A Closer Look At EPA Inspector General's New Strategic Plan

by King & Spalding

On Oct. 4, the U.S. Environmental Protection Agency's Office of Inspector General released its strategic plan for 2019 to 2023. The OIG is charged with the prevention of fraud, waste, abuse, mismanagement and misconduct in the EPA and the U.S. Chemical Safety and Hazard Investigation Board, or CSB. Previously in February 2018, the EPA released its strategic plan for fiscal year 2018 to 2022. Unlike the EPA strategic plan, which differs drastically from the prior EPA strategic plan for 2014 to 2018 and charts a new course for the EPA, the OIG strategic plan largely resembles the OIG’s prior strategic plan for 2012 to 2016. As in the 2012 to 2016 OIG strategic plan, the OIG strategic plan adopts the goals of the EPA and identifies how it will help the EPA perform its stated goals.[1] This article focuses on a few aspects of the OIG strategic plan worth noting for industry and other stakeholders with interest in environmental regulatory enforcement:

  • The OIG will hold the EPA accountable for meeting 2019 targets identified in the EPA strategic plan.

  • The OIG provides less guidance on how it will support other EPA goals, such as rebalancing regulatory power to the states and returning the EPA to its statutory obligations.

  • The OIG will rely on data and business analytics to meet its goals.

  • The OIG characterizes its oversight role as creating value propositions.

  • The OIG reinforces its commitment to staff retention, satisfaction and diversity.

Importantly, the resignation of Inspector General Arthur A. Elkins Jr., which took effect on Oct. 10 of this year, creates the possibility of a subsequently appointed inspector general changing the OIG’s focus. In the meantime, Charles J. Sheehan, who has served as Elkins’s deputy inspector general since 2012, is the acting inspector general, and there has been no indication that he intends to deviate from the OIG strategic plan.

The EPA Strategic Plan Was a Drastic Departure From the Prior Strategic Plan

The current EPA strategic plan is in stark contrast to the prior strategic plan and could be characterized as a repudiation of the prior administration’s vision for an inclusive and proactive EPA. In the new EPA strategic plan, the stated goals reflect a new direction for the EPA:

  • Core Mission: Deliver real results to provide Americans with clean air, land and water, and ensure chemical safety.

  • Cooperative Federalism: Rebalance the power between Washington, D.C., and the states to create tangible environmental results for the American people.

  • Rule of Law and Process: Administer the law as Congress intends, to refocus the agency on its statutory obligations under the law.

Whereas the previous 2014 to 2018 EPA strategic plan included the following goals:

  • Addressing climate change and improving air quality.

  • Protecting America’s waters.

  • Cleaning up communities and advancing sustainable development.

  • Ensuring the safety of chemicals and preventing pollution.

  • Protecting human health and the environment by enforcing laws and ensuring compliance.

Moreover, the “Administrator’s Message” at the beginning of that report reinforced the EPA’s commitment to environmental justice and its “focus on urban, rural and economically disadvantaged communities to ensure that everyone — regardless of age, race, economic status or ethnicity — has access to clean water, clean air, and the opportunity to live, work, and play in healthy communities.”

Gone in the current EPA strategic plan is the goal of addressing climate change or environmental justice, and, in fact, refocusing the EPA on its “statutory obligations” could be interpreted as a repudiation of both of those objectives.

Main Goals of the OIG Strategic Plan

From a high-level perspective, the OIG strategic plan varies little from its prior incarnation, as the stated goals of both plans are largely the same. The similarity between the two plans is not entirely surprising given that Elkins was the inspector general of the EPA when both plans were created. Divided into three primary goals and 13 strategic measures, the new OIG strategic plan outlines the ways in which the OIG plans to provide oversight to the EPA while extending leadership and support.

  • Goal 1: Contribute to improved EPA and CSB programs and operations protecting human health and the environment, and enhancing safety. The OIG plans to perform targeted audits and evaluations that assess the EPA’s processes and procedures, so the programs and operations protecting human health, the environment and safety can be made more effective and efficient. The focus is on being agile while addressing key aspects of air quality standards, clean drinking water, land remediation and chemical safety. Within this goal, OIG creates specific targets for the next five years to increase its impact on laws and regulations regarding human health, the environment and safety, and to reduce environmental risks and challenges.

  • Goal 2: Conduct audits, evaluations and investigations that enable the EPA and the CSB to improve business practices and accountability. The second goal is targeted toward accountability and reducing waste in the EPA. It focuses on assisting the EPA with improving business practices by conducting audits, evaluations and investigations. Under this goal, OIG plans to monitor and review the EPA’s use of operational resources in an effort to promote efficiency while detecting and preventing fraud, waste, abuse, mismanagement and misconduct. Notable here is the focus on mitigating potential for fraud and loss through establishing governance over enterprise risks. The OIG places increased focus on maximizing resources by utilizing automated tools to target investigations. The OIG anticipates using enterprise risk management and internal control assessment tools as well as data and business analytic technology in order to achieve this goal. The OIG makes it a priority to reduce wasteful misconduct not just for the sake of efficiency but with an eye toward proactively creating monetary benefit for the agency.

  • Goal 3: Improve OIG processes, resource allocation and accountability to meet stakeholder needs. The third goal is focused internally toward the OIG itself and is oriented toward ensuring that the OIG is equipped to provide the greatest return on investment. The objectives described within this goal address improving the OIG’s processes, resource allocation and accountability to meet stakeholder needs. Particular focus is given to ensuring that products and services provided to stakeholders and the agency are timely and that high-risk and high-vulnerability items are minimized. Within this goal are also numerous workforce-focused objectives to ensure a well-trained, satisfied and diverse staff. Specific employee-related goals include being rated “above satisfactory” in the Federal Employee Viewpoint Survey and for the majority of employees to indicate satisfaction in working with the OIG as assessed by the “Best Places to Work” score administered by the Partnership for Public Service.

OIG Holding EPA to Stated 2019 Benchmarks

In a document comprised primarily of broad discussion of goals and methods, one of the most explicit statements in the OIG strategic plan is the intent to audit whether the EPA meets its “Agency Priority Goals” for FY 2018 to 2019. Specifically, the OIG will “conduct audits that assess the EPA’s progress toward its goals to implement the following by September 30, 2019”:

  • Reduce the number of nonattainment areas from 166 to 138.

  • Increase by $16 billion the nonfederal dollars leveraged by the EPA water infrastructure finance programs.

  • Make an additional 102 Superfund sites and 1,368 brownfield sites ready for anticipated use.

  • Complete 100 percent of the EPA-initiated Toxic Substances Control Act risk evaluations and risk management actions for existing chemicals and 80 percent of TSCA premanufacture notice final determinations.

  • Reduce the percentage of Clean Water Act National Pollutant Discharge Elimination System permittees in significant noncompliance with permit limits to 21 percent from a baseline of 24 percent.

  • Reduce by 50 percent the number of permitting-related decisions that exceed six months.

To the extent that an EPA stakeholder — including a company being regulated by the EPA — is involved with a project that would further one of the above stated goals, the EPA is likely to respond proactively. Additionally, to the extent that the EPA fails to meet any of the goals above, the OIG may scrutinize any ongoing sites or regulatory actions that played a role in EPA’s failure to meet its goals.

OIG Does Not Specifically Address Other EPA Goals

Notably missing from the OIG strategic plan are concrete measures to support the goals in the EPA strategic plan to (1) rebalance regulatory powers to the states and (2) refocus the EPA to its statutory obligations. In the EPA strategic plan, the EPA emphasizes its intended collaboration with state, local and tribal organizations, addressing the shared responsibility for environmental enforcement actions. The EPA’s “refocus” on its “statutory obligations” likely means a movement away from issues like addressing climate change. The OIG strategic plan does not identify any metrics or goals that it will use to assess whether the EPA is meeting either goal. The OIG strategic plan does indicate that it will conduct “major investigative activities” that will include identifying any “criminal activities related to agency grants and contracts dealing with state revolving funds and interagency and cooperative agreements that help state, local, and tribal governments, universities, and nonprofit recipients; ...”

OIG Will Rely on Data and Business Analytics to Meet its Goals

With spending at the EPA on the decline since President Donald Trump took office and environmental regulation under increased scrutiny, the OIG recognizes that it will have to leverage technological innovation in order to achieve more with less. The OIG places particular emphasis on technological solutions such as the E-Enterprise Web Portal, data analytics and business analytical tools. The OIG strategic plan does not provide great detail on exactly which analytics will be used and how they will be used, but industry and environmental stakeholders can expect to see increased utilization of technological and automated tools by the EPA and the OIG.

OIG Characterizes its Role as Creating a Value Proposition

The OIG states that it will not just support the EPA’s stated goals and promote efficiency, but it will proactively create a monetary benefit through its efforts. The OIG articulates an ambitious plan to create a 20:1 return on investment within the next five years. Whereas previous OIG strategic plans describe creating savings and results, in the new OIG strategic plan, the OIG recognizes the urgent need to create ongoing value in realizing immediate and measurable monetary benefit, thus ensuring the watchdog’s worth and longevity.

For businesses and stakeholders with an interest in environmental regulation, the increased focus on creating monetary benefit likely means increased scrutiny from the OIG, particularly on larger projects where the “return” on identifying any malfeasance would involve larger sums of money.

OIG Will Focus on Staff Retention, Satisfaction and Diversity

Previous OIG strategic plans identify diversity as a priority for its workforce, and not only does the OIG retain that goal, but there is a greater emphasis on the importance of staff retention and satisfaction. The OIG strategic plan provides several measures focused toward quantifiable metrics of workforce satisfaction. This is noteworthy at a time when the EPA has been accused of a “brain drain” as high-level, long-time experts have left the agency and numerous others have admitted concern. Moreover, the EPA’s movement away from environmental justice and a focus on addressing environmental issues that specifically impact communities of color has not gone unnoticed in these communities. The OIG’s commitment to diversity in the workforce conveys an important message to all stakeholders. What remains to be seen is whether this commitment to diversity and workplace satisfaction will continue when and if a new inspector general is confirmed.           

[1] The CSB also periodically issues strategic plans. However, the CSB strategic plans issued during the Obama and Trump administrations are largely unchanged, as is the OIG’s discussion of its CSB oversight in the current OIG strategic plan and the prior incarnation. Accordingly, this article focuses on the OIG report as it relates to the EPA.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© King & Spalding | Attorney Advertising

Written by:

King & Spalding

King & Spalding on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.