update on the singapore ship sale form (ssf 2011) · 2019. 3. 11. · 11.25 am presentation by ms...

Update on the Singapore

Ship Sale Form (SSF 2011)

28 November 2016

Maxwell Chambers, Stamford Room

Programme

9.30 am Guest Registration

10.00 am Introduction by Mr David Chin

10.05 am Presentation by Mr Henry Mytton-Mills, Sale & Purchase Practice

using the SSF

10.20 am Presentation by Mrs Gina Lee-Wan, Overview of SSF clauses

10.35 am Tea Break

10.55 am Presentation by Mr Tan Chin Hee, Buying and Selling a Vessel

Using SSF 2011: A Shipowner’s Perspective

11.10 am Presentation by Mr Leong Kah Wah, Ship Sale and Purchase:

An Arbitrator’s Perspective

11.25 am Presentation by Ms Maite Bolivar Karup, BIMCO’s IDEA2

11.40 pm Q&A moderated by Mr David Chin

12.15 pm Lunch

1.00pm Ends

Update on the Singapore Ship Sale Form (SSF 2011)

Introduction

By Mr David S.S. Chin

Executive Director

Singapore Maritime Foundation

• In 2009, SMF was asked by the Singapore and Asian maritime communities to have analternate Sales Form that would better serve their needs for S&P of second-handvessels.

• We discussed extensively and had close consultation with shipping associations andmaritime professionals across various specialisations and decided that we shouldcome up with such an alternate Ship Sale Form.

• This will cement Singapore’s reputation as a thought leader for maritime affairs and;

Also

• Encourage the growth of Singapore as a Maritime arbitration centre and the use ofSCMA Rules.

• The Singapore Ship Sale Form was launched on 6 January 2011.

• Inclusion of the SSF in the widely used BIMCO Charter Party Editor, , IDEA●2 inMarch 2016.

Why did we draft the SSF?

www.singforms.com – Information resource for the SSF

www.bimco.org – Information on BIMCO’s IDEA●2 charter party editor

www.sdsd.com/charter-party-editor/ - Information on SDSD charter party editor

www.scma.org.sg – Information on the Singapore Chamber of Maritime Arbitration (SCMA)

Relevant websites

http://www.singforms.com/

http://www.bimco.org/

http://www.sdsd.com/charter-party-editor/

http://www.scma.org.sg/

• Mr Henry Mytton-Mills, Managing Director, Aries Shipbroking (Asia) Pte Ltd

– Sale & Purchase Practice using the SSF

• Mrs Gina Lee-Wan, Partner, Allen & Gledhill LLP

– Overview of SSF clauses

• Mr Tan Chin Hee, Executive Director, Pacific Carriers Limited

– Buying and Selling a Vessel Using SSF 2011: A Shipowner’s Perspective

• Mr Leong Kah Wah, Head, Dispute Resolution, Rajah & Tann Singapore LLP

– Ship Sale and Purchase: An Arbitrator’s Perspective

• Ms Maite Bolivar Klarup, General Manager, BIMCO

– BIMCO’s IDEA2

• Mr David Chin, Executive Director, SMF

– Introduction and Q&A Moderator

Introduction to Speakers

Comments and insights on S&P

practice using the SSF

By Mr Henry Mytton-Mills

Managing Director

Aries Shipbroking (Asia) Pte Ltd

SMF Board Member

The Holy Grail of Ship Sale & Purchase

Willing Buyer : Willing Seller

No need for a contract.

The best contracts never come out of the drawer

But on this Market ………

Contracts are not needed unless there is a

problem, then it is way too late to say what you

were trying to mean or thought you agreed.

So let’s get it right

Food for Thought

1. When you complete the SSF, you have an effective workable Contract.

However, even on the latest 2012 Saleform, it is only an Option agreement.

2. For the SSF, we dissected 15 years of legal precedence on S&P

transactions, i.e. we took a lot of care and logically incorporated it.

3. In chartering deals, many C/P’s are not drawn until even after re-delivery.

For S&P, there is no such luxury, everything has to be in place before the

deal is done. S&P deals have to have a contract, no getting away from it.

4. Unlike charter parties it is usual to start with a blank form, be it the SSF,

Saleform or NipponSale. That is why we made the SSF holistic and clear so

that everyone knows what it is saying and their respective responsibilities.

Why Use the SSF?

Boxes 1 to 11 (Page 1)1. The Sellers:

1(a) Guarantor (optional)*:

2. The Buyers or Nominee**:

2 (a) Guarantor (optional)*:

3. Name of the Vessel: 4. IMO No./Official No./Call Sign:

5. Type, Built Yard, Built Year & GT: 6. (a) Flag/Port of Registry:

(b) Bare-boat Registry (if any):7. Classification Society (“Class”):

8. Purchase Price:

(i) Deposit (10 % of Purchase Price):

(a) Payee Bank:

(b) Value Date:

(ii) Balance Purchase Price (Purchase Price less Deposit): + any extras under Clause 7

(a) Payee Bank:

(iii) Place of Closing: (iv) Daily Cost of Delayed Delivery:

9. (i) Physical Inspection (Port and Date):

(ii) Pre-Delivery Divers Inspection (Port):

10. Delivery Place (at safe anchorage or berth in):

Delivery Date (Range): Cancelling Date:

Declaration: It is hereby mutually agreed that this Agreement shall be performed according to the terms and conditions set out herein. Additional clauses, if any, shall be

deemed to be fully incorporated into this Agreement.

11. Signatures - For and on behalf of:

The SELLERS: The BUYERS:

(Name/Title) (Name/Title)

GUARANTOR, if any: GUARANTOR, if any:

(Name/Title) (Name/Title)

Objectives:

1.Provides a consolidated view of the transaction and allows parties to refer to

essential details without having to go through the entire agreement.

2.Reduces the risks of mistakes, omissions and inconsistencies with the

agreement.

3.Increases the clarity and flow of the substantive clauses and minimises

alterations needed.

Highlights:

1.Optional guarantor(s) clause (Box 1)

2.Expanded nominee clause (Box 2)

Comments for Boxes 1 to 11

The Buyers shall pay a deposit of 10 per cent of the Purchase Price specified in Box 8 (i) as security for the fulfillment

of this Agreement to the bank nominated by the Sellers in Box 8 (i) (a), with a value date no later than that specified

upon in Box 8 (i) (b) of this Agreement. Notwithstanding that the amount received may be lesser due to bank

remittance charges imposed during the normal course of transfer, such amount shall stand as due fulfillment of the

Buyers obligation to pay the deposit and be held in a joint escrow account of both the Sellers and the Buyers, which

shall be released to the Sellers as part of the Purchase Price in accordance with joint written instructions of the Sellers

and the Buyers. The Sellers are to arrange the opening of the joint escrow account latest by 2 banking days prior to the

Value Date. The Buyers, latest together with their remittance of the Deposit, are to arrange bank-to-bank confirmation

from the remitting bank to the bank specified in Box 8 (i) (a) that the Buyers, and the remitting party if different, are a

known customer of the bank and should it be required by the bank in Box 8 (i) (a), the Buyers will also arrange for the

bank-to-bank confirmation to include the confirmation by the remitting bank that they know the source of funds. Both

Sellers and Buyers shall comply with the anti-money laundering laws and regulations of the country in which the

bank(s) specified in Box 8 are located.

Any interest earned on the deposit shall accrue to the Buyers whereas any closing fee/fees charged for holding the

deposit shall be borne equally by the Sellers and the Buyers.

Clause 1: Deposit

(a) The Buyers shall pay the Balance Purchase Price specified in Box 8 (ii) in full including any extras under Clause 7

free of bank/transfer charges to Sellers’ nominated bank account at Sellers’ bank stated in Box 8 (ii) (a) upon delivery

of the Vessel. The agreed Purchase Price shall be paid for same day value within 3 full banking days, (being banking

days in the place of closing and in the country of the Purchase Price currency) after the Sellers tender the written

notice* of actual readiness of the Vessel for delivery in accordance with Clause 5 (b).

(b) The Buyers may delay to take delivery of the Vessel for up to a maximum of further seven (7) consecutive days

paying to the Sellers the sum specified in Box 8 (iv) per day, or part thereof, as compensation for such delay provided

that the Buyers have declared their intention to take late delivery prior to the expiry of the specified 3 full banking

days. Any such amount due shall be paid at the time and place and in the same currency as the Purchase Price and any

additional amounts due under Clause 7. If such delay exceeds seven (7) consecutive days then the Sellers shall have

the right to cancel this Agreement and claim damages for their losses incurred.

*Throughout this Agreement, a written notice is to mean a registered letter, telex, tele-fax, e-mail or other modern form

of written communication between the Sellers and the Buyers.

Clause 2: Payment

Comments for Clauses 1 & 2Objectives:

1.Certainty of payment of the deposit and the balance purchase price.

2.Clarity on the ancillary duties of sellers and buyers.

Highlights:

1.Addresses the issues arising from The Aktor.

2.Prevents technical breach (bank charges causing shortfall in deposit)

resulting in contract being terminated.

3.Avoids issues that arise when sellers insist that the whole purchase price be

paid to the bank nominated by them in the payment clause (The Aktor).

4.Update to anti money laundering laws and KYC requirements.

5.Option for late delivery of vessel.

Note: The NSF requires cooperation between both parties to open a joint bank

account. Should any party have any second thoughts on the deal, this is where

the first problem starts.

THANK YOU

Overview of the Singapore Ship

Sale Form (“SSF”)

Gina Lee-Wan

Partner, Co-Head of Maritime and Aviation,

Allen & Gledhill LLP

28 November 2016

Introduction

• The Singapore Ship Sale form (“SSF”) was launched by the Singapore

Maritime Foundation on 6 January 2011 in response to Singapore and Asian

maritime communities’ call for an alternative sale form that would better serve

their needs.

• Objectives and aims were to: a) provide a more balanced starting point for

both Sellers and Buyers, b) to improve and update the existing forms and c)

to resolve and more adequately deal with issues and legalities that had

previously arisen over the course of the years with the existing sale forms.

18

Salient Features

• User-friendly

– tabular layout with boxes + substantive clauses.

• Improved Deposit and Payment Clause

– deals with the issues arising from the English case of PT

Berlian Laju Tanker TBK & Another v. Nuse Shipping Ltd

(2008) EWHC 1330 Comm (The Aktor).

• New concept of Notice of Actual Readiness

– physical readiness + legal readiness.

19

Salient Features (continued)

• Comprehensive Documentation Clause

– includes a comprehensive documentation clause – much easier

to delete than to add!

• Encumbrances

– includes a list of broad, unambiguous encumbrances which is

clear and provides certainty to all parties.

– provides buyers with the right to reject delivery in the event that

the vessel is encumbered.

• Buyers Default

– adds certainty and clarifies remedies in two scenarios: a) where

the deposit has been paid and b) where the deposit has not been

paid; balances competing interests of buyers and sellers.

20

Salient Features (continued)

• Pro-Asian Arbitration Clause

– provides for Singapore or English law and allows for Singapore arbitration – an

effective cost-saving and quality option.

• Confidentiality and Entire Agreement

– provides for a confidentiality clause, and the addition of an entire agreement

clause ensures that prior negotiations and agreements are superseded.

– Tip: may wish to also include exclusion of any applicable statutes or laws (as an

example: the Sale of Goods Act).

21

Objectives

• What are the aims and objectives of the SSF?

– concise, simple and unambiguous;

– ensures that the transaction proceeds as smoothly as

possible;

– user-friendly;

– takes into account market practice and resolves issues and

case law that have arisen over the years;

– time and cost effective; and

– minimises disputes and litigation.

22

Usage

• Certain (but not all) provisions of the SSF have been adopted

by the NSF 2012.

• Also available on the BIMCO IDEA•2 platform.

===================

Conclusion: the SSF is a well-balanced document which is user-

friendly, concise and clear, which we hope will be utilised by the

shipping community.

======================

23

Questions?

24

Thank You

Gina Lee-Wan

T +65 6890 7582

E [email protected]


One Marina Boulevard #28-00

Singapore 018989

www.allenandgledhill.com

25

Notes:

• This presentation is intended to provide general information and is not meant to be exhaustive, comprehensive or authoritative. Allen & Gledhill LLP does not

warrant its accuracy or completeness or accept any liability for any loss or damage arising from any reliance thereon.

• The information in this presentation should not be treated as a substitute for specific legal advice concerning particular situations.

26

Our Regional Network27

Singapore


One Marina Boulevard #28-00

Singapore 018989

T +65 6890 7188

F +65 6327 3800

E [email protected]

W allenandgledhill.com

Malaysia

Rahmat Lim & PartnersIn association with Allen & Gledhill LLP (Singapore)

Suite 33.01, Level 33

The Gardens North Tower

Mid Valley City, Lingkaran Syed Putra

59200 Kuala Lumpur, Malaysia

T +603 2299 3888

F +603 2287 1278

E [email protected]

W rahmatlim.com

Laos

Allen & Gledhill (Laos) Co., Ltd

Level 5, Lao Securities Exchange Building

T4 Road, Phonthanh Village, Saysettha District

Vientiane Capital, Lao PDR

T +856 21 419237 / 419247

F +856 21 419248

E [email protected]

W allenandgledhill.la

Myanmar

Allen & Gledhill (Myanmar) Co., Ltd.

No. 05-03, Union Business Centre (UBC)

Nat Mauk Road, Bo Cho Quarter

Bahan Township, Yangon, Myanmar

T +95 1 860 3385 / 3387

F +95 1 860 3382

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W allenandgledhill.com.mm

PRESENTATION BY: TAN CHIN HEE

EXECUTIVE DIRECTOR, PCL

28 November 2016

PACIFIC CARRIERS LTD

SELLING AND BUYING A VESSEL USING SSF 2011

A SHIPOWNER’S PERSPECTIVE

SPEAKER’S PROFILE

• Started Shipping career 1975 to 1980 in liner shipping with Nedlloyd and Inchcape Group.

• Pacific Carriers Ltd since 1981 to date

- 20 years in dry bulk and tanker chartering

- responsible for PCL Group’s Sale and Purchase, Marine Insurance

- Currently serving as

Executive Director of Pacific Carriers Ltd.

Director on the Board of the U K Defence Club

Committee member of Assuranceforeningen Skuld since 1994.

Councillor/Vice President Singapore Shipping Association since 2011

Chairman of the Singapore War Risk Mutual Committee

TYPES OF SALE FORMS

• NORWEGIAN SALE FORM – NSF• NSF 1966/1983/1987/1993/2012

• NIPPON SALE FORM• NIPPONSALE 1965/1971/1977/1993/1999

• SINGAPORE SHIP SALE FORM 2011

SO I WHY USE AND LIKE THE SSF 2011 ??

• Loyalty to Singapore to do my little part in promoting SINGAPORE as an International Maritime Centre

- First vessel sold using the SSF2011 MV Atlantic Cozumel MOA dated 16th Dec 2011

- 18 vessels sold to date using the SSF 2011

• The use of the Form is free of charge and is available on BIMCO Idea.2 platform

• It’s very USER FRIENDLY with the front page Box Layout which effectively provides the key terms of the S+P contract at one glance

• It is a fair and balanced contract for both Buyers and Sellers with interests of both parties well served. As parties to such contracts eventually discover and endorse the MOA as a balanced one the use of the SSF 2011 will gain further traction

• Clause 8 provides a very comprehensive list of documents to be tendered by Sellers and Buyers for a completion or closing. This does away with having to generate a list by way of an Addendum to the MOA

Inadequacies in the SSF 2011

1. The provision of a Notice Clause in the event of the vessel missing the Delivery Cancelling Date and the obligation of Buyers accepting or rejecting such revised delivery cancelling date. The SSF 2011 is silent in this regard

2. Some areas of Clause 4 – Condition On Delivery are too subjective which could give rise to disputes• Cargo spaces to be clean and free of cargo subject only to immovable residues

(line 57)

• Condition of Vessel on delivery being different than when she was inspected permits Buyers only to reject the Vessel if the difference has a substantial impact upon the Buyers’ ability to trade the vessel (lines 58/59)

3. Entire Agreement Clause (Clause 17) – Whilst there is an existing clause in SSF 2011 I feel it is inadequate

The written terms of this Agreement comprises the entire agreement between the

Buyers and the Sellers in relation to the sale and purchase of the Vessel and supersedes

all previous agreements whether oral or written between the Parties in relation thereto.

Each of the Parties acknowledges that in entering into this Agreement it has not relied

on and shall have no right or remedy in respect of any statement, representation,

assurance or warranty (whether or not made negligently) other than as is expressly set

out in this Agreement.

Any terms implied into this Agreement by any applicable statute or law are here by

excluded to the extent that such exclusion can legally be made. Nothing in this Clause

shall limit or exclude any liability for fraud."

An Encompassing Entire Agreement Clause (NSF 2012)

SSF 2011 Entire Agreement Clause

17. Entire Agreement Clause

• This Agreement and any Addenda thereto contain the entire agreement between the Sellers and the Buyers relating to the transaction which is the subject of this Agreement and all negotiations, understandings and agreements whether in writing or otherwise between the Sellers and the Buyers are superseded and/or replaced by this Agreement.

An arbitrator’s perspective

Ship Sale And Purchase

28 November 2016

Prepared for Perspectives on the use of the Singapore Ship Sale Form (SSF2011)

Presentation by Leong Kah Wah

Head, Dispute Resolution

Tel : (65) 6232 0504

Email : [email protected]

Not to be reproduced or disseminated without permission. 36

Leong Kah Wah

Head, Dispute ResolutionPartner : Shipping & International TradeRajah & Tann Singapore LLP

Qualifications

- Advocate & Solicitor, Supreme Court of Singapore, 1991

- Fellow, Chartered Institute of Arbitrators

- Fellow, Singapore Institute of Arbitrators

- Panel of Principal Mediators, Singapore Mediation Centre


Leong Kah Wah is the Head of Disputes’ Practices, and a Partner of theShipping & International Trade Practice Group, of Rajah & TannSingapore LLP. He has extensive experience dealing with a wide range ofadmiralty and shipping work. He has appeared as lead counsel innumerous cases, including 2 landmark admiralty cases, The STX Mumbai[2015] and The Bunga Melati 5 [2012]. He also successfully acted forsellers in a ship sale and purchase dispute in an SCMA arbitration lastyear. He is acknowledged as a leading individual for shipping inChambers (2004 to 2016); Asia Pacific Legal 500 (2004 - 2016); Asia LawProfiles; and Who's Who Legal.

Speaker’s Profile


Outline

• Introduction – Nature of a ship sale and purchase

• An arbitrator’s considerations in handling ship sale and purchase disputes

• Conclusion – How to avoid ship sale and purchase disputes


Nature of a ship sale and purchase

• Parties negotiate and reach an agreement (recap)

• Execution of a signed contract

- Usually standard forms: eg. Norwegian Sale Form (NSF) 87, 93,2012 ; Nippon sale form 99; Singapore Ship Sale Form 2011.

• Operation of sale and purchase in accordance with terms of contract

- Buyers to conduct inspection of the vessel, pay 10% deposit, paybalance of sale price, de-registration from the seller’s registryand registration onto buyer’s registry.

- Sellers to provide NOR regarding vessel’s delivery, warranty thatvessel is free from encumbrances, deliver the vessel “as it was” atthe time of inspection with class maintained, provide allrequired documents.


An arbitrator’s considerations in handling ship sale and purchase disputes


1. What did parties agree?

• Searching for the agreement:

- Is the agreement contained in a signed contract? (Eg. MOA)

- Is the agreement contained in other correspondence anddiscussion? (Eg. Email correspondence, recap, priornegotiation)


2. If there is a signed agreement, is there a term in the agreement dealing with the subject matter of the dispute?


• Express clauses in the contract

• Terms implied in law

- The Union Power [2013] 1 Lloyd’s Rep 509 – a term as tosatisfactory quality was implied into the MOA by virtue of s14(2)of the Sale of Goods Act.

- Terms can be implied if they are not inconsistent with theexpress terms.

• Possibility of terms being implied by binding custom and practice:The Union Power [2013] 1 Lloyd’s Rep 509


3. How should the terms of the agreement be interpreted?

• Parties frequently have contending versions of parties’ intention inrelation to interpretation of a clause in dispute

- The Rewa [2012] 1 Lloyd’s Rep 510 – Is an ISPP Certificate aninternational trading certificate for the purposes of thedocumentation clause in the MOA?

- The Griffon [2014] 1 Lloyd’s Rep 471 – Are Sellers entitled toclaim both the deposit and damages for failure to pay deposit?


• The arbitrator’s preference is usually to take an objective reading ofthe term

- Interpretation of the wording of the clause in the context of theagreement.

- Reliance on case law precedents to support particularinterpretations.


4. What kind of evidence is available to aid resolution of the dispute?


• Written evidence

- Arbitrators are definitely more progressive and open toaccepting various types of written evidence.

- In addition to usual emails, letters, and faxes, communicationsthrough Whatsapp, SMS can also be considered as evidence forthe arbitration.


• Oral evidence is less preferred

- Oftentimes contending versions of events are put forth in oralevidence of factual witnesses, eg. what was discussed during acall.

- The Tribunal would be left to choose the evidence of one witnessover another.


- Alternatively, the Tribunal will consider on whom the burden ofproof lies

• Tribunal could be left to decide against the party who bearsthe burden of proof but has no written evidence tocorroborate his oral evidence which is directly contradictedby the opponents’ oral evidence.


Conclusion

• How to avoid ship sale and purchase disputes?

- Option 1: the “run and hide” approach.

- Option 2: the “throw money” approach.

- Option 3: the : “R & T” approach – prevention of disputes bycareful documenting of ship sale and purchase agreement,ensuring clear express terms and written evidence are availablefor arbitrators to adjudicate on the disputes.

51 Not to be reproduced or disseminated without permission.

The material in this presentation is prepared for general information only and is notintended to be a full analysis of the points discussed. This presentation is also notintended to constitute, and should not be taken as, legal, tax or financial advice byRajah & Tann. The structures, transactions and illustrations which form the subject ofthis presentation may not be applicable or suitable for your specific circumstances orneeds and you should seek separate advice for your specific situation. Any referenceto any specific local law or practice has been compiled or arrived at from sourcesbelieved to be reliable and Rajah & Tann does not make any representation as to theaccuracy, reliability or completeness of such information.

Disclaimer

52 Not to be reproduced or disseminated without permission. Not to be reproduced or disseminated without permission.

BIMCO – IDEA2

Singapore Ship Sale Form Seminar

28 November 2016

Maite Bolivar Klarup

Outline

• Introduction – BIMCOs core areas

• Internet Document Editing Application - IDEA2 features

• How does IDEA2 work

• Conclusion

BIMCO’s core objective is to facilitate the commercial operations of our members by developing standard contracts and clauses, and providing quality information, advice and education.

BIMCO actively promotes the application of globally agreed regulatory instruments

Our mission

BIMCO’s core areas

Products Training Regulation Information and advice

Ships Commercial

Contracts & clauses

IDEA2

Shipping KPIs

eLearning

Live courses

Webinars

International

Regional

Environment

Safety

Security

Navigation

Chartering support

Market analysis

Credit risk

Debt recovery

Ports and cargo

databases

IDEA2 quick facts

• The industry’s No. 1 selling charter party editor

• Used by over 2,500 companies world-wide

• 120 different contract templates available

• 3,000+ contracts concluded every month

IDEA2 most used documents

Annual turnover of all of BIMCO contracts more than 30.000 finals

SUP

PLYTIM

E

These 6 froms approx. 20.000 final contracts in the past 12 months

IDEA2 key features

Microsoft Word 2010. Works on any computer running Windows or using an Apple Mac

Full access to BIMCO’s entire range of standard contracts and clauses.

Secure and authentic copies of BIMCO contracts

IDEA2EASY TO USE

SMART DOCUMENTS

IDEA2 Log in www.BIMCO.org

http://www.bimco.org/

IDEA2 creating a file - clause updates

1

2

Autofill boxes / Mini-database

Working with clauses

Share documents | Work together

Reviewing panel

IDEA2 print assist

Print the document

IDEA2 Price schemeidea free

BIMCO Member

Non-Member

Start-up fee Free Euro 150

Price per print count Euro 10 Euro 15

Additional email addresses, per 5 email addresses Euro 50 Euro 50

idea standard

Start-up fee Free Euro 150

Annual subscription fee Euro 200 Euro 500

Price per print count Euro 1 Euro 2

Additional email addresses, per 5 email addresses Euro 50 Euro 50

IDEA2 easy to use

Conclusion

BIMCO Contracts - Online. Anywhere. Anytime.

• one-stop digital shop for all the standard maritime contracts and clauses• secure and authentic copies of BIMCO contracts• don’t spend valuable time proof checking• access for non-BIMCO member as well• runs on any computer • whether you produce just one or two contracts a year or hundreds each month,

we have a tariff to suit your needs.

Thank you!

Contact BIMCO at

www.bimco.org

update on the singapore ship sale form (ssf 2011) · 2019. 3. 11. · 11.25 am presentation by ms...

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