News & Events

2012 Workplace Relations Review and looking ahead at 2013

Submitted By Firm: Corrs Chambers Westgarth

Contact(s): John Tuck, John W.H. Denton

Author(s):

Anthony Forsyth

Date Published: 11/11/2013

Article Type: Legal Article

Share This:

This In Brief provides a summary of the major workplace relations developments in 2012, and an overview of the key issues that employers will need to consider in 2013. We begin by examining the year ahead, in which proposed changes to federal anti-discrimination laws and the federal election on 14 September loom large.

Bargaining in key sectors including road and rail transport, coal production and aviation may lead to industrial action, off the back of higher levels of disputation in the second half of last year.

 

2013: Workplace relations watch list and anticipated hot topics

1 January 2013 and ongoing

Paid parental leave and other family-friendly measures

The national Paid Parental Leave scheme implemented in 2011 provides financial support to eligible working parents who are the primary carers of newborn or recently adopted children. Under the scheme, the Government funds employers to provide parental leave pay to their eligible employees for 18 weeks at the minimum wage.

From 1 January 2013, the Government also funds ‘Dad and Partner Pay’, which is paid leave for 2 weeks at the minimum wage for fathers or other partners after the birth or adoption of a child.

The Government will later this week make some announcements about proposed legislative changes to assist families to balance work and caring responsibilities, including a stronger “right to request” flexible work arrangements; and new protections for workers in relation to roster changes that can make organising child care difficult.

Ongoing

Health and Safety harmonisation

On 1 January 2013, the model Work Health and Safety Act (Model WHS Act) commenced in South Australia and Tasmania. This means Victoria and Western Australia are now the only two jurisdictions with ‘non-harmonised’ WHS legislation.

The first round of transitional arrangements under the model Work Health and Safety Regulations came to an end on 1 January 2013. This means persons conducting a business or undertaking (PCBUs) have to comply with additional provisions of the Model WHS Act.

The Queensland Parliament will consider a number of changes to Queensland’s WHS Act and Regulations, following an industry roundtable discussion on the impact of the new laws, including the delay of the introduction of particular Regulations until 1 January 2014 .

1 February 2013

New National Building Code commences operation

The Building Code 2013 (Building Code) was made as a legislative instrument, replacing the procurement rules previously applicable to contractors and participants in the building and construction industry under the National Code of Practice for the Construction Industry. The Building Code is intended to provide construction industry stakeholders with greater certainty, and also appears aimed at addressing the emerging conflict between the federal procurement rules and those issued by some state governments. Contractors and building industry participants should note that the new rules in the Building Code apply to certain Commonwealth-funded projects for which tenders were submitted prior to 1 February 2013, as well as those submitted on or after that date.

See here.

Continuing through 2013

Proposed overhaul of anti-discrimination laws

2012 saw the release of an Exposure Draft of the Human Rights and Anti-Discrimination Bill 2012 (HRAD Bill), which would consolidate all five pieces of federal anti-discrimination legislation into one statute.

Changes proposed by the Bill include redefining the concept of discrimination, expanding the grounds of prohibited discrimination, and introducing a ‘shifting burden of proof’. If enacted, these changes would enable discrimination complaints to be more easily established than is the case presently. See here.

At the end of January 2013, the Attorney-General indicated that there would be a redrafting of some contentious provisions of the Exposure Draft relating to when a person is taken to discriminate against another person.

The HRAD Bill has been referred to the Senate Legal and Constitutional Affairs Committee for inquiry and report by 18 February 2013. Developments can be monitored here.

Continuing through 2013

Modern Awards Review

Under the Fair Work (Transitional Provisions and Consequential Amendments) Act 2009 (Cth), modern awards setting minimum wages and other employment conditions across industries are subject to a one-off review, two years after their commencement on 1 January 2010.

The review process started in 2012 before Fair Work Australia (FWA), and will continue in the Fair Work Commission (FWC) in 2013. This process is unlikely to result in any major changes to minimum employment standards (such as ‘penalty rates’ for overtime or weekend work, a major concern for small business employers in the retail and hospitality sectors). However, employers will need to keep track of any changes that are made to specific modern awards applicable to their workforce. Developments can be monitored here.

Continuing through 2013

Phase 2 of implementation of the Fair Work Act Review

We discuss the outcomes of the Fair Work Act Review in the below section: ‘Looking Back 2012’.

In addition to the changes made by the Fair Work Amendment Act 2012 (Cth) (FW Amendment Act), the Government is now consulting with stakeholders over a second piece of legislation to implement the remaining recommendations of the Fair Work Act Review Panel. These include:

  • extending the good faith bargaining obligations to the process of varying (as well as negotiating) an enterprise agreement;
  • making the process for reaching greenfields agreements one based on genuine negotiation between an employer and a union;
  • facilitating the easier use of individual flexibility agreements under awards and enterprise agreements;
  • preventing unions from instigating the process for taking protected industrial action until bargaining has commenced.

It is expected that reaching a consensus on the Review Panel’s remaining recommendations will be much harder to achieve than was the case with the changes reflected in the FW Amendment Act, discussed below. Further, it is unlikely that the Government will be able to obtain passage of a second piece of amending legislation through Parliament in the eight sitting weeks remaining before the next federal election (see below).

14 September 2013

Federal election

The Prime Minister has called an election for 14 September 2013, avoiding speculation throughout the year about the timing of the poll. While the major parties have yet to formally announce their workplace and industrial relations policies, it is expected that the Coalition (if elected) would implement some changes to the Fair Work Act 2009 (Cth) (FW Act).

The ALP’s workplace relations policy will probably be to maintain the system introduced by the FW Act, and to implement any remaining recommendations of the 2012 Review (see above). The Government also intends to make the issue of family-friendly workplace arrangements a key election issue.

LOOKING BACK AT THE MAJOR DEVELOPMENTS IN 2012

5 December 2012

Transfer of business changes

The Fair Work Amendment (Transfer of Business) Act 2012 (Cth) took effect, protecting the employment entitlements of state public sector employees where there is a transfer of business from a state government entity to a national system employer. This legislation is a response to increased privatisation and outsourcing activity by state governments, particularly in New South Wales and Queensland. It has important potential implications for private sector employers considering tendering for contracts from any state public sector employer. See here.

5 December 2012

Fair Entitlements Guarantee

The Fair Entitlements Guarantee Act 2012 (Cth) took effect, replacing the General Employee Entitlements and Redundancy Scheme with a Fair Entitlements Guarantee scheme. This government-funded scheme enables employees to recover unpaid employment entitlements in the event of their employer’s liquidation or bankruptcy; and increases the level of redundancy payments that are recoverable to a maximum of four weeks’ pay per year of service. See here.

28 November 2012

Fair Work Act changes passed by Parliament

Following a post-implementation review of the FW Act in the first half of 2012, the independent Review Panel’s Report was released by the Government in August. Overall, the Review Panel found that the FW Act was meeting its objectives and (therefore) there was no case for major changes of the kind wanted by major employer groups (eg restrictions on union-initiated bargaining in the resources sector, and limits on the content of enterprise agreements). See here.

However, the Review Panel’s Report included 53 recommended changes to the FW Act, mostly of an administrative or technical nature. This led to the passage of the FW Amendment Act in late November 2012, implementing around one-third of the Review Panel’s recommendations. These include some significant changes to the FW Act provisions dealing with unfair dismissal and general protections claims, certain aspects of agreement-making, and ballots for protected industrial action.

Changes were also made to the structure and operation of FWA, which from 1 January 2013 was renamed as the FWC. In addition, the FWC has been given new functions in relation to default superannuation funds in modern awards. See here.

22 November 2012

New gender equity reporting requirements

The Equal Opportunity for Women in the Workplace Amendment Act 2012 (Cth) was passed by Parliament, introducing more onerous reporting obligations on gender equity issues for private sector employers with more than 100 employees. Commencing with the reporting period 1 April 2013-31 March 2014, employers must provide information about their compliance with a number of ‘gender equality indicators’ (eg gender composition of the workforce and of the employer’s board or other governing body, equal remuneration practices and flexible working arrangements). See here.

7 September 2012

High Court overturns Barclay decision

The High Court of Australia handed down its much-anticipated decision in Board of Bendigo Regional Institute of Technical and Further Education v Barclay [2012] HCA 32, which overturned a majority decision of the Full Court of the Federal Court. The case involved consideration of the test to be applied in determining a decision-maker’s reasons for acting, for purposes of establishing whether an employer has breached the ‘general protections’ (or ‘adverse action’) provisions in Part 3-1 of the FW Act.

The High Court rejected the ‘objective’ test articulated by the majority in the Full Court, with the practical result that greater weight can now be given to the subjective intention of employers in adverse action cases in circumstances where the evidence of the decision-maker is reliable. Despite this, given the continued overall growth in numbers of adverse action claims (see below), we anticipate that this will continue to be a high risk area for employers.

See here.

3 September 2012

Implied term of trust and confidence: Barker v Commonwealth Bank of Australia [2012] FCA 942

Justice Besanko of the Federal Court of Australia held that there exists in Australian law an implied term of mutual trust and confidence in a contract of employment. It was determined that a serious breach by an employer of its own redeployment policy amounted to a breach of the implied term, resulting in a substantial award of damages to a dismissed employee. This decision is now the subject of an appeal to the Full Court of the Federal Court. The state of Australian law regarding the implied term of mutual trust and confidence may be further clarified in the appeal proceedings. However, the case is an important reminder to employers of the importance of complying with their own policies. See here.

14 August 2012

Full Federal Court upholds contractor and union rights clauses in ADJ Contracting Case

In Australian Industry Group v Fair Work Australia [2012] FCAFC 108 (the ADJ Contracting Case), the Full Court of the Federal Court rejected an argument that a job security clause in an enterprise agreement (requiring parity of pay and conditions for contractors with existing employees) is an unlawful term because it requires or permits a contravention of the general protections provisions in Part 3-1 of the FW Act. The Full Court also upheld the validity of agreement clauses requiring the employer to promote union membership among its employees, and permitting union entry to the workplace for purposes of assisting employees in dispute resolution processes under the agreement. See here.

8 August 2012 & 17 January 2013

TWU v Qantas Airways Limited; Q Catering Limited [2012] FWAFB 6612
AIPA v Qantas Airways Limited [2013] FWCFB 317

The high-profile industrial dispute at Qantas, including months of work bans and stoppages by three unions seeking new enterprise agreements, resulted in the airline grounding its world-wide fleet in late 2011 ahead of a proposed lockout of employees. This led to the federal Government making a successful application to FWA to have all industrial action terminated. FWA was then required to arbitrate the terms of new agreements for three groups of employees involved. See here.

In early 2012, a Full Bench of FWA ratified an agreement settling the dispute between Qantas and the ALAEA representing licensed aircraft engineers (see ALAEA v Qantas Airways Limited [2012] FWAFB 236).

In a decision handed down on 8 August 2012, a Full Bench of FWA rejected key claims by the TWU (representing catering and ground staff), including limits on the amount of work that can be outsourced, the extension of agreement rates and conditions to contractors and labour hire staff, and the union’s 5% per annum wages claim (the Full Bench awarded a 3% per annum increase). In the decision, the Full Bench also confirmed the view that management has the right to manage its business (especially in a competitive operating environment such as the aviation industry); and demonstrated a reluctance to endorse union bargaining claims where these would negatively impact on efficiency and productivity.

The remaining dispute, between Qantas and the AIPA representing long-haul pilots, was also the subject of arbitration proceedings in 2012. In a decision handed down on 17 January 2013, an FWC Full Bench rejected the union’s job security and wages claims – while agreeing to back-date pay increases from 1 January 2012. This decision was also generally supportive of the airline’s need to ensure that its labour costs do not place it at a competitive disadvantage.

While arbitration of bargaining disputes under the FW Act remains relatively uncommon, these two decisions of FWA/FWC Full Benches mean that employers should consider seeking arbitration in difficult agreement negotiations with strong unions. Whether this is an advisable strategy will depend on the specific circumstances of the negotiations and parties involved. See also FWA v Schweppes Australia Pty Ltd; United Voice – Victorian Branch [2012] FWAFB 7858 and [2012] FWAFB 8599; and here.

19 July 2012

Endeavour Coal Pty Ltd v APESMA [2012] FCA 764

The Federal Court upheld a decision of a Full Bench of FWA that Endeavour Coal had engaged in surface bargaining in its negotiations with the union (APESMA). Justice Flick held that the good faith bargaining requirements in s 228(1) of the FW Act meant that an employer must do more than ‘adopt the role of a disinterested suitor’ in agreement negotiations; some effort must be made to enter into an agreement, such as the employer putting its own proposals.

Despite this, Justice Flick set aside three of the four bargaining orders made by the Full Bench of FWA , finding they were beyond the tribunal’s power. This included an order requiring the employer to inform the union of the matters that it would be prepared to include in an agreement. Justice Flick found that this order fell foul of the explicit provision stating that parties are not required to make concessions in bargaining (s 228(2)).

On balance, the decision means that employers should engage meaningfully in the process of negotiating an enterprise agreement under the FW Act – including providing the union(s)/other bargaining representatives with some indication of the terms that the employer may be prepared to agree to.

1 July 2012

New regulatory agency in the road transport industry

The Road Safety Remuneration Tribunal (RSRT) commenced operations. Established by the Road Safety Remuneration Act 2012 (Cth), the RSRT’s role includes the making of road safety remuneration orders setting minimum conditions for employee drivers and owner drivers; and resolving disputes between drivers, employers/hirers, and other participants in the transport industry supply chain. See here.

At present, the RSRT’s work is mainly focused on investigating the retail, livestock, bulk grain, interstate and intrastate sectors of the road transport industry (see: [2012] RSRTFB 3), which is considered likely to expose working arrangements in the supply chains of major Australian retailers to some scrutiny.

29 June 2012

Regulation of trade unions and employer organisations

Most provisions of the Fair Work (Registered Organisations) Amendment Act 2012 (Cth) commenced operation. This legislation amended the Fair Work (Registered Organisations) Act 2009 (Cth), increasing the level of regulation of registered trade unions and employer organisations (and their officials) in response to allegations of corruption and mismanagement within the Health Services Union.

1 June 2012

Changes to regulation of the building and construction Industry

The Building and Construction Industry Improvement Amendment (Transition to Fair Work) Act 2012 (Cth) came into operation, replacing the Office of the Australian Building and Construction Commissioner with the Fair Work Building Industry Inspectorate (which operates under the name ‘Fair Work Building and Construction’).

The 2012 amendments also removed some of the regulator’s investigative powers, and reduced penalties applicable to certain breaches of workplace laws – both matters of concern to employers operating in the building and construction industry. See here and here.

1 February 2012

Equal remuneration ruling

A Full Bench of FWA handed down its decision in a test case seeking to increase minimum wage levels for social and community services workers, based on the equal remuneration provisions in Part 2-7 of the FW Act. In Equal Remuneration Case [2012] FWAFB 1000, a majority of the Full Bench decided to award substantial pay increases phased-in over an eight-year period. This outcome was based on an earlier decision which found that the relevant workers were paid less than other comparable employees due to their gender: Equal Remuneration Case [2011] FWAFB 2700.

2011-2012

FWA caseload statistics

FWA reported the following statistics for the financial year 2011-2012:

General protections/adverse action claims increased by 12.6% from the previous year, with 2303 claims lodged in 2011-12.

Unfair dismissal claims increased by 9.2% - 14,027 claims were lodged in 2011-12.

Protected action ballot applications increased from 759 in 2010-11, to 1011 in 2011-12. ABS data showed an increase in days lost to industrial disputes in the September quarter 2012.

Enterprise agreements: the number of agreements increased by 18.8%, with 8,565 agreements lodged for approval in 2011-12. However, recent ABS data shows that the overall level of collective bargaining coverage fell from 43.4% in May 2010 to 42% in May 2012

 

Find an Employment Lawyer

In all 50 U.S. states, every Canadian province, and over 135 countries. View or print a complete ELA member list by clicking here.

Find an Immigration Lawyer

Facilitate employee transfers around the globe. View or print a complete ELA member list by clicking here.

International Background Checks Summaries

Your free resource summarizing the requirements for pre-employment checks around the world.

Client Successes

Altra Industrial Motion Inc.

Altra Industrial Motion Inc. has multiple locations in the U.S., as well as Central America, Europe, and Asia. The Employment Law Alliance has proved to be a great asset in assisting us in dealing with employment issues and matters in such diverse venues as Mexico, Australia, and Spain. We have obtained excellent results using the ELA network for matters ranging from a multi-state review of employment policies to assisting with individual employment issues in a variety of foreign jurisdictions.

In one instance, we were faced with an employment dispute with a former associate in Mexico that had the potential for substantial economic exposure. The matter had been pending for over a year, and we were not confident in the employment advice we had been receiving. I obtained a referral to the ELA counsel in Mexico, who was able to obtain a favorable resolution of the dispute in only a few days. Based on our experiences with the ELA, we would not hesitate to use its many resources for future employment law needs.

American University in Bulgaria

In my career I have been a practicing attorney, counsel to the Governor of Maine, and CEO of a major public utility. I have worked with many lawyers in many settings. When the American University in Bulgaria needed help with employment litigation in federal court in Syracuse, New York, we turned to Pierce Atwood, the ELA member we knew and trusted in Maine, for a referral. We were extremely pleased with the responsiveness and high quality of service we received from Bond Schoeneck & King, the ELA's firm in upstate New York. I would not hesitate to recommend the ELA to any employer.

David T. Flanagan
Member of Board of Trustees 

Arcata Associates

I really enjoyed the Conducting an Effective Internal Investigation in the United States webinar.  We are in the midst of a rather delicate employee relations issue in California right now and the discussion helped me tremendously.  It also reinforced things that you tend to forget if you don't do these investigations frequently.  So, many, many thanks to the Employment Law Alliance for putting that webinar together.  It was extremely beneficial.

Lynn Clayton
Vice President, Human Resources

Barrett Business Services, Inc.

I recently participated in the ELA-sponsored webinar on the Employee Free Choice Act.  I was most impressed with that presentation.  It was extremely helpful and very worthwhile.  I have also been utilizing the ELA's online Global Employer Handbook.  This compliance tool is absolutely terrific. 

I am familiar with several other products that purport to provide up-to- date employment law information and I believe that this resource is superior to other similar compliance manuals.  I am delighted that the ELA provides this free to its members' clients.

Boyd Coffee Company

Employment Law Alliance (ELA) has provided Boyd Coffee Company with a highly valued connection to resources, important information and learning. With complex operations and employees working in approximately 20 states, we are continually striving to keep abreast of specific state laws, many of which vary from state to state. We have participated in the ELA web seminars and have found the content very useful. We appreciate the ease, cost effectiveness and quality of the content and presenters offered by these web seminars.  The Global Employer Handbook has provided our company with a very helpful overview of legal issues in the various states in which we operate, and the network of attorneys has helped us manage issues that have arisen in states other than where our Roastery and corporate headquarters are located in Portland, Oregon.

Capgemini Outsourcing Services GmbH

As an international operating outsourcing and consulting supplier Capgemini has used firms of the Employment Law Alliance in Central Europe. We were always highly satisfied with the quality of employment law advice and the responsiveness. I can really recommend the ELA lawyers.

Hirschfeld Kraemer

As an employment lawyer based in San Francisco, I work closely with high tech clients with operations around the globe. Last year, one of my clients needed to implement a workforce reduction in a dozen countries simultaneously. And they gave me 48 hours to accomplish this. I don't know how I could have pulled this off without the resources of the ELA. I don't know of any single law firm that could have made this happen. My client received all of the help they needed in a timely fashion and on a cost effective basis.

Stephen J. Hirschfeld
Partner 

Hollywood Entertainment Corporation

As the Vice President for Litigation & Associate General Counsel for my company, I need to ensure that we have a team of top-notch employment lawyers in place in every jurisdiction where we do business. And I want to be confident that those lawyers know our business so they don't have to reinvent the wheel when a new legal matter arises. With more than 3400 stores and 35,000 employees operating in all 50 U.S. states and across Canada, we rely on the ELA to partner with us to help accomplish our objectives. I have been delighted with the consistent high quality of the work performed by ELA lawyers. I encourage other in-house counsel to use their services, as well.

Ingram Micro

Ingram Micro is the world's largest technology distributor, providing sales, marketing, and logistics services for the IT industry around the globe. With over 13,000 employees working throughout the U.S. and in 35 international countries, we need employment lawyers who we can count on to ensure global legal compliance. Our experience with many multi-state and multi-national law firms is that their employment law services are not always a high priority for them, and many do not have experts in many of their offices. The ELA has assembled an excellent team of highly skilled employment lawyers, wherever and whenever I need them, and they have proven to be an invaluable resource to our company.

Konami Gaming

Our company, Konami Gaming, Inc., is growing rapidly in a very diverse and highly regulated industry. We are aggressively entering new markets outside the domestic U.S., including Canada and South America. I have had the recent opportunity to utilize the services provided by the ELA. The legal advice was both responsive and professional. Most of all, the entire process was seamless since our Nevada attorney coordinated the services and legal advice requested. I look forward to working with the ELA in the future, as it serves as a great resource to the legal community.

Jennifer Martinez
Vice President, Human Resources

Nikkiso Cryo, Inc.

Until recently, I was unaware of the ELA's existence. We have subsidiaries and affiliates throughout the United States, as well as in Asia, the Middle East and Europe. When a recent legal issue arose in Texas, our long-time Nevada counsel, who is a member of the ELA, suggested that this matter be handled by his ELA colleague in Dallas. We are very pleased with the quality and timeliness of services provided by that firm, and we are excited to now have the ELA as an important asset to help us address employment law issues worldwide.

Palm, Inc.

The ELA network has been immensely important to our company in helping us address an array of human resources challenges around the world. I strongly encourage H.R. executives who have employees located in many different jurisdictions to utilize the ELA's unparalleled expertise and geographic coverage.

Stacy Murphy
Former Senior Director of Human Resources

Rich Products

As the General Counsel for a company with 6,500 employees operating across the U.S. and in eight countries, it is critical that I have top quality lawyers on the ground where we do business. The ELA is an indispensable resource. It has taken the guesswork out of finding the best employment counsel wherever we have a problem.

Jill K. Bond
Senior Vice President/General Counsel, Shared Services and Benefits

Ricoh Americas Corporation

We have direct sales and service offices all over the U.S., but have not necessarily had the need in the past for assistance with legal work in every state where we have a business presence. From time to time, we suddenly find ourselves facing a legal issue in a state where we have no outside counsel relationship. It has been a real benefit to know that the ELA has assembled such an impressive team of experts throughout the U.S. and overseas.

A few years ago, we faced a very tough discrimination lawsuit in Mississippi. We had never had to retain a lawyer there before. I was absolutely delighted with the Mississippi ELA firm. We received an excellent result. They will no doubt handle all of our employment law matters in Mississippi in the future. I have also obtained the assistance of several other ELA firms around the U.S. and have received the same outstanding service. The ELA is a tremendous resource for our company.

Roberts-Gordon LLC

Our affiliated companies have used the Employment Law Alliance in connection with numerous acquisitions, and have always been extremely pleased with our ability to obtain the highest quality legal advice on due diligence issues from jurisdiction to jurisdiction. We have found the Employment Law Alliance firms to be not only first rate with respect to their legal advice but also responsive and timely in assisting us with federal and state law issues critical to our due diligence efforts. We consider the Employment Law Alliance to be an important part of our team.

Rockwell Collins, Inc.

We have partnered with many ELA firms on the development and execution of case management strategies with very positive results. We have been very pleased with the legal advice and counsel provided by the law firms we have utilized who are affiliated with the Employment Law Alliance. The ELA firms we have worked with are customer focused, responsive, and thorough in their approach to handling labor and employment law matters.

Elizabeth Daly
Assistant General Counsel

Sanmina-SCI

Sanmina-SCI has facilities strategically located in key regions throughout the world. Our customers expect that we will provide them with the highest quality and most sophisticated services in the marketplace. We have that same expectation for the lawyers with whom we do business. With operations in 17 countries, we need to be certain that we have a team of lawyers working together to address our employment law needs worldwide. The ELA has delivered exactly what it promised-- seamless and consistent high quality services delivered in each locale around the globe. It has quickly become a key asset for our human resources department.

Starwood

We own, manage, and franchise hotels throughout the U.S. and in more than 90 countries. With more than 145,000 employees worldwide, ensuring that we comply with the complex web of local labor and employment laws in every one of these jurisdictions is a daunting task. The Employment Law Alliance has served as an important resource for us and we have benefited greatly from its expertise and long reach. When a legal dispute or issue has arisen in some far-flung place, Employment Law Alliance lawyers have always provided responsive, practical, and cost-effective assistance.

Wilmington Trust Corporation

Wilmington Trust has used the ELA to locate firms in California, Washington State, Georgia, and Europe. Our experience with the ELA lawyers with whom we have worked has always been one of complete satisfaction and prompt, practical advice.

Michael A. DiGregorio
General Counsel  

Loading...