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Chapter 2
The reform agenda of the
Council of Australian Governments
2.1
In 2008,
Council of Australian Governments (COAG) launched the Directors' Liability
Reform Project as part of its National Partnership Agreement to Deliver a
Seamless National Economy. The project followed a series of reviews into
personal liability on directors for corporate fault. This chapter provides a
chronological overview of the respective reviews and key developments in
relation to directors' liability. It also details the COAG reform agenda
process and the timeline for directors' liability reform.
Senate Standing Committee on Legal
and Constitutional Affairs—1989
2.2
In its
November 1989 report titled Company Directors' Duties, the Senate
Standing Committee on Legal and Constitutional Affairs detailed a trend towards
imposing personal liability on directors for corporate fault.[1]
In evidence to the committee, Professor Brent Fisse, then professor of law at
Sydney University, noted that the present law provides 'for both individual and
corporate liability but makes no attempt to achieve a well-balanced mix; the
balance in fact achieved depends on the vicissitudes of prosecutorial
discretion'.[2]
The committee recommended further consideration of an appropriate balance of
individual and corporate liability for corporate misconduct.[3]
Corporate
Law Reform Program—1997
2.3
In 1997, a
Corporate Law Economic Reform Program paper recognised a 'growing trend for
legislatures to impose strict personal liability upon directors of corporations
for breaches of statutory obligations by the corporation'.[4]
The paper noted the potential ramifications of this trend:
...if directors risk personal liability for breaches incurred
by the corporation, irrespective of the directors' culpability, they may be
increasingly reluctant to serve on boards or may become overly concerned with
compliance issues and processes rather than wealth creation. Certainly, it
would be an unfair and unnecessary burden on directors if they can potentially
be made responsible for breaches by their corporation, even where they have
taken all reasonable steps to prevent such breaches.[5]
2.4
The review
body recommended consideration of the appropriateness of developing a standard
or model due diligence defence for directors in cases where they are
effectively subject to strict liability under statutes other than the
Corporations Law.[6]
Australian
Law Reform Commission—2002
2.5
In its 2002
report Principled Regulation, the Australian Law Reform Commission
(ALRC) found that there had been an increasing trend towards provisions that
'deem directors and other senior corporate officers personally liable for a
contravention where the body corporate has contravened the legislation and may
also be held liable for such a contravention'. The ALRC concluded that:
This
represents a departure from accessorial liability as proof of knowledge of or
involvement in the contravention is not an essential element; generally,
involvement in the management of the body corporate will be sufficient.[7]
2.6
The ALRC
noted in this regard that the effect of section 8Y of the Taxation
Administration Act 1953 is to 'reverse the onus of proof' as an officer may
escape liability if he or she can prove that he or she was not 'directly or
indirectly knowingly concerned in, or party to' the relevant act or omission
and did not 'aid, abet, counsel or procure the particular act or omission'.
2.7
The ALRC made
a number of recommendations of which Recommendations 8-1, 8-2 and 8-4 were
later considered by the 2008 Corporations and Markets Advisory Committee
(CAMAC) as an integral part of a model provision it recommended. These three
ALRC recommendations are as follows:
Recommendation
8-1—The Regulatory Contraventions Statute should provide that any provision in
legislation that deems an individual to be personally liable for the
contravening conduct of a corporation should define the individual who may be
liable as an individual (by whatever name called and whether or not the
individual is an officer of the corporation) who is concerned in, or takes part
in, the management of the corporation and includes an individual:
(a) who makes, or
participates in making, decisions that affect the whole, or a substantial part,
of the business of the corporation; or
(b) who has the
capacity to affect significantly the corporation’s financial standing; or
(c) in accordance
with whose instructions or wishes the directors of the corporation are
accustomed to act (excluding advice given by the individual in the proper
performance of functions attaching to the individual’s professional capacity or
his or her business relationship with the directors or the corporation).[8]
Recommendation
8-2—The Regulatory Contraventions Statute should provide that, in the absence
of any clear, express statutory statement to the contrary, any legislation that
deems an individual to be personally liable for the contravening conduct of a
corporation should include a fault element that the individual knew that, or
was reckless or negligent as to whether, the contravening conduct would occur.[9]
Recommendation
8-4—The Regulatory Contraventions Statute should provide that, in the absence
of any clear, express statutory statement to the contrary, any provision in
legislation that deems an individual to be personally liable for the
contravening conduct of a corporation should include as a threshold test for
liability that:
(a) the
individual failed to take all reasonable steps to prevent the contravening
conduct; and
(d) the
individual was in a position to influence the conduct of the body corporate in
relation to the contravening conduct.[10]
Taskforce
on Reducing the Regulatory Burdens on Business—January 2006
2.8
In its
January 2006 report, the Taskforce on Reducing the
Regulatory Burdens on Business highlighted the inconsistencies across
jurisdictions in provisions imposing personal liability on company directors
and officers for corporate fault. It recommended that COAG initiate reviews to
identify reforms to achieve 'more nationally consistent regulation of personal
liability for company directors and officers'.[11]
2.9
The Taskforce
received evidence from companies that the personal liability attached to a
number of directors' duties had led to a 'very conservative approach by some
directors to the detriment of business development'.[12]
In recommending that the Australian Government review the penalties for
breaches of directors' duties, the Taskforce commented that:
While the
Taskforce supports the deterrent value of penalties for breaches of regulatory
obligations, it is important that the use of penalties strikes an appropriate
balance between promoting good behaviour and ensuring business is willing to
take sensible commercial risks. A risk-averse approach by business may limit
their willingness to adopt innovative approaches in developing products and
meeting new challenges. It would also be reflected in an overly cautious
approach to compliance such as in product disclosure statements. This would
undermine the overall efficiency and dynamism of the economy.[13]
Corporations
and Markets Advisory Committee—September 2006
2.10
In September
2006, CAMAC reviewed the circumstances in which directors and other individuals
involved in managing a company can incur personal criminal liability in
consequence of misconduct by the company. It identified two principal areas of
concern:
- a marked
tendency in legislation across Australia to include provisions that impose
personal criminal sanctions on individuals for corporate breach by reason of
their office or role within the company (rather than their actual acts or
omissions) unless they can establish an available defence; and
- considerable
disparities in the terms of personal liability provisions, resulting in undue
complexity and less clarity about requirements for compliance.[14]
2.11
CAMAC raised
concerns regarding legislation which in effect deems an individual to be
criminally responsible for a breach by a company of a statutory requirement. It
emphasised the need to distinguish an individual's criminal liability for
his/her own misconduct in a corporate context from an individual's criminal
liability in consequence of misconduct by a company.
2.12
In raising
concerns with the latter context, otherwise termed 'derivative liability',
CAMAC noted that the 'usual pattern in these statutes is to hold the individual
criminally liable in consequence of the corporate misconduct unless he or she
can prove one or more of the defences set out in the legislation'. Derivative
liability arises without the need to establish that 'these persons either
breached the law through their own misconduct or were accessories to the
misconduct of their corporation'.[15]
The CAMAC report highlighted concerns with:
...the
practice in some statutes of treating directors or other corporate officers as
personally liable for misconduct by their company unless they can make out a relevant
defence. Provisions of this kind are objectionable in principle and unfairly
discriminate against corporate personnel compared with the way in which other
people are treated under the law.[16]
2.13
CAMAC held
that as a general principle, 'individuals should not be penalised for
misconduct by a company except where it can be shown that they have personally
assisted or been privy to that misconduct, that is, where they were
accessories'.[17]
2.14
In
highlighting the lack of legislative consistency across the Commonwealth,
states and territories, CAMAC stated that the differences in legislative
approach and the consequential lack of harmony result in a situation whereby:
Directors
and other individuals may be subject to differing standards of responsibility
with divergent defences available to them under various statutes that affect
the operations of their company in different jurisdictions. This very lack of
harmony can impair ready communication of statutory requirements and effective
compliance efforts.[18]
2.15
CAMAC recommended
a more consistent, principled approach to personal liability across
Commonwealth, state and territory jurisdictions. It called for a more
standardised approach and considered three models to that end. Recognising that
a legislature may see the need to impose on relevant corporate personnel 'a
more positive duty of care in regard to corporate conduct that may be derived
from ordinary principles of accessorial liability', CAMAC identified three
criteria for assessing the elements of any extended personal liability
provision—practicality and fairness, suitability and enforceability.[19]
The criteria were applied in relation to the following three possible model
provisions:
1.
A model provision based on the ALRC's 2002 report
2.16
This model
combines the ALRC recommendations (8-1, 8-2 and 8-4 listed above) in a
provision similar to that in the Environment Protection and Biodiversity
Conservation Act 1999 and Hazardous Waste (Regulation of Exports and
Imports) Act 1989 that impose personal liability for corporate fault.
2.
A model provision reflecting the predominant pattern in current state and
territory provisions
2.17
This model
was rejected by CAMAC on the grounds that it lacks any personal fault element.
CAMAC held that this model places a 'considerable burden on any defendant, who
has to prove a defence on the balance of probability'.[20]
The model
states that were a corporation contravenes relevant legislation, 'any director
or other person who is concerned, or takes part, in the management of the
corporation is also liable unless the person proves that he or she:
- was
not in a position to influence the relevant conduct, or (if the person cannot
prove this defence) that he or she
- exercised
all due diligence to prevent the relevant conduct, or
- took
all reasonable steps to prevent the relevant conduct.[21]
3.
A model provision based on section 144 of the Victorian Occupational Health and
Safety Act 2004 [22]
2.18
While CAMAC
saw merit in the provision for setting out factors for a court to take into
account in determining a person's guilt in consequence of corporate misconduct,
it considered the provision 'too open-ended in the way it ties criminal liability to
failure to take reasonable care'.[23]
Where an
offence committed by a body corporate is attributable to an officer of the body
corporate failing to take reasonable care, that officer is also guilty of an
offence.
In
determining whether an officer of a body corporate is guilty of an offence,
regard must be had to:
- what
the officer knew about the matter concerned, and
- the
extent of the officer's ability to make, or participate in the making of,
decisions that affect the body corporate in relation to the matter concerned,
and
- whether
the contravention by the body corporate is also attributable to an act or
omission of any other person, and
- any
other relevant matter.
'Officer'
has the same meaning as in s 9 of the Corporations Act.[24]
CAMAC
recommended model
Where a
corporation contravenes relevant provisions, the prosecution must prove the
following physical and fault elements in any action against an individual based
on that individual’s position in the company in relation to that contravening
conduct:
-
the
individual, by whatever name called, was a director or other officer of the
corporation or otherwise took part, or was otherwise concerned, in the
management of the corporation, and
- the
individual was in a position to influence the conduct of the body corporate in
relation to the contravening conduct, and
-
the
individual knew that, or was reckless or negligent as to whether, the
contravening conduct would occur.
It is a
defence if the individual took all reasonable steps to prevent the contravening
conduct. The individual has an evidential burden to raise that defence, which the prosecution
would then have to negate beyond reasonable doubt.[25]
Treasury
discussion paper (2007)
2.19
In March
2007, Treasury issued a discussion paper titled the Review of Sanctions in
Corporate Law. This paper formed the basis for the review of civil and
criminal sanctions in the Corporations Act 2001 and the Australian
Securities and Investments Commission Act 2001 emanating from the
Regulation Taskforce recommendation to review penalties for breaches of
directors' duties.[26]
Survey
of directors–May 2008
2.20
Treasury, in
conjunction with the Australian Institute of Company Directors (AICD),
conducted a survey of 600 directors of S&P/ASX-200 companies to consider
the impact of current laws on decision making by directors. The survey provided
a sample of the views of Australia's estimated 2.1 million directors.[27]
The survey revealed that director liability, and personal liability in
particular, had a 'negative affect [sic] on board recruitment, retention and
decision-making'. Further, 78 per cent of those surveyed believed that the risk
of personal liability had caused them, or the board on which they sat, 'to
occasionally or frequently take an overly cautious approach to business
decision-making'. Of them, 64 per cent suggested that such an approach had
'inhibited an optimal business decision to a medium to high degree'.[28]
COAG
Directors' Liability reform project–November 2008
2.21
On 29
November 2008, COAG agreed to progress reform of personal criminal liability
for corporate fault across Australian law.[29]
The matter of directors' personal criminal liability was considered a serious
economic concern to the extent that it was included as a reform stream as part
of COAG's seamless national economy reforms aimed at promoting competition,
boosting productivity, improving labour mobility, and reducing business
compliance costs by removing unnecessary or inconsistent regulation.
2.22
Indeed, a
survey of its company director members conducted in November 2010 by the AICD
found that:
- 65 per cent
said they felt the risk of personal liability had caused them or a board on
which they sit to take an overly cautious approach to business decision-making
frequently or occasionally;
- more than 90
per cent of respondents said that the personal liability of directors had an
impact on optimal business decision-making or outcomes. Of these respondents,
42.4 per cent noted that this impact was marginal while 6.7 per cent
viewed the impact as severe; and
- more than 90
per cent of respondents were moderately to seriously concerned about the lost
time and opportunity costs for companies defending actions brought as a result
of automatic personal liability for directors, and corporate legal expenses
that would be incurred.[30]
2.23
The COAG
reform initiative commits all jurisdictions to establishing a nationally
consistent and principled approach to the imposition of personal liability on
directors and other corporate officers for corporate fraud. As part of the
reform agenda, COAG endorsed a three-step approach to reforming derivative
liability in Australia:
(a) COAG endorsed
principles to guide jurisdictions when imposing personal liability for
corporate fault. The principles concern personal liability provisions that hold
directors and other corporate officers criminally liable because an offence has
been committed by the corporation. Guidelines were also developed to provide
greater clarity and consistency in the way the COAG principles would apply.
(b) All
jurisdictions would undertake an audit of their legislation against these
principles and recommend amendments to bring them into line with the
principles. The outcomes of the respective audits by Commonwealth, states and
territories were collectively reviewed to ensure that the principles had been
applied appropriately.
(c) Jurisdictions
would commit to implementing the audit outcomes by introducing legislation to
make any necessary amendments to their laws by the end of 2012, and to apply
the COAG principles when drafting future legislation.[31]
COAG had set December 2012 as the deadline by which a legislative plan to
implement agreed reforms and legislation would be introduced.[32]
COAG
principles and guidelines
2.24
The six
principles for the imposition of personal liability for corporate fault were
endorsed by the Ministerial Council for Corporations (MINCO) in November 2009
and by COAG a month later. The Commonwealth, states and territories agreed to
apply the principles to existing legislation as well as to new legislation.
With over 700 different legislative provisions relating to personal criminal
liability of directors and corporate officers across the Commonwealth, states
and territories, the Assistant Treasurer and Minister Assisting for
Deregulation, the Hon. David Bradbury MP stated that application of the
principles is expected to:
- reduce, using
five of the jurisdictions implementing this reform as an example, the number of
underlying offences from 6,700 to 2,400—a reduction of over 60 per cent; and
- [almost] halve
the number of Acts which include directors' liability provisions, from 287 to
148.[33]
COAG
principles
2.25
The six COAG
principles are as follows:
(a) Where a corporation contravenes a statutory requirement, the corporation
should be held liable in the first instance.
(b) Directors
should not be liable for corporate fault as a matter of course or by blanket
imposition of liability across an entire Act.
(c) A 'designated
officer' approach to liability is not suitable for general application.
(d) The
imposition of personal criminal liability on a director for the misconduct of a
corporation should be confined to situations where:
-
there are
compelling public policy reasons for doing so (for example, in terms of the
potential for significant public harm that might be caused by the particular
corporate offending);
- liability of
the corporation is not likely on its own to sufficiently promote compliance;
and
-
it is
reasonable in all the circumstances for the director to be liable having regard
to factors including:
- that the obligation on the
corporation, and in turn the director, is clear;
-
that the director has the capacity
to influence the conduct of the corporation in relation to the offending; and
-
that there are steps that a
reasonable director might take to ensure a corporation's compliance with the
legislative obligation.
(e) Where
principle 4 is satisfied and directors' liability is appropriate, directors could
be liable where they:
- have
encouraged or assisted in the commission of the offence; or
- have been
negligent or reckless in relation to the corporation's offending.
(f) In addition,
in some instances, it may be appropriate to put directors to proof that they
have taken reasonable steps to prevent the corporation's offending if they are
not to be personally liable.
2.26
The
Explanatory Memorandum (EM) notes that the reform project aims to 'harmonise
the imposition of personal criminal liability for corporate fraud across
Australian jurisdiction'. In its 2009-10 performance report, the COAG Reform
Council highlighted the following 'significant' risk to the achievement of the
output of the reform:
based on
a preliminary review of the jurisdiction audits that have been finalised, the
council is concerned that the directors' liability principles have been applied
in a way that raises significant risks to the achievement of the
principles-based approach of this reform.[34]
2.27
Noting that
the reform was being pursued to provide greater certainty for companies, their
corporate officers and the public as to when a corporate officer may be
personally criminally liable because of a company's misconduct, the COAG Reform
Council emphasised that the application of a consistent set of principles for
the imposition of the liability by the Commonwealth, states and territories
should provide more certainty for companies. However, its initial review of the
audits indicated that:
jurisdictions
have broadly interpreted the threshold principle of 'compelling public policy
reasons' to justify the retention of a significant number of different
provisions, based on specific jurisdictional priorities and existing
legislative schemes. In addition, it seems that, in some instances, this
'public policy' threshold is being considered as the preeminent principle, with
less regard to whether—once this threshold has been met—the form of liability
imposed is consistent with the other principles.[35]
2.28
In
conclusion, the COAG Reform Council stated that it considers:
that it
will not be possible to achieve a nationally consistent approach to
directors' liability if the principles are applied in varying ways by each
jurisdiction. It will not be possible to achieve a principles-based approach
to directors' liability if there are instances where all of the principles are
not applied in considering the retention, amendment or repeal of the relevant
legislative provisions.[36]
Centro
case (June 2011)
2.29
On 27 June
2011, the final decision in the Centro case provided new impetus for change to
directors' liabilities.[37]
In the case, the Federal Court found that six non-executive directors of the
Centro Group were in breach of their statutory duty of care and diligence under
the Corporations Act 2001. The case concerned the role and
responsibilities of directors in relation to financial reporting. It found that
Centro's financial statements failed to properly classify certain interest
bearing liabilities as $1.5 billion of current (short-term) liabilities were
classified as non-current (long-term) liabilities and guarantees of US$1.75
billion of an associate's short-term debt were not disclosed. Similarly, the
2007 accounts of Centro Real Estate failed to disclose $500 million of
short-term liabilities that had been classified as non-current.[38]
2.30
Justice
Middleton found that in approving the financial statements, each director
failed to take all responsible steps required of them to exercise the care and
diligence the law requires of them.[39]
COAG
guidelines
2.31
COAG engaged
Corrs Chambers Westgarth to examine the audits conducted by all jurisdictions
to ascertain where they accurately applied the COAG principles. In August 2011,
Corrs Chambers Westgarth published an independent analysis of the application
of COAG's principles by each jurisdiction and found that, among other things,
many jurisdictions 'overwhelmingly relied on the Public Policy principle to
justify the retention of the provisions reviewed' but that their audits did not
explain the public policy reasons relied upon or where they did provide
reasons, establish a 'compelling or convincing basis for retaining the
provision'.[40]
The COAG Reform Council acknowledged the findings of the Corrs Chambers
Westgarth report and recommended that COAG utilise the findings to advance the
reform process.[41]
2.32
At the
request of COAG, its Business Regulation and Competition Working Group (BRCWG)
developed a set of supplementary guidelines to assist jurisdictions in auditing
their legislation against the COAG principles. On 25 July 2012, COAG agreed to
apply these guidelines when drafting future legislation.
2.33
In August
2011, following concerns raised by the COAG Reform Council in its performance
reports, the Minister Assisting on Deregulation, Senator the Hon. Nick
Sherry announced that all states and territories would be required to re-audit
their laws against the COAG principles and the specific guidelines. Thereafter,
they would have to amend their laws.[42]
New milestones and timeframes were introduced. COAG set the final milestone in
the implementation plan to require jurisdictions to develop a 'legislative plan
to implement agreed reforms and introduce legislation by December 2012'.[43]
However, of the milestone, the Minister stated that:
The final
milestone in the Seamless National Economy Implementation Plan will be to
introduce legislation by December next year and I'm sure the States and
Territories acknowledge that business expects them to have legislation passed
by this time.[44]
2.34
Four months
later, the COAG Reform Council reiterated its concern that the intended reform
may not be achieved:
The
council remains concerned that the intended output of this reform—a nationally
consistent and principled approach to the imposition of personal criminal
liability of directors or other corporate officers for corporate fault—is at
risk of not being achieved.[45]
BRCWG
collective review of audit reports—March 2012
2.35
In March
2012, a sub-committee of the BRCWG was formed which initiated a collective
review of individual audit reports to ensure that all jurisdictions had applied
the COAG principles and guidelines consistently. In June 2012, the final
outcomes of the audits and collective review were reported to the BRCWG. The
Treasury, which was part of the discussions for the Commonwealth, noted that
the collective review had identified a number of areas where consensus between
jurisdictions was required:
For
example, the Principles contemplate that personal criminal liability for
corporate fault may be appropriate in circumstances where an offence has the
potential to cause serious public harm. A general consensus was reached as to
the types of serious public harms for which the imposition of personal
liability was justified. This consensus ensures that, after all jurisdictions
amend their legislation to bring them into alignment with the Principles and
Guidelines, personal criminal liability for corporate fault will only be
imposed where an offence risks a serious public harm occurring, and will be
imposed consistently across jurisdictions.[46]
2.36
Similarly,
consensus was reached in relation to the provision that a defendant would only
be subjected to a burden of proof where justified under the COAG principles and
guidelines. Furthermore, where there were areas of thematic overlap across
jurisdictions such as laws that provide protection for vulnerable persons,
'subsequent discussions between jurisdictions ensured that the material
differences between the ways in which jurisdictions had approached the auditing
process or had interpreted the Principles or Guidelines were largely resolved'.[47]
Nevertheless, Treasury noted that:
This does
not mean that provisions that impose personal criminal liability for corporate
fault will necessarily be identical across jurisdictions. Variations in the
drafting of provisions that impose such liability may remain both within and
between jurisdictions. However, the passage of this Bill, in conjunction with
the passage of similar Bills in the States and Territories pursuant to the
reform of directors’ liability under the SNE NP, should ensure that across
Australia, personal criminal liability for corporate fault is imposed in
accordance with the COAG Principles and Guidelines and in a manner consistent
with the principles of good corporate governance and criminal law.[48]
Implementation
across the states and territories
2.37
In June 2012,
all jurisdictions 'indicated that they will seek to introduce an omnibus Bill
to implement all or most of the audit outcomes by December 2012'.[49]
2.38
According to
the COAG Reform Council, there are over 700 state and territory laws imposing
personal liability on the 2.1 million Australian company directors.[50]
In 2010, the AICD reported that Western Australia had the highest number of
laws imposing personal liability on directors with 139 followed by NSW with 134
and Queensland with 106.[51]
2.39
On 31 July
2012, the NSW government released a Memorandum formally adopting the COAG
guidelines as NSW policy and announced that it would implement the outcomes of
its audit of existing NSW Acts against the guidelines by the end of 2012.[52]
The proposed amendments add to reforms already implemented by the NSW
government in 2001 in the Miscellaneous Acts Amendment (Directors'
Liability) Act 2011. The reforms are expected to reduce the number of NSW
offences to which directors' liability provisions apply from over 1000 to less
than 150.[53]
2.40
NSW was the
second jurisdiction to take steps to implement the directors' liability reforms
after the ACT.[54]
2.41
In
Queensland, Premier the Hon. Campbell Newman stated that there are over 3800
offences for which a director can be held personally liable for acts undertaken
by their company with or without their knowledge. Premier Newman noted that the
reforms being considered 'will mean a director will only be personally liable
if they encourage or assist in the commission of an offence or they have been
negligent regarding its commission'.[55]
The Premier highlighted that the reforms would reduce the number of offences
for which a director can be held personally liable would be cut by half.[56]
Queensland Attorney-General, the Hon. Jarrod Bleijie announced that legislation
addressing company directors liabilities would be introduced before the end of
the year.[57]
He highlighted that '[C]onsistency of approach to directors' liability across
Australia is paramount'.[58]
Exposure
drafts of the bill
2.42
As part of
the Commonwealth's fulfilment of its obligations to the COAG reform agenda,
Treasury released three exposure drafts of the Personal Liability for Corporate
Fraud Reform Bill 2011 (the bill being examined by this report) in January,
June and August 2012 and engaged in a consultation from 27 January 2012 to 3
September 2012.
2.43
The bill
includes many of the provisions originally contained in the exposure drafts and
is largely an amalgamation of the three exposure draft bills. Treasury noted
the following in relation to the consultation process:
The
Commonwealth Treasury carefully considered the matters raised in the
consultation process before advising the Government. Furthermore, the
development of Commonwealth’s revised audit outcomes and the Bill also had
regard to the CRC Report and the analysis it commissioned from Corrs Chambers
Westgarth on the application of the COAG Principles by each jurisdiction in
relation to an initial audit of all Australian legislation.[59]
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