Funding Infrastructure Gaps

THE STAR Businessweek DECEMBER 22, 2018

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Funding infrastructure gaps Public infrastructure has long been viewed as a risky investment but 2019 brings new, potentially lucrative opportunities across the region

By Catherine Morris, STAR Businessweek Correspondent

Home Office in ‘golden visa’ climbdown The UK Home Office has reversed a decision to suspend its so-called “golden visa” programme offering fast track settlement to investors less than a week after announcing it would close the scheme over concerns about money-laundering Page 3

Venezuela is the forgotten loser of 2018 There have been many unfulfilled expectations and disappointments in the energy market during 2018. At the beginning of the year I listed four issues for readers to watch

Resilient building has been a hot topic in the Caribbean of late as damage from natural disasters highlighted infrastructure gaps across the region. For too long, governments have largely ignored infrastructure needs, preferring to invest in shorter-term projects either for electoral gain or simply to address more pressing issues.

Continued on page 4

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DECEMBER 22, 2018

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Venezuela and Trinidad Show The Strain of Modern Refugee Crises

By ED Kennedy, STAR Businessweek Correspondent

H

istorically, many humanitarian crises, though tragic, have been foreseeable. The displacement of citizens after major wars is a common example. Historians today continue to study the impact of conflicts like World War II, Vietnam and the more recent incursions in the Middle East, that have served as a trigger for crisis migration.

The recent experience of Venezuelans warrants a different consideration. While events this year have confirmed that this chapter is now the biggest migration crisis in Latin American history, the pace and scale of its emergence has also been relentless, with over 2.3 million people — around 7% per cent of the country’s population — departing in just a few years.

The proximity of Trinidad and Tobago to Venezuela has ensured that this twin island nation would be among those Venezuelans look to first.

And the latest development in this relationship provides a window into the very heart of the Venezuelan issue, and signifies a new chapter in the global emigration debate.

The Speed of Venezuela’s Decline

In 2015 the United Nations credited Venezuela as the nation that had achieved the greatest progress in the fight against the eradication of hunger throughout Latin America and the Caribbean.

Yet in November 2018 Venezuela received US$9 million in emergency aid to help alleviate medicine and food shortages. As with any economic meltdown, there are always numerous factors in play behind such a rapid turn of fortunes, and this is true in the oilabundant nation.

Undoubtedly at the forefront of these were the Venezuelan government’s populist policies. For a time the socialist ethos by the government spurred the economy but it ultimately came crashing down decisively. The government was officially declared in default in November 2017, further driving the situation from bad to worse.

Colombian police officers stand in front of people lining up to try to cross into Colombia from Venezuela through Simon Bolivar International Bridge in Cucuta, Colombia, on January 24, 2018. Carlos Garcia Rawlins/Reuters

Venezuelans look to Trinidad

With an economy faltering and social unrest growing, many Venezuelans understandably looked to depart and seek safety in neighbouring nations.

These nations have come under great pressure to provide humanitarian relief to Venezuelan migrants, and tensions have risen both within domestic political circles and between the ruling Maduro regime in Venezuela and other regional governments.

At its shortest measurement, the distance between Venezuela and Trinidad’s shores is a mere 11 kilometres, with part of Venezuela’s expansive coastline encircling Trinidad’s, like a crescent moon, on the Gulf of Paria.

Looking beyond this issue’s politics

to simple logistics, it’s difficult to overstate the challenge for Trinidad’s border security officials, especially when this crisis is compounded by former Venezuelan fisherman-turned-pirates, who operate in waters that Jonathan Franklin of Bloomberg called “the most lawless market on Earth today”.

Longstanding international convention surrounding refugees has been tested anew in the era of globalisation.

Challenges to community stability — whether they’re economic, like a market meltdown, or a security threat, like a terrorist attack — can arise rapidly without warning, and play out over multiple locations.

There is no suggestion that the emergence of these issues offers easy absolution to those who would advocate

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for nations to totally close their borders; just instead a recognition that this is a difficult matter, now made more difficult by the interconnectivity of our world.

Trinidad In The Refugee Debate

Border security has been a hot political issue globally. The tensions between the Trump White House and Mexico City have evidenced this especially.

The border security debate between Mexico and the US has long raged. So too the ‘debates in the debates’, such as how critics of the White House point to rising illegal border crossings via the Canadian side into the US, that is by and large ignored, as a vivid example of the distance Continued on page 5

UK IMMIGRATION

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Home Office in ‘golden visa’ climbdown Latest embarrassment for struggling department comes after threat of legal challenge Robert Wright in London

T

he UK Home Office has reversed a decision to suspend its so-called “golden visa” programme offering fast track settlement to investors less than a week after announcing it would close the scheme over concerns about money-laundering.

The surprise reversal on Tuesday came after the department received a letter from a group of immigration lawyers warning it that the suspension of the Tier 1 investor visa was illegal and would lead to a legal challenge.

The climbdown is the latest embarrassment for a department that has suffered considerable reputational damage this year because of its role in the Windrush scandal over the treatment of longstanding Commonwealth immigrants to the UK. The department has also been forced to admit that it improperly demanded DNA tests from some applicants for visas and passports to prove their eligibility, following revelations in the Financial Times, and has announced a wideranging review of the functioning of the immigration system.

In a statement the Home Office said the Tier 1 (Investor) visa was “not currently suspended”. But it went on: “We remain committed to reforming the route.”

It added that a further announcement would be made “in due course”.

The department declined to explain why it had changed course so soon after the announcement on Thursday

by Caroline Nokes, immigration minister, that no new applications

The UK Home Office made an abrupt about-face announcing that the Tier 1 Visa programme will be reformed, not suspended, as originally stated

would be accepted under the programme, which would be suspended from midnight on Friday.

However, the Immigration Law Practitioners’ Association (ILPA) confirmed that it had written to the Home Office after Thursday’s announcement and warned of the potential consequences of the suspension. The letter complained that the department had not followed usual practice and given those involved 28 days’ notice of upcoming changes, nor had it published the new rules.

ILPA said it was “extremely disappointed” by the abrupt change. “The situation in our view makes a mockery of the principles of certainty and stability that are inherent in the rule of law,” it said.

Nick Rollason, head of immigration at

“The government shouldn’t be announcing that things are going to be suspended when they don’t have ready the legal instrument to do that,” Mr Rollason said.

Kingsley Napley, a London-based law firm, said it was “pretty concerning” how the announcement and its reversal had come about.

“The government shouldn’t be announcing that things are going to be suspended when they don’t have ready the legal instrument to do that,” Mr Rollason said.

The Tier 1 investor visa has been controversial because of concerns it might be making it easier for corrupt business figures and government officials to launder money through the UK. Under the programme, foreign nationals who invest £2m or more in the UK can apply for permanent residence after five years. Those who invest upwards of £5m can apply after three years, while those investing £10m or more wait only two years.

The scheme is particularly popular with Chinese and Russian nationals and has faced intense scrutiny after the UK’s relations with Russia deteriorated in the wake of the apparent poisoning of Sergei Skripal, a former Russian agent, and his daughter Yulia, in Salisbury in March.

Leftover poison from the incident has been blamed for the death in July of Dawn Sturgess, a British woman who was apparently exposed to novichok, the agent implicated in the incident.

ILPA’s letter warned the Home Office that the announcement would disadvantage people who had already taken steps — such as purchasing property — in connection with applications under the scheme. It pledged to launch a legal challenge if the department failed to rescind the planned changes.

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Funding infrastructure gaps Continued from page 1

moved to address this issue as interest in PPPs grows. “We are seeing the trend of PPP projects coming up; the challenge now is to get those projects implemented and developed in a transparent manner,” said Samuel.

Areas of opportunity

The increasing intensity of hurricanes, flooding and tropical storms has necessitated an upgrade of essential infrastructure and this is an area where the private sector can step in

And it’s understandable — public infrastructure is widely regarded as a massive drain on the public purse and funding such large-scale work can be difficult. This is where the private sector can play a role. Public Private Partnerships (PPPs) have been under-utilised in the Caribbean but have huge potential to deliver resilient, sustainable infrastructure that doesn’t stretch the government coffers.

According to Jorge Familiar, World Bank Vice President for Latin America and the Caribbean: “Combining public and private capital and taking advantage of the efficiency and innovation of the private sector can make a huge difference.

When well designed, PPPs bring greater

efficiency and sustainability to public services. As the region emerges from six years of economic slowdown, PPPs can help it boost infrastructure investments and strengthen the momentum for growth.”

Under-used

Head of Public Private Partnerships for the Caribbean Development Bank, S. Brian Samuel believes that the region is playing catch-up when it comes to realising PPP potential. Speaking on a panel for the Caribbean Infrastructure Finance Forum, held earlier this month, he said: “Sometimes the Caribbean is a little bit late in adopting international trends and this is one of them. In the region we are good at paying

lip service to PPPs but when it comes to actually doing them, we need some help.”

There are many factors to explain why the Caribbean has not embraced PPPs but chief among them is concerns of corruption. A lack of transparency translates into a lack of competition as preferred bidders are permitted or encouraged to jump the queue.

Procurement processes are often ad-hoc, inconsistently implemented or simply for show. In areas where this is a longstanding problem, highly-skilled contractors are dissuaded from even entering the bidding process — lowering the standard of providers and, ultimately, the completed work.

The Caribbean Development Bank has

One of the most potentially profitable areas for infrastructure investment is the energy sector. With the Caribbean becoming ever more aware of the need to cut pollution, promote renewables and lower the cost of electricity, this is a growth industry that is set to benefit from cutting-edge technologies. As the region moves to cut its diesel dependency, opportunities are emerging in solar, wind and geothermal energy.

Another area of environmental concern that could offer opportunities is waste management. Waste to energy initiatives, recycling projects and waste disposal efforts are gaining interest as governments realise that waste disposal requires a viable, long-term, sustainable strategy. Trinidad is currently working on a solid waste PPP while Bermuda is considering a PPP mechanism for its wastewater treatment.

Private sector investors should also consider transportation infrastructure.

Many countries in the region have adopted the PPP framework to upgrade highways, airports and sea terminals. The increasing intensity of hurricanes, flooding and tropical storms has necessitated an upgrade of these facilities and this is an area where the private sector can step in.

When it comes to disaster recovery, coastal protection infrastructure projects are paramount and global groups such as the International Monetary Fund are urging the Caribbean to focus on this area in the near future.

Attracting investment

The opportunities are there, but is there interest? Samuel believes so, but the project itself must be well-defined and well thought out. “There is actually more money than projects. If you have a strong project, with a strong sponsor, well-structured and viable,

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you will get financing for it. Many projects tend to get rushed. You are going to the market with half-baked projects, which are not bankable and you are going to have challenges.”

In assessing projects, private partners prioritise security and return. Many PPPs fail to launch because they cannot deliver on either. A strong PPP sector in the Caribbean is dependent upon a strong institutional and regulatory framework within which these projects can be developed, executed, monitored and managed. According to a 2017 report by the World Bank, 19 countries in Latin America and the Caribbean have PPP legislation and 17 have dedicated PPP units. The ideal enabling environment for PPP success requires structured procurement processes, bankable contracts that share risk among the parties, and a means of robust oversight during project delivery.

In recent years, Saint Lucia has been positioning itself as a PPP-friendly

destination. In 2015, as it sought a private partner for the redevelopment of Hewanorra International Airport, the government adopted a PPP framework for the country with assistance from the World Bank. The policy’s objectives are to provide value for money, prioritise fiscal responsibility, ensure transparency, assess environmental impacts of PPP projects and promote partnership and inclusivity.

But putting a strong foundation in place is only the first step. According to Samuel, small island governments such as Saint Lucia’s need to be more proactive in selling themselves to potential partners.

Putting the right framework and policies in place is key, but then governments should identify their needs and locate the right partner in the international marketplace — whether through trade shows, government delegations, conferences or simply online connections. “You have to use all kinds of different platforms. There is somebody out there for you.”

Hurricanes and heavy rain are not the only weather-related causes of road deterioration. Warmer weather in Saint Lucia means more cracks in frequently-trafficked roads and a greater need for regular upkeep

DECEMBER 22, 2018

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Venezuela and Trinidad Show The Strain of Modern Refugee Crises Continued from page 2

Curaçao hosts 16,000 undocumented Venezuelans who live under threat of summary deportation and many more have fled crisis at home to Trinidad and Tobago

between good politics and good policy in Washington on this issue.

The rapidity and scale of Venezuela’s crisis is of a different consideration but the same challenges arise surrounding the Venezuela migration issue, like any other.

Presently Trinidad, though a signatory to the United Nations 1951 Refugee Convention and its 1967 Protocol, has long resisted calls to adopt that into domestic law.

Given that by the middle of 2018 over 3,300 Venezuelans had applied for asylum in the nation of 1.3 million, it’s not hard to understand that the desire of Trinidadians to help could be strained by the island’s capacity to properly offer it.

While there is unfortunately always a small segment of any nation that champions ‘Fear of the Other’, in Trinidad there are simple questions of resources and structures. Any reasonable person could identify the very real and unique hurdles there.

Nations with 100 million or more may not blink an eye at processing 3,300 asylum seeker claims, and can do so with speed and precision given their years of accepting people from other countries.

Yet the experience of Trinidad is further complicated by the fact that, historically,

Venezuela shares its place as a leading source of emigrants to Trinidad alongside Syria, Bangladesh, Jamaica, Nigeria and Colombia, each with expats making strong claims for residency. Even if not as urgent as Venezuela’s, each forms a part of Trinidad’s future, and its own right to ultimately chart a course for how it wishes to engage with the world beyond its borders.

A New Landscape

The story of Venezuela and Trinidad is one that the people of Latin America and beyond must observe. The lesson is: If business can become truly global, so can humanitarian crises.

It may not appear, at first, that the path of Venezuelans to Trinidad is truly a global concern but it demonstrates the tension that can arise when international conventions of refugee support require certain action, yet small nations are usually not adequately resourced for a regional crisis.

The recent volatility experienced in the currencies of Argentina and Turkey, and the news that South Africa is now in recession, are not crises on the scale of Venezuela but they are further sign that all nations now have truly global citizens. So now a new conversation is required about what it means to be a responsible one.

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DECEMBER 22, 2018

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A new approach to tourism analysis is long overdue

S

By David Jessop

ince the mid-2000s the ability of the Caribbean tourism sector to generate rapid economic growth has been widely accepted by international financial institutions such as the IMF, World Bank and the InterAmerican Development Bank. This seems to have occurred at the point at which it became apparent that services exports were starting to eclipse the export of goods and commodities in much of the region.

Despite this, and the now widespread recognition of the centrality of tourism to the Caribbean economy, development institutions continue to struggle to find sound data on which to undertake the analysis necessary to guide economic policy.

This is largely because the tools the region uses to measure tourism’s performance are still rudimentary and unreliable. So much so that decisions about pricing, taxation, competitiveness, and the possible impact that industry related decisions may have on national economic performance, are all too often based on flimsy data.

The consequence is that without evidence

Are policymakers basing their decisions on inaccurate tourism data?

to the contrary, politicians and institutions have become used to equating increases in visitor arrivals with economic growth; a belief that visitors are prepared to bear almost any level of taxation; that airlines are in some way responsible for the high cost of a Caribbean vacation; and that building more hotel rooms automatically increases the revenues governments receive.

Inspired by the ‘Big Mac Index’, it measures the price of a basket of typical expenditures during a beach holiday based on three-star hotels, taxi fares, beverages, and meals, but does not include air travel costs In response, researchers, academics and others have been struggling to obtain verifiable statistics and information that might support a better analytical framework for policy making towards tourism. Their hope has been that by doing so, governments and the industry can then develop facts-based responses to issues such as sustaining competitiveness, the interrelationship between visitor

numbers, taxation and earnings, and changing economic circumstances in source markets.

These are matters of some importance as there are indications that the region’s tourism sector may be performing less well than recent headlines suggest. This month, for example, the World Tourism Barometer produced by the UN’s World Tourism Organisation indicated that arrivals into the Caribbean have this year so far fallen by 8%. There are also other indications that Caribbean tourism is on average less competitive than other parts of the world.

This suggests that new approaches are required to tourism analysis and data gathering, and the relationship of both to forecasting and policy formulation.

Until relatively recently the industry rarely figured in international financial institutions econometric modelling or in their subsequent recommendations, largely because of the absence of a substantial volume of reliable Caribbean statistics.

However, this may be set to change as the growing availability of big data and more sophisticated algorithms now make it possible to produce indicators in much shorter periods of time using consistent information from multiple non-Caribbean data sources.

Since 2015 the IMF has been producing, largely for internal purposes, an index of the nominal cost of a one-week beach holiday in eighteen small and large Caribbean destinations.

Inspired by the ‘Big Mac Index’, it measures the price of a basket of typical expenditures during a beach holiday based on three-star hotels, taxi fares, beverages, and meals, but does not include air travel costs. Despite some shortcomings, the figures clearly demonstrate that the nominal cost of an average one-week beach holiday in the Caribbean is consistently higher than on average elsewhere in the world.

The importance of this and its policy implications emerged in a recent webcast, ‘A Week on the Beach’, led by the economist Marla Dukharan.

Continued on page 8

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Opinion – Oil

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Venezuela is the forgotten loser of 2018 Given its resources, the country should be one of the richest in Latin America

By Nick Butler FT Energy Commentator

T

here have been many unfulfilled expectations and disappointments in the energy market during 2018. At the beginning of the year I listed four issues for readers to watch.

• Renewables, despite continuing price falls, have failed to break through.

Hydrocarbons remain entrenched as the dominant source of energy supply.

• China’s shift to a lower carbon economy has slowed down. Coal use has increased again after two years of decline and, as a result, emissions have grown.

• The political situation in Saudi Arabia has not been stabilised and the killing of journalist Jamal Khashoggi in Turkey has only served to remind the world of the dangers of the concentration of power in the hands of Crown Prince Mohammed bin Salman.

• Perhaps the only true success story has been the continuing expansion of shale production in the US — lifting total US oil production by 2m barrels a day year on year, according to the latest official figures. That surge in output has contributed to the persistence of low prices — at just over $60 a barrel for Brent it is slightly lower than 12 months ago.

But another development deserves note.

Nearly 20 years after Hugo Chávez came to power, Venezuela has continued to decline. Oil output is down from over 2.2m b/d in January to some 1.1m b/d in

Venezuela’s economic crisis has led to a growing refugee crisis and an exodus of talent © AP

November. That represents a fall of over 68 per cent from the country’s peak production of almost 3.5m b/d in 1998.

The economy is shrinking but the country has so far refused to produce economic data on gross domestic product or inflation despite repeated requests and potentially a major default on Venezuela’s sovereign debt. The country’s inability to pay bondholders could lead to it losing over the next few months of one its main assets — the international trading company Citgo.

What should be one of the richest countries in Latin America, given its extensive oil and mineral resources from gold to bauxite and diamonds, is now one of the poorest. Basic supplies and food are scarce and, as well as an exodus of talent, there is a growing refugee crisis as people try to escape to neighbouring countries such as Colombia and Brazil. According to a recent paper from Brookings, there

If oil were scarce, the pressure for intervention — especially in Washington — would be intense are already more than 3m Venezuelans living outside the country, including a million in Colombia.

The exodus includes the desperately poor but also skilled workers and technicians on whom the economy depends. Within that group are many of those who built the state oil company PDVSA but are fleeing the corruption and mismanagement that now dominates the company.

What is left of the economy only keeps going as a result of loans from Russia, in return for which Moscow is being allowed to establish a military base in the country and cash-for-oil deals with the Chinese.

But there has been no regime change.

Nicolás Maduro remains in power. One reason for that is repression led by the president’s allies in the military. The other is the fact that Venezuela has ceased to matter very much to the global oil market. The US no longer depends on Venezuelan oil imports. International companies would love to return but will make no serious investments while the current government remains in power.

If oil were scarce, the pressure for intervention — especially in Washington — would be intense. But the market has dealt with the loss of Venezuelan exports and a significant cut back in Iranian supplies because of US sanctions without blinking.

For much of the year I thought events in Venezuela would shape the market and push prices up. I was wrong. The global surplus of oil supply is profound even though demand continues to grow.

It is hard to see this balance changing in 2019. The oil market has learnt to manage without Venezuela. That means the country’s political problems are unlikely to be altered by external intervention. The next “Bolivarian revolution” will have to come from within, driven perhaps by desperation as oil production declines further and possibly by a growing reluctance on the part of the Chinese to invest further in a bankrupt regime. Until that happens the already tragic situation in Venezuela can only deteriorate further.

I wish Venezuela a happier New Year and all readers the compliments of the season.

The writer is an energy commentator for the FT and chair of the King’s Policy Institute at King’s College London

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DECEMBER 22, 2018

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Bartlett Defends Retention In Tourism As Highest Among Industries

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inister of Tourism Edmund Bartlett, in conversation with financial and market analysts, acknowledged criticism that the leakage of earnings from the tourism sector was as high as 70 per cent, but said the figure was still the lowest among big industries in Jamaica.

Essentially, of the money spent on Jamaica’s tourism products and services, just 30 per cent is thought to stay in Jamaica. The rest flows overseas to foreign investors in the Jamaican sector, and external service providers.

But Bartlett, in his defence of how much Jamaicans benefits from tourism spend, said at the latest ‘Breakfast Conversation with Analysts’ hosted by MoneyMasters Limited on Thursday, that the retention rate in Jamaica was about midpoint the performance of its regional peers.

“Thirty per cent retention is perhaps the highest value added in any industry in the country today. Not even bauxite gives you 30 per cent,” he reasoned.

His statement came just as MoneyMasters President Claudette Crooks was wrapping

A new approach to tourism analysis is long overdue Continued from page 6

Jamaica Minister of Tourism, Edmund Bartlett

up the event. While thanking Bartlett for his participation in the forum, she urged his ministry to publish targets to reduce leakages by 2030 — the date by which Jamaica hopes to be reclassified as a developed country.

“So while we monitor the growth in

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arrivals, we also monitor closely the growth in our retention, no matter how small it is,” said Crooks, who also called for the establishment of a commodities exchange for farm items, including tomatoes and other crops that flow into the tourism trade.

Earlier, Bartlett said in his speech that Jamaica ranked 13th among the countries in the world most dependent on tourism and that leakages will only be managed by increasing linkages.

“This is why we established a $1 billion revolving loan, through the Tourism Enhancement Fund and the EXIM Bank, to further assist with investment for micro and small Jamaican-owned businesses to build capacity to create and compete,” he said. EXIM received 51 loan applications totalling $941 million, according to information in the written speech.

The tourism sector is performing at record levels, with around 4.3 million annual visitors who spend US$3.3 billion, with a growth rate that is six times that of the overall economy.

“At US$3 billion, it means US$1 billion is in circulation around the island, and you feel it in the industries that are connected,” the tourism minister asserted.

“As you expand your loan portfolios, look at tourism seriously,’’ he said, while noting that more local investment is one of the ways to arrest or reduce leakages.

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The online broadcast, which can be seen on YouTube, indicated that at a staff level the IMF is now working towards developing a more sophisticated understanding of tourism in ways that will eventually allow the findings to be built into future economic modelling. To achieve this, the Fund staff intend making more use of ‘big data’ and are now teaming up with TripAdvisor and others, utilising their data and analytics to support the development of a more sophisticated analysis.

What, in outline, the ‘Week on the Beach’ exchanges revealed was that, on average, a Caribbean three-star hotel costs more than in almost all other beach destinations; the Caribbean is 30 to 50% more expensive than Central America and Mexico; the Asia Pacific region is still the cheapest region in the world; the average cost of a week in Cuba is comparable to Central America and significantly lower than in other sample Caribbean countries; the number of flights rather than airlines positively impacts on competitiveness; the number of rooms a destination has may not be significant; and the overall findings were largely consistent over the four-year period surveyed.

It also indicated the importance of external factors.

During the webcast, Nicole Laframboise, the Deputy Division Chief, for its Western Hemisphere southern division observed that a 1% increase in the exchange rate could lead to a 0.16% decline in arrivals, and that this and other influences required governments and the industry to contain exchange rates and costs, particularly at the lower more price-inelastic end of the tourism market.

The exercise still has shortcomings. For example, it is hoped that in time a separate methodology can be developed to value the competitiveness of all-inclusive hotels and cruise ships, and an approach created that can quantify less tangible impacts, such as crime.

The IMF hopes to create eventually a much bigger tourism related matrix to supplement existing Caribbean tourism indicators to inform all aspects of the IMF and World Bank analysis and forecasting for the region.

This new big data led approach should be welcomed, particularly if it enables the region and those beyond to understand what is really happening to Caribbean tourism and how it relates to, and helps explain, Caribbean economic performance.

Apart from enabling external development agencies to better advise — they still have very few experts on the sector — it should also enable more thoughtful voices in government and the industry to demonstrate why decision making on tourism must be seen in the round and is about much more than simply trying to balance the budget.

David Jessop is a consultant to the Caribbean Council and can be contacted at: david.jessop@caribbean-council.org

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