Natural Capital: Practical Ways to Assess Financial Materiality for Companies
How does biodiversity impact investment portfolios? What are the risks and opportunities for companies when it comes to natural capital? In this episode of the All Angles podcast, Pooja Daftary sheds light on calculating the financial materiality of natural capital for companies and offers practical ways for investors to integrate natural capital into an investment strategy. Listen now for insights into building a repeatable process to assess this nascent but existential investment theme.

Vish Hindocha: Hello and welcome to another episode of the All Angles Podcast. In this episode, we invited Pooja Daftary to come on to talk a little bit more about natural capital. She thinks about it, what frameworks she uses, the questions she asks, and what the landscape is within the investment industry around assessing, evaluating and investing based on natural capital risks. Natural capital is one of the hottest topics across the investment landscape. And it’s much more nascent than many other sustainability-related risks or fundamental risks that we are very used to now in incorporating and integrating into our work. So this episode comes at a critical time when I know many investors, asset owners and investment managers are really thinking about natural capital and the way in which they need to start governing towards it. We also touched briefly on the role of policymakers. We cover specific case studies and examples in different sectors and talk about some resources and some recommended guidance for investors that are starting out on their natural capital journey.

I hope you take from this conversation as much as I did. And if you have any comments, questions, suggestions for future episodes, please reach out to us at allangles@mfs.com. Hello and welcome to another episode of the All Angles podcast. It is my great pleasure and delight to welcome back, Pooja Daftary. Pooja, welcome back to the show!

Pooja Daftary: Thanks, Vish. Thanks for having me.

Vish Hindocha: So for listeners that have listened before, Pooja was one of our first guests on Season 1, Episode 4 where we touched on a few things. In particular, one of the things that really stayed with me was how you think about systemic thinking or system-wide thinking, and there’s lots of chatter about that in our part of the industry. And I thought it was really powerful how you talked about the marriage of bottom up and top down rather than thinking about it purely from one or the other. But one of the other flags that we planted in that conversation was around natural capital and some of the work that you had been doing at that point in time. As you went back to that episode, it was April ’22, so a long time has elapsed since then. So my first question for you, Pooja, is how has your thinking developed over the last 12 to 18 months when it comes to natural capital?

Pooja Daftary: Yeah, I think that the main difference is we still use the same framework to identify the natural capital risks but where we’re seeing the biggest changes is in regulation, that previously there was a lot of conversation that if regulation were to come about, then the issue of natural capital would become material. But I think that debate is already done and dusted, that it is material and that there is a very wide recognition that it is as much, if not more material than climate risk, and that it’s not just a matter of costs, but it’s a matter of availability of the types of goods and services that we’ve been used to consuming for these decades, if not centuries. It’s an existential question as to whether those commodities and services can be produced in the same manner going forward.

And that there’s also the question of incentives, which is one that I think is, again, relatively new thinking for us. You’ve identified the problem, but understanding the incentives of different players within value chains, that really the regulator does need to come in to change that incentive system up for companies to invest early behind mitigating natural capital risks. Otherwise, from a timeframe it’s just too far out for them to want to take action right now and there’s too much of a free rider problem.

Vish Hindocha: Yeah, thanks. And you and I were both at the PRI in person this year in Tokyo in ‘23. And I think one of the themes that really permeated was to your point, how much natural capital has come forward in terms of being fairly well established now as a material investment risk. There was a lot of excitement over the TNFD and the task force for nature-related financial disclosures and their work and their frameworks that they published in September of ‘23. So to your point, it feels like there’s lots of excitement. But then you also said long term you think it’s a time horizon, it’s challenging. Incentives are challenging, data’s challenging. So there’s also a recognition, I think, that understanding and assessing the potential investment impacts of natural capital is really, really complex. And I know we touched on this a little bit last time, but I wondered: If we just take a small step back, I’d love for you to just talk about where do you start from?

It’s such a kind of myriad of complexity. Where do you begin? And I think that would be really helpful for the listeners as we walk through. How do you as an investor start to appreciate and analyze natural capital risks?

Pooja Daftary: I think we start from a broad funnel to, say, let’s just start with our position sizes. Where do we have the most exposures? In which sectors? And within those sectors, where do you see natural capital risk being the most material? And I think if you look at some of the research that’s being done by TNFT and other bodies, it’s pretty evident that the food supply chain is one of the most natural resource–intensive supply chains, with very high dependency on natural resources but also impacts. Apart from that, I think there’s mining and utilities, but I think those are a bit better understood, and they’re better regulated. But I think that the food industry, because of how disparate the supply chains are, how globally dispersed they are and how companies have very little control really over upstream supply chains, that that’s where we need to figure out how to spend the time and what work needs to be done.

And so we typically would start by saying how material is natural capital for an issuer, financially material, i.e, how much do they depend on it for their operations, for their goods and services? Then trying to figure out what are some of the hot spots within those supply chains where there’s the greatest natural capital risk. So in the case of — let’s say if you’re looking at — dairy and beef have been identified as being two of the most resource intensive products, and significant contributors to land use change emissions but also just very resource-intensive from water and from other perspectives. And so trying to figure out where those supply chains are located — and could they really disrupt operations for companies that we own? Are companies taking proactive measures to protect natural capital? Are they exposing themselves to risks further down the supply chain, and how might it impact the business?

And once we do that analysis, we can then begin to craft an engagement strategy with companies. And I’d say the engagement at this stage is very much diligence. Rather than coming in and advising companies with very specific actions that they need to take, it’s about first trying to think through — are you even thinking about these risks and opportunities within the board, within senior management? Have you identified and stress tested areas of weak links within your supply chains? Are you investing capital? Are you investing R&D in trying to fix the problem? And most importantly, are you trying to scale it? Because we’re seeing that time and time again companies are doing lots of interesting things like regenerative agriculture, etc., but they tend to be in very small pockets of the farm. And it’s not really scaled such that it could impact global value chains. And that’s the scale of change that we really need to see for the needle to move even a tiny bit.

Vish Hindocha: Yeah, there’s so much there that maybe we can spend the next three hours unpacking together. I want to come back to maybe some specific examples, but your point is really well-made on the engagement at this point being more about due diligence. And I think we’ve often made this point that I think people can sometimes be seduced into thinking that engagement is just about influence or about changing someone’s mind or about sort of a shareholder resolution or a vote. But often for us, engagement is actually much more about understanding the company and first figuring out what the right questions are to ask and then asking them in a bid to inform our thesis. So I definitely want to come into some examples on the engagement side. But before we do that, you touched on the food sector, beef specifically. You also mentioned some other sectors. Could you give us some examples of specific sector or industry work that has been done? And how has that influenced the investment team’s thinking around the thesis of either particular names or particular industries?

Pooja Daftary: Sure. I think where we’ve done the most work is probably on the consumer staples companies in the food supply chain, because what we see is that food has more exposure even than beverages, for example, which is mainly limited to water stress. There’s some grains exposure there, like barley and hops, etc., if you’re selling beer or whiskey. But with the food companies, I think they have the biggest exposure. And so what we decided to do was kind of develop a multiprong strategy to say there’s no point only engaging with the brands. We have to talk to the other sort of large influential players in the value chain to really understand how this value chain is incentivized to operate. So we started off by picking one topic, which was deforestation, primarily because it is kind of the one that’s most closely related to climate and probably the easiest one to fix because regulation is really building momentum towards ending deforestation and therefore companies are more inclined to talk to us about it as well.

So we picked on that one topic of deforestation, linked it to companies net zero plans as well, because for a lot of the consumer brands, 90% of their emissions sit in upstream Scope three. And off that upstream Scope three, most of it is land use emissions change. And so deforestation, if addressed, could really address a very big piece of that kind of carbon target setting. So we came at it from that angle, we started talking to a few companies with the brands and tried to understand what their purchasing practices were. So how vertically integrated were the supply chains versus how many of them use the large green trading companies to do the purchasing for them. And what we learned was they’re heavily reliant on the green trading companies. Most of them don’t really have visibility into the farmer level to see what’s really going on in terms of deforestation, etc.

And so while we started talking to the brands, we parallel-processed and started talking to some of the green traders. And what we saw was that the brands had set far more ambitious targets to end deforestation across their supply chains commitments for 2030 zero deforestation, zero land conversion. But when you talk to the grain traders, the commitments really felt short, and they didn’t really see it as their responsibility to influence things. And the conversation there then became that, well, if the customer demands it, they would do it. And so we were trying to then understand what’s the disconnect here. We also tried to speak to some of the suppliers to understand how they got paid.

Would they be paid a higher price for those regenerative agriculture type projects or would they be paid the same price, which means that they are not really incentivized to act in that manner. And then we started basically asking for the same commitments throughout the value chain in a consistent manner between the grain trading companies, the consumer brands saying  “Look, your customers have made these commitments, so in order to fulfill those commitments, they’re going to rely on you. And you have great visibility into the end suppliers all the way upstream, and you have the relationships with the farmers.” So they could actually be a big part of the solution just given their massive global scale and the traceability of supply chain information, which is very hard to do the further downstream you go.

Vish Hindocha: Yeah, it’s fascinating, isn’t it? The way that you’ve looked through the supply chain. And whilst again it can be tempting to look at a particular issuer or a company that maybe we invest in and look at their claim of be it net-zero or being nature-neutral or nature-positive or whatever it might be and take that something at face value. But then if you said 90% issue of their carbon emissions, for example, come from upstream. And if you actually go upstream and say what are the incentives or what are the desires there, how is that actually in reality going to sort of flow through? I think that’s really, really interesting and how we rebuild those incentives to do that. So I guess that’s one of the challenges, is the value chain can be really complex and can be quite far-reaching for some of these products. Are there any other challenges that you or the investment team have come across when trying to integrate this into your analysis?

Pooja Daftary: Yeah, the biggest other challenge is just that regulations globally are so different. And companies are setting their own policies based on the regulations of the geographies that they’re operating in or where their supply chains are operating. And that’s completely fair, but many of the requirements today in terms of getting to zero deforestation or nature-positive, require companies to basically act in place of governments by holding themselves to a much higher standard than the regulators currently do. And I think that’s a hard ask for companies. Even if they’re focused on the long term, it’s still — management teams are still incentivized and paid on three to five year horizons, not on 30 years. Most CEOs today won’t be around to see the next 30 years. So that’s some of the other challenges, like thinking about, well, what about the policy piece of it, how does that change?

Do companies need to influence policy, or do they need to wait for policy to change first and react to it? So those are complicated questions. It takes us back to kind of debates on carbon border tax in Europe, whereby some of the companies that want to have more green businesses can’t do so economically because of carbon leakage. And it’s kind of the same then, in deforestation and in natural capital. And so trying to understand and follow the regulations is a real critical part of the integration process, because then it helps you size the risk and time it. And it also gives us more context and context with which we can go then to companies and ask them to make any change.

Vish Hindocha: Yeah, it’s really powerful. So you’ve talked about a few things there, incentives of the companies, comparability of the different regimes around the world, but balancing that with the need for nuance at a more regional and local level.

Pooja Daftary: The third part that we struggle with, I think or we’re spending time on, is trying to understand the financial implications of investing behind solving natural capital crises before they actually appear and hit the bottom line. And that’s a really tough part, for companies to give that sort of guidance on capex, on R&D, partly because they may not know what those numbers actually look like. So having those conversations with companies has been really critical. And I think that’s where some of the target- setting has been really helpful to understand, is when they say that they’re going to get to net zero by 2050 and you know that land use emissions is such a big part of it. And then when you see the capex estimates that they’re kind of sharing and where that capex is going to be spent, then you can kind of come back and say, “Well, 80% of your capex estimates are being spent on 10% of your carbon production requirement.”

So how do you address that 90%? And what does that mean in terms of maths and how much it’s going to cost you? So I think that’s a real critical piece of the equation, is trying to put some numbers into it.

Vish Hindocha: And there’s so much room for, I think, growth. It feels like we’re in a much more nascent stage of understanding exactly how we think about this as investors. One of the challenges that I think about often with natural capital (and would welcome your view): You touched on sort of the interconnectedness of nature and net zero claims. And so we seem to be further down the path on climate, but I definitely agree with you that often the net of net zero relies on often some kind of nature-based solution. And deforestation and water will play a kind of critical role in carbon sequestration and soil as well. And therefore these are deeply interconnected. But I often think that nature is by multiples more complex than climate change. And I wonder if you encounter this too, that there are so many different facets to it, often four or five different ways that you could think about natural capital — each with its own set of metrics that might be relevant to a particular case — versus climate that has this sort of common currency of CO2e that we’ve landed on and we universally accept as being, whilst not necessarily entirely perfect, kind of a really good measure to understand and make comparable estimations and assessments across different industries or sectors or geographies. And we just don’t necessarily have that yet. How do we give investors some kind of safe haven of simplicity to be able to operate from? Because it feels as though sometimes the complexity is a little bit overwhelming and we don’t quite know where to start. Does that resonate with you, or do you have any thoughts on?

Pooja Daftary: It does resonate, but I don’t think you can really simplify it a whole lot, to be honest, because it is incredibly complicated. And I think the only way you can try to make more sense of it is by linking it back to financial materiality to an individual company, because ultimately we’re talking about major systemic issues with lots of companies and countries in play and not necessarily aligned incentives to solve it, either. You have incentives based on timelines, based on vested interests, etc. So coming back to the financial materiality point in understanding how does a company make money, what major natural resources is it dependent on? What are the three natural resources? Let’s say if it’s Nestlé, you know that cocoa and palm oil are extremely important in its supply chain. That’s the same as Mondelez. There may be soy in there as well. But if that’s only 10%, then maybe we first focus on the ones that are 80 or 90%.

And then within that, think through, well, where do they source those commodities from? Ninety percent of cocoa — 80% of it comes from West Africa, which is heavily desertified. So what are the implications, then, of the yield of cocoa going forward? Will that supply chain have to move to say, Vietnam and parts of Latin America? How do the costs of having those multiple diversified supply chains change? What does it mean for regulation if you have a cocoa supply chain now originating in Brazil or parts of Latin America, where we know there’s a lot of scrutiny now on deforestation? And so these are the kinds of analyses that we try to do to say what could be realistically most disruptive for a company’s operations, most expensive for their cost of goods sold, most reputationally damaging for them in the next five to seven years. And let’s just focus on digging deep into those first, matching it up with where is their revenue footprint located and where is their cost footprint located. And are they going to see regulatory pressure on either side of that? How can they react and can we try and size that response?

Vish Hindocha: And so that’s a perfect segue to come back to maybe engagement. So as you’re doing that and thinking that through and using that as the lens through which presumably to engage with companies, how open are the companies that you’re engaging with, maybe in the staple sector or even the mining sector, to discussion on these topics? If it’s financial material to us or we observe that as investors, is that something that resonates with them that they fully understand and they embrace? Or what is the attitude generally that you’ve found in management, or does it vary quite widely between different companies and issuers?

Pooja Daftary: It does vary between — I would say it even varies across sectors. So it varies for the consumer facing sectors that will be sort of the first line of defense, so to speak, even for regulators. They’ll be the first ones that will be impacted. They’re able to understand why we want to talk to them about this, and they have the profit pools and the margins to support investments in solving some of these issues. There’s a brand risk as well. But then as you move upstream to grain trading companies. They’ve always, I think — they’ve seen their role as quite different. The margin profile is different. They’re very asset-heavy industries, moving bulk volume from one place to another. And maybe they haven’t quite seen their role as being able to provide that traceability for their customers upstream.

So yeah, it completely differs by sector. I think it is an easier conversation with some of the staples companies right now because they’ve already kind of faced backlash for plastic pollution from emissions. So they’ve kind of been in that mode of trying to think through some of these sustainability issues and solve for them. But I think with some of the upstream players, they’re only now really starting to get drawn into that discussion, being positioned as either part of the problem or part of the solution. So I do think that there’s understandably a muscle that still needs to be developed. There’s institutional knowledge and that still needs to be built. So there are very palpable differences between who you talk to. And I think we have to tailor the conversations as well based on who you’re talking to.

Vish Hindocha: Yeah, that’s really insightful. And the adaptability that the engagers or the investors have to show to meet the different companies, sectors, industries where they are. And you mentioned this earlier, sort of what they have agency over as well. To your mind, are there any — I know, again, we’re early in this journey generally, and there are some collaborative stewardship initiatives being set up around nature, but thinking about the work that you’ve seen or you’ve done within MFS — are there any stories that come to mind in terms of specific advances that have been made or challenges that we’ve run into when we come to engaging with companies on natural capital issues?

Pooja Daftary: We’ve actually seen some advances, especially with the great integrating companies. We’ve seen them improve on their deforestation commitments. That’s happened actually fairly recently. And we found that sometimes talking to them one on one, we can make a bit more progress than talking to them in a wide group of investors. Many of which — everybody has different priorities, different mandates, and they’re a lot more guarded when they’re speaking to a big group of investors than when maybe they’re talking to one investor, so I think both have a place, but I do think at this stage, just stepping in slowly, asking the right questions, asking for data, asking for disclosure rather than finger-pointing is the way to go because naming and shaming doesn’t get you very far. And it’s not going to solve the problem, and it just might just close a lot of doors.

Vish Hindocha: That’s really interesting, especially as we get going on this. Pooja, I know you are involved in some of these discussions that are industry level as well as obviously within MFS. I’m just curious, if you look forward 12 months — and you mentioned this right at the beginning of how much has changed in the last 12 around some of the policy regulation disclosure standards coming to the table — looking ahead 12 months, how do you think our attitude towards natural capital will change as the investment industry? Was the finance industry — do you have any thoughts or predictions, dangerous as they might be, in terms of how things might evolve from here?

Pooja Daftary: I expect it’ll become a lot more like climate, where it was hard to kind of take a view on climate, but now it’s so mainstream and I think the same should happen with nature. And I think we’ll all be a lot more educated and well-versed on some of these issues. And I also think that we would have seen some of those supply shocks and things play out. Many times when we are talking to companies we ask them about the sustainability of their commodity supply chains in the food sector. And without naming companies, they’d say, “Yeah, we think that our supply chains are incredibly resilient.”

I said, “Well, you’ve been having a lot of weather-related disruptions.” They said, “Yes, there are lots of one-off weather-related disruptions that keep happening.” So to me, if one-off disruptions keep happening, it’s no longer one-off. But I think you need to see a few of these events actually play out. And you have to see companies come under the spotlight, have some evidence to show how their businesses are being impacted, how markets are reacting and that the markets consider this to be financially material. We start seeing the bottom line impact in earnings, and suddenly it becomes a lot more mainstream. We saw it happen with plastics. With plastics you started seeing single-use plastic bans. You started seeing recycled content and feedstock be in incredibly short supply. And you started seeing capex and opex for feedstock procurement and packaging innovation go into the millions, tens to hundreds of millions. So once it starts hitting the bottom line, it’s not so much a sustainability conversation. It becomes more of a business operations conversation.

And I think eventually the same will happen with nature because there is mounting evidence that supply chains are going to come under pressure. Parts of the world where you could grow certain types of food, you may not be able to grow it anymore. So the chickens will come home to roost, and then we’ll have those conversations then.

Vish Hindocha: I couldn’t agree more. I think a couple of thoughts, to your mainstreaming of nature, that’s my prediction, my hope as well. In my role, I get to interface with clients from all around the world, and I definitely sense that the expectations that asset owners are placing on investment managers to just think about the value chain of our own industry for a second, the expectations are shifting. And our clients will increasingly expect us to have nature-related policies, be they specific on deforestation or water, maybe for now but maybe broader as the industry develops this thinking. And then you’ll start to see the flywheel move in terms of interest in this more broadly across the industry. And then as you say, as it comes home to roost, as those material risks and or opportunities start to really manifest, then it can also galvanize capital and start bringing things together.

Something you touched on we probably won’t address in this podcast, but we might maybe come back in future is policy and how policy evolves over the next 12 months. I think about the Inflation Reduction Act in the US, for example, or the EU Green Deal or what Singapore is legislating for around climate change and how much that has helped move things forward as a more progressive policy when it comes to addressing climate related risks and opportunities, both physical and transition. And I wonder what we’re going to see on policy, because even just thinking about your example of the desertification of West Africa and moving production across the world, that’s going to have almost just-transition type implications for these communities. What does it mean to have quality employment in that space but continue to invest regeneratively in agriculture on those often subsistence level economies that are really reliant on those farms? And so I think that’s actually going to catalyze policy that protects. And again, it’ll be really interesting to see how that starts to come out.

Pooja Daftary: I was just going to make a comment that the linkages between some of these environmental and social issues would also start becoming glaringly obvious. So when we talk about the case of West Africa and we talk about cocoa deforestation, it’s also one of the highest instances of child labor globally is in the cocoa supply chain. And a lot of it, both deforestation and child labor, are so deeply interlinked to the farm gate prices that cocoa farmers in West Africa are paid, which can be quite different from the fair trade prices, for example, that are set. And so really fixing things like pricing for example, and having more transparent pricing or getting that money into the hands of farmers could impact both. It would impact deforestation. It would impact child labor because both deforestation and child labor are ways for farmers to earn more margin, or squeeze more money out of what little resource they have, i.e., the land or labor, underpaid labor.

Vish Hindocha: Yeah, exactly. And I think if we, the royal We, do it in a smart way, you could end up solving both problems at the same time. Or if we don’t think about it, you might end up exacerbating one problem at the expense of another. One thing that you said earlier was in 12 months time maybe your hope and your prediction might be that we’ll all be better educated. I’m just curious, as someone that has spent some time in this space and maybe just to share with the audience, are there any resources that you’ve found particularly helpful? Or do you have any advice or guidance as many investors and many people in our industry are really getting just started in this space, where would you point them to in terms of a good place to start?

Pooja Daftary: I think there are a number of different frameworks. I think TNFD is one that’s a good one to start thinking about, especially if you’re going to talk to companies about improving disclosure. It’s already widely adopted from a climate perspective, so companies kind of know how to work it into their strategy, what the ask is. So I think there’s some transferability, scalability when it comes to nature-related risk. There’s a connection to climate. So I think that’s a good place to start. But there are lots of organizations. Like Ceres is doing good work on land use change, deforestation. AIGCC, which is the Asian Arm of the IGCC, they’re doing some really good work as well on deforestation, especially in Asia. So it’s hard to say that there’s one that’s better than the other. Each of these organizations have their own kind of niche they’re trying to carve out. I think the only thing that I would think about is, where does your firm find the most alignment based on your mandate?

And then try to identify the right organization to partner with. But in terms of doing diligence, the world’s really your oyster because there’s so much good information coming out and a lot of it is free, too.

Vish Hindocha: Yeah. Thank you, Pooja. That’s super helpful. Maybe the very last question for the listeners, anything that you would have them do next week? So any practical insights, takeaways for investors to start doing or thinking or any questions that you found really powerful when doing your work around natural capital?

Pooja Daftary: Yeah, so actually one great resource that I think is quite underused is: The CDP has forestry, water and climate surveys that they send out to companies, and many companies respond to it. And the surveys are very financially oriented, where they ask companies to actually size what percent of their revenues are dependent on different commodities that are considered deforestation risk commodities. Or what part of their operations are based in very heavily water stress areas. And then they ask them to price out what the financial impact could be in a three-, five- and ten-year time horizon if that risk is not mitigated. And they ask them to price out what is the cost of mitigating that risk? And that is extremely informative because you can start to put some numbers around what deforestation could cost them, or what physical risk from water stress or rising sea levels, how it could impact and hurt their business.

And it’s not something that shows up in their sustainability reports, but because the CDP questionnaire forces them to put numbers around it, however theoretical those numbers might be, there’s some thought that goes into putting those numbers together. It requires some amount of mapping across the organization. So I think those are just incredibly useful documents to look at. Not always the easiest to read, it’s a lot of text. But to be able to just even pull out a few important data points and compare those across companies, across sectors to me has been really valuable. And it’s just a really good way to have a conversation with a company because this is stuff they’ve already disclosed. So to go to them and say, “This is how you size the natural capital risk. And you said that 60% of your revenues are dependent on these three commodities, so can we talk about what you’re doing to make sure that you can keep using that commodity and do it at the same cost?”

Or how is a regulator going to impact it? So I think that would be — it’s a very basic approach. It’s not taking into account any crazy modeling or traceability tools and things. But it’s like, to me, thinking about — I guess like reading an annual report of a company when you’re just trying to understand what does the company do, how much money does it make, what does the balance sheet look like? It’s just a really good kind of back-to-basics approach. And it’s standardized because sustainability reports are so different, each company’s report is different. But this is a really good, standardized way to get through a lot of information quickly.

Vish Hindocha: That’s super valuable. Thank you so much for sharing that. It’s very generous of you, Pooja. You’ve been really generous with your time today, as well and your insight. So on behalf of everyone, thank you so much! And to our listeners, thank you for listening! If you have any comments, questions or things that you would like us to put to Pooja afterwards, please email us at allangles@MFS.com. Thank you very much.

Speaker 3: The views expressed are those of the speaker and are subject to change at any time. These views are for informational purposes only and should not be relied upon as a recommendation to purchase any security or as an offer of securities or investment advice. No forecast can be guaranteed. Past performance is no guarantee of future results.

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