Cloud is the owner of a small business, Highwind Pty Ltd, that manufactures reusable face masks. The face masks are sold at Shinra Supermarkets. Shinra recently introduced a policy which stated that late delivery of supplies to Shinra will result in substantial penalty fee and if this occurs too often, the supermarket will stop selling the product.

Due to the COVID 19 lockdown imposed by the Government, Cloud is experiencing difficulties delivering the face masks on time. When Cloud was late delivering the face masks, Shinra imposed a $10,000 late fee and declared the supermarket will stop selling the Highwind face masks permanently. Cloud argued the lockdown has made it difficult to deliver the products on time and that Shinra should take this into consideration. Shinra refused to negotiate with Cloud, stating the policy is final and they will make no exceptions.

Advise Cloud whether Shinra Supermarket's conducts are in breach ofs 21 of the ACL.

Please Use IRAC to answer this question.