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Expert Working Group Meeting: First Meeting, Washington DC, 30-31 August 1999

Expert Working Group Meeting on Governments' Role in Promoting Environmental Management Accounting

Report

The Expert Working Group Meeting on Improving Governments' Role in Promoting Environmental Managerial Accounting was organized for the exchange of information among governments on how they could promote the use of environmental managerial accounting (EMA) by business and industry. The Expert Working Group was organized as a follow-up to informal discussions on the issue at the 1998 session of the United Nations Commission on Sustainable Development (CSD) in the context of discussions on environmentally sound technologies. Those discussions indicated that a number of governments were involved in, or interested in, promoting EMA, but that there had been little or no communication between the agencies concerned. In particular, the United States Environmental Protection Agency (USEPA), which had an active programme in this area, was interested in exchanging information with agencies in other countries. 

The first meeting of the Expert Working Group was organized by the United Nations Division for Sustainable Development (DSD) and the USEPA, and hosted by the USEPA in Washington DC, on 30-31 August 1999. The participants in the Expert Working Group meeting were from national environment agencies, intergovernmental organizations, industry, accounting firms and academia.   The Group included participants from Australia, Austria, Canada, Finland, Germany, Japan, Mexico, Nepal, Norway, the Slovak Republic, United Kingdom and United States, as well as from the United Nations DSD, the European Commission, and the United Nations Environment Programme (UNEP).   A written contribution was also received from an expert from China who was unable to attend the meeting.   The Nature and Purpose of EMA The costs to industry of environmental protection, including pollution reduction, waste management, monitoring, regulatory reporting, legal fees and insurance, have increased rapidly in the past 20 years with increasingly stringent environmental regulations.   Conventional management accounting systems attribute many of those environmental costs to general overhead accounts, with the consequence that product and production managers have no incentive to reduce their environmental costs and executives are often unaware of the extent of environmental costs.  There is no consensus on the scope, content or procedures of EMA, and it would probably not be useful to try to reach consensus or promote standardization.   EMA systems should be adapted to the management needs and priorities of specific enterprises, economic sectors and national systems for accounting and reporting.   

To a large extent, EMA procedures that focus management attention on environmental costs are more important than the particular system used or results obtained. While most EMA approaches focus on actual costs to the enterprise (internal costs), EMA can also take into account external environmental costs.   Assessment of such external costs is particularly useful for long-term investment planning, considering that current external costs may be internalized through future regulations.  EMA systems that identify external costs can support supply-chain environmental assessment and product life-cycle assessment, and can benefit from recent work in those areas.   While the focus of EMA is generally on accounts in monetary terms, accounts in physical terms (natural resource accounts) may also be useful in some situations. Environmental costs can be categorized as follows: Conventional costs: Hidden costs:> Contingent costs (liabilities, risks) Relationship/image costs (consumer, community and NGO relations) Societal costs (environmental and social externalities).   The Benefits of EMA In conventional management accounting, the aggregation of environmental and non-environmental costs in overhead accounts results in their being "hidden" from management.   

There is substantial evidence that management tends to underestimate the extent and growth of such costs.   By identifying, assessing and allocating environmental costs, EMA allows management to identify opportunities for cost savings.   Prime examples from the EMA literature are the savings that can result from replacement of toxic organic solvents by non-toxic substitutes, thus eliminating the high and growing costs of regulatory reporting, hazardous waste handling and other costs associated with the use of toxic materials. A rule of thumb of environmental management is that 20 per cent of production activities are responsible for 80 per cent of environmental costs.   When environmental costs are allocated to overhead accounts shared by all product lines, products with low environmental costs subsidize those with high costs.   

This results in inefficient product pricing which reduces profitability. A relatively simple application of EMA that may yield large benefits is to waste management, as the costs of handling and disposing of waste are relatively easy to define and to allocate to specific products. Other environmental costs, including costs of regulatory compliance, legal costs, damage to the corporate image, and environmental liabilities and risks, are more difficult to assess. Some enterprises are now using EMA systems, most commonly large enterprises that process natural resources and are subject to extensive environmental regulations. The USEPA Environment Accounting Project had developed forty-five case studies of EMA applications and benefits in various industries.   Examples that were presented and discussed in the Working Group meeting included DuPont in the United States and Siemens in Germany. Environmental regulations, consumer demands and public pressure concerning environmental performance are constantly changing.   

Companies with EMA systems can quickly determine the costs and implications of responding to such changing regulatory and market conditions and hence can gain a competitive advantage over other enterprises.   Obstacles to EMA A major obstacle to more widespread use of EMA by enterprises is the cost and difficulty of implementing an EMA system.   This is in part due to the inherent complexity and cost of collecting and analyzing more data, and in part due to the lack of established, “off-the-shelf” EMA systems. Each enterprise thus has to define, design and develop its own EMA system, which is a costly process. Even some large organizations, such as AT&T and the United States Department of Defense, have initiated EMA systems and then dropped them. Some accounting and consulting firms that have tried to develop environmental accounting services have abandoned the effort as unprofitable, although others see it as a future growth area. There is, therefore, a need to assess the costs and benefits of various approaches to EMA for enterprises of various sizes and activities.   It may be that detailed EMA systems are not cost-effective for small enterprises with low environmental impacts.  

 There is a need to develop, demonstrate and make easily available a range of EMA systems, including very simple systems for small enterprises. The accounting profession has been slow to take up environmental issues, perhaps due in part to a certain caution and conservatism in the professional culture.   Efforts through professional associations, professional journals and education institutions could help to overcome such obstacles.   Environmental Management Tools Related to EMA There are important linkages between EMA and other environmental management and accounting systems.   EMA systems and those other systems should be designed to be compatible and mutually supportive.   An important means for governments and other organizations to promote EMA, for which there are no official standards or regulations, is to develop the standards and regulations for financial accounting and reporting, and environmental management systems, in such a way as to make it advantageous to enterprises to have EMA systems. 

Environmental Management Systems (EMS)

Most directly related to EMA are environmental management systems (EMS). International voluntary standards have been established for EMS by the International Organization for Standardization (ISO 14000) and the European Union Eco-Management and Audit Scheme (EMAS). Under each of these systems, enterprises can seek certification that an EMS that meets the established criteria has been established for a particular site (not for the enterprise as a whole).   Such certification can be useful for public relations purposes and is required by some organizations, both public and private, of their suppliers. Both ISO 14000 and EMAS set standards for environmental management procedures and institutional structures, rather than for environmental performance. Neither ISO 14000 nor EMAS includes EMA requirements, but an EMS and an EMA system could be mutually supportive. Both ISO 14000 and EMAS are subject to review and revision, and could be revised to require, or more strongly promote, EMA. The Working Group agreed that a priority for future work would be a study of the actual and potential linkages between EMA and EMS. EMAS certification requires an environmental policy for a site, a public statement of the environmental policy, an environmental assessment of the site, an action plan, and a management structure and procedures for system.   Surveys of enterprises indicate that public image improvement is the primary incentive for EMAS certification, with cost reduction as a secondary incentive.   

The interest in EMAS certification varies substantially from country to country, with Germany having 1453 certified sites, Austria 141, Sweden 110, Denmark 76 and the United Kingdom 61.   Many enterprises with EMAS-certified sites also have ISO 14000 certifications.  In Austria, the cost of establishing an EMAS system and obtaining certification depends on the size of the operation and has been estimated at roughly $500 per employee.   EMAS systems for medium-size sites have generated average cost reductions of about $170,000, with a payback period of less than one year. 

Environmental Reporting

Financial accounting for required corporate public reporting is better developed than managerial accounting for internal use.   Accounting education focuses largely on financial accounting, as does the accounting literature.   In some respects, managerial accounting and financial accounting use the same basic data, but organize, analyze and present them differently. Financial accounts include most environmental costs, but aggregated in a way that does not identify the specifically environmental costs.   There is evidence, however, that some environmental liabilities and risks that are in principle covered by reporting requirements, are often not reported; for example, liabilities for cleaning up contaminated land.   A comprehensive EMA system would promote more complete financial accounts in such cases. While management accounting for internal use, including EMA, is not subject to government requirements or standards, many developed countries have requirements, standards or guidelines for mandatory or voluntary environmental reporting.   And an increasing number of corporations are voluntarily publishing annual environmental reports to accompany their annual financial reports.   

Commonly, such environmental reporting is in physical terms, such as tonnes of pollutants released or waste generated, rather than in the monetary terms normally used in EMA. Regulatory provisions and requirements provide a major incentive for corporate EMA. Regulations such as toxic release inventories, liability for pollution damage, hazardous waste management and other requirements that increase environmental costs increase the benefits of EMA. EMA systems often focus specifically on the costs arising from regulatory compliance. Increasingly stringent environmental regulations will therefore further increase the benefits of, and incentives for, EMA systems. Internal corporate EMA systems can support environmental reporting, and reporting requirements or guidelines can encourage the development of internal EMA systems.   

The International Accounting Standards Committee (IASC), whose members are national professional accounting associations, promotes accounting standards for financial reporting. The Working Group agreed that another priority for future work would be a study of the actual and potential linkages between EMA and corporate environmental reporting. 

National Environmental Accounting (NEA)

There are also linkages between national environmental accounts and EMA.   The United Nations Systems of Integrated Environmental and Economic Accounts (SEEA) provides an accounting framework that can be adapted for corporate EMA systems. Corporate EMA can also generate information for use in national environmental accounts through corporate reporting requirements. Natural capital accounting, as promoted by the World Bank, has been a focus of recent work in “green national accounts” and may have interesting linkages with corporate EMA. The Working Group agreed that future work should also consider linkages between NEA and EMA.

Government Promotion of EMA

By promoting wider use of EMA in industry, government environment agencies can achieve pollution reduction at minimal cost to government and with minimal political resistance, in keeping with the current emphasis on voluntary initiatives and use of market forces. Wider use of EMA will tend to increase the effectiveness of new environmental regulations and economic incentives, as enterprises will be able to quickly calculate the costs of such policy measures and to adapt production systems and pricing in accordance with the new conditions at minimum cost. EMA systems will also encourage management to plan new production systems taking into account prospective new regulations and incentives designed to internalize environmental costs that are now external. International mechanisms for coordination and standard setting, with the participation of United Nations agencies, exist for corporate reporting, including environmental reporting, and for national environmental accounting, both of which are government responsibilities. Corporate managerial accounting, however, is not subject to government regulation and has therefore not been a subject for inter-governmental discussions.   

The participants in the Working Group welcomed this first opportunity for international exchange of information. The Working Group agreed that managerial accounting systems must be adapted to the specific needs of enterprises and the economic and regulatory system in which they operate.   It is, therefore, probably not desirable to try to standardize EMA systems, but to offer enterprises a variety of flexible EMA tools and systems. Similarly at the inter-governmental level, there is little need for international harmonization of programmes for promoting EMA, but agencies can gain by sharing experience and undertaking cooperative projects. There is a need for guidelines and case studies on EMA, explaining concepts and terms, describing a variety of tools and options, and discussing the implementation and benefits of such systems. Such information and publications would be valuable for many potential users of EMA and for government agencies interested in promoting its use.   

In countries where EMA systems are in use in a significant number of enterprises, this could be done at the national level. For other countries, international guidelines and case studies would be valuable. Some enterprises in developed countries are now using EMA systems, most commonly large enterprises that process natural resources and are subject to extensive environmental regulations.   The experience of those enterprises can be used for the preparation of guidelines on best practices in EMA at the sectoral and national levels. Use of EMA systems can be promoted by governments through a variety of measures, including dissemination of information, development and dissemination of low-cost, off-the-shelf EMA software, cooperation with industry associations in key sectors, consultant services, seed funding of EMA projects, EMA development for public sector use, and introduction of EMA into accounting education and practices. EMA systems should complement and be compatible with conventional accounting systems, environmental management systems (EMS), and environmental reporting standards.   As noted above, voluntary EMS standards (ISO 14000, EMAS) which do not currently require EMA, could be revised in the future to do so.   

Environmental reporting requirements could also be revised to encourage EMA, in particular by requiring reporting in monetary terms as well as physical terms. Environmental taxes and incentives, emission trading schemes, and other environmental policies could also be designed to encourage the use of EMA by affected companies.   Regulatory procedures and permitting could also be made more flexible, while maintaining overall performance standards, for enterprises with approved EMA systems. The ECOMAC project (Eco-Management Accounting as a Tool of Environmental Management), sponsored by the European Commission, conducted a survey of 84 enterprises in 4 European countries.   The survey indicated that reporting requirements can effectively promote the use of EMA if they require accurate data rather than accepting rough estimates.   

It also indicated that EMA generated the greatest benefits for large companies with complex production processes, and was often not economic for small companies. EMA was used mostly for capital budgeting, bookkeeping, cost control, and product pricing. Some 26 per cent of the enterprises surveyed were using activity-based costing, providing the data necessary for EMA.   The survey revealed some sectoral differences in accounting procedures relating to EMA, indicating for example, that sectors other than utilities usually allocated hazardous waste management to overhead accounts.   

The survey also indicated that energy costs are more often allocated to production units in Europe than in the United States. (ECOMAC ref. www.eim.nl/uk/nl/ecomac.html) To promote voluntary use of EMA by enterprises, governments need a menu of incentives. A Working Group participant from industry noted that the incentives need to be substantial, as corporate managers prefer not to change their procedures and priorities unless there is strong reason for doing so. Incentives should be used not only to induce changes in practices, but also to reward enterprises that have pioneered the development of new practices that go beyond compliance. Possible incentives for the adoption of EMA might include faster review of regulatory applications, simpler procedures for extending permits, regulatory flexibility such as plant-wide emissions limits, self-certification for permits, and reduced inspections for enterprises with approved EMA systems.   

Favorable tax treatment would be attractive, but would require joint action by environmental and tax authorities, which might be difficult. To be attractive, incentive systems should not involve a burdensome qualification process. Governments can also encourage insurance companies to assess environment-related liabilities and risks in setting insurance rates.   The potential for lower insurance rates would be an incentive for enterprises to use EMA to identify and reduce such liabilities and risks. Governments can also work with industry associations and non-governmental organizations (NGOs) to support voluntary programmes to promote EMA. While voluntary environmental programmes are often adopted by enterprises primarily for their public relations effect, there is evidence that policies adopted for external public relations purposes gradually become internalized and put into practice. Education and training in EMA, for accountants and managers as well as students in those fields, is central to promoting use of EMA. Enterprises interested in EMA need accountants trained in EMA techniques, and trained accountants and managers can take the initiative in introducing EMA concepts and systems into corporate management. Educational institutions and professional associations can both play an important role in basic and continuing education. 

Current Programmes Relating to EMA

Participants in the Working Group described programmes to promote EMA and related programmes in their countries. The following is a brief summary of the information presented.   The Working Group agreed that a more comprehensive and detailed review and assessment of existing programmes for promoting EMA should be prepared. Norway has instituted a competition and prize for EMA systems, conducted in cooperation with a management school, with the prize awarded in a public ceremony at the stock exchange. This is part of a general effort to improve the environmental performance of small and medium-size enterprises through environmental management systems, product management with respect to environmental impacts, and market-based environmental protection measures.   

Norway has recently revised its corporate reporting law to clarify the requirements for environmental reporting.   The revision does not involve quantitative reporting, but calls for a broad and clear public statement of environmental policy.   Norway is also working with the banking industry to increase attention to environmental risk assessment. Norway, Australia and the United Kingdom are promoting environmental accounting by public authorities, both to improve the environmental performance of the authorities and as an example to private companies.   In Norway, a 55-point environmental check-list and an internet networking system have been developed for use by local authorities.   Norway also has a "Lighthouse" programme, with consultant assistance, publicity and an eco-logo, that promotes environmental accounting programmes in small businesses.  In Australia, a project to promote the use of EMA by local authorities is working with 178 local governments, using the UN System of Integrated Environmental and Economic Accounting (SEEA) for national accounts, which includes accounts for environmental protection expenditures, depletion of natural resources, and costs of environmental damage.   The accounts indicate that local authority spending on environmental protection has amounted to between $40 and $250 per capita, depending on the scope of the environmental expenditures covered.   

The project showed that the SEEA approach was useful for EMA by local authorities, but that it was generally incompatible with existing data management systems.   SEEA was considered more useful than the "ecological footprint" or "material flow" approach. In the United Kingdom, the Environment Agency, which is funded by the national government, by local authorities, and through corporate charges, has undertaken an Environmental Accounting Initiative covering its own activities, including management accounting, financial accounting and environmental planning.   Specifying the criteria for inclusion of items in the environmental accounts, defining the items to be included, and setting standards for their assessment have proven difficult.   To date, the environmental costs, notably for energy and travel, have been defined, and work is proceeding on environmental assets, savings, liabilities and preventive expenditures. In the United States, an Environmental Accounting Project was established in 1992 as part of the implementation of the Pollution Prevention Act of 1990, which emphasized voluntary and market-based programmes. The Project has leveraged its limited resources through cooperation with partner organizations, outreach efforts, and education of other government departments.   

As part of the Project, EPA has undertaken a variety of activities in cooperation with enterprises or other organizations, with various objectives, including: Definition of concepts, terms and the roles of different organizations; Development of incentives; Education, training, guidance and outreach; and Development of analytical tools, methods and systems.  In the E-COST project, the Environmental Accounting Project is working with the Best!Ware computer software company to develop an EMA module for the best-selling "Mind Your Own Business" (M.Y.O.B.) accounting program for small businesses.   Information on this and other project activities and reports is available on the USEPA Environmental Accounting Project web-site: www.epa.gov/opptintr/acctg/

A number of states in the United States offer tax incentives to encourage enterprises to undertake environmental protection measures beyond those required by regulations. Currently there are no tax incentives for EMA systems, but the existing incentives may encourage analysis of environmental costs and consideration of alternatives. Tax incentives include accelerated depreciation of capital equipment for environmental protection, favorable tax treatment of spending on contamination remediation, corporate income and property tax credits for environmental protection spending, and sales tax waivers for purchases of environmental protection equipment. Other financial incentives include low-interest loans and tax exempt bonds for capital investments. The Green Ledgers Project of the Washington-based World Resources Institute studied nine United States-based companies, including Amoco Oil, Ciba-Geigy, Dow Chemical, DuPont and S.C. Johnson, showing how those companies used environmental cost information to increase profitability and reduce environmental risk.   The publication resulting from the project provides guidelines on practical steps for integrating environmental accounting practices into business systems. Environment Canada has produced an “Introductory Guide to Environmental Accounting”, which covers financial and non-financial data and qualitative information, as well as some external environmental costs. The agency also organizes community-based “Enviro-Clubs” of about 15 small businesses, which are supported for about 6 months with consultant services on EMS, EMA and other aspects of pollution prevention.   Mutual support among the members also makes an important contribution to benefits.   

Participants pay $5000 to join, and are guaranteed their money back through cost savings. For a typical business, pollution prevention measures undertaken on the basis of work in the Club produce savings of about $90,000 per year from an investment of about $100,000. Canada is introducing requirements for corporate pollution prevention plans, including cost-benefit analysis.   The government is also promoting voluntary environmental initiatives such as the Responsible Care Programme initiated by the chemical industry in Canada and subsequently expanded to 42 countries. The Canadian Institute of Chartered Accountants (CICA) is a quasi-judicial body that sets accounting standards in Canada, undertakes research and disseminates information.   

EMA related work includes studies on environmental auditing (1992), sustainable development (1993), accounting and reporting of environmental costs and liabilities (1993), environmental performance reporting (1994), waste management guidelines (1995), and full cost accounting (1997).   A study is underway on accounting of externalities. In the province of Ontario, Canada, the provincial Ministry of Environment has undertaken some case studies of corporate EMA, including Husky Injection Molding and the Interface Canada carpet company.   The Ministry also works with industry to promote reduction of harmful emissions on a voluntary basis through regulatory incentives including reduced reporting requirements and flexibility on permitting.   The Ministry also published sectoral guidelines on eco-efficiency and guidelines on ISO 14000 certification. In Germany, guidelines have been developed for assessing the cost of air quality protection (VDI RL 3800).   

Those guidelines, prepared with the participation of industry, industrial associations, government and academia, are currently being revised to cover all environmental protection costs.   The revision process is addressing a number of cost assessment questions including recycling, take-back and life-cycle costs, whether costing should be by facility, process or product, and whether it should cover worker safety, noise, product quality and economic factors. The Japan Environment Agency has produced a Draft Guideline for Evaluating Environmental Costs and Publicly Disclosing Environmental Accounting Information.   The Guideline specifies in detail how environmental costs are defined and calculated, and provides forms for both internal cost accounting and public reporting. In Sweden, most enterprises now include environmental issues in their annual reports, and more and more companies are establishing environmental management systems.   

The 1999 Annual Accounts Act requires annual environmental reports, including information on regulatory compliance. More extensive information is required from enterprises with major environmental impacts due to emissions, noise or waste, and enterprises which require environmental permits.   Sweden does not yet have a programme to promote corporate EMA, but is interested in the question. In Finland, a working group on environmental accounting has been established with the participation of industry. In 1999, Finland published Guidelines for Environmental Reporting, including EMA, and organized a competition for corporate environmental reports. Finland also carried out a study of the external environmental costs of the forest industry, concluding that, in the case of paper, external environmental costs amounted to about 3-5 per cent of the price of the product, with the largest cost attributed to climate change resulting from energy consumption and greenhouse gas emissions. In Europe, an Eco-Management Accounting Network (EMAN) has been established with the participation of researchers, consultants, business people and policy advisors.   

The purpose of the Network is to promote the understanding and use of EMA by businesses, to stimulate research in the field, to promote education in EMA, and to identify opportunities for government support for EMA.   Areas of research that have been identified as promising include cost-benefit analysis of cleaner production, accounting and the internalization of external costs, tools for supply-chain analysis, and EMA for public sector organizations. The Network organizes periodic conferences on EMA, with the next conference to be held at the Wuppertal Institute in December 1999 on "EMA: The role of information systems". In the Slovak Republic, the government and the National Cleaner Production Centre are promoting environmental reporting and accounting.   

The government, however, has very limited resources and little leverage for enforcing or promoting environmental protection measures. Environmental regulations exist, but if strictly enforced, they would close a large portion of Slovak industry, which is politically and economically unacceptable. The Mexican economy has a large informal sector, and economic development takes priority over environmental protection. As a result, government agencies are not very effective in promoting environmental protection and have little leverage for directly promoting EMA. Under such conditions, an effective approach might be to train accountants and consultants, who would have greater credibility in persuading businesses of the productivity increases and cost savings to be achieved from cleaner production. Simple accounting software could also be useful. In Nepal, industry contributes about 10% to GDP and is estimated to contribute about 8% of pollution. The major environmental problems are dust and other air pollution from brick and cement plants, and water pollution from iron and steel mills, carpet making and sewage. There are few environmental standards, and those that do exist are not enforced.

FUTURE WORK AND PRIORITIES FOR THE WORKING GROUP

Among members of the Working Group, the most common EMA-related activity has been learning about EMA, disseminating information by writing and teaching, and trying to build support for EMA within their own organizations. The Group agreed that priority work for the near future was information, education and training, including preparation of case studies, guidelines and tool kits for using EMA.   The Working Group agreed that particular efforts should be made to disseminate information on EMA through internet web-sites. The Working Group agreed that it should coordinate its work with groups working on related issues, including the Eco-Management Accounting Network (EMAN), the Greening of Industry Network, the Global Environmental Management Initiative (GEMI), the Global Reporting Initiative (GRI), the UNCTAD Intergovernmental Group of Experts on International Standards of Accounting and Reporting (ISAR), and the Financial and Management Accounting Committee of the International Federation of Accountants. The Working Group agreed that it should continue to meet periodically for exchange of information, coordination, and development of cooperative activities, with the United Nations Division for Sustainable Development as the secretariat. While the primary function of the Group would be to bring together people from government agencies and international organizations concerned with EMA, it was agreed that participants from industry, the accounting profession, and academia should also be invited to bring their perspectives and expertise to the Group. The Group agreed that a priority for future work should be studies of linkages between EMA and the related issues of financial and environmental reporting, environmental management systems (EMS) and national environmental accounts (NEA).   Studies were also needed of the feasibility and effectiveness of various incentives for promoting EMA. A number of national agencies indicated willingness to prepare studies on such issues for consideration at the next meeting.   They will consult with the secretariat to coordinate the studies. The Working Group agreed that one of its goals should be to produce a report on EMA for broad international distribution and submission to the Commission on Sustainable Development at its 2001 session under the theme “Information for Decision-Making”.   The report could include a description of EMA and its benefits for business and society, consideration of the role of governments in promoting EMA, a review of national and international activities for promoting EMA, and recommendations or guidelines for government efforts to promote EMA. 

The next meeting of the group will be hosted by Austria in May 2000. A planned meeting on environmental management tools organized by the European Commission in Lisbon in March 2000 provided an interim opportunity for exchange of information and review of preparations for the next meeting.

Meeting Details