2024-05-16T15:49:11-05:00 2023-09-30 BDO USA 200 PARK AVENUE 38TH FLOOR NEW YORK NY 10166 990 2022-10-01 900080500 ENVIRONMENTAL DEFENSE ACTION FUND % N LOUIS MKANGANWI ENVI 2125052100 257 PARK AVENUE SOUTH NEW YORK NY 10010 N Louis Mkanganwi CFO 2125052100 2024-05-16 true N Louis Mkanganwi 999009999 Paul Hammerschmidt P01384178 2128858000 2 2022 2023-04-26 12:10:37Z David Kieve 257 PARK AVENUE SOUTH NEW YORK NY 10010 19959256 false X WWW.EDFACTION.ORG X 2002 DE TO EDUCATE THE PUBLIC REGARDING ENVIRONMENTAL & CONSERVATION ISSUES AS WELL AS ADVOCATE LEGISLATION & POLICIES THAT PROTECT THE ENVIRONMENTAL RIGHTS OF ALL PEOPLE. 20 20 0 2388 0 0 29002795 19821920 0 0 1376 118573 20436 17647 29024607 19958140 2283236 750108 0 0 4238136 4802109 0 0 433679 23200837 13193084 29722209 18745301 -697602 1212839 6474489 6517593 2545065 1375473 3929424 5142120 X TO EDUCATE THE PUBLIC REGARDING ENVIRONMENTAL AND CONSERVATION ISSUES AS WELL AS ADVOCATE LEGISLATION AND POLICIES THAT PROTECT THE ENVIRONMENTAL RIGHTS OF ALL PEOPLE. false false 12933629 4983583 0 CORE CAPACITIES AND EDUCATION - Environmental Defense Action Fund (EDF Action) leverages deep expertise in science and economics to drive sweeping change through advocacy and focused engagement in communities most impacted by climate change. 1997753 294300 0 STABILIZE THE CLIMATE - The Environmental Defense Action Fund (EDF Action) is the advocacy partner of the Environmental Defense Fund (EDF). The two organizations take on different roles in achieving common objectives. EDF supported research, scientific analysis, and policy positioning, and EDF Action's primary purpose is to engage in advocacy, education, lobbying and legislative work. In 2023, EDF Action defended progress at the federal level, fighting back threats to the Inflation Reduction Act and the Bipartisan Infrastructure Law, as well as at the state level including supporting water conservation policies in the southwest, methane emission reduction measures in oil and gas states, and promoting clean air through better oversight and mitigation. At the federal level, EDF Action worked to protect limits on methane pollution, advocated for robust policies to advance transportation electrification, supported policies to reduce emissions from agriculture in partnership with farming allies, advanced legislative and regulatory changes to preserve healthy fisheries and oceans, and made strides on reducing air pollution that disproportionally impacts frontline communities. As part of this process, EDF Action and its partners held over 947 meetings with members of Congress in 2023; spent over $700,000 in paid advertising to build public support clean energy and the environment; generated nearly 200,000 emails to Capitol Hill; and managed earned media events in target states to support key priorities. EDF Action continued to invest in building a robust grassroots membership capable of advancing policy priorities including state commitments on clean energy and implementation of the Inflation Reduction Act and Bipartisan Infrastructure Law. 1833963 27500 0 Strengthen People's and Nature's Ability to Thrive - EDF Action works to ensure that communities across the country can withstand existing climate impacts while building their resilience as the climate changes. 702633 0 0 17467978 false true true true false false false false false false false false false true true true true false false false false false false false false false true false true false false false false false false false false false false false false false true false false true 83 0 true 0 false false false false true true false false false X 20 20 false false false false true true true true true false false false true true true true true false false false AL AK AR CA CO CT FL GA HI IL KS KY ME MD MA MI MN MS MO NV NH NJ NY NC ND OH OK OR PA RI SC TN UT VA WA WV WI X X N LOUIS MKANGANWI 2125052100 257 PARK AVENUE SOUTH NEW YORK NY 10010 X FREDERIC D KRUPP EXECUTIVE DIRECTOR 4.0 36.0 X 0 1134624 58170 N LOUIS MKANGANWI CHIEF FINANCIAL OFFICER 4.0 36.0 X 0 300789 27387 DAVID KIEVE PRESIDENT 36.0 4.0 X 0 219846 7539 ASHLEY LOUGH SECRETARY 36.0 4.0 X 0 59028 3636 SUSAN FORD DORSEY CO-CHAIR THRU 5/23 / DIRECTOR 2.0 2.0 X X 0 0 0 CODDY JOHNSON CO-CHAIR 2.0 0.0 X X 0 0 0 ELIZABETH B STRICKLER CO-CHAIR 2.0 2.0 X X 0 0 0 FRANK LOY CHAIR EMERITUS 2.0 2.0 X X 0 0 0 THOMAS F DARDEN II DIRECTOR 2.0 0.0 X 0 0 0 RICHARD H DAVIS DIRECTOR 2.0 0.0 X 0 0 0 KIRSTEN J FELDMAN DIRECTOR 2.0 2.0 X 0 0 0 CARL FERENBACH DIRECTOR 2.0 2.0 X 0 0 0 CHARLES J HAMILTON JR ESQ DIRECTOR 2.0 2.0 X 0 0 0 KEVIN JOHNSON DIRECTOR 2.0 2.0 X 0 0 0 THE HONORABLE THOMAS H KEAN DIRECTOR 2.0 2.0 X 0 0 0 JOHN C KERR DIRECTOR 2.0 0.0 X 0 0 0 ABBY LEIGH DIRECTOR 2.0 2.0 X 0 0 0 SUSAN MANDEL DIRECTOR 2.0 2.0 X 0 0 0 MARY POWELL DIRECTOR 2.0 2.0 X 0 0 0 JON POWERS DIRECTOR 2.0 0.0 X 0 0 0 CLARA PRATTE DIRECTOR 2.0 2.0 X 0 0 0 GARY RAPPEPORT THRU 523 DIRECTOR 2.0 2.0 X 0 0 0 THAIS LOPEZ VOGEL ESQ DIRECTOR 2.0 0.0 X 0 0 0 JEFFREY P WILLIAMS DIRECTOR 2.0 2.0 X 0 0 0 JOANNE WITTY DIRECTOR 2.0 0.0 X 0 0 0 0 1714287 96732 0 false true false GLOBAL STRATEGY GROUP LLC 215 PARK AVENUE SOUTH 15TH FLOOR NEW YORK NY 10003 RESEARCH SURVEYS 398000 EDGEMARK PARTNERS INC 4510 COX ROAD SUITE 305 GLEN ALLEN VA 23060 POSTAGE/MAIL PROD. 375855 THE OUTREACH TEAM LLC 407 COLLEGE AVENUE SUITE 349 ITHACA NY 14850 field organizing 270000 COMPETE DIGITAL LLC 1317 POTOMAC AVENUE SE WASHINGTON DC 20003 DIGITAL ADS 264450 KL GATES LLP 210 SIXTH AVENUE PITTSBURGH PA 15222 LEGAL/AQUACULTURE 154500 9 704859 7867820 11249241 19821920 0 119689 119689 0 0 0 0 0 1116 -1116 -1116 -1116 0 0 0 0 0 0 0 0 0 OTHER INCOME 900099 17647 17647 17647 19958140 136220 X 750108 750108 0 0 0 0 0 0 3726941 3717018 9923 0 992918 990135 2783 82250 82019 231 0 26064 21429 3016 1619 0 0 0 175 175 6954772 5717853 804859 432060 737391 737375 16 464175 444253 19922 0 0 0 64469 64294 175 0 34812 34118 694 0 0 0 0 POLITICAL AFFAIRS- SEE SCH C 4555275 4555275 SUBSCRIPTIONS & DUES 334766 333876 890 MISCELLANEOUS EXPENSES 21185 20225 960 18745301 17467978 843644 433679 4558505 2682029 1084641 3747010 725000 0 0 0 0 0 0 0 0 0 0 0 106343 88554 0 0 0 0 0 0 0 0 0 0 0 0 6474489 6517593 903739 723806 51500 51500 0 0 0 0 0 0 0 0 0 0 0 0 1589826 600167 2545065 1375473 X 2483840 4653099 1445584 489021 3929424 5142120 6474489 6517593 1212839 -143 X false true X true false RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 5189584 6277 634309 4555275 5189584 false EDF ACTION VOTES INC 1875 CONNECTICUT AVENUE NW WASHINGTON DC 20009 841880479 4065000 0 KEEP THE LIGHTS ON PO BOX 750823 NEW ORLEANS LA 70175 883782491 450000 0 ALL TOGETHER COLORADO 191 UNIVERSITY BOULEVARD SUITE 118 DENVER CO 80250 853959470 15000 0 EMILY'S LIST 1800 M STREET NW SUITE 375N WASHINGTON DC 20036 521391360 10000 AMERICA VOTES 1155 CONNECTICUT AVENUE NW SUITE 6 WASHINGTON DC 20036 264568349 15275 0 true false false PART I-A: The amount reported on Schedule C, Part 1-A, Line 2 reflects political expenditures Environmental Defense Action Fund (EDF Action) spent directly or contributed to partners in the interest of supporting pro-environment candidates in the 2023 elections. The work supported allies critical to implementation of the Inflation Reduction Act and Bipartisan Infrastructure Law. In addition, EDF Action worked to advance policies at the federal, state and local level including to address methane emissions; advance vehicle electrification, support climate-smart agriculture and support clean air and safer chemicals. In addition EDF Action continues to build the political power necessary to help protect our environment and the health of American families. OF THE TOTAL AMOUNT OF POLITICAL EXPENDITURES, $420,384 WAS SPENT ON STAFF SALARIES (INCLUDING BENEFITS AND OVERHEAD), AND THE REMAINING $4,769,200 WAS SPENT ON DISCRETIONARY EXPENSES INCLUDING CONSULTANTS, ADVERTISING AND CONTRIBUTIONS TO LIKE-MINDED PARTNERS WORKING TO ADVANCE ENVIRONMENTALLY-MINDED POLITICAL PRIORITIES. THE TOTAL AMOUNT OF POLITICAL EXPENDITURES REPRESENTS APPROXIMATELY 27.68% OF EDF ACTION'S OVERALL EXPENDITURES FOR THE YEAR. POLITICAL EXPENDITURES: $5,189,584. VOLUNTEER HOURS: 6,277. 0 INTERCOMPANY PAYABLES 600167 600167 X 19957822 -143 -143 19957965 175 175 19958140 18745126 18745126 175 175 18745301 PART X, LINE 2: IN ACCORDANCE WITH GAAP, THE ENVIRONMENTAL DEFENSE ACTION FUND MUST RECOGNIZE A TAX LIABILITY ASSOCIATED WITH TAX POSITIONS TAKEN FOR TAX RETURN PURPOSES WHEN IT IS MORE LIKELY THAN NOT THAT THE POSITION WILL NOT BE SUSTAINED UPON EXAMINATION BY A TAXING AUTHORITY. THE ORGANIZATION DOES NOT BELIEVE IT HAS TAKEN ANY MATERIAL UNCERTAIN TAX POSITIONS AND, ACCORDINGLY, IT HAS NOT RECORDED ANY LIABILITY FOR UNRECOGNIZED TAX BENEFITS. true AMERICA VOTES 1155 CONNECTICUT AVE WASHINGTON DC 20036 264568349 501(c)(4) 15275 PUBLIC AND CLEAN AIR ACTION FUND 135 S 19TH STREET PHILADELPHIA PA 19103 844967138 501(c)(4) 30000 METHANE ADVOCACY CLEAN ENERGY BUSINESS NETWORK LLC 805 15TH STREET NW WASHINGTON DC 20005 821291947 501(c)(6) 36000 POLITICAL AFFAIRS CLIMATE CHANGEMAKERS 5540 CENTERVIEW DR RALEIGH NC 27606 870863486 501(c)(4) 35542 POLITICAL AFFAIRS EDF ACTION VOTES INC 1875 CONNECTICT AVE NW WASHINGTON DC 20009 841880479 501(c)(4) 4065000 POLITICAL AFFAIRS EEN ACTION INC 1800 M ST NW STE 375N WASHINGTON DC 20036 521391360 501(c)(4) 10000 METHANE ADVOCACY ELECT KATIE HOBBS INAUGURAL ACCOUNT 530 E MCDOWELL RD PHOENIX AZ 85012 820756676 527 17500 POLITICAL AFFAIRS EMILY'S LIST 1800 M STREET NW WASHINGTON DC 20036 521391360 501(c)(4) 10000 POLITICAL AFFAIRS ENVIRONMENT AMERICA INC DBA ENVIRON TEXAS 1543 WAZEE STREET DENVER CO 80202 205355252 501(c)(4) 10000 METHANE ADVOCACY GROUND GAME TEXAS 611 PENNSYLVANIA AVE WASHINGTON DC 20003 830567866 501(c)(4) 10000 POLITICAL AFFAIRS KEEP THE LIGHTS ON 1875 CONNECTICUT AVE WASHINGTON DC 20009 883782491 501(c)(3) 450000 POLITICAL AFFAIRS LATINO VICTORY PROJECT PO BOX 34104 WASHINGTON DC 20036 464651149 501(c)(4) 10000 POLITICAL AFFAIRS LEAGUE OF CONSERVATION VOTERS - DC 740 15TH STREET NW WASHINGTON DC 20036 521379661 501(c)(4) 17500 POLITICAL AFFAIRS MINORITIES IN AQUACULTURE 117 PARRIS LANE EASTON MD 21601 851764271 501(c)(3) 7500 OCEANS NATURAL RESOURCES COUNCIL OF MAINE ACT FD 3 WADE STREET AUGUSTA ME 04330 821044033 501(c)(4) 16000 POLITICAL AFFAIRS PARTNERSHIP PROJECT INC (THE) PO BOX 65826 WASHINGTON DC 20035 522192070 501(c)(3) 200000 POLITICAL AFFAIRS PENNENVIRONMENT INC 1429 WALNUT STREET PHILADELPHIA PA 19102 020611111 501(c)(4) 10000 US METHANE ADVOCACY PENNSYLVANIA ENVIRONMENTAL COUNCIL INC 2124 PENN AVENUE PITTSBURGH PA 15222 237286159 501(c)(3) 20000 US METHANE ADVOCACY RIO GRANDE INTERNATIONAL STUDY CENTER 1 WEST END WASHINGTON LAREDO TX 78040 742742037 501(c)(3) 9000 US METHANE ADVOCACY SARA ASHLEY STEVENS DBA ALL TOGETHER COLORADO PO BOX 102673 DENVER CO 80250 853959470 501(c)(4) 15000 POLITICAL AFFAIRS SEAFOOD HARVESTERS OF AMERICA 1717 K ST NW STE 900 WASHINGTON DC 20006 465541606 501(c)(4) 15000 AQUACULTURE TAXPAYERS FOR COMMON SENSE ACTION 651 PENNSYLVANIA AVE WASHINGTON DC 20003 522071292 501(c)(4) 20000 US METHANE ADVOCACY NM NATIVE VOTES 7900 MENAUL BLVD NE ALBUQUERQUE NM 87110 831860603 501(c)(4) 10000 US METHANE ADVOCACY WEST VIRGINIA RIVERS COALITION INC 3501 MACCORKLE AVE SE CHARLESTON WV 25304 521736621 501(c)(3) 10000 US METHANE ADVOCACY WESTERN CONSERVATION ACTION 1536 WYNKOOP STREET DENVER CO 80202 208091495 501(c)(4) 90000 DECARB. US POWER, WESTERN LEADERS NETWORK PO BOX 4433 DURANGO CO 81302 820625994 501(c)(3) 10000 US METHANE ADVOCACY WYOMING OUTDOOR COUNCIL 262 LINCOLN STREET LANDER WY 82520 830259411 501(c)(3) 10000 US METHANE ADVOCACY 8 19 PART I, LINE 2: ENVIRONMENTAL DEFENSE ACTION FUND ("EDF ACTION") HAS A NUMBER OF GRANTS AND OTHER ASSISTANCE IT PROVIDES TO ORGANIZATIONS IN THE UNITED STATES. THE MAJORITY OF THESE GRANTS ARE TO OTHER LIKE-MINDED ENTITIES THAT PERFORM WORK ALONGSIDE OF EDF ACTION IN THE ACCOMPLISHMENT OF ITS MISSION. EDF ACTION MONITORS THE PERFORMANCE OF THE GRANT RECIPIENTS BY WRITTEN REPORTS, SITE VISITS, VERBAL COMMUNICATION AND REVIEW. PARTIAL PAYMENTS ARE TYPICALLY MADE ON A GRANT UNTIL A PATTERN OF PROVEN ACHIEVEMENTS ON OBJECTIVES IS DEMONSTRATED. IN THE END, THE GRANTEE TYPICALLY PREPARES A REPORT TO EDF ACTION ON THE USE OF GRANT FUNDS, BOTH BY ITSELF AND BY ANY SUB-GRANT RECIPIENTS. false true false false false false false false false DAVID KIEVE PRESIDENT 0 214846 0 5000 0 0 0 7539 0 0 0 227385 0 0 FREDERIC D KRUPP EXECUTIVE DIRECTOR 0 878502 0 102030 0 154092 0 44900 0 13270 0 1192794 0 0 N LOUIS MKANGANWI CHIEF FINANCIAL OFFICER 0 230789 0 70000 0 0 0 13234 0 14153 0 328176 0 0 PART I, LINE 4B: FREDERIC D. KRUPP, EXECUTIVE DIRECTOR, RECEIVED A PAYMENT FROM A SECTION 457(F) PLAN IN THE AMOUNT OF $154,092, WHICH IS REPORTED ON SCHEDULE J, PART II, COLUMN (B)(III). FORM 990, PART III, LINE 4D: 1) REGIONALLY FOCUSED WORK - THE ENVIRONMENTAL DEFENSE ACTION FUND (EDF ACTION) IS THE ADVOCACY PARTNER OF THE ENVIRONMENTAL DEFENSE FUND (EDF). THE TWO ORGANIZATIONS TAKE ON DIFFERENT ROLES IN ACHIEVING COMMON OBJECTIVES. EDF SUPPORTED RESEARCH, SCIENTIFIC ANALYSIS, AND POLICY POSITIONING, AND EDF ACTION'S PRIMARY PURPOSE IS TO ENGAGE LOBBYING AND LEGISLATIVE WORK. IN 2023, EDF ACTION WORKED SUCCESSFULLY TO DELIVER HISTORIC PROGRESS ON CLEAN ENERGY AND PUBLIC HEALTH LEGISLATION. EDF ACTION'S WORK FOCUSED ON PASSAGE OF THE INFLATION REDUCTION ACT. AS PART OF THIS PROCESS, EDF ACTION AND ITS PARTNERS HELD OVER 500 MEETINGS WITH MEMBERS OF CONGRESS OVER 18 MONTHS TO DISCUSS THE CONTOURS OF A FINAL MEASURE; SPENT OVER $10 MILLION IN PAID ADVERTISING TO BUILD PUBLIC SUPPORT IN KEY PLACES FOR CLIMATE ACTION DURING THE DEBATE; GENERATED MORE THAN 140,000 EMAILS TO CAPITOL HILL; DEVELOPED EARNED MEDIA STRATEGIES SUPPORTING CLIMATE LEGISLATION THAT REACHED OVER 20 MILLION PEOPLE; AND FACILITATED SEVERAL CONSTITUENT FLY-INS TO VOICE SUPPORT FOR CONGRESSIONAL ACTION. IN ADDITION TO THAT MARQUEE LEGISLATION, EDF ACTION WORKED TO ADVANCE FEDERAL EFFORTS AIMED AT PROTECTING OCEAN HEALTH, CLIMATE SMART AGRICULTURE, CHEMICAL SAFETY AND COASTAL RESILIENCE. EDF ACTION CONTINUED TO INVEST IN STATE LEVEL ACTIVITY INCLUDING EFFORTS TO ADVANCE STATE COMMITMENTS TO REDUCING CARBON EMISSIONS, IMPLEMENTATION OF THE BIPARTISAN INFRASTRUCTURE LAW. TOTAL EXPENSES: $604,118. TOTAL GRANTS: $0. TOTAL REVENUE: $0. 2) Support People's Health - EDF Action works to support policies that improve air and water quality, deliver safer products, incentivize innovation through advocacy, and block efforts that would hinder the government from adopting regulations that are protective of health and safety. TOTAL EXPENSES: $98,515. TOTAL GRANTS: $0. TOTAL REVENUE: $0. FORM 990, PART VI, SECTION A, LINE 6: ENVIRONMENTAL DEFENSE ACTION FUND HAS TWO CLASSES OF MEMBERS, THE DIRECTORS-MEMBERS AND THE DONOR-MEMBERS. FORM 990, PART VI, SECTION A, LINE 7A: UNDER THE BYLAWS OF ENVIRONMENTAL DEFENSE ACTION FUND ("EDF ACTION") THE BOARD OF DIRECTORS OF ENVIRONMENTAL DEFENSE FUND, INCORPORATED ("EDF"), A RELATED 501(C)(3) ORGANIZATION, HAS THE RIGHT TO APPOINT CANDIDATES TO BE ELECTED BY THE EDF ACTION BOARD TO REPLACE DIRECTORS WHOSE TERMS HAVE EXPIRED AND THE RIGHT TO APPOINT DIRECTORS TO FILL VACANCIES. FORM 990, PART VI, SECTION A, LINE 7B: UNDER THE BYLAWS OF ENVIRONMENTAL DEFENSE ACTION FUND ("EDF ACTION") THE BOARD OF DIRECTORS OF ENVIRONMENTAL DEFENSE FUND, INCORPORATED. ("EDF"), A RELATED 501(C)(3) ORGANIZATION, HAS THE RIGHT TO FIX THE NUMBER OF DIRECTORS ON THE EDF ACTION BOARD FROM TIME TO TIME AND THE RIGHT TO REMOVE DIRECTORS FROM THE EDF ACTION BOARD. FORM 990, PART VI, SECTION B, LINE 11B: FORM 990 WAS PREPARED BY A NATIONAL ACCOUNTING FIRM IN CONJUNCTION WITH INFORMATION PROVIDED BY EDF'S FINANCE DEPARTMENT AND MEMBERS OF SENIOR MANAGEMENT. EDF'S FINANCE DEPARTMENT HAS REVIEWED DRAFT FORM 990 AND A REVISED DRAFT WAS PROVIDED AND REVIEWED. DRAFT FORM 990 WAS PROVIDED TO SENIOR MANAGEMENT FOR REVIEW AND COMMENT. WITH THE EXCEPTION FOR THE NAMES AND ADDRESSES OF DONORS ON SCHEDULE B, EDF ACTION HAS PROVIDED A COMPLETE FORM 990 TO ITS GOVERNING BODY BEFORE FILING THE FORM. FORM 990, PART VI, SECTION B, LINE 12C: IT IS THE RESPONSIBILITY OF ALL DIRECTORS AND EMPLOYEES OF EDF ACTION TO FAMILIARIZE THEMSELVES WITH THE CONFLICTS OF INTEREST POLICY AND TO ENSURE COMPLIANCE OF RELATED PARTIES WITH IT. IN ADDITION TO THE DISCLOSURES REQUIRED BY THIS POLICY, EACH DIRECTOR AND KEY EMPLOYEE WAS PROVIDED WITH A STATEMENT TO COMPLETE AND RETURN INDICATING THAT THEY HAVE READ, UNDERSTAND AND ARE IN COMPLIANCE WITH THIS POLICY. DIRECTORS WHO KNOWINGLY OR UNKNOWINGLY VIOLATE THE POLICY ARE SUBJECT TO CENSURE OR REMOVAL AT THE DISCRETION OF THE BOARD OF DIRECTORS. EMPLOYEES WHO KNOWINGLY OR UNKNOWINGLY VIOLATE THE POLICY WILL BE SUBJECT TO DISCIPLINARY ACTION, INCLUDING POSSIBLE DISMISSAL. ALL NEW BOARD MEMBERS ARE REQUIRED TO MAKE CONFLICT OF INTEREST DISCLOSURES. FORM 990, PART VI, SECTION B, LINES 15A AND 15B: EDF ACTION HAS NO COMPENSATION PAID TO THE TOP MANAGEMENT OFFICIAL OR OTHER OFFICERS OR KEY EMPLOYEES OF THE ORGANIZATION. COMPENSATION IS PAID BY ENVIRONMENTAL DEFENSE FUND, INC., A RELATED SECTION 501(C)(3) ORGANIZATION. FORM 990, PART VI, SECTION C, LINE 19: EDF ACTION'S AUDITED FINANCIAL STATEMENTS AND FORM 990'S ARE AVAILABLE ON ITS WEBSITE AND UPON REQUEST. EDF ACTION MAKES ITS GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC UPON REQUEST. 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