Predatory pricing and the ACCC's investigation
This chapter examines:
- the issue of predatory pricing and the current thresholds in
statute that need to be met for a predatory pricing case to be successful; and
- the Australian Competition and Consumer Commission's (ACCC)
approach to publicly commenting on individual matters.
Two major issues that this inquiry was concerned about was the effect that
Coles' January 2011 private label milk price cuts had on the ability of its
direct competitors to compete with it, and the impact on other businesses that
may not ordinarily be in direct competition with Coles.
Predatory pricing occurs:
... when a company sets its prices at a sufficiently low
level with the purpose of damaging or forcing a competitor to withdraw from the
market. This leaves the company with less competition so it can disregard
market forces, raise prices and exploit consumers.
Under Australia's competition law, predatory pricing is addressed by
section 46 of the Competition and Consumer Act 2010 (CCA), although
the concept is not expressly mentioned in that section.
Subsection 46(1) of the CCA prohibits the misuse of market power. It has
a number of elements that need to be satisfied for it to be relevant. They are:
that the corporation has a substantial degree of power in a
that the corporation takes advantage of that power in that or any
other market for one of three proscribed purposes:
(a) eliminating or substantially damaging a competitor of the corporation or
of a body corporate that is related to the corporation in that or any other
(b) preventing the entry of a person into that or any other market; or
(c) deterring or preventing a person from engaging in competitive conduct in
that or any other market.
Subsection 46(1AAA), a relatively new provision that was inserted into
the CCA in November 2008, provides that if a corporation supplies goods or
services for a sustained period at a price that is less than the relevant cost
to the corporation of supplying the goods or services, the corporation may
contravene subsection 46(1) even if the corporation cannot, and might not ever
be able to, recoup losses incurred by supplying the goods or services.
A number of other provisions in section 46 provide guidance to the court
when considering alleged contraventions of the section.
Another element of section 46 that is relevant to predatory pricing is
subsection 46(1AA), more commonly referred to as the 'Birdsville Amendment'. Subsection
46(1AA) applies to a corporation that has a substantial share of a
market, as opposed to the prohibition in subsection 46(1) that refers to a substantial
degree of power in a market. The subsection prohibits these corporations
from supplying, or offering to supply, goods or services for a sustained period
at a price that is less than their relevant cost. However, it is similar to
subsection 46(1) in that it requires that the supply of goods or services is
for one of the three proscribed purposes noted earlier. To date, the Birdsville
Amendment has not been tested in the courts.
The ACCC summarised what forms of conduct may, in general, constitute
Predatory pricing has two key elements to it. Firstly, there
has to be a target. There must be an intention to predate someone. That is
different to someone suffering loss or harm as a result of the competitive
process. What the company with market power does must be targeted at a
competitor. It could be a particular competitor, it could be more than one
competitor but it must be targeted at someone. Secondly, it must have the
purpose of damaging whoever it is targeted at. It could be an existing
competitor, or it could be a potential new competitor. They are the two key
ingredients that we look for and what is in the legislation is really an
embellishment of those key ingredients.
These considerations are key as price discounting by companies can be
pro‑competitive. Legitimate price discounting can occur when large
companies pass on to consumers the benefits of lower costs or increased
efficiencies arising from reduced internal costs or better deals from suppliers.
The ACCC notes that predatory pricing can be difficult to prove. This is
because 'the initial signs of predatory pricing are pro-competitive and there
is often no written evidence of anti-competitive purpose with which an
allegation could be upheld'.
Section 46 differs from other provisions concerning general anti-competitive
conduct in the CCA, as the prohibition only relates to conduct that has the
'purpose', as prescribed by the section, of substantially lessening
competition. Other sections in that part of the CCA that do not prohibit
conduct outright include an allowance for the 'effect' (or likely effect) of
the conduct to be considered.
This difference is explored in more detail in chapter 7.
Initial calls for an ACCC investigation
The ACCC is an independent statutory authority formed in 1995 by the
merger of the Trade Practices Commission and the Prices Surveillance Authority.
The ACCC has responsibilities under a number of Commonwealth laws, but most of
its work relates to the administration and enforcement of the Competition
and Consumer Act 2010 (CCA).
A number of submissions and witnesses raised concerns that Coles'
conduct constituted predatory pricing (as well as other trade practices
We call on the ACCC to investigate the latest discounting by
Coles as a matter of urgency. We feel that there is probably predatory pricing
there. We feel that the ACCC needs to investigate the pricing practices of
Coles, including the guarantee that has been made to dairy farmers that they
will not be adversely affected. We do not believe that to be the case.
They are buying very strongly, they are selling at cost, they
are loss leading in regions, they are damaging milk value on the shelf and to a
degree they are damaging the milk value of their partners, the processors who
supply them and rely on branded milk to extract an average price from the
market. So I think that is where the issue is. They are abusing their market
power. There is predatory pricing, loss leading. They are all terms that came
up in the Tasmanian inquiry. We can say we are not sure about those things, but
I think the ACCC should look into that.
CHOICE notes recent media reports referencing claims from
unnamed industry sources that Coles Supermarkets are incurring losses of
$300,000-$400,000 per week to sell heavily discounted milk, and that
representatives of Woolworths Supermarkets have expressed concerns about the
impacts of price reductions on dairy farmers. These claims require further
investigation, given it is difficult to see why any retailer would sustain such
losses if it were not seeking to eliminate or damage its competitors.
... we believe there is an urgent need for ... [t]he
ACCC to investigate the pricing practices of Coles, including its 'guarantee'
that dairy farmers returns will not be reduced, to ensure that predatory
pricing is not being practiced and that sustainable returns are delivered to
Australian farmers and processors.
Coles actions are not only hurting farmers. They will also
damage Coles' competitors such as small businesses like local corner stores,
independent service stations and other small retailers of milk. The industries
that service these stores, such as delivery drivers will also be affected.
Lower sales for corner stores and independent service stations will lead to a
substantial lessening of competition in the market place and leave consumers
with less choice.
As the inquiry progressed, submissions and supplementary submissions
became more direct on this issue, calling for the relevant Federal Minister to
issue to a direction to the ACCC to investigate Coles' conduct.
It is important to keep in mind that the economic concept of predatory
pricing is separate to the concept that exists in the language of the CCA. As
noted in Boral Besser Masonry Limited (now Boral Masonry Ltd) v Australian
Competition and Consumer Commission:
There is a danger that a term such as predatory pricing may
take on a life of its own, independent of the statute, and distract attention
from the language of s 46.
In the context of predatory pricing, a question arises as to what is
meant by 'cost'. The ACCC noted that under the CCA, the focus regarding cost
'is on the corporation that is making the supply', not whether the sale price
is below a competitor's cost of supply.
The ACCC further defined what they consider cost includes:
Senator WILLIAMS—... if Coles buy two litres of milk and
land it in their store for $1.50, does that cost also include the margin for
running their people at the check-outs, their electricity and their rent? In
other words, $1.70 could be their cost...
Mr Bezzi—It is the cost of supply, so it would include the
additional amount. It includes the 20c.
Senator WILLIAMS—It includes the labour factor and the
electricity factor et cetera?
Mr Bezzi—The cost of supply, yes.
Woolworths told the committee:
From a cost of product to a sell, at our first margin we are
making a profit. When we take into consideration the costs associated with our
supply chain and distribution, our handling costs and the other costs
associated within the store, we are still not selling milk below cost.
Coles stated that it is confident that 'it has not sold milk at prices
below the cost it acquired it from milk processors'.
Coles was asked about how they define cost:
Senator XENOPHON—... You say in your submission that Coles
is not selling milk at prices below the cost it acquired from milk processors.
Have you chosen your words carefully by choosing not to focus on just the
acquisition cost instead of also including the cost of refrigeration, in-store
handling costs and transport?
Mr McLeod—No. We have described it that way because it is the
way in which we manage our business. On a product-for-product basis, when we
are determining the margin that we make on those products, it is done on the
basis of the cost that we buy at and the price that we sell at. In terms of the
overall costs within our business, we spread them across the entire company
Senator XENOPHON—Can you categorically say that, when milk is
being sold at $1 a litre in Darwin or Kununurra, for instance, that that is not
Mr McLeod—We take the individual prices that we pay for those
products on an individual basis by the arrangements that we have with those
processors in those individual states and we apply that across that state. You
may recall I mentioned earlier on that we have operated since last year with
state based pricing, therefore we have uniform pricing across Western
Australia, across Victoria, across New South Wales.
Senator XENOPHON—But that means in some parts of Western
Australia—and in the Darwin market, for instance—you would be selling milk
Mr McLeod—I am not saying that at all.
The ACCC's investigation
The public hearings conducted in March 2011 provided an opportunity for
the committee to question the ACCC about its approach to investigating
predatory pricing matters generally, as well as its specific actions regarding Coles'
pricing decision. The implications of the decision by Coles to make its price
cuts apply nation-wide were explored:
Senator COLBECK—Does targeting it broadly at the market in
that context not necessarily constitute that sort of action [intention to
predate and a purpose of damaging the target]?
Mr Cassidy—No, it would be unlikely to in the sense that it
is a competitive process in which someone is trying to gain market share, and
that is not predatory behaviour.
Senator COLBECK—In this overall context how do you go about
the process of determining it? Let me use an example: our motive in all of this
is to provide cheaper milk to our customers. That is the stated motive that is
put on the public record. How do you go about determining what is effectively
the action versus what is the stated action?
Mr Cassidy—We would look at it in general terms. We would
look at the action taken and whether in all likelihood it is about delivering
cheaper prices for consumers or whether the action that was taken and the way
it was taken was really more likely to be about damaging a particular
competitor where whatever benefits were offered to the consumer were probably a
byproduct rather than being the prime objective. Let me give you a hypothetical
example. If a firm with market power, with the ability to do it, was selling
products at below cost and choosing the particular outlets in which to sell the
products and the outlets just happened to be sitting alongside a particular
competitor, you might say that is getting lower prices to consumers but if that
is the objective why are they just doing it in these particular outlets? You
would start to form a suspicion that what the conduct is really about is
damaging the competitor rather than providing lower prices to consumers.
The committee was advised of discussions between various organisations and
the ACCC regarding the price decisions at an early stage of the inquiry. The
ACCC's responses to questions on notice from the March hearings also outlined
the meetings it had held with representatives of Coles and Wesfarmers on the
The ACCC also made a public request for firm evidence:
If someone has got that evidence—because there are some
fairly wild claims being made—then we would certainly like to have it. But on
the basis of what we have got, we have no evidence.
Unsurprisingly, based on the above statement, on 22 July 2011 the ACCC
issued a media release stating that 'it considers there is no evidence' that
Coles had acted in breach of the CCA. The ACCC Chairman at the time was quoted
It is important to note that anti-competitive purpose is the
key factor here. Price cutting, or underselling competitors, does not
necessarily constitute predatory pricing. Businesses often legitimately reduce
their prices, and this is good for consumers and for competition in markets.
The media release further elaborated on the need to prove an
ACCC enquiries have revealed evidence that Coles’ purpose in
reducing the price of its house brand milk was to increase its market share by
taking sales from its supermarket competitors including Woolworths. This is
consistent with what the ACCC would expect to find in a competitive market.
After Coles [sic] price reductions, Woolworths and other
supermarket retailers have also reduced prices for house brand milk.
The ACCC’s enquiries show that there is a significant
variation between respective costs of supply and operating margins among
The mechanics of the ACCC's investigation was explored at the hearing
the committee conducted in October 2011. The ACCC advised that they discussed
the issue with 'just about everyone in the supply chain, from the retailers
back to the farmer organisations'. The ACCC also noted that they considered a
range of confidential material during their inquiries.
Additionally, the ACCC explained some of the factors that restricted the
scope of its investigation; as the material they had did not indicate that
Coles' actions would match one of the anti-competitive purposes outlined in
section 46 of the CCA, the ACCC limited some other parts of its assessment
because a contravention would not be able to be proved. Although the ACCC
advised it did assess whether Coles was selling below relevant cost in capital
cities and regional centres (noting that in those areas it was confident that Coles
was not), it did not examine more geographically remote areas because:
... from the evidence that we had we could see that we
were not going to get a purpose in terms of section 46. There was, if a you
like, a commonsense approach taken by us in terms of the resources that we
would put in to establishing one leg in certain geographic areas when we
basically knew that we did not have the required other elements.
Transparency of ACCC investigations
An issue which the committee has considered as part of this and other
inquiries is the transparency of the ACCC's investigations. Whether or not the
ACCC was undertaking an active investigation into Coles' milk price cuts was a
question that frequently arose during the early stages of this inquiry:
We said to the ACCC that we would welcome an ACCC inquiry,
and make a submission to an ACCC inquiry, and felt they should bloody well do
one. Clearly, they should. I do not know by what process the ACCC is triggered
into action. You politicians have to decide that. But we need an ACCC inquiry
here, without any doubt.
We wonder if the ACCC is providing leadership in the area of
supermarkets. They might be doing a lot of things behind the scenes...
Some witnesses commented that the ACCC could be more active and upfront
about their activities:
From what we have seen, the ACCC likes to watch. They take a
long time to investigate. They could not even answer the question on whether
they could give an answer about their investigation before the end of the year.
If we have to wait beyond the year then there is something seriously wrong with
someone’s investigative processes.
After reflecting on a regular meeting they had with the ACCC during
which the milk price issue was discussed, a representative of CHOICE stated:
I suppose I got the impression—and this is a broad impression
I got—that the ACCC does not always signal what they are doing in terms of
investigation. I do not know if that applies to supermarkets. I think it was
argued that perhaps there needed to be more prominent smoke signals, as it
were, to the ACCC. Basically, they have been very quiet on this whole issue. I
think many people would have looked to them to have real guidance in terms of
what was and was not predatory pricing and what was and was not in the consumer
In their proposal to the committee that a Supermarket Ombudsman be
appointed, CHOICE and the Australian Food and Grocery Council argued that one
of the benefits of such an office would be that it could shed light on certain
issues at an early stage, 'rather than operating under the veil of secrecy
associated with the ACCC'.
The ACCC's policy on commenting on
The ACCC's website provides the following advice on where information
about its enforcement actions can be sourced:
For information on the enforcement activity of the ACCC see:
- News releases
- ACCCount, a quarterly report of
Australian Competition and Consumer Commission's activities
- ACCC annual report.
For up to date information on current ACCC litigation in the
Federal Court of Australia for alleged breaches of the Trade Practices Act go
to the Commonwealth Courts Portal www.comcourts.gov.au. The Commonwealth Courts
Portal is a web-based service that provides access to information about cases
before the courts.
The ACCC generally issues a media release and otherwise engages with the
media only if an investigation reaches a certain stage, such as when court
proceedings are instituted or finalised, or when a matter has been resolved by
way of an enforceable undertaking or other arrangement. Prior to one of these
stages being reached, however, in most cases there will be little public
information available as to whether or not the ACCC is investigating, or has
investigated, a particular matter.
The ACCC states in its Compliance and Enforcement Policy that one
of the principles it has adopted to achieve compliance with the law is
... in general, investigations are conducted
confidentially and the ACCC does not comment on matters it may or may not be
The effect of this policy is demonstrated by this exchange at Senate
Estimates in February 2011 regarding a different matter:
Senator CORMANN—... Are you undertaking any investigations
at present of financial institutions in Australia for suspected breaches of
part IV of the Trade Practices Act? I am not asking you to name anyone;
I am just asking whether you are currently conducting any investigations.
Mr Samuel—Senator, I do not think we can give any details of
any matters that we may or may not be investigating in relation to this area.
That is not to imply that we are and not to imply that we are not; it is just
that it is not appropriate for us to give any details on those issues. You
would be aware—and our records would indicate—that one or two matters currently
before the courts relate to part IV matters concerning one or other of the
major trading banks, but beyond that I really cannot comment any more.
On occasion, however, substantial public interest will pressure the ACCC
to provide some insight into its investigative activities. The supermarkets'
milk pricing decisions being examined by this inquiry, for instance, is one
such matter. At its public hearing on 9 March 2011, and in response to written
questions on notice, the ACCC outlined some of the actions it has taken,
including meetings with senior Coles and Wesfarmers executives. The then
Chairman of the ACCC also gave an example of his engagement with the media on
In an interview I gave on the Perrett Report on Sky News,
which predated the Senate inquiry, I was asked by Janine Perrett what our
position was on milk. I said that we were examining all aspects of the milk
supply chain from the grower through the processor through the delivery chain
through to the wholesalers, the retailers and the like but our primary concerns
were—I am almost quoting myself verbatim—at the grower level and at the level
of the consumer. There were some strong vested interests that were interposed
in between. They were very powerful vested interests. In particular, I referred
to both the retailers, the wholesalers and the processors. I thought that gave
a fairly open answer to indicate that there was a lot that we are examining.
As noted earlier in the chapter, the ACCC then issued a media release
summarising the findings of its investigation of whether Coles' actions were
likely to constitute predatory pricing. While this was a divergence from the
ACCC's usual practice regarding its investigations, it was not unique as similar
announcements have been made in the past.
The different approach was explained by the then ACCC Chairman:
... where a matter, milk for example, is the subject of
examination that is of clearly intense public interest, it could be reasonably
expected that once that examination is completed, we will make a public
statement as to our findings. Those findings will necessarily be largely
focussed on whether or not there have been determined to be breaches of the
Competition and Consumer Act, though they may well relate to some incidental or
other relevant matters.
It is not clear whether the ACCC's approach is changing; on 2 September
2011 it also issued a media release stating that it considered allegations that
protests against certain businesses with Israeli ownership and which carry on
business with the Government of Israel were unlikely to constitute a secondary
Issues with increasing transparency
It is important to keep in mind that the ACCC is a law enforcement
agency, and accordingly there are certain principles and practices it should be
expected to adhere to. While increased transparency of what the ACCC is
investigating at any point of time may be desirable in terms of ensuring public
confidence in the ACCC, there are important factors to consider.
Publicising investigations prior to proceedings being instituted or the
matter being resolved in some other way is likely to deny procedural fairness
to individuals or corporations that are the target of an ACCC investigation.
This is significant because under Australia's competition law framework it is
the courts that decide whether a contravention of the CCA has occurred. This
principle forms an integral part of the ACCC's policy on engagement with the
The ACCC will issue a news release when it decides to
institute proceedings in relation to an alleged contravention that accurately
describes the allegations and does not imply that the allegations are more than
allegations. In practice, the ACCC rarely makes public comments regarding an
investigation because of the potential detrimental impact on the reputation of
While these concerns may not be relevant now, the ACCC has in the past
been criticised for how it engages with the media. A number of concerns were
raised in 2002 and 2003 as part of the Review of the Competition Provisions
of the Trade Practices Act (Dawson Review). Submissions to that review
raised instances of the ACCC publicising investigations before they were
concluded, before proceedings were instituted and when no decision had been
reached by the court. The report of the Dawson Review devoted a chapter to the
Regardless of any actions to increase transparency, a further issue is
that the nature of many investigations undertaken by the ACCC would still
require confidentiality while evidence was being gathered. The public
disclosure of the existence of an investigation could damage that process. The
ACCC has in the past noted:
... firms with substantial market power appear to be very
much aware of the consequences of "smoking
gun" documents being found in their internal records such as those
relied upon in the QWI, Boral and Rural Press proceedings. Such firms appear to
be taking great care to avoid potentially incriminating documents being created
or stored. For example, the ACCC is aware from experience of instances where
corporations have issued specific instructions in relation to the creation or
destruction of internal documents, that display a disregard for compliance with
the TPA [Competition and Consumer Act]. Consequently, the forensic task for the
ACCC in proving section 46 breaches is getting more difficult.
Comparison with international
The ACCC's approach to releasing information about its investigations is
not radically different from that used by the consumer protection and
competition agencies in other countries, although there are some interesting
The Office of Fair Trading (UK OFT) is the agency responsible for consumer
protection and competition issues in the UK. Like the ACCC's website, the UK OFT's
(www.oft.gov.uk) provides general information to consumers and businesses about
the legislation it administers. However, the UK OFT's website also includes
information about its enforcement activities by sector (such as consumer
credit, retail and transport) and by the category of investigation the conduct
falls under (such as consumer protection legislation, consultation or mergers).
This includes its completed enforcement matters, as well as a selection of
The information the UK OFT's website provides about its current
enforcement activities is not a complete list of investigations—the site notes
it is limited to 'those investigations in the public domain'—however,
it does include a discussion of matters before the courts and, in some
instances, investigations prior to a decision to institute proceedings being
Similar to the ACCC's online record of media releases, the Competition
Bureau of Canada's (CBC) website (www.competitionbureau.gc.ca) includes its
past announcements. However, the CBC also publishes on its website a 'Litigation
Status Report' which provides a consolidated summary of matters before the
The website also summarises judgements and orders made by the courts,
and provides examples of discontinued investigations:
... where the Commissioner of Competition ended an inquiry
initiated under the Competition Act because of insufficient evidence to
institute proceedings before the courts or to refer the matter to the Director of
Public Prosecutions of Canada.
The New Zealand Commerce Commission's website provides access to
information relating to its enforcement activities through a number of methods.
An Enforcement Action Register outlines all litigation and settlements
since January 2010 and all warnings and cease and desist orders issued since
January 2011 under the Commerce Act 1986 and the Fair Trading Act 1986.
Investigations which resulted in no further action being taken are not
included. For competition matters, certain investigation reports are published,
such as the Commission's investigation into New Zealand electricity markets.
The policy on whether to produce and publish these reports is summed up on the
In some cases the Commerce Commission decides to publish
investigation reports that are of general interest.
The website also includes a selection of court judgements.
Summary of the approaches taken by
overseas agencies compared to the ACCC
Unlike the websites of the UK, Canadian and New Zealand competition and
consumer protection authorities, for most enforcement matters visitors to the
ACCC's website need to search through numerous media releases or the agency's
quarterly and annual reports to find details about specific enforcement activities.
Even then, those matters which the ACCC has been willing to publicise to some
degree either in the media, at Senate Estimates or during a specific
parliamentary inquiry—but which it has not issued a formal statement such as a
media release—are unlikely to be found on its website.
The major exception appears to be for franchising matters. For these
enforcement outcomes, the ACCC operates a dedicated page on its website which
provides some information about the number of complaints received, the investigative
process, and summarises the enforcement outcomes since 2004.
The information provided about matters before the courts also differs.
As noted earlier, the ACCC merely provides a link to the Commonwealth Courts
Portal website (www.comcourts.gov.au). While the Commonwealth Courts Portal
provides some useful material such as hearing dates and copies of orders made,
the information provided is limited and does not include a summary of the
matter. In many instances it also requires the user to have some knowledge of
the details of a particular case, such as the formal name of the applicant or
respondent, in order to search for it successfully.
The committee is aware that, at times, there can be significant concern
within certain sectors and the wider community regarding the effectiveness of
the ACCC in enforcing the CCA. On the other hand, the fact that the ACCC has a clear
remit and is bound by the specific text of the CCA needs to be remembered.
The ACCC is an independent statutory authority. To ensure confidence in
the organisation, it is critically important that the ACCC exercises, and is
seen to exercise, its powers independently and based on the evidence it is able
to gather. Having said this, the committee had the expectation that the ACCC
would review Coles' price decisions against the legislation it is entrusted to
enforce. The committee would have had serious concerns if it did not do so.
The committee is pleased that the ACCC was, on this occasion, willing to
publish a statement that provided a high-level summary of the findings of its
investigation. The committee believes that such public statements on key
matters help inform the broader public debate.
The committee acknowledges that greater transparency of the ACCC's
investigations could help improve public confidence in the regulator and further
inform the public debate on certain competition or consumer protection issues.
There is a need to consider other factors, however, such as the effect that
greater transparency could have on the integrity of the ACCC's investigations
and ensuring that, because it is the courts that determine whether the CCA has
been contravened rather than the ACCC, the reputations of individuals and
businesses are not unfairly damaged due to allegations or the stigma that could
be associated with being under an ACCC investigation.
The committee notes that the ACCC's enforcement outcomes are highlighted
within point‑in‑time documents, such as its annual report, quarterly
reports and media releases. While the ACCC's website provides links to these
documents, the website itself appears more directed at providing general
information to consumers and businesses rather than highlighting specific
outcomes. While this approach is understandable, and helps fulfil the ACCC's
statutory obligations under section 28 of the CCA, it may be the case that the
ACCC's website under‑emphasises its enforcement activities compared to
the approach taken by its international counterparts.
Therefore, the committee believes there is some scope, albeit limited,
for additional transparency of the ACCC's enforcement activities. Improvements
to the way the ACCC releases this information could help ensure that the public
is confident that matters are being taken seriously, and increase the
accountability of the ACCC.
6.58 The committee recommends that the Australian Competition and Consumer
Commission (ACCC) review its approach to publicly releasing information about
its investigations, with a view to providing greater general information about
its current enforcement activities and relevant issues of particular public
6.59 This recommendation is subject to the proviso that such action would not
deny procedural fairness to the parties involved or threaten the integrity of
the ACCC's investigations.
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