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IN THE MATTER OF the Inquiries Act 2014

AND IN THE MATTER OF a Board of Inquiry into the Covid-19 Hotel Quarantine Program

WITNESS STATEMENT OF MO NAGI

1 I make this witness statement on behalf of Unified Security Group (Australia) Pty Ltd (Unified Security) in relation to the Victorian Government's Board of Inquiry (Inquiry) into the COVID-19 Hotel Quarantine Program.

2 I make this witness statement in response to a Notice to Produce dated 10 August 2020 with reference NTP-040.

3 This witness statement is made to the best of my knowledge and belief and I confirm the contents to be true.

4 This witness statement has been prepared at short notice and I have endeavoured to provide the Inquiry with as much detail as possible in relation to the topics for which I have been asked to provide responses.

My role at Unified Security

5 I am employed by Unified Security as Victorian Operations Manager.

6 My day to day duties and responsibilities for Unified Security include providing operational support on projects which the company is involved in throughout Victoria.

7 In relation to the Hotel Quarantine Program, my role was primarily an operational one which involved conducting walk-throughs of quarantine hotels, incident response, dealing with subcontractors and generally assisting with all aspects of the security services which were provided at each of the hotels.

Professional background

8 I have worked in the private security industry for approximately 20 years. Prior to joining Unified Security, I held roles in risk management and loss prevention for a clothing chain. Most recently, I worked in the Global Loss Prevention department of a jewellery company.

Security services rostering arrangements at hotels involved in the Hotel Quarantine Program

9 The rostering set up was predominantly the same across each of the quarantine hotels. In most cases, Unified Security provided the following personnel for each shift:

x 1-2 Operational Manager;

x 1 Shift Supervisor;

x 2 guards in the lobby area;

x 3 guards to assist with fresh air walks;

x 3 relievers;

x 3 guards dealing with deliveries; and

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• 2-4 guards per level of the hotel.

10 However, there were some differences between each hotel depending on thehotel's individual needs.

11 Each day, Unified Security provided security guards for 2 shifts of 12 hours each.The day shift ran from 6:00am to 6:00pm and the night shift ran from 6:00pm to6:00am.

12 The duties of security guards are set out in Annexure A of the Agreement forProfessional Services with the State of Victoria, as represented by the Departmentof Jobs, Precincts and Regions (DJPR) (Agreement) produced at[USG.0001.0001.2688 and USG.0001.0001.2688]. Annexure A stated a list of'Services' to be provided by security guards before guests had checked in, duringcheck-in and once check-in had been completed. Those services includedescorting guests to their room, assisting with the arrival of buses carrying luggage,managing on site issues and maintaining a presence on all floors, lobbies and frontdoors.

13 The duties of security guards was also determined by reference to the area of thehotel in which they worked, whether that be in the lobby or on a particular floorwhere guests were staying.

Changes in the number of security personnel required

14 The number of shifts per day did not change over the course of the HotelQuarantine Program. There was a day shift and a night shift.

15 The number of persons rostered on to each shift at each hotel did however changeover time for a number of reasons. Those reasons included circumstances wheremore passengers were expected at a hotel and so additional floors were utilised orin case where changes in process required additional security staff to helpimplement.

16 The most significant change to the rostering patterns occurred in June 2020, wherethe numbers of guards were significantly reduced across all quarantine hotels.

17 On 19 June 2020 at 6:22.m Personal Informatio (Principal Policy Officer, Employment,l InformationInclusion at the DJPR) Persona emailed my colleague David Millward (Mr

Millward) stating that the DJPR is embarking on a process of minimising thenumber of people on site at quarantine hotels. The email further stated that GonulSerbest (Chief Executive Officer of Global Victoria at the DJPR) (Ms Serbest) waskeen to speak with Mr Millward about how staff numbers could be reduced on sitewhilst ensuring that guests continue to receive the services that they require in anenvironment that is safe for both guests and staff. A copy of that email is producedat [USG.0001.0001.2710]

18 On 21 June 2020, I sent the DJPR revised allocations of security personnel at 10 ofthe sites where Unified Security provided security services, which was requestedby the DJPR two days prior. A copy of this email is provided at[USG.0001.0001.2566]

19 Ms Serbest replied on 21 June 2020 at 3:50 pm stating "Grateful if we can reducenumbers on floors at Novotel Collins as discussed. I'll also revert back as soon aspossible on numbers required for fresh air walks at Metropol [...] let's proceed withreduced numbers [...]"A copy of this email is provided at [USG.0001.0001.2566]

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20 I replied at 5:07pm on the same day stating that I made the adjustments at Novotelon Collins, translating to a reduction in security staffing by 143 per sift (i.e. a 30%overall reduction). These changes in the number of security staff mandated by theDJPR materially reduced the scope of Unified Security's involvement in the HotelQuarantine Program. A copy of this email is provided at [USG.0001.0001.2566].The new arrangements were set out in a spreadsheet produced at[USG.0001.0001.2576] provided to the DJPR.

Changes in the duties of security personnel during the course of the Hotel QuarantineProgram

21 The nature of the duties of security guards did change over time.

22 On 28 March 2020, when I was first asked by Mr Leitner to assist in the HotelQuarantine Program, my understanding was that security guards would be presentat the hotels to ensure that guests remained in their room and to ensure that therewere no unauthorised personnel either entering or leaving the hotel.

23 On 29 March 2020, I observed that the scope of services required to be performedby security guards extended beyond what Unified Security had been initiallyinformed would be required. I recall arriving at the Crown Promenade between7:00am and 8:00am that day. When guests began to arrive at the hotel, I recall thatwe assisted with carrying their luggage and escorting them inside the hotel. We didthat for approximately 10 hours that day before I moved over to the CrownMetropol to assist there.

24 To the best of my knowledge and belief, Unified Security did not receive anyguidance from specific Government personnel about processes or systems tomove guests from the buses and into their rooms. I remember being concernedabout some guests not having any PPE, and that the 1.5 metre rule was not beingenforced, particularly between passengers on the buses. We tried to ensurepersonnel maintained 1.5 metre distance from each other when moving around.

25 As a result of the concern regarding guests not having PPE, of our own accord,Unified Security also started providing PPE to the passengers we noticed did nothave any. We also gave PPE to Police and Government officials.

26 I recall there were many different groups of people on site from differentGovernment departments but it was not clear what their respective roles andresponsibilities were.

27 I understand that on 3 April 2020 Personal Informatio (Principal Policy Officer, Inclusion,Personal Informatio

Employment within DJPR) emailed Mr Coppick at 10:11am, detailing thetasks and responsibilities required of Unified Security guards in the HotelQuarantine Program. Specifically, on top of maintaining a presence on floors, in thelobby and at the front door, security guards were to assist with arriving buses andtaking luggage off buses, accompanying guests in lifts to their floor during check-in,support receipt and delivery of parcels to rooms and escalate issues to variousparties. A copy of this email is produced at [USG.0001.0001.3767].

28 On 3 April 2020 at 3:24pm, Mr Coppick forwarded me the email fromregarding guard responsibilities. I replied to Mr Coppick that day at 21:29pmconfirming that I would implement first thing the following morning. A copy of theemail chain is produced [USG.0001.0001.2462].

Personal Informa

29 Throughout the Hotel Quarantine Program, there were other occasions whenguards were requested to perform tasks which I thought were outside the original

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brief for services (for example fresh air walks and exercise breaks). I explain thesebelow.

Fresh air walks and exercise

30 At the beginning of the Hotel Quarantine Program, my understanding was thatguests were not permitted to leave their hotel rooms for fresh air or exercise unlessthey were suffering from mental health issues. That position changedapproximately 2 weeks in when a health and welfare policy was introduced for allguests allowing them to exercise outside while supervised.

Personal Infor31 On 9 April 2020 at 8:57pm, emailed Mr Coppick explaining that the DH HS

had requested that an additional three security guards would need to be rosteredon per shift between 8:00am and 8:00pm to implement the new health and welfarepolicy and that Authorised Officers would work with security to facilitate this. A copyof the email is produced at [USG.0001.0001.2620].

32 I understand that Mr Coppick responded to this email at 9:18pm, informingthat he had spoken to the necessary personnel on site to support theimplementation of the policy and that suitable areas for walks would be identified.In that same email chain at 9:41pm,

Personal Inform *also requested that security staff

support DHHS's further direction. This direction indicated that high risk individualscould organise food deliveries from services such as Uber Eats, to meet theirdietary requirements. After prompting from Mr Coppick on a specific process, ii

responded the DHHS would liaise with security staff on site. A copy of thisemail chain is produced at [USG.0001.0001.3700].

33 Similarly, in relation to the Rydges on Swanston hotel, I am informed and verilybelieve that Personal Infor sent a further email to Mr Millward on 17 April 2020 at 9:15am,requesting Unified Security's co-operation to deliver food and facilitate exercisebreaks. Noting that this was not in the original services brief, Personal Inform indicated thathe would approve the use of additional staff. Mr Millward later con irmed that theserequests would be facilitated. This email chain is produced at[USG.0001.0001.2678].

Personal I

Personal nfor

34 On Saturday 18 April 2020 at 9:52am, I understand that Personal lnforma emailed MrCoppick a policy approved by the Department titled 'Exercise and Fresh AirImplementation Plan (Exercise Plan), which would become operational fromMonday 20 April 2020.

35 The Exercise Plan, which was dated 15 April 2020, contained information onguests accessing exercise breaks, and set out a procedure to be followed by boththe guest and the security escort during the exercise break. Copies of the emailand Exercise Plan are provided at [USG.0001.0001.3652] and[USG.0001.0001.3653], respectively.

36 Pursuant to the Exercise Plan, when guests were taken out of their room, securityguards were required to wear a mask, be the person who touches all surfaces(such as lift buttons and handles), maintain distance from the guests and ensurethat there was no more than 3 people in a lift at any one time (including the guard).

37 I recall that we were asked to take about 40 or 50 groups for fresh air walks perday. At Crowne Plaza, we encountered problems as we were being asked to takemultiple rooms for walks at the same time. We were of the view that this wouldincrease the likelihood of cross-conta•ion. Mr Coppick raised this in an email toPaul Stagg of DJPR (Mr Stagg) and Personal Inform copying in myself and Mr Leitner, on28 April 2020 at 8:39am. In that email, Mr Coppick sought clarification from DJPR

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on the process to be used. In response, Personal

Informpassed the query on to DHHS,who advised that the policy had not changed and multiple rooms could not betaken out at the same time. A copy of that email chain is provided at[USG.0001.0001.2625].

38 A further policy was introduced whereby guests could order food from Uber Eats. Acopy of this policy was emailed to me and Mr Leitner on 22 April 2020 by

(Director of Global Victoria, DJPR) Personal Information Copies of that email andthe Food Delivery Policy which was attached are at [USG.0001.0001.2612] and[USG.0001.0001.2614], respectively, detailing that security personnel would assistto log the delivery and deliver it to the guests' room.

Check out process

39 Security guards were required to assist guests with luggage and any issues thatarise during the check in process. However, we were later requested to also assistguests who were checking out after they had completed their 14 day period inquarantine.

40 On 10 April 2020 at 10:35am, in preparation for the first guests checking out fromCrown Promenade and Crown Metropol on 12 April 2020, Personal Inform emailed MrCoppick and Mr Leitner setting out a proposed process. In relation to the role ofsecurity guards specifically, Personal Inform informed that security personnel would knockon the doors of guests departing the hotel, and would assist with carrying theirluggage to the lobby and into transport. A copy of this email is provided at[USG.0001.0001.3673].

41 In one instance on 23 May 2020, while carrying out this process, a Unified Securityguard was asked to escort a guest from his room to check out, and handled theguest's belongings. The Authorised Officer later realised that the paperworkprovided to the guard was incorrect, as the form failed to indicate that the guesttested positive for COVID-19. I then had to ensure the guards involved were testedand isolated in hotel rooms while awaiting their results. I emailed Mr Coppick andMr Leitner information about this incident at 6:06pm on 23 May 2020, a copy ofwhich is at [USG.0001.0001.2443].

Cleaning and other services

42 There were also occasions in which guards were asked to perform housekeepingand care services.

Personal Infor

Personal

43 I recall receiving an email at 10:58am on 23 April 2020 from Vuna Tu'ikolovatu (MrTu'ikolovatu), a supervisor of Unified Security's subcontractor (Tui & SonsSecurity Services Pty Ltd trading as Hi8 Security) (Hi8) who was providing securityservices at Holiday Inn. Mr Tu'ikolovatu was asked by the hotel manager andnurses if security personnel could assist with various different tasks, includingassisting nurses with elderly or disabled guests who needed to be lifted or moved,collecting and changing the yellow biohazard bins, and plunging toilets, assistingwith TVs and air-conditioners, and unlocking safes and internal doors. MrTu'ikolovatu informed them that security could perform minor housekeeping tasks,such as taking rubbish left outside rooms if approval was granted, but could notchange linen and other tasks. A copy of that email is provided at[USG.0001.0001.2236]

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Relocating COVID-19 positive guests

44 During their periods of quarantine, some guests were identified as having COVID-19. At the commencement of Unified Security's services, these guests were movedto another floor of the hotel to which they were originally allocated to separate themfrom others. However, at a certain point in the Hotel Quarantine Program, positivecases for COVID-19 began being transferred to Rydges on Swanston, as the 'red'hotel. Security was asked to provide support to relocate these guests.

45 On 30 April 2020 at 2:22pm Mr Coppick emailed Personal Inform,o confirm whether there

was a process determined for relocating guests to Rydges on Swanston. A copy ofthe email chain is provided at [USG.0001.0001.2943].

Assisting Victoria Police

46 I am also aware of occasions in which guards were asked to assist Victorian Policeofficers who were required to enter the rooms of guests who were causing issuesor were believed to be self-harming.

47 On one occasion at Crown Metropol, I was directly involved in a violent episode bya guest who appeared to be suffering from mental health issues. This particularguest was located in a room directly next door to another guest with similar issues.I recall that in June 2020, the police were required to enter this guest's room tocalm her down after she had refused to come out. I called a DJPR staff member toadvise that the police would be making a forced entry. When the female guestexited her room, she chased a nurse down the corridor and began to attack her. Iwas required to apprehend the guest before police officers were able to place herin handcuffs. She then proceeded to spit at one police officer. When medicsarrived, an injection was administered and the guest was taken to hospital.

48 Following the incident, although I do not recall precisely when, I received a call thatthe guest had been brought back to the hotel. It was only after another incidenttook place involving this guest that was she was removed permanently.

Government-organised deliveries for guests and similar tasks

49 We also received other requests from the DJPR to assist the Government duringthe Hotel Quarantine Program. For instance, at Easter, we were asked byGovernment representatives to deliver Easter eggs to guests. On Mother's Day, theDJPR organised that we deliver gifts to each of the mothers in quarantine.Evidence of this is produced at [USG.0001.0001.3304].

50 We were also asked to drive to Toyworld Docklands to purchase, at theGovernment's expense, approximately $5000 worth of children's toys and gamesfor families in quarantine. Guards were required to separate the gifts into ageappropriate categories and deliver them to each of the rooms. Evidence of this isproduced at [USG.0001.0001.2669].

51 Towards the end of the operation, I recall that the Travelodge and Crowne Plazahad left over shampoos and personal items. We were asked by the DJPR to deliveritems to other hotels still in operation, so our guards took on that task, too.

52 Throughout the duration of the Hotel Quarantine Program, the approach taken byUnified Security guards was to do as much as they possibly could (within reasonand provided it was safe to do so) to assist the Government in its running ofunprecedented program.

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Decisions made by Unified Security regarding staff numbers at hotels

53 The decision as to how many security guards were required to be rostered on at a particular hotel depended on a number of factors.

54 When Unified Security was asked by the DJPR to provide security services for a new hotel, a walk-through of the site was conducted. We would document that walk through with a Workplace Inspection Checklist. Copies are produced at [USG.0001.0001.3973 - USG.0001.0001.3997 and USG.0001.0011.0091].

55 During the walk-through, a decision would be made as to how many guards were required on each level of the hotel taking into account:

a. how many passengers were expected to arrive;

b. the number of floors to be utilised;

c. the layout of the hotel including considerations regarding the number of potential access/egress points for quarantine guests and the sight lines in hotel corridors on the quarantine floors; and

d. the need to provide for security guard numbers to include coverage for guard break times (that is, relievers).

56 I had no involvement in relation to walk-throughs conducted at Crown Promenade and Crown Metropol on 28 March 2020. I understand that these walk-throughs were conducted by my colleagues Karl Leitner (Mr Leitner) (General Manager at Unified Security) and Mr Coppick together with a team of representatives from the DJPR, including Ms Serbest.

57 I was involved in each of the hotel walk-throughs Unified conducted from that point forward. As far as I recall, Ms Serbest was always present too and possibly other people from the DJPR.

58 There were occasions when more passengers were expected to arrive at certain hotels. In those circumstances, the hotel would sometimes make additional floors available to house guests. If that was the case, the number of guards increased accordingly. At the same time, as and when passengers began to leave hotels or those hotels began to wind down operations, personnel were similarly reduced.

59 Additional staff would need to be rostered on in circumstances where the DHHS or DJPR implemented a policy which required extra guards (such as for fresh air breaks).

Unified Security and DHHS

60 In relation to the contacts that Unified Security had at the DHHS, the information is set out in the table below to the best of my knowledge and recollection.

61 My communications with DHHS representatives were mostly by telephone as this was the most effective way to communicate quickly. This is because our dealings with the DHHS usually concerned guest health related issues.

Hotel DHHS Contacts

Crown Metropol (DHHS Team Leader)

Crown Promenade (DHHS Team Leader)

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DHHS Contacts

Travelodge I cannot recall a specific contact on the ground

Rydges on Swanston (DHHS Team Leader), (DHHS Team Leader) and PublicHealth Operations)

Novotel Collins I cannot recall a specific contact on the ground

Marriot I cannot recall a specific contact on the ground

Holiday Inn (DHHS Team Leader)

Novotel South Wharf (DHHS Team Leader)

Crowne Plaza (DHHS Team Leader)

Pan Pacific (DHHS Team Leaders)

Comfort Inn Portland I cannot recall a specific contact on the ground. I hadlimited involvement with this hotel.

Grand Chancellor

The Brady (DHHS Team Leader)

Directions given to Unified Security by DHHS regarding security services

62 DHHS did not provide specific direction regarding the way security services shouldbe performed. We received a document from DHHS with 'PPE Advice for HotelBased Security Staff and Authorised Officers' which was updated on a number ofoccasions. The PPE Advice documents are produced at [USG.0001.0001.2955,USG.0001.0001.2946 and USG.0001.0001.3788].

Unified Security and DJPR

63 In relation to the contacts that Unified Security had at the DJPR, the information isset out in the table below to the best of my knowledge and recollection. I would addthat I primarily dealt with Personal Informati Ms Serbest and Personal Information from DJPR. Mypersonal dealings with the DJPR were usually limited to information on passengernumbers, staffing arrangements and incidents.

64 Hotel-specific contacts from DJPR are summarised in the table below.

DJPR Conte

Crown MetropolPersonal Information

Crown Promenade

Travelodge

Rydges on Swanston We would contact Personal Informati. on contract related issues.On the ground issues would be dealt with by the DHHSthrough DHHS Team Leaders. I recall that from around

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DJ PR Contacts

Novotel Collins

Marriot

Holiday Inn

Novotel South Wharf

Crowne Plaza

Pan Pacific

Comfort Inn Portland

Personal InformationJune 2020 onwards, became the DJPRcontact for the hotel.

Personal Information

I cannot recall a specific contact on the ground

Grand Chancellor Personal Information

The Brady I understand that this particular hotel was managed bythe DH HS and later by Alfred Health Services. I do notrecall the DJPR's involvement.

Facilities at hotels for security staff

65 Each hotel had toilet facilities for security guards. There was also an area in eachhotel termed a 'green zone where staff such as nurses, Authorised Officers andother personnel from Government departments would be located.

66 I recall that each hotel had lunch facilities except for the Crown Promenade andCrown Metropol.

Training provided to Unified Security by DHHS, DJPR or other GovernmentDepartments regarding COVID-19

67 None that I can recall but security guards were required to complete the AustralianGovernment Department of Health COVID-19 online training course.

68 On 29 June 2020 at 2:31pm, I received an email from of HealthEducation Collaborative who I understand was engaged by DHHS on a pilottraining session on reducing the risk of COVID-19 arranged for 1 July 2020.[USG.0001.0001.2424]

Training provided to staff by Unified Security regarding COVID-19

69 All guards were required to complete the COVID-19 online training courseirrespective of whether they were engaged directly by Unified Security or asubcontractor. All guards were of course required to hold valid Victorian SecurityLicenses. In order to obtain a Victorian Security Licence, individuals must alsoobtain a level 2 first aid qualification.

70 In relation to the Rydges, given this was a 'red' hotel (which refers to a hotelhousing confirmed Covid-19 guests), I am informed Mr Coppick and verily believethat a full briefing with all staff was completed on the first day of arrivals. On thisday, Unified Security outlined the requirements and use of PPE and discussed therisk of COVID-19.

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71 All guards working at hotels operated by Crown were also required to undergo a Crown specific induction.

72 I understand that shift supervisors did verbal briefings too.

Supervision of Unified Security staff/subcontractors

73 For the security services at each hotel, Unified Security ensured that there were two Operations Managers for each hotel during the program. Operations Managers were a mix of Unified Security and subcontractor personnel. Unified Operations Managers for the hotels included myself, Mr Coppick, Mr Leitner and Matt Belton.

74 The role of the Operations Managers was to:

1. check that sub-contractors and guards were performing the services required;

2. check that guards were wearing the correct PPE which at that time included masks, gloves and eyewear (in the event that guards were coming into contact with a COVID-19 positive individual, (for example, during a move));

3. check that there were a sufficient number of guards on duty; and

4. act as a contact point for Government Departments, hotel management and Victoria Police as necessary.

75 There was a day supervisor and night supervisor rostered on for every shift. The shift supervisor was responsible for security staff management, shift briefings, day-to-day support of operations and site management and supporting the Operations Managers. There would also be a team leader on site.

76 I would attend each hotel where Unified Security was providing security services at least once every couple of days to check those matters set out at paragraph 74.

77 By way of example, I would attend a hotel such as Crown Metropol and the subcontractor supervisor would be there. I would ask the subcontractor supervisor if I could have a look at the rosters and I would ask them if they had sufficient guards arriving for the shift. I would then ask to take a look at the fresh air/ exercise walk list that had been provided by the nurses or Authorised Officers for that day. I would also ask them whether they had enough PPE and water for everyone. I always had additional supplies of PPE in my car so that I could replenish the stock at a particular hotel if required. I would ask subcontractor supervisors to confirm that each of their guards had completed the online COVID-19 training course and had received a briefing on how to wear PPE.

78 After having a discussion with the subcontractor supervisor, I would do a walk-through conducting a check on the floors just to see how things were operating in practice. I would observe how guards were wearing their PPE and whether it was being worn effectively. For example, if I saw that a guard was wearing their mask under their chin, I would talk to them about it and tell them that they need to keep it on in areas where PPE was required to be worn and it cannot be under their chin. At that point I would tell them that they need to remove the mask they had been wearing under their chin and replace it with a new mask because that mask would now need to be treated as contaminated. I would also outline the risk of not removing masks effectively and confirm that they understood. I would on occasion ask guards to show me how they put on and take off PPE (e.g. masks and gloves) to check that they were doing so appropriately. For example, I wanted to observe whether guards were removing PPE in the correct sequence, that is, removing

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gloves and disposing of them appropriately then hand sanitizing before removing masks.

79 If I saw guards with their masks under their chin when they were off duty or outside away from quarantine guests (for example on a break), I would tell them that they must remove their PPE before leaving the hotel and discard them in the biohazard bins. I would note that we put a stop to guards wearing their shift PPE outside the hotel when not performing security services pretty quickly during our service provision for the Program by asking the lobby guards to also monitor this requirement.

80 In the event that I saw guards who were not meeting our requirements (for example seeing masks being worn under the chin), I would speak to the subcontractor supervisor and ask them why we are seeing these issues and would ask the supervisor to follow through with reinforcing the matters I had raised directly with those guards across the workforce. These checks were a daily occurrence as I performed my role across hotels.

Supervision provided by Unified Security subcontractors

81 Subcontractors provided on site supervision for the service. Each hotel would have 1-2 Operations Managers assigned by Unified Security, one of which would usually be a supervisor from the subcontractor.

Responsibility for recruiting and rostering staff 82 Subcontractors were responsible for recruiting staff and to ensure that there were a

sufficient number of guards per shift in accordance with the service level requirements outlined by Unified Security.

Limitation on the means by which subcontractors could recruit staff

83 I was not involved in the recruiting and rostering of staff for the hotel quarantine program.

Factors relevant to the rostering of security staff

84 As far as I am aware, Unified Security had no involvement in relation to how often subcontractors rostered on guards.

85 I recall having a conversation with Sterling Security Group and Acost Security Services (two of the Unified Security Subcontractors) to ensure that they were not overworking their guards.

Records of hours worked

86 Records of hours worked by security guards were contained in the sign on sheets which guards were required to complete at the start and end of their shift.

Rates of pay

87 I had no involvement in relation to what Unified Security guards were being paid per hour. My colleagues Mr Coppick and Mr Leitner dealt with these matters.

Payment arrangements for security staff

88 In relation to security staff who were directly engaged by Unified Security, I understand that they were paid into their nominated bank account.

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89 In relation to security staff engaged via subcontractors, I understand that Unified Security was issued with and paid invoices direct to subcontractors who in turn paid the guards they had engaged. Unified Security's expectation was that all security guards were directly engaged by those subcontractors.

Security staff rostering between hotels 90 I am not aware of any security staff who were engaged by Unified Security and

also worked at other quarantine hotels.

91 The person with responsibility for subcontracting arrangements at Unified Security is Mr Coppick.

PPE provided by Unified Security to guards

92 Each security guard was provided with 3 face masks and 3 pairs of gloves per shift. Hand sanitizer was also available throughout the hotels. Eyewear was also provided.

PPE provided by DHHS or other Government Departments

93 I do not recall DHHS or other Government Departments providing PPE until in or around June 2020. Unified Security provided masks, gloves and eyewear for security guards.

Requirements for staff to provide their own PPE

94 Unified Security staff were not required to provide their own PPE. This was provided by the company.

Provision of PPE training

95 My understanding is that all guards were required to complete the COVID-19 online training course. I had no direct involvement in developing or issuing PPE instructions. I understand that that additional verbal briefings were provided to guards however this was within the responsibilities of Mr Coppick and Mr Leitner.

96 I specifically recall that at Rydges on Swanston, we held a full staff briefing on the first day where we outlined the requirements for wearing PPE and how to apply it properly.

97 During the Hotel Quarantine Program, Unified Security also received PPE Advice documents from the DHHS which applied to security guards. Copies of those PPE documents are produced at [USG.0001.0001.2955, USG.0001.0001.2946 and USG.0001.0001.3788].These documents caused confusion as they contradicted the instructions that Unified Security was providing to guards, that is, to always wear PPE.

PPE shortages

98 I am not aware of Unified Security experiencing a shortage of PPE. I recall Mr Leitner making multiple car journeys to and from NSW and Melbourne to ensure there was a sufficient amount of PPE at all times.

Arrangements regarding temperature checking of security staff 99 I am aware that temperature testing was formally introduced into the Hotel

Quarantine Program in June 2020.

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100 On 18 June 2020 at 17:22pm, following a meeting between the DHHS andmanagement from Rydges on Swanston hotel, Mr Menezes (General Manager atRydges) emailed Mr Coppick and myself advising that as part of some operationalchanges being introduced by the DHHS, the temperatures of guards would need tobe taken each day.

101 On 19 June 2020 at 10:00am, Mr Coppick replied to that email advising MrMenezes that Unified Security was currently working through this process with theDJPR and DHHS. A copy of this email chain is produced at[USG.0001.0001.2990].

102 A few minutes prior to that, at 9:52am on 19 June 2020, I was copied into an emailfrom Mr Coppick to Personal Information DJPR) to recommend that mandatory temperaturechecks be implemented for all personnel entering quarantine hotels. Mr Coppicksuggested that if a high temperature is recorded, the following should occur:

a. The person be denied entry to the green zone of hotel;

b. The persons details should be recorded;

c. The person should attend a mandatory COVID-19 test;

d. The DHHS should be provided with details; and

e. The person should isolate until their test results are provided.

103 On 19 June 2020 at 10:00am, Personal Informatio responded confirming her support tohave this policy implemented. A copy of this email chain is atUSG.0001.0001.2861.

104 In terms of monitoring the health of security staff generally, any guards whodisplayed symptoms of COVID-19 were immediately sent for testing and requiredto isolate until their test results were produced.

105 On 24 June 2020 at 12:25pm, I was forwarded an email chain from the DHHSTeam Leader of Holiday Inn Flinders Lane attaching DHHS-issued draft guidelinesto assist with the Temperature and COVID-19 screening. It was noted that theguideline document was a draft policy which would undergo revisions before it isfinal.

106 I also note that the email chain included an email from Glynn Owens (OperationSoteria, Operations Team Leader) to DHHS Team Leaders for the HotelQuarantine Program dated 22 June 2020 at 8:39pm. The email stated that theprocess of introducing screening of staff prior to every shift including a temperatureand symptom check had already commenced at the Brady Hotel. I note that UnifiedSecurity's involvement with the Brady Hotel ended on 23 June 2020.

107 On 24 June at 1:22pm, I was forwarded an email chain from the DHHS TeamLeader from Crown Metropol attaching the draft guidelines, a copy of which is at[USG.0001.0001.2952].

108 Both emails attached the guideline document 'Hotel Quarantine Staff ScreeningJob Description' which stated that a temperature and symptom check would be arequirement for all staff prior to commencement of every shift.[USG.0001.0001.2884]

109 On 25 June 2020 at 8:51pm, the DHHS Team Leader for Pan Pacific issued draftguidance notes to "support the person rostered for temperature checking to

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supplement the guide provided by EOC and following discussion and feedback from hotel team leader meetings” [USG.0001.0001.2950]. The draft guidelines stated that “Security staff will have signed on in their own register at the security desk, and will be required to provide contact details on this register when their temperature/symptoms are checked.” [USG.0001.0001.2951]

Responsibility for identifying and acting on instances of poor or unacceptable conduct by security staff

110 All personnel on site had a role to play in relation to identifying instances of misconduct.

111 On some occasions, as I explain below, incidents would be reported by management at the hotels to the relevant representative of the DJPR and then the DJPR would contact Mr Coppick who would in turn ask me to investigate and report back immediately.

112 On other occasions, Unified Security would be made aware of incidents by subcontractors.

113 On each and every occasion that an incident was brought to the attention of Unified Security, it would be investigated and acted upon as quickly as possible.

Responsibility for identifying and acting on complaints or concerns regarding unsafe work conditions for security staff

114 I repeat my answer at paragraphs 108 to 111 above.

115 Unified Security also has a dedicated whistleblower email that allows staff and subcontractors to anonymously report bullying, harassment, workplace misconduct or work health and safety issues.

Instances of misconduct by security staff

116 There were some occasions in which Unified Security received notice of, or identified issues of, misconduct by security staff. I set out below incidents which were brought to my attention.

Subcontractor Date of Notification

Nature of incident

Action taken by Unified Security

Document ID

Sterling 21 April 2020 Guards taking towels from hotel to sleep on

Investigation and report

USG.0001.0001.2444

Sterling 10 May 2020 Related incident

Investigation and report

USG.0001.0001.2487 USG.0001.0001.2483

Sterling 21 May 2020 Related incident

Investigation and report

USG.0001.0001.3425 USG.0001.0001.2523

Sterling 22 May 2020 Related incident

Investigation and report

USG.0001.0001.2493

WIT.0001.0036.0014

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Subcontractor Date of Notification

Nature of incident

Action taken by Unified Security

Document ID

Sterling 28 April 2020 Whistleblower complaint in relation to misconduct by security guard and supervisors

Unified Security investigated the allegations and confirmed findings in a letter to DJPR

USG.0001.0001.2191 USG.0001.0001.3407

Acost 14 June 2020 Incident regarding members of the public entering hotel

The security guards who let the individuals into the hotel were stood down

USG.0001.0001.2838 USG.0001.0001.2846 USG.0001.0001.2850

Notices received by Unified Security relating to alleged unsafe work conditions

117 I understand that an email from Simone Morrison (WorkSafe Victoria) to Nigel Coppick (Unified Security) dated 2 June 2020 at 10:33am [USG.0001.0001.3288] states that concerns were raised to WorkSafe Victoria regarding the health and safety of security guards working at an unspecified Crown hotel namely, that workers were experiencing fatigue and stress due to working excessive hours. I understand that Unified Security cooperated with WorkSafe Victoria.

118 I understand that on 2 June 2020, a finding was reached by WorkSafe Victoria was unable to substantiate the allegations.

Additional information

119 I was proud to be a part of the team providing security services to support the Victorian Government doing its best to protect the public during extraordinary and unprecedented circumstances. I personally built wonderful working relationships, particularly with the team at Global Victoria (DJPR), as we all did our best to make things run smoothly in a constantly changing and challenging program. I hope we can learn lessons from what happened for the future.

Signature _____________________________________

Print Name _____________________________________

Date _____________________________________

24/08/2020

Mohammed Nagi

WIT.0001.0036.0015