Examination of Witnesses (Questions 60
- 79)
TUESDAY 9 JUNE 2009
MR PETER
FRANKENTAL, MS
JENNIFER ZERK,
MS EMILY
ARMISTEAD AND
MR RICHARD
MEERAN
Q60 Lord Lester of Herne Hill: It
is very helpful to have a recitation of foreign laws, but I wonder
whether Amnesty, as a global NGO, could provide us not only with
the list of the names of countries with laws, but their own evaluation
of the effectiveness of them. May I, therefore, take as just one
example the reference to the US Alien Tort Claims Act. What is
your evaluation, as an organisation, of the effectiveness of that
Act in the context of our inquiry?
Mr Frankental: As an organisation,
we have not done a proper evaluation of the Alien Tort Claims
Act, but we do have some views about this Act. It is significant
because it gives foreign plaintiffs an avenue of redress which
they would not otherwise have in their own countries. Its limitation
is that it only refers to universal crimes, in other words, the
most egregious of violations of human rights and, as a whole,
companies tend not to be involved in these kinds of abuses, so
95 per cent of corporate impacts on human rights and most of the
rights that companies do have impacts on are not reflected in
the Alien Tort Claims Act, but nevertheless, it is a significant
instrument. Whether the solution is for lots of states to develop
their own Alien Tort Claims Act within their civil liability systems
or whether it is actually a much better solution to have an overarching
international framework, I think, is something which does need
to be evaluated, and Professor Ruggie has taken an interest in
that issue.
Chairman: We had quite a lot of evidence
from him about that last week, and we will come on to the extraterritorial
issue after Lord Onslow's short supplementary.
Q61 Earl of Onslow: I am looking
into the Bribery Bill at the moment and we are having this problem
of how you control UK companies when bribing foreign governments,
whoever it may be, and the Americans have got an Act, the name
of which I cannot remember, but it does make it a very serious
criminal offence for American companies to indulge in that sort
of skulduggery. Where we come up with immense difficulties is
with subsidiaries, agencies, all these sorts of people and the
point you were making earlier on about this UK company, which
was presumably producing aluminium smelter or something like that,
digging up sacred graves. What happens if we have an Act along
the Alien Tort Claims Act line which says, "You must observe
human rights", the indigenous Government then says, "We
don't care about the sacred ground" and, if those people
then produce a claim against the company in an English court for
abuse of human rights, how do you get round that problem? I am
looking at problems the whole time because I am not saying they
should not be got round, but the sooner we recognise what the
problems are, the easier possibly it will be to establish what
problems we have to face and how to get round the difficulties.
Mr Frankental: Perhaps we can
refer this question to CORE's legal adviser.
Ms Zerk: As regards public law
requirements, and you mentioned the example of the Foreign Corrupt
Practices Act in the US, yes, there are real difficulties with
applying laws to subsidiaries of local companies. There are international
law restrictions under international law relating to extraterritoriality
which say that you cannot apply directly your own law to foreign
subsidiaries. However, there is a great deal that you can do in
relation to the parent company, and this is the basis of most
extraterritorial regulation in the bribery area, that you apply
your primary obligations to your parent company and then you make
it their responsibility to ensure that those under their control
do not breach UK law, which was the approach, and there is a very
neat device in the Corruption Bill which deals with that exact
problem, but, as far as the civil liability issues go, Richard?
Mr Meeran: Yes, my area of work
is bringing claims on behalf of people affected by the overseas
operations of multinationals, so these are civil claims, and an
example would be the South African asbestos miners' claim a few
years ago against Cape plc, the South African asbestos miners
against a British asbestos company. The common feature of all
these cases is that they involve operations of subsidiaries of
UK multinationals, so you have the typical set-up of a parent
company based in the UK, a subsidiary operating locally, and the
problem for the local victims is that they are invariably unable
to bring claims in the local courts because of problems of access
to justice, so they sought to bring claims in England against
the parent company, and it is against the parent company because
the English courts would not have jurisdiction over the overseas
subsidiary. That gives rise to a problem of the so-called `corporate
veil', the principle which is well-established in English law
and the laws of most countries that the parent company, as a shareholder,
would not be liable for the conduct of companies in which it invests,
so the approach that we have taken in all of our cases is to focus
on wrongdoing by the parent company itself, the decisions that
it made and actions that it took which directly impacted on people
overseas and gave rise to whatever the harm is that we are dealing
with. You would look at things like the case we brought against
a company, Thor Chemicals, which was a company which made mercury
compounds in England and which then was subject to investigation
by the Health & Safety Executive here, was on the verge of
being shut down, but shipped all its operations, lock, stock and
barrel, to South Africa where it carried on operating in the same
way and people died and lots of people were injured. There, we
were able to bring a claim against the parent company because
it had been involved in the design of the defective technology,
it had taken the decision to ship everything over to South Africa
and it had been supervising, so the focus was on things that the
parent company did. That is an approach which has been described
by academics here as `foreign direct liability', so it is a way
of getting round the problem of subsidiary and parent companies.
Q62 Lord Dubs: But the difficulty
with that is that you have to be quite lucky that you establish
the link between the head office and the company where the incident
happened and you may not always be able to do that.
Mr Meeran: Exactly. It makes a
case enormously complicated and it would be much easier if it
were possible to bring a case against the local subsidiary employer
or the local subsidiary that had been responsible for the missions.
To have to investigate the precise relationship between the parent
and the subsidiary company and who was taking what decisions is
the real challenge in these types of cases and makes it very complicated.
Q63 Lord Dubs: Which brings me clearly
to my question, and it is this: if there is no clear international
legal obligation on the UK to deal with the human rights impacts
of UK companies' activities outside the UK, what incentive is
there for the Government to act? Where do we stand?
Ms Zerk: There are differing views
about whether there is an international law obligation on states
to regulate human rights abuses by companies in other countries.
My own view is yes, I would agree with Professor Ruggie's assessment
of that, that there is not enough state practice at the moment
to support the idea that states are obliged to regulate companies'
human rights impacts overseas, so I would agree with that assessment,
but, insofar as the incentives for doing so are concerned in the
absence of a legal obligation, I would say that there are three
main reasons for doing this. The first is because it is the morally
right thing to do because we, as citizens in the UK, shareholders
and consumers of products in the UK, benefit enormously from the
activities of companies abroad and the activities of their subsidiaries
and suppliers, but there are costs in other countries. Other people
in other countries bear substantial costs in relation to the benefits
that we enjoy, so there is, therefore, a moral case to do something
about it. A second incentive would be because it could actually
enhance the competitiveness of UK companies, and I say that because
there is a pretty clear correlation between corporate social responsibility
performance, which includes human rights performance, and financial
performance. John Ruggie has repeatedly made the comment that
the failure of governments to provide leadership on issues as
to what corporate human right obligations are and the failure
of governments to provide guidance on this is actually not really
in companies' best interests. I am told by businesspeople that
deciding what is and is not an appropriate use of management resources
in relation to the human rights problems that they encounter every
day takes up a lot of management time and resources. There is
also the lack of clarity about companies' responsibilities for
human rights which also creates significant litigation and reputational
risk, especially in developing countries and conflict zones, so
there is a possible competitiveness case that needs to be looked
at. Finally, it would show leadership by the UK Government. The
human rights performance of companies is an enormously important
political issue at the moment and, given that the UK is a significant
home state for multinationals, it is right that they should show
some leadership on this. I would also suggest that, if there is
good human rights performance of companies, it reflects well on
their home states and, if it is poor, it reflects badly, so there
are political issues there as well.
Q64 Lord Morris of Handsworth: Could
I pick up the point about the division of responsibility, and
my question is directed primarily to you, Jennifer and to Emily.
You have all said that the current division of responsibility
across the UK Government is incoherent and unworkable. What changes
would you make?
Mr Frankental: A good starting
point would be for the UK to have an overarching strategy on business
and human rights which does not exist at the moment. If it is
left to individual government departments to try to address these
issues, the human rights impacts of business will always be subsumed
within other departmental goals, so you have the situation at
the moment where the Foreign Office leads on certain initiatives,
such as the Human Rights Council, Ruggie's mandate, the voluntary
principles of security, human rights and, I think, on the global
impact as well, DFID leads on the Ethical Trading Initiative and
BERR leads on the OECD guidelines, so you have a fragmentation
of strategies and approaches and you do not have an overarching
business and human rights strategy for the UK, so I think that
would be a good starting point to increase coherence. I think
another important step that would need to be taken is that at
the moment the UK conflates human rights with corporate social
responsibility. Initiatives that advance corporate social responsibility
are deemed by the Government to have positive impacts on human
rights and, in our view, corporate social responsibility is a
very nebulous concept whereas human rights entitlements are very
clear, embedded in international law and, therefore, frameworks
to improve business impacts on human rights should relate to international
standards. There is nothing wrong with the UK promoting corporate
social responsibility, providing that it takes steps to ascertain
whether the voluntary initiatives and codes of conduct that it
promotes have the effect of protecting human rights on the ground
and, if not, why not, so we feel that the UK should initiate an
independent review of all its mechanisms across government departments
with regard to assessing their effectiveness in preventing and
ending abuses by UK companies and particularly abroad. There are
several other aspects of coherence, particularly coherence with
regard to investment support agencies. Does the UK Export Credit
Guarantee Department embody the UK's human rights obligations?
Should it screen companies and transactions for impacts on human
rights overseas? We believe it should, and likewise with the Stock
Exchange listing requirements. We know, for example, that a number
of small and speculative mining and exploration companies are
listed on the alternative investment market and some of these
companies are known to have a poor track record on human rights.
One of them was the subject of a recent action by Amnesty International
for their activities in Peru, yet there is no screening of such
companies as a listing requirement, and we believe that such screening
should be considered. Coherence of government policy should also
be reflected in the activities of UK missions abroad. UK missions
abroad have as a key objective to promote UK business interests,
but do they also have as an objective to address business impacts
on human rights. We believe that business impacts on human rights
should be integrated not just into training of UK missions, but
also into their objectives with regard to promoting business interests.
There are also other aspects of governmental coherence, for example,
with regard to company law. The recently enacted Company Law Reform
Bill enhanced the duties of directors and reporting requirements,
but without any specific requirements regarding human rights,
except insofar as the particular issue to be addressed has consequences
that are material to shareholders. Essentially, coherence is about
taking all governmental instruments that relate to business impacts
on human rights and integrating them into one overarching strategy
with clear objectives that are independently assessed and evaluated.
Q65 Lord Morris of Handsworth: You
obviously make a very strong linkage between leadership and responsibility,
but, when we saw Professor Ruggie a few days ago, he told us that
it did not really matter who leads, whether it is human rights
experts or indeed business experts, but what mattered for him
was a coherent and indeed a consistent policy. Do you agree with
that?
Mr Frankental: Yes, I agree that
coherence and consistency should be the two primary benchmarks
for developing effective business and human rights policies and
that it does not matter who is leading these, but I think there
does need to be a body at arm's length from Government that can
assess their effectiveness and that can provide policy guidance
to Government that is removed from the immediate interests of
individual government departments, so that is why we believe that
a UK commission, which would reflect inputs from business, from
non-governmental organisations and expert advice, would be in
a position to assess the performance of different instruments
with regard to improving business impacts on human rights and
to providing some policy guidance to Government. That would reassure
all stakeholders, whether it is Parliament, consumers, international
NGOs or business, that the considerable resources that the Government
are putting into its corporate social responsibility initiatives
actually have the effect of improving impacts on the ground.
Q66 Mr Sharma: Emily, Action Aid
appears to agree with John Ruggie, that there is a difference
between actions which companies are required to take in order
to respect human rights and worthy endeavours that may contribute
to the enjoyment of human rights, but which do not go very far.
How should a business identify what steps are required rather
than merely desirable?
Ms Armistead: Where I think we
do absolutely agree with John Ruggie is where we have had some
experience of that in some of the fieldwork that we have been
doing, for example, in India where the company that I mentioned
earlier, Vedanta, is funding community programmes which it puts
at the heart of its corporate social responsibility strategy and
meanwhile, at the same time, is involved in activities which appear
to be violating the human rights of those same communities. What
Action Aid would say is that certainly we need to have, on the
one hand, those baseline standards that companies can refer to
to ensure that they are not infringing on human rights and also
that companies are ensuring that they are, if they are going into
activities, in proper consultation with local communities and
taking into account the wishes of those communities, that there
are transparent and open processes that allow that kind of engagement
and that their wishes are being followed. I think the case of
Vedanta in the Niyamgiri Hills is an absolute case in point where
the wishes of the local communities are absolutely being overlooked.
Q67 Mr Timpson: Richard, you told
us earlier a little about the more imaginative ways that you have
had to go about trying to bring a case against a UK parent company
for an overseas litigant. In your written evidence, you have told
us about some of the barriers, both procedural and substantive,
in UK civil law which prevent these cases coming to court and
being successful, and you talk about cost, lack of protection
for group actions, complexity of the facts of the case and so
on. In some of the cases that you have been involved with, would
it, or could it, have been better for that action if it had taken
place as overseas litigation as opposed to in the UK?
Mr Meeran: If it were possible,
in short yes, and in fact at the moment we are involved in a case
which is being litigated in South Africa against Anglo American
on behalf of gold-miners who contracted silicosis, and we are
working on that case in conjunction with local public interest
lawyers and local counsel. That case has been partially funded
by the South African Legal Aid Board, but that is quite an unusual
case, quite an unusual situation. It is invariably impossible
in practical terms to bring these cases locally, which is why
we have been asked to try and pursue them here, but, as has previously
been noted, there are very difficult problems that we have to
deal with in bringing a case against the parent, in investigating
the relationship between the parent and subsidiary companies to
identify the manner in which the parent company was involved.
That is an expensive exercise and we are usually faced on the
other side with well-resourced lawyers and multinationals who
drag us up and down the legal system. In previous times, we had
the benefit of legal aid which made seeing those cases financially
less risky for the law firms involved and nowadays you have to
run these cases on a `no win, no fee' basis and, as far as I can
tell, we are probably the only firm that has shown any enthusiasm
for doing these types of cases because of the financial risk involved,
not because there are not other lawyers who would be interested
in doing these cases if they were able to do so, but the `no win,
no fee' system is one which enables these cases to be pursued,
but with great difficulty. The kind of burden that a law firm
has to carry can often be prohibitive and you have then got problems
with `after the event' insurance which you need to get to protect
claimants against the risk of having to pay the other side's costs
and also to pay for your expenses as you go along. Those can be
prohibitively expensive and the insurers are often unwilling to
back cases where the value of the cases is not sufficiently high,
and that means quite often that, where you have got very significant
human rights cases, but on behalf of people who are very poor,
the value may be too low for insurers to want to back the case.
The other problem is again a cost problem which is that, unlike
in the US and Australia, for instance, it is not possible to bring
class actions in this country. You can bring group actions, but
there is no class action legislation. If there were class action
legislation, it would be possible to bring one representative
case and it would be possible, because of the legislation provided
for it, to ensure that the limitation period of the rest of the
members of the class was protected. Often in cases, people are
worried about their safety if they bring claims and in a class
action only one person needs to be identified, the rest are not
named, so that would be an important advantage as well.
Q68 Mr Timpson: You have mentioned
a number of countries, South Africa, the States and Australia,
where there seems to be better protection or the system is less
complex for these types of actions. Are there any countries that
you have come across where the barriers that exist in the UK do
not exist or do not exist to the same degree?
Mr Meeran: Yes, South Africa is
not one of them. The case that I mentioned is just a unique case
that we have been able to pursue, but I would not say that it
was easy to bring cases there at all. Australia has a class action
procedure which is an opt-out class, which means that everyone
is in the class, unless they opt out of it. That enables lawyers
to focus on the generic issues in a case which will apply to all
members of the class rather than having to take instructions from
vast numbers of people and investigate their individual cases.
In the US, obviously they have class actions, but, more importantly,
they do not have a rule that costs follow the event. In other
words, a claimant who brings a case does not have to worry about
having to bear the risk of paying the defendant's costs if they
lose, but both sides bear their own costs in the US, so that is
another important advantage.
Q69 Chairman: Have you got some examples
of cases where you have been asked to take it up, but you have
declined because of funding issues, where you thought there might
be merit in the case, but the funding issues were just prohibitive?
Mr Meeran: Yes, there are certainly
examples of that. Those would be cases where perhaps we did not
have sufficient evidence of the role that might have been played
by the parent company. I can think of a case, though perhaps I
should not discuss specific cases, but certainly there have been
cases where we did not have sufficient evidence and it would have
been very expensive to try and accumulate that evidence.
Q70 Lord Lester of Herne Hill: A
couple of the issues that you have raised are of course under
scrutiny by the Ministry of Justice at the moment. The issue about
class actions or representative proceedings is, I think, being
looked at as a topic by the MoJ at the moment across the whole
civil justice system. The issue of conditional fee agreements
and their abuse has been tackled by the Justice Secretary and
his Department where lawyers have been abusing conditional fee
agreements, and I am thinking particularly of, for example, equal
pay cases in this country where I have some experience. In other
words, those issues are difficult and controversial, quite apart
from the subject matter of this inquiry. You have not talked about
protective costs orders in what you have just said, that is to
say, going to the judge before you litigate and saying, "We
are an NGO in a public interest case seeking to bring the case.
Will you please make an order before we go any further that, even
if we lose, we will not have to pay the other side's costs?"
I should declare an interest because I did the Corner House
case originally. Now, am I not right in saying that, since the
Corner House case, the courts have been much more liberal
in their approach to protective costs orders for the reasons you
have been giving already and that we are moving towards a South
African position of no costs order in public interest cases fashioned
by the courts if governments cannot produce a similar solution?
In other words, although I understand what you are saying and
share many of your concerns about access to justice, the protective
costs order, if it is rationalised, either procedural or otherwise,
offers some way, does it not, of taking away the great risk that,
if you bring litigation, you are going to have to pay the other
side's costs, even if you can find public-spirited lawyers, like
yourself, willing to take the case pro bono or on a conditional
fee agreement basis?
Mr Meeran: I think that is absolutely
right. As far as I know, the vast majority of cases in which protective
costs orders have been made are public law cases. There has only
been one example that I know of where a protective costs order
has been made in private civil litigation, but, in principle,
there does not seem any reason why, if it were extended to cases
generally which raise human rights issues, whether those are public
or private cases, that would not be an important benefit, I agree.
Q71 Lord Lester of Herne Hill: I
guess what is implicit in my question is that on the other two
aspects, class actions in particular, there need to be safeguards
against abuse of the system, as also with conditional fee agreements,
where a greedy or unscrupulous hypothetical lawyer might, in a
conditional fee agreement, if you take the libel area at the moment
which is well-known, a claimant's lawyer, knowing that there is
no defence, clocks up £200,000 worth of legal costs and the
newspaper then has to pay £10,000 damages, but £200,000
or £300,000 legal costs completely unnecessarily because
of the unscrupulous conduct of the claimant's lawyer using a CFA.
That is one example and I could give others. That is why, is it
not, that the MoJ is so concerned about abuses of the CFAs?
Mr Meeran: Well, I agree, these
are valid concerns. The idea of a protective costs order—
Q72 Lord Lester of Herne Hill: I
did not mean a protective costs order, but a CFA.
Mr Meeran: I understand that,
but the protective costs order only solves one of the dilemmas
that I mentioned and that is the adverse costs risk faced by the
claimant. What it does not assist with is the enormous financial
burden that lawyers will have to take on when running these cases
on a conditional fee basis, cases which may utilise a vast amount
of the law firm's resources for a period which was uncertain,
and it is in relation to that aspect that a class action mechanism
would assist.
Q73 Chairman: How would that solve
your CFA problem? The whole point about a CFA is that you get
an uplift on your costs, there is an excess premium, and that,
in order to offset the cases where you lose, you do not get anything
paid at all because effectively the law firm runs the risk of
losing the case and not getting paid, so how would the class action
resolve that issue?
Mr Meeran: Well, it would mean
that you did not have to spend so much money pursuing a case because
you could run one case on behalf of a whole class and you could
focus your resources then on the generic aspects of the case and
not on having to take instructions from vast numbers of people
to particularise their cases in order to protect their limitation
position.
Q74 Mr Sharma: John Ruggie has suggested
that states consider ways of strengthening the national contact
point mechanism through possible linkage to government support,
for example, through export credit guarantees. What do you think
of this suggestion? Does this go far enough?
Mr Meeran: First of all, I think
the national contact point system and the OECD guidelines are
an important tool because there are only so many cases you can
litigate, for a start. The problem with the system is that it
involves voluntary, non-legally binding guidelines, there is no
guidance given to companies about the standards that they are
expected to meet in order to comply with the guidelines, the contact
point is viewed sometimes as not as impartial because it is part
of the UK Government and, finally, the contact point does not
have any power to impose sanctions. Now, being able to report
non-compliant companies to export credit guarantee departments
would be one important additional tool, and also perhaps reporting
non-compliant companies to banks, funders, would be another, so,
in answer to your question, I do not think that that would be
sufficient.
Q75 John Austin: Can I follow on
from that and go on to the Corporate Responsibility Coalition's
proposal for a Commission for Business and Human Rights. CORE
has proposed that this would not only be a policy guidance, advisory
and educational body, but it should also have the power to adjudicate
on complaints and impose penalties on UK companies. Have any other
states introduced this kind of extraterritorial power, or would
the UK be breaking new ground if they went down this road?
Ms Zerk: As far as the extraterritorial
aspects of the Commission's proposal are concerned, this would
be a case of the UK trailblazing and providing a less formal means
of resolving disputes between people affected in other countries
by the operations of UK companies abroad and UK companies. Many
of the elements of the CORE proposal are already in place as regulatory
devices in the UK. For example, the informal dispute resolution
services are already provided within the powers of the Equality
and Human Rights Commission, they are provided by the Financial
Services Ombudsman. The power to investigate complaints, the power
to make financial awards up to a specified limit, the promulgation
of certain standards, these are all regulatory devices that are
already in use. It would not be the first time either that a state
had attempted to control corporate activity abroad, and we were
already discussing earlier on the example of what states currently
do in relation to bribery and corruption, but it would be the
first time that a state were to pull all of this together into
one package and create a regulatory body with specific responsibility
for the human rights performance of companies abroad.
Q76 John Austin: Mr Frankental, do
you have anything to add?
Mr Frankental: I can perhaps describe
a little bit some of the more potential functions, but that was
not really your question.
Q77 John Austin: I know that Mr Meeran
is somewhat sceptical about an enhanced role for the national
contact points system, but there are those who argue that a strengthened
system could provide a non-judicial solution. If we pursue the
CORE proposal, is that going to detract from the possibility of
a strengthened NCP?
Mr Frankental: Not at all; the
two could exist side by side. The problem at the moment is that
the NCP is part of a mechanism that has been established by the
OECD and that mechanism does not allow for remedies, so either
the UK would have to develop this mechanism in an entirely different
way or the UK and other governments would have to press the OECD
to change not just the guidelines to give them more specificity
on human rights because, as my colleague said, they do not actually
specify what activities are acceptable and what are not, but they
would actually have to offer a remedy. Governments would have
to be committed, as part of the mechanism, not just to cite the
company, but to actually offer a remedy to the victims. The Commission
would have an ombudsman role and would receive complaints, investigate
complaints and offer a remedy and, at some point in the future,
there is no reason why that function should not subsume the national
contact point, but at the moment it is a completely different
kind of animal with no enforcement, no remedies, no specificity
on human rights, whereas what we are proposing with the Commission
would be an ombudsman which would be able, under particular circumstances,
to receive complaints and offer a remedy and have some limited
enforcement powers, and that could include requiring the company
to give an undertaking not to repeat the behaviour that led to
the abuses in the first place. Those kinds of requirements of
companies to give undertakings are not part of the remit of the
existing national contact points.
Q78 John Austin: In her answer to
me earlier, Jennifer Zerk mentioned the role of national human
rights institutions. We have not yet taken evidence from the HRC,
but can you tell us what you think the Human Rights Commission
in the UK could add to the process?
Ms Zerk: Well, they clearly have
a very important role to play in relation to business and human
rights issues, particularly in relation to equality and discrimination
issues where they have a specific mandate to enforce specific
pieces of legislation, and they have a number of very useful powers
at their disposal to do this, including commissioning research,
carrying out inquiries and promulgating codes of conduct as well.
It will be interesting to hear what their evidence to you is,
but, as yet, they do not seem to be playing a very significant
role in relation to business and human rights, although, it has
to be said, there has been a very interesting submission from
the Scottish institution which clearly advocates a greater role
for these kinds of institutions in relation to business and human
rights issues, particularly in relation to foreign, extraterritorial
issues. It may just be that they are very new institutions, and
they may have other priorities, but it would be good to find out
what their plans are, of course. As regards business and human
rights issues in other countries they are restricted by legislative
mandate and resources, although, yes, it would be interesting
to hear some more about that.
Q79 John Austin: That is true here
with the EHRC terms of its powers of investigation and enforcement,
is it not, which are limited to discrimination and the Act?
Ms Zerk: That is right.
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