Impact investors are ready to invest increasing amounts of impact capital in sustainable fisheries; what’s missing are profitable businesses and organizations with the capacity to accept investment. These profitable “investible entities” aren’t emerging apace because the entrepreneurial ecosystem to develop their business capacity is lagging.
Developing and Implementing SIMP Compatible Seafood Data Reporting and Traceability System in the Crab Supply Chain
Problem Statement and Opportunity
The U.S. implementation of the Seafood Import and Monitoring Program (SIMP) on 1 January 2018 establishes reporting and recordkeeping requirements to prevent illegal, unreported and unregulated (IUU) seafood from entering the U.S. The onus of proof is placed on the importer of record to provide and report key data from harvest to U.S. entry. In geographically diffuse supply chains, like blue swimming crab from Southeast Asia, with thousands of “points of entry”, i.e., fishers, tracking landings to the vessel is far less straightforward than short and narrow supply chains, such as skipjack tuna or sardines. This reporting requirement, while worthwhile, will require U.S. seafood importers to incorporate cost-effective traceability initiatives in their often-complex supply chains.
There is a growing appreciation that the needs of ﬁshers and their communities must be addressed in order to improve the underlying causes of ﬁshery exploitation in the developing world, particularly for small-scale ﬁsheries. -California Environmental Associates
The requirement also presents an opportunity to promote resource sustainability through supply chain transparency and catch monitoring. Despite pledges to abide by size limits, U.S. importers of blue swimming crab (BSC) have difficulty ensuring their supply chain partners are buying only crabs larger than the agreed minimum size of 10cm and excluding berried females. The application along with a web-based reporting tool we developed can meet the requirements of the SIMP, as well as the European Catch Documentation (CD) requirements, and elucidate the in-country supply chain. By tracking landings by vessel and by harvester, this tool further provides the opportunity to address key social and environmental outcomes associated with the Sustainable Development Goals (SDGs), which gives seafood importers a mulit-purpose toolkit to both decrease their reporting costs and increase the sustainability of the crab stocks.
The opportunity to spur social and economic impact should not be underestimated. Educating, engaging and rewarding fishers and communities directly for complying with ecological goals like minimum size, berried females, no-take areas, and more offers an opportunity to engage communities directly in resource management and provide key links to SDGs. Aside from nascent work by Fair Trade and SmartFish, there are few fishery sustainability efforts that actually benefit the fishers that form the foundation of many supply seafood chains. Indeed, most efforts impose costs on fishing communities—time, foregone income, capital for new equipment—without providing benefits. Our tool allows identification of compliant fishers, so they can be awarded price premiums and other incentives.
Supply chain transparency is beneficial to the U.S. importer not only in terms of identifying good actors and meeting reporting requirements, but also gives them an edge in the marketplace full of otherwise opaque supply chains.
When initially considering how to provide BSC supply chain transparency from the ocean to the end buyer, we researched existing options, hoping to find one that could be customized to the supply chain. We conducted a desk review, scouring the internet and our personal network to identify all available options. In total, we reviewed nearly forty systems that provided varying levels of traceability; of these, we interviewed approximately six potential providers that met or came close to our key considerations:
- Ease of use – the user interface needed to be easy for data collectors in Indonesia and importers in the U.S. to use
- Utility for marketing purposes – a consumer-facing component was a must
- Facilitate regulatory compliance – must collect and provide data required by the SIMP and EU CD in a straightforward format
- Mapping – needs to provide maps of fishing locations to determine which areas are best for avoiding undersized and berried crabs
- Business model – a cost effective and durable business model that did not result in excessive fees or costs to each level of the value chain
- Data access, storage and ownership – data must be accessible by multiple parties within the value chain, stored in Indonesia, and owned by the funding company
- Reasonable set-up costs – ideally, a system would be compatible with existing software and hardware and would require little in the way of training. A team should be able to begin data collection with a few hours or less of upfront training on the system interface and they should be able to readily convey to the fishers the benefits of the system.
- Geographic and cultural relevance – the system needed to function in rural, relatively isolated areas with little to no telecommunications access
- Engage Harvesters and Vessel owners in order to build their understanding and the relative importance of adhering to harvest control regulation
- Ease of integration – overall, the platform needed to be easy to readily integrate into the supply chain.
Findings from Assessment
None of the reviewed systems met the requirements of the lead firm with the exception of the Pelagic Data Systems units for vessel management, i.e., vessel tracking. Due to the cost of acquisition and the relatively high ongoing costs of use, these were installed on a trial basis. This test was not successful, and cheaper, more effective units were identified.
Not finding a suitable existing program, Blue Star Foods decided to develop their own application to gather data tied to their marketing goals and objectives around supply chain integrity. The SIMP and EU CD data requirements were integrated into the data collection system. Wilderness Markets worked closely with an app-development team to develop an Android and iOS application and support the field trials. After the initial field trials, the system was deployed to in-house teams from Blue Star Foods Indonesian partners, consisting of procurement and quality control specialists.
Implementation and Deployment
Data was collected at selected mini-plants and landing sites during a six-month period. Both harvesters and data collectors were simply encouraged to log landings during the pilot phase without any indication or reference to IUU or other considerations. They were not penalized or otherwise reprimanded for reporting undersized or berried crabs during this time period. Vessel tracking data was collected for a select number of boats during this period, which could be matched to landings data.
Initial learning points
- Data collection required additional training of procurement and quality control teams. This in turn required an additional budget to be implemented effectively.
- The pilot only covered a small portion of overall U.S. imports from Indonesia (less than 1%) – the current opacity of the supply chain means we did not know how much each mini-plant contributes to the supply chain before the pilot
- The system efficiency is high enough that recording all landings at a mini-plant or at a landing site is possible, though unless a quality control individual is onsite continually, it cannot guarantee there will be no side selling unless all buyers agree to use the system.
- The data feedback loop to management has been significantly shortened and is possible in nearly real-time allowing:
- Faster identification of low productivity landing sites
- Faster identification of high productivity landing sites
- Faster identification of undersized and/or berried crab seasons and locations
- Data integrity and accuracy continues to be an issue and needs to be worked on – Due to their small size, most vessels are unregistered so vessel identification is challenging. Usual data integrity and accuracy issues for data collection operations exist, such as ensuring consistent data entry, checking entries for errors, etc.
Initial Data Findings
- Initial indications, based on sampling approximately 10% of the harvest per vessel, are that up to 25% of landings can likely be classified as IUU (berried females & sub 10cm).
- Boats with lowest supply chain loyalty appear to have higher levels of IUU (an assumption to be tested in additional sites)
- It is now possible to identify the specific boats that are causing the high levels of infractions, and to address with through the supply chain in a focused manner.
- Less than 20% of the surveyed vessels were responsible for 80% of the IUU landings
Fishery Management Implications
The ability to specifically identify vessels not complying with agreed harvest controls will permit a more targeted, focused and cost-effective approach to monitoring and enforcement of infractions. With less than 20% of the vessels are causing 80% of the issues with regards to IUU landings, efforts can be made to reduce IUU in a focused manner.
The data provides:
- Ability to provide shore-based landing information
- Ability to identify both geographic and seasonal potential closure options based on real data
- Ability to target enforcement based on recorded infractions
Links to SDGs
In addition to the business and fishery management implications, the findings are directly linked to at least three SDGs:
SDG 8 Decent Work and Economic Growth
Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all
Biological data indicates a quick (less than 1 year) stock recovery when undersized crabs are left in the water, thereby increasing the economic value of the fishery and decoupling growth from environmental degradation (Target 8.4)
SDG 9 Industry, Innovation and Infrastructure
Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation
Increasing the transparency of the supply chain means that small-scale enterprises, like the mini-plants, can have better access to financial services (Target 9.3).
SDG 14 Life Below Water
Conserve and sustainably use the oceans, seas and marine resources for sustainable development
Using the data generated by the app, progress can be made towards sustainably managing fish stocks, combatting IUU, and providing meaningful market access for small-scale artisanal fishers (Targets 14.4, 14.6 and 14.B).
Recommendations and Next Steps
A key recommendation of the initial pilot is the need to establish unique vessel IDs with the support of local government authorities, which will allow more meaningful monitoring and enforcement of landings.
In addition, the need to engage with, and involve, other firms purchasing from the fishery was identified in order to reduce the opportunities for side selling.
A second phase is being planned to address the constraints of the first. The goal of the second phase is to:
- Capture a minimum of 25% of the Blue Star Foods Indonesia sourcing;
- Integrate improved vessel activity geographic data
- Expand geographically
- Include more processors, mini-plants and fishers in Indonesia, particularly in co-packer conditions
- Replicate into the Blue Star Foods Philippine supply chain
The drivers of market access compliance requirements, improved social and financial impact in in artisinal fisheries and greater supply chain integration are powerful drivers for change in any industry. The relatively low cost now associated with data capture tools mean lead firms can utilize almost ubiquitous cell phone availability to cost effectively assess the degree and extent of IUU in their supply chain, while strengthening their impact objectives and improving market recognition.
This approach provides resource managers and NGOs as well as development agencies with a relevant, cost effective tool to engage private sector supply chains in achieving SDGs in a measurable, informed and data driven manner.
 “U.S. Seafood Import Monitoring Program”. Retrieved on 7 March 2018 from: https://www.iuufishing.noaa.gov/RecommendationsandActions/RECOMMENDATION1415/FinalRuleTraceability.aspx
 “Sustainable Development Goals”. Retrieved on 19 March 2018 from https://sustainabledevelopment.un.org/?menu=1300
 “Capture Fisheries Standard (CFS)”. Retrieved on 8 March 2018 from: https://www.fairtradecertified.org/business/producer-certification
 “Rescate de Valor”. (English: Value Rescue) Retrieved on 8 March 2018 from: http://rescatedevalor.org/
The Need for Sustainable Fisheries Finance
We know all the problems associated with overfishing and we know that research shows:
1) that switching to more sustainable management will lead to increased revenues and food security; and
2) the cost for doing so exceeds what can be provided through traditional development and philanthropic organization.
How do we get past the second to make the first possible? Supported by the World Bank, and with input from dozens of impact investors and fishery experts, we detail the main barriers and potential approaches to overcome them in our latest paper: Developing Impact Investment Opportunities for Return-Seeking Capital in Sustainable Marine Capture Fisheries.
Who Should Read This Paper
This paper provides an overview for international development organizations, development finance institutions, NGOs, and the governments they work with of (i) the key concerns that impact investors may have when considering the financing of sustainable fisheries, and (ii) potential approaches for public-private partnerships to overcome these obstacles. It is intended as a primer for these actors, to understand the perspective of the commercial impact investor.
This paper explains the central challenges that keep impact investors from participating in sustainable fisheries, and is structured along four main barriers:
- A lack of reliable fishery data
- Ineffective fisheries management
- Unreliable infrastructure systems
- A paucity of investment-ready enterprises
It then proposes three models for sequencing and combining different sources of capital to overcome these obstacles:
- Serial approach: Public and philanthropic funders first support the establishment of strong governance arrangements, improved data collection, and fishery management. Once these initiatives mitigate some of the risk associated with a fishery investment, then return-seeking investors are incentivized to finance sustainable infrastructure projects (often through public-private partnerships) and/or enterprises along the value chain, focused on outcomes that achieve a triple bottom line: social responsibility, economic value, and environmental impact.
- Consolidated approach: Governments negotiate agreements with a single private sector entity or cooperative to delegate fishery management responsibilities. The private firm or cooperative then simultaneously invests in fishery data, management, infrastructure, and triple bottom line enterprises.
- Parallel approach: A range of investors and other stakeholders (for example, governments, nonprofit organizations, fishing collectives) develop coordinated investments to improve fisheries data, management, infrastructure, and triple bottom line enterprises. Efforts can be separately funded, but they work in tandem and share the ultimate goal of achieving sustainable catch with an appropriately capitalized and profitable fishing sector.
Each of these sequencing models presents particular challenges and opportunities. Structuring investments to achieve triple bottom line outcomes is still a new idea within the fisheries sector. There is growing evidence from other sectors, however, including agriculture and forestry, that these types of investments are achievable. Examples include the Moringa Fund and Livelihood Funds, which bring together public institutions, private investors, and NGOs, using innovative investment models to simultaneously address environmental degradation, climate change, and rural poverty while helping businesses become more sustainable.
Attracting impact investments is critical for the future of fishery recovery and expansion—these projects cannot rely on short-term loans and grants; they need longer-term finance that is committed to sustainability and responsibility. Development organizations, NGOs, and other noncommercial actors have a critical and catalytic role to play in crowding-in impact investment for sustainable fisheries by sharing risk with the private sector, promoting policy reforms, and funding interventions (through either concessional lending, grants, and/or technical assistance) with the intention of removing the barriers to impact investment.
 The Moringa Fund is a EUR 84 million investment fund that targets profitable large-scale agroforestry projects with high environmental and social impact in Latin America and Sub-Saharan Africa. The fund makes equity investments of EUR 4–10 million per project and adds value through its technical skills, environmental and social expertise, and global network.
 The Livelihood Funds are a series of investment funds created by Danone, which brings together investors—including Schneider Electric, Crédit Agricole S. A., Michelin, Hermès, SAP, CDC Climat, La Poste, Firmenich, and Voyageurs du Monde—to invest over EUR 40 million to finance nine on-the-ground programs for mangrove restoration, agroforestry, and rural energy.
In our previous posts, we’ve discussed reasons and ways for involving private capital in fisheries reform, including taking a lead firm approach. This post about the parallel approach is a direct follow-up to the three models we propose for investment sequencing; we recommend checking out that post first.
Is there only one way to make a fishery sustainable? We don’t think so. That said, we do know that there are some key areas that need support on the way to sustainability. Indeed, whether to consider a “governance” or “markets” approach to fishery sustainability is a false dichotomy. In areas where a market is present, which is most, governance and markets must be considered simultaneously and balanced for the short and long-term benefits.
The working model we’re developing adopts a parallel approach to address the challenges associated with developing countries fishery reform. In this approach, the markets, and by definition, the private sector, are key partners. The commercial relationships with harvesters developed by this model are critical to ensuring support for long term fisheries reform given the lack of representation and organization at the base of the value chain. We explain our thinking in more detail below.
Approaches to Management
Under ideal circumstances, fisheries reform would have a “serial” approach to design, implement, and enforce regulations. Scientific and economic data would be the bases for robust fisheries management. With reasonable assurance that stocks will not be overfished, value chain participants can plan investments in tandem with stock recoveries.
Emerging market fisheries face significant social and political concerns to the serial approach. For example, legislating changes that result in reduced fishing effort to promote species and stock recovery has political and social ramifications that not all governments are prepared to address. Furthermore, the cost of enforcing such changes are likely to be higher than what is considered normal – both in monetary and social terms.
Given the desire to reform fisheries while also demonstrating the economic benefits associated with such reform, we propose that a “parallel” approach may be more appropriate in emerging markets. In this approach, different actors work in tandem to develop and implement measures to increase sustainability.
What’s are the Management Basics?
Investments to improve data and management are primary concerns for fisheries reform as these will demonstrate the success and costs of various efforts. Though species, geographies and cultural norms vary, there are some agreed-upon fishery management principals which will be informed and supported by good data. These include five parameters for:
- geographies and
- ability to access to the fishery.
Generally, social and legal changes necessary to create and enforce these management measures increase as complexity and distance from the resource increases. The degree to which the value chain can enforce them runs in the opposite direction. That is, the value chain has the greatest potential to enforce size, sex and seasons, but their ability to enforce rules decreases for geographic restrictions and even more so for access control. Rulemaking must involve local society and governments, and their participation is particularly important for complex tasks like access and geography restrictions.
The blue swimming crab (BSC) fishery in Indonesia is a good example of a parallel approach opportunity that currently engages both the value chain and government. National government has already adopted and passed restrictions regarding size and sex. The challenge now is how best to implement and enforce these efforts.
In our parallel approach model, value chain stakeholders in Indonesia have begun gathering data to help inform and reinforce decision-making. At the same time, the provincial government, in cooperation and communication with the local community, will set standards and provide enforcement for the five parameters. Managing seasonality, geographic limits and access restrictions are also actionable through the value chain. However, these will require a higher degree of social acceptance, enforcement and value chain adoption. Good data from working closely with cooperatives and harvesters will provide foundation for the harvest control strategies. We envision starting with the easiest strategies first, essentially moving from 1 (size) down to 5 (access control) over a period of less than four years for creation and testing of the rules. It is imperative that the local government and community create the standards to ensure the lead firm can work to establish sustainability within the fishery.
The value chain and lead firm approaches provide a valuable opportunity to implement effective enforcement needed to achieve sustainability. Value chain participants can insist on the adoption of these standards, which may then be verified based on effective data collection and using internal and external audits. The current working model also includes a proposal for the lead firm to make purchases through a preferred supplier network currently formed as a cooperative. Consequently, access to finance for value chain stakeholders will be contingent upon their compliance with the rules. Working in collaboration with local cooperatives and harvesters, the economics of this fishery are such that all participants should benefit from improved BSC size and abundance.
Final Thoughts on the Parallel Approach
Ideally, government would provide the necessary framework and policies to implement these strategies, while providing effective enforcement as in the serial approach to reform. However, in the absence of this involvement, providing market-based opportunities to adopt these measures in a socially acceptable manner may provide a viable alternative approach, which is why the parallel approach is the most viable in many fisheries like BSC in Indonesia.
lnvestors, including impact investors, can invest in the fisheries sector through two general approaches (see figure below). The first, more traditional, approach invests in fishing or seafood supply chain businesses. Examples at the level of fishers in supply chain include funding for fishing companies or cooperatives to purchase more sustainable fishing gear (e.g., that excludes bycatch or protects ocean habitats), improve vessels, or buy cold storage equipment. Further up the supply chain are investments in processing and logistics businesses. Return on these investments stems from increased productivity and efficiency of fishing; reduced waste; increased access to markets; ; and/or higher product values.
The second approach for investors is at the resource level. For example, in some fisheries like West Coast Groundfish in the United States, investors can purchase rights to fish with the potential to sell or lease these rights for environmental, social, and/or financial benefit in the future. Similar to purchasing equity or stock in a company, equity in the right to fish in a limited-access fishery can be bought and sold. Examples include tradable fishing licenses, effort quota (such as vessel days), and fishing quota. Return on these investments relies on fish populations maintaining or increasing in abundance in the future.
These resource-level investments in the second approach require legally enforceable rights and robust tenure systems. As such, they currently exist almost exclusively in developed country fisheries that have robust ocean policies and strong legal systems to create, manage, and enforce ownership and transfer of fishing rights. Few of these resource-level investment opportunities exist in developing country fisheries.
Because of the open access nature of fisheries, without fisheries policy and management in place, investments in the supply chain are unlikely, in and of themselves, to improve the health of a fishery. They may reduce the impact of a participating firm or entity, but unless all firms apply the same standard, negative practices will continue to impede the recovery of a fishery.
More impactful are well structured resource level investments intrinsically tied to the biological recovery of a fishery. Improved fishery health will likely benefit these investments and thus drive a virtuous circle of fishery improvements, leading to improved social and economic outcomes, which in turn increases the economic value of the fishery.
Adapted from: Inamdar, Neel, Larry Band, Miguel Jorge, and Jada Tullos Anderson. Developing Impact Investment Opportunities for Return-Seeking Capital in Sustainable Marine Capture Fisheries. Edited by Ashley Simons. Washington, D.C.: World Bank Group, 2016.
Marine fisheries provide an important source of food and livelihoods for millions of people globally, contributing more than US $274 billion to the global economy and some estimates of the potential net gain for improved management at US $600-$1400 billion in present value over fifty years after rebuilding fish stocks.
How can governments, development banks, philanthropic grant-makers, and nonprofit organizations create the conditions that will attract and recruit impact investors to participate in the sustainable fisheries sector and contribute to the long-term value of global fisheries? We at Wilderness Markets recently tackled this question as part of our work with World Bank.
The first step is to clearly understand the barriers that keep these investors from engaging with sustainable fisheries and the information they need to evaluate investments. With this knowledge in hand, leaders in government, international development, and philanthropy can align their own funding to create the conditions for more capital to contribute to sustainable fisheries.
The central challenges that keep return-seeking investors from participating in sustainable fisheries fall into four main categories: a lack of fishery data, ineffective fisheries management, unreliable infrastructure systems, and a paucity of investment-ready opportunities.
We propose three potential models for sequencing and combining different sources of capital to overcome these obstacles and achieve sustainable fisheries:
- Serial Approach: Public and philanthropic funders first support the establishment of strong governance, data collection, and management of a fishery. Based on the de-risking effort of these initial projects, return-seeking investors subsequently fund sustainable infrastructure projects (often in conjunction with public resources) and/or enterprises focused on triple bottom line outcomes.
- Consolidated Approach: Governments negotiate agreements with a single private sector entity or cooperative to delegate fishery management responsibilities. The private firm or cooperative then simultaneously invests in fishery data, management, infrastructure, and triple bottom-line enterprises.
- Parallel Approach: A range of investors and other stakeholders (e.g., governments, nonprofit organizations, fishing collectives) develop concurrent and coordinated investments in fisheries data, management, infrastructure, and triple bottom line enterprises. Each effort is separately funded, but they work in tandem and share the ultimate goal of achieving sustainable catch with an appropriately capitalized and profitable fishing sector.
Each of the above sequencing models has pros and cons, and each warrants additional exploration; making return-seeking investments that achieve the triple bottom line outcomes of social, environmental, and economic benefits is early on in it its evolution within the fisheries sector. They hold potential to attract additional funds and encourage private-sector approaches to help speed the transition to sustainable fisheries.
Adapted from: Inamdar, Neel, Larry Band, Miguel Jorge, and Jada Tullos Anderson. Developing Impact Investment Opportunities for Return-Seeking Capital in Sustainable Marine Capture Fisheries. Edited by Ashley Simons. Washington, D.C.: World Bank Group, 2016.
 World Bank. 2012. “Hidden Harvest: The Global Contribution of Capture Fisheries.” 66469–GLB. https://openknowledge.worldbank.org/bitstream/handle/10986/11873/664690ESW0P1210120HiddenHarvest0web.pdf?sequence=1
 Sumaila, Ussif Rashid, William Cheung, Andrew Dyck, Kamal Gueye, Ling Huang, Vicky Lam, Daniel Pauly, et al. 2012. “Benefits of Rebuilding Global Marine Fisheries Outweigh Costs.” Edited by Julian Clifton. PLoS ONE 7 (7): e40542. doi:10.1371/journal.pone.0040542.
What’s an easy way for an investor to tell if a natural resource-based enterprise is going to be viable in three to five years? Part of that answer lies in evaluating the business and the regulatory environments in which it operates, but for natural resources in particular, the resource base trend needs to be examined; is it predicted that there will be more or less in the future, based on current extraction rates and scientific estimates of the resource level? And for conservation-focused impact investments, how can investors ensure they are not using more than the ecosystem can sustain?
In wild-capture fisheries, this translates to: “Will there be more or less of the fish to harvest in the future? Will my investment exacerbate overfishing?” Less fish to harvest means the effort level, and thus costs, will need to increase to find the remaining fish.
We’ve recently been puzzling through the easiest way for banks and impact investors to gauge the investability of fisheries enterprises, with a focus on Indonesia. Indonesia hosts some of the most biodiverse ocean ecosystems on our planet and is the world’s second largest harvester of wild capture fish. Banks and investors need quick, easily understood data that doesn’t unnecessarily burden their due diligence process but ensures they aren’t contributing to overfishing.
One tool that is already available in many fisheries is the stock assessment status, usually indicated as under- or moderately exploited, fully exploited, or over-exploited. The exploitation levels reflect scientific data on whether the fish in a fishery (the stock) are being sustainably harvested. Fully exploited indicates a stock that is thought to be fished and reproducing at nearly equal rates, i.e., the amount of fish harvested is the same as the fish being hatched and surviving to maturity. Over-exploited means harvest rates are too high, and under-exploited means they could increase rates without having a harmful effect on stocks.
Indonesia’s Ministry of Marine Affairs and Fisheries recently released the results of the National Commission on Stock Assessments (NOMOR 47/KEPMEN-KP/2016 TENTANG). The assessment provides an updated snapshot of ministry data in each fishery management area for the status of nine Indonesian fishery stocks.
In addition to focusing government investments on improving the fishery health, we think the data can be useful for banks and investors. The assessment data can help investors quickly determine the potential health of the resource an enterprise relies on, helping to ensure they are not causing more fish to be used than can be replaced. The key to balancing conservation and investment entails finding new opportunities to do more, without using more.
The findings and conclusions in this report represent the interpretations of Wilderness Markets and do not necessarily reflect the view of expert stakeholders. This publication has been prepared solely for informational purposes, and has been prepared in good faith on the basis of information available at the date of publication without any independent verification. Wilderness Markets does not guarantee or warrant the accuracy, reliability, adequacy, completeness or currency of the information in this publication nor its usefulness in achieving any purpose. Charts and graphs provided herein are for illustrative purposes only. Nothing contained herein constitutes investment, legal, tax, or other advice nor is it to be relied on in making an investment or other decision. Readers are responsible for assessing the relevance and accuracy of the content of this publication. this publication should not be viewed as a current or past recommendation or a solicitation of an offer to buy or sell securities or to adopt any investment strategy.