Chief Compliance Officer Roundtable

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MODERATOR/PANELIST: NATALIA SHEHADEH PANELISTS: STEVEN GYESZLY, JAY MARTIN, RYAN RABALAIS, JOHN SARDAR

MS. SHEHADEH

In preparing for our chat today, I did a little bit of news review. In regard to ethics cases, allegations, and challenges, 2018 was a pretty stunning year. For example, recent cases include the university admissions scandal, Facebook Cambridge Analytica disclosures, very high profile individuals being ousted from jobs in the wake of the #MeToo movement, and Goldman Sachs getting wrapped up in the 1MDB massive scandal in Malaysia with respect to the former regime. Also, the allegations, with respect to Ghosn (Renault/Nissan) for alleged selfdealing and the Deutsche Bank anti-moneylaundering case—the list goes on and on. That is a survey of just the last twelve months.

What do you think is the global state of corporate ethics from your perspective?

MR. GYESZLY

One thing that I find interesting is that it is somewhat easy to get involved with some of the glamourous topics, like anti-corruption or cybersecurity, but some of the cases you mentioned are a return to some of the basic components of our code of business conduct. These cases lead us to refresh and re-examine what our compliance risks may be. One focus this year is the “back to the basics,” focus within our code of business conduct.

Natalia Shehadeh - Senior Vice President and Chief Compliance Offlcer for TechnipFMC Steven Gyeszly - Chief Compliance Counsel for Marathon Oil Jay Martin - Senior Counsel for Wilkie, Farr & Gallagher Ryan Rabalais - VP & Chief Compliance Officer of Rowan Companies John Sardar - Chief Compliance Officer for Noble Energy, Inc.

MR. RABALAIS

I think the state of corporate ethics is better than it has ever been in one sense. However, there is still a ton of work to do— plenty of work to do for a career for anyone entering the field. The issues that compliance departments and compliance officers face are broader in comparison to issues that arose even a few years ago. For example, if company executives are looking at the compliance department and asking how the corporation is dealing with #MeToo, financial scandals, data privacy, things well beyond FCPA or export regulations and the problem does not fit anywhere else, the executives will ask the chief compliance officer about it. Honestly there is an ethical angle to just about any issue, if you look at it in a certain light. Certainly, if it does not sit well with Human Resources or through the legal group, or whomever, the executives will probably look to the compliance department, which needs to have some answer. Whether compliance professionals want to deal with the issue or not, we are tasked to deal with all those issues and having to anticipate what those may be by staying up with the headlines.

If for no other reason, some shareholders are demanding things of their companies that they did not in the past or were silent on in the past; you better believe that gets board members attention. So, board members in turn on their last day are asking about X or Y, and again, you have got to have some form of an answer. If for no other reason than shareholders are raising these issues, they are going to come to light within the organization. God forbid you get an activist shareholder really targeting the company or put on your board in some instances. While these are things that might have happened in the past, they just did not happen in that way. This puts a lot of demand on the compliance department.

MR. MARTIN

There are a lot of companies across the world that now have compliance officers and compliance roots where they did not a few

years ago. You would think that would have a positive impact and lead to less compliance issues, particularly the more serious ones. I think there has been a positive impact, but other factors have pushed everything in the other direction. Part of that is globalization. Part of it is that competition is intense across the world. Our business community colleagues are under unprecedented amounts of pressure. The business models have been changing at warp speed. Acquisitions are frequent. There is a tremendous amount of outsourcing functions and a tremendous use of third parties.

We were in one-hundred and twenty countries, so we used to think of American companies as an American company with some international operations. Now, there are a lot of American companies that are truly international if you examine the makeup of their board and their senior management group. Compliance for the U.S. firms is still a challenge. I think how simple that would be to not worry about one-hundred and twenty countries. Each of those countries has its own challenges, culture, day-to-day working environment, and business model. If the business continues to change at warp speed, compliance must change to keep up with business. That means if you are not worried about compliance every minute of every day you are not doing your job. You cannot get to a steady state on compliance. If you are standing still, you are falling behind. There needs to be consistency in the processes, but you want to continuously evolve those to deal with the risks that are changing every day.

MR. SARDAR

Licensed offering and social license offering have given us the function to have a bit more say within our organizations. Historically, compliance officers have been the custodians of the company’s ethical practices. The business leaders ask the compliance department for advice when they feel they are being challenged on their social license offering. For each one of us, our mandates have changed. The way companies are looking at their risks has broadened, providing chief compliance lawyers with opportunities.

MS. SHEHADEH

Over the last five years, it has been a conversation associated with culture. Suddenly, in the last few years, we started to see a pivot towards culture and the convergence of ethics and the impact that strong enterprise cultures can have as a deterrent to non-compliant behavior, or as an encouragement or reinforcement, to reduce risk. With that, comes some budding recognition that “gone is the day that you don’t need to teach right from wrong.”

Most of our compliance programs evolve with the focus on triaging a legal risk area, for example, whether an act violates the law as it is written in the anti-bribery and corruption (ABC) space. Now, the convergence of this opportunity is not just teaching employees about the law to mitigate legal risk, but it is about getting away from the assumption that everyone grew up in the same household and learned from the same lens what right from wrong is. We cannot make that assumption anymore because the risk is getting too big. The litany of cases from 2018 alone shows this.

MR. MARTIN

I think there’s some truth there, but the reason we are all in business and under more pressure than we have ever been is because we live in the gray areas. If you talk to any general counsel, the things that reach the general counsel’s desk are usually the most difficult, the grayest area issue, because otherwise they would have been resolved before they ever got to the General Counsel or to the Chief Compliance Officer (CCO).

There are a lot of times where you are here in the twilight zone, this gray zone, where you cannot say to the business client that there is zero risk. There is also a risk in losing the deal. Attorneys are always trying to balance the mission of what is the legal compliance role, which is to enable operations to do their deals, but to do it in a legally compliant way. You have to know when you say no. However, if every other deal you kill because you cannot find a compliance solution, as one CEO said, “we can be the most compliant company in the world, and we also should be going out of business because we can never do a deal in one of these countries.”

That is the challenge. Because of the fast moving environment, the best protection is creating a culture. CCOs cannot be everywhere, you cannot be your brother’s keeper or micromanage people. The pace of the business is so rapid and at a global scale that you have to trust people. The vast majority, hopefully ninety-nine percent of the people want to do the right thing. If you

are one of those people that want to do the right thing but the issue is in an ambiguous area, bring it up the ladder and get other sets of eyes to look at it. What we worry about is not the things we know about but the things that we do not know about. That is what terrifies a CCO. Most companies have a lot of smart people and a lot of assets. If you determine the issue you can get the right set of eyes on it and come up with a solution.

MR. RABALAIS

Each company has a different culture. As you go to a new company, I think it is very important, even in the interview stage, to get to know that company’s culture. It is a big deal. Within that, there is the nationality of people. A lot of the companies we are talking about employ people from many different countries. You encounter not just different nationalities but different cultures of business; whether there is an aggressive business mindset where they conduct business at a rapid pace or something more moderate than that. What the business puts its employees through and how they experience working at that company shapes a lot of that culture.

Every company that I worked for has had an FCPA investigation or settlement, except one, where I work right now, Rowan. It is a stark difference to me, the companies that I worked for that had those experiences, those employees were put through the ringer, particularly if there was a monitor.

When I worked at Noble, some individuals had been charged personally in addition to the company being charged. There were people who were deposed in Washington, D.C. as part of the FCPA investigation. Some of those people deposed were West African operations-personnel that do not usually put on a suit and go to D.C. for any reason. At the other end, there would be a company that did not have as severe of an investigation experience or that has never been investigated. The operations team wanted to do the right thing and they were good people, but they had not been through the ringer, and there is a big difference. Literally, at some of the companies with serious cases, people in these high-risk jurisdictions would call me to say, “when are you coming over to do the training? When are you coming over to do this year’s risk assessment?” The things that shape the culture are multifaceted. The bigger the company, the more countries the business operates in, the more lines of business undertaken, the more varied it gets, the more comfortable the attorney is in acting in that type of world. If compliance personnel have any cultural background or experience, that helps, because the attorney is going to deal with this working in compliance for a multinational company.

The culture of the company matters. I cannot understate it. Yes, the board has ideas about it and do help shape it, but it goes down to the people on the front line that are working in these countries day to day. It is kind of a comment on the countries. People do want to do the right things. However, I have had it explained to me; some of the people that grow up in some of these countries say they want to do the right thing, but they have to deal with bribery, corruption in all of the facets of their lives, from trying to get their children’s grades back from the school to daily transportation needs within the country. It is a tough call for them about whether to participate or not in bribery on personal bases. Such employees will say “I understand working for this company I cannot do that.” You must have an appreciation for the world they are living in day-to-day and what you are asking of them. Frankly, it is a lot simpler living in Houston, Texas and saying that I am not bribing anyone at all in my life. It is not nearly as simple for some of the people with whom we do a lot of business.

MR. GYESZLY

We have colleagues that have worked for Marathon for twenty or thirty years. It is easy for them in a given situation to distinguish what is the Marathon way. As the company has new colleagues coming in, we do not know what these employees have learned from other places, so we have to be clear about explaining Marathon’s values and delineating what is acceptable for us and what is not.

However, it is not just, “what do we want the culture to be.” The other aspect of culture that I think is critical for a compliance program is determining your company’s culture as it currently stands, because you have to sell your program within that context. When you are trying to persuade someone to buy into a compliance initiative, for example, ensuring training completion, do you highlight to a manager that his or her equivalent in another asset currently has a better completion rate? If it is not competition, is the driver of your message wanting to do the right thing, or that a board member has asked about the issue? You have to figure out what resonates. You must figure out what is culturally relevant to them and

how to build out and deploy a program to make sure it fits within the culture even while you are trying in some cases to change the corporate culture.

MS. SHEHADEH

We are not here preaching. I do not say this from a position of judgment. But I have been with organizations that have a “company way” and companies that were still in a certain maturity infancy and trying to figure out their value proposition. In organizations such as this, the compliance journey is difficult. It takes more time, but it is still achievable. You are really winning hearts and minds at a more local level, triaging as it were. For example, say that I cannot get to the base for the company without paying three policemen along the roadway. Well, now, there is going to be a company bus that is going to pick up everybody from the community to get everyone to the base. To use the phrase, we started playing “whack-amole” at solving the problem at a local level. If we are excited about the convergence now and the recognition that culture plays and culture pays for greater leverage, what are things that are working for you? Or if not, your personal organizations? What are things that you think work?

MR. SARDAR

The reality is, that even as the Chief Ethics Officer, we are looked upon as a business facilitator. We become less effective if we forget that. We are lawyers and bring that technical background to be able to facilitate. If I lose my focus and I just become a preacher, my function will lose. People will stop listening. At the end of the day, I need to be able to, pragmatically, make something work. The way I tell my people—stuff which is risk-free or risk that can be effectively managed, that is the “low-hanging fruit.” Knock it out as soon as possible. There, you show that you are being effective. At the end of the day, we are business facilitators. You look at risk perhaps through a different lens, but don’t ever think that we sit outside the organization, that we are the prophets, that we just issue judgment without consequences for us.

These are the skills for young lawyers— particularly in the ethics space—that are so important. You can have the right personality. You are going to use your soft skills. Those who are good at debates will succeed in ethics. What are you doing selling your ideas, selling yourself?

The way I look at my function, to be effective, I need to operate at the speed of business. Not do everything that they ask us to do, but to support them at their speed. That is what is most effective.

MR. GYESZLY

One small but effective step, in that we regularly receive positive feedback on this, is focusing on how we are perceived at the first point of contact. When someone reaches out to us, regardless of the matter, we work to respond to them quickly and give them the information they need, even if that means pointing them in the right direction or resource if it’s not within our remit.

At an extreme example, we are Marathon Oil, a company that explores for and produces oil. We are not the similarly named gas station or the refining company. However, we receive reports through our reporting helpline along the lines of “your gas station prices are too high”. While the easiest response would be to ignore the report, it’s still important to respond quickly and be clear that we appreciate them reaching out to us, but that their report needs to be directed to a different company. Even in responding to reports that have nothing to do with our company, maybe the reporter appreciates that someone responded quickly and will see value in raising a question or concern through the right reporting helpline.

In addition to the initial touchpoint, we are also focusing on refining our program to distinguish between “must haves” and “nice to haves.” I think this is where compliance programs bring a lot of value and frankly can build credibility. My experience is that when you build a track record of being pragmatic and streamlining compliance requirements where feasible, your non-negotiables carry more resonance because you have the business people saying “you have shown on ten other occasions that you could figure out another way. Here, when you say no, that really means no.”

MR. MARTIN

There have been great writings over the years by a fellow named Ben Heineman, who used to be the General Counsel at General Electric (GE). The general theme of what he writes is that companies nowadays are extremely complex and intertwined. In order for anyone to get anything done, they have to build coalitions and relationships. In the compliance area, we have a lot of dealings with internal audit, dealings with HR, dealings with security, and dealings

with health, safety, and environment. There are a lot of sister organizations that are very important to the compliance officer who can get support and can learn from those functions, as well as leverage off all those resources to make maximum use of them.

Particularly in the oil and gas industry, we put an enormous emphasis on safety. Firstly, at virtually every meeting at GE-Baker Hughes, we have a safety moment. In order to build a culture, you cannot just give once a year training for a thirty-five (35) minute electronic module. Compliance should be something that people think about in their daily lives as they go about their own business. One way to do that is to have it be a reoccurring event that is in their normal activities, and where possible, down to the desk level, so they can see the relevance of what you are trying to communicate to them. People can then see that this is critical and not just preaching. It is integral to the success of the business. Like anything else, if you go out on a job in the field and the job fails technically, is the client, the customer, willing to come back? The same thing goes in the compliance area. If you have a breach, the compliance department can lose the confidence of that customer and the confidence of your own employees. It is this idea of principle, reliable performance and compliance that is important. Once you help the business people understand that, it makes a huge difference.

MR. RABALAIS

A comment for the law students. What the business team does not want is some lawyer sitting in an office emailing in a legal opinion, explaining why they cannot do something, period. That is kind of the worst end of the spectrum. What would be better, is somebody that can fit in. The social skill of fitting in is something you are not taught in law school. It is an important social skill, fitting into the team, being part of the team, and being able to tell the business people “no you cannot do this” because you have built enough respect over time with them. They will understand if you really tell them, “we, not just you, we cannot do this. But I am going to help find an alternative way to do the job.” That approach is on the other end of the spectrum. At the same time, we hopefully strive to get the same results with the company being compliant.

How the business people view that, perceive that, and ultimately work with you, is what will make or break you. It goes for almost anybody in the company, but for us, it is an acquired skill that you have to work on over time. The foundation is knowing the right legal answer. However, there are probably ten different ways to deliver that message, which is very important to the recipient of the message and the company. That goes a long way in trying to do your job. You can make your own job ten times harder if you are not careful about how you do it. Building those relationships over time is just invaluable.

MR. SARDAR

Steven said something about building credibility with the business side, such as in transactions where you can help the businesses see what they are doing. That credibility is so critical on the occasion when you have to deliver the bad news.

For example, some of my business people wanted to do something and I had a slightly different view. They convened the meeting, scheduled for an hour, which lasted about five minutes, because the business guy just looked at me, asked me, “what do you think?” Before I finished my sentence, he look at his team and said, “God has spoken.” I chased him down after the meeting and told him that we could find a way to make the deal work. He said, “I don’t think so, I am not going to waste your time.”

MS. SHEHADEH

If we do not act as partners, we will achieve nothing. That goes for anyone in any discipline of law or business-credibility. For the value proposition, there is the growing recognition in some enterprises that it is not “business at all cost,” but a business alignment between what is the culture value proposition of the organization so as not to end up in catastrophic ethical dilemmas.

MR. MARTIN

The tension point does not come in so long as the business is not being interrupted. The tension comes when they say, “if we don’t do something in three hours, we are going to lose this deal, or we cannot submit this bid.” That is where the wheels hit the road, and CCOs get that more often than we probably would like.

The challenge obviously in those situations is to give the best possible advice within the time period that you have for that situation. At the same time, do not lose sight. We do want to be business partners, but we also want to protect shareholders. We have fiduciary duties. I can assure you that

the business person that is pressuring you, “I need to do this, I need to do this,” if you sign off on it and the deal goes bad, it is on the compliance department. The business people will come back and say, “I ran it by compliance and they said it was okay.” That is the tension that you are always dealing with.

It helps enormously if there is trust, credibility, and a relationship there. That is as true for outside counsel as it is for in-house counsel. Some outside counsel have twentyor thirty-year relationships with companies. This is because the company has learned to trust them over the years by providing reliable solutions. When the business gets into a tough deal, it wants the best advice available and will go back to people that have produced results in the past every time. Every time they produce, the credibility and the trust grows even more.

MS. SHEHADEH

We would not all be here with interest and gainfully employed in this space without working long hours. Let us dispel an idea for the student community. If you thought we had cushy, in-house jobs, where we were punching the clock. No—it is quite a slog. Let us talk a little bit about the challenges. There is a lot to be grateful for, and there is a lot of progress, but there are still challenges. What are we still struggling to tackle in this space?

MR. SARDAR

Companies are relying more and more on the compliance function, which is a great thing. It has created opportunities. Years ago, when looking at compliance officers, there were not many lawyers in these roles. Look at the profiles of companies now. They are requiring that these roles be filled with lawyers. Companies are recruiting from some of the best firms for these roles. They are relying more and more on the compliance function. That is a double-edged sword. Some companies want to the use AIfacilitated compliance, creating a false sense of security, because the business folks do not feel the need to exercise any judgment. There you have to be careful.

The challenge I would say, for my sector that I am in, in the oil and gas space, is the shrunken budget. Compliance continues to excel and to do so much. The business folks are continuously looking to compliance to do more. Our responsibilities and what is being asked of us has not gone down one bit and continues to escalate. Every time a peer company gets in trouble, the first thing the executive wants to know is whether the company is covered for a certain risk. “What policies, processes, and controls do we have to avoid running into this issue? Are we exposed, essentially?” That is certainly one of the best ways to learn, from other people’s mistakes. We are working with budgetary constraints.

MS. SHEHADEH

It is not just more, but more in multiple ways. The initiation of our compliance programs, a decade or more ago, could not have been precipitated by a technical issue. However, then there was the advent of DoddFrank, conflict minerals, and now human rights. Oftentimes, organizations are looking to the compliance function to navigate all these spaces. There is an ethical nexus to most of this. On the one hand there is great synergy. It makes a lot of sense, especially with the challenge through the economic downturn. Coming out of the downturn, there are a panoply of things to manage today which far exceed just trade compliance, antibribery, and anticorruption compliance.

MR. MARTIN

The workload is such that if anybody comes in at any level, even if you are one week out of law school, and you don’t find yourself very busy very quickly, you should be concerned. There is a tremendous amount of work out there. Good work. There is always something that can be done in trade compliance, antibribery, and competition law.

When Courtney Flores came to GEBaker Hughes, she had the right attitude. She would always raise her hand and within a very short period of time as a rookie, she was totally immersed, probably more than she wanted to be because the word got out, “call Courtney.” We started sending stuff to her and she showed she had interest, enthusiasm, and confidence. That feeds upon itself. People start sending you stuff. I honestly cannot remember a situation as a compliance officer where someone working for me said, “you know, I am kind of slow right now.” Usually, they are hiding under their desk.

MR. GYESZLY

As much as you have to build relationships throughout the company, you can never forget what your role is. There are times you have to say no and be willing to accept the ramification. You may even

face a situation where you have to back up your decision with a willingness to walk. In the compliance world, your inability to say “no” can have serious ramifications both for yourself and the company.

That may be extreme and rare example, but it is important to keep in mind that your duty is not to an individual business partner but rather to the larger entity. If you are working with that one manager all of the time, you may have developed a great working relationship, but there may come a situation where you have to escalate things to a higher level. You have to be prepared and go beyond that, and, again, be prepared to say no regardless of the impact to the individual business relationship.

MS. SHEHADEH

What are your creative thoughts on how to innovate? Are there new technologies and new ways of thinking about how to bring the culture piece into our ever-expanding role to raise the bar, cover greater swaths of territory, and win more hearts and minds?

MR. RABALAIS

New technologies? No. I do not know any that are a silver bullet. They keep coming up with the “new” or “better” thing. Business can consolidate five systems into three systems, or something efficient like that, but you are still more or less in the same area.

One thing that would be innovative and efficient is for the industry to lobby and get together on certain things. Meanwhile, we are doing things with due diligence forms in the most inefficient manner one can dream up.

MR. GYESZLY

There is a lot of great technology out there, but not necessarily within the budget. However, there are innovations that we can build in to existing processes and technology. For example, can we deploy automated approvals by utilizing logic from existing requirements? For lower risk areas, do we still need approvals? Be mindful of whether you are forcing folks to do things that they do not need to do. For example, if a manual process has twelve steps, but you manage to cut out four steps in the course of developing the corresponding online tool, the innovation can be in process efficiency, not just the move to a new technology. We are really forcing ourselves to think about why the process is the way that it is. If there is no justification that makes sense for requiring X, Y, or Z, you have to be willing to move on and shift those resources to other risk areas, and accept the risk of no longer requiring X, Y, or Z.

MS. SHEHADEH

Do you all see a leverage opportunity? My organization has a strong core value and foundational belief proposition. We have multiple players in the culture and ethics space. It is not limited to the compliance function. Earlier this week, we unofficially inaugurated a culture value working group for health, safety, security, and environment. They are advocating for behavior management and behavior change. We keep that goal zero—not physically affecting any lives— delivering our people that go home the same way in which they arrive that morning. HR, we call them the “people culture,” they are in the behavior management space. It is what they are doing every day. We are trying to find innovative ways in which to touch an employee base in this value proposition in minding ethics and culture.

Is there a leverage opportunity for us? What we find challenging is ultimately for the employee, it is getting incredibly noisy. One day it is this, the next day it is that. One day, you are telling me what I can do regarding the customers and competitors from a competition perspective. The next day you are telling me what personal data I cannot be sharing from a privacy perspective. “Do not forget, do not bribe and do not export anything without knowing what its license treatment is,” etc. There is a lot of noise in the line.

Are you all thinking there is value in exploring cross-enterprise, cross-functional partnerships?

MR. MARTIN

There are new types of disciplines in the compliance group. For example, in communications, there is a tremendous amount of communication that should go in a compliance group. Having communication well-thought through, orchestrated, and in the proper form is crucial. I have found many times in my career, something I thought was absolutely clear was not so clear to someone on the business team.

You can never have enough IT support. Some compliance groups are adding their own IT person or professional trainers to the compliance group. As the needs arise, you need people with those skill sets.

One last area is project management. Somebody has to manage the initiative

and quantity of communications. What form is it? In person, is it worldwide, will communications be sent out in the same week? There are all of these decisions that have to be made. Having somebody that understands project management is important.

One thing we did at Baker Hughes, the brainchild of the CEO, was that the company would rotate high potential business people through the compliance group for a year or two. It was invaluable. When these people went through compliance and then back to the business, they became disciples of compliance. These business group would also bring a certain perspective. They could explain to the compliance group how insane, legalistic, and incomprehensible things could be. The business group would keep the compliance group honest. It was great having that kind of input.

MS. SHEHADEH

Have any of your company’s hiring style or hiring requirements changed to navigate the changing world of technocrat to culture steward?

MR. RABALAIS

In one sense, I would say “no.” Attention to detail is still very important. Now, it is being exposed to slightly different things. However, being able to listen to someone remains the same.

MR. GYESZLY

Certainly, the need for technical skills has increased. You can be the go-to expert, whether it is investigations or trade or whatever subject matter is, but you also need the technical skills so that you do not need to rely on others to do part of your job. Then, of course, there are the soft skills. Can someone go out into the field to provide training and go out to dinner with the folks after work, have breakfast, and build those relationships? If necessary, I can always go to outside counsel for pure subject matter expertise. I look for someone who also has the soft skills to demonstrate what we are trying to achieve and convey the message we are trying to convey.

MS. SHEHADEH

There is the criticality of supply chain experience. Echo that one-hundred times over. Also, the criticality of being more open-minded to cross-technical skills. For example, somebody coming from supply chain and then coming into this field, or somebody coming from forensics coming into this field. The next frontier for me from a hiring perspective--and I never in a million years thought I would say this--is a computer engineer. We really want to explore with machine learning and AI. I know there is a ton of noise in our circles right now. I have seen the light on this issue with a spectacular program that a beer company has shown us. With lots of Budweiser going around the room about two weeks ago, in a benchmarking session, my company got socialized with sophisticated machine learning. Believe it or not, this includes AI tools on monitoring, system identification of vendors with third parties, diligence, and transaction monitoring. We must work smarter. We cannot work any harder.

MR. SARDAR

As for external regulators, how good is a company at real time monitoring? Are we using technologies? That is where the technology piece is coming in as there is more access to the financial information for the risk in third party relationships. Because of the demand of needing to know the information now, versus what it used to be, this relationship has evolved. Now, it is all machine learning. That is where the technology is going to come in. Bringing in people who can look at our processes, not just from a technical perspective, but to solve our technology issues.