® 2015 CORPORATE PROFILE i Introdu c t i on INNOVATION We value the innovative minds of our people; we strive to create innovative products. COMMITMENT We value our commitment to our employees, customers and suppliers. RELIABILITY We value the reliability of our company, products and services. I n tr od u c t ion OUR MISSION We offer our customers integrated solutions using innovative products combined with unrivalled service and reliability worldwide. OUR VISION To be the world leader in medium voltage outdoor switchgear. ii 1 M anagi n g B oar d MANAGING BOARD Oleg Samarski Quality & Service Director Neil O’Sullivan Managing Director Ma na g in g B o a r d Quynh Anh Le Finance Director Jay Manne Engineering Director David Dart R&D Director 2 3 DIRECTOR ’s M essa g e Neil O’Sullivan Managing Director D I RE CTOR ’ s Messa g e Dear Stakeholders, In 2014 NOJA Power returned an on budget result with increased profitability and a consolidation across our global operations. customers to develop new smart grid functionality particularly in relation to impedance earthed networks and fire mitigation programs. The manufacturing capacity at our Brisbane Australia corporate office and factory has been enhanced with three separate medium voltage reclosing circuit breaker production lines operating two shifts a day throughout the entire year. We are committed to continuing to invest in research and development and plan to launch several new products and technologies in 2015 as a result. Many of these technologies will be world firsts and are expected to fuel significant growth in the business over the next decade. Our electricity utility customers globally are continually tasked with building smarter grids and our R&D team is continually challenged with providing solutions for these smart grid challenges. We have continued partnering with several of our utility Our subsidiary entities and exclusive distributors in 82 countries continue to provide a network across the globe to provide our customers with solutions in their own time zones. NOJA Power Brazil Campinas manufacturing facility has now matured to provide consistent output and 4 recently obtained ISO9001 accreditation. We have recently obtained third party accreditation to ISO18001 Occupational Health and Safety, our health and safety programs are recognised as industry leading. We will continue to strive for zero harm in the work place in addition to ensuring the highest possible quality through our ISO9001 quality accreditation and remain very committed to initially reducing our environmental foot print through our ISO14001 program. NOJA Power is well placed in 2015 for continued growth with an ever increasing product portfolio and financial capability to support the growth. We look forward to being of service. Neil O’Sullivan Managing Director 5 Histor y HISTORY NOJA Power’s vision is to be the world leader in medium-voltage outdoor switchgear. The company has moved towards achieving that vision with the installation of more than 35,000 NOJA Power OSM series Automatic Circuit Reclosers in over 82 countries worldwide. Since its inception, NOJA Power has fuelled growth by offering clients across the globe innovative, robust, safe and environmentally friendly products that offer years of reliable service. The products’ quality has been recognised through multiple awards across several years from Australian Government authorities and various international bodies such as the Latin America Business Council. externally type tested and certified by Netherlands-based independent test laboratory KEMA. We believe R&D is the corner stone of the company’s products NOJA Power is committed to quality and environmental responsibility and the company has been certified to AS/NZS ISO9001, AS/NZS ISO14001, AS/NZS 4801 and OHSAS 18001 Standards. “ ” Factories in Australia and Brazil incorporate advanced in-house test facilities to ensure our products are routinely checked during the development and manufacturing process. In addition the company’s products are In the company’s quest to provide innovative and effective solutions for our customers worldwide it invests a substantial amount in Research and Development (R&D). NOJA Power believes R&D forms the cornerstone of the company’s products. The R&D H I S TOR H I STOR Y Y team uses the latest three-dimensional modelling and finite element analysis tools to create the next generation of products and solutions. NOJA Power strives to provide the latest technical advances to customers. As part of this strategy, the company is involved in future developments through its membership in various bodies such as the Distributed Network Protocol (DNP3) group, Institute of Electrical & Electronics Engineers (IEEE) and Electrical & Communications Association (ECA). The company is proud of its highly-skilled multicultural workforce. The workforce’s combined background, knowledge and experience ensure NOJA Power remains at the forefront of research, development, manufacturing, sales and service of medium voltage outdoor switchgear. NOJA Power is committed to maintaining a loyal and healthy workforce as well as creating a positive working environment. In 2012 the company introduced a 6 health and wellbeing program that has subsequently won multiple awards. Social activities are held on a regular basis and the staff is encouraged to participate in various sporting events and wellbeing programmes. In addition, NOJA Power sponsors external sporting events such as female rugby sevens and offshore yacht races. Company personnel also receive ongoing training to extend their skills, knowledge and experience. 7 Histor COMPy A N Y PRO FI LE The company’s medium voltage Automatic Circuit Reclosers are suitable for both pole-mount and substation applications for conventional distribution networks ranging from 10 to 38kV. In addition, NOJA Power’s Automatic Circuit Reclosers are essential building blocks for smart grids, the computerised electricity distribution networks of the future. The functionality of our RC10 controller, which controls the operation of the OSM series Automatic Circuit Recloser, is continuously enhanced to meet the latest specifications and the highest level of advanced automation. NOJA Power collaborates with its clients worldwide to ensure their different needs and requirements are met. “ We collaborate with our clients worldwide to ensure their different needs and requirements are met ” For example, the company recently released a single triple Automatic Circuit Recloser to meet the unique requirement of the US Market. The company retains offices throughout the world with business developers and authorised distributors servicing clients in Australia, the U.S., South America, Europe, Africa and Asia. In January 2012 NOJA Power Brazil was founded to service the already high and increasing demand for the OSM series and RC10 controller products in Brazil. The company is also breaking through into new markets such as Vietnam where there is a rapidly growing need for a reliable electricity supply as the country develops. 8 H I S TOR Y COMPANY STRUCTURE The following organisation chart illustrates the management structure of NOJA Power. Managing Director Research and Development Sales and Marketing Engineering/ Manufacturing Quality and Service Finance NOJA Power Brazil Australia & Pacific Engineering/ Manufacturing Technical Support Asian Region Europe Finance USA Sales UK Chile Software and Electronic Development Switchgear Development IT & Communication Test & Training Quality Service Warehouse Production Facilities Management Accounting Contract Administration Procurement & Logistics 9 M anufa c tu r i n g A c tivi t ies JAY MANNE Engineering Director M an u fa c tu r i n g A c t ivities “ The company’s main facility is a modern factory strategically located in the Trade Coast precinct of Brisbane, Australia. A finished goods manufacturing facility located in Campinas, São Paulo, Brazil, complements the main Australian facility. This last year has been one of consolidation for our manufacturing and warehousing processes, our electronics reliability and the well-being of our personnel. Our manufacturing staff all look forward to the challenges associated with new product developments during the course of 2015 “ MANUFACTURING ACTIVITIES NOJA Power’s main production facility is purpose built for the manufacture of low- and medium-voltage switchgear and houses the latest in lean assembly processes together with advanced testing facilities. 10 11 Resea rc h & Devel opme n t David Dart R&D Director Resear c h & Develo pme n t 12 RESEARCH & DEVELOPMENT commitment to Research & Development (R&D) activities. Up to 10% of the company’s turnover is invested in R&D every year. Our R&D team are highly skilled and talented with relevant industry experience. “ The company works hard to limit the environmental impact of its products. NOJA Power’s OSM series Automatic Reclosers employ environmentally friendly solid dielectric insulation. The products have also been designed and manufactured with important safety features such as arc fault containment and venting. The products are then type tested by independent test laboratories to verify the performance of the safety features. NOJA Power is committed through its ongoing investment in R&D to providing clients with the best mediumvoltage switchgear products and services. Innovation is a part of the organisation’s culture. This year we have seen the broadening of our single and dual phase product range. The launch of the single triple for the US market and the introduction of a whole new range of features allowing us to broaden our support for electrical networks now and well into the future. We are committed to our R&D through our skilled team of people and the innovation instilled in the culture of the organisation “ NOJA Power maintains a long-term QUALI TY A S S URA NCE oleg samarski Quality & Service Director “ Quality of our products is a continuous improvement journey at NOJA Power. Health and Safety of our employers and workers is a major focus including ISO18001 certification in 2014 “ 13 Qu ali t y A ss u r a n ce 14 Quality Management System NOJA Power’s established Quality Management System has been certified in accordance with AS/NZS ISO9001:2008 and guarantees the manufacture of quality, leadingedge finished goods in each of the company’s factories. The company focuses on continuous improvement of its internal quality processes to consistently improve product performance, reliability and functionality for the benefit of the clients. NOJA Power is committed to environmental responsibility and safety when servicing its customers. The OSM series Automatic Circuit Reclosers are built using environmentally friendly solid dielectric insulation and employ arc fault containment to ensure personnel safety. The company has also introduced a Recloser App for smartphones that allows utility maintenance personnel to check the status of an Automatic Circuit Recloser without the risks associated with pole climbing and contact with medium-voltage switchgear in all weather conditions. The company also has an integrated Health, Safety and Environmental Management System which has been certified to AS/NZSISO 14001, AS/NZS 4801:2001 and OHSAS 18001:2007. Superior product safety, reliability and performance is underwritten by type testing and certification conducted on all products using both NOJA Power’s in-house test facilities and those of independent laboratories such as KEMA, TCA, EMC technologies and SIMTARS. The company is constantly developing the in-house test capabilities and they now include a new synthetic test laboratory (for testing 38kV, 800A products) and EMC test facilities. The facilities have been upgraded for impulse testing up to 600kV and power frequency testing up to 200kV. NOJA Power’s in-house test capability includes: • • • • • • Up to 600kV Impulse Testing Up to 200kV power frequency partial discharge Primary Current up to 3.5kA EMC Test Equipment High temperature to +135°C low temperature to -70°C power system simulator Salt fog laboratory 38kV, 800A NOJA Power recognises that customer satisfaction is of utmost importance and strives to deliver unrivalled service. A highly qualified staff responds to any customer enquiries within 24 hours. 15 FI NANCI A LS Quynh Anh Le FINANCE Director FI N A NC I A LS Financial Report 2014 delivered a strong financial performance for the NOJA Power Group. This performance resulted in a significant increase in the net worth of the group and an on-budget net profit after tax performance. The group balance sheet has no significant debt and allows the company to continue to invest in the coming years to finance expansion and growth. The NOJA Power group enjoys positive 2 5% 20% 1 5% 1 0% 5% 0% 2009/2010 2 01 0/ 2 0 1 1 2 01 1 / 2 0 1 2 2012/2013 2 0 1 3 / 2 01 4 Total Sales Revenue Growth 2010-2014 16 cash flow and is well supported by the Commonwealth Bank of Australia to ensure all its obligations are met. The financial results for 2014 are within the expectations of the shareholders. 17 FI NANC I A LS FINANCIAL GRAPH 30% 30% 2 5% 2 5% 20% 20% 1 5% 1 5% 10% 10% 5% 5% 0% 0% 2009/2010 2010/2011 2011/2012 2012/2013 2 0 09 / 2 01 0 2013/201 4 2 01 0/ 2 0 1 1 2 01 1 / 2 0 1 2 2 01 2 / 2 0 1 3 2 0 1 3 / 2 01 4 Net Worth Growth 2010-2014 Net Profit After Tax Growth 2010-2014 9% 8% 45% 7% 4 0% 6% 35% 5% 3 0% 4% 25% 3% 20% 2% 15% 1% 10% 0% 5% 0% 2009/2010 2010/2011 2011/2012 2012/2013 2013/201 4 Expenses Against Sales Revenue 2010-2014 2 0 09 / 2 01 0 2 01 0/ 2 0 1 1 2 01 1 / 2 0 1 2 2 01 2 / 2 0 1 3 Return on Equity 2010-2014 2 0 1 3 / 2 01 4 IN S URA NC E 18 Insurances NOJA Power maintains a wide range of insurances to make sure our business operates in a safe, risk-free environment. Motor Vehicle Policy No. 141A0021576VSD Key Person Insurance Policy No. 1817128 Travel Insurance Policy No. 9602633CTR Professional Indemnity Policy No. 2214702PIL NOJA Power Limited Combined Insurance Policy No. RTT269460-144213 Marine Cargo Insurance Policy No. Q-LAT-CARG-1390 Workers Compensation Policy No. PNB050197836 Policy No. PNB050197824 Policy No. PNB050197834 Policy No. PNB050197784 Policy No. PNB050197799 LawyerS AccountantS Banker McCullough Robertson Lawyers Level 11 Central Plaza Two, 66 Eagle Street Brisbane QLD 4000 Australia Grant Thornton Australia 145 Ann Street Brisbane QLD 4000 Australia Commonwealth Bank of Australia 240 Queen Street Brisbane, QLD 4000 Australia Industrial Special Risks with Business Insurance Policy No. 432992818ISR Public & Products Liability Policy No. 43 2107431 LIA Machinery Breakdown Policy No. MEB011668985 NOJA Power LLC Workers Compensation Policy No. 20 WEC Al3718 19 NO JA Powe r BRA Z IL NOJA Power Brazil Campinas, São Paulo BRUNO KIMURA NOJA Power Brazil Managing Director “ “ From inception in 2012 to date NOJA Power Brazil has presented considerable growth as a result of our marketing activities, product reliability and 24/7 service and support availability to our customers NOJ A P owe r B R A Z I L NOJA Power Brazil was founded in January 2012 to service the high and increasing demand for the OSM series Automatic Circuit Reclosers and RC10 controllers in Brazil. The company’s premises are located in a modern industrial state in Campinas, São Paulo, and house the company’s office and factory from where the staff provides nationwide marketing, sales, service and technical support services. The production system has been built by the company’s Brazilian and Australian engineering teams and is designed to reproduce the same ISO9001 certified quality standards for products as those maintained by the main facility in Australia. The company’s electricity utility customers demand these quality standards. NOJA Power Brazil has executed several major smart grid projects in the country. 20 21 C HANNE L TO M AR K ET Channel to Market Global SUPPORT NOJA Power enjoys close to 100% market share in Australia in its product sector and the number of export customers continues to increase. In 2012, NOJA Power Brazil was founded to service the high and increasing demand for OSM series Automatic Circuit Recloser and RC10 controller products in Brazil. NOJA Power Brazil has executed several major smart grid projects in the country. “ Collaboration with our clients is of utmost importance as we continuously enhance the functionality of our products ” NOJA Power’s Business Development Managers are based throughout the world to service an expanding client list in Australia, the U.S., South America, Europe, Africa and Asia. The company strives to exceed client requirements and understands their different needs. In 2014 NOJA Power released the single triple Automatic Circuit Recloser to meet the unique requirements of the U.S. market. The product offers coordinated individual protection of each phase in the U.S. fourwire electricity distribution system. Asia “Our presence in Asia, where 50% of the world’s population live, is ever increasing with recent sales in Vietnam opening up a whole new market.” In the U.K., the company has been able to service SP Power smart grid requirements for the last decade and is the only company to have a Notice of Conformity Certificate for NOJA Power’s full 1.0 second arc fault contained and vented Automatic Circuit Recloser. With 50% of the world’s population living in the Asian region and growing economies in many countries, NOJA Power’s Automatic Circuit Reclosers are the ideal choice for the foundation of the reliable electricity supply that the region demands. The company’s presence in Asia is expanding and recent sales in Vietnam have opened up a whole new market. Collaboration with the company’s clients is important as it continuously enhances the functionality of its products. NOJA Power aims to offer innovative, robust, safe and environmentally friendly solutions that will reliably service customers for years to come. Peter Bull Sales Manager - Asia C H A NN E L TO M A R K E T Australia Pacific “NOJA Power enjoys 100% marketshare in Australia as a result of our commitment to our customers.” Glen Harris Sales Manager - Australia Pacific Martin Van Der Linde Sales Engineer - Australia Pacific 22 23 C HANNE L TO M AR K ET Brazil Chile “Our recloser is the product of choice for many of our Brazilian electricity utility customers. This certainly helps us conquest new customers in Brazil.” “Regional Offices throughout the world are an effective way to cover the whole territory with a fast response.” Danilo Linares Sales Manager - Brazil NOJA Power Switchgear do Brasil Ltda Juan Jose Navarro Sales Manager - America Latina NOJA Power SpA Chile C H A NN E L TO M A R K E T USA 24 Europe UK “The European and African regions continue to grow as electrical utilities embrace our state-of-the-art OSM product complete with its RC10 control. Smart reclosers are a Smart Grid building block and certainly many European and African utilities have already understood this.” “NOJA Power has been able to service SP Power smartgrid requirements for the last 10 years.” “In 2014 NOJA Power opened an office in the United States, the largest market for electrical products in the world and developed a single triple recloser specifically for clients in the U.S.” Sergio Tanus JOHN DYKES Rick Campanalie Business Development Manager Europe and Africa Sales Manager - United Kingdom NOJA Power Limited Vice President - NOJA Power, LLC 25 EMPLO Y E E P ROFI LE EMPLOYEE PROFILE E M P LO Y E E P RO FI LE Employee Every day, the employees of NOJA Power Group work diligently to manufacture the best products, drive innovation and efficiency, improve customer service, build our brand, and create sustainable, long-term growth as we continue to strive to achieve our ultimate vision “To be the world leader in medium-voltage outdoor switchgear”. “ To be the world leader in medium voltage outdoor switchgear ” NOJA Power’s employees are the most valuable resource of the company. The staff is highly-skilled, -qualified and -innovative. The company is proud of the fact that it has a very diversified workforce STAFF QUALIFICATION Certificate and Diploma University or above Unrelated or no prior training and the employees come from more than 50 different cultural backgrounds. The diversified workforce combined with its experience and qualifications has given NOJA Power the strength and competitive advantage to sell products in more than 82 countries worldwide. Because education is the key to innovation and success, NOJA Power is committed to staff training and the company’s employment program for business trainees, university cadets and electrical apprentices is expanded every year. NOJA Power employs a young and dynamic workforce but one which has many skills and much experience. AGE GROUP Under 35 35 - 49 Over 50 26 27 HEALTH & WE LLB E I NG HEALTH & WeLLBEING ProgramS H E A LT H & WE LLB E I NG NOJA Power is committed to the health and wellbeing of its staff and in 2012 it introduced a health program that continues to run successfully. The program includes bike racks, showers and lockers to encourage employees to cycle to work, two pieces of fresh fruit daily for each staff member, educational seminars on food and exercise and participation in social sporting events such as “Bridge to Brisbane”. “ Best demonstrated leadership in work health and safety ” A video produced by NOJA Power describing the program has been selected by the Queensland Government to appear on its “Workplace for Wellness” website as a leading example for other companies. Since the program has been running, NOJA Power has seen a reduction in sick leave and staff turnover and an increase in productivity. In 2013, NOJA Power received the Queensland Health Workplaces for Wellness award and in 2014 the company received the Highly Commended award in the “Best demonstrated leadership in work health and safety” category. 28 29 MV P RODUCT LI NE M V PRODUCT LI N E WORLD CUP 2014 NOJA Power circuit breakers standing guard over Castelao Stadium in Fortaleza during the Brazil vs Mexico World Cup game 30 31 MV PRODUCT LI NE MV PRODUCT LINE Our medium voltage switchgear division specialises in Medium Voltage Autoreclosers for both pole mounted and substation applications from 10kV to 38kV. OSM38 & RC10 The products are in service today in more than 82 countries world wide providing Smart Grid Solutions such as automatic back feed restorations and remote control and monitoring. Automatic Circuit Recloser & RC Control & Communications Cubicle: • • • • • Vacuum Interrupt & Solid Dielectric Insulation Arc Fault Contained & Vented Micro processor based Protection / Communication Data Logging / SCADA Ready OSM27 & RC10 OSM15 & RC10 OSM27 SINGLE Phase & RC10 OSM27 Two Phase & RC10 OSM15 Two Phase & RC10 GROUND MOUNT KIOSK SIDE GROUND MOUNT KIOSK BACK OSM SINGLE TRIPLE LV P RODUCT LI N E 24. 32 LV PRODUCT LINE These Substation Metering, Protection and RTU Panel products are offered in voltage ranges from 415V up to 1000V, current ratings up to 4000A continuous current and 100kA fault current withstand capacity. The design meets the demanding requirements of the mining and process control industries. Brisbane City Council Cement Australia Enviro Future Alliance Eastern Star Gas Facilities John Holland Pty Ltd John Holland Group MI&E Holdings Pty Ltd Monadelphous Group North Queensland Bulk Ports Corporation PNG Power, Papua New Guinea Port Corporations of Queensland Rockwell Automation Australia Ltd Stowe Australia Pty Ltd Tenix Alliance Pty Ltd Thiess John Holland Thiess UGL Infrastructure United Group Infrastructure Uhde Shedden LOW VOLTAGE DISTRIBUTION KIOSK CLOSE DOOR LVK1-2IFS LOW VOLTAGE DISTRIBUTION KIOSK CLOSE DOOR LVK2-3FSCC Our low voltage switchgear division specialises in the design and manufacture of high quality low voltage motor control centres and low voltage switchgear assemblies. LOW VOLTAGE SWITCHGEAR CUSTOMERS Low Voltage Switchgear 33 AWA RDS & M E M B ER S H I P AWARDS & MEMBERSHIP A WA RD S & M E M B ER S H IP AWARDS & MEMBERSHIPS AWARDS Winner - 2015 Gold recognition - Health and wellbeing program Winner - 2013 Queensland Health Workplaces for Wellness Award Winner - 2012 Queensland Premier’s Exporter of the Year Winner - 2011 Brisbane Young Entrepreneur of the Year - Quynh Anh Le Winner - 2009 Australian Prime Minister’s Exporter of the Year Winner - 2009 Queensland Premier’s Exporter of the Year Winner - 2009 Queensland Large Advanced Manufacturer Premier’s Export Award Winner - 2009 Latin America Business Council Award - Export Business Excellence Award Winner - 2007 Queensland Exporter of the Year Award Winner - 2007 Australian Export Heroes Awards - Neil O’Sullivan Winner - 2007 Latin America Business Council award - Export Business Excellence Award Winner - 2006 Australian British Chamber of Commerce Awards - Export Excellence Award Winner - 2006 AEEMA Excellence Awards - Excellence in Exporting Winner - 2004 Queensland Export Awards - Emerging Exporter MEMBERSHIPS Achillies Utilities Vendor Database Australian British Chamber of Commerce Australian Company Directors (ACD) Australia Latin American Business Council Corporate Member of the Electric Energy Society of Australia (EESA) Distributed Network Protocol Group (DNP3) Electrical and Communication Association (ECA) Export Council of Australia (ECA) Institution of Engineering and Technology Business Partner Institute of Electrical and Electronics Engineers (IEEE) 34 35 NO JA Powe r Hea d quar t e r NO J A P owe r Hea d q ua r te r NOJA Power HQ The company’s main facility is a modern factory strategically located in the Trade Coast precinct of Brisbane, Australia 36 ® NOJA Power Australia NOJA Power BRAZIL NOJA Power CHILE NOJA POWER EUROPE NOJA Power Switchgear Pty Ltd 16 Archimedes Place, Murarrie Brisbane Qld 4172 Australia NOJA Power do Brasil Ltda Avenida Pierre Simon de Laplace, 764 Techno Park – Campinas – SP CEP 13069-301, Brasil NOJA Power SpA Ramón Subercaseaux 1268, Of 1206, San Miguel, Santiago. Chile NOJA Power Switchgear Pty Ltd NOJA Power Limited Adolfstrasse 39, 53111, Bonn, 4 Stalyhill Drive, Stalybridge NRW, Germany Cheshire SK 15 2TR United Kingdom Phone: Fax: Email: Web: Phone: Fax: Email: Web: Corporate Office & Factory +61 (7) 3907 8777 +61 (7) 3399 6777 sales@nojapower.com.au www.nojapower.com.au Office & Factory Sales Office Sales Office NOJA Power UK Sales Office NOJA Power USA Sales Office NOJA Power, LLC 5065 Timberbridge Ln. Alpharetta, Georgia 30022 United States of America +55 (19) 3283 0041 Phone: +56 (2) 2897 9649 Phone: +49 (0) 228 8236 9408 Phone: +44 (0) 1457 764538 Phone: +1 (971) 404 9039 +55 (19) 3283 0041 Email: sales@nojapower.eu Email: sales@nojapower.co.uk Email: sales@nojapower.com Email: sales@nojapower.cl vendas@nojapower.com.br Web: www.nojapower.cl Web: www.nojapower.eu Web: www.nojapower.co.uk Web: www.nojapower.com www.nojapower.com.br Distributor: Scan to view NOJA Power web site NOJA Power® is a registered trademarks of NOJA Power Switchgear Pty Ltd. This document is copyright and is intended for users and distributors of NOJA Power Switchgear product. It contains information that is the intellectual property of NOJA Power Switchgear and the document, or any part thereof, should not be copied or reproduced in any form without written permission from NOJA Power Switchgear. NOJA Power Switchgear applies a policy of continued fundamental research and development and reserves the right to change designs and specifications of this product without notice. NOJA Power Switchgear does not accept any responsibility for loss or damage incurred by anyone as a result of acting or refraining from action based on information in this document. NOJA-562-04