Critical infrastructure and the foreign investment review process
Port of Darwin lease
In its interim report, the committee considered the Northern Territory
Government's decision to lease the Port of Darwin to Landbridge Group (a
Chinese company). The committee detailed evidence which raised concerns about
the adequacy and comprehensiveness of the FIRB review process in relation to
the Port of Darwin matter. The evidence brought to the fore questions about the
transparency, adequacy, comprehensiveness and timeliness of the review process
The committee's examination of the Port of Darwin lease brought to light
a number of concerns in respect of the review framework's capacity to assess the
risks and benefits of foreign investment proposals from both national security
and economic development perspectives. In particular, the following issues were
FIRB, as a non-statutory authority, does not have independent
authority to review proposed acquisitions in relation to Australia's long term
The FIRB process appeared to be ad hoc, operating on a case by
case basis. Consistency in approach and decision making, along with the
desired transparency and certainty that investors and the Australian public
require, was not demonstrated.
The Port of Darwin lease announcements indicated that strategic
partners such as the US were not necessarily fully advised of developments.
The committee took the view that FIRB's assessment processes, especially
in relation to the sale or lease of critical infrastructure assets, such as the
Port of Darwin, Transgrid or S. Kidman and Co. Ltd, required further
examination in terms of their capacity to protect and further Australia's
In June 2014, the Premier of New South Wales (NSW), the Hon. Mike Baird
MP, announced that the NSW Government intended to lease 49 per cent of the
state's electricity network as part of its Rebuilding NSW plan. Mr Baird
went on to announce that the proceeds of the lease arrangement, projected to
total $20 billion, would be used to fund 'once-in-a-generation' investments in
productivity enhancing infrastructure across NSW.
The plan to lease 49 per cent of the state's electricity network assets
called for the entirety of Transgrid to be leased to private investors. As the
largest single electricity provider in NSW, Transgrid is responsible for the
management and operation of around 12,800 kilometres of transmission lines and
underground cables. It connects generators, distributors and end users in both
NSW and the Australian Capital Territory (ACT), and possesses links with
Queensland and Victoria for the facilitation of interstate energy trading.
The NSW Government's leasing policy also included the proposal to lease
50.4 per cent of two other state-owned electricity providers, Ausgrid and
Endeavour Energy. All three leases would be offered over a period of 99 years.
Essential Energy, a state-owned corporation responsible for building, operating
and maintaining NSW's electricity grid, was not included in the government's
After the March 2015 state election, legislation enabling the lease
transactions was introduced into the NSW Parliament. On 4 June 2015, the Electricity
Network Assets (Authorised Transactions) Act 2015 was passed by the NSW
Parliament, clearing the way for the state government to begin the process of
leasing 49 per cent of NSW's electricity network.
On 25 June 2015, the NSW Treasurer, the Hon. Gladys Berejiklian MP,
announced the opening of the expression of interest (EOI) process for the 99
year lease of Transgrid to private investors.
On 25 November 2015, approximately five months after the commencement of the
EOI process, the NSW Government announced that an Australia-led consortium, NSW
Electricity Networks, had made the successful bid for the Transgrid lease.
After a consultation and assessment process, which involved FIRB; the
Australian Taxation Office (ATO); and the Australian Competition and Consumer
Commission (ACCC), NSW Electricity Networks agreed to pay the NSW Government a
total of $10.258 billion for the right to lease the entirety of Transgrid for
As a precondition of the award of the lease, NSW Electricity Networks
agreed to sign an Electricity Price Guarantee, an undertaking that committed
the consortium to ensuring that network charges will be lower at the end of the
financial year 2018–2019 than they were on 30 June 2014.
NSW Electricity Networks is a consortium made up of five private
investors, including two Australian companies, which together have a 35.03 per
cent stake in Transgrid. The five members of the consortium are:
Caisse de dépôt et placement du Québec (CDPQ), a Canadian
pension fund with a total stake of 24.99 per cent.
Hastings, as the manager of Utilities Trust of Australia, which
owns a 20.02 per cent stake in Transgrid.
Tawreed Investments Limited, the global direct infrastructure
vehicle of the Abu Dhabi Investment Authority, with a total stake of 19.99 per
Wren House Infrastructure, a wholly-owned subsidiary of the
Kuwait Investment Authority, which also has a 19.99 per cent stake in the
Spark Infrastructure, an Australian infrastructure manager and an
ASX-listed owner of energy infrastructure, which has a total stake in Transgrid
of 15.01 per cent.
As a consequence of the Transgrid lease, the NSW Government announced
that it would be eligible for approximately $1 billion in additional
Commonwealth infrastructure funding, on the basis of the National Partnership
Agreement on Asset Recycling.
According to the NSW Government, the EOI process for the eventual lease
of Ausgrid, the second largest provider in the NSW electricity network, was
launched 24 November 2015.
The EOI phase for the lease of Endeavour Energy, the final component of the
state's electricity assets to be leased, is also currently underway. At the
time of writing, the NSW Government had made no announcement in relation to
indicative bids for either company.
Critical infrastructure assets do not feature as a separate component of
Australia's national interest test for foreign investment, as is the case in
the US. However, the Government has in place a strategy aimed at ensuring that
the nation's critical infrastructure assets can be operated under all
conditions. This overarching policy position is outlined in the Government's Critical
Infrastructure Resilience Strategy: Plan (the Strategy).
The Strategy is administered by the Attorney General's Department, which
is also the lead Commonwealth agency on matters relating to critical
infrastructure resilience policy. The Strategy provides a definition of
critical infrastructure that is shared by the Commonwealth, state and territory
Those physical networks, supply chains, information
technologies and communication networks which, if destroyed, degraded or
rendered unavailable for an extended period, would significantly impact the
social or economic wellbeing of the nation or affect Australia's ability to
conduct national defence and ensure national security.
For the purpose of defining the destruction or disruption of critical
infrastructure assets, the Strategy uses the phrase 'significantly impact' to
mean an event or incident that threatens public safety and confidence;
threatens national economic security; harms Australia's international
competitiveness; or otherwise impedes the continuity of government and its
To prevent these effects from degrading or undermining Australia's national
interest, the Strategy seeks to ensure that the nation's critical
infrastructure assets can continue to operate effectively in the face of all
threats and risks.
In order to achieve its aim of ensuring that critical infrastructure
assets can operate 'in the face of all hazards', the Government has adopted an
approach that seeks to produce a non-regulatory business-government
This approach is founded on two principal policy objectives:
That critical infrastructure owners and operators can effectively
manage reasonably foreseeable risks to the continuity of their operations,
through a mature, risk-based approach;
That critical infrastructure owners and operators can be
effective at managing unforeseen risks to the continuity of their operations
through an organisational resilience approach.
On the basis of its partnership approach to managing threats and risks
to Australia's critical infrastructure, the Government seeks to achieve a
number of key outcomes including:
a strong and effective business-government partnership;
enhanced risk management of the operating environment;
effective understanding and management of strategic issues; and
a mature understanding and application of organisational
The Government's partnership approach to securing Australia's critical
infrastructure rests on effective engagement with both industry and other
levels of government. In order to engage and coordinate effectively with
industry participants, in 2003, the Australian Government established the
Trusted Information Sharing Network (TISN). This network allows critical
infrastructure owners and operators across seven sector groups to share
information and cooperate within a secure environment, in order to address a
range of security and business continuity challenges.
The seven groups within TISN comprise the following sectoral participants:
banking and finance, communications, energy, food and grocery, health,
transport and water services.
Additionally, the Government's Critical Infrastructure Advisory Council
(CIAC) provides both coordination and strategic guidance for the members of
TISN, and comprises the chairpersons from the seven sectoral groups; senior
Australian Government representatives from the relevant agencies; and senior
state and territory government representatives.
In addition to participating in TISN, state and territory governments
also have defined roles and responsibilities in relation to the resilience of
critical infrastructure. Given Australia's federal system of government, state
and territory governments are responsible for managing all threats to life and
property that might occur within their jurisdictions. They are also responsible
for providing a range of basic services, such as healthcare and the supply of
water, which form part of Australia's critical infrastructure assets. As the
Strategy makes clear:
All Australian state and territory governments have their own
critical infrastructure programs according to the operating environment and
arrangements for each jurisdiction. The Strategy aims to complement these
programs and support their objectives wherever possible...It is essential that
critical infrastructure owners and operators know and understand the jurisdictional
response arrangements and have good working relationships with the appropriate
state and territory agencies.
While Australia's foreign investment review process does not formally
define critical infrastructure assets, or incorporate a codified definition of
critical infrastructure in the national interest test, the government maintains
a strategic approach to the protection of critical infrastructure from a range
of threats and risks.
Concerns regarding the current framework in relation to critical infrastructure
The Australian Strategic Policy Institute (ASPI) raised a number of
concerns regarding the adequacy of critical infrastructure protection under
Australia's foreign investment review process. At the heart of its concerns was
the need for a comprehensive, high-level review process which is consistent,
transparent and robust.
State Owned Enterprises
Drawing on the Transgrid matter, ASPI highlighted that one of the
unsuccessful bidders for the lease was State Grid, a Chinese State Owned Enterprise
According to ASPI, the close links between Chinese SOEs and the ruling
Communist Party of China (CPC) has the effect of making these entities into
little more than instruments of the CPC, even though they operate in the global
ASPI raised particular concerns that the close and ambiguous relationship
between the CPC and SOEs does not appear to be sufficiently or effectively
captured in FIRB's review and assessment processes.
ASPI held the view that, in light of the close links between SOEs,
including major corporations like State Grid, and the CPC, Chinese SOEs should
not be considered as appropriate bidders for Australian critical infrastructure
ASPI further argued that:
These considerations...should lead to a judgement that Chinese
SOEs ought not be considered as appropriate partners in NSW's 'poles and wires'
infrastructure. No Australian company would ever be allowed by Chinese
authorities to tender for parts of their electricity distribution and
transmission network. Indeed, State Grid was kept as an SOE at a time when
Beijing privatised many businesses precisely because power infrastructure was
seen to be critical to Chinese security and must be kept in Government hands.
ASPI maintained that Australia's electricity networks are potentially
vulnerable to a variety of different forms of cyber intrusion and attack, and
that some networks, such as the Transgrid distribution network, are unusually
significant in virtue of their strategic importance.
According to ASPI, the number and scale of recent attacks, principally
in the cyber sphere, against critical infrastructure targets has increased
ASPI observed that the US has seen a number of successful cyber-attacks on
major electricity networks over the last few years. It argued that such attacks
have the potential to cause significant damage to vital elements of critical
infrastructure and national security.
ASPI pointed out that NSW's electricity distribution system is a
significant part of Australia's critical infrastructure because major parts of
the Commonwealth Government, including the defence and intelligence
communities, rely on the electricity supply from that network.
The Committee should note that the NSW 'poles and wires'
network is as vulnerable to cyber attack as the US electricity distribution
network or the networks of other countries. Moreover there is increasing
interest on the part of malicious cyber actors to explore how to damage the
critical infrastructure of potential opponents. Australia cannot isolate itself
from these international developments...NSW's electrical transmission and
distribution system is an element of critical infrastructure on which
significant parts of the Federal Government, Defence and Intelligence community
relies. We cannot afford to be casual about the security of this critical
ASPI criticised the view that the vulnerability of critical
infrastructure to hacking means that it is unimportant who owns these assets.
ASPI maintained that physical access to control systems is still a significant
advantage in an attempt to sabotage a critical infrastructure asset, such as an
electricity transmission network, and that control systems remain more vulnerable
to 'locally-launched' attacks than they are to intrusion attempts from remote
ASPI maintained that arguments to the contrary are a 'cyber red herring':
It has been claimed that, if Australian infrastructure is
vulnerable to Chinese cyber hacking, then the ownership and control of our
infrastructure should make no difference. This is a council of despair, and
hardly a basis on which to make sensible decisions about controlling our
critical infrastructure. It remains the case that physical access is by far the
easiest way to tamper with control systems, as, while effective, remote access
can take a great deal of time and requires a high degree of technical ability.
Sensible strategies to manage security around physical and cyber access to control
systems of critical infrastructure will go a very long way to protecting
ASPI welcomed the fact that the NSW Government, after consulting with
FIRB and other Commonwealth agencies, did not award the 99 year of Transgrid to
bids from consortia that included Chinese State-owned Enterprises (SOEs).
However, ASPI also questioned the extent to which this decision was based on
ASPI concluded that the decision does not constitute evidence that the foreign
investment review process adequately considers, in every case, the national
security implications of foreign investment, especially in respect of critical
Ad hoc and opaque process
Mr Peter Jennings, Executive Director of ASPI, argued that FIRB does not
have in place a robust framework for the assessment of the national security
implications of some forms of foreign investment. This is particularly significant
because the review process is conducted on a case-by-case basis. While
providing for flexibility, under such a system, it is unlikely that sufficiently
clear, consistent and rigorous procedures for assessment are currently being
followed. Mr Jennings suggested that:
A robust framework would start with a series of fairly
defined procedures that could be applied in any test of foreign direct
investment. As I say, a robust test is one that could be replicated over any
foreign investment application. What I find disturbing is that there seems to
be almost a, sort of, bespoke process of interaction that takes place between
agencies that is reinvented every single time one of these proposals comes
Mr Jennings further maintained that the current assessment process needs
to be supplemented by the establishment of an additional committee at the
deputy secretary level. This would provide the additional, senior-level
scrutiny that would help to produce a more thorough assessment framework.
It would also help to ensure that those agencies that are most central to the
assessment process, such as the Department of Defence (Defence) and Treasury,
are required to undertake a formal assessment process that is decisively above
the desk officer level:
It [the review process] can be very informal or could be
nothing more than a phone call between desk-level officials where one says, 'We
don't have problem,' and that seems to be the end of the discussion. Our
submission to the committee suggested that, at the very least, there ought to
be a deputy secretary level committee, which would create some structures and
processes that would require agencies to go through somewhat more formal
ASPI suggested that the current FIRB process remains largely opaque. In
particular, it criticised the Treasury's view that the current assessment
process is necessary to create community confidence in the foreign investment
review framework. ASPI argued that 'it is difficult to see how such an opaque
and impenetrable process can create any basis for public
confidence in FIRB decisions.'
Support for the current framework in relation to critical infrastructure
According to the Attorney General's Department (AGD), foreign investment
plays a significant role in maintaining the resilience of Australia's critical
AGD further observed that, in a relatively small number of cases, foreign
investment in critical infrastructure can pose a number of potential risks to
Australia's national security, which require appropriate consideration and
AGD maintained that well established mechanisms already exist within the
Commonwealth Government to facilitate the effective cooperation of agencies in
assessing the risks posed by some types of foreign investment.
Ms Katherine Jones, Deputy Secretary for National Security and Emergency
Management, observed that the AGD engages on a regular basis with agencies that
have an interest in foreign investment in critical infrastructure sectors:
...we do have well established mechanisms for working across
the Commonwealth government, and we engage very regularly with a whole range of
agencies that may have interest generally in foreign investment in critical
infrastructure but specifically in relation to particular elements of our
critical infrastructure sectors.
Ms Jones informed the committee that in 2014–2015, the AGD was involved in
the assessment of 54 cases that were referred to it by FIRB. The assessment
process involved liaising with other Commonwealth Government agencies,
including Defence and the Australian Security and Intelligence Organisation
Ms Jones suggested that one of ASPI's criticisms of the review process –
that it lacks a senior officials' committee, ideally at the deputy secretary
level – had been addressed. She explained that a committee at the deputy
secretary level already meets on a regular basis, and that it discusses issues
that arise from foreign investment in critical infrastructure.
Over the past six months, the volume of work addressed by the committee had
Ms Jones also pointed out that the committee's work is informed by contributions
from a large number of agencies, including the Departments of Foreign Affairs
and Trade (DFAT); Prime Minister and Cabinet (DPMC); Agriculture and Water
Resources (DAWS); Infrastructure and Regional Development (DIRD); Defence; AGD;
In terms of the AGD's contribution to the investment review process, the
department assesses proposals on the basis of their potential effects on the
continuity of the services provided by the critical infrastructure asset in
In carrying out its assessment, the department also liaises with national
security agencies and the relevant line agencies, in order to provide a comprehensive
evidence base for the department's final assessment of the potential risks and
benefits of the proposed investment.
According to the AGD, the department's assessment process involves a
consideration of the applicant; the nature of the investment proposal; the
criticality and potential vulnerabilities of the infrastructure being acquired;
and the general characteristics of the critical infrastructure sector in which
the investment is to occur.
In addition to the contributions of other Commonwealth agencies to the
assessment of proposals, the Australian Government, represented by the AGD,
engages with a number of key international partners on questions of critical
infrastructure security and resilience.
In particular, the Australian Government actively participates in a
well-established forum on critical infrastructure security with its 'five eyes'
Known as the 'Critical Five', the forum consists of senior representatives from
the 'five eyes' intelligence alliance, comprising the US, Britain, Australia,
Canada and New Zealand. The focus of the forum is on improving information
sharing and cooperation on a range of common threats to critical
Ms Jones observed that:
Australia plays a leading role in this forum and has
specifically led initiatives to deliver enhanced information-sharing on foreign
investment in critical infrastructure, including best practice approaches for
managing national security risks over the past three years.
DFAT also explained its role in the foreign investment review process to
the committee. According to Mr Justin Brown, Acting Deputy Secretary, DFAT provides
a range of information, analyses and assessments to assist in the Government's
decision-making process. DFAT provides FIRB with any information that might be
valuable in the assessment process. As Mr Brown explained:
We also provide any other information we think might be
valuable for the government to take into account. Quite often that will include
what we might describe as 'broader foreign and trade policy considerations'. I
mentioned earlier that we have free trade obligations with a large number of
countries now. We would typically provide advice on any legal obligations or
compliance issues as part of these agreements. We would also look at the
broader trade and investment relationship with those countries – whether there
are any other issues that might impact on the government's decision. We tend to
cast the net very wide. We typically consult with our diplomatic networks in a
pretty broad way to try to ensure that all of our assets and the intelligence
from within our system are brought to bear and that we provide the most
comprehensive input we can into the whole-of-government process.
In its submission, the Treasury reiterated the point that one of the
fundamental aims of the FIRB assessment process, in addition to facilitating
foreign investment in Australia, is to ensure that the Treasurer receives
comprehensive, thorough and rigorous whole-of-government advice on any
potential national interest concerns that arise from a proposed foreign
Treasury also pointed out that FIRB is always involved, early and directly, in
the consideration of any investment proposals that are assessed to be either
significant or complex.
According to the Treasury, the review process is fundamentally based on
a thorough consultation process, one that not only involves a large number of
Commonwealth agencies, but also takes in early and comprehensive consultation
with state and territory governments:
Treasury consults with Australian, state and territory
government departments, national security agencies and authorities with
responsibilities relevant to the proposal. Advice and comments provided by such
agencies are important in assessing the implications of proposals and, in
particular, in determining whether they potentially raise any national interest
issues. For example, advice from the relevant national security agencies is relied
upon for assessments as to whether an investment raises national security
In its submission, the Treasury noted that the assessment and
consultation process in relation to the Transgrid lease lasted for more than 12
months, with FIRB engaging with both the NSW Government and a number of
Commonwealth agencies in order to ensure that all national interest
considerations were addressed.
In particular, FIRB's assessment and consultation process led to the
implementation of a range of safeguards as a condition of the lease. These reflect
the fact that the Transgrid electricity transmission system is a vital piece of
Australia's critical infrastructure.
The Treasury pointed out that these safeguards are more stringent than any
conditions hitherto imposed on comparable critical infrastructure acquisitions.
The safeguards are designed to make sure that:
the operation and control of Transgrid's transmission system and
telecommunications business are undertaken solely from within Australia. Maintenance
is also to be undertaken in Australia unless it is not possible to do this on
reasonable commercial terms;
electricity supply data and personal information are accessible
from and held solely within Australia;
individual foreign members of the consortium maintain their
interests in Transgrid at no more than 50 per cent;
50 per cent of Transgrid's board comprise Australian citizens and
Transgrid has an independent chairperson and an independent
director on the board who are Australian citizens and residents, one of whom is
required for all board quorums;
senior personnel in critical positions hold appropriate security
annual reporting takes place:
to the NSW Government, certifying compliance with NSW’s critical infrastructure
licence conditions; and
to FIRB, certifying compliance with all of the safeguards.
Flexible and comprehensive approach
In his evidence to the committee, Mr Brian Wilson, Chairman of FIRB,
observed that the foreign investment review process, especially in respect of
the national interest test, benefits significantly from its broad and unlegislated
character. Mr Wilson made the point that the uncodified nature of the national
interest test, which takes in questions of national security in addition to
other considerations, provides a flexible and comprehensive method by which to
judge the risks and benefits of foreign investment:
I think that it would be difficult to suggest there is a
material component of national interest that is not picked up in the five
subcomponents that we define – impact on the economy and the community,
national security, competition, other laws and regulations and the nature and
character [of the investor and the proposed investment]...I think that it would
be dangerous to somehow provide a numerical weighting or a 20-page checklist. I
think what that would do would, on the one hand, potentially deny transactions
that are not contrary to Australia's national interest, or that could be
mitigated through appropriate conditions coming in.
Mr Wilson observed that the current assessment framework possesses both
the flexibility and the comprehensiveness to ensure that Australia's national
interest is protected, while also ensuring that proposals for foreign
investment are not unnecessarily stymied as a result of a review framework that
is overly restrictive.
In addition, Mr Wilson suggested that a fully codified review framework, in
which a set of criteria is mandated and published, could have the paradoxical
effect of allowing a potential investor to structure a proposal to take
advantage of any loopholes in the assessment criteria. This could make possible
investments that would otherwise be contrary to Australia's national interest.
Mr Wilson also pointed out that the consultative character of the
foreign investment review framework, in which the Treasury, on behalf of FIRB,
engages with a range of agencies to inform the Government's decision making
process, means that the framework ultimately rests on taking advice from the
appropriate agencies. This is the fundamental basis of FIRB's overview of the
risks and benefits posed by a proposal for foreign investment:
I would not expect that someone from Defence, ultimately,
would second-guess me on matters of corporate structure. I would not expect
that someone from the Attorney-General's Department, ultimately, would
second-guess the ATO or revenue division of Treasury on matters of tax. All we
can do is ask, and if we are not satisfied with the results, continue to ask.
But at the end of the day, I do not think it would sensibly be open to me or
any board member—having asked and continued to ask—if the department of
Defence, in consultation with the Navy and with the security agencies, is
saying, 'We are comfortable. We have looked at this. We have looked at this up,
down and sideways on each time you have asked, and we are still comfortable,'
to then say, 'Well, notwithstanding your views, I am not.' It cannot happen.
Mr Wilson highlighted that the effectiveness of the investment review
process is based on accessing a wide range of advice from those agencies best
placed to assess the implications of a proposal for foreign investment.
FIRB is responsible for producing advice to the Treasurer on the basis of the
cumulative 'weight' of the assessments that it receives from the relevant
State Owned Enterprises
In its evidence, the Australian National University's East Asian Bureau
of Economic Research (EABER) argued that some of the concerns about Chinese
investment, especially by SOEs or by companies that have a close relationship
to the CPC, are based on misconceptions about the nature and intentions of the Chinese
State and Chinese companies.
EABER maintained that, because China is a one-party state, it is almost true by
definition that every Chinese corporate entity will have some degree of involvement
with the State.
EABER further observed that:
Yet such concerns about private Chinese investment are
overstated. Because a single party governs China, almost by definition
virtually every Chinese private company and every Chinese businessperson has
some degree of commercial or personal association with the Chinese party-state.
The vast majority of business-state linkages are borne of commercial
practicality and have no bearing on strategic intent.
EABER made the point that if these connections were enough to
automatically disqualify Chinese investment on national security grounds, then
Australia should not accept any Chinese investment. Such a position would not
only devastate the Australian economy but would also undermine national
security through reduced military spending capabilities.
Further, EABER informed the committee that recent research on the
operations and intentions of Chinese SOEs suggested that central government
control is often minimal, and that there is no conclusive evidence that SOEs
feature as a major component of a wider and aggressive Chinese strategic
posture. EABER pointed out that:
Concerns regarding FDI from Chinese SOEs are also overblown.
A significant body of academic research has concluded that SOEs are generally commercially
motivated entities and that profitability and national economic development are
the key determinants of SOE investment decisions.
However, EABER made the point that public debate in Australia fails to
distinguish between different types of SOEs and that most Chinese SOEs are
neither large nor strategically important to Beijing. Furthermore, as over half
of SOE assets are controlled by local governments at the county level and
below; 87 per cent of state assets are held in corporatised structures; and
almost half of SOE capital is from non-state sources, arguments about any kind
of centrally planned grand strategy for Chinese SOE investment abroad are
difficult to sustain.
Notwithstanding the debate regarding foreign investment by SOEs and the
national security implications, the point remains that investment in Australia
by Chinese SOEs, in particular, is a contentious issue amongst many
Australians. Herein lies on of the primary concerns regarding the current
foreign investment review process. It is important that the Government take
action to maintain public confidence in the Australian foreign investment review
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