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Focus: Detailed analysis of White Paper: emissions-intensive trade-exposed industries 

23 December 2008

In brief: Following on from our summary of the Federal Government's White Paper on its Carbon Pollution Reduction Scheme, Australia's Low Pollution Future, Partner Grant Anderson (view CV) discusses in greater detail the assistance that is to be provided to emissions-intensive trade-exposed industries. This is the first in a series of articles that examines in more depth the principal proposals contained in the White Paper.

• Background
• Assisted activities
• Eligibility for EITE assistance
• Amount of assistance
• Entity to receive assistance
• Review of EITE assistance program
• The next step

Background

There is a risk that the Carbon Pollution Reduction Scheme (CPRS) will adversely affect Australia's international competitiveness.  This risk arises to the extent the CPRS imposes costs on an industry that is unable to recoup those costs because it competes with industries in countries that do not face a carbon price impost and because it sells its output at a world price over which it has little influence.  These costs may take the form of:

• the cost of acquiring the Australian emissions units (AEUs) which are required to cover the emissions that are attributable to that industry; and/or
• increases in the price of the energy, or in the price of the energy-intensive or emissions-intensive inputs, that the industry uses. 

Both the Garnaut Climate Change Review (See Focus: Climate Change 4 July and 30 September) and the Federal Government's own Green Paper therefore recognised the need to 'level the playing field' by providing emissions-intensive trade-exposed (EITE) industries with free carbon permits to at least partly cover these additional costs.  Consistent with this the Federal Government, in its White Paper, has decided to provide free AEUs to EITE industries 'to reduce the risk of carbon leakage and to support these industries' transition to a carbon-constrained economy'¹.  The precise extent of this assistance has been the subject of much debate, and the White Paper's final position is considerably more favourable to EITE industries than that proposed by either the Garnaut Climate Change Review or the Green Paper. 

Assisted activities

The free AEUs will be allocated to activities rather than on an industry, company or plant basis.  For these purposes an activity is defined as 'the chemical or physical transformation of inputs to produce a given set of outputs'², rather than by reference to the particular technology, plant or fuel that is used in that process.  However, as experience with the implementation of the national greenhouse and energy reporting scheme demonstrates, the process of defining an activity is a difficult one that involves a substantial degree of judgment, particularly where a production process produces intermediate inputs or a number of outputs, or is conducted over different sites³. At the beginning of 2009 the Government will issue a guidance paper that will define at least some of the activities that will qualify for EITE assistance, including the boundaries of those activities⁴. This guidance paper will not be exhaustive of the activities that may be eligible for EITE assistance, and provision will be made for industry to propose other activities for this purpose.

Even after the CPRS has commenced, industry will still be able to apply to the Government, on an ad hoc basis, to have EITE assistance extended to activities that are new to Australia or that have not previously been assessed for EITE assistance.  In such a case, these activities will be assessed using revenue, cost and emissions data for the same historical periods as were relevant in assessing the eligibility for assistance of CPRS commencement date EITE activities.  Indeed, even if an activity has been assessed as not qualifying for EITE assistance as at the CPRS commencement date, or has qualified for Category 2 rather than Category 1 assistance, industry is able to apply for a reassessment of that activity's eligibility for EITE assistance when the EITE assistance program is reviewed on the basis that commodity prices have changed such that a rerun of the assessment using those commodity prices (albeit still using emissions data from the same historical periods as were applied in assessing the eligibility of CPRS commencement date EITE activities) would result in the activity now being eligible for EITE assistance⁵. It is noteworthy that, while such a review may increase the rate at which EITE assistance is provided to an activity, it cannot result in a reduction in the rate of assistance that a qualifying activity enjoys (ie where a rerun of the assessment would result in that activity ceasing to meet the eligibility criteria that apply in respect of that rate of assistance)⁶.

All activities that qualify for EITE assistance are to be prescribed by regulation.

A disadvantage of this process for determining the activities that qualify for EITE assistance is that it will subject the Government to continuing industry pressure to expand the categories of qualifying activities and, because such activities will be prescribed by regulation, it is likely that the process will become highly politicised.  Moreover, the difficulties inherent in accurately defining activities (so as to avoid the scope for windfall gains through changing input sourcing arrangements or through the overlap of activities), together with the periodic opportunities to expand the range of qualifying activities, mean that there is a real risk that the proportion of AEUs that are allocated for free to EITE activities will substantially increase.  The White Paper estimates that, as at the commencement of the CPRS, around 25 per cent of all AEUs (accounting for $2.9 billion of value in the first year at a carbon price of $25/tCO₂-e) will be allocated for free to EITE activities and that this proportion will increase to 35 per cent if the Government gives effect to its declared predisposition to extend the coverage of the CPRS to agriculture in 2015 (agricultural activities such as the production of beef cattle, sheep, dairy cattle, pigs and sugar cane are highly emissions-intensive). This already represents a not insignificant increase in the proportion of free AEUs that would have been used to provide EITE assistance under the Green Paper, which proposed capping this proportion of AEUs at 20 per cent (excluding agriculture) and 30 per cent (including agriculture).

Further, unlike the Green Paper, the White Paper does not cap the proportion of AEUs that may be allocated for free to EITE activities.  On the contrary, because the number of free AEUs that will be provided in respect of qualifying activities is determined by reference to the output of those activities, and because the allocations of free AEUs to existing qualifying activities will not be adjusted downwards to accommodate allocations to new or expanded qualifying activities, the number of free AEUs that is provided to EITE activities will increase as the output of those activities increases.  If qualifying activities grow at the same rate as the rest of the economy, the White Paper estimates that, by 2020, 45 per cent of AEUs will be allocated for free by way of EITE assistance. However, it is not inconceivable that the proportion of such free AEUs will exceed 50 per cent if EITE activities grow at a faster rate or if the Government adopts a 2020 target that is more stringent than a 5 per cent reduction in 2000 level emissions. Expanding the proportion of free AEUs that is provided by way of EITE assistance will detrimentally affect activities that do not receive such assistance because they will then bear an increasing share of the emissions reduction burden, as well as the economic costs of an inefficient allocation of resources as between assisted and unassisted activities. In addition, the greater the proportion of free AEUs that is provided by way of EITE assistance, the less revenue will be available from auctioning AEUs to fund the Government's household assistance package and other structural adjustment assistance initiatives such as the Electricity Sector Adjustment Scheme and the Climate Change Action Fund.  To the extent that EITE assistance soaks up this revenue, the Government will need to draw on the general revenue to meet these commitments.

Eligibility for EITE assistance

Eligibility criteria

The White Paper sets out two criteria for determining whether an activity is eligible for EITE assistance and, if so, the level of that assistance. 

The first criterion is that the activity must be trade-exposed.  This is a departure from the Green Paper which viewed all industries, other than where there was a physical barrier to trade (eg as in the case of electricity and gas supply), as being trade-exposed.  For these purposes, an activity will be trade-exposed if the Government is satisfied that either of the following tests is met:

• quantitative test: the annual trade share of the output of the activity, calculated as the annual value of imports and exports of that output expressed as a proportion of the domestic production of that output, is more than 10 per cent in any of the years 2004-05, 2005-06, 2006-07 or 2007-08; or
• qualitative test: there is only limited capacity to pass through cost increases due to the potential for international competition, eg as where the domestic and international prices for the output of the activity are highly correlated (taking into account tariffs and transportation costs) or internationally-produced output is readily substitutable for the domestically- produced output of the activity (taking into account trade barriers, transportation costs and access to distribution networks). 

The second criterion is that the activity must be emissions-intensive.  While the Green Paper also proposed an emissions-intensive criterion, the emissions-intensive thresholds set out in the White Paper are less restrictive than those set out in the Green Paper.  Under the White Paper formulation:

• activities that have an emissions intensity above 2,000tCO₂-e/$million revenue or 6,000tCO₂-e/$million value-added ('Category 1 activities') will initially qualify for EITE assistance at the rate of 90 per cent; and
• activities that have an emissions intensity between 1,000 to 2,000tCO₂-e/$million revenue or between 3,000 to 6,000tCO₂-e/$million value-added ('Category 2 activities') will initially qualify for EITE assistance at the rate of 60 per cent.

The data by reference to which satisfaction of the emissions-intensive thresholds will be measured is set out below:

The longer period for the measurement of revenue (and value-added) data, compared to that proposed in the Green Paper, is intended to ensure that an activity does not fail to qualify for EITE assistance because the revenue attributable to it is measured over a short period that is characterised by unusually high commodity prices. 

Calculation of emissions

In order to determine whether the emissions associated with an activity meet one of the emissions-intensive thresholds it is necessary to include in the calculation of those emissions the following components:

• Direct emissions component: the direct (scope 1) emissions of that activity.
• Steam component: the emissions associated with the generation of steam that is used by the activity – including steam-related emissions within the EITE assistance program is an expansion of the Green Paper proposals but is supported by the White Paper because steam is a substitute for other forms of energy.  On this basis, it might be thought that emissions incurred upstream in the production of other fuel sources that are used in an activity (such as natural gas, coal and petroleum) should also be taken into account in the calculation of EITE assistance.  However, the White Paper justifies the exclusion of these other energy sources on the grounds that traded fuel sources (such as petroleum and coal) are already being provided with some assistance, which is predicated on the inability of the producers of those fuel sources to pass on the carbon costs associated with them to downstream activities, and that the carbon costs associated with non-traded fuel sources (such as natural gas) are relatively less material.
• Electricity component: the emissions associated with the generation of electricity that is used by the activity – for this purpose, the White Paper specifies a single national electricity allocation factor of 1tCO₂-e/MWh, ie 1tCO₂-e of greenhouse gas emissions is taken to be emitted in the generation of each MWh of electricity that is used in the activity.  This factor applies irrespective of whether the electricity is supplied on-grid or off-grid and irrespective of the emissions intensity of the generation source.  The White Paper recognises that this allocation factor is 'relatively generous'⁸, but justifies it on the basis that it is difficult to predict the effect of the CPRS on wholesale electricity prices and so it is preferable to err on the conservative side.
• Natural gas feedstock component: the emissions associated with the extraction, processing and transportation of natural gas (and its components such as ethane and methane) that is used by the activity as a feedstock (ie as a raw material rather than an energy source) – for this purpose, state-based natural gas allocation factors will be used to convert the amounts of natural gas feedstock used to produce $1 million of revenue (or value-added) into emissions.  Extending EITE assistance to these kinds of emissions is also an expansion on the Green Paper proposals and represents the only indirect non-energy emissions that attract EITE assistance.  This component of EITE assistance has been included on the basis that, particularly in the plastics and chemicals industries, the carbon cost component of natural gas feedstock is likely to be substantial and able to be passed through to downstream activities.

Although the White Paper states that assistance will not be provided in relation to other indirect upstream or downstream emissions, it is presumably not intended to exclude EITE assistance being provided in respect of activities (such as petroleum refining) that attract liability for emissions associated with the downstream combustion of their output.  However, it would be useful for the Government to clarify this.

Qualifying activities

On the basis of the eligibility criteria set out above it is estimated that around 40 activities are likely to qualify for EITE assistance, with Category 1 activities including aluminium smelting, lime production, cement clinker production, integrated iron and steel manufacturing, and silicon production, and Category 2 activities including alumina refining, petroleum refining and LNG production. 

The decrease of the Category 2 activities eligibility threshold from 1,500tCO₂-e/$million revenue to 1,000tCO₂-e/$million revenue will give relief to some activities (such as LNG and petroleum refining) that previously did not qualify for any assistance at all.  However, whether even the 60 per cent rate satisfies those industries remains to be seen.  Some participants in the LNG industry have been particularly vocal in opposing the Government's CPRS proposals, asserting that they may be forced to cancel or relocate proposed LNG projects, and lobbying the Government to exempt LNG production from the CPRS altogether or to provide free AEUs to LNG production on the basis that it is a rapidly expanding industry which produces a much lower emissions-intensity fossil fuel than coal⁹. While not acceding to these demands, it is clear that the Government is concerned that the CPRS is likely to affect the growth of EITE industries.  Commonwealth Treasury modelling suggests that the CPRS is not likely to lead to much carbon leakage in the sense of the relocation of existing production activities from Australia to overseas.  The more realistic concern is whether the CPRS will deter investment in new projects in Australia.  The White Paper therefore emphasises that new, as well as existing, entities undertaking EITE activities will be eligible for assistance and that, because such assistance is provided on the same basis to all activities, new investments will receive relatively more generous support (and a greater competitive boost) because they will typically be more emissions efficient than existing (older) plant ¹⁰. 

The addition of alternative value-added thresholds is also a modification of the Green Paper proposals and follows industry calls for the Government to recognise that the most vulnerable industries are those which have low margins due to international competition, even if their revenue is relatively high.  In its Discussion Paper ¹¹, the Government canvassed the difficulties involved in calculating and using a value-added measure, including the fact that value-added is typically measured on an entity (rather than an activity) basis, a degree of judgment is entailed in determining the costs that are to be included in measuring value-added, and value-added can be a fairly volatile metric as it depends on firm-specific factors.  It is for these reasons that the White Paper proposes that the revenue metric (tCO₂-e/$million revenue) will be applied to determine the eligibility of an activity for EITE assistance unless an entity that conducts an activity specifically requests that the activity be assessed using the value-added metric (tCO₂-e/$million value-added).  Where this is the case, the value-added metric will be calculated as revenue derived from the sale of the output of the activity less the cost of the most significant non-labour non-capital inputs used in the production of that output (eg the cost of the major consumable inputs into the activity such as feedstock, energy and raw materials).  The determination of the costs that are to be included in the value-added metric for any identified activity will be the subject of consultation by the Government, and the Government will determine whether the activity meets a value-added threshold.  It may be that the application of the value-added metric will result in some activities undertaken in the pulp and paper, plastics and chemicals industries in particular qualifying for EITE assistance which they would not receive using the revenue metric. 

Conversely, the Government has determined to exclude coal-mining from EITE assistance on the grounds that most of the fugitive emissions from the coal mining sector derive from a small proportion of particularly gassy underground mines, so that providing EITE assistance to all coal mines would result in windfall gains to the majority of coal mines.  Instead, the Government has committed to applying up to $500 million from the Climate Change Action Fund, over the period 2010-11 to 2014-15, towards assisting gassy coal mines meet their obligations under the CPRS.  To qualify for this assistance, the coal mine must be in operation as at 3 June 2007 (the date of Federal bipartisan support for an emissions trading scheme) and have an emissions intensity of more than 0.1tCO₂-e/tonne of output.  The coal mine will also need to establish and comply with a Government-approved emissions reduction plan.

Amount of assistance

Calculation of assistance

The initial EITE rates of assistance of 90 per cent (Category 1 activities) and 60 per cent (Category 2 activities) are deliberately structured at less than 100 per cent in recognition of both the distortionary economic effects that result from the shielding of EITE activities and the fact that it is likely to be possible to abate some of the emissions associated with those activities, as well as to pass through and absorb some of the carbon costs imposed in respect of them. 

In addition, the amount of EITE assistance that an activity receives is to be calculated by reference to industry-average emissions so as to provide proportionately more assistance to relatively more emissions-efficient activities, thereby encouraging less emissions-efficient activities to reduce their emissions intensity.  For this purpose 'allocative baselines' will be established for each activity.  These baselines will specify the values that are to be attributed, for each qualifying activity, to the emissions generated per unit of output (which is to be used to calculate the direct emissions and steam components of the EITE assistance), the electricity used per unit of output (which is to be used to calculate the electricity component of the EITE assistance) and the natural gas feedstock used per unit of output (which is to be used to calculate the natural gas feedstock component of the EITE assistance).  These values are to be set using Australian historical industry-average data for the years 2006-07 and 2007-08 or, if there are no (or insufficient) entities that undertake the relevant activity to provide a representative average, using international best practice benchmarks.  The guidance paper that is to be released at the beginning of 2009 will set out further details of the methodology that the Government will use to set the allocative baselines. 

The level of EITE assistance that an entity receives per unit of output of a qualifying activity is  calculated by applying the relevant EITE assistance rate (ie 60 per cent or 90 per cent) to the baseline emissions calculated using the allocative baselines (the indirect emissions associated with the production of electricity and natural gas feedstock being calculated by applying the relevant allocation factor)¹². 

It should be noted, however, that an entity will not be entitled to EITE assistance in respect of a qualifying activity that produces direct emissions where the entity does not actually incur liability under the CPRS in respect of those emissions.  For example, if the direct emissions of the activity fall below the threshold for liability (25,000tCO₂-e pa for a particular facility), no EITE assistance will be provided in respect of those emissions.  Assuming petroleum refining is a qualifying activity, this presumably also means that it will be necessary to exclude from any EITE assistance that is provided to petroleum refineries both emissions that would otherwise be attributable to petroleum that is not combusted (but that, eg, is used as a feedstock) and emissions in respect of petroleum for which the liability has been transferred to another entity under the proposed Obligation Transfer Number scheme.  Conversely, EITE assistance will only be provided in respect of natural gas feedstock where the relevant entity has assumed liability for the associated emissions under the proposed Obligation Transfer Number scheme.

The calculation of the EITE assistance that is to be provided to a large electricity user that undertakes a qualifying activity is subject to yet a further modification in terms of the electricity allocation factor that is to be applied to determine the electricity component of that assistance.  For these purposes, a 'large electricity user' is a user that consumes more that 2,000GWh pa of electricity at a single facility. Large electricity users will be required to provide the regulator with copies of their electricity supply contracts where those contracts were entered into before 3 June 2007 and are still in force, and have not been renegotiated or renewed, as at the date that is six months before CPRS commencement (1 January 2010 on the current timetable).  The purpose of this is to enable the regulator to determine a user-specific electricity allocation factor that is to be applied, instead of the national electricity allocation factor, for the purpose of determining the electricity component of that user's EITE assistance.  The user-specific allocation factor might conceivably be higher than the national allocation factor if the user's electricity supply contract provides for a full pass through of CPRS-related costs on the basis of the supplying generator's actual emissions intensity.  Conversely, the user-specific allocation factor might be lower than the national allocation factor if the user's electricity supply contract substantially restricts the pass through of CPRS-related costs to the user.  The 3 June 2007 cut-off date has been chosen on the basis that the parties to any electricity supply contract that is negotiated, amended or renewed after that date would have taken into account the allocation of carbon price risk as between them because that was the date of Federal bipartisan support for an emissions trading scheme.  A user-specific electricity allocation factor will cease to apply when the relevant contract ends or can be reviewed and, after that time, the national electricity allocation factor will be applied in the calculation of the user's electricity component of its EITE assistance.  Where there is no incentive for a large electricity user to provide its electricity supply contract to the regulator (ie where the contract constrains the pass through of carbon costs to the user), a regulatory incentive to do so is provided in that, unless the user submits its contract to the regulator, the user will not be entitled to any EITE assistance for the electricity component. 

Reduction of EITE assistance rates

The initial EITE assistance rates of 90 per cent (Category 1 activities) and 60 per cent (Category 2 activities) will decrease by a 'carbon productivity contribution' of 1.3 per cent pa for each of the 10 years following the year in which the CPRS commences (2010-11).  So, for example, in 2011-12 (the second year of the CPRS), the EITE assistance rate for Category 1 activities will be 88.8 per cent (0.987 x 90 per cent) and in 2020-21 (the 11th year of the CPRS), the EITE assistance rate for Category 1 activities will be 79.0 per cent (0.987¹⁰ x 90 per cent).  While this means that EITE activities will need to reduce their emissions by 1.3 per cent pa on average so as to continue to receive the same amount of EITE assistance per unit of output, this is somewhat less than the 4 per cent pa overall reduction required to meet the Government's minimum 2020 target (a 5 per cent reduction on 2000 emissions levels) and the 5 per cent pa overall reduction required to meet the Government's maximum 2020 target (a 15 per cent reduction on 2000 emissions levels). 

Withdrawal of EITE assistance

In addition, the Government may withdraw (or reduce) EITE assistance for an activity, on five years' notice, if a review of the EITE assistance program concludes that broadly comparable carbon constraints apply internationally in respect of that activity.  Such carbon constraints may take the form of an explicit carbon price (imposed under an emissions trading scheme or a carbon tax) or a regulatory-induced shadow carbon price (eg due to the mandated use of low emissions technologies or mandated energy efficiency, transport fuel or vehicle emissions standards).  While it is clear that this does not require all countries that host competing activities to adopt equivalent emissions reduction targets to Australia, the test to be applied in determining whether there are comparable carbon constraints is extremely vague, the White Paper stating that '[b]roadly speaking, a comparable carbon constraint will imply similar reductions in emissions from business-as-usual levels across countries, if countries have similar abatement opportunities'.¹³

Measurement of output

As can be seen from the above, the amount of free AEUs that will be allocated by way of EITE assistance to a qualifying activity is based on that activity's output.  These free AEUs will be provided at the start of each financial year (ie in advance of the need for those AEUs), with the number of such AEUs generally being determined by reference to the qualifying activity's output for the previous financial year.  However, there are some exceptions to this general approach:

•  in calculating the EITE assistance to be provided for the first scheme year of 2010-11, the qualifying activity's output for that purpose will be the highest average output of the activity over any two of the three financial years preceding that scheme year; and
• in calculating the EITE  assistance to be provided for the year in which a new entrant commences a qualifying activity or an existing entrant substantially expands a qualifying activity, the qualifying activity's output for that purpose will be determined by reference to the activity's expected output for that year. 

Conversely, if an entity ceases to conduct a qualifying activity in a particular year, it will be required to return to the Government that proportion of the AEUs provided for that year which is not covered by production in that year, failing which it will be liable to pay a penalty.  The returned AEUs will be auctioned off.

Entity to receive assistance

The free AEUs that are provided by way of EITE assistance in respect of a financial year will be allocated to the entity that, as at the last day of the previous financial year, would be liable under the CPRS for the direct emissions of the qualifying activity (assuming that any applicable liability threshold is met) ¹⁴. This entity will be either the entity that has operational control over the activity (or its controlling corporation, if there is one) or the entity to which that liability has been transferred.  If more than one entity would be liable for those direct emissions, then all of those entities will be required to jointly instruct the regulator as to how the free AEUs are to be allocated between them.  The liability provisions that will apply under the CPRS are rather complicated and will be the subject of a separate Focus article.

The entities to which free AEUs are allocated, the number of free AEUs that are allocated to each entity, the basis of their allocation and the total number of AEUs allocated to each qualifying activity will be published by the regulator. 

Review of EITE assistance program

Every five years, or at such other times as the Minister for Climate Change and Water may require, an independent expert advisory panel will review the EITE assistance program in order to determine, among other things, whether the program is fulfilling its objectives.  If the Government determines to change the program, it must give five years' notice of those changes. 

The next step

The Federal Government is proposing to release an exposure draft of the CPRS legislation for public comment in late February 2009.  If you would like further information in regard to the White Paper proposals that will form the basis of this draft legislation, or any other information, please contact any of the people below.

Footnotes

1. White Paper, p.12-6.
2. White Paper, p.12-20.
3. Under the National Greenhouse and Energy Reporting Act 2007 (Cth) it is necessary to measure and report the greenhouse gas emissions, energy production and energy consumption of 'facilities', ie activities or series of activities (s.9).  
4. White Paper, p.12-90.
5. It is not clear whether such a reassessment is also available where there has been a significant change in the costs that are relevant to assessing the value-added of such an activity.
6. White Paper, p.12-38.
7. Four out of five periods are used so as to exclude commodity price spikes.  
8. White Paper, p.12-66.
9. The Australian Financial Review, 'Voelte blasts emission stance' (17 September 2008), 'Carbon aid ' too generous'' (18 September 2008), 'Emissions scheme threatens LNG' (25 September 2008), 'Chevron MD slams emissions scheme' (20 October 2008), 'Chevron says ETS risks $25bn project' (21 October 2008).
10. White Paper, pp.12-9 to 12-10.
11. Department of Climate Change, 'Discussion Paper: Assessing Emissions Intensity Using a Value Added Metric' (14 October 2008).
12. White Paper, pp.12-58 to 12-59.
13.  White Paper, p.12-86.
14. It is conceivable that a qualifying activity will only receive EITE assistance on the basis of its consumption of electricity and will in fact not produce any direct emissions at all.  

For further information, please contact:

• Grant AndersonPartner, Melbourne
  Ph: +61 3 9613 8928
  Grant.Anderson@allens.com.au
• Chris SchulzPartner, Melbourne
  Ph: +61 3 9613 8772
  Chris.Schulz@allens.com.au
• John GreigPartner, Brisbane
  Ph: +61 7 3334 3358
  John.Greig@allens.com.au
• Ben ZillmannPartner, Brisbane
  Ph: +61 7 3334 3538
  Ben.Zillmann@allens.com.au
• Matthew SkinnerPartner, Singapore
  Ph: +65 6535 6622
  Matthew.Skinner@allens.com.au
• Jim ParkerPartner, Sydney
  Ph: +61 2 9230 4362
  Jim.Parker@allens.com.au
• Darren MurphyPartner, Singapore
  Ph: +65 6535 6622
  Darren.Murphy@allens.com.au
• Campbell DavidsonPartner, Sydney
  Ph: +61 2 9230 4465
  Campbell.Davidson@allens.com.au