Coronavirus - Testing the waters
14 April 2020
The global daily trend of cases is now starting to plateau, as a number of countries are seeing the benefit of government restrictions. Austria, Italy and Spain are tentatively starting to lift some restrictions as they have seen a clear down trend in new cases. Countries around the world will be watching the outcomes carefully and learning from the success and failures of others. Caution will be required as, for example, Hokkaido (Japan’s northern island) has re-declared a state of emergency following a resurgence of the outbreak after restrictions were lifted on 19 March.
• OBR forecasts a 35% contraction to UK’s GDP in June.
• Last week, 47% of all deaths in London were linked to Covid-19.
• India has extended its lockdown until 3 May.
• Spain, Italy and Austria are lifting some restrictions.
• Heathrow Airport predicts 90% drop in passengers in April.
• China could temporarily freeze debt repayments by African nations.
Buildings & Construction
• Marshalls# – “Marshalls has now implemented a detailed operational plan which includes the temporary cessation of certain operations across its manufacturing network. Our operational planning continues to be dynamic and capable of reacting to the changing environment.
We are closely monitoring cash flows to ensure that the business is in a strong position for eventual recovery. Discretionary expenditure is being controlled and non-essential capital expenditure has been deferred. No actions are being taken at the expense of health and safety.
The Group is utilising the Government’s scheme which allows the deferral of tax payments that would normally have been payable in the period to 30 June 2020 and is also utilising the furlough arrangements that are now in place.
Board and Executive Remuneration – With effect from 1 April 2020 until further notice, the Board has unanimously agreed to take an immediate 20 per cent reduction in its remuneration for the duration of the crisis. The effect of this will be to reduce the salary of the Executive Directors by 20 per cent, including pension contributions, salary supplement and 2020 bonus payments which are calculated as a percentage of salary, and to reduce the annual fees of the Chair and Non-Executive Directors by 20 per cent. Other members of senior management have also voluntarily agreed similar reductions.
Bank facilities – Our banking partners, NatWest, Lloyds and HSBC, continue to be supportive. Each bank has confirmed its full support for an additional £30 million, 12 month committed RCF facility to be provided. The discussions held have been positive and, subject to the finalisation of documentation, are now well advanced. We anticipate the documentation process to be completed by the end of April. These additional facilities comprise £90 million in total and will strengthen the Group's headroom as we continue to manage the current situation.
Including these additional facilities, the Group will have total bank facilities of £255 million of which £230 million will be committed.”
• Paragon Banking Group# – “Prior to any Covid-19-related impacts, the business operated in line with the Board's expectations for the period from 1 October 2019 to 31 March 2020, with sustained levels of new lending flows in the Group’s Mortgages and Commercial Lending businesses, a strong pipeline of buy-to-let business and lower redemptions.
Underlying net interest margins continued to improve, tempered by the expected amortisation of the Idem Capital portfolio, where no further purchases were made during the period. Deposit costs have continued to benefit from our strategic actions, including broadening the product range, distribution and scale of market access and were lower at the end of March 2020 than at the end of September 2019. Operating costs are running slightly below expectations and charge-offs remained benign.
However, in spite of the strength of our business, it remains too early to determine the impact that the Covid-19 crisis will have on new business flows, redemptions, income recognition and IFRS9-related impairment charges.
Paragon enters this period of uncertainty with a strong capital base and significant liquidity. The Group's unaudited capital ratios at 29 February 2020 comprised CET1 of 14.4% and a Total Capital Ratio of 16.7%. Its Liquidity Coverage Ratio was 218% as at 31 March 2020.
The Group had effective contingency and resilience plans in place to respond to these developments which has allowed us to focus on supporting and protecting our customers, employees, business partners, capital and the long-term value of our business. Paragon's through-the-cycle experience, robust credit approach, experienced workforce and resilient systems will be crucial as the Group navigates the coming months.
Notwithstanding this strong position, Paragon’s Board is conscious that we are operating in an exceptionally uncertain environment and recognises the importance of its role in supporting its customers, UK businesses and consumers during this period. As a consequence, the Board has decided not to declare an interim dividend with its forthcoming half-year results. The Board also recognises the significance of dividends to its shareholders and will consider an appropriate dividend for the year as a whole with its full-year results in November, when more will be known about the extent of this crisis, as well as the Group’s performance and outlook.”
Food, Drinks & Household
• Brand Architekts (beauty products) – “More than 90 per cent of the Group’s bricks and mortar sales are through grocery and pharmacy retailers. These customers continue to trade and our products continue to be available for consumers to buy. We are seeing fluctuating patterns of sales in response to varying store footfall and in-store operational focus, including changes to in-store promotional activities.
We have noted differences in sales patterns across different product types. Sale volumes of handcare products have increased significantly and we have been able to secure extra supply to support retailer demand whereas, for example, sales of male haircare and shaving products have, unsurprisingly, declined significantly in recent weeks.
Within our International business a number of our General Merchandise and Department Stores’ customers have temporarily closed their doors, which is expected to have a detrimental impact on our sales through those channels whilst lockdowns are maintained.
Online sales, both through large e-tailers and our own branded websites, have increased significantly and we have stepped up promotional activity to capitalise on this route to market.
Combining all of the above, the impact of the Covid-19 situation has resulted in a significant reduction to the Group’s overall sales volumes, however, it does remain a very fluid situation and we are focussed on identifying and securing incremental opportunities as well as managing situations of demand reduction.
Supply Chain – 6 of our 7 UK-based suppliers remain fully operational and we are focussed on adjusting incoming inventory to respond more appropriately to the changes within our volume projections across the portfolio.
All of our suppliers based in China have now returned to normal operation. We have confirmed volumes for our two largest Christmas gift customers and are working through the associated supply plans with our Chinese partners.
Cost Control and Cash conservation - In order to mitigate the possible impact on the business, the Group has taken the following measures to reduce operating costs and associated cash requirements.
We have undertaken a number of short-term reductions on our discretionary expenditure and as part of this, we have also secured a short-term suspension of rent payments on our offices in Teddington.
As all our manufacturing, logistics, R&D and IT functions are outsourced, we currently operate with a lean team of 31 employees and therefore our staff payroll costs are relatively low as a percentage of sales. Whilst we have taken steps to manage staff costs, including the postponement of hiring across a number of current vacant positions. Our team remains fully utilised, managing the ongoing business and developing and adapting the growth opportunities that may arise during, and those that will follow after the government imposed lockdown. We will continue to monitor this closely and respond appropriately to any material change to the trading situation.
As a further step, all the Directors of the Board including our interim Chief Executive have agreed to take a reduction to their respective salaries or fees of 20 per cent at least until the end of this financial year (June 2020).
Balance Sheet and Cash – Our balance sheet remains strong and our available cash balance is £20.1m with a net cash position (including outstanding term loans) of £17.8m, with no material capital expenditure programme to support. Our customer base is made up of major retailers, the vast majority of whom continue to trade and who for the most part, are experiencing strong cash inflows even through lockdown. Whilst we continue to manage our cash resources we are fully confident that our cash position remains secure and indeed positions us well to take advantage of any appropriate strategic or tactical opportunities that may emerge during these fast changing times.
Dividend – Notwithstanding the Group's strong balance sheet, the current environment is one of heightened uncertainty. After due consideration, the Board has decided to suspend the interim dividend for the half year ended 11 January 2020. The Board recognises the importance of dividends to shareholders and, as such, it intends to consider the appropriateness, quantum and timing of this dividend payment when it has a clearer view of the effects and duration of the current Covid-19 situation on the Group’s business.”
• Cake Box – “In the period to 8 March 2020, trading continued to be strong across the Group, with like-for-like sales growth of c.5.1% in franchise stores.
However, the Group saw a reduction in sales across its franchise stores as the Covid-19 crisis developed during the remainder of March 2020. Following updated UK Government advice on 23 March 2020, we decided to close all of our franchise stores as we looked to protect our staff, franchisees and customers and also to help relieve any further pressure on our NHS. As a result of this impact towards the end of our reporting period, total like-for-like franchise store sales growth for the full year to 31 March 2020 was c.2.0% (FY19: 6.5%).
The Group expects to report revenue for the year of c.£18.7m, up c.10% compared to the same period last year despite the disruption experienced in March 2020 from Covid-19. The Board expects adjusted profit before tax to be in the range of £4.1-4.3m (FY19: £4.0m). This figure excludes a £1.4m uplift from the freehold revaluation of the Group's Enfield warehouse and head office which is expected to be included in the Group's statutory numbers.
The Cake Box proposition remains attractive to new and existing customers across the country, offering personalisation, convenience and serving dietary requirements at an appealing price point. The Group is confident that consumers remain loyal to Cake Box and will continue to be so following the lifting of restrictions.
Covid-19 update and support for franchisees – Further to our announcement of 24 March 2020, the Group is exploring all possible routes to support franchisees amidst the current crisis. In particular, we are assisting them in applying for the Government's Retail, Hospitality and Leisure Grant which will provide a significant level of support. We are also providing franchisees with advice and assistance relating to the furloughing of staff, whilst providing flexibility in certain payment terms where appropriate. In addition, we welcome the UK Government announcement that our franchisees will not have to pay business rates for 12 months.
As a result of the above, noting that our franchise stores have relatively low levels of rent and overheads, we are very confident that our franchisees will be able to navigate this unprecedented period. The Group has very healthy stock levels and therefore is well placed to support the reopening of its franchise stores as soon as UK Government advice allows.
At Group level, we are applying to the Government's Job Retention Scheme in relation to Head Office, Warehouse and Bakery staff that have been furloughed due to being unable to work in the business during the current crisis. We are also taking all other appropriate cost saving measures.
New store openings and pipeline – The Group opened 20 new high street stores in the year, including Cardiff, Harlow and Portsmouth, whilst also expanding the successful initial small trial of shopping centre kiosks to 12 locations, operated by local franchisees. The Company ended the period with 133 franchise stores.
The Group has a strong pipeline of new franchise store openings, although there may be an impact on the timing of openings as a result of Covid-19, as there has been during March 2020.
Balance sheet and dividend – As reported on 24 March 2020, Cake Box has a strong balance sheet with a current cash balance of c.£4m. The Group's only debt is a mortgage of £1.6m secured by its freehold properties in Enfield and Coventry.
The Group operates a franchise model and therefore has a relatively low and flexible cost base. Following the cost saving measures described above, the Group expects to have a monthly cash burn of c.£200k while its franchise stores remain shut. The Board is therefore very comfortable with the Group's current cash level and liquidity despite the closure of its franchise stores.
Despite the strength of our balance sheet, the Board feels that it is not appropriate to recommend a final dividend for FY20 with the Group’s full year results. At a time when there is so much uncertainty, it seems inappropriate to use the cash for anything other than protecting the financial strength and resilience of the business. The Board recognises the importance of income to many of the Group's shareholders and will continue to assess when it is appropriate to recommence dividend payments.”
• Chemring – “In the US, the UK and Norway, Chemring’s operations have been designated as critical to the defence and national security industrial base, and in Australia the risk of business interruption is considered to be low. All our businesses remain open, with business continuity plans mobilised at every location. We continue to make every effort to maintain delivery of essential services and manufacturing production in support of our customers.
Customers – We are proud of the essential contribution that Chemring makes to the ongoing defence and national security missions of our customers and we are committed to supporting them throughout this crisis.
As disclosed in our trading update on 4 March 2020, the Group has a strong order book with order cover for the 2020 financial year of almost 90% at that time. Since that announcement order placement has continued including the recent receipt of a $17m order to supply countermeasures for the F-35 Joint Strike Fighter programme; work under this contract will be carried out at our facilities in Tennessee and Australia.
Our manufacturing businesses continue to work closely with their customer representatives to deliver timely testing and acceptance of products. To date we have worked through some CV-19 related disruptions where customer representatives have not been able to complete product acceptance procedures on a timely basis and going forward this presents a risk of some short term revenue deferrals. Our wide geographic and customer base provides some mitigation to this potential short-term risk.
Financial position and mitigating actions – The Group has committed revolving credit facilities (‘RCF’) totalling approximately £150m. These facilities mature in October 2022, with a two-year extension option. The Group's current level of net debt is approximately £84m, comprising current cash balances of c.£33m and drawings under the RCF of £108m. In total the Group therefore has available liquidity of approximately £73m.
The financial covenants associated with the RCF are Net debt:EBITDA of less than 3.0x and Net interest cover greater than 4.0x. At the last measurement date of 31 January 2020, the actual covenants were 1.18x and 15.6x.
Given the uncertainty surrounding the length of the CV-19 pandemic, the Group has taken various actions to protect profitability and to conserve cash. Operational expenditure has been reduced and all discretionary spending is tightly controlled as we seek to ensure the Group is well placed to navigate the current challenges. The already established enhanced focus on working capital management, in particular the reduction of intra-period net debt volatility, is proving beneficial and the Group is focusing on ensuring working capital disciplines are maintained in these challenging times.
Dividend – The Group’s FY19 final dividend of 2.4p (£6.7m) was approved by shareholders at the Annual General Meeting on 4 March 2020. The dividend will be paid on 24 April 2020 to those shareholders who were on the register on 3 April 2020.
Outlook and guidance – The duration and impact of CV-19 across our home markets is at this stage unknown, and we are clearly working in a changing and more challenging environment. We will continue to work closely with our customers and other stakeholders, and will provide further updates as appropriate.
In the longer term, Chemring is well placed, with a robust strategy, market-leading positions across different geographies and sectors, and with products and services that are critical to our government and blue-chip customers. This, together with the Group's strong balance sheet, gives the Board confidence that despite the near-term uncertainty, Chemring's long-term prospects remain strong.”
• Ultra Electronics – “All facilities remain open and productive, and there has been no significant disruption to product or programme delivery.
Current Trading – Trading in the first quarter of 2020 was broadly in line with our expectations with good underlying order book, revenue, profit and cash performance.
Demand in our defence markets and most of our critical detection and control markets remains robust. Our supply chains are also proving generally stable, and we are working to mitigate and provide support as necessary where we see isolated issues. Production inefficiency associated with changing working patterns has so far been kept to a minimum.
We also remain focused on driving transformation across Ultra and we made good progress on the key initiatives in the first quarter.
Whilst Ultra is currently operating broadly as normal, as a result of the rapidly changing environment caused by Covid-19 we have developed a response plan with detailed actions to mitigate any possible profitability, liquidity and cash flow challenges that may arise. Currently we do not see any material deterioration in trading that merits the need to initiate any of these actions. We are therefore continuing to invest in Ultra where we see opportunities to improve the long-term growth prospects for the business and remain focused on delivering our order book. We will continue to keep the situation under constant review.
Liquidity and balance sheet position – The liquidity of the Group is strong, with significant cash and access to our £300m Revolving Credit Facility (‘RCF’), the majority of which is committed to November 2024, along with long-term committed Private Placement debt of £50m and $70m, as well as other smaller uncommitted short-term overdraft facilities. At 31 December 2019 the Group had committed liquidity available of £296.7m comprising cash of £82.2m and £214.5m of undrawn RCF.
At 31 December 2019 the Group's net debt (excluding IFRS 16) was £113.6m. The net debt to EBITDA covenant on our debt facilities is 3.00x (on a pre-IFRS 16 covenant basis) and is tested on a rolling twelve-month basis at 30 June and 31 December. At 31 December 2019 our net debt to EBITDA was 0.86x (on a pre-IFRS 16 covenant basis) and further improved in the first quarter.
Full Year Dividend – Ultra has an exciting strategy for value creation, is financially very robust and continues to trade broadly in line with expectations. The Board is, however, mindful of the uncertainty as to the duration and impact of further disruption from Covid-19. As a precautionary measure the Board has therefore decided to delay payment of its 2019 final dividend by withdrawing the proposed recommendation to pay a final 2019 dividend of 39.2 pence per share from the resolutions being put at the forthcoming AGM. Based on the Board's current knowledge, it intends to pay an additional interim dividend of the same amount in the second half of 2020. The Board will keep this under review as the Covid-19 pandemic unfolds.”
• Mitchells & Butlers – “All sites have now been closed for over three weeks, and a number of actions have been taken to reduce our cost base: • Over 99% of employees have been put on furlough, with basic pay for all employees including the Board reduced to between 60% and 80%, depending on seniority.
• Operating costs have been reduced to the minimum required to keep the estate secure, safe and in good condition.
• Discretionary capital expenditure projects have been stopped.
It is possible that the forced closure of our sites, as required by the Government, could amount to a technical breach of our secured financing arrangements but, as a first step, we are announcing today that a temporary waiver until 15th May has now been granted to avoid this pending further discussions.
Great uncertainty remains not only as to the extent of the current shutdown but also the profile of any reopening and recovery period back to normality. In light of this the group is in close contact with stakeholders, with whom it has strong relationships and who are supportive of the long-term fundamentals of the business.
The group has material cash resources which we believe should be sufficient to fund obligations well into the second half of the year.”
• Revolution Bars# – “Following the UK Government’s announcement on 20 March 2020 to temporarily enforce the closure of all pubs, nightclubs, restaurants and cafes, the Group has been rapidly implementing actions to help mitigate the impact of closure and preserve cash. These measures include: • Protecting the welfare of 2,775 furloughed team members (98% of the Group’s workforce) through accessing the UK Government's Coronavirus Job Retention Scheme, enabling future retention of employment for these employees whilst delivering a considerable payroll saving.
• CEO, CFO and Non-Executive Directors salaries reduced by 50% and implementing significant salary reductions for senior employees remaining in work.
• Receiving the Government-backed twelve-month business rates relief.
• Deferring all PAYE and VAT payments from 18 March 2020 for three months.
• Assistance from suppliers regarding contract suspensions and extended credit and payment terms.
• Negotiations with landlords regarding rent relief.
• All capital expenditure cut.
These measures have significantly reduced the Group’s weekly running costs to approximately £0.4m per week and management continues to seek further cost reduction opportunities. Costs will be kept to a minimum until the Group's bars can reopen given the ongoing uncertainty as to the length of the enforced closure period and how trading may be impacted by any ongoing restrictions when trading is able to recommence.
The Group has also renegotiated the completion terms of the transaction to surrender five leases to its landlord Aprirose that was originally announced on 15 January 2020. The completion payments have been reduced from £3.64m to £2.25m and deferred payment terms agreed for more than half of the reduced amount, which saved a cash outflow in March of £2.8m (includes VAT).
Additional debt facility – As previously announced on 18 March 2020, the Board has been exploring all funding options available to the Group. This has included discussions with its lending bank, Natwest. The Group's Revolving Credit Facility (the ‘Facility’) runs to December 2021 and currently is for £21.0m but due to step down to £18.0m at the end of June 2020 consistent with the Group's strategy and successful execution of reducing debt. Following the impact of Covid-19, as at the end of last week (11 April 2020), the Group had net bank debt of £17.8m.
The Board is pleased to announce that, subject to final documentation, Natwest has agreed to increase the Facility to £30.0m until 31 August 2020, following which it will step down to £24.0m as the Group begins to benefit from its normal positive working capital cycle following an assumed recommencement of trade in July 2020. Natwest has also agreed to waive all financial covenant tests at March and June. Given the prevailing level of uncertainty regarding both the timing of being able to reopen the Group's bars and the trading environment in the post Covid-19 period, Natwest has indicated it will review both the amount of available Facility and the covenant tests applicable from the end of September 2020 by reference to the Group's updated trading forecasts closer to that date, however, as demonstrated by the agreed increase in the facility, they remain supportive of the Group.
The additional Facility, agreed on normal commercial terms, will provide additional liquidity, headroom and financial flexibility to support the business through these challenging times.”
• Hochschild Mining – “Announces that in light of the ongoing uncertainty caused by the Covid-19 outbreak and the resulting temporary suspension of the Company's operations, the Board of directors (the ‘Board’) has decided to withdraw its proposal to pay a final dividend in respect of the financial year ended 31 December 2019.
The Board believes this is a prudent course of action reflecting the Company’s focus on the conservation of cash resources. When the Board is in a clearer position to assess the overall financial impact of the Covid-19 outbreak on the business, a decision will be taken on the appropriate level of any future shareholder distribution. The cash and cash equivalent balance at 31 December 2019 was $166 million with net debt of $33 million.
Both the Inmaculada and Pallancata mines in Peru remain temporarily suspended following the Peruvian government's recent decision to extend social restrictions until 26 April 2020. In Argentina, whilst permission has been granted by the government to restart the San Jose mine, in light of the current restrictions on the movement of people in the country, the Company expects the ramp-up to be phased over a number of weeks. Details on the Company's performance during the first quarter will be provided in the scheduled production report on 22 April 2020.”
• Fletcher King – “The business performance for the first 11 months of the financial year has been in line with the Board’s expectations and consistent with the update given in the Interim Statement in December 2019. Performance for the full year to 30 April 2020 is not currently expected to be materially affected by the current crisis.
Looking further ahead, whilst there is huge uncertainty caused by the Covid-19 virus, it seems increasingly likely that the wider economic impact will be severe and prolonged. In this scenario, transaction-based fees such as investment deals and bank valuations are likely to be materially lower than would otherwise be expected. The progress of rating appeals is also likely to be further delayed. Property management activity (which is a core service of the Company) is not expected to be affected to the same extent, although fees may come under pressure should there be a significant decline in the collectability of rents from tenants in client properties (the Property Management team has been successful in collecting 85% of rents for the March quarter by the due date, compared with normal achievement of 99%). The Company is grateful for the support of its loyal clients who have been with the Company for many years.
Fletcher King is in a good position to withstand the current crisis and continues to have a strong balance sheet with no debt.
The Company will continue to monitor the Covid-19 situation and its potential impact on the wider economy and the Company's business and cash flows. Once our Annual Results to 30 April 2020 are available, we will consider whether a final dividend is appropriate, and if so, at what level.”
• Next – “On Thursday 26 March NEXT announced it had temporarily closed its Online business along with its Warehousing and Distribution Operations, having listened very carefully to colleagues.
NEXT has since implemented very extensive additional safety measures and having consulted with colleagues and our recognised union, USDAW, it will re-open Online in a very limited way from today, Tuesday 14 April 2020. Initially only categories that our customers most need will be offered, such as Childrenswear and selected small Home items. Other product ranges may be added at a later date.
Operations will start with support from colleagues who are willing and able to safely return to work. The idea is to begin selling in low volumes, so that we only need a small number of colleagues in each warehouse at any one time, helping to ensure rigorous social distancing is complied with.
To achieve these limited volumes, NEXT will only allow customers to order the number of items that it believes can be picked safely on any given day. At that point we will then stop taking orders and convert the website to ‘browse only’ until the following morning.”
• dotdigital – “Best estimates show a slight softening of revenue this year, however we expect to deliver consensus earnings and cash for the full year to 30 June 2020. The impact of a prolonged Covid-19 lock down on customers is harder to forecast, impacting our ability to be more precise about mid to long term guidance. We believe the strong fundamentals of the Group remain unchanged, with a proven contracted recurring revenue business model and strong financial position. We remain confident in our ability to continue to deliver against our strategic growth pillars.
Operational trends – Messaging volumes and omnichannel usage (predominantly SMS) from existing customers are continuing to grow. There is some evidence of new business being affected both by lead flow volumes, due to cancellations of tradeshows/events, and decision deferral. Inevitably temporary closures by customers in some industries has had an impact but this is being mitigated in part by customers’ digital transformation related decisions having slowed, resulting in a reduction in the usual level of natural churn. In summary, there has been an expected slowdown of new business wins, but also an increased customer loyalty which plays to our core services and business model.
Robust financial position – The business has 90% recurring revenues (of which 90% is contracted), giving us strong future revenue visibility. We achieve a high operating margin and enjoy good operating cost flexibility. Cash at the end of March was on target at £22.0m with zero debt. Customers come from a diversified mix of industry types and company sizes, with no client representing more than 1.5% of revenue. Stress test modelling gives a high level of confidence that we could, if required, maintain our business model through a prolonged global downturn.
Actions taken – All of our 340 employees worldwide have now transitioned to home working. Staff engagement is high. There has been minimal operational impact and customer support teams, engineers and sales and marketing are all fully functioning. Business continuity plans are tested, working and scaled. As ever, operating costs are closely scrutinised, and all discretionary spending has been curtailed.”
• IDOX# – “Idox along with most companies has been impacted by the emerging Covid-19 pandemic. We continue to assess the impact of the Covid-19 pandemic on the business, taking actions to mitigate or limit the impacts on our organisation where we can and supporting our staff, customers and partners in dealing with the emerging situation. As part of the preparation of our FY19 results, the Group has carefully assessed the likely impact of the Covid-19 pandemic on our business and considered specifically changes in the way we engage with our customers, staff, supply chains and banking partners. Idox is fundamentally resilient to the Covid-19 pandemic due to the Group’s high recurring revenue base, its focus on public sector markets and the high proportion of staff that routinely work from home. The Group retains significant liquidity with cash and available committed bank facilities and has strong headroom against financial covenants. We continue to monitor the situation as it continues to evolve and adapt our approach as required.”
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