Other matters considered
This chapter canvasses other matters considered by the committee
including management of resource and service agreements, contract management, performance
reporting and accountability of DPS to the Parliament.
Management of resource and service agreements
The inquiry terms of reference included consideration of resource
agreements and/or memoranda of understanding for the provision of services
within and by DPS. The committee received very little information on these
matters. The following provides an overview of arrangements entered into by
DPS has three resource agreements in place:
- DPS and Australian Federal Police (AFP) security services
agreement: this agreement has been in place for over 20 years for the AFP to
provide external perimeter security for Parliament House. DPS pays the AFP
around $10 million per year for this service;
- DPS and the Department of the House of Representatives: under
this agreement the Department of the House of Representatives provides, and is
paid for provision of, payroll services to DPS; and
- Secretary, DPS, and the Parliamentary Librarian: this agreement
specifies the annual level of funding for the Parliamentary Library.
The former arrangement between Department of Finance and Deregulation
(Finance) and DPS IT helpdesk has now been superseded by the transfer of
electorate office IT to DPS.
DPS advised that it has seven main areas of services:
library and research services;
- parliamentary records services (including Hansard and
- information and communication technology (ICT) services;
- security services;
- building services and amenities (including building operations
and maintenance, heating, cooling, catering, cleaning, landscape maintenance
and events management);
- visitor services; and
- support services (including project/capital works management, as
well as finance, HR and procurement).
The DPS Services Catalogue outlines the services provided by DPS and how
senators, members and staff access them.
Commenting on service levels, Mr Andrew Podger, former Parliamentary
Service Commissioner, stated:
Some articulation in agreements or memorandums of
understanding of the service levels expected from a common provider can be
helpful to clarify expectations and to promote proper monitoring and
evaluation. But there are dangers in taking such formalities too far, in
encouraging the sense that one department (or one part of DPS) is purchasing
services from another and has concomitant power over the service provider.
Agreements should promote collaboration including shared learning from
performance reviews. The Parliamentary Service is too small to benefit from
formal purchaser/provider contracts between or within departments.
Two of the largest on-going contracts managed by DPS are the catering
and cleaning contracts. The following provides a overview of the contacts and
their management by DPS as many aspects of the contracts relate to
External cleaning of the building is undertaken by Canberra Queanbeyan
Cleaning Services (CQCS). Limro Cleaning Services (Limro) undertakes the
general cleaning of the inside of the building.
Limro was first awarded the contract for cleaning at Parliament House in
1988. The contract has been renewed on several occasions, the last being 2003. The
current expiry date of the Limro contract is up to 2018. Its current value is
The committee sought information about the Limro cleaning contract at
its hearing on 30 October 2012. Ms Carol Mills, Secretary, DPS, stated that DPS
has sought information in the past as to whether the contract could be altered
or a new contract could be formed, and whether there were ways in which the
contract might be effectively managed. Ms Mills stated that 'the advice that we
have received, at least in recent years, has been that the contract that was
put in place in 2003 has limited possibility for us to change until its expiry
date', that is, 2018.
In addition, DPS had commissioned Knight Frank in 2009 to audit cleaning
services including the DPS management team and systems associated with the
management and administration of the contract, a physical audit of Parliament
House and a contractor audit. Knight Frank identified a number of areas which
were 'challenges' for DPS in contract management.
Knight Frank also provided recommendations to DPS, including that no further
extensions be granted to Limro Cleaning Services 'beyond the current extension
expiry date of 30 June 2011'.
Following receipt of the review, DPS sought legal advice as to whether
it could terminate the contract. However, in April 2010 the contract was
extended to 30 June 2014.
In relation to concerns about damage to the fabric of the building from
inappropriate cleaning methods, DPS stated:
Some general surface damage through bathrooms has been
identified related to the use of inappropriate cleaning products, scourers and
processes. This is generally as a result of cleaners trying to clean large
areas in short time frames. The use of environmentally friendly products is
recommended at Parliament House; however, they generally do take more time to
use. On occasion when the cleaners are meeting deadlines, it is evident that
unapproved products are used. DPS has improved consultation, induction and
supervision of the internal cleaning contract in an effort to reduce future
DPS also outlined other areas where there has been concern about damage
to the fabric and/or contents of building and the action taken:
External stone paving: high pressure hosing of the external stone
paving has resulted in damage to the jointing. In July 2012, external stone
cleaning procedures were revised to ensure best practice. In addition, the use
of high pressure hosing reduced to its lowest pressure setting has been
trialled and DPS indicated that this should reduce any ongoing damage;
- Internal stonework: some efflorescence and staining were evident
on internal stonework, due to use of unclean water. Best practice cleaning
procedures, using distilled water, were introduced in June 2011 and there has
been an improvement in these surfaces. DPS noted that distilled water is
expensive and can be difficult to store in adequate quantities and, as a result,
the cleaners have substituted tap water. DPS is currently trialling the
production and use of reverse osmosis water;
Ewater: Ewater is an electrolysed water cleaning product
introduced into the new kitchens. Its use is primarily as a sanitising agent
for foodstuffs as well as for cleaning kitchen preparation surfaces. The use of
this products as a cleaning agent was extended beyond the kitchen spaces
against the recommendations of specialist curators working in APH and the DPS
furniture managers. This is because Ewater's acid and alkaline levels are too
high to be used on building fabrics–long term use could cause damage.
Permission for the widespread use of this product has been withdrawn;
- Chipped stone: the facades are chipped as a result of the impact
on the stone by machinery used to clean or maintain external facades and this
practice is being reviewed;
- Brass work: in the past, the cleaners were found to be
responsible for damage to brass work. DPS Building Fabric Services section has
been working with the cleaners over the last three years to better understand
the patina of the brass work and, since this time, damage has ceased. The
patina will redevelop over time; and
- Carpet shrinkage: there have been some incidents over the last
few years where cleaners have over-wet carpets, resulting in shrinkage.
Ms Mills indicated that there had been more 'active management' of the
contract in recent times including working with the contractor to rectify
cleaning methods which have damaged the fabric of the building as noted above. DPS
noted that it had issued 14 breach notices to Limro since August 2009.
Ms Mills concluded:
I believe that the department has improved its management of
the contract. The reality remains that the contract is not as robust as one
might like in terms of performance indicators. There certainly appear to be
relatively few mechanisms for us to deal with it if we had a very serious
issue, but we are certainly more focused on working with the cleaning company
to provide consistently high service across the building.
On 1 July 2008, DPS entered a contract with IHG to provide event
catering in Parliament House and with W Catering to provide catering in the
Staff Dining Room and Queen's Terrace Café. From 1 July 2010, all catering in
Parliament House has been provided by IHG following the termination of the
contract with W Catering. A new contract with IHG was entered into in January
2012. The new contract consolidated IHG's original contract for event catering
and the catering in the Staff Dining Room and Queen's Terrace Café which IHG had
taken over from W Catering on an temporary basis. The IHG contract has an
expiry date of 2017 but has the potential to run to 2022, that is 10 years.
Ms Mills stated that IHG had approached DPS with a proposal to combine the
contracts. A catering consultant had indicated to DPS that it was an effective
proposal and contract negotiations were completed in December 2011.
As part of the previous contract with IHG, there was a cost
reimbursement that related to the 'difference between the revenues they
generate at the counter compared with the total costs'. At the February 2011
Additional Estimates this was stated as being around $700,000 to $800,000 per
Following the 30 October hearing, DPS indicated that:
The catering contractor is not paid a subsidy. The contract
provides for DPS to pay the catering contractor an annual management fee of
$530,000 per annum ex-GST (CPI indexed from 1 July each year). The management
- services provided by the contractor to the Parliament. The
contract requires the contractor to cover the costs of the set-up of
parliamentary funded activities (including CERHOS in the Great Hall), up to 220
events per calendar year. If the number of events exceeds 220 per calendar
year, DPS pay the contractor at a rate of 0.1% of the management fee for each
additional event; and
- the challenges of operating at Parliament House (such as
irregular trade, requirement to give precedence to parliamentary activities,
security and other requirements).
Payment of the management fee in full is contingent on the
contractor meeting key performance indicators set out in the contract. Up to 50
per cent of the management fee can be withheld. In accordance with transition
in plan set out in the contract, for the first year of the contract (2012), DPS
will pay the management fee in full.
The 2012 client survey indicated a lack of satisfaction with catering
services, mainly in the Staff Dining Room, including variety of food and
DPS pointed to the difficulties of catering in APH – the cyclical nature and
the logistics of bringing food into the building including vetting through the
Ms Mills also added her view:
It is certainly clear that, over an extended period, catering
contracts at this building have not always worked effectively. Inevitably, as
you suggested, with the peak and trough, it is virtually essential to have some
type of subsidy built in and some kind of incentive for contractors to come
here—similar to other parliament houses. My understanding is that, in a very
early period, it was an in-house contractor, and a decision was made fairly
early on to go to an outsourced model. That in itself is not uncommon.
Certainly across the houses of parliament in Australia there is a mixed set of
arrangements. So it has always been complicated.
Ms Mills also noted that the same model had been utilised for a number
of years with the outcome being a compromised response. Ms Mill went on to
state that other ways of delivering catering services had not been explored and
there is a need to review the model periodically.
The committee did not explore in any great detail the cleaning or
catering contracts. However, the committee considers that, even on the little information
received, it would appear that DPS (and JHD in relation to the cleaning
contracts) has shown poor contract development and management. In particular,
the committee notes the long time periods before contracts have been
re-negotiated or have been put out to competitive tender, the lack of
flexibility in contracts and deficiencies in the management of contracts by DPS.
The committee notes DPS's comments that indicate that management of the
cleaning contract has improved. However, it is concerned that inappropriate
cleaning practices have damaged the fabric of the building.
Accountability of DPS to the Parliament
A matter considered by the committee was the accountability arrangement
for DPS. The discussion below canvasses the governance arrangements for DPS
including the role of the Presiding Officers and the bodies which assist and
advice the Presiding Officers as well as performance reporting through annual
reports. The committee's conclusions on accountability arrangements are
provided in chapter 10 of the report.
The Parliamentary Service Act 1999 provides for the establishment
of the parliamentary departments. Section 57 provides for the responsibility
for managing a department:
(1) The Secretary of a
Department, under the Presiding Officers, is responsible for managing the
Department and must advise the Presiding Officers in matters relating to the
(2) The Secretary of a
Department must assist the Presiding Officers to fulfil the Presiding Officers'
accountability obligations to the Parliament and provide factual information,
as required by the Parliament, in relation to the operation and administration
of the Department.
The DPS annual report states that the Presiding Officers have joint
powers in relation to DPS that are similar, but not identical, to those of a minister
administering an executive department.
In this role, the President of the Senate appears before the committee during
estimates with DPS.
Former President, Senator the Hon. Paul Calvert, explained his understanding
of the role of the Presiding Officers in relation to DPS and stated:
It is not the Presiding Officers' role to interfere with the
DPS. We are presiding officers and we do not interfere with the chamber
departments or the DPS. If you look at the [Parliamentary Service Act], it
points out that the only hands-on role in the DPS that we provide is appointing
The committee does not share this view. While the committee notes that
the Secretary of DPS is the administrative head of the department, the
Parliamentary Service Act provides the Presiding Officers with responsibility
for DPS along the lines of a minister: DPS is responsible to the Parliament
through the Presiding Officers.
In undertaking their role in relation to DPS, the Presiding Officers are
assisted by the:
- Joint House Committee: a House committee is established under the
standing orders of each House. The two committees may sit as a joint committee
with the senior Presiding officer as the chair. The committee considers any
matter relating to the provision of facilities in Parliament House for example,
security works, IT, parking and catering. Matters to be considered may be
referred by the Senate, House of Representatives or the Presiding Officers. The
committee met twice in 2010–11;
- Joint Standing Committee on the Parliamentary Library: a Library
committee is established under the Parliamentary Service Act. The committee has
joint chairs and considers any matters related to the provision of library
services to parliamentarians;
- Art Advisory Committee: assists the Presiding Officers in
determining the suitability of artworks for addition to the Parliament House
Security Management Board: provides advice to the Presiding
Officers on security policy and the management of security measures for Parliament
- Heritage Advisory Board: provides advice to the Presiding
Officers on the heritage management of Parliament House.
DPS also noted that DPS officers regularly meet with House of
Representatives Committee on Appropriations and Administration.
In relation to ICT matters, the Presiding Officers' Information
Technology Advisory Group (POITAG) has assisted the Presiding Officers. As a
consequence of the implementation of the recommendations of the Roche Review of
ICT for the Parliament, POITAG is to be abolished and replaced by the
Parliamentary ICT Advisory Board. A further development as a result of the
Roche Review will be the establishment of a joint appropriations and staffing
committee with oversight of the delivery of parliament-wide ICT services by
Senators and members comprise, or are included in, the membership of all
the above committees and boards except the Heritage Advisory Board and the
Security Management Board.
There are also two other coordination bodies: the Senior Management
Coordination Group (SMCG) and the Project Assessment Committee (PAC). The SMCG
is established to coordinate corporate and related matters among the three
parliamentary departments. DPS is represented by the Deputy Secretary. The
Department of the House of Representatives is represented by the
Serjeant-at-Arms, and the Usher of the Black Rod represents the Department of
the Senate. The position of chair of the SMCG rotates annually among the three
members. The PAC has the same membership as SMCG and is part of the formal
approval process for projects and makes recommendations on the prioritisation
and selection of projects based on a whole-of-parliament perspective.
The following figure provides an overview of the DPS governance
arrangements and groups advising the Presiding Officers. The committee notes
that the internal structure of DPS is currently under review and a number of
new bodies will be establishes as a result of the Roche Review.
Figure 9.1: Existing DPS
Note: in addition to the
arrangements indicated above, DPS appears at estimates hearings held by the
Senate Finance and Public Administration Legislation Committee.
Governance arrangement in other
The committee has identified a range of governance arrangements in other
parliaments and for iconic buildings.
- bodies directly engaged in governance:
- The Scottish Parliamentary Corporate Body (SPCB) is an example of
such an approach, being a statutory body, consisting of 5 members of the
parliament elected as individuals to represent the interests of all members and
not as party representatives. The SPCB provides staff, accommodation and
services for the Parliament. It meets fortnightly and agendas and minutes are
published on the Scottish Parliament website. The Presiding Officer chairs the
- Under the Parliament of
Canada Act, the Board of Internal Economy governs the House
Administration. It is responsible for all matters of financial and
administrative policy that affect the House and its Members, premises, services
and employees. It has the legal authority to make by-laws—which are tabled in
the House—to regulate the use of resources available to the House of Commons.
- The House of Commons Commission is responsible for the
administration and services of the House of Commons, including the maintenance
of the Palace of Westminster and the rest of the Parliamentary Estate. The
Commission provides the non-executive governance of the House by Members, but
it does not manage day to day operations. It has delegated this power to the
senior officials who make up the House of Commons Management Board. The Board
is responsible for the management of the services provided for the House of
Commons by the Departments of the House; and advising the Corporate Officer of
the House of Commons on the nature and level of services that should be
provided by joint departments of the two Houses.
independent skills-based entities to assist with the maintenance
of iconic buildings:
the Old Parliament House Advisory Council;
- the Official Establishments Trust advising on Government House
and The Lodge in Canberra, and Admiralty House and Kirribilli House in Sydney; and
- the Sydney Opera House Trust.
Annual reporting and the
examination of performance
The provision of annual reports is a significant mechanism for informing
the Parliament about the operation of departments and agencies and assisting
with the examination of the performance of those entities. The scrutiny of
annual reports is formalised in the Senate Standing Orders which provide that
legislation committees inquire into, and report upon, annual reports and the
performance of departments and agencies allocated to them.
The matters to be included in the annual reports of departments are set
out in the Requirements for Annual Reports for departments, executive
agencies and FMA Act bodies (the Requirements) issued annually by the
Department of the Prime Minister and Cabinet and approved by the Joint Committee
of Public Accounts and Audit. The Requirements list the specific information
required in annual reports. However, the Requirements also emphasise that
annual reports are an accountability mechanism and should 'provide sufficient
information and analysis for the Parliament to make a fully informed judgement
on departmental performance'.
The following discussion provides the committee's views on the adequacy
of DPS annual reports as reports on performance and as an accountability
Assessment of performance reporting
The committee has reviewed all of DPS's annual reports from the
establishment of the department in February 2004 to the most recent report for
the financial year 2011–12. The committee notes that the annual report for
2011–12 was not available for examination at the October 2012 Supplementary
Budget estimates but was tabled in the Senate by the due date on 30 October
2012. Ms Mills, the Secretary of DPS, apologised for the delay in tabling the
report and explained the reasons for that delay:
I feel as part of the changes that I am trying to make to the
organisation that the annual report as drafted did not meet some of the
expectations that I think are important for us in providing you with as much
information and clarity as possible about the organisation's delivery of
The committee welcomes Ms Mills' comments about the need to ensure that
the 2011–12 annual report provides sufficient information to analyse the
department's performance. The committee's review of the DPS annual reports from
previous years indicates that improvement in performance reporting is required
as a matter of priority. Indeed, since DPS was established, the quantity and
quality of information provided in annual reports has declined to such an
extent that the 2010–11 Annual Report is notable only by its level of opacity
and the extent of use of abstract data which is of no assistance in judging
performance. The committee also notes the comments of one submitter who stated that
there has been 'a long term practice of disguising the truth in the DPS Annual
The following highlights some of the deficiencies identified in DPS annual
The inclusion of a secretary's review is a requirement for annual
reports. The review is used to provide a summary of significant issues and
developments for the year. The first report for the full financial year
provided by DPS was that for 2004–05. The secretary's review included a
discussion of amalgamation issues, problems faced in the completing of the
construction program for security enhancement works and the outlook for the
department in 2005–06. In contrast, the secretary's review of 2010–11 provides
few insights into difficulties encountered during the reporting period. For
example, there are no comments regarding problems being experienced with the
completion of the upgrade of the Parliament House website which was
experiencing significant delays and increases in costs at that time.
Little information is provided about other major capital works being
undertaken by DPS in Parliament House. During 2010–11, DPS undertook a range of
security enhancement work including a security wall in the public car park.
Additional funding of $18.3 million was received to undertake this work. The
2010–11 Annual Report commented that 'upgrades to security infrastructure were
also a major focus during 2010–11' and included a new operations room, improved
security for the various garages, film on external windows and a security wall
in the public car park.
However, there are few other detail provided about the expenditure of $18.3
million of additional funds provided to DPS for security enhancements.
Another major project completed in 2010–11 was the DPS Staff
Accommodation project. Staff moved into the new accommodation in April and May
2011. The cost of the project was $5.11 million. Significant issues occurred
during the project as the building architect, Mr Romaldo Giurgola, raised
objections to the planned work and DPS failed to recognise that it should have
consulted Mr Giurgola in relation to moral rights requirements. As a
consequence, the project was delayed. The 2010–11 departmental overview lists
the management of the project as an achievement to consolidate DPS staff
and that two projects undertaken during the year 'were delayed to meet planning
and consultation requirements'.
No other discussion is provided in relation the accommodation project nor is
there any indication of the cost of the project.
In DPS's discussion on administered funds, one of the quality indicators
is the price indicator 'Extent to which building projects are completed on
budget' with the measure described as 'Projects are completed within approved
total budget (target: 100%)'. For the three financial years 2008–09 to 2010–11,
the annual report indicated that the target of 100 per cent of projects
completed within the approved total budget was met.
The committee considers such information to be of little use; it would be
expected that the budgets of all projects would be approved by the DPS Strategy
and Finance Committee (SFC). What is not indicated in the annual report is
whether the initial estimate of the cost of a project was met, or not, or
whether additional funds were allocated by the SFC. While it might be the case
that all projects undertaken by DPS were completed within the initial budget,
the committee considers that this is unlikely.
The lack of specific financial information in regard to major projects
is an obvious deficiency and is thrown into stark contrast by the information
provided about consultancies undertaken. A list of all consultancies valued at
more $10,000 was a mandatory requirement for departmental annual reports until
2012–13. DPS provided a list of 77 consultancies (total expenditure of $2.7
million) in its 2010–11 report but did not provide detailed information on
project expenditure of $23.4 million for security enhancements and the
Staff Accommodation project.
A further deficiency in relation to financial information is the
omission of discussion and analysis of the department's financial performance.
This is a mandatory annual reporting requirement. For all annual reports from
2005–06 to 2010–11, the compliance index references the DPS Financial
Statements for this item.
In some reports, for example, the 2008–09 Annual Report, limited commentary on
the department's financial performance has been provided in the Secretary's
This is less than adequate and does not provide the Parliament with a clear and
easily accessible analysis of the department's financial performance. For
example, in 2010–11, DPS recorded an operating deficit of $14.2 million, an
increase from the operating deficit of $25.5 million in 2009–10.
This is recorded in the department's financial statements. However, no
explanation is given for the deficit or the change recorded. The committee
points to the Department of Finance and Deregulation's reporting on financial
performance as a suitable model for the reporting of financial performance.
DPS annual reports have over a number of reporting periods identified,
but failed to adequately canvass, significant issues in relation to the fabric
of the building. Comments, for example, are made that the ageing of the
building is influencing the level of the Building Condition Index. Given that
the building is nearly 25 years old, that is only to be expected. However,
there is little frank discussion in annual reports about priority projects and
any difficulties being experienced in addressing ageing of systems, for example
funding and design integrity issues.
The committee is concerned that the annual reports do not provide
adequate commentary on some of the measures reported and lack clarity about
what is being measured. For example, the 2010–11 Annual Report states that
Maintenance Services achieved 89 per cent of the planned maintenance for the
There is no discussion about whether or not this level of maintenance is
adequate for a 25 year-old building with many unique systems and custom made fittings.
DPS annual reports provide the indices used to measure the condition of
the building. However, while the factors influencing the calculation of the
indices are provided, there is little or no discussion about the significance
of the factors identified. For example, a contributing factor to the decrease
in the Building Condition Index in the Ministerial Wing in 2009–10 was that
painting and carpet replacement was reduced in the general circulation area. No
commentary is provided as to why a decision has been made to paint and
re-carpet less frequently, the long-term effect, or whether or not the decrease
is a temporary measure.
DPS annual reports include a range of performance measures for many
services. While these are provided over a three year reporting period, often
there is little explanation of trends and the data provided does not allow for
an analysis of actual performance. For example, the quality indicators provided
for security services include 'extent to which procedures are followed' and 'validation
of security procedures'. While performance for these indicators have been
either 100 per cent, or close to it, for the three financial years to 2010–11,
there is no discussion about the adequacy of security measures being used in
Another area where it is difficult to identify trends is with complaints
about cleaning and catering. Prior to 2010–11, complaints for cleaning, catering
and other services were provided in subprogram 2.2.
The presentation of this data changed in 2010–11 with catering remaining under
program 2 and cleaning and other services moving to program 3.
While there may be valid reasons for this change, the committee considers that
disaggregated data should have been provided for previous years so that trends
could be identified.
Other areas of concern identified in reviewing the annual reports are
errors in calculations and lack of the provision of reasons for changes in data
from that provided in previous annual reports. For example, as part of its
review of program 4, parliamentary records services, the 2010–11 Annual Report
provides a quantity indicator for broadcasting services. For the Chambers, it is
stated that there were 1,138 hours of Chamber proceedings broadcast which,
while fewer than 2009–10 levels, was a '44% increases in the activity levels of
the previous election year (2007–08: 929 hours)'. Rather, this is a 22.5 per
cent increase over 2007–08, not 44 per cent as the incorrect financial year was
used in the calculation. Similarly, in relation to the recording of committee
proceedings of 1,961 hours in 2010–11, it is stated that there was an 81 per
cent increase over the previous election year (1,208 hours). This is an
increase of 63 per cent when comparing election years.
In some tables the data presented for previous annual reports is
different to that provided in the 2010–11 Annual Report. For example, in
relation to security provided for non-parliamentary functions, there are major
changes to the number of functions listed in the 2009–10 Annual Report as
Table 9.1: Security provided for non-parliamentary functions
2009–10 Annual Report
2010–11 Annual Report
Number of non-parliamentary
Source: DPS Annual Report 2009–10,
p. 38; Annual Report 2010–11, p. 46.
No explanation is provided in the 2010–11 annual report as to the
reasons why the numbers reported previously had changed.
The committee also notes that there should be a 'clear read' between the
Portfolio Budget Statements (PBS) and the annual report in regard to
performance information, for example, if there is a change in program
structure, the details should be provided. The committee has found that the DPS
annual report does not provide a 'clear read' with the PBS. For example, the
KPI 'Parliament House Works Programs: Extent to which design integrity is
preserved' is reported under Program 3 in the annual report but is under Program
5 in the PBS. The PBS contains, at sub-program 3.1, the deliverable 'Waste
volume reduced as a percentage of total waste generated'. This is not reported
on in the 2010–11 Annual Report.
There are also a number of less significant issues which should be
addressed to improve the quality of the DPS annual report including the
provision of a more comprehensive index.
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