Profitability, commercial awareness, risk management and compliance - PowerPoint PPT Presentation

Title: Profitability, commercial awareness, risk management and compliance


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Profitability, commercial awareness, risk
management and compliance

• Peter Scott
• PETER SCOTT CONSULTING
• www.peterscottconsult.co.uk

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Challenges now facing law firms

• The economy
• Government cuts
• New competitors in the market
• The P I insurance market
• Increasing regulation and compliance
• Technology
• The changing needs of clients
• A fragmented profession
• Given these challenges, never has the need to be
• more competitive been so great

3
Todays session

• How to compete in tomorrows markets
• Building financial awareness and performance
• How to manage your risks and compliance under the
  new regulatory regime
• Achieving your goals

4
How to compete in tomorrows markets
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The need to be more competitive

• Competition is a process by which
• services that people are not prepared to
• pay for
• high cost methods of production and inefficient
• organisations
• are weeded out and
• opportunity is given for newservices methods and
  organisations to be tried
• Could this apply to the legal profession today?

6
Your future market competitors?

• ABS - owned wholly / partly by non-lawyers with
  deep pockets?
• MDP - owned by lawyers and other professionals?
• Highly developed traditional law firms?
• - national / regional
• - branded
• - strong sector focus
• - franchised / federal models
• - heavy investment in IT, management and
  infrastructure
• Combinations / variants of any of the above
• Others?
• Which kind of law firm do you want to be?

7
The greatest danger?

• - complacency!
• Our strategy is to keep a lid on
• expenditure and weather the storm. We
• cannot reinvent ourselves as something
• we are not
• Managing Partner of a major London law firm
  Autumn 2008

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An alternative view

• there seems to be a disturbing strategy of
  hunkering
• down, cutting some fat and hoping that business
  will
• return to normal. That is not good. The terrain
  will look
• very different when this is over. This is not a
  minor blip,
• but a discontinuity
• the problem is that most senior lawyers think
  only two months ahead.
• They have no coherent picture of the future. The
  planning is not being
• done. And it is senior lawyers who need to be
  driving change
• Professor Richard Susskind May 2009

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Forward planning - focus on the fundamentals of
your business

• Your clients
• Your people
• How you can achieve your goals

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The fundamentals of your business are you
making the most of them?
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Do you know what your clients want?Will
your people deliver what your clients want?
12
Your clients
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Preventing client leakage

• Clients usually do not tell their law firm they
  are leaving they just never again instruct the
  firm.
• Are you unknowingly at risk of losing part of
  your client base?

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Key issues for clients?

• Client based research consistently demonstrates
  that unless law firms listen to their clients and
  act accordingly, then those clients are likely to
  migrate to other firms.

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Your client base

• It is not only the at risk clients you should be
  concerned about.
• The graph shows that typically three out of ten
  clients have hidden potential to grow that has
  not been identified.

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The cost of sales

• The cost and effort to ensure client satisfaction
  and thus the retention and development of clients
  is many times less than the cost of trying to win
  new business
• Do you know your clients potential which could
  be unlocked for your firm?

19
Protect your backyard

• This should be an obvious and profitable way to
  ensure
• not only survival but also
• one of the best ways to build long term
  competitive advantage
• But are law firms doing so?

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Strategic forward planning

• What services are your clients going to need in
  the future?

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What are clients looking for?

• Core issue is to add value
• More than the competitors
• In a way which is regarded as valuable by clients
  and which differentiates you to create a
• brand

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What is added value?
23
Value Clients Care About

• Our clients perspective
• Not our own perspective
• Is there a gap?

24
The value gap

• It is the clients perception of value that
  matters
• Professionals often put too much emphasis on
  service attributes
• Not enough on helping clients achieve results

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You will add value if

• You provide clients with what they want and
  more
• At prices they perceive to be value for money
  and
• You do this better than the competition

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Understanding the clients needs and requirements

• So what do clients want?

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Price on its own is rarely a determining factor

• However, value for money is key

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The clients perspective

• They always try to sell to us on price but
  what we really want is to have a good job done at
  a reasonable price
• Client feedback from a perception survey
  commissioned by
• a law firm

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Positioning your practice to be competitive by
adding value more than your competitors



(Brown and Faulkner 1994, Long Range
Planning)
High
Client Perceived Added Value
X
Ave
Suicide Zone
Low
High
Low
Ave
Client Perceived Cost
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So what do clients want?

• Here are some of our most important research
  findings from interviewing clients of law firms
  and in particular from those clients which were
  in the at risk category

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Perceived lack of skills and technical expertise

• Clients absolutely expect that law firms have the
  necessary technical expertise to get the results
  clients require
• This should be a given but unfortunately it is
  often not the case

33
What some clients said

• They are OK for most work but when it comes to
  something really important to us, we go
  elsewhere
•  
• If named partner is not there we go elsewhere
  because they lack depth of expertise.
•  
• They need to improve the quality of staff in the
  2nd tier.

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However, it is not enough just to be a good lawyer

• The following factors can all influence a
  clients choice of law firm

35
Brand and Positioning

• Law firms win and lose work based on how clients
  and key decision makers perceive them, and
  particularly in relation to transactions, factors
  around
• complexity
• risk or
• size

36
Some relevant client comments

• For high value / high risk work I would use a
  big name firm very unlikely to get bad advice
•  
• Our accountants tell us to use a corporate
  firm
• The firm is under pressure if it does not do
  some bigger corporate work
•  
• Sometimes we dont use them for complex work
•  
• (They) may not be able to do complex
  transactions

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Lack of client awareness of specialisms offered

• Sometimes the problem is not so much actual lack
  of technical expertise but more a failure on the
  part of the law firm to make clients aware of
  what the firm can do

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The following client quotes show this

•  
• They must not assume that people know what they
  do
•  
• If I had a 5m project, would I think of
  (Firm)probably notI would think of one or two
  others first it may be that I dont know enough
  re the full extent of their expertise.
•  
• Not sure if they have certain capabilities
•  
• They are not proactive with their own clients
•  
• I dont think they have anyone in
  litigation...but if (the client partner) told me
  they did, I would trust him...Id be interested
  in talking to them
•  
• Maybe not so good at telling people what they
  do

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Speed and other service factors including

• Meeting deadlines
• Keeping commitments
• Ability to offer advice quickly and efficiently
• Keeping clients informed of progress
• Care and attention to work
• Billing as expected
• Personable and likeable people / rapport with the
  team
• Interest in / knowledge of clients business

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These client comments help to illustrate this

•  
• Their response times leave much to be desired
•  
• We had to chase all the time we said it was
  urgent but it still ended up drifting
•  
• They didnt communicate enough, or didnt seem
  to be on top of things
•  
• I dont believe they have the resources

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Relationship and understanding of needs

• If a law firm is unaware of a clients strategic
  needs then it is at risk
• An example of this was a firm which was unaware
  that it was likely to lose a large client
  relationship in an imminent review of panel firms

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For service, I would rate them 8.5 out of 10
(they are upper quartile on this)...for strategic
value I would rate them 2/10

• Being aware of this client feedback, and
  effectively responding to it, enabled the firm to
  retain what was its largest single client

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Referrers of work

• Different factors are likely to be identified
  from listening to referrers of work such as
  accountants, banks, overseas lawyers, IFAs,
  surveyors and estate agents

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Research indicates that referrers consider these
factors important

• Knowing the individual / the personal
  relationship / having confidence in the
  individual
• Expertise / technical ability / good quality
  advice
• Track record in an area of work
• Turnaround time / speed / ability to meet
  deadlines
• A fit with client
• Location
• Reciprocation
• Working as a team

45
Your firm

• For any individual firm it is key to identify
  what is important to your clients and referrers
  of work and how you perform in key areas
• Understanding and then responding to the issues
  can create immediate financial benefit and
  clarify the future direction of your firm

46
To be unaware of or to ignore client and referrer
perceptions is to put at risk a firms very
existence
47
Your people
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Your people?

• Are you presently unable to add
• value to your clients because of
• Gaps in your skills base?
• Under performance?
• internal attitudes and behaviour?

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What should your people be doing

• better?
• more of?
• less of?
• differently?
• How are you going to manage this?

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In particular

• how should your people be using technology more
  effectively?
• How financially aware are your people?

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Making technology effective

• Technology without people does nothing
• Law firms are people businesses
• People use technology
• Are your people helping you to get the most
• benefit out of technology?

52
Your IT

• IT is a tool to be used by you in your business
  to help you be competitive
• Is it doing so?
• Do you analyse the cost / benefits of the IT you
  use?
• Could you use it better to achieve your business
  objectives?

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Your business objectives

• Client service delivery
• Financial management
• Business development
• Knowledge management
• Risk and compliance management
• Others?

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Encourage your people to think creatively about
how to use technology to

• Provide better service
• Improve productivity
• Build competitive advantage
• Build profitability

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How financially aware are your people?
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I dont have a clue about the financial reports
I receive

• PETER SCOTT CONSULTING

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Do your partners / other fee earners have
financial knowledge gaps?Do they understand why
you provide them with financial reports?Do they
understand why you are asking them to take
certain actions?

• PETER SCOTT CONSULTING

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Does your firm have a financial education gap?

• How can I grow revenue?
• How can I price more creatively?
• How can I improve profitability?
• How should I manage working capital?
• How do I control the cost base?
• What reports do I need to better manage my
  practice?
• Why should I fully record time?
• How can our partners gain more confidence to talk
  to clients about money?

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Defining the financial education gap

• What do our partners and other fee earners tell
  us they need to know?
• What do we think they need to know?
• What messages are fed back from clients?

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Finding the right solution

• What is realistically achievable?
• What is the cost / benefit?
• What is the most appropriate forum / method for
  training?

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Gaining partner buy-in

• Must be relevant to the partner
• Needs to be user-friendly and practical
• Should demonstrate a clear benefit and
  improvement opportunity for the firm

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Implementation

• Identify the key sponsors, stakeholders and
  likely blockers
• Involve partners and other fee earners in the
  design and implementation of the education
  programme

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Would a financial education programme for your
firm help to achieve the outcomes you want?

• PETER SCOTT CONSULTING

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Measure and report what matters

• PETER SCOTT CONSULTING

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Financial measurement and reporting- create
KNOWLEDGE- help to manage RISK

• PETER SCOTT CONSULTING

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Without good financial measurement and reporting
it is not possible to adequately manage your
knowledge of what is happening in your business
and the risks to which your business subject.

• PETER SCOTT CONSULTING

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Risk and Knowledge Management
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Financial measurement enables you to manage
performance

• PETER SCOTT CONSULTING

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If you cannot measure it, you cannot manage it.

• PETER SCOTT CONSULTING

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What is the purpose of financial measurement and
reporting?

• PETER SCOTT CONSULTING

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To provide clear information to those running
the business to enable them to - Know what is
happening / will happen in the business - Make
decisions based on sound knowledge - Take
effective action

• PETER SCOTT CONSULTING

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Is your financial measurement and reporting
aligned with and helping you to achieve your
objectives?

• PETER SCOTT CONSULTING

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How do you use financial information?

• PETER SCOTT CONSULTING

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Financial management - whose responsibility is
it in your firm?

• PETER SCOTT CONSULTING

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Is your IT helping or hindering your financial
measurement and reporting?
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Data Vs Information?

• PETER SCOTT CONSULTING

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Avoiding financial information overload

• PETER SCOTT CONSULTING

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In a law firm what needs to be measured- and
why?

• PETER SCOTT CONSULTING

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Only measure what matters

• PETER SCOTT CONSULTING

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What matters? -How can we measure the
financial performance of each part of our
firm?-How profitable / loss making are our
clients?-Which parts of our firm generate good
cash flow or soak up cash?

• PETER SCOTT CONSULTING

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Are you measuring and reporting on what matters?

• PETER SCOTT CONSULTING

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Is there anything you should measure which you do
not currently measure and report on?

• PETER SCOTT CONSULTING

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Your key performance indicators?

• PETER SCOTT CONSULTING

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Testing your KPIs

• PETER SCOTT CONSULTING

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Your KPIs?

• Why do we produce this information?
• Does it tell us what we need to know about our
  business?
• What does it not tell us about our business?
• Do we ever use this information?
• If not then why do we produce it?
• PETER SCOTT CONSULTING

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Real time or historical information?

• PETER SCOTT CONSULTING

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Do you / your people use everything you measure /
report on ?If not why do you measure it /
report it?

• PETER SCOTT CONSULTING

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Identifying your priority financial
outcomesAligning measurement and reporting to
achieve those outcomes

• PETER SCOTT CONSULTING

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Outcomes?- Accelerating cash flow?-
Improving profitability?- Building
performance?- Effective business development?-
Risk management and compliance?- Others?

• PETER SCOTT CONSULTING

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How to design clear and understandable reports to
achieve required outcomes

• PETER SCOTT CONSULTING

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How can you ensure the most effective use is made
of your financial reports?

• PETER SCOTT CONSULTING

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Accurate reports build credibility

• PETER SCOTT CONSULTING

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Financial roles in a law firmWho needs what?

• PETER SCOTT CONSULTING

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Hard copy or available on line?

• PETER SCOTT CONSULTING

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Frequency of reporting?

• PETER SCOTT CONSULTING

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Is it enough just to provide reports or do you
need to do more?

• PETER SCOTT CONSULTING

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Questions?

• PETER SCOTT CONSULTING

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Implementing effective risk management and
compliance procedures
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Law Firm Risks
Management
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Who has looked at the new SRA Code?

• Go to Freedom in Practice at
• www.sra.org.uk
• Peter Scott Consulting

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Timetable towards implementation

• April 2011 publication of final Handbook
• August 2011 Anticipated designation of SRA as a
  Licensing Authority for ABSs
• 6 October 2011 first ABSs licensed and
  implementation of new Handbook
• Peter Scott Consulting

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Key elements of Outcomes Focused Regulation (OFR)

• Principles not rules
• Emphasis on results rather than process
• Sets out expected outcomes
• Provides indicative behaviours
• Peter Scott Consulting

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A New Online Handbook

• Will contain all the elements of the regulations
• Principles
• Code of Conduct
• Accounts Rules
• Authorisation and Practicing Requirements
• Client Protection
• Discipline and Costs Recovery
• Specialist Services
• 
  
• 
  Peter Scott Consulting

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Handbook and risk based regulation

• Firms will need to demonstrate their approach to
  compliance
• through compliance officers
• compliance plans
• possible self certification of compliance
• reporting of non compliance
• A new relationship between regulator and
  regulated required
• more openness
• more information provision by firms both annually
  and ad hoc.
• Peter Scott Consulting

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The Principles

• Ten mandatory over-arching Principles
• Embody key ethical requirements on firms and
  individuals
• Not part of the Code
• Six you will recognise but four are new
• Peter Scott Consulting

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The six Principles you will recognise

• Uphold the rule of law and proper administration
  of justice
• Act with integrity
• Do not allow your independence to be compromised
• Act in the best interests of each client
• Provide a proper standard of service to clients
• Behave in a way that maintains the trust the
  public places in you and in the provision of
  legal services
• Peter Scott Consulting

107
Four new Principles

• Comply with your legal and regulatory obligations
  and deal with your regulators and ombudsmen in an
  open, timely and co-operative manner
• Run your business and carry out your role in the
  business effectively and in accordance with
  proper governance and sound financial and risk
  management principles
• Run or carry our your role in the business in a
  way that encourages equality of opportunity and
  respect for diversity.
• Protect client money and assets
• Peter Scott Consulting

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Outcomes

• Generally replace rules in the Code
• Describe what you are expected to achieve in
  order to comply with the relevant Principles in
  the context of the relevant chapter
• Supplemented by Indicative Behaviours
• NB there are 81 outcomes but they are not an
  exhaustive list of the application of all the
  Principles
• Peter Scott Consulting

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Your Challenge

• How can you best achieve the outcomes, taking
  into
• account the nature of your firm, the particular
• circumstances of the matter and the needs of your
  
• clients?
• Peter Scott Consulting

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How they work

• Principles and Outcomes are mandatory
• Indicative behaviours are not mandatory
• NB Indicative behaviours specify, but do not
  constitute an exhaustive list of the kind of
  behaviour which may establish compliance with or
  contravention of the Principles
• Peter Scott Consulting

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The Code

• Has five sections
• You and your client
• You and your business
• You and your regulator
• You and others
• Application, waivers and interpretation
• Each section is divided into chapters
• Applies to solicitors, RELs, RFLs, authorised
  bodies and their
• managers, and all employees in relation to
  practice from an office in
• England Wales. Has in-house and overseas
  application.
• Peter Scott Consulting

112
1st section You and your client

• Chapter 1 Client Care
• Chapter 2 Equality and diversity
• Chapter 3 conflicts of interest
• Chapter 4 Confidentiality and disclosure
• Chapter 5 Your client and the court
• Chapter 6 Your client and introductions to third
  parties
• Peter Scott Consulting

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2nd section You and your business

• Chapter 7 Management of your business
• Chapter 8 Publicity
• Chapter 9 Fee sharing and referrals
• Peter Scott Consulting

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Under Chapter 7 the Outcomes provide that firms
must inter alia ....

• - have appropriate systems and controls in place
  to achieve and comply with all Principles, rules
  and outcomes and other requirements of the
  Handbook
• - identify, monitor and manage risks to the
  achievement of all outcomes, rules, Principles
  and other requirements in the Handbook if
  applicable and take steps to address issues
  identified
• Who already has appropriate systems and controls
  in place to
• comply with the present regulatory framework?
• Peter Scott Consulting

115
3rd Section You and your regulator

• Chapter 10 You and your regulator
• Peter Scott Consulting

116
4th Section You and others

• Chapter 11 Relations with third parties
• Chapter 12 Separate businesses
• Peter Scott Consulting

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Authorisation Rules

• Every firm must have
• - a Compliance Officer for Legal Practice (COLP)
  who
• must be a lawyer and
• - a Compliance Officer for Finance and
  Administration
• (COFA)

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COLP and COFA role requirements

• COLP must ensure general regulatory and statutory
  compliance by the firm and its managers and
  employees
• COFA must ensure compliance with the Accounts
  Rules
• Both must promptly report non compliance
• Notes to the rule make clear that the firm and
  its managers are not absolved from their own
  responsibilities

119
NB - Authorisation Rules para 8.5 (b)

• The COLP of an authorised body must
• (ii) as soon as reasonably practicable, report to
  the SRA any failure so to comply.
• Peter Scott Consulting

120
Consider the risks of non-compliance

• Disciplinary action
• Bad publicity and loss of reputation
• Lost clients
• Complaints and claims
• Increased P.I. insurance premiums

121
Complaints

• LSA sets up role of Legal Ombudsman (operational
  from 6.10.2010) to handle complaints
• Establishment of Consumer Panel now operational
  to represent interests of consumers and report
  to LSB
• Peter Scott Consulting

122
Complaints handling

• Legal Ombudsman and Consumer Panel both targeting
  poor standards of service.
• Legal Ombudsman is examining first tier
  complaints handling by firms - firms that dont
  measure up will be penalised.
• Consumer Panel have laid down outcomes they want
  to see in relation to complaints handling. Also
  want firms to analyse complaints and learn from
  mistakes.
• Peter Scott Consulting

123
How to approach OFR?

• Peter Scott Consulting

124
What is required?

• A need to manage your
• Resources
• Knowledge

PETER SCOTT CONSULTING
125
Resources?

• People and Money
• Internal or external?
• Part time partners or professionals?
• Bespoke or off the peg?
• Carry out a cost / benefit analysis to establish
• the most resource effective method for your firm
• to manage compliance

PETER SCOTT CONSULTING
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Knowledge? - Failure to manage knowledge
involves widespread risk
127
Compliance and risk do you know your compliance
risk areas?

• Where does the knowledge of your compliance risk
  areas reside?
• Can you access it?
• Do you have systems to maintain and
• upgrade your knowledge?
• PETER SCOTT CONSULTING

128
Where to start?

• A systematic approach is needed
• Management driven, with top level buy-in
• Zero tolerance is required
• Managing risk and compliance needs to be seen as
  everyones job a mind set change is needed
• Need a no guilt culture to encourage disclosure
• Approach compliance and risk management from a
  knowledge management viewpoint and vice versa

PETER SCOTT CONSULTING
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A systematic approach is required

• Put in place a formal compliance and risk
• management process to identify and manage
  every area of compliance and risk for the new SRA
  Code
• Establish a comprehensive database covering all
  compliance and risk areas
• Standards such as Lexel and ISO 9000 are likely
  to help
• Use of IT systems?

PETER SCOTT CONSULTING
130
Advantages of a formal compliance and risk
management process for the new SRA Code?

• Structured approach focuses on key compliance and
  risk areas
• Can demonstrate how a firm is complying and the
  effectiveness of compliance / outcomes
• Continuous monitoring ensures management of
  compliance and risk is lived day to day
• Universal application to all compliance and risk
  areas
• Comfort / assurance to PI insurers and SRA?
• PETER SCOTT CONSULTING

131
Use of IT systems for compliance and risk
management?

• Use an integrated compliance and risk management
  system to cost effectively manage compliance and
  risk areas by
• creating and maintaining one central, up to date
  compliance and risk database
• providing information access to all who need it
  in relation to exposure to risk
• embedding compliance and risk management
  procedures e.g. client inception procedures
• streamlining identification, assessment,
  mitigation and monitoring
• PETER SCOTT CONSULTING

132
Implementing a compliance and risk management
strategy
Diagnosis Identification and assessment
Implementation of compliance procedures and
Mitigation of risk Avoidance, control or transfer
Monitoring Auditing, tracking and reporting
Limitation Minimising the effects of
crystallised risks
133
Identification of compliance and risk areas?

• Needs to be management- driven
• Top down bottom up brainstorming sessions to
• - to identify every compliance and risk area
• - are we achieving every Outcome under the
  new Code?
• - are we compliant in every area?
• - do we have gaps?
• - what will be required to fully comply?
• - to what standards should we comply?
• - how should we prioritise our efforts?
• Assignment of responsibilities and lines of
  accountability

PETER SCOTT CONSULTING
134
Assessment of non-compliance and other risks

• Consider the impact of, inter alia
• Disciplinary action
• Bad publicity and loss of reputation
• Lost clients
• Complaints and claims
• Increased P.I. premiums

PETER SCOTT CONSULTING
135
Risk Mapping-where to focus resource?
136
Try this out on your ...

• Supervision arrangements
• Financial controls
• Business continuity planning
• Client care letters
• AML procedures
• etc

137
Compliance and Risk Mitigation

• Designed to-
• Ensure effective compliance
• Avoid / reduce non compliance
• Avoid / reduce incidence of risks
• Transfer some risks
• PETER SCOTT CONSULTING

138
Some techniques to put in place compliance and
mitigate risks

• Top level buy-in management must not only drive
  compliance but also live it
• Zero tolerance just do it!
• Training and education programmes to build
  awareness and change mind sets
• Continuous and systematic monitoring and
  reporting
• A need to continuously challenge the
  effectiveness of compliance and risk management

PETER SCOTT CONSULTING
139
Compliance and risk monitoring involves

• Auditing, tracking and reporting
• Comparing actual outcomes to preset indicators
• Confirming effectiveness of risk responses
• Reporting compliance and exceptions
• Annual compliance and risk management report
• PETER SCOTT CONSULTING

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Start now Systemise your compliance and
risk managementPETER SCOTT CONSULTING
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Any questions?

• PETER SCOTT CONSULTING

142
How to achieve your goals?
143
You have developed a realistic plan, but

• This will require RESOURCE - resource which
• many firms cannot realistically and at
• an economic and acceptable cost provide
• themselves

144
Is lack of resource making you -
uncompetitive?- non compliant?- financially
underperforming?
145
Lack of resource

• Often a lack of resource of expertise
• (client perception surveys will show if this is
  the
• case)
• Often a lack of financial resource
• (inability to invest in your people and in the
• business)

146
Resource to enable you to

• attract and retain the best talent

147
Resource to enable you to

• provide clients with the depth
• and breadth of expertise they
• will require
• when they need it
• where they need it

148
Resource to enable you to

• build the quality management which will be
• required to successfully compete in the future

149
Resource to enable you to

• provide the necessary infrastructure to
• underpin the effective provision of high quality
• professional services

150
Resource to enable you to

• provide the necessary technology to make you
• more efficient and profitable

151
Building resource to compete

• Will you be able to build sufficient
• resource on your own to achieve your
• goals?

152
The profession is too fragmented

• Over 11,000 law firms
• Over 85 have 4 or fewer partners
• Many will not be able to compete and survive if
  they remain as they are
• Size does matter

153
Competitive growth models?

• Organic growth alone?
• Some form of consolidation?

154
How can consolidation enable tomorrows law firms
to compete?

• Not about size for the sake of size
• A means to develop resource at an acceptable
  economic cost to each constituent firm which
  individual firms cannot on their own provide
• A better platform on which to build a more
  competitive law firm capable of succeeding in
  tomorrows legal market

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A Vision

• To build a law firm which over a given period of
• time will become greater than the sum of the
• individual firms which comprise it. This will
  involve
• building a BRAND which can begin to compete with
  larger,
• more developed firms for better quality, higher
  value
• work leading to greater competitiveness and
  profitability.

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Is that a Vision you share?
157
How are you planning to compete to win?
158
Any questions?