Публична комуникация
Public Communication
Milka Semova
Bulgarian Association of CSR Professionals
and OECD National Contact Point workgroup
E-mail: milka.semova@gmail.com
Abstract: This theoretical research asks the question What forms of policymaking and protest lead to social changes nowadays? Social movements for social responsibility are a vast topic and numerous examples with different outcomes can be given from all five continents. This article aims at giving an overview of the global
understanding of sustainable development and a structural approach to analyzing advocacy and protest campaigns. Methods are content analysis of law, administrative documents prepared by international organizations, content analysis of publications in authoritative media as well as desk research concerning definitions of basic concepts. The hypothesis is that socially responsible behavior is as much governmental as organizational and individual responsibility. There are socio-economic and political systems that rely on direct democracy. Their citizens actively take part in national and federal referendums on issues concerning quality of life and public services, commonly referred to as social issues. The recommendations are that additional research could use combined heuristic and mathematical methods to suggest a system for measuring the vulnerability of political, economic, and technological environments towards social risks, to achieve higher levels of prioritization be regions and crisis prevention.
Keywords: sustainable development, socially responsible behavior, global reporting initiative, and corporate sustainability standards.
Introduction to sustainable development
Sustainable development goals (SDG), derived mostly from the 1987 Brundtland Report, are a call for action by the United Nations to promote prosperity while observing human rights and protecting nature. The goals are grouped in 17 areas and are bound by 169 achievement criteria, to be reached by 2030. They include measures against poverty and hunger, the improvement of education and health systems, the promotion of economic development, active actions against global warming, and the destruction of forests and oceans. The implementation of the Sustainable Development Agenda requires a global partnership of UN member states to coordinate and show solidarity with the most vulnerable communities.
Figure 1. Understanding sustainable development
Source: Rosen, Marc A., Hossam A. Kishawy (2012) Sustainable
Manufacturing and Design. Sustainability, vol. 4, issue 2
The UN Sustainable Development Agenda requires socially responsible behavior from governments, organizations and individuals, regardless of the socio-economic and political systems. Citizens in direct democratic systems are the ones who most actively take part in national and federal referendums. These referendums (quarterly in Switzerland, for instance) are typically preceded by broad information campaigns. Direct democratic federal governance and the socially engaged national mindset are among the pillars of building a strong civil society. Direct democracy is the type of democracy where the wide participation of citizens in politics is guaranteed.
Besides direct democracy, we also observe representative democracy and constitutional democracy depending on their cluster around different values. Representative democracy is an indirect democracy where sovereignty is held by the people’s representatives. Constitutional or Liberal democracy is a representative democracy with the protection of individual liberty and property by rule of law. Overall, democracy is a governing system based on the belief in freedom and equality among people in which power is either held by elected representatives or directly by the people themselves.
In this overview of sustainable development stakeholders, we claim future development should include improved quality of the dialogue among key players, common goal setting supported by legal alignment, decreased transaction costs, specialized financial aid, administrative capacity, and quality control where there is just registration control.
Top-down leadership: policymaking
Although different international bodies such as the United Nations and the OECD aim at ensuring a better socio-economic environment globally, countries are still working on achieving basic virtues such as protecting human rights, preserving nature, decreasing corruption, and preventing the economy from money laundry practices. The text in this section is an attempt at a chronological overview of the global sustainable development policymaking.
After WWII
The United Nations, founded in 1945 in the aftermath of the Second World War, consists of 193 member states and aims to maintain international peace and security. Its six main bodies are the General Assembly; the Security Council; the Economic and Social Council; the Trusteeship Council; the International Court of Justice; and the UN Secretariat. The UN System includes a multitude of specialized agencies, funds, and programs such as the World Bank Group, the World Health Organization, the World Food Program, UNESCO, and UNICEF. Its officers and its agencies aim at protecting, respecting, and remedying and have won many Nobel Peace Prizes. Yet the UN has been praised as the ultimate force for peace and human development or condemned as ineffective, biased, or corrupt. The UN unites 193 member states plus 2 observer states as of Q1 of 2022.
The OECD was established after WWII in 1948 to administer the Marshall Plan for establishing democracy and a market economy and allocating United States financial aid to post-war states in Europe. It is recognized as a highly influential publisher of mostly economic data through publications as well as annual evaluations and rankings of the 38 member countries as of Q1 of 2022. The OECD Human Development Index is a statistic composite index of life expectancy, education, and per capita income indicators, which are used to rank countries into four tiers of human development: very high, high, medium, and low. Official Development Assistance is a term coined by the Development Assistance Committee of the OECD in 1969 to measure aid. It is widely used as an indicator of international aid flow, including some loans.
In the 3rd millennium
The Business Social Compliance Initiative is neither an auditing company nor an accreditation system. BSCI provides companies with a social auditing methodology. BSCI is the European system of social monitoring for ethical security established by the Brussels-based Foreign Trade Association in 2003. The BSCI system is based on the labor standards of the International Labor Organization and supports the continuous improvement of the social performance of suppliers. The BSCI Code of Ethics aims to comply with certain social and environmental standards.
The goal of the G7 (Group of Seven) is to achieve a fair social contract with comprehensive strategies, net-zero, and the measurement of non-financial risks and opportunities. It was founded in 1975 in France at the initiative of French president Giscard d’Estaing and his German counterpart Helmut Schmidt. It brought together the representatives of six countries: Italy, Japan, the United Kingdom, the United States and, of course, France and West Germany, leading to its original name Group of Six or G6. In 1976, after the admission of Canada, it was renamed the G7 and after 1997, when Russia was invited to join, it was known as the G8. Russia’s membership was suspended in 2014 due to the Crimea crisis.
To include the 5 leading emerging economies (Brazil, China, India, Mexico, and South Africa) a separate sub-group was formed in 2005, it was known as the G8+5.
At the G8 summit in Scotland, an endorsement of the Action Plan on Climate Change, Sustainable Development and Clean Energy was reached, and it was decided to collaborate on the development of clean energy technologies.
In 2012, the G8 nations collectively constituted over 50% of global nominal GDP. In 2018, now the G7 countries’ global net wealth was more than 60%, totalling 317 trillion USD.
Another sub-organisation worth mentioning is the Y8 or the Youth of Eight. It assembles young leaders from the G8 nations and the European Union to aid discussions of international affairs, build global relationships and encourage cross-cultural understanding.
Environmental, social, and corporate governance (ESG) is a set of standards and metrics for a company’s operations that socially conscious investors use. The term was first used by UN Secretary-General Kofi Annan in 2004 in correspondence to 50 CEOs of major financial institutions, inviting them to participate in a joint endeavor to integrate ESG into capital markets. The initiative was held under the patronage of the United Nations Global Compact, the International Finance Corporation, and the Swiss Government.
The New Development Bank, formerly referred to as the BRICS Development Bank, is established in 2014 by the BRICS states (Brazil, Russia, India, China, South Africa). The Bank supports public and private projects. The BRICS members are known for their significant influence on regional affairs and gather for regular meetings since 2006 (South Africa became an official member in 2010). The member states have the following competitive advantages, alphabetically: Brazil is the world’s warehouse; Russia has immense energy supplies; India is the outsourcing hub, China is the factory of the world; South Africa is rich in natural resources such as gold and diamonds. The New Development Bank is focused on investing in BRICS countries to strengthen their economies via energy cooperation and sustainable development, helping with youth development programs, and coming up with resolutions on migration and peacekeeping [1].
Standard setting and reporting
The Global Reporting Initiative transitioned from advising to setting standards in 2016, when Standards have been strengthened so they deliver the transparency for impacts on the economy, environment, and people, by updating the very foundation of the world’s most widely used sustainability reporting standards.
The SA8000 is based on internationally recognized standards of decent work, including the Universal Declaration of Human Rights and International Labor Organization conventions created in 1997 by the Social Accountability International (SAI). SA8000 applies a management-systems approach to social performance and emphasizes continual improvement, rather than checklist-style auditing. SA8000 consists of the following elements: (1) child labor; (2) forced or compulsory labor; (3) health and safety; (4) right to collective bargaining; (5) discrimination; (6) disciplinary practices; (7) working hours; (8) remuneration; (9) management system. SA8000:2014 is the current version of the SA8000 standard.
ISO 26000:2010 guides the relationship among the organization, its stakeholders and society, on recognizing social responsibility and on ways to integrate socially responsible behavior into the organization (Clauses 1, 2, 3 and 5) in Figure 2, below. Its principles are given in Clause 4. Clause 6 elaborates the core subjects of social responsibility as (1) organizational governance; (2) human rights; (3) labor practices such as employment relationships, social dialogue, and health and safety at work; (4) the environment; (5) fair operating practices; (6) consumer issues; (7) education and awareness; (8) community involvement and development, which represents a much broader version of SA8000 standard. Clause 7 elaborates on the implementation of the standard within the organization, its communication and document workflow.
Figure 2. Schematic overview of ISO 26000
Source: ISO 26000:2010
The EU’s policy is built on its 2011 renewed strategy for Corporate Social Responsibility, which aims to align European and global approaches to CSR. On 23 February 2022, the European Commission published a proposal for a directive on corporate sustainability due diligence, or the European Union’s corporate social responsibility legislation. The objective of EU-level CSR regulation is to promote respect for human rights and the transition toward a carbon-neutral economy. Another objective is to provide a level playing field and legal certainty for businesses operating in the European Union.
In the report, World Giving Index 2021 of the Charity Aid Foundation, the USA ranks 19th, the UK – 22nd, the Netherlands – 39th, Bulgaria – 45th, Russia- 67th, Switzerland – 97th, and France – 106th out of 114 surveyed countries. Indonesia, Myanmar, Australia, and Thailand are the countries with the highest percentage of donors (83-60%). People in Indonesia, Tajikistan, Kenia, and Nigeria participate more than anyone as volunteers for social causes (60-42%). People from Nigeria, Cameroon, Iraq, Georgia, Zambia, Kenia, and Uganda are most willing to help a stranger (86-75%). The overall index points to the Indonesian, Kenyan, Nigerian, Myanmar, and Australian nations on top of the list of most empathic nations. Overall, data found that more than three billion people helped someone they didn’t know in 2020.
Bottom-up leadership: social movements for social responsibility
We define social movements as loosely organized but sustained campaigns in support of the implementation of prevention of a change in society’s structure or values [2]. Similar is the definition for social protest: a form of political expression that seeks to bring about social or political change by influencing the knowledge, attitudes, and behaviors of the public or the policies of an organization or institution [3]. In addition to the above two definitions, we would also refer to social pressure as the rational argument and persuasion (informational influence), calls for conformity when people change only their behaviors but not their beliefs (normative influence), and direct forms of influence, such as demands, threats, or personal attacks on the one hand and promises of rewards or social approval on the other (interpersonal influence). [4] We will need all the above definitions when thinking of bottom-up leadership for social responsibility.
The proposed impact measurement methodology would require data on the following 12 factors: (1) continent; (2) country/state; (3) human development index of the country/state; (4) social issue; (5) period; (6) official government information campaign or initial position; (7) social claims and advocacy outreach; (8) protest campaign scope; (9) government’s immediate response to social pressure; (10) following response and undertaken legal measures; (11) percentage of companies reporting ESG or CSR in the country/state; (12) existence or not of a national strategy on sustainable development.
Existing statistical data sources which could be potentially useful for monitoring and measuring social responsibility include national UN Global Compact networks, OECD Human development index division, the Corruption perceptions index of Transparency International, S&P ESG data for corporations.
These indices are interrelated, e.g. the Corruption perceptions index is regularly lower in democratically governed countries and higher predominantly in low-income countries.
Other global indices can also be used for indirect measurement of national sustainable development practices: Ease of doing business index, Global competitiveness index, Index of economic freedom, Press freedom index, Political rights index, Civil liberties index, Property rights index, Prosperity index, Happiness Index.
Figure 3. The quadruple managerial model, ensuring sustainable development
Source: Semova, Milka (2021). How to build alumni relations:
because investing in alumni matters. Amazon.
EuroMonitor, BioMonitor, CSR Europe, Human Rights Watch, The World Giving Index by Gallup International and the Charity Aid Foundation are among the organizations that use the “hybrid approach” of looking into social matters and serve as initiators of strategic dialogue as given in Figure 3 below.
Successful models and case studies from all aspects of social responsibility should be publicly promoted from top to bottom via effective promotional campaigns. Also, effective systems to escalate social issues from bottom to top should be set in place [5] to avoid long-term industry blockings from social protests.
Upon setting national targets for socially responsible industry, corporations may follow these six strategic planning steps: (1) quantity baseline; (2) understanding alignment with the latest CSR directives; (3) analyse future risk scenarios; (4) set science-based targets aligned with global goals; (5) report progress; (6) finance ambition [6]. The following change management of the organizational culture: (1) identifying the need for change; (2) craft a vision and plan for change; (3) implement the changes; (4) embed changes within company culture and practices; (5) review progress, analyse results and outline goals for future development.
Benchmark case studies: social priorities by continent
A selection of myriad case studies on sustainable investing is available at many private equity firms (Bain, KKR, LeapFrog Investments, Partners Group), impact specialist firms (Big Society Capital, Calvert Impact Capital, Closed Loop Partners, FullCycle) diversified asset managers (BlueOrchard, Nuveen, Prudential Financial, UBS), and development finance institutions (CDC Group, EBRD, FinDev Canada, Finnfund). Yet, how often are governments and industries ready to hear the civic society’s voice and by what means? It seems that evermore thanks to the latest technologies which allow real-time information flow.
The leading auditing companies for socially responsible business conduct – SGS, TÜV SÜD, TÜV NORD, Intertech, Bureau Veritas and Eco Vadis – can also be used for representative data by industry or by geographical region.
North America
For five years, Greenpeace has been campaigning against Kimberly-Clark, which produces Kleenex, Scott, Huggies and Pull-Ups wipes, accusing the company of destroying virgin forests to produce disposable products. When they reached an agreement in 2009, Greenpeace made a clever video to mark the reconciliation. Today, Kimberly-Clark and Greenpeace continue to work together [7].
In 2017 Nestlé sold its US and Canadian bottled water brands to a private equity firm for 4.3 billion USD. The division has been under constant attack from communities in the US that argue the food giant is draining local water sources and profiting from it. The company sold its water business in Brazil in 2018 amid similar criticism [8].
Europe
In 2012 after broad public discussions, social media advocacy campaigns and live protests, Bulgaria, the Czech Republic, and Romania made a U-turn in their approach to shale gas exploration [9]. Critics say shale gas drilling can poison underground (mineral) water and even cause earth tremors, although industry experts say correct drilling is safe.
In 2016, Contour Global in partnership with Coca-Cola Hellenic Bottling Company implemented a signature innovation in several countries from Western Europe to Poland. The combined-heat-and-power plants supply the bottling factories with less expensive and environmentally-friendly energy. With this technology, the CO2 emissions are reduced by 95% or more than 80,000 tons a year [10].
In 2017, France’s parliament passed a law to ban the production of oil and gas in all of its territories by 2040. No new permits for extracting fossil fuels can be issued and no existing licenses can be extended past the deadline. The measure is considered symbolic as France only extracts 815,000 tons of oil per year – an amount produced in Saudi Arabia in a matter of hours. UN Secretary-General Antonio Guterres said that the intergovernmental report on climate change was “code red for humanity and countries should also end all new fossil fuel exploration and production, and shift fossil fuel subsidies into renewable energy”.
In 2020, in an effort to become climate neutral, Denmark agreed to ban new exploration and end oil and gas production in the North Sea by 2050. Denmark is one of the largest producers in the continent, extracting more than 7,000,000 tons of oil per year [11]. French and Danish example was followed by ecological movements leading to the end of oil exploration in Belize Barrier Reef, Spain, and Ireland.
Germany intends to reduce primary energy consumption by 20% by 2020 and 50% by 2050 compared with 2008. This transformation has been envisioned in the country’s Renewable Energy Sources Act. It has put in place a new tariff that obligates grid operators to pay for renewable energy fed into the electricity supply.
Due to strong human rights movements, numerous multinational corporations and sports organizations joined the campaign to isolate Russia’s economy following Russia’s invasion of Ukraine on 24 Feb. 2022. G7 governments and other political alliances that support the current security architecture arrangement in Europe, also combined efforts to influence the outcome of the war. Yet, despite the heavy sanctions, Russia insists on “a comprehensive agreement, which, in addition to Ukraine’s neutral status and security guarantees, provides some points vital to our country – demilitarization, denazification, recognition of Crimea and Donbas, as well as several other points” [12]. Among the heavy governmental and private economic restrictions on Russia, intended to restore peace, as a basic prerequisite for sustainable development, were:
- SWIFT, the global member-owned cooperative and the world’s leading provider of secure financial messaging services, banned transactions of seven Russian banks (Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, Vnesheconombank, and VTB Bank)
- Formula 1 terminated the Russian Grand Prix contract in Sochi
- British Petroleum sold its 20% stake in Rosneft by taking a USD 25 bln writedown [13]
- Airline software giant ended distribution service with Russia’s Aeroflot, crippling the carrier’s ability to sell seats [14]
- German and Austrian railways Deutsche Bahn and ÖBB provided free transport for refugees entering via the Schengen internal borders of Hungary and Slovakia, as well as via the Czech Republic (coming from Poland) only against a Ukrainian identity document. Should refugees plan to continue to a next destination, the railways provide a free second-class ticket [15]
- Swiss government broke the country’s traditional neutrality by adopting EU sanctions against Russia [16]
- The USA and its NATO allies have imposed several rounds of sanctions, including targeting the country’s largest lenders, more than 40 defence companies, and 400 other Russian entities, as well as more than 300 Parliament members [17]
Asia
The pandemic gives Asian states an excuse to clamp down on the opposition, but it will also allow protesters to build stronger solidarity with their communities [18]. Anti-racism, feminism and labor movements are the most common ones on the continent. In India, millions protested the Citizenship Amendment Bill, a law explicitly excluding Muslim migrants from becoming citizens that was rushed through Parliament in the last month of 2019. “The right to assemble peacefully has been suspended for now,” said Thomas Fann, chairperson of Bersih 2.0, a Malaysian non-profit coalition calling for fair and free elections.
In March 2018, China’s legislature passed the Supervision Law, granting extremely broad investigative powers to a new anti-corruption agency – the National Supervision Commission [19]. The second-biggest economy, China, has long fought against corruption and improved the country’s ranking on the Corruption perceptions index of Transparency International.
In April 2019, a bill was proposed allowing Hong Kong citizens to be extradited to China. The news was met with a series of protests that lasted for months and led to the withdrawal of the discussed legal changes. In response to the protests, the United States passed a federal law on human rights and democracy in Hong Kong, obliging the US government to impose sanctions on China in case of human rights violations at Hong Kong’s borders.
Africa
Scholars of social movements and global protest have long-neglected social movements in Africa, supposedly because African societies are too rural. Despite that local governments have practiced huge surveillance of Pan African activists and grassroots organizations [20], African youth is rising for justice, peace, and dignity, dissatisfied with their elites. The non-profit organization African Arguments at the end of 2020 even comments that “the extraordinary success of mass mobilizations on the black continent stands in striking contrast to their declining effectiveness in the West” [21].
Latin America
Networking and cooperation between the social movements of Latin America is nothing new, as it has always existed. Discussion of collective action is not rare in the Latin American academic literature, yet only in recent years have more systematic and comparative works on this topic begun to proliferate, challenging the predominance of single-case qualitative studies. Argentina is contrasted with Chile, where high institutional quality, according to the argument, allows citizens to use institutional channels for voicing grievances [22].
We cannot talk about regional social priorities anymore
Sometimes the study of social movements seems to portray dramatic actions as though they are self-contained and not set in a historical frame or global frame. It is crucial to confront questions as to where movements initiate and why. Ideally, decision-makers and legislators would be able to focus and allocate resources to prevention promptly.
If we look at any sustainability crisis from a corporate point of view, the need for a true global dialog becomes obvious. With the expanding globalization, responsibility doesn’t lie anymore, just within the individual business entity as the whole supply chain networks are affected. A single member in a global supply chain who is not socially responsible may affect the sustainability of the whole supply chain and can therefore damage the reputation of other companies that are linked to the end product or service.
It seems that world leaders understand that peacekeeping and sustainable development are inseparable. But when it comes to putting words into action, the result is often not convincing. The obstacles result from a combination of human greed, political short-term thinking, the unwillingness of governments and companies to speed up the realization of common objectives, and political instability. Additional research could use combined heuristic and mathematical methods to suggest a system for measuring the vulnerability of political, economic, and technological environments towards social risks, to achieve higher levels of prioritization be regions and crisis prevention.
References and Notes
[1] New Development Bank information portal. (20 March 2022). Goa declaration at 8th BRICS summit. BRICS. https://www.ndb.int/. Retrieved in 20.03.2022.
[2] Killian, L. M. (2020). Social movement definition. Encyclopedia Britannica.
[3] Loya, L. & McLeod, D. (2020) Social protest definition. Oxford Bibliographies.
[4] Social pressure definition. (2022). American Psychological Association. Dictionary of Psychology.
[5] EU Directive for the Protection of Persons Reporting Irregularities. (2019). European Parliament.
[6] S&P Global Market Intelligence. (2022). Get your company started on the road to sustainability. https://www.spglobal.com/. Retrieved in 20.03.2022.
[7] Skar, Rolf (2014) What Greenpeace learned from five years with Kimberly-Clark. Greenpeace.
[8] Plüss, J. (2021). When companies sell off their problem child. SwissInfo. (20.02.2021).
[9] Daborowski, T. & Groszkowski, J. (2012). Shale gas in Bulgaria, the Czech Republic and Romania: political context – legal status – outlook. Center for Eastern Studies.
[10] Marshall, G. (2016). Contour Global – Coca-Cola Partnership for CHP Development. Energy Live News.
[11] Frost, R. (2022). The end of fossil fuels: Which countries have banned exploration and extraction? EuroNews. (14.01.2022).
[12] Medinsky, Vladimir (2022) No Moscow-Kyiv deal with Russian concerns unaddressed: negotiator. XinhuaNet. (25.03.2022)
[13] Hurst, L. & Ross-Thomas, E. (2022). BP to Exit Rosneft Stake and May Take a $25 Billion Hit. Bloomberg. (27.02.2022).
[14] Toh, M., Ogura, J., Humayun, H., Yee, I., Cheung, E., Fossum, S. & Maruf, R. (2022). The list of global sanctions on Russia for the war in Ukraine. CNN. (28.02.2022).
[15] Germany and Austria announce free train transport for Ukrainian refugees. (2022). Brussels Times. (27.02.2022).
[16] Keaten, J. (2022). Sanctions vs. neutrality: Swiss fine-tune response to Russia. Associated Press. (27.02.2022).
[17] Pettypiece, Shannon (2022) The U.S. announces new Russian sanctions, plans to admit thousands of Ukrainian refugees. NBC News. (24.03.2022).
[18] Coca, N. (2020). What’s next for Asia’s social movements? The Nation. (13.05.2020).
[19] Client Alert (2018) China’s New Anti-Corruption Agency Will Wield Broad Powers. Morrison & Foerster. (20.03.2018)
[20] Vienna Institute for International Dialogue and Cooperation (2020). Social Movements in Africa. Mobilization in the Middle of a Pandemic. (18.11.2020).
[21] Faupel, A. & Wojtanik, A. (2020). What the rest of the world can learn from Africa’s protest movements. African Arguments. (16.12.2020).
[22] Krausova, A. (2020). Latin American Social Movements: Bringing Strategy Back. Latin American Research Review. 55(4), 839–849. DOI: http://doi.org/10.25222/larr.1398.
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ISO 26000:2010
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Killian, L. M. (2020). Social movement definition. Encyclopedia Britannica.
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Marshall, G. (2016). Contour Global – Coca-Cola Partnership for CHP Development. Energy Live News.
Medinsky, Vladimir (2022) No Moscow-Kyiv deal with Russian concerns unaddressed: negotiator. XinhuaNet. (25.03.2022)
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Skar, Rolf (2014) What Greenpeace learned from five years with Kimberly-Clark. Greenpeace.
Toh, M., Ogura, J., Humayun, H., Yee, I., Cheung, E., Fossum, S. & Maruf, R. (2022). The list of global sanctions on Russia for the war in Ukraine. CNN. (28.02.2022).
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Sustainable Development: Driving Factors and Impact Measurement – Milka Semova
Manuscript was submitted: 12.03.2022.
Double Blind Peer Reviews: from 14.03.2022 till 28.03.2022.
Accepted: 29.03.2022.
Брой 51 на сп. „Реторика и комуникации“, април 2022 г. се издава с финансовата помощ на Фонд научни изследвания, договор № КП-06-НП3/75 от 18 декември 2021 г.
Issue 51 of the Rhetoric and Communications Journal (April 2022) is published with the financial support of the Scientific Research Fund, Contract No. KP-06-NP3/75 of December 18, 2021.