credit-suisse Environmental Report 1997/1998 Short version

1. CREDIT GROUP NOVEMBER 1998 SUISSE ENVIRONMENTAL REPORT 1997/98 www.csg.ch/ecoreport98

2. PORTRAIT CREDIT SUISSE GROUP AND THE ENVIRONMENT Credit Suisse Group (CSG) is decided to use the EMS of Credit evaluation referred to in the opera- a global financial services com- Suisse, the most sophisticated in tional ecology section covers CSGs pany offering a comprehensive the Group at the time, for the entire banking sites in Switzerland and range of banking and insurance CSG. does not include Winterthur (refer- products. Represented on all ence date 1 January 1997). The environmental management continents and in all major system of the Swiss banking sites is financial centres, it comprises certified to ISO 14001. four banking business units and one insurance business unit, Environmental focal points Key figures CSG 1997 each of which is geared to In addition to its environmental ef- specific customer groups and Key financial figures in CHF forts on the operational front (pri- markets. marily aimed at cutting energy con- Balance sheet sumption), CSG focuses mainly on Bank in transition total: 690 000 m checking for environmental risks Since it published its first environ- Annual profit 397 m when granting credit or insurance mental report in 1996, the Credit cover. Increasingly, major earnings Suisse Group has undergone a fun- Key personnel figures potential and opportunities are also damental change. On 1 January Personnel 62 242 emerging in the products sector. 1997, CS Holding, as it was then in Switzerland: known and which consisted pri- Banking 21 442 System limit of this marily of the two full-service banks environmental report Insurance 7 108 Credit Suisse (CS) and Swiss Unless otherwise indicated, this Volksbank (SVB) and the invest- outside Switzerland: environmental report refers to the ment bank CS First Boston Banking 13 235 whole of CSG including Winterthur. became Credit Suisse Group. Insurance 20 457 The environmental performance Credit Suisse Group merged with Winterthur Insurance (hereafter Winterthur) in the autumn of 1997, although Winterthur remains an operationally independent insurance company. Credit Suisse Group and the environment About 20 years ago, an environmental management system (EMS) was set up in the various companies comprising what is today Credit Suisse Group. As part of the reorientation of the Group it was CSG organisational chart: position as of 1 January 1998. Winterthur sites abroad only include national and company head offices. Cover photo: Juvent SAs windpower plant on Mont Crosin. See p. 10 for further details of our involvement. Page 2

3. ENVIRONMENTAL MANAGEMENT CERTIFIED TO ISO 14001 In April 1997, Credit Suisse (1995), CSG has committed itself munication and co-operation on Group became the first Swiss to the systematic incorporation of environmental issues plays an im- bank and the first major bank environmental considerations into portant part in this. anywhere in the world to be all areas of its business activities. awarded the ISO standard Environmental organisation In the autumn of 1998, our environ- of CSG 14001 environmental certificate. mental policy was updated and ap- Within CSG, environmental activities The certification process pro- proved by CSGs Chief Executive are co-ordinated by the environmen- vides independent confirmation Officer. Key changes are the inclu- tal management unit. Specific tech- that the environmental manage- sion of the Winterthur Group and nical responsibility and the implement system complies with this the commitment to remaining envi- mentation of environmental meas- standard and that ongoing ronmentally certifiable. Maintenance ures are largely matters for the vari- improvement in environmental of conformity with environmental ous line and specialist units. The performance has been provided legislation was included as an whole environmental sector is con- for. explicit goal. trolled by the Environmental Execu- Main aims The environmental policy will be An environmental management reviewed every three years, at the system (EMS) conforming to ISO latest in the autumn of 2001. Strengths 14001 is designed to achieve the pISO 14001 certification of following objectives: 2 Planning all CSGs Swiss banking sites since April 1997 pImplementation of defined Outsourcing targets pEnvironmental policy The following services in Switzer- extended to Winterthur pCompliance with all relevant envi- land are provided by external part- ronmental laws and regulations ners. pOutsourcing: ecological targets agreed pThe steady improvement of cor- pBuilding management porate environmental perform- pDecentralised IT systems Weaknesses ance pSystematic environmental pCatering Our EMS consists of four phases management so far only in- pStorage and distribution of office that are repeated: troduced in Switzerland supplies, printed matter and pOrganisational structures and advertising materials 1 Environmental policy procedures in environmental Environmental policy defines the Contracts and agreements were management still tied strongly priority assigned to environmental concluded which commit the con- to specific individuals protection within CSG, as well as tractors to continuous improvement representing a commitment to envi- of their environmental performance Next steps / objectives ronmental protection vis-à-vis and to compliance with CSGs strict pMaintenance of eligibility for personnel, customers (private and environmental standards. Among certification corporate) and other stakeholders. other things, these contractors are pExtension of environmental required to endorse CSGs environ- In signing the UNEP (United Na- management system to sites mental policy and energy guidelines tional Environment Programme) outside Switzerland and and to establish their own energy Statements for financial institutions subsidiaries management system. Open com- (1992) and the insurance industry Page 3

4. ENVIRONMENTAL MANAGEMENT Benefits of certified tive Board which handles strategic were also brought in to carry out environmental management and business policy tasks. Chaired checks. Remedial measures are The environmental certification by CSGs Environmental Executive integrated in eco controlling. has enabled our institution to be Board, this Working Group includes included in the portfolios of environ- representatives from all business Certification process mentally oriented investors. In addi- units and from the Environmental The certification audit took place in tion to cutting costs and reducing Management unit. April 1997. The focus was on the risks, this has created further practical implementation of the envi- added value for our shareholders. 3 Implementation ronmental commitment on the part In implementing environmental man- of the line organisation. The audi- Certification enhances the credibility agement measures, CSG intends to tors questioned 50 key environmen- of CSGs environmental manage- adhere to the environmental policy tally-relevant personnel at head ment program. obligations it has assumed. Compo- office in Zurich, in four regions and nents of the implementation phase in certain branches Future and trends include: Validated environmental perform- The audit report produced by the ance evaluations and certificated pEnvironmental controlling certifying company (SGS-ICS) con- environmental management systems firms the success of CSGs environ- pEnvironmental standards are increasingly important in as- mental management. As well as sessing whether a company is best- pTraining of personnel bearing out the evidence of steady in-class. Accordingly, central impor- improvement, the report also lists pEnvironmental report tance is attached to questions from remedial measures. environmentally-oriented investors 4 Monitoring The certificate is valid for three concerning the introduction of envi- years providing that the annual ronmental management systems Internal audits monitoring audits are completed and their possible certification, as Over 25 sector-specific checklists successfully. The Group passed the well as management involvement were prepared for internal audits. In first audit in June 1998. and endorsement and support for individual cases, external specialists product ecology. Moreover, demonstrating the benefits of the EMS will gain in importance. Also on the Internet pOverview of EMS in chart form pEnvironmental policy pCSGs environmental organisation pMilestones pBenefits of certified environ- Key environmental figures according to the VfU standard for Credit Suisse Group mental management (Switzerland), 1996. Emp. = employees. Page 4

5. PRODUCT ECOLOGY A CHALLENGE FOR THE FUTURE Environmental risks associated In the field of environmental accordingly. In international busi- with the granting of loans and policy, we have committed our- ness, where necessary, Credit with real estate ownership selves to gradually incorporating Suisse First Boston consults exter- Credit Suisse only conducts busi- the environment factor into nal specialists to enable it to tailor ness with corporate customers in new and existing services and its response to differing operating Switzerland. Since 1992, it has products. The main focus of our conditions and legal frameworks. been systematically analysing all efforts in the field of product loan applications for environmental ecology is on risk management risks such as contaminated sites. both in the context of granting Environmental hazards inherited credit and of providing third- from the past can be an important party liability insurance cover. factor not only in the field of loans Strengths We see earnings potential and but also in the valuation of real es- opportunities in the sector of pRisk management in the con- tate. environmentally-oriented finan- text of granting credits and of cial investments and niche prod- Where necessary, the specialist third-party liability and property ucts. environmental risk unit assists our insurance credit specialists in their evaluation pTwo powerful special funds: The environment and products and in recommending measures. Eco Efficiency (Lux) and Fel- CSGs environmental activities in In this way, we also create added lowship Trust (UK) the products sector can be classi- value for many of our customers: fied into the three areas of environ- pOpen for innovative, environ- in the context of the background mental risks, investment business mentally oriented products, documentation and information re- and niche products. e.g. WinCAT and Energy quired for credit checks, environ- Contracting mental issues are systematically 1 Environmental risks reviewed in order to pinpoint envi- Weaknesses Environmental risks are likely to be ronmental risks at an early stage. encountered in the following three If a problem arises, the bank is pTraining and support material areas of business: available to the customer as a in investment business still too competent partner with contacts piecemeal pCredit Suisse (granting of loans to specialists and the authorities. and real estate ownership) pReview of environmental risks and opportunities in project pCredit Suisse First Boston Environmental risks relating financing not adequately (project financing) to project financing systematised Environmental risks may also arise pWinterthur (third-party liability in connection with project financing. Next steps / Objectives and property insurance and real This mainly affects Credit Suisse estate ownership) pGreater sensitisation and infor- First Boston in its role as a financ- mation concerning products ing partner. In most cases the fi- with an environmental impact nancing is undertaken with other banks acting jointly with the World pStructured procedure for as- Bank; in examining the risks, their sessing environmental risks environmental standards are applied and opportunities in project financing Page 5

6. PRODUCT ECOLOGY MARKET SUCCESS WITH GREEN FUNDS Environmental risks The fund invests worldwide in com- million Swiss francs (July 1998). Its at Winterthur panies that are successfully imple- success shows that ethically/envi- In the insurance industry, the envi- menting the concept of eco-effi- ronmentally-oriented funds are ronmental debate centres on the ciency. Sustainable Asset Manage- meeting a market need. possibility of climate changes, which ment (SAM) AG, Zurich, seeks out are generally expected to lead to an eco-efficient companies on the ba- Sustainable Performance increase in natural disasters with Group (SPG) goes public sis of a rating system which it has repercussions for property insur- SPG shares were floated on the developed itself. ance. Another major topic is envi- stock market by Credit Suisse First The stocks proposed by SAM ronmental liability insurance. This Boston in the summer of 1997. undergo final selection taking has prompted Winterthur to address It successfully invests in companies account of the usual fund principles environmental issues and take whose products and services gener- at Credit Suisse Asset Manage- measures to improve risk control as ate economic, environmental and ment (CSAM) in a multistage pro- part of its subscription and tariff social benefits and in doing so cess. In this way, CSAM invests policy, in product management and achieve competitive advantages. worldwide in listed companies in all handling of claims, and in its envi- Credit Suisse First Boston is con- sectors that stand out by virtue of ronmental services. sulted for financial analysis. their above-average environmental One of Winterthurs main interests and financial performance. lies in overcoming the conse- The yield outlook is highly promising: quences of natural disasters and since the funds repositioning, it has environmental catastrophes from a posted above-average performance technical underwriting point of view. by international comparison. Meas- On a global scale, they are respon- ured against traditional funds, its sible for the lions share of all in- market share is still marginal. sured property damage. Since the mid-1980s, natural disaster claims have been on the rise, though the Fellowship Trust fluctuations from one year to the In the UK and the USA, ethically/ Also on the Internet next are substantial. environmentally-oriented funds have already been established for some pInformation on the environ- 2 Investment business time. In the Credit Suisse Fellowship mental risk unit Trust Fund of Credit Suisse Asset Eco efficiency pExamples of environmental Management Funds (UK) Limited, In 1990, CSG became the first risks CSG has a fund which has won Swiss bank to launch an environ- several awards on the strength of pInformation on risk manage- mental technology fund (Oeko- such criteria. The Fellowship Trust, ment at Winterthur Protec). In the spring of 1997, a which is only available in the UK, is new fund management reviewed a country-specific fund that has pNatural disasters and climate the investment concept and reposi- been investing in selected small and change - steps taken by tioned the equity fund under the medium-sized companies since Winterthur name Credit Suisse Equity Fund 1986. The Fellowship Trust com- (Lux) Eco Efficiency. pUp-to-date information on prises a total volume of over 200 the Eco Efficiency Fund and Fellowship Trust Page 6

7. 3 Niche products Future and trends The securitisation of environmental WinCAT catastrophe bond and health risks will become in- Innovative financial products allow creasingly common. One example the insurance industry to hedge of this trend is emission certificates. against environmental risks on a These certificates are securities broader basis and offer investors that entitle their holders to emit set diversification opportunities outside quantities of pollutants into the traditional markets. An example of environment over a given period of such a product is Winterthurs Cat time. They are sold (or issued) to Bond, a convertible bond with a individual companies by the govern- special additional condition at- ment or an independent national or tached: the annual coupon payment international authority and can sub- is cancelled in years in which hail or sequently be traded. Depending on storm damage is above a fixed limit. the reduction target for the eco- To compensate for this risk, inves- nomy as a whole, the authority in tors receive a coupon bearing a question can influence the quantity higher rate of interest. Trading of emission certificates: a new of emission certificates through area of business for banks? purchases. Accordingly, providers of Energy contracting financial services are called upon to This financing and operating model establish a market and train market involves commissioning a specialist participants. There is a huge need for finance to outside firm to supply energy and fund the implementation of interna- Emission certificates are character- maintain facilities. Instead of buying tional environmental agreements ised by high environmental target oil, gas and electricity, the energy (Convention on Climate Change, attainment levels on the basis of user purchases heat, refrigeration, Biodiversity Convention). For finan- free market mechanisms. For light or steam in other words en- cial service providers, this means banks, the trading of certificates ergy services. growing opportunities to participate also opens up new business oppor- in the financing of environmental This enables companies to avoid tunities. projects or projects beneficial to the expensive investments, for example environment in close co-operation We are actively involved in research in modern heating systems, while on with multilateral banks. CSG wants and discussion aimed at developing the supply side economies of scale to tap into the opportunities in ecologically-oriented financial prod- and technical expertise can be sys- these business areas. ucts. tematically exploited to supply heat on an energy- and cost-efficient basis. In the context of the Swiss Federal Governments Energy 2000 investment programme, Credit Suisse offers contract-leasing models. For larger investments, we also examine project financing solutions. Page 7

8. OPERATIONAL ECOLOGY IN THE CHANGING COMPANY Environmental performance Our company has stepped up its it more difficult both to co-ordinate evaluation of Credit Suisse efforts in operational ecology environmental management and to Group (Switzerland) 1996/97 even during the restructuring collect environmental data. Extended system limit of CSG. Our extended 1996-97 A number of ecologically signifi- environmental performance Compared with our first environmen- cant technical functions were out- evaluation for Credit Suisse tal performance evaluation in 1994, sourced by CSG to external firms. Group (Switzerland) shows a fall the system limit has been extended Thus, from January 1998, Merkur in paper consumption and a fur- to include all bank offices of CSG in Immobilien Bewirtschaftungs AG ther rise in the consumption of Switzerland but not Winterthur, (MIB AG) took over building man- power and heat. The evaluation which joined CSG only after the agement operations, an area which highlighted a number of areas cut-off date of 1 January 1997. CSG had previously handled itself in where improvements could be Switzerland. This system covers around 470 made in the collection of data. sites with an energy reference area One of the next steps must be To guarantee monitoring and control of 1,200,000 m² and 20,700 em- to ensure that the environmen- of operational ecology in the future, ployees. tal targets set for our contrac- CSG needs to be able to rely on the tual partners are adhered to co-operation of the building man- and implemented. agement company. Under its contract, MIB AG has undertaken to Operational ecology steadily reduce energy consumption reflected by the reorientation levels and to actively co-operate in In recent years, CSG has under- the implementation of the environ- gone several changes with a major mental targets through systematic environmental impact. Following the Strengths environmental controlling, as well as reorientation of our banking busi- pExpansion of the environ- other means. ness on 1 January 1997, August mental performance evalua- 1997 saw CSG merge with Winter- Since mid-1998, MIB AG has also tion in terms of breadth and thur. This increased the size of our been servicing properties occupied depth workforce and real estate holdings by Winterthur in Switzerland. This pReduction in paper both within Switzerland and in par- means that the same environmental consumption ticular abroad. requirements apply as for the properties of the banking business units. A separate environmental perform- Weaknesses ance evaluation was prepared on IT Services, which belongs to CSG, pIncreased consumption of the environmental repercussions of is taking over the management of heat and electricity the reorientation of our banking our decentralised computer systems pReorientation made data business. The restructuring process which consist of around 43,000 collection and comparison had less impact on the environment computers, 15,000 printers and more difficult than one week of ordinary banking 1,400 networks in Switzerland operations. alone. As well as being responsible Next steps / objectives for installation and maintenance, IT Because of the increase in changes pEnvironmental controlling to Services also sees to the evaluation of responsibilities and personnel and be increasingly geared to and disposal of equipment. owing to changes in the branch energy saving measures network, the reorientation has made pImproved data management Page 8

9. Our first survey of stocks of fire extinguishing and cooling agents (halon and freons) at all our fixed installations brought to light an ac- cumulation of freon losses. Reme- dial measures have been initiated. For our evaluation we used the environmental scarcity method (EIP methodology) according to Braunschweig and Müller-Wenk. Changes since the 1994 environmental performance evaluation As a result of the new corporate structure and the extended system Saving energy is a crucial factor in improving the environment. limit of the environmental performance evaluation, direct comparisons fields of data collection and cost Our environmental aims envisage between the 1994 and 1996 per- transparency which we shall now be reducing our consumption of energy formance evaluations are not always addressing in co-operation with MIB and resources for materials and appropriate. Nonetheless, certain AG. services. We give preference to the trends are emerging. use of durable materials and products and aim to increase recycling Future and trends As a result of the expansion of our of the items used. To this end, when The co-ordination and responsibili- business activities and the increas- procuring materials, we not only ties of the two operational ecology ing penetration of technology into examine their environmental compat- programmes run by Credit Suisse new areas, there was an increase in ibility but also the manufacturers and Winterthur will be aligned on consumption of electricity, heat and ecological commitment. the new organisation. By sharing water in absolute terms. The reduc- common logistics platforms, we aim tion in paper consumption is attrib- to exploit as many synergies as utable to steps taken to encourage possible. So far, no operational the use of electronic media. ecology organisation has been es- The lions share of CSGs direct tablished for the many sites outside environmental impact still stems Also on the Internet Switzerland, most of which are from the provision and consumption small. In the longer term, in addition pEco Performance 1996-97 of electricity and heat. Accordingly, to the Swiss system, we also aim to our medium-term priorities in the include sites outside Switzerland pEnergy Guidelines field of operational ecology focus on that are relevant in terms of opera- reducing these energy flows. pVfU key figures together with tional ecology. This plan affects a comparison with other mainly Winterthur, which employs The targets set in our 1995-96 banks more personnel abroad than within environmental report have not yet Switzerland. been achieved everywhere. There is pUetlihof certification for still room for improvement in the nature-compatible design Page 9

10. COMMUNICATION GREATER USE OF ELECTRONIC MEDIA Through direct contact with our Since the summer of 1998, we In the context of its support for internal and external partners, have been communicating via the environmentally-friendly technolo- we help to strengthen environ- Internet as well as in printed form. gies, Winterthur provides support mental awareness. Through an for the wind-power plant on Mont We support scientific research. We exchange of experience and Crosin. This modern plant is the first value our links with NGOs and data, Credit Suisse Group also in Switzerland to generate electricity other interest groups. supports the environmental from wind energy on a significant efforts of the business and re- scale. As the suppliers first major Sponsorship and contributions search communities. Because customer, Winterthur has committed CSG does not regard its social and of this commitment, Credit itself to consuming 200,000 kWh environmental commitment as spon- Suisse Group is perceived by per year over the next ten years at sorship in the sense of a marketing the public as an environmen- an additional cost of CHF 30,000 instrument but as a core compo- tally-aware company. In future, per annum. We are prepared to pay nent of its corporate culture. Where we shall be redoubling our twice the usual price for the invest- we sponsor a project, we make training and communication ment in this environmentally-friendly, available our environmental exper- efforts. These include our pres- renewable energy. tise and facilitate environmentally- ence on the Internet. compatible measures. External communications We support selected environmental and commitments organisations with affiliations and CSG is actively involved in numer- financial contributions and we also ous national and international bod- support specific research or devel- ies concerned with environmental opment projects. We have, for ex- protection, including the United ample, made a significant contribu- Nations Environment Programme tion to the guidelines produced by UNEP and the Swiss Bankers As- the Swiss Bankers Association on sociations Working Group on the environmental management in Environment. We organise events Strengths banks. and lectures on environmentally- pPositive media response to relevant topics such as environmen- our environmental activities tal management and credit risks for corporate customers. We also pub- pActive involvement in lish articles in specialist journals on environmental bodies environmentally-relevant topics. Weaknesses pEnvironmental awareness still insufficient in certain areas Next steps / Objectives pStrengthen communication by use of electronic media pFormulate and implement training concept Page 10

11. Internal communications Our ecological aims can only be achieved if everyone is familiar with these aims, creating a correspond- ing corporate culture. The basis for such a culture is dialogue, along with regular information and training on the subject of the environment. In our efforts, we encourage the individuals we are addressing to act in an environmentally-aware manner in their private lives as well. The steadily growing Environmental Circle, a forum for staff interested in environmental issues, makes a In environmental communication, we leave no one out in the cold. key contribution towards achieving this aim. Its members, who now number 1,300, receive tips and information on environmental issues Further training from the environmental manage- We attach importance to training ment unit; events are also organised our personnel in environmentally- from time to time. Our aim in setting sound behaviour. To date, training up this informal network is to anchor events have been staged covering environmental awareness on as the areas of building and materials broad a basis as possible. management, catering and trans- port. We also train our loan special- We also provide information in the ists to identify environmental risks. form of articles in various staff We will be expanding our training magazines and external trade publi- strategy in order to strengthen our cations. In order to foster environ- in-house training. mentally-compatible conduct in the workplace, we distribute copies of our environmental standards re- cently issued in the form of a handy bookmark to all personnel. Also on the Internet: pOur affiliations pSBA guidelines on environmental management in financial institutions pOur environmental policy Page 11

12. DEAR READER the field of climate change. We Validation by SGS-ICS AG want to utilise the major growth potential that exists in the field of We have verified the correctness ecologically-oriented asset manage- of the statements in the 1997/98 ment. The very good performance environmental report of Credit of our two environmental funds Eco Suisse Group and, where neces- Efficiency and Fellowship Trust sary, have requested that proof be shows that we are on the right track presented. in this respect. A special challenge We hereby confirm that the report that we need to address is the In our second environmental report, has been prepared with the neces- evaluation of ecological risks in the sary care, that its contents are we provide our staff, customers correct, that it describes the essen- context of project financing. and shareholders, as well as eco- tial aspects of the environmental logically-oriented investors and in- As regards expanding our environ- management system at Credit terested members of the public, Suisse Group and that it reflects mental management system and with information on our commitment the Groups actual practices and introducing new cost-cutting meas- to the environment. procedures. ures, we shall increasingly focus on our major sites outside Switzerland In April 1997 our environmental Elvira Bieri and Dr Franz Heinzer as well. Zurich, 19 October 1998 management system in our Swiss locations was awarded the ISO A process of transformation is tak- 14001 environmental certificate. ing place not just within Credit We are extremely pleased to be the For further information and to Suisse Group (CSG), but through- first Swiss bank and indeed the first order additional copies: out the whole media scene. We bank anywhere in the world to have have therefore decided to break been awarded this certificate. This Credit Suisse new ground with this environmental distinction is helping to strengthen Environmental Management, CCUE report in publishing this printed ver- our good reputation among our P.O. Box 100 sion, which is a summary of the full stakeholders. CH-8070 Zurich text now available in both German and English on the Internet at CSG is one of the first financial www.csg.ch/ecoreport98. As well Tel. ++ 41-(0)1-333 73 33 service providers to have committed as saving paper, this approach also Fax ++ 41-(0)1-333 76 33 itself to comprehensive environmen- ensures that you always have ac- tal protection and we want to con- E-Mail: csg.eco@csg.ch cess to our most up-to-date infor- tinue to play a pioneering role in the http://www.csg.ch/ecoreport98 mation. future. Our aim is to find ways of integrating environmental considera- We would like to thank everyone tions into our banking and insurance Projectteam who helped produce this environ- business. Having already achieved a mental report. We would also be Otti Bisang, Patrik Burri, good number of successes in the interested to hear your views and Thomas Frei, Nick Marolf, field of operational ecology, we shall constructive criticisms; we look for- Bernd Schanzenbächer increasingly be turning our attention ward to your feedback. (Environmental Management) to product ecology and the new risks and opportunities that exist in Less waste, more information: we would be grateful if you could pass this report on to others or circulate it. Please do copy or quote from this CCUE 11.98 Lukas Mühlemann Peter Lienhart report: we would appreciate notifi- Chief Executive Officer Member of the CS Executive Board cation or a specimen copy of your of Credit Suisse Group and Environmental Officer of CSG article. Page 12

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