Webinar Summary: Work Hard, Play Harder: Managing Employee Off-Duty Behaviour

Sam Andrews:

Hello everybody, and welcome to today’s webinar. We’ve got a fun title today.
It’s coined Work Hard, Play Harder. It’s about managing employee off-duty behaviour.

My name is Sam Andrews. I am a Business Development Consultant here at LegalVision, and we’re lucky to be joined today by my co-hosts. We have Ellie Kenny and Joel Hayden. Both Ellie and Joel are working in our employment team here at LegalVision, with Joel Hayden being our Practice Leader.

Before we begin, we will just go through a few quick housekeeping items.

You will receive a recording of this webinar and the slides in your email after the session. So we certainly hope you can all remain for the duration of the session today, but if you do have to leave early for any reason, rest assured that it will be recorded and will be sitting in your email inbox after the webinar.

Secondly, please do submit any questions in the Q&A box. At the end of the webinar today, Joel and Ellie will take some time to answer those questions for you.

Lastly, we are always trying to make these sessions bigger and better for you, so please take some time to complete the feedback survey at the end of the webinar.

By viewing today’s session, you are actually eligible for what we call a complimentary consultation, or a free call with us here at LegalVision, to have a discussion around how we can help you and help your business. In the consultation, we’ll discuss your growth plans and how we can set you up for success from a legal perspective.

To claim this consultation, it’s very simple. Just leave your contact details in the survey that appears when the webinar ends. Alternatively, feel free to jump onto our website — all of our contact details are on there — and you can send us an email or give us a call.

Now I’m going to hand over to Ellie.

Ellie:

Thanks so much, Sam. We’ll start by running you through the agenda for the webinar today.

We’ll start off by chatting you through the intersection of an employee’s personal life and work life, and how difficult that can be for employers to traverse.

We’ll then go through a little bit of a case study which some of you may have heard of — the Latou and ABC case.

We’ll then go into how businesses can control out-of-hours conduct from their employees, how your internal policies can assist, and some other practical tips for all employers.

And then we’ll finish off the webinar today with a Q&A. As Sam said, feel free to submit those questions throughout the presentation.

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Ellie:

We’ll start with a bit of an introduction to the topic.

The extent to which employers can manage their employees’ out-of-hours conduct is a difficult area of the law to traverse, and employers should exercise caution before attempting to address an employee’s conduct that occurs outside the workplace and in their personal time.

The issue of whether an employee’s conduct is considered within the scope of their employment can arise in a variety of contexts, including:

• where an employer wishes to terminate or discipline an employee for out-of-hours conduct;
• where an employee injures themselves and makes a workers’ compensation claim requiring the injury to have occurred in the course of performing their duties; and
• where an employee claims that their employer is vicariously liable for the actions of its employees — for example, where an employee has been sexually harassed by another employee and is claiming that the employer is vicariously liable for the damage incurred.

These differing jurisdictions have all considered the circumstances in which an employee’s conduct in their personal life can be considered in the course or scope of their employment. In each jurisdiction, the courts have taken a very cautious approach to determining whether there is a sufficient nexus between the relevant conduct and the individual’s employment.

As such, employers should carefully consider the relevant circumstances before taking any action against an employee for out-of-hours conduct.

Beyond determining whether there is a sufficient nexus to the employee’s employment, it is also necessary to determine whether the out-of-hours conduct is protected in any way by the Fair Work Act. For example, there is an express prohibition in the Act against terminating an employee for their political views or religious beliefs.

This issue was dealt with in a recent case, which Joel will now provide more detailed analysis on.

Joel:

Thank you, Ellie. And we are lucky enough to have a recent example to look at — unlucky for the ABC, as you’ll find out as we talk through it. But given today we are focusing on what an employer can restrict in relation to an employee’s out-of-hours conduct, it is good to consider not just how an employer should view this, but also how a body like the Federal Court of Australia would view it.

Because if a dispute arises, it is either there or the Fair Work Commission where the matter will likely play out.

In this decision, which is Antoinette Latou and the Australian Broadcasting Corporation (ABC), Ms Latou argued that the ABC had unlawfully terminated her employment because of social media posts made on her personal accounts that expressed her political beliefs and opinions in relation to the Israeli–Palestinian conflict.

The issues in dispute in that proceeding raised the difficult practicalities associated with:

• determining whether conduct is within the scope of employment; and
• assessing whether a proposed dismissal is based on unlawful grounds, whether or not there is a nexus with the workplace.

The unlawful termination jurisdiction is very similar to the general protections provisions under the Fair Work Act. It just applies a bit more broadly to all employees, not just national system employees. But you can consider them, for the sake of this discussion, to be largely parallel to the general protections, which most of you will have heard of.

Ms Latou had been engaged by the ABC to run a morning radio show for a period of five days only. It was a very short contract. Shortly after her employment commenced, she made social media posts indicating her support for Palestine in the scope of the conflict with Israel and condemning the Israeli government on her personal accounts.

The ABC became aware of these posts when they received several complaints from the public suggesting that Ms Latou could not be an unbiased and impartial reporter given her social media activity. Much of the commentary in this case made it clear that it was not just direct from the general public — it was also from various lobbying organisations aligned more with Israel’s interests than with Palestine’s.

The ABC informed Ms Latou that she should be cautious about posting controversial matters on her social media accounts and advised her to limit all social media activity to purely factual statements. This was expressed somewhat uncertainly as a direction in the ABC’s view; the court did not necessarily agree it was a direction. It was more of a suggestion — not particularly relevant for our purposes.

Ms Latou continued engaging on social media on this topic in the same way, meaning she continued expressing opinions rather than sticking to fact. The ABC terminated her employment with two days remaining on her five-day contract.

Ultimately, the Federal Court of Australia found that the ABC had unlawfully terminated Ms Latou’s employment on the basis that the termination was, at least in part, motivated by her political opinions — which, as Ellie pointed out, is expressly prohibited under the Fair Work Act’s unlawful termination provisions. The same protection exists under the general protections provisions.

The ABC attempted to argue that the actual reason for dismissal was Ms Latou’s failure to follow a direction from the employer. But this was not accepted factually by the court. And in any case, even if a direction had been issued, the dismissal would still likely have been unlawful because part of the reason still related to her political opinion.

The result — and remember, this was a contract intended to last only five days — was a significant amount of negative publicity for the ABC. Not just for the broadcaster but for a number of its senior executives, which I’m sure many of you saw commentary about.

The court awarded Ms Latou $220,000 in compensation — partially by way of damages, partially as penalties for breaching the Fair Work Act. A very significant outcome in the context of a five-day employment contract. The time and cost spent dealing with the proceedings would have been significant and likely far exceeded the damages award.

This decision highlights the difficulties for employers in managing employees’ social media presence outside the workplace. It is a reminder that employers must exercise caution before terminating an employee for expressing political beliefs, religious views, or any other trait expressly protected under the Fair Work Act.

Even if the employer is concerned about reputational risk — and it is very easy to see how Ms Latou’s opinions could cause reputational harm to the ABC — this does not override the prohibition on dismissing an employee because of their political opinion.

This reinforces an important principle:
It is not just about whether the conduct has a nexus with the workplace. An employer must ensure the reason for dismissal is not unlawful under employment legislation, which contains broad protections relating to matters such as race, sex, ethnicity, sexual orientation, political opinion, exercising workplace rights, and union participation.

Keeping this in mind, Ellie will now tell us a bit about the principles governing when an employer can restrict employees’ conduct outside of working hours, with more of a focus on the nexus.

Ellie:

Thanks so much, Joel.

As we mentioned previously, the courts have considered this issue across various contexts over the years and have established general principles regarding the relevant considerations when determining whether an employee’s out-of-hours conduct will be considered within the scope or course of their employment.

Some of these considerations include:

• Whether the conduct is likely to cause serious damage to the relationship between the employer and employee, when viewed objectively, such that the relationship cannot viably continue — for example, where an employee makes false and disparaging comments about their employer’s business on their personal social media accounts.
• Whether the conduct is likely to damage the employer’s interests, including reputational or financial damage.
• Whether the conduct is incompatible with the employee’s duties.
  For example, if a truck driver is convicted of a serious driving offence outside work, an employer may reasonably consider whether this impacts their ability to perform their role. Or where an employee engages in recreational drug use in their personal time but attends the workplace still affected — this may also be reasonably managed by an employer.

The High Court has historically found that there will be an insufficient connection to employment where conduct occurs during an employee’s personal time and where there is an absence of the functional, temporal, and geographical aspects of the employee’s scope of employment. Essentially, if the employee is not in the workplace and the relevant conduct does not occur during working hours or while performing aspects of their duties, it may be difficult to argue there is a sufficient connection to employment.

The High Court has also found that it is necessary to consider whether the conduct is so remote from the employee’s duties that it is altogether outside of and unconnected with their employment.

Some specific considerations for employers include:

• Whether the conduct occurs in the workplace or during working hours, including where an employee is required to be on call.
• Whether the conduct occurs at a work-sanctioned event — for example, a work Christmas party. The Fair Work Commission has previously formed the view that conduct occurring at a work Christmas party is considered within the scope of employment, particularly where the employer makes a direction beforehand that workplace policies still apply during the event.
• However, the Commission has also found that misconduct at an afterparty organised by employees and away from the official venue is unlikely to be captured by their employment.
• Whether the individual is identifiable as an employee of the business — for example, if they were wearing a company uniform or have identified themselves as an employee on social media. If the individual is not identifiable as an employee, it may be difficult to argue there is a potential for reputational harm.

Whilst this is not an exhaustive list, it identifies key factors for employers when determining whether there is a sufficient connection to employment and therefore whether out-of-hours behaviour can be lawfully managed.

I’ll now pass back to Joel to discuss how internal policies can be a helpful tool to manage employee conduct.

Joel:

Thank you, Ellie. It is obvious that policies are a really important starting point for a business to set expectations for employees and regulate employee conduct, including conduct that may occur outside the workplace. In the same way that you would expect to have policies that regulate behaviour within the workplace — like anti-discrimination, harassment, bullying, etc. — having written policies like these that employees are aware of and understand is a key step in addressing the reasonableness of any restrictions an employer looks to place on its employees.

We need to make sure an expectation is actually communicated before we can even start to answer whether it’s reasonable in nature.

It is important to note that a policy will not be enforceable just because an employer puts it in writing. If a policy attempts to prohibit conduct unlawfully or deals with matters beyond what is reasonably associated with the employment relationship, it would likely not stand up to scrutiny.

This means that if an employer tried to rely on a breach of such a policy to dismiss an employee, this would not amount to a valid reason in most cases, and that employee would likely succeed in an unfair dismissal application at the very least.

While the core principles Ellie set out will always be relevant in determining whether an employer can lawfully regulate employee behaviour, employers can still implement policies that set out general expectations.

For example, employers may implement a policy regulating social media use, particularly on sites where workers identify themselves as employees of the business, such as LinkedIn. This ensures these platforms are used appropriately, and confidential information is not shared.

Conversely, if an employer tried to restrict an employee from using social media entirely in their personal time, this would likely not be enforceable, as it is not reasonable within the scope of freedoms an employee should have outside work.

Importantly, and as we saw in the Latou case, employers must not implement policies that discriminate against employees for their political views or religious beliefs, whether directly or indirectly. However, employers can manage inappropriate content such as disparaging comments about the business, its clients, or other key relationships.

This is not exhaustive, but you can see some examples of policies on the screen that you may want in place to regulate out-of-hours conduct. These could include vehicle policies, relationship policies, conflict of interest policies — anything with a reasonable nexus to the workplace that calls for regulation by the employer.

A good example of how this can be managed is in relation to a relationships policy. It is unlikely to be enforceable to prohibit employees outright from having personal relationships with each other. But a reasonable policy would require employees to disclose relationships where they occur within lines of reporting, so the employer can validly manage conflicts of interest. That is generally how employers deal with relationship policies.

With all policies — whether related to in-work or out-of-work matters — they should always:

• clearly explain any restricted behaviour and the rationale for it;
• illustrate examples of what is acceptable and what is not;
• ensure restricted matters are proportionate to the business need; and
• provide training as necessary to support compliance.

Whenever a new policy is implemented, particularly in a complex area like this, it is beneficial to conduct training for employees and managers alike so they understand how to implement and comply with the policy.

Beyond these general policies, businesses should also consider issuing clear and express directions to employees before high-risk events, such as Christmas parties — particularly where alcohol will be supplied and where the context may be partly in and partly out of the workplace. There can be confusion around whether workplace policies apply once the “official” part of the event ends.

These directions should include warnings that the business expects responsible consumption of alcohol and that the business’s standard workplace behaviour policies continue to apply for the duration of the event.

A lot of employers want to discourage employees from holding afterparties following the main event. It is difficult to prohibit this entirely, as people will almost always continue socialising after the official event. However, clear statements can be issued making it explicit that any afterparty is not a work-sanctioned event, while reminding employees that, where they are engaging with colleagues outside the workplace, they should still act in accordance with expected standards.

Employers should not seek to unreasonably regulate what employees do outside the workplace. However, they should absolutely take steps to protect legitimate business interests by addressing:

• conduct that conflicts with an employee’s duties;
• conduct that poses reputational risk;
• how employees treat each other both in and out of the workplace; and
• maintaining professional standards when holding themselves out as representatives of the employer.

Any policy of this nature should be supported by a clause in every employee’s employment agreement requiring compliance. This reinforces that it is reasonable to expect compliance.

Ellie will now give us a few more pointers about how practically we can address matters related to this in the workplace.

Ellie:

Thank you very much, Joel.

When a business becomes aware of an allegation of misconduct relating to conduct that occurred outside the workplace, it is essential that a proper investigation is performed. This should include an assessment as to whether the alleged misconduct actually occurred, whether there is a sufficient connection to employment, and whether the conduct is captured by the protections in the Fair Work Act, as was the case in Latou and ABC.

Some examples of circumstances where an employer could reasonably manage an employee’s out-of-hours conduct include:

• where an employee posts objectively disparaging and false comments about their employer on social media;
• where an employee discloses confidential information about the employer’s business online;
• or where an employee commits a crime while wearing their company uniform and the employer receives negative publicity as a result.

Equally, some circumstances where it would be difficult to establish a sufficient nexus to employment include:

• where an employee expresses a mild political view on their personal social media account but does not identify themselves as a representative of the business (noting this is also a prohibited reason for termination);
• or where two employees have a personal relationship and have a conflict or disagreement in their personal time.

This assessment of nexus should be clearly documented as part of an investigation report to demonstrate that the employer carefully considered whether the conduct was in the course of employment before taking action.

When thinking about general principles of a proper investigation:

• The investigation should commence with a thorough interview with the complainant to identify the exact allegations and any potential witnesses.
• The employer must also interview the respondent, putting the allegations to them to allow a response. This is essential. It is almost impossible to establish procedural fairness in an unfair dismissal claim if an employee was not afforded an opportunity to respond.
• The business should interview relevant witnesses and consider documentary evidence such as emails, Slack or Microsoft Teams messages, and CCTV footage.

Once the employer has considered all available evidence from the complainant, respondent, witnesses, and other sources, it must form a view as to:

• whether the conduct occurred on the balance of probabilities;
• whether the conduct can be considered in the course of employment; and
• whether the conduct is protected under the Act.

If a business fails to properly consider or determine any of these matters, the employee may make a successful unfair dismissal, general protections, or unlawful termination application on the basis that:

• the conduct was not within the scope of employment;
• procedural fairness was not afforded; or
• the reason for dismissal was unlawful.

Employers must ensure all investigations are properly concluded and factual findings are made before taking disciplinary action. Once completed, a detailed investigation report should be kept on file, and any resulting termination must be carried out in accordance with policy and established procedures to ensure procedural fairness.

Sam:

Thank you very much, Ellie. That concludes the main part of our webinar today on managing employee off-duty behaviour.

We are always trying to get as much information out there as we can to assist you and your business. Feel free to download the free resource we’ve put together for you today. It is relevant to today’s session and is titled A Guide to Employment Disputes.

Coming up next week on Wednesday at 11:00 a.m., the 26th of November, we will be hosting our next webinar, Think Before You Ink, which will cover what to review before signing business contracts. So feel free to join us again next week.

We are going to answer your questions shortly. I’ll hand back over to the team in a moment. While you submit them, we’ll take a minute to tell you about LegalVision’s membership.

By becoming a member with LegalVision, your business gets unlimited access to our full team. We have over 100 specialist lawyers here at LegalVision, including Joel and Ellie, for all your day-to-day legal needs. It is like having your own in-house legal counsel for a fraction of the cost.

Our team can assist you with a few things I’d like to highlight:

• unlimited document drafting and reviewing;
• unlimited legal advice consultations;
• and unlimited domestic trade mark registration.

Much more is included within the membership as well.

As a LegalVision member, you don’t need to worry about the cost of lawyers. Think of it as having your own in-house counsel. We take care of all the BAU work so you can focus on running and growing your business.

We also offer a dedicated service for in-house teams. If you are a General Counsel, we can manage your high-volume BAU legal tasks. Our lawyers invest upfront in understanding what is most important to you and your business, and they work as an extension of your in-house legal function.

If you want to learn more about the LegalVision membership or the desk-extension model for in-house counsel, feel free to request a free consultation. You will be able to do so when the survey appears at the end of the webinar. Alternatively, as mentioned earlier, all of our contact information is on our website, so feel free to email or call us. The easiest way is simply to opt in for the consultation via the survey at the end of the webinar. It is complimentary and free.

We will now hand back over to our hosts to answer some of your questions. Before we do that, you will see a poll question pop up on your screen. If you can take a moment to answer it, we would really appreciate it.

Now I’m going to hand back over to Joel to take us through some of those questions. Thanks, Joel.

Joel:

Thank you, Sam.

Just to confirm, we have a few questions that came in prior to today, which we will start with, and then we’ll move on to the questions submitted throughout. Keep in mind with everything we say, this is a risky area, as the Latou decision shows. Always seek specific advice if you are thinking about relying on an out-of-work reason to dismiss or discipline an employee. Definitely a sticky situation — get specific advice.

We’ll start working through the questions now.

Question: How do we balance a LinkedIn account for an employee and how they deal with their personal versus professional brand, and how can this be managed from the employer’s side?

As we said, this is a great example of where a policy should exist within a business to manage how someone is representing themselves on social media when it is necessarily tied to their employer. Everyone who uses LinkedIn has it tied to their employer. It is clear that, at least indirectly, they are holding themselves out as associated with their employer, and that is relevant to reputation.

There should absolutely be policies managing what an employee can and can’t do on LinkedIn. It does not mean an employee has no ability to represent themselves personally. You may require them to state expressly when something is their personal opinion and not that of the employer.

This will depend on the employee’s seniority and the nature of the business. The more reputation-sensitive the business, and the more senior the employee, the more guidelines you can impose. A robust social media policy is appropriate here.

Question: What are the legalities around using employees’ social media posts in performance discussions?

Again, not a lot of detail here, but there is nothing preventing an employer from using publicly available information in disciplinary processes. For example, if an employee calls in sick and is then seen on social media out at the beach that same day, that can absolutely be relevant.

If information is public and relevant, it can be used — provided it is dealt with reasonably and proportionately.

Question: How do we address policies in employment contracts?

Ellie will take this one.

Ellie:

Thank you, Joel.

As you mentioned earlier, the primary consideration for managing employee conduct is implementing appropriate workplace policies. In an employment contract, you should ensure the contract contains a provision requiring employees to comply with all company policies, and also specify that the policies do not form part of the contract itself.

That caveat is essential, so the employer is not in breach of contract if it deviates from a policy. There have been recent cases where this issue has arisen, and significant compensation has been awarded to employees, so it is very important to include that provision.

Joel:

Thank you, Ellie.

Question: What is the process if someone from the public makes a complaint about an employee’s online conduct but there is no evidence?

If the issue is serious enough to cause reputational harm or relates to misconduct that should be addressed, then you should conduct an investigation. You should not finalise an investigation without sufficient evidence.

If the post has been deleted, that does not prevent you from putting the allegation to the employee. For example:

“We have received this allegation. It was posted publicly but appears deleted. This is a credible allegation we are investigating.”

If the employee credibly denies it, you likely cannot make a finding. But if they make admissions or other evidence supports it, there may be grounds for a finding.

Question: Should policies differ for full-time, part-time, or casual employees?

Usually, no. These policies should apply consistently across the workforce — and often to contractors as well. Conduct expectations do not change depending on employment status. A casual employee is not “less restricted” from engaging in harassment, for example.

Joel:

We have another one for Ellie.

Question: If an employee stole from one of our clients while off duty, and it wasn’t work-related, would their dismissal be unfair?

Ellie:

Thank you, Joel.

A very serious allegation. Considering the factors discussed earlier:

• This conduct would cause significant reputational damage if the client became aware.
• If the employee used information gained through employment to commit the crime, the connection becomes even stronger.
• The conduct would severely impact trust in the employee.

Each situation still requires a full factual assessment and investigation, but this is generally the type of conduct that may be considered within the scope of employment. For unfair dismissal, the investigation process and substantiation of facts are also critical.

Joel
Thank you, Ellie. We’ll now move to some questions submitted after the session started.

Question: Did the Latou decision create a precedent?

The Latou decision did not create new law. It was a straightforward application of the unlawful termination provisions in the Fair Work Act. The ABC simply failed to rebut the presumption that Ms Latou was dismissed for a reason that included her political opinion.

One point of clarification from the decision is that the unlawful termination provisions should be applied in the same way as the general protections provisions. The drafting in the Act differs slightly, but the decision makes it clear they should be treated similarly.

Question: If the connection to employment is made by a third party, is that a consideration? For example, a news outlet names an employer as being associated with a recent protest.

Yes. It does not matter how the information comes to light. If something becomes public and damages the employer’s reputation, it can be dealt with by way of investigation and potential disciplinary action. The employer must still determine whether the conduct occurred and whether the nexus with employment exists.

Question: A manager and an employee communicate via personal social media accounts, and the manager sends inappropriate messages outside work hours. The social media policy only covers use of the company page. How should this be handled?

This is serious. If the conduct amounts to sexual harassment, the employer is generally vicariously liable unless it can demonstrate it took reasonable steps to prevent such conduct. This is why harassment policies must cover all work-related interactions, including digital communications and out-of-hours contact.

In this scenario, the employer may not have done enough to mitigate its liability, given the narrow scope of its policy. If the employee pursues a claim, they would almost certainly include the employer as a respondent, not just the individual responsible.

Question: If employees choose to drive themselves to a voluntary employer-organised Christmas party located two hours away, does the company carry liability for accidents during travel?

This scenario falls into a grey area. If the event is work-related and the employee is attending at the employer’s invitation, there is potential for the travel to be considered within the course of employment for the purposes of workers’ compensation. This depends heavily on the state legislation involved, and laws differ significantly across jurisdictions.

If covered by workers’ compensation, that regime typically bars personal injury claims against the employer directly.

Question: What is your view on employees openly discussing their use of illicit drugs outside of work? How should an employer respond?

This type of discussion is inappropriate in the workplace, even if the conduct itself occurs outside of work. It can make others uncomfortable and involves discussion of criminal activity.

A proportionate approach is needed:

• A mild comment may warrant a verbal warning.
• Repeat behaviour may warrant further warnings.
• If it escalates — for example, encouraging colleagues to use illicit substances — or if drug use affects the workplace (e.g., attending work impaired), dismissal may be justified, subject to proper investigation and legal advice.

Again, context and procedural fairness are key.

Joel:

We have one more question.

Question: Does the contractual disclaimer stating that policies are not incorporated into the employment contract depend heavily on policy wording and consistency of application?

Yes. The disclaimer alone is not always enough, but it is an important first step. Without it, courts may presume a policy is contractually incorporated, especially if the policy uses promissory language.

A strong approach includes:

• stating clearly in the contract that policies are not incorporated;
• ensuring the policy itself repeats this statement;
• avoiding contractual or promissory wording in the policy; and
• ensuring the policy reads as a direction rather than a contractual obligation.

Conduct-related policies (e.g., anti-discrimination, harassment) are rarely found to be contractual if drafted appropriately. Incentive or bonus schemes are more likely to be considered contractual.

That concludes the questions we have.

Thank you everyone for attending today. Please reach out for your complimentary consultation if you would like to speak to our team.

Sam:

Thanks, Joel.

That’s all we have time for today, everybody. I want to take a moment to say thank you to Ellie and to Joel — they’ve certainly earned themselves a glass of water.

Apologies if we didn’t get time to answer your question. However, if you submit your details at the end of the survey, we will be able to address anything we didn’t get to. As Joel said, it will also give you an opportunity to learn more about how our membership can help you through the complimentary consultation.

Please opt in for that consultation — we’ll get an understanding of your business, your growth plans, and how LegalVision can provide a tailored solution.

This is a free webinar, and as I mentioned earlier, we’re always trying to make them bigger and better for you. Please give us some feedback in the 30-second survey at the end — we really appreciate it.

And once again, thank you to Joel, Ellie, and everyone for joining.