International Trade Committee on Feb. 9th, 2023

[The Chair (Hon. Judy A. Sgro (Humber River—Black Creek, Lib.)), Liberal, Judy Sgro]

I call this meeting to order.

Welcome to meeting number 48 of the Standing Committee on International Trade.

Today’s meeting is taking place in a hybrid format, pursuant to the House order of June 23, 2022. Therefore, members are attending in person in the room and remotely using the Zoom application.

Everybody seems happy today. That's terrific. It's the weather. It's inspiring us.

I would like to make a few comments for the benefit of witnesses and members. Please wait until I recognize you by name before speaking. When speaking, please speak slowly and clearly. For those participating by video conference, click on the microphone icon to activate your mike. Please mute it when you are not speaking.

With regard to interpretation for those on Zoom, you have the choice at the bottom of your screen of floor, English or French audio. For those in the room, you can use the earpiece and select the desired channel.

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In accordance with the committee’s routine motion concerning technical tests for witnesses, I am informing the committee that all witnesses have completed the required tests. Should any technical challenges arise, please let us know, and we will suspend in order to ensure that all members have full access to translation.

Pursuant to Standing Order 108(2) and the motion adopted by the committee on Wednesday, February 2, 2022, the committee is resuming its study of environmental and human rights considerations regarding Canadian mining firms abroad.

With us today as an individual is André Gauthier, a geologist with Eval Minerals. From Global Compact Network Canada, we have Rumina Dhalla, chair of the board. From KAIROS: Canadian Ecumenical Justice Initiatives, we have Silvia Vasquez-Olguin, coordinator of Latin America, gender justice and extractivism, by video conference. From the United Steelworkers union, we have Meg Gingrich, assistant to the national director, also by video conference.

Welcome to Ms. Dhalla and Mr. Gauthier, who are here in person, and to the remaining panellists, who are here via Zoom.

Mr. Gauthier, I invite you to make a presentation of up to five minutes, please.

[André Gauthier, Geologist, Eval Minerals, As an Individual]

Thank you, Madam Chair.

Thank you for giving me the floor for five minutes. It's not much time to talk about the international mining industry, but at least it's enough to introduce the topic.

I am privileged to be here today because I am sure all of my colleagues in the mining industry are very busy working. As you know, the mining industry is very complicated.

The mining industry is a very complex industry, which includes many activities, such as exploration, development, feasibility studies, construction, metallurgical operation planning, the environment, human resources, logistics, supply, ore transportation, as well as social, legal, financial and political considerations. Working in the mining industry means dealing with all of these issues.

When we work internationally in the mining industry, there are usually a number of parameters that must be determined: discovery statistics; exploration, discovery and operation costs; the number of years required to discover deposits and to develop and build mines; and the tax benefits available for exploring, developing and building.

Finally, this is an industry where the risks are immense, especially on the technical side. I won't list them, but we're talking about some twenty technical risks. There are also financial, environmental, social, political, logistical and human resources risks, among others.

I am providing a lot of information, but, to give credibility to my words, I will add that I have over 47 years of experience in the mining industry, particularly in exploration, but also in the development of mining projects. Before working internationally, I had 15 years of experience in Canada. I then worked in over 35 countries. I was first an exploration manager for a company you may know, Cambior. Then I was president of various companies. In that capacity, I did not work from Canada, but from the countries where our activities took place, which set me apart from many of my peers and friends. I would come back to Canada to talk to people in the stock market and financiers.

I was involved in gold and copper discoveries in Canada and in a few other countries. I also participated, as a leader and promoter, in the creation of Lima's venture capital exchange, in Peru. That is a stock exchange for mining prospectors, just like the Vancouver Stock Exchange. Many Canadian companies are listed there. In the countries I was in, I was usually part of local organizations and I always worked with our Canadian authorities—in other words, embassies—which were always very helpful in my case.

For those with a little more grey hair, I am part of the first wave of Canadians who worked abroad. We're talking about 1989, after the big flow-through share boom that had started in 1984. At that time, the environmental, financial and operational rules were not necessarily the same as today. Everything had to be developed. For those who remember, this was before the Bre‑X and Southwestern scandals, which forced the creation of professional associations of geologists in Canada and led to the famous National Instrument 43‑101 on information about mining projects. We Canadians taught all the countries of the world how to do this. Other countries were not used to working with public funding.

With respect to the environment and human rights, it was the same thing. We have been decidedly forward-thinking, from prospecting to operations.

Finally, in terms of education, an unimaginable number of people and an immeasurable number of countries have been trained by Canadian companies. These companies, unlike some of the American, English and South African companies, were generally listed on the stock exchange and had the privilege and the obligation to consider human rights and to train local people. That's the way it is with all Canadian mining operations around the world. The truth is, everyone wants to work for Canadian companies when they are there.

I could go on, but I will stop here. Thank you.

[The Chair, Liberal, Judy Sgro]

I think you could keep going for the whole two hours, with the knowledge you clearly have.

Thank you, Mr. Gauthier.

We will move on to Dr. Dhalla, please.

[Dr. Rumina Dhalla, Board Chair, Global Compact Network Canada]

Good afternoon. Thank you, Madam Chair and members of the standing committee, for this opportunity to speak with you.

It is without doubt that mining is an important business for Canada; however, some Canadian mining companies doing business abroad have come under global scrutiny for the way they operate outside Canada.

There are key priorities for the extractive sectors from the UN Global Compact business and human rights navigator program, which aims to guide companies in understanding and addressing the impact of their operations and supply chains on human rights. I would like to highlight a few of them.

One of the critical priorities that need to be addressed from the mining sector relates to indigenous rights violations. The sector has been linked to the use of lethal force or targeted violence of indigenous climate and human rights defenders; the forced displacement of local communities; improper management or disposal of mining waste, including environmental degradation and damage; the indiscriminate use of water required for mining operations, leading to water shortages; and the use of public or private security, leading to increased violence against indigenous communities.

Another key priority is gender equity. Mining is a male-dominated industry, and women account for less than 15% of mining leadership positions globally. Recent studies show that in Canada less than one-quarter of board members in mining companies are women. Women who do work in mining are generally lower paid and occupy less valued roles. In some places there are limited grievance mechanisms in place, or they need to be filed by a male family member.

There are also global concerns relating to children in poverty working in dangerous mining operations, and issues related to workers' health and safety.

All these have reputational and other tangible risks for companies, for the industry and for Canada.

The growing competition and identified challenges present an opportunity to focus on how Canadian mining companies can respond to these challenges and move forward to succeed in this turbulent and hyper-competitive global environment. It is no longer enough to be reactive and enter the crisis in damage control mode. Businesses can no longer expect sustained competitive advantage by focusing on financial performance only.

Canadian mining companies must be proactive in ensuring their ESG strategy is integrated in all their operations across the world. This must be authentic. Anything less will likely signal greenwashing.

Mining companies are no longer able to claim ignorance or say that they are not responsible for the actions of contractors or their supply chains. Parent companies are increasingly being held accountable. Canadian mining companies abroad must pay attention to their global supply chain and conduct due diligence on who they do business with.

There have been reports of under-reporting and an absence of investigations on human rights violations. Disclosure and transparency will increase trust and confidence. Canadian mining companies should be required to report not just on financial and environmental dimensions, but also on human rights and social issues. The Canadian mining industry must operate abroad in the same way and under the same regulatory scrutiny and laws as it does in Canada.

Competition in the global extractive industry has become ferocious. Simultaneously, the scrutiny for human rights violations, action on climate crisis, the rights of indigenous people, diversity, transparency and reporting have become a priority for many investors.

There are tangible consequences for Canadian mining companies abroad that are not able to form strong relationships and collaborations with local communities. There is a growing trend in mining-rich jurisdictions where Canadian mining companies have interests for increases in royalties, taxes and larger ownership stakes in the mines. Global lawsuits for human rights violations are seeking large companies that are perceived to have gotten away with bad behaviour and making them exemplars.

ESG investing is on the rise, and investors will not ignore any unethical and irresponsible behaviour of mining companies. It is no longer enough to operate with judicial and administrative permits.

The Global Compact Network Canada can be an important resource for Canadian companies. We currently have a few companies from the mining sector that have joined the network and benefit from the resources.

Lawsuits for human rights violations and accusations of slavery and malicious treatment of protesters put the global spotlight on Canada and have negative implications for the Canadian mining sector. Failure to respond effectively can give advantage to Canada's competitors.

While Canada continues to occupy a strong place in the sector, investment can be mobile. Investments now come with the strong desire for business sustainability considerations. The question to ask is this: How do we benefit from this new environment, and how do we gain sustained competitive advantage?

Thank you for the opportunity to speak with you.

[The Chair, Liberal, Judy Sgro]

Thank you very much, Dr. Dhalla.

We'll go on to Dr. Vasquez-Olguin for five minutes, please.

[Dr. Silvia Vasquez-Olguin, Coordinator, Latin America, Gender Justice and Extractivism, KAIROS: Canadian Ecumenical Justice Initiatives]

Thank you very much.

I want to address the chair and the members of the committee for one second, to get you to think about the amazing opportunity you have today. Let's think about what we are learning. We're receiving a lot of information. Let's keep our minds and hearts open to receive it.

Since the creation of KAIROS more than three decades ago, and even before that, global partners, church members and various Canadian NGO networks have been calling on Canada to address allegations of human rights abuses and environmental harm linked to Canadian businesses operating abroad. How? Through stronger corporate accountability measures. Corporate accountability in the Canadian extractive sector is a gender issue.

KAIROS is not anti-miner or anti-business. KAIROS advocates for the rights of indigenous people to be upheld and for the inclusion of women in decision-making spaces, including the right to free, prior and informed consent.

It's been noted that some companies have a reputation of mistaking consultation for consent. When it happens, partner organizations around the world have consistently sounded the alarm on the concerning attitudes and consequences of Canadian extractive companies' mining, oil fracking and gas extraction operating in their territories.

Mining activities have consequences more evidently local but undeniably national and regional. Regarding women, mining impacts the territories of their bodies, their lands and their organizations, and has deepened the structural violence exerted against them.

Furthermore, mining activities become a fundamental nexus within the enclaves of a masculine-focused economy. Mining is developed mainly by men in the field, which leads to a reconfiguration and a reprioritization of local social activities that didn't exist before the arrival of the companies.

The introduction of a utilitarian and monetary model of engaging with nature leads to the commodification of important natural environments and later environmental destruction. I can bring examples of that.

The productive process has increased the numbers and intensity of daily violent encounters within the communities, particularly violence against women and girls. Nothing can show that more painfully than the El Salvador case in Las Cañas.

In the last decade alone, extractive mining has increased in Meso-America and South America, leading to more than 200 conflicts around mining activities in just four countries: Ecuador, Colombia, Peru and Chile, increasing the violation of human rights and the criminalization of environmental land and water defenders.

Women and indigenous communities are vital stewards of land and water. Fresh water is vital. Women and girls are vital for the communities and their livelihoods. Water is needed for everyday life tasks that usually fall upon women to perform, such as cooking, cleaning, child-rearing and cultivating. These jobs are socially and conveniently invisible and underestimated.

Women protect the social and community structure of preserving knowledge and transmitting it. At the cost of their well-being, their safety and sometimes their lives, they stand in a long-standing fight against corporations extracting resources from their lands. For their efforts, they are stigmatized, ostracized and, in many cases, criminalized, threatened, attacked and even killed.

Local women are the centre of building a just, equitable and lasting peace in their regions, and large-scale resource extraction projects undermine their efforts.

How can we do this better? I think the task starts at home through strong accountability and responsible legislation. We have to move on. Bill C-262 and Bill C-263 are the core of solving this problem, and the pun is intended.

Because of all this, I'm here now in front of all of you to remind you that the lives of women and girls around the world are under threat more than ever, and the time to act is now.

At KAIROS, we believe that women are leaders in community resistance to extractivism. Because of that, we advocate for including women and water and land defenders in the decision-making process and for protecting them, because activists are always under threat.

Because extractivist activities cause severe environmental and social impacts, which often are invisible because they happen in the bodies and lives of women and girls, KAIROS advocates for gendered impacts of resource extraction to be considered a key aspect of business development.

Finally, because of environmental racism and colonialism and for many other reasons, most of the extractive mining operations are found on or near indigenous territories in the global south. KAIROS advocates to protect the rights of indigenous and local communities of the global south to be fully informed and consulted before operations are even started on their territories, and to recognize the possibility of rejection.

Dear members of the committee, one life lost and one inch of land destroyed is one too many. You have the unbelievable power to stop it.

Thank you.

[The Chair, Liberal, Judy Sgro]

Thank you very much.

Ms. Gingrich, please, for up to five minutes.

[Meg Gingrich, Assistant to the National Director, United Steelworkers Union]

Thank you, Chair. Through you, I would also like to thank the clerk and all members of the committee for the opportunity to join you here today.

My name is Meg Gingrich, and I'm here with the United Steelworkers.

The United Steelworkers union is the largest private sector union in North America. It includes 225,000 members in nearly every economic sector, right across Canada, about 15,000 of whom work in the mining industry.

As a labour union, our core mission is to improve the lives of our members. That work necessarily extends to fighting for better conditions for all workers everywhere. Our members understand that to serve Canadian workers, we have to fight the race to the bottom of salaries and working conditions and flip that old paradigm on its head.

That starts by holding Canadian companies accountable for their global operations. By raising the basic standards everywhere and closing the delta between fair pay and the need to respect human rights in Canada and in other countries, we can decrease the incentive to cut Canadian jobs and compensation in favour of operations elsewhere, and we can secure a new foundation on which we can build stronger workers' rights here.

Put simply, doing the right thing for workers around the world is good for working people in Canada. At the USW we do this work directly through our Steelworkers Humanity Fund and in collaboration with civil society organizations and a variety of coalitions, some of whom you've heard from here, and that includes the Canadian Network on Corporate Accountability.

It is through the CNCA and the Non-Negotiable campaign that we've been actively lobbying Parliament to pass mandatory human rights and environmental due diligence legislation. As you know, that legislation, Bill C-262, is at the heart of addressing the concerns that are being raised in and by the study you're undertaking.

With all due respect to the work done by diplomats and those in any form of foreign service, I'm sure we can all agree that a country's foreign policy includes the international operations and business dealings of the private sector. Canada's mining sector is active in at least 100 countries. Without oversight of the private sector, the Canadian government risks harming some of its bilateral relationships and foreign policy goals in aid, trade, diplomacy and defence.

The impacts on the Canadian economy as a whole, as well as on communities and individual workers and their families, is significant. Governments in other countries are understanding these facts and are taking action. Recent G7 discussions saw a reinforced collective support for working together towards trade that lifts up workers, businesses and peoples.

However, frankly, here at home we're discouraged to see the Canadian government pushing legislation. We're talking about Bill S-211 now, which does not actually create a legal obligation to stop the practice or provide a path to remedy for anyone affected by a violation. This will not stop the abuses.

As this committee has already heard, to be robust and effective, legislation on this must legally oblige Canadian companies operating or sourcing abroad to identify, prevent and mitigate violations and provide remedies to those affected and for damage caused by their operations. This must apply to all human rights violations and environmental damage.

Some might suggest to not let the perfect be the enemy of the good, but as you may be aware, the experience of a similar law in the U.K. and other jurisdictions shows that modern slavery acts and the reporting only requirements have not brought the change they promised. Worse, when compared to the effective changes proposed in legislation before the House, for example, the corporate responsibility to protect human rights act, passing Bill S-211 could actually hurt the movement towards increased corporate accountability by being pitched as enough and used as an excuse to stop further work on this file.

Another more effective course of action would be to finally give the Canadian ombudsperson for responsible enterprise the investigative and enforcement powers she needs to effectively do the job she's been tasked with doing. Again, another bill before the House, Bill C-263, would be a step in the right direction in terms of that goal.

In advance of any questions, I would like to close on this point. We all understand that jobs and increased compensation rely on corporate success and profitability. It's not about deciding between doing the right thing or making a profit, because as we watch global awareness and the focus on corporate accountability rise, these goals are increasingly connected.

Thank you.

[The Chair, Liberal, Judy Sgro]

Thank you very much.

We'll go to our witnesses.

I want to acknowledge that we have John McKay with us at committee today, who I think is the founder of C-262 and C-263.

[John McKay, Liberal, Scarborough—Guildwood, ON]

No, no, no. Bill S-211 is mine. The last witness and I would not see eye to eye.

[The Chair, Liberal, Judy Sgro]

That's fine. Thank you very much.

Mr. Martel, for six minutes.

[Richard Martel, Conservative, Chicoutimi—Le Fjord, QC]

Thank you very much, Madam Chair.

Mr. Gauthier, I'm very glad you're here today to talk to us about the situation. It is rare for someone from the mining industry to appear.

You have been on the ground. Your background in the mining industry is also very noteworthy. I find it extraordinary. You're a real expert: you have 47 years of combined experience and have worked in 35 countries.

What is the reputation of Canadian mining companies abroad?

[André Gauthier]

I am pleased to say that, as of today, the standards of the Canadian ministry industry are among the highest in the world and that the industry is appreciated in the countries where it operates. I speak from experience in at least 15 countries.

Of course, there are issues, but it's important to distinguish between the exploration and extraction sides. They are almost two separate industries. Generally, extraction touches on all the activities I listed earlier. You're generally going to generate net cash flow.

The Canadian mining industry consists of over 1,500 junior companies, working around the world. These junior companies are companies that are not involved in production, but in exploration. The junior companies are trying to do a good job overseas, but what happens when the money is unfortunately no longer available? We live in a time when everyone is able to fund their activities easily, but, when funding is no longer available, the result is what happened to Canadian companies: they are not necessarily able to finish their activities diligently.

The environmental and social damage is obviously minimal. Aside from a few drill holes, exploration does not really result in significant environmental damage. For—

[Richard Martel, Conservative, Chicoutimi—Le Fjord, QC]

Mr. Gauthier, I apologize for interrupting.

We have heard from a number of witnesses that Canadian mining companies are violating human rights. At the same time, we hear that everyone abroad wants to work for Canadian mining companies. There is a contradiction here: human rights are apparently being violated, but everyone wants to work for Canadian mining companies abroad.

[André Gauthier]

For Canadian mining companies operating abroad, respect for human rights is more than essential. They go even further than what the rules of the stock market dictate.

I'll give you an example.

Suppose a mine is built in a town the size of Val-d'Or, with about 50,000 people. The workers are going to have benefits, and they're going to work under fantastic human conditions, on par with those in a developed country. People will have enough money to buy a car, for example. However, if the mine is built near a town that doesn't have electricity yet, it's going to create jealousy in the community.

Unfortunately, this is a very difficult problem to solve. All mining companies have pretty much the same problem. To find a solution, we have to work with local governments. That's why it's difficult to set certain standards in countries where those kinds of standards are not usually imposed. So we have to find a middle ground.

[Richard Martel, Conservative, Chicoutimi—Le Fjord, QC]

Some people say that relations with indigenous communities are difficult. You've been on the ground. What can you say about that?

[André Gauthier]

They are difficult in every country, without exception. It's extremely rare for us to be able to solve them on our own. It is almost impossible. The same is true for relations with local authorities. It is strictly by talking to the local communities that we can do it.

Again, this has to do with the financial system, which I talked about with Mr. Martel. Here in Canada, we have what I call a progressive taxation system, which means that our government taxes activities and profits. This is well known in the financial community. But in most countries in the world, the mining industry is governed by a taxation system that is not progressive, but rather regressive. In fact, the government earns revenues directly from the mining activity. Since the resource is non-renewable, some countries' governments do not want to let mining companies extract deposits that will be unable to generate sufficient cash flow to fund government activities.

[The Chair, Liberal, Judy Sgro]

Thank you, Mr. Gauthier.

I don't mean to cut you off, but there's a limit on everybody's time.

Mr. Virani, please.

[Arif Virani, Liberal, Parkdale—High Park, ON]

Thank you very much, Madam Chair.

I want to thank all the witnesses for their testimony and for helping us with this study.

I'm going to come to you in entirely good faith and with some open questions. I've been working on this in my role as parliamentary secretary for the minister, and we're keenly aware of the fact that improvements need to be made, as well as of the economic contributions that the mining sector makes.

I'm going to turn to Ms. Dhalla first. You used one word, which is competitiveness.

When we relaunched the responsible business conduct strategy, we revised it and we felt it was an improvement. We attached an attestation whereby they must agree to this responsible business conduct in order to avail themselves of the trade commissioner services. We created the CORE. We're the only country in the world that has an ombudsperson. I appreciate that people have concerns—they've been expressed today—that the ombudsperson needs greater powers, but we have an ombudsperson. That's a good start.

I'll say to you in all candour that when I've been in places like South Africa for Indaba, I've talked about these great things and how I think it makes Canadian mining entities more attractive for those investors that you said want legitimate good actions on the part of corporate actors. I've received push-back, to be blunt.

I'm wondering how you could help me and our government deal with some of that push-back. For the many people who say to me that these are steps in the right direction, there are still those who say to me that when we're dealing with entities like China in a race for critical minerals on a continent like Africa, a lot of the gloves are off. I would like us to hold ourselves to a better standard than that.

I want your best pitch as to how we should be making that pitch to Canadian companies.

[Dr. Rumina Dhalla]

I think the ESG numbers are in the trillions. Institutional investors all the way down to individual investors want to invest in ESG. We're talking about trillions, and it continues to grow.

One challenge with having these programs that you speak about is that they are aspirational. There are not a lot of sanctions. If I don't do this, if I don't produce a report or if I don't meet these metrics, there are no sanctions, really. That's one way to look at it.

The other thing is we have to decide if we are going to operate differently. Not being as bad as the bad guy doesn't really make anyone the good guy, if you know what I mean. Basically, what we have to do is say, “This is how Canada operates.” We have a stellar reputation. Canada has a great reputation for being all kinds of wonderful things. Do we want to protect that, and how?

The EU has.... Somebody mentioned critical metals and minerals. Do we want to have legislation? Why don't we have that?

I think it's important for us to look ahead. A lot of industries are being affected by this. They are producing integrated reports. There is going to be a requirement to report on all three dimensions—the environmental, social and financial. We are seeing that in the global financial markets.

We can either get ahead of the curve and say, “This is how we do business,” and stick to it and find a way to be competitive within those new parameters, or we say we're just going to continue on as long as we can and just milk it.

[Arif Virani, Liberal, Parkdale—High Park, ON]

I want to feed some of the other witnesses into the conversation. I will turn to the representative from KAIROS.

Thank you very much for the work that KAIROS does and for your input today. I just want to raise something that I raised with the witnesses last week, which is that you talked a lot about the impact on indigenous communities and their consent. You tracked some of the language that is found in the UN declaration on the rights of indigenous persons, UNDRIP. You know that we are a signatory to UNDRIP. We passed legislation on the rights of UNDRIP in the House of Commons.

How do we connect that domestic legislative initiative to the work that Canadian companies are doing abroad to give meaning in operationalizing what you're seeking, which is a greater indigenous say, into the actions of Canadian mining companies when they're operating abroad? Do you see a way of connecting the two directly?

[Dr. Silvia Vasquez-Olguin]

Sadly, we are working here in a responsive way. If we were really aware and acting according to the legislation, we have to accept free, prior and informed consent. We have to invite everyone to the table and listen to them, and if the answer is no, the answer is no, not on my land.

I will give you an example. Do you want mining activities in your backyard without consent, knowing that it is going to happen? Having the right to say no, you would like it to be respected.

I would say that it's the same happening at home and happening abroad. As the person before me said, we have to be consistent. If we have this idea of not in my backyard but in anybody else's backyard is okay, we are wrong. Let's not react; let's check this work with legislation that works according to the signatures that we gave.

If we agree, we compromise, and we are in favour of respecting indigenous opinions and their livelihoods. We have to accept that maybe they are going to reject the project. Maybe they are thinking of development in a different way; maybe they don't want pollution and violence; maybe they want something different; maybe they want a car but in a different way.

That's my invitation, and that's my message here, to be coherent in the way we work at home and work better at home, by the way, and then work accordingly abroad, respecting the possibilities of a no, of a rejection. Let's not react later, like, “Oops, there was something wrong, let's see what we do.” Let's avoid that. That's the idea.

[The Chair, Liberal, Judy Sgro]

Thank you very much.

We'll go to Mr. Savard-Tremblay for six minutes, please.

[Simon-Pierre Savard-Tremblay, Bloc, Saint-Hyacinthe—Bagot, QC]

Thank you, Madam Chair.

I acknowledge my colleagues, and I thank all the witnesses for their testimony.

Mr. Gauthier, you answered my colleague's question earlier about the good reputation of mining companies abroad. With which clienteles do these companies have a good reputation?

[André Gauthier]

It's hard to say. Generally, we are talking about various governments, the local mining industry, local workers or regional governments that we work with. They find it easy to communicate with Canadian companies; they think the companies are open and have high standards. As I explained earlier, there are jealousy issues. I don't like that term, but it's something I've experienced personally in some countries.