Attn Ministry of Health,

I am seeking all records of The Ministry of Health's due diligence as it relates to the following COVID response measures;

What due diligence has The Ministry of Health undertaken in assessing and understanding potential risks and harmful effects (including lack of efficacy) of lock-downs, "traffic lights", and similar measures? When were such risks and harmful effects assessed? How is such due diligence ongoing?

What due diligence has The Ministry of Health undertaken in assessing and understanding potential risks and harmful effects (including lack of efficacy) of face-mask recommendations and requirements? When were such risks and harmful effects assessed? How is such due diligence ongoing?

What due diligence has The Ministry of Health undertaken in assessing and understanding potential risks and harmful effects (including lack of efficacy) of COVID inoculations for the general public; for employees in specific roles and/or industries and/or employed by certain employers; for children younger than 16; for children younger than 12? When were such risks and harmful effects assessed? How is such due diligence ongoing?

What due diligence has The Ministry of Health undertaken in assessing and understanding potential risks and harmful effects (including lack of efficacy) of the "My Vaccine Pass" system? When were such risks and harmful effects assessed? How is such due diligence ongoing?

For clarity, please define "efficacy" for each of the COVID response measures, as specified above.

To the extent that any of the due diligence, as specified above, in assessing and understanding potential risks and harmful effects (including lack of efficacy) of these COVID response measures has not been undertaken by The Ministry of Health, please explain why such due diligence has not been done.

Thank you,
ASE

Attn Ministry of Health,

• The term “due diligence” means "required carefulness" or "reasonable care" in general usage - https://en.wikipedia.org/wiki/Due_dilige...

• action that is considered reasonable for people to be expected to take in order to keep themselves or others and their property safe - https://dictionary.cambridge.org/diction...

The term "due diligence" is also used in section 44 of the Health and Safety at Work Act 2015, consistent with the use of the term in my request for information, dated 1 Feb 2022.

The term "due diligence" is also used in section 140 of the Accident Compensation Act 2001, consistent with the use of the term in my request for information, dated 1 Feb 2022.

If The Ministry of Health prefers that I propose another term, I will refer to section 157 of the Crimes Act 1961, and instead of the term "due diligence", I will ask how The Ministry of Health assessed and complied with its "duty to avoid omissions dangerous to life" while assessing and understanding potential risks and harmful effects, and how is such "duty to avoid omissions dangerous to life" ongoing, as requested on 1 Feb 2022.

As the information requested is overdue, and The Ministry of Health has only attempted to engage in word-games instead of providing a substantive response, I am now forced to file a formal complaint with The Office of the Ombudsman. I hope that The Ministry of Health can provide the requested information before The Office of the Ombudsman takes action.

Thank you,
ASE