Aley Moyer

The Californian 2022 Q3 – Bike Patrol: A Great Choice for Community Relations

BIKE PATROL: A GREAT CHOICE FOR COMMUNITY RELATIONS 

Ellen LeMasters, American Bike Patrol

From the benefits bike patrol has had on law enforcement, all the way down to the positive
environmental values bike patrol puts forth, one may instead ask why not bike patrol? Bike
patrol was first invented in the mid-to-late 1800s, starting with a very heavy iron and wood pedal
bicycle. The bike patrol industry has continued to grow ever since it developed into the modern
diamond frame safety bicycle. Because of the ease that comes along with integrating bike patrol
into a community, bike patrol offers a better way to protect and serve a community in the most
cost-friendly manner.

Did you know that bike patrols result in more than twice as many contacts with the public than
vehicle patrols? The novelty of a police officer on a bike creates an atmosphere where members
of a culturally diverse community can start overcoming any negative perceptions that may have
been placed upon law enforcement from prior encounters with patrol cars. A bicycle patrol
officer has been proven to be more easily approachable than a car patrol officer.

Even more than just their role in community relations, bike patrol units also generate faster
response times than patrol cars due to the mobility and stealth bicycles have to offer, especially
with the introduction of Patrol eBikes. Bike patrol units can fit and maneuver into areas that
patrol cars cannot, such as squeezing into small alleyways, riding right up to the doors of
buildings, and even going down stairwells. They are also way less obvious and easy to point out
than patrol cars, making it harder for criminals to notice them approaching.

Along with their impact on community relations and visibility, bike patrol is drastically more cost
effective and environmentally safe than patrol cars. A fully outfitted bike costs around $1500,
requires no gas, and is lower maintenance, while also providing a significantly lower carbon
intake than patrol cars. Even at an average cost of $2500 per bike, which includes bike training
and bike maintenance, a police or security department can put a team of approximately 15-20
officers on bicycles for the price of one patrol unit. Even further, bike patrol units provide a
physical health benefit for patrol officers who have to stay active during their entire shift as they
are constantly cycling throughout their communities.

At American Bike Patrol Service, we are dedicated to serving law enforcement by covering any
needs when it comes to bike patrol. With over 25 years in the industry, hundreds of officers
trained from police departments, security agencies, military and private corporations, we
continue to utilize the knowledge we have gained from our experiences and years of product
testing in order to ensure that all clients are receiving the finest products and services that align
with their specific budget and needs. We as a company strive to help ensure safety within
communities by offering law enforcement and security with the best bike patrol services they
can receive.

 

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Aley Moyer

The Californian 2022 Q3 – “Sit Down And Be Counted!” – Court Reiterates Duty To Provide Suitable Seating

“SIT DOWN AND BE COUNTED!” – Court Reiterates Duty To Provide Suitable Seating

Barry A. Bradley, Esq., Managing Partner, Bradley, Gmelich + Wellerstein, CALSAGA Legal Advisor

In California, an employee is entitled to use a seat while working if the nature of the work reasonably permits the use of a seat. An employer is required, in that circumstance, to provide the employee with a suitable seat.  

In the recently decided case of Meda vs. AutoZone, Inc., et. al. (7/19/2022), the California Court of Appeal reversed summary judgment in favor of the employer and sent the case back to the trial court level for trial on the issue of whether the employer “provided” suitable seating.  Although this case takes place in a retail store setting, the same rules apply to the security industry.

Facts:

Plaintiff and appellant Monica Meda (plaintiff) worked as a sales associate for about six months at an AutoZone auto parts store (store) operated by defendant and respondent AutoZoners, a Limited Liability Company (AutoZoners). After she resigned from her position, plaintiff filed a lawsuit alleging one claim under the California Labor Code Private Attorneys General Act of 2004 (Lab. Code, § 2699 et seq.) (PAGA). She asserted that AutoZoners failed to provide suitable seating to employees at the cashier and parts counter workstations, and that some or all of the required work could be performed while sitting.

About 40% of plaintiff’s duties were performed at the cashier’s station, another 40% at the parts counter, and the remainder around the floor.  Plaintiff asserted that her time at the cashier’s station could have been performed while seated on a stool, and about half of her work at the parts counter could, likewise, have been performed while seated.  

California Wage Orders:

As a refresher, the court stated that “’wage and hour claims are today governed by two complementary and occasionally overlapping sources of authority: the provisions of the Labor Code, enacted by the Legislature, and a series of 18 wage orders, adopted by the [Industrial Welfare Commission (IWC)].” [Citation.] The IWC, a state agency, was empowered to issue wage orders, which are legislative regulations specifying minimum requirements with respect to wages, hours, and working conditions.’ ” [citations omitted.]

Although this case addresses wage order No. 7, the identical requirement is listed in Wage Order No. 4, applicable to security guards.  Specifically, it states:

“14. SEATS 

(A) All working employees shall be provided with suitable seats when the nature of the work reasonably permits the use of seats. 

(B) When employees are not engaged in the active duties of their employment and the nature of the work requires standing, an adequate number of suitable seats shall be placed in reasonable proximity to the work area and employees shall be permitted to use such seats when it does not interfere with the performance of their duties.”

AutoZoners claimed that it satisfied the Wage Order requirement by providing two stools by the manager’s office, located around the corner (and out of sight) from the parts counter and the cashier stations.  Unfortunately, it did not provide any seating at these workstations nor did it advise any of the employees that they had a right to carry the stools to their workstations.  The court pointed out that even if the employees used the two stools, there were five to nine employees working at any given time, so there would have been a shortage if more than two wanted to use them at once.

Totality of the Job Duties:

Although the court did not focus on the issue as to whether an employer has an obligation to place a seat at every location (such as in an office setting where desks are located), it did provide some guidance. Citing to a Supreme Court decision, the court restated:  

“[W]hen evaluating whether the ‘nature of the work reasonably permits the use of seats,’ courts must examine subsets of an employee’s total tasks and duties by location, such as those performed at a cash register or a teller window, and consider whether it is feasible for an employee to perform each set of location-specific tasks while seated. Courts should look to the actual tasks performed, or reasonably expected to be performed, not to abstract characterizations, job titles, or descriptions that may or may not reflect the actual work performed. Tasks performed with more frequency or for a longer duration would be more germane to the seating inquiry than tasks performed briefly or infrequently.” (Kilby, supra, 63 Cal.4th at p. 18, 201 Cal.Rptr.3d 1, 368 P.3d 554.)

Result:

In reversing the summary judgment (which would have ended the case in favor of AutoZoners without the need for a trial), the court held:

“We conclude that where an employer has not expressly advised its employees that they may use a seat during their work and has not provided a seat at a workstation, the inquiry as to whether an employer has “provided” suitable seating may be fact-intensive and may involve a multitude of job-and workplace-specific factors.”

Lessons Learned For Security Employers:

In order to try to avoid PAGA or class action lawsuits based on suitable seating claims, employers should remember that each security post and assignment will be different and should be evaluated separately. Your employee handbook should make it clear that seats are available where the nature of the work would allow for their use. Employers should make the seats available where appropriate and notify employees of the same. This would satisfy the “providing suitable seating” requirement of the Wage Order according to this court. You can accomplish this analysis by incorporating suitable seating as part of your Post Site Survey performed at each of your accounts. 

Barry A. Bradley is the Managing Partner of Bradley, Gmelich & Wellerstein LLP located in Glendale, California, where he oversees the Employment and Business Teams at the firm.  A former Deputy District Attorney, Barry’s practice concentrates on representing business owners in employment, business and licensing issues, as well as defending litigated cases involving negligent security, employment and business related issues.  The firm acts as general counsel for many security companies in California.  Barry is a volunteer Legal Advisor to the California Association of Licensed Agencies, Guards, & Associates (CALSAGA), and multiple other non-profits.  

He has been conferred an AV-Preeminent Peer Rating by Martindale Hubbell, the highest rating attainable, and has been named a Southern California Super Lawyer for the past 16 consecutive years in the area of Business Litigation. Barry can be reached at bbradley@bgwlawyers.com / 818-243-5200.

About Bradley, Gmelich & Wellerstein LLP

Founded in 2000, Bradley, Gmelich & Wellerstein, LLP is dedicated to providing sound advice and exceptional results for our clients. Our twenty-five plus skilled, dedicated and diverse attorneys represent individuals and businesses of all sizes in a wide variety of business, employment law and litigation matters.  www.bgwlawyers.com.

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Aley Moyer

The Californian 2022 Q3 – TIPS FOR CHOOSING A SOFTWARE PARTNER

TIPS FOR CHOOSING A SOFTWARE PARTNER

Tony Unfried, CSA360

As companies grow or become acquired, they tend to change; whether it’s an increase in price, a  decrease in customer service, or both. It’s important to be aware of these changes because it affects  the quality of service you receive. As you navigate your relationships with trusted partners, we’ve found  some best practices that can help you assess whether your needs are being met: 

The company you choose provides consistent outstanding client services. This is the most important  asset a partner can provide. Do your users have access to knowledge base articles? Do their support  tickets get fast and efficient responses? Your team should be able to ask questions and be provided with  high-quality answers. 

Does the company know your business goals? Is your trusted partner checking in quarterly to connect  with stakeholders to learn how they can support your growth? Do they know exactly what tools you will  need further down the pipeline? Maintaining clear communication is key so your partner can launch  new services the moment your team is ready. 

They supply hands-on training. Being able to work through real time scenarios with a highly trained  implementation specialist can make all the difference in your onboarding experience. Being able to learn  the software by doing is the best way to retain training. In addition, it’s important to have a key team  member to hold that knowledge to train new staff and manage any turnover that may occur. 

Along with training through real time scenarios, having homework scenarios prior to the next training  can be equally as helpful. It provides a challenge to learning the software and allows the trainers to see  what needs more focus and if trainees are truly retaining the information.  

Leadership in innovation. In this competitive market, companies grow by staying innovative.  Introducing new features and benefits can help improve the status quo. Receiving these  communications via newsletter or email can give you access to new features, often without any  additional cost. 

Company transparency is everything. Is your partner following through with promises made to their  client base, to the employees, and to their product? As some companies grow, their transparency can  become opaque. They focus less on the quality of what they provide and more on the quantity of who  they can provide too. 

The security landscape is constantly changing with new challenges to be met. It’s now more important  than ever to vet your choices. Plan a meeting with potential partners to find out what they’re about and  be ready to make the switch if they can’t provide these key aspects. You want to choose someone who  can provide you with unwavering customer support- a White Glove Partnership. 

Tony Unfried, CEO of CSA360, holds a master’s degree in Public Affairs and Criminal Justice from Indiana University, where he graduated with honors. While enrolled in his master’s program, Tony worked for The TJX Companies, Inc., leading the region in loss prevention and moving the company toward technology use in Security. Tony went on to join the most significant security company in Indiana, managing more than 500 employees and 50 sites, including the Indiana Convention Center, Bankers Life Fieldhouse, and Ruoff Home Mortgage Music Center. Seeing a noticeable gap in technology use in the physical security sector, Tony created his first security software application, launched at the Super Bowl in 2012, and recognized twice for Excellence in Mobile Technology by Techpoint. Tony has also spoken on Tech in Physical Security on panels with ASIS and IAVM.

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Aley Moyer

The Californian 2022 Q3 – Best Practices for Intake and Onboarding

BEST PRACTICES FOR INTAKE AND ONBOARDING

Simplifying paperwork, avoiding liability, and more best practices for today’s hiring climate.

Nina “Nine” De Forge, Agency Relations Manager, TEAM Software by WorkWave

Between employment contracts, payroll and benefits forms, handbooks and standard operating procedure information, and emergency contact forms (to name a few), the onboarding process of a newly hired officer can be time consuming. Add into the mix the ongoing challenges of hidden turnover, where new hires leave during or soon after onboarding (or, never report for their first day of training), and your HR teams are bound to feel like they’re climbing an uphill battle.

The good news is there are some best practices your team can put in place to ease the process.

1. Simplify paperwork. Much like asking too many unnecessary questions during the hiring process can deter job candidates in a tight labor market, the sheer volume of onboarding paperwork can overwhelm your new hires. If you’re still collecting onboarding documentation manually, with managers collecting physical copies of documents in the field or via unsecured email processes, you’re well aware of just how hard it can be to finalize an employee’s paperwork prior to importing into their employee master file.

Automating onboarding processes speeds up the process, and reduces the number of errors that can occur during otherwise manual documentation and processing. (Plus, it gives you the option to securely store documentation digitally, so you don’t have to maintain countless filing cabinets.)

2. Use the most updated, necessary intake forms. Reducing the amount of paperwork your team needs to collect isn’t always an option, as certain documents are required by the government or corporate policies.

For example, the Equal Employment Opportunity Commission (EEOC) recently modified several standard forms to fully implement a nonbinary ‘X’ gender marker in addition to male and female indicators and an ‘Mx’ in the selection of prefixes. This change was made to help support nonbinary employees in the workplace. These forms are typically required of businesses with 100 or more employees (or federal contractors with at least 50 employees). Look for updates in your software solution to help support this change and decrease your company’s risk of liability. (For example, TEAM Software is already working on a user interface that will support the nonbinary gender marker in this format.)

3. Don’t forget about making onboarding easy on both sides. At TEAM’s recent annual client conference, a client said this, and it bears repeating: 

“Onboarding should be quick and easy. It has to be easy for the employee, so you can get them on the job and on the path towards retention, faster. But, it also has to be easy on the company.” 

Onboarding is an inherently complex task, with moving parts that involve not only HR, but finance, IT, operations and more. Add in typical security industry employee turnover percentages and amplified repercussions still being felt by the labor market, and this could very easily be a recipe for burnout. By establishing clear, concise processes, taking advantage of self-service options when you can, and leaning into automation, the administrative side of onboarding will reap the benefits of a streamlined workflow.

Nina De Forge joined the team in 2017 and is the Agency Relations Manager. Nina, also known as “9,” has been working with human resources, payroll and tax compliance since the 1980s and has a broad range of experience across each discipline. She is an active member of many industry organizations, including the IRS Information Reporting Advisory Committee and its Nationwide E-Filer’s National Focus Group, the Canadian Payroll Association, the Society for Human Resource Management and the International Association for Human Resource Information Management. She is a published author in the book American Payroll Association Basic Guide to Payroll. Outside of her career work, Nina is a hobby photographer.

 

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Aley Moyer

The Californian 2022 Q3 – Three Tips to Reduce Overtime, Now.

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THREE TIPS TO REDUCE OVERTIME, NOW. 

Plus: Things to keep in mind when dealing with overtime during a labor shortage.

Gail Tutt, TEAM Software by WorkWave

We’ve said it before and we’ll say it again: the best way to reduce overtime is to stop it before it starts. It’s a little cliché, especially when overtime (and, unfortunately, non-billable overtime) is an inherent part of the security industry. Still, there are several tactics you can use to get a handle on overtime and manage labor costs. 

1. Know your service-level agreements. This doesn’t just mean at the executive level. Because SLAs dictate the service standards and pricing obligations you’re required to deliver to your customers, it’s imperative that any employee who is involved in managing your company’s scheduling is well versed in bill and pay rates by contract. By ensuring understanding in all scheduling roles, you can prevent costly mistakes (like wage creep, which can occur in a variety of scenarios, but especially when officers are scheduled for overtime shifts outside of the scope of what’s budgeted per job.) 

By knowing your SLAs inside and out, your company is also setting up the foundation for best practices in job costing. With industry-specific software solutions to assist in the heavy lifting of tracking and analyzing job performance, you can see at a glance which jobs are lending themselves to your profit margins, and which are under performing.

2. Don’t forget about compliance. In some cases, there’s no way around scheduling overtime without compromising your compliance with state and federal labor law regulations and overtime rules. In our industry, there are compliance risks posed from misclassification, recordkeeping and other hour and wage-related activities that can turn your timekeeping and overtime tracking into a headache. Earlier this year, even, this entity reported a wage settlement (with waiting time penalties) due to an upheld ruling alleging an employer failed to include meal period premiums on wage statements. A different case in 2021 found the California Supreme Court upholding that employers are required to pay meal and rest break violation premiums at the same rate as when paying overtime. Translation: these costs add up quickly.

While many integrated workforce management solutions don’t track compliance for you, they do provide tools to more easily prove compliance. Look for feature sets which include things like time and attendance (including punch times), scheduling, regulation monitoring and reporting to gain well-rounded visibility into your compliance.  

3. Become friends with your data. This point is straightforward: dig into your data early on in your scheduling process. In available TEAM solutions, we recommend including criteria like parameter searches for available guards that fit within the bill rate specified per job. That way, your schedulers will only be able to assign officers to shifts whose rate fits the given budget (see our first point).

Often, we find companies can implement at least one of these tips to help prevent and improve overtime. But we also recognize that the current labor market throws a new wrench into the mix. When it’s hard to find officers to fill shifts in general, of course it becomes more likely for regular shifts to turn into overtime to stay on top of SLAs. While there’s no easy answer, it’s possible resolving this particular overtime challenge can be addressed by refocusing on retention.

Start by taking a few steps back to analyze what your voluntary separations look like. Are officers leaving for higher hourly rates or benefits? Or are they leaving for more flexibility in their schedules? Maybe they’re pivoting careers into adjacent industries or taking even bigger leaps into entirely new verticals. The common theme of all these scenarios is that it is likely not a separation on bad terms. This could be an opportunity to think outside the box in the form of a self-scheduling program. This way, employees stay in your employee management system (as part-time or ad hoc employees) and can pick up shifts based on when they want to work (even if they are employed elsewhere). While it may not work for everyone, it is an interesting tactic to reduce overtime needs while increasing employee retention.

It’s hard to theorize if there will ever be a world without overtime in some capacity. But, there are steps you can take to improve this metric now. See how at teamsoftware.com. 

Gail has spent over 35 years in the private sector as a senior level finance and operations manager across multiple industry. Most recently CFO of a regional security company in San Jose, CA, Gail now works providing invaluable insight and expertise as a business consultant with TEAM Software.  Her hobbies include breeding and showing standard wirehair dachshunds, hiking and spending time with her family.

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Aley Moyer

The Californian 2022 Q3 – What is Included and/or Excluded from Premium in a Workers Compensation Audit?

WHAT IS INCLUDED AND/OR EXCLUDED FROM PREMIUM IN A WORKERS COMPENSATION AUDIT?

Shaun Kelly, Tolman & Wiker, CALSAGA Preferred Broker

Hope all is well with everyone.

In my last article, we discussed why Workers Compensation auditors are requesting more information than they have in previous years. This is due to the passing of Assembly Bill 5 (AB-5), which redefines the guidelines of whether a worker is an independent contractor or not (The ABC test). Auditors are requesting additional financial information to determine if employers are using independent contractors.

In this article, we are providing information on what is included and/or excluded in determining your premium in a Workers Compensation audit. This will include information regarding some of the following:

  • Sick pay
  • Vacation Pay
  • Bonuses
  • Attendance at conferences
  • Automobile allowance
  • Employee benefits
  • Commuter compensation
  • Meals
  • On Call/Stand By pay
  • Uniform allowance
  • More

Please see the attached Payroll/Remuneration Table from the California Workers Compensation Uniform Statistical Rating Plan (Also known as the USRP).

The USRP is updated and approved by the California Insurance Commissioner periodically. You can find the complete USRP on the Workers Compensation Insurance Rating Bureau (WCIRB) website at wcirb.com under Filings and Plans.

If you have any questions, please feel free to contact me.

Take care and see you all at the CALSAGA Annual Conference.

Shaun Kelly joined Tolman & Wiker Insurance Services in 2005.  He specializes in all lines of property and casualty insurance for industries including contract security firms, agriculture, construction, oil and gas. Shaun received a BS in Business Administration with a major in Finance from California State University in Fresno, California. He is an active member of several industry associations, including the Association CALSAGA, the Kern County Builders Exchange and the Independent Insurance Agents of Kern County. Shaun can be reached at 661-616-4700 or skelly@tolmanandwiker.com.

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Aley Moyer

The Californian 2022 Q3 – Is Inflation to Blame for Rising Security Firm Insurance Premiums?

IS INFLATION TO BLAME FOR RISING SECURITY FIRM INSURANCE PREMIUMS?

Tory Brownyard, Brownyard Group

In California gas prices have risen above five dollars a gallon. Food banks are experiencing extraordinary demand. Mortgage rates, housing prices, residential rent and even home repair and replacement costs are soaring. For many Americans, this historic rate of inflation has become real, unprecedented and problematic. As consumers feel the brunt of inflation, its impact also spans various industries throughout the U.S. For the private security insurance industry, the market continues to harden, due to both inflation and other factors.  

While a major contributor, however, inflation is just one factor making it more challenging for security firms to secure the insurance they need to mitigate their risk exposure, and of course, meet required insurance obligations featured in every service contract.

Extreme Loss and a Rise in Crime

Inflation aside, many insurance carriers assess the risk and associated cost of premiums based on the history of loss in the industry as well as the individual organization’s claims history and operational practices.

One tragic example of an operational impact includes the May 2022 Securitas Security Services $517.5 million settlement paid to the victims of the June 24, 2021 partial collapse of Champlain Towers in Miami. Among the determining factors for Securitas paying nearly half of the more than $1 billion settlement included the failure of the security guard on duty in activating the building’s alarm system to signal an emergency evacuation. In a deposition, the company’s manager acknowledged a lack of training contributed to the system not being used despite the guard on duty calling 911 approximately 10 minutes before the structure failed, killing 98 people. 

Multi-million-dollar settlements like that of Securitas will have major ripple effects across the security industry for years to come.

Other examples include the recent spike in active shooter situations, including the devastating incident in Uvalde, TX and the Fourth of July shooting in Highland Park, IL. In addition to the tragic loss of life, more than 300 mass shootings have occurred by the mid-point of the year, putting 2022 on track to meet or surpass the record 700 shootings in 2021 or the previous record of 611 shootings in 2020. In many, but not all such mass shooting incidents, private security firms face the public’s wrath, legal inquiries and countless lawsuits. The resulting litigation often produces what many term nuclear verdicts handed down by the courts, loosely defined as exceptionally high jury awards that exceed what most would consider reasonable.

Large jury awards against security firms can often be traced back to failures in training, client screening, contract language and communication. So, while inflation is certainly a factor, there are other circumstances within the control of the industry itself to limit its own risk and exposure.

Managing Risk

Steps security firms can take to reduce their exposure and slow or mitigate the rise in their premiums include:

  •         Carefully selecting clients: As the shootings in Uvalde, Buffalo, Highland Park and Biloxi — among others — have taught us, active shooter or violent situations can occur anywhere, among anyone at any time. However, when it comes to underwriting the security industry, insurers will often look closely at the types of clients the firm takes on. Those who take on high-risk clients, those with more public exposure such as bars and nightclubs, shopping malls and sport or concert venues, will often give insurers pause. If an insurer does cover a security firm with such clients, the premium is sure to be much higher than those who take on low-risk clients. Low-risk clients are those with less public exposure, including warehouses, office buildings and industrial type clients.
  •         Mitigating liability: To minimize risks, a security firm should always speak with their insurance partner before taking on a new contract. The insurance partner can help advise on what to avoid and can ensure proper coverage is obtained to best meet the firm’s needs and client types. Firms should also consider their policy limits when taking on new clients and make necessary adjustments in consultation with their agent or broker. High-risk clients can often demand higher limits of liability, and excess and umbrella policies can provide needed coverage beyond the scope of the original policy.
  •         Reading the fine print: Security firms should also consider contractual language carefully before taking on new clients. Ensuring their guards are only liable for their own negligence and wrong doing is critical. Also, it is recommended that clear and concise expectations for all parties are written into the contract. This can help avoid costly lawsuits and needless blame.
  •         Prioritizing training and communication: California state law requires 32 hours of training to acquire a security license, and eight hours of training each subsequent year to maintain the license. While this training provides guards with the tools and knowledge to perform their duties to industry standards, additional training for de-escalation, the dangers of restraints, active shooter or other situations is also recommended. Regularly revisiting and updating such training is vitally important. However, even the best training can fall short in an emergency. Clear communication protocols for security guards to seek and receive updated instructions can make the difference between managing a crisis or facing unfortunate and avoidable consequences. When all else fails, security guards should be able to rely on universally understood and transparent orders and expectations established within the signed contract.

Staffing and resource limitations among local law enforcement along with rising crime in certain localities will continue to drive the need for more private security by event and property managers, among others. Increased demand, paired with higher risk security situations, directly affects the rise in insurance premiums for private security firms. This rise of risk and premiums will continue to contribute to insurers being much more selective in the types of security firms they are willing to cover. Working with their insurance agents and brokers, security firm leaders can play an active role in minimizing their risk to avoid major losses and secure reasonable coverage to allow them to keep both their clients and their businesses safe.

Tory Brownyard, CPCU, is president of Brownyard Group, an insurance program administrator with specialty programs for select industry groups. In addition to his responsibilities as president, he currently spearheads the Brownguard® security guard insurance program.

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