*Watch an “AQ Q&A” interview on this topic, featuring two leading scholars in Peru: Miguel Santillana and Cynthia Sanborn.
*Access an AQ study guide for this article.
China’s huge appetite for energy and minerals to fuel its expanding economy has strained international markets for oil, natural gas, iron ore, coal, copper, nickel, aluminum, and other resources. To satisfy China’s hunger for raw materials, Chinese companies, backed by the government, have been acquiring
equity stakes in natural resource companies, extending loans to mining and petroleum investors, and writing long-term procurement contracts for oil and minerals in Africa, Latin America, Australia, Canada, and other resource-rich regions.
In fact, more than half of Chinese foreign direct investment (FDI) in natural resources is in Latin America. It is concentrated in 34 major projects that stretch from Venezuela and Ecuador through Brazil, Bolivia and Peru to Argentina and Chile. Since China launched its “going out” strategy, encouraging companies to become more competitive, total Chinese FDI in Latin America has increased nearly sevenfold, from $226 million in 2003 to $1.6 billion in 2009.1
As Chinese FDI in Latin America has grown, so have concerns about the practices of Chinese companies.
Egregious violations of international labor and environmental standards, particularly in the mining sector, have been uncovered in Chinese-led investments in the Democratic Republic of the Congo, Angola and Zambia, to name a few examples. And persistent allegations of corruption and bribery offer an additional cautionary note for Latin American policymakers. “China has difficulty regulating what its companies do abroad,” writes Cynthia Sanborn of Peru’s Universidad del Pacífico, who has conducted an extensive study of Chinese investment in Latin America. “There are no incentives for Chinese leaders to take a stand on social and environmental responsibility.”
The controversial activities of Chinese companies abroad underscore the larger question about the implications of such a huge investment—and its impact on individual countries and the region as a whole. How can host-country policies in Latin America be structured (and enforced) to achieve the most benefit from Chinese resource investments—while ensuring that those benefits do not cause harm?
Moreover, the sheer volume of the investment raises a political question not just for Latin America but for its traditional trading partners. It has aroused concern that Chinese efforts to procure raw materials might be exacerbating the problems of strong demand—locking up natural resource supplies, gaining preferential access to available output and extending control over the world’s extractive industries.
The Risk of Resource Monopoly
Will Chinese investments in Africa, Latin America and elsewhere enhance Chinese ownership and control within a concentrated global supplier system—in effect, locking up an ever larger portion of the world’s resources for China? Or will Chinese investments in natural resources help expand, diversify and make the global supply base more competitive? Evidence from Chinese investments in Latin American resource industries, added to evidence about Chinese resource investments in other parts of the world, can show which outcome is most likely.
The Chinese deployment of capital to procure natural resources takes four forms.
1) Chinese investors take an equity stake in a large, established producer to secure an equity share of production on terms comparable to other co-owners.
2) Chinese investors take an
equity stake in an up-and-coming producer to secure an equity share of production on terms comparable to other co-owners.
3) Chinese buyers and/or the Chinese government make a loan to a large, established producer in return for a purchase agreement to service the loan.
4) Chinese buyers and/or the Chinese government make a loan to finance an up-and-coming producer in return for a purchase agreement to service the loan.
These four structures provide the basis for defining what it means to tie up supplies. If the procurement arrangement simply solidifies the legal claim to a given structure of production (numbers one and three above), tying up or gaining preferential access to supplies has zero-sum implications for other consumers. If the procurement arrangement expands and diversifies sources of output more rapidly than growth in world demand (numbers two and four), the zero-sum implication vanishes as all consumers, including Chinese purchasers, have easier access to a larger and more competitive global resource base.
Previous research by the Peterson Institute for International Economics (PIIE) shows a few instances in which Chinese natural resource companies take an equity stake to create a “special relationship” with a major producer.2 But the predominant global pattern (13 of 16 projects) is to take equity stakes and/or write long-term procurement contracts with the competitive fringe.
Of the 34 Chinese natural resource investments and procurement arrangements we studied, 25 help diversify and make more competitive the portion of the world natural resource base located in Latin America. (For a description of all 34 projects go to www.americasquarterly.org/piie.)
The preceding analysis holds some good news for Latin American host countries, since it suggests that Chinese investors will be more willing to take on new frontier or even fringe projects that the major established oil and mining companies might pass by. But this potential benefit will be overshadowed by bad news if it turns out that the economic, social and environmental framework within which Chinese companies operate is different from—and inferior to—the best-practice standards that the established oil and mining companies typically maintain.
Individual host countries in the developing world may be exposed to the resource curse: practices of illicit payments, graft and corruption, plus poor worker treatment and lax environmental standards. The UN Commission on Trade and Development’s World Investment Report notes that non-OECD investors—most prominently Chinese investors operating under the doctrine officially labeled as “noninterference in domestic affairs”—have often undermined hard-won governance standards observed by multinational corporations subject to home country legislation that conforms to the OECD Convention on Combating Bribery (including the U.S. Foreign Corrupt Practices Act), engaged in poor labor practices, and ignored or bypassed the best-practice environmental standards insisted upon elsewhere.3
A recent report by the Economic Commission on Latin America and the Caribbean (ECLAC) summarizes the dynamics of the economic relationship between China and Latin America. Over the past decade, Latin America has become China’s most dynamic trading partner, with exports and imports growing twice as fast as those of any other region [see figure 1]. From the perspective of Latin America, China has become a major trading partner, potentially displacing the European Union as the region’s second-largest partner in the next few years. In 2010 China also became the third-largest foreign investor in the region, after the U.S. and the Netherlands, with a 9 percent share of total FDI.4
Figure 2 (p.52) illustrates the dominance of the natural resources sector in Chinese investment in Latin America. Our case study focuses on the mining sector in Peru, which is China’s fourth-largest destination for investment in the mining sector (second in Latin America) during the period from 2003 to 2011 [see figure 3, p.53].
Four Mines in Peru
Peru’s experience with foreign mining companies offers an insight into the question of whether there are clear differences with regard to labor, environmental and other practices between Chinese-owned and managed resource projects and similar projects owned and managed by OECD-headquartered investors.
Peru—the leading Latin American producer of gold, lead, silver, tellurium, tin, and zinc, the second-largest regional producer of copper, and a country with an open foreign investment regime—is host to a number of foreign mining companies. In 2009, mining accounted for 6 percent of GDP and 60 percent of total exports, and made up over 20 percent of Peru’s $19.4 billion inward FDI.5 Currently, according to Peru’s investment authority, over 80 percent of Peru’s 2010 FDI stock in the mining industry was sourced from OECD countries [see figure 4, p.54].
Our structured comparison includes two OECD-owned mining companies: the Yanacocha gold mine, which started operations in 1993; and the Compañía Minera Antamina, Peru’s largest operational copper-zinc mine, which started operations in 2001. We also examine two Chinese investments: Shougang’s 1992 purchase of Hierro Peru and Chinalco’s acquisition of the Toromocho mine in 2008. The cases were selected because they involved large investments (roughly similar in magnitude) and each pair included one case that began operations during the Fujimori period and one that began operations after the return to democracy.
The OECD Investments
Yanacocha, Peru’s largest gold mine and located in the Cajamarca region, is co-owned by Peruvian Buenaventura, S.A. (43.6 percent), U.S.-based Newmont Mining Corp. (51.3 percent) and the International Finance Corporation (5.1 percent). It was privatized in 1993.
Yanacocha’s early history is spotty. Newmont Mining Corp. was accused of not properly consulting with, and failing to obtain consent from, local communities before initiating operations. Newmont executives also faced accusations of bribery—notably involving Fujimori’s intelligence head, Vladimir Montesinos. The company also was fined for a serious mercury spill in 2000 that poisoned an estimated 900 people; cases relating to this continue to be brought against Newmont. In 2004, a proposed expansion generated massive public protest and the company suspended further exploration.
Newmont has worked to overcome its negative reputation by placing greater emphasis on community relations and the environment, undertaking community-oriented corporate social responsibility (CSR) projects and undergoing international certification in environmental and social standards.
In Peru’s Ancash region, Antamina, a joint venture among four OECD-based companies (Xstrata, BHP Billiton, Teck, and Mitsubishi, with 33.75, 33.75, 22.5, and 10.0 percent ownership, respectively), is seen as the gold standard for Peru in terms of community relations, CSR and stewardship of workers and the environment. Antamina weathered some early bumps in the road. A bungled relocation effort and a plan to build a road through nationally protected parkland were the target of much negative domestic and international attention. The latter plan was ultimately abandoned in favor of a costlier and cumbersome—but less controversial—plan to build a new pipeline. Since then, Antamina has built a reputation for strong community outreach and CSR programs and fair treatment of workers and the environment.
While Antamina’s record is clearer than Yanacocha’s, both are seen as upholding international standards of corporate behavior. Both companies comply with international human rights, environmental, transparency, labor, and anti-corruption standards. Both support the Extractive Industries Transparency Initiative (EITI), which has worked to set a global standard for transparency in the extractive resource sector; belong to the International Council on Mining and Metals (ICMM), dedicated to improving sustainable development performance in the mining and metals industry; and are members of the UN Global Compact, which encourages businesses to adopt sustainable and socially responsible policies.
Within Peru, they participate in the Grupo de Diálogo Minería y Desarrollo Sostenible Perú, an interagency initiative that brings together different actors in the mining industry to work on issues such as transparency, sustainable development and responsible management. Both are also major contributors to Peru’s Programa Minero de Solidaridad con el Pueblo (PMSP), a voluntary contribution in lieu of greater mining royalties. Antamina has 423 PMSPs registered with the Ministry of Energy and Mining, and contributed $46 million to this fund in 2010; Yanacocha contributed $29 million through 85 PMSPs across Peru. Antamina is ranked highest (94.5 percent) among 39 companies surveyed by Propuesta Ciudadana, a Peruvian civil society watchdog group focused on PMSP transparency; at 77.5 percent, Yanacocha ranks fourth. Both companies have fulfilled their concession obligations and, according to the Superintendencia Nacional de Administración Tributaria (SUNAT), the Peruvian tax authority, they pay their taxes on time.
Both Antamina and Yanacocha make information on their operations easily available and appear frequently in the press. Antamina has an extensive website in English and Spanish, which includes annual reports and sustainability reports; detailed information on its operations and expansion efforts; personnel policies, including its code of conduct, work opportunities and worker accommodations; environmental programs; health and safety issues; and social responsibility programs.
Yanacocha makes information available in Spanish and Quechua, including through its radio station, Radio Yanacancha. Yanacocha’s website also includes annual reports and sustainability reports, information on operations, company statements on its social and environmental principles, and information about social funds and projects.
With regard to labor practices, Antamina offers the highest wages in the industry at all levels; Yanacocha’s wages are also high for the industry. Neither has been accused officially of labor infractions or of violating Peru’s regulations on foreign workers (no more than 20 percent of total workers can be foreign). Both companies have programs to promote local hires and hold training programs for workers at all levels, and both have adequate housing and facilities for laborers and their families. Antamina underwent an extensive expansion of its facilities in 2010.
Both companies have joined the Voluntary Principles on Security and Human Rights, which set guidelines for managing the risks and impacts of business activities and for relations with government security agencies and private security firms. Both have instituted a grievance system—a key measure recommended by the ICMM. And both have been certified under International Organization for Standardization 14001 environmental and Occupational Health & Safety Advisory Services 18000 health and safety standards.
Yanacocha is certified under AccountAbility’s AA1000 CSR standards. Antamina has won several industry prizes for social and environmental responsibility. In 2009 Antamina was the first Peruvian company to receive a grade of “A” for its sustainability report from the Global Reporting Initiative. According to Pablo de la Flor, Antamina’s vice president of corporate affairs, this “reflects [Antamina’s] policies of environmental responsibility, stakeholder obligations, industrial security, transparency and sustainability.”6
Both companies have created a foundation to run their CSR activities and Antamina has a designated CSR/community relations manager. Antamina’s Ancash Association has developed projects in education, tourism, organic agriculture, fishing, and conservation of natural resources with an investment of $1.25 million in 2010. Antamina also launched a $2.25 million extraordinary fund to support sustainable development in the region. Yanacocha’s social programs concentrate on infrastructure development and programs to develop productive activities, particularly in farming and livestock in Cajamarca.
The China Investments
Peru is the site of China’s first investment in Latin America: the Shougang Group’s 1992 purchase of state company Hierro Peru. It is also the site of one of its newest: the Toromocho mine, owned by the Aluminum Corporation of China (Chinalco) and scheduled to start operations in 2013.
The Shougang Corp. is one of China’s oldest industrial companies and its fourth-largest steel company. Shougang was originally hailed for investing in territory still controlled by the Shining Path, for taking over a financially troubled major mine and for being the first company to invest in an uncertain business environment following the April 1992 Fujimorazo, or self-coup.
However, questions were soon raised about Shougang’s corporate behavior. Shougang’s bid for Hierro Peru exceeded a private company’s valuation of the property by a factor of fourteen. It was also found that Shougang did not fulfill an important element of the concession agreement: a promise to invest $150 million in the community over three years.7 Instead, Shougang invested $35 million and paid a $14-million fine, rather than investing the agreed balance. Three commissions set up to investigate Hierro Peru’s privatization concluded that irregularities in the privatization warranted further study and that Shougang had failed to fulfill its commitment to the community.
Shougang also angered the local population by cutting the Peruvian workforce in half and bringing in Chinese laborers. It reduced the quantity and quality of workers’ housing, while leaving blocks of homes once occupied by workers vacant in a town with an acute housing shortage. According to a source familiar with the situation, “Rather than providing new and better houses, the Chinese took the existing houses and divided them so that where one family or worker was living, now there were two or three. They did not follow local (let alone international) labor standards, did not invest in social funds and had some environmental issues.”8
At an average of $14 a day, Shougang’s wages are among the lowest in Peru’s multi-billion-dollar mining industry (according to calculations based on data from the International Labor Organization, the national average is $29 a day for wage earners). Labor relations have also been contentious: Shougang has been fined for outdated and unsafe equipment, and the company was cited in the International Trade Union Confederation’s 2007 Annual Survey of Violations of Trade Union Rights for brutal repression of a trade union demonstration.
Shougang has also been fined for shirking health regulations. In Peru, mine workers are obliged to undergo annual examinations, and if lung disease is found, this must be reported and the employee must be moved to a less risky environment.9 A 2006 inspection by OSINERGMIN, Peru’s mining investment regulatory agency, found that 12 percent of Shougang’s workforce had unreported pneumoconiosis—a fact that Shougang refused to acknowledge.
Shougang was fined for environmental damage after the 2002 collapse of tailings thickener installations contaminated water supplies in Marcona and surrounding areas, and was accused of pumping waste water into the nearby San Nicolas Bay, where its deepwater port is located. In March 2006, the Ica regional government declared a state of “environmental emergency” in San Juan de Marcona, a largely symbolic measure enacted to protest Shougang`s activities. As of 2011, Shougang was listed by the SUNAT as being delinquent in its tax payments.
Shougang’s website contains much less information than that of Antamina or Yanacocha’s, although a July 2011 redesign provides much more information than the previous version. The site does not contain annual reports or sustainability reports, and though the section on social support gives a definition of the PMSP, it offers no information about Shougang’s activities. Shougang was ranked 32nd out of 39 companies in Propuesta Ciudadana’s ranking of companies in terms of transparency with respect to disbursement of social funds.
Shougang has seemingly fulfilled the worst expectations of Chinese companies—firing locals and bringing in Chinese workers at low wages in substandard conditions, showing little concern for health, safety or environmental considerations.
While Shougang was long China’s largest investment in Peru, it was surpassed by Chinalco’s $2.2 billion purchase of the Toromocho mine in 2008. Toromocho, still in the construction phase, is scheduled to begin operations by the end of 2013.
Chinalco appears to be working to avoid the behavior of Shougang. The company has received praise for its handling of the relocation of the town of Morococha, offering guaranteed housing and a compensation sum that has been accepted by the majority of the population. An environmental impact assessment was approved in December 2010, and, as part of these proceedings, Chinalco has conducted public hearings with the local community. In 2010 Chinalco contracted a Canadian firm to implement an Environmental Information Management System.
Chinalco has not imported labor from China; in fact, the company largely left in place the management team of the previous owner, Peru Copper, a Canadian company. Until December 2010, the company’s president was a Canadian who had previously worked at Antamina. Chinalco has begun to comply with its concession agreement, funding development programs for the surrounding region through the Fondo Social Toromocho.
Chinalco is also investing in infrastructure for the local community through an agreement with the transport and communications ministry and a Colombian firm whose website lists projects in education, health and productive development. Through the government’s investment body, Proinversión, Chinalco has also set up a social fund, the Asociación Fondo Social Toromocho, with an initial commitment of $1 million. Chinalco’s website lists among its objectives the environment, health, education, and productive development, and contains a section on corporate social responsibility. According to Miguel Santillana, principal researcher at the Instituto del Perú, Chinalco has so far behaved much more cautiously and transparently than did Shougang, and with more involvement of civil society.
Comparing the Cases
Several factors lead to differences in the behavior of OECD-based firms versus Chinese firms in Peru.
One key factor is the period of the initial investment. Both Yanacocha and Shougang invested in Peru during the Fujimori era, whereas Antamina and Chinalco began operations after the return to democracy. There has been an evolution in Peru’s attitudes toward business and civil society. In the 1990s, the focus was primarily on privatization, and the voice of businesses dominated; but in the 2000s civil society has played a much greater role. The decentralization process has also granted regional governments a larger role, and both domestic and international NGOs have increased their vigilance and voice. As a result, in the 2000s, the state was under greater pressure to enforce labor, environmental and social standards.
Figure 5 (p.57) shows how Peru has changed since the 1990s. The increased scores on “voice and accountability” show the greater roles of civil society actors and the significant increase in political stability. However, the drops in “government effectiveness” and “control of corruption” are worrying. The former illustrates one reason why mining companies in Peru attract so much attention and are under such pressure to provide the public goods that government does not.
A second factor is the evolution of international norms constraining the behavior of transnational companies. There has been a sea change in attitudes and regulations between the two periods studied, with NGOs leading the way to push for more stringent standards on human rights, labor, the environment, transparency, and anti-corruption.
The 1997 OECD Convention on Combating Bribery, adopted by 34 OECD countries and 4 nonmember countries, criminalized bribery of foreign public officials in international business transactions. ICMM began promulgating best practices in international mining operations in 2001, and the extractive industry transparency initiative was launched in 2002–2003, highlighting the need for revenue transparency.
A third factor is the evolution in Chinese policies toward the rest of the world—specifically toward Latin America. While nonintervention continues as a guiding principle, China has been sensitive to criticism and eager to be seen as a responsible international investor. In its 10th Five-Year Plan (2001–2005), the Chinese government pledged to “[perfect] its economic laws and regulations to increase its policy transparency” and proposed the establishment of “a system that complies with international practices.”10
In 2002, then-Chinese President Jiang Zemin’s Report to the 16th Congress outlined the goal to “keep economic development as the central task and solve problems cropping up on our way forward through development,” taking into account “resources and the environment” and the need to “promote all-around social progress.”11 In 2008 the Chinese government released its first Policy Paper on Latin America and the Caribbean, which elaborated a number of goals designed to assuage host country fears. The first goal is to “promote mutual respect and mutual trust and expand common ground. Based on the Five Principles of Peaceful Coexistence, China and Latin America and the Caribbean will treat each other as equals and respect each other.”12 In investment cooperation, the Chinese government pledges to encourage investment by “Chinese companies with a good reputation” to “promote the economic and social development of both sides.” For their part, international NGOs and their local counterparts have expanded dialogue and joint cooperative initiatives with international investors, replacing a purely confrontational stance in earlier periods.
Fourth, the Chinese are interested in long-term investments and expanding their presence in Peru. As a senior executive at Antamina observed, “The Chinese have become more active recently, taking majority stakes in various resource companies in Peru. It appears that they want a greater say in operations, which is a transition away from their historically passive role. With Chinese companies becoming more active, the danger then becomes the knowledge gap regarding local labor and social relations, and the related activism that takes place at the local level.”13
One major difference between Shougang and Chinalco is that the former has unusual autonomy from the Chinese government, while the latter is a central state-operated enterprise—accountable to the state-owned Assets Supervision and Administration Commission of the State Council—and must adhere more closely to Chinese governmental directives. Chinalco has also reportedly secured a $21 billion loan from the China Export and Import Bank and will thus be subject to that entity’s standards; these were revised in the mid-2000s to focus more on compliance with international standards on the environment and social responsibility.
Shougang has recently announced a major, $1 billion expansion of operations for which it secured a $240 million syndicated loan from a consortium of banks, including Citibank, BCP, HSBC and Santander—thus necessitating greater accountability to international creditors than was true for the initial purchase.
There has also been a learning process as China gains experience investing abroad. One Chinalco official who did not wish to be named said, “There has been a negative perception of Chinese FDI in Peru since Shougang, but Shougang is an outlier—it was the first Chinese investment in Latin America during the previous generation of investments. The Chinese are interested in investing much more in Peru and are therefore committed to change, adhering to best practices and sustainable investment.”
Subsequent Chinese investors have been able to learn from Shougang’s experience. “There is a learning curve for Chinese companies and all mining companies have learned from the case of Shougang,” says Xiaohuan Tang, general manager of Jinzhao Mining in Peru. “It is a good platform for understanding how to do business in Peru.”14
Shougang itself has apparently learned from its own mistakes. The relationship with the local community has been slowly improving. Large-scale strikes, previously commonplace at the Shougang Hierro Peru mine, have been absent for the past year and a half.
China is also starting to overcome its Latin American culture shock. “It’s hard for the Chinese to understand the large influence and power of the peasants in Peru,” says Richard Graeme, senior vice president and general manager at Lumina Copper SAC, a consortium of the Chinese companies Minmetals and Jiangxi Copper. ”The Chinese are used to top-down management, [whereas] Peru functions more along the lines of a bottom-up approach. Learning how to work in Peru is a cultural quantum leap for China.”15
Lessons and Policy Implications
What can the Peruvian government do to encourage firms to behave more like Antamina and less like Shougang? How can it avoid repeating the experience of several countries in Africa? Compared to African countries, Peru appears to be in a relatively strong position in terms of levels of transparency, according to Transparency International’s annual index of corruption perceptions for all African and Latin American countries with gold, copper or iron ore mining. Peru’s score of 3.5 is about average for Latin America, but better than all but five African countries.16
Our research has found that Chinese investment in Latin America predominantly expands and makes more competitive the global resource base. Chinese investors tend to be more willing to take on new frontier projects that others pass up.
This good news could turn to bad, however, if Chinese companies, traditionally guided by a principle of nonintervention, are not held to high standards. International standards have become more stringent over the past decade in terms of labor and environmental practices, transparency and control of corruption and community outreach and support.
A company such as Yanacocha, which began with a problematic record in terms of community outreach, questionable practices and environmental issues, has in the past decade brought its practices up to international standards. Antamina, which began operations in the 2000s, has consistently helped set the standards in Peru. Shougang Hierro Peru, which does not participate in international forums, nor is it accountable to shareholders, has shown far less evidence of changed behavior. However, its expansion, financed by external creditors, will be a proving ground. Chinalco, under the guidelines of China’s new policies toward foreign investment, shows efforts to meet international standards.
The bottom line is that how natural resource investors behave in a market depends on a number of factors—not just the source of the investment, though that matters as well, especially when it is in a country that has few mechanisms for transparency and accountability.
Here are several lessons that can be drawn from the Peruvian experience.
Financial Markets Bring Accountability. Investors that have to withstand scrutiny as they register their equity, raise capital and seek multilateral assistance in international markets tend to adopt defensible standards, or face reputational risk. Supporting groups that monitor the activity of corporations helps to shed light on both positive and negative practices and helps encourage constructive behavior.
The Host Country Regulatory Environment Makes a Big Difference. The business environment, along with tolerance of civil society participation, was very different before and after the Fujimori regime in Peru, and companies’ behavior reflects this. Chinese investor behavior in some African countries reflects the inability or unwillingness of leaders to set or to enforce corporate behavior guidelines. Over the course of our research, weak institutional capacity and political will were cited repeatedly as factors limiting the potential for a positive development impact.
Foreign Investment Is a Catalyst for Change. Using foreign investment in the extractive sector for broad-based national development has some of the attributes of a public good: international standards (e.g., International Finance Corporation, ICMM); support for capacity-building and enforcement of said standards (e.g., Multi-Donor Trust Fund, Revenue Watch); and institutions to provide credible monitoring (e.g., EITI, Global Witness, Publish What You Pay) are needed to shape the pure play of market forces. Antamina in Peru is an example of this, often mentioned by other companies and by Peruvian officials as forging the path for others to follow. In the words of David Splett, Antamina’s vice president for finance, “Companies can fulfill a significant role in a country when institutional and social weaknesses exist. Antamina is an excellent example of what companies can do in helping communities address social and infrastructure needs. But to do this there needs to be significant leadership provided at the executive level to set the standards.”
Access the endnotes and appendices.