He also alleges that FCA CEO Sergio Marchionne – then chief of Chrysler LLC – told him to prepare a new plan for Australia not bound by any of the rules of “the old Chrysler” and that he (Marchionne) had said he did not care how he did it.
“Marchionne said to plan for what was possible without the constraints imposed by Detroit,” the defence document to the FCA statement of claim says.
“Further, at the end of the meeting in Shanghai in 2010 that John Elkann (FCA chairman and grandson and heir to long-time Fiat boss Gianni Agnelli) told Campbell that he had been given a big opportunity without the constraints normally imposed and that he should make sure he did not waste the chance,” the document says.
Mr Campbell is being sued for damages by FCA Australia over allegations that he misused $30 million in company funds when he was company CEO between October 2010 and May 2013.
He also stands accused of breaches of contracts and conflicts of interests during the same period.
The civil case is set to return to the Federal Court on September 18 for a directions hearing in front of Justice Beach.
The 48-page defence document, filed by Mr Campbell’s lawyer Samuel Bond on Wednesday (July 29) and subsequently obtained by GoAuto, serves as Mr Campbell’ s rebuttal of accusations by FCA Australia.
The document states that in a conversation between Mr Campbell and his superiors in Shanghai in October 2010, he was told Chrysler LLC would pull out of right-hand-drive vehicle production within three years if he did not increase sales to 20,000 units a year in Australia.
Elsewhere in the document, Mr Campbell claims Chrysler executive Mike Manley – now global president and CEO of Jeep – told Mr Campbell that FCA Australia was “not going fast enough and needed to match Kia and Volkswagen in (sales) volume”.
Mr Campbell allegedly told Mr Manley that Kia and Volkswagen had more dealerships than FCA, which was trying to expand its dealership network.
Mr Manley is alleged to have replied: “I’m sick of this excuse. Get 100 dealerships by June next year or you are out of a job. I don’t care how you do it. I don’t care how much it costs, just get it done. All your marketing is being wasted if you do not have the dealer network to deliver on it.”
Mr Campbell outlines in the document how a Brighton dealership in Melbourne, owned by Ross Cruickshank, needed to be replaced in “the best interests of FCA”.
He said Mr Cruickshank told him “I want out”, but that he, Cruickshank, wanted a payment of $600,000 for goodwill on the condition that he would give up the Brighton franchise.
Mr Campbell said no incoming dealer wishing to take over the Brighton dealership would have been prepared to pay $600,000 for goodwill.
In the document, Mr Campbell outlines how FCA reimbursed the incoming dealer, Brighton Investments, for the $600,000 paid to Mr Cruickshank as an inducement to establish an Oakleigh dealership as well as others in Mentone and Brighton.
However, Brighton Investments had got into financial difficulty because it had tried to expand too fast.
He outlined three more payments – for $230,000, $460,000 and $1.2 million – to Brighton Investments, all of which Brighton Investments “either was already entitled or was likely to become entitled”.
Mr Campbell says when FCA was looking for suitable premises for its NSW offices, he told Mike Manley and John Kett – FCA’s Asia-Pacific chief who left the company last week – that his (Campbell’s) private superannuation fund had bought a Strathfield premises in Sydney and that FCA would enter into 10 consecutive one-year leases for it.
He said that Mr Manley had said that provided Veronica Johns – a fellow FCA Australia executive and successor to Mr Campbell as FCA Australia CEO – thought the premises suitable, he did not see any problem.
In its suit, FCA Australia claims Mr Campbell was not authorised to enter into the Strathfield sub-lease, and that the premises were not suitable for the office purpose, having been zoned industrial.
By Ron Hammerton