RESTORING TRANSPARENCY AND ACCOUNTABILITY IN THE
NIGERIAN OIL AND GAS INDUSTRY
By
Femi Aborisade[1]
Labour
Consultant and Attorney-at-Law
09093536706 Or
08091371874
Introduction
My
central argument in this paper is that political corruption is at the root of
corruption in the oil and gas sector of the Nigerian economy. It is not simply
a question of administrative and/or organisational weaknesses. Whatever
administrative and/or organisational weaknesses that facilitate corruption in
the sector are consciously so programmed or designed. In other words, there is
a relationship between political corruption and corruption in the oil and gas
sector. Solving corruption at the political sphere level is a pre-condition for
bringing transparency in the oil and gas sector.
However,
an attempt to deal with corruption in the oil and gas sector must also
adequately recognise that it is a fight against a network of politically and economically powerful and
influential individuals, institutions, governments, government agencies cutting
across the executive, legislative and judicial arms, cabals, political party
leaders, media merchants, nationally and internationally.
Structure of the paper
- The Role
of oil and gas industry in the Nigerian economy
- Corruption
and scandal in the oil and gas sector
- Broad typology of corruption in the sector
- Five strongest corruption points in the oil and gas
sector.
- A Few instances of scandals
in the oil and gas sector, including Halliburton scandal.
- Lessons
from NEITI’s empirical findings on elements of corruption in the oil and
gas industry, 1999 to 2008.
- The main
cause of corruption in the Nigerian oil and gas industry
- How to
restore transparency and accountability
1.
THE ROLE OF OIL
AND GAS INDUSTRY IN THE NIGERIAN ECONOMY
The
Nigerian economy is dominated by the oil industry. This is why, in the
literature, petroleum sector of the Nigerian economy is variously described as
the “cash cow” of the economy or the “pot of gold”. Oil has been the main source of government
revenues since the 1970s. Until recently, oil accounted for close to 90% of
exports and roughly 75% of the country’s consolidated budgetary revenues.
Nigeria
is rated as the world’s seventh largest exporter of
crude oil, the world’s 10th biggest holder of process gas reserve,
the largest oil producer and exporter in Africa, with the largest
natural gas reserves in the continent. Although
the significance of oil is declining drastically with about fifty percent collapse
in the global price of crude oil since June 2014, the fact that about half of
the Federal Government’s revenue is still coming from the oil sector shows the
centrality of the subsector to the entire economy.
Poverty In The Midst Of
Plenty
Nigeria
is a paradox – a rich country with majority of the citizenry living in poverty.
According to Prof. Watts (2009), relying on the IMF, over $700bn had been
realized as oil revenue between 1960 and about 2009. About eighty five per cent
(85%) of this sum accrues to only 1% of the population. The remaining 99% of
Nigerians struggle over 15% of the collective wealth.
The National Bureau of Statistics (2012) established
that between 1979 and 2011, the country earned about N51.5 trillion from crude
oil and that between 2000 and 2011, N48.4 trillion was earned. The earnings
grew from N724.4 billion in 1999 to N4.4 trillion in 2007 and peaked to N8.8
trillion in 2011.
The critical question to pose is where has all the oil money gone?
What is the impact of oil wealth on the overall wellbeing of the people? In
spite of the massive collapse in the price of oil, the problem of Nigeria up
till today, is not a lack of money but how to ensure that the commonwealth is
devoted to serving the common good rather than being captured for the greed
of a few. If the average wellbeing of
Nigerians was better when the price of oil collapsed to about $9/barrel in the
late 1990s, definitely, at about $50 per barrel currently, it would be wrong to
accept that “Nigeria is broke” to the extent that labour rights and the welfare
of ordinary people would continue to be criminally neglected and attacked.
In
spite of its oil wealth, Nigeria is now reckoned to be one of the 25 poorest
countries in the world. Officially, more than 70% of
the estimated 170 million people wallow in chronic poverty while only about 1%
swim in scandalous astonishing opulence.
It
is a paradox that there is a sea of poverty in the Nigerian sea of stunning
wealth. Unemployment is unprecedented. Insecurity is unprecedented. Boko Haram
atrocities in the North, armed robbery and kidnapping for ransom in the South.
Yet, Nigerian politicians are not concerned. All we are inundated with on a
daily basis is how deregulate minimum wage on state basis, why state
enterprises, including refineries should be privatised, deregulated, liberalised, commercialised,
concessioned, and so on. All we witness from time to time are disputes about
positions, power, influence and money, political defections, rallies sponsored
with public money, and so on, without a thought on a programme of social
security schemes to address widespread poverty.
Indeed, the relationship between the ruling class and the rest of
the society can best be described as a predatory relationship, a relationship
in which one organism (the predator) captures and
feeds upon the other organism (the prey). Members of the ruling political
classes in Nigeria, without exception, capture the resources that belong to
all; they live in opulence while the masses live in abject poverty. The ruling
political parties in Nigeria have brought this country to its knees. They have
captured, monopolised, stolen, looted or diverted resources that should have
been used for the welfare and socio-economic development of the larger society,
to their private benefits. Thus, in
spite of huge resources, the ruling parties can only give us squalor,
homelessness, darkness, diseases, hunger, misery, frustration and hopelessness.
If the heavy dependence of the Nigerian economy on oil money is
adequately appreciated, then, it would be clear that corruption in Nigeria is
rooted in corruption in the oil subsector of the economy. Tackling corruption
in Nigeria therefore is about restoring transparency and tackling corruption in
the oil and gas sector of the Nigerian economy.
2.
CORRUPTION AND
SCANDAL IN THE OIL AND GAS SUBSECTOR
Broad typology of corruption in the oil
and gas sector
Obioma (2012), cited by Donwa, Mgbame and Ogbeide (2015)[2] suggests that corruption
in the Nigerian petroleum sector may be categorized into four levels, as
follows:
a)
Policy Corruption: This
involves deliberately designing the working framework of institutions in a way
to ensure they produce predetermined outcomes, not in public interests but to
serve private and/or group interests. The controversies and delays surrounding
the Petroleum Industry Bill (PIB) also fall into this category.
b)
Administrative Corruption:
This refers to corrupt acts perpetrated in the course of day-to-day running of
sections and departments, resulting in individuals extracting illegal personal
and/or group benefits, either by not performing official duties or by
manipulating the performance of official acts to favour select individuals in commercial
and operational activities.
c)
Commercial Corruption: This includes
areas such as abuse in the procurement processes – rigging of tenders, taking
of kickbacks, inflating costs, and so on.
d) Grand Corruption: this refers to forms of corruption, which enjoy
the direct influence of political actors, which often involve direct theft of
massive amounts of money through diversion of production, diversion of revenue
flows to non-existing Joint Venture accounts, fraudulent cash cash call
arrears, non-remittance into Federation account, diversion of petroleum
products, and so on.
The five strongest corruption risk areas
in the oil and gas industry
Gillies (2009) cited by Donwa, Mgbame and Ogbeide (2015)[3] has also proposed that the
following five key areas are more susceptible to corrupt practices in the
Nigerian oil and gas industry:
- Award
of licenses: Gillies (cited
above) explains that the Petroleum Act gives the Minister of Petroleum
full authority or discretion in the award of oil blocks and allocation of
licenses for the exploration, prospecting, and mining of oil. In most
cases, the Ministers tend to be the errand boy of Mr. President or the
Head of State, depending on the political regime – military of civilian. The
licenses given for the oil blocks, in certain cases, may hardly be paid
for in reality. In some cases, they may be awarded to a select few to
secure patterns of behaviour supportive of the ruling regime. The
beneficiaries of the oil blocks, in such contexts, may simply resort to sell
them to foreign oil companies to earn enormous resources without making
any investment, at the expense of the Nigerian poor people.
- Award
of contracts:
Primarily the oil and gas sectors involve numerous awards of contracts to
oil service companies. The process of such awards usually creates
conflicts of interests, resulting in award of contracts to companies owned
by insiders, cronies, politicians, in and out of the various arms of
government.
- Bureaucratic
bottlenecks and inefficiencies: a typical contract award is required to scale through three
stages, depending on the size or the sums involved. Larger contracts often
require the approval of the Federal Executive Council. Gatekeepers exist
at each of the stages, with the effects of undermining the efficiency and
costs of operations in the subsector.
- Bunkering:
Bunkering is defined as
the theft of crude oil directly from pipelines, flow stations, and
export facilities (Gillies, 2009). From the
works of Gillies (2009) and Gentile (2007), the estimated quantity of
crude oil theft through bunkering in Nigeria ranges from 100,000 bpd, 180,000
bpd, 200,000 bpd (equivalent to the entire Cameroun’s oil production), to
600,000 bpd. According to the International Energy Agency, the figure of the crude oil theft
in Nigeria, at a point, was estimated at US $7 billion annually (Oketola,
2013). Bunkering is perpetrated
by a network of governments and
oil companies. It has been suggested that the armed militia who are
involved in bunkering tend to enjoy the sponsorship and support of top
government officials, particularly at the levels of the executive and law
enforcement agencies. The specific act of bunkering through
under-recording of crude oil into export vessels can hardly take place
without the complicity of government and oil companies’ officials. It has
also been suggested that communities tend to support the activities of
those involved in crude oil theft because they tend to derive some benefit
from such activities, as against the criminal neglect of their welfare by
government.
- Export
of crude and importing refined products: the processes of exporting crude oil and
importing refined products are laden with corrupt practices. As Donwa,
Mgbame and Ogbeide (2015) explain, the exporting process involves the NNPC
issuing “lifting” or export contracts to international oil trading
companies, some NNPC-affiliated companies, and a few foreign governments.
These traders buy the crude from NNPC at market price and sell to
refineries and other buyers internationally.
Similarly,
the importing process of petroleum products involves the NNPC also awarding
licenses to private companies to import refined petroleum products – e. g.
petrol, kerosene, and diesel. Even though the Federal Government claims to
subsidise the cost of the imported products, it has been established that
the process is overwhelmingly corrupt such that what government actually subsidises
is corruption – eg., payment for products that were never imported,
multiple payments for the same set of imports, false demurrage claims, and
so on.
A Few Instances Of Scandals In The Oil
And Gas Sector
- Unremitted
$20bn:
The
then CBN Governor, Mallam Sanusi
Lamido Sanusi, established with documentary evidence, the fact that the NNPC
did not remit into the Federation account the sum of $20bn between January 2012 and July 2013, alone:
“In summary, it
is established that of the $67 billion crude shipped by NNPC between January
2012 and July 2013, $47 billion was remitted to the Federation Account. It is
now up to NNPC, given all the issues raised, to produce the proof that the
$20billion unremitted either did not belong to the Federation or was legally
and constitutionally spent. There is no dispute that $20 billion out of $67
billion has not been paid into any account with the CBN”.
- The
Farouk Lawan (House of Reps) Panel
implicated the NNPC in the fuel subsidy scam of $6.5bn.
- The
N10b allegedly spent by the former Minister of Petroleum, Mrs Diezani Alison-Madueke on hiring private jets during her travels. - THE HALLIBURTON SCANDAL
In
the Halliburton scandal, a US oil service company pleaded guilty to paying over
US$180million in bribes to many top Nigerian public officers to secure four
contracts, worth over US$6billion. The beneficiaries and the amount involved
are as stated below:
THE
HALLIBURTON SCANDAL[4]
S/N
|
Periods
|
Beneficiaries ( company / Individual)
|
Amount involved
|
1.
|
1994 – 1995
|
General Sanni Abacha (former Nigeria Military Dictator)
|
$40 Million
|
2.
|
1996 – 1998
|
Dan Etete (former Minister of Petroleum under Abacha)
|
$2.5 Million
|
3.
|
1996 – 1998
|
M. D. Yusuf (Former Inspector General of Police and Chairman of
LNG)
|
$75,000
|
4.
|
1998
|
General Sanni Abacha’s brother, Abdulkadir Abacha
|
$1.887milion
|
5.
|
1999 – 2000
|
Atiku Abubakar (former Vice President, 1999 – 2007) and Don
Etiebet, ex Petroleum Minister)
|
$37.5 Million
|
6.
|
2001 – 2002
|
Olusegun Obasanjo and Atiku Abubakar, and Funsho
Kupolokun (Former President, Vice President and GMD, NNPC
respectively)
|
$74 Million
|
7.
|
2001 – 2002
|
Bodunde Adeyanju, ex personal assistant to Obasanjo.
|
$5 Million
|
8.
|
2001 – 2002
|
Ibrahim Aliyu, a retired federal permanent secretary (Urban Shelter
and Intercellular)
|
$11.7 Million
|
9.
|
2001 – 2002
|
Mohammed Gidado Bakare, a retired Chief Planning Officer
|
$3, 108, 675
|
10.
|
March, 1999
|
Nasir Ado Bayero, Son of the Emir of Kano (Gosmer International,
Risers Brothers)
|
$600,000
|
11.
|
1999 - 2000
|
Shinkafi and Glosmer International
|
$195,000
|
12.
|
March, 1999
|
Edith Edeghoughou
|
$290,000
|
13.
|
March, 1999
|
Zertasha Malik and Grety overseas
|
$600,000
|
14.
|
March/June,1998
|
Grety Overseas and Riser Brothers
|
$1.12Million
|
15.
|
2001 and 2002
|
Principal officials of the Nigerian Federal Inland Revenue Service
|
$2.4 million
|
TOTAL AMOUNT INVOLVE IN THE BRIBERY SCANDAL.
|
$181,650,675
|
Source: Usman, S. O. (2011). The opacity and conduit of corruption in the
Nigeria oil sector: Beyond the rhetoric of the anti-corruption crusade. Journal
of Sustainable Development in Africa. 13(2), 294-308.
LESSONS FROM NEITI’S EMPIRICAL FINDINGS ON ELEMENTS OF
CORRUPTION IN THE OIL AND GAS INDUSTRY
In
NEITI’s 10 years of empirical findings covering the period 1999 to 2008, the
key challenges of corruption have been summarized as follows:
- Discrepancies
between Company-Reported Payments And Government-Reported Receipts Of Payments.
According to NEITI, these discrepancies over the 10 years came to US$2.6
billion.
- Unrecorded
government liftings (exports)
- False
capital allowance claims on non-associated gas
- Loss in
PPT on overclaims of investment tax allowances
- Claims on intangible drilling and development
costs in excess of financial statements
- Claims on operating expenses in excess of
companies’ financial statements
- Contested interpretation of PPT fiscal value
- Contested interpretation of royalty legislation
- Dividends, interests and loan repayments made by
NLNG but not recorded by NNPC
- Lost imports
- Claims on non-associated gas
NB: It is important to note, however, that the
discrepancies, according to NEITI, were limited to only the potential losses
that the auditors could readily quantify and estimate.
The Reports highlighted a large number of additional
problems and challenges in the oil sector, many of which were likely to have caused
losses in revenue for the government but were impossible to estimate.
- Domestic Crude Value Reconciliation
and indebtedness by the NNPC: NEITI
explains that ordinarily, subsidy payments “should normally be made from
the CBN through the Petroleum Support Fund on the approval of the
Accountant General of the Federation (AGF) based on claims approved by the
Petroleum Products Pricing Regulatory Agency (PPPRA). However, the
reconcilers observed that NNPC deducts the subsidy claims directly from
the domestic crude proceeds before remitting to the Federation Account.”
This practice appears to have been partially continued as recent
publications on the website of the NNPC show that total receipts for crude
oil and gas exports between January and September 2015 were $3.69bn. Out of the receipts, $610m was remitted
to the Federation account while $3.09bn was used to fund Joint Venture
cash calls during the same period.
3.
The actual amount of oil produced
in Nigeria is not known. NEITI explains
that “oil is measured at terminals but not at well heads of flow
stations”. For this reason, oil theft takes place between these points, resulting
in lost revenue for the government.
4.
Unclear tax legislation which has
led to beneficial interpretations of tax liabilities by oil companies “resulting
in reduced revenue for government both from PPT and Royalty payments”. NEITI
also points out that “the tax regime of the sector is one characterised by ‘unregulated
self-assessment’, which encourages tax evasion and tax under assessment.
NEITI further found for example that “Tax assessments submitted by two
companies do not match their own internal audited financial statements”.
5.
Application
of legal incentives: NEITI found that “there are interpretation
differences between NNPC and PSC contractors regarding how the PSC agreements
and legal incentives should be applied…”.
6.
Overstatement of costs in tax
assessments:
According to NEITI, this implied that companies might be abusing capital
allowances in an attempt to reduce their tax liabilities.
7.
Information
Technology: NEITI found that “I.T. systems in government are not
sophisticated enough to deal with financial information flows from the
sector.
8. Conflict
of interests:
NEITI found that the NNPC was both
the buyer and seller of oil, thus creating a conflict of interests and
resulting in lost revenue for the Government.
3. THE MAIN CAUSE OF CORRUPTION IN THE
NIGERIAN OIL AND GAS INDUSTRY
The argument by
SPDC clearly shows that the main cause of corruption in the oil and gas
industry, which includes oil theft, is governmental and political involvement.
“The truth
is that small criminals in the creeks of the Niger Delta bursting pipelines and
stealing crude oil are not working for themselves. Like the drug cartels around
the world, they are being sponsored by big principalities and powers in high
places, which the government should go against if the fight against crude oil
theft is to be won”.
Indeed,
one of the former leaders of NUPENG, Comrade Akpatason (2013:21) has provided
an excellent insight in explaining that oil theft cannot take place at the rate
experienced in Nigeria without the connivance and conspiracy of government
institutions and their officials. Akpatason[6]
had explained, with the benefit of his experience, that:
“Crude oil
theft is not possible without the connivance of the security agencies, because
petroleum tanker or vessels (are) not small objects, (they) are large enough
for anybody to see from anywhere. Barges and ships are not small, and they are
the instruments they use in carting crude oil away. The security agencies were
given uniforms and arms to protect Nigerian interest, but they are using it to
protect criminal syndicates against the Nigerian people”.
4.
HOW TO RESTORE
TRANSPARENCY AND ACCOUNTABILITY
i.
Establish and/or verify the quantity of
barrels of crude being produced. Metering infrastructure to determine the
quantity of crude oil being produced on a daily basis ought to be installed.
ii.
Prosecute all those who had been arrested
in connection with incidences of oil theft.
iii.
Establish or disclose the true actual cost
of producing one barrel of crude oil so that the true actual profit margin per
barrel can be determined. Without establishing these figures, those who are in
control of the sector would continue to short-change the rest of the society. It
has been established that in the course of 2006, the
average price of a barrel of crude oil on international markets was in the
range of $65-$75, while costs per barrel ranged from $4-$5 (in the Middle
East), $12 (in the Gulf of Mexico), to $15 in the North Sea (Obioma, 2012).
This meant that the profit margins ranged between $50 to over $70 per barrel.
iv.
Regular publication of revenue flows (the
sources, the rates, the amount, etc) on a daily and/or weekly basis so as to
make it difficult for manipulation of figures, provided that the remuneration
of the political chief executives is brought within limits, reflective of the
economic realities of Nigeria and the living standards of workers in the
industry.
v.
Democratic management of the industry,
including representatives of trade unions in the sector, the central labour
organisations, communities’ representatives, professional bodies, in the
governing and management structures in the sector. It does not appear to me
that autocratic type of Management based on the whims and caprices of
politically appointed GMDs and Ministers can inspire sustained smooth running
of the sector. For example, while appearing at the Ministerial screening
exercise, Dr Emmanuel Ibe kachikwu spoke like an autocratic Manger, saying,
among others, that he had given the Management of the refineries a 90-day
deadline for the plants to commence full operation and that the non-performing
ones would be shut down. According to him, at the end of the 90-day ultimatum
in December 2015, “we will look at management issues and tidy them up and
procurement issues and tidy them up as well. But those that are not
(performing) we will have to shut down and do complete maintenance.” He also
declared, at the Ministerial screening, “I’m glad that over the last few weeks,
Port Harcourt, for example, has come out of the albatross and is producing
right now at about 67 per cent capacity. Our target is to grow Port Harcourt to
about 70 t0 75 per cent capacity by the end of the year. Warri is beginning to
signal that there is a likelihood that it will come on stream. If any refinery
produces below 60 per cent, then it is not production because the performance
capacities of refineries worldwide are in the 90 per cent and above categories,
and that is when you begin to make yields. That is when it can be said to be a
profitable refinery.” (see http://www.nairaland.com/2708689/nnpc-loses-120bn-two-month
accessed on 9/11/15). But a few days ago, the same Kachikwu lamented
that the
country “needs $500m to fix the nation’s crude oil refineries, which have all
shut down” (See Sunday Punch, 8 November
2015:8). According to media reports, he further stated that he “… has not
dropped the idea of conducting forensic audit on its account books”. One would
have expected that the first step a new GMD would embark upon is to conduct an
audit in order to understand the real issues as the man behind the wheel.
vi.
Elected Democratic bodies, including
trade union and labour movement representatives, to be set up for the award of
licences for exploration, prospecting, and mining of
oil, rather than leaving such to the discretion of the Minister or Mr.
President’s directives.
vii.
Execution of projects, primarily, through
direct labour in the NNPC and/or collaboration with governments, nationally and
internationally, through Public-Public-Partnerships as opposed to contractocracy and Private-Private-Partnerships.
viii.
Establishing of clear
and open criteria for the award of contracts to service companies where such
cannot be carried out in-house through direct labour on account of lack of
skills or appropriate technology required.
ix.
Establish mandatory timelines for the
award and completion of contracts. Indeed, a policy may be established, in appropriate
situations, such that failure of public officials to perform their duties
within the stipulated timeline means consent, provided that any public official
that makes government to incur losses through deliberate inept attitudes would
be made to personally suffer the consequences, in terms of being responsible to
assume such losses on behalf of government and being made to go through
prosecution processes.
x.
Massive investment in training and
retraining so that workers and staff in the industry acquire the necessary
skill to operate and monitor various categories of activities in the industry.
xi.
Establish more refineries and carry out
repairs of the existing ones. Ensure the refineries acquire the capacity to
refine the crude for both domestic consumption and export. Those who have
diverted the investments meant to carry out Turn Around Maintenance (TAM) over
the decades should be brought to justice. Where this is done, there would be no
need for subsidy on domestic consumption of petroleum products. Rather, the
sector would generate surplus for investment in public enterprises for public
good. Resist the privatisation of the refineries. Rather, government should
take the fight against corruption to the oil and gas subsector.
xii.
The fight against corruption should not be
discriminatory. All those involved in the ruin of the oil and gas sector,
including the refineries, should be brought to justice. What they have looted
in money and physical assets should be traced, wherever they may be, internationally,
seized, forfeited and recovered and they should be allowed to cool their legs
in prison for the rest of their lives.
xiii.
Urgent review of tax
legislation to clear ambiguities and provide against self-tax assessment by oil
companies.
xiv.
Carry out urgent review
of incentives regime in order to remove any ambiguities in their application to
any agreements.
xv.
Penalise
falsification of tax assessments or non-disclosure of relevant facts to enable
proper tax assessment.
xvi.
Acquire appropriate
level of I.T. to effectively monitor financial information flows.
xvii.
Enforce constitutional
and statutory remedies against the offence of conflict of interests, without
discrimination.
xviii.
Government should give
implementation of Chapter II of the Constitution the priority attention it
deserves to discourage young people and community members who participate in
oil theft or support those who carry out acts of bunkering, on account of being
criminally neglected.
xix.
The Federal Government
to demonstrate transparency by disclosing how much it recovers from looters,
the names of the looters, the bargain behind the recovery, as recoveries occur,
from time to time. It is not sufficient for government to publicly declare that
certain recoveries have been recorded without publicly disclosing all the
details.
xx.
Take an inventory of all assets, bank
account details, buildings, of all public officers, past and current, and
disclose the assets of all those possessing 5% of the GDP and above. Those who
cannot justify how they acquire such assets should be prosecuted and the assets
seized. Those who may show by proof that the assets were legitimately acquired
should be made, by law, to be liable to paying 100% property tax on such
assets.
I
thank you for your attention.
Femi
Aborisade, Esq.
12/11/15.
[1] Being Paper delivered
at the NUPENG 2015 Annual Education Seminar on the theme “Global Oil Politics,
Investments and Employment Relations in the Nigeria Oil And Gas Industry” held
on 11th - 13th September 2014 at Immaculate Royal (Int’l)
Hotel, Port Harcourt Road, Opposite Imo State House of Assembly, Owerri, Imo
State.
[4] See Usman, S. O. (2011). The opacity and conduit of corruption in the
Nigeria oil sector: Beyond the rhetoric of the anti-corruption crusade. Journal of Sustainable Development in
Africa. 13(2), 294-308.
[5] See M. Sunmonu
(2013) “Powerful Nigerians Behind oil Theft – Shell” in The Punch, Thursday,
February 21, 2013, Lagos, p. 30.
[6] See Akpatason peter (2013) “Blame Crude Theft on Security
Agencies - Akpatason” in Vanguard, May 7, Lagos, p.21.
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