
## **Chinese In Wales Association** 

Charitable Incorporated Organisation 

**Annual Report and Financial Statements For the year ended 31 March 2021** 

Registered Charity Number 1175444 




## **Chinese In Wales Association** 

## **Report of the Trustees for the year ended 31 March 2021** 

The trustees present their annual report and the independently examined financial statements for the year ended 31 March 2021. The association was registered as a charitable Incorporated Organisation with the Charity Commission on 30[th] October 2017. The Trustees have adopted the provisions of the Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) issued in 2015. This report covers the activities of the Chinese In Wales Association for the period from 1[st] April 2020 to 31[st] March 2021. 

## **Reference and Administrative details** 

> Charity name: Chinese In Wales Association 

> Other name the charity uses: CIWA, Chinese In Wales 

> Registered charity number: 1175444 

> Charity’s principal address: 2[nd] Floor, Arts Wing, Swansea Grand Theatre, Singleton Street, Swansea, SA1 3QJ 

## **Trustees:** 

Mrs Xuehua Au-Yeung Dr Ching-Yi Chen Mrs Xinya Li Ms Yen Yen Lai 

Chair 

## **Patrons:** 

Mrs Wai Fong Lee MBE 

**Legal Advisor:** Prof. Uzo Iwobi OBE 

## **Independent Examiner:** 

Mr Matthew Woolway, FCCA Chartered Accountant Butterfield Morgan, Druslyn House, De La Beche Street, Swansea, SA1 3HJ 

## **Bankers:** 

HSBC, 10 Portland St, Swansea, SA1 3DF 

## **Insurance Brokers:** 

Prescott Jones Insurance Brokers Caswell House, 53 Walter Road, Swansea, SA1 5PW 

CHINESE IN WALES ASSOCIATION                                                                                                     1 | Page 




## **Chinese In Wales Association** 

## **Report of the Trustees for the year ended 31 March 2021** 

## **STRUCTURE, GOVERNANCE AND MANAGEMENT** 

## **Governing document:** 

CIWA is a Charitable Incorporated Organisation registered with the Charity Commission on 30[th] October 2017.  The charity was established under the Charity Commission model constitution: Constitution of a Charitable Incorporated Organisation whose only voting members are its charity trustees. 

## **Organisational structure:** 

The charity trustees are responsible for the general control and management of the charity and may for that purpose exercise all the powers of the charity. The trustees give their time freely and receive no remuneration or other financial benefits. 

The trustees meet quarterly or whenever deemed necessary and responsible for the strategic direction and policy of the charity. The day-to-day management of the activities and projects are delegated to the staff team. 

## **Recruitment and appointment of trustees** 

Apart from the first charity trustees, every trustee must be appointed for a term of three years by a resolution passed at a properly convened meeting of the charity trustees. The existing trustees are responsible for the recruitment of new trustees. 

In selecting individuals for appointment as charity trustees, the charity trustees must have the skills, knowledge and experience needed for the effective administration of the charity. Potential trustees are invited to attend trustees’ meetings as observers and are given more details of the charity’s aims and activities and, if all agree, they are then proposed as new trustees at the subsequent trustees’ meeting. All appointed trustees are required to have an enhanced DBS check. 

## **Induction and training of trustees** 

Following appointment, new trustees are introduced to their new role and given access to the trustee folder which includes CIWA’s constitution, policies and procedures, past trustee meeting minutes and financial reports. All trustees are invited and encouraged to undertake a series of training sessions to equip them with the necessary knowledge, skills and awareness of their roles and responsibilities. 

## **Risk management** 

The trustees have a duty to identify and review the risks to which the charity is exposed and to ensure appropriate controls are in place to provide reasonable assurance against fraud or error. The trustees have the responsibility to manage risk to sustain the charity and ensure that all its activities are risk assessed before they are carried out. Systems and procedures have been established to mitigate the risks the charity faces. Most significant is the external risk to funding 

CHINESE IN WALES ASSOCIATION                                                                                                     2 | Page 




which has led to the development of a strategic plan which will allow diversification of funding and activities. Internal control of risk is minimised by the implementation of procedures for authorisation of all transactions and projects. All relevant policies are regularly reviewed periodically to ensure that they meet the needs of the charity. 

## **OBJECTIVES AND ACTIVITIES** 

## **Purposes:** 

CIWA’s purposes as set out in the objects contained in its constitution are to promote social inclusion for the public benefit by working with people in Wales who are socially excluded on the grounds of their ethnic origin, age, disability, ill health, poverty and other personal circumstances, in particular members of the Chinese community, to relieve the needs of such people and assist them to integrate into society, in particular by: 

1. Promoting community cohesion, both within the ethnic Chinese community and the wider community. 

2. Delivering to and representing the Chinese community including disabled people, children and young people as well as elderly people, in planning and service delivery to ensure their greater well-being. 

3. Supporting members of the ethnic Chinese community facing disadvantages to address the inequalities that they face to participate fully in society. 

4. Promoting both Chinese and Welsh cultures and heritage. 

5. Having due regard to the provisions of the Equality Act. 

## **Public benefit:** 

When reviewing its objectives and aims, reference is made to the guidance contained in the Charity Commission's general guidance on public benefit, the trustees consider in detail how planned activities contribute to the aims and objectives set out in the organisation's constitution. 

## **Summary of activities:** 

CIWA is a community-led grassroots association. CIWA has its head office in Swansea. Since its establishment, CIWA has gone from strength to strength and has become the first contact point for residents with Chinese heritage in Wales. 

We have been developing services to meet the changing needs of the Chinese communities in Wales. We meet our charitable objectives by providing core services including language services alongside advice, advocacy, an information service and case referral. We also organise social, cultural and educational activities and participate in the promotion of a diverse, multicultural society. We offer wellbeing services including multilingual counselling service, physical and social activities. CIWA facilitates several social groups including Autism Support Group, Older People Group, Parents Group, Youth Group, After School Club and Sports Club. 

We provide volunteering opportunities for community members to give back and help the charity support the communities. We also offer student internships and paid work placements to help young people gain employability skills and work experience. 

CHINESE IN WALES ASSOCIATION                                                                                                     3 | Page 




The Covid pandemic significantly made the year 2020/21 a challenging time. Due to the lockdowns and restrictions, CIWA’s face to face activities were hugely disrupted. CIWA’s head office was closed to the public throughout the whole year and all staff and volunteers have been working remotely. While the Chinese community members have been suffering with lots of new challenges and uncertainty due to COVID, CIWA is needed more than ever before, to deliver the types of support and community services that are so critical in such periods. 

Through the whole year, CIWA has been tremendously resilient and rapidly developing new services and adapting current projects to meet the Chinese community members’ urgent needs, such as Chinese language counselling service, benefits advice and promotion on Wales’s Covid regulations and guidelines. We applied other approaches to achieve our aims and objectives. All services/projects have been adapted to be online and by telephone where possible. Our frontline team have been working additional hours to ensure its members are fully supported. 

## **ACHIEVEMENTS AND PERFORMANCE** 

## **Summary of key projects and activities:** 

## **- Fundraising Campaign PPE Appeal** 

When the first national lockdown in Wales happened, in response to the lack of protective gear for  the health workers, we raised about £6000 from our supporters via Localgiving to purchase PPE and collected PPE donated by our community members and the Chinese embassy. Through this appeal, we have distributed over 15,000 face masks to promptly address a lack of PPE for frontline health workers and vulnerable individuals across Wales.  In addition, countless community members were encouraged and inspired by us and donated PPE anonymously to their network directly. 

## **COVID-19 Support** 

This year CIWA’s work focused on supporting the communities getting through COVID. Since the pandemic hit Wales, we promptly recruited volunteers and staff to provide a helpline to deal with overwhelming enquiries from community members across Wales. We added in additional hours to extend our services to 6 days a week, 12 hours a day during lockdown periods. We successfully applied for the **Third Sector Integrated Care Fund (ICF) Covid19 Related Discretionary Capital Grant** to purchase most needed equipment to support our staff and key volunteers to work remotely with enhanced digital devices and a safer work environment at home. 

We have been working around the clock to translate many continually updated information coming from the Welsh Government, Local Councils and Local Services into Chinese. This enabled a prompt response from the Chinese community to know and follow through all latest guidelines and critical information. We thank **Community Foundation Wales** for their **Wales Coronavirus Resilience Fund** to support our additional translation works. 

Furthermore, we were initially awarded funding from **The National Lottery Community Fund Award For All** to run “ **The Community Hub and the People” project** , which is a 6- 

CHINESE IN WALES ASSOCIATION                                                                                                     4 | Page 




month project primarily aimed to connect community people and develop new wellbeing activities in the Community Hub located in Swansea Grand Theatre. The funder gave us more flexibility to make any necessary adjustments to meet the needs of the community during this difficult time. Despite all the challenges that the Chinese community in Wales is facing, through this project we launched “Thanks NHS Heath Heroes” Campaign to express the gratitude of the Chinese community to those working so hard to fight COVID-19. 

## **Information and Advocacy Services** 

CIWA has been continually running the **“Stand Up For You”** Project. This is a two-year advocacy project funded by **The National Lottery Community Fund People and Places’ Medium grants** , started in October 2019. In the reported period, there have been 1,002 instances of advocacy recorded, with 668 unique clients. We helped the community especially in explaining the latest COVID guidance, promoting vaccination, and writing to authorities for clarifications on ambiguity of guidance. The team promoted UK Census 2021 and reduced barriers for the Chinese community members to complete the Census. We also continued to speak for the community regionally and nationally to raise awareness of the disadvantages faced and have our voice heard in various areas. Our contribution was recognised by Swansea Council and we received a thank you letter. 

CIWA promptly ran a new one-year pilot **“Benefits Advice”** service to give direct support for the Chinese community in light of the financial and mental stresses of Covid-19. It was funded by the **National Lottery Community Fund COVID 19 Fund Getting through Covid-19.** Additionally, the funding also enabled us to refer those who have poor mental health to have multilingual counselling sessions. 

## **Wellbeing Services** 

In the last quarter of the year, CIWA ran the “ **You Matter** ” project- a 3-month pilot project funded by **The Community Wellbeing Grant Scheme** . It primarily aimed to maintain positive mental health and wellbeing of ethnic Chinese people during the winter months. This project involved different groups of people including older persons, carers, people living with a lifelong/long term disability or illness. We offered weekly online exercise sessions to different groups and provided 32 remote counselling sessions. This pilot project showed a promising start and a need for professional help without language barriers and a great level of cultural sensitivity to reach more of the Chinese community. 

## **Chinese Autism Support** 

This service provides support to meet the needs of ethnic Chinese residents who are touched by autism and related conditions. Our vision is to see more and more Chinese people to come forward, and together to understand the condition of autism, breaking the cultural stigma and embracing the difference. 

The **Find Me** project is an extended project funded by **Western Bay Integrated Care Fund,** to provide sufficient support to parent carers bringing their children who are autistic and/or have other related conditions such ADHD, learning difficulties and developmental milestone delays. Promoting self-advocacy with language support through translation and interpretation is at the core of our line of work, as well as developing close relationships with the families to 

CHINESE IN WALES ASSOCIATION                                                                                                     5 | Page 




align our work with their best interests at heart. We still provided our support to parent carers through virtual meetings and telephone calls whenever necessary. In addition, we attended with the parent carers of 6 statutory special education needs annual reviews, 3 school admission meetings, 1 school transport appeal meeting and even 4 school transitions were successfully done virtually in this year. Furthermore, we have also organised 6 online webinars and workshops from topics ranging from autism diet to special educational rights. During this time, we continue to work with other third sector organisations to keep the families updated with their news and available activities with translated information. 

Furthermore, we successfully applied for the **BBC Children In Need COVID-19 2020 Booster Grants** programme aimed to fill in the need seen among children who are autistic and/or have other related conditions. Some really struggled with the changes in their daily routine impacted by COVID-19 measures, which led to them being ‘stuck’ at home for a longer period than it was anticipated. To help them better cope with the situation, the grant enabled us to offer practical solutions through giving out equipment such as trampoline, scooter, bike to get active and stay healthy physically and mentally, and art materials, board games or equipment to help with sensory processing. 45 children and young people benefited. 

During the pandemic, libraries were one of many facilities that children love and benefit from going that had to be closed from public access to follow through with COVID-19 measures. **Swansea Council 3rd Sector CYP Emotional Health & Wellbeing Grant** has allowed us to create a **Kindle Book Club** , directed by and for children to have better access to books and other reading materials. 7 Kindles have been purchased and 10 children/young people benefited directly from the club through connection in between exchanges of book ideas/thoughts while more children/young people are thought to have benefitted too as siblings have enjoyed sharing and using the Kindle. 

## **Culture and Heritage Promotion** 

Despite the negative news around pandemic and lack of resources, CIWA trustees voluntarily took responsibility to organise CIWA’s first online Chinese New Year Celebration via our social media platforms in Feb 2021. We showcased performances from local community members and professional musicians from Taiwan who were all voluntarily contributing their time and skills to promote resilience. We have received greeting videos from many distinguished guests including First Minister of Wales Rt Hon Mark Drakeford MS to show their support to our Chinese communities. 

## **FINANCIAL REVIEW Financial position** 

CIWA’s total income for 2020/21 was £104,014 (compared with £91,821 for 2019/20). The restricted income was £96,237, which is about 92% of total income (compared with 87% of all income for 2020/21). 

The principal funding sources for the year were The National Lottery Community Fund Community Foundation Wales, BBC Children In Need, Third Sector Integrated Care Fund, Regional Health Social Care and Wellbeing Grant Schemes, Western Bay Integrated Care 

CHINESE IN WALES ASSOCIATION                                                                                                     6 | Page 




Fund, The Community Wellbeing Grant Scheme, and Swansea Council 3rd Sector CYP Emotional Health & Wellbeing Grant. 

The total expenditure was £120,574 of which wages and salaries accounted for £86,418 (72%). The cost for office rent was £1,000 which was kindly reduced due to lockdowns (compared to last year of £4,625). The cost for equipment was £9,321 (compared to last year of £1,334). 

Total funds carried forward on 31st March 2021 was £19,581 compared with £36,141 on 1st April 2020. 

The total unrestricted funds at the end of the year represent the Charity's free reserves and amounted to £17,330 (compared to last year of £14,447). 

## **Reserves policy** 

It is the policy of the charity that unrestricted funds which have not been designated for a specific use should be maintained at a level equivalent to between three- and six-months’ expenditure. The trustees consider that reserves at this level will ensure that, in the event of a significant drop in income, they will be able to continue the charity's current activities while consideration is given to ways in which additional funds may be raised. The reserves policy will be reviewed on an annual basis for this purpose. 

## **Going concern** 

Having considered budgets for the next twelve months, the trustees are confident that the charity will continue to meet its liabilities as they fall due for the foreseeable future and consider that there are no material uncertainties about CIWA's ability to continue as a going concern. It is therefore considered appropriate by the Trustees to prepare the financial statements on a going concern basis. 

## **Plans for future periods** 

The trustees believe that the available assets of the charity are sufficient to meet ongoing items of expenditure and obligations not yet met. Due to the uncertainty of the pandemic, the trustees will make sure the charity follows the government’s guidance and continue to fundraise to provide much needed services to support the Chinese communities in Wales. CIWA will build and improve workplace culture and resilience to support staff and key volunteers’ wellbeing. CIWA will enhance the staff members’ fundraising skills and empower them to expand their work to reach out more beneficiaries. CIWA will continually endeavour to grow its reserves for sustainability by applying for more funding to meet the community’s needs and using more digital fundraising methods to raise funds. 

## **STATEMENT OF TRUSTEES’ RESPONSIBILITIES** 

The charity trustees are responsible for preparing the trustees' annual report and the financial statements in accordance with applicable law and United Kingdom Accounting Standards (United Kingdom Generally Accepted Accounting Practice). 

CHINESE IN WALES ASSOCIATION                                                                                                     7 | Page 




The law applicable to charities in England and Wales requires the charity trustees to prepare financial statements for each year which give a true and fair view of the state of affairs of the charity and the incoming resources and application of resources of the charity for that period. In preparing the financial statements, the trustees are required to: 

- select suitable accounting policies and then apply them consistently; 

- observe the methods and principles in the applicable Charities SORP; 

- make judgments and accounting estimates that are reasonable and prudent; 

- state whether applicable accounting standards have been followed, subject to any material departures disclosed and explained in the financial statement; 

- prepare the financial statements on the going concern basis unless it is inappropriate to presume that the charity will continue in business. 

The trustees are responsible for keeping proper accounting records that disclose with reasonable accuracy at any time the financial position of the charity and to enable them to ensure that the financial statements comply with the Charities Act 2011, Charities (Accounts and Reports) Regulations 2008 and the provision of the trust deed. They are also responsible for safeguarding the assets of the charity and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities. 

The trustees for the purposes of charity law who served during the year and up to the date of this report are set out on page 1. 

## **Approved by the trustees and signed on its behalf by:** 

## **Mrs Xuehua Au-Yeung (Chair) 30 January 2022** 

CHINESE IN WALES ASSOCIATION                                                                                                     8 | Page 





**----- Start of picture text -----**<br>
Charity Name No (if any)<br>Chinese In Wales Association 1175444<br>Receipts and payments accounts<br>CC16a<br>Period start date Period end date<br>For the period from To<br>01/04/2020 31/3/2021<br>**----- End of picture text -----**<br>


## **Section A Receipts and payments** 


**----- Start of picture text -----**<br>
Unrestricted funds Restricted funds Endowment funds Total funds Last year<br> to the nearest      £ to the nearest £ to the nearest £ to the nearest £ to the nearest £<br>A1 Receipts<br>The National Lottery Community Fund                                  -                        46,894                                 -                          46,894                     47,717<br>Third Sector Integrated Care Fund (ICF)                                   -                          9,759                                 -                            9,759                              -<br>BBC Children in Need                                  -                          3,300                                 -                            3,300                       9,974<br>Regional Health, Social Care & Wellbeing Grant Schemes                                  -                        26,000                                 -                          26,000                              -<br>The Community Wellbeing Grant Scheme                                  -                          7,284                                 -                            7,284                              -<br>Other Grants                             459                          3,000                                 -                            3,459                     22,468<br>Donations                              404                                 -                                   -                                404                           737<br>Fees for Charitable Services                          1,119                                 -                                   -                            1,119                       9,565<br>Fundraising Events (Localgiving PPE Campaign)                    5,795                                 -                                   -                            5,795                       1,360<br>Supporters' subscription                                  -                                 -                                   -                                   -                                -<br>Sub total  (Gross income for AR)  [                        7,777 ]                       96,237                                 -                        104,014                      91,821<br>A2 Asset and investment sales, (see table).<br>                                 -                                   -                                   -                                 -<br>                                 -                                   -                                   -                                 -                                   -<br>Sub total  [                                 - ]                                  -                                   -                                 -                                   -<br>Total receipts                         7,777                        96,237                                   -                      104,014                      91,821<br>A3 Payments<br>Cost of activities<br>                        4,837                        12,002                                 -                          16,839                      15,825<br>Wages and Salaries                                   -                        86,418                                 -                          86,418                      53,655<br>Insurance<br>                                 -                              634                                 -                                634                            479<br>Telephone                                   -                              498                                 -                                498                            588<br>Rent including utilties                                  -                          1,000                                 -                            1,000                        4,625<br>Sundries<br>                              45                          2,868                                 -                            2,912                        3,339<br>Marketing                                  -                              604                                 -                                604                               -<br>Office Supplies                                   -                          2,335                                 -                            2,335                        2,296<br>Subscriptions                               13                                 -                                   -                                  13                               -<br>Sub total<br>                        4,894                      106,358                                 -                        111,253                      80,807<br>A4 Asset and investment purchases, (see table)<br>Purchases of equipment                                  -                          9,321                                   -                          9,321                        1,334<br>                                 -                                   -                                   -                                 -<br>Sub total<br>                                 -                          9,321                                   -                          9,321                        1,334<br>Total payments                         4,894                      115,679                                   -                      120,574                      82,141<br>Net of receipts/(payments)                         2,883  -                     19,442                                 -   -                     16,559                       9,680<br>A5 Transfers between funds                                  -                                 -                                  -                                   -                                -<br>A6 Cash funds last year end                        14,447                        21,694                                 -                          36,141                     26,462<br>Cash funds this year end                       17,330                          2,252                                 -                         19,582                     36,142<br>**----- End of picture text -----**<br>


Page 1 of 2 

CIWA Accounts FY 31.03.2021 



|**Section B Statement of assets and liabilities at the end of the period**|**Section B Statement of assets and liabilities at the end of the period**||||
|---|---|---|---|---|
|**Categories**<br>Signed by one or two trustees on behalf of all the trustees<br>**B4 Assets retained for the charity’s own use**<br>**B5 Liabilities**<br>**B2 Other monetary assets**<br>**B3 Investment assets**<br>**B1 Cash funds**|2018 Purchases<br>2019 Purchases<br>2020 Purchases<br>2021 Purchases<br>Signature<br>**Details**<br>**Details**<br>Trade Creditors<br>NEST Control<br>Cash at Bank<br>**Details**<br>**Details**<br>**_Total cash funds_**<br>(agree balances with receipts and<br>payments account(s))<br>**Details**|**Unrestricted funds**<br>**Restricted funds**<br>**to nearest £**<br>**to nearest £**<br>**17,330**<br>**2,252**<br>**-**<br>**-**<br>**-**<br>**-**<br>**17,330**<br>**2,252**<br>OK<br>OK<br>**Unrestricted funds**<br>**Restricted funds**<br>**to nearest £**<br>**to nearest £**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**Fund to which**<br>**Cost (optional)**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**Fund to which**<br>**Cost (optional)**<br>320<br>603<br>1,434<br>9,410<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**Fund to which**<br>**Amount due**<br>Unrestricted<br>**9**<br>Unrestricted<br>**350**<br>**-**<br>**-**<br>**-**<br>Print Name<br>Xuehua Au-Yeung<br>Xinya  Li||**Endowment funds**<br>**to nearest £**<br>**-**<br>**-**<br>**-**|
|||||**-**|
|||||OK|
|||||**Endowment funds**<br>**to nearest £**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**Current value**<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**Current value**<br>177<br>331<br>897<br>7,716<br>**-**<br>**-**<br>**-**<br>**-**<br>**-**<br>**When due**<br>**April 2021**<br>**April 2021**<br>Date of approval<br>10.Nov.2021<br>15 Nov.2021|



Page 2 of 2 

CIWA Accounts FY 31.03.2021 



CHARITY COMMISSION
FOR ENGLAND AND WALES
Independent examiner's
report on the accounts
Section A
Independent Examiner's Report
Report to the tru5teesl
membors of
lia¥ily N4Trie
Chinese in Wales Association
On accounts for the year
ended
31 March 2021
Charity no
(if any)
1175444
Set out on pages
I report lo the trustees on my examination of the accounts of the above
charity ("the Trust.) for the year ended 3110312021.
Responsibilities and As the charity trustees of the Trust. you are responsible for the preparation
basis of report of the accounts in accordance with the requirements of the Charities Act
2011 (°Ihe Act").
I report in respect of my examination of the Tnjst's accounts carried out
under section 145 of the 2011 Act and in carrying out my examination, I
have followed the applicable Directions given by the Charity Commission
under section 145(5}{b) of the Acl.
I have completed my examination. I confirm that no material matters have
come to my altention (other than that disclosed below ,} in connection with
the examination which gives me cause to believe that in, any material
respect..
accounting records were nol kepl in accordance with section 130 of
the Act or
the accounts do not accord with the accounting records
Independent
examiner's statement
I have no concerns and have. come across no other matters in connection
with the examination lo which attention should be drawn in order to enable a
proper understanding of Ihe accounts to be reached.
Pleas6 d818te Ihe words in the brackets if they do not apply.
Slgned:
Date:
1511112021
Name".
Matthew Woofway
Relevant professional
qualificationls) or body
{if any}:
ICAEW
Address".
Druslyn House, De la Beche Street,
Swansea
SA13HJ
IER
October 2018

Section B
Disclosure
Only complete if the examiner needs lo highlight matters of concern (see CC32,
Independent examination of charity accounts.. directions and guidance for
examiners}.
Give here brief details of
any itoms that the
examiner wishes to
disclose.
IER
October 2018