How The Task Force is Leading Thailand’s Seafood Supply Chain Towards a More Sustainable Pathway
Progress Report following Membership review and planning meeting in Bangkok Aug 2016 2 Contents
1. Overview
2. The problem the Task Force is trying to solve
3. Unique approach to the problem
4. Current situation
5. Task Force pathways and what success looks like
6. June ‘16 Members meeting - Bangkok
7. Reaching out to the NGO and Civil Society community
8. Headline progress and next steps
9. The Task Force and its journey to the future
10. Abbreviations and acronyms.
Purpose of this report
It is two years since the Seafood Task Force (Task Force) was established. Formerly known as the Shrimp Sustainable Supply Chain Task Force, it recently changed its name to reflect the equal emphasis now being placed on tuna and other seafood products. This Management Summary is written following the Membership’s review and strategy meeting held in Bangkok - June ‘16.
3 1 Overview
What is the Task Force? Aims In June 2014, The Guardian published an investigation into the Thai The Task Force aim is to drive measurable social Shrimp supply chain. It alleged that Asian slave labour was contributing to and environmental change in the Thai seafood the production of shrimp for supermarkets in the US and the UK. Charoen industry through greater supply chain accountability, Pokphand Foods (CPF) and a number of its customers including Costco verification and transparency. were implicated. As a result of this investigation and the serious concerns it raised, CPF and Costco established the Task Force in July 2014. Particular emphasis is being placed on feed for farmed shrimp, tuna and other seafood products Since its inception, Task Force Membership has grown exponentially and now, in the exported to the US and the EU. words of leading NGO Humanity United, it represents ‘the most influential and diverse coalition of stakeholders operating in Thailand on this issue’ with its own set of initiatives It is promoting the common interests of its Members to reform the seafood industry. through the application of social, environmental and related standards within the seafood supply The Task Force describes itself as a leading international industry-led coalition chain and it is doing this with considered strategies including major US and EU retailers, Thai manufacturers, proactive seafood companies, to improve the livelihood and dignity of workers importers, governments and NGOs. With current membership exceeding 20 commercial and the sustainability of Thailand’s fisheries for the organizations, it’s a group of like-minded people with the desire to make things happen. longer term.
And with estimated seafood purchases from Thailand* exceeding $7B US and $145M EU, the Task Force is a powerful force for change.
* Source: Seafish Focus on Ethical Issues – Thailand Profile
Task Force Current Membership List - Aug 2016 listed in alphabetical order
Commercial Organizations NGO and Advisory Current Participating Organizations
Aqua Star National Fish & Seafood Aquaculture Stewardship Council - ASC Asian Seafoods Nestle Purina Ethical Trade Initiative - ETI Beaver Street Foods Rubicon Resources Environmental Justice Foundation - EJF Charoen Pokphand Foods / CP Foods Seafresh Group Fishwise Costco Southeast Asian Packaging and Canning Co. Global Aquaculture Alliance - GAA Eastern Fish Company Sysco Corp IDH – The Sustainable Trade Initiative Grobest Tesco Satellite Applications Catapult Lyons Seafoods Thai Royal Frozen Food Sustainable Fish Partnership - SFP Marine Gold Thai Union Group UL Mars Petcare Walmart Verite Mazzetta WM Morrsons World Wildlife Fund - WWF
4 August 2016 Progress Report following Membership review and planning meeting in Bangkok Overview
Governance and Terms of Reference During its review in October 2015, detailed consideration was given to the development of Governance and suitable Terms of Reference to meet the growing needs of the coalition and external stakeholder feedback. Particularly important was the need to address concerns regarding its original voluntary compliance structure.
Formal structure, process, perspectives and priorities were fully drafted in Q1 of 2016. Also considered were the financial requirements, communications and how the Task Force should function as it continues to gain momentum. Task Force Board Members – June ‘16 Organisation listed in alphabetical order
In June ‘16, the Task Force became fully registered as a non-profit corporation organized in the USA as a 501(c) Dave Martin Aquastar (6) trade association. With this registration, a formal Membership Agreement, fit-for-purpose Bylaws and Pitipong Dejjarukul Charoen Pokphand Foods Anti-Trust regulations have been introduced. Ken Kimble - Board Chairperson Costco
The Membership Agreement requires all commercial Choopong Luesukprasert Marine Gold Members to pay annual dues and its Bylaws outline the Huw Thomas Morrison’s scope of work and the principles and procedures by Nick Leonard Rubicon Resources which the organisation now operates. Nuntawan Rujiwong Thai Royal Frozen Foods A formal Board was elected from the membership in Scott Solar Thai Union June ‘16 and the Board has successfully elected a Chairperson, Treasurer and Secretariat. Jeff Lough Walmart
The Secretariat is full-time and has been employed to co-ordinate and support Task Force activities as the needs of the organisation grow. To ensure global balance, the The Board Board is equally represented by US, EU and Thai entities.
expects the To support the Board and the Secretariat, the National Fisheries Institute in the US (NFI) is providing independent book keeping and accounting services.
ESA to be fully To ensure appropriate levels of independent verification and validation are met and to ensure overall credibility of the Task Force’s work, the new board is appointing twelve formed and individuals from the NGO community to serve as an External Stakeholder Advisory Group (ESA).
established by Members of this ESA will consist of individuals bringing valuable technical expertise in the areas of social responsibility, environmental sustainability and traceability with two Dec ‘16. of these members serving as co-chairs. The Board expects the ESA to be fully formed and established by Dec ‘16.
The Secretariat continues to receive healthy expressions of interest from US and EU retailers and Thai manufacturing organizations across the supply chain. Currently, there are over ten further organizations that have formally requested Terms of Reference and copies of the Membership Agreement for consideration.
Task Force success is largely dependent on critical mass and achieving high penetration levels across each section of the seafood supply chain. It is currently considering a capacity model for optimum membership but, in the meantime, is accepting further Membership applications to gain this essential critical mass.
Progress Report following Membership review and planning meeting in Bangkok August 2016 5 2 The Problem that the Task Force is trying to solve
Leading Thailand’s seafood supply chain towards a more Information provided by this extensive NGO community has, amongst many other sustainable pathway requires attention to both the social things, informed the US Traffic in Persons (TIP) report and Thailand’s TIP rating. and environmental aspects of sustainability. Although its Tier 3 rating has been moved in 2016 to Tier 2 Watch List, which is a level between 2 and 3 due to recent recognized improvements, the NGOs and From a social aspect, Governments, the media and NGOs have Industry are understandably keeping a watchful eye. documented horrific cases of forced labour and human trafficking in Thailand’s seafood supply chain. Particularly disturbing are reports The environmental aspect relates to poor fisheries management leading of labour abuses in fisheries supplying tuna, feed for farmed shrimp, to overfishing. In April 2015, the European Commission put Thailand on and other seafood products exported to the US and the EU. formal notice (via a ‘Yellow Card’) for not taking sufficient measures in the international fight against illegal, unregulated and uncertified fishing (IUU) With a history of false promises and lack of action by the Thai - particularly in its fisheries monitoring, control and sanctioning systems Government to address these reported issues, there are now in (MCS). This ‘Yellow Card’ has now been extended to December ‘16 due to the excess of 120 different NGO organizations actively campaigning acknowledgment of progress made. However, a ‘Red Card’ is still an imminent for change in Thailand from either a social or environmental threat to Thailand’s business community and the Country’s ability to export perspective. product to the EU.
The Task Force is taking a strategic approach with a combination of short, medium and long-term initiatives.
3 Unique Approach to the Problem 4 Current Situation
The Task Force is taking a strategic approach with a combination The last two years have seen genuine signs of tangible of short, medium and long-term initiatives. improvement in Thailand and this has been recognized by a number of leading NGOs. These initiatives are realistic and planned with long-term sustainability in mind. With recent changes in the Thai Government, there is finally an It recognizes that the social issues related to human rights abuse and the acceptance that the country faces serious problems and that a environmental issues related to marine conservation are both closely linked to long-term strategy and short-term tactics are required. illegal, unreported and unregulated fishing (IUU) hence the Task Force’s clear focus on tackling IUU. Leading NGOs - The Freedom Fund and Humanity United recently published an up-to-date assessment of the progress It is the only international multi-stakeholder collaboration with entire supply achieved in fighting the social aspects described above. chain participation and it believes in taking practical and pragmatic steps with This assessment outlines the new systems that have been action speaking louder than words. established to drive traceability, transparency and worker protection. Whilst it details gaps and the need for further All work is currently focused on Thailand but the intention is that the outputs improvements, it describes many of the reforms so far as being created are fully scalable and will serve as replicable models for similar encouraging. impact across the globe at a later date. The assessment also refers heavily to the work of the Task Force and describes how the Task Force is now successfully complimenting the Thai Government’s response and making significant progress.
The assessment also suggests a number of areas for Task Force improvement and this valuable feedback is currently being addressed following the June ‘16 Members meeting in Bangkok.
6 August 2016 Progress Report following Membership review and planning meeting in Bangkok Progress Report following Membership review and planning meeting in Bangkok – August 2016 7 8 August 2016 – Progress Report following Membership review and planning meeting in Bangkok 5 Task Force Pathways
The Task Force has three core objectives, Objective 3 which remain as follows: To assist in driving Fishery Improvement Projects (FIPs) for the Gulf of Thailand and the Andaman Sea. Objective 1 To implement track and trace systems that meet International verification Deliverable standards spanning from vessel to port, feed-mill and farm. • Successful fishery pre-assessments in both Gulf of Thailand and Andaman Sea. Deliverable • Business case, costings and funding proposals that secure FIP implementation. An independent, Internationally recognized benchmark industry supply 3rd Party Certification. chain model for adoption by all. •
How will this drive fundamental change? How will this drive fundamental change? Industry experts recognize that the key to long-term Nothing of this description currently exists in Thailand. Building a • • sustainability of Thailand’s seas sits with properly managed fit-for-purpose model that has been rigor tested by independent fisheries and that FIPs can provide the structure behind specialists will provide a benchmark for all to follow. Over time, these suitable reform. models can be used as the requirement for Thailand related purchases across the supply chain. And longer term, there will be a concept These three core objectives and resultant deliverables remain protocol that is scalable and adaptable for use in other countries and the cornerstone to future progress in Thailand. Each contributes industries. to the elimination of forced labour, human trafficking and the overfishing problems described. Progress made against these provides a structured approach that is yielding step-by-step Objective 2 progress in a logical fashion. To create codes of conduct that will receive International recognition. The Task Force has split the work required to deliver these objectives into 8 Sub-Groups to tailor the broad skills of the Deliverable Membership to the tasks and action plans required. • Standard codes of conduct to cover vessels, ports and brokers. The Sub-Groups are as follows: The trial introduction and successful roll out of a Vessel Monitoring • Sub-Group 1 - Vessel Watch – Feed containing System (VMS) that can analyze vessel behavior by exception. (VMS • fishmeal supply chain alone is not the solution. Vessel behavior monitoring is required that can manage data by exception.) • Sub-Group 2 - Surimi & Electronic Traceability How will this drive fundamental change? • Sub-Group 3 - List of Asks and SFP Control Document • There are no standard codes currently in existence. By creating a recognized standard, written by experts and rigor tested for practicality, • Sub-Group 4 - Vessel Behaviour Monitoring there will be a powerful tool available that can be used by all. • Sub-Group 5 - FIP’s Development • VMS with vessel behavior analysis is an essential tool for the comprehensive tracking of fishing vessels at sea. A combination of • Sub-Group 6 - Independent Validation (to ensure all satellite technology, software and trained analysts can identify illegal Sub-Group work is credible amongst external stakeholders) fishing activity in seconds, providing governments with the intelligence to act fast. This underpins robust fisheries management as well as • Sub-Group 7 - Tuna Oversight providing evidence of what the vessels identified in Track & Trace are actually doing. • Sub-Group 8 - Farm to Plant
Progress Report following Membership review and planning meeting in Bangkok August 2016 9 6 June ‘16 Members meeting in Bangkok
The June ‘16 Member face-to-face meeting in Bangkok took place over an intense 4-day programme and saw up to 75 delegates join the event representing a 50% uplift from the October ‘15 face-to-face meeting. This is a reflection of the interest levels that the Task Force is now commanding.
These four essential days provided the Membership and guests with: • Progress updates • Establishment of Caucus sessions – Retailers | Manufacturers | NGOs and Advisors • Special guest Q&A with Director General of the Thai Department of Fisheries – Adisorn Promthep • Sub-Group forward planning • Organizational strategic planning – Key focus for next 6 months.
During the four days, the newly elected Board held its inaugural Board meeting and is currently being assisted from a legal perspective by legal counsel – Webster, Chamberlain & Bean, LLP – Washington DC. This will help the Organization during its early stages of formation and ensure compliance with the Task Force’s organizing documents, policies and applicable laws.
7 Reaching out to the NGO and Civil Society community
Whilst significant time was set aside for strategy Following this session, the Secretariat has received multiple expressions of and Sub-Group work planning, the Task Force interest from guests wishing to continue the dialogue and to become part of also held a unique speed-briefing event in the Task Force’s External Stakeholder Advisory Group (ESA). recognition of the need to meaningfully reach out to NGO and Civil Society actors - in particular, the The Independent Validation Sub-Group (Sub-Group 6) is in the process local NGO community. of drafting recommendations to the Task Force Board that will include the recommendation for ESA composition. It is also developing a full validation This was a truly groundbreaking event that saw multiple plan to ensure that all work of the Task Force and the programs it is developing NGO Organizations and Worker representatives presenting meet with NGO and Civil Society approval. their initiatives in a condensed and concise fashion - all under one roof. Amongst these guests were the following organizations: • International Labour Organization • Project Issara • SSG Advisors • Migrant Workers Rights Network - MRWN • Oxfam • Environmental Justice Foundation – EJF • International Justice Mission • Labour Rights Protection Network • Sustainability Incubator • International Organization for Migration • IDH - Sustainable Trade Initiative The 50% uplift in delegate attendees is a reflection of the interest levels that the Task Force is now commanding
10 August 2016 Progress Report following Membership review and planning meeting in Bangkok ‘The sector should look to existing beacons of best practice in labour generation and social conditions – such as the Task Force.’ The Prince’s Charities – International Sustainability Unit – June 2016
Progress Report following Membership review and planning meeting in Bangkok – August 2016 11 8 Headline Progress and Next Steps
Objective 1 Achieved so far Focus for next 6 months 1 Working Together 1 Audit Traceability Protocol 4 Farm to Plant Supply Chain Combined the strengths of all leading Thai • Formation of a permanent • Agree minimum acceptable To implement seafood manufacturers working together for committee to manage forward performance amongst the first time in history. audit activity covering: all buyers. Consideration track and trace factors to include: - Activity monitoring - Marine Docket – with 2 Feed containing Fishmeal Supply Chain - Remediation systems that feed info. • Mapped by-catch ‘feed containing - Guidelines fishmeal’ supply chain - All TFFA members to meet International - Data management & mandate feed lots • Fully completed first round ofsupply analytics. verification chain audits (including Social - Plants to set expectations Compliance measures) of farmers to feed with 2 Surimi supply chain MCPD or equivalent • 100% of vessels in Task Force standards assured feed Membership audited • Confirm Task Force requirements to buying - Encourage farms into spanning from • To date the companies involved in Surimi fishmeal sub groups purchasing fish meal from the By-catch vessel through have spent upwards of 10 Million Baht on • Utilize Task Force - Introduction of feed these audits connections to develop TF logbooks. approved Surimi producer • Social Compliance to port, feed-mill • 20 ports, 13 fishmeal plants, 5 feed mill network plants also fully audited - Education programme • Engage Surimi trade and farm. - set up tours to visit • Created the Audit traceability protocol association to create list of associations as a TF for audits going forward. asks for Surimi Association membership - Align audit needs (if possible use some of 3 Surimi Supply Chain • Determine outlets and map the existing) • Held full discussions with Surimi the export supply chain - Pilot project with farms, processors and commenced Surimi • Engage the IFFO in support train via Task Force processor traceability compliance audit of Surimi fishmeal producers using UL Protocol - Buying influence over Code of Conduct • Engage Surimi by-product exports identified. - Social audits to become producers and feed requirement. companies - an open forum 4 Tuna Supply Chain focused on use of input • Created new Sub-Group to focus on Tuna product in aqua feed. 5 Developing Electronic supply chain - fish & by-product -Jan ’16 Traceability • Work Plan and scope agreed 3 Tuna Supply Chain • Determine specification, timelines and collaboration • Engaged with fleet owners to ensure full • Conduct landscape analysis level with Thai Department of supply chain representation and input. - flow of tuna and existing Fishery (DoF) government validated catch • Develop road map to include 5 Farm to Plant Supply Chain documentation and other documents with addition - Defining mandatory DoF • Created new Sub-Group to focus on of company-specific asks/ documents required traceability mapping from farm to plant - practices as appropriate Jan ’16 - VMS minimum • Review current Task Force requirements. • Work Plan and scope agreed Code of Conduct draft • Problems affecting Traceability and social and suggest edits to make 6 Establishing Task Force compliance identified. applicable to tuna Member minimum trading • Gap analysis between Code conditions 6 Establishing Task Force Member and current practices by tuna • Industry associations still minimum trading conditions companies lack minimum membership • Drafted formal Task Force List of Asks • Connect with ISSF on labour requirements for Code of that will form part of Sustainable Fish on vessels conduct (CoC) – so Control Partnership’s Control Document. • Create template to map Document not currently supply chain possible 7 Developing Electronic Traceability • Send mapping spreadsheet • Plan to identify one • Secured funding for project working with to processors, request association and develop/ World Wildlife Fund and Deloitte. source/vessel info. implement CoC providing training and facilitation as • Aggregate data • Conducted ‘Buy’ vs. ‘Build’ analysis required. ready for TF Board to consider • Initial Risk Analysis • Traceability vendors interviewed and - Insight generation of Code demoed vs. practices in place on • Integration with Government considered. vessels - Analyze results from tuna 8 Funding mapping. • Secured funding from National Fisheries • Pilot audits for gap analysis Institute. on Tuna Purse Seine vessels and Long liners.
12 August 2016 Progress Report following Membership review and planning meeting in Bangkok Headline Progress and Next Steps
Objective 2 Achieved so far Focus for next 6 months 1 Overall Code of Conduct • Created a framework 1 Overall Code of Conduct Development where the Department Development • Final review of Codes with Membership of Fisheries can use the To create codes • Developed and drafted Sub-Groups and Task Force Board information generated to Codes of Conduct for prosecute offending boat of conduct vessels, ports and labour • Creation of formal Policy Documents, owners. providers within the seafood Implementing Documents and Reporting that receive supply chain Documents. 3 Sharing experiences • Translated Maritime Labour International and lessons from other Act BE 2558 2 Development of fit-for-purpose Vessel countries and working Monitoring with Thai Fishers to recognition. • Created working code • Review of trial performance with DoF document and translated understand the challenges into Thai they face and to inform • Establish DoF commitment to extend trial ongoing work to 5,600 vessels based on trial results • Held working sessions with • Facilitated a UK research CCCIF in Bangkok. visit in May ‘15 for senior • Develop proposal for extension of Thai Government and support to DoF for all >30GT vessels, influential Thai Fishers incorporating cross reference of all 2 Development of fit-for- records (labour & fishing), and to support purpose Vessel Monitoring • Proposed a follow-up visit enhancement of Department of Fisheries • Researched VMS systems for senior Thai Government Standard Operating Procedures (SOP) worldwide delegation to visit EU – Deliverables, personnel, costs Centre for Environment, • Worked with The Satellite Fisheries and Aquaculture • Develop proposal to support DoF in MCS Applications Catapult to Science CEFAS for 10-29GT vessels, building on proposal scope and implement a for >30GT and seek commitment from DoF Vessel Behavior analysis • Conducted four rounds to engage trial – monitoring and of fishermen interviews in surveillance of 41 vessels Thailand and multiple visits • Encourage DoF to improve Port in Port in Task Force membership to Songkhla Out (PIPO) systems for inspection by supply chain (40 Tones and offering suitable Task Force training above). Funding for trial • Held regular progress and structure developed as part of the project provided by The Pew review meetings with the Vessel Watch audit programme. Charitable Trusts Department of Fisheries • Worked with Thai • Presented the progress of Department of Fisheries the Task Force to DG MARE and The Satellite in Brussels. Applications Catapult to • Met with CCCIF Head scope and implement trial - Admiral Na Arreenich • As part of project, worked with Department of with DoF to help strengthen Commerce in October coastal parameters and all 2015 to present Task Force requirements under Thai recommendations. Law including definition of Thai coastal waters, no fish zones, resting periods and Thai EEZ
1 Helped to bring together eight seafood industry 1 Progress Andaman Sea Action Plan following Objective 3 associations in Thailand to form the Thai Sustainable report on Baseline study – socio economic– Fishmeal Roundtable (TSFR). artisanal fishing. To assist in 2 Worked with the TSFR to engage directly with the Thai 2 Facilitate plan for Gulf of Thailand pre-assessment Government. and Action Plan. driving Fishery 3 Worked with TSFR and NGOs WWF and the SFP to drive 3 Identify stepwise standards – IFFO RS >>MSC. the initial pre-assessment work required for the Andaman Improvement Sea and the Gulf of Thailand. 4 Encourage more consistent TSFR reporting and supplement with Task Force reporting on Thai Projects (FIPs) 4 Formed FIP Sub-Group to formulate and drive action improvements as required. plan with the fishery management expertise in the membership. 5 TSFR may need to fund preliminary stages; for the Gulf of TF to explore early funding opportunities in 5 Preliminary assessment for the Andaman Sea now been anticipation of this. Thailand and the completed by MRAG. 6 Task Force Board delegation presentation/briefing for TSFR to ensure alignment of objectives and Andaman Sea. forward plan.
Progress Report following Membership review and planning meeting in Bangkok August 2016 13 9 The Task Force and its journey to the future
Opportunities, aspirations, headlines and It was generally agreed that the Task Force must continue to focus on the successful common themes completion of its original three objectives and that further scope would be considered in January ‘17 at the next face-to-face Member meeting to take place in Bangkok. The June ‘16 Meeting provided the Membership with a further opportunity to consider Task Force ambitions both Amongst other things, there will be due consideration to the balance of the Task Force short and longer term. Membership and how it can actively encourage further on-the-ground commitment and involvement from Thai society, The Royal Thai Government and the local Thai With a 501(c) 6 status now established and with NGO community. Ultimately, it is the Task Force ambition that Thai Government, Thai Bylaws, Antitrust and Membership Agreements Industry and local stakeholders own the outputs that bring about long lasting change. in place, healthy debate included broader scope requirements beyond shrimp, geography and species. The Organisation will rename to ensure that the Task Force is not perceived as limited to shrimp 10 Abbreviations and Acronyms
IUU Illegal, Unreported and Uncertified (Fishing) ESA External Stakeholder Advisory CCCIF Command Centre for Combatting Illegal Fishing DG Director General FIP Fishery Improvement Program MSC Marine Stewardship Council TF Task Force TIP Trafficking in Persons DG MARE Director General for Maritime Affairs & Fisheries MSY Maximum Sustainable Yield CPUE Catch per Unit Effort NFI National Fisheries Institute IDH Initiatief Duurzame Handel – The Sustainable Trade Initiative MCPD Marine Catch Purchasing Document VMS Vessel Monitoring System AIS Automatic Identification System MD Movement Document FCR Feed Conversion Ration LIS Line Item Summary TSFR Thai Sustainable Fisheries Roundtable DOF Department of Fisheries PIPO Port in Port Out MCS Monitoring Control and Surveillance MRAG Marine Resource Management Consultancy
14 August 2016 Progress Report following Membership review and planning meeting in Bangkok IUU Illegal, Unreported and Uncertified (Fishing) ESA External Stakeholder Advisory CCCIF Command Centre for Combatting Illegal Fishing DG Director General FIP Fishery Improvement Program MSC Marine Stewardship Council TF Task Force TIP Trafficking in Persons DG MARE Director General for Maritime Affairs & Fisheries MSY Maximum Sustainable Yield CPUE Catch per Unit Effort NFI National Fisheries Institute IDH Initiatief Duurzame Handel – The Sustainable Trade Initiative MCPD Marine Catch Purchasing Document VMS Vessel Monitoring System AIS Automatic Identification System MD Movement Document FCR Feed Conversion Ration LIS Line Item Summary TSFR Thai Sustainable Fisheries Roundtable DOF Department of Fisheries PIPO Port in Port Out MCS Monitoring Control and Surveillance MRAG Marine Resource Management Consultancy
Progress Report following Membership review and planning meeting in Bangkok – August 2016 15 For more information about the Task Force or to make contact, please visit: www.seafoodtaskforce.global
The Seafood Task Force Inc. Formerly the Shrimp Sustainable Supply Chain Task Force, Inc. is a non-profit corporation organized in the USA as a 501(c)(6) trade association. © Seafood Task Force, Inc. 2016. All rights reserved.
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