 and Principal Lawyer at ComHour Group on an Australian-based legal and policy advisory firm. She is a climate change and environmental law specialist with extensive experience in land use and development, environmental and social impact assessments, native title, environmental markets, climate resilience incentives and renewable development projects. Emily comes very highly recommended. I've heard her name dropped in multiple occasions, in multiple meetings and a number of people said that they were very excited to see her come today. So not to build you up too much Emily, sorry. She plans to help explain what a carbon broker is, what happens in the event of a carbon deficit at the end of a contract, which is something I think we all need to understand, and the legalities around brokers, what to watch out for from a rangelands perspective. So Emily, I'll hand it over to you. We're going to try and wrap up at around 11.25 and have a break. No worries. I'll try a multi-task and get my slideshow up and running. Can you see that screen at your end? Hoping that's a yes. Interrupt me if you can't see my covering slide there and thanks for that. Very lovely introduction. It's pleased to be with you virtually, similar to Dean. Our travellers are officially prevented from coming across at my home in Melbourne to you all in South Australia and Port Augusta, but I'm looking forward to today's discussion. Carbon and climate change are among my favourite topics, so it'll be a pleasure to keep discussing here and also on the panel with you, and I'm really looking forward to that because it's nice to hear about the issues and questions that you have that are relevant to you as well. Before I begin, I'd like to acknowledge the traditional owners of the land on where you are and also to where I'm coming from you, coming to you from in Melbourne, and pay my respects to their elders past and present. There were injury people here in Melbourne. I'm not far from the MCG where I am, and I hope it's not too early to mention football. It's not far away and the women's season is going well. So I'm looking forward to today's discussion. As mentioned, I'm going to cover a few things in this discussion and then hopefully they will plant the seeds, pardon the pun, for some good discussion over the panel. I wanted to outline for you some of the context and legal framework that we'll go through and also some of the key concepts under the Act, and then, as mentioned, role of broker and role of other typical players that you might see in carbon project development. If I keep looking to my left here, it's because I've got my slides that you can see on my screen to my left, so I'm not gazing out the window, although I could be thoughtfully I am if I look directly in front of me. I want to leave you with this relevant context because I think it's important. I think Dean's discussion was incredibly useful and it's always pleasing to hear about the innovation that's going on in this space, including in relation to the self-hurting, the tech and management innovation going on in the agricultural sector at the moment is wonderfully exciting and it's only going to continue to improve and that's equally as exciting. The legal framework tries to keep up with it. There are some clunky elements to it and I think it goes without saying that the Clean Energy Regulator and others in Canberra and in the South Australian Government are working hard to create practical solutions as we all evolve different methods and different ways of doing things and can prove the science, both Western and increasingly traditional owner science as well from up north and fire management, blending those things together to create and continue a scheme with good integrity. So I'll outline a little bit about how contracts work and some of the things to look out for in practice and also touch on co-benefits and how they're coming through in the markets and evolving as well. I would ask you to stop me as I go but similarly to Dean, I think tech makes it tricky to ask questions as you go. So if you have got a pen and paper or a smartphone or something in your hands, please note questions down. I'm more than happy to come back to them if time permits at the end or otherwise after the break when we have the panel session. But to give you a little bit of general context and I think it's important to touch on the international, I'm not going to stay there for too long, but it is important to understand it as both a driver for carbon markets but also a signal as to how things will evolve in Australia domestically. So carbon markets are broadly part of environmental markets and we're seeing greater convergence and almost interplay between environmental markets which include things like water trading and biodiversity and native vegetation offsetting and those sorts of things. We're seeing more and more interplay between carbon and biodiversity markets and the recent review of the Federal Environmental Law, the Environment Protection Biodiversity Conservation Act, which is certainly a mouthful, has recently been reviewed and the final report from the reviewer of that of that act notes the opportunities around leveraging carbon markets to really stimulate recovery of Australia's biodiversity. So there is this confluence that's increasing between environmental, you know, typically separate environmental markets and carbon markets and I think we'll continue to see some of those trends but I'll come back to that at the end. Big picture, those of you in mind the room might have heard of and I'm not going to spend too much time on it, the Kyoto Protocol at the international level and now it's dropping away and the Paris Agreement which was agreed in 2015 is coming on stream and taking operation but essentially the Kyoto Protocol is important because it really set up carbon credit trading as we know it and set the example for how it can work and set up a number of standards and rules, you know, telephone books and telephone books if you go back that long and remember the telephone books from the days of old, you know, it reams and reams of paper if you printed them on on how quantification of activities can lead to carbon credits and that's some of what Dean took you through in relation to a human induced regeneration project. The rules, the modelling, all of those details which get set out in regulatory frameworks it's a huge job so a lot of a lot of what we know and through learning by doing comes from that international framework and comes from the Kyoto Protocol. For those of you that are interested in follow us we we at Comhard do attend the international negotiations and assist at those and follow it very closely in particular Article 6 which is the part of the Paris Agreement that deals with market mechanisms and trading so the continuation of those carbon credit markets. For those of you who are interested there's still outstanding discussion and negotiation on how the rules of the Paris Agreement will treat the transition across from the Kyoto Protocol. So there's a little bit of uncertainty there at the moment in the international realm as well as industry who are moving and this is sort of for context and because it does affect markets and does affect future pricing and ways of delivering abatement and incentivizing things like carbon credit projects and carbon projects shipping so shipping and aviation are sort of outside the general framework for Kyoto and the Paris Agreement and so those industry sectors and industry bodies at the international level are setting up their own frameworks and certainly aviation involves using offsetting and carbon credit units and they look at accrediting units that have high high credibility and looking at do-no-harm type tests so really again looking at this positive angle of some of these projects where they're not harming the environment they're not harming social and community communities in which they they operate and and they're not you know at the huge scale internationally they're not resulting in human rights abuses and those sorts of things so sectors and industry are looking at their own schemes and that's that's driving up demand for carbon credits and we'll come back to that later on as well locally really important to be aware that in Australia as Dean mentioned the carbon credits carbon farming initiative act is the is the national law that is is key to carbon farming activities because it's the law that regulates the registration of carbon projects as well as their operation and when you get when you can apply for and receive a come Australian carbon credit units or accuse or what we'll call carbon credits in this context compliance with that act and its requirements is important and it sets the details to ensure integrity of the scheme and system including the scientific robustness of activities and methods that can be used to generate credits like the human induced regeneration method the act also establishes what you what you might know as the emissions reduction fund and I think it's a really important point that sometimes gets lost that the ERF or the emissions reduction fund is exactly that it's a fund it's a fund that's used by the clean energy regulator to purchase carbon credits and that fund is established by the by that CFI act the carbon carbon credits carbon farming initiative act the clean energy regulator is is therefore on behalf of the government one of the main purchases of carbon credits at the moment in Australia and is therefore sort of on one level a very important customer a very important buyer and that's through the auctions that are conducted a couple of times a year and and even through COVID we're still we're still conducted so I think that's just a point that helping helping separate some of these concepts that really the carbon farming initiative act is is the details and the ins and outs of what you'll need to comply with with the help of service providers and others in looking at projects the ERF itself is a fund that is used to purchase carbon credits should you want to sell them through that method through that that pathway the safeguard mechanism is basically sort of a capping of of emissions that goes on in the in the heavy emitter sector under the the national greenhouse energy reporting system so it's it's a driver of what we call a compliance driver of purchasing of carbon credits because in a nutshell what that scheme does is it says certain high emitting facilities so power plants and other other emitting facilities have a baseline that caps the number of the caps their emissions and if they're going to go above their baseline they can seek to vary things or do various things to to have temporary exemptions but in a nutshell they need to purchase carbon credit units at the moment and and retire them to bring themselves back essentially within their baseline so there's some purchasing that's been going on under the safeguard mechanism which i'll come back to and last but certainly not least local and state laws are incredibly important in looking at carbon projects South Australia has policies and strategies which guide its effort and the government's effort to engage and move forward and and the pastoral pastoral act review is is part of that as well as their sequestration strategy and and those here in South Australia and also elsewhere know to move towards trying to maximize co-benefits which i'll come back to as well there is a need to comply with local laws so it's not just all about that that national law that i mentioned the carbon farming initiative act there's a need to ensure that you comply with any town planning laws and permits if you need border allocations the pastoral land management conservation act requirements and processes any other crown lease or license terms and conditions that you might have you need to ensure that you're complying with what you may need for your activity as well as any conditions attaching to those instruments that you might hold for what you're doing already on properties in some circumstances and this is really limited sort of water forestry type activities in South Australia but in other jurisdictions there's a there's a need to create and and hold a carbon right as well at a at a state level in South Australia as i said it's a little bit more limited looking at forest property agreements to create and transfer a carbon right and really that's evidence of a person's right to benefit from the carbon stored in forest vegetation so sometimes that's an additional legal legal mechanism that's required to demonstrate a proponent's legal right to carry out a project so that's that's a little bit of an overview i i know we're going through some some pretty needy topics in a little bit of detail but some of these were covered by Dean and i i think it never never hurts to recap and and have them repeated in in minds but i i do want to draw your attention to some really key concepts under the framework as a whole and this is the national framework and and they're they're terms that you'll hear thrown around they're terms that you'll see if you research on on the internet they're terms you might be familiar with already in terms of looking at doing projects and speaking to people and and engaging with both governments so eligible offsets project project proponent agents eligible interest holders methods crediting periods permanence periods reporting and auditing relinquishment requirements and carbon and maintenance obligation i've cherry picked a few there there are a raft of other things under the act to be cognizant of but these are these are some of the the high level ones i'm going to go through some of these in more detail but essentially the eligible offsets project is really making sure that what you want to do the carbon project that you want to do meets requirements of the act and is therefore eligible and you need to formally seek that declaration and meet the requirements of the act when you go through to seek that it's important that before you take that step that you identify who is going to be the project proponent and i'll go into more detail about that shortly that can be yourselves as there's pastoral leaseholders or as owners or as other leaseholders of various properties or you can actually convey that legal right to carry out a project to somebody else and they would be the project proponent in some circumstances there's flexibility to have joint proponents as well so there's a little bit of a discussion that needs to happen around who is actually going to be the project proponent for a project and therefore legally responsible for it and also accountable for it as well methods and and i think deans touched on that one so i won't go into too much detail about it other than to note that there are specific methods or suites of activities that get approved through the scheme and so you need to apply an approved method that's been tested under the act and considered to be sufficiently robust and therefore activities that can be used to demonstrate the the abatement of carbon or the storage of carbon and and the basis on which to apply for carbon credits crediting periods are really the periods in which you can apply to receive carbon credits typically 25 years for a sequestration project and sequestrations a fancy way of saying storage and most of your most of the projects that we've been discussing and probably we'll be discussing today are sequestration projects but happy to go into that in more detail if it's relevant permanence period is really the period over which the carbon has to stay stored in the ground and deans touched on that as well that you can't have carbon being stored in vegetation and soils and and trees and other things only to then let it out and have leakage in other areas so the act and the framework sets up a requirement for nominating either a 25-year period that you'll keep the carbon stores and and pool in the ground in the biomass or a 100-year period and there's some price and and carbon credit differences potentially between those two options depending on what you'd like to do and also what you can do under under the tenure or leases that you hold there needs to be the identification of a project area and interestingly the the discussion that Dean mentioned around carbon estimation areas and how many of them you might have on a on a property it's sort of called stratification so you start with a project area which is the overall area that you'll be conducting your project within and then that gets broken into estimation areas and they can they can be stratified on advice of your of your ecologists and the people helping you to set up a carbon project but looking at getting the most out of the project area as well as identifying the project area because it's it's actually incredibly important because of some of the notification requirements under the act and particularly if there are either conduct or natural disturbance activities that occur and lead to a loss of carbon that's stored there's notification and potentially relinquishment obligations attached to the the project area as a whole which are sometimes informed by the carbon estimation areas but the project area is really the pivotal test for some of those notification requirements and relinquishment requirements and so that's that's important and again I think that's an area where we're learning by doing it makes more logic and sense for it to actually be if you're storing carbon it should be where the carbon's released rather than the project area as a whole however again this is part of the clunky fit of trying to trying to keep up and match things particularly that are modelled with real world measurements and and examples of of loss and incidents that can occur so just to very briefly touch on that some of these key concepts I don't want to go into them all in too much detail but the project proponent as I mentioned is the person and this comes from the act who is responsible for carrying out the project and has the legal right to do it and that's important because the legal right comes back to the raft of interests making sure you've got appropriate access that your that your access or your rights to be on on the land that you're on are sufficient to enable you to do what it is that you're saying you want to do with that and and with looking at tenure in the land interests comes the concept of an eligible interest holder and again this is important and I always encourage people to look at it early because they're basically people who hold a legal or equitable interest in the land and that can be in in some circumstances if it's a freehold property that's being leased and the less he is undertaking the the project the freehold owner would be an eligible interest holder similarly for crown land and pastoral leases the crown land minister is an eligible interest holder banks are eligible interest holders so if you if you do have a mortgage attaching to the land that you want to do a project on the bank is an eligible interest holder and there's a bit of a mixed there's a bit of a mixed response at the moment with banks some banks are viewing carbon projects in a very progressive way and understanding that they improve the productivity and and sustainability of a lot of farming practices and seeing it as an asset other banks for reasons that we'll get to shortly they're seeing it as a potential restriction or encumbrance on the productivity of the property so there's a mixed response and I'd encourage you depending on are you bank with to to shop around and see how you go or to have those conversations early because you'll you'll realise very quickly how difficult or how long it might take to to get those consents again engaging early with any determined native title holders so native title holders have an eligible interest in in areas and if you want to do a carbon project on an area where native title has been determined to exist you need to get the consent of the native title holders particularly the prescribed body corporate that holds the native title on behalf of of people under a native title determination so again engaging early is certainly important there in order to to have that have discussions early in fact to that into your into your carbon project I mentioned before some of these concepts are a crediting period and a permanence period as well as relinquishment and carbon maintenance obligations so I won't I won't go through crediting period and permanence period again because I mentioned them earlier and we can touch on them if there are questions later but basically your your permanence obligations require you to hold the carbon and to maintain carbon that's stored in the country maintain it in the country so if there are if there is a loss so carbon that's stored in the in the project land is lost either due to unavoidable natural disturbance of fire or something or deliberate conduct there are circumstances in which the regulator can require a project proponent to relinquish carbon credits to reflect that loss of of storage so again that's why it's important to identify who the who the project proponent is and in looking at it if you're looking at developing projects with a carbon project developer and there are some models where the developers actually like to be the project proponent make sure you think about and and talk about and then get clarity in agreements around what happens in some of these circumstances whether you both share in the in the ups and downs or whether or not there are certain things that the the developer or your self-take on as the risk or potential liability so if there is a relinquishment requirement so if there is an incident and carbon is lost from from an area in which it's been stored and there is a requirement to relinquish credits or to give back credits to the regulator if there's either non-compliance with that or it looks like there will be non-compliance with that and and that the relinquishment requirement might be met the regulator can actually put in place what's called a carbon maintenance declaration of carbon maintenance obligation they can declare a project to be subject to a CMO or a carbon maintenance obligation and basically that sets a benchmark level of carbon that needs to be maintained in the country and it and it binds anyone with an interest in that property to comply with that and it may allow certain activities it it certainly is intended to allow standard activities to continue to to be undertaken provided they're not going to interfere with that carbon store that's required to be maintained now the important part of that and and it links back to why you need eligible interest holder consent is that it can affect people who had nothing to do with the project so a future purchaser if land is sold and someone else buys it they can be bound to follow one of these carbon maintenance obligations and because of the ability to to permit or to restrict activities on the land to protect the carbon store it also has implications for native title holders and farmers and others you know if you sub lease a property as well so that's again something to be aware of when you're looking at looking at entering into these projects um I I reckon we're almost halfway there so I'm going to head into some of the practical considerations and I'm noting I need to need to wrap up in a bit sort of 15 minutes yep that's my 15-minute check in for you so thank you yeah good all right thanks cheers um what I've got on this slide um is really trying to summarize what I've what I've said in a little bit of technical jargon more clearly I think lawyers should always be forced to to communicate with diagrams um because it does help to try and simplify some concept so really when you're looking at a project there's a few things to check from your legal perspective in addition to the feasibility and and certainly some of the work that Dean and his team do looking at the location and the condition of land the movement of stock and how you might modify activities to to fit with the method or improve methods and sequester land and what the potential is for a carbon project the other lens that's incredibly important to put to these things is looking at land tenure and the legal rights associated with the right to carry out a project so that involves looking at regulatory consents that you might need there's a regulatory angle to testing of projects as well land tenure making sure that you can access and do what it is that you're willing to do on land or if you're conveying that to someone else that that's done properly as well as securing eligible interest holder consents that you need and then also looking at operation and delivery which we'll get to shortly and the type of method the type of project that you're going to engage in and the method that applies to that as well so human and regeneration is one example of those buying and selling ACC use will come to as well but on eligible interest holder consents I mean some of the some of the questions to to look at here are who owns the land and who has interests that are registered on the land and I think to the title searching and those sorts of things checking to see if there's native title determinations what I've put on this slide for you at the moment is that you can see much of South Australia including in the far north is covered either by APY lands or also not exclusive native title determinations so there's a high likelihood that native title exists in areas that you might be looking at projects and therefore looking at that working out who you need to contact and getting in touch with eligible interest holders early in your in your thought process helps structure and plan the project with the greatest efficiency crown leases and pastoral leases which I know are topical again looking at what's permitted and not permitted under the lease and and that comes back also to mandatory conditions and mandatory reservations under the lease back to the crown when you when you need pastoral board approval and and being timely about getting that and covering off on on any review and changes that are coming which no doubt friends and colleagues in the in the government might cover off on or will certainly be keeping you up to date with as things progress there from the bill that was released um the other the other figure that I've got up there shows you roughly as it sort of earlier this week the number of projects and carbon credits that have been issued in South Australia and the generally the type of project so you can see that there's quite a few vegetation type projects and a few agricultural projects as well as closer into Adelaide and urban areas and some landfill and waste projects as well looking at mapping out and and and how some of these key concepts come together um I this slide's really intended to show you how some of these things fit together sequentially and therefore how you might approach a project um pre-registration the need to go through some of the things we've talked about feasibility your due diligence on your property um getting estimates as to what your carbon yield might be whether it's going to be worthwhile to to do a project or if it's marginal and and it might you might be motivated to do a project for any number of reasons including biodiversity and and other general productivity reasons and looking to identify and engage with your eligible interest holders early so that dotted blue line is really looking at a pre-registration phase um there is an overlap in that you can apply to have a project registered on a conditional basis which means that you still need to satisfy conditions like obtaining consents that you haven't yet obtained when you apply to register a project before the end of your first reporting period and really that's before the period in which you're going to report on your activities and apply for for carbon credits so essentially if if you do proceed and get a project conditionally registered you won't be able to receive carbon credits until you've satisfied those conditions so it it can be done and sometimes it's useful because then you have security that you've got a project up you know you can do it but you still need to get these consents in place if you're negotiating delivery contracts so sale contracts in parallel certainly it's useful to carry those conditions through as conditions on your sale contract so you don't get yourself into a sticky corner and commit to delivering things that you don't yet have or at least assess your confidence and risk around some of those things at the outset but again it can be it can be useful to do that because then you have certainty of knowing that you you can if you get those consents you can deliver projects that might give you more more confidence to discuss how payments and and benefit distribution might work in order to get some of those consents up front the crediting period so the period in which you can apply to get credits starts when the project's registered so if your conditional registration eats into that it eats into it that your reporting period is is a little bit up to you there's there's rules around how soon it can be and how late it can be but otherwise there's some flexibility around how often you report and you can you can talk to the regulator about that and they will agree on on when you should be reporting and that will be formalised in declarations as well as shown here your permanence period can either be the same as your crediting period 25 years or it can be longer 100 years so you you apply and you receive credits and you you get the thing that you can sell and trade in 25 over a 25 year period it's not linear I'm sure Dean will explain to you that vegetation grows and you all know working on the land as well that vegetation grows at different rates in different areas and therefore there'll be all sorts of curves associated with the yield the growth of vegetation the measurement the sequestration of storage of carbon and therefore how many units you you generate over that period and and whether that comes in peaks and troughs and all manner of curves but bearing in mind then that if if your project does involve fencing and other maintenance of infrastructure it is less intensive the reporting and maintenance obligations over the longer term but there will continue to be maintenance obligations and and that permanence obligation stretching for 100 years so that includes you know the requirement to keep up fences and weeds and ferrules and all those sorts of things so really splitting it into three phases planning operating and managing projects and then managing your carbon stores is is one way to think about this agreement wise so looking at agreements and project engaging with project developers it often occurs in the planning stage so there might be service agreements some developers like you to sign up to exclusivity for both the feasibility of a project and then its registration and operation so depending on who you're talking to and what you're talking about your agreements might cover both the planning and the operating and managing stages or you might want to break it into these sorts of sequential parts where you're looking at upfront planning before you make a decision and not looking yourself in to get your feasibility assessments and paying for that fee for service type advice as well as getting your eligible interest identified and dealt with looking at your tenure and carbon rights and engaging with other eligible interest holders including native title holders early and contracting the help that you need during that planning and feasibility process if you roll it together with operating and managing it there might be concepts like agents that pop up and agents can be they're recognised under the act we will always encourage people if you if you're appointing an agent to think about potentially a side agreement that deals with how that agent behaves and and how you can and can't terminate that sometimes for simplicity agent provisions are thrown into carbon project development agreements and the service provider or the the carbon developer will also act as your agent and it's it's important to carefully look at those provisions to make sure you're comfortable with with what they'll be doing as well as the the types of services that they'll be providing to you the stages and timing of obligations so there's there's different milestones and also looking at pricing and how how payments might work some of this as Dean mentioned earlier the spot price from OMF and others that spot price related to carbon credits only and increasingly now there are ways to to attract buyers based on co-benefits so some of the other benefits that these projects can deliver either to the environment or to indigenous groups to traditional owners as well as to communities more broadly if they're if they're measurable and quantifiable or describable a lot of certainly companies are looking at paying a premium for them as well as some of the example funds that are popping up by other governments like the land restoration fund in Queensland and there's other governments looking at doing the same thing so really encouraging those co-benefits and actually paying a premium for co-benefits on top of the carbon credit which which makes good sense for everybody but I guess in the agreements making sure that you know what's being sold and how any payments that you receive if you're not actually the project proponent will come back to you whether it's just as one revenue stream as a as a percentage of overall or whether you do look at splitting out prices and floor prices and uplifts and and these things can become remarkably detailed depending on what it is that you want to do there's ease in keeping it simple and there's there's benefits in keeping it simple but there's also the need to closely inspect sometimes what are very simple arrangements to make sure they work for you also important to talk about what happens in the longer term project proponent who's going to be responsible for risks relinquishment requirements and and particularly being aware of the possibility of carbon maintenance obligations in the long term as well I think we're I'm probably coming up on on time but a couple of things that I did want to quickly mention towards the end is in working out who's doing wash and payment structures it's important to look at initial outlays payment milestones and approaches and and delivery risk if there are shortfalls if you're contracted to deliver things that you don't deliver there's breach of contract issues there's also potential ways and I think your contracts with project developers needs to sort through some of these issues and document them in terms of if there are those contractual shortfalls but also if your estimates are under and they can be under because of you know various inadvertent errors in in looking at these things as Dean mentioned most people tend to be conservative because you minimise the risk of that but they can also be under because of environmental or climactic reasons as well you have a good or a bad year and therefore your your yield is is not as good so looking at what you agree to deliver so how many carbon credits you agree to deliver to someone you need to you need to look into some of those risks and shortfalls and ensure that you have a level of confidence otherwise you'll have to go and buy from the market to top up and deliver on accused depending on the terms of your contract to ensure that that gets met and that can have costing implications for you we've talked about some of those concepts as the slides I've got in PDF form and I'm comfortable for them to be circulated and some of this information was included for those reasons this provides an overview of the types of carbon markets operating in Australia and includes renewable energy markets as well and the clean energy regulators now got quite a lot of sophisticated and interesting information on it in relation to the market and what I've extracted on this slide from the clean energy regulator is sort of a historic snapshot of the of the carbon price and and talking about I couldn't help myself whenever I think of going to market I do think of of little piggies and going to markets excuse the the slide there but I think I think brokers and the role of brokers is really to buy and sell and they're increasingly being used by some of those companies with a high heavy emitters who have high emissions and need to need to buy credits either to fulfill compliance obligations or because of branding and carbon neutrality commitments and brokers are exactly that they're they're people who sit in the middle and buy and sell credits to and from you need to make sure they've got financial services licensing and accreditation if you're dealing with brokers and if you're seeking advice on on the price of credits ensure that you're dealing with people that have that the carbon industry code of conduct which was on the screen before is is a useful thing to look at google the people that are coming to you and talking about it I know that select carbon and dean are founding signatories of the carbon industry code of conduct so they're up front helping ensure that the carbon industry continues to have the integrity it has but make sure if you're not sure if who you're talking to you hop onto google it can be your friend and check and ask whether or not they're signatories to the code and Emily can I sorry I'm going to jump in I'm just really conscious of the time and I actually had one of my questions on the list to talk about that code of conduct so I might I might if it's opportunity to jump in and sorry to interrupt you and stop you there but we will have plenty of opportunity to talk I'm going to invite Bill McIntosh back but we are going to take a break I'm just going to flag the fact that we can't go out the front door here