Dynamic Competition in Dynamic Markets: A Path Forward – Fireside Chat

Below we have provided the full transcript from the Fireside Chat portion of our broadcasted conference, Dynamic Competition in Dynamic Markets: A Path Forward from August 6, 2020

Allan FELS AO:

Good morning, good afternoon, good evening everyone. I’m Allan FELS AO, former Chair of the ACCC and today it’s my pleasure an honor to conduct a question and answer interview with Rod Sims, Chairman since 2011 of the Australian Competition and Consumer Commission, the ACCC, in his third term. And the subject is the proposed news bargaining code that’s to be introduced in Australia shortly. And it follows from an earlier, larger report that the ACCC did on digital platforms inquiries. I’d like to ask Rod, before turning to the details of the proposed code to give us a little bit of the background to how this came to be.

Rod SIMS:

Thanks, Allan and welcome, everybody. We were asked in 2018 to do an inquiry, it wasn’t an investigation, an inquiry into digital platforms. The government requested, or dare I say, under the act is able to direct us to do this inquiry and that allows us to use information gathering powers in doing the inquiry. The inquiry asked us to look at competition issues, market power, consumer issues which linked to privacy as well and a particular focus on advertising in the media. It was broad range inquiry. The objective was to get recommendations to them, much as you would do if you were doing a bit of work of advocacy.

Now of course the ACCC is both the competition enforcer, the consumer enforcer but we are also an infrastructure regulator ranging from telecommunications to water trading in the Murray-Darling, we do a lot of infrastructure regulation as well. We’re broad, the terms of reference was broad. We made recommendations in that inquiry, which came out in July 2019, on a whole range of things, competition issues, consumer enforcement issues, privacy issues, media issues and one recommendation of 23, was to have a bargaining code between the digital platforms and the various news media businesses. And the reason we came up with that is we saw, as one of the many observations in the report, a fundamental imbalance in the bargaining position between the media businesses and the platforms.

While the platforms of course need news, they don’t need any particular news outlet, whereas every news outlet needed Google or Facebook. We saw the potential for a bargaining imbalance, we saw the reality of that when we looked into all the arrangements between them and looked at how things worked. We saw a real market failure in this bargaining imbalance. There’s bargaining imbalances all over the economy, but this one we judged, had a significant negative impact on journalism. And of course journalism is fundamental to a well functioning society. One of our recommendations was, let’s even up that bargaining imbalance, let’s have a real commercial negotiation between the news media businesses and the platforms where they both got better equality in their bargaining so that we can address this market failure. And therefore address something that was in our report, in our view, eroding journalism. I hope that covers, in the broad, Allan you may have-

FELS:

No, that covers it well for the moment. And we’ll talk mechanics later. But one question I wanted to put to you is that the platforms say that actually, the media does very well out of its access to their platforms, that there’s a lot of referrals to their sites. It’s a net, quite large benefit to them and on the other side, the platforms said they don’t get all that much out of it, not that much benefit, so what’s the fuss?

SIMS:

Yeah, I’ve heard that argument many times, Allan. The way to envisage the value is to think about what the platforms would be like if there was no media on them at all, so that when you go onto Google search, YouTube, any other part of Google, or Facebook news feed, you just can’t get access to anything written by a new media business. When you do that, you realize that there’s tremendous indirect value to the platforms from new media businesses. And of course, we accept that there’s not a great deal of advertising done against media items, but that indirect value where Google and Facebook, in their respective roles, are destinations where you can get a lot of things. They wouldn’t be that if they couldn’t get the media. It is of huge indirect value to them.

Their argument, that they send a lot of referrals to news media businesses, well, we don’t know how many people would go to those news media businesses directly if there was no media on Facebook and Google, it’s just very hard to work out. And of course, those referrals disguise the fact that there’s many people going onto the platforms and not clicking through. They’ve got all they need from the snippet of the news item and they can stay within Google, within Facebook and get their news without having to move on at all. These are really complicated questions, Allan. But I think when you imagine a world where Google and Facebook don’t have any media, then you start to get an idea of how that overall value transfer works to the benefit of the platforms, in net terms.

FELS:

What seemed to be very important, in any case, is that the Australian government has basically very much accepted your point of view on this. Could you tell us what happened in between the publication of your general digital platforms inquiry and why we now have a compulsory code proposal?

SIMS:

Yes. Our report was released in July, there were 23 recommendations, they are quite significant ones. The government came out with a response in December, which is pretty good, that’s within, was probably about four and a half months of our report landing with them for them to come out with their response. And they accepted 16 or 17 of our recommendations. They accepted the essence of what we were putting, which we’re very pleased about. And you think about some other reports that have been done overseas, they probably haven’t had that speedier response.

One of the responses, in December, exactly picked up our recommendation on the code. Our recommendation was, let the parties see if they can negotiate a code between themselves without any role for government, let’s see if they can work out those arrangements with the ultimate threat that if they can’t, government will step in. The government tried that, it was called a voluntary code, but the code was never meant to be voluntary. It was really just letting the two parties see if they could work it out and once they come to an agreement, that agreement would be binding, so there’s nothing voluntary about it. But we allowed nine or 10 months in our recommendations for the parties to be able to see if they could sort it out themselves. As I say, with the ultimate threat of government action if they couldn’t. In April, which is four months after December, and of course you had Christmas in the middle, the government said, look, you’re looking at all this, you’re watching all this, do you think the parties will be able to get there, particular on any sense of revenue sharing? We said, look, they’re making good progress on a lot of things, but if you ask us now, we’d have to say we don’t think they’ll get there on revenue sharing.

With that, the government then said, right, let’s not wait until November, let’s start a process in April where ACCC, could you please… They directed us to put together a mandatory code and put that back to them as a code for consultation in July and that’s what we’ve done.

FELS:

Before we talk about the details of the code, could you just say a word please about the idea of codes of conduct? They’re not applicable in every jurisdiction of the world and in this case it’s linked with legislation. Just tell us a bit about codes please.

SIMS:

Yes, we have the ability under our Act for codes to be, to sit under our Act. They sit as essentially, regulation. That is, they don’t need legislation, they can be formulated and unless parliament disallows them within a certain time, they become the law of the land, but they were subsidiary legislation. And we have those codes for franchising sectors, horticulture and things of that ilk. Here, the government thought, well calling it a code, it felt most of it should be in the primary legislation and this was the government’s call rather than ours as to where it would sit, because they felt this was important. And they also felt that if there’s any breaches of the code, they wanted significant penalties to apply. And they felt penalties better applied to legislation rather than codes that sit as subsidiary regulation.

It’s more in the legislation than in other codes, Allan. But we do have other codes and this is of that ilk, but more of it’s in legislation as I say, I think because they want significant penalties to apply if there’s any breaches of the code.

FELS:

Thanks, Rod. Now, could you tell us what is the code, what are the elements of it, including what forms of journalism are covered in regard to the revenue sharing side of the code, but also the other elements and also the processes that you envisage? A rather big question there.

SIMS:

Yes. I’ll try and keep it succinct, Allan, do my best. A news media business, to qualify under the code, must be doing what we call core journalism, serious journalism. It must be journalism that stimulates debate and really adds to society. Businesses that do produce predominantly that journalism in their news can get though the gate and be part of the code. Clearly, our major newspapers, our regional newspapers, our TV and radio stations. Where you’ll have an issue of dispute, is some of the magazines, but put that to one side. You get through the gate by producing core news, news that stimulates debate or at a local level, reports on local court reporting, council work and all that sort of thing. But, it’s there to inform and engage the community.

FELS:

What wouldn’t get in, Rod, like sports events?

SIMS:

If you had a journal that was just devoted to sport, that probably wouldn’t get in. Certainly, if what you were doing was just showing sporting events, that wouldn’t get in. It’s really got to be things done by journalists and it’s got to have a core element to it of engaging public debate. It’s pretty close to public interest journalism, Allan, that you need to be doing to get through the gate. Once you’re through the gate, then all your journalism counts, because we feel that people who produce public interest journalism do so as part of a package. Once they’re through the gate, the whole package is enabled. Then, they start negotiating on revenue and non-revenue aspects. The code has a range of minimum non-revenue matters, such as 28 days notice of algorithm changes or other changes that are going to have a significant effect on news. Certain data information has to be provided, certain ways in which news media can prevent commentary on their news on the platforms, a bit of moderations they can engage in. A range of things like that, of non-revenue. And then, they can also negotiate to get payment for their content and they can do that in whatever way they want.

The parties, once they’re through the gate, trigger a bargaining and mediation process. That can run for as much as three months and in that three months the parties could do a deal. Now, the parties can be either individual media organizations, or a collective media organizations and we’ve done that so that our two main newspapers in Australia, we’ve got two main newspaper groups, we envisage they would bargain separately. They may not, but that’s their call. And then we have a whole range of regional, rural newspapers and 88 of them came together to give us a joint submission. We would expect they would come together and bargain as a collective. And under the ACCC Act, collective bargaining is allowed, it has to go through certain processes of ACCC approval, but it’s something that happens all the time. Dairy farmers collectively negotiating with a dairy processor and the like. The parties can either be collectives or individual media companies, three months bargaining.

If they can’t agree, then that starts and arbitration process that arbitration process involves each party putting in what’s called a final offer. I think in some jurisdictions this is called baseball arbitration, there’s various names for it. But it’s a final offer arbitration. The arbitrator gets a final bid from the news media business and a final bid from the platform, either Google or Facebook. Each party has five days to comment on the other’s final bid and the arbitrator has 30 days to choose between those bids and decide which one should be the offer that’s arbitrated as being what will become the payment contract between the parties.

Now, once they see each other’s bids, that might start off a lot more bargaining so we’re hopeful that commercial agreements will come out of this before it gets to the arbitrator making a decision. But, at the end of the day, the arbitrator can make that decision and can determine what the payment is. They can reach a bargain on revenue and non-revenue matters at any time. But the arbitrator, because we tried to keep this simple, is really only arbitrating on the revenue payment element. In the case of Google, Google search and Google News and things like that and Facebook news tab and Facebook news feed, things of that ilk as well, payment for media content shown on those platforms. It’s only the revenue that would get arbitrated, but if they want to do a deal between themselves, they can bargain on anything they like.

FELS:

Before we dig into that, could you tell us, what’s the role of several institutions? The Australian Communications and Media Authority, which is a little bit like the Federal Communications Commission or Ofcom, but not that similar and then, there’s the ACCC. What’s their role in all of this?

SIMS:

The Australian Communications and Media Authority, they do regulate media, they also regulate spectrum in Australia. If the media come out and say something outrageous on radio or TV, or in print, ACMA have a role. And they auction off spectrum allocation and do a range of other things in terms of retail communications, they also regulate retail telecommunications. Their role is two-fold, one is to decide who meets the criteria of providing core news. That is, who gets through the gate to be allowed to bargain. Their second and only other role is to put together a panel of arbitrators so that if the parties can’t agree on an arbitrator, ACMA will choose a legal industry, an economic person from their panel of 10 arbitrators who will do the arbitrations. ACMA gets to choose the arbitrators from a panel they have put together.

The ACCC’s role is to enforce the code. If there’s breaches, take people to court or do whatever one needs to ensure compliance with the code. The ACCC also has a role in advising the arbitrator, the arbitrator can completely ignore the ACCC’s advice. But the ACCC does provide advice to the arbitrator, and that’s just an attempt to see if we can get some consistency to be a friend of the court as it were, to help the arbitrator who’s probably coming to these issues fairly cold. But, as I say, try and get some consistency. A key issue with the arbitration, just to close off Allan, is that when the arbitrator’s deciding on final offers, most of the time we envisage they’ll pick the offer of the platform or media business and go with one of those. And of course, that has the advantage that we won’t get ombud claims, we don’t think. But if the arbitrator decides neither offer is in the public interest, then they can take the best offer and modify it. And again, the ACCC can provide them a bit of advice on that.

FELS:

And just before we get into the final offer arbitration a bit more, just on the institutional side, what happens to the Australian Broadcasting Commission, the public broadcaster, the equivalent if you like of the BBC?

SIMS:

And this is something on which we didn’t provide advice, because we felt it was very much an issue for government. The government has decided that the Australian Broadcasting Commission, as well as the Special Broadcasting Service, the SBS, which is also government owned and largely government funded, they won’t be included in the code. They can bargain for non-revenue items, but they can’t be included for revenue. Now, that’s a government decision, that’s up to government. I certainly think one of the considerations was that the ABC is publicly funded for a reason, so that it’s not influenced by commercial issues and I think that logic had something to do here. But, there may well have been other forces at work, but certainly it’s publicly funded for a reason. And the ABC gets 95% of its revenue from government, free from any commercial influence.

FELS:

Could we dig a little deeper into the possible benefits, but also the possible difficulties of final offer arbitration? And in that regard, there is some final offer arbitration at work where there isn’t a huge amount of difference between the parties where there’s a pretty good knowledge by everyone, including the arbitrators, of what’s going on in the industry. And, where there’s not much difference in the principles that people believe should be applied. Now this is a different situation. The parties seem to be a million miles from one another. They have a completely different view of the rights and wrongs of it. It’s also not that easy, actually, to work the numbers and so on. Are there any possible unintended consequences or difficulties that could arise in this situation? Or, is it a stroke of genius, the ideal way of finding a way through the middle?

SIMS:

Allan, I think many of the points you made actually support final offer arbitration. You’re right, the parties are a long way apart. Both sides were posturing publicly. We had Google and Facebook, as you mentioned earlier saying, no, we don’t get any value out of media or its trivial value, but we give them a lot of value. So if you want a value transfer, the media businesses should pay the platforms. And the platforms alternatively were talking about extremely high numbers, 600 million in the case of one of them, a billion dollars a year in the case of the other as per annum collective payments. Now, it’s really hard to tell what the right number is when you try and do the value. It’s really hard to get the information to do those calculations. We certainly couldn’t get it from Google or Facebook. The problem is, if you have as it were, normal arbitration, we strongly believe each party would put in bids at very different ends of the spectrum and leave the arbitrator with what seemed to us to be the impossible job of working out what the right answer is. It would almost be a one to two year exercise to try and get data, which we haven’t been able to get from the platforms. Even if you get the data, it’s really hard.

We felt that because it was so hard, much better to try final offer arbitration. That way, you’re going to have to put in a real bid. Because you’re worried that if you go the extremes, and the other side puts in a real bid, their bid will win. Or the other puts in a partly ombud claim and you put it a full ombud claim, they might win and you’re in very great trouble. This is the only way we could think to bring the parties together to avoid an arbitrator having to really arbitrate when they’re stuck, they’ve got nothing to guide them. The parties are best placed to work out what the value should be here.

What we’ve done, Allan, though is a couple of things to ground it a bit. Firstly, we’ve said that the arbitrator can make a public interest adjustment if they find that both offers aren’t in the public interest. As I say, the ACCC will be there to advise on that. But the other thing is that you’ve got other criteria there. The arbitrator is to decide the payment based on three things. One is the value of the media content to the platforms, I’d say very hard to calculate, but essentially what this is about. Two is, in any negotiation like this you would think if it was a proper commercial negotiation, you would have some regard to the cost of producing the journalism. That’s a consideration and obviously, it’s not one percent of the cost of producing the journalism and it can’t be 100%. You start to frame the numbers that way. And also, it can’t be an undue burden on the platforms and so, understanding the platform finances. I think once you take that cost of journalism, and it’s the cost of journalism taking into account other forms of revenue and reasonably attributable to the platforms. I think you can get your hands around that. The arbitrator will be able to do that. And also, making sure it’s not an undue burden.

We think with those extra criteria it’s manageable. The only other thing I’d say, Allan, these one year deals, if it turns out it doesn’t work we might have to think again. But it’s a one year arrangement. There’s the capacity to optimize as we go, but we think it will work.

FELS:

I want to ask a question, which you’ve largely implicitly answered, but I’ll put it. Why didn’t you just say, the government and the ACCC will decide these questions or decide there should be a certain amount of revenue taken off Facebook and Google? And maybe that would be determined by the government, or by the ACCC, or by an independent body and process. And also, that the money would be allocated by some kind of independent, public minded body. And to add just a touch to that question, leaving it this way actually hands over very big value judgements and other judgements to a few arbitrators, whoever they are.

SIMS:

Yeah. Allan, I think this alternative way you posited, leaves that judgment to either the government or the government perhaps relying on the ACCC’s advice or some other body’s advice. Ultimately, you would have that body make the judgment without any input from the parties whatsoever. And I think we would find that really hard to do. The whole point of this is, bargain over the value of news media to the platforms. The whole logic of this was, there’s a bargaining imbalance. Google is 98, 99% of search in Australia. Facebook and with Instagram and WhatsApp, it just completely dominates the social media scene. These are really dominant platforms. And there is a significant bargaining imbalance. And yet, here we’re bargaining over access to media content and how media businesses get remunerated. And if media businesses can’t get remunerated for their content, then you really have a problem in Australian society. We want it to be bargained between the players. We think there’s every benefit in the players trying to sort this out amongst themselves. And this final offer arbitration is really just to even up the bargaining imbalance. To say to the platforms, well, if we can’t reach agreement, we’re going to go to this final offer arbitration. Wouldn’t it be better to avoid that, by coming up with a reasonable deal?

And it could well be the media businesses says, well, it’s not everything I wanted, but it’s a reasonable deal and goodness knows what I’ll get out of the final offer arbitration. I think, Allan, we’re trying as much as we can to set up a proper commercial negotiation. You can’t have a commercial negotiation when you’ve got a very uneven bargaining situation. We often find in Australia, we’ve got monopolies and they want commercial bargaining. But of course, they’re a monopoly, they’ve got to be used so there’s no choice. And we’re in a pretty similar situation here, to get a proper commercial negotiation with proper commercial drivers, we think you need a forcing device, but we’re really trying to solve for a commercial outcome here. We’re not trying to have the government impose it. We think it’s very difficult for the government to work that out.

FELS:

Thank you. Now, I had a couple of questions about the multilateral bargaining that will go on. Firstly, can Facebook and Google talk to one another, exchange information, even coordinate and collaborate their response?

SIMS:

No, they can’t. Nor can the individual media bargaining entities. Up front, you must decide whether you’re bargaining on your own, which our major newspaper groups may do or you’re bargaining collectively. Once you’re in your group, your group is your group and then you can’t be exchanging information between groups, either the platforms or the news media businesses.

FELS:

Prior to your announcement there was quite a bit of discussion about your smaller publishers such as rural and regional small suburban newspapers and so on. And you’ve said something about them, maybe you could say briefly what you’re doing about them. And also address the concern that existed, certainly before your recent announcement, that they might get almost left out of it. That there would be, so to speak, no money left for the little people.

SIMS:

Yeah. Well, this is a key issue, Allan. And that was never intended and from our point of view, never going to be the outcome. The whole point of allowing them to bargain collectively is that they can come together, pull their resources. There’s also organizations out there to help them, the public interest journalism institute, I think it’s called, which you’re familiar with, Allan. But there’s other entities there that can help them.

We think they can come together and bargain just as effectively as the individual large newspaper groups. This is worth it for them, to get the resources they need. We don’t see any reason why they shouldn’t benefit in the same way the larger companies do. And we want of course is diversity in news media. And look, players will come and go, but new players who come along, they can join themselves onto a bargaining group. That’s quite straightforward. I expect maybe that bargaining groups, with those 88 regional and rural, may get enlarged by other players coming on. We really don’t know how big that collective bargaining is going to be. But we do encourage collective bargaining, we think that is really the only way those smaller innovative players, or that is the way for them to get the benefits and the full benefits from the code. We don’t see any reason why they shouldn’t benefit as much as the larger players under what we’ve set up. If someone thinks we’ve missed something out, then of course this consultation period is there to help us fix anything we’ve got wrong.

FELS:

I think to a degree you’ve answered the question what about innovators who start with nothing and want to do a new form of publication. And I think you have a revenue floor of 150 000 Ozzie dollars. What about small innovators, can they just join in?

SIMS:

Yeah. Look, we’re open to that. I think though, one has to accept that if you’re a company that just starts up and you’ve got nothing and you’re producing media content, you don’t just want somebody who starts a blog to automatically be in this process. That’s going to get you nowhere. It’s got to be a company of some substance. We’ve got a lot of small towns in Australia, as you know, but as your listeners may not. They’ve got individual newspapers, but those papers still are big enough, we think, to fit under that 150 000. You’ve got to have at least some substance to you. If you come along and innovate, you’ve obviously had two digital-only companies that have started off in Australia, the Guardian Australia and the Daily Mail. Now obviously, they’ve come from the UK, they’ve got big backing overseas. But we’ve got other organizations, The Conversation, Crikey, a range of others who started up, they’ve got themselves established.

If you startup, you get yourself established in some way, like those other ones I’ve mentioned have had to do often starting from nothing, then when you get to some size, show us you’ve got something that matters, you can come into the code. But to just stick your hand up and say, “I’m nothing and I want to walk through the door.” I don’t think we can allow that. You’ve got to be some respectable sized media organization. We’re open to discussing that to see that we don’t in any way damage diversity and innovation, but I don’t think we have.

FELS:

One final big question. What if Google and Facebook don’t play ball. What if they walk, as they seem to do in Spain. What happens then?

SIMS:

Yes, well what happened in Spain, if I remember it correctly is, there was a need for payment on the Google News tab, which is a tab not many people know about. It’s a special tab for news, Google just closed that down. In France, there’s a bargaining arrangement based on copyright and as I understand it, Google offered to pay zero. And the competition regulator there said well, you can’t do that, you’ve got to offer something. What we’ve done here is say, this is about media content on your platform. This does include all the parts of your platform that has snippets of news, Google News tab yes, but your basic search. The only way this could be avoided is if Google and Facebook either left Australia completely, which of course, they can do or show no news at all from anywhere on their platforms. Because the other thing here is a non-discrimination provision, which says you can’t discriminate between media businesses based on their participation or otherwise in the code.

If Google or Facebook said, right, we won’t show any Australian news on search, but we’ll show international news, that would be discrimination, that’s not allowed. As we understand it and as this is formulated, the only way it could be avoided is if Google and or Facebook decide that they won’t have any news, international or domestic, on their platform. Now, I think if they did that, in both cases that would diminish their platforms significantly. If they did want to do that, there may well be other platforms that spring up, wanting to provide that news and that would then be a serious competitive threat to Google and Facebook, respectively. What I’d say, Allan, is that both Google and Facebook have built fantastic businesses, really very innovative business providing things for free to get people’s data. They provide great services for free to get people’s data to sell advertising. I think they have to understand that their platforms do benefit from news media that gives their platforms credibility.

Does Google really want people Googling Coronavirus only to get a whole lot of non-media answers back as distinct from all the massive media research that goes into COVID-19 issues. This is why Google and Facebook could go to search and social media platforms. I know I’m going beyond your question, but I think, as mature businesses, they do need to realize that they can’t grab everything for free. They are relying on people who spend a lot of money to create this product, journalism doesn’t come cheap. It is important to their platform and this codes says they really need to pay something for that.

FELS:

That’s a very substantial answer. I was just going to add a comment which is that, they possibly would be worried if they pulled out totally in that manner you have suggested. The government has got some steps it could take. It could bring in a general internet tax, for example.

SIMS:

Yes, Allan. I think we, I mean our code proposal has got nothing to do with taxation, nothing at all. It’s got nothing to do with copyright, which is the European model, because that’s its complicated issue. Whatever the government wants to do about taxing Google and Facebook must be based on tax principles. Those standard provisions about tax havens avoidance, that’s its own other issue sitting over there. Just like copyright’s its own issue sitting over there. This is about purely, companies that have got substantial market power, which creates a bargaining imbalance, which creates a market failure which is damaging journalism and that’s what we’ve got to fix up. It’s purely that economic issue and I’m afraid I would push back very strongly if the code got caught up with concepts of copyright, tax or anything else. It’s simply fix the economic market failure here. It matters to society. Many market failures don’t matter that much, this one does.

FELS:

Finally, Rod, what’s the timing?

SIMS:

Well, the plan as I understand it from the government, is to allow consultation until the end of August. The code came out at the end of July on the 31st, so until the end of August, I think it’s the 28th of August for comment. And we’ll be actively knocking on everybody’s door talking to Google, talking to Facebook, talking to the news media businesses large and small, getting their comments on the code. We’re leaving them alone for a few days to let them get their mind around it, then we’ll present a final back to government at the end of August. If the government’s comfortable with that, it will present it to parliament. There’s parliamentary sittings, I think, in October. My hope, personally, is that this wins bipartisan support and gets through parliament in October or early November. Gets assented to by the governor general and becomes the law of the land in early November so that the three months bargaining process starts. That does ruin people’s Christmas, I realize, but hopefully we can get some deals done, proper bargains done by March, April next year and get relationship between media businesses and platforms on a proper footing that’s sustainable for both sides.

FELS:

Thanks very much, Rod. Unless you wanted to add anything after that, very comprehensive explanation to us. I’ll just close this part of the program, but thank you very much for giving us your time and your very clear explanation.

SIMS:

Thanks, Allan. It’s a pleasure. It’s a really important issue, so I’m delighted that this is being broadcast by CPI. Thanks very much to CPI for doing that.