was the fundraising authority, and I presumed the

17 sub-branches, this was back in August 2016, were operating

18 as volunteers for WBI.

19

20 Q. As you were looking into this, did the donations

21 appear to be flowing from the sub-branches into WBI or into

22 RSL (NSW), or both?

23 A. I'm just trying to - I became increasingly aware that

24 the money was - the net proceeds were being banked in,

25 I found out subsequently, an account, RSL Appeals (NSW),

26 which subsequently I found out is an account of WBI, but

27 I actually didn't see the bank account so I couldn't

28 actually tell you for certain that the money flowed there.

29 But I was of that understanding that the money was being

30 banked - the net proceeds of the appeals was being banked

31 in the RSL Appeals account, WBI, but initially the gross

32 was being paid into sub-branches's accounts. I'm sorry,

33 I'm not sure if I've explained that very well.

34

35 PUBLIC INQUIRER: Q. You have explained it very well.

36 A. Yes.

37

38 MR CHESHIRE: Q. You had a concern that the sub-branches

39 appeared to be taking out money before they passed it on to

40 WBI?

41 A. Yes.

42

43 Q. At this time, this is after Ms Mulliner has gone on

44 leave; correct?

45 A. Yes.

46

47 Q. And at this time you are taking back control of the



1 financial affairs?

2 A. Starting to, yes.

3

4 Q. Then, as part of your review, did you not look into

5 the RSL's appeals bank account?

6 A. Not the bank account. Mr Umrigar was part of the

7 review committee and he brought the reports that he could.

8 He did not bring transaction records. He brought the

9 reports out of the financial system Sage that RSL (NSW) is

10 using, and was using then, were inadequate to truly

11 understand what was happening. I'm not sure - sorry, I'm

12 not sure that answered your question there.

13

14 Q. Is the effect of that that the operational review

15 revealed a number of deficiencies; correct?

16 A. Yes.

17

18 Q. But it didn't fully get to the bottom of everything

19 that was going on; is that right?

20 A. No, it didn't.

21

22 Q. When a decision then was made to proceed with the

23 Anzac Day Appeal in April of this year, as I understand it,

24 you had considerable issues at that time that you had

25 identified as to non-compliance; correct?

26 A. I had started to identify the issues of what

27 I believed were non-compliance, that I believe we needed to

28 get legal advice on. The preparation from the Anzac Appeal

29 started in approximately early January. In terms of time

30 frames, it probably was about the same time I was becoming

31 increasingly aware of compliance issues.

32

33 Q. I think your evidence is that, as you say, with the

34 benefit of hindsight, the compliance issues or breach

35 issues were such that you ought to have recommended

36 cancellation of the Anzac Appeal to the Trustees; correct?

37 A. With the knowledge I have now, yes.

38

39 Q. After the Anzac Appeal, in May, there was an

40 application for a further fundraising authority; correct?

41 A. Yes.

42

43 Q. In that WBI's authority was coming up for renewal;

44 correct?

45 A. Yes.

46

47 Q. Given the issues of breach that you had identified at



1 that stage, why was a decision taken to proceed with the

2 application?

3 A. I'm not 100 per cent sure in terms of the issues that

4 I actually was fully across sufficient of the issues to be

5 able to form a full view as to whether - as to the extent

6 of the issues and also the potential remedies for the

7 issues.

8

9 Q. Am I right that the compliance review, I think, was

10 commenced in August of last year; is that right?

11 A. It was an operational review.

12

13 Q. The operational review. In terms of getting to the

14 bottom of what, in fact, was going on, do you feel that

15 you've got to the bottom of it now?

16 A. Yes.

17

18 Q. May I take it from the timetable of applying in May,

19 that that is a a view that you've only come to the last

20 month or so?

21 A. I would say around about by the end of July I think

22 I felt fully across the issues. One of the last issues

23 came about in July.

24

25 Q. And at that stage --

26 A. End of July, August, sorry. Sorry.

27

28 Q. Then, at that stage, a decision was made to suspend

29 fundraising activities; correct?

30 A. Yes.

31

32 Q. Was that your decision or the Trustees's decision?

33 A. I made that decision and immediately emailed the

34 Trustees.

35

36 Q. In terms of actioning it, was it your decision that

37 you informed them about, or was it a recommendation to

38 them?

39 A. I informed them about it.

40

41 PUBLIC INQUIRER: Q. Can I just clarify something

42 because of other material that has been received in the

43 Inquiry. I apprehended that what had happened is that

44 Fair Trading had communicated with you and advised you that

45 you were not able to fundraise while the fundraising

46 authority was not extant; is that right?

47 A. Yes, that's right.



1

2 Q. So, as a result of that communication, there was the

3 suspension; is that right?

4 A. That's right, yes.

5

6 PUBLIC INQUIRER: Yes, thank you. Yes, Mr Cheshire.

7

8 MR CHESHIRE: Q. As I understand it, you understand the

9 position to be that fair trading has not yet made a

10 decision; correct?

11 A. We've received correspondence from Fair Trading that

12 I have forwarded on to the Trustees for their

13 consideration, that lists certain requirements that now

14 need to be met.

15

16 Q. That was the letter of 22 September; is that correct?

17 A. I'm not sure of the date.

18

19 Q. Would you look at paragraph 226 of your statement.

20 A. Oh, yes. Yes.

21

22 Q. That's the letter to which you refer?

23 A. Yes.

24

25 Q. As at today's date, is it right that WBI has not yet

26 provided the various confirmations that Fair Trading have

27 sought?

28 A. No, not that I know of.

29

30 Q. To your understanding, as and when that information is

31 provided to Fair Trading, if further authority is granted,

32 then it would be the intention of WBI to resume

33 fundraising; is that right?

34 A. No, that would be a decision for the Trustees. It's

35 not something that will necessarily happen.

36

37 Q. Do you have any understanding of whether that is the

38 current intention of WBI?

39 A. No, I believe the Trustees are looking at a number of

40 options, one of which is to not fundraise.

41

42 Q. When you say looking at a number of options, have they

43 had discussions with you about those options?

44 A. I've had some input.

45

46 Q. And what options are being discussed?

47 A. I believe there are a number of options relating to



1 the structure of RSL (NSW) and its entities in total.

2

3 Q. Yes. What options have been discussed with you?

4 A. The possibility of WBI not continuing as a trust and

5 potentially application being made to the court for WBI not

6 to continue and for DefenceCare to move to potentially

7 another entity, but I understand it is only discussions at

8 this stage.

9

10 Q. Is that an option with which you would agree or

11 disagree?

12 A. Depending on the detail. I think the services that

13 DefenceCare provides are absolutely invaluable and are in

14 incredibly high demand. It would be my hope that the

15 services that have been established would continue. If

16 there was a vehicle that would enable it to continue and to

17 be able to fill the demand, it would be infinitely

18 preferable. At the moment, DefenceCare - we are literally

19 run off our feet in terms of the number of calls and we

20 can't meet the demand. I would truly love to see the

21 services, the really good work that DefenceCare does,

22 continue. I don't think it matters necessarily what legal

23 entity. If there's a better way and a better funding

24 model, I think that would be excellent.

25

26 Q. The issue of the objects that I've asked you about, is

27 that a factor in setting out DefenceCare in a different

28 organisation?

29 A. That would be a matter for the Trustees.

30

31 Q. When I asked you as to whether you thought it would be

32 a good thing, you said it wouldn't matter where it was

33 done?

34 A. Yes.

35

36 Q. Am I right that if it was done in a different entity

37 that had objects that extended to current service

38 personnel, that would at least remove that problem of WBI

39 being in breach?

40 A. It would. It would.

41

42 Q. Had that occurred to you before?

43 A. Yes, in November 2012 I recommended to the Trustees

44 that they consider setting up a new legal entity, a new

45 charity, and I think I even suggested a company called

46 DefenceCare Limited and to wind down WBI.

47



1 Q. As you understand, when you say to "wind down WBI", is

2 it your understanding that the fundraising activities would

3 go to wherever DefenceCare goes?

4 A. That's if it was to be a charitable entity that

5 required fundraising to sustain itself. Would you like me

6 to explain a bit about that?

7

8 Q. Yes, please.

9 A. DefenceCare is a professional service model with

10 professional services. I find that in those

11 instances - and my background is from a charity when you're

12 providing professional services, there are alternate income

13 options, and one of those is grants. There are a

14 considerable number of bodies that are willing to offer

15 grants for the delivery of services.

16

17 We also at DefenceCare tendered for the delivery of a

18 pilot peer to peer support program. We tendered with the

19 DVA and we were successful with that tender. That's

20 another source of income. And it was actually - I'm a

21 believer, very strongly, of the importance of charities

22 having a sustainable income because of the value of their

23 services. I actually had raised on a number of occasions

24 with the Trustees potentially establishing a business that

25 could fund DefenceCare so that it did not need to rely on

26 donations, because we were so struggling with the demand

27 and trying to meet that demand.

28

29 Q. What business did you have in mind setting up to fund

30 DefenceCare?

31 A. A funeral service, because we were asked to - we had a

32 lot of clients, veterans who had no family left and no-one

33 to pay for the funeral, or the significant funeral costs

34 were actually quite devastating to many of the families.

35 We were already providing significant assistance to meet

36 the hardship of some families. I believed that potentially

37 that may be a service we could provide that could possibly

38 earn some income and feed into DefenceCare or WBI.

39

40 Q. Am I right that in terms of the sources of income that

41 you envisage as being realistic for DefenceCare, one of

42 them is to have a business model where the business

43 supports DefenceCare, other one of which is to have grants

44 supporting DefenceCare, and another one of which is to have

45 donations. Do you see those three as being exclusive or do

46 you see it being realistic to either have a combination of

47 two of them or all three?



1 A. I think you can have all three. Certainly a lot of

2 charities do have all three. The previous organisation

3 I worked for, we were government funded, and we also had a

4 significant number of grants. That was a program

5 I initiated. We also had charitable fundraising as well,

6 but the charitable fundraising was heavily regulated and we

7 had a compliance officer - we ran Charity Housie and

8 clothing collection bins. They weren't part of my

9 responsibility, except the Charity Housie in the last

10 couple of years which was run by a compliance officer.

11 I certainly believed that it is a sustainable model, and a

12 number of charities do run business operations.

13

14 I also for the previous charity bought a long day care

15 centre. We were in the children's learning area and the

16 profits from the long day care centre supported the

17 charitable work of the organisation.

18

19 Q. This Inquiry has heard evidence about the potential

20 for there to be at least a tension between business, on the

21 one hand, and benevolence on the other, in that if you have

22 a business model, even a charitable business, there is a

23 temptation to use profits to put back into the business to

24 make the business more profitable, which is not necessarily

25 the ideal model of supporting the benevolent side. Is that

26 something which impacts upon what you've just said?

27 A. I don't believe so. I don't believe that you need to

28 put profits back into the business. If the profits of the

29 business are to support the charitable purpose, that's

30 where they should go. I don't necessarily think you need

31 to put profits back into the business.

32

33 Q. Am I right, your view is that as long as the business

34 is sufficiently established and big to support itself, then

35 one doesn't need to keep growing that business; is that

36 right?

37 A. I don't think you need to. I think it depends on the

38 aims and objects of the charity and the needs of the

39 charity and the services of the charity. It may be that

40 some charities decide that they need to grow the business

41 to further the charitable purpose, but ultimately the

42 business is there for the charitable purpose.

43

44 Q. If DefenceCare then is attached to a business, do you

45 see DefenceCare as running its own fundraising or

46 fundraising being dealt with somewhere else?

47 A. That would, I guess, be a matter for how it's



1 structured. When you have a charity, I think you

2 inevitably attract people who would like to donate.

3 I think it really depends on whether, one, you need the

4 donation; whether you want to get a charitable fundraising

5 licence. I think you can be a charity without doing

6 fundraising. I don't think you necessarily have to do

7 fundraising. It does come about that people often want to

8 donate because you are undergoing charitable work. I think

9 it depends on the situation. I think you've just got to be

10 very aware of where your income comes from and how you're

11 structured. I don't necessarily think there's a hard and

12 fast "yes" or "no".

13

14 Q. In relation to WBI, one of the things that I think you

15 talk about is the benefit of the association with the

16 various RSL entities; correct?

17 A. Yes.

18

19 Q. But, at the same time, you also talk about

20 endeavouring to treat WBI and RSL (NSW) as separate

21 entities; correct?

22 A. Yes.

23

24 Q. I think part of your role, part of what you've been

25 doing in the last year or so, is to achieve some form of

26 separation, for instance, with the financial affairs to

27 ensure that they come back to WBI rather than stay with


29 A. Yes.

30

31 Q. In this business model that you have raised the

32 possibility for with WBI going forward, or DefenceCare

33 going forward, how does that, then, fit in with RSL (NSW)?

34 Is it your view that the two should proceed together or

35 that there should be some separation?

36 A. I think the legal entities' governance needs to be

37 well managed and appropriate. Whether there's separation,

38 I guess, will depend on where DefenceCare resides

39 ultimately, what legal entity it is a part of, if it is not

40 a part of - if it is not a separate legal entity in and of

41 itself. I think whatever combination is decided upon by

42 RSL (NSW) State Council, and ultimately the Trustees, needs

43 to be done with the utmost care and the utmost

44 appropriateness of governance. What that is and how that

45 comes about, I'm sure I will have input, but ultimately,

46 obviously, it's not my decision.

47



1 Q. But in terms of where one puts DefenceCare, for

2 instance, would it be your view that DefenceCare could,

3 effectively, be run by RSL (NSW)?

4 A. It is in other States. That is a model where the

5 services provided by RSL - similar services, claims and

6 advocacy and welfare - are actually part of the RSL State

7 Branch in other States. I don't know about every state but

8 certainly some other States such as Victoria and

9 Queensland. I believe, or I was told when I first joined

10 the organisation, that one of the reasons that WBI was set

11 up was related to the Constitution and the statute that

12 governed RSL (NSW), although I haven't investigated it, but

13 I understand the issue - I was told the issue was that

14 RSL (NSW) wanted to provide additional services to

15 non-members, to veterans who were non-members, and that,

16 I believe, was not possible through the current

17 Constitution and the statute, but I have not investigated

18 that, so I can not be sure of that.

19

20 I understand that's the reason they set up the trust.

21 If that changed, if it was possible to do it under

22 RSL (NSW), I don't see why that wouldn't be an option.

23

24 Q. That's not attaching it to a business model, is it?

25 A. No, that would be part of RSL (NSW).

26

27 Q. You wouldn't envisage attaching a business model then

28 to RSL (NSW); is that right?

29 A. You wouldn't need to, necessarily, although the

30 RSL (NSW) runs the Hyde Park Inn now.

31

32 Q. Also, with the fundraising, you're aware that the

33 sub-branches are answerable to the State Branch; correct?

34 A. I am aware, yes.

35

36 Q. And you're aware that a number of the sub-branches

37 have their own fundraising authorities; correct?

38 A. Yes.

39

40 Q. So it would seem to make some sense for RSL (NSW) to

41 continue to have some involvement in fundraising; correct?

42 A. Yes.

43

44 Q. And so that model would seem at least to have some

45 sense of fundraising being collected under RSL (NSW), would

46 that be --

47 A. It's possible. That's a possible model.



1

2 Q. You accept that certain possibilities have been

3 discussed with you. Is that one of the possibilities that

4 has been discussed with you?

5 A. No, I don't believe so, no, I don't recall that

6 particular model.

7

8 Q. What then are the possibilities that have been

9 discussed with you?

10 A. The potential for DefenceCare to be part of a

11 professional service organisation that comprises both the

12 LifeCare professional services and DefenceCare professional

13 services.

14

15 Q. You say DefenceCare. So DefenceCare to be moved over,

16 effectively, to LifeCare; correct?

17 A. Possibly.

18

19 Q. Would that leave anything left for WBI to do?

20 A. If you include RSL Active as part of DefenceCare, no,

21 it would not leave anything left.

22

23 Q. As you understand it, as least one of the suggestions

24 is to move across all of WBI to LifeCare?

25 A. That's a possibility.

26

27 Q. To your understanding, then, what happens to

28 fundraising on that scenario?

29 A. I don't know of RSL LifeCare's fundraising plans, I'm

30 sorry.

31

32 Q. What about fundraising within RSL (NSW), under that

33 model?

34 A. It could still continue, if it could be compliant.

35

36 Q. Is it your understanding that RSL (NSW) would wish to

37 continue fundraising?

38 A. I've heard the comment, but I'm not - I haven't been

39 involved in discussions. That would be a matter for

40 State Council.

41

42 Q. Am I right, you now have the position of General

43 Manager of both WBI and RSL (NSW)?

44 A. Yes.

45

46 Q. Do I take it from your answers that those proposals

47 are, as you understand it, nothing more than proposals



1 being discussed at the present time; is that right?

2 A. I'm not up to date with where it's at, I'm sorry.

3

4 Q. To your understanding, they haven't got beyond that

5 stage; is that right?

6 A. I don't know, sorry.

7

8 Q. Have you seen a formal document that has details for

9 this proposal?

10 A. I haven't, no.

11

12 Q. You're not aware of any resolutions from any of the

13 entities for a particular proposal to proceed; is that

14 right?

15 A. No. No, I'm not aware.

16

17 Q. I showed you I think, or you referred to the letter

18 from Fair Trading of 22 September. Am I right that at the

19 moment WBI is not in a position to provide Fair Trading

20 with all of the information that it requested; is that

21 right?

22 A. Would you like me to --

23

24 Q. Please do. You have an advantage, can you remind me

25 of the paragraph?

26 A. I'm sorry, it is 226.

27

28 Q. 226. Thank you. Would you then go through each of

29 those?

30 A. Okay. In terms of (a), yes, the new financial and

31 payroll system is in place. We have done an internal

32 assessment and believe it meets regulatory requirements.

33 It has not been externally assessed, though. We have

34 appointed a new auditor and that auditor will be starting

35 on 23 October. That's a tentative date but we believe that

36 will eventuate. They will be auditing the 2016 and the

37 first half of the 2017 annual accounts, and that is

38 Ernst & Young.

39

40 We would be able to advise New South Wales Fair

41 Trading of any fundraising appeal we intend to conduct, but

42 at this stage we do not intend to conduct any fundraising

43 appeals, and then we could notify them of any instance of

44 non-compliance with the Act.

45

46 Q. Am I right that at least in respect of (c), that will

47 depend upon a decision being made as to the structure going



1 forward?

2 A. I would imagine so. That may have some bearing on it,

3 but I can't be sure.

4

5 Q. Because if in fact all of the affairs of WBI are to be

6 transferred, for instance, to LifeCare, then WBI would not

7 be intending to conduct any further fundraising appeals;

8 correct?

9 A. I believe that would happen, yes.

10

11 Q. You started to become more involved and to look into

12 the affairs of WBI in the middle of last year, as I

13 understand it?

14 A. Yes.

15

16 Q. Since then, there are various steps that have been

17 taken to try to improve the way in which WBI operates;

18 correct?

19 A. Yes.

20

21 Q. You have referred to Mr Luong who was replaced by

22 Ms Rocchi. Their title was, was it, marketing and

23 fundraising?

24 A. Mr Luong's title is marketing and fundraising and

25 I believe we made it fundraising and marketing for

26 Ms Rocchi.

27

28 Q. Is Ms Rocchi still there?

29 A. Yes.

30

31 Q. What's her current title?

32 A. Now it's fundraising manager.

33

34 Q. What's happened to marketing?

35 A. We split the function and we have a marketing

36 coordinator.

37

38 Q. Why was the function split?

39 A. I was asked to take over the appeals and because we

40 were starting to have numerous concerns over the appeals,

41 I had a number of discussions with Ms Rocchi, with

42 Ms Pinkstone, who was the marketing corporations manager

43 for RSL (NSW), and we decided over the course of

44 discussions and several meetings that it would be better to

45 separate the function.

46

47 Q. Ms Rocchi currently has responsibility for all



1 fundraising within WBI; is that correct?

2 A. Yes.

3

4 Q. To whom does she report?

5 A. She reports directly to me. I'm sorry, her

6 responsibility started in January this year.

7

8 Q. And she reports to you?

9 A. Yes.

10

11 Q. As part of WBI taking back control of its financial

12 affairs from RSL (NSW), am I right that it employed some

13 full-time accounting staff?

14 A. Yes, we did.

15

16 Q. Initially two; is that correct?

17 A. It was initially going to be two, it is now three.

18

19 Q. When was the third person engaged?

20 A. From memory, around 21 or 22 September.

21

22 Q. Of this year?

23 A. This year.

24

25 Q. What are the titles or at least descriptions of what

26 each of those three does?

27 A. We have a finance manager. Our finance manager

28 started on 1 June and we employed an assistant accountant,

29 and the first assistant accountant might have been in July

30 some time, sorry, I'm just not clear on date. Then we

31 employed a second assistant accountant and they're

32 currently in the process of developing the appropriate

33 roles and responsibilities for each of the positions,

34 bearing in mind it's a team of three, so they need to make

35 sure that the appropriate responsibilities are segregated

36 and that we make sure that no one person has responsibility

37 for all things. We have to be very careful in the

38 delineation of those roles and responsibilities and we're

39 working on that at the moment in developing the appropriate

40 role.

41

42 Q. Am I right the two assistants report to the finance

43 manager?

44 A. They do.

45

46 Q. Who does the finance manager report?

47 A. The finance manager reports to Mr Nair, who is the



1 chief operations officer, and he straddles both RSL (NSW)

2 and RSL WBI, as I do.

3

4 Q. To whom does Mr Nair report?

5 A. To me.

6

7 Q. Within both RSL (NSW) and WBI?

8 A. Yes.

9

10 Q. Mr Nair was engaged, I think, in about September 2016;

11 is that right?

12 A. Yes.

13

14 Q. He was engaged at that time as a specialist business

15 analyst; is that right?

16 A. Yes.

17

18 Q. Initially, he was engaged on a one-year contract; is

19 that right?

20 A. I believe so, yes.

21

22 Q. Has that been renewed?

23 A. The contract has been developed as now and a new

24 contract will be given to Mr Nair in the coming week.

25

26 Q. I should have asked, as a specialist business analyst,

27 that's different from being chief operating officer, isn't

28 it?

29 A. It is, yes, I'm sorry.

30

31 Q. That was my fault. What did he do as specialist

32 business analyst?

33 A. He didn't report to me, that was in RSL (NSW). He was

34 brought on by Mr Kolomeitz, reporting directly to

35 Mr Kolomeitz. He didn't report to me.

36

37 Q. Do you know what he did?

38 A. Broadly?

39

40 Q. Yes.

41 A. Broadly, when the problems with the finances were

42 coming about, I suggested to Mr Kolomeitz that perhaps he'd

43 bring in someone such as a specialist business analyst

44 because I believe there needed to be a lot of repair work

45 done, and so as I understand he was brought into the

46 organisation to overview all the financial systems and

47 processes that were occurring in RSL (NSW) and to recommend



1 repairing that. I do know that events that transpired

2 after he joined the organisation meant that he was involved

3 in organising the forensic audits. I'm not sure he had the

4 opportunity to perhaps do what he was brought in to do.

5 I also asked Mr Kolomeitz if I could engage - get Mr Nair's

6 help to rectify the financial issues that I was seeing with

7 WBI.

8

9 Q. Am I right that you understood that Mr Nair was

10 brought in to assist RSL (NSW); correct?

11 A. Yes.

12

13 Q. The task that he was given related to the finances of


15 A. Yes.

16

17 Q. At the same time you were taking over the finances of

18 WBI from RSL (NSW) - at about the same time?

19 A. Not taking over, but investigating and working out how

20 to better obtain financial reports.

21

22 Q. As part of that, you sought to have Mr Nair provide

23 input in relation to WBI; is that right?

24 A. Yes.

25

26 Q. At some stage Mr Nair became involved in WBI, either

27 through that approach or becoming the COO. When did that

28 happen?

29 A. Sorry, which one? The getting involved with WBI or --

30

31 Q. Was its first involved with WBI when he became chief

32 operating officer?

33 A. No.

34

35 Q. When did he first become involved with WBI, then?

36 A. I believe it was probably around about October 2016.

37 I asked him for assistance with two matters: one was

38 potential modifications to the RSL (NSW) finance system so

39 that we could get appropriate reporting to the Trustees,

40 and the other was to do with the objects of WBI and to

41 source an alternate legal advice.

42

43 Q. Did Mr Nair assist with both of those tasks?

44 A. Yes.

45

46 Q. Then at some stage he became chief operating officer

47 of both organisations; is that right?



1 A. Yes, recently.

2

3 Q. Was that at the same time as you became

4 General Manager of both?

5 A. Shortly after.

6

7 Q. Dealing with the financial system, that was the Sage

8 financial system; is that right?

9 A. Yes.

10

11 Q. Was the financial system for RSL (NSW), the Sage

12 system, the same as for WBI?

13 A. WBI's financial system is called Microsoft Navision.

14

15 Q. Hang on.

16 A. Sorry.

17

18 Q. At the time when Mr Nair started looking at that

19 issue --

20 A. Sorry.

21

22 Q. -- were both being operated through Sage?

23 A. Yes, I believe so.

24

25 Q. Was it effectively one system being combined between

26 New South Wales and WBI?

27 A. I don't know that level of detail. I assumed so.

28

29 Q. Am I right that Mr Nair raised some issues, problems

30 with Sage; is that right?

31 A. Yes.

32

33 Q. He recommended some modifications; correct?

34 A. Yes.

35

36 Q. Those were not in fact adopted by RSL (NSW); is that

37 right?

38 A. That's right.

39

40 Q. WBI is currently not on Sage; is that right?


42

43 Q. So, at some stage, WBI changed or moved its financial

44 system from Sage to Navision; is that right?

45 A. Microsoft Navision, yes.

46

47 Q. Is that N-A-V-I-S-I-O-N?



1 A. Yes.

2

3 Q. When did that happen?

4 A. Microsoft Navision came online on 1 August this year.

5

6 Q. When you say "came online", does that mean that

7 everything was transferred to it on that date?

8 A. Yes.

9

10 Q. So WBI now has its entire financial records on

11 Navision; correct?

12 A. Only backdated to a certain point, not historical

13 records.

14

15 Q. When you say "only backdated to a certain point", what

16 point is that?

17 A. I believe it's 2016.

18

19 Q. And so for --

20 A. I'm sorry, I might need to check that, I'm not

21 100 per cent certain.

22

23 Q. For records going back to 2012, 2013 or 2010, where

24 are those records?

25 A. They're still on Sage and prior to that I believe they

26 used a system called Coresoft.

27

28 Q. Are they, effectively, still held by RSL (NSW)?

29 A. We requested that the entire financial records be

30 handed over from RSL (NSW) to RSL WBI.

31

32 Q. Right. Did that happen?

33 A. I haven't had an update on that.

34

35 Q. Does WBI still have a Sage system?

36 A. WBI doesn't have a Sage system.

37

38 Q. If the records are held on Sage, how would they be

39 handed over to WBI?

40 A. That's a little bit beyond my technical expertise, but

41 I believe we would - sorry, it is a bit beyond my technical

42 expertise. I would need to get advice as to how that would

43 happen.

44

45 Q. At the moment your understanding is that WBI has its

46 own financial records available going back to 2016;

47 correct?



1 A. Yes.

2

3 Q. Yes. But before that, you don't know what the current

4 position is; is that right?

5 A. No, I'm not 100 per cent sure that transfer has been

6 done yet. I believe we keep the files.

7

8 Q. Or indeed, as to how it is going to be done; is that

9 right?

10 A. I'm not across how it is going to be done yet.

11

12 Q. Are you able to assist as to why the change from

13 Navision to change to Sage or how that came about - sorry,

14 from Sage to Navision?

15 A. Oh, yes. In terms of the choice of the system

16 Navision, do you mean?

17

18 Q. Yes, why the change?

19 A. Why the change? Sage's reporting functionality was

20 very poor and very difficult to get the information we

21 needed to make sound decisions to understand where the

22 organisation was financially. The way it had been set up,

23 I understand, was inadequate and the choice of Navision,

24 I had used - transitioned my previous organisation to

25 Navision and it was a very flexible system that could cater

26 for ensuring moneys that were given to an organisation

27 could be expended and acquitted.

28

29 Mr Nair had come from Northcote and Northcote was also

30 using the Navision accounting system, so the choice was

31 made to use that accounting system, or the recommendation,

32 sorry, was made to the Trustees that that was the

33 accounting system and it had a considerable amount of

34 benefit for a charity.

35

36 Q. Is the payroll system operated through Navision?

37 A. No, the payroll system is - we use a system called

38 Aurion.

39

40 Q. When you say you "use", is that also a new payroll

41 system?

42 A. New to WBI, yes.

43

44 Q. How was WBI's payroll being dealt with until recently?

45 A. I'm sorry, RSL (NSW) did the payroll and I'm not

46 across their system.

47



1 Q. Until recently, am I right that WBI's financial system

2 and its payroll system were being dealt with through

3 RSL (NSW)?

4 A. Yes.

5

6 Q. That new payroll system - which I think is Aurion?

7 A. Aurion.

8

9 Q. Came into force on 13 September; is that right?

10 A. Yes.

11

12 Q. Was that due to, as you understand it, deficiencies in

13 the previous payroll system?

14 A. We made the recommendation to the Trustees that we

15 should move not only the finances but also the payroll and

16 the client management system as well, that it was better to

17 move the entire suite primarily because we wanted to move

18 to a Microsoft Office solution, but also because WBI was

19 using a part of the RSL's client relationship management

20 system, which was a Sage system, which had originally been

21 purchased, as I understand it, to cater for the RSL (NSW)'s

22 membership, which meant that it really wasn't - it was

23 modifiable to meet the client management needs of

24 DefenceCare, but it is very slow. It has very poor

25 reporting functionality and it requires a considerable

26 amount of re-entering data, so we recommended to the

27 Trustees that we move - change WBI over to an entire system

28 solution that would better cater for the needs of the

29 services of DefenceCare which involved providing financial

30 assistance.

31

32 Q. So that's, effectively, a movement of three systems;

33 is that right?

34 A. Yes.

35

36 Q. Client management, payroll, financial management?

37 A. Yes.

38

39 Q. Am I right that the last piece of the jigsaw was the

40 payroll system; is that right?

41 A. No, the client relationship - the client management

42 system is the last piece.

43

44 Q. Has that happened yet?

45 A. No, we have to get someone in to help us with scoping

46 that and we hope that will be all up and running by no

47 later that March next year.



1

2 Q. You talked about having all three systems on, I think

3 you said, a Microsoft platform?

4 A. A Microsoft Office platform, yes.

5

6 Q. So you see that there is an advantage in the three

7 systems working together; is that right?

8 A. Yes.

9

10 Q. At least until some time after March of next year, you

11 won't know how successful in fact it has been; is that

12 right?

13 A. I think we're already seeing some success. I'm sorry,

14 Aurion is not a Microsoft office, I'm sorry. Aurion is not

15 part of the Microsoft Office platform, but it's a very

16 capable and very high quality payroll system.

17

18 Q. Does that interact with the other two systems or not?

19 A. Well, it interacts with Navision.

20

21 Q. Navision is the financial management system?

22 A. Yes.

23

24 Q. What is the new client management system going to be

25 called?

26 A. I'm not sure it has a name other than Microsoft CRM.

27 It may have a name I'm not aware of, but the at Microsoft

28 Office Suite CRM.

29

30 Q. In terms of the client management system and the

31 financial management system and how they work together,

32 that's something you won't know until March of next year;

33 is that correct?

34 A. We will need to work that out in terms of the

35 implementation.

36

37 Q. That will be after March of next year?

38 A. It will be progressive, but in terms of how it works

39 together - sorry, your question, yes, it will be after

40 March next year, sorry.

41

42 Q. When you say it will be progressive, it will be

43 progressive leading up to March of next year or progressive

44 from March next year?

45 A. No, leading up to. We hope that it will functional

46 from March next year.

47



1 Q. From March next year, WBI should have all of its

2 systems in place as it wants it going forward; is that

3 right?

4 A. Yes.

5

6 Q. Those systems you perceive to have significant

7 advantages over the previous systems; correct?

8 A. Yes.

9

10 Q. RSL (NSW) is currently still using, effectively, the

11 old systems; is that right?

12 A. Yes.

13

14 Q. Is there any plan that you're aware of to move over

15 the RSL (NSW) systems?

16 A. Yes.

17

18 Q. What stage is that at?

19 A. At the last finance and remuneration committee meeting

20 last week, we put up a proposal to move the RSL (NSW)

21 finances to Navision.

22

23 Q. But having its own Navision system or combined with

24 WBI?

25 A. Its own.

26

27 Q. If that is put into operation, when it that likely to

28 be achieved?

29 A. I'm just - we do I have a timetable, sorry. I'm just

30 trying to recall it. March next year.

31

32 Q. What about the client management system for RSL (NSW)?

33 A. We haven't as yet prioritised that. That would be a

34 lower priority to the financial system and the payroll

35 system.

36

37 Q. What about RSL (NSW)'s payroll system?

38 A. That will be, I would imagine, we are looking at

39 transitioning that to Aurion. I can't recall the date off

40 the top of my head as to our plan for that.

41

42 Q. Are we talking March of next year, June of next year?

43 A. Oh, everything finished - sorry, Navision and the

44 payroll system completed by June of next year.

45

46 Q. I think you said that Mr Nair has also conducted a

47 review of the Navision system; is that right?



1 A. A review? Sorry, could you clarify "a review"?

2

3 Q. Has Mr Nair looked at the new financial management

4 system?

5 A. For WBI?

6

7 Q. Yes.

8 A. Yes, Mr Nair was involved in the implementation

9 process.

10

11 Q. Is Navision, as you understand it, set up to generate

12 records specifically limited to fundraising?

13 A. Yes, although - could I answer that with an

14 explanation?

15

16 Q. Yes.

17 A. I'm not 100 per cent sure a financial system alone can

18 meet the requirements of the Fundraising Act as I

19 understand them, and as a result of the learnings from this

20 journey. My belief is that the requirements of the Act,

21 the regulation and our authority, really need management

22 that includes both the financial system and the bank

23 accounts, and also the policies and procedures that

24 surround everything you do in terms of the transactions,

25 the accounts payable, receivable, et cetera. I believe it

26 needs to be a suite of things that one alone - I'm

27 struggling to find, with the way the current legislation is

28 and the regulations - to be able to implement the

29 appropriate compliance without taking into account more

30 than the financial system.

31

32 Q. That process of trying to work out precisely what you

33 need to achieve compliance, who is looking into that?

34 A. Mr Nair and the finance team are looking into that and

35 they are already at the stage of having implemented, along

36 with the bank accounts and the procedures and the setup of

37 Navision, a system whereby we believe it can now be fully

38 compliant with charitable fundraising legislation. There

39 are other aspects, however, that are of concern that we

40 will need to look at, certainly in coming weeks, and there

41 are aspects of the Charitable Fundraising Act legislation

42 such as items, such as what is a lawful expense and how we

43 review the expenses. So there are a number of questions

44 still to look at, but the basic structure and the basic

45 processes are already in place.

46

47 Q. On those questions, such as what is a lawful expense,



1 have you been receiving legal advice?

2 A. Yes. We have been receiving legal advice for the past

3 not quite 12 months, possibly nine months, on all aspects

4 of compliance from a financial systems perspective, but

5 also with the policies and procedures, with how fundraising

6 is conducted by volunteers, quite overarching advice

7 related to a huge number of issues.

8

9 Q. Is that advice ongoing?

10 A. Yes.

11

12 Q. Who is that advice from?

13 A. Ashurst.

14

15 Q. Do you recall that earlier this year there were

16 reports that were obtained from Ernst & Young that revealed

17 certain deficiencies in the financials - for instance, the

18 bank accounts of RSL (NSW) and WBI?

19 A. Yes.

20

21 Q. Am I right that the issue of financial compliance was

22 a matter that Ernst & Young were looking into; correct?

23 A. Financial compliance of WBI?

24

25 Q. Yes.

26 A. Yes.

27

28 Q. And also of RSL (NSW)?

29 A. Compliance of RSL (NSW)?

30

31 Q. Yes.

32 A. Sorry, in what --

33

34 Q. In respect of fundraising?

35 A. In respect of fundraising - I understood they did the

36 forensic audit of RSL (NSW), in terms of compliance of its

37 financial system. I know Ernst & Young has put a proposal

38 to the Trustees for the WBI financial system.

39

40 Q. Let's deal with --

41

42 PUBLIC INQUIRER: Perhaps we could do that at 2 o'clock.

43

44 MR CHESHIRE: Yes, Madam Inquirer.

45

46 PUBLIC INQUIRER: Thank you, Ms Collins, would you like to

47 step down now and we will adjourn until 2pm. Yes, thank



1 you.

2

3 LUNCHEON ADJOURNMENT

4

5 PUBLIC INQUIRER: Yes, thank you. Come back into the

6 witness box, please, Ms Collins. Yes, Mr Cheshire.

7

8 MR CHESHIRE: Q. As I understand, Ms Collins, you are

9 aware that a number of reports have been prepared by

10 accountants in respect of WBI and RSL (NSW) over recent

11 years; correct?

12 A. Yes.

13

14 Q. For instance, you're aware of the 2015 Grant Thornton

15 review into expenses, particularly of the State President?

16 A. I am now, yes.

17

18 Q. You're aware that, as I understand it, steps have been

19 taken within RSL (NSW) to put in place, as I think you call

20 it, an expense limit matrix; correct?

21 A. Yes.

22

23 Q. Does that cover the matrix for all of the State

24 Councillors?

25 A. That particular matrix is for the State Councillors,

26 yes.

27

28 Q. Is there another matrix for the employees of

29 RSL (NSW)?

30 A. There will need to be as well. We have not yet got to

31 that.

32

33 Q. Does the State Councillors's matrix also encompass the

34 State President?

35 A. Yes. Could I just clarify that? We put that matrix

36 up to the finance and remuneration committee, but it still

37 has to go to State Council.

38

39 Q. Was it approved on 9 October?

40

41 PUBLIC INQUIRER: At the meeting?

42

43 MR CHESHIRE: Q. At the committee?

44 A. Was it approved? Sorry, the State expenses matrix?

45 Yes, they agreed with it, yes, but it will need to go to

46 State Council as well.

47



1 MR CHESHIRE: Q. Yes, but it went to them presumably for

2 approval, is that right, to the committee?

3 A. Yes, it went to the committee.

4

5 Q. For approval?

6 A. I'm sorry, I'm struggling to recall whether it was for

7 recommendation or decision. No, when we put that matrix

8 up, the State Councillor expenditure matrix, it was for

9 discussion and the committee decided that they would take

10 it to the next State Council meeting.

11

12 Q. Are you telling the Madam Inquirer that in fact the

13 committee did not make any decision as to whether they

14 approved it or recommended it?

15 A. They agreed with it and will recommend it. They will

16 recommend it.

17

18 Q. When will that go to State Council?

19 A. The next State Council meeting is 19 October.

20

21 Q. Do you expect that that document will be put before

22 State Council on that date?

23 A. Yes.

24

25 Q. If it is approved, to your understanding, it will then

26 be in force; is that right?

27 A. Yes.

28

29 Q. What about in WBI, is there any similar exercise that

30 has been carried out?

31 A. In WBI, we have a delegation matrix that covers the

32 Trustees as well as the employees. In WBI, we had also

33 developed guidelines for expenditure for employees - this

34 was several months ago - to develop some more clarity

35 around guidelines for expenditure for employees. It is

36 slightly different.

37

38 Q. Do you still have a credit card?

39 A. I do.

40

41 Q. And that's a credit card that I asked about earlier

42 that is then billed to the Hyde Park Inn?

43 A. I understand that facility is still in the

44 Hyde Park Inn's name.

45

46 Q. Do you have any guidelines as to the amount that you

47 can spend on particular items?



1 A. Well, I have an expenditure delegation, an overall

2 delegation, but not specific items, not at the moment.

3

4 Q. When you say a "delegation", what does the delegation

5 specify?

6 A. The delegation specifies an amount per approval that

7 I can approve, and on the credit card it is an expenditure

8 limit.

9

10 Q. What is that expenditure limit on your credit card?

11 A. The delegation I have is $10,000, although I believe

12 the credit card limit is still $5,000 which is the limit I

13 had on the credit card when I was in WBI.

14

15 Q. In terms, though, of individual items that you may use

16 the credit card for, do you have any guidelines or guidance

17 in that regard?

18 A. Yes, there's a credit card policy and that does list

19 the sorts of things - work-related expenditure that you can

20 put on the credit card.

21

22 Q. Things such as entertaining guests, is that a matter

23 that could come within the credit card policy?

24 A. Possibly, yes, it would, if it's work-related

25 expenditure.

26

27 Q. Does the policy have any limits for each item?

28 A. Not that I can recall.

29

30 Q. For instance, if you were taking a guest out for a

31 meal, is there anything that would indicate to you, other

32 than your common sense or your honesty, as to whether you

33 should spend $100 on dinner or $10,000 on dinner?

34 A. Well, if it's within WBI, yes, we have some guidelines

35 that indicate the approximate amounts that would be

36 reasonable for taking - if you were to take a guest out to

37 lunch.

38

39 Q. What I'm after is what form do those guidelines take

40 that you have within WBI?

41 A. Sorry, it's a one-page guidelines about appropriate

42 expenditure, how much - if you're taking a client out to

43 lunch, the types of things you would normally expend on

44 your credit card.

45

46 Q. That has dollar figures, does it, as to what would

47 ordinarily --



1 A. Yes, we actually put in some guidelines as to what we

2 thought would be appropriate.

3

4 Q. Your credit card statements for the work credit card,

5 how are they dealt with internally?

6 A. The Trustees approve those every month.

7

8 Q. When you say "approve them", are copies of your credit

9 card statements provided to the Trustees?

10 A. Yes, with all of the receipts.

11

12 Q. One of the other reports I think you are aware of is

13 an Ernst & Young report, in particular, that dealt with

14 issues of expenses in particular within RSL (NSW); correct?

15 A. Yes, I am now, yes.

16

17 Q. To your understanding, have the recommendations in

18 that Ernst & Young report been put in place in both

19 RSL (NSW) and WBI?

20 A. In terms of WBI, which I'm actually more familiar with

21 at the moment, many of the recommendations about

22 expenditure were not - things that were highlighted in that

23 report actually weren't happening in the area of WBI that

24 I controlled, but the transition to Navision with

25 appropriate accounting procedures and appropriate

26 delegation matrix, made sure - that transition made sure

27 that none of what had happened in the RSL (NSW) finance

28 area would be repeated in WBI.

29

30 Q. Am I right, from something you said there about

31 RSL (NSW), that at the moment you are still in the process

32 of familiarising yourself with the RSL (NSW) systems and

33 procedures?

34 A. Yes.

35

36 Q. You have given a lot of evidence about changes that

37 have taken place in WBI, but at the moment, am I right,

38 that you are not familiar with changes that have taken

39 place in RSL (NSW)?

40 A. I'm familiar with some.

41

42 Q. I think you've given evidence so far about the

43 engagement of Mr Nair?

44 A. Yes.

45

46 Q. The changing over of the financial management system

47 to Navision?



1 A. Yes.

2

3 Q. And I think the involvement in Ernst & Young, which

4 I'm about to ask you about. Are there any other changes

5 within RSL (NSW) that you are aware of to address

6 deficiencies in that organisation?

7 A. Yes. I felt extremely uncomfortable with the approval

8 process of expenditure in RSL (NSW), when I started to

9 receive invoices and requests to approve certain items of

10 expenditure and I did not feel that I could see there was

11 sufficient checking, particularly checking against

12 contractual amounts - sorry, I did not feel that I could

13 see on the receipts and on the expenditures put to me for

14 approval that there was adequate checking. I could not

15 tell. So I asked Mr Nair to change the system and

16 introduce - pending the implementation of an expense

17 management system, which I'll address in a minute, to

18 change to a manual coversheet that forced a certain process

19 of checking of expenditure before it came to the ultimate

20 approver.

21

22 So, for example, was this contractual related

23 expenditure? Yes/no. If so, have you checked the contract

24 that it is an appropriate level of expenditure? Who has

25 checked off that the receipts were checked against, for

26 example, in a credit card, a credit card statement, and not

27 only who but the name. I could not understand the

28 signature, I could - I did not know who signed. When there

29 were some signatures, so I asked - I asked for the form to

30 include the name of the person and for two levels of

31 checking before it came to, for example, me. That's one

32 system I've introduced which is a manual system. We have

33 also approved the --

34

35 Q. Just stopping you there, is that system both within

36 RSL (NSW) and WBI?

37 A. No, WBI is using Navision and using a different system

38 now.

39

40 Q. So that's RSL (NSW)?

41 A. Yes, it is.

42

43 Q. You were about to say?

44 A. Yes. I have recently approved the implementation of

45 an expense management system called Concur.

46

47 Q. Would you spell that?



1 A. C-O-N-C-U-R.

2

3 Q. Thank you.

4 A. I was originally wanting to implement that, but my

5 discussion with Mr Nair originally was that would follow

6 the implementation of Navision. However, when I started in

7 RSL (NSW) by the end of August, I was starting to get very

8 uncomfortable with the expense approval process, so we

9 implemented the coversheet, the manual system as an interim

10 measure and we brought forward the implementation of

11 Concur. That implementation will take eight weeks and that

12 will commence in the next couple of weeks.

13

14 I have introduced the entire organisation delegation

15 matrix including recently putting up a delegation matrix

16 and expansion of that delegation matrix for

17 State Councillor and we've introduced those

18 State Councillor expenditure guidelines in addition to

19 that. One of the things we have done with the delegation

20 matrix is make sure that it is shared with every single

21 member of the team. I personally sent an email out to - in

22 the RSL (NSW) to all members of RSL (NSW), with the

23 delegation matrix attached and to ask people to question,

24 question, question expenditure and ask if you're not sure

25 and to make sure that the delegation matrix was adhered to

26 at all times.

27

28 Q. That's within RSL (NSW)?

29 A. Yes. When the delegation matrix for WBI was approved,

30 I sent a similar email.

31

32 Q. One of the issues that I think you have become aware

33 of is the requirement for WBI to have three Trustees;

34 correct?

35 A. Yes.

36

37 Q. Does it currently have its third Trustee?

38 A. Someone has consented, but that needs to go to the

39 next Trustees meeting.

40

41 Q. To your you understand ending, when will that be?

42 A. The date was 18 October, but because of the

43 requirements of the Inquiry, we are now being looking at

44 trying to get an alternate date in early November.

45

46 Q. Is that Trustee an RSL (NSW) State Councillor?

47 A. No.



1

2 Q. It is an independent external person?

3 A. No.

4

5 Q. Is there any reason why I shouldn't ask you who that

6 person is?

7

8 PUBLIC INQUIRER: You can ask that question and see if the

9 objection is taken.

10

11 MR CHESHIRE: Q. I will ask. Who is the person?

12 A. Her name is Ms Del Gaudry, and she's an RLS sub-branch

13 member.

14

15 Q. If she is appointed then there will be three Trustees;

16 is that correct?

17 A. Yes.

18

19 Q. You give some evidence in your statement about

20 policies for dealing with conflicts of interest that you've

21 addressed within WBI; correct?

22 A. Yes.

23

24 Q. As I understand it, the conflicts of interest policy

25 has not yet been finalised; is that right?

26 A. That's right. There is a draft and that will be

27 finalised and put to the Trustees for the next Trustee

28 meeting.

29

30 Q. What about a conflicts of interest policy within

31 RSL (NSW)?

32 A. Yes, that was approved at a State Council meeting,

33 I think it might have been August - no, it might have been

34 by circular resolution.

35

36 Q. Are you able to say when that was? Was it in the last

37 week or so, the last month or so?

38 A. No, the last two months. I'm not exactly sure, I'm

39 sorry, the date escapes me.

40

41 Q. You understand that there is now a conflicts of

42 interest policy in place for RSL (NSW)?

43 A. Yes.

44

45 Q. Does that include a register of interests?

46 A. I understand there is a register of interest and that

47 is - I understand that because Jeff O'Brien, who is the



1 State Secretary - sorry, I found registers of pecuniary

2 interests of some of the State Councillors in the office

3 and I handed them to Jeff O'Brien because I understand he

4 has that information, but I have not seen the RSL (NSW)

5 register of pecuniary interests.

6

7 Q. Do you recall that in July of this year Ernst & Young

8 provided a report on the financial systems of RSL (NSW) and

9 WBI; correct?

10 A. I thought it was a report on expenditure.

11

12 PUBLIC INQUIRER: Q. No, this is the letter to Mr Nair

13 of 5 July?

14 A. Oh, sorry. Oh, yes, sorry, yes, I recall that.

15

16 PUBLIC INQUIRER: Is that right, Mr Cheshire?

17

18 MR CHESHIRE: Yes.

19

20 Q. Do you recall that that letter referred to

21 deficiencies, for instance, in the general ledger?

22 A. Yes.

23

24 Q. At that stage, your understanding was that Ernst &

25 Young had been retained to perform an analysis or a review

26 of the financial systems; correct?

27 A. My understanding was that Ernst & Young in that

28 letter - that was a proposal to review the financial

29 system of WBI -the donations, charitable moneys received

30 for the last 10 years, the income in and then how it had

31 been spent. Is that the correct letter?

32

33 Q. I'll show you the letter at Exhibit 16, tab 5.

34 A. Sorry if I haven't got the right letter.

35

36 Q. It is page 11, which is WBI.15.0000010. Do you have

37 that letter?

38 A. 5 July?

39

40 Q. Yes.

41 A. Page 11?

42

43 Q. Yes. In the bottom right-hand corner, page 11.

44 A. I've only got four pages.

45

46 Q. Do they have numbers in the bottom right-hand corner?

47 A. Oh, sorry, yes, I was looking at the top.



1

2 Q. Do you have page 11?

3 A. Yes.

4

5 Q. Do you see there a letter of 5 July?

6 A. Yes.

7

8 Q. You will see:

9

10 We confirm that Ernst & Young ... have been

11 engaged to perform forensic data extraction

12 services ...

13

14 Do you see that?

15 A. Yes.

16

17 Q. This may be what you were thinking of and the scope is

18 set out on page 12.

19 A. Yes.

20

21 Q. Then on page 13, there are the limitations on scope;

22 do you see that?

23 A. Yes.

24

25 Q. Do you see there the observations about the problems

26 with the general ledger; correct?

27 A. Yes.

28

29 Q. Did you understand at that stage that this was a

30 proposal or that Ernst & Young had formally been retained?

31 A. I understood - okay, reading that now, sorry, they

32 were engaged. The limitations on the scope I took to mean

33 potential limitations that may apply and that their

34 subsequent data extraction, I presumed, would confirm or

35 not the limitations that may apply.

36

37 Q. There was then a further letter which is page 47 in

38 the same bundle, WBI.15.0000017, page 47, bottom right.

39 A. Yes.

40

41 Q. You will see there:

42

43 In accordance with our engagement letter,

44 dated 3 July ... requested Ernst & Young to

45 undertake a forensic data extraction.

46

47 You also requested that we present the



1 extracted transactional data in accordance

2 with mapping specifications provided by

3 you. These were received 10 July 2017 and

4 revised on 14 July 2017.

5

6 Do you see that?

7 A. Yes.

8

9 Q. Then there's an outline of the procedures that were

10 performed, and then the limitations. Do you see that?

11 A. Yes.

12

13 Q. At that stage, whilst you have some general

14 observations, you do not have any specific data or

15 conclusions from that data; correct, as of this letter?

16 Do you see that?

17 A. I'm sorry, I don't quite understand the question,

18 please.

19

20 Q. That letter on 27 July, was that it? Was that the end

21 of what Ernst & Young were doing?

22 A. I believe so. I'm sorry, I think I'm a bit lost.

23

24 Q. I've just shown you two letters from Ernst & Young.

25 A. Yes.

26

27 Q. One of which was 7 July.

28 A. Yes.

29

30 Q. It had narrative in it. This is the letter of 27 July

31 that has some narrative in it?

32 A. Yes. This was after it had complete - after Ernst &

33 Young had completed the review, I understand.

34

35 Q. But is this the review, these two letters? Is that

36 the extent of the review?

37 A. No. There was a lot of data that accompanied the

38 letter.

39

40 Q. When you say "a lot of data", was there any analysis

41 of that data?

42 A. The data was grouped into various categories. The

43 data was grouped into donations. There was registered - am

44 I --

45

46 PUBLIC INQUIRER: Just pardon me, we do have that data.

47



1 MR CHESHIRE: Q. I beg your pardon. After that, that

2 letter and that report, was that the end, as you understood

3 it, of Ernst & Young's functions?

4 A. Only for that particular matter.

5

6 Q. When you say "for that particular matter", was there

7 anything further that was done with Ernst & Young?

8 A. Yes. We approached Ernst & Young to put forward a

9 proposal to take over the audit.

10

11 Q. Yes.

12 A. And we also approached Ernst & Young to put forward a

13 proposal to check the compliance of Navision and the other

14 systems in place to see if they - sorry, an external

15 assessment of compliance to make sure they met the

16 requirements of charitable fundraising legislation.

17

18 PUBLIC INQUIRER: Q. Could you just have a look at your

19 statement in Volume 3, tab 65. Would you have a look over

20 the page, page 991.

21 A. Yes.

22

23 Q. You will see a reference in the middle to the

24 corporate compliance. Do you see that?

25 A. Yes.

26

27 Q. Is this the response from EY after you approached them

28 to provide that?

29 A. This independence letter was in response to a request

30 to provide surety that EY conducting the audit would not

31 conflict with EY conducting the compliance assessment of

32 Navision and the procedures surrounding Navision to comply

33 with the Charitable Fundraising Act.

34

35 Q. So between the time that they provided their review,

36 to which you've referred, and this letter of 25 September,

37 what else did they do?

38 A. I can't recall anything in WBI.

39

40 Q. I see. The material to which you've referred which is

41 the data which is in tabulated form, that was provided to

42 you and also provided to the Inquiry.

43 A. Yes.

44

45 Q. But since then, nothing further has been done by EY;

46 is that right?

47 A. No. We have just received the proposals. They have



1 been approved as the auditor and given us a date, an

2 engagement letter, and a start date of approximately

3 23 October.

4

5 Q. That's for the auditing?

6 A. That's for the auditing.

7

8 Q. What about the other aspects of compliance?

9 A. No, I have recommended that for the Trustees and

10 that's for their decision.

11

12 Q. I'm sorry, I think we're at cross-purposes. What

13 about the requirements process, the review?

14 A. That review - the independent assessment by EY was a

15 request for a proposal and I've provided that proposal to

16 the Trustees.

17

18 Q. Just let me understand what you're saying to me.

19 Since the material was provided to you by EY in tabulated

20 form, about which you've spoken, has EY provided any

21 further report in respect of compliance?

22 A. No.

23

24 Q. Have they done any further work in respect of

25 compliance?

26 A. No, just submitted a proposal.

27

28 Q. When you say "just submitted a proposal", what are you

29 talking about?

30 A. We asked Ernst & Young for a proposal to independently

31 assess the compliance of Navision and the procedures, the

32 NWBI, to ensure it meets the requirements of the Charitable

33 Fundraising Act and regulations.

34

35 Q. Anything else?

36 A. No.

37

38 PUBLIC INQUIRER: Thank you. Yes, Mr Cheshire.

39

40 MR CHESHIRE: Q. Do you have your statement there?

41 I think you do. Would you go to paragraph 130.

42

43 PUBLIC INQUIRER: No, she doesn't have it.

44

45 MR CHESHIRE: I beg your pardon.

46

47 PUBLIC INQUIRER: Volume 1, please, Mr Buckley.



1

2 THE WITNESS: Could you repeat the paragraph?

3

4 MR CHESHIRE: Q. Volume 1, paragraph 130.

5 A. Yes.

6

7 Q. I think you refer in the last sentence of that

8 paragraph to an engagement agreement with a statement of

9 work and a proposal and that, as I understand it, is in

10 respect of compliance; is that correct?

11 A. Yes, that's correct.

12

13 Q. That in respect of compliance of the Navision system;

14 is that right?

15 A. And the policies and procedures that surround

16 Navision.

17

18 Q. As I understand the position, from what your evidence

19 was before lunch, you accept that in order to comply with

20 the Charitable Fundraising Act, there needs to be not only

21 use of the Navision system, but also setting up systems

22 outside of the Navision system; correct?

23 A. The use of the word "system", I'm not quite sure, but

24 certainly I'm unsure as to whether an accounting system

25 alone in isolation is sufficient to ensure full compliance

26 with the charitable fundraising legislation, the

27 regulations and the authority conditions. My assessment,

28 and we are reflecting and having considerable discussions

29 on this, is that alone - I find it very difficult to feel

30 sure that an accounting system alone is sufficient to

31 ensure compliance.

32

33 Q. Ernst & Young, when they are looking at the issue of

34 compliance, are they looking just at the point of view of

35 the financial system or are they looking at it

36 holistically?

37 A. If we - if they are engaged - if the Trustees engage

38 Ernst & Young, we would be having those discussions with

39 Ernst & Young.

40

41 Q. As I understand it, they have provided, effectively, a

42 proposal, but it has not yet been accepted by the Trustees;

43 is that right?


45

46 Q. What is then the timeline for that being accepted or

47 not by the Trustees?



1 A. I have sent the Trustees the proposal and a

2 recommendation and it is up to them to consider. I do not

3 have a timeline.

4

5 Q. But that proposal was received on 19 September; is

6 that right?


8

9 Q. As you understand it, nothing further has happened

10 with Ernst & Young between 19 September and today; is that

11 right?

12 A. In terms of the audit, yes.

13

14 Q. In terms of this review?

15 A. No. Sorry.

16

17 PUBLIC INQUIRER: Q. Compliance.

18 A. As I understand it, nothing - I'm sorry, sometimes

19 I answer the wrong word.

20

21 MR CHESHIRE: Q. In terms of compliance.

22 A. In terms of compliance, it is my understanding that

23 nothing has been done with Ernst & Young in that space,

24 only internally.

25

26 Q. As I understood your evidence before lunch, it will be

27 at least until March of 2017 before WBI has all of its

28 systems bedded down?

29 A. At this stage, it's likely to be March 2018, yes.

30 Sorry, could I just revise that? We have taken - we have

31 been working with legal advice provided by Ashurst on the

32 compliance and aspects of compliance with the fundraising

33 legislation and our finance team are looking at that.

34 That's independent of EY, I'm sorry.

35

36 Q. As I understand it, to give you the comfort that you

37 were able to comply, you would want to have the Ernst &

38 Young report, correct, on compliance?

39 A. In my personal opinion?

40

41 Q. Yes.

42 A. Yes.

43

44 Q. That in itself, then, would depend upon WBI having all

45 of its systems in place; correct?

46 A. I'm not 100 per cent sure this client relationship

47 management system would need to be in place to ensure



1 compliance. I would need to reflect on that. Certainly

2 Navision, certainly the payroll system. I'm not

3 100 per cent sure whether a database of clients is

4 necessarily required. I would need to reflect on that, I'm

5 sorry.

6

7 Q. When you say reflect on it, presumably also discuss

8 that matter with Ernst & Young?

9 A. Yes, and people within the team, yes.

10

11 Q. And also with Ashurst; correct?

12 A. Yes, possibly.

13

14 Q. So that's WBI.

15

16 PUBLIC INQUIRER: Q. Just before you leave WBI, you have

17 expressed a concern a couple of times about that platform

18 for the Navision not being enough on its own to comply with

19 the Charitable Fundraising Act. Do you remember saying

20 that a couple of times?

21 A. Yes.

22

23 Q. What you've got happening, as I apprehend what has

24 been received by the Inquiry, is that you not only are

25 dealing with Ernst & Young, you're also receiving quite a

26 deal of information and advice from Ashurst in respect of

27 the more broader compliance issues that are not just

28 financial; isn't that right?

29 A. Yes, that's correct.

30

31 Q. Do you have anyone else advising you other than EY,

32 Ashurst and --

33 A. EY, Ashurst, we have - we have engaged a contractor to

34 work on the policies and procedures and she is very

35 experienced in the fundraising space.

36

37 Q. All right. So you have a consultant?

38 A. Yes.

39

40 PUBLIC INQUIRER: Yes, thank you, Mr Cheshire.

41

42 MR CHESHIRE: Q. I was about to ask you about RSL (NSW).

43 Do you recall that the letters from Ernst & Young of 5 July

44 and --

45

46 PUBLIC INQUIRER: Just pardon me, I'm terribly sorry to

47 interrupt. Are you leaving WBI for the moment?



1

2 MR CHESHIRE: Yes.

3

4 PUBLIC INQUIRER: Q. Could I just ask, one of the things

5 that you said about the new Trustee who has not yet been

6 approved, but has accepted the nomination, as I apprehend

7 what your evidence is, has that candidate been informed of

8 the problem with the trust?

9 A. I arranged --

10

11 Q. I'm just going to ask it again.

12 A. Yes.

13

14 PUBLIC INQUIRER: Thank you. Yes.

15

16 MR CHESHIRE: Q. On RSL (NSW), do you recall that the

17 reports from Ernst & Young that identified deficiencies in

18 the system were deficiencies in the system of WBI and

19 RSL (NSW)? Do you recall that?

20 A. I believe so, although I understand the WBI in

21 relation to expenditure of certain State Councillors,

22 I believe. I'm not sure how extensive it is --

23

24 Q. I'll have you shown Exhibit 16.

25 A. Thank you.

26

27 Q. Tab 5, page 11, bottom right-hand corner. Do you

28 recall this is the letter of 5 July that I showed you?

29 A. Oh, yes.

30

31 Q. Do you see that the retainer in the second paragraph

32 is recorded:

33

34 We confirm that Ernst & Young have been

35 engaged to perform forensic data extraction

36 services for RSL (NSW).

37

38 Correct?

39 A. Yes.

40

41 Q. And for WBI, do you see that?

42 A. Yes, I'm sorry, I think I was thinking of some other

43 report.

44

45 Q. If you turn over two pages to "Limitations on Scope".

46 Do you see "Limitations on Scope"?

47 A. Yes.



1

2 Q. In the second paragraph there:

3

4 We draw to your attention some inherent

5 limitations to this exercise which are

6 known to EY having previously examined RSL

7 and WBI's financial records ...

8

9 Do you see that?

10 A. Yes.

11

12 Q. You understand from that that Ernst & Young were

13 identifying deficiencies both in respect of WBI and

14 RSL (NSW)?

15 A. Yes.

16

17 Q. You have given evidence as to Ernst & Young looking at

18 WBI's systems from a compliance point of view. What then

19 has RSL (NSW) done with looking at its compliance.

20

21 PUBLIC INQUIRER: Q. With Ernst & Young?

22 A. With Ernst & Young? I'm unaware of anything with

23 Ernst & Young in relation to RSL (NSW) compliance at this

24 stage.

25

26 MR CHESHIRE: Q. As I understand the position --

27 A. Sorry, I'm just trying to reflect --

28

29 Q. As I understand the position, WBI has engaged Ernst &

30 Young on the compliance issue in order to ensure that it

31 can have confidence going forward that it is compliant;

32 correct?

33

34 MR HERZFELD: I'm sorry to interrupt, but the evidence is

35 not that WBI has engaged Ernst & Young. They have not yet

36 been --

37

38 MR CHESHIRE: I withdraw that.

39

40 PUBLIC INQUIRER: They have been engaging with.

41

42 MR HERZFELD: I have difficulty with --

43

44 MR CHESHIRE: I withdraw the question.

45

46 Q. As you understand it, the reason why there has been

47 engagement with Ernst & Young on the issue of compliance



1 that has led to it making a proposal, which is before

2 Trustees, is to ensure that WBI can have confidence as to

3 its compliance going forward; correct?

4 A. Yes.

5

6 Q. It would seem to follow, would it not, that RSL (NSW)

7 would also need to have that confidence going forward;

8 correct?

9 A. My personal opinion is yes.

10

11 Q. Are you aware, then, of any steps being taken within

12 RSL (NSW) to give that confidence going forward?

13 A. Can I answer that by way of explanation?

14

15 Q. Yes.

16 A. RSL WBI is in a position to call in Ernst & Young to

17 assess the new systems and the new procedures, because they

18 have now been set up. I am not yet sure of the extent of

19 the problems of compliance in RSL (NSW), and RSL (NSW) is

20 still operating the Sage accounting system. I would think

21 that the process would normally be once we are fully aware

22 of the extent of non-compliance in RSL (NSW), then there

23 would be the steps to remedy the situation, put in place

24 new processes, a new system, and at that stage bring in a

25 firm like EY to assess the compliance of that. EY has been

26 already engaged as the auditor for RSL (NSW), however, for

27 2016 and 2017. That was approved by a resolution of the

28 State Council.

29

30 Q. So Ernst & Young have been appointed as the auditor of

31 both RSL (NSW) and WBI; correct?

32 A. Yes, with separate resolutions.

33

34 Q. As I understand it from your evidence earlier,

35 RSL (NSW) is also going to be transitioning from Sage to

36 Navision; is that right?

37 A. Yes, we have proposed that and that was approved.

38

39 Q. Am I right that the effect of your evidence is that

40 once RSL (NSW) has transitioned to Navision and once you

41 have had the opportunity of looking at the RSL (NSW)

42 processes, then it would also be sensible for a similar

43 exercise of a compliance review to take place within

44 RSL (NSW)?

45 A. Yes. Could I expand on that?

46

47 Q. Yes.



1 A. RSL (NSW), that is the State Branch area. However,

2 there are other areas of RSL (NSW) that we would need to

3 look at, but the Navision system is for the State Branch.

4

5 Q. When you say other areas of RSL (NSW), you're

6 encompassing in that, are you not, the sub-branches?

7 A. Yes.

8

9 Q. It is your understanding that there are likely to be

10 issues of compliance within the sub-branches; correct?

11 A. Yes, that's my understanding.

12

13 Q. As I understand it, RSL (NSW) has sent out a survey to

14 the sub-branches; is that correct?

15 A. Yes, it is.

16

17 Q. With a view to ascertaining what the position is with

18 compliance; correct?

19 A. Yes, to gain some key information, to form a picture

20 of potential areas of non-compliance so that where we get

21 certain information, we can actually make further

22 inquiries. In and of itself the survey will probably not

23 encompass everything, but we believe there are enough

24 questions in there to enable us to go further if we need

25 to.

26

27 Q. The responses to those surveys have been received?

28 A. Many of them have.

29

30 Q. What to date has been done with the answers to the

31 surveys?

32 A. We have developed a framework as to how to pull out

33 some key information from those surveys, some key details

34 that will allow us to very quickly ascertain whether a

35 sub-branch, for example, is fundraising or not, and some of

36 the key fields that will enable us to dig deeper into the

37 sub-branch and compare - pick out the sub-branches that we

38 need to focus on in the first instance, to either gain more

39 information, or compare it with information that is already

40 held by RSL (NSW) and make further inquiries.

41

42 Q. What are those answers to the surveys, what have they

43 shown you so far?

44 A. I have looked at a few, scanned a few of the responses

45 and they have highlighted, from what I have seen, what

46 I believe to be areas of non-compliance.

47



1 Q. Apart from identifying areas of non-compliance, as

2 with WBI and RSL (NSW), identifying non-compliance is the

3 first step, putting in systems to remedy and rectify

4 non-compliance is the next step?

5 A. That is correct.

6

7 Q. Has any thought been given, to your understanding, to

8 rectifying issues of non-compliance within the

9 sub-branches?

10 A. Yes. We've started to think about various aspects

11 that relate to non-compliance, including the auditors of

12 the individual sub-branches, including how we can best help

13 sub-branches with compliance. Could I expand that this

14 actually does step over a little bit into the appeals area,

15 because some of the issues associated with compliance with

16 the appeals are in relation to just how much is collected.

17 Issues of ensuring receipts are given when donations,

18 collected by volunteers, for example, don't match the

19 receipted amount on the back of the token. These are all

20 aspects of compliance, and I know the appeals are

21 authorised by WBI, but have an impact in RSL (NSW) and for

22 the sub-branches as well. There are a number of areas and

23 a number of things we need to address in this area.

24

25 Q. As I understand it, your evidence is that the issues

26 in the sub-branches that you have identified have

27 consequences for WBI as well; correct?

28 A. Yes, I believe so.

29

30 Q. In effect, to solve the issues within WBI and

31 RSL (NSW) going forward in relation to compliance, you also

32 need to sort out the sub-branches; correct?

33 A. That's my belief, yes.

34

35 Q. As I understand it, in relation to the sub-branches,

36 you're at a very early stage in identifying the problems

37 before even considering how to solve them; is that right?

38 A. Yes, we are.

39

40 Q. I asked you earlier about the communications with

41 Fair Trading. The authority was submitted in May of this

42 year - sorry, the application for a renewal was submitted

43 in May of this year; correct?

44 A. Yes.

45

46 Q. There was then a letter which I asked you about of

47 22 September from Fair Trading, effectively saying that it



1 needs certain further information before it would grant --

2

3 PUBLIC INQUIRER: Before it would consider.

4

5 MR CHESHIRE: Q. -- before it would consider granting a

6 further authority; correct?

7 A. I believe so. I don't have the wording in front of

8 me.

9

10 Q. Had you or WBI notified Fair Trading of the issues

11 that you had identified with breach?

12 A. Not that I'm aware of.

13

14 Q. At least by the time of your application, you were

15 aware that there was non-compliance within WBI; correct?

16

17 PUBLIC INQUIRER: That's May. Late May.

18

19 THE WITNESS: Late May. I believe there were areas of

20 non-compliance. I was not yet fully across them. I did

21 not have the degree of confidence that I have now at that

22 time.

23

24 MR CHESHIRE: Q. Did you give any consideration at that

25 time to informing Fair Trading as to the issues that you

26 had identified?

27 A. I don't believe I had sufficient confidence to be able

28 to paint an accurate picture of the full extent of the

29 breaches.

30

31 Q. Did you raise that with the Trustees, the question of

32 whether you should inform Fair Trading about the potential

33 areas of breach?

34 A. In April I raised issues that I was concerned about

35 with the Trustees.

36

37 Q. But, as I understand it, you didn't suggest to them,

38 or raise the issue with them as to whether should notify

39 Fair Trading of that; is that right?

40 A. I don't recall doing that. I don't feel - I was -

41 I did not feel confident in my knowledge of the breach, the

42 extent of the breaches.

43

44 Q. At least as matters currently stand, as I understand

45 it, you are now satisfied that there has been significant

46 non-compliance; correct?

47 A. I've seen the statement of the breaches and I



1 understand the statement of the breaches.

2

3 Q. What I think is described as the statement of

4 admissions; is that right?

5 A. Sorry, yes.

6

7 Q. Of 6 September?

8 A. Yes.

9

10 Q. In the context then of the pending application to

11 Fair Trading for a renewal, did you take any steps to

12 notify Fair Trading of those admissions?

13 A. I haven't, no.

14

15 Q. To your knowledge, has anybody within WBI notified

16 Fair Trading of those admissions?

17 A. Not to my knowledge, no.

18

19 Q. Is there any reason for that?

20 A. I believe that - is there any reason for that, that's

21 a good question. Not that I'm aware of - not that I'm

22 aware of. Have Trustees have been made aware of the

23 breaches? Not that I'm aware of.

24

25 Q. But you haven't discussed to the Trustees that these

26 matters should be notified to Fair Trading; is that right?

27 A. I don't recall suggesting that to the Trustees.

28

29 Q. You're aware also, are you not, that in the course of

30 this Inquiry RSL (NSW) has made certain admissions of

31 non-compliance; correct?

32 A. I am aware that that has happened.

33

34 Q. And RSL (NSW) has a current fundraising authority;

35 correct?

36 A. Yes. Yes, it does.

37

38 Q. Have you given any consideration to notifying

39 Fair Trading of those acts of non-compliance that have been

40 identified for RSL (NSW)?

41 A. In terms of RSL (NSW), no, I haven't been able to -

42 I haven't had time or - I haven't been able to put my head

43 around that, no, I'm sorry, I haven't. I have considered,

44 in terms of WBI, the next approach to Fair Trading around

45 our policies and procedures and around the next steps, but

46 I have not put my mind to RSL (NSW) around that.

47



1 Q. As I understand it, in relation to WBI, you have given

2 consideration as to satisfying Fair Trading as to the

3 suitability of your systems going forward; correct?

4 A. Yes. It was my intention to - with the development of

5 all the policies and procedures and the Trustees' consent,

6 I have sent the letter from Fair Trading to the Trustees

7 with a recommendation for a response. That's for their

8 consideration, but personally, I have reflected on the next

9 steps I'd like to take with WBI, and they were to

10 collectively - now our policies and procedures are nearly

11 finalised, they're in the final stage of review, to take

12 those policies and procedures and all the information we

13 have to the Office of Fair Trading with the Trustees'

14 consent, to ask the Office of Fair Trading if they would

15 review those policies and procedures and to discuss

16 potentially some changes to - or the potential for changes

17 to the fundraising authority or the way forward for the

18 organisation.

19

20 Q. Do you accept that in the context of giving

21 Fair Trading proper information for it to be able to assess

22 WBI's authority, that it ought to be informed of the

23 admissions that have been made?

24 A. Yes, I would agree with that.

25

26 Q. Would you accept the same in relation to RSL (NSW)?

27 A. Yes, I would agree with that.

28

29 MR CHESHIRE: Thank you very much. Thank you,

30 Madam Inquirer.

31

32 PUBLIC INQUIRER: Q. I just wanted to ask you questions

33 before perhaps any other counsel might like to seek leave

34 to ask questions. I want to go back to the problems that

35 you raised with the Trustees in 2012 relating to, as you

36 saw it, a breach of trust. Could you be shown, please,

37 Volume 3 of your statement. Would you go to your email

38 which is tab 66, Ms Collins. As I look at what you've

39 said, I understand that you became concerned and then you

40 took advice from Mr John Cannings informally; is that

41 right?

42 A. Informally, yes.

43

44 Q. This email was a consequence or as a result of taking

45 that advice and putting your concerns on paper?

46 A. And doing some research ourselves.

47

.13/10/2017 (25) 2881 R G COLLINS


1 Q. Yes. When did you commence there?

2 A. August.

3

4 Q. As soon as you saw this, effectively, you started to

5 take the advice and then put in place a recording of what

6 your concerns were?

7 A. Yes.

8

9 Q. Was Mr Cannings retained by WBI as the solicitor of --

10 A. I'm sorry, I don't know.

11

12 Q. How did you come to speak with Mr Cannings?

13 A. When I first raised the issue with the Trustees at a

14 Trustee meeting, they said that they believed the Trust was

15 not in breach and I asked them if I could investigate that

16 and they gave me permission to do so and they suggested

17 that I go and meet with Mr Cannings because he was the

18 person that had recently had the Administrative Rules -

19 worked on the Administrative Rules and had them approved by

20 the Supreme Court.

21

22 Q. That was prior to this email?

23 A. Yes.

24

25 Q. Yes. The next thing that happens, as I read your

26 evidence, is on 12 December, if you go to tab 67. You were

27 in attendance at this meeting. If you go to page 1004,

28 your report was received, the 29 November email was

29 received, as I understand it?

30 A. Yes.

31

32 Q. Then the Trustees resolved to obtain advice from

33 senior counsel. Do you see that in paragraph 3?

34 A. Yes.

35

36 Q. Did you understand that they were going to take advice

37 from a QC or an SC?

38 A. All I understood at the time - I believe they

39 mentioned, and I'm not sure if it was at that meeting, that

40 they would refer my email to John Cannings.

41

42 Q. So you don't have a recollection of whether this

43 resolution was for senior counsel to be briefed to provide

44 an advice to assist the Trustees? If you look at page

45 1004, paragraph 3.

46 A. No.

47

.13/10/2017 (25) 2882 R G COLLINS


1 Q. You don't recall?

2 A. No, I don't recall that, sorry.

3

4 Q. That was in the December. The next document that

5 records anything is about four years later; is that right?

6 19 January 2016.

7 A. That could be right.

8

9 Q. If you have a look at 1007, you will see that

10 Mr John Cannings is to be invited to advise the Trustees in

11 relation to the deed?

12 A. Yes.

13

14 Q. Do you see that?

15 A. Yes.

16

17 Q. Do you know what happened between January 2012 and

18 January 2016 in respect of briefing a lawyer to help work

19 out whether this was a breach?

20 A. Briefly, yes.

21

22 Q. What happened?

23 A. From what I was told, when it was originally referred

24 to Mr Cannings, Mr Perrin explained that this may take some

25 time to sort out.

26

27 Q. When you say it was originally referred to

28 Mr Cannings, when was that?

29 A. Some time in December - after the December 2012

30 meeting.

31

32 Q. All right.

33 A. So I was anticipating that it may take a long time to

34 sort out. I had never been involved in a Trust before.

35

36 Q. Don't worry. Just tell me what happened.

37 A. All right. Then about 12 months or so later I had

38 heard nothing and read nothing in the minutes, and

39 I followed up with Mr Perrin to ask what had happened and

40 Perrin explained that Mr Cannings had been diagnosed with a

41 serious illness. I asked him what would then happen and he

42 said - I think it was to the effect of - I don't know the

43 exact words, I'm sorry, but the impression I got was that

44 it would take - he needed to work out what then to do.

45

46 Then following that, that would have been early 2014,

47 I'm starting to remember --

.13/10/2017 (25) 2883 R G COLLINS


1

2 Q. I think mid-2014 was when Mr Cannings was diagnosed.

3 A. Right. Sorry, the timing may be slightly off. Then

4 Mr Rowe - the next thing Mr Rowe resigned, Mr Perrin

5 resigned, and then Mr White was left as the sole Trustee.

6

7 Q. And then Mr Hardman comes in with Mr Kolomeitz?

8 A. That's right. I raised the issue - sorry, when

9 Mr White was the sole Trustee, at a Trustee meeting

10 Ms Mulliner explained to Mr White - they discussed the

11 issue of what he could do as a sole Trustee, and

12 Ms Mulliner raised that she had received some legal advice

13 that all Mr White could do would be day to day business --

14

15 Q. Let me see if I can focus you back on the Trust breach

16 allegation.

17 A. Yes.

18

19 Q. After Mr Cannings had his health problem, nothing

20 seems to have happened - is that right - until 2016, if you

21 go to page 1012, which is a meeting in March 2016. You

22 were there for part of the meeting, and what is decided at

23 that meeting is when Mr Cannings is asked to advise again?

24 A. I'm not aware if anything was happening at that time.

25 It wasn't communicated to me.

26

27 Q. Were you aware that the matter was yet again referred

28 to Mr Cannings?

29 A. I was after that.

30

31 Q. Then Mr Cannings met with you a couple of months later

32 with the Trustees on 14 March 2016; is that right?

33 A. Yes.

34

35 Q. The detail of that is recorded at 1013 and 1014?

36 A. Yes.

37

38 Q. You will see the resolution. Mr Cannings is

39 instructed yet again to do some more advice. It seems to

40 be the same advice; is that right?

41 A. Yes.

42

43 Q. Have you ever had any advice from Mr Cannings?

44 A. I have never seen anything.

45

46 Q. So that is the end of the process, as far as you can

47 tell, in respect of what the Trustees were to do about the

.13/10/2017 (25) 2884 R G COLLINS


1 alleged breach?

2 A. No, no, that's not the end. Would you like me to

3 explain what happened next?

4

5 Q. Yes, in terms of legal advice.

6 A. Legal advice. Because I didn't hear anything or see

7 anything, I approached Mr Kolomeitz to change - to get

8 different independent legal advice. That was towards -

9 probably around September 2016. I asked Mr Kolomeitz's

10 permission to ask Mr Nair to source a different solicitor

11 who had not previously been engaged with WBI. Mr Kolomeitz

12 agreed and I asked Mr Nair could he look for an independent

13 solicitor. Mr Nair made a number of inquiries and

14 recommended we engage Ashurst, and the Trustees agreed with

15 that. Ashurst were engaged approximately October 2016 to

16 give advice. Then they gave a series of steps to the

17 Trustees which were approved at a meeting of the Trustees

18 either November/December that year, and then part of that

19 advice was to go and see a Queen's Counsel.

20

21 They recommended that a new little entity be set up, a

22 company, a public benevolent institution and a charity with

23 broader objects, that RSL WBI would engage the new legal

24 entity, the new legal entity would have a fundraising

25 licence and it would fundraise and WBI would no longer and

26 WBI would engage the legal entity. This was taken to a QC.

27 I attended that meeting, and the QC reviewed the current

28 services. In particular, we discussed the grey area of

29 services, that because of the changes in the way Defence

30 dealt with veterans and current serving members who were

31 injured or ill and the need to hold discharge in abeyance

32 because of the length of the delay of the claims process,

33 she felt that those veterans in that grey area may possibly

34 be covered by the objects of WBI. Many of our clients are

35 in that grey area prior to discharge. She recommended

36 that - she, sorry, endorsed the steps that Ashurst had

37 recommended to the Trustees. Those steps were taken to a

38 meeting of the Trustees, and I'm thinking that might have

39 been the December meeting. They were approved. So the

40 Trustees approved the setting up of a new independent legal

41 entity tentatively called RSL DefenceCare Limited, and the

42 course of action that was the subject of the QC's advice.

43

44 Then a resolution was put to RSL (NSW) State Council

45 because part of that advice was that RSL (NSW) would be the

46 sole member of the new legal entity to gain in principle

47 approval, or in principle support, I'm sorry, for the

.13/10/2017 (25) 2885 R G COLLINS (Mr Sulan)


1 concept of setting up RSL DefenceCare Limited. That was

2 passed by a circular resolution in January.

3

4 Subsequent to that, the Trustees have changed in those

5 early months of 2017, and then when Mr Brown commenced as a

6 Trustee, I think his first meeting was in June, Ashurst

7 came to go through all the steps that had been taken up to

8 date, to explain those to Mr Brown and to Mr Evans who were

9 then the Trustees of RSL WBI as to the way forward.

10

11 Q. Is that it?

12 A. That's it. I think so.

13

14 Q. And that's where it sits?

15 A. That's where it sits at the moment.

16

17 PUBLIC INQUIRER: Thank you, Ms Collins. That's very

18 helpful. Anything? Mr Sulan.

19

20 MR SULAN: I have some questions about changes which are

21 currently being considered by RSL (NSW). Mr Cheshire asked

22 a number of questions about consultants currently engaged

23 by RSL (NSW) and there were just a couple of questions

24 I wanted to ask.

25

26 PUBLIC INQUIRER: Yes, I grant you leave.

27

28 <EXAMINATION BY MR SULAN:

29

30 MR SULAN: Q. Ms Collins, I'm counsel engaged by

31 RSL (NSW), and I just have a couple of questions in the

32 area I just discussed with Madam Inquirer.

33

34 Do you recall that Mr Cheshire asked you about changes

35 currently occurring in RSL (NSW)?

36 A. Yes.

37

38 Q. He asked you about various professionals that are

39 currently engaged by RSL (NSW) to assist with some of the

40 changes that are occurring?

41 A. Yes.

42

43 Q. You named a number of consultants and professionals

44 that are currently assisting RSL (NSW). I just wanted to

45 ask you: are you aware of Social Ventures Australia's role

46 with respect to RSL (NSW)?

47 A. Yes, I am, sorry, I omitted that.



1

2 Q. Could I just ask you to tell the Inquiry about what

3 you understand Social Ventures Australia is, firstly, in

4 terms of an organisation, and then, secondly, what you

5 understand they're doing to assist RSL (NSW)?

6 A. Yes. Social ventures Australia are a not-for-profit

7 organisation that assists other not-for-profit

8 organisations in a number of areas. One of those areas is

9 the development of strategy, helping organisations redefine

10 their purpose, and helping take them on the journey of

11 change. RSL (NSW) has engaged Social Ventures Australia as

12 part of the strategic planning process to look at its

13 purpose - to look at the organisation's purpose and to talk

14 to stakeholders, members, other ex-service organisations,

15 to glean what is needed for RSL (NSW) and develop a new

16 purpose and develop a new strategy for the organisation.

17

18 Q. Do you understand them to also have expertise in

19 respect of governance?

20 A. Yes, they do have expertise in respect of governance.

21

22 Q. Is that one of the areas that you understand that

23 they're looking at with respect to RSL (NSW)?

24 A. They are looking at governance probably in the context

25 of the strategic planning, as I understand it.

26

27 Q. That's one of the matters that you understand that

28 they're speaking to stakeholders about, including people at

29 RSL (NSW)?

30 A. Could you just - in terms of governance, are there

31 particular areas?

32

33 Q. Could you just assist the Inquiry in what you

34 understand they're doing with respect to governance issues.

35 A. In respect of governance issues, I guess preliminary

36 to all governance is understanding the organisation's

37 purpose and how it should be structured going forward.

38 Social Ventures Australia are engaging in discussions about

39 a potential structure for RSL (NSW) and the delivery of

40 core services. They're looking at the current services and

41 the current organisation, what is happening in the

42 organisation, what is needed by the community and how best

43 the organisation can structure itself going forward.

44

45 Q. How long do you understand they have been looking at

46 these issues for?

47 A. I believe we engaged them in approximately about early



1 to mid-September, and their report is due late October,

2 early November, I believe.

3

4 Q. Do you understand that once the strategy issues have

5 been resolved by RSL (NSW), considerations as to compliance

6 will then be considered by particular professionals?

7 A. I would imagine so, yes.

8

9 Q. And that might include, for example, EY?

10 A. Yes.

11

12 Q. Do you understand that part of that is because EY will

13 have some experience in having looked at the WBI compliance

14 issues?

15 A. Yes.

16

17 Q. As far as you understand what the strategy or the

18 timeline is, it is to finish the strategy piece and then to

19 look at the compliance issues and ensure you have

20 professional advice about compliance with respect to

21 RSL (NSW)?

22 A. Yes.

23

24 Q. One other question in this area: do you understand

25 that there are any moves within RSL (NSW) to appoint a

26 company secretary?

27 A. Yes.

28

29 Q. Do you understand that to be, without naming names, an

30 imminent matter that will be attended to?

31 A. Yes.

32

33 Q. What do you understand the role of the company

34 secretary will be one they are appointed?

35 A. The role of the company secretary will be on all

36 matters relating to governance and and compliance in the

37 corporate - in the company secretary space. So how

38 meetings are run, the appropriate policies and procedures,

39 the appropriate documents that are needed, conflicts of

40 interest, standardisation, a whole host of matters that are

41 associated with appropriate governance in the organisation.

42

43 Q. When do you understand that appointment will likely

44 come into effect?

45 A. I'm hoping 21 October.

46

47 MR SULAN: Thank you. Thank you, Madam Inquirer.

.13/10/2017 (25) 2888


1

2 PUBLIC INQUIRER: Mr Herzfeld, anything?

3

4 MR HERZFELD: No.

5

6 PUBLIC INQUIRER: Q. Do you understand the nature of the

7 Terms of Inquiry, Ms Collins? I presume you've read them.

8 A. Yes.

9

10 Q. You understand that there is a requirement for me to

11 report to the Minister as to whether the Minister could

12 have a view as to whether an authority should be granted or

13 an authority could be revoked, do you know that?

14 A. Yes.

15

16 Q. At the moment - and this is no criticism of you,

17 please don't think so - the position is that the

18 organisations of which you are the General Manager are in a

19 state of flux; is that right?

20 A. I believe so, Madam Inquirer.

21

22 Q. From what you tell me today, any certainty as to the

23 good governance and the measure of good governance in each

24 of the organisations will not be able to be tested until at

25 least March 2018; is that right?

26 A. I don't think I'd agree with that as a statement.

27 I think a lot of things have been put in place already,

28 certainly in WBI and in RSL (NSW), that are very good

29 examples of good governance of an intent to move towards

30 much better systems, much better procedures. I think

31 there's considerable intent in individuals and in the new

32 governing body to understand the mistakes that have been

33 made, how the situation came about and the progressive

34 steps are being taken.

35

36 Q. To actually look at it and say, "This is an exemplar of

37 a good operation" - from what you tell me about Navision

38 and various other aspects of the organisations that will

39 not be in place until March, as you told me, one couldn't

40 be satisfied, until that is in place, that a true judgment

41 can be made of the performance measured against those

42 systems that are then in place?

43 A. I could understand that, I agree.

44

45 Q. Yes. As I said, please don't think that that's a

46 criticism of you.

47 A. No.

.13/10/2017 (25) 2889


1

2 PUBLIC INQUIRER: Thank you, Ms Collins. Anything arising

3 from that?

4

5 MR CHESHIRE: No.

6

7 PUBLIC INQUIRER: You may step down, Ms Collins, thank

8 you.

9

10 <THE WITNESS WITHDREW

11

12 PUBLIC INQUIRER: Mr Herzfeld, Ms Collins's evidence has

13 concluded, but it does seem that there are negotiations or

14 discussions with the regulator.

15


17

18 MR CHESHIRE: I should, having regard to the additional

19 evidence that Ms Collins gave as to the timetable and the

20 position that has been reached, I should reiterate that it

21 is urgent and I would be most appreciative of a report back

22 next week.

23

24 MR HERZFELD: I will take that on board.

25

26 PUBLIC INQUIRER: Thank you, Mr Herzfeld. Yes,

27 Mr Cheshire.

28

29 MR CHESHIRE: Thank you, Madam Inquirer. Next week

30 Mr Winter returns on Wednesday, Ms Sheridan on Thursday and

31 then Mr Kells on Friday.

32

33 PUBLIC INQUIRER: Thank you. I will adjourn until then.

34 Thank you.

35

36 AT 3.15PM THE INQUIRY WAS ADJOURNED TO

37 WEDNESDAY, 18 OCTOBER 2017 AT 10.00AM 38

39

40

41

42

43

44

45

46

47

.13/10/2017 (25) 1


# 2871:5, 2871:10,

2882:6

1991 [1] - 2785:12

1st [1] - 2787:29

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268 [1] - 2806:39

27 [2] - 2867:20,

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accountant [3] -

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achieving [1] -

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acquitted [1] -

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Act [35] - 2800:32,

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ACT [1] - 2785:12

action [1] - 2884:42

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activities [4] -

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#25 [1] - 2787:2

$ 2

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2 [4] - 2786:47,

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2010 [1] - 2851:23

2012 [11] - 2787:6,

2787:43, 2801:46,

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2013 [2] - 2822:24,

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2014 [6] - 2809:18,

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2882:46

2015 [5] - 2798:6,

2799:37, 2826:9,

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2016 [24] - 2794:28,

2795:3, 2795:7,

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2798:40, 2799:32,

2828:6, 2835:17,

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2017 [12] - 2785:27,

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2018 [2] - 2871:29,

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21 [2] - 2847:20,

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22 [4] - 2838:16,

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23 [2] - 2845:35,

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25 [3] - 2785:28,

3

3 [8] - 2785:20,

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3.15PM [1] - 2889:36

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1

1 [13] - 2785:22,

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1004 [2] - 2881:27,

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11 [6] - 2791:4,

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4

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5

5 [7] - 2865:13,

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7

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9

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991 [1] - 2868:20

A

abeyance [1] -

.13/10/2017 (25) 2


ADJOURNED [1] - agreed [5] - 2799:6, 2813:37

answers [4] - 2813:14,

2844:46, 2876:30,

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anticipating [1] -

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2836:36, 2836:39

apart [1] - 2877:1

apartment [1] -

2809:25

Appeal [30] - 2795:11,

2795:12, 2816:3,

2823:34, 2823:35,

2824:41, 2824:42,

2825:2, 2825:3,

2826:40, 2827:29,

2827:34, 2827:35,

2827:43, 2827:44,

2828:3, 2828:14,

2828:18, 2834:45,

2834:46, 2836:23,

2836:28, 2836:36,

2836:39

appeal [2] - 2810:41,

2845:41

appeals [41] -

2794:45, 2795:8,

2795:11, 2810:26,

2810:27, 2810:35,

2815:45, 2815:47,

2817:8, 2823:29,

2823:31, 2825:15,

2825:46, 2826:23,

2826:27, 2826:32,

2826:36, 2826:44,

2827:30, 2828:10,

2828:12, 2828:13,

2833:30, 2834:3,

2834:7, 2834:9,

2834:14, 2834:25,

2834:28, 2835:2,

2835:15, 2835:30,

2836:5, 2845:43,

2846:7, 2846:39,

2846:40, 2877:14,

2877:16, 2877:20

Appeals [7] - 2824:45,

2826:47, 2827:2, 2842:44

approval [8] -

2831:27, 2859:2,

2859:5, 2860:6,

2862:7, 2862:14,

2863:8, 2884:47

approve [5] - 2831:12,

2860:7, 2861:6,

2861:8, 2862:9

approved [17] -

2833:7, 2858:39,

2858:44, 2859:14,

2859:25, 2862:33,

2862:44, 2863:29,

2864:32, 2869:1,

2873:6, 2875:27,

2875:37, 2881:19,

2884:17, 2884:39,

2884:40

approver [1] - 2862:20

approximate [1] -

2860:35

April [2] - 2836:23,

2878:34

area [16] - 2818:47,

2820:11, 2820:18,

2821:12, 2832:23,

2841:15, 2861:23,

2861:28, 2876:1,

2877:14, 2877:23,

2884:28, 2884:33,

2884:35, 2885:32,

2887:24

areas [12] - 2876:2,

2876:5, 2876:20,

2876:46, 2877:1,

2877:22, 2878:19,

2878:33, 2886:8,

2886:22, 2886:31

arise [1] - 2805:35

arising [1] - 2889:2

arose [1] - 2805:38

arranged [1] - 2873:9

arrival [2] - 2791:5,

2791:9

Art [4] - 2824:11,

2824:14, 2824:16,

2824:26

ascertain [1] -

2876:34

ascertaining [1] -

2876:17

Ashurst [10] -

2857:13, 2871:31,

2872:11, 2872:26,

2872:32, 2872:33,

2884:14, 2884:15,

2884:36, 2885:6

aside [1] - 2833:25

aspect [3] - 2821:27,

2889:36 2858:45, 2859:15, 2833:40, 2833:43,

adjournment [1] - 2884:12, 2884:14 2835:25, 2835:31

2812:22 agreement [3] - appear [6] - 2786:10,

ADJOURNMENT [3] - 2823:24, 2823:46, 2786:11, 2797:5,

2812:32, 2828:32, 2870:8 2799:1, 2829:39,

2858:3 aims [1] - 2841:38 2835:21

Administrative [2] - Albert [1] - 2785:22 appearance [1] -

2881:18, 2881:19 alerted [1] - 2831:20 2786:10

admission [1] - allegation [1] - appeared [7] -

2812:20 2883:16 2800:16, 2802:7,

admissions [5] - alleged [1] - 2884:1 2805:35, 2834:24,

2879:4, 2879:12, allow [1] - 2876:34 2834:32, 2834:36,

2879:16, 2879:30, allowed [2] - 2819:16, 2835:39

2880:23 2819:20 application [10] -

admitted [1] - 2800:31 alone [5] - 2856:17, 2812:1, 2812:3,

adopt [1] - 2832:40 2856:26, 2870:25, 2812:10, 2829:19,

adopted [1] - 2850:36 2870:29, 2870:30 2836:40, 2837:2,

advantage [2] -

2845:24, 2854:6

advantages [1] -

alternate [3] -

2840:12, 2849:41,

2863:44

2839:5, 2877:42,

2878:14, 2879:10

applies [1] - 2821:38

2855:7 alternative [1] - apply [2] - 2866:33,

advice [30] - 2803:2, 2803:4 2866:35

2829:19, 2836:28, alternatively [2] - applying [2] -

2849:41, 2851:42, 2829:21, 2829:46 2829:12, 2837:18

2857:1, 2857:2, amended [2] - appoint [1] - 2887:25

2857:6, 2857:9, 2802:32, 2833:18 appointed [4] -

2857:12, 2871:31, amount [8] - 2820:39, 2845:34, 2864:15,

2872:26, 2880:40, 2820:40, 2835:9, 2875:30, 2887:34

2880:45, 2881:5, 2852:33, 2853:26, appointment [1] -

2881:32, 2881:36, 2859:46, 2860:6, 2887:43

2881:44, 2883:12, 2877:19 appreciate [2] -

2883:39, 2883:40, amounts [2] - 2812:28, 2819:45

2883:43, 2884:5, 2860:35, 2862:12 appreciated [1] -

2884:6, 2884:8, analysis [2] - 2865:25, 2832:3

2884:16, 2884:19, 2867:40 appreciative [1] -

2884:42, 2884:45, analyst [4] - 2848:15, 2889:21

2887:20 2848:26, 2848:32, apprehend [4] -

advisable [1] - 2805:7 2848:43 2813:4, 2829:13,

advise [3] - 2845:40, AND [1] - 2787:3 2872:23, 2873:6

2882:10, 2883:23 and,indeed [1] - apprehended [1] -

advised [1] - 2837:44 2805:12 2837:43

adviser [4] - 2788:41, announce [1] - 2786:9 approach [5] - 2813:5,

2788:45, 2789:3, annual [5] - 2798:1, 2830:42, 2831:16,

2795:43 2798:4, 2798:5, 2849:27, 2879:44

Adviser [1] - 2795:28 2798:8, 2845:37 approached [5] -

advising [1] - 2872:31 answer [16] - 2796:13, 2829:5, 2868:8,

advocacy [2] - 2789:9, 2796:14, 2802:41, 2868:12, 2868:27,

2843:6 2804:15, 2808:28, 2884:7

Affairs [1] - 2795:28 2808:29, 2810:38, appropriate [19] -

affairs [6] - 2788:41, 2811:19, 2813:42, 2793:17, 2804:18,

2836:1, 2842:26, 2814:37, 2818:37, 2804:33, 2805:24,

2846:5, 2846:12, 2827:46, 2827:47, 2805:26, 2842:37,

2847:12 2856:13, 2871:19, 2847:32, 2847:35,

agent [1] - 2819:17 2875:13 2847:39, 2849:39,

ago [1] - 2859:34 answerable [1] - 2856:29, 2860:41,

agree [7] - 2804:47, 2843:33 2861:2, 2861:25,

2805:26, 2839:10,

2880:24, 2880:27,

2888:26, 2888:43

answered [1] -

2836:12

answering [1] -

2862:24, 2887:38,

2887:39, 2887:41

appropriateness [1] -

.13/10/2017 (25) 3


2829:28, 2834:5 2798:40, 2799:8,

2799:17, 2800:13,

2800:14, 2800:16,

2801:16, 2801:25,

2801:30, 2857:36,

2868:9, 2868:30,

2871:12

audited [2] - 2825:39,

2825:42

auditing [3] - 2845:36,

2869:5, 2869:6

auditor [15] - 2799:9,

2799:32, 2799:35,

2799:39, 2800:17,

2801:10, 2805:46,

2806:1, 2806:4,

2845:34, 2869:1,

2875:26, 2875:30

auditors [4] - 2798:23,

2799:27, 2801:8,

2877:11

auditors' [1] - 2799:10

audits [1] - 2849:3

August [17] - 2787:16,

2787:19, 2787:20,

2787:23, 2787:25,

2787:33, 2828:5,

2828:6, 2833:30,

2834:13, 2835:17,

2837:10, 2837:26,

2851:4, 2863:7,

2864:33, 2881:2

Aurion [6] - 2852:38,

2853:6, 2853:7,

2854:14, 2855:39

Australia [8] -

2821:34, 2821:42,

2823:18, 2823:35,

2886:3, 2886:6,

2886:11, 2886:38

Australia's [1] -

2885:45

authorised [1] -

2877:21

authorities [6] -

2818:46, 2819:2,

2821:47, 2822:29,

2822:39, 2843:37

authority [33] -

2785:4, 2807:20,

2811:6, 2811:10,

2811:38, 2814:15,

2814:21, 2814:45,

2816:23, 2819:4,

2819:12, 2819:21,

2824:46, 2824:47,

2835:4, 2835:5,

2835:8, 2835:14,

2835:16, 2836:40,

2836:43, 2837:46,

2838:31, 2856:21,

2870:27, 2877:41,

2878:6, 2879:34,

2880:17, 2880:22,

2888:12, 2888:13

automatic [1] -

2820:17

automatically [1] -

2820:9

auxiliaries [2] -

2803:32, 2807:42

auxiliary [1] - 2807:31

available [2] -

2821:34, 2851:46

average [1] - 2831:8

aware [75] - 2792:33,

2796:18, 2797:31,

2800:31, 2801:35,

2801:45, 2806:20,

2806:23, 2806:25,

2806:29, 2806:45,

2807:15, 2807:16,

2807:19, 2809:16,

2811:1, 2811:5,

2811:9, 2811:11,

2811:13, 2811:14,

2811:28, 2811:32,

2814:10, 2814:14,

2814:21, 2814:25,

2814:30, 2814:32,

2817:37, 2819:41,

2821:3, 2821:7,

2821:37, 2823:17,

2823:27, 2824:3,

2824:11, 2824:22,

2824:30, 2824:33,

2828:19, 2829:26,

2832:30, 2834:10,

2834:35, 2835:23,

2836:31, 2842:10,

2843:32, 2843:34,

2843:36, 2845:12,

2845:15, 2854:27,

2855:14, 2858:9,

2858:14, 2858:18,

2861:12, 2862:5,

2863:32, 2875:11,

2875:21, 2878:12,

2878:15, 2879:21,

2879:22, 2879:23,

2879:29, 2879:32,

2883:24, 2883:27,

2885:45

awareness [1] -

2825:28

backdated [4] - benevolent [2] -

aspects [12] - 2813:2, 2787:19, 2787:23, 2841:25, 2884:22

2819:30, 2821:16, 2851:12, 2851:15 Bergin [1] - 2785:32

2834:15, 2856:39, background [1] - best [6] - 2800:24,

2856:41, 2857:3, 2840:11 2801:14, 2801:24,

2869:8, 2871:32, bad [1] - 2808:14 2801:27, 2877:12,

2877:10, 2877:20, balance [4] - 2798:31, 2886:42

2888:38 2798:33, 2798:35, better [9] - 2818:12,

assess [4] - 2869:31, 2798:46 2839:23, 2846:44,

2875:17, 2875:25, bank [13] - 2811:33, 2849:20, 2853:16,

2880:21 2816:42, 2817:3, 2853:28, 2888:30

assessed [1] - 2817:11, 2820:39, between [14] -

2845:33 2820:41, 2821:5, 2787:29, 2803:30,

assessment [5] - 2835:27, 2836:5, 2803:39, 2803:44,

2845:32, 2868:15, 2836:6, 2856:22, 2805:28, 2805:36,

2868:31, 2869:14, 2856:36, 2857:18 2823:24, 2823:46,

2870:27 banked [3] - 2835:24, 2824:33, 2841:20,

assist [7] - 2849:10, 2835:30 2850:25, 2868:35,

2849:43, 2852:12, basic [2] - 2856:44 2871:10, 2882:17

2881:44, 2885:39, basis [1] - 2831:5 beyond [3] - 2845:4,

2886:5, 2886:33 bearing [2] - 2846:2, 2851:40, 2851:41

assistance [6] - 2847:34 big [1] - 2841:34

2802:7, 2802:12, became [22] - bill [2] - 2808:32,

2829:46, 2840:35, 2788:10, 2789:6, 2808:37

2849:37, 2853:30 2789:17, 2792:33, billed [1] - 2859:42

Assistance [1] - 2794:33, 2794:40, bins [1] - 2841:8

2788:8 2794:44, 2795:7, bit [9] - 2788:40,

assistant [3] - 2795:15, 2796:32, 2789:35, 2789:36,

2847:28, 2847:29, 2796:33, 2797:12, 2798:29, 2840:6,

2847:31 2797:26, 2801:35, 2851:40, 2851:41,

assistants [1] - 2801:45, 2834:35, 2867:22, 2877:14

2847:42 2835:23, 2849:26, blurring [3] - 2803:39,

assisting [1] - 2849:31, 2849:46, 2805:28, 2805:36

2885:44 2850:3, 2880:39 board [1] - 2889:24

assists [1] - 2886:7 become [4] - 2787:10, bodies [1] - 2840:14

associated [4] - 2846:11, 2849:35, body [1] - 2888:32

2800:14, 2816:14, 2863:32 bothered [2] - 2834:6,

2877:15, 2887:41 becoming [3] - 2834:8

association [1] - 2797:8, 2836:30, bottom [7] - 2836:18,

2842:15 2849:27 2837:14, 2837:15,

assume [1] - 2796:17 bedded [1] - 2871:28 2865:43, 2865:46,

assumed [2] - BEFORE [1] - 2785:31 2866:38, 2873:27

2795:22, 2850:27 beg [3] - 2824:16, bought [1] - 2841:14

AT [2] - 2889:36, 2868:1, 2869:45 box [6] - 2786:6,

2889:37 beginning [3] - 2813:31, 2828:27,

attached [2] - 2798:27, 2798:30, 2828:35, 2830:5,

2841:44, 2863:23 2806:39 2858:6

attaching [2] - behalf [2] - 2812:37, Branch [4] - 2843:7,

2843:24, 2843:27 2819:8 2843:33, 2876:1,

attendance [1] - belief [4] - 2793:39, 2876:3

2881:27 2793:42, 2856:20, branch [3] - 2864:12,

attended [3] - 2877:33 2876:35, 2876:37

2830:39, 2884:27, believer [1] - 2840:21 Branches [1] -

2887:30 below [1] - 2831:31 2823:21

attending [2] - 2796:3, benefit [4] - 2812:36, branches [22] -

2799:31 2836:34, 2842:15, 2803:32, 2807:16,

B attention [2] - 2852:34 2834:41, 2834:44,

2803:29, 2874:4 benefits [1] - 2812:24 2835:8, 2835:10,

attract [1] - 2842:2

audit [14] - 2798:28, back-end [1] -

2820:11

benevolence [1] -

2841:21

2835:17, 2835:21,

2835:38, 2843:33,

.13/10/2017 (25) 4


2843:36, 2876:6, 2841:22, 2841:23, 2794:7, 2804:39, 2862:4, 2880:16,

2884:29, 2885:20,

2885:34, 2885:40

changing [1] -

2861:46

charitable [18] -

2807:20, 2811:5,

2818:37, 2835:8,

2840:4, 2841:5,

2841:6, 2841:17,

2841:22, 2841:29,

2841:41, 2841:42,

2842:4, 2842:8,

2856:38, 2865:29,

2868:16, 2870:26

CHARITABLE [1] -

2785:12

Charitable [25] -

2800:32, 2801:32,

2805:25, 2808:19,

2810:32, 2810:37,

2810:41, 2811:17,

2812:38, 2814:25,

2814:45, 2818:27,

2818:41, 2819:31,

2820:3, 2821:4,

2821:17, 2821:37,

2832:21, 2834:21,

2856:41, 2868:33,

2869:32, 2870:20,

2872:19

charities [4] -

2840:21, 2841:2,

2841:12, 2841:40

charity [11] - 2831:35,

2839:45, 2840:11,

2841:14, 2841:38,

2841:39, 2842:1,

2842:5, 2852:34,

2884:22

Charity [2] - 2841:7,

2841:9

chart [4] - 2791:4,

2791:19, 2791:24,

2791:28

charts [2] - 2790:42,

2790:43

check [2] - 2851:20,

2868:13

checked [3] - 2862:23,

2862:25

checking [5] -

2862:11, 2862:14,

2862:19, 2862:31

CHESHIRE [50] -

2786:3, 2786:22,

2786:24, 2786:45,

2787:5, 2787:42,

2794:27, 2797:18,

2800:11, 2802:47,

2806:12, 2806:37,

2807:8, 2810:47,

2814:7, 2818:17,

2819:27, 2821:33,

2822:28, 2823:9,

2824:8, 2824:16,

2828:24, 2830:9,

2830:37, 2835:38,

2838:8, 2857:44,

2858:8, 2858:43,

2859:1, 2864:11,

2865:18, 2868:1,

2869:40, 2869:45,

2870:4, 2871:21,

2872:42, 2873:2,

2873:16, 2874:26,

2874:38, 2874:44,

2878:5, 2878:24,

2880:29, 2889:5,

2889:18, 2889:29

Cheshire [18] -

2785:36, 2786:1,

2800:8, 2806:10,

2806:34, 2807:5,

2814:5, 2819:25,

2821:31, 2830:7,

2838:6, 2858:6,

2865:16, 2869:38,

2872:40, 2885:21,

2885:34, 2889:27

Chief [2] - 2830:21,

2830:33

chief [4] - 2848:1,

2848:27, 2849:31,

2849:46

children's [1] -

2841:15

choice [3] - 2852:15,

2852:23, 2852:30

circular [2] - 2864:34,

2885:2

circumstance [1] -

2813:47

circumstances [1] -

2813:4

civil [1] - 2813:39

claims [3] - 2789:9,

2843:5, 2884:32

clarify [6] - 2788:34,

2790:8, 2815:34,

2837:41, 2856:1,

2858:35

clarity [1] - 2859:34

clear [8] - 2787:22,

2789:17, 2799:34,

2801:9, 2812:21,

2825:4, 2829:45,

2847:30

clearing [6] - 2805:31,

2806:4, 2806:16,

2876:10, 2876:14, 2841:24, 2841:28, 2817:42, 2827:31,

2876:37, 2877:9, 2841:29, 2841:31, 2835:2

2877:12, 2877:13, 2841:33, 2841:35, case [6] - 2788:1,

2877:22, 2877:26, 2841:40, 2841:42, 2790:16, 2801:41,

2877:32, 2877:35 2841:44, 2842:31, 2804:9, 2834:32,

branches's [1] - 2843:24, 2843:27, 2835:11

2835:32 2848:14, 2848:26, Castlereagh [1] -

breach [22] - 2802:8, 2848:32, 2848:43, 2786:29

2802:17, 2811:9, 2883:13 categories [1] -

2812:43, 2828:40, BY [2] - 2786:22, 2867:42

2829:40, 2829:45, 2885:28 cater [3] - 2852:25,

2832:36, 2832:39, 2853:21, 2853:28

C 2832:41, 2832:47, ceased [3] - 2792:41,

2836:34, 2836:47, 2793:45, 2824:26

C-O-N-C-U-R [1] -

2863:1

campaign [1] -

2826:46

Camporeale [1] -

2785:38

cancellation [1] -

2836:36

candidate [1] - 2873:7

Cannings [16] -

2880:40, 2881:9,

2881:12, 2881:17,

2881:40, 2882:10,

2882:24, 2882:28,

2882:40, 2883:2,

2883:19, 2883:23,

2883:28, 2883:31,

2883:38, 2883:43

cannot [2] - 2809:13,

2813:43

capable [1] - 2854:16

card [18] - 2808:22,

2831:12, 2859:38,

2859:41, 2860:7,

2860:10, 2860:12,

2860:13, 2860:16,

2860:18, 2860:20,

2860:23, 2860:44,

2861:4, 2861:9,

2862:26

cards [3] - 2809:2,

2809:13, 2816:34

care [3] - 2841:14,

2841:16, 2842:43

careful [1] - 2847:37

carefully [1] - 2812:18

carried [11] - 2810:36,

2816:28, 2826:24,

2826:28, 2826:32,

2826:36, 2827:35,

2827:44, 2834:35,

2835:3, 2859:30

carry [1] - 2825:22

carrying [6] - 2792:18,

2839:39, 2878:11, ceasing [1] - 2824:34

2878:33, 2878:41, cent [7] - 2793:23,

2880:36, 2881:15, 2837:3, 2851:21,

2882:19, 2883:15, 2852:5, 2856:17,

2884:1 2871:46, 2872:3

breaches [10] - central [2] - 2834:24,

2800:31, 2800:35, 2834:26

2800:40, 2801:31, centre [2] - 2841:15,

2834:20, 2878:29, 2841:16

2878:42, 2878:47,

2879:1, 2879:23

break [1] - 2828:27

briefed [1] - 2881:43

Centre [1] - 2788:8

certain [18] - 2800:31,

2811:33, 2814:22,

2814:26, 2821:4,

briefing [1] - 2882:18 2835:28, 2838:13,

briefly [1] - 2882:20 2844:2, 2851:12,

bring [4] - 2804:27, 2851:15, 2851:21,

2836:8, 2848:43, 2857:17, 2862:9,

2875:24 2862:18, 2873:21,

broad [1] - 2818:42 2876:21, 2878:1,

broader [5] - 2803:5, 2879:30

2803:7, 2829:31, certainly [9] - 2819:9,

2872:27, 2884:23 2841:1, 2841:11,

broadly [2] - 2848:38, 2843:8, 2856:40,

2848:41 2870:24, 2872:1,

brochure [7] - 2833:7, 2872:2, 2888:28

2833:9, 2833:10, certainty [1] - 2888:22

2833:11, 2833:12, cetera [2] - 2813:4,

2833:16, 2833:18 2856:25

brought [7] - 2836:7, CFO [3] - 2797:37,

2836:8, 2848:34, 2797:39, 2814:42

2848:45, 2849:4, change [15] - 2804:24,

2849:10, 2863:10 2804:25, 2804:26,

Brown [2] - 2885:5, 2804:27, 2805:16,

2885:8 2809:10, 2852:12,

buckets [3] - 2816:29, 2852:13, 2852:18,

2816:31, 2818:45 2852:19, 2853:27,

Buckley [1] - 2869:47 2862:15, 2862:18,

building [2] - 2830:42, 2884:7, 2886:11

2831:1 changed [6] - 2803:3,

Building [1] - 2785:20 2827:25, 2833:17,

bundle [1] - 2866:38 2843:21, 2850:43,

business [27] - 2885:4

2794:41, 2840:24, changes [11] -

2840:29, 2840:42, 2798:30, 2832:44,

2841:12, 2841:20, 2861:36, 2861:38,

.13/10/2017 (25) 5


2806:21, 2806:27, 2837:10, 2885:5 2857:21, 2857:23,

2857:29, 2857:36,

2868:13, 2868:15,

2868:24, 2868:31,

2869:8, 2869:21,

2869:25, 2869:31,

2870:10, 2870:13,

2870:25, 2870:31,

2870:34, 2871:17,

2871:21, 2871:22,

2871:32, 2871:38,

2872:1, 2872:27,

2874:18, 2874:19,

2874:23, 2874:30,

2874:47, 2875:3,

2875:19, 2875:22,

2875:25, 2875:43,

2876:10, 2876:18,

2876:20, 2876:46,

2877:1, 2877:2,

2877:4, 2877:8,

2877:11, 2877:13,

2877:15, 2877:20,

2877:31, 2878:15,

2878:20, 2878:46,

2879:31, 2879:39,

2887:5, 2887:13,

2887:19, 2887:20,

2887:36

compliant [8] -

2811:30, 2816:11,

2818:5, 2818:6,

2820:3, 2844:34,

2856:38, 2874:31

complied [1] -

2821:17

comply [5] - 2814:30,

2868:32, 2870:19,

2871:37, 2872:18

complying [5] -

2805:24, 2810:36,

2811:17, 2815:40,

2815:41

comprises [1] -

2844:11

concept [1] - 2885:1

concern [12] -

2805:30, 2807:8,

2807:12, 2807:26,

2807:34, 2812:22,

2825:12, 2834:15,

2835:6, 2835:38,

2856:39, 2872:17

concerned [8] -

2796:33, 2796:38,

2805:33, 2825:2,

2825:13, 2834:20,

2878:34, 2880:39

concerning [1] -

2829:25

concerns [5] - 2852:33, 2853:25,

2807:47 comment [2] - 2834:10, 2834:11, 2870:28, 2888:31

clearly [1] - 2818:8 2810:17, 2844:38 2846:40, 2880:45, consideration [17] -

client [11] - 2853:16, commercial [2] - 2881:6 2811:23, 2811:25,

2853:19, 2853:23, 2806:13, 2806:22 concluded [1] - 2820:38, 2820:47,

2853:36, 2853:41, Committee [7] - 2889:13 2821:11, 2821:13,

2854:24, 2854:30, 2826:47, 2827:2, conclusions [1] - 2821:16, 2821:20,

2855:32, 2860:42, 2833:35, 2833:39, 2867:15 2821:26, 2821:46,

2871:46 2833:40, 2833:43, Concur [2] - 2862:45, 2822:16, 2829:43,

clients [3] - 2840:32, 2834:14 2863:11 2838:13, 2878:24,

2872:3, 2884:34 committee [12] - conditions [4] - 2879:38, 2880:2,

closer [2] - 2797:13, 2827:2, 2827:7, 2814:22, 2814:31, 2880:8

2797:16 2833:33, 2834:2, 2815:38, 2870:27 considerations [1] -

clothing [1] - 2841:8 2836:7, 2855:19, conduct [4] - 2785:6, 2887:5

collected [3] - 2858:36, 2858:43, 2845:41, 2845:42, considered [6] -

2843:45, 2877:16, 2859:2, 2859:3, 2846:7 2829:2, 2832:20,

2877:18 2859:9, 2859:13 conducted [6] - 2832:38, 2879:43,

collection [3] - common [1] - 2860:32 2794:45, 2810:28, 2885:21, 2887:6

2816:29, 2818:45, communicate [1] - 2823:30, 2824:26, considering [2] -

2841:8 2830:32 2855:46, 2857:6 2803:13, 2877:37

collectively [1] - communicated [2] - conducting [3] - constituted [2] -

2880:10 2837:44, 2883:25 2795:8, 2868:30, 2789:2, 2819:45

collectors [3] - communication [1] - 2868:31 Constitution [2] -

2816:6, 2816:29, 2838:2 conducts [1] - 2843:11, 2843:17

2816:31 communications [5] - 2823:31 consultant [1] -

Collins [27] - 2786:4, 2797:28, 2801:7, confidence [6] - 2872:37

2786:7, 2786:11, 2801:10, 2809:35, 2874:31, 2875:2, consultants [2] -

2786:18, 2786:24, 2877:40 2875:7, 2875:12, 2885:22, 2885:43

2786:26, 2787:5, community [3] - 2878:21, 2878:27 contemplated [1] -

2806:40, 2806:41, 2789:8, 2793:14, confident [1] - 2829:12

2812:23, 2813:3, 2886:42 2878:41 content [1] - 2831:27

2813:31, 2813:32, company [7] - confirm [4] - 2817:24, contents [2] - 2785:5,

2814:9, 2829:31, 2821:21, 2839:45, 2866:10, 2866:34, 2813:25

2830:5, 2830:11, 2884:22, 2887:26, 2873:34 context [7] - 2805:23,

2857:46, 2858:6, 2887:33, 2887:35, confirmations [1] - 2805:28, 2809:16,

2858:8, 2880:38, 2887:37 2838:26 2818:2, 2879:10,

2885:17, 2885:30, compare [2] - conflict [1] - 2868:31 2880:20, 2886:24

2888:7, 2889:2, 2876:37, 2876:39 conflicts [5] - continue [11] -

2889:7, 2889:19 complaint [1] - 2864:20, 2864:24, 2803:25, 2809:7,

COLLINS [2] - 2793:44 2864:30, 2864:41, 2832:45, 2833:6,

2786:20, 2787:2 complete [1] - 2887:39 2839:6, 2839:15,

collins' [1] - 2812:37 2867:32 connect [1] - 2807:23 2839:16, 2839:22,

Collins's [1] - 2889:12 completed [4] - conscious [1] - 2843:41, 2844:34,

colour [1] - 2799:46 2798:6, 2798:9, 2812:42 2844:37

combination [2] - 2855:44, 2867:33 consent [2] - 2880:5, continued [4] -

2840:46, 2842:41 completely [1] - 2880:14 2796:21, 2802:11,

combined [2] - 2797:22 consented [1] - 2802:17, 2802:35

2850:25, 2855:23 compliance [82] - 2863:38 continues [2] -

comfort [1] - 2871:36 2805:19, 2811:29, consequence [1] - 2801:41, 2803:21

coming [6] - 2798:28, 2812:38, 2815:38, 2880:44 continuing [1] -

2825:18, 2836:43, 2816:20, 2816:36, consequences [1] - 2839:4

2848:24, 2848:42, 2818:2, 2818:3, 2877:27 contract [9] - 2787:16,

2856:40 2818:22, 2818:26, consider [9] - 2787:19, 2787:22,

commence [3] - 2818:36, 2819:30, 2794:16, 2796:10, 2792:28, 2827:18,

2787:18, 2863:12, 2834:36, 2836:25, 2804:13, 2810:35, 2848:18, 2848:23,

2881:1 2836:27, 2836:31, 2810:38, 2839:44, 2848:24, 2862:23

commenced [8] - 2836:34, 2837:9, 2871:2, 2878:3, contractor [1] -

2787:42, 2789:16, 2841:7, 2841:10, 2878:5 2872:33

2792:32, 2801:46, 2845:44, 2856:29, considerable [6] - contractual [2] -

2810:47, 2814:9, 2856:33, 2857:4, 2836:24, 2840:14, 2862:12, 2862:22

.13/10/2017 (25) 6


control [5] - 2791:41, 2804:34, 2804:41,

2804:44, 2805:6,

2805:13, 2805:20,

2805:25, 2805:32,

2806:13, 2806:17,

2806:22, 2806:31,

2807:9, 2807:13,

2807:26, 2807:31,

2807:34, 2807:38,

2807:43, 2807:47,

2808:15, 2808:23,

2808:27, 2808:32,

2808:37, 2808:41,

2808:45, 2810:28,

2811:10, 2811:18,

2811:39, 2811:44,

2814:11, 2814:15,

2814:22, 2814:31,

2815:18, 2815:20,

2815:28, 2815:32,

2817:18, 2817:19,

2818:18, 2818:23,

2818:32, 2821:11,

2821:34, 2821:38,

2821:42, 2823:10,

2823:18, 2823:21,

2823:31, 2823:35,

2824:12, 2825:8,

2825:18, 2826:4,

2826:28, 2826:32,

2826:41, 2827:3,

2827:8, 2830:18,

2831:36, 2831:40,

2831:44, 2831:47,

2832:4, 2832:32,

2833:30, 2833:34,

2833:43, 2834:32,

2834:37, 2834:41,

2835:44, 2836:15,

2836:25, 2836:36,

2836:40, 2836:44,

2837:29, 2838:10,

2838:16, 2842:16,

2842:21, 2842:28,

2843:33, 2843:37,

2843:41, 2844:16,

2846:8, 2846:18,

2847:1, 2847:16,

2849:10, 2849:14,

2850:33, 2850:41,

2851:11, 2851:47,

2854:33, 2855:7,

2857:22, 2858:11,

2858:20, 2861:14,

2863:34, 2864:16,

2864:21, 2865:9,

2865:26, 2865:31,

2866:26, 2867:15,

2870:10, 2870:11,

2870:22, 2870:44,

2871:7, 2871:38,

2871:45, 2872:11,

2872:29, 2873:38,

2874:32, 2875:3,

2875:8, 2875:31,

2876:10, 2876:14,

2876:18, 2877:5,

2877:27, 2877:32,

2877:43, 2878:6,

2878:15, 2878:46,

2879:31, 2879:35,

2880:3

corrections [1] -

2813:6

correctly [1] - 2827:47

correspondence [1] -

2838:11

costs [1] - 2840:33

Council [12] -

2833:45, 2842:42,

2844:40, 2858:37,

2858:46, 2859:10,

2859:18, 2859:19,

2859:22, 2864:32,

2875:28, 2884:44

Councillor [4] -

2859:8, 2863:17,

2863:18, 2863:46

Councillors [4] -

2858:24, 2858:25,

2865:2, 2873:21

Councillors's [1] -

2858:33

counsel [5] - 2813:40,

2880:33, 2881:33,

2881:43, 2885:30

Counsel [1] - 2884:19

couple [8] - 2798:36,

2841:10, 2863:12,

2872:17, 2872:20,

2883:31, 2885:23,

2885:31

course [8] - 2798:39,

2813:11, 2813:39,

2829:9, 2833:21,

2846:43, 2879:29,

2884:42

Court [2] - 2829:47,

2881:20

court [7] - 2813:5,

2828:46, 2829:5,

2829:12, 2829:19,

2839:5

cover [1] - 2858:23

covered [4] - 2813:18,

2814:18, 2816:2,

2884:34

covering [1] - 2791:36

covers [1] - 2859:31

coversheet [2] -

2862:18, 2863:9

credit [20] - 2808:22,

2809:2, 2809:13,

2831:12, 2859:38,

2859:41, 2860:7,

2860:10, 2860:12,

2860:13, 2860:16,

2860:18, 2860:20,

2860:23, 2860:44,

2861:4, 2861:8,

2862:26

criminal [1] - 2813:38

criticism [2] -

2888:16, 2888:46

CRM [2] - 2854:26,

2854:28

cross [1] - 2869:12

cross-purposes [1] -

2869:12

current [34] - 2786:31,

2788:14, 2791:28,

2791:32, 2793:21,

2793:27, 2801:37,

2802:12, 2802:18,

2802:35, 2802:47,

2803:2, 2803:22,

2804:25, 2822:44,

2823:2, 2831:39,

2832:27, 2832:32,

2832:41, 2833:3,

2833:16, 2833:25,

2838:38, 2839:37,

2843:16, 2846:31,

2852:3, 2856:27,

2879:34, 2884:27,

2884:30, 2886:40,

2886:41

current" [2] - 2833:6,

2833:7

cy [1] - 2829:12

dated [2] - 2786:35,

2796:17, 2814:41, 2866:44

2835:47, 2847:11 day-to-day [1] -

controlled [2] - 2804:39

2790:25, 2861:24 deal [3] - 2789:33,

convenient [1] - 2857:40, 2872:26

2828:24 dealing [4] - 2817:29,

conversation [1] - 2850:7, 2864:20,

2818:4 2872:25

COO [1] - 2849:27 dealings [6] -

coordinates [1] - 2797:28, 2799:26,

2824:41 2799:39, 2801:25,

coordinator [1] - 2805:47, 2830:37

2846:36 dealt [7] - 2821:22,

copies [1] - 2861:8 2841:46, 2852:44,

COPYRIGHT [1] - 2853:2, 2861:5,

2785:1 2861:13, 2884:30

Copyright [1] - 2785:2 December [5] -

core [1] - 2886:40 2881:26, 2882:4,

Coresoft [1] - 2851:26 2882:29, 2884:39

corner [3] - 2865:43, decide [2] - 2819:33,

2865:46, 2873:27 2841:40

Cornerstone [1] - decided [4] - 2842:41,

2821:21 2846:43, 2859:9,

corporate [2] - 2883:22

2868:24, 2887:37 decision [18] -

corporations [1] - 2803:16, 2803:19,

2846:42 2804:28, 2804:29,

correct [205] -

2786:35, 2786:39,

2787:7, 2787:11,

2787:45, 2788:1,

2788:6, 2788:10,

2788:23, 2788:29,

2789:9, 2789:13,

2789:18, 2790:26,

2836:22, 2837:1,

2837:28, 2837:32,

2837:33, 2837:36,

2838:10, 2838:34,

2842:46, 2845:47,

2859:7, 2859:13,

2869:10

decisions [3] -

2790:33, 2790:38, 2804:20, 2804:23,

2790:42, 2791:5, 2852:21

2791:13, 2791:20, decompression [2] -

2791:29, 2791:42, 2792:33, 2792:37

D 2791:46, 2792:10, deductible [1] -

2792:22, 2792:25, 2831:44

data [15] - 2853:26,

2866:11, 2866:34,

2866:45, 2867:1,

2867:14, 2867:15,

2867:37, 2867:40,

2867:41, 2867:42,

2867:43, 2867:46,

2868:41, 2873:35

database [1] - 2872:3

date [16] - 2802:40,

2838:17, 2838:25,

2845:2, 2845:35,

2847:30, 2851:7,

2855:39, 2859:22,

2863:42, 2863:44,

2864:39, 2869:1,

2869:2, 2876:30,

2885:8

2792:34, 2792:42, deed [1] - 2882:11

2794:3, 2794:7, deeper [1] - 2876:36

2794:23, 2794:28, Defence [7] - 2788:8,

2794:32, 2794:37, 2788:14, 2788:28,

2794:41, 2794:46, 2831:13, 2831:17,

2795:4, 2795:16, 2831:39, 2884:29

2795:22, 2795:27, defence [1] - 2832:31

2796:26, 2796:38, DefenceCare [72] -

2796:41, 2797:23, 2788:5, 2788:7,

2798:12, 2800:32, 2788:10, 2788:32,

2800:36, 2801:38, 2788:45, 2789:2,

2801:42, 2801:46, 2789:6, 2789:7,

2802:8, 2802:13, 2789:12, 2789:18,

2802:18, 2802:21, 2789:31, 2789:33,

2802:24, 2802:32, 2790:38, 2791:23,

2802:36, 2803:22, 2791:46, 2792:6,

2803:26, 2803:34, 2792:10, 2792:15,

2803:45, 2804:10, 2792:38, 2794:2,

.13/10/2017 (25) 7


2794:11, 2795:38, describe [3] -

2792:13, 2792:21

described [9] -

2791:45, 2792:3,

2792:9, 2792:33,

2797:18, 2805:30,

2807:29, 2810:25,

2879:3

descriptions [1] -

2847:25

detail [4] - 2831:28,

2839:12, 2850:27,

2883:35

details [2] - 2845:8,

2876:33

devastating [1] -

2840:34

develop [3] - 2859:34,

2886:15, 2886:16

developed [5] -

2789:34, 2789:36,

2848:23, 2859:33,

2876:32

developing [2] -

2847:32, 2847:39

development [5] -

2830:11, 2831:25,

2831:28, 2880:4,

2886:9

diagnosed [2] -

2882:40, 2883:2

difference [1] -

2831:47

different [13] -

2788:22, 2789:32,

2799:45, 2808:9,

2829:14, 2833:39,

2839:27, 2839:36,

2848:27, 2859:36,

2862:37, 2884:8,

2884:10

differently [1] -

2827:30

difficult [4] - 2796:13,

2800:22, 2852:20,

2870:29

difficulty [1] - 2874:42

dig [1] - 2876:36

dinner [2] - 2860:33

direct [2] - 2789:41,

2789:45

directed [1] - 2820:14

direction [1] - 2789:30

directions [1] -

2828:45

directly [2] - 2847:5,

2848:34

disagree [1] - 2839:11

discharge [3] -

2832:43, 2884:31,

2884:35 2807:21, 2808:9, 2807:29, 2810:21,

2795:39, 2796:12, discovered [1] - 2823:1, 2823:3, 2810:22, 2813:41,

2809:42, 2810:28, 2796:34 2825:3, 2828:21, 2815:39, 2817:16,

2814:10, 2814:44, discovering [1] - 2831:43, 2832:21, 2818:6, 2827:5,

2817:42, 2819:36, 2797:9 2833:13, 2835:20, 2836:14, 2875:39,

2826:33, 2826:35, discuss [10] - 2815:1, 2840:26, 2840:45, 2877:30, 2882:42,

2826:36, 2827:31, 2815:28, 2815:31, 2865:29, 2867:43, 2887:44

2827:35, 2827:37, 2816:12, 2816:14, 2877:17 effectively [18] -

2828:16, 2828:21, 2816:26, 2831:11, done [25] - 2797:35, 2789:21, 2789:26,

2831:19, 2831:35, 2833:2, 2872:7, 2797:37, 2799:18, 2790:25, 2795:39,

2833:11, 2834:28, 2880:15 2800:26, 2801:33, 2804:10, 2819:17,

2839:6, 2839:13, discussed [13] - 2802:24, 2802:40, 2828:2, 2830:25,

2839:18, 2839:21, 2805:45, 2806:3, 2813:5, 2815:45, 2832:12, 2843:3,

2839:27, 2839:46, 2815:27, 2838:46, 2835:13, 2839:33, 2844:16, 2850:25,

2840:3, 2840:9, 2839:3, 2844:3, 2839:36, 2842:43, 2851:28, 2853:32,

2840:17, 2840:25, 2844:4, 2844:9, 2845:31, 2848:45, 2855:10, 2870:41,

2840:30, 2840:38, 2845:1, 2879:25, 2852:6, 2852:8, 2877:47, 2881:4

2840:41, 2840:43, 2883:10, 2884:28, 2852:10, 2863:19, eight [1] - 2863:11

2840:44, 2841:44, 2885:32 2868:7, 2868:45, either [11] - 2793:20,

2841:45, 2842:32, discussing [2] - 2869:24, 2871:23, 2802:39, 2804:28,

2842:38, 2843:1, 2816:22, 2817:7 2874:19, 2876:30 2811:43, 2815:31,

2843:2, 2844:10, discussion [7] - donor [2] - 2808:10, 2828:45, 2829:44,

2844:12, 2844:15, 2800:39, 2810:1, 2820:19 2840:46, 2849:26,

2844:20, 2853:24, 2810:5, 2817:32, donors [1] - 2817:29 2876:38, 2884:18

2853:29, 2884:41, 2817:34, 2859:9, door [2] - 2790:10, email [12] - 2830:44,

2885:1 2863:5 2790:12 2832:7, 2832:12,

deficiencies [8] - discussions [21] - dormant [3] - 2799:1, 2832:26, 2833:3,

2836:15, 2853:12, 2789:46, 2790:1, 2799:7, 2799:11 2863:21, 2863:30,

2857:17, 2862:6, 2810:14, 2816:10, doubt [1] - 2834:4 2880:37, 2880:44,

2865:21, 2873:17, 2816:38, 2816:40, down [7] - 2812:23, 2881:22, 2881:28,

2873:18, 2874:13 2817:38, 2817:43, 2825:5, 2839:46, 2881:40

degree [1] - 2878:21 2819:9, 2824:33, 2840:1, 2857:47, emailed [1] - 2837:33

Del [1] - 2864:12 2824:38, 2826:11, 2871:28, 2889:7 emails [4] - 2801:12,

delay [1] - 2884:32 2838:43, 2839:7, draft [1] - 2864:26 2801:18, 2831:31,

delegation [16] - 2844:39, 2846:41, draw [1] - 2874:4 2832:22

2830:44, 2859:31, 2846:44, 2870:28, drawn [1] - 2803:29 employed [6] -

2860:1, 2860:2, 2870:38, 2886:38, due [4] - 2813:10, 2818:18, 2827:17,

2860:4, 2860:6, 2889:14 2813:39, 2853:12, 2827:19, 2847:12,

2860:11, 2861:26, document [3] - 2887:1 2847:28, 2847:31

2863:14, 2863:15,

2863:16, 2863:19,

2863:23, 2863:25,

2863:29

2845:8, 2859:21,

2882:4

documentation [1] -

2827:4

employee [1] -

2788:42

employees [6] -

2809:34, 2817:4,

delineation [1] - documents [1] - E 2858:28, 2859:32,

2847:38 2887:39 2859:33, 2859:35

early [17] - 2794:28,

2794:47, 2795:3,

2798:9, 2799:20,

2799:32, 2822:24,

2826:21, 2834:8,

2835:6, 2836:29,

2863:44, 2877:36,

2882:46, 2885:5,

2886:47, 2887:2

earn [1] - 2840:38

easiest [1] - 2806:38

effect [18] - 2789:32,

2800:24, 2801:15,

2806:16, 2807:19,

deliver [1] - 2803:6 dollar [1] - 2860:46 employment [1] -

delivery [3] - 2840:15, donate [8] - 2807:37, 2827:18

2840:17, 2886:39 2807:41, 2819:41, enable [3] - 2839:16,

demand [5] - 2839:14, 2820:8, 2832:8, 2876:24, 2876:36

2839:17, 2839:20, 2842:2, 2842:8 encompass [2] -

2840:26, 2840:27 donated [2] - 2820:7, 2858:33, 2876:23

Department [2] - 2820:17 encompassing [1] -

2785:3, 2785:4 donation [6] - 2876:6

department [4] - 2807:15, 2807:22, encourages [1] -

2798:16, 2798:19, 2808:11, 2820:26, 2788:27

2820:15 2833:19, 2842:4 end [12] - 2795:17,

departure [1] - 2810:2 donations [21] - 2795:19, 2796:18,

dependants [3] - 2796:37, 2805:31, 2820:11, 2820:35,

2788:14, 2802:13, 2806:17, 2806:21, 2837:21, 2837:26,

2802:36 2806:29, 2806:45, 2863:7, 2867:20,

.13/10/2017 (25) 8


2868:2, 2883:46, entities' [1] - 2842:36 2877:25, 2881:26,

2889:12, 2889:19

eWAY [3] - 2820:10,

2820:21, 2821:20

ex [13] - 2793:14,

2801:37, 2802:13,

2803:22, 2803:25,

2831:14, 2831:16,

2831:39, 2832:27,

2832:31, 2833:4,

2833:26, 2886:14

ex-defence [1] -

2832:31

ex-service [6] -

2793:14, 2803:22,

2803:25, 2831:14,

2831:16, 2886:14

ex-servicemen [2] -

2801:37, 2832:27

ex-serving [1] -

2831:39

exact [1] - 2882:43

exactly [1] - 2864:38

EXAMINATION [2] -

2786:22, 2885:28

examined [1] - 2874:6

example [7] - 2831:16,

2862:22, 2862:26,

2862:31, 2876:35,

2877:18, 2887:9

examples [1] -

2888:29

excellent [1] - 2839:24

except [2] - 2785:4,

2841:9

exception [1] -

2799:25

excluded [5] -

2789:22, 2789:26,

2797:22, 2804:31,

2804:34

excluding [1] -

2828:17

exclusive [1] -

2840:45

excuse [2] - 2812:13,

2829:7

Executive [2] -

2830:21, 2830:33

exemplar [1] -

2888:36

exercise [4] - 2821:22,

2859:29, 2874:5,

2875:43

Exhibit [3] - 2786:46,

2865:33, 2873:24

exhibit [1] - 2790:41

EXHIBIT [1] - 2787:2

exhibits [2] - 2786:38,

2786:46

EXHIBITS [1] - 2787:3 expose [1] - 2813:38

expressed [1] -

2872:17

extant [1] - 2837:46

extended [1] -

2839:37

extensive [1] -

2873:22

extent [6] - 2837:5,

2867:36, 2875:18,

2875:22, 2878:28,

2878:42

external [3] - 2820:22,

2864:2, 2868:14

externally [1] -

2845:33

extra [1] - 2788:40

extracted [1] - 2867:1

extraction [4] -

2866:11, 2866:34,

2866:45, 2873:35

extremely [1] - 2862:7

EY [15] - 2868:27,

2868:30, 2868:31,

2868:45, 2869:14,

2869:19, 2869:20,

2871:34, 2872:31,

2872:33, 2874:6,

2875:25, 2887:9,

2887:12

2884:2 entitled [1] - 2818:31 exist [1] - 2822:41

endeavouring [1] - entity [17] - 2803:4, expand [2] - 2875:45,

2842:20 2803:7, 2803:17, 2877:13

ending [1] - 2863:41 2804:23, 2839:7, expansion [1] -

endorsed [1] - 2839:23, 2839:36, 2863:16

2884:36 2839:44, 2840:4, expect [1] - 2859:21

endorsing [1] - 2842:39, 2842:40, expected [1] - 2798:8

2829:27 2884:21, 2884:24, expend [1] - 2860:43

engage [7] - 2803:5, 2884:26, 2884:41, expended [2] -

2825:45, 2849:5, 2884:46 2799:16, 2852:27

2870:37, 2884:14, envisage [2] - expenditure [21] -

2884:23, 2884:26 2840:41, 2843:27 2831:12, 2831:13,

engaged [20] - 2811:2, Enzo [1] - 2785:38 2859:8, 2859:33,

2847:19, 2848:10, Ernst [42] - 2845:38, 2859:35, 2860:1,

2848:14, 2848:18, 2857:16, 2857:22, 2860:7, 2860:10,

2866:11, 2866:32, 2857:37, 2861:13, 2860:19, 2860:25,

2870:37, 2872:33, 2861:18, 2862:3, 2860:42, 2861:22,

2873:35, 2874:29, 2865:7, 2865:24, 2862:8, 2862:10,

2874:35, 2875:26, 2865:27, 2866:10, 2862:19, 2862:23,

2884:11, 2884:15, 2866:30, 2866:44, 2862:24, 2863:18,

2885:22, 2885:30, 2867:21, 2867:24, 2863:24, 2865:10,

2885:39, 2886:11, 2867:32, 2868:3, 2873:21

2886:47 2868:7, 2868:8, expenditures [1] -

engagement [5] - 2868:12, 2869:30, 2862:13

2861:43, 2866:43, 2870:33, 2870:38, expense [6] - 2856:42,

2869:2, 2870:8, 2870:39, 2871:10, 2856:47, 2858:20,

2874:47 2871:23, 2871:37, 2862:16, 2862:45,

engaging [3] - 2872:8, 2872:25, 2863:8

2832:12, 2874:40, 2872:43, 2873:17, expenses [10] -

2886:38 2873:34, 2874:12, 2809:21, 2810:6,

F ensure [12] - 2808:3, 2874:17, 2874:21, 2810:10, 2810:22,

2814:43, 2816:10, 2874:22, 2874:23, 2820:40, 2820:41,

facilitate [1] - 2807:20

facility [1] - 2859:43

fact [27] - 2788:1,

2789:17, 2789:39,

2790:16, 2792:2,

2792:5, 2792:18,

2793:12, 2801:36,

2810:36, 2811:9,

2811:22, 2814:30,

2815:23, 2815:40,

2816:11, 2818:17,

2819:28, 2820:40,

2833:3, 2833:6,

2833:43, 2837:14,

2846:5, 2850:36,

2854:11, 2859:12

factor [1] - 2839:27

Fair [24] - 2837:44,

2838:11, 2838:26,

2838:31, 2845:18,

2845:19, 2845:40,

2877:41, 2877:47,

2878:10, 2878:25,

2878:32, 2878:39,

2879:11, 2879:12,

2879:16, 2879:26,

2816:36, 2842:27, 2874:29, 2874:35, 2856:43, 2858:15,

2869:32, 2870:25, 2874:47, 2875:16, 2858:44, 2861:14

2870:31, 2871:47, 2875:30 experience [1] -

2874:30, 2875:2, escapes [1] - 2864:39 2887:13

2887:19 essential [1] - 2805:9 experienced [1] -

ensuring [4] - established [2] - 2872:35

2816:11, 2819:30, 2839:15, 2841:34 expertise [4] -

2852:26, 2877:17 establishing [1] - 2851:40, 2851:42,

entering [1] - 2853:26 2840:24 2886:18, 2886:20

entertaining [1] - et [2] - 2813:4, explain [11] - 2787:38,

2860:22 2856:25 2789:35, 2799:28,

entire [6] - 2817:18, Evans [1] - 2885:8 2803:46, 2806:26,

2851:10, 2851:29, events [1] - 2849:1 2808:29, 2824:37,

2853:17, 2853:27, eventuate [1] - 2832:33, 2840:6,

2863:14 2845:36 2884:3, 2885:8

entirely [1] - 2805:24 evidence [26] - explained [7] -

entirety [6] - 2788:32, 2801:8, 2813:2, 2822:32, 2825:5,

2788:34, 2788:38, 2813:11, 2817:30, 2835:33, 2835:35,

2788:46, 2789:12, 2817:46, 2818:14, 2882:24, 2882:40,

2790:24 2829:42, 2830:16, 2883:10

entities [13] - 2803:6, 2830:24, 2833:42, explanation [7] -

2803:31, 2803:34, 2836:33, 2841:19, 2800:21, 2800:22,

2803:40, 2803:45, 2861:36, 2861:42, 2800:25, 2804:15,

2804:14, 2805:32, 2864:19, 2870:18, 2818:38, 2856:14,

2805:36, 2823:17, 2871:26, 2873:7, 2875:13

2839:1, 2842:16, 2874:17, 2874:34, explore [2] - 2814:34,

2842:21, 2845:13 2875:34, 2875:39, 2829:24

.13/10/2017 (25) 9


2879:39, 2879:44, finances [10] -

2789:25, 2796:26,

2804:9, 2811:28,

2817:18, 2848:41,

2849:13, 2849:17,

2853:15, 2855:21

financial [65] -

2790:24, 2794:41,

2795:4, 2796:33,

2796:41, 2797:12,

2797:27, 2797:31,

2797:46, 2798:1,

2798:8, 2800:36,

2804:32, 2804:34,

2804:40, 2811:32,

2814:40, 2815:45,

2817:12, 2817:17,

2818:21, 2818:46,

2825:36, 2825:38,

2825:39, 2825:44,

2830:24, 2836:1,

2836:9, 2842:26,

2845:30, 2847:11,

2848:46, 2849:6,

2849:20, 2850:7,

2850:8, 2850:11,

2850:13, 2850:43,

2851:10, 2851:29,

2851:46, 2853:1,

2853:29, 2853:36,

2854:21, 2854:31,

2855:34, 2856:3,

2856:17, 2856:22,

2856:30, 2857:4,

2857:21, 2857:23,

2857:37, 2857:38,

2861:46, 2865:8,

2865:26, 2865:28,

2870:35, 2872:28,

2874:7

financially [3] -

2805:5, 2805:13,

2852:22

financials [1] -

2857:17

fine [1] - 2787:42

finish [1] - 2887:18

finished [1] - 2855:43

firm [1] - 2875:25

first [20] - 2798:4,

2798:27, 2799:39,

2808:36, 2810:9,

2815:6, 2815:23,

2815:35, 2830:41,

2830:47, 2834:7,

2843:9, 2845:37,

2847:29, 2849:31,

2849:35, 2876:38,

2877:3, 2881:13,

2885:6

firstly [1] - 2886:3 frames [1] - 2836:30

framework [1] -

2876:32

Friday [2] - 2785:27,

2889:31

front [2] - 2806:37,

2878:7

fruition [1] - 2816:25

full [7] - 2786:25,

2804:35, 2820:39,

2837:5, 2847:13,

2870:25, 2878:28

full-time [1] - 2847:13

fully [7] - 2787:34,

2836:18, 2837:4,

2837:22, 2856:37,

2875:21, 2878:20

function [5] - 2804:21,

2819:42, 2846:35,

2846:38, 2846:45

functional [1] -

2854:45

functionality [2] -

2852:19, 2853:25

functions [1] - 2868:3

fund [3] - 2798:36,

2840:25, 2840:29

Fund [1] - 2824:12

funded [1] - 2841:3

funding [1] - 2839:23

fundraise [13] -

2811:27, 2819:4,

2819:7, 2819:12,

2819:20, 2823:5,

2823:26, 2824:4,

2824:34, 2825:32,

2837:45, 2838:40,

2884:25

fundraisers [3] -

2814:44, 2816:13,

2818:43

fundraises [4] -

2816:15, 2824:22,

2828:20

fundraising [87] -

2807:19, 2810:27,

2811:2, 2811:6,

2811:37, 2811:38,

2814:11, 2814:14,

2814:18, 2814:21,

2814:35, 2815:3,

2815:6, 2815:34,

2816:23, 2816:25,

2816:28, 2817:22,

2819:10, 2819:20,

2819:45, 2821:5,

2822:47, 2823:9,

2823:13, 2824:26,

2824:27, 2824:43,

2824:44, 2824:46,

2824:47, 2825:14,

2825:22, 2825:29,

2825:46, 2826:13,

2828:17, 2832:13,

2832:17, 2833:9,

2833:13, 2833:19,

2833:23, 2835:8,

2835:16, 2836:40,

2837:29, 2837:45,

2838:33, 2840:2,

2840:5, 2841:5,

2841:6, 2841:45,

2841:46, 2842:4,

2842:6, 2842:7,

2843:32, 2843:37,

2843:41, 2843:45,

2844:28, 2844:29,

2844:32, 2844:37,

2845:41, 2845:42,

2846:7, 2846:23,

2846:24, 2846:25,

2846:32, 2847:1,

2856:12, 2856:38,

2857:5, 2857:34,

2857:35, 2868:16,

2870:26, 2871:32,

2872:35, 2876:35,

2879:34, 2880:17,

2884:24

Fundraising [26] -

2800:32, 2801:32,

2805:25, 2808:19,

2810:32, 2810:37,

2810:41, 2811:18,

2812:39, 2814:26,

2814:45, 2818:27,

2818:41, 2819:31,

2820:3, 2821:4,

2821:17, 2821:37,

2832:21, 2834:21,

2856:18, 2856:41,

2868:33, 2869:33,

2870:20, 2872:19

FUNDRAISING [1] -

2785:12

funds [10] - 2798:31,

2798:33, 2798:36,

2798:41, 2798:43,

2798:44, 2799:1,

2799:11, 2799:13,

2799:17

funeral [3] - 2840:31,

2840:33

future [1] - 2798:45

2880:2, 2880:6, fit [1] - 2842:33

2880:13, 2880:14, flag [1] - 2834:10

2880:21 flagged [1] - 2834:6

fair [1] - 2838:9 flexible [1] - 2852:25

familiar [3] - 2861:20, floor [1] - 2809:33

2861:38, 2861:40 floors [2] - 2809:40,

familiarising [1] - 2809:45

2861:32 flow [1] - 2804:40

families [3] - 2831:40, flowed [1] - 2835:28

2840:34, 2840:36 flowing [1] - 2835:21

family [1] - 2840:32 flux [1] - 2888:19

far [4] - 2861:42, focus [2] - 2876:38,

2876:43, 2883:46, 2883:15

2887:17 follow [2] - 2863:5,

fast [1] - 2842:12 2875:6

fault [1] - 2848:31 followed [1] - 2882:39

February [2] - following [2] -

2795:29, 2801:26 2824:34, 2882:46

February-March [1] - footer [4] - 2831:31,

2801:26 2831:35, 2832:31,

feed [1] - 2840:38 2833:3

feet [2] - 2812:41, forbidden [1] -

2839:19 2794:17

felt [7] - 2796:17, force [2] - 2853:9,

2817:27, 2818:42, 2859:26

2834:8, 2837:22, Force [2] - 2788:28,

2862:7, 2884:33 2831:39

few [3] - 2801:12, forced [1] - 2862:18

2876:44 forensic [5] - 2849:3,

fields [1] - 2876:36 2857:36, 2866:11,

figures [1] - 2860:46 2866:45, 2873:35

files [3] - 2798:41, form [11] - 2803:37,

2799:10, 2852:6 2803:44, 2807:46,

fill [1] - 2839:17 2819:13, 2837:5,

film [2] - 2806:13, 2842:25, 2860:39,

2806:22 2862:29, 2868:41,

final [1] - 2880:11 2869:20, 2876:19

finalised [3] - formal [7] - 2789:30,

2864:25, 2864:27, 2794:45, 2795:8,

2880:11 2795:11, 2810:26,

finance [35] - 2795:45, 2833:33, 2845:8

2796:1, 2796:3, formally [3] - 2795:7,

2796:6, 2796:19, 2795:22, 2866:30

2796:21, 2796:25, formed [1] - 2808:44

2797:13, 2797:18, former [1] - 2788:14

2797:22, 2797:28, forward [17] -

2797:36, 2798:11, 2842:32, 2842:33,

2815:42, 2819:28, 2846:1, 2855:2,

2820:11, 2820:14, 2863:10, 2868:8,

2820:16, 2820:18, 2868:12, 2874:31,

2820:31, 2821:12, 2875:3, 2875:7,

2821:16, 2847:27, 2875:12, 2877:31,

2847:42, 2847:46, 2880:3, 2880:17,

2847:47, 2849:38, 2885:9, 2886:37,

G 2855:19, 2856:34, 2886:43

2858:36, 2861:27, forwarded [1] -

2871:33

Finance [3] - 2785:3,

2785:5, 2821:23

2838:12

four [2] - 2865:44,

2882:5

GAI [2] - 2786:20,

2787:2

Gai [1] - 2786:26

.13/10/2017 (25) 10


gain [3] - 2876:19, 2858:14

grant [2] - 2878:1,

2885:26

granted [3] - 2786:13,

2838:31, 2888:12

granting [1] - 2878:5

grants [4] - 2840:13,

2840:15, 2840:43,

2841:4

grey [3] - 2884:28,

2884:33, 2884:35

gross [2] - 2821:5,

2835:31

ground [1] - 2813:37

grouped [2] - 2867:42,

2867:43

grow [1] - 2841:40

growing [1] - 2841:35

guess [3] - 2841:47,

2842:38, 2886:35

guest [2] - 2860:30,

2860:36

guests [1] - 2860:22

guidance [2] - 2813:5,

2860:16

guidelines [9] -

2859:33, 2859:35,

2859:46, 2860:16,

2860:34, 2860:39,

2860:41, 2861:1,

2863:18

hear [2] - 2813:10, hope [3] - 2839:14, 2863:11

implemented [2] -

2856:35, 2863:9

importance [2] -

2818:2, 2840:21

important [1] -

2794:23

imposed [2] -

2814:22, 2814:26

imposes [1] - 2821:4

impression [1] -

2882:43

improve [4] - 2804:2,

2804:4, 2804:7,

2846:17

in-house [1] - 2804:28

inadequate [2] -

2836:10, 2852:23

include [4] - 2844:20,

2862:30, 2864:45,

2887:9

included [2] -

2813:14, 2832:32

includes [3] -

2791:13, 2805:19,

2856:22

including [5] -

2831:27, 2863:15,

2877:11, 2877:12,

2886:28

income [8] - 2817:28,

2840:12, 2840:20,

2840:22, 2840:38,

2840:40, 2842:10,

2865:30

increasingly [3] -

2796:32, 2835:23,

2836:31

incredibly [1] -

2839:14

indeed [2] - 2821:41,

2852:8

independence [1] -

2868:29

independent [6] -

2864:2, 2869:14,

2871:34, 2884:8,

2884:12, 2884:40

independently [1] -

2869:30

indicate [3] - 2813:36,

2860:31, 2860:35

indicated [1] -

2824:42

individual [2] -

2860:15, 2877:12

individuals [1] -

2888:31

inevitably [1] - 2842:2

infinitely [1] - 2839:17

2876:38, 2884:46 2884:6 2853:46, 2854:45

gateway [3] - 2820:12, heard [5] - 2813:32, hoping [1] - 2887:45

2820:13, 2830:13 2841:19, 2844:38, hospital [1] - 2798:36

Gaudry [1] - 2864:12 2882:38 host [1] - 2887:40

General [17] - Hearing [1] - 2785:16 House [3] - 2809:30,

2786:32, 2787:6, heavily [1] - 2841:6 2809:41, 2809:45

2787:10, 2787:14, held [3] - 2851:28, house [6] - 2804:28,

2789:40, 2792:21, 2851:38, 2876:40 2805:31, 2806:4,

2792:29, 2795:26, Held [1] - 2785:19 2806:16, 2806:21,

2795:39, 2795:40, Hellfire [1] - 2793:36 2807:47

2796:11, 2804:33, help [4] - 2849:6, Housie [2] - 2841:7,

2804:35, 2805:3, 2853:45, 2877:12, 2841:9

2844:42, 2850:4, 2882:18 HR [1] - 2795:45

2888:18 helpful [2] - 2797:5, hub [1] - 2807:46

general [14] - 2790:37, 2885:18 huge [1] - 2857:7

2791:46, 2792:4, helping [3] - 2832:42, Hyde [10] - 2808:27,

2792:5, 2792:10, 2886:9, 2886:10 2808:34, 2808:37,

2792:14, 2792:15, HERZFELD [27] - 2808:40, 2809:8,

2810:17, 2813:12, 2786:9, 2786:16, 2809:16, 2809:26,

2816:19, 2816:21, 2812:3, 2812:8, 2843:30, 2859:42,

2865:21, 2866:26, 2812:13, 2812:17, 2859:44

2867:13 2812:28, 2812:36,

I generally [2] - 2812:45, 2813:8,

2796:41, 2813:1 2813:17, 2813:22,

ID [2] - 2816:33,

2818:45

idea [2] - 2793:47,

2816:25

ideal [1] - 2841:25

identified [7] -

2836:25, 2836:47,

2873:17, 2877:26,

2878:11, 2878:26,

2879:40

identify [1] - 2836:26

identifying [4] -

2874:13, 2877:1,

2877:2, 2877:36

ignored [1] - 2829:37

ill [3] - 2793:13,

2793:16, 2884:31

illness [1] - 2882:41

imagine [3] - 2846:2,

2855:38, 2887:7

immediately [1] -

2837:33

imminent [1] -

2887:30

impact [2] - 2822:3,

2877:21

impacts [1] - 2841:26

implement [3] -

2832:44, 2856:28,

2863:4

implementation [7] -

2854:35, 2856:8,

2862:16, 2862:44,

2863:6, 2863:10,

generate [1] - 2856:11 2813:27, 2828:38,

given [23] - 2789:30, 2828:42, 2829:1,

2800:21, 2801:8, 2829:7, 2829:11,

2804:24, 2814:35, 2829:18, 2829:30,

2817:12, 2817:41, 2829:36, 2830:2,

2819:29, 2829:42, 2874:34, 2874:42,

2829:43, 2830:24, 2888:4, 2889:16,

2836:47, 2848:24, H 2889:24

2849:13, 2852:26, Herzfeld [13] -

2861:36, 2861:42,

2869:1, 2874:17,

2877:7, 2877:17,

hair [1] - 2799:46

half [1] - 2845:37

2786:10, 2786:14,

2811:47, 2812:26,

2812:34, 2812:42,

2879:38, 2880:1 hand [5] - 2788:33, 2813:15, 2813:29,

glean [1] - 2886:15 2841:21, 2865:43, 2828:35, 2829:34,

GM [1] - 2791:32 2865:46, 2873:27 2888:2, 2889:12,

goal [1] - 2804:4 handed [3] - 2851:30, 2889:26

goals [1] - 2804:2 2851:39, 2865:3 high [3] - 2829:26,

governance [21] - handle [1] - 2817:10 2839:14, 2854:16

2804:2, 2804:5, handled [4] - 2817:9, highlighted [2] -

2804:7, 2804:14, 2817:13, 2821:21, 2861:22, 2876:45

2804:20, 2804:26, 2821:22 hindsight [5] -

2834:16, 2842:36, handling [1] - 2787:20 2811:19, 2811:24,

2842:44, 2886:19, handover [1] - 2811:29, 2818:11,

2886:20, 2886:24, 2787:28 2836:34

2886:30, 2886:34, handover" [1] - historical [2] -

2886:35, 2886:36, 2787:30 2798:43, 2851:12

2887:36, 2887:41, hang [1] - 2850:15 historically [1] -

2888:23, 2888:29 hard [2] - 2811:19, 2804:8

governed [1] - 2842:11 hit [1] - 2810:11

2843:12 Hardman [1] - 2883:7 Hodges [1] - 2795:28

governing [1] - hardship [1] - 2840:36 hold [1] - 2884:31

2888:32 head [2] - 2855:40, holistically [1] -

government [1] - 2879:42 2870:36

2841:3 health [2] - 2793:16, Hon [1] - 2785:32

Grant [2] - 2799:26, 2883:19 honesty [1] - 2860:32

.13/10/2017 (25) 11


inform [1] - 2878:32 2819:24, 2821:25,

2821:30, 2822:9,

2822:26, 2822:44,

2823:7, 2824:6,

2824:14, 2828:26,

2828:34, 2828:40,

2828:44, 2829:5,

2829:9, 2829:16,

2829:21, 2829:34,

2829:39, 2830:4,

2830:32, 2835:35,

2837:41, 2838:6,

2857:42, 2857:46,

2858:5, 2858:41,

2864:8, 2865:12,

2865:16, 2867:46,

2868:18, 2869:38,

2869:43, 2869:47,

2871:17, 2872:16,

2872:40, 2872:46,

2873:4, 2873:14,

2874:21, 2874:40,

2878:3, 2878:17,

2880:32, 2885:17,

2885:26, 2888:2,

2888:6, 2889:2,

2889:7, 2889:12,

2889:26, 2889:33

inquiries [4] -

2814:37, 2876:22,

2876:40, 2884:13

INQUIRY [2] -

2785:12, 2889:36

Inquiry [16] - 2786:25,

2805:23, 2809:17,

2813:40, 2825:47,

2826:9, 2833:22,

2837:43, 2841:19,

2863:43, 2868:42,

2872:24, 2879:30,

2886:2, 2886:33,

2888:7

insofar [2] - 2822:41,

2823:4

instance [16] -

2794:12, 2805:23,

2807:41, 2808:36,

2810:20, 2824:11,

2831:24, 2842:26,

2843:2, 2845:43,

2846:6, 2857:17,

2858:14, 2860:30,

2865:21, 2876:38

instances [1] -

2840:11

institution [1] -

2884:22

instructed [1] -

2883:39

instruction [1] -

2833:5

intend [2] - 2845:41,

2845:42

intended [5] -

2799:16, 2806:30,

2807:12, 2808:9,

2808:12

intending [3] -

2791:36, 2825:32,

2846:7

intent [2] - 2888:29,

2888:31

intention [3] -

2838:32, 2838:38,

2880:4

interact [1] - 2854:18

interaction [2] -

2809:40, 2809:42

interactions [1] -

2809:44

interacts [1] - 2854:19

interest [6] - 2864:20,

2864:24, 2864:30,

2864:42, 2864:46,

2887:40

interests [3] -

2864:45, 2865:2,

2865:5

interim [3] - 2832:39,

2832:40, 2863:9

internal [1] - 2845:31

internally [2] - 2861:5,

2871:24

interrupt [2] -

2872:47, 2874:34

interstate [2] - 2823:1,

2823:3

introduce [1] -

2862:16

introduced [3] -

2862:32, 2863:14,

2863:17

invaluable [1] -

2839:13

investigate [2] -

2834:15, 2881:15

investigated [2] -

2843:12, 2843:17

investigating [1] -

2849:19

invited [2] - 2832:8,

2882:10

invites [1] - 2807:5

invoices [1] - 2862:9

involved [26] -

2788:24, 2794:34,

2794:40, 2794:44,

2795:8, 2795:15,

2796:32, 2797:8,

2797:12, 2797:26,

2810:27, 2820:23,

2826:14, 2828:22,

2830:12, 2831:24,

2844:39, 2846:11,

2849:2, 2849:26,

2849:29, 2849:31,

2849:35, 2853:29,

2856:8, 2882:34

involvement [8] -

2790:20, 2798:23,

2827:7, 2828:2,

2830:29, 2834:41,

2843:41, 2862:3

irrespective [1] -

2819:27

isolation [1] - 2870:25

issue [32] - 2792:2,

2793:11, 2793:44,

2794:22, 2794:23,

2799:26, 2800:28,

2801:31, 2802:2,

2802:6, 2807:8,

2809:21, 2810:10,

2810:15, 2811:17,

2816:39, 2818:22,

2820:47, 2826:12,

2839:26, 2843:13,

2850:19, 2857:21,

2870:33, 2874:30,

2874:47, 2878:38,

2881:13, 2883:8,

2883:11

issued [3] - 2816:34,

2819:4, 2820:17

issues [65] - 2792:45,

2793:2, 2793:17,

2793:30, 2794:12,

2794:17, 2797:9,

2797:12, 2797:22,

2801:35, 2803:29,

2804:8, 2805:19,

2805:24, 2805:29,

2809:17, 2809:24,

2816:6, 2816:14,

2816:18, 2816:19,

2816:21, 2816:30,

2817:7, 2819:28,

2831:11, 2834:18,

2834:20, 2834:36,

2834:40, 2835:6,

2836:24, 2836:26,

2836:31, 2836:34,

2836:35, 2836:47,

2837:3, 2837:4,

2837:6, 2837:7,

2837:22, 2849:6,

2850:29, 2857:7,

2861:14, 2863:32,

2872:27, 2876:10,

2877:8, 2877:15,

2877:17, 2877:25,

informal [1] - 2815:47 2877:30, 2878:10,

informally [2] - 2878:25, 2878:34,

2880:40, 2880:42 2886:34, 2886:35,

information [22] - 2886:46, 2887:4,

2796:4, 2804:19, 2887:14, 2887:19

2804:22, 2804:23, issuing [4] - 2816:22,

2804:40, 2808:11, 2816:33, 2818:45,

2817:12, 2831:26, 2819:2

2833:14, 2838:30, IT [1] - 2795:45

2845:20, 2852:20, item [1] - 2860:27

2865:4, 2872:26, items [5] - 2856:42,

2876:19, 2876:21, 2859:47, 2860:2,

2876:33, 2876:39, 2860:15, 2862:9

2878:1, 2880:12, itself [7] - 2813:18,

2880:21 2840:5, 2841:34,

informed [4] - 2842:41, 2871:44,

2837:37, 2837:39, 2876:22, 2886:43

2873:7, 2880:22

J informing [1] -

2878:25

January [7] - 2795:29,

2836:29, 2847:6,

2882:6, 2882:17,

2882:18, 2885:2

Jeff [2] - 2864:47,

2865:3

Jennifer [1] - 2785:37

jigsaw [1] - 2853:39

John [3] - 2880:40,

2881:40, 2882:10

joined [2] - 2843:9,

2849:2

journey [2] - 2856:20,

2886:10

judgment [1] -

2888:40

July [17] - 2801:22,

2837:21, 2837:23,

2837:26, 2847:29,

2865:7, 2865:13,

2865:38, 2866:5,

2866:44, 2867:3,

2867:4, 2867:20,

2867:27, 2867:30,

2872:43, 2873:28

June [10] - 2799:33,

2799:41, 2800:11,

2801:21, 2801:22,

2801:29, 2847:28,

2855:42, 2855:44,

2885:6

inherent [1] - 2874:4

initial [2] - 2827:25,

2832:46

initiated [1] - 2841:5

injured [1] - 2884:31

Inn [9] - 2808:27,

2808:34, 2808:37,

2808:40, 2809:8,

2809:16, 2809:26,

2843:30, 2859:42

Inn's [1] - 2859:44

Innovation [2] -

2785:3, 2785:5

input [3] - 2838:44,

2842:45, 2849:23

Inquirer [11] -

2785:31, 2786:3,

2786:9, 2786:45,

2857:44, 2859:12,

2880:30, 2885:32,

2887:47, 2888:20,

2889:29

INQUIRER [88] -

2786:1, 2786:6,

2786:13, 2786:18,

2786:42, 2787:40,

2794:25, 2797:16,

2799:44, 2800:8,

2802:43, 2805:45,

2806:10, 2806:33,

2806:47, 2810:40,

2811:47, 2812:5,

2812:10, 2812:15,

K 2812:20, 2812:30,

2812:34, 2812:41,

2812:47, 2813:10,

2813:20, 2813:24,

2813:29, 2814:5,

2818:10, 2819:2,

keen [1] - 2803:43

keep [4] - 2798:45,

2816:40, 2841:35,

2852:6

.13/10/2017 (25) 12


keeping [1] - 2816:6 2814:10, 2817:41, 2867:35, 2872:43

level [4] - 2786:29,

2790:5, 2850:27,

2862:24

Level [1] - 2785:20

levels [1] - 2862:30

liaison [1] - 2818:42

licence [3] - 2823:42,

2842:5, 2884:25

licences [5] - 2821:47,

2822:29, 2822:31,

2822:40, 2823:2

licensing [1] -

2821:41

LifeCare [7] - 2803:31,

2807:31, 2807:42,

2844:12, 2844:16,

2844:24, 2846:6

LifeCare's [1] -

2844:29

light [1] - 2802:6

likely [4] - 2855:27,

2871:29, 2876:9,

2887:43

likewise [2] - 2791:8,

2814:25

limit [5] - 2858:20,

2860:8, 2860:10,

2860:12

Limitations [2] -

2873:45, 2873:46

limitations [6] -

2866:21, 2866:32,

2866:33, 2866:35,

2867:10, 2874:5

Limited [3] - 2839:46,

2884:41, 2885:1

limited [11] - 2789:17,

2789:31, 2791:23,

2794:11, 2798:38,

2801:37, 2802:6,

2803:25, 2809:46,

2832:31, 2856:12

limits [1] - 2860:27

line [1] - 2803:8

lines [4] - 2803:18,

2803:39, 2805:28,

2805:36

list [1] - 2860:18

listening [1] - 2812:18

lists [1] - 2838:13

literally [1] - 2839:18

living [1] - 2809:25

look [18] - 2807:21,

2810:31, 2836:4,

2838:19, 2846:11,

2856:40, 2856:44,

2868:18, 2868:19,

2876:3, 2880:38,

2881:44, 2882:9,

2884:12, 2886:12,

2886:13, 2887:19,

2888:36

looked [9] - 2808:18,

2809:17, 2811:43,

2812:25, 2820:10,

2833:29, 2856:3,

2876:44, 2887:13

looking [27] - 2795:3,

2811:29, 2816:13,

2824:47, 2825:21,

2828:9, 2835:20,

2838:39, 2838:42,

2850:18, 2855:38,

2856:33, 2856:34,

2857:22, 2863:43,

2865:47, 2870:33,

2870:34, 2870:35,

2871:33, 2874:17,

2874:19, 2875:41,

2886:23, 2886:24,

2886:40, 2886:45

lost [1] - 2867:22

love [1] - 2839:20

lower [1] - 2855:34

LPI [1] - 2785:20

lunch [4] - 2860:37,

2860:43, 2870:19,

2871:26

LUNCHEON [1] -

2858:3

Luong [17] - 2815:10,

2815:13, 2815:16,

2815:27, 2815:46,

2816:4, 2816:7,

2816:38, 2817:7,

2817:37, 2819:9,

2822:23, 2826:16,

2826:27, 2826:31,

2830:13, 2846:21

Luong's [2] - 2815:23,

2846:24

2854:21, 2854:24,

Kells [1] - 2889:31 2821:3, 2821:9, 2854:30, 2854:31,

kept [2] - 2811:34, 2825:45, 2828:4, 2855:32, 2856:3,

2811:42 2839:38, 2841:20, 2856:21, 2861:46,

key [4] - 2876:19, 2843:44, 2844:23, 2862:17, 2862:45,

2876:33, 2876:36 2845:46, 2847:25, 2871:47

knowledge [9] - 2854:10, 2871:27, manager [27] -

2805:4, 2813:3, 2878:14, 2878:44, 2790:37, 2791:46,

2818:12, 2818:13, 2888:25 2792:4, 2792:5,

2827:46, 2836:37, leave [12] - 2786:13, 2792:10, 2792:14,

2878:41, 2879:15, 2794:28, 2797:45, 2796:3, 2796:6,

2879:17 2812:25, 2816:7, 2796:19, 2796:21,

known [4] - 2788:19, 2828:27, 2835:44, 2796:25, 2797:14,

2788:20, 2788:26, 2844:19, 2844:21, 2797:19, 2797:28,

2874:6 2872:16, 2880:33, 2797:36, 2798:11,

Kolomeitz [9] - 2885:26 2815:3, 2815:7,

2796:45, 2797:4, leaving [1] - 2872:47 2826:46, 2846:32,

2848:34, 2848:35, led [2] - 2834:18, 2846:42, 2847:27,

2848:42, 2849:5, 2875:1 2847:43, 2847:46,

2883:7, 2884:7, ledger [2] - 2865:21, 2847:47

2884:11 2866:26 Manager [18] -

Kolomeitz's [1] - left [6] - 2795:43, 2786:32, 2787:6,

2884:9 2814:38, 2840:32, 2787:10, 2787:14, 2844:19, 2844:21, 2789:40, 2792:15,

L 2883:5 2792:21, 2792:29,

legal [25] - 2803:4, 2795:26, 2795:39,

L-U-O-N-G [1] -

2815:14

lack [2] - 2793:15,

2811:28

lady [1] - 2799:45

2803:5, 2803:7,

2803:34, 2803:45,

2804:23, 2836:28,

2839:22, 2839:44,

2842:36, 2842:39,

2842:40, 2849:41,

2795:40, 2796:11,

2804:33, 2804:35,

2805:3, 2844:43,

2850:4, 2888:18

manager's [1] -

2797:36

larger [1] - 2794:32 2857:1, 2857:2, managing [1] -

last [16] - 2833:30, 2871:31, 2883:12, 2817:18

2837:10, 2837:19, 2884:5, 2884:6, manual [3] - 2862:18,

2837:22, 2841:9, 2884:8, 2884:23, 2862:32, 2863:9

2842:25, 2846:12, 2884:24, 2884:26, mapping [1] - 2867:2

2853:39, 2853:42, 2884:40, 2884:46 March [19] - 2798:29,

2855:19, 2855:20, legally [1] - 2823:43 2801:26, 2853:47,

2864:36, 2864:37,

2864:38, 2865:30,

2870:7

legislation [7] -

2812:25, 2856:27,

2856:38, 2856:41,

2854:10, 2854:32,

2854:37, 2854:40,

2854:43, 2854:44,

late [4] - 2795:38, 2868:16, 2870:26, 2854:46, 2855:1,

M 2878:17, 2878:19, 2871:33 2855:30, 2855:42,

2887:1 length [1] - 2884:32 2871:27, 2871:29,

Madam [9] - 2786:3,

2786:45, 2857:44,

2859:12, 2880:30,

2885:32, 2887:47,

2888:20, 2889:29

madam [1] - 2786:9

managed [4] -

2815:46, 2816:4,

2817:13, 2842:37

management [22] -

2787:44, 2796:41,

2804:39, 2817:16,

2818:21, 2853:16,

2853:19, 2853:23,

2853:36, 2853:41,

lawful [2] - 2856:42,

2856:47 letter [27] - 2819:13,

2819:14, 2820:19,

2883:21, 2883:32,

2888:25, 2888:39

lawyer [1] - 2882:18 2838:16, 2838:22, March/April [1] -

leading [2] - 2854:43, 2845:17, 2865:12, 2799:23

2854:45 2865:20, 2865:28, marketing [8] -

leads [1] - 2804:3 2865:31, 2865:33, 2815:3, 2815:6,

learning [3] - 2787:26, 2865:34, 2865:37, 2846:22, 2846:24,

2787:37, 2841:15 2866:5, 2866:37, 2846:25, 2846:34,

learnings [1] - 2866:43, 2867:15, 2846:35, 2846:42

2856:19 2867:20, 2867:30, match [1] - 2877:18

least [26] - 2787:24, 2867:38, 2868:2, material [3] - 2837:42,

2788:4, 2788:5, 2868:29, 2868:36, 2868:40, 2869:19

2795:25, 2802:16, 2869:2, 2873:28, matrix [18] - 2858:20,

2802:40, 2803:38, 2877:46, 2880:6 2858:23, 2858:25,

2805:35, 2811:1, letters [3] - 2867:24, 2858:28, 2858:33,

.13/10/2017 (25) 13


2858:35, 2858:44, 2800:44, 2801:4, 2868:23

might [11] - 2800:44,

2812:21, 2832:22,

2834:20, 2847:29,

2851:20, 2864:33,

2880:33, 2884:38,

2887:9

mind [6] - 2810:18,

2811:16, 2816:30,

2840:29, 2847:34,

2879:46

Minister [2] - 2888:11

minute [2] - 2812:13,

2862:17

minutes [2] - 2833:46,

2882:38

misleading [1] -

2825:14

mistaken [2] -

2799:35, 2799:38

mistakes [1] - 2888:32

misunderstanding [1]

- 2812:24

misunderstood [1] -

2814:38

mixed [1] - 2806:33

model [14] - 2839:24,

2840:9, 2840:42,

2841:11, 2841:22,

2841:25, 2842:31,

2843:4, 2843:24,

2843:27, 2843:44,

2843:47, 2844:6,

2844:33

modifiable [1] -

2853:23

modifications [2] -

2849:38, 2850:33

moment [20] -

2799:18, 2802:33,

2803:14, 2807:5,

2812:23, 2813:2,

2813:12, 2825:10,

2829:7, 2839:18,

2845:19, 2847:39,

2851:45, 2860:2,

2861:21, 2861:31,

2861:37, 2872:47,

2885:15, 2888:16

money [17] - 2799:15,

2817:8, 2817:21,

2817:33, 2820:6,

2820:8, 2820:13,

2820:15, 2820:21,

2820:26, 2820:34,

2834:45, 2835:9,

2835:24, 2835:28,

2835:29, 2835:39

moneys [5] - 2807:12,

2807:14, 2807:16,

2852:26, 2865:29 2878:24, 2880:29,

2859:7, 2859:8, 2801:21, 2801:29, month [6] - 2799:22, 2885:20, 2885:28,

2859:31, 2861:26, 2830:39, 2834:13, 2830:41, 2831:9, 2885:30, 2887:47,

2863:15, 2863:16, 2855:19, 2858:41, 2837:20, 2861:6, 2888:4, 2889:5,

2863:20, 2863:23, 2859:10, 2859:19, 2864:37 2889:16, 2889:18,

2863:25, 2863:29 2863:39, 2864:28, monthly [3] - 2798:2, 2889:24, 2889:29

matter [24] - 2786:34, 2864:32, 2881:14, 2798:15, 2830:39 MS [1] - 2787:2

2794:2, 2801:15, 2881:27, 2881:39, months [7] - 2857:3, Mulliner [24] -

2808:18, 2812:22, 2882:30, 2883:9, 2859:34, 2864:38, 2790:25, 2794:27,

2817:42, 2818:22, 2883:21, 2883:22, 2882:37, 2883:31, 2794:37, 2797:42,

2819:32, 2820:30, 2883:23, 2884:17, 2885:5 2797:45, 2798:6,

2821:10, 2828:35, 2884:27, 2884:38, morning [1] - 2830:16 2799:37, 2815:31,

2829:34, 2830:41, 2884:39, 2885:6 most [4] - 2803:2, 2815:33, 2815:40,

2839:29, 2839:32, meetings [6] - 2796:4, 2816:15, 2819:8, 2817:33, 2817:34,

2841:47, 2844:39, 2801:8, 2801:11, 2889:21 2817:38, 2817:43,

2857:22, 2860:22, 2830:43, 2846:44, move [10] - 2801:16, 2818:4, 2818:11,

2868:4, 2868:6, 2887:38 2839:6, 2844:24, 2818:17, 2820:11,

2872:8, 2883:27, meets [2] - 2845:32, 2853:15, 2853:17, 2822:31, 2827:26,

2887:30 2869:32 2853:27, 2855:14, 2830:14, 2835:43,

matters [21] - 2787:20, member [5] - 2798:28, 2855:20, 2888:29 2883:10, 2883:12

2796:37, 2797:8, 2820:7, 2863:21, moved [2] - 2844:15, Mulliner's [1] - 2796:2

2802:40, 2804:32, 2864:13, 2884:46 2850:43 must [1] - 2799:17

2804:34, 2808:4, members [7] - movement [1] -

N 2816:7, 2816:19, 2788:27, 2798:42, 2853:32

2816:32, 2818:26,

2831:13, 2831:17,

2831:22, 2839:22,

2849:37, 2878:44,

2879:26, 2886:27,

2887:36, 2887:40

meal [1] - 2860:31

mean [16] - 2787:23,

2843:15, 2863:22,

2884:30, 2886:14

membership [1] -

2853:22

memory [2] - 2806:44,

2847:20

mental [1] - 2793:16

mention [2] - 2825:3,

moves [1] - 2887:25

MR [81] - 2786:3,

2786:9, 2786:16,

2786:22, 2786:24,

2786:45, 2787:5,

2787:42, 2794:27,

2797:18, 2800:11,

2802:47, 2806:12,

Nair [22] - 2847:47,

2848:4, 2848:10,

2848:24, 2849:9,

2849:22, 2849:26,

2849:43, 2850:18,

2850:29, 2852:29,

2855:46, 2856:3,

2856:8, 2856:34,

2861:43, 2862:15,

2863:5, 2865:12,

2884:10, 2884:12,

2884:13

Nair's [1] - 2849:5

name [12] - 2786:10,

2786:25, 2788:22,

2806:35, 2815:23,

2827:45, 2854:26,

2854:27, 2859:44,

2862:27, 2862:30,

2864:12

named [1] - 2885:43

names [1] - 2887:29

naming [1] - 2887:29

narrative [2] -

2867:30, 2867:31

national [1] - 2788:41

National [3] - 2788:43,

2795:28, 2795:33

nationally [1] -

2824:42

nature [1] - 2888:6

Navision [38] -

2850:13, 2850:44,

2850:45, 2851:4,

2851:11, 2852:13,

2787:30, 2790:8, 2825:4 2806:37, 2807:8,

2798:1, 2798:34, mentioned [9] - 2810:47, 2812:3,

2806:27, 2820:22, 2798:15, 2820:21, 2812:8, 2812:13,

2821:46, 2823:43, 2823:29, 2824:46, 2812:17, 2812:28,

2825:30, 2828:12, 2825:1, 2825:13, 2812:36, 2812:45,

2833:9, 2834:26, 2826:16, 2829:31, 2813:8, 2813:17,

2851:6, 2852:16, 2881:39 2813:22, 2813:27,

2866:32 messages [1] - 2814:7, 2818:17,

means [1] - 2824:44 2806:33 2819:27, 2821:33,

meant [4] - 2794:40, met [8] - 2799:10, 2822:28, 2823:9,

2795:25, 2849:2, 2799:33, 2799:41, 2824:8, 2824:16,

2853:22 2814:44, 2816:12, 2828:24, 2828:38,

measure [2] - 2838:14, 2868:15, 2828:42, 2829:1,

2863:10, 2888:23 2883:31 2829:7, 2829:11,

measured [1] - Microsoft [10] - 2829:18, 2829:30,

2888:41 2850:13, 2850:45, 2829:36, 2830:2,

media [2] - 2810:11, 2851:4, 2853:18, 2830:9, 2830:37,

2810:12 2854:3, 2854:4, 2835:38, 2838:8,

medical [1] - 2832:43 2854:14, 2854:15, 2857:44, 2858:8,

meet [6] - 2839:20, 2854:26, 2854:27 2858:43, 2859:1,

2840:27, 2840:35, mid [1] - 2887:1 2864:11, 2865:18,

2853:23, 2856:18, mid-2014 [2] - 2868:1, 2869:40,

2881:17 2826:42, 2883:2 2869:45, 2870:4,

meeting [34] - mid-September [1] - 2871:21, 2872:42,

2799:31, 2799:35, 2887:1 2873:2, 2873:16,

2799:37, 2799:40, middle [6] - 2791:32, 2874:26, 2874:34,

2799:45, 2800:11, 2794:33, 2794:47, 2874:38, 2874:42,

2800:41, 2800:43, 2795:7, 2846:12, 2874:44, 2878:5,

.13/10/2017 (25) 14


2852:14, 2852:16, 2853:23, 2853:28, 2876:20, 2876:46,

2877:1, 2877:2,

2877:4, 2877:8,

2877:11, 2878:15,

2878:20, 2878:46,

2879:31, 2879:39

non-compliance [17] -

2834:36, 2836:25,

2836:27, 2845:44,

2875:22, 2876:20,

2876:46, 2877:1,

2877:2, 2877:4,

2877:8, 2877:11,

2878:15, 2878:20,

2878:46, 2879:31,

2879:39

non-financial [1] -

2815:45

non-members [2] -

2843:15

none [2] - 2817:4,

2861:27

normally [3] -

2824:41, 2860:43,

2875:21

Northcote [2] -

2852:29

not-for-profit [2] -

2886:6, 2886:7

note [3] - 2813:12,

2813:24, 2825:44

Note [1] - 2785:2

noted [1] - 2813:36

notes [2] - 2826:1,

2826:8

nothing [13] -

2799:18, 2802:24,

2802:40, 2810:17,

2813:4, 2844:47,

2868:45, 2871:9,

2871:18, 2871:23,

2882:38, 2883:19

notice [1] - 2826:7

notified [3] - 2878:10,

2879:15, 2879:26

notify [3] - 2845:43,

2878:38, 2879:12

notifying [2] -

2828:46, 2879:38

noting [1] - 2813:41

November [8] -

2809:18, 2809:29,

2815:7, 2832:37,

2839:43, 2863:44,

2881:28, 2887:2

November/

December [1] -

2884:18

NSW [140] - 2787:11,

2787:15, 2787:24,

2787:26, 2787:33,

2791:33, 2796:7,

2796:25, 2798:11,

2798:20, 2803:31,

2804:10, 2808:41,

2809:34, 2810:15,

2817:10, 2817:17,

2817:23, 2818:18,

2819:29, 2820:30,

2821:23, 2827:3,

2827:17, 2827:44,

2830:21, 2830:25,

2830:29, 2830:33,

2835:22, 2835:25,

2836:9, 2839:1,

2842:20, 2842:28,

2842:33, 2842:42,

2843:3, 2843:12,

2843:14, 2843:22,

2843:28, 2843:30,

2843:40, 2843:45,

2844:32, 2844:36,

2844:43, 2846:43,

2847:12, 2848:1,

2848:7, 2848:47,

2849:10, 2849:14,

2849:18, 2849:38,

2850:11, 2850:36,

2851:28, 2851:30,

2852:45, 2853:3,

2855:10, 2855:15,

2855:20, 2855:32,

2857:18, 2857:28,

2857:29, 2857:36,

2858:10, 2858:19,

2858:29, 2861:14,

2861:19, 2861:27,

2861:31, 2861:32,

2861:39, 2862:5,

2862:8, 2862:36,

2862:40, 2863:7,

2863:22, 2863:28,

2863:46, 2864:31,

2864:42, 2865:4,

2865:8, 2873:16,

2873:19, 2874:14,

2874:19, 2874:23,

2875:6, 2875:12,

2875:19, 2875:22,

2875:26, 2875:31,

2875:35, 2875:40,

2875:41, 2875:44,

2876:1, 2876:2,

2876:5, 2876:13,

2876:40, 2877:2,

2877:21, 2877:31,

2879:30, 2879:34,

2879:40, 2879:41,

2879:46, 2880:26,

2884:44, 2884:45,

2885:23, 2885:31,

2885:35, 2885:39,

2852:23, 2852:25, 2856:26, 2863:38, 2885:46, 2886:5,

2852:30, 2852:36, 2870:20, 2878:1 2886:11, 2886:15,

2854:19, 2854:21, negotiations [1] - 2886:23, 2886:29,

2855:21, 2855:23, 2889:13 2886:39, 2887:5,

2855:43, 2855:47, net [2] - 2835:24, 2887:21, 2887:25,

2856:11, 2856:37, 2835:30 2888:28

2861:24, 2861:47, never [8] - 2801:30, NSW) [10] - 2786:32,

2862:37, 2863:6, 2815:39, 2817:32, 2795:46, 2797:40,

2868:13, 2868:32, 2818:7, 2818:10, 2817:14, 2843:25,

2869:31, 2870:13, 2827:4, 2882:34, 2848:33, 2872:42,

2870:16, 2870:21, 2883:44 2873:36, 2885:21,

2870:22, 2872:2, New [16] - 2785:23, 2885:44

2872:18, 2875:36, 2821:38, 2823:10, NSW)'s [2] - 2853:21,

2875:40, 2876:3, 2823:13, 2823:31, 2855:37

2888:37 2824:4, 2824:22, number [27] -

NAVISION [1] - 2824:27, 2824:35, 2790:41, 2796:44,

2850:47 2824:45, 2825:1, 2798:35, 2798:39,

nearly [1] - 2880:10 2825:22, 2825:29, 2815:33, 2816:26,

necessarily [10] - 2825:33, 2845:40, 2834:7, 2836:15,

2804:20, 2816:21, 2850:26 2838:39, 2838:42,

2838:35, 2839:22, new [28] - 2803:4, 2838:47, 2839:19,

2841:24, 2841:30, 2803:5, 2803:7, 2840:14, 2840:23,

2842:6, 2842:11, 2803:17, 2831:14, 2841:4, 2841:12,

2843:29, 2872:4 2839:44, 2845:30, 2843:36, 2846:41,

necessary [1] - 2845:34, 2848:23, 2856:43, 2857:7,

2805:16 2852:40, 2852:42, 2858:9, 2877:22,

need [34] - 2804:19, 2853:6, 2854:24, 2877:23, 2884:13,

2806:40, 2807:4, 2856:3, 2873:5, 2885:22, 2885:43,

2815:12, 2821:10, 2875:17, 2875:24, 2886:8

2821:47, 2838:14, 2884:21, 2884:23, numbering [1] -

2840:25, 2841:27, 2884:24, 2884:40, 2816:33

2841:30, 2841:35, 2884:46, 2886:15, numbers [1] - 2865:46

2841:37, 2841:40, 2886:16, 2888:31 numerous [1] -

2842:3, 2843:29, next [30] - 2787:40, 2846:40

2847:34, 2851:20, 2794:25, 2853:47, NWBI [1] - 2869:32

2851:42, 2854:34, 2854:10, 2854:32,

O 2856:21, 2856:33, 2854:37, 2854:40,

2856:40, 2858:30, 2854:43, 2854:44,

O'Brien [2] - 2864:47,

2865:3

o'clock [1] - 2857:42

oath [1] - 2829:42

object [2] - 2812:11,

2813:37

objection [7] -

2812:37, 2813:1,

2813:12, 2813:15,

2813:24, 2813:41,

2864:9

objections [1] -

2813:41

objects [20] - 2801:36,

2802:7, 2802:8,

2802:17, 2802:31,

2803:3, 2803:5,

2803:7, 2803:8,

2803:25, 2828:38,

2829:23, 2832:30,

2832:36, 2839:26,

2858:45, 2871:47, 2854:46, 2855:1,

2872:1, 2872:4, 2855:30, 2855:42,

2875:7, 2876:2, 2855:44, 2859:10,

2876:24, 2876:38, 2859:19, 2863:12,

2877:23, 2877:32, 2863:39, 2864:27,

2884:31 2877:4, 2879:44,

needed [24] - 2793:40, 2879:45, 2880:8,

2794:36, 2799:7, 2881:25, 2882:4,

2800:26, 2803:8, 2883:4, 2884:3,

2811:26, 2811:43, 2889:22, 2889:29

2815:45, 2816:30, nine [1] - 2857:3

2816:39, 2816:40, no" [1] - 2842:12

2818:15, 2825:5, no-one [1] - 2840:32

2830:40, 2831:2, nominated [1] -

2831:13, 2836:27, 2820:14

2848:44, 2852:21, nomination [1] -

2882:44, 2886:15, 2873:6

2886:42, 2887:39 non [20] - 2815:45,

needs [11] - 2804:4, 2834:36, 2836:25,

2822:42, 2841:38, 2836:27, 2843:15,

2842:36, 2842:42, 2845:44, 2875:22,

.13/10/2017 (25) 15


2839:37, 2841:38, 2848:27, 2849:32,

2849:46

often [5] - 2819:10,

2830:44, 2830:47,

2831:8, 2842:7

old [1] - 2855:11

omitted [1] - 2885:47

once [5] - 2818:46,

2875:21, 2875:40,

2887:4

one [73] - 2788:5,

2788:33, 2789:7,

2789:8, 2790:9,

2791:14, 2793:3,

2793:36, 2797:1,

2798:36, 2798:42,

2799:9, 2799:40,

2801:20, 2801:22,

2801:35, 2803:29,

2803:43, 2804:2,

2804:8, 2805:29,

2807:15, 2809:17,

2809:24, 2809:35,

2811:32, 2812:13,

2817:11, 2819:18,

2820:9, 2830:18,

2833:12, 2833:29,

2834:5, 2834:15,

2834:16, 2834:19,

2834:40, 2835:6,

2837:22, 2838:40,

2840:13, 2840:32,

2840:41, 2840:43,

2840:44, 2841:21,

2841:35, 2842:3,

2842:14, 2843:1,

2843:10, 2844:3,

2844:23, 2847:36,

2848:18, 2849:29,

2849:37, 2850:25,

2856:26, 2860:41,

2861:12, 2862:31,

2863:19, 2863:32,

2867:27, 2873:4,

2886:8, 2886:22,

2886:27, 2887:24,

2887:34, 2888:39

one-page [1] -

2860:41

one-year [1] - 2848:18

ones [1] - 2825:42

ongoing [1] - 2857:9

online [4] - 2816:45,

2820:17, 2851:4,

2851:6

onwards [1] - 2811:1

operate [2] - 2832:45

operated [5] -

2834:14, 2834:25,

2834:29, 2850:22,

2852:36 2849:3 2880:45

paragraph [13] -

2806:39, 2807:21,

2807:30, 2838:19,

2845:25, 2869:41,

2870:2, 2870:4,

2870:8, 2873:31,

2874:2, 2881:33,

2881:45

pardon [5] - 2824:16,

2867:46, 2868:1,

2869:45, 2872:46

Park [10] - 2808:27,

2808:34, 2808:37,

2808:40, 2809:8,

2809:16, 2809:26,

2843:30, 2859:42,

2859:44

part [32] - 2788:13,

2788:18, 2788:43,

2794:44, 2799:21,

2805:35, 2808:40,

2821:22, 2824:19,

2832:16, 2833:5,

2833:43, 2836:4,

2836:6, 2841:8,

2842:24, 2842:39,

2842:40, 2843:6,

2843:25, 2844:10,

2844:20, 2847:11,

2849:22, 2853:19,

2854:15, 2883:22,

2884:18, 2884:45,

2886:12, 2887:12

participate [1] -

2788:28

particular [17] -

2789:7, 2800:28,

2800:41, 2804:21,

2806:30, 2817:29,

2844:6, 2845:13,

2858:25, 2859:47,

2861:13, 2861:14,

2868:4, 2868:6,

2884:28, 2886:31,

2887:6

particularly [3] -

2800:6, 2858:15,

2862:11

partly [3] - 2787:24,

2787:36, 2787:37

parts [2] - 2788:5,

2789:7

Pass [1] - 2793:36

passed [4] - 2799:8,

2799:9, 2835:39,

2885:2

past [1] - 2857:2

pause [1] - 2822:22

pay [1] - 2840:33

2849:40, 2884:23, operates [1] - 2846:17 originally [5] -

2884:34 operating [6] - 2853:20, 2863:4,

obligation [2] - 2812:43, 2835:17, 2863:5, 2882:23,

2811:39, 2814:43 2848:27, 2849:32, 2882:27

obligations [7] - 2849:46, 2875:20 ought [5] - 2817:43,

2814:27, 2814:36, operation [3] - 2818:3, 2819:29,

2814:38, 2814:40, 2815:44, 2855:27, 2836:35, 2880:22

2814:41, 2815:1, 2888:37 ourselves [1] -

2832:20 Operational [3] - 2880:46

observations [2] - 2833:35, 2833:39, outline [2] - 2802:29,

2866:25, 2867:14 2834:13 2867:9

obtain [2] - 2849:20, operational [4] - outscored [1] -

2881:32 2834:2, 2836:14, 2818:22

obtained [1] - 2857:16 2837:11, 2837:13 outside [10] - 2794:2,

obviously [4] - operations [2] - 2794:6, 2795:35,

2813:17, 2829:3, 2841:12, 2848:1 2801:10, 2814:41,

2829:30, 2842:46 opinion [2] - 2871:39, 2818:47, 2823:13,

occasion [2] - 2875:9 2829:23, 2830:44,

2815:34, 2816:22 opportunity [2] - 2870:22

occasional [2] - 2849:4, 2875:41 outsource [3] -

2819:18, 2830:43 option [4] - 2803:11, 2804:21, 2804:25,

occasionally [3] - 2803:13, 2839:10, 2805:24

2817:28, 2819:4, 2843:22 outsourced [3] -

2831:19 options [7] - 2838:40, 2795:46, 2819:28,

occasions [4] - 2838:42, 2838:43, 2830:25

2794:14, 2830:40, 2838:46, 2838:47, overall [2] - 2787:44,

2840:23 2839:3, 2840:13 2860:1

occupation [1] - orally [1] - 2801:31 overarching [1] -

2786:31 order [3] - 2811:42, 2857:6

occur [2] - 2832:7, 2870:19, 2874:30 oversight [2] -

2832:11 ordinarily [1] - 2811:28, 2820:36

occurred [2] - 2860:47 overview [1] - 2848:46

2791:42, 2839:42 organisation [23] - own [9] - 2809:2,

occurring [3] - 2804:36, 2808:10, 2809:13, 2835:3,

2848:47, 2885:35, 2822:33, 2839:28, 2841:45, 2843:37,

2885:40 2841:2, 2841:17, 2851:46, 2855:23,

October [12] - 2843:10, 2844:11, 2855:25, 2872:18

2785:27, 2786:35, 2848:46, 2849:2,

P 2816:43, 2845:35, 2852:22, 2852:24,

2849:36, 2858:39, 2852:26, 2862:6,

page [15] - 2860:41,

2865:36, 2865:41,

2865:43, 2866:2,

2866:18, 2866:21,

2866:37, 2866:38,

2868:20, 2873:27,

2881:27, 2881:44,

2883:21

pages [2] - 2865:44,

2873:45

paid [6] - 2808:26,

2808:37, 2809:8,

2820:29, 2835:9,

2835:32

paint [1] - 2878:28

Palmer [3] - 2826:46,

2827:14, 2827:17

paper [2] - 2806:34,

2859:19, 2863:42, 2863:14, 2880:18,

2869:3, 2884:15, 2886:4, 2886:7,

2887:1, 2887:45 2886:16, 2886:41,

OCTOBER [1] - 2886:42, 2886:43,

2889:37 2887:41

OF [1] - 2787:2 organisation's [2] -

offence [1] - 2813:39 2886:13, 2886:36

offer [2] - 2833:18, organisational [3] -

2840:14 2790:42, 2790:43,

Office [6] - 2853:18, 2791:28

2854:4, 2854:15, organisations [13] -

2854:28, 2880:13, 2805:29, 2824:3,

2880:14 2824:6, 2824:8,

office [2] - 2854:14, 2831:14, 2831:17,

2865:2 2849:47, 2886:8,

Officer [2] - 2830:21, 2886:9, 2886:14,

2830:33 2888:18, 2888:24,

officer [6] - 2841:7, 2888:38

2841:10, 2848:1, organising [1] -

.13/10/2017 (25) 16


payable [1] - 2856:25 2881:16, 2884:10 2815:35, 2829:36, 2876:20, 2878:32,

2880:16, 2886:39

potentially [5] -

2839:5, 2839:6,

2840:24, 2840:36,

2880:16

practice [3] - 2808:15,

2808:45, 2823:45

precisely [1] - 2856:32

predates [2] - 2791:5,

2791:9

preferable [1] -

2839:18

preliminary [1] -

2886:35

preparation [2] -

2825:47, 2836:28

prepare [1] - 2790:44

prepared [8] -

2786:34, 2790:41,

2791:19, 2797:31,

2798:40, 2799:38,

2826:9, 2858:9

preparing [2] -

2797:46, 2798:16

pres [1] - 2829:12

present [4] - 2799:33,

2819:16, 2845:1,

2866:47

presentation [1] -

2800:35

presently [1] -

2829:22

President [2] -

2858:15, 2858:34

presumably [4] -

2818:31, 2827:39,

2859:1, 2872:7

presume [3] -

2811:47, 2819:12,

2888:7

presumed [4] -

2798:5, 2817:27,

2835:16, 2866:34

prevent [1] - 2805:41

previous [6] -

2791:14, 2841:2,

2841:14, 2852:24,

2853:13, 2855:7

previously [3] -

2788:22, 2874:6,

2884:11

primarily [1] - 2853:17

Prince [1] - 2785:22

principle [2] -

2884:46, 2884:47

prioritised [1] -

2855:33

priority [1] - 2855:34

probability [2] -

2829:26, 2829:27

paying [1] - 2808:31 Perrin [17] - 2793:6, 2851:12, 2851:15, problem [8] - 2810:6,

payment [3] - 2793:11, 2827:26, 2851:16, 2870:34, 2812:30, 2813:12,

2820:12, 2820:13, 2830:17, 2830:28, 2874:18 2817:46, 2817:47,

2830:13 2830:42, 2830:43, points [1] - 2815:34 2839:38, 2873:8,

payments [1] - 2831:1, 2831:2, policies [11] - 2883:19

2807:30 2831:11, 2831:15, 2856:23, 2857:5, problems [7] -

payroll [17] - 2845:31, 2831:24, 2882:24, 2864:20, 2870:15, 2800:14, 2848:41,

2852:36, 2852:37, 2882:39, 2882:40, 2872:34, 2879:45, 2850:29, 2866:25,

2852:40, 2852:44, 2883:4 2880:5, 2880:10, 2875:19, 2877:36,

2852:45, 2853:2, Perrin's [1] - 2793:8 2880:12, 2880:15, 2880:34

2853:6, 2853:13, person [8] - 2815:16, 2887:38 procedures [18] -

2853:15, 2853:36, 2847:19, 2847:36, policy [6] - 2860:18, 2856:23, 2856:36,

2853:40, 2854:16, 2862:30, 2864:2, 2860:23, 2860:27, 2857:5, 2861:25,

2855:34, 2855:37, 2864:6, 2864:11, 2864:24, 2864:30, 2861:33, 2867:9,

2855:44, 2872:2 2881:18 2864:42 2868:32, 2869:31,

pecuniary [2] - personal [2] - poor [3] - 2804:20, 2870:15, 2872:34,

2865:1, 2865:5 2871:39, 2875:9 2852:20, 2853:24 2875:17, 2879:45,

peer [2] - 2840:18 personally [5] - Poppy [21] - 2795:12, 2880:5, 2880:10,

penalty [1] - 2813:39 2786:11, 2806:8, 2810:26, 2816:3, 2880:12, 2880:15,

pending [2] - 2862:16, 2821:1, 2863:21, 2823:29, 2823:34, 2887:38, 2888:30

2879:10 2880:8 2824:41, 2824:44, proceed [4] - 2836:22,

pension [1] - 2831:36 personnel [4] - 2825:2, 2825:8, 2837:1, 2842:34,

people [24] - 2793:13, 2788:14, 2831:39, 2825:18, 2825:22, 2845:13

2793:16, 2793:21, 2832:31, 2839:38 2825:32, 2826:23, proceedings [2] -

2793:39, 2802:8, perspective [2] - 2826:40, 2827:29, 2785:7, 2813:43

2802:36, 2803:22, 2808:19, 2857:4 2827:34, 2827:43, proceeds [3] - 2821:5,

2803:26, 2807:37, phenomenon [1] - 2828:3, 2828:14, 2835:24, 2835:30

2807:41, 2809:37, 2806:4 2828:18, 2834:45 process [16] -

2809:44, 2811:26, phone [1] - 2801:12 port [1] - 2830:47 2820:23, 2820:33,

2816:24, 2818:43, pick [1] - 2876:37 portion [1] - 2821:20 2829:32, 2830:12,

2819:8, 2831:19, picture [3] - 2800:2, position [18] - 2847:32, 2856:9,

2832:8, 2832:42, 2876:19, 2878:28 2787:14, 2787:18, 2856:32, 2861:31,

2842:2, 2842:7, piece [4] - 2806:34, 2793:8, 2802:11, 2862:8, 2862:18,

2863:23, 2872:9, 2853:39, 2853:42, 2802:47, 2803:2, 2863:8, 2869:13,

2886:28 2887:18 2805:12, 2838:9, 2875:21, 2883:46,

per [8] - 2793:23, pilot [1] - 2840:18 2844:42, 2845:19, 2884:32, 2886:12

2837:3, 2851:21, Pinkstone [1] - 2852:4, 2870:18, processes [4] -

2852:5, 2856:17, 2846:42 2874:26, 2874:29, 2848:47, 2856:45,

2860:6, 2871:46,

2872:3

perceive [1] - 2855:6

place [20] - 2806:21,

2808:7, 2845:31,

2855:2, 2856:45,

2875:16, 2876:17,

2888:17, 2889:20

positions [2] -

2875:24, 2875:42

produced [2] -

2790:43, 2790:44

perform [3] - 2865:25, 2858:19, 2861:18, 2791:37, 2847:33 production [1] -

2866:11, 2873:35 2861:37, 2861:39, possibilities [3] - 2807:4

performance [1] - 2864:42, 2868:14, 2844:2, 2844:3, professional [8] -

2888:41 2871:45, 2871:47, 2844:8 2786:28, 2840:9,

performed [3] - 2875:23, 2875:43, possibility [3] - 2840:10, 2840:12,

2788:22, 2796:1, 2881:5, 2888:27, 2839:4, 2842:32, 2844:11, 2844:12,

2867:10 2888:39, 2888:40, 2844:25 2887:20

performing [4] - 2888:42 possible [4] - professionals [3] -

2787:24, 2789:40, plan [2] - 2855:14, 2843:16, 2843:21, 2885:38, 2885:43,

2795:26, 2796:11 2855:40 2843:47 2887:6

perhaps [9] - 2790:47, planning [2] - possibly [8] - 2799:22, profit [2] - 2886:6,

2794:16, 2801:20, 2886:12, 2886:25 2810:16, 2840:37, 2886:7

2812:47, 2831:9, plans [1] - 2844:29 2844:17, 2857:3, profitable [1] -

2848:42, 2849:4, platform [5] - 2820:22, 2860:24, 2872:12, 2841:24

2857:42, 2880:33 2854:3, 2854:4, 2884:33 profits [5] - 2841:16,

period [2] - 2787:28, 2854:15, 2872:17 potential [9] - 2837:6, 2841:23, 2841:28,

2822:2 point [10] - 2797:23, 2841:19, 2844:10, 2841:31

permission [2] - 2797:26, 2810:32, 2849:38, 2866:33, program [2] - 2840:18,

.13/10/2017 (25) 17


2841:4 2853:29

provision [2] -

2829:23, 2829:44

psychological [1] -

2793:30

public [5] - 2785:16,

2819:16, 2820:7,

2833:10, 2884:22

Public [2] - 2785:31,

2786:25

PUBLIC [88] - 2786:1,

2786:6, 2786:13,

2786:18, 2786:42,

2787:40, 2794:25,

2797:16, 2799:44,

2800:8, 2802:43,

2805:45, 2806:10,

2806:33, 2806:47,

2810:40, 2811:47,

2812:5, 2812:10,

2812:15, 2812:20,

2812:30, 2812:34,

2812:41, 2812:47,

2813:10, 2813:20,

2813:24, 2813:29,

2814:5, 2818:10,

2819:2, 2819:24,

2821:25, 2821:30,

2822:9, 2822:26,

2822:44, 2823:7,

2824:6, 2824:14,

2828:26, 2828:34,

2828:40, 2828:44,

2829:5, 2829:9,

2829:16, 2829:21,

2829:34, 2829:39,

2830:4, 2830:32,

2835:35, 2837:41,

2838:6, 2857:42,

2857:46, 2858:5,

2858:41, 2864:8,

2865:12, 2865:16,

2867:46, 2868:18,

2869:38, 2869:43,

2869:47, 2871:17,

2872:16, 2872:40,

2872:46, 2873:4,

2873:14, 2874:21,

2874:40, 2878:3,

2878:17, 2880:32,

2885:17, 2885:26,

2888:2, 2888:6,

2889:2, 2889:7,

2889:12, 2889:26,

2889:33

pull [1] - 2876:32

purchased [1] -

2853:21

purpose [12] - 2785:6,

2799:16, 2800:12,

2801:4, 2841:29, R reasons [1] - 2843:10

programs [1] - 2841:41, 2841:42, recalled [1] - 2799:45

raise [11] - 2789:38,

2792:2, 2793:2,

2793:5, 2793:11,

2794:12, 2794:23,

2801:3, 2801:5,

2878:31, 2878:38

raised [19] - 2789:41,

2789:45, 2793:3,

2793:45, 2794:22,

2796:44, 2801:30,

2802:2, 2802:21,

2809:24, 2832:36,

2840:23, 2842:31,

2850:29, 2878:34,

2880:35, 2881:13,

2883:8, 2883:12

raising [4] - 2792:45,

2794:17, 2812:6,

2834:44

ran [3] - 2828:20,

2833:40, 2841:7

range [1] - 2788:13

rather [4] - 2791:23,

2801:37, 2816:19,

2842:27

re [1] - 2853:26

re-entering [1] -

2853:26

reached [1] - 2889:20

read [6] - 2806:40,

2826:1, 2826:8,

2881:25, 2882:38,

2888:7

reading [1] - 2866:31

real [1] - 2831:47

realised [2] - 2799:34,

2799:38

realistic [2] - 2840:41,

2840:46

reallocated [1] -

2795:33

really [13] - 2789:44,

2795:25, 2799:15,

2804:4, 2827:44,

2829:27, 2829:43,

2830:35, 2839:21,

2842:3, 2853:22,

2856:21

reason [9] - 2809:12,

2809:14, 2810:1,

2817:47, 2843:20,

2864:5, 2874:46,

2879:19, 2879:20

reasonable [1] -

2860:36

reasonably [1] -

2831:21

2788:29 2886:10, 2886:13, recalling [1] - 2789:44

progress [1] - 2799:18 2886:16, 2886:37 receipt [1] - 2820:17

progressive [5] - purposes [1] - receipted [1] -

2854:38, 2854:42, 2869:12 2877:19

2854:43, 2888:33 pursued [1] - 2803:12 receipts [5] - 2820:18,

prohibited [1] - put [30] - 2789:31, 2861:10, 2862:13,

2785:7 2794:16, 2798:42, 2862:25, 2877:17

pronounced [1] - 2802:31, 2808:3, receivable [1] -

2815:13 2808:7, 2830:2, 2856:25

proper [2] - 2793:40, 2841:23, 2841:28, receive [1] - 2862:9

2880:21 2841:31, 2855:20, received [13] - 2797:4,

proposal [18] - 2855:27, 2857:37, 2800:25, 2837:42,

2845:9, 2845:13, 2858:19, 2858:35, 2838:11, 2865:29,

2855:20, 2857:37, 2859:7, 2859:21, 2867:3, 2868:47,

2865:28, 2866:30, 2860:20, 2861:1, 2871:5, 2872:24,

2868:9, 2868:13, 2861:18, 2862:13, 2876:27, 2881:28,

2869:15, 2869:26, 2864:27, 2868:8, 2881:29, 2883:12

2869:28, 2869:30,

2870:9, 2870:42,

2871:1, 2871:5,

2875:1

proposals [3] -

2844:46, 2844:47,

2868:47

proposed [1] -

2868:12, 2875:23,

2879:42, 2879:46,

2881:5, 2884:44,

2888:27

puts [1] - 2843:1

putting [5] - 2829:37,

2833:25, 2863:15,

2877:3, 2880:45

receiving [3] - 2857:1,

2857:2, 2872:25

recent [4] - 2791:12,

2791:14, 2803:2,

2858:10

recently [9] - 2787:10,

2803:39, 2833:21,

2850:1, 2852:44,

2875:37

2853:1, 2862:44,

Q prosecution [1] - 2863:15, 2881:18

2813:38 recipient [1] - 2808:12

QC [3] - 2881:37,

2884:26, 2884:27

QC's [1] - 2884:42

qualified [1] - 2793:40

quality [1] - 2854:16

Queen's [1] - 2884:19

Queens [1] - 2785:21

Queensland [2] -

2824:19, 2843:9

questioning [1] -

2818:15

questions [17] -

2798:40, 2812:18,

2813:14, 2813:37,

2813:42, 2815:36,

2834:8, 2856:43,

2856:47, 2876:24,

2880:32, 2880:34,

2885:20, 2885:22,

2885:23, 2885:31

quickly [1] - 2876:34

quite [10] - 2798:29,

2816:16, 2818:8,

2818:42, 2840:34,

2857:3, 2857:6,

2867:17, 2870:23,

2872:25

protection [1] - recognise [4] -

2813:47 2799:34, 2799:44,

provide [13] - 2802:12, 2800:1, 2800:5

2802:35, 2803:21, recollection [10] -

2813:13, 2813:40, 2793:24, 2793:27,

2820:18, 2840:37, 2793:32, 2793:36,

2843:14, 2845:19, 2799:31, 2800:24,

2849:22, 2868:28, 2801:14, 2801:24,

2868:30, 2881:43 2801:27, 2881:42

provided [21] - recommend [4] -

2790:47, 2808:23, 2834:19, 2848:47,

2809:25, 2814:1, 2859:15, 2859:16

2820:15, 2832:38, recommendation [8] -

2833:10, 2838:26, 2799:5, 2834:12,

2838:31, 2843:5, 2837:37, 2852:31,

2861:9, 2865:8, 2853:14, 2859:7,

2867:2, 2868:35, 2871:2, 2880:7

2868:41, 2868:42, recommendations [2]

2869:15, 2869:19, - 2861:17, 2861:21

2869:20, 2870:41, recommended [11] -

2871:31 2833:38, 2836:35,

provider [5] - 2804:26, 2839:43, 2850:33,

2804:27, 2820:23, 2853:26, 2859:14,

2820:26, 2820:29 2869:9, 2884:14,

provides [3] - 2884:21, 2884:35,

2788:13, 2789:7, 2884:37

2839:13 record [1] - 2798:43

providing [6] - 2796:4, recorded [2] -

2802:7, 2831:36, 2873:32, 2883:35

2840:12, 2840:35, recording [1] - 2881:5

.13/10/2017 (25) 18


records [16] - regulations [5] - 2790:20, 2790:29,

2796:19, 2796:21,

2827:21, 2827:24,

2847:4, 2847:42,

2847:46, 2848:4,

2848:33, 2848:35,

2861:13, 2861:18,

2861:23, 2865:8,

2865:10, 2868:2,

2869:21, 2871:38,

2873:43, 2881:28,

2887:1, 2888:11,

2889:21

reported [6] - 2790:32,

2796:29, 2797:19,

2810:11, 2830:17,

2833:45

reporting [8] -

2788:42, 2790:9,

2790:37, 2814:41,

2848:34, 2849:39,

2852:19, 2853:25

reports [12] - 2793:14,

2798:15, 2836:7,

2836:9, 2847:5,

2847:8, 2847:47,

2849:20, 2857:16,

2858:9, 2861:12,

2873:17

reproduction [1] -

2785:4

request [2] - 2868:29,

2869:15

requested [5] -

2811:26, 2845:20,

2851:29, 2866:44,

2866:47

requests [1] - 2862:9

required [2] - 2840:5,

2872:4

requirement [2] -

2863:33, 2888:10

requirements [14] -

2811:33, 2814:44,

2815:27, 2821:4,

2821:27, 2821:41,

2838:13, 2845:32,

2856:18, 2856:20,

2863:43, 2868:16,

2869:13, 2869:32

requires [1] - 2853:25

research [1] - 2880:46

researching [1] -

2811:26

RESERVED [1] -

2785:1

reserved [1] - 2785:2

resides [1] - 2842:38

resignation [1] -

2809:18

resigned [2] - 2883:4,

2883:5

resolution [6] -

2864:34, 2875:27,

2881:43, 2883:38,

2884:44, 2885:2

resolutions [2] -

2845:12, 2875:32

resolve [2] - 2802:39,

2808:8

resolved [2] -

2881:32, 2887:5

respect [29] - 2790:19,

2796:37, 2800:32,

2812:43, 2813:2,

2813:13, 2813:42,

2828:45, 2829:28,

2832:21, 2845:46,

2857:34, 2857:35,

2858:10, 2869:21,

2869:24, 2870:10,

2870:13, 2872:26,

2874:13, 2882:18,

2883:47, 2885:46,

2886:19, 2886:20,

2886:23, 2886:34,

2886:35, 2887:20

response [6] - 2797:4,

2832:22, 2832:46,

2868:27, 2868:29,

2880:7

responses [2] -

2876:27, 2876:44

responsibilities [3] -

2847:33, 2847:35,

2847:38

responsibility [19] -

2795:44, 2795:45,

2814:42, 2818:28,

2818:35, 2818:42,

2818:44, 2818:47,

2819:30, 2820:43,

2821:19, 2826:44,

2832:23, 2832:24,

2841:9, 2846:47,

2847:6, 2847:36

responsible [5] -

2787:44, 2795:22,

2796:25, 2826:31,

2828:16

result [7] - 2799:4,

2799:5, 2804:3,

2822:28, 2838:2,

2856:19, 2880:44

resume [2] - 2828:28,

2838:32

retained [3] - 2865:25,

2866:30, 2881:9

retainer [1] - 2873:31

retired [1] - 2795:29

return [1] - 2812:26

2790:45, 2804:40, 2814:46, 2815:39, returned [1] - 2808:10

2816:39, 2817:17, 2856:28, 2869:33, returns [1] - 2889:30

2825:37, 2836:8, 2870:27 revealed [2] - 2836:15,

2851:10, 2851:13, regulator [1] - 2889:14 2857:16

2851:23, 2851:24, regulatory [1] - Review [3] - 2833:35,

2851:29, 2851:38, 2845:32 2833:39, 2834:14

2851:46, 2856:12, reimbursing [2] - review [26] - 2834:2,

2874:7, 2882:5 2808:33, 2808:44 2834:19, 2834:35,

recruited [1] - 2815:6 reiterate [1] - 2889:20 2836:4, 2836:7,

rectify [2] - 2849:6, reject [1] - 2794:25 2836:14, 2837:9,

2877:3 relate [1] - 2877:11 2837:11, 2837:13,

rectifying [2] - related [8] - 2803:6, 2855:47, 2856:1,

2829:44, 2877:8 2834:40, 2843:11, 2856:43, 2858:15,

redefine [1] - 2886:9 2849:13, 2857:7, 2865:25, 2865:28,

refer [7] - 2803:31, 2860:19, 2860:24, 2867:33, 2867:35,

2807:4, 2816:18, 2862:22 2867:36, 2868:35,

2831:19, 2838:22, relating [4] - 2817:7, 2869:13, 2869:14,

2870:7, 2881:40 2838:47, 2880:35, 2871:14, 2875:43,

reference [5] - 2887:36 2880:11, 2880:15

2806:40, 2807:22, relation [16] - 2800:35, reviewed [1] - 2884:27

2817:29, 2833:3, 2804:32, 2812:8, revise [1] - 2871:30

2868:23 2812:38, 2815:34, revised [1] - 2867:4

referred [14] - 2789:8, 2818:26, 2842:14, revoked [1] - 2888:13

2792:28, 2804:31, 2849:23, 2873:21, right-hand [3] -

2813:44, 2831:35, 2874:23, 2877:16, 2865:43, 2865:46,

2832:26, 2845:17, 2877:31, 2877:35, 2873:27

2846:21, 2865:20, 2880:1, 2880:26, ring [1] - 2816:24

2868:36, 2868:40, 2882:11 RLS [2] - 2825:7,

2882:23, 2882:27, relationship [6] - 2864:12

2883:27 2797:13, 2803:30, Road [1] - 2785:22

referring [4] - 2819:3, 2803:33, 2853:19, Robyn [2] - 2786:4,

2829:41, 2831:43, 2853:41, 2871:46 2786:26

2833:35 reliance [1] - 2835:7 ROBYN [2] - 2786:20,

refers [1] - 2833:25 rely [2] - 2818:31, 2787:2

reflect [4] - 2872:1, 2840:25 Rocchi [12] - 2815:17,

2872:4, 2872:7, remedial [1] - 2829:21 2816:38, 2819:9,

2874:27 remedies [1] - 2837:6 2826:17, 2826:18,

reflected [1] - 2880:8 remedy [3] - 2829:32, 2826:29, 2826:35,

reflecting [1] - 2875:23, 2877:3 2846:22, 2846:26,

2870:28 remember [6] - 2846:28, 2846:41,

refresh [1] - 2806:44 2799:22, 2810:1, 2846:47

regard [4] - 2796:29, 2810:5, 2822:20, ROCCHI [1] - 2815:20

2803:1, 2860:17, 2872:19, 2882:47 role [25] - 2787:24,

2889:18 remind [1] - 2845:24 2787:33, 2788:23,

regarded [1] - 2818:21 remove [1] - 2839:38 2788:42, 2789:17,

register [5] - 2816:31, removing [1] - 2806:3 2789:40, 2792:17,

2864:45, 2864:46, remuneration [2] - 2792:45, 2792:47,

2865:5 2855:19, 2858:36 2794:6, 2794:11,

registered [1] - renewal [3] - 2836:43, 2794:32, 2795:26,

2867:43 2877:42, 2879:11 2795:31, 2795:33,

registers [2] - 2816:6, renewed [1] - 2848:22 2796:11, 2817:41,

2865:1 repair [1] - 2848:44 2818:7, 2818:10,

Registry [1] - 2809:35 repairing [1] - 2849:1 2830:29, 2842:24,

regular [3] - 2831:5,

2831:6, 2831:21

regulated [1] - 2841:6

regulation [3] -

2814:26, 2814:31,

2856:21

repeat [2] - 2806:18,

2870:2

repeated [1] - 2861:28

replaced [1] - 2846:21

report [28] - 2790:2,

2790:6, 2790:13,

2847:40, 2885:45,

2887:33, 2887:35

roles [2] - 2847:33,

2847:38

Rowe [4] - 2809:18,

2810:5, 2883:4

.13/10/2017 (25) 19


Rowe's [2] - 2810:2, 2858:10, 2858:19, 2851:36, 2851:38,

2852:13, 2852:14,

2853:20, 2875:20,

2875:35

Sage's [1] - 2852:19

satisfied [2] -

2878:45, 2888:40

satisfying [1] - 2880:2

saw [7] - 2789:21,

2789:39, 2792:17,

2834:2, 2834:16,

2880:36, 2881:4

SC [3] - 2785:32,

2785:36, 2881:37

scanned [1] - 2876:44

scenario [1] - 2844:28

schedule [2] -

2813:13, 2813:40

scheme [1] - 2829:13

scope [3] - 2866:17,

2866:21, 2866:32

Scope [1] - 2873:46

Scope" [1] - 2873:45

scoping [1] - 2853:45

seat [1] - 2786:18

second [3] - 2847:31,

2873:31, 2874:2

secondly [1] - 2886:4

Secretary [1] - 2865:1

secretary [4] -

2887:26, 2887:34,

2887:35, 2887:37

section [4] - 2812:1,

2829:16, 2833:12,

2833:19

sector [2] - 2803:9,

2831:14

see [54] - 2798:28,

2798:41, 2798:44,

2800:13, 2806:40,

2806:41, 2807:1,

2807:22, 2809:12,

2809:14, 2817:24,

2817:28, 2819:6,

2821:9, 2827:18,

2830:40, 2831:2,

2831:20, 2833:45,

2833:46, 2835:27,

2839:20, 2840:45,

2840:46, 2841:45,

2843:22, 2854:6,

2862:10, 2862:13,

2864:8, 2866:5,

2866:8, 2866:14,

2866:22, 2866:25,

2866:41, 2867:6,

2867:10, 2867:16,

2868:14, 2868:23,

2868:24, 2868:40,

2873:31, 2873:41,

2873:46, 2874:9,

2881:33, 2882:9,

2882:14, 2883:15,

2883:38, 2884:6,

2884:19

seeing [2] - 2849:6,

2854:13

seek [2] - 2822:29,

2880:33

seeking [2] - 2828:45,

2829:46

seem [6] - 2798:37,

2829:42, 2843:40,

2843:44, 2875:6,

2889:13

segregated [1] -

2847:35

send [1] - 2808:11

sending [3] - 2806:33,

2832:7, 2832:11

senior [2] - 2881:33,

2881:43

sense [3] - 2843:40,

2843:45, 2860:32

sensible [1] - 2875:42

sent [7] - 2808:9,

2831:32, 2863:21,

2863:30, 2871:1,

2876:13, 2880:6

sentence [1] - 2870:7

separate [6] -

2803:33, 2804:14,

2842:20, 2842:40,

2846:45, 2875:32

separation [6] -

2803:38, 2803:44,

2804:3, 2842:26,

2842:35, 2842:37

September [12] -

2838:16, 2845:18,

2847:20, 2848:10,

2853:9, 2868:36,

2871:5, 2871:10,

2877:47, 2879:7,

2884:9, 2887:1

sequential [1] -

2816:33

series [3] - 2789:45,

2790:1, 2884:16

serious [2] - 2834:11,

2882:41

service [16] - 2793:14,

2793:21, 2802:35,

2803:22, 2803:25,

2804:18, 2804:25,

2804:27, 2831:14,

2831:16, 2839:37,

2840:9, 2840:31,

2840:37, 2844:11,

2886:14

servicemen [4] -

2801:37, 2802:12,

2832:27

services [27] -

2788:13, 2803:6,

2829:23, 2829:44,

2831:36, 2833:11,

2833:14, 2839:12,

2839:15, 2839:21,

2840:10, 2840:12,

2840:15, 2840:23,

2841:39, 2843:5,

2843:14, 2844:12,

2844:13, 2853:29,

2866:12, 2873:36,

2884:28, 2884:29,

2886:40

Services [3] - 2785:3,

2785:5, 2788:8

serving [5] - 2788:27,

2793:27, 2831:39,

2832:42, 2884:30

set [22] - 2803:4,

2803:17, 2819:35,

2819:38, 2820:33,

2821:15, 2821:27,

2821:33, 2821:45,

2822:5, 2822:13,

2822:19, 2833:33,

2833:38, 2834:13,

2843:10, 2843:20,

2852:22, 2856:11,

2866:18, 2875:18,

2884:21

setting [10] - 2820:1,

2820:46, 2821:9,

2834:19, 2839:27,

2839:44, 2840:29,

2870:21, 2884:40,

2885:1

setup [1] - 2856:36

several [2] - 2846:44,

2859:34

severely [2] - 2793:13,

2793:16

shared [1] - 2863:20

sheet [4] - 2798:31,

2798:33, 2798:35,

2798:46

Sheridan [5] -

2799:33, 2799:41,

2799:44, 2800:39,

2889:30

Sheridan's [1] -

2799:40

shocked [1] - 2810:17

short [2] - 2812:21,

2828:26

SHORT [2] - 2812:32,

2828:32

2810:10 2858:29, 2861:14,

RSL [198] - 2786:32, 2861:19, 2861:27,

2787:11, 2787:15, 2861:31, 2861:32,

2787:24, 2787:26, 2861:39, 2862:5,

2787:33, 2788:19, 2862:8, 2862:36,

2788:20, 2788:26, 2862:40, 2863:7,

2788:33, 2788:43, 2863:22, 2863:28,

2788:45, 2789:3, 2863:46, 2864:31,

2789:22, 2790:19, 2864:42, 2865:4,

2791:33, 2792:38, 2865:8, 2872:42,

2792:39, 2794:12, 2873:16, 2873:19,

2794:18, 2795:16, 2873:36, 2874:6,

2795:33, 2795:40, 2874:14, 2874:19,

2795:46, 2796:7, 2874:23, 2875:6,

2796:25, 2797:40, 2875:12, 2875:16,

2798:11, 2798:20, 2875:19, 2875:22,

2798:35, 2803:30, 2875:26, 2875:31,

2803:31, 2804:10, 2875:35, 2875:40,

2808:41, 2809:34, 2875:41, 2875:44,

2810:15, 2817:10, 2876:1, 2876:2,

2817:14, 2817:17, 2876:5, 2876:13,

2817:23, 2818:18, 2876:40, 2877:2,

2819:29, 2820:30, 2877:21, 2877:31,

2821:23, 2823:17, 2879:30, 2879:34,

2823:21, 2824:6, 2879:40, 2879:41,

2824:8, 2824:19, 2879:46, 2880:26,

2824:38, 2824:41, 2884:23, 2884:41,

2824:43, 2824:46, 2884:44, 2884:45,

2825:21, 2827:3, 2885:1, 2885:9,

2827:17, 2827:39, 2885:21, 2885:23,

2827:41, 2827:44, 2885:31, 2885:35,

2828:21, 2830:21, 2885:39, 2885:44,

2830:25, 2830:29, 2885:46, 2886:5,

2830:33, 2835:22, 2886:11, 2886:15,

2835:25, 2835:31, 2886:23, 2886:29,

2836:9, 2839:1, 2886:39, 2887:5,

2842:16, 2842:20, 2887:21, 2887:25,

2842:28, 2842:33, 2888:28

2842:42, 2843:3, RSL's [2] - 2836:5,

2843:5, 2843:6, 2853:19

2843:12, 2843:14, rules [1] - 2801:41

2843:22, 2843:25, Rules [2] - 2881:18,

2843:28, 2843:30, 2881:19

2843:40, 2843:45, run [8] - 2804:10,

2844:20, 2844:29, 2824:45, 2835:15,

2844:32, 2844:36, 2839:19, 2841:10,

2844:43, 2846:43, 2841:12, 2843:3,

2847:12, 2848:1, 2887:38

2848:2, 2848:7, running [3] - 2834:28,

2848:33, 2848:47, 2841:45, 2853:46

2849:10, 2849:14, runs [1] - 2843:30 2849:18, 2849:38,

2850:11, 2850:36, S 2851:28, 2851:30,

Sage [16] - 2836:9,

2850:7, 2850:11,

2850:22, 2850:30,

2850:40, 2850:44,

2851:25, 2851:35,

2852:45, 2853:3,

2853:21, 2855:10,

2855:15, 2855:20,

2855:32, 2855:37,

2857:18, 2857:28,

2857:29, 2857:36,

.13/10/2017 (25) 20


shortly [2] - 2812:26, 2886:38

social [1] - 2886:6

sole [4] - 2883:5,

2883:9, 2883:11,

2884:46

solicitor [3] - 2881:9,

2884:10, 2884:13

solution [2] - 2853:18,

2853:28

solutions [2] -

2832:39, 2832:40

solve [2] - 2877:30,

2877:37

SOM [1] - 2815:13

Som [1] - 2815:13

someone [5] - 2819:7,

2831:20, 2848:43,

2853:45, 2863:38

sometimes [1] -

2871:18

somewhere [3] -

2820:34, 2825:12,

2841:46

son [1] - 2809:25

soon [3] - 2801:45,

2825:18, 2881:4

sorry [99] - 2792:7,

2792:26, 2793:37,

2794:14, 2800:29,

2802:41, 2805:26,

2805:38, 2806:1,

2806:8, 2806:14,

2806:18, 2806:26,

2806:27, 2807:23,

2807:24, 2810:18,

2810:33, 2811:20,

2815:12, 2815:25,

2820:27, 2820:36,

2820:44, 2822:10,

2823:39, 2824:28,

2826:29, 2827:12,

2827:47, 2828:5,

2828:14, 2832:38,

2834:30, 2835:32,

2836:11, 2837:26,

2844:30, 2845:2,

2845:6, 2845:26,

2847:5, 2847:30,

2848:29, 2849:29,

2850:16, 2850:20,

2851:20, 2851:41,

2852:13, 2852:32,

2852:45, 2854:13,

2854:14, 2854:39,

2854:40, 2855:29,

2855:43, 2856:1,

2857:32, 2858:44,

2859:6, 2860:41,

2862:12, 2864:39,

2865:1, 2865:14,

2865:34, 2865:47,

2866:31, 2867:17,

2867:22, 2868:14,

2869:12, 2871:15,

2871:18, 2871:30,

2871:34, 2872:5,

2872:46, 2873:42,

2874:27, 2874:34,

2877:42, 2879:5,

2879:43, 2881:10,

2882:2, 2882:43,

2883:3, 2883:8,

2884:36, 2884:47,

2885:47

sort [4] - 2831:11,

2877:32, 2882:25,

2882:34

sorts [4] - 2816:7,

2816:31, 2831:22,

2860:19

sought [3] - 2832:39,

2838:27, 2849:22

sound [3] - 2804:19,

2804:23, 2852:21

source [3] - 2840:20,

2849:41, 2884:10

sources [1] - 2840:40

South [16] - 2785:23,

2821:38, 2823:10,

2823:13, 2823:31,

2824:4, 2824:22,

2824:27, 2824:35,

2824:45, 2825:1,

2825:22, 2825:29,

2825:33, 2845:40,

2850:26

space [3] - 2871:23,

2872:35, 2887:37

speaking [1] -

2886:28

specialist [5] -

2793:15, 2848:14,

2848:26, 2848:31,

2848:43

specialists [2] -

2793:13, 2793:17

specific [4] - 2810:18,

2817:34, 2860:2,

2867:14

specifically [7] -

2789:41, 2815:29,

2815:41, 2816:19,

2832:37, 2832:43,

2856:12

specifications [1] -

2867:2

specifics [1] - 2810:16

specifies [1] - 2860:6

specify [1] - 2860:5

spell [2] - 2815:12,

2862:47 2858:15, 2858:23,

2858:25, 2858:33,

2858:34, 2858:37,

2858:44, 2858:46,

2859:8, 2859:10,

2859:18, 2859:19,

2859:22, 2863:17,

2863:18, 2863:46,

2864:32, 2865:1,

2865:2, 2873:21,

2875:28, 2876:1,

2876:3, 2884:44

statement [22] -

2786:34, 2786:38,

2786:45, 2791:40,

2803:37, 2806:38,

2812:8, 2813:18,

2813:25, 2829:1,

2829:11, 2838:19,

2862:26, 2864:19,

2868:19, 2869:40,

2870:8, 2878:47,

2879:1, 2879:3,

2880:37, 2888:26

STATEMENT [1] -

2787:2

statements [13] -

2797:31, 2797:47,

2798:1, 2798:8,

2800:36, 2812:42,

2817:28, 2825:38,

2825:39, 2825:45,

2826:3, 2861:4,

2861:9

States [13] - 2821:42,

2822:29, 2822:32,

2822:40, 2823:18,

2823:25, 2823:46,

2824:4, 2824:34,

2825:25, 2843:4,

2843:7, 2843:8

status [1] - 2807:20

statute [2] - 2843:11,

2843:17

stay [1] - 2842:27

step [6] - 2812:22,

2857:47, 2877:3,

2877:4, 2877:14,

2889:7

steps [20] - 2802:25,

2802:27, 2802:39,

2805:41, 2808:3,

2829:2, 2829:28,

2846:16, 2858:18,

2875:11, 2875:23,

2879:11, 2879:45,

2880:9, 2884:16,

2884:36, 2884:37,

2885:7, 2888:34

still [19] - 2795:46,

2850:5 spelt [1] - 2815:23

show [3] - 2791:36, spend [2] - 2859:47,

2833:46, 2865:33 2860:33

showed [2] - 2845:17, spent [1] - 2865:31

2873:28 split [2] - 2846:35,

shown [4] - 2867:24, 2846:38

2873:24, 2876:43, spoken [1] - 2869:20

2880:36 sporting [1] - 2788:28

shows [2] - 2791:28, Square [1] - 2785:21

2791:41 staff [3] - 2818:32,

sick [2] - 2794:28, 2818:35, 2847:13

2797:45 stage [26] - 2789:38,

side [17] - 2789:18, 2798:24, 2807:15,

2789:22, 2790:19, 2811:11, 2812:17,

2790:21, 2790:24, 2817:11, 2817:45,

2792:37, 2792:38, 2837:1, 2837:25,

2794:41, 2795:4, 2837:28, 2839:8,

2796:33, 2797:27, 2845:5, 2845:42,

2800:17, 2811:32, 2849:26, 2849:46,

2815:45, 2817:12, 2850:43, 2855:18,

2830:24, 2841:25 2856:35, 2865:24,

signature [1] - 2866:29, 2867:13,

2862:28 2871:29, 2874:24,

signatures [1] - 2875:24, 2877:36,

2862:29 2880:11

signed [2] - 2787:16, stakeholders [2] -

2862:28 2886:14, 2886:28

significant [5] - stalled [2] - 2800:13,

2840:33, 2840:35, 2800:17

2841:4, 2855:6, stalling [2] - 2800:14,

2878:45 2800:16

similar [6] - 2807:29, stand [2] - 2803:21,

2834:29, 2843:5, 2878:44

2859:29, 2863:30, standardisation [1] -

2875:42 2887:40

simple [1] - 2816:16 start [3] - 2787:32,

simply [3] - 2789:33, 2797:27, 2869:2

2804:44, 2826:7 started [22] - 2788:34,

single [1] - 2863:20 2788:37, 2788:38,

Single [1] - 2785:37 2788:40, 2788:46,

sit [2] - 2818:11, 2794:31, 2795:3,

2829:40 2802:18, 2802:44,

sits [2] - 2885:14, 2802:45, 2815:5,

2885:15 2822:2, 2836:26,

sitting [2] - 2799:36 2836:29, 2846:11,

situation [5] - 2809:7, 2847:6, 2847:28,

2829:22, 2842:9, 2850:18, 2862:8,

2875:23, 2888:33 2863:6, 2877:10,

slack [1] - 2824:36 2881:4

slightly [4] - 2829:13, starting [6] - 2796:17,

2833:17, 2859:36, 2836:2, 2845:34,

2883:3 2846:40, 2863:7,

slow [1] - 2853:24 2882:47

small [6] - 2814:43, state [2] - 2843:7,

2816:12, 2816:15, 2888:19

2818:43, 2828:19, State [31] - 2821:47,

2833:12 2823:21, 2833:45,

Social [4] - 2885:45, 2842:42, 2843:6,

2886:3, 2886:11, 2843:33, 2844:40,

.13/10/2017 (25) 21


2822:23, 2831:31, sub-branches's [1] -

2835:32

subject [2] - 2801:14,

2884:42

submitted [4] -

2869:26, 2869:28,

2877:41, 2877:42

subsequent [2] -

2866:34, 2885:4

subsequently [3] -

2788:10, 2835:25,

2835:26

succeeded [2] -

2815:16, 2826:16

success [1] - 2854:13

successful [2] -

2840:19, 2854:11

sufficient [9] -

2804:22, 2811:23,

2811:25, 2814:37,

2837:4, 2862:11,

2870:25, 2870:30,

2878:27

sufficiently [1] -

2841:34

suggest [5] - 2813:1,

2817:30, 2818:14,

2878:37

suggested [4] -

2832:40, 2839:45,

2848:42, 2881:16

suggesting [1] -

2879:27

suggestions [2] -

2831:15, 2844:23

suit [1] - 2813:15

suitability [1] - 2880:3

suite [2] - 2853:17,

2856:26

Suite [1] - 2854:28

Sulan [1] - 2885:18

SULAN [4] - 2885:20,

2885:28, 2885:30,

2887:47

supervise [1] -

2805:12

supplier [2] - 2820:23,

2820:29

support [8] - 2789:8,

2793:15, 2793:40,

2832:3, 2840:18,

2841:29, 2841:34,

2884:47

supported [1] -

2841:16

supporting [2] -

2840:44, 2841:25

supports [1] - 2840:43

supposed [1] - 2790:6

Supreme [2] -

2829:47, 2881:20 2848:46, 2853:32, 2843:1, 2845:30,

2832:32, 2833:17, surety [1] - 2868:30 2854:2, 2854:7, 2852:15, 2854:30,

2833:25, 2844:34, surround [2] - 2854:18, 2855:2, 2854:34, 2854:38,

2846:28, 2851:25, 2856:24, 2870:15 2855:6, 2855:7, 2856:24, 2857:36,

2851:28, 2851:35, surrounding [1] - 2855:11, 2855:15, 2860:15, 2861:20,

2855:10, 2856:44, 2868:32 2857:4, 2861:32, 2871:12, 2871:14,

2858:36, 2859:38, survey [2] - 2876:13, 2865:8, 2865:26, 2871:21, 2871:22,

2859:43, 2860:12, 2876:22 2868:14, 2870:21, 2879:41, 2879:44,

2861:31, 2875:20 surveys [4] - 2876:27, 2871:28, 2871:45, 2884:5, 2886:4,

stop [4] - 2795:32, 2876:31, 2876:33, 2874:18, 2875:17, 2886:30

2809:1, 2823:41, 2876:42 2877:3, 2880:3, Terms [1] - 2888:7

2823:43 suspend [1] - 2837:28 2888:30, 2888:42 terribly [1] - 2872:46

stopped [1] - 2833:23 suspension [1] - Territories [9] -

T stopping [2] - 2838:3 2821:42, 2822:30,

2829:44, 2862:35 sustain [1] - 2840:5 2822:32, 2822:40,

tab [9] - 2791:4,

2791:8, 2791:12,

2791:27, 2865:33,

2868:19, 2873:27,

2880:38, 2881:26

tabulated [2] -

2868:41, 2869:19

tags [1] - 2818:45

task [1] - 2849:13

tasks [1] - 2849:43

tax [1] - 2831:43

tea [1] - 2830:16

team [12] - 2797:36,

2798:28, 2798:42,

2799:10, 2799:40,

2801:26, 2801:30,

2847:34, 2856:34,

2863:21, 2871:33,

2872:9

technical [2] -

2851:40, 2851:41

telephone [4] -

2801:15, 2801:18,

2801:19, 2801:20

temptation [1] -

2841:23

tend [1] - 2813:38

tender [2] - 2786:45,

2840:19

tendered [2] -

2840:17, 2840:18

tension [1] - 2841:20

tentative [1] - 2845:35

tentatively [1] -

2884:41

terms [36] - 2787:20,

2787:37, 2794:20,

2802:39, 2815:38,

2815:42, 2817:12,

2830:13, 2831:27,

2832:23, 2834:18,

2836:29, 2837:3,

2837:13, 2837:36,

2839:19, 2840:40,

straddles [1] - 2848:1 sustainable [2] - 2823:18, 2823:25,

strategic [2] - 2840:22, 2841:11 2823:46, 2824:34,

2886:12, 2886:25 sworn [1] - 2786:20 2825:25

strategy [5] - 2886:9, Sydney [2] - 2785:23, Territory [1] - 2822:1

2886:16, 2887:4, 2786:29 tested [1] - 2888:24

2887:17, 2887:18 system [79] - 2820:10, THE [5] - 2785:12,

Street [1] - 2786:29 2820:16, 2834:24, 2870:2, 2878:19,

strongly [1] - 2840:21 2836:9, 2845:31, 2889:10, 2889:36

structure [5] - 2839:1, 2849:38, 2850:7, therefore [2] -

2845:47, 2856:44, 2850:8, 2850:11, 2802:16, 2832:11

2886:39, 2886:43 2850:12, 2850:13, thinking [3] - 2866:17,

structured [3] - 2850:25, 2850:44, 2873:42, 2884:38

2842:1, 2842:11, 2851:26, 2851:35, third [2] - 2847:19,

2886:37 2851:36, 2852:15, 2863:37

struggling [3] - 2852:25, 2852:30, Thornton [2] -

2840:26, 2856:27, 2852:31, 2852:33, 2799:26, 2858:14

2859:6 2852:36, 2852:37, three [16] - 2786:38,

sub [26] - 2803:32, 2852:41, 2852:46, 2786:40, 2830:45,

2807:16, 2834:41, 2853:1, 2853:2, 2831:9, 2840:45,

2834:44, 2835:8, 2853:6, 2853:13, 2840:47, 2841:1,

2835:10, 2835:17, 2853:16, 2853:20, 2841:2, 2847:17,

2835:21, 2835:32, 2853:27, 2853:40, 2847:26, 2847:34,

2835:38, 2843:33, 2853:42, 2854:16, 2853:32, 2854:2,

2843:36, 2864:12, 2854:21, 2854:24, 2854:6, 2863:33,

2876:6, 2876:10, 2854:30, 2854:31, 2864:15

2876:14, 2876:35, 2855:23, 2855:32, throughout [1] -

2876:37, 2877:9, 2855:34, 2855:35, 2821:34

2877:12, 2877:13, 2855:37, 2855:44, Thursday [1] -

2877:22, 2877:26, 2855:47, 2856:4, 2889:30

2877:32, 2877:35 2856:17, 2856:22, timeline [3] - 2870:46,

sub-branch [3] - 2856:30, 2856:37, 2871:3, 2887:18

2864:12, 2876:35, 2857:37, 2857:38, timetable [3] -

2876:37 2861:46, 2862:15, 2837:18, 2855:29,

sub-branches [22] - 2862:17, 2862:32, 2889:19

2803:32, 2807:16, 2862:35, 2862:37, timing [1] - 2883:3

2834:41, 2834:44, 2862:45, 2863:9, title [3] - 2846:22,

2835:8, 2835:10, 2865:29, 2870:13, 2846:24, 2846:31

2835:17, 2835:21, 2870:21, 2870:22, titles [1] - 2847:25

2835:38, 2843:33,

2843:36, 2876:6,

2876:10, 2876:14,

2876:37, 2877:9,

2877:12, 2877:13,

2877:22, 2877:26,

2877:32, 2877:35

2870:23, 2870:24,

2870:30, 2870:35,

2871:47, 2872:2,

2873:18, 2875:20,

2875:24, 2876:3

system" [1] - 2834:26

systems [24] -

TO [1] - 2889:36

today [4] - 2809:7,

2829:41, 2871:10,

2888:22

today's [1] - 2838:25

TOGETHER [1] -

2787:2

.13/10/2017 (25) 22


together [5] - 2798:43, 2827:30

trips [9] - 2792:33,

2792:37, 2792:41,

2792:46, 2793:2,

2793:15, 2793:20,

2793:34, 2793:46

trouble [2] - 2789:44,

2831:21

true [1] - 2888:40

truly [3] - 2834:14,

2836:10, 2839:20

trust [6] - 2829:24,

2829:40, 2839:4,

2843:20, 2873:8,

2880:36

Trust [6] - 2812:43,

2830:39, 2881:14,

2882:34, 2883:15

Trustee [14] - 2793:9,

2813:3, 2831:3,

2863:37, 2863:46,

2864:27, 2873:5,

2881:14, 2883:5,

2883:9, 2883:11,

2885:6

trustees [2] - 2790:3,

2790:33

Trustees [78] - 2790:7,

2796:4, 2796:22,

2796:29, 2797:1,

2797:19, 2799:6,

2799:32, 2803:13,

2804:44, 2808:8,

2814:42, 2815:28,

2817:5, 2818:29,

2819:32, 2828:9,

2828:36, 2829:22,

2829:39, 2829:46,

2830:18, 2830:38,

2830:45, 2831:26,

2832:37, 2832:43,

2833:38, 2836:36,

2837:34, 2838:12,

2838:34, 2838:39,

2839:29, 2839:43,

2840:24, 2842:42,

2849:39, 2852:32,

2853:14, 2853:27,

2857:38, 2859:32,

2861:6, 2861:9,

2863:33, 2863:39,

2864:15, 2864:27,

2869:9, 2869:16,

2870:37, 2870:42,

2870:47, 2871:1,

2875:2, 2878:31,

2878:35, 2879:22,

2879:25, 2879:27,

2880:6, 2880:35,

2881:13, 2881:32,

2881:44, 2882:10, 2835:3, 2835:5,

2835:13, 2843:21,

2843:45, 2844:32

UNDER [1] - 2785:12

undergoing [1] -

2842:8

understood [30] -

2787:43, 2788:47,

2790:6, 2793:35,

2797:37, 2797:42,

2808:26, 2808:29,

2808:31, 2808:33,

2808:36, 2808:40,

2814:40, 2814:43,

2817:10, 2817:13,

2817:17, 2818:7,

2818:17, 2818:24,

2820:12, 2821:19,

2832:16, 2835:3,

2849:9, 2857:35,

2866:31, 2868:2,

2871:26, 2881:38

undertake [1] -

2866:45

Union [3] - 2824:14,

2824:16, 2824:26

unsure [1] - 2870:24

unwell [1] - 2793:39

up [54] - 2787:14,

2788:4, 2790:6,

2797:23, 2797:24,

2799:13, 2799:15,

2803:4, 2803:17,

2816:14, 2819:35,

2819:38, 2820:1,

2820:33, 2820:35,

2820:46, 2821:10,

2821:15, 2821:27,

2821:33, 2821:45,

2822:5, 2822:13,

2822:19, 2824:36,

2825:9, 2825:18,

2833:33, 2833:38,

2834:13, 2834:19,

2836:43, 2839:44,

2840:29, 2843:11,

2843:20, 2845:2,

2852:22, 2853:46,

2854:43, 2854:45,

2855:20, 2856:11,

2858:36, 2859:8,

2863:15, 2870:21,

2871:2, 2875:18,

2882:39, 2884:21,

2884:40, 2885:1,

2885:7

update [1] - 2851:33

urgent [3] - 2829:43,

2830:41, 2889:21

urgently [1] - 2829:28

utmost [2] - 2842:43

2842:34, 2854:7, 2883:32, 2883:47,

V 2854:31, 2854:39 2884:14, 2884:17,

token [1] - 2877:19 2884:37, 2884:38,

vague [1] - 2799:31

value [1] - 2840:22

various [17] - 2788:28,

2803:30, 2803:40,

2803:45, 2805:36,

2810:27, 2816:12,

2823:25, 2823:46,

2824:33, 2838:26,

2842:16, 2846:16,

2867:42, 2877:10,

2885:38, 2888:38

vehicle [1] - 2839:16

venture [6] - 2806:22,

2806:30, 2806:35,

2807:13, 2807:17,

2807:21

Ventures [4] -

2885:45, 2886:3,

2886:11, 2886:38

ventures [5] -

2806:12, 2806:13,

2806:14, 2886:6

version [1] - 2791:12

Veterans [1] - 2795:28

veterans [9] -

2788:27, 2788:41,

2793:21, 2793:22,

2793:28, 2840:32,

2843:15, 2884:30,

2884:33

via [1] - 2820:9

Victoria [7] - 2824:38,

2824:41, 2824:43,

2824:46, 2825:7,

2825:21, 2843:8

view [16] - 2803:38,

2808:45, 2810:32,

2817:26, 2826:3,

2833:13, 2835:5,

2837:5, 2837:19,

2841:33, 2842:34,

2843:2, 2870:34,

2874:18, 2876:17,

2888:12

virtue [2] - 2830:29,

2835:8

volume [2] - 2791:1,

2806:37

Volume [4] - 2868:19,

2869:47, 2870:4,

2880:37

volumes [2] - 2786:38,

2786:47

VOLUMES [1] -

2787:3

tokens [1] - 2835:10 2884:40, 2885:4,

took [10] - 2818:44, 2885:9

2826:27, 2826:35, Trustees' [2] - 2880:5,

2826:41, 2826:44, 2880:13

2826:45, 2827:28, trustees's [1] - 2796:3

2832:26, 2866:32, Trustees's [1] -

2880:40 2837:32

top [2] - 2855:40, truth [1] - 2814:1

2865:47 try [3] - 2798:4,

topic [2] - 2812:38, 2801:16, 2846:17

2813:17 trying [12] - 2787:32,

total [1] - 2839:1 2794:13, 2799:22,

totality [1] - 2811:30 2809:9, 2814:34,

towards [4] - 2795:17, 2822:20, 2835:23,

2795:19, 2884:8, 2840:27, 2855:30,

2888:29 2856:32, 2863:44,

traction [1] - 2804:25 2874:27

Trading [24] - turn [9] - 2790:16,

2837:44, 2838:11, 2791:4, 2791:8,

2838:26, 2838:31, 2791:27, 2806:39,

2845:18, 2845:19, 2807:30, 2816:29,

2845:41, 2877:41, 2819:10, 2873:45

2877:47, 2878:10, turned [2] - 2788:1,

2878:25, 2878:32, 2811:16

2878:39, 2879:11, two [22] - 2787:29,

2879:12, 2879:16, 2788:5, 2789:7,

2879:26, 2879:39, 2802:39, 2809:35,

2879:44, 2880:2, 2809:37, 2820:8,

2880:6, 2880:13, 2828:12, 2831:9,

2880:14, 2880:21 2840:47, 2842:34,

trading [1] - 2838:9 2847:16, 2847:17,

train [1] - 2808:3 2847:42, 2849:37,

transaction [1] - 2854:18, 2862:30,

2836:8 2864:38, 2867:24,

transactional [1] - 2867:35, 2873:45

2867:1 type [2] - 2801:25,

transactions [5] - 2810:17

2798:37, 2798:38, types [1] - 2860:43

2798:43, 2818:46,

U 2856:24

transcript [2] - 2785:2,

ultimate [1] - 2862:19

ultimately [4] -

2841:41, 2842:39,

2842:42, 2842:45

Umrigar [6] - 2798:6,

2798:9, 2798:11,

2799:8, 2806:5,

2836:6

unaware [1] - 2874:22

uncomfortable [2] -

2862:7, 2863:8

under [11] - 2785:4,

2801:41, 2814:44,

2819:20, 2824:45,

2785:6

transfer [1] - 2852:5

transferred [2] -

2846:6, 2851:7

transit [3] - 2806:21,

2807:30, 2807:46

transition [2] -

2861:24, 2861:26

transitioned [2] -

2852:24, 2875:40

transitioning [2] -

2855:39, 2875:35

transpired [1] - 2849:1

treat [1] - 2842:20

treated [2] - 2792:5,

.13/10/2017 (25) 23


volunteers [3] - 2808:9, 2808:15,

2808:33, 2808:44,

2809:2, 2809:12,

2810:36, 2811:1,

2811:9, 2811:17,

2811:37, 2814:10,

2814:14, 2814:30,

2815:2, 2816:11,

2816:42, 2817:2,

2817:3, 2817:11,

2817:18, 2817:22,

2817:27, 2818:22,

2818:27, 2818:35,

2819:29, 2819:35,

2820:14, 2822:31,

2822:39, 2823:9,

2823:13, 2823:30,

2823:34, 2824:26,

2824:34, 2824:43,

2825:4, 2825:13,

2825:14, 2825:37,

2825:38, 2825:45,

2826:12, 2826:24,

2826:32, 2826:40,

2826:45, 2827:19,

2827:28, 2827:36,

2827:37, 2827:39,

2827:45, 2828:17,

2830:18, 2830:25,

2830:29, 2830:38,

2832:8, 2833:43,

2834:3, 2834:28,

2835:13, 2835:15,

2835:18, 2835:21,

2835:26, 2835:31,

2835:40, 2838:25,

2838:32, 2838:38,

2839:4, 2839:5,

2839:38, 2839:46,

2840:1, 2840:38,

2842:14, 2842:20,

2842:27, 2842:32,

2843:10, 2844:19,

2844:24, 2844:43,

2845:19, 2846:5,

2846:6, 2846:12,

2846:17, 2847:1,

2847:11, 2848:2,

2848:7, 2849:7,

2849:18, 2849:23,

2849:26, 2849:29,

2849:31, 2849:35,

2849:40, 2850:12,

2850:26, 2850:40,

2850:43, 2851:10,

2851:30, 2851:35,

2851:36, 2851:39,

2851:45, 2852:42,

2853:18, 2853:27,

2855:1, 2855:24,

2856:5, 2857:18,

2857:23, 2857:38,

2858:10, 2859:29,

2859:31, 2859:32,

2860:13, 2860:34,

2860:40, 2861:19,

2861:20, 2861:23,

2861:28, 2861:37,

2862:36, 2862:37,

2863:29, 2863:33,

2864:21, 2865:9,

2865:29, 2868:38,

2871:27, 2871:44,

2872:14, 2872:16,

2872:47, 2873:18,

2873:20, 2873:41,

2874:13, 2874:29,

2874:35, 2875:2,

2875:16, 2875:31,

2877:2, 2877:21,

2877:27, 2877:30,

2878:10, 2878:15,

2879:15, 2879:44,

2880:1, 2880:9,

2881:9, 2884:11,

2884:23, 2884:25,

2884:26, 2884:34,

2885:9, 2887:13,

2888:28

WBI's [13] - 2801:36,

2807:19, 2819:20,

2824:45, 2835:4,

2835:5, 2836:43,

2850:13, 2852:44,

2853:1, 2874:7,

2874:18, 2880:22

WBI.15.0000010 [1] -

2865:36

WBI.15.0000017 [1] -

2866:38

website [26] -

2816:14, 2819:35,

2819:36, 2820:2,

2820:9, 2820:12,

2820:46, 2821:10,

2821:15, 2821:20,

2821:27, 2821:33,

2821:34, 2821:45,

2822:5, 2822:13,

2822:19, 2825:2,

2825:3, 2825:8,

2825:12, 2828:20,

2830:12, 2831:25,

2831:27, 2831:28

Wednesday [1] -

2889:30

WEDNESDAY [1] -

2889:37

week [5] - 2848:24,

2855:20, 2864:37,

2889:22, 2889:29

weekly [1] - 2816:12

weeks [4] - 2787:29,

2856:40, 2863:11,

2863:12

welfare [2] - 2831:36,

2843:6

Western [1] - 2823:35

whereby [1] - 2856:37

whilst [1] - 2867:13

White [3] - 2883:5,

2883:9, 2883:10

white [1] - 2883:13

whole [5] - 2787:45,

2789:25, 2791:41,

2806:18, 2887:40

willing [1] - 2840:14

wind [3] - 2799:15,

2839:46, 2840:1

Winter [1] - 2889:30

wish [2] - 2813:14,

2844:36

WITH [1] - 2787:3

withdraw [2] -

2874:38, 2874:44

WITHDREW [1] -

2889:10

WITNESS [3] - 2870:2,

2878:19, 2889:10

witness [6] - 2786:6,

2813:31, 2828:27,

2828:35, 2830:4,

2858:6

women's [3] -

2803:32, 2807:31,

2807:42

word [3] - 2833:7,

2870:23, 2871:19

wording [1] - 2878:7

words [1] - 2882:43

work-related [2] -

2860:19, 2860:24

works [1] - 2854:38

worried [1] - 2793:12

worry [1] - 2882:36

worrying [1] - 2828:36

wound [1] - 2799:13

write [2] - 2806:34,

2820:19

writing [1] - 2801:31

Y 2835:18, 2857:6,

2877:18

year [46] - 2787:16,

W 2794:33, 2794:47,

2795:1, 2795:17,

2797:32, 2798:7,

wait [2] - 2787:40, 2798:27, 2798:30,

2806:47 2799:21, 2799:33,

Wales [16] - 2785:23, 2799:41, 2800:12,

2821:38, 2823:10, 2801:22, 2801:26,

2823:14, 2823:31, 2806:1, 2816:43,

2824:4, 2824:22, 2828:4, 2833:30,

2824:27, 2824:35, 2836:23, 2837:10,

2824:45, 2825:1, 2842:25, 2846:12,

2825:22, 2825:29, 2847:6, 2847:22,

2825:33, 2845:40, 2847:23, 2848:18,

2850:26 2851:4, 2853:47,

walked [3] - 2790:8, 2854:10, 2854:32,

2790:10, 2790:12 2854:37, 2854:40,

wants [1] - 2855:2 2854:43, 2854:44,

WAS [1] - 2889:36 2854:46, 2855:1,

ways [2] - 2794:19, 2855:30, 2855:42,

2820:8 2855:44, 2857:15,

WBI [251] - 2786:10, 2865:7, 2877:42,

2786:32, 2787:6, 2877:43, 2884:18

2787:43, 2787:45, years [6] - 2798:39,

2788:4, 2788:13, 2826:9, 2841:10,

2788:18, 2788:32, 2858:11, 2865:30,

2788:38, 2788:42, 2882:5

2788:46, 2789:16, yes/no [2] - 2811:19,

2789:25, 2789:39, 2862:23

2789:40, 2790:24, Young [41] - 2845:38,

2791:24, 2791:28, 2857:16, 2857:22,

2791:34, 2791:41, 2857:37, 2861:13,

2792:4, 2792:14, 2861:18, 2862:3,

2792:22, 2792:29, 2865:7, 2865:25,

2792:32, 2793:9, 2865:27, 2866:10,

2794:23, 2794:32, 2866:30, 2866:44,

2794:45, 2795:4, 2867:21, 2867:24,

2795:8, 2795:26, 2867:33, 2868:7,

2795:35, 2796:18, 2868:8, 2868:12,

2796:23, 2796:26, 2869:30, 2870:33,

2796:29, 2796:33, 2870:38, 2870:39,

2797:27, 2797:31, 2871:10, 2871:23,

2797:47, 2798:23, 2871:38, 2872:8,

2798:35, 2799:27, 2872:25, 2872:43,

2800:31, 2801:42, 2873:17, 2873:34,

2802:7, 2802:16, 2874:12, 2874:17,

2802:35, 2803:3, 2874:21, 2874:22,

2803:5, 2803:21, 2874:23, 2874:30,

X 2803:30, 2804:5, 2874:35, 2874:47,

2804:9, 2804:32, 2875:16, 2875:30

XIONG [2] - 2815:24,

2815:25

Xiong [2] - 2815:10,

2815:35

XUONG [2] - 2815:13,

2815:23

2804:34, 2804:41, Young's [1] - 2868:3

2805:4, 2805:30, yourself [6] - 2789:26,

2806:16, 2806:20, 2792:13, 2792:14,

2806:26, 2806:27, 2792:21, 2805:3,

2806:30, 2807:13, 2861:32

2807:14, 2807:15,

2807:16, 2807:37,

2807:38, 2807:46,

Documents

Note: Copyright in this transcript is reserved to the Department of … · 2018. 1. 9. · .13/10/2017 (25) 2787 R G COLLINS (Mr Cheshire) Transcript produced by DTI 1 2 EXHIBIT #25