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Standing Committee on Economics

PIPER, Mr Timothy Charles Henry, Victorian Director, Australian Industry Group

RAWORTH, Mr Christopher Ian George, Systems and Compliance Manager, Mars Chocolate Australia

TALBOT, Mr Simon Edmund, Director, Kraft Foods Australia/New Zealand

THOMPSON, Ms Jennifer, Technical and Regulatory Manager, Australian Industry Group


CHAIR: I welcome representatives of the Australian Industry Group to the hearing. I remind you that, although the committee does not require you to give evidence under oath, these hearings are legal proceedings of the parliament and warrant the same respect as proceedings of the House or the Senate. The giving of false or misleading evidence is a serious matter and may be regarded as a contempt of parliament. Would you like to make an opening statement?

Mr Piper : A couple of us are keen to make an opening statement. I will make one on behalf of the industry in general and manufacturing in particular. If they can, my colleagues will make statements also. Thank you for the opportunity to speak to you today about the confectionery industry's concern about the truth in labelling palm oil bill. The Australian Industry Group, as many of you might be aware, is a national organisation. We represent about 70,000 businesses around Australia. They vary from the very largest—all of the names that you know regularly—to some of the very smallest. About 50 per cent of our members have fewer than 50 employees. So we represent companies from the very largest to the very smallest.

We recently took responsibility for representing the interests of Australian and New Zealand confectionery manufacturers. These include, for example, Kraft—which recently merged with Cadbury—Ferrero, Mars, Nestle, Wrigleys and many others in the smaller areas but who certainly are important members of the confectionery sector.

As our submission to the committee advises, our members are opposed to the palm oil bill. Some of the reasons are that we believe that it will fail to achieve sustainable palm oil production and use and that we believe that enforcement of the provisions of the bill is highly problematic, particularly given our relationship with New Zealand. The bill ignores the voluntary move to source certified palm oil by a number of confectionery manufacturers that have recently been looking to do that; and it will add substantial costs, which we estimate at $25 million for the label changes alone, to confectionery manufacturers. I must add again that that is to both large and small confectionery manufacturers, who will find the costs quite significant.

Palm oil is an important ingredient for the confectionery manufacturing industry, and we share concerns with you and with other members of the public about the destruction of rainforest and associated habitat in South-East Asia. For these reasons, many manufacturers support the Roundtable on Sustainable Palm Oil, or RSPO, as the most appropriate means of achieving sustainable palm oil production. Many AI Group confectionery sector member companies are actively involved in the RSPO, supporting sustainable sourcing, and are already on this journey.

Palm is a highly efficient yielding product. The world population is growing by approximately 80 million a year and it is forecast that by 2050 the world will need about a third more calories than we have at the moment to meet the projected need. We therefore need to produce palm sustainably.

As the Leader of the Opposition highlighted in the House of Representatives earlier this week, following the announcement of foreshadowed large job losses at Qantas and OneSteel, Australian industry, and the manufacturing industry in particular, is under considerable pressure. It makes little sense, therefore, to us to be adding additional burdens, certainly via food-labelling changes. We believe that it is important to give you an idea of just how manufacturing is coping at the moment.

Manufacturing in Australia employs nearly one million Australians and most of those jobs are full time. The resources industry, in comparison, employs a little less than 200,000. That is one million families which are reliant on the income of a manufacturing plant. That is one million families who see manufacturing as part of their future. Manufacturing is being impacted in a way that, I must say, I have not seen in the 10 years I have been in this present position. I now see friends who are in business or who were in business that have recently passed into administration in a particular sector—it was in the defence sector—that we actually thought was a strong niche area. I just want to tell you a little bit about it because I think it brings home the impact on manufacturing at the moment.

This friend had 40-plus staff. He had contracts for the joint strike fighter and he has not been able to complete those, simply because of the high Australian dollar. He invested many millions of dollars in high-tech machinery that literally has been made redundant because of the costs that the dollar has imposed on him. My friend cannot compete and really a lot of his life's work has now gone; and his and the jobs of 40 others with him have gone as well.

I visited a yacht supplies manufacturer earlier this week; the company was Ronstan. They invested millions of dollars into their business several years ago. The business has been hit by the dollar. It is now working to 30 per cent capacity. He is reconsidering his position in Australia and trying to decide which Asian country he should invest in next. It literally will not be in Australia, as we stand. Then there are other companies, such as the one that I visited on Tuesday. Four or five years ago, this company had 2,400 employees; today, it has 255 employees. We only need to look to Ballarat, to some of the regional areas, and look at the manufacturing impact there. Over a third of the economy in Ballarat is based on manufacturing. Eighteen months ago, they had 5,400 people employed full time in manufacturing; today, it is 1,600 less.

I tell you these stories but, of course, there are many more, because it is the environment that manufacturers find themselves in—and they are not unusual stories or one-off stories; they are what is happening to manufacturing companies every day around Australia. I certainly ask you to take this into account when you are deciding whether to impose further additional costs on Australian companies.

We also ask you to consider our nearest neighbour, New Zealand, which may not have to comply with any new regulations that you are considering imposing. Is it reasonable to have those additional costs, therefore, imposed in Australia?

The other point that I would like to make is that the Australian Industry Group maintains a number of indices; one of them is the performance of manufacturing index. At 50, the industry is neither contracting nor growing. Over the past 12 months, it has been very rarely in the 50 territory. But last month or the month before, it happened to get to 52. In the next month, it went down by nine points—down to 43. What we are finding is that we are back into almost GFC territory. At that stage, there was certainly concern with manufacturers but it was probably more of a perception at that stage as to whether there was going to be demand. Now we are back to the 43 level, GFC territory, but it is more than perception. There is not the demand there. We are feeling the effects of the Australian dollar. We are feeling the effects of a two-speed economy. We do know that we are competing in an export market that is very difficult to compete in because of the high Australian dollar. But, equally as important, back here in Australia we are competing with imports; we are competing on our own shores, and it is very difficult. We are having to keep our costs to a minimum, of course. We are fighting to compete. Every size of manufacturer is dealing with supermarkets, but the smaller ones are being forced to reduce their margins by the supermarkets here in Australia and they have concerns about additional costs that are always being imposed on them. Any new regulations, whether it be this or whether it be others, whether it be a carbon tax or labelling laws, are obviously going to impose costs on Australian manufacturers. We do ask that, when you are considering any steps in labelling, you consider just the impact on those Australian manufacturers.

Mr Talbot : I would like to give a marketeer and manufacturer's perspective from Kraft Foods. We are the world's second largest food company. Ninety-five per cent of our manufacturing in Australia uses locally sourced material, with the exception of cocoa and coffee beans. We strongly support the dairy industry and we do import palm oil and are members of the RSPO.

From a manufacturer's perspective, we see a number of concerns that place us at a global disadvantage. We recently upgraded a number of our manufacturing facilities—Ringwood, which employs 1,100 people in Victoria; and Claremont, which employs 700 people in Hobart—to a level where we would say that they are now getting close to being globally competitive.

This bill, as I read it, has four major cost implications, and I want to lay these out for your review. The plate changes, which we have touched upon—that is, changing a label, a label that we hold quite precious with our consumers, because that is how we survive as a marketeer—are in the order of $6 million to $8 million of direct cost. Operating inefficiencies: we have worked for the last 15 years to have one label for many of our products that can be exported across South-East Asia and also to New Zealand. So a Cadbury block of chocolate can be exported to around 16 countries with the current label on it.

I just want you to look at the operating complexity of our stopping machines to change labels. There is no doubt in my mind that Malaysian and Indonesian export markets will not accept a palm oil label due to the tarnished reputation that palm oil has in this country; likewise we have the anomaly of New Zealand. Those operating inefficiencies are quite dramatic and they take us off that global competitive radar.

The third concern I have—and I have not quantified it with my team yet—is the potential loss of markets. I have no doubt that there could be some implications with Malaysian and Indonesian consumers around this particular issue. The last cost we face is the replacement of emulsifiers. Palm oil is an ingredient in many of the emulsifiers we use and the replacements often have a more negative health benefit. Palm oil is a wonderful carrier of a number of natural colours, as an example. So we will almost be taking a step backwards and also taking on an additional cost by taking out some of the wonderful formula benefits of palm oil.

I want to give you an example of this as it relates to our brands, and it is a very broad comment: our brands sit in 95 per cent of Australian households, from Vegemite to Cadbury chocolates. If you had an absolute threshold of palm oil, as in every single part per million palm oil in every product, 75 per cent of our brands would be affected and we would have to label accordingly. If you had the threshold at two per cent, that would affect less than 10 per cent of our products having to be labelled.

Palm oil is, as I have said, a wonderfully beneficial product. From a calorific value viewpoint, we do not see major health implications. From a formulaic viewpoint, we see some wonderful benefits in relation to food safety. It is an outstanding product in biscuits in particular for keeping moisture out, and moisture is the enemy of food safety. So we see a series of concerns from the economic viewpoint and from the health viewpoint.

The last comment I want to make is on the sustainability front. I have seen this move before; we faced it five years ago with cocoa and some labour and sustainability issues in Ghana. We implemented fair trade with consumers and with NGOs. I see palm oil as we stand at the moment as another fair trade element. The major companies globally are very close; they are at the threshold of getting to a point where we have sustainable palm that benefits the communities in Indonesia and Malaysia. If we walk away from that commitment—as with fair trade, we underwrite a minimum price that goes into health, societal benefits and education in those communities—the lowest cost producer and the Chinese will take up the excess demands.

We feel we have a mandate and a responsibility as an ethical food manufacturer, to work and to continue. With the palm oil bill as it stands at the moment, the labelling will tarnish all manufacturers in the same way, and I would hate to see a number of major manufacturers move away from that sustainability commitment—and why would they want to have that sustainability commitment if they are not getting any benefit in the marketplace with their brands?

CHAIR: Thank you for those comments. Mr Piper, with your general proposition in relation to where the manufacturing industry is in Australia, were you disappointed that the coalition changed their position in relation to this legislation? Previously both Labor and the coalition had opposed this legislation. Was it a source of disappointment to you that they had changed their position?

Mr Piper : We are obviously keen to see that there is not a change made to the legislation as it now stands. We would prefer to see that there was not a change. We do not see there is a need for change. Industry sees it as an imposition if we have to make labelling changes; therefore, we just want to keep the costs as low as we can in order to remain as competitive as we possibly can.

CHAIR: So the Greens-coalition alliance is not, in your view, friendly for manufacturing?

Mr Piper : Manufacturing is going through a difficult time; we know that. The dollar is just making impositions that we have not seen before, and the concern is that this dollar will stay strong for quite some time and we are going to have to start to deal with it. So if there are any new costs imposed on manufacturing, with any regulations in particular, we think it will be disadvantageous for our members.

CHAIR: You meet with the senior members of the coalition frequently to talk about business concerns and policy options that are there, don't you?

Mr Piper : We do.

CHAIR: And you have been raising this issue with them—that their alliance with the Greens is something that is a disadvantage in relation to this legislation?

Mr Piper : I have not spoken to them individually. However, my organisation has. We have mentioned to them that we would prefer that they were not focusing on this, that they did not create any legislation that might disadvantage manufacturers.

CHAIR: So you are happy to be on the record saying that you think the coalition have got it wrong in relation to this legislation—that they should not have changed their minds?

Mr Piper : We would like to see all sides recognise the impact on manufacturing.

CHAIR: That was not the question I asked. Have the coalition got it wrong in relation to this legislation?

Mr Piper : We would like to see—

CHAIR: No, I am asking you: have the coalition, in your view, got it wrong in relation to their approach to this legislation?

Mr Piper : As I said, we would prefer to see that all sides of government recognise the impacts of any labelling changes on the manufacturers and ensure that our competitiveness is maintained just where it is.

CHAIR: You are trying a lot of linguistic gymnastics here, but this is a question that invites a yes or no answer—

Mr BUCHHOLZ: He has answered that.

CHAIR: In relation to—

Mr BUCHHOLZ: I understood it, Chair.

CHAIR: I am glad you understood it. I was not quite clear. I thought that, given what he said, the answer would be that he does think the coalition has got it wrong. But I am giving him the opportunity to actually say that himself.

Mr BUCHHOLZ: You have strayed a bit from palm oil. Normally, I am the one who strays.

CHAIR: You will get your chance to ask your questions.

Mr Piper : Whether it is the coalition, the Labor Party, the Greens or Independents, we obviously would prefer them to recognise that manufacturing is in a difficult situation—that includes the food manufacturers—and any labelling changes that are made will impact detrimentally on them and, therefore, it will be a competitive issue for us. If the coalition or the Greens were to amend their position, we would be pleased to see that.

CHAIR: This is not just a political point I am making. The coalition had a different position when this bill went to the Senate, so it is a live point that is there. They then changed their position, so I am doing more than just trying to make a political point. There has been a change there and that is affecting, you are saying, the outcome of this. If they did not change their view from the position that was previously there, you would have both major parties saying that this legislation is unnecessary and we would not be here today, I imagine.

Mr Piper : That is more than likely the case. We have spoken to members of the coalition about our concerns and have sought for them to agree with the position that we have taken.

CHAIR: And to agree with their previous position, presumably.

Mr Piper : Presumably so, yes.

Mr BUCHHOLZ: Thank you, Mr Chairman. I do not know what you are winking about, Timmy! Your wonderful manufacturing sector should be as buoyant as it has ever been. The Treasurer constantly reminds us that we are the envy of the world.

Mr Piper : I only wish that were the case, but it simply is not.

Mr BUCHHOLZ: He was on the floor of the parliament the other day singing it with great praise, so I do not know what you are whingeing about, mate.

Mr Piper : In Victoria, when I walk around and talk to my members, as I have done particularly in the last week, and have spoken to them about their difficulties, and when I see friends who have been in the industry for many years who are literally going out the back door—they have high-tech businesses that are in niche areas such as defence and they are still finding it impossible to deal with the manufacturing environment at the moment—it just explains to me how much of a two-speed economy we have.

Mr BUCHHOLZ: I totally agree. Trying to get back a bit closer to the bill now—if we can just break it down and take the palm oil section out of it and look at the truth in food labelling aspect—do you guys have an opinion one way or the other as to whether or not the whole food labelling stuff is as tight as it should be, or is there room for improvement? I am not suggesting that it happen now but, at a point in the future, would you guys have any comment on having another look at the way that we have truth in labelling?

Mr Talbot : From a global perspective—and we have to take a global look at this—the current system in Australia is globally recognised as pretty close to better practice, if not best practice. The anomalies that we have seen in both this bill and some that are proposed from the Blewett report are seen as quite left of centre for a country that has a wonderful brand in terms of food manufacturing, food regulation and food labelling. We see it as quite erratic, as a manufacturer, and being erratic does not give us the strength of commitment to invest further. Again, we would like to see the existing process that has been in place for the last 15-plus years followed in terms of food labelling and food regulation. We would not want to see us fronting bills like this for a variety of issues—GM et cetera.

Mr BUCHHOLZ: What percentage of your product line has a component of palm oil?

Mr Talbot : If we had absolute traceability of palm, around 75 per cent of the products we manufacture; but the vast majority are 0.001 per cent components.

Mr BUCHHOLZ: So it is only minimal.

Mr Talbot : If you established a logical benchmark of two per cent palm oil by weight, volume et cetera, it would be less than 10 per cent of our products. What I am suggesting is that a lot of the tiny ingredient elements—and I am not a nutritionist—contain palm, due to the benefits of palm oil.

Mr BUCHHOLZ: Yes; but would you say 0.01 of one or two per cent?

Mr Talbot : That is right. There are trace elements. Again, we would hate to see an absolute criterion that says, 'If it contains palm, regardless of the percentage, it must be labelled,' because I do not think that has any benefit to anyone.

Mr BUCHHOLZ: We heard earlier on from some guys—and the chair may be able to help me—who suggested that the label cost of swapping over was around the $4,000 mark. I think that could be perceived to be accurate if they had to do a new label line halfway between a normal rollover of stock. What would be the lower end of that cost if it were done—and I am not suggesting that we are going down this way; I am just trying to gather evidence to catch what the lower end of the cost structure would be—in complete cooperation with a manufacturer or processor?

Mr Talbot : Our figures—I might let Chris jump in here—are $6,000 to $8,000 per plate change, per label change and we have a two-year cycle. In reality, we upgrade or refurbish our brands every two years. So that impact, if it occurred within a two-year cycle, would be incurred by the company.

Mr Raworth : Just to expand on that a little, the cost of the label depends heavily on how many colours that any particular package has and also whether it is a box or flexible wrap. For instance, if it is a five-colour plate, such as a Mars bar, it would cost us, just for the plate and change, about $5,000. If it were only the cost of the box that we put it in, we are only looking at around $400— because of the differences in costing. But for us to do a product that contains three layers of packaging—so it has its first wrap, an overwrap and then a box—it can cost us around $13,000 for that particular product. Some products have more colours than Mars bars and that would cost them up to $3,000 or $4,000 more. That does not take into account the write-off of packaging, because you are never able to run out all types of packaging at once and our law does not allow us to have different information on one pack than is on another pack.

Mr Piper : I would ask you to think about small manufacturers here too.

Mr BUCHHOLZ: Yes, I am. Perhaps I can just stay on that point for a moment. Even at the heightened figure of $6,000 to $8,000—and I suggest Mars—one would assume that $6,000 to $8,000 for a larger manufacturer as a percentage of the gross turnover of your sales on a popular product line would be less than the content of the palm oil.

Mr Raworth : No. Actually, the cost of changing all our wrap is more than we would pay for palm oil.

Mr BUCHHOLZ: On a single product line.

Mr Raworth : On a single product, yes.

Mr BUCHHOLZ: But I do take your point that it would be drastically skewed for a smaller manufacturer.

Mr Piper : Yes.

Ms OWENS: I would like to talk about the difference between the intention of the bill and the likely outcome. Initially the intention of the bill was about orangutans; it was about sustainable palm oil. It has been amended now and it is just palm oil generally. But there is no doubt that it exists because that original intention was to provide some longer term protection for the environmental aspects. I assume that you, like us, are aware that the ability of the community to engage and run consumer campaigns is growing rapidly and that it is only a matter of time before a consumer campaign is well and truly run on palm oil and that you are actually preparing for that. Without this bill, what would be the likely outcome and what would be the time frame before messages such as 'no orangutan died to make this chocolate bar' start appearing on your packages and sustainable sources are found?

Mr Talbot : We regularly face consumer feedback on critical issues. We have faced palm oil with our Cadbury Dairy Milk brand to New Zealand. We have made a commitment to the Australian and New Zealand consumers not to have any palm oil in Cadbury Dairy Milk and that has had its own problematic supply chain issues. I would think it would be very close to 2013 to 2014, as the sustainable palm comes on-line. The vast majority of major global manufacturers are buying green palm credits. That surplus cash is going into securing the sustainable palm supply and providing for sanctuaries and also providing buffer zones and educating the farmers in Indonesia and Malaysia. At the moment we are putting money in as we speak to get the industry to a stage where they are sustainable. We cannot just switch on sustainability. We expect 2013 to 2014—the first true sustainable palm to be coming into the Australian marketplace. We have listened to consumers and we are responding to consumers already. We cannot move any faster because the trees are growing, literally.

Ms OWENS: When you say 'the majority', would that be maybe 50 per cent of Australia's palm oil use or 70 per cent of Australia's palm oil use?

Mr Talbot : I am not across palm oil use outside perhaps the confectionery industry. What I would say is that Nestle, Mars and Kraft Foods, who are the three large confectionery players, have made commitments by 2015.

Ms OWENS: Even without this bill, we would probably start to see some changes in the labelling and certainly changes in sourcing by about 2015.

Mr Raworth : Unfortunately, for confectionery items in particular, space on a label is at a large premium. Adding extra sentences, words, logos et cetera is something that we do not undertake lightly. It is quite possible, if not probable, that messages regarding the use of sustainable palm will be through an extended labelling application such as websites, advertisements on TV or whatever rather than actual labelling on a wrap.

Ms OWENS: Can I talk about the intention and the outcome just in terms of the detail? For example, we know that New Zealand is not on board and the states get to choose, so some states will and some states will not. If I pick up a product that does not say it contains palm oil, that does not mean that it does not contain palm oil, does it? If the outcome for me as a consumer is that I know, does this bill improve my ability to know or not?

Mr Piper : If it comes from New Zealand, it is certainly not going to improve your ability to know, because they may not label it as having palm oil in it. It could well be something that consumers are uncertain of. I do not think it will improve their position.

Ms OWENS: It may, in fact, make it worse, if I think I am buying something that does not contain palm oil simply because it is not labelled.

Mr Piper : One of the issues here is that it seems like the orangutan issue and the health issues are crossing over each other too. I do not think that consumers understand that palm oil is not a health issue; it is not going to hurt them. I think that tends to have been lost in all of this discussion. Palm oil might be calorific, but it is not a health matter for them.

Ms OWENS: I was going to ask that next. If my issue was health and I was looking for unsaturated fats instead of saturated fats, the labelling of 'no palm oil' might lead me to believe that it does not contain saturated fats, and that would not be true either, would it?

Mr Piper : You are going to have a more confusing arrangement than you have right now. At least now we understand whether it is a saturated fat or an unsaturated fat. Vegetable oils are labelled at the moment and you have imported products that may or may not be labelled. You have the problem of actually dissecting what is in the product as well—whether you can determine whether there is going to be palm oil. I think it could become more confusing than it is.

Ms OWENS: There is the issue also of synthetic trans fats and some of the more bad health stuff that has been replaced by palm oil. Would you anticipate that some of that may return and that, again, you may pick up something and think it has no palm oil, but actually it has been replaced by something worse in terms of health?

Mr Talbot : That is one of our key concerns—that a number of proprietary products have been developed utilising palm as the carrier and a number of those are natural colours. That is really good R&D that has been developed in Australia. We can see a number of companies moving backwards instead of forwards because of this issue, because the consumer backlash will be great. As I said before, I can expect to see consumers seeing palm oil as palm oil and not reading anything further and directly in the line of sight to an orangutan situation rather than actually understanding underlying principles.

Mr Raworth : I think there is another thing, while we are talking about sustainability. Palm oil is one of the most efficient oils to grow. If we converted all our oil needs to seed oils, it would take approximately nine times the land area to grow the same amount of oil. As to the sustainability effects—for instance, if everybody demonises palm oil to the extent that nobody wants to eat it, we would use nine times the landmass producing the same amount of oil using seeds.

CHAIR: Just on that, you clearly see the labelling of palm oil as, using your words, 'demonising' palm oil?

Mr Raworth : Potentially it is there, because the education will not be there to give a balanced viewpoint.

CHAIR: With the legislation as it currently stands, which does not distinguish between sustainable and non-sustainable palm oil, both would be equally—again using your words—'demonised' by the labelling.

Mr Raworth : Potentially, yes.

Mr Talbot : I would go one step further here and say that the legislation, I think, will actually take the sustainability agenda backwards rather than move it forwards, because there is no consumer benefit or imperative.

Ms OWENS: I have one more question, but you are probably not the right people to ask. Palm oil is planted after the logging, so it is the logging that clears the rainforest. If it is not palm oil, what else would it be? Would it be bananas?

Mr Talbot : In a previous life, I had the fortune to work in the forestry industry for Australia's largest forestry and paper company and I have seen firsthand, from a forestry perspective and also as a food manufacturer, based on my last trip to Malaysia, a lot of the acacia plantations, which are of low benefit to the community, being replaced by farm plotted palm oil, which is a much better cash crop. It is a much better sustainability crop in terms of putting income back into local communities than broadacre plantations. The green palm certificates ensure that there is no more clearing of any more rainforests at all and, as I have said, it is the plantations of anything that are being cleared back for palm oil.

Ms OWENS: It is always easy for a country which has already cleared its forests to plant its sugar to criticise another country for doing what we did a few years ago. If the clearing does stop, do countries like Malaysia and Indonesia still have the capacity to grow through efficiencies and replacement of other crops? Is that what you are saying? The capacity to supply the world and to continue to grow is still there?

Mr Talbot : Absolutely. As I have said, by having sustainable palm, you are underwriting a limited base price and anything above the base price, the premium pay, goes back into that local community for better agricultural practices, better scientific education, medical et cetera. It is very similar to fair trade and where fair trade has moved in the cocoa situation.

Mr Raworth : One of the alternative crops that most farmers consider for cost and efficiency of growing would be rubber. I suspect that, if farmers no longer grow palm oil, they will grow rubber at this stage.

Mr Piper : And companies have moved in relation to cocoa without any legislation. They have recognised that consumers want change. They are putting significant amounts of dollars into African countries to assist there to improve the conditions. That is not going to happen overnight, but it will happen. They have also recognised that they have no choice but to do that. Some companies now have determined—I think Kraft by 2020—that all of their products are going to have fair trade cocoa as part of their make-up. The movement is there and they are moving as quickly as they can in cocoa, and the same thing is happening in relation to palm oil.

CHAIR: Thank you for your contribution here today. We really appreciate it and your expertise that you have brought to this committee hearing. Hansard will be sending a transcript to you. If there are any errors or omissions, please get back to us with those as quickly as you can. Once again, thank you for your contribution.