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Policy

From Amanda Lynch, Chairman, Council of Small Business Australia

COSBOA has been around for almost 35 years and in that time our needs have not changed.

We still suffer from the demands and behaviours of big government, big unions and big business.

Our policies are designed to give the self employed their human rights, to give them back time they need to spend with their families and in their businesses. We will continue to review these policies and fight the good fight for the people who earn an income from their own endeavours. 

COSBOA Policies for 2011 and beyond 

  • These policies are designed around two immutable and un-arguable facts: 
  • Small businesses are owned and run by an individual or a couple 
  • Small business are an integral part of the Australian Economy 

Summary 

There are over 2 million individuals who run a small business. These people cannot be expected to have the same knowledge, skills, experience and resources as experts from medium to large businesses. A small business owner cannot possibly meet all the requirements asked from government nor compete on an equal level with big businesses. 

All political parties and most bureaucrats acknowledge the role played by small business in the economy but over the last twenty years they have not shown that they understand that a small business is different from big business and must have different policy responses and different processes and rules. 

COSBOA believes that we must give small business owners the same treatment and protection that we give consumers. For example we must not automatically view negotiations between experts from large business and the owner of small business as equal. 

We can only expect small business owners to act like the individuals they are and not to act like all the experts from a larger business such as a paymasters, accountants, OH&S experts, tax experts, apprenticeship and training experts and an expert on local rules and legislation. Each small business owner will have some or many of these skills but not all of these skills. And, importantly, a small business owner has a family and a life outside work and does not have the infrastructure to support them during life crisis or stressful events outside the business. 

Therefore the policies of government and the actions and requests from government must reflect the individual nature of small business. 

In our campaign to make life fairer for people in their own business the main aims of COSBOA are to: 

  • have governments treat small business as individuals and not expect them to have the same skills, knowledge, resources and capacity of big business; 
  • decrease red tape and compliance costs on small business owners; 
  • create a fairer market place for the owners of small business; and 
  • provide support to small business owners who are in crisis or who are ready to grow. 

Specifically COSBOA wants all political parties to commit to: 

  • removing employers involvement in the collection of superannuation funds for their employees, this can be achieved by better use of the taxation system; 
  • having a dedicated small business minister in the federal cabinet; 
  • having a dedicated small business Ombudsman or small business commissioner operating in the federal bureaucracy. This is to ensure a fair go for small business and provide a person to whom a small business owner, or family, can go to when they believe they have been treated harshly;
  • developing a workplace relations system that acknowledges that a small business is run by an individual who cannot be expected to have the same ability and understanding as the paymaster of a large company;
  • giving small business owners the same protection from unfair contracts and unscrupulous behaviour by big business as provided to the consumer;
  • conducting a small business impact statement when any new significant retail development occurs in a town or community and ensure that the developer compensates the family of any business that is unfairly affected by the development;
  • completing an independent small business impact statement on any new policy proposal or any new legislation from the federal bureaucracy or parliament;
  • developing healthier workplaces that also consider the health of the small business operator/s to be important. 

Small Business Ombudsman

COSBOA Small Business Policy Proposals 

Small Business is the engine room of Australia’s economy. This is a statement based upon research and a fact recognised by the major political parties. 

With more than 2.4 million small businesses in Australia (ATO figures) and some 798,000 independent contractors (Productivity Commission figures) the small business community is the major private sector employer in our country. Through PAYG tax collections small business is one of the greatest contributors to Commonwealth revenue. Equally, through the personal expenditures of a huge number of employees small business is also a major contributor to the GST revenue that drives state budgets. 

Small business is not asking for a hand out or a hand up, but simply a fair go to get on with business with the minimum impediment and an equitable market place in which to operate.  The small business community in Australia recommends the following policy proposals as a positive contribution to the economic wealth and the social appreciation of all Australians. 

Policy Proposal:  Stop Press - In February 2012 the Prime Minister Julia Gillard announced the appointment of Brendan O'Connor as the Small Business Minister and also announced that he would be in cabinet.That the Prime Minister appoints a Small Business Minister to Cabinet and supports the role by establishing a Small Business Ombudsman
 
Rationale
 
Government policies and bureaucratic red tape should fit the need. Their application should relate to the size and operation of the class of business to which they will apply.
 
There needs to be a process that enables the relevant level to be determined early, and not after policy proposals have ministerial approval. By then it is difficult if not impossible to achieve any effective change.
 
Thinking about solving this very real problem and the attendant costs for both government and small business leads COSBOA to suggest the merits of establishing a “Small Business Ombudsman” STOP PRESS - In March 2012 the Prime Minister Julia Gillard announced that the position of Small Business Commissioner would be created.
 
The “Small Business Ombudsman” could add value by achieving cost economies for government as well as help to control the unnecessary bureaucratic intervention into the small business world.
 
The Small Business Ombudsman could have the roles of:
*    Providing government with an “internal advocate” for small business by gathering data, facilitating consultation and most importantly provide a pre approval voice in the room to avoid potential new or changed policies having a deleterious impact on the nations productivity.
 
  • Provide a reference point for bureaucrats to gain informed (and confidential) feedback on their proposals.
  • Provide a single point of reference or signpost office to enable small business to communicate effectively with government.
  • Accept the reciprocal role of ensuring that government policies are effectively and efficiently communicated to the small business community where the majority of private sector employees work.
The obvious question is one of cost. And the answer lies in the substantial savings that will be mad by both government and consumers with every bureaucratic and wasteful regulation that can be withdrawn.

Unpaid tax collectors

Policy proposal – That small business is not required to provide free services on behalf of governments. Small business not be asked to be the pay clerk for paid parental leave and small business is removed from the collection of superannuation. 

Rationale 

Small and micro businesses are neither resourced nor administratively equipped to provide free services on behalf of government. This includes GST collection; Superannuation collection and distribution; and paymaster for Paid Parental Leave. The added burden and costs are counter productive to good business practices and could lead to administrative errors and false accusations of fraud. 

Small business research

Policy proposal – That the government collaborate with COSBOA to research and determine the numbers and nature of small business in Australia. 

Such research also to determine: 

  • Small business employment and economic contributions in both urban and regional areas 
  • Any widely applicable inhibitors to the growth and success of small enterprises 
  • Possible opportunities to enhance the growth and success of small businesses 
Rationale 

Research to determine a consistent definition of small business will be necessary to implement the potential preferred taxation treatment of “Small Business”,  Accompanying enquiry will achieve recognition by government in its policies that the circumstances, strengths and weaknesses of small business are different from those of medium and large firms. Policies that recognise these differences can promote economic efficiency and growth. 

Rights in law

Policy proposal – That small business is given the same rights in law as that provided to other individuals in the community.
 
Rationale

In the end Small and Micro businesses are people and they suffer from undue pressure or poorly written contracts as any other individual. The current situation where it is assumed that a business owner has the same negotiating capacity and the same ability to understand a contract as the experts of large companies and organisations is not tenable. These people should be given the same protection as consumers.

Small business impact statement

Policy proposal – That a small business impact statement is developed when any new significant retail or office development occurs in a town or community and that the developer compensates the family of any business that is unfairly affected by the development. 

Rationale 

Over the last two decades large shopping centre developments have emerged across Australian communities. This has often resulted in closure of businesses outside the shopping centre. The closures have often resulted from rearrangement of streets and bus stops and closure of car parks outside the shopping centre. This has removed the capacity of consumers to access the existing shops and caused their closure. We consider this to be unconscionable and demand compensation to business owners for loss of business. 

Impact Statement 2

Policy proposal – That an independent and public small business impact statement is developed when any new policy or legislation is introduced, this includes any new process in key areas of small business activity. 

Rationale 

Currently government departments are asked to develop a small business impact statement on new policies but this is not compulsory and is often completed by people with no real idea of the needs of small business. An independent person, such as the Ombudsman, should review new policy and provide a public assessment of its impact on small business. 

Personal Services Income Tax Laws

Policy proposal – That government commit to the retention of the existing Personal Services Income Tax Laws ensuring the most appropriate tax outcome for independent contractors. 

Rationale 

The commercial world and governments are driving the trend towards greater contracting to individuals. The personal service incomes tax laws should support these types of commercial practices. Stopping individuals from entering into contracts on terms that meet their personal situation inhibits natural business behaviour and is unfair in the terms and conditions it forces on micro contractors. 

Health

Policy proposal – That the health of small business owners are considered as important as the health of other people in the community. 

Rationale 

When healthy workplaces are being discussed the health of employees is considered the main concern. This covers CEOs and highly paid executives as well as the lowest paid worker and casuals and temporary staff. The business owner is asked to consider the health of the employees but the health of the business owner is not considered in any way and this must change. 

Fair WorkPlaces

We need a Small Business Industrial Award to remove complexity and add certainty. 

In the small workplace we need a system that is not based on philosophy and vested interests - we need a system that is based on reality and people.

Work Choices
and Fair Work are and were systems based on outmoded beliefs about the way the workplace should operate and behave. One system was designed by big business to suit their belief in what a workplace should look like and the other system is in many ways designed by the Australian union movement and big business associations to reflect their needs.

In the end these systems, their development and implementation (and their eventual dismantling and reconstruction into other systems) has failed everyone except the vested interests.

We propose that we accept the reality of our working world and we have two systems. One for big business and one for small business.


Large Workplace System
The big business system will involve unions, legal experts, big business associations and government agencies and departments. They can have a workplace relations system that requires legal interference and court cases, various agreements, complications at all levels, negotiations, ambit claims, ‘game’ playing, registrars, threats, strikes, lock outs, political intrigue, go slows, regular award restructuring, industry superfunds, compliance by everyone, corporate and union machinations as well as true and false accusations. The Commissioners for this system will be appointed with a rotation of three years so that no certainty will ever be obtained and all participants will regularly justify their existence and their pay by having to fight or support the current commissioners. The people involved in this system can design and redesign the process and argue and debate and change and modify to their hearts and wallets content. Basically this is a continuation of the workplace relations system of the last hundred years.

Small Workplace System
The small workplace is different from the world of big business. There isn't that much conflict and not as many problems in the world of small business. This world consists of real people working together trying to earn some money through effort. It is more often than not a simple world where people work closely together, they respect each other, are tolerant of normal human behaviours and rarely need government or union interference. It is a world without paymasters or award experts. It is a world where family and free time is valued and the participants, the employer and the employees, seem to know what the rules are because those rules are to be found in every day life. These rules are built around respect of people, working hard, forgiving minor indiscretions, telling the truth, tolerance, communicating as often as possible, not asking for the impossible, support for each other in times of stress, accepting of reality and enjoying or putting up with what is happening.

The reality is that the world of the smaller workplace is never as bad as is made out. Last year there were around 26,000 employers fined in some way or another. That is less than 1% of employers. Last year there were less than 20,000 unfair dismissal claims made by disgruntled employees. That is a small percentage of people, and in the end we are not sure whether the dismissals were truly unfair as only one side, the employee, gets support and assistance. One side has to prove the facts (the employer) the other side doesn't (the employee). And it is such a small number - why do we spend hundreds of millions of dollars on such a few issues that may or may nor be true?

We will still need support for those that are vulnerable and that support must be obvious and easily available.  The support needs to be for both employers and employees. The majority of those that feel vulnerable will be employees because there are more of them. Employers can, and do, feel vulnerable. If a woman of slight build needs to confront a much larger man about theft in the workplace then she may feel vulnerable, very vulnerable. If a pregnant woman is dismissed for being pregnant, no matter what ‘excuse’ is used, that is also an appalling event that must be addressed. Is having a complicated system that assumes blame will always rest with the employer, unless positive proof can be produced, the best way of managing a small number of bad situations?

A potentially simple solution is to have a help line that is available for both the employer and employee and that is about providing information on wage levels and on managing conflict and situations that are wrong. This help line would treat both employers and employees as equal in human rights, this system will provide real support and information. At the moment the FWO has a help line for employees that is focused and well resourced. There is an information line for employers that starts with a threat to use any information they gain against the business and finishes by stating that the information that is provided might be wrong and the employer will need to contact a legal person if they want the facts (and no lawyer can actually guarantee facts on wages). 

Any help line or any information for employees and the employer must give the same information to both these people.  Currently it cannot be guaranteed that the information will be the same and this has the potential to create unnecessary conflict.  It cannot and should not be this hard for the small workplace. 

Under our proposal, for people who work in a small business, any dispute that cannot be resolved in the workplace and escalates will be settled by one person from the new FWO who considers the facts and makes a decision. That FWO is tasked with considering the needs of both the employer and the employee, communicating effectively and giving all individuals involved the same rights. Any decision is based on a simple set of rules and pay rates. The system is designed for people not for experts.  There should be no assumption made on who is right or wrong until facts can be determined from both sides of the arguments.

The rules of the small business workplace will be based on human rights, the reality of the workplace and parts of the National Employment Standards.

Unfair dismissal will relate to issues such as discrimination, pregnancy and the like, issues already embedded in legislation.

When it comes to clashes in the workplace then if the dispute resolution process cannot work out the problem then issues such as accusations of theft etc will be dealt in a civil court and will not be supported through further intervention by government. This reflects the fact that in the small workplace for many of these cases it is one person's opinion against another person's opinion. When an individual catches a person stealing they should have the right to remove that person from the workplace. If, on the rare occasions, the accusation is false then this should be managed by the people involved not by a third party from the industrial relations system.

There is also the fact that managing personality clashes should not be something that government agencies attempt. In the end if a personality clash is so bad then one party will leave the relationship.  It is a fact that the employer cannot leave the business, that fact cannot be resolved by systemic rules or by punishing one party or rewarding another – it is a part of everyone’s life and should not be confused with discriminatory or dishonest behaviour.

Our proposed system is an improvement on the current system where the force of government is behind one individual, the employee, but ignores the rights of the other individual, the employer. Our system reflects real life, real relationships and the fact that the great majority of people resolve their issues one way or the other.

If two people are working together and one is the employer and one is the employee the situation will be judged on the fact that it is two individuals. They both have roles and responsibilities. One earns a wage completing tasks for the other person. They both focus on a task. Any disputes are nearly always sorted. So let's have a simple system that is fair, less complicated than the system for big business and reflects reality.

This system will work, more than 99% of people will be satisfied. And big business, the unions, and other stakeholders who would rather have philosophy than reality can enjoy their moments in the sun in the "big business" system without hurting anyone but themselves.

Let's have a workplace relations system that reflects the needs of all the people in a small workplace, not of the institutions who sit above those people.  We need a system that reflects reality not philosophy. 



Superannuation

Take Small Business People out of the Inefficient Superannuation Collection System

COSBOA believes that the involvement of small business people in the superannuation system has created inefficiencies within the superannuation industry and has impacted negatively on the earnings of the funds. 

It is also an unreasonable task to impose on small business people who are not skilled in superannuation and are the only people in the superannuation system who are not paid for their contribution which is the collection and distribution of funds. 

The current superannuation system was set up in the early 1990s as a means to the self funding of retirement for the growing and ageing workforce. When the Super Guarantee was set up the number and nature of small business was different. The demand placed on small business people in the initial stages was less onerous as super choice was not in place. There was no GST and no Paid Parental Leave to impact on the time available for managing new compliance and red tape. As the system has evolved and the number of small businesses has increased the demands and costs to the small business sector and the economy has grown. In 2010 some 20,000 small business people were fined for failure to complete tasks to do with super collection and that number would have been substantially more except for the lack of resources available to the ATO in identifying the difference between mistakes and deliberate non compliance. 

The recent initiative through the government’s ‘Stronger Super’ aims to decrease costs for superfunds, streamline process, ensure compliance and engage workers. The overall aim will not decrease costs for employers and may not reduce costs for superfunds given the potential requirement for more frequent contact with fund members and employers. The current approach will increase costs in time and money for individuals who are also employers and also increase a non compliance.

The Superannuation Industry is run by the private sector for its various members and is funded from the members’ contributions. We find it difficult to understand a regime where a small business person is asked to do the work of the private sector for no financial return and will be fined by the government if they get it wrong. We believe that private sector behaviours should be reflected in the whole process. We believe that an individual in business is being asked to do the same activity as a paymaster from a big business, which is not normally possible. 

The inclusion of default funds in awards also adds a different complexity and asks a small business person to have a level of understanding of process and of the superannuation industry that is not reasonable to expect. 

We offer a constructive solution that provides minimum savings of potentially $2 billion per year for the funds. 

Employer involvement in Superannuation advice 

Currently an employee can nominate their fund. The employer has no choice but to be involved with that fund. In the business context the fund is just another supplier of a service. The fund may be inefficient in its communications and its record keeping and may cause extra work for an employer, time that would be better spent on the business or with their families. But a small business owner has no choice but to work with an inefficient supplier. If the employee does not nominate a fund then an employer must pick a superannuation default fund or must use the one provided in whatever award or Enterprise Agreement. That fund will also likely be inefficient. 

The process also, in effect, makes one person, the small business employer, responsible for financial advice to another person or persons (the employee). This is not a reasonable request to make of people who are not trained in the financial industry. 

Many, if not most, of the superannuation funds are inefficient in their record keeping and in their interaction with employers. The forms that are sent to employers are designed for paymasters and people with the time and understanding to complete the forms. 

When a super fund loses information on a member they will often contact the current, or last, employer seeking information such as date of birth, address or member number. The funds know that we must work with them or there is a chance we will be fined (and many funds use a threat of contacting the ATO if information isn’t supplied). 

Due to the placement of a fund in an industrial award or instrument there is no motivation for a fund to be efficient in dealings with employers. We are forced to use inefficient suppliers and cannot change to a different more employer friendly fund as the choice of fund is not one that we can make. We also have no room for complaint as these organisations are outside the public service and there is no capacity for APRA or ASIC to demand they become more efficient. 

Remove employers from the collection process 

We propose to resolve all the problems by including superannuation in a person’s gross pay and in the PAYG payment to the ATO. 

Projected savings for funds under the COSBOA proposal.  If superannuation is included in the PAYG process then the members of funds will receive a higher return on their investments. The potential savings for members of superfunds is over $1.8 billion per year. 

The calculations for these savings are based on the fact that superannuation funds have to manage their contacts with employers and the interaction between their members and employers. 

We have estimated an annual administrative cost for funds of $800 per employer and $200 per employee/member. This cost has been estimated by COSBOA as we cannot identify any fund that discloses a detailed cost breakdown of expenditure or costs. We believe our costs to be conservative. 

The activity that justifies the $800 per year for administration involved with employers involves what is required by a fund to manage the contact and processes involved with the employer. This involves:

  • Electronic communications with the employer
  • Mail contact with the employer
  • Maintaining a help line
  • Printing of paperwork and reports required for internal reports
  • Printing of paperwork required for employers
  • Assessment of reports by experts and management
  • Updating information on new and old employers into the system
  • Matching employers with old and new fund members
  • Ledger entries
  • Receiving and processing cheques
  • Receiving and processing EFT payments
  • Maintaining up to date records
  • Identifying errant employers
  • Contacting errant employers
  • Employing debt collection agencies as needed
  • And the list goes on

The activity that justifies the $200 per year for administration of the interaction between the employee/member and employer involves what extra activity is required by a fund to administer and manage the contact and processes involved with an employer. This involves:

  • Matching the member with an employer 
  • Movement of funds from an employer payment to the members account on a monthly or quarterly basis 
  • Changing details of the employer as the member changes jobs 
  • Informing the member of any payments made by the employer or any activity 
  • Maintaining the record and data base with correct information 
  • Cost of mail activity which includes stationary, stamps, use of mail house or internal employees 
  • If electronic contacts are made there is a cost of data base management, managing “returned email address unknown, managing “out of office replies” and ensuring the information still reaches the member.

There are almost 1m employers. The costs per year to superfunds of their dealing with employers would be $800m per annum. 

There are at least 12 million employed people in Australia who also are members of funds and many of these people have accounts in three of four different funds . There are at least 18 million fund accounts. The costs per year to superfunds of their dealing with employees is $3.6 billion per annum. 

Therefore the minimum cost of administration is $4.4 billion per year. 

Under our proposal the only cost for superfunds will then be any extra costs to government for using the PAYG system to move superfunds. This has been costed by the Australian Taxation Office at $114m per year. 

There will also be an administration cost of contacting the clearing House/ATO for the superfunds. Given that each fund will have one point of contact to maintain that cost will be low, let’s say it might be $100 per member. This is based on: 
Contacts with the ATO

Managing information on funds received from the tax office. 

All other activity would be at the funds discretion and not a part of the role in managing funds and communicating progress. This is a total cost of 

Costs and savings 

  • Current costs to funds $4 Billion 
  • Cost of dealing with employers 0.800 
  • Cost of maintaining records on employer/member interaction 3.600 
  • Total current costs 4.400 

Costs under the COSBOA proposal

  • Costs for the Government (to be funded by the superfunds) 0.114 
  • Costs to funds of dealing with the clearing house 1.800 
  • Total projected costs 1.314 
  • Net savings for funds per year $2.486B 

This does not include the efficiency dividend for small business people who will not be forced to be part of the superannuation collection process. We conservatively consider that saving would also be in the vicinity of $800 per year which results in a further saving off over $800m. 

Remove us from the system or pay us for our work 

The current system is complicated and inefficient due to the continued involvement of employers in the process and, in particular, the inefficiency of the industry funds. The industry funds will remain inefficient as long as we have no choice in which fund we use. 

It should also be noted that, in the main, the retail funds are much easier to deal with and their payment processes, communications and information management reflects their better understanding of the business world. 

The other solution is that the small business employer gets paid for collecting and distributing funds. This is extra work they will either do after hours or pay someone else to on their behalf. We should be paid for our work, the same as everyone else in the system. 

Efficiency will create opportunity 

It should also be noted that under our proposal that there are other issues and benefits: 

There will be a general increase in efficiency in the economy, as well as in the management of superannuation funds. This increase in efficiency will come mainly from saved time and expense for employers and for superannuation funds. 

There will be a decrease in non compliance by employers (there will be zero non compliance as they will not be involved in the system.) In 2010 some 20,000 small business people were fined for not completing the process according to law. 

There will be improved, streamlined communications and processes for super funds who will deal only with the ATO not with many employers. 

This approach creates savings for the user (taxpayer), superannuation funds and employers. 

Taxpayers outside the tax system are more likely to be re-engaged as the ATO will need information to be able to forward payments to their fund of choice. The need to engage with the ATO would be more compelling for these people as 8.25% of earnings would normally be a substantial amount of unclaimed funds. 

The superfunds and employers would have the capacity to better plan and manage cash flow. 

Employees would be aware of the full income they are receiving from their employers as their gross wages would now include the super component. 

The employee would also be more engaged at least once a year in deciding what happens to their superannuation funds. When a person fills out their tax return they will understand exactly how much money they contribute to superannuation and this will provide greater interest in how the funds are performing. 

The employee would no longer be worried about whether the employer has remitted their funds. The employer would no longer be stressed about whether he or she has got it right. 

The unions could save time and money as they no longer have to monitor employers role in superannuation and can concentrate on safety, pay and other workplace issues. 

In the case of bankruptcies and business failure the ATO normally has first call on any ‘money due’ and the demands of employees have a much lower priority. In this proposal the super guarantee component would have the same priority as the ATO, giving some surety in super payments. 

There are no extra costs for employers, only savings and an ability to concentrate on business issues rather than the financial affairs of its employees.

Employers would have some increased costs. The current situation where any earnings under $450 a month do not accrue super contributions will be dropped and overtime will obviously be included in the overall income and the super component. The issue of extra costs to some employers can be resolved during the change over from the current system to the new system and this can occur at the same time that the SG contribution is increased from 9% to a higher rate. There will be no losses or change for employees. The only difference would be the need to provide information on superannuation funds to the ATO rather than to each employer. Superfund management activities would become more streamlined and less complicated. 

The Seamless Economy - COAG submission

Recommendations to Improve the Productivity of the Australian Economy

Summary of Recommendations – The seamless economy agenda

The ‘first phase’ of ‘seamless economy’ reforms should be concluded as soon as possible. In particular, the COAG Select Council on Workplace Relations should be tasked to resolve the ‘control of business’ issue, which is a major concern for small business, by 31 December 2012.

National schemes should be administered, and have services delivered by a single agency.

Delivering services through state and territory agencies under service level agreements should be seen as a transitional step. 

National agencies should be given the resources necessary to give them ‘the teeth’ to ensure that national regulations are administered consistently throughout the country.

The COAG Reform Council could be tasked with the responsibility of reporting how efficiently the new national regulatory schemes created by the seamless economy agenda are operating.

Finally, a mechanism also needs to be developed to identify areas that can be included in the second wave of ‘seamless economy’ reforms, such as for example uniform real property laws.

In the longer term, a commitment should be made to a new intergovernmental agreement for a new seamless economy agenda (sometimes called ‘seamless economy II’ or ‘second phase seamless economy’) preferably with competition payments attached, dealing with the next areas of microeconomic reform, such as uniform property laws.

However, small business must be involved in the development of this agenda and be involved in genuine consultation with government as new schemes are being implemented.

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