Financial System and Corporate Governance Impacts of Passive Management
Maureen O’Brien VP Segal Marco Advisors Julian Regan SVP Segal Marco Advisors June 12, 2018
Copyright © 2018 by The Segal Group, Inc. All rights reserved. Agenda The Rise of Passive Equity Management Objectives and Uses of Passive Management Market and Financial System Implications Corporate Governance: Voting Trends Over Time By Passive Managers Examples of Votes on Key Proposals By Passive Managers Takeaways Glossary
“This the new realty of today’s stock market: Funds that track financial indexes have become a dominant force, and they can act as accelerants, adding to the market’s rise and fall” —New York Times, February 8, 2018
2 Background Passive vs. Active Investing Definitions
Many Investors use a combination of passive and active investment strategies as a means of implementing their public markets asset allocation strategy. Active Management: An investment strategy that seeks to earn a higher return than the benchmark index return by holding and trading a subset of securities in an index based on price discovery and the exercise of discretion in selecting securities. Passive Management: An investment strategy that seeks to track the returns of an index, such as the S&P 500, rather outperforming it. A passive portfolio is typically implemented by holding the securities in an index in proportion to their weight.
3 Executive Summary Financial System Impacts of Passive Management
Rise of Passive Equity Management (indexing) and Benefits The rapid rise of low cost equity indexing is helping investors implement increasingly cost effective investment programs At the same time, however, asset flows to passive management are raising questions about potential impacts on the U.S. financial system and the corporate governance movement. Impact on Capital Allocation As passive management’s share of the U.S. equity market has grown to an estimated 30% - 40%, investors and corporate boards are awakening to a market where capital flows to equity securities are almost as likely to be determined by index weights as by traditional measures of corporate performance. Financial System and Corporate Governance Concerns Against this setting, a growing number of experts and academics are raising concerns that concentration in the index fund industry, a decline in price discovery and the rise of exchange traded index funds (ETFs) are leading to concentrated control of U.S. public companies, contributing to market volatility and may lead to long-term changes in our markets.
4 Background Passive Management Response to Concerns about Market Impacts
BlackRock Estimate: Global Equity Ownership (Trillions)
$38.7
$11.9 $17.4 Index Funds Actively Managed Remaining Funds Source: Reuters, October 3, 2017 Passive Management Industry Response According to passive managers, data regarding passive management’s rising share of the U.S. equity market is inexact and may be overstated. Contrary to concerns expressed by some industry experts, passive managers believe active management will continue to play a significant role in setting equity prices. Growth in passively managed assets should create greater opportunity for active managers. Due to the fact that portfolio turnover is largely limited to rebalancing to match index weights, passive equity managers are motivated to act as long-term owners of U.S. companies.
“…the question of whether the rise of passive investing is an existential threat to capitalism remains an open one.” —Bloomberg, August 23, 2016
Note: Sample information. Not all inclusive. 5 Background Ownership of U.S. Equities
Ownership of Corporate Equities (2013) Other 8% ETFs 4% Hedge Funds 3% International Investors 14% Government Retirement Funds 8% Pension Funds (non-Public) 9% Mutual Funds 20% Households 34%
Source: Federal Reserve Board, Lionshares and Goldman Sachs Global ECS Research.
Public and private retirement funds reportedly own 17% of the U.S. equity market This does not include equities owned indirectly by public and private defined contribution plans that are held in mutual fund and other commingled investment vehicles
“The big pools of equity owners in the world today are the pension funds. They're the policemen, they're the firemen, they're the teachers, they're the civil servants…” —Gary Cohn, White House Economic Advisor, September 1, 2017
6 Background Public Equity Ownership: Active vs. Passive Management
Exhibit 1 Exhibit 2 100 Largest Public Pension Funds Public Funds: Assets (Billions) FY 2016 Average Asset Allocation
3,785 47.6%
2,466 23.2% 24.9% 4.3%
2009 2017 Public Equities Fixed Income Alternatives / Cash/Other Real Estate
Source: U.S. Census Bureau. Source: National Association of State Retirement Administrators (NASRA).
Most public pension funds utilize a combination of passive (indexed) and active investment strategies to implement their public equity allocations. Indexing benefits public funds by enabling low cost exposure to markets where active management has been challenged to generate net-of-fee returns that exceed benchmarks. Individual and institutional investors flows from active to passive equity management have increased dramatically since the financial crisis due in part to performance and fees.
7 Background Passive vs. Active Equity Management
Investment Program Roles Active Passive Strategy to achieve equity market exposure (beta) ● ● Potential to add return above benchmark (alpha) ● Lower cost ● Return objective: outperform benchmark return ● Return objective: match benchmark return ● Exposes investor to tracking error ● Limited tracking error relative to index ●
Demand for active management varies across investors depending on tolerance for tracking error, time horizon, market efficiency and return, risk and cost objectives. A recent study found that over half of global non-corporate pension funds manage 40% or more of their equities passively.
“In many ways, this stampede toward passive investing…is uncharted territory.” —New York Times, February 9, 2018
Note: Sources include BlackRock/Economist Intelligence Unit, March 2018. 8 The Rise of Passive Management Capital Flows
Net Mutual Fund Flows (Billions) 2016 (est)
(400) Active Mutual Funds Index Fund Flows 200 Index Fund ETFs 286
Source: Bloomberg.com, U.S. ETFs 2017 Outlook
By matching holdings and weights to an index (e.g. Russell 1000), passive management minimizes costs, while limiting or eliminating tracking error Public pension funds have utilized indexing to gain exposure to more efficient parts of the capital markets at a low costs for decades What is new are the trillions in asset flows from active management to traditional index funds and to index exchange traded funds (ETFs)
“Most of today’s 1,800 ETFs are less diversified, carry greater risk, and are used largely for rapid-fire trading – speculation, pure and simple.” —John C. Bogle CFA Publications, January/February 2016
9 The Rise of Passive Management Growth of Equity Index Mutual Funds
EQUITY INDEX FUNDS MARKET SHARE*
34%
16%
4% 0%
1985 1995 2005 2015
Source: CFA Publications. John C. Bogle. January/February 2016
Indexed mutual fund assets increased from $55 billion or 4% in 1995 to $4 trillion or 34% in 2015 due in part to active management performance following the crisis. A Moody’s study predicted that passively managed assets will exceed actively managed assets by 2024.
“…perhaps we shouldn’t be shocked if an investment method that encourages us to use as little discernment as possible ends up being too good to be true.” —Is Passive Investment Actively Hurting the U.S. Economy? The New Yorker, March 9, 2016
Source: Fichtner, Heemskerk and Garcia-Bernardo, Cambridge University Press, April 25, 2017. 10 The Rise of Passive Management Historical Performance
Exhibit 1 Exhibit 2 % Active Managers Underperforming U.S. Equity Active Funds Outperformance Benchmark Periods Ended 2017 February 1, 1998 - January 31, 2018
U.S. Large Cap Core U.S. Mid Cap Core U.S. Small Cap Core 60%
91.1% 85.0% 86.3% 88.8% 84.2% 80.5%
63.0% 32% 44.4% 47.7%
5 Yr 3 Yr 1 Yr Down Markets Up Markets
Source: SPIVA Scorecard Source: Morningstar, February 28, 2018
In the wake of the global financial crisis, most active equity managers have been challenged to outperform their benchmark index amid rising markets (Exhibit 1). Proponents of active management and industry research supports the case that active management performs better in down markets (Exhibit 2).
11 The Rise of Passive Management Reasons for Active Manager Underperformance
CFA Survey Reasons for Active Manager Underperformance
Active managers' lack of opinion diverstity 5% Lack of thorough analytical due diligence 5% Other 10% Concentration of top performing stocks 10% Active managers' short-termism 13% Managers cannnot compete with market intellegence 15% Benchmark, stylebox and tracking error constraints 18% Higher Expenses of Active Management 24%
Sources: CFA Institute, Jason Voss, CFA, October 2015
Reasons for recent active manager underperformance include fees, market efficiency, low interest rates, stock price correlations driven by macroeconomic factors (e.g. monetary policy) and benchmark constraints, among other reasons. According to an October 2015 CFA publication survey, the top reason for active managers’ underperformance was higher fees relative to passive (see above).
12 The Rise of Passive Management Investment Management Fees
Exhibit 1 Exhibit 2 Mutual Funds Hypothetical Management Fees (%): Average Expense Ratio: 2016 Active vs. Passive
Passive Equity Mutual Funds 0.09% Passive U.S. Large Cap 0.06% Value Manager (sample)
Active U.S. Large Cap Value Active Equity Mutual Funds 0.82% 0.50% Manage (sample)
Source: Investment Company Institute Sample. For illustrative purposes only.
By constructing a portfolio that matches or replicates index holdings, passive management provides market exposure at a fraction of the cost of active management (Exhibits 1 and 2). In contrast to passive managers, active managers engage in price discovery, analyzing factors such as balance sheets, earnings growth, strength of management, discounted cash flows, dividend yields, debt coverage ratios and other inputs to support portfolio decisions. Price discovery requires investment manager skill sets and resources and plays an important role in determining the allocation of capital through financial markets and the economy.
13 The Rise of Passive Management Passive vs. Active Equity Ownership
Exhibit 1 Exhibit 2 Passive Ownership of Mutual Fund Inflows / (Outflows) U.S. Equity Funds Billions: 2016
428.7 2017 37%
(285.2) 2009 19%
Passive Funds Active Funds
Source: Reuters, Bank of America, October 3, 2017 Source: Reuters, BlackRock, October 3, 2017
A Bank of America report found that index funds’ ownership of the U.S. equity market nearly doubled between 2009 and 2017 from 19% to 37% (Exhibit 1) In 2016, mutual fund investors added $428.7 billion to passive (indexed) funds and withdrew $285.2 billion from active funds (Exhibit 2). A Moody’s study predicted that passively managed assets will exceed actively managed assets by 2024
“By design passive investors, passive funds invest in all securities included in the index they track…A higher share of passive investors could therefore weaken market discipline and alter the incentives of corporate and sovereign issuers to act in the interest of investors.” — BIS Quarterly Review, March 2018
14 Market and Financial System Impacts Largest Managers of Indexed Assets
The Largest Managers of Indexed Assets June 30, 2017 ($ Millions)
3,682,536 3,301,070
1,934,329
Black Rock Vanguard SSgA
Source: Pensions & Investments, October 2, 2017
The index fund industry is highly concentrated among three firms, BlackRock, State Street Global Advisors and Vanguard, who reportedly manage approximately 80% of indexed assets Due to concentration of market share among the top three indexers, these firms (the “big three”) are now collectively the largest owners at 40% of U.S. public companies The “big three” collectively are reportedly the largest owner of 90% of S&P 500 companies.
“...what may be good for investors individually, may not be good for the economy and the market as a whole.” —Fortune, December 30, 2015
15 Market and Financial System Impacts Asset Flows to Index Fund ETFs
Exhibit 1 Exhibit 2 Global ETF Assets Market Share of Global ETFs (Trillions) Passive Funds Active Funds
4.569 86% 78% 3.396 69%
31% 14% 22% December 2016 November 2017 2011 2016 2022E
Source: MarketWatch, September 27, 2017 Source: Ernst & Young, Global ETF Research 2017
Global ETF assets grew by over $1.1 trillion or 34% in less than a year (Exhibit 1). Index funds’ share of Global ETFs is expected to grow to 31% by 2022 (Exhibit 2).
“Exchange-traded funds are leading a passive revolution, as investors dump active mutual funds and pile into index funds and ETFs.” —Bloomberg.com, US ETFs 2017 Outlook
Source: Fichtner, Heemskerk and Garcia-Bernardo, Cambridge University Press, April 25, 2017. 16 Market and Financial System Impacts Largest Managers of Indexed Assets and ETFs
Exhibit 1 Exhibit 2 The Largest Managers of Indexed Assets U.S. – Listed ETF Assets June 30, 2017 ($ Millions) U.S. Market Share (June 2017) $ Billion % of Total 3,682,536 3,301,070 BlackRock 1,176 39% Vanguard 734 25% 1,934,329 State Street 540 18% Top 3 Total 2,652 82% Black Rock Vanguard SSgA
Source: Pensions & Investments, October 2, 2017 Source: Forbes, ETF.Com, August 24, 2017
The trend in asset flows to passive management raises debate about broader market tradeoffs between active and passive management that extent beyond investor impacts. Some industry experts are concerned that continued growth in indexing may contribute to a self-perpetuating market bubble and/or heightened volatility if carried to an extreme Concentrated ownership among index fund managers, where three firms control approximately 80% - 90% of the market, also raises concerns about impacts to corporate governance The three firms also reportedly manage 82% of U.S. exchange traded funds (ETFs).
“The last time we had this this degree of concentrated financial power was in the Morgan days.” — Edward Rock, NYU School of Law
17 Market and Financial System Impacts The Role of Price Discovery
Passive Management and Price Discovery Some experts believe the rise of indexing may result in stocks moving up and down in tandem more frequently, diminishing the market’s role in allocating capital effectively across securities. Other publications have raised concerns about indexing’s impact on competition, since passive equity managers tend to own tend to own more than one company in an industry. Rising cash flows into stocks based on market capitalization only, rather than strength of management and innovative ideas, may misallocate capital to the detriment of the economy.
“Only 77% of the average S&P component’s shares trade on fundamentals now, compared with 95% a decade ago.” — MarketWatch, September 27, 2017
Source: Fichtner, Heemskerk and Garcia-Bernardo, Cambridge University Press, April 25, 2017. 18 Market and Financial System Impacts Risk and Volatility
Concerns about Market Volatility Index fund ETFs are increasingly used for active trading strategies that have potential to exaggerate market lows and highs during periods of heightened buying and selling. Exchange traded index funds reportedly accounted for 38% of total equity trading on some days during the week of February 5, 2018. Firms have claimed that flows to passive management may contribute a self-perpetuating market bubble, since capital is allocated indiscriminately, rather than based on fundamentals.
“This week, as markets shuddered, exchange-traded index funds were responsible for 38% of total stock trading….” —New York Times, February 9, 2016
Source: Fichtner, Heemskerk and Garcia-Bernardo, Cambridge University Press, April 25, 2017. 19 Corporate Governance Impacts Voting Record
Percentage of Proxy Votes in Favor
Management Proposals 2017 Shareholder Proposals 2017 Management Proposals 2016 Shareholder Proposals 2016
96% 96% 97% 97% 92% 92%
64% 64%
34% 30% 30% 30%
20% 22% 19% 16% BlackRock State Street Global Advisers Vanguard Segal Marco
Source: Fund Votes.com 20 Corporate Governance Impacts Voting Records
2017 AFL-CIO Key Vote Survey BlackRock: 9 of 29 = 31% State Street Global Advisors: 13 of 27 = 48% Vanguard: 10 of 29 = 34% Segal Marco: 29 of 29 = 100%
2016 AFL-CIO Key Vote Survey BlackRock: 7 of 31= 23% State Street Global Advisors: 11 of 32 = 34% Vanguard: 8 of 32 = 25% Segal Marco: 32 of 32 = 100%
21 Corporate Governance Impacts Voting Records
2017 NCPERS Key Vote Survey BlackRock: 3 of 9 = 33% State Street Global Advisors: 3 of 9 = 33% Vanguard: 4 of 9 = 44% Segal Marco: 9 of 9 = 100%
22 Corporate Governance Impacts 2017 Wells Fargo Board of Directors Phony-accounts scandal in September: 2M fake accounts 5,300 people fired for ethics violations, board told of only 230 Division head ran group like a sales organization, not a financial institution Company paid $185M in fines Claw-backs on CEO ($69M) and former head of community banking ($66M). Neither is currently employed at Wells Fargo Date: April 25, 2017 Result: Four director nominees received less than 60% support
23 Corporate Governance Impacts Votes Against Wells Fargo Board Members
Segal Marco John S. Chen Lloyd H. Dean Enrique Hernandez, Jr. BlackRock Cynthia H. Milligan Lloyd H. Dean Federico F. Peña Elizabeth A. Duke Stephen W. Sanger James H. Quigley Susan G. Swenson John D. Baker II Enrique Hernandez, Jr. Cynthia H. Milligan Elizabeth A. Duke Federico F. Pena Stephen W. Sanger Donald M. James Karen B. Peetz James H. Quigley SSGA Vanguard Ronald L. Sargent Timothy J. Sloan Suzanne M. Vautrinot
24 Corporate Governance Impacts Pace of turnover on Wells Fargo Board
2017 2018
John D. Baker II John S. Chen Lloyd H. Dean Elizabeth A. Duke Enrique Hernandez, Jr. Donald M. James Celeste Clark Cynthia H. Milligan Karen B. Peetz Theodore Craver Jr. Federico F. Peña James H. Quigley Maria Morris Stephen W. Sanger Ronald L. Sargent Juan Pujadas Susan G. Swenson Timothy J. Sloan Suzanne M. Vautrinot
2017 Resignations: 7 2018 New Directors: 4
25 Corporate Governance Impacts 2018 Ongoing Corporate Culture Concerns
Proposal: Report on Incentive Pay and Risks of Material Losses Proponent: New York State Common Retirement Fund Meeting date: April 24 Vote result: 21.7% in favor Segal Marco vote: FOR Sept. 2016: phony-accounts scandal 2M fake accounts Company paid $185M in fines Claw-backs on CEO ($69M) and former head of community banking ($66M) July 2017: Collateral protection insurance scandal 570,000 customers overcharged for auto insurance $80 million paid in remediation to customers
“Many witnesses believed that incentive compensation plans overly emphasized sales performance, and many complained to Community Bank leadership that incentive plan goals were too high, too focused on sales and led to bad behavior.” —April 2017 Report
26 Corporate Governance Impacts Fake News at Facebook and Alphabet
Sponsor: Arjuna Capital Dates: Facebook June 1, 2017 Alphabet June 7, 2017 Segal Marco Vote Recommendation: FOR Proposal: Issue a report reviewing the impact of current fake news flows and management systems on the democratic process, free speech, and a cohesive society, as well as reputational and operational risk from potential public policy developments
BlackRock SSGA Vanguard
27 Corporate Governance Impacts McDonald’s Franchise Director
Sponsor: Segal Marco Proposal: Allow franchisees the opportunity to elect a board representative Segal Marco Vote Recommendation: FOR Date: May 24, 2017 McDonald’s aims for 95% of its stores to be franchise-owned (up from 85% now). It is passing on significant costs to the franchisees and has no representative with authority to convey challenges to the Board.
BlackRock SSGA Vanguard
28 Corporate Governance Impacts Eliminate Dual Class Stock at Swift Transportation
Sponsor: The International Brotherhood of Teamsters General Fund Proposal: Develop a plan for recapitalization to result in one vote per share for all outstanding common stock Segal Marco Vote Recommendation: FOR Date: May 24, 2017 CEO owns a minority of shares but retains majority voting power IRRC Institute 2016: companies with dual-class capital structures underperformed non-controlled companies over three-year, five-year, and ten-year periods.
BlackRock SSGA Vanguard
29 Corporate Governance Impacts CEO Target Pay at SL Green Realty Corp.
Sponsor: Trowel Trades S&P 500 Say-on-Pay Investor Working Group Public Companies that agreed to policy: Fund Participants: City of Philadelphia Public Employees Retirement System Connecticut Retirement Plans and Trust Funds Firefighters’ Pension System of Kansas City, Missouri, Trust Miami Firefighters’ Relief and Pension Fund New York City Pension Funds New York State Comptroller’s Office Proposal: Consider pay throughout the firm when setting CEO pay Segal Marco Vote Recommendation: FOR Date: June 1, 2017
BlackRock SSGA Vanguard
30 Corporate Governance Impacts Lobbying Disclosure at Chevron
Sponsor: The City of Philadelphia Public Employees Retirement System Proposal: Political Spending Disclosure Segal Marco Vote Recommendation: FOR Date: May 31, 2017 Consistent vote support year over year has led to incremental improvements in disclosure: – Board Oversight of political spending – Federal lobbying disclosure (2014, 2015): $15M – Global donations in 2016 (non-U.S.): $12M Gaps in disclosure however remain
BlackRock SSGA Vanguard
31 Corporate Governance Impacts Board Diversity at Cognex Corporation Sponsor: The City of Philadelphia Public Employees Retirement System Proposal: Rooney Rule—make sure nominee pool is diverse Segal Marco Vote Recommendation: FOR Date: April 27, 2017 Result: 62% McKinsey & Company 2015: companies in the top quartile for gender or racial and ethnic diversity tend to report financial returns above their national industry medians. Credit Suisse 2016: Greater gender diversity in companies’ management coincides with improved corporate financial performance and higher stock market valuations.
BlackRock SSGA
Vanguard
32 Corporate Governance Impacts Declassify the Board of Directors of Tesla
Sponsor: Connecticut Retirement Plans and Trust Fund Proposal: Every director subject to shareholder vote each year Segal Marco Vote Recommendation: FOR Date: May 31, 2017 A 2004 Harvard study by Lucian Bebchuk and Alma Cohen: staggered boards are associated with a lower firm value (as measured by Tobin’s Q) and found evidence that staggered boards may contribute to, not merely reflect, that lower value. Board plagued by conflicts of interest; entrenchment concerns Tesla founder and CEO Elon Musk is also Tesla’s board chair. The lead independent director of Tesla’s board, Antonio Gracias, serves on the board of SpaceX, also led by Musk, and served on the board of SolarCity, another Musk-founded firm that was recently acquired by Tesla. Gracias is the CEO and majority owner of a limited partnership in which both Musk and his brother are limited partners.
BlackRock SSGA Vanguard
33 Corporate Governance Impacts Proxy Access at IBM
Sponsor: New York City Pension Funds Proposal: Allow shareholders with a 3% stake held for 3 years to nominate a candidate to the board. Segal Marco Vote Recommendation: FOR Date: April 27, 2017 Result: 59.4% Since 2014 half of the S&P500 CFA Institute found proxy access would: has adopted proxy access, 342 • benefit both the markets and corporate companies in total. boardrooms, with little cost or disruption. • has the potential to raise overall US market capitalization by up to $140.3 billion if BlackRock adopted market-wide. SSGA Vanguard
34 Corporate Governance Impacts 2018 NCPERS Key Proxy Votes
Executive Compensation Telsa’s $2.3B grant to founder Elon Must TJX Clawback Policy following investigation into working conditions of port truckers Diversity First Hawaii shareholder proposal on the Rooney Rule Opioids Johnson & Johnson, McKesson shareholder proposal on legal exclusions Cardinal Health shareholder proposal on opioid risk report Corporate Governance Wells Fargo shareholder proposal on unintended consequences of incentive pay Facebook governance on contents Marriott International majority voting standard Activist Investing At Newell Brands, Starboard Value vs. Carl Ichan
35 Corporate Governance Impacts Workforce Diversity and Pay Parity Votes
2015 Cumulative 2016 Cumulative 2017 Cumulative Abstain Against For
34 277 527 1,755 590 1,522
3,182 6,297 13,278
Total: 3,806 Total: 8,096 Total: 15,561
36 Corporate Governance Impacts Workforce Diversity and Pay Parity Votes
2015 BlackRock 2016 BlackRock 2017 BlackRock Against For
24 119 968
1,675 3,626 6,927 Total: 1,699 Total: 3,745 Total: 7,895
37 Corporate Governance Impacts Workforce Diversity and Pay Parity Votes
2015 SSGA 2016 SSGA 2017 SSGA Abstain Against For
10 135
44 158 330 527
456 1,087 1,896
Total: 510 Total: 1,575 Total: 2,558
38 Corporate Governance Impacts Workforce Diversity and Pay Parity Votes
2015 Vanguard 2016 Vanguard 2017 Vanguard
Abstain Against For
652 546 1,192 1,584 1,051
4,456 Total: 1,597 Total: 2,776 Total: 5,108
39 Corporate Governance Impacts Workforce Diversity and Pay Parity High Votes
Shareholder proposals that received majority support
Company Proposal Year BlackRock SSGA Vanguard Hudson Pacific Prepare a report 2017 For Abstain For Properties, Inc. regarding diversity on the board Fleetcor Board diversity and 2016 Against For Against Technologies Inc. reporting Cognex Corp. Adopt policy for 2017 Against Against For improving board diversity Joy Global Inc. Board diversity 2016 Against For Abstain Ebay Inc. Gender pay equity 2016 Against Against Abstain
40 Takeaways
Passive and active management are viable approaches to implementing an long- term investment strategies in public markets. Passive management (indexing) benefits investors by enabling low cost exposure to markets where active management has been challenged to exceed benchmarks. Due in part to active management results in rising markets that followed the crisis, passive management’s share of the U.S. equity market has grown to up to 40%. Notwithstanding its benefits, the rise in passive management is causing concerns among experts about potential impacts to markets, economy and corporate governance. Potential impacts include the diminishing role of price discovery in allocating capital, potential market volatility and concentrated ownership and control of U.S. companies. Financial system and corporate governance impacts of asset flows from active to passive equity management warrant close monitoring and study.
4120 Presenters
Julian Regan Senior Vice President and Public Sector Market Leader [email protected]
Maureen O’Brien Vice President Corporate Governance Director [email protected]
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