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Sep 19 2023
2023 Practical ESG Conference
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Sep 21 2023 #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social
SEC Adopts Names Rule Changes, Impacting ESG Funds
Yesterday morning, the SEC voted 4-1 to adopt a 283-page document of amendments to the “Names Rule” to prevent fund names from misrepresenting a fund’s investments and risks; in other words, “ensuring that a fund’s investment activity is consistent with...
Sep 21 2023 #climate, #diversity, #environment, #equity, #esg, #investors, #social
The Names Rule Amendments: “Potential Interpretive Issues”
Under the new Names Rule amendments, the use of ESG terminology in prospectuses (prospecti??) may be a challenge given the substantial variability and ambiguity in both plain English and industry use of ESG wording, labels, programs, strategies and themes. The...
Sep 21 2023 #climate, #compliance, #environment, #esg, #investors
About Those 10-K Climate Risk Factor Disclosures…
Yesterday was Day 1 of CCRcorp’s Proxy Disclosure Conference and the first speaker of the day was Erik Gerding, Director of SEC’s Division of Corporation Finance, who provided comments on a number of things (standard disclaimer that his comments were...
Sep 20 2023 #climate, #compliance, #esg
California Sues Major Oil Companies For 70 Years of Climate Disinformation
California was on a roll last week. On Wednesday and Thursday, new climate disclosure bills passed in the legislature and are expected to be signed by the Governor. To follow that one-two punch, the California Attorney General threw a haymaker...
Sep 20 2023 #climate, #compliance, #environment, #esg
How California’s Oil and Gas Lawsuit Fits in the Big Picture
Previously, I wrote about California’s lawsuit against five major oil and gas companies. That blog discussed the alleged facts of the complaint and the underpinnings of the case. Today we’ll look at the legal theories advanced by the California AG...
Sep 20 2023 #diversity, #equity, #esg, #human-rights
Ending Your Remote Work Option Hurts Your DEI Goals
The workplace transformed significantly as the pandemic forced many companies to go remote. For the first time, companies had to find ways to stay in business while employees remained in the safety of their own homes. With numerous companies (including...
Sep 19 2023 #assurance, #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social, #supply-chain
Today is the Day! The Annual PracticalESG Conference Begins This Morning
Couldn’t make it to Climate Week in NYC? Don’t despair – you can STILL register for our day-long virtual ESG conference, themed “Finding Shelter in the ESG Bomb Cyclone”. The conference, sponsored by Morrison Foerster, consists of nine programs designed to...
Sep 19 2023 #climate, #compliance, #environment, #esg
Flashy Apple Sustainability Ad Cute But Could Be Trouble
A new video ad touting Apple’s sustainability progress on the company’s website is more of a short film than a traditional advertisement. The ad feels more like a scene from The Good Place than sustainability marketing. The premise is simple:...
Sep 19 2023 #climate, #compliance, #environment, #esg
Underground Injection Permitting & Geologic CO2 Sequestration
I have been somewhat curious about how states (which typically have primary authority for regulating waste management and disposal activities) approach CO2 geologic sequestration since CO2 is not a regulated solid waste. This article from the Texas Environmental Law Journal...
Sep 18 2023 #climate, #compliance, #environment, #esg
The Wait is Over – California Governor to Sign Climate Disclosure Bills
Last week, the California legislature passed two climate disclosure bills and sent them to the desk of Governor Gavin Newsom. You can read my summaries of SB258 (the Climate Corporate Data Accountability Act) and SB261 (Greenhouse gases: climate-related financial risk)....
Sep 18 2023 #climate, #environment, #esg, #supply-chain
Will Carbon Removal Plans Hold Up to Litigation?
To accomplish their climate goals, many countries are betting on ambient carbon dioxide removal (CDR) more than emissions reductions. Reliance on developing technologies that have not been brought to scale is almost certain to face further scrutiny in the courtroom....
Sep 18 2023 #diversity, #equity, #esg, #human-rights, #social
Tech is Losing Black, Latina and Native American Women
It’s no secret that the tech industry has struggled with its representation of women, especially women who are Black, Latina, and Native American. For years, tech companies invested in improving the representation of women through various programs and even by...
Sep 15 2023 #assurance, #climate, #compliance, #environment, #esg, #investors
Another California Climate Bill Passes, Impacting More Non-California Companies
Things moved pretty fast in the California legislature ahead of its Interim Recess. Yesterday I wrote about the state’s climate disclosure bill that went to the Governor’s desk. After that bill was passed, the legislature passed a second climate bill...
Sep 15 2023 #diversity, #equity, #esg, #human-rights, #social
Starbucks’ Legal Victory: DEI Is Within Board Business Judgment
DEI has been under fire recently with the Supreme Court’s ruling against affirmative action in university admissions and Florida’s suite of anti-DEI bills. Companies are trying to understand business implications of these DEI restrictions. Luckily, a recent win is on...
Sep 15 2023 #compliance, #diversity, #equity, #esg, #investors
More on the Starbucks Decision: A Blow to Anti-ESG, but More Court Battles Ahead
As Ngozi wrote, the National Center for Public Policy Research (NCPPR)’s anti-ESG case against Starbucks’ board of directors was dismissed with prejudice and faced scathing criticism from the presiding judge. The failure of this case marks a win for corporate...
Sep 14 2023 #assurance, #climate, #compliance, #environment, #esg, #supply-chain
California Climate Disclosure Bill Passes, Impacting non-California Companies
California SB-253, the Climate Corporate Data Accountability Act, passed in both state houses and now sits on the desk of Governor Newsom for final action or inaction (in California, laws become final automatically if executive action is not taken within...
Sep 14 2023 #compliance, #diversity, #esg, #social
Law Firms Sued for Considering Race in Fellowship Programs
American Alliance for Equal Rights, the organization behind the US Supreme Court case ending affirmative action in college admissions last June, filed lawsuits against two major law firms. The lawsuits target the firms’ programs offering fellowships to diverse candidates and...
Sep 14 2023 #diversity, #equity, #esg
New Podcast: Netta Jenkins on Making Organizations Inclusive
Our newest podcast is now available. I talk with Netta Jenkins – CEO of Aerodei, a gamified platform for organizations that ignite Inclusion efforts by measuring the impact of every employee and offers real-time employer data. Netta is the author...
Sep 13 2023 #climate, #compliance, #diversity, #environment, #esg, #human-rights, #social, #supply-chain
CLOs Expect ESG Focus to Expand
The role of Chief Legal Officer (CLO) is on the rise. A CLO oversees the legal department from a big-picture level, as opposed to a General Counsel which provides support in various legal matters. CLO’s have their attention split in...
Sep 13 2023 #diversity, #equity, #esg, #human-rights, #social
Assessing Company Impacts on Society and Business Dependencies
One of the core challenges of DEI is the ability to define its value to the business in ways that managers across the business can understand. The Capitals Coalition, a group of businesses, institutions, and experts, has introduced a new...
Sep 13 2023 #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social, #supply-chain
Proliferation of Industry ESG Initiatives Is a Problem
We all complain about ESG’s alphabet soup of abbreviations and acronyms. Those complaints are well-deserved. While that may be fodder for jokes, it isn’t necessarily funny and can be a real distraction to getting things done. The increase in abbreviations...
Sep 12 2023 #diversity, #equity, #esg, #social
And Then There Was One (Black Woman Fortune 500 CEO)
Only one Black woman Fortune 500 CEO remains after Rosalind “Roz” Brewer steps down from Walgreens leadership role after starting in 2021. The news leaves Thasunda Brown Ducket, president and CEO of TIAA, as the only Black woman currently leading...
Sep 12 2023 #climate, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social
ESG Counterspin – Is Adding ESG Staff Now Bad?
Another day, another new ESG risk pops up for companies. Usually, one sign that organizations are serious about backing up their ESG talk is to add headcount. Sure, that is an imperfect indicator of virtuous intent but it is usually...
Sep 12 2023 #assurance, #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social, #supply-chain
One Week Until Our Conference – Have You Registered?
Our conferences kick off one week from today – starting with our “2nd Annual Practical ESG Conference” on Tuesday and continuing with the “Proxy Disclosure & 20th Annual Executive Compensation Conferences” bundled together as one virtual event on Wednesday, Thursday and...
Sep 11 2023 #climate, #environment, #esg, #social
Oregon County Seeks Climate Change Damages from Energy Companies
[Ed. note: Today is the 22nd anniversary of the terrorist attacks of the World Trade Center, the Pentagon and United Flight 93. It is a difficult day for many, but we take this moment to remember those who died in...
Sep 11 2023 #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social, #supply-chain
ESG Credibility Is Being Tested Like Never Before
[Ed. note: Today is the 22nd anniversary of the terrorist attacks on the World Trade Center, the Pentagon and United Flight 93. It is a difficult day for many. I had a friend who perished in the first tower. A...
Sep 11 2023 #climate, #environment, #esg, #supply-chain
More Uncertainty in Climate Management Assumptions
[Ed. note: Today is the 22nd anniversary of the terrorist attacks on the World Trade Center, the Pentagon and United Flight 93. It is a difficult day for many. I had a friend who perished in the first tower. A...
Sep 8 2023 #compliance, #environment, #esg, #investors, #social, #supply-chain
EFRAG and GRI Issue Joint Statement of Interoperability
The European Financial Reporting Advisory Group (EFRAG) and the Global Reporting Initiative (GRI) issued a joint statement announcing alignment of their standards. The two organizations see eye to eye on the issue of impact materiality, with EFRAG adopting GRI’s definition...
Sep 8 2023 #assurance, #climate, #compliance, #environment, #esg, #investors
EU CSRD Part 2 – It’s Not Just Reporting Companies That Aren’t Ready
Following yesterday’s blog on company readiness for reporting under the new CSRD, it isn’t just the reporting companies that aren’t prepared – there are concerns about the expertise and availability of auditors to do the work. Responsible Investor’s article discusses...
Sep 8 2023 #compliance, #environment, #esg, #investors
Will the CSRD Create Litigation Risk from the SEC?
Since we are on the topic of the EU’s CSRD – its extra-jurisdictional scoping requirements require non-EU companies with a large enough presence in the EU to disclose under the framework. Materiality assessments must be conducted on a variety of...
Sep 7 2023 #climate, #compliance, #environment, #esg, #investors
Will Climate-Related Disclosures Survive the Climate of the Supreme Court?
The SEC’s Climate-Related Disclosure Rule has been proposed for over a year now. Many are expecting the final rule in October (although timing is uncertain) and litigation about the rule’s validity is a certainty. This has led to speculation on...
Sep 7 2023 #assurance, #climate, #compliance, #environment, #esg, #investors
EU CSRD Part 1 – Reporting Companies Aren’t Ready
EU’s new Corporate Sustainability Reporting Directive (CSRD) requires the first group of regulated companies – 11,000 or so large EU companies already reporting under the existing Non-Financial Reporting Directive (NFRD) – to report on 2024 data in reports published in 2025. Assurance...
Sep 7 2023 #diversity, #equity, #esg, #human-rights, #social
How the “Black Tax” Perpetuates Systemic Racism
Ever since emancipation, Black Americans have been subjected to a “Black Tax”. Even after 400 years, experts estimate African Americans own just 2% of US wealth. Data reveals that Black borrowers pay more than White borrowers due to receiving higher...
Sep 6 2023 #climate, #diversity, #environment, #equity, #esg, #investors, #social, #supply-chain
ESG Spending is Both Up and Down – Depending on Who You Ask
Is ESG still a corporate priority and are companies continuing to invest in related initiatives? Well, it depends. If you ask automotive supply chain executives, the answer seems to be “no” according to results from a new CapGemini survey: “Sustainability...
Sep 6 2023 #assurance, #climate, #compliance, #diversity, #environment, #equity, #esg, #human-rights, #investors, #social, #supply-chain
A CSO’s View on Benefits & Risks of ChatGPT in ESG
An interview with investment bank J Safra Sarasin’s chief sustainability officer Daniel Wild about their experiences using chatGPT in ESG was just published by ESGClarity. Wild emphasizes the need for human involvement, assessment and ultimate decision making rather than deferring...
Sep 6 2023 #compliance, #diversity, #equity, #esg, #social
The Supreme Court’s Blow to LGBTQ Protections
The same week the Supreme Court dismantled affirmative action in university admissions, it also made a detrimental decision about LGBTQ rights. In the case 303 Creative LLC v. Elenis, the Supreme Court ruled in favor of the Christian graphic artist...
Sep 5 2023 #assurance, #climate, #compliance, #diversity, #environment, #equity, #esg, #investors, #social
Managing Your ESG Scores – Maybe Not What You Think
Companies and ESG raters have developed an interesting – if not adversarial – relationship since ESG ratings became mainstream a few years ago. The ratings systems evolved rapidly and imperfectly, while companies struggled to understand the basics of black-box ESG...
Sep 5 2023 #climate, #environment, #esg, #supply-chain
How Climate Mitigation Wording is Evolving
Whether due to anti-ESG pressures or because of how much fraud and uncertainty has recently been discovered in carbon offsets – we are starting to see some surprising changes in how companies word what they are doing on climate mitigation....
Sep 5 2023 #equity, #human-rights, #social
Studies Show Remote Employees Work Longer and Harder
The pandemic compelled employers to reevaluate their approach to work, leading to a substantial shift towards remote work. In the pre-pandemic era, a mere 5% of the workforce operated from home; however, the virtual workspace currently accounts for nearly 30%...
Sep 1 2023 #climate, #environment, #esg, #supply-chain
Is the World’s Largest Carbon Credit Issuance in Danger?
[Ed. note: No blogs will be published Monday in recognition of the Labor Day holiday in the US. We will return Tuesday September 5.] By now, you know about the military coup in Gabon. While it may not be the...
Sep 1 2023 #assurance, #climate, #compliance, #diversity, #environment, #equity, #esg, #investors, #social, #supply-chain
More About Fraud in ESG
[Ed. note: No blogs will be published Monday in recognition of the Labor Day holiday in the US. We will return Tuesday September 5.] Even against anti-ESG and “greenhushing” headwinds, we are seeing more ESG disclosures and ESG-related performance components...
Sep 1 2023 #diversity, #equity, #esg, #human-rights, #social
The Pressure Grows on DEI Programs
[Ed. note: No blogs will be published Monday in recognition of the Labor Day holiday in the US. We will return Tuesday September 5.] With corporations facing increasing litigation in the wake of the Supreme Court’s decision in SFFA v....
Aug 31 2023 #climate, #compliance, #esg, #investors
Must US Companies Comply with EU’s Taxonomy Regulation?
The EU’s Corporate Sustainability Reporting Directive (CSRD) extends an extra-jurisdictional requirement for certain companies that operate – but are not headquartered – in the EU. These companies, referred to as third-country companies, must file reports at the consolidated entity level...
Aug 31 2023 #assurance, #compliance, #esg, #investors
Safety Professionals – Ready to Report to the SEC?
In reading over my daily deluge of ESG information, I was reminded of the SEC’s Human Capital Management (HCM) rule which went into effect three years ago. The rules are principles-based and provide a lot of room for discretion and...
Aug 31 2023 #compliance, #diversity, #equity, #esg, #social
Webcast Today: Corporate DEI Programs After Students for Fair Admissions v. Harvard
Join us today at 2 pm eastern for the webcast – “Corporate DEI Programs After Students for Fair Admissions v. Harvard” – to hear Orrick’s J.T. Ho, NextRoll’s Travis Sumter and PracticalESG.com Editor Ngozi Okeh discuss the implications of the Supreme Court’s...
Aug 30 2023 #compliance, #esg, #human-rights, #social, #supply-chain
Canada Investigates Big Names for Uyghur Supply Chain Issues
The U.S. isn’t the only country concerned with human rights problems in corporate supply chains in relation to Chinese Uyghurs. The Canadian Ombudsperson for Responsible Enterprise (CORE) published Initial Assessment reports regarding complaints about three Canadian companies that are alleged...
Aug 30 2023 #climate, #compliance, #environment, #esg, #investors
Tips for Threading the Needle of Pro- and Anti-ESG
It’s no secret that ESG has become divisive in national and state politics, particularly in the financial services sector. A recent memo from Reed Smith delves into the trends of ESG investing and outlines current legislative developments from both pro-...
Aug 30 2023 #compliance, #esg, #investors
PRI Discloses ESG Litigation Risks to its Own Business
UK-based Principles for Responsible Investment (PRI), the UN-backed investor coalition focused on sustainable finance, has flagged both ESG backlash litigation and the reputational risks of greenwashing as risks affecting its own business. Responsible Investor reports that, even though PRI is...
Aug 29 2023 #climate, #compliance, #environment, #esg, #social
Climate Concerns Create Crisis for Oil and Gas Hiring
The US oil and gas industry has long faced interesting staffing challenges with its boom-or-bust business cycles and notorious sector-wide mass layoffs. In the past, oil companies overcame the obstacles with high pay during boom times. That may not be...
Aug 29 2023 #climate, #environment, #esg, #investors
Carbon Offset Investments on the Rise, Along With Risk
This LinkedIn post from PracticalESG.com Advisory Board member Mark Trexler is emblematic of what I expect to see more frequently as investors – including retail investors – become more willing to jump into carbon markets for profit and capital growth....
Aug 29 2023 #climate, #environment, #esg, #supply-chain
Another Study: CO2 Offsets Don’t Cut the Mustard
More troubling news about more problems with carbon offsets being purchased by companies pursuing Net Zero goals. This scientific study published in Science. It’s a technical review of REDD (reducing emissions from deforestation and forest degradation) projects that create offsets...
Aug 28 2023 #climate, #compliance, #esg, #investors
Would SEC Have a Five Year Wait to Reissue Climate Rules?
In my blog last Monday, I included an excerpt from an ESG Clarity article about anticipated legal challenges to the SEC’s final climate disclosure rule (once issued). That excerpt included this statement: “If the SEC loses in court after publishing its...
Aug 28 2023 #climate, #compliance, #environment, #esg, #supply-chain
EU Issues New Rules as CBAM Ramps Up
The EU’s Carbon Border Adjustment Mechanism (CBAM) comes into effect on October 1, 2023. This will be the beginning of CBAM’s “transitional phase” which will require companies to report on embedded carbon in imported products. This phase will last until...
Aug 28 2023 #diversity, #equity, #esg, #social
Gender Biases to Avoid in Remote and Hybrid Settings
Ed. note: This blog was originally written for us by research intern Tristin Young. Since the pandemic, many have grown accustomed to having remote and hybrid work. I personally love the flexibility of remote work, but there are subtle pitfalls....
Aug 25 2023 #assurance, #climate, #compliance, #environment, #esg, #investors, #supply-chain
Deloitte Analysis Sheds Light on Common ESG Questions
A recent analysis from Deloitte “Many financial services companies mobilize for ESG reporting” offers answers to questions I hear frequently from companies about structuring the internal ESG function, preparations for ESG disclosures and data quality concerns. Here are a couple...
Aug 25 2023 #assurance, #climate, #environment, #esg
More on Deloitte’s Analysis of Corporate ESG Functions
The Deloitte analysis provided other valuable insights on financial services firms’ views on data and assurance: “Most (80%) of our respondents say their financial institutions are prepared to disclose details about their Scope 2 greenhouse gas (GHG) emissions. However, only...
Aug 25 2023 #climate, #environment, #esg, #social
An Update on Germany’s “True Pricing” Experiment
I recently blogged about a bold ESG experiment by German food retailer Penny, who selected a handful of basic grocery items for “wahren Kosten” (“real” or “true” pricing) for one week earlier this month. These “real costs” include impacts such...
Aug 24 2023 #climate, #environment, #esg, #investors
UK GFANZ Members Push Back Against “Sole Responsibility” for Net Zero
GFANZ members are making clear that they have a limited role in achieving UK’s Net Zero goals. Responsible Investor reports on written comments that were submitted to the UK Parliament: “Financial institutions should not be held solely accountable for delivering...
Aug 24 2023 #climate, #environment, #esg, #investors
Most Asset Managers “Misaligned” on Climate
While we’re talking about asset managers and climate, there is this. InfluenceMap recently issued an assessment of 45 of the world’s largest asset managers (“Asset Managers & Climate Change 2023“), looking at equity portfolios, stewardship, and sustainable finance policy engagement...
Aug 24 2023 #climate, #environment, #esg, #investors
It’s a Beach: California Pensions’ Net Zero Policies Differ
Even in California – a state where you think everyone would agree on climate issues – consistency in Net Zero approaches doesn’t exist. This piece from Net Zero Investor raised my eyebrows about how different net zero investment strategies are...
Aug 23 2023 #climate, #compliance, #environment, #esg
SoCalGas Settles Greenwashing Case with State AG
Southern California Gas Company (SoCalGas) – an energy company in California – settled with the California Attorney General over greenwashing allegations. The company made repeated marketing claims that natural gas is a “renewable” energy source, which the state’s Attorney General...
Aug 23 2023 #climate, #compliance, #environment, #esg, #investors, #social
EU Urges IFRS to Adopt Double Materiality
The European Securities and Markets Authority (ESMA) and the European Banking Federation (EBA) responded to the IFRS ongoing consultation regarding the organization’s priorities over the next two years. IFRS standards use a financial materiality lens, whereas European standards require ESG...
Aug 23 2023 #climate, #compliance, #environment, #esg, #investors, #social
EU Does a Double Take on Double Materiality Guidance
More on the EU’s use of double materiality standards and how it conflicts with the view of financial materiality used by other frameworks, including the ISSB. Earlier this month, EFRAG attempted to clear the air around double materiality by publishing...
Aug 22 2023 #climate, #environment, #supply-chain
US EIA: Fossil Fuel Production to Increase in 2023 and 2024 …
Last year and even earlier this year, there were some predictions that 2022 would be the year of peak oil and use of fossil fuels would start a permanent decline from 2023 forward. Earlier this month, the US Energy Information...
Aug 22 2023 #climate, #environment, #supply-chain
… But Carbon Emissions Are Going Down
While the previous blog about the EIA’s Short Term Energy Outlook fossil fuel predictions doesn’t sound great, there is good news near the end of the report – renewable energy and coal use reductions are having an effect: “We expect...
Aug 22 2023 #climate, #environment, #esg, #investors, #supply-chain
Amazon Loses Support from Key Climate Organization
This isn’t great news for Amazon, a company known for its efforts on sustainability and ESG. Bloomberg reports that “The Science Based Targets initiative, a United Nations-backed entity that validates net zero plans, has removed Amazon from its list of companies taking action on climate...
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Featured Q&A Members Only
Private equity and the CSRD
I saw Meredith’s DealLawyers blog about private equity and the CSRD, and am looking to better understand how that could apply to non-EU entities. The checklist, which is helpful, says that the scope for the CSRD will be expanded to cover non-EU companies if they meet both of the following criteria:
a. net turnover of more than €150 million in the EU at the consolidated level; and
b. at least one subsidiary or branch generating a turnover of €40 million in the EU.
I have three questions:
1. Does this only apply to “companies” or also entities like limited partnerships, etc.
2. Is there anything stopping a company from creating more subsidiaries so that none of them meet the “turnover” prong of the test?
3. Is “turnover” a similar concept to revenue?
09/15/2023, Question #18073
What GHG emission factors to use?
We are unclear on which emission factors are best to use (generically) and why, with associated pros and cons. For example:
- Business Travel. EPA vs. DEFRA: DEFRA is much more inclusive and well rounded, resulting in higher CO2e (almost double). Should we take a conservative approach, going with higher estimates rather than lower? But as DEFRA is such a gross overstatement, would that threaten our credibility?
- Purchased Goods and Services. EPA has subcategories for emissions factors based on spend, but there are other emission factors that could be used. How would a practitioner know which emission factor to apply?
Also, IPCC is over 20 years old. When and why should such EFs be used?
07/25/2023, Question #17162
Conflict minerals smelter list reporting
I heard that some companies may be starting to omit the annex/list of smelters from their conflict minerals reports because of the risk that some of those entities either are already or could be added to the UFLPA list from the dept of homeland security. Three questions:
- Is that permitted under the conflict minerals rules?
- Obviously this doesn’t resolve potential UFLPA violations, but is there any downside to doing this?
- Has there been any commentary on UFLPA enforcement priorities?
07/6/2023, Question #16791