Examination of Witnesses (Questions 152-168)
Mr Lee White and Mr Andrew Stringer
2 NOVEMBER 2011
Q152The Chairman: Good morning. Can you hear
me all right?
The Chairman: I think there is a two
second gap between us speaking and you hearing. Mr White and Mr
Stringer, thank you very much indeed for appearing in front of
us, and welcome to our Economic Affairs Committee. We think this
is probably the first time we've done a video link with Australia,
so we hope that it works successfully. I'm not even looking at
the camera, which I should be doing. So thank you very much indeed
for that. The form is that we've a number of questions we want
to ask you and I think you know the flavour of them. We will be
taking it in turn to ask the question and the camera will pan
to each Member who is doing it, but we do tend also to come in
with impromptu questions. So I will try and control that at this
end. Thank you very much also for your written evidence to us
and we are very grateful for that. I would like to ask you whether
you want to make any opening statement or go straight on to the
questions.
Mr White: I might just make a very brief opening
statement and not really to re-emphasise what was already included
in the written submission, my Lord, but really just to set a little
bit of context from the Australian perspective.
Very briefly, if we look across the Australian
experience in the last five or six years, there have been about
four significant changes to the public policy framework around
auditing in Australia that I think we should just reflect on for
one moment. Those four components are, firstly, the creation of
government audit oversight, which is similar to what your UK FRC
has been doing. Secondly, auditing standards became legally enforceable
in Australia from 2006. Thirdly, there were a number of independence
rules written into our laws for auditors, and fourthly was the
creation and development of professional standards legislation
and proportionate liability, which really is around the capping
of liability for auditors. So in a very brief period of time we
have seenexcuse me for a minute, I think our lights have
just gone; my apologies. You have to keep moving occasionally
here to keep the lights going. But those four changes have been
very important in the auditing framework in Australia.
Q153 The Chairman: Thank you very
much for that. Your written evidence suggests that the Australian
market for large firm audit is less dominated by the Big Four
than elsewhere and certainly than here in the United Kingdom.
Why do you think this is and is the Big Four market share in large
firm audit a concern in Australia? We have just heard evidence
before you from some of the second-tier firms and one of our starting
points is that there is clear concern that if one more major audit
firm disappears we really are in a risk situation. That is the
concern here. Is that sort of concern shared in Australia or is
your position different?
Mr White: That last concern is certainly one
that we do share, but let me set a little bit of context again
from an Australian perspective. If we look at the listed market
community in Australia, there are approximately 1,800 entities
currently on the market. If we drew the ASX 200, the top 200 entities,
that would account for in excess of 80% of the market capitalisation.
So you can see in the spread of our listed markets we have 1,800
by number but most of the market capitalisation concentrated in
the top 200. So that leads us to seeing that we have a lot of
entities on the market that need auditing that are spread around
Australia and, in some senses, the geographical spread of Australia
has been one of our strengths to encourage audit firms to remain
competitive within the market.
One further element of that, my Lord, is certainly
around Western Australia. So that is where we have a lot of the
mining community and a lot of the junior miners that are listed
on the market to try and raise monies, which may or may not be
successful. So partly it is the geographical spread that has allowed
our markets to have a little bit more healthiness than perhaps
what you have in the UK. But the other element I would like to
point out, which is something building from my opening remarks,
is that the presence of the professional standards legislation
and the proportionate liability arrangements in Australia have
certainly been an element that our membership has said has allowed
them to remain within the audit community and practising as auditors
and if that strength wasn't in existence then perhaps they would
have left the Australian market as well.
The Chairman: Thank you. I am going to
ask Lord Best to ask the next question.
Q154 Lord Best: Could I preface my
question by asking to what extent the Institute of Chartered Accountants
in Australia is dominated by the Big Four in terms of your income
as an Institute and in terms of the influence that the Big Four
exert on your affairs?
Mr White: It is a bit mixed. Certainly they
are members; so individual partners and staff are members of the
Institute. We have about 55,000 members all up. I couldn't tell
you the proportion exactly but it wouldn't be a large element
individually of that membership. They do contribute strongly in
terms of assistance with some of the work that we're doing with
the rest of our membership. So we will find leaders within the
major firms who are giving time to share experiences with other
colleagues within the profession and to assist in some education
and training as well. So that would be their primary contribution.
They do have representatives that come and exist on our governance
boards at times as well.
Q155 Lord Best: Okay. Your evidence
notes that there has been a reduction in the number of audit firms,
and indeed the number of registered auditors, and you imply that
this is because of the more onerous regulations. Has that, in
itself, led to an increase in the market share from the big firms
because they can cope with all the heavy regulation? So on balance
do you think these auditing rules have gone too far, become rules
focused neglecting underlying principles, and have themselves
led to a greater concentration in the hands of the Big Four firms?
Mr White: Okay. There are a few elements to
that question. The implication that you've raised is one that
we would certainly say that's what we were implying. So those
changes that I made reference to in my opening remarks about the
introduction of government oversight and inspection and also that
the auditing standards in Australia having the force of law, did
lead to certain auditors in Australia saying in our markets, "This
is too hard now to participate in this market. We will withdraw
and do other things as accountants, other than auditing".
So, in some senses, that was a concern for us but we also saw
that it was a natural evolution; that as thresholds continue to
increase and expectations of auditors increase, then perhaps some
who no longer wish to do this in a part-time capacity would leave.
So that's what we've seen in recent times in the Australian market.
But where we saw people leave was perhaps at
quite the small end of the registered company auditor community
and we didn't really see that work flowing up or concentrating
into the major firms. In some senses that work flowed up into
the next layer above those firms and perhaps then also assisted
some of what we might call the mid-tier firms; but in Australian
terms that would be the next 20 firms underneath the Big Four.
We did also see, my Lord, in that grouping of the 20 firms underneath
the Big Four, some consolidation or aggregation of those firms.
So we started to see some greater concentration in mid-tier firms
arising from this need of trying to keep up with regulations and
focus as well.
The final part of your question was about whether
auditing rules have gone too farand I will use that phrase
of auditing rules as not being just about auditing standards.
We think in Australia at the moment there is probably a fairly
good balance. We would reach out and say we in the community all
have one goal and that goal is the delivery of high quality auditing
for the consumers of those services. So we think the combination
of the government oversight, the legal enforceability of the auditing
standards, together with the presence of professional standards
legislation and the capping of liability, have all brought about
the right components for a rigorous framework.
Mr Stringer: If I could add something to that.
The question about the auditing standards being heavily rules-based
and neglecting the underlying principles is misplaced, but the
standards that we have are very much principle-based and scalable
to all sizes of entities and, from the Institute's perspective,
one of the core objectives is to make sure we make available tools
to enable smaller practitioners, in particular, to remain on top
of the standards.
The Chairman: Thank you. Lord Forsyth?
Q156 Lord Forsyth of Drumlean: You
referred in your written evidence to the regulator's focus on
audit quality. Has that come about because there have been cases
of inadequate audit quality?
Mr White: The regulator's focus on the audit
quality has been in existence pretty well since the creation of
their oversight function in 2005. The regulator puts out onto
the public record, fairly regularly, an aggregated report of their
findings. Through that work they have not really identified any
systemic issues that are threatening audit quality in Australia,
but they have identified areas of focus for practitioners to continue
to develop and improve on in the work that they're doing.
In recent times the regulator has spoken quite
publiclyand we have supported the regulator on thisabout
the current level of discounting, for want of a better word, of
audit fees in the Australian community. That is coming not from
the regulator having seen evidence of deficiencies in audit quality
at this point; rather, it is coming, and rightly so, from the
regulator looking forward and saying, "I am concerned that
significant discounting of audit fees could potentially lead to
a compromise in audit quality in future years". So the regulator
is really on the front foot in saying, "You, the audit community,
need to be very careful here that, in striving to win or retain
work by heavily discounting fees, that is a business decision
you can take but you need to be careful you do not end up compromising
audit quality".
The Chairman: Thank you. Lord Tugendhat,
do you want to come in on the same point?
Q157 Lord Tugendhat: This is a supplementary
to that point. In this country it has been increasingly the case
that the relationship between the board and the auditors is conducted
by the audit committee and that the main relationship is that
way. First of all, is that equally the case, do you think, in
Australia? Secondly, do you feel, in terms of audit quality, that
the concentration on the audit committee has created problems
and that if the board as a whole had more access to the auditor
that would lead to a wider coverage of issues and questions?
Mr White: The first question is that the audit
committee presence in Australia has been an evolving practice.
Currently in Australia we have some requirements for the top 300
listed entities to have an audit committee. Now, that audit committee
can be just simply the full board or it can be a sub-committee
of the board. But, my Lords, you can see, again, over a fairly
short period of time that the importance of the audit committee
in the governance structures of companies in Australia has grown
in importance quite substantially and will continue to do so.
Why are we seeing that? Because you're seeing a mechanism which
brings together independent directors, management, external auditors,
internal auditors, and I think we're certainly trying to encourage
the practice and the thinking of the audit committee to be much
broader than perhaps it previously was. In Australia, perhaps
only a few short years ago, the audit committee was only focused
just on the financial statements and its breadth now is expanding
quite substantially.
The second component to your question was about
the dynamics between the board and the audit committee and how
easily that works in the Australian environment. I'd have to say
to you it is a little bit mixed. We would certainly see some experiences
where the audit committee engagement with the auditor is, in our
opinion, first rate but that audit committee then also assists
the board quite substantially in its deliberations as well. But
in other senses we are perhaps not seeing that performance as
strongly as we would like.
But we certainly would come and reach out and
say that we think there is a future for the audit committee to
continue to build on what we have as a very good foundation. But
the risk in Australia at the moment is whether the liability for
an individual existing on the audit committee is potentially much
stronger than if that individual just remained on the board, if
that makes sense. There is a sense that being on an audit committee,
particularly if you are an individual with a level of financial
acumen, trained financial acumen, you might start to be carrying
more personal liability than if you remained on the board and
that potentially can lead to the right sorts of people not being
on the audit committee.
The Chairman: Lord Hollick?
Q158 Lord Hollick: How might auditors
expand their role into reporting on risk to a client's business
model and its scope to fail? For instance, might auditors start
to provide assurance on narrative content within annual reports
including the director's corporate governance assertions, risk
management assertions and other narrative assertions?
Mr White: Thank you. We are very confident and
optimistic that the role of the auditors does need to expand.
We believe that the relevance of audit in remaining simply a retrospective
examination primarily of financial statements is important, but
still seems to be losing its relevance with a lot of the business
community and analysts and so on. We feel that auditors being
involved in some prospective worklooking at perhaps prospective
figures or risk-to-business modelsis the right way for
the audit function to move. To answer the first part of your question,
we feel it would come from perhaps the audit committee or the
full board making disclosures in the annual report outside of
the financial statements about these risks to the business model
and then for the auditors to provide a level of assurance but
not necessarily the type of assurance they would in a normal statutory
audit report. So the disclosure would first come from the organisation.
Then the onus would be on the auditors to look at that type of
disclosure on the key business risks and then to offer their opinion
on that.
Q159 The Chairman: I think this is
a very interesting point and I notice that in your written evidence
to us you had three themes and the first one was future of audit
and you did stress this point when you said that auditors are
well placed to be involved with the reporting on risks to the
business model and the potential for that model to fracture. That's
getting away from the traditional role and skills of the auditors
in many ways and I wondered whether you think that this presents
a new challenge to auditorsthe need for new skills and
wider skillsand also whether clients would be prepared
to pay for that extra service?
Mr White: We're quite passionate around this
and the reason we're passionate is that we feel, at least in the
Australian environment, that this relevance of audit is starting
to wane and we need to really think about how it can substantially
contribute back into the capital markets. The implications, some
of which you've captured there in your questions, are where we're
thinking as well, my Lord. Certainly the first one around the
skill sets and the experience of auditors will need to change.
The mind-sets of approaching and thinking about risks to a business
model auditors do to some degree now, as part of their work, but
I think that we're taking this to a very different level. So we,
as a professional body, will need to demonstrate our leadership
in building it into our core education programmes and training.
So I think there's a large piece of work there that if you're
going to change the model you need to make sure your profession
has the right skills and experience. I think we're coming from
a good foundation there but I think there's much more to be done
around how that could be improved.
The pricing element is really a very interesting
question and the pricing element comes back to this core function
around the relevance matter. At the moment in Australia, as I
indicated, there is a degree of quite substantial discounting
of audit fees going on. To some purchasers of the audit that means
or it feels like audit is just a commodity that you can take off
the shelf and anyone can buy. What we're trying to think about
is making sure that the relevance and the value proposition is
clearly understood. In doing that, if we can get the value recognition
of audit to be improved, then I believe you will get the pricing
to flow through as well.
The Chairman: Thank you. Lord Smith wants
to come in on this one and then Lord Tugendhat.
Q160 Lord Smith of Clifton: Yes please.
With regard to your second point, you were talking about mission
creep on the part of the professionthe analysing business
models and so on and just move away from just retrospective analysis
of past financesurely this needs to be delineated very
carefully, because you are almost getting a sort of professional
imperialism there. What is left to the board? If you have your
auditors doing the business model and doing the retrospective
analysis who, apart from the salesmen in the company, are doing
anything?
Mr White: Understood. I would fully agree and
support your phrase that we need to very careful in the delineation.
We believe that clearly the responsibility for the organisation
rests with the management and obviously the board of directors.
So, in the earlier comment that I made, the disclosure around
the business model and the risk to those business models needs
to, first and foremost, come from the organisation. So that information
would then be what the auditor would need to reflect on. Now,
that is where you're going to have to be very careful about whether
there is new information that the auditor wishes to then introduce
and how would that occur. But I haven't taken that as far in my
thinking as perhaps where you're asking me to, but I certainly
do support the issue around the delineation.
The Chairman: Lord Tugendhat?
Q161 Lord Tugendhat: Some of your
most important companies in Australia are in the mining business
and the most important market for the mining business is increasingly
China. Doing business in China and being dependent on China gives
rise to risks and hazards and unexpected eventualities that don't
necessarily apply in other markets. Now, in the light of what
you were saying and what Lord Smith said about mission creep,
do you think that there are aspects of the business of companies
in China that, in practice, are very difficult indeed for auditors
to assess?
Mr White: I might need a little bit more information
there to understand the question. If I could perhaps at least
offer up a first comment and then perhaps pass back to you, my
Lord. Certainly the Australian economy at the moment is very reliant
on our exports of our mining industries and certainly to China.
We think it's been a very substantial component to why we were
able to weather the GFC as an economy stronger than others. Are
you alluding to the idea that there would be subsidiaries of Australian
companies in China and how do you then get the audit assurance
around those countries?
Q162 Lord Tugendhat: Yes. I mean
China is a very different place from OECD countries and Japan,
of course, is an OECD country. So the more involved in China your
biggest companies become the more there is an element of the unknown
and uncertainty in the business environment, which both the management
and the auditors have to consider.
Mr White: I agree wholeheartedly. I suppose
we could think of some other jurisdictions outside of China as
well. That comes back to then the auditors discharging their responsibilities
in a robust way and they have rules and points of focus that they
need to deal with in what we would call group audit situations.
In dealing with countries where potentially there is some level
of greater risk, then the onus is really on the auditor to do
what is required above and beyond perhaps the norm between an
Australian and an English environment to making sure that they're
getting the right level of audit evidence to support their opinions
around that Chinese subsidiary, or any other country for that
matter.
I think an important element in this as well
is how the regulatory frameworks are building up in each country
and, again, how government regulators are starting to exchange
information as well. Now, again, China is perhaps a little bit
further away than some of the more western countries in these
discussions but you can see this as being an important element
to assist audit quality as things develop over time, too.
The Chairman: Lord Lipsey?
Q163 Lord Lipsey: Can I ask about
limited liability? It is allowed in the United Kingdom but, on
the whole, it's not been taken up; perhaps because there is a
suspicion in many minds that it is auditors trying to get out
of paying up when they mess up. But you appear to have felt that
it has brought benefits in the Australian system. I wonder if
you could expand on them and, in particular, might I ask does
it apply across the board in Australia or only where it is agreed
between the company and the auditors?
Mr White: Let me just give a little bit of the
Australian dynamics because I think the Australian model is quite
different to what may have been introduced into the UK. As I understand
it, in the UK your laws were modified to allow two parties basically
to contract together about limiting liability and, therefore,
you have this discretionary element to the arrangements. That
is quite different to what we do have in Australia and I would
have thought, without being derogatory in any way, the English
model may be working against certainly some smaller audit firms
or even mid-tier who might be wishing to engage with some significantly
larger clients who then might be putting pressure on them to not
go down the route of contracting out around liability.
The Australian example or the Australian context
is that it's mandatory. So anyone who is holding an Auditing Practising
Certificate is required, under legislation, to hold minimum levels
of professional standards capping. Therefore, while I think I
heard some reference to saying, "Well, this is just the auditors
getting out of situations", the drivers of this in Australia
were quite different. The drivers in Australia were that the insurance
markets for professional services pretty well dried up in the
earlier part of this decade and, therefore, it was seen that legislation
was required to bring the insurance back into a level of supply.
Now, why was that incredibly important? Partly
for the auditors but partly for the consumers of the audit services.
You needed consumers to have confidence that the people they were
dealing with had appropriate insurance sitting behind them. So
it's an important component of consumer protection. The other
part of the Australian scheme that works is that by being given
the limited liability the auditor profession and practitioners
have to demonstrate how they are improving their risk management
and how they are improving the delivery of audit quality in order
to see that level of giving, in order to bring the insurance components
in.
My Lord, I give just a little bit of further
context here and I apologiseand it is starting to sound
like I am more like a lawyer than an accountant, which is my training.
The other element important to this in the Australian environment
has been around proportionate liability. So, again, in earlier
years we didn't have clarity in our laws around proportionate
liability and that was more under the joint and several implications,
which again meant that auditors, at times being the last man standing,
were seen to carry too much of a burden in proportion to perhaps
the directors or others involved in whatever financial difficulties
there were.
So the introduction of proportionate liability
was a very important element to strengthening our audit profession
and community. It meant basically auditors bore a proportionate
amount of responsibility to what the courts felt they were responsible
for. So the two elements that have contributed a lot to strengthening
the Australian framework were the introduction of compulsory professional
standards legislation, the capping of liability, together with
the proportionate liability as well.
The Chairman: Thank you. Lord Maclennan?
Q164 Lord Maclennan of Rogart: There
is increasing interest in a continuous assurance approach to audit.
We wonder if the necessary software and systems might be so costly
as to strengthen the audit market position of the Big Four firms.
Might it be, impractical for smaller audit firms to develop software
to monitor their client systems on a continuing basis?
Mr Stringer: Perhaps I can respond to that.
We believe, as we said in our submission, that the move towards
continuous assurance is something that will happen perhaps as
supplementary to, rather than replacing, the historical model
that we currently work with. The question of whether there will
be this large barrier to entry for the smaller firms is something
that we do not believe is necessarily so. There will likely be
a cost element but the underpinnings for that are in place already.
The underlying technology is called XBRL and that is currently
available at little or no cost. So, to go the additional step,
we don't see that as a major hurdle.
Mr White: What we would say is that with the
development of continuous assurance you have two elements, my
Lord. You have the technology element, which Mr Stringer has just
referred to, but you also have the methodology side. Therefore,
methodology, the major firms and certainly some of the mid-tier
firms spend a lot of their time and energy in making sure they
have a robust methodology and that's their own intellectual property
and that's great. We, as a professional body, need to make sure
that we're able to also assist practitioners with their methodology
who mightn't be able to invest in it as substantially as others
can. We will certainly be carrying that commitment through as
the continuous assurance starts to be developed up in the auditing
regime. So this continuous assurance was certainly another element
we feel is certainly part of the future of the auditing and the
investing community as well.
Mr Stringer: If I could just add to that as
well. A consequence that we can see of the emerging field of continuous
assurance is the tighter integration of the external audit function
and the greater use of the internal auditors as well. That might
be something to be welcomed. There are obviously implications
for all of us in how that moves forward.
Lord Maclennan of Rogart: Thank you.
The Chairman: Lord Smith?
Q165 Lord Smith of Clifton: Yes.
Gentlemen, we see from your evidence, when we're looking at this
issue of conflict of interest between auditing and consultancy
and providing other services, that the ICCA members follow a "threats
and safeguards" approach to manage this potential conflict
of interest. While it is broadly similar to the UK approach, while
both may deal with what you call the real conflict of interest,
how can we deal with the perceived conflict of interest that forms
at least part of the expectations gap? And, on this, we have heard
from other witnesses that they maintain Chinese walls and things
like that. Well, I don't know about the Antipodes but in this
part of the world Chinese walls are very permeable.
Mr White: And, with no disrespect to our major
trading partner now, yes, they're probably a bit vulnerable down
here too, my Lord. It's really tough with the perception. It is
really tough. It's like you and I could both be looking at a similar
set of circumstances and I might be okay with that and you might
just have a very different view. So it is a little bit that each
individual will have a slightly different view in their own perception.
But where I would reach out and say, "How do we tackle the
perception issue"because it's as strong as the real,
no doubt about thatperhaps comes back to the conversation
we've already had with some of the other Lords here today, which
is around the future positioning of the audit committee.
So in Australia if we can see the evolution
of the audit committee developing, then the engagement of the
external auditor in other activities outside of just the statutory
audit really needs to be tested by an independent third party.
To me, the right independent third party falls back to being the
audit committee. So if the audit committee can clearly communicate
to its stakeholders and shareholders that they have continually
considered the relationship between the external auditor and any
other services that auditor might be providing, notwithstanding
they might be legally allowed within the frameworks within Australia,
I think that goes a long way to helping deal with and tackle some
of these perceptions.
My advice to our membership is always very much
focused, first and foremost, on perception rather than reality.
While I may have some members at times who come to me and say,
"But, Lee, we can deal with this, it's appropriate",
I always say, "But how would you feel if this was on the
front page of the Financial Review?", which is like
your Financial Times. "If it was on the front page
of the Financial Review, would you feel comfortable with
being able to explain that perception?" I think that's always
a really simple way to keep them focused on making sure that's
first and foremost in their thinking.
The Chairman: Thank you. Lord Tugendhat?
Q166 Lord Tugendhat: Well, we've
come quite a long way down the question list. If I could ask you
this question. If you could introduce one measure to improve competition
and choice in the Australian or the global audit market, what
do you reckon it would be?
Mr White: I have been thinking about this question,
because it's quite a good one. I will probably, if I'm allowed,
talk about two measures. First, I probably have already made enough
representation around this, but it wouldn't be from an Australian
perspective, it would be from a global one. It would involve saying
if we could try to have alignment of the legal structures around
the capping of legal liability and proportionate liability, I
think that alignment would go a long way to assisting audit quality;
because that's the goal that we are striving for.
I think the second element would be that we
need to be very careful that the growth of regulation cross-border
activities does not become a barrier to auditors wishing to remain
or at least join the audit profession. By that I mean that in
Australia we have made mention that we have government oversight;
the UK has the government oversight through the FRC; America has
the PCAOB and so forth. What we are experiencing in Australia
now is the visit from different audit regulators other than the
home regulator.
So, for example, the United States has been
an audit regulator that comes to the Australian community and
conducts oversight of Australian firms. So, if it is not managed
carefully, as more countries develop audit oversight, you're going
to have layer upon layer upon layer of regulators from different
countries all visiting audit firms and firms will just say, "This
is too hard", and will lead to a greater concentration of
audit firms. So I reach out to regulators to make sure that they
can try and align their work as sharply as they can.
Q167 The Chairman: I was interested
that you put the capping of liability first. I was going to ask
you, if you hadn't mentioned it, where you would rate it but you
have already dealt with that. Can I just ask you one question
about it, though? I think I heard you say that this would, in
particular, help to deal with quality and I just wondered to what
extent you would also say that it would help very considerably
to introduce more competition and make it easier for the non-Big
Four to break into the big market?
Mr White: Let me clarify my reflections there,
my Lord. Certainly the first is around the quality and we agree
with that. The second is we have certainly had direct feedback
from our membership to say that they would not have remained in
audit practice in Australia unless professional standards legislation
and proportionate liability had been introduced. So it was very
clear to us, particularly as you started to go down in size of
firms, that this was a really important piece for them to remain
competitive. Has it assisted firms come in? Very unclear for me
to say that but I certainly can say it has been a very important
component to preventing greater concentration in the Australian
market.
Q168 The Chairman: Well, I think
it is a very interesting note for us to end on; unless there is
anything else you would like to say?
Mr White: I'll ask Mr Stringer as well whether
he did. Mine would be to say thank you very much for the opportunity.
We share the passion and the focus of our British friends around
audit quality and so thank you for the opportunity to present
our views. And we look forward to the tour around the Ashes and
we look confident that we will remain successful in that sphere,
my Lord.
The Chairman: Are you going to say anything,
Mr Stringer?
Mr Stringer: I would just like to echo Mr White's
comments and thank you again.
The Chairman: I won't comment on the
controversial last point.
Lord Tugendhat: I was in Melbourne, down
in Australia, when you won 5-0 last time. I think hope springs
eternal, but we have a better team this time.
The Chairman: Can I also thank you very
much, not only for the interest you have taken in our inquiry
and for the evidence you've given us, but for the very helpful
dialogue we've had today. We're particularly grateful to you for
doing this at such an ungodly hour, from your point of view. So
thank you very much indeed for your help.
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