Mr. AoP. What a pleasant surprise. Glad you are still in the game. Amazing when you say para 2 is still the same. How is it that so simple a statement can mean something else after all. Also odd that, as it is a legal document, no union has challenged the interpretation. There should not be ambiguity in legal limitation documents.
As for competative with continental cousins; no competition has ever been won based on slave/cheap labour. There is far more to it than that. Oddly, the continental outfits I've worked for had much more draconian FTL's than CAP 371, and they used them, but they still went bust.