COVID-19 Leave, Testing & Isolation Requirements

Posted on 22 February 2022 | by Allan Hall

COVID-19 Guide to Leave, Testing and Isolation Requirements

Navigating changes in employment legislation related to Covid-19 has been difficult for many business owners across Australia.

As COVID-19 hospitalisation/ ICU numbers decrease and vaccination numbers increase, the NSW Government is committed to easing restrictions, including no longer needing to wear masks in offices from Friday 25 February 2022. Although testing and isolation requirements have been in place across each State for some time now, with many employees returning to work in communal office environments in NSW it will remain important for employers to have access to up-to-date Covid-19 related processes and leave options.

The below information provides a guide regarding leave, testing and isolation requirements to support you in managing your employees. For assistance in resolving employee-related queries or situations which are not covered below, please get in touch with our HR Consultants for support on 1300 675 393 or at [email protected].

Illness

Employees should stay home if they have cold symptoms, such as coughing/fever/sore throat/shortness of breath/loss of taste or smell or other symptoms of COVID‑19.

If employees develop symptoms while at work, they should be directed to:

separate themselves from other employees;
notify their manager; and
make arrangements to go home immediately.

If employees are unfit for work due to symptoms, they can access their Personal (Sick/Carer’s) Leave. If the symptoms are mild, employees may request to continue working from home and this may or may not be suitable depending on their position and specific situation.

Close contact of COVID-19 positive

If your employee is notified that they are a close contact of a person with COVID-19, advise them to separate themself from other employees, notify their manager and make arrangements to go home immediately. You can advise them to follow the Testing and Isolation Rules that apply in your state as per the table below.

Confirmed Case of COVID-19

If an employee tests positive for COVID-19 they should self-isolate immediately and notify their manager. You can advise them to follow the Testing and Isolation Rules that apply in your state as per the table below.

Employees should follow all medical advice to recover from their infection as soon as possible. Employers must take the necessary steps to determine possible exposure to COVID-19 by colleagues in the workplace and undertake appropriate sanitisation and quarantine if necessary. Employees may return to the office only in accordance with advice from the relevant health authorities in each State or Territory.

If an employee has contracted the virus (or has caring responsibilities for someone who has contracted the virus) and has consequently fallen ill, they will be entitled to Personal (Sick/Carer’s) Leave. An employer’s standard Notice and Evidence requirements will apply.

Quarantining or Self-Isolating

Employees may be required to quarantine or self-isolate, and consequently not be able to work, for a number of different reasons, including but not limited to:

contracting the COVID-19 virus;
an enforceable government direction;
a government-imposed travel restriction; or
a lawful and reasonable direction made by the employer to get tested which has led to a quarantine/self-isolation period.

Payment during Self-Isolation Period:

If an employee is unwell and unfit to work (or caring for a family or household member who is unwell) during the quarantine/self-isolation period they will be eligible for paid personal (sick/carer’s) leave (full-time/part-time employee) or unpaid personal (sick/carer’s) leave (casual employee)
If an employee is fit to work and has the capacity to continue to work during their quarantine or self-isolation period (which will be dependent on their role and eligibility to work from home), they will continue to be paid for the work they are doing.
If an employee is fit and able to work, however cannot continue to safely perform work whilst quarantining at home, they may have other paid or unpaid leave options or other flexible work arrangements available to them, including:
- access to untaken paid Annual Leave entitlements
- access to paid Long Service Leave entitlements (as applicable)
- access to Unpaid Pandemic Leave for up to 2 weeks (this entitlement is only available to certain award covered employees – see below for further information)
- access to Leave Without Pay
- access to Pandemic Leave Disaster Payment through the Government for eligible employees (see below for further information)
- other flexible work arrangements, such as an agreement to work to make up time upon conclusion of the isolation period

Unpaid Pandemic Leave – Award covered employees

Most Awards have been temporarily amended to give employees access to Unpaid Pandemic Leave. Two weeks of unpaid pandemic leave is available to all employees (including casuals). The employee will not receive payment, however, any time taken under this leave type will count as service and the employee will continue to accrue paid leave entitlements as if they were working.

Note: Unpaid Pandemic Leave does not apply to non-award covered employees.

Pandemic Leave Disaster Payment:

If any employee cannot work and earn an income, has no sick leave entitlements and has been directed to self-isolate or quarantine or needs to care for someone who needs to self-isolate or quarantine they may be eligible for the government funded Pandemic Leave Disaster Payment. There are eligibility criteria for the lump sum payment. Further details can be found here: https://www.servicesaustralia.gov.au/pandemic-leave-disaster-payment

State and Territory Testing and Isolation Rules

NSW / ACT / VIC / QLD: The Eastern States of Australia reached agreement on 5 January 2021 on COVID-19 Test & Isolate National Protocols which can be found here: https://www.health.gov.au/news/updated-covid-19-test-and-isolate-national-protocols
WA: Testing https://www.healthywa.wa.gov.au/Articles/A_E/Coronavirus/COVID19-testing
- Isolation https://www.healthywa.wa.gov.au/Articles/A_E/Coronavirus/Quarantine-and-isolation
SA: Testing and isolation https://www.sahealth.sa.gov.au/wps/wcm/connect/public+content/sa+health+internet/conditions/infectious+diseases/covid-19/testing+and+tracing/test%2c+trace%2c+isolate+and+quarantine
NT: Testing https://coronavirus.nt.gov.au/stay-safe/symptoms-testing
- Isolation https://coronavirus.nt.gov.au/stay-safe/covid-19-positive
TAS: Isolation https://www.coronavirus.tas.gov.au/travellers-and-visitors/quarantine-and-isolation-directions/isolation
- Testing https://www.coronavirus.tas.gov.au/keeping-yourself-safe/contact-tracing/types-of-contacts

Our experienced HR Consultants are available to support you with any employee-related questions. Please get in touch with us today on 1300 675 393 or at [email protected].

Employers’ Biggest Challenges for 2022

Posted on 3 December 2021 | by Allan Hall

3 Tips for Employers

Attracting and retaining good employees has always been a big challenge for businesses, however we now see it looming as a major obstacle for employers in 2022.

Business is looking to boom, but you will need the right team to be able to take advantage of the opportunities.

Why now?

As we come out of nearly two years of unprecedented business disruption and uncertainty due to the COVID-19 Pandemic, a number of factors have combined to produce an extraordinary set of circumstances, including:

business confidence has surged as we come out of lockdown and economic activity is rebounding quickly
the Reserve Bank has increased its forecast GDP growth for 2022, to 5.5%
recruitment activity is now nearly 50% above pre-pandemic levels and job advertisements are now at historical highs
at the same time, unemployment is historically low, and there are now serious and persistent shortages of skilled labour across the country, with trades and technical areas particularly in short supply
with easing concerns over COVID-19, a number of employees are taking the opportunity to re-evaluate their careers and how they want to work in the future, and it has been predicted that this trend will develop further next year as the economy takes off. This phenomenon has now come to be known as, “the Great Resignation”.

As you wind down from 2021 and before the new year gets into full swing, we recommend that you get ahead of the game by following these three tips for employers.

3 tips to attract and retain good employees in 2022

Tip 1: Conduct an employee satisfaction/engagement survey

Take the time to understand how satisfied your employees are with their work and how engaged they are with your business. Employees who are satisfied and engaged, rarely leave, even when offered more money. Consider undertaking an employee survey to help you better understand your employees’ thoughts and feelings and identify any “imminent flight risks”.

Tip 2: Review your employee remuneration, benefits and rewards

With surging economic activity, a booming recruitment market, and skilled labour in short supply, there is likely to be pressure on increasing wages and salaries, particularly as they have remained flat for a number of years. Many employers are also looking at new and different benefits and rewards to make their offer more attractive than their competitors. It is suggested that all employers take the opportunity now to review salaries, wages, benefits and rewards to ensure you remain competitive and well-positioned to retain your valued staff.

Tip 3: Proactively source quality talent

Spend some time forecasting your labour requirements for 2022 and determine if you are likely to need additional skilled staff. The tightening labour market over recent months has seen the number of applicants per job advertised, decline steadily, and clients report that quality candidates are becoming increasingly hard to find. This means that if you are in the market for staff in 2022, you will most likely need to be more creative in how you find the “right” people for your business, and you should consider seeking professional assistance to proactively source the highest quality talent.

Our highly skilled and experienced team at Allan Hall HR have assisted our clients in all these areas, such as engagement surveys, salary reviews and quality sourcing and recruiting of talent.

Please contact us if you would like to discuss your current business situation and people needs. We would be excited to help you prepare for the year ahead with the right team in place to seize all the opportunities coming your way!

Contact Allan Hall Human Resources in Brookvale

National Minimum Wage Rise Reminder

Posted on 1 November 2021 | by Allan Hall

As a reminder to all our clients, the third and final fleet of Awards are due to have wages increased from the first full pay period on or after 1 November 2021.

To re-cap, the wage increase is part of the national minimum wage rise.

This year the Fair Work Commission announced a 2.5% increase to all Award wages, which were to be rolled out in three stages.

There are 21 Awards which will be impacted by this last stage.

Please refer back to our initial article for further details:

National Minimum Wage rise

In light of the current Coronavirus pandemic, we want you to know that our team at Allan Hall HR is still working hard and assisting many businesses with HR matters. First and foremost, we are here to help, so please do not hesitate to contact us should you have any questions or require any HR advice.

Casual Employee Conversion deadline

Posted on 23 September 2021 | by Allan Hall

Casual Employee Conversion deadline is 27 September 2021

In our article in March this year, we provided information about recent changes to legislation relating to casuals.

The legislation introduced the requirement that all employers must issue all current and future casual employees with the Casual Employment Information Statement.

In addition, under the changes, employers with more than 15 employees are required to assess all casuals employed before 27 March 2021 to determine whether they are eligible to be offered conversion to permanent employment. This assessment needs to be done by 27 September 2021. This requirement does not apply to small business employers (with 15 employees or less).

In summary, unless there are reasonable business grounds not to make an offer, casuals must be offered casual conversion if they:

(a) have worked for the employer for 12 months; and

(b) have worked a regular pattern of hours for at least the last six of those months on an ongoing basis; and

Within 21 days of the assessment, employers are required to notify each casual employee of the outcome of the assessment, even if the employee is not eligible for conversion.

There is an ongoing obligation to assess each casual employee for eligibility to be converted to permanent employment on the anniversary of their employment each year.

Allan Hall HR can assist you with the assessment of your casual workforce, drafting the required communications to your casuals and implementing processes to ensure ongoing compliance with the legislation.

As there are penalties for non-compliance with the legislation, we encourage you to act now.

If you have any questions or require support, please do not hesitate to contact us directly at [email protected].

COVID-19 employee vaccinations

Posted on 16 August 2021 | by Allan Hall

COVID-19 Vaccinations for employees

The Fair Work Ombudsman has released additional guidance to employers on the circumstances in which it could be appropriate to require their employees to be vaccinated.

See link: https://coronavirus.fairwork.gov.au/coronavirus-and-australian-workplace-laws/covid-19-vaccinations-and-the-workplace/covid-19-vaccinations-workplace-rights-and-obligations#lawful-and-reasonable-directions-to-get-vaccinated

Employers can only require their employees to be vaccinated where:

a specific law (including the public health orders) requires an employee to be vaccinated
the requirement is permitted by an enterprise agreement, other registered agreement or employment contract, or
it would be lawful and reasonable for an employer to give their employees a direction to be vaccinated, which is assessed on a case-by-case basis.

As to whether or not a direction is reasonable requires a case-by-case assessment based on factors which include:

the nature of the workplace (are employees in public-facing roles and is the business an essential service?)
The extent of community transmission in the location of the workplace, including the risk of transmission of the Delta variant
WHS obligations and the effectiveness of vaccines
Each employee’s circumstances including if there is a legitimate reason not to get vaccinated
Vaccine availability

To guide employers in the case by case assessment, the Fair Work Ombudsman has divided workplaces into four tiers:

Tier 1 work where employees are required as part of their duties to interact with people with an increased risk of being infected with coronavirus (for example, employees working in hotel quarantine or border control).
Tier 2 work where employees are required to have close contact with people who are particularly vulnerable to the health impacts of coronavirus (for example, employees working in health care or aged care).
Tier 3 work where there is interaction or likely interaction between employees and other people such as customers, other employees or the public in the normal course of employment (for example, stores providing essential goods and services).
Tier 4 work where employees have minimal face-to-face interaction as part of their normal employment duties (for example, where they are working from home).

As you would be aware from our recent article, the NSW Government has imposed a number of restrictions to combat COVID-19 including making specific public health orders which require workers in certain industries to have had a vaccination (or have an exemption) in order to work.

From 11 August 2021, additional restrictions were imposed on employees from “areas of concern” which are currently the local government areas of Blacktown, Campbelltown, Canterbury-Bankstown, Cumberland, Fairfield, Georges River, Liverpool, Parramatta and some suburbs of Penrith. To keep up to date with changes to the public health orders and updates to the local government “areas of concern” go to https://www.nsw.gov.au/covid-19/rules/affected-area#summary-of-restrictions.

Construction industry

Since 31 July 2021, work has been allowed to resume on construction sites in Greater Sydney including in local government areas of concern. However, construction sites in local government areas of concern must comply with a number of requirements listed here: https://www.nsw.gov.au/covid-19/rules/construction-rules-and-restrictions#rules-for-construction-sites.

One of the requirements is that from 11 August 2021 workers who live in or are temporarily staying in a local government area of concern must comply with vaccination requirements in order to work at or enter a construction site in Greater Sydney. A person from these areas must not enter or remain at a construction site in Greater Sydney unless they have:

had 2 doses of a COVID-19 vaccine or
had one dose of a COVID-19 vaccine before Wednesday 21 July 2021 or
had one dose of a COVID-19 vaccine after Wednesday 21 July 2021 and you have been tested for COVID-19 in the past 72 hours (3 days) or
evidence of a medical exemption and you have been tested for COVID-19 in the past 72 hours.

If a person is required to have a COVID-19 test to enter or remain at a construction site, they must have a COVID-19 test once every 72 hours.

Construction workers can request a COVID-19 vaccination exemption for medical reasons.

Further information in relation to the evidence requirements is here: https://www.nsw.gov.au/covid-19/health-and-wellbeing/covid-19-vaccination-nsw/covid-19-vaccination-for-workers.

Other industries

There are also vaccination requirements for quarantine facilities, transport providers and airport workers. Further information is available here: https://www.nsw.gov.au/covid-19/health-and-wellbeing/covid-19-vaccination-nsw/covid-19-vaccination-for-workers

Residential Aged Care

From 17 September 2021, COVID-19 vaccinations will be mandatory for all residential aged care workers. For further information see: https://www.health.gov.au/initiatives-and-programs/covid-19-vaccines/information-for-aged-care-providers-workers-and-residents-about-covid-19-vaccines/information-for-residential-aged-care-workers-about-covid-19-vaccines.

Assisting your employees to get vaccinated

The NSW Government has released a number of resources for businesses to use to encourage their employees to get vaccinated and to ensure that employees have access to accurate information on the vaccination program.

The information is available here: https://www.health.gov.au/resources/collections/covid-19-vaccination-business-kit#information-sheets.

Allan Hall HR will continue to provide updated information about managing vaccinations in workplaces and keep you apprised of changes to the COVID-19 restrictions which impact you and your employees. If you need advice and assistance in relation to the specific circumstances in your workplace, please get in touch with our team on 1300 675 393.

National Minimum Wage rise

Posted on 18 June 2021 | by Allan Hall

National Minimum Wage to rise by 2.5%

In its decision on 16 June 2021, the Fair Work Commission increased the national minimum wage to $772.60 per week or $20.33 an hour.

Unions had sought an increase of 3.5% on the basis that pay growth is crucial to stimulate post-pandemic economic recovery, while some employer groups called for no increase due to the impact of the pandemic on businesses.

When does the change come into effect?

The new national minimum wage will apply from 1 July 2021. However, the award increase has been delayed in sectors most affected by the COVID-19 pandemic and will therefore take effect in 3 stages.

Most awards will increase from 1 July 2021. Wages in the Retail Award will increase from 1 September 2021 and the rates in 21 other awards where the FWC deemed there were exceptional circumstances will increase from 1 November 2021.

The awards that will increase from 1 November 2021 are listed here.

Pilots Award
Cabin Crew Award
Airline Ground Staff Award

Airport Award
Alpine Resorts Award
Amusement Award
Dry Cleaning and Laundry Award
Fitness Award

Hair and Beauty Award
Hospitality Award
Live Performance Award
Models Award
Marine Tourism and Charter Vessels Award

Nursery Award
Racing Clubs Events Award
Racing Ground Maintenance Award
Registered Clubs Award
Restaurant Award

Sporting Organisations Award
Travelling Shows Award
Wine Award

Which employees will receive this increase? 

Employees whose minimum wage entitlements are set by:  

The national minimum wage  
A modern award   
A registered agreement (in some circumstances)

It is important to note that if you have non-Award covered employees on a salary which is above the national minimum wage, you are not obliged to increase their salary, however you could consider an increase at their next salary review meeting.  

What do employers need to do? 

Check whether your employees are covered by the national minimum wage, or a modern award.

Should a modern award apply to your employees, ensure you have correctly classified employees under the relevant award, and confirm the minimum rates of pay that will apply.

Review the  current rates of pay  for your employees  and, if  required, adjust their  pay rates from their first full pay period starting on or after the appropriate date as it applies to your modern award.

Need help?

We assist many businesses with their application of the relevant awards and the minimum rates of pay for their employees to ensure businesses remain legally compliant. Our team at Allan Hall Human Resources can assist you to navigate this process smoothly and efficiently. Please do not hesitate to contact us should you require assistance or have any further questions.

Super Guarantee base rate rise 1 July

Posted on 3 June 2021 | by Allan Hall

SG base rate rise set from 1 July which will increase from 9.5% to 10%

Employers should turn their attention to managing the superannuation guarantee (SG) increase which comes into effect on 1 July.

An SG base rate rise is set from 1 July which will increase from 9.5% to 10%, followed by incremental half percentage point increases each year to 12% on 1 July 2025.

Businesses should establish an approach strategy to the increase now because non-payment, underpayment or late payments of the new rate are likely to attract ATO attention.

Regardless of how a business approaches the change, it should be done with transparency that clearly communicates how employees’ payslips will be impacted.

Employers should also review their employees’ contractual and award arrangements to ensure their strategy to the payment increase is in accordance with their legal obligations. Please contact Allan Hall HR on 1300 675 393 or [email protected] if you would like assistance in reviewing or interpreting your current employment arrangements.

Contributions for each employee are required to be paid on at least a quarterly basis. Employers are urged to brace for the SG increase on 1 July by provisioning for payroll changes via business activities that sustain cash flow.

Do note that software providers will be making the adjustment to their systems but, depending on your setup if you have manually entered a rate you may need to adjust this.

CONTACT ALLAN HALL HR

JobMaker Hiring Credit Scheme

Posted on 29 March 2021 | by Allan Hall

Wondering if you can afford to take on any new employees in the aftermath of COVID19?

The JobMaker Hiring Credit Scheme is a payment-based program offered by the Government to incentivise employers to hire job seekers aged under 35 during the COVID-19 recovery.

Eligible employers can access the JobMaker Hiring Credit for each eligible employee they hire between 7 October 2020 and 6 October 2021.

The JobMaker Hiring Credit enables eligible employers to:

claim $200 per week for hiring each additional eligible employee aged 16-29 year old
claim $100 per week for hiring each additional eligible employee aged 30-35 years old
make a claim quarterly in arrears for up to 12 months after the eligible employee starts work

Similar to JobKeeper, to make a claim, eligible employers need to register for the scheme and report employees’ payroll information to the ATO.

The first claim period closes on 30 April 2021 so it is important to check if your business and employees are eligible and register now.

Are you an eligible employer?

You are eligible to receive the JobMaker Hiring Credit if you:

Have an Australian Business Number (ABN)
Are up to date with tax lodgement obligations
Are registered for Pay As You Go (PAYG) withholding
Satisfy the reporting requirements through up-to-date Single Touch Payroll (STP)
Have registered for the scheme and are claiming in respect of an eligible employee
Satisfy the payroll and headcount increase conditions of the JobMaker Hiring Credit Scheme
Have not claimed JobKeeper payments for a fortnight that started during the JobMaker period

What is an eligible employee?

Is aged 16–35 years
Needs to increase your total employee headcount and payroll
Has received the JobSeeker Payment, Youth Allowance (Other) or Parenting Payment for at least one of the previous three months at the time of hiring
Is employed or is paid for a minimum of 20 hours a week

For more information visit https://www.ato.gov.au/General/JobMaker-Hiring-Credit/

If you would like assistance with registration, please contact your Allan Hall Business Advisor.

Need help with recruiting eligible employees for your business?

Offering a fresh approach to your recruitment needs while delivering value for money, why not consider utilising our highly skilled recruitment team at Allan Hall Human Resources to assist you with sourcing eligible employees? We can help you find people fast who will thrive and help your business to grow.

Happy friends enjoying on terrace. Smiling man and women are celebrating together during sunset. They are wearing casuals in party

How to avoid HR Issues during the Festive Season

Posted on 10 December 2020 | by Allan Hall

A different kind of Christmas Party during COVID!

Each year we like to send out a reminder to employers of your obligations when it comes to those end of year celebrations.

CLICK HERE to read ‘How to Avoid Christmas Party Incidents!’

This information certainly still applies, in fact this year you have additional responsibilities, including making sure that your party is held in a COVID safe manner.

What does this mean? Essentially, you need to continue to abide by the latest COVID safe advice from the NSW Government. Updated information can be found HERE.

If you have a large workforce and are planning a gathering, you might have to consider breaking your team up into smaller groups to satisfy social distancing requirements.

Or get creative and host a virtual gathering with some added flare, such as a guided Christmas cooking class with all ingredients delivered, virtual wine tasting or traditional trivia. You may even consider ways in which you can take your event outdoors where more people are allowed to gather.

We have all had to adapt to new ways of thinking this year. Including those ever important social events!

Annual Leave Requests

With the Christmas–New Year period fast approaching, you may notice an increased number of annual leave requests waiting for your approval. For those businesses that shut down over this period, approving annual leave is usually a joyous task. However, for smaller businesses continuing to trade during this period, it can be somewhat of a difficult juggling act to ensure you have enough employees on board to meet your customers’ needs while also ensuring employees receive a well-deserved break.

When reviewing annual leave applications, it is important to remember that you cannot unreasonably refuse to authorise an employee’s request to take annual leave. If you need assistance with understanding the rules surrounding ‘reasonableness,’ please do not hesitate to make contact with our HR team.

Public Holidays

In NSW the gazetted public holidays for the holiday season are:

Christmas Day Friday 25 December
Boxing Day Saturday 26 December
Additional Day Monday 28 December 2020
New Year’s Day Friday 1 January 2021
Australia Day Tuesday 26 January 2021

Can employees refuse to work on Public Holidays?

Employers can request that employees work on a public holiday if the request is reasonable. Likewise, an employee can refuse to work on a public holiday if the employer’s request is not reasonable. In determining whether the employer’s request is reasonable, under the Fair Work Act a broad range of factors are taken into account. These include:

The nature of the employer’s workplace and the nature of the employee’s work
The employee’s personal circumstances
Whether the employee could reasonably expect the employer might request work on the public holiday
Whether the employee is entitled to receive overtime or other penalty payments that reflects the expectation to work public holidays
The type of employment of the employee (eg whether full-time, part-time, casual or shift work)
The amount of notice in advance of the public holiday given by the employer to the employee
The amount of notice given by the employee when refusing a request to work on a public holiday.

Payment for Public Holidays

A permanent employee who is absent from work on a public holiday is entitled to be paid their usual pay for his or her ordinary hours that would have been worked, even if they reasonably refused to work that day. Payment is at the employee’s base rate of pay (which excludes bonuses, loadings, allowances, overtime or penalty rates). Casual employees who refuse to work on a public holiday are not entitled to payment.

For Award covered employees or employees covered by enterprise agreements, it is important to check the penalty rates which apply on public holidays. Where a public holiday falls on a weekend, as it does on Boxing Day this year, there may be an entitlement to either the greater of the applicable penalty rates between the public holiday and the weekend penalty rates or both penalty rates. It is therefore important to check the Award or enterprise agreement carefully to ensure you pay your employees correctly.

Proposed changes to Employment Laws

Also, very topical in the lead up to Christmas this year is the Government’s significant proposed changes to employment laws in Australia. These include:

The way casuals are defined and treated
Changes to underpayment of wages, compliance and enforcement measures
Changes to the way Enterprise Agreements are made and approved
Simplification of Modern Awards

On 9 December 2020, the Federal Government introduced into Federal Parliament the Fair Work Amendment (Supporting Australia’s Jobs and Economic Recovery) Bill 2020 which set out several reforms to the Fair Work Act 2009 to address some long-standing issues in these areas.

Our HR experts are experienced in interpreting these reforms and are monitoring the progress of the Bill closely. It seems likely that there will be amendments negotiated in coming weeks and we will provide you with further detail and explanation once the legislation has passed. In the meantime, if you have any questions, please don’t hesitate to contact us directly at [email protected].