The Bell Gully Regulator Report lists recent changes, decisions and developments at the main New Zealand corporate, commercial and competition regulatory bodies and also lists relevant updates from the Australian Competition and Consumer Commission. This edition of the Regulator Report covers the period from 8 February 2008 to 7 March 2008. For further details on any matter in this report, just click on the hyperlink below each item.
Ministry of Economic Development (MED)
Strategic assets to be protected in national interest
Under the Overseas Investment Act 2005 and the Overseas Investment Regulations 2005 the criteria for consent to an overseas investment in sensitive land includes a detailed set of factors for assessing the benefit to New Zealand and New Zealanders. By Order in Council on 3 March, the government has amended Regulation 28 of the Regulations by adding the following additional factor which must be taken into consideration:
“(h) whether the overseas investment will, or is likely to, assist New Zealand to maintain New Zealand control of strategically important infrastructure on sensitive land.”
Click here to view the press release
Government releases draft regulations for emissions trading
A draft of the emissions trading regulations for forestry and liquid fossil fuels has been released by Climate Change Minister David Parker and Forestry Minister Jim Anderton to provide more certainty for potential participants from the forestry and transport sectors about their obligations once they are required to take part in the emissions trading scheme. The final content of the regulations is dependent on the provisions of the Climate Change (Emissions Trading and Renewable Preference) Bill once passed into law. The draft regulations and accompanying guidance can be found at www.climatechange.govt.nz.
To view the press release click here
Click here to view the draft forestry sector regulations
Click here to view the draft liquid fossil fuels regulations
Examining New Zealand's competitive environment "Business as Usual or Room for Improvement?”
In a keynote speech to the 8th Annual Competition Law & Regulation Review, Commerce Minister Lianne Dalziel outlined the government’s position on the current competition law and regulatory reform agenda. The speech largely focused on how competition policy has evolved in New Zealand and the rationale for, and new approaches addressed by, the new Part 4 of the Commerce Act. She also noted that the government was aware of the high interest around the transitional arrangements for regulated firms and it is hoping that it will be able to provide a greater degree of certainty around the timetabling of decisions – for example, by when the Commerce Commission needs to set input methodologies. In regards to the review of Part 5 of the Commerce Act, Ms Dalziel notes that this is on a slower track. Officials will be presenting the government with policy proposals in June this year and any new legislation will be introduced in 2009. Ms Dalziel also noted that the government is on track to having the Commerce (Regulated Goods & Services) Amendment Bill introduced into the House in mid-March which means that the Bill could be passed before the election.
Click here to read the full transcript of the speech
Minister declines Telecom's Amended Separation Plan - Minister for Communications and Information Technology release
Communications and Information Technology Minister David Cunliffe has notified Telecom NZ that he will not approve their Amended Separation Plan. The Minister noted that in general terms, Telecom’s revised undertakings come close to meeting the Amending Determination. However, areas where clarification is still required include:
- Telecom providing a clear upper limit on group-based incentives to ensure that Wholesale management is encouraged by those incentives to treat all its customers (including retail) equally;
- greater clarity around IP interconnection, as well as a range of other technical and definitional matters .
Telecom has until 25 March 2008 to revise its separation plan.
Click here for more
Update on the Financial Service Providers (Registration and Dispute Resolution) Bill
The Financial Service Providers (Registration and Dispute Resolution) Bill has been introduced into Parliament and referred to the Finance and Expenditure Select Committee. Submissions for this Bill closed on 28 February 2008.
The Bill is available on the Parliament website:
Financial Service Providers (Registration and Dispute Resolution) Bill
Consultation on Draft Emissions Units, Settlement Systems and Futures Bill
The MED, in consultation with other agencies, including the Reserve Bank and the Securities Commission, has led the policy development that has resulted in the drafting of the Draft Emissions Units, Settlement Systems and Futures Bill (Draft Bill). The Draft Bill is intended to implement the recommendations in the following Cabinet papers:
- Reform of the Law Relating to Futures Exchanges and Clearing and Settlement Systems (POL (07) 382); and
- Designated Settlement Systems and the Primacy of Clearing Houses' Interest in Collateral (CAB (07) 632)
The purpose of this consultation is to test with stakeholders and other interested parties how well the Draft Bill implements the recommendations agreed to by Cabinet, including whether there are better ways of implementing these proposals in legislation.
Click here for more details and to access the consultation paper
Click here for Bell Gully's comments on this Bill
Financial Advisers Bill - first reading
Commerce Minister Lianne Dalziel has moved that the Financial Advisers Bill be read for the first time. The intention of the Bill is:
- to foster consumer confidence in those who hold themselves out to be financial advisers; and
- to ensure that those who claim to be professionals in this area are held accountable for their performance, integrity and competence.
Ms Dalziel intends to move that the Bill be considered by the Finance and Expenditure Committee and that the committee reports to the House on or before 20 June 2008.
Click here to view a copy of the first reading speech.
Securities Markets (Investment Advisers and Brokers) Amendment Regulations 2008
These regulations amend the Securities Markets (Investment Advisers and Brokers) Regulations 2007, principally for advice given in relation to term life insurance policies. The re-worded regulation clarifies that the exemption from compliance with any investment advisers’ obligation in relation to term life insurance policies operates whether or not other investment advice is given on the same occasion. However, if other investment advice is also given, the exemption for investment advice in relation to term life insurance does not extend to that additional investment advice. The regulations came into force on 29 February 2008.
Click here to view these regulations
Ministry for the Environment
New regulations for telecommunications equipment
Environment Minister Trevor Mallard has announced that new regulations governing the size of and noise from telecommunications equipment such as antennas, masts and roadside cabinets have now been approved and will be drafted by the Ministry for the Environment. Mr Mallard noted that the regulations “will allow faster and more cost effective installation of telecommunications equipment because they standardise the rules across the country so there is a level playing field. This is likely to speed up the rollout of telecommunications services, such as high-speed internet and mobile phones, to a greater number of people and businesses and provide greater choice to consumers.” The regulations are expected to be in force by the second half of 2008.
Click here for more details
Te Mihi call-in - Board of Inquiry appointed
Environment Minister Trevor Mallard has announced the members of a Board of Inquiry to consider Contact Energy’s proposal for a new geothermal power station at Te Mihi, near Taupo. Trevor Mallard has appointed a four-person board with Judge Gordon Whiting as the chairperson and Dr Patrick Browne, Denis Nugent and Glenice Paine as the board members. The role of the board is to consider submissions on Contact’s applications for resource consent, to hold a public hearing and to make a final decision on its Te Mihi geothermal power station proposal.
Click here for more
Securities Commission
Investment advisers must disclose more information to investors from 29 February
To alert people to their rights to information from investment advisers the Commission has published a brochure "Choosing an investment adviser". This is available at www.seccom.govt.nz. The Commission has also worked with the Retirement Commission to include the new disclosure requirements on www.sorted.org.nz and a booklet associated with Sorted will be published and widely distributed early next month.
Click here for more
Securities Commission to call for disclosure statements of investment advisers and investment brokers
The Securities Commission has announced that it will be contacting investment advisers and brokers early this month to check their compliance with new investment adviser disclosure laws which came into effect on 29 February and will be taking enforcement action in appropriate cases. The Commission can take enforcement action against advisers or brokers:
- who do not have a disclosure statement; or
- whose disclosure statement does not contain the required information; or
- whose disclosure statement or advertising is deceptive, misleading or confusing.
Click here for more
Cycle 6 of Financial Reporting Surveillance Programme completed
The Securities Commission has completed Cycle 6 of its Financial Reporting Surveillance Programme. The Commission reviewed financial reports of 30 issuers, with balance date from 31 December 2006 to 30 April 2007. In its report the Commission notes that issuers' compliance with NZ GAAP is good. The Commission was encouraged by the fact that most issuers who have adopted NZ IFRS for the first time in this cycle have adequately disclosed the effect of the transition from previous NZ GAAP to NZ IFRS. The report:
- reminds issuers to review their compliance with statutory requirements as a critical step in the preparation and finalisation of an annual report; and
- notes that for issuers moving to NZ IFRS in their next financial statements, they will find that NZ IFRS generally requires more disclosures than previous NZ GAAP.
For a copy of the report on Review of Financial Reporting by Issuers Cycle 6, go to www.seccom.govt.nz
Recommendation for regulations to amend the Securities Regulations 1983
On Monday 11 February 2008 the Commission gave notice of its intention to recommend that regulations be made amending the Securities Regulations 1983. This follows the publication of a consultation document, "Investment adviser statements" on 21 December 2007. The proposed regulations will make an amendment to the information about investment adviser disclosure required to be included in investment statements. The amendment reflects changes to the Securities Markets Act 1988, which came into force on 29 February 2008.
A copy of the proposed recommendation can be found here
Securities Act Exemption Notices
The following Securities Act Exemption Notices have been published:
Securities Act (Investment Adviser Information) Exemption Notice 2008
This notice exempts issuers who make an offer of securities in respect of an investment statement dated on or after 29 February 2008 from the requirement in clause 1(1) of Schedule 3D of the Securities Regulations 1983 to contain the prescribed information in the investment statement concerning investment advisers. Instead, the investment statement must contain information that is consistent with recent changes to the law relating to investment advisers' disclosure obligations.
Click here to access this notice
Securities Act (Amendments to Exemption Notices Affecting Investment Adviser Information) Exemption Notice 2008
This notice amends 13 exemption notices to update the advice that is provided to investors in relation to investment advisers. The updated advice reflects the recent changes to investment advisers’ disclosure obligations arising from the new securities law provisions which came into effect on 29 February. The amendments only apply to documents that are distributed on or after 30 April 2008.
To access this notice visit www.legislation.govt.nz.
Securities Act (Telecom Corporation of NZ Limited) Exemption Revocation Notice 2008
This notice revokes the Securities Act (Telecom Corporation of New Zealand Limited) Exemption Notice 1991 (the old notice). The old notice is replaced by the Securities Markets Act (Telecom Corporation of New Zealand Limited) Exemption Notice 2008 (see below).
Click here to access this notice
Securities Act (Overseas Employee Share Purchase Schemes) Exemption Amendment Notice 2008
This notice amends the Securities Act (Overseas Employee Share Purchase Schemes) Exemption Amendment Notice 2002. The 2002 notice contains a condition requiring the specified securities offered in New Zealand under the employee share purchase scheme in accordance with the notice to also be offered under the scheme in the overseas jurisdiction in which the scheme is established. This notice modifies this requirement by allowing instead for the securities to be offered in the overseas jurisdiction under a parallel scheme that has substantially the same terms.
To access this notice visit www.legislation.govt.nz.
Securities Markets Act Exemption Notices
The following Securities Markets Exemption Notice has been published:
-
Securities Markets Act (Telecom Corporation of New Zealand Limited) Exemption Notice 2008
This notice replaces the Securities Act (Telecom Corporation of New Zealand Limited) Exemption Notice 1991. The old notice exempted the relevant persons from the substantial security holders’ disclosure obligations found in sections 20 to 22 of the Securities Markets Act 1988 (the Act), before amendment by the Securities Markets Amendment Act 2006, in relation to holdings of American Depositary Shares in Telecom Corporation of New Zealand Limited. Now the 2006 amendments have come into force, the corresponding disclosure provisions for substantial security holders can be found in sections 22 to 25 of the Act. This notice effectively carries over the exemptions under the old notice in sections 22 to 25 of the amended Act.
Click here to access this notice
Takeovers Panel
Bell Gully responds to the latest Takeovers Panel’s reform proposals for Schemes of Arrangement and Amalgamations Involving Code Companies
In December 2007 the Takeovers Panel released a consultation paper to address its concerns (and those of some market participants) over the perceived trend for Code companies to use schemes of arrangement and amalgamations in order to circumvent the requirements of the Takeovers Code. The consultation paper follows the panel’s June 2006 discussion paper on the same matter, and the panel’s subsequent recommendations to the Minister of Commerce and to the Commerce Select Committee in which the panel called for legislative amendments to be included as part of the 2006 Business Law Reform Bill in order to address the problem. This request failed, and in March 2007 the panel was asked by the Minister of Commerce to lead a further review and consultation process on this matter with market participants. As part of this exercise, the Takeovers Panel issued a consultation paper setting out six options for consideration. The Panel invited comments on the options in the form of a questionnaire to the consultation paper and has noted it will take all comments into account before reporting to the Minister.
Click here to view Bell Gully's submissions on this paper
New Zealand Commerce Commission (NZCC)
Media releases
The NZCC has issued the following media releases:
Mergers and Acquisitions
- New Zealand Investment Holdings applies for clearance to acquire RX Plastics
The NZCC has received an application from New Zealand Investment Holdings Limited (NZIH) seeking clearance to acquire 100% of the shares, or assets and business, of RX Plastics Limited. NZIH ultimately owns Marley.
Click here for more
- Crane Group applies for clearance to acquire RX Plastics
The NZCC has received an application from Crane Group Limited seeking clearance to acquire 100% of the shares in, or assets of, RX Plastics Limited. Crane Group is listed on the Australian Stock Exchange and supplies products in both Australia and New Zealand. In New Zealand, Crane Group operates through its subsidiaries Iplex Pipelines New Zealand Pty Limited and Crane Distribution New Zealand Limited.
Click here for more
- Air Liquide cleared to acquire ASCOGAS
The NZCC has cleared Air Liquide to acquire all the shares of ASCOGAS. In making its decision the NZCC noted the presence of BOC as a very strong national competitor which, together with two smaller independent competitors, was likely to constrain the pricing behaviour of the merged entity.
Click here for more
Market Behaviour
- Nufarm’s prosecution brings fines in NZ’s biggest cartel case over $7.5m
New Zealand’s largest cartel case to date has resulted in further heavy penalties for companies and individuals involved in the cartel in the timber preservatives industry. Three Nufarm companies, which operated the Fernz Timber Protection brand, have been fined a total of $1.9 million for price-fixing and market sharing with competitor Koppers Arch.
Click here for more
- Real estate agent and his company admit misleading advertising
In an out-of-court settlement with the NZCC, a Wellington real estate agent, and the company he worked for, have admitted advertising a property in a way that was likely to mislead potential buyers, in breach of the Fair Trading Act. As a condition of the settlement, the agent is required to undertake at least six compliance training sessions.
Click here for more
Telecommunications
- Telecommunications Commissioner launches study into Next Generation Networks issues
Dr Ross Patterson, Telecommunications Commissioner, has announced that the NZCC intends to use its sector monitoring powers under the Telecommunications Act 2001 to proactively initiate a study into Next Generation Networks (NGN). NGN is a broad term to describe changes to telecommunication core and access networks to provide for modern day voice, data and media services. The Commission has published a draft terms of reference of the study and has invited industry participants to comment.
Click here for more
- Draft standard terms released for local loop and bitstream backhaul services
The NZCC has released draft determinations on the price and non-price terms for the backhaul services that support the unbundled copper local loop (UCLL) and unbundled bitstream (UBA) broadband services. The closing date for submissions on the draft determinations is 7 March 2008. This will be followed by a period for cross-submissions. It is anticipated that the final determinations will be issued in June 2008.
Click here for more
- Next step underway for mobile co-location standard terms determination
On 8 February 2008, the Commerce Commission issued a notice to Vodafone to prepare a standard terms proposal for mobile co-location. This proposal will specify the non-price terms and conditions on which the co-location should be available to mobile network operators Vodafone is required to submit the standard terms proposal by 28 April 2008.
Click here for more
- Vodafone cleared to acquire radio spectrum management rights
The NZCC has cleared Vodafone Mobile NZ Limited (Vodafone) to acquire the management rights from the New Zealand Government for the radio frequency range between 899.8 and 915 MHz, together with the corresponding natural pair management rights in the 944.8 – 960 MHz range.
Click here for more
Consumer issues
- Cancer society asked to provide sunscreen results
The NZCC has asked the Cancer Society for information about the alleged failure of one its sunscreen products, and what the society is doing about the problem. This follows the Commission testing of a range of sunscreen products from four companies, after a complaint from the Cancer Society that the products could not offer “all day protection” as claimed. Making misleading claims can be in breach of the Fair Trading Act, which is punishable by fines of up to $60,000 for an individual and $200,000 per offence for a company.
Click here for more
- Sunscreen companies settle with Commission
The NZCC has reached settlements with four sunscreen companies that have admitted to misleading consumers about the protection from the sun offered by their products.
Click here for more
- Finance company to refund 1200 customers
In an out-of-court settlement with the NZCC, Allied Nationwide Finance has agreed to refund approximately $173,000 to more than 1200 customers who had been charged an unreasonably high prepayment fee when they repaid their loan early. Allied Nationwide admitted that its conduct was in breach of the Credit Contracts and Consumer Finance Act, which requires that the prepayment fee charged by a creditor must not exceed a reasonable estimate of its loss caused by the early repayment.
Click here for more
- Commerce Commission to look into Blue Chip
The NZCC will examine documentation relating to Blue Chip New Zealand after complaints that people may have been induced to invest based on false or misleading representations.
Click here for more
- Petrol station fined for misleading prices
The Auckland District Court has fined a North Shore petrol station $35,000 for breaching the Fair Trading Act by misleading their customers about the price of petrol.
Click here for more
- Septic tank cleaning company pleads guilty to misleading customers
A Waikato septic tank cleaning company and its director have been fined a total of $28,500 for misleading customers.
Click here for more
- Commerce Commission freezes assets associated with Wings and Wheels over Waikato
The NZCC has obtained a court order freezing the assets of Hawker Holdings, airshow.co.nz - Media Limited, airshow.co.nz Limited and Kenneth James Ross. Mr Ross is the promoter of the air and car show, Wings and Wheels over Waikato, which was to take place at Hamilton's international airport on 7-9 March. Following the postponement of the show, and further information that came to light during the NZCC’s investigation, the NZCC became concerned that ticket holders, sponsors and exhibitors would not get back the refunds they may have been entitled to.
Click here for more
Australian Competition and Consumer Commission (ACCC)
ACCC media releases
The ACCC has issued the following media releases:
Mergers and Acquisitions
- ACCC seeks comment on new revised merger guidelines
The ACCC has issued its Draft Merger Guidelines 2008 for public comment. The guidelines outline the general principles underpinning the ACCC's approach to merger analysis under section 50 of the Trade Practices Act 1974. The closing date for submissions is Friday 28 March 2008.
Click here for more
- ACCC not to oppose the proposed acquisition of Borders Australia by Angus & Robertson
The ACCC will not oppose the proposed acquisition of Borders Australia by A&R Whitcoulls Group Holdings (owner of Angus & Robertson). Amongst the reasons given for reaching its decision, the ACCC took into account in relation to retail markets:
- the constraint provided by existing book retail chains, such as Dymocks and QBD, and the possible expansion of these chains to further constrain the merged entity post acquisition; and
- the partial constraint imposed by department and discount department stores.
- It reached the view that while each of these constraints is limited in its own right, the combination of these constraints is such that no substantial lessening of competition is likely in book retailing.
Click here for more
- ACCC to oppose proposed acquisition of Carter Holt Harvey's assets by Sumitomo
The ACCC has concluded that the proposed acquisition of certain assets of Carter Holt Harvey Limited’s Woodproducts Australia business would, or would be likely to, substantially lessen competition in the manufacturing and supply of raw MDF.
Click here for more
- ACCC seeks further comment on Lake Imaging's proposed merger with Western Medical Imaging
The ACCC has released a Statement of Issues in relation to the proposed merger between Lake Imaging and Western Medical Imaging.
Click here for more
- Tabcorp, TOTE Tasmania agreement authorised by ACCC
The ACCC has authorised certain provisions of an agreement between Tabcorp and TOTE Tasmania governing TOTE Tasmania's participation in the SuperTAB pool.
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- ACCC revokes North West Shelf Gas joint marketing authorisation
The ACCC has granted North West Shelf Gas Pty Limited's request to revoke the authorisation granted to it in 1977 by the Trade Practices Commission. The North West Shelf project participants established a joint venture for the sale of gas to the Western Australian domestic market and sought authorisation from the TPC. The joint venture partners intend to continue their gas joint marketing practices, including ongoing administration of gas supply contracts, without the authorisation.
Click here for more
Market Behaviour
- ACCC proposes to approve collective sale of wine grapes by King and Alpine Valley growers
The ACCC has issued a draft decision proposing to authorise 39 wine grape growers in the Alpine Valleys and King Valley region of north east Victoria to appoint a common agent, North East Valleys Wine Group, to negotiate wine grape supply contracts.
Click here for more
- ACCC allows removalists to collectively negotiate with Pacific National
The ACCC has not objected to a collective bargaining notification lodged by a group of removalists for negotiations on rail freight services with Pacific National.
Click here for more
Telecommunications
- ACCC begins public consultation on Telstra's second transmission capacity exemption applications
The ACCC has issued a discussion paper on Telstra's applications for exemption from standard access obligations in respect to the domestic transmission capacity service in specified CBD, metropolitan and regional exchange service areas for inter-exchange and tail-end transmission capacity.
Click here for more
- ACCC issues ninth Telstra accounting separation current cost report
The ACCC has today issued the ninth current cost accounting report relating to Telstra. The report contains current cost financial information for 'core' telecommunications access services.
Click here for more
- Telstra submits revised ULLS monthly charge undertaking
The ACCC has published Telstra's revised Unconditioned Local Loop Service monthly charge access undertaking. This was lodged on 3 March 2008, at the same time as it withdrew its previous ULLS undertaking dated 21 December 2007.
Click here for more
Access
- High Court unanimously supports validity of the telecommunications access regime
A unanimous decision by the Justices of the High Court of Australia confirms the constitutional validity of Part XIC of the Trade Practices Act 1974, and specifically its application to the Unconditioned Local Loop Service (ULLS) and Line Sharing Service (LSS). The High Court confirmed that Telstra's ownership of the public telephone network has always been subject to the rights of its competitors to gain access to and use its network for the ultimate benefit of customers.
Click here for more
- Notification of telecommunications access disputes
The ACCC has received notification of the following three telecommunications access disputes under Part XIC of the Trade Practices Act 1974. These disputes relate to Telstra's supply of the Line Sharing Service.
Click here for more
- Notification of telecommunications access disputes
The ACCC has recently received notification of two telecommunication access disputes with Telstra under Part XIC of the Trade Practices Act 1974.
Click here for more
Consumer issues
- Tasti Products amends Weight Watchers fruit bar packaging
Tasti Products Ltd has given court enforceable undertakings to the ACCC after concerns that the overall impression created by the wording and pictorial images used on Weight Watchers fruit cereal bar packaging may be misleading. The products are manufactured and sold by Tasti, a New Zealand based company, under the Weight Watchers brand.
Click here for more
- ACCC provides guidance for 'green' marketers
The ACCC has issued updated guidance for businesses and industry on the use of environmental claims in marketing. The release of Green marketing and the Trade Practices Act follows recent ACCC action over potentially misleading environmental marketing claims in the energy industry.
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- ACCC releases groceries issues paper
The ACCC has released an issues paper on matters relevant to its inquiry into the competitiveness of retail prices for standard groceries.
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- VIPtel mobile phone telemarketers misled consumers: refunds follow
The Federal Court in Darwin has declared that VIPtel Mobile engaged in multiple breaches of the Trade Practices Act 1974 during telemarketing calls across Australia.
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- Court orders against Wesfarmers Kleenheat Gas for misleading or deceptive pricing conduct
The Federal Court, Brisbane, has made orders by consent against Wesfarmers Kleenheat Gas Pty Ltd in relation to conduct of Kleenheat Gas varying the pricing for bulk LPG supplied to particular customers, selected as 'Managed Monthly Accounts' or 'Quickhits', which differed from representations it made to those customers as to how their prices would move.
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- ACCC court action against Nudie Foods Australia Pty Ltd
The ACCC has instituted proceedings in the Federal Court, Perth against Nudie Foods Australia Pty Ltd alleging Nudie made misleading claims on the packaging and in promotional material for two of its fruit juice products, Rosie Ruby and Rosie Blue.
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- Prouds 'was/now' discount advertising misleading
The Federal Court has held 'Was/Now' discount advertising by Prouds Jewellers Pty Ltd to be misleading in breach of the Trade Practices Act 1974. The ACCC views the case as an important warning to businesses who consistently conduct 'sale' promotions of the need for accuracy in advertising, particularly in relation to price, which is so important to consumers' purchasing decisions.
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- Another medical sheepskin supplier undertakes to not make false claims: ACCC warns industry
Less than three months after sheepskin manufacturer Tasman Sheepskin Tannery, gave a court enforceable undertaking for making false claims, Australian Linen Supply, trading as Confident Care Products, has given a court enforceable undertaking to the ACCC for similar conduct.
Click here for more
The Bell Gully Regulator Report is designed to highlight certain New Zealand and Australian corporate, commercial
and competition regulatory developments. The Bell Gully Regulator Report is not designed to be comprehensive and is
necessarily brief and general in nature and is not intended to provide legal advice. You should seek professional legal
advice before taking any action in relation to the matters dealt with in this publication. Bell Gully is not the author of
any information received by clicking on the hypertext links and therefore is not responsible for their accuracy.