Making the skies ever safer
Safety is the airlines’ top priority. It always has been and always will be. In 1945, when IATA started, there were 9 million passengers and 247 fatalities. In 2012, nearly 3 billion people flew safely on 37.5 million flights. There were just 417 fatalities. Overall, there was one accident for every 5 million flights. It was the safest year ever. Every life lost is a tragedy, but in the industry we are proud that flying is the safest form of transportation.
The tireless work by IATA and airlines to keep raising the bar in safety is responsible for this incredible record. Anybody who thinks that airlines will cut corners in safety just to cut cost is wrong. Let’s be clear— an accident is so costly that it would never make business sense not to be as safe as possible. So even if you think airlines are heartless (which they are not), accept the rational argument that safety is paramount because an accident could bankrupt the business.
Concerns about safety run through aviation history. It has been a crucial part of the industry since the Wright Brothers took to the air. In fact, when the first IATA was established in 1919, safety was the focus. IATA worked alongside the International Commission for Air Navigation (ICAN), which was founded the same year by the Paris Convention, to set the guidelines for the technical and operational standards for the fledgling industry. The 1944 Chicago Convention moved things on and ICAO became the responsible body for setting the technical regulations with the new IATA assisting on a practical level. On each step of the way, cooperation was the key. The impressive improvements made so far have stemmed directly from this approach. Safety cannot have political, economic or commercial boundaries.
Remember, governments originally gave IATA the responsibility to decide the price of air tickets because they did not want to compromise collaborative safety efforts by making the market a free-for-all. Airlines needed to work together and allowing a fare that gave carriers the opportunity to make a return and reinvest in better equipment was thought to be the best way forward. The United States eventually moved toward deregulation in the 1970s, but by then the market had matured and it was clear that airlines understood the need to be safe. Nobody gains from an accident—it dampens demand for the industry as a whole.
And of course manufacturers have played an important part in safety advances too. Every technological advance has made flying safer. And there have been plenty, from improved avionics to geared turbofan engines. In short, there really are no barriers. All safety-related information is shared openly and there is total transparency.
Handle with care
It is all very well talking about this openness and the desire to improve safety. But it was clear to me when I took over at IATA that there needed to be a formal approach, a focus on exactly what needed to be done. Regulators, while making the right noises about safety, had failed to hammer home the advantages of an industry consensus. A steady decline in their budget and relevant skills was becoming apparent. A lack of money was affecting the airlines too and many of them were flying old aircraft. Added to this was a high proportion of non-Western aircraft, a legacy of the old geopolitical environment. This didn’t help matters because the old Russian jets still being flown weren’t up to the same standard as a modern jet aircraft. In some regions, aircraft-worthiness certification seemed too easy.
I started to think about what IATA could do to raise the bar. I knew there was a genuine desire to improve but this was not enough. I also felt there was a little too much dependency on technical solutions. The reliability and sophisticated systems of modern turbine-engine aircraft means it is rare for an accident to have a strictly aircraft-related cause. So there needed to be a greater focus on the human elements of the systems. I’m not just talking about pilots. All areas of airline operations are a part of safety, from the top management down. I began to mould together a “big picture” perspective. I wanted a safety program that could be developed and applied universally to achieve genuine safety improvements. And it had to work whatever the size or the geographical location of the airline.
In 2000, the accident rate (measured as Western-built jet hull losses per million flights) was 1.2. I thought cutting this rate in half would be an achievable aspiration. As usual, I was told this was impossible as so much of the process was outside of the airlines’ control. Also as usual I decided to ignore this advice. Finding the right role for IATA in the ongoing challenge to improve safety was essential. It wasn’t just a case of fighting internally this time, however. In theory, I would be going up against civil aviation authorities, which, by law, were the only ones capable of making safety rules in their own territories and ensuring those rules were enforced. Battling civil aviation was not what I had in mind though. Too many of our member airlines had close links with their national authority and IATA too had formed close ties. Much of our work depended on the cooperation of civil aviation authorities. So the only way forward was to have them involved from the outset.
With the help of my Safety, Operations and Infrastructure team, several of the top civil aviation authorities were identified. These included the United States, Canada, Australia and the European Aviation Safety Agency (EASA). We asked these authorities to be involved from the start and follow the work step-by-step by playing a role in our steering committees. We made it clear from the beginning that this was an IATA program but their expertise was essential for the success of our program. Lots of meetings followed and eventually we were able to agree on some standards that we believed would help improve the safety process.
While this was going on it was becoming increasingly clear that certain countries faced a bigger challenge than others. Each of these countries had a different problem, however. In China and Russia, for example, despite the leadership of two very competent ministers—Yang Yuanyuan and Igor Levitin respectively—aviation had grown so quickly that civil aviation authorities had been unable to react fast enough. There was a string of accidents in both of these countries in the 1990s and early 2000s. In other countries, in Central Africa in particular, it was more straightforward. Simply, there was no safety oversight. The authorities there—if you can call them “authorities”—seemed to be actively against industry efforts, providing havens for all manner of airlines, some of them involved in illegal trade. The situation had become so serious that ICAO became involved and a number of internal meetings were held to address the problem.
Around this time there was an internal Boeing report. It worried that, because aircraft deliveries were increasing and new airlines were entering the market, that the hull loss rate would rise. It was a simple sum really. More flights meant more chance of an accident, especially with so many start-up, novice airlines. There is a tipping point to this equation. If there are too many accidents in any one year, the public demand for flights would be greatly reduced. There would rightly be an outcry about the safety of aviation. The Boeing document pointed out that it didn’t matter that the increase in flights could mean it was a smaller hull loss rate than before. If there is an accident every month, would you be keen to fly?
So something had to be done. We couldn’t put our number one priority at risk. I knew I had to make some strong decisions but I also knew I had to remember the message on the side of boxes with fragile goods inside: handle with care.
Beginning the audit process
I had to be careful because regulators are very sensitive about safety. In one sense they are right to be so because safety should always be a very serious issue. But on the other hand they are rarely experienced pilots or engineers. Their rulings sometimes reflect political sensitivities rather than deep industry knowledge.
As we had some civil aviation authorities working with us, I felt sure we could set up a team that could implement a new safety audit system without upsetting the regulators too much. This was an issue that needed everybody pulling in the same direction. Mike O’Brien was chosen as the Director for this project because more than any other candidate he had this balanced approach—a firm hand but a fair one. But it was Günther Matschnigg, Senior Vice President of IATA’s Safety, Operations and Infrastructure division, who got the ball rolling by having a few, small meetings with select airlines. Air Canada, United Airlines and American Airlines were some of the carriers involved. It is no surprise the Americans were interested in the idea of a universal audit. In 1999, Swissair Flight 111 crashed off the coast near Halifax, Nova Scotia, at a place called Peggy’s Cove. A fire on board had become uncontrollable. It had become apparent that a lot of passengers were issued tickets by Swissair’s codeshare partner, Delta Air Lines. These passengers didn’t know they were flying on a non US airline. The FAA had moved to ensure that US carriers were required to enhance significantly their safety audit of foreign codeshare partners. So the US carriers reasoned that a new auditing process would be of great assistance to them in handling FAA requirements.
The FAA regulations also highlighted the challenge we faced. There was no consistency in standards, no required experience for the auditors and very limited quality assurance processes. There were just rules—and plenty of them. And the even bigger problem was the fact that security had taken over the agenda. Since 9/11, regulators had become convinced that security issues were the industry’s top priority. A new safety audit based on common standards was put on the backburner.
The main players
I didn’t want the momentum to fade though. Some good work had been done and IATA had a tool in place, the Operational Safety Audit (IOSA), that seemed to me to be the perfect vehicle for our new safety program. But we needed a strategy, a roadmap to transform an idea into a viable tool, one that could mark a major breakthrough in the industry’s safety efforts.
I talked about this a lot with my great friend, ICAO President Dr Assad Kotaite. We discussed the idea of a safety audit extensively, focusing on how it could work in a practical sense. ICAO was behind many of the existing safety programs and I learned a lot. But this time, ICAO was the starting point and not the finishing line for an IATA initiative. We talked further with the Americans and Europeans about what a good safety audit would look like. The new process had to be comprehensive. One element was pure ICAO, however. Because the system had to take into account all carriers, we needed to construct the audit in such a way that there would be areas that were mandatory and others that were optional, that would only apply according to the size of the fleet or type of aircraft. So ICAO continued to play an important role and Dr Kotaite was instrumental in setting the right framework for the project.
The ICAO audit—the Universal Safety Oversight Audit Program (USOAP)—had been established in 2001 to allow ICAO to check on its contracting states. Countries always have ultimate responsibility for carriers registered in their territory, but either through neglect or inexperience, many failed to ensure safety levels were adequately maintained. It wasn’t so much that safety was jeopardized but more that the proper documentation was lacking. In this line of work there has to be a very detailed record. It may be vital should an incident occur.
Marion Blakey, the newly-appointed Administrator for the FAA, was another key player. The FAA was crucial to the success of the project. No other authority had their resource and skill levels. Marion was on board with the idea from the start. We developed a personal friendship and she took the trouble to visit me in Geneva to discuss better ways to cooperate. Very quickly we established that there was no conflict with existing FAA and ICAO safety regulations. The way was open for a comprehensive airline program. IATA had to step up.
Devil in the detail
The big picture was looking very promising but the practical details still had to be decided. How big should the audit be? How many auditors would be needed and in which disciplines? How much would an audit cost? Who would pay for it? This was a major undertaking and we needed clear answers.
By the beginning of 2003 we had pre-tested some of the standards and the results and methodology had been vetted by an Advisory Group. At the next Board meeting I updated the members on our progress. It was very informal. We always say that safety is the number one priority, so this was in a sense a very straightforward plan, one that was in keeping with the traditional priority of all our members.
Of course, in the aftermath of 9/11, cost was also a priority. I had been cutting the IATA workforce, so the main question I had to answer was how to implement a new audit while keeping our structure slim and our costs down. I decided the best way to go about this was to contract out the actual audit process to accredited organizations. In 2003, the first two companies were accredited—Aviation Quality Services and United Pros. Later that year, Qatar Airways became the first airline to be registered with the new-look IOSA.
The pricing of the audit turned out to have a simple solution despite the seeming difficulty of the challenge. A direct negotiation between an audit organization and an airline seemed to me to be counterproductive. It could potentially affect the accuracy of the audit and that couldn’t be allowed. Nor could the audit cost too much. Smaller airlines with limited resources needed this audit at least as much as the larger airlines and I didn’t want lack of money to act as an excuse. So in the end I decided that IATA, in the initial stages, would pay, regardless of the size or financial situation of the airline. We had extra revenue coming in through the expansion of our commercial services and this seemed to be the best way we could use the money. Safety, after all, is the top priority. Needless to say, this was very well received by the airlines. Not only did they get to be safer—they got to be safer free of charge.
While I had them in this state of mind, I implemented the next phase of my strategy: targets. These never went down well but hitting the target button was essential to a business approach. It’s a recipe for success. Targets make the difference to any strategy. In any case, my insistence on targets was now expected by the Board. And in turn I expected an internal battle on what those targets should be. I was not disappointed.
A maybe to a must
I started discussing our goals with Robert Milton, CEO of Air Canada and Chairman of IATA at the time. Leo van Wyck and Jean-Cyril Spinetta, CEOs of KLM and Air France respectively, were also heavily involved. I suggested making the IOSA Registration mandatory for all IATA member airlines and a precondition for any airlines wishing to join IATA. While the notion of pushing safety as much as possible was acceptable, tying it to IATA membership was thought to be a step too far. It was argued that some airlines would lose the benefits of IATA membership because they could not afford to make all the changes necessary to pass the audit or because they would fail on some small technicalities. In other words, the association was turning its back on those members that needed it most. To stop this argument in its tracks I had the idea of a special fund for deserving airlines called Partnership for Safety (PfS). This would ensure that an airline had all the necessary help, financial or otherwise, to meet the exacting standards of IOSA. PfS consisted of seminars, targeted training courses and specific help from relevant experts. The IATA Training Fund (IAFT) also contributed to the PfS program. Over 100 airlines in many parts of the world benefited from PfS, and many attribute their ultimate IOSA success to the support they received through the scheme.
Even so, Board discussions about IOSA were not plain sailing. More than once I was told that we would lose all our African members or that regional airlines would choose not to undergo the audit. There were suggestions that a significant percentage of airlines would drop out of the association. I didn’t want to talk about numbers though. I knew that a limited number of airlines might not make it, but I personally met with as many of the borderline carriers as I could, explaining and providing the resources that would help them meet IOSA standards.
Finally, at the 2006 Paris AGM, the following was announced:
• Members had to plan an audit by end-2006.
• That audit had to be conducted by end-2007.
• All audit findings had to be closed and the airline on the IOSA Registry by end-2008.
Failure to meet these goals would mean the airline would lose IATA membership. The time for talking was over. Airline CEOs had to show that safety was indeed at the top of the agenda and ensure their companies passed IOSA.
In the end, we lost 21 members. Some of those that failed initially have now passed IOSA and rejoined IATA. Crucially, from the beginning of 2009, all IATA member airlines had passed the most stringent and comprehensive safety audit. There were more airlines than that on the IOSA Registry though. As the program gathered strength over the first few years, it had become an accepted part of the industry safety efforts. Even non-member airlines were keen to undergo the audit to prove that they also held safety in the highest regard. IOSA also helps enormously with insurance premiums. IOSA not only made the skies safer, it made them cheaper too.
With airlines showing strong support, I started travelling extensively to promote IOSA with Civil Aviation Authorities and with Ministers of Transports. Although I talked mainly about IOSA being an airline tool, there was clearly an advantage in a country making IOSA a national requirement. I explained this would support ICAO’s work. If every home airline was IOSA-registered then complying with USOAP would be a formality, a natural extension of aviation safety efforts.
Bit by bit, IOSA was gaining momentum. But the big breakthrough came when I received a call from the Egyptian Minister of Transport, General Shafik. A former military man, he had done a great job with civil aviation, and in so doing, made a huge contribution to Egyptian tourism. I had met him previously. I was on vacation in Cairo but agreed to a meeting while I was there. It didn’t go exactly as planned because we got on so well the meeting went on for most of the morning. He isn’t at all what you would expect from a five-star General and knew as much about the commercial side of aviation as he did about the technical side. That meeting was the start of a fruitful cooperation between IATA, the Ministry of Transport and Egyptair. The home airline was getting better all the time under the guidance of Eng. Atef, who was leading his own revolution at the carrier.
General Shafik’s phone call was about the investigation into the crashed Flash Airlines plane that had gone down in the Red Sea, killing 148 people. He was worried that all his good work would be undone by the resulting stories and so he asked for an IATA team to go to Egypt immediately to present on IOSA. He wanted it made mandatory for every carrier in Egypt and for every carrier flying to Egypt. It was a good meeting and in due course, Egypt became the first country to make IOSA a national requirement. Not long after, Egyptair joined Star Alliance. I remember it well because I had suggested the move to Wolfgang Mayrhuber and Eng. Atef. Wolfgang was hesitant because he thought Africa was covered by South African Airways and Eng. Atef wasn’t sure his carrier was ready. But somehow they made it happen. Egyptair threw the most fantastic party in the desert to celebrate, with the pyramids as a backdrop.
Because of the special relationship we enjoyed with the authorities and airline in Egypt, IATA had chosen Cairo to host its 2011 AGM. Unfortunately, the Arab Spring was on the horizon and Egypt was among the first to witness the revolutionary fervor. We had no option but to cancel and I had to call General Shafik, who had been appointed Prime Minister by Mubarak following the Egyptian uprising, as well as Eng. Atef, who had become Minister of Transport. It was a shame we couldn’t reciprocate the magnificent support Egypt has shown for IATA programs. I hope that one day IATA will again consider Cairo as a venue for its AGM.
A meeting at the Kremlin
With the Egyptian mandate, IOSA had become a national tool as well as an airline one. My next target was Russia. Russia’s problem was the large number of small airlines (nearly 100) still flying old Soviet-era aircraft. These were affecting the hull loss rate and damaging the perception of Russian aviation. I raised this point during a very interesting meeting with President Medvedev in November 2009 at the Kremlin. The meeting was organized by Igor Levitin, the Minister of Transport, and the man who has really transformed Russian aviation. Without him, there wouldn’t be electronic ticketing in Russia and the safety record would be a lot worse. Minister Levitin supported me in all IATA projects and we became great friends in the process.
We arrived for the meeting with President Medvedev at the Kremlin in a minibus. I was with Minister Levitin, the US Secretary for Transport, Ray La Hood, and three European Ministers of Transport. The Red Square is very impressive, with red brick framing Lenin’s Mausoleum and Saint Basil’s Cathedral. Then, as you enter the big courtyard at the Kremlin you have the impression of a medieval citadel, complete with churches, administrative buildings and huge reception halls. You can imagine the many fine events this building has hosted but you are also left in no doubt about the communist history as there is a modern, concrete structure inaugurated by Khrushchev in 1961 to hold the Communist Party Assembly.
The first problem on the agenda was to solve Secretary La Hood’s missing passport. He had forgotten it and so was having a problem getting through the strict security check. I had to rush up a wonderful marble staircase to ask Minister Levitin to solve the issue. Walking through the corridors at the Kremlin is an amazing experience, not only for the incredible statues, furniture and decoration, but also because you can almost hear the conversations from history, from Tsars to Cold War politics.
President Medvedev met us in a large, round meeting room and greeted us all personally. He showed a great grasp of aviation and had obviously studied his dossier well. He spoke for about 20 minutes without notes and summed up the Russian aviation situation perfectly. He expressed his appreciation of the role IATA had been playing in improving the safety and efficiency of the industry. I asked the President to support the e-freight program, explaining the benefits it would have for the business and security.
When talk turned to safety, I suggested making IOSA mandatory in Russia and giving the small airlines financial assistance. Although we didn’t quite get that far, I did agree to translate the complete IOSA into Russian. I have had many similar meetings to this one but I have to say President Medvedev was one of the most impressive leaders. He had a very formal manner but was very professional and elaborated on his points with great clarity. He immediately grasped all aspects of a particular argument. The positive atmosphere generated at the meeting meant that safety was vigorously pursued at all levels of Russian aviation.
It’s strange to think of the number of airlines in Russia because everybody still thinks mainly of Aeroflot. The reason for this is that it was once the biggest airline in the world, flying 120 million passengers every year. It had a fleet that was equal to the largest American carriers combined. Aeroflot is also one of the oldest airlines. It was founded in 1923 following a study on air transport that was signed by Lenin. Aeroflot started modernizing under the leadership of Vladimir Tikhonov in the late 1980s and early 1990s. I knew him quite well during my Alitalia days and I clearly remember the ceremony in 1989 when Aeroflot officially joined IATA. A huge delegation entered the meeting room at the start of the meeting, which was very impressive. It was a big day for IATA, too, because until then it had been perceived as a Western association. Aeroflot joining the Board sent a strong political statement.
One day, Tikhonov called me in my position as Chairman of the Association of European Airlines and told me he had a major problem and asked for my assistance. A meeting of the European CEOs had been planned for the weekend, so I invited him to join us in a small Italian town called Gubbio. I then invited Günter Eser, IATA Director General at the time, and organized a private meeting for the three of us at the end of the weekend. I thought if I can’t help Tikhonov then surely Günter can. But when the Aeroflot CEO told us the problem, we were stunned. “The USSR is breaking up,” he said. “And I have lost control of the airline. When an Aeroflot plane lands in a distant part of the USSR, it is being captured and used by the region to start its own airline.” We didn’t know what to say and of course couldn’t offer any concrete help. But we said we would remain vigilant.
The next day Vladimir and I visited the Basilica of Assisi, where people from all religions come to pray for a better world. I didn’t take him there on purpose but it does seem appropriate now. Eventually, Valery Okulov became CEO and transformed Aeroflot into a successful modern business. His successor, Vitaly Savelyev, has continued the good work. Aeroflot now flies Airbus and Boeing aircraft and has excellent customer service and an excellent safety record.
I returned to Russia shortly before I left IATA. Minister Levitin had organized a meeting attended by all the top people in Russian aviation. It was a kind gesture and he gave me a big picnic case as a leaving present. I have got a lot of use out of it while relaxing in the wonderful Swiss countryside. My final remarks to him were on safety. I proposed giving the smaller airlines two or three years to rid themselves of old aircraft and again called for financial assistance for them. I said the credibility of Russian aviation was at stake, especially as a new regional Sukhoi jet was coming to market. The day after this meeting I attended the La Bourget Air Show at the invitation of Jean Paul Hartman, the visionary Chairman and CEO of Safran, the maker of the successful CFM engine. I had lunch with my colleagues on the Safran Board and then went to visit Vitaly Savelyev at the Russian chalet. President Putin was there and clearly not in a good mood. A Yak-Service Yakovlev Yak-42 plane had crashed that morning in Northern Russia, killing many members of a Russian ice hockey team. In total, Russia had 15 accidents during 2007–11. And in 2012, a Sukhoi Superjet-100 crashed in Indonesia. Clearly, the country still has some work to do.
A dangerous traffic jam
Another country where IATA played a huge role in was Nigeria. It’s a big country with a sizeable population and significant oil reserves, yet it hadn’t ever paid much attention to aviation and aviation safety in particular. In 2005, a Bellview Airlines Boeing 737 crashed, killing 117 people. I wrote a letter of condolence to the President of Nigeria, explaining IATA’s emphasis on safety and offering to help. I received a formal letter in reply but there was no follow-up. Soon after, in 2006, an ADC Airlines Boeing 737 went down with several dignitaries on board, including the son of a former President. It was the 11th accident in the country in just over ten years. This time there was a follow-up and IATA began working with Harold Demuren, the new Head of Nigerian Civil Aviation, and a man who worked day and night for several years to improve aviation safety in the country.
A new Minister of Transport, Diezanni Allison-Madueke, also played an important role. I met her at an ICAO Assembly not long after she became the Minister and she was instrumental in helping to set up a new IATA office in Lagos. She was a former Executive Director of Shell Nigeria and is now the Minister of Petroleum. I often meet her at Davos at the World Economic Forum where she is an active participant and we always talk about the old times and aviation.
I planned to visit our new office in early 2007, flying to Lagos from Madrid. Just before I left the Spanish capital, I had a breakfast meeting with Iberia CEO Fernando Conte and he told me to be careful in Nigeria because only a few days before an Iberia manager had been shot in his car on the way from the airport. I expressed how sorry I was to hear the news but didn’t pay too much attention to the warning. I had often visited so-called dangerous countries and risk was part of the job.
I changed my mind very quickly, however. On arrival I learned I was to be guarded during my entire trip by a group of specially-trained Presidential soldiers. Apparently, the authorities had gathered intelligence that there was a threat on my life as IATA’s strong position on the enforcement of security and safety regulations was threatening the illegal trade in arms and drugs. At the hotel I discovered I had been given the entire top floor, which was easier for the troops to secure. Every so often, even during the night, I was told to change rooms so my exact location couldn’t be pinpointed. About 20 armed soldiers watched over me, some sleeping on the floor of my room. Anybody who came to see me, even my own staff, had to be searched.
All the journeys in the city were conducted at high speed in a convoy of six armed, bulletproof vans. The roads of Lagos, usually very busy, were cleared so my group of vehicles could get directly to the destination without stopping. My Corporate Communications Director, Tony Concil, couldn’t get used to this, although I must admit it was worse for him because he was always told to travel in the first minivan. He was at the front of the action.
On my final day there, we held a press conference for about 100 journalists. Tony was very busy, so he excused himself from my final appointment at the local airline. This meeting wasn’t planned and so the route through the city hadn’t been cleared in advance. A few minutes into the journey we stopped suddenly.
And then the shooting started.
I was pushed to the floor of the van and my guard started shouting into the radio. I heard car doors slam and people running and screaming. The gunfire carried on and I started to get very scared. After several minutes the shooting stopped and I was allowed up from the floor.
When I asked what had happened, I couldn’t believe the answer: a traffic jam! Because we were forced to stop, the soldiers started shooting in the air as a way of getting the cars to move out of the way. But everybody had become so scared that they had abandoned their cars and run away leaving us stuck in the middle. It wasn’t a pleasant end to the trip but I can laugh about it now.
Accidents still happen of course. But we are learning all the time. Thanks to the great efforts of all the authorities involved, safety is improving. We also have to thank the efforts of centres of learning such as Cranfield University. Its School of Engineering is studying aircraft design and many other aerospace issues with great attention to detail. It has a dedicated course and a large part on accident investigation that helps explain what to do should an accident occur.
As for IOSA, it now has over 300 registered airlines and the number of countries that have mandated it at the state level is increasing all the time. There is no doubt that the audit has made a difference to IATA members and to aviation in general. Numbers tell the story. In 2012, no IOSA carrier had a Western-built jet hull loss accident. For the period 2002–11, there was a 58% improvement in safety. It is an incredible result. IATA achieved this by working with commitment and passion and utilizing the skills of the many aviation stakeholders.