by Marion Nestle

Search results: food policy action

Dec 2 2016

Weekend reading: Fixing the Food System

Steve Clapp.  Fixing the Food System: Changing How We Produce and Consume Food.  ABC-Clio, 2017  (but it’s out).

I wrote the Foreword to this book.  Here’s what I said:

In this welcome addition to my library of books about food policy and politics, Steve Clapp’s Fixing the Food System reviews the past and current history of calls for a national food policy, the most contentious controversies over food and nutrition issues that have impeded development of such a policy, and the work of advocates to achieve one.   As this book makes clear, this history began decades ago.

I first became aware of the importance of federal food policies in the early 1980s when I was teaching nutrition to medical students at the University of California San Francisco (UCSF).  First-year students were eager to learn about nutrition, but for personal more than for professional reasons.  They wanted to know what they—and the patients whose health problems they were learning to treat—should eat.  But by the time they were residents, I could see their dietary concerns vanish under the daily demands of patient care.  Trying to advise about diets was too difficult, time-consuming, and financially unrewarding to be worth the trouble.  It seemed unreasonable to expect doctors to take the time needed to counsel individual patients about the prevention of diet-related conditions—heart disease, type 2 diabetes, cancer, and the like.  If nutritionists like me wanted to focus on disease prevention rather than treatment, we would have to advocate to change the food environment to make healthful food choices the easy choices—even better, the preferred choices.  This meant we would have to advocate for food and nutrition policies aimed at promoting public health.

In 1983, I co-authored an article with UCSF colleagues on the need for such policies.[i]  It began:

The U.S. government helps to assure an adequate food supply for Americans by sponsoring a wide variety of food, nutrition, and agricultural support programs.  These federal activities were developed in the absence of a clearly articulated national policy, a situation that has resulted in the fragmentation of government programs and their wide disbursement among numerous agencies and departments.

Our article quoted the earliest calls we could find for a national policy to address these problems.  In 1974, long before the term “food system” came into common use, the National Nutrition Consortium of four leading nutrition and food science societies[ii] argued for a national nutrition policy that would:

  • Assure an adequate, wholesome food supply, at reasonable cost, to meet the needs of all segments of the population.
  • Maintain food resources sufficient to meet emergency needs and to fulfill a responsible role as a nation in meeting world food needs.
  • Develop a level of sound public knowledge and responsible understanding of nutrition and foods that will promote maximal nutritional health.
  • Maintain a system of quality and safety control that justifies public confidence in its food supply.
  • Support research and education in foods and nutrition with adequate resources and reasoned priorities to solve important current problems and to permit exploratory basic research.

Whether offered as nutrition or food policies, these were and remain highly appropriate goals for an abundant, healthy, safe, and effective food system.

My co-authors and I went on to identify the constraints that then limited government action to achieve such goals.  Despite an emerging consensus on the basic elements of healthful diets—fruits and vegetables, balanced calories, not too much junk food (as Michael Pollan put it more recently, “eat food, not too much, mostly plants”[iii])—the greatest impediment to policy development was the controversy over the science of diet and health.  As our article understated this issue,

The effect on the nation’s health of food processing and other changes in the U.S. diet is controversial.  Salt, sugar, fiber, saturated fats, alcohol, caffeine, calories, vitamins, and food additives all elicit vigorous debate.

Today, more than 30 years later, we are still arguing about that science, and the scientific arguments still impede policy development.  In Fixing the Food System, Steve Clapp brings us up to the minute on federal progress (or the lack thereof) toward achieving a clearly articulated national food policy.  He begins and ends his book with the most recent policy proposals from leading food advocates Michael Pollan, of course, but also Mark Bittman, Olivier de Schutter, and Ricardo Salvador.  Their recent suggestions for improving our current food system reflect the many changes in agricultural production and food consumption that have taken place since 1974 but retain the basic elements of those earlier proposals.  Fixing the Food System explains why a national food policy is so badly needed and matters so much.

Steve Clapp is in a unique position to comment on food policy issues.  He’s been at the policy game for a long time.  I don’t remember when I first met him but I have been reading his work since he reported for the Community Nutrition Institute’s newsletter, Nutrition Week.  For those of us outside the Beltway in those pre-Internet days, Nutrition Week was a lifeline to the ins and outs of food politics in Washington, DC.   Later, when Steve moved to Food Chemical News, also—and still—a lifeline, I continued to read his reporting.  I often ran across him at meetings and hearings in Washington, DC and found it instructive to read what he wrote about those deliberations, not least because he got it right.

I say all this because he has been a keen observer of the food politics scene in Washington for decades and I can’t think of anyone who ought to know it better.  Fixing the Food System reviews the major debates he witnessed—the Dietary Guidelines, of course, but also attempts to set policy for food safety, marketing to children, hunger in America, and humane treatment of farm animals, among others.

Over the years, he also observed the work of policy advocates, and this book includes profiles of many individuals engaged in this work, some likely to be familiar to readers, whereas others may not.  Impossible as it is for me to judge whatever impact my own writing and advocacy might have, I am honored to be included among those whose work he presents.

Fixing the Food System describes political arguments over the kind of food system we ought to have and what an ideal system should accomplish.  But it is also about the importance of personal and political advocacy for a better food policies, those aimed squarely at promoting public health and environmental sustainability.

Advocacy makes a difference.  Advocates are scoring successes in improving one after another aspect of the food system.  In comparison to the 1970s or 1980s, we now have better food in supermarkets, more organic foods, more farmers’ markets, more nutritious food in schools, and impressive declines in consumption of sugary drinks.  My personal favorite among indicators of advocacy success—the change that makes me most optimistic—is the increasing number of college students who care deeply about food issues.  They are demanding local, seasonal, organic, and sustainably produced food in their cafeterias, and campus vegetable gardens.  And they are demanding and getting food studies courses and programs like the ones we started at New York University in 1996 that teach about how food is produced and consumed and the practical and symbolic meanings of food in modern culture and societies.  Today’s students are tomorrow’s advocates for healthier and more sustainable diets for everyone, everywhere, and for fixing what needs fixing in our food systems.  This book is a great starting place for this work.

–Marion Nestle, New York, June 2016

[i] Nestle M, Lee PR, Baron RB.  Nutrition policy update.  In: Weininger J, Briggs GM, eds.  Nutrition Update, Vol. 1.  New York: John Wiley and Sons, 1983:285-313.

[ii] National Nutrition Consortium, Inc.  Guidelines for a national nutrition policy.  Nutrition Reviews 1974;32(5):1253-157.  The Consortium included the American Institute of Nutrition, the American Society for Clinical Nutrition, the American Dietetic Association, and the Institute of Food Technology.

[iii] Pollan M.  In Defense of Food: An Eater’s Manifesto.  Food Rules: An Eater’s Manual.  Penguin Press, 2008.

Oct 12 2016

WHO takes action against sugary drinks, urges taxes

The World Health Organization took two actions yesterday to encourage people to cut down on consumption of sugar-sweetened beverages.

It issued a report urging national governments to consider taxes: “Taxes on sugary drinks: Why do it?  

Governments can take a number of actions to improve availability and access to healthy foods and have a positive influence on the food people choose to consume. A major action for comprehensive programmes aimed at reducing consumption of sugars is taxation of sugary drinks. Just as taxing tobacco helps to reduce tobacco use, taxing sugary drinks can help reduce consumption of sugars.

It defines sugar drinks as products that contain added sugar, corn or fruit-juice concentrates and include carbonates, fruit drinks, sports drinks, energy and vitamin water drinks, sweetened iced tea, and lemonade.

It also took immediate action to remove sugary drinks from its Geneva headquarters

The agency explained this action:

The move signifies how seriously WHO is taking its leadership role in implementing policies to improve public health…By implementing this policy WHO is setting a positive example for Member States, other organizations and visitors…WHO vending machines, restaurants and coffee shops will continue to sell water, fizzy water, and unflavoured milks with different fat contents, teas and coffees, and beverages with non-sugar sweeteners (such as diet and zero calorie drinks). Sugar packets for use with tea and coffee will continue to be served.

These actions are getting plenty of attention.

The Guardian pointed out that:

Battle lines are being drawn in Colombia, where a consumer movement is pressing the case for a sugary drinks tax and the industry is fighting back…Last month, the Asociación Educar Consumidores – the consumer organisation which, like its Mexican equivalent, has backing from Bloomberg Philanthropies in the US – produced an educational video to be broadcast on television, warning that drinking too many sugary drinks can lead to diabetes and other diseases.

But after a complaint from Postobón, the Colombian beverage giant, the government’s regulatory agency charged with consumer protection banned any showing of the video on TV, saying it was inaccurate and could confuse the public.

Michael Bloomberg, now a global ambassador for WHO issued a statement.

A growing number of cities and countries – including Mexico – are showing that taxes on sugary drinks are effective at driving down consumption. The World Health Organization report released today can help these effective policies spread to more places around the world, and that will help save many lives.

The International Council of Beverages Associations (ICBA) issued a statement:

ICBA is disappointed that this technical committee’s report advocates the discriminatory taxation solely of certain beverages as a ‘solution’ to the very real and complex challenge of obesity. We strongly disagree with the committee’s recommendation to tax beverages, as it is an unproven idea that has not been shown to improve public health based on global experiences to date.

Healthy Food America says the soda industry has spent $30 million to fight soda taxes, just this year.

WHO has just given its blessing to soda taxes.  Will countries respond?  How much more is the soda industry willing to spend to stop taxes?

Stay tuned.

Other accounts:

Oct 11 2016

Do we have a food movement? The New York Times food issue

The New York Time published its annual food issue on Sunday, this one with the theme, “Can Big Food Change?”

In the circles in which I travel, Michael Pollan’s “Big food strikes back: Why did the Obamas fail to take on corporate agriculture?” caused the biggest stir.  Here’s what set people off:

On “Outlobbied and Outgunned:”  The word I’ve been using to describe food industry lobbying against Michelle Obama’s Let’s Move! campaign is ferocious.

I’ve always thought that Mrs. Obama must have picked the goal of Let’s Move!—“Ending childhood obesity in a generation“—as a safe, bipartisan issue that Republicans and Democrats could all get behind.  Doesn’t everyone want kids to be healthy?

I can’t imagine that she could have predicted how controversial matters like healthy school lunches or nutrition standards for food advertising to kids would become.

Whatever.  The food industry’s response to everything Let’s Move! tried to do was ferocious.

Despite all that, as I’ve said, Let’s Move! managed to accomplish some important gains: healthier school meals, more informative food and menu labels, the White House garden, and—most important—getting food issues on the national agenda.

On “the food movement barely exists:” I once taught a course on food as a social movement with Troy Duster, a sociologist then at NYU, who had much experience teaching about social movements.

He made one point repeatedly: those who are in the middle of a social movement cannot possibly judge its effectiveness.  You can only know when a movement has succeeded or failed when it is over.

This one is not over yet.

This movement, fragmented in issues and groups as it most definitely is, may not have clout in Washington, DC, but it is having an enormous effect on supermarkets, food product manufacturers, fast food chains, the producers of meat, eggs, and poultry, and young people in this country.

How else to explain:

  • The vast improvement in the quality of foods sold in supermarkets
  • The rush of food product makers to remove artificial colors, flavors, trans-fats. and other potentially harmful food additives, including sugars and salt
  • The insistence of fast food chains on sourcing meat from animals raised without hormones or antibiotics
  • The actions of meat, egg, and poultry producers to care for their animals more humanely
  • Soda tax initiatives in so many cities

And my personal favorite,

  • The enormous numbers of college students clamoring for courses about food systems and the role of food in matters as diverse as global resource inequities and climate change.

As Troy Duster kept telling us, it’s not over until it’s over.

While waiting for enlightenment, let’s celebrate the proliferation of food organizations.  They are all working on important issues and doing plenty of good.

And yes, let’s encourage all of them to move beyond the local, engage in national politics, and put some pressure on Washington to come up with better food policies.

Here are the other articles in the magazine, all of them well worth reading.

Jul 25 2016

USDA finalizes school food rules: Applause!

Last week, the USDA sent out a press release announcing the last four Final Rules for school meals under the Healthy, Hunger-Free Kids Act (HHFKA) of 2010:

The press release summarizes USDA’s view of what’s most beneficial in these policies:

You probably won’t want to read all the fine print.  Fortunately, others have done just that.

Bettina Siegel at The Lunch Tray

  • Wellness policies will be required to prohibit on-campus marketing of foods and drinks that fail to meet the Smart Snacks nutritional standards.
  • Whether companies can market “copycat” snacks in schools (Smart Snacks-compliant versions of junk food available in supermarkets) is left up to local districts.
  • Also left to local districts are policies about incentive programs, such as Box Tops for Education or fast food coupons passed out to kids for reading books.
  • School wellness policies will be required to set nutritional standards for foods and drinks offered to kids at classroom parties or by teachers as treats, but districts can determine the actual policies.
  • Schools will be allowed to sell hard-boiled eggs, low-sodium canned vegetables, and peanut butter and celery.

Her bottom line:

With the finalization of these four rules, the historic work of the Obama administration in improving children’s school food environment is now complete. But, of course, we’re already one year overdue for the next CNR [Child Nutrition Reauthorization], a process which could easily roll back or weaken these reforms – many of which have already been overtly threatened by House Republicans.

CSPI’s Take on What’s New

  • Local wellness policies must address marketing of foods and drinks that do not meet the Smart Snacks standards.
  • Local wellness policies must involve the public and school community and produce an annual progress report.
  • Local wellness policies must designate a school official for compliance and undergo administrative review every 3 years.
  • School districts must update goals for nutrition promotion, nutrition education, physical activity, and school wellness activities based on evidence-based strategies.

CSPI says the new rules mean local wellness policies can and should:

  • Shift unhealthy school fundraisers to profitable healthy food or non-food fundraisers
  • Ensure that school celebrations support healthy eating and physical activity
  • Use non-food rewards
  • Provide ample opportunities for physical activity, quality physical education, and recess

My comments

Nutritionism: Many of the complaints about USDA’s nutrition standards derive from their focus on single nutrients—fat, salt, sugar—rather than on foods. Boiled eggs weren’t allowed because of their fat and cholesterol content, but copy-cat snack foods were.  If the standards applied to minimally processed whole foods, they would make more sense. USDA now has to take comments on whether to eliminate the standard for total fat from Smart Snacks because of the egg issue and the confusing nature of current research on saturated fat (also a problem resulting from studying one nutrient at a time).

Politics:  Regardless of how trivial some of these rules may appear, USDA’s school food standards must be considered an extraordinary achievement.  Against all odds—unrelenting opposition from companies that supply junk food to schools, Congress, and, weirdly, the School Nutrition Association—the new rules will improve the nutritional quality of school meals and snacks, at least most of the time.  School districts with officials who care deeply about improving the food served to kids now have a mandate to do so.  Those who don’t will have a harder time doing a bad job.  Applause to USDA for bringing the rules to closure.  May they survive the next round of lobbying.

 

Jun 29 2016

Brexit: What it means for the food and drink industries

What Britain’s exit from the European Union (“Brexit”) means for food and agriculture is worth attention.

As The Guardian put it,

It is no coincidence that food and drink is at the heart of so much of the debate about whether we are better off in or out of the EU. Worth £80bn a year and employing 400,000 people, it is our largest manufacturing sector and a big exporter and importer. Moreover, 38% of its workers are foreign-born, placing its demand for cheap labour at the centre of arguments about immigration.

The common agriculture policy (CAP) swallows up nearly 40% of the total EU budget…Britain produces just more than half what it consumes and depends on Europe to provide more than a quarter of the rest, while the EU’s population of more than 500 million people provides the UK’s most significant export market for food.

Agrimoney, a London-based concern that reports on commodity markets began its report on Brexit’s impact with these words:

Oh dear.

Tim Lang, professor at City University London’s Centre for Food Policy, told Food Navigator:

People will pay more for food. The British people have voted to raise the food prices…Where do they think their food comes from? Planet Zog?

Bakery & Snacks is especially interested in the meaning of Brexit for the food and drink industries.

It produced a Special Edition highlighting its articles on the topic.

The UK’s decision to leave the European Union goes against the wishes of 71% of the UK food & drink industry, according to a poll by the Food and Drink Federation. William Reed Business Media publications assess the impact for individual sectors such as snacks, confectionery, dairy, bakery and feed as well as food ingredients suppliers. What will Brexit mean for the food, feed and drink industries?

And here is one more.

It’s obvious from reading all this that the effects of the Brexit decision are largely unknown. not easy to predict, but unlikely to be good.  The follow-up will be interesting to watch.

Fingers crossed that the fallout won’t be as bad as predicted.

Additions

  • Bee Wilson’s eloquent elegy for the benefits of European Union food for British palates in the New Yorker
  • Tim Lang’s expanded and referenced discussion in The Guardian
May 17 2016

Congressional (mis)action on child nutrition

First the good news

The USDA is applying its school-food rules  to child and adult care programs.  It has just released its final rule for these programs.  These go into effect in October 2017.

Previously, the USDA released standards for the Women, Infants and Children program and for the National School Lunch Program.

Now all three food assistance programs are more or less aligned with the Dietary Guidelines.

The child and adult feeding programs will specify more fruits and vegetables, less sugar and fat, but have reduce the standards for whole grain-rich products and sodium.  Presumably, this will make the rules more acceptable to people who don’t like them, of which there are many (see below).

And now the bad news

The House has released its child nutrition reauthorization bill, with the Orwellian title: “Improving Child Nutrition and Education Act.”  Like all such titles, this one means the opposite of what it says.

The House bill increases reimbursements for school breakfasts (good), but then lowers the nutrition standards for school meals and makes it harder for schools to qualify for universal free meals.  Here’s the committee’s bill summary.  And here is what the House Education and Workforce Committee says in its fact sheet.

The Hagstrom Report quotes Margo Wootan of Center for Science in the Public Interest saying that the House bill will:

  • Freeze sodium reduction for at least three years.
  • Require yet another scientific review of sodium.
  • Weaken the whole grain standards.
  • Let junk food back into schools
  • Allow schools to replace fresh produce with dried (without a sugar limit), canned (without a sodium or sugar limit), and frozen fruits and vegetables, thereby allowing schools to replace fresh apples and carrots with sugary fruit snacks, potato chips, jam, or trail mix containing candy.

The Center on Budget and Policy Priorities says this bill will increase food insecurity among children.

Fortunately, not everyone in the House loves this bill.  A letter signed by 111 House members details objections.

The House will be working on this bill tomorrow.  What will the Senate do?

School food advocates: it’s time to get busy.  Here’s the list of House members.  Write to yours today!

Nov 25 2015

A retraction and apology

The Journal of Public Health Policy (JPHP) will soon announce the retraction of a Viewpoint—an opinion piece—I co-authored with a Guatemalan physician, Dr. Joaquin Barnoya, “The food industry and conflicts of interest in nutrition research: A Latin American perspective.” Because of factual errors in the piece, and in response to valid objections about the errors from its subjects, they and we requested its retraction and JPHP is doing so.

I believe it is useful to explain how this happened.  In late summer, Dr. Barnoya brought to my attention an advertorial, a sponsored news account, published in el Periódico and other Guatemalan newspapers announcing an alliance among the Central American Bottling Corporation (cbc), the largest beverage distributor in Guatemala and bottler for PepsiCo; the Guatemala-based Institute of Nutrition of Central America and Panama (INCAP); and the U.S.-based Shalom Christian Foundation to distribute a supplemental food product, Mani+, to chronically malnourished children in rural areas (here is a translation of the advertorial).  Mani+ is a sweetened, peanut-based, nutrient-fortified supplemental food made from local ingredients in Guatemala, used to prevent malnutrition in young children.  The advertorial displayed a photograph of the directors of the three organizations holding the agreement.  It also displayed statements from all three directors emphasizing the alliance’s importance in addressing childhood malnutrition.

As readers of this blog should know, I have long been concerned about the conflicts of interest that arise when food companies—especially soda companies—enter into alliances with public health organizations.   The New York Times made the consequences of such alliances clear in its recent revelations of Coca-Cola sponsorship of the Global Energy Balance Network and the fallout from those revelations.  The announced alliance between cbc and INCAP raises similar concerns, particularly in the light of more general food industry partnerships with research and health institutions in Latin America.  Our intention in writing the Viewpoint was to question the appropriateness of this alliance, as well as of other such partnerships and alliances.

We should, however, have exercised more care.  Shortly after publication of the Viewpoint, Carolina Siu Bermúdez, the director of INCAP who appears in the advertorial, wrote to object that our piece incorrectly implied a financial relationship with cbc, and that Dr. Barnoya had failed to disclose that INCAP paid a substantial portion of his salary via a grant from yet another organization.  We also received letters from Dr. Edward Fischer, the founder of NutriPlus/Mani+, Professor of Anthropology and Director of the Center for Latin American Studies at Vanderbilt University, objecting to our statement that the alliance was responsible for manufacturing (rather than just distributing) the product.   Both asked us to retract the Viewpoint.

Upon investigation, we realized their objections had merit.  Indeed, further investigation by us and by the editors of the JPHP exposed additional errors.  Together, these include the following clarifications and corrections:

  • The alliance is involved only in the distribution of Mani+, not its manufacture (as we had asserted).
  • The actual nature of the alliance between cbc, INCAP, and the Shalom Christian Foundation—who does what—is, in fact, unclear. The Viewpoint should have characterized the relationship with less certainty and specified that cbc has no financial relationship with either INCAP or the Foundation.
  • Dr. Barnoya should have disclosed his financial relationship with INCAP, and I should have insisted that he do so.
  • The Viewpoint was triggered by the advertorial, and we should have made this connection more explicit.
  • The reference in the Viewpoint to the advertorial is incorrect. It is listed as (2015) cbc co. Unidos contra la desnutricion. INCAP, cbc y Fundacion Crisitiana Shalom Firman Convenio 23(July): 9.  The correct reference is Alianza Contra la Desnutricion. elPeriódico. July 23, 2015;Advertorial: 9.

To correct and clarify these issues, we would need to revise the Viewpoint.  Doing so, however, is not possible once a paper is published.  That left us no choice but to request a retraction, which I believe is the right course of action in this situation.

In my books and other writing, I try as hard as I can to be precise and accurate.  This incident is a lapse that I regret deeply, for which I take responsibility, and for which I apologize to Carolina Siu Bermúdez, to Dr. Fischer, and to my readers.  I also apologize to Phyllis Freeman and Anthony Robbins, the editors of JPHP, and to Lucy Wheeler of Palgrave, who have set an exemplary standard of ethics and integrity throughout these investigations and discussions.

As for lessons learned: Although I fully intend to continue to write critically about alliances between food companies and public health organizations, I also intend to use this experience to recommit myself to accountability and to diligence in checking and double-checking facts and disclosures going forward.   Again, my deepest apologies.

Addition, December 14: The actual retraction notice is published here.  The discussion on Retraction Watch is here.

Oct 23 2015

100 Mayors Sign Milan Urban Food Policy Pact

This morning, I received this press release from Franca Roiatti in Milan, announcing that on October 15 the mayors of more than 100 cities signed the Milan Urban Food Policy Pact and Framework for Action.  This pact commits these cities—New York among them—to work for more equitable and sustainable urban food systems.

The mayors made 7 commitments, among them working to

  • Develop sustainable food systems that are inclusive, resilient, safe and diverse, that provide healthy and affordable food to all people in a human rights-based framework, that minimise waste and conserve biodiversity while adapting to and mitigating impacts of climate change;
  • Engage all sectors within the food system (including neighbouring authorities, technical and academic organizations, civil society, small scale producers, and the private sector) in the formulation, implementation and assessment of all food-related policies, programmes and initiatives;
  • Use the Framework for Action as a starting point for each city to address the development of their own urban food system and we will share developments with participating cities and our national governments and international agencies when appropriate;

The Framework recommends 37 actions, among them

  • Identify, map and evaluate local initiatives
  • Develop or revise urban food policies and plans
  • Address non-communicable diseases associated with poor diets and obesity, giving specific attention where appropriate to reducing intake of sugar, salt, transfats, meat and dairy products and increasing consumption of fruits and vegetables and non-processed foods
  • Develop sustainable dietary guidelines to inform consumers, city planners (in particular for public food procurement), food service providers, retailers, producers and processors, and promote communication and training campaigns.
  • Explore regulatory and voluntary instruments to promote sustainable diets involving private and public companies as appropriate, using marketing, publicity and labelling policies; and economic incentives or disincentives; streamline regulations regarding the marketing of food and non-alcoholic beverages to children in accordance with WHO recommendations.
  • Those aimed at social and economic equity (cash transfers, school feeding programs, employment, education, training, research).
  • And those aimed at improving food production and reducing waste.

Finally, it comes with an e-book that collects 49 selected good practices from 28 signatory cities.

The point?  Even though everything about this pact and framework is voluntary, these findings and recommendations ought to be enough to give any city mayor a mandate to start working on sustainability issues.

I am looking forward to seeing how New York City uses the report and framework.

Additional documents