Case Study: Business Risks and Human Rights Reputational Risks in Wilmar’S Palm Supply Chain

Case Study: Business Risks and Human Rights Reputational Risks in Wilmar’s Palm Supply Chain

engagethechain.org BUSINESS RISKS AND HUMAN RIGHTS

Executive Summary

Wilmar International (SGX:F34) is one of the largest listed palm plantation companies on the Singapore Exchange and its public stock is held by major U.S. institutional investors, including mutual funds, pensions, endowments and foundations. Over the past several years, the company has been implicated in scandals involving violations of workers’ rights and land disputes in its Indonesian palm oil business. Some of these claims include: An investigative report released in November 2016 organizations and other land issues. These claims by Amnesty International alleged significant human exposed Wilmar to a variety of business risks, including rights abuses, including child labor and forced labor, litigation and disruption to operations. Wilmar incurred on Wilmar’s own plantations as well as within its supply legal costs in its defense against complaints and chain. Coverage of the report included widespread expenses for development and implementation of its media attention and articles by outlets such as Reuters, internal preventative programs. The Guardian, Mongabay, and Sustainable Brands. Due to its strategic position within the global palm oil The coverage by advocacy media exposed Wilmar to supply chain and its role as the world’s largest trader reputational risk due to inadequate supplier policies of palm oil, Wilmar has an important role to play in and deficient supplier monitoring and verification. advancing reforms on social issues in the wider palm The company responded by undertaking internal oil industry by demonstrating compliance with human reviews and external collaborations for assessments rights norms committed by its NDPE (No Deforestation, of labor practices in upstream operations in 2017. No Peat, No Exploitation) policy within both its own The historical insuﬃciency of land rights processes operations and those of third-party suppliers. has resulted in claims of land grabs by civil society

WILMAR INTERNATIONAL (SJX) SOCIAL ISSUES TIMELINE

Wilmar joins collaboration Amnesty with Business International for Social releases Wilmar Responsibility WORKING “The Great announces (BSR) to CONDITIONS Palm Oil collaboration improve Scandal” with Verité to working Forest Peoples Wilmar investigative improve labor conditions and Programm launches Company report practices launches Child releases Wilmar online develops and Protection investigative announces dashboard implements Policy report on NDPE Policy featuring the human rights Certification Aggregator abuses and Progress, Refinery land conflicts Traceability Transformation The RSPO declares in Wilmar and Supply (ART) program community of that Wilmar Group Chain, and developed Wilmar’s Nagari Kapa took over Kapa plantation Grievance with The appeal on files a lands without LAND Procedure Forest Trust RSPO decision RIGHTS complaint consent in granted by the against Wilmar violation of Complaint for mis- RSPO Panel appropriation standards and of land Indonesian law

NOVEMBER DECEMBER OCTOBER JANUARY AUGUST NOVEMBER FEBRUARY APRIL NOVEMBER 2011 2013 2014 2015 2015 2016 2017 2017 2017 Note: Timeline is not representative of all working conditions and land conflict issues, nor is it representative of all actions to remedy these issues taken by Wilmar. All the land rights cases involving Wilmar were acquired before the 2007 establishment of RSPO Principles and Criteria, which includes the FPIC methodology. Page 2 BUSINESS RISKS AND HUMAN RIGHTS

Wilmar International

Founded in 1991, Wilmar International Limited is one of the largest publicly listed palm plantations 1 in the world, and the largest global processor and merchandiser of palm and lauric oils. Wilmar is a vertically integrated agribusiness, with business activities ranging from cultivation, to reﬁning, to manufacturing of consumer products. While palm oil-related businesses account for a signiﬁcant portion of Wilmar’s revenue, its businesses extend into oilseeds, grains, and sugar.

Wilmar is one of the world’s biggest oil palm plantation For fiscal year 2017, the company posted an 5.9 percent owners, with a total planted area of 228,443 hectares increase in annual revenue to US$43.85 billion. Its (as of 30 Sep 2018), 66 percent of which is in Indonesia tropical oils division, which comprises the company’s and 25 percent in East Malaysia. 2 It has over 500 entire value chain of palm oil assets, generated over manufacturing plants, distributes to more than 50 $18 billion in revenue in fiscal year 2017. 5 Wilmar lists countries and employs about 90,000 people worldwide. 3 19 key subsidiaries, eight of which are palm oil cultivation, milling or refining operations in Indonesia. The company has certifications from the four major sustainable palm organizations: International Wilmar benefits from optimistic growth outlooks for Sustainability & Carbon Certification (ISSC), Indonesian the global demand palm oil in both food and non-food Sustainable Palm Oil (ISPO), Malaysian Sustainable applications. Wilmar’s stock would mostly be found Palm Oil (MSPO) and the Roundtable for Sustainable in sector- and region-specific portfolios. Archer Daniels Palm Oil (RSPO). As of 2017, Wilmar reported 28 mills Midland (ADM) has been gradually increasing its and more than 80 percent of planted area across ownership of Wilmar and is reported as having a Malaysia, Indonesia and Ghana being RSPO-certified. 4 24.89 percent interest in the company as of March 13, 2018. 6 ADM views its ownership of Wilmar as a key part of its Asia strategy. 7

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Social Issues in Palm Oil

Civil society actors have identiﬁed human rights violations and land disputes within Wilmar’s extended palm supply chain.

1. Working Conditions Many companies within the palm oil Health and safety issues. Amnesty International industry have been implicated in researchers found evidence that Wilmar suppliers were violations of workers’ rights for decades, using a highly toxic, paraquat-based herbicide called as advocacy media and civil society actors Gramoxone. Workers who spray and prepare the together have raised awareness on these issues. chemicals and fertilizers were not provided sufficient protective gear and have experienced regular In December 2016, Amnesty International published inhalation and contact-based poisoning effects, The Great Palm Oil Scandal highlighting labor rights including fingernails rotting out. violations in Indonesia’s palm oil industry, based on its investig ation of Wilmar’s su pply chain. Amnesty Gender discrimination. Researchers found that women International conducted 120 interviews with workers were routinely denied permanent employment status at Wilmar’s PT Milano and PT Daya Labuhan Indah and benefits, including health insurance and pensions. subsidiaries and unaffiliated Wilmar suppliers for the Women were hired as casual day laborers while exte nsive, more than 10 0 pag e report. A sample of the men were hired as harvesters with permanent labor ri ghts viola tion s u ncovered inclu de: employment contracts.

Exploitation via wages and production targets. As detailed in the Risk Mitigation section, Wilmar has Researchers found that companies had complex taken steps to address the abuses published in the systems to calculate workers’ wages based on time Amnesty International report. Wilmar was also subject worked and output per worker. Companies set output to numerous additional special independent assessments targets and, in at least one example, harvest er salaries in 2017 under the RSPO and ISCC certification schemes would be reduced if production targets were not met. arising from the Amnesty International report. These Production targets were static regardless of season, assessments have found no non-compliance in relation c rop y ield, and number of h our s wor ke d. to the RSPO Principles and Criteria, which many of the a llegations refer to. 8 However, NGO reports and recent Forced labor. The large number of penalties (which can in dependent investigations into labor violations by the be applied at the employer’s discretion) and the lack of RSPO Complaints Panel have revealed widespread illegal clarity and transparency on deductions from wages make labor abuses on RSPO-certified plantations, indicating workers vulnerable to pressure from their supervisors, that regular RSPO audits are not properly detecting or who can extract work under the threat of loss of pay or reporting on labor non-compliance. 9 loss of employment. The ILO Committee of Experts has said these kinds of practices amount to forced labor.

Child labor. The investigation uncovered instances of children assisting parents on plantations to help meet production targets, sometimes by carrying heavy loads of palm fruit or by transporting fruit via wheelbarrows. In some cases, children as young as eight dropped out of school to help their parents.

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BUSINESS RISKS AND HUMAN RIGHTS SOCIAL ISSUES IN PALM OIL

2. Land rights Wilmar International has experienced Another land dispute involves the Kapa community of land disputes with local communities West Sumatra, who filed a complaint with the RSPO in over several of its sites, which have been October 2014. The complaint alleges that Wilmar failed described as land grabs by activists. to obtain Free, Prior and Informed Consent (FPIC) with Forest Peoples Programme (FPP) has been one of the the local community before establishing a plantation predominant critics of Wilmar for its land acquisition on Kapa land, in violation of both RSPO Indonesian practices, including its investigative report on the standards. 14 After a two-year process leading up to Jambi province of Indonesia in November 2011. 10 their ruling, the RSPO found that Wilmar International had taken over Kapa lands without their consent. 15 In November 2012, FPP reported that a Wilmar subsidiary, In April 2017, the RSPO Complaints Panel agreed to PT Mustika Sembuluh, was slow in settling ongoing land review the decision on the case, 16 but the case was disputes in Central Kalimantan. 11 In October 2013, FPP eventually settled later in the year with consensus to highlighted conflict with local communities in Southern implement processes determined by the Action Plan Merauke, West Papua. FPP claimed that Wilmar of the initial decision, including participatory mapping subsidiaries co-opted tribal leaders and convinced and stakeholder engagement. 17 This complaint case has villagers to sell their lands. 12 According to a report issued been closed as of September 2018. 18 As detailed later in by Profundo, FPP claimed the subsidiary “did not get the Risk Mitigation section, land rights issues are now consent to land conversion from some members of recorded in the company’s Grievance Procedure. 19 the community, and the community gave their consent to land conversion based on deceptive information and restricted freedom of choice.” 13 Wilmar has not proceeded with plantations in West Papua.

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Risks

Wilmar International is exposed to several business risks arising from issues related to land rights and labor conditions. The next section highlights some of these risks by drawing upon the framework established in Engage the Chain .

(which was ruled in Wilmar’s favor at the Indonesian 1. Operational risk Supreme Court), but it also risks scrutiny from RSPO Land conflict is an issue that affects all and other certification organizations if reputable and plantation companies and therefore can egregious claims against it continue to arise. present material business risk. If production Additionally, findings of forced labor in Wilmar’s is compromised when injunctions are extended supply chain could leave the company open imposed, these issues can be considered operational risks. to litigation if imported goods were proven to have While it hasn’t happened with Wilmar, there is a possibility been produced using forced labor. 24 that local governments could put a halt to operations. As noted by Rights and Resources, an NGO based out of Washington, D.C., “Insecure [land] rights also threaten 3. Reputational risk companies’ bottom lines and long-term financial success. Issues related to working conditions and Disputes over land between companies and local land conflict both pose reputational risk communities frequently lead to conflict, work stoppages, for Wilmar when left unattended. and stalled investments.” 20 Reputational risk is the risk that adverse publicity regarding [a company’s] business practices The impact of land conflicts can be long-term in nature, and associations, whether accurate or not, will cause as more than half of 288 land-related conflicts reported a loss of confidence in the integrity of the institution. 25 after 2001 in the Tenure and Investment in Southeast Asia For the issues highlighted previously, the company report between companies and communities were still faced significant reputational risk due to media and 21 unresolved in 2017. This study also cites that these advocacy group scrutiny on its supply chain. Dozens conflicts are more difficult to resolve in Southeast Asia of articles by media and activist organizations focusing than any other region in the world, partially due to unclear on Wilmar and abuses within its supply chain were and/or unenforced property rights. The Indonesian posted in the nine months following the release of palm oil monitoring group SawitWatch has identified the Amnesty International report in December 2017. 660 land disputes between palm oil companies and The alleged human rights abuses were covered in local communities in Indonesia — though the actual articles by leading advocacy media organizations 22 number many be higher than this. including Mongabay, One Green Planet, Eco-Business, and Sustainable Brands. 2. Litigation risk Litigation risk refers to the risk of legal 4. Market risk sanctions stemming from a company’s Wilmar’s social issues present market risks failure, or alleged failure, to comply with on two levels. First, with each major laws, regulations, rules, related self- allegation of human rights abuses or illegal regulatory organization standards, and codes of land acquisition, relationships with major 23 conduct. Wilmar International not only incurred more buyers may be adversely affected. As the Amnesty than three years’ worth of legal counsel costs in its International report pointed out, major brands are clients defense against the Kapa community land disputes

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of Wilmar — including Colgate-Palmolive, Kellogg, Nestlé, issue of deforestation cases, including the current Leuser Unilever, and Procter & Gamble. A number of other major ecosystem situation, exposes Wilmar to market risk. 27 brands also source from Wilmar including PepsiCo, Mars, Second, as Wilmar continues to peg its financing Mondelez, General Mills, and Johnson & Johnson. 26 As to sustainability metrics, the most favorable interest each of these brands has their own sustainable supply rate may not be achieved if the company fails to chain policies and are members of sustainable palm achieve certain targets. These sustainable financing organizations, they run their own reputational risk if commitments include facilities with ING, DBS, and Wilmar as supplier violates their standards. The resulting OCBC Bank, and the announcement for each of these market risk is that these brands could terminate, reduce garnered coverage by the broad financial press, such or suspend supply contracts with Wilmar. Importantly, as Nikkei Asian Review , The Business Times , and Global land rights and labor conditions are not the only source Trade Review . of business risk shared with their customers. The parallel

Risk Mitigation

Wilmar has made advances in addressing social issues within its supply chain. Over the past several years, the company has sought to address working conditions and land conﬂict issues with internal reviews and external collaborations with several consultants and NGOs, including TFT, BSR and Verité. (Details can be found in Wilmar’s two-year progress report on labor practices ).

Engagement with stakeholders and implementation of Trust (TFT), is a combination of site evaluation and new processes mitigated imminent reputational risk. In education for suppliers. The mills are prioritized for January 2015, Wilmar launched an online transparency an audit based on spatial and non-spatial data. Spatial tool which was hailed as an important step towards factors using GIS include legally protected areas, key transparency at its time by civil society organizations. biodiversity areas, and peat; non-spatial factors include The Dashboard featured include information on mills that have their own NDPE policy, RSPO certification, Certification Progress, Traceability & Supply Chain, volumes, public information, and TFT assessment. as well as the Grievance Procedure. At year-end 2017, Wilmar conducted 62 assessments In its 2015 annual report, Wilmar described its Grievance in Indonesia and Malaysia. 30 The assessments were Procedure as part of risk management. The grievance then compiled into anonymized reports which were procedure “provides stakeholders with an avenue summarized and discussed at regional workshops. The to report suspected sustainability-related breaches topics of regional workshops also included “guidance on and concerns pertaining to its own operations and land-use planning, and respecting the rights of workers its suppliers.” 28 While most grievances are related and indigenous and local communities.” 31 The ability of environmental issues such as deforestation and peatland the ART program to zoom into supplier practices based clearance, the interactive dashboard enables stakeholders on regional characteristics demonstrates that Wilmar to view a list of grievance cases and their developments. recognizes how land issues impact operational costs and revenues. However, NGO and advocacy groups such In addition to the dashboard, Wilmar implemented the as Rainforest Action Network (RAN) called into question Aggregator Refinery Transformation (ART) program, the utility of the tool, identifying a lack of overall which seeks to strengthen all actors’ practices in their transparency and strong human rights approach. 32 supply chain. 29 The program, developed with The Forest

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Improving Disclosure

Although the company was an early adopter of a NDPE disclosed key performance indicators pertaining to the policy and has invested in several sustainability pilots environment as well as health and safety but did not and programs, Wilmar’s public documentation can be explicitly frame them within business risk categories. improved to allow for more eﬃcient evaluation by As a publicly traded company and dominant actor in engaged investors. For example, Wilmar’s disclosure the global palm supply chain, Wilmar is in a unique of risk can be tied more closely to sustainability issues position to lead social practices in palm oil production. like the framework established in Engage the Chain Continued engagement with stakeholders and and should align with Ceres’ Reporting Guidance for enhancements in disclosures can be expected to help Responsible Palm Oil . In its 2017 filings, the company’s Wilmar maintain and improve its value proposition disclosure structure separated its business risk among sustainable investors. discussion from its sustainability discussion. Wilmar

PALM OIL MATERIALITY MATRIX

Jurisdictional approaches/certifications ● Transparency and accountability ● Supplier/supply chain monitoring ● ● Labor conditions S

R Corporate governance/ethics E ● ● D and anti-corruption L

O Deforestation/High H

E Sustainability certification, Carbon Stock (HCS) forests, K

A water impacts, peat High Conservation Value ● T S development (HCV) area, supply chain Child protection L

A transformation

N ● ● ● R E

T Greenhouse gas emissions Community relations Pesticides and chemical usage, X

E and conflict resolution health and safety

’ Small holder inclusiveness ● R A

M ● L

I ● ● W

O Investment in community Wildlife conservation, T infrastructure fire and haze E C N A T R O P M I

Moderate Significant Priority IMPORTANCE TO WILMAR’S BUSINESS

Source: Wilmar International Limited (2018). Sustainability Report 2017 . Singapore: Wilmar International Limited.

Page 8 BUSINESS RISKS AND HUMAN RIGHTS ENDNOTES

1 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 2 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 3 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 4 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 5 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 6 Wilmar International Limited. (2018). 2017 Annual Report . Singapore: Wilmar International Limited. 7 Archer Daniels Midland. (n.d.). ADM Worldwide Asia and Pacific Rim . Retrieved from Archer Daniels Midland: https://www.adm.com/adm-worldwide/asia 8 Wilmar No Deforestation, No Peat, No Exploitation update: Q1 2017 Update, page 6, https://www.wilmar- international.com/sustainability/wp-content/uploads/2018/05/Wilmar-Sustainability-Report-2017.pdf 9 The Human Cost of Conflict Palm Oil Revisited: How PepsiCo, Banks, and the Roundtable on Sustainable Palm Oil Perpetuate Indofood’s Worker Exploitation , November 2017, https://www.ran.org/wp- content/uploads/2018/06/Human_Cost_Revisited_vWEB.pdf RSPO Complaints Decision on FELDA GLOBAL VENTURES HOLDING BERHAD (FELDA), November 2018, https://askrspo.force.com/Complaint/s/casetracker RSPO Complaints Decision on PT. PP London Sumatra Indonesia Tbk (Indofood), November 2018, https://askrspo.force.com/Complaint/s/casetracker 10 Forest Peoples Programme. Human rights abuses and land conflicts in the PT Asiatic Persada concession in Jambi. November 2011. https://www.forestpeoples.org/sites/default/files/publication/2011/11/final-report- pt-ap-nov-2011-low-res-1.pdf 11 Forest Peoples Programme. Press Release — New oil palm land grabs exposed: Asian palm oil companies run into trouble in Africa. 1 November 2012. https://www.forestpeoples.org/en/topics/palm-oil- rspo/news/2012/11/press-release-new-oil-palm-land-grabs-exposed-asian-palm-oil-compa 12 Rights and Resources. New report by FPP, Pusaka and Sawit Watch launched on World Food Day. 23 October 2013. https://rightsandresources.org/en/blog/new-report-by-fpp-pusaka-and-sawit-watch-launched-on- world-food-day/#sthash.4vMlCIVL.dpbs 13 Profundo. (2018, January 21). External Concerns on the RSPO and ISPO Certification Schemes . Retrieved from Friends of the Earth Europe: https://www.foeeurope.org/sites/default/files/eu- us_trade_deal/2018/report_profundo_rspo_ispo_external_concerns_feb2018.pdf 14 Diaz-Bastin, R. (2017, February 16). Wilmar grabbed indigenous lands in Sumatra, RSPO finds . Retrieved from Mongobay: https://news.mongabay.com/2017/02/wilmar-grabbed-indigenous-lands-in-sumatra-rspo-finds/ 15 Forest Peoples Programme. (2017, February 2). PRESS: Wilmar has violated the rights of the Kapa indigenous community of West Sumatra, concludes RSPO. Retrieved from www.forestpeoples.org: https://www.forestpeoples.org/en/palm-oil-rspo/press-release/2017/press-wilmar-has-violated-rights-kapa- indigenous-community-west 16 Wilmar International Limited. (2017 April 26). Update: Wilmar’s appeal on land conflict in West Sumatra granted by the RSPO Complaints Panel . http://www.wilmar-international.com/sustainability/wp- content/uploads/2017/04/Update-on-Wilmars-Appeal-to-the-RSPO-Complaints-Panel-26-April-2017-Final.pdf 17 RSPO. Case Tracker PT Permata Hijau Pasaman 1 (Wilmar International Ltd). https://www.rspo.org/members/complaints/status-of-complaints/view/76

Page 9 BUSINESS RISKS AND HUMAN RIGHTS ENDNOTES

18 RSPO. Case Tracker PT Permata Hijau Pasaman 1 (Wilmar International Ltd). https://askrspo.force.com/Complaint/s/case/50090000028Erz4AAC/detail 19 Direct communication from RAN — Wilmar made a commitment in November of 2018 to align their grievance procedure with the eﬀectiveness criteria for non-judicial grievance mechanisms outlined by the United Nation Guiding Principles on Business and Human Rights . 20 Ogden, B. (2018, May 31). To End Deforestation, We Must Protect Community Land Rights. Big Ideas. In Brief. by the . Retrieved from https://rightsandresources.org/en/to-end-deforestation-we-must-protect-community- land-rights/ 21 (2017). Tenure and Investment in Southeast Asia . United Kingdom: The Munden Project Ltd. trading as TMP Systems. 22 Sawit Watch. What’s Happen[ing] in the Indonesia Palm Oil Industry? September 20, 2011. http://sawitwatch.or.id/2011/09/what%E2%80%99s-happen-in-the-indonesian-palm-oil-industry-2/ 23 Modified from CEA definition. (2007). Solvency II Glossary. Brussels: CEA and Groupe Consultatif. 24 https://www.cbp.gov/trade/programs-administration/forced-labor 25 Modified from CEA definition. (2007). Solvency II Glossary. Brussels: CEA and Groupe Consultatif. 26 Mars: https://www.mars.com/global/about-us/policies-and-practices/palm-oil-policy PepsiCo: https://www.pepsico.com/sustainability/palm-oil Nestle: https://www.nestle.com/csv/raw-materials/palm-oil Mondelez: https://www.mondelezinternational.com/~/media/mondelezcorporate/uploads/downloads/supplier_list.pdf General Mills: https://www.generalmills.com/~/media/Files/Issues/PalmOil%20MasterList%20318.pdf?la=en Johnson & Johnson: https://www.jnj.com/_document?id=00000164-ed97-d1a7-a9e7-ﬀ9f7d0f0001 27 Gore-Langton, Louise. (2017, March 26) Nestlé “very concerned” over deforestation links to palm oil . Food Navigator.com. https://www.foodnavigator.com/Article/2017/03/27/Nestle-very-concerned-over- deforestation-links-to-Wilmar-palm-oil 28 Wilmar International Limited. (2016, March). Annual Report 2015 . Retrieved from Wilmar Corporate Information: https://wilmar-iframe.todayir.com/attachment/20180820150703324005316_en.pdf 29 Wilmar International Limited. (2018). Sustainability Report 2017 . Singapore: Wilmar International Limited. 30 Wilmar International Limited. (2018). Sustainability Report 2017 . Singapore: Wilmar International Limited. 31 Wilmar International Limited. (2018). Sustainability Report 2017 . Singapore: Wilmar International Limited. 32 Direct communication from RAN, December 10, 2018

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Ceres is a sustainability nonprofit organization working with the most influential investors and companies to build leadership and drive solutions throughout the economy. Through powerful networks and advocacy, Ceres tackles the world’s biggest sustainability challenges, including climate change, water scarcity and pollution, deforestation, and human rights abuses.

Support for this series was provided by the Gordon and Betty Moore Foundation as part of a conservation and financial markets collaboration among Ceres, World Wildlife Fund (WWF) and World Business Council for Sustainable Development (WBCSD).

REPORT AUTHOR

Bridget Bearden, Strooga Consulting

Ceres would like to thank those employees who provided extensive support with this project, including Julie Nash, Christie Merino, and Siobhan Collins.

We would also like to acknowledge the following individuals and organizations who shared their time and expertise to review and provide feedback on this white paper including Michael Guindon and Annabelle Dodson of ZSL SPOTT, Sharon Smith, and Robin Averbeck of Rainforest Action Network (RAN).

DISCLAIMER

Ceres reports are oﬀered to Engage the Chain subscribers and our Investor Network on Climate and Sustainability (INCRS). Ceres is not an investment adviser and makes no recommendations regarding the advisability of investing in any particular company, investment fund or other vehicle. The information used to compile this report has been collected from a number of sources believed to be accurate which are available in the public domain.

CONTACT FOR MORE INFORMATION

Siobhan Collins, [email protected] Senior Manager of Food & Capital Markets

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