Pointless rules and regulations hurt businesses, especially small companies, keeping them in the shadows and forcing them to stay small. There are several reasons for Sri Lanak’s thick red tape; including an outdated legal and regulatory framework, corruption, rent seeking and a general distrust of private capital.

In the latest in a series of discussions called Re:start21, a collabortion between economynext.com and the Friedrich Naumann Foundation Sri Lanka office, featured a panel of experts on the costs of red tape and how to fix it. Held in late 2021, the discussion was moderated by Imran Furkan.

It featured Shiran Fernando, the Chief Economist of the Ceylon Chamber of Commerce, Roshan Perera, Senior Research Fellow at the Advocata Institute, and Saliya Wickramasuriya, Acting Chairman of the Colombo Port City Economic Commission.

Imran Furkan started by asking Shiran Fernando about the key areas that need to be addressed to improve the investment climate. Excerpts of the conversation…

Shiran Fernando: There are official indicators such as the World Bank Ease of Doing Business. If you look at the history of it, we’ve been swinging from around No. 80 to 110 in the last 10-15 years. There have been issues across subcategories where we have fallen through. From a South Asian or Asian perspective, other countries have done much better. For example, India has given a lot of focus to it and done better, realizing how to advance in these indices through carefully crafted reform policies.

Looking at an index like the World Bank Ease of Doing Business, we see the subcategories of registering property, getting credit, paying taxes, trading across borders and enforcing contracts where Sri Lanka does worse than the overall ranking. If we were ranked 99 overall, we ranked 130 or 140, and even around 160, in some of these subcategories. This is what’s dragging our overall place down.

We fell behind other countries that have typically attracted FDI in the region, like Malaysia, Vietnam, Thailand and India. If you look at the comparative performance of Sri Lanka versus these countries, they are doing much better in most of these indices. Even with certain African and sub-Saharan countries, Sri Lanka doesn’t do too great in these four or five indicators mentioned. That’s where we’re dropping off.

Beyond the index, there are other things that matter for businesses, like paying taxes. With regard to the Deregulation Commission, the Chamber sent across submissions of the private sector from the members, in particular on taxation and how can we get rid of unnecessary documentation, for registration related to SVAT or tax clearance and certifications, and how those can be simplified.

When it comes to paying income taxes, RAMIS was introduced a few years back. But there are operational issues around it, which the private sector finds not conducive for the ease of doing business. It is not only about bringing in these systems, but also having them updated.

There are other areas like para tariffs, the Customs Act and National Single Window that the private sector has been talking about for the last 15 to 20 years. But we’ve seen very slow progress. That’s primarily why whether looking at the index or other factors, we’re stuck in the middle, compared to a lot of other countries, which are doing much better on deregulation.

How can Sri Lankan SMEs compete, from a global perspective? How can state-owned monopolies be tackled in a way that protects all stakeholders and brings about significant reforms that filter down to the rest of the economy?

Roshan Perera: Some state-owned enterprises are the largest commercial institutions operating in this country. Any inefficiencies generated in those sectors would feed into the rest of the economy. They operate either as monopolies or in an oligopolistic environment. This is because there are certain legal or regulatory, or technological or economic barriers to entry.

An industry that has been in the news recently is gas, where there are just two players in the market. One is a state entity but there’s also a private entity. You would expect that if there’s a private entity that would create more competition in the industry, it should be more efficient. Unfortunately, there are several factors that prevent it from being so, and one of it is price controls. This has led to severe market distortions. In recent times, we’ve seen the worst manifestation of these distortions in the form of shortages and queues.

However, these are only the seen costs. There are unseen costs, where because of price controls, companies are unwilling to make long-term investments as they aren’t sure if they’ll make an adequate return due to these controls. It therefore leads to under-investment. We’ve seen this in several other sectors as well, particularly in large utilities.

What’s missing in many of these sectors is good international class transparent regulations on how the rules should be applied

There are also barriers to entry in these sectors. To continue with the example of gas, it’s quite a capital intensive industry, in the sense that you need huge storage facilities. There are certain restrictions on setting up such facilities in the current environment, and this prevents new entrants from coming into the industry and developing a more competitive market.

If you have common storage facilities and allow other players into the market, that would make it more competitive and as a result, more efficient and keep prices down so that the consumer benefits. By bringing in more players, you can make it more competitive and have downward pressure on prices.

SOEs should be subject to more market competition, because that will lead to greater efficiencies, and improve service and performance. The classic example from a Sri Lankan context is the telecom industry. Because of privatization and deregulation, they allowed more entrants into the market. As a result, the sector became more efficient and responsive to consumer needs.

How can Sri Lanka reach the potential of where its FDI needs to be, and what steps need to be taken?

Saliya Wickramasuriya: The root cause of one of the aspects of the issue is the dominant government presence in the economy. This leads to government control or efforts to control certain sectors that leave those sectors open to influence and lobbying at certain government institutions and ministries. We can’t have our cake and eat it; we’ve got to let go of something.

In this case, control is what we need to let go of, because with control comes the ability to make mistakes. Take the policy of a given sector at a given time in any given government. Every government brings into being certain policies, but the challenge is taking those policies from what they are, which is the highest thinking of the government, to operationalization, which is a proper blend of debt and equity, and instruments of investment that requires good regulations.

What’s missing in many of these sectors is good international class transparent regulations on how the rules should be applied. This is what investors ultimately end up looking at. They look at how to get in, how to stay in, how to get out, their return on investment, how to commercialize this, how to mitigate this and how to seek recourse for this.

We have the right idea, a fabulous product, a fantastic combination of the virtual (trade agreements and market access mechanisms) and the physical – our location, which has been leveraged by our shipping and maritime logistics sector to a great extent. We are ranked number 22 or 23 in the world, in terms of container handling support. That’s not a small size of the pie. However, when the narrative is spun, we tend to leave it at the narrative and don’t support it with the structure required for investors to take a step.

This brings in a theory of marketing and sales, which is that you can increase the awareness of people about an opportunity, and you can do it successfully and globally. But in order to make somebody invest, which is to do what in the oil and gas sector is known as FID (final investment decision), there needs to be something called a compelling event. A compelling event drives that person to take the decision to go to the board and get the approvals required because Sri Lanka is the best place to be for them at that time. We haven’t been very good at identifying these compelling events.

The problem with that is compelling events change from person to person. So the necessity is we have to market ourselves broadly and seek proper investment to get inside the minds of each and every individual investor, understand what their pain points, business processes and revenue models are, and seek the compelling event within that structure.

If we can engage on a one-to-one basis with not more than 10 or 15 international investors who are in this area, as they’ve already taken the step to move outside their own jurisdiction, we can have that conversation more successfully.

Right now, we’re leaving those conversations to promoters and people in the private sector, which is not a bad thing. It’s just that the full weight of government influence to make something a success cannot be brought to bear. As a result, there’s a lot left up in the air and to somebody else to sort out, and grandfathering that could be done by the government that’s not getting done.

From an investor’s point of view, in an economy that is state dominated, they need the state to be speedy in action. If they perceive that the state is not speedy in action or is distancing themselves from the key questions or the hard questions, it’s not going to be very compelling to them. Over the years, we’ve succeeded in building ourselves a fantastic story to sell, but haven’t used the network that we have in place to sell it well enough.

When I was in the BOI, we cut down on broad-based scattergun roadshows and had dialogues with the existing investors to see what could be leveraged from their own networks, because one testimonial is worth a thousand printed words. From that point of view, we haven’t maintained a very strong focus on the individual business case for investors and in Sri Lanka’s case, the same applies for the Port City.

At the moment, we’re focusing on what we would call anchor investors. It’s a fantastic value proposition if put in the right sense, but an anchor investor will need a customized approach, and that customized approach in some ways overcomes many of the regulatory barriers and much of the red tape, as you call it. We need to learn there’s a difference between marketing the proposition and making the actual sale.

Roshan: We need to look at labour reforms, because the cost of hiring is very high, compared to other countries in the region. We are not a low-cost destination in that sense in terms of labour. Another area is infrastructure. In certain areas, we are very strong in terms of infrastructure but there are infrastructure gaps, which we need to address, particularly in terms of digital infrastructure. These are aspects we need to think about to be able to attract investment.

Shiran: Sri Lanka has historically banked on giving long tax holidays or trade tax incentives, but the investor is looking for more than that, which is policy consistency, so that they know what the path is at least for the next 10-15 years and beyond.

Historically, we’ve relied on giving tax incentives, haven’t really deregulated and sometimes, over-regulated certain markets. Usually, the trade-off has been on the tax side, which has had implications for the fiscal side as well. It’s difficult to unravel because there has to be some level of incentive or attraction for investors to come in; from their perspective, consistency is key.

Another aspect that investors are looking at, especially on the manufacturing side, is land; having land available where you can plug and play, without having underdeveloped land and an investor having to start from scratch.

When laws and regulations are convoluted, it opens the door for those who are interpreting those laws and regulations to enrich themselves. We are reaching a critical juncture in our development journey, so how do we tackle corruption in Sri Lanka?

Saliya: Making things easy for investors, and thereby simplifying the process of engagement and ironing out the pain points, is not something to be done lightly. There is the need for regulating and to regulate relevant parts of a business, so we can’t do away with regulations completely. Due diligence is a person who they say they are.

All those things are important. What is happening is a mixture of both. Regulations themselves are causing corruption, because of the rent seeking nature of many of the steps that are taken and the number of approvals required for everything. There is value in reducing the number of steps and pain points to get approvals, imposing deadlines and imposing if and/or no responses are heard by, and so on and so forth. This is fairly standard process in other parts of the world.

There’s also a case of corruption causing regulation. Because of the tendency of successive governments to strangle the mal-intents of 5%, they inhibit the expansion potential of 95%.

Sri Lanka has historically banked on giving long tax holidays or trade tax incentives, but the investor is looking for more than that, which is policy consistency

From that standpoint, we need to be a little smarter about how we deregulate. Margaret Thatcher did it extremely effectively in the UK in the 1980s; thousands upon thousands of obsolete statutory notices, acts and regulations were removed. But we should also be mindful that we don’t want to create another problem.

Let’s say we have good policy and regulation to support that policy, to drive it into operation equitably. What we often then tend to do is confuse things with numerous circulars and gazettes, which act in a spirit that is intended to address a different problem but affects everybody else. Simple examples can be given where a gazette issued for a particular purpose then puts a blanket dampener on any public sector official taking the initiative to do something in a different sector.

We must be mindful of not just the policy, but the regulations and sometimes ad hoc intervention in those policies by way of different circulars, because every single thing the government does sends a message, and that message goes to places we can’t control. If you’re looking at investment from the outside, we must be mindful of the messages we are sending.

Roshan: Since we’re looking for the government’s point of view, one area is transparency. There’s the open government initiative, which enables citizens to have greater oversight over the operations of government to strengthen accountability. The Right to Information Act was one major step in this process. But its implementation is key, because it’s not just having the act, but you also need to have that enabling environment to facilitate and make it implementable.

We need to encourage the use of technology in government, because that’s a powerful tool to combat corruption. It can help minimize human interaction. Another aspect is to enable the collection of information and data, which can be shared between institutions, and be made available to public scrutiny and improve accountability.

It’s not just technology. You need strong institutions that are able to implement these processes and procedures. You also need to give incentives to public officials to provide information accurately and in a timely way, so that people can use that information.

You need collaboration between sectors, not just government. When we talk about corruption, we only talk about government. But we need two hands to clap. The private sector needs to be involved, along with civil society and citizens. Corruption is not only within borders; we’re seeing it across international jurisdictions. You need collaboration between jurisdictions to be able to address corruption.

Shiran: There was a national procurement commission. Unfortunately, in its previous mode, it could only flag and couldn’t really act beyond that because it didn’t have powers with vested with it. That commission no longer exists. There isn’t a procedure, at least within government or in policy, to scrutinize procurement. We may need to bring back some of those measures; maybe some of them weren’t working fast enough, but at least they were able to highlight certain gaps.

On the other hand, some of the legislation has been there. For example, Sri Lanka was one of the first countries in the region to bring in digital signatures through the Electronic Transaction Act. But we’re not seeing too many institutions or the private sector making full use of it.

Those are the low-hanging fruit in terms of adoption, which can minimize the need for manual processes and thereby reduce corruption.

What are the biggest barriers to seamless trade in Sri Lanka and how can we tackle the barriers?

Roshan: For a country with such a small market in terms of size and per capita [income], trade has to play a major role in its growth strategy, and everybody has to focus on how to increase trade, particularly exports.

Although Sri Lanka was one of the first countries in South Asia to open its borders to trade and foreign direct investment, its trade openness index has fallen below most countries. This is something we need to address.

There are regulatory barriers. Verité did a detailed study particularly focusing on the agriculture sector. Some of the major issues that they identified cut across all exports.

One major issue exporters complain about is regulatory barriers, in terms of high tariff rates. Our tariff rates are high compared to other developing countries. Tariff rates are supposed to protect domestic industries, but if they’re too high, they become anti-competitive and affect our export industries. That is being seen now, particularly with the new import restrictions that have come in. These non-tariff barriers, where we’ve had across-the-board import restrictions, have had an adverse impact on exports.

There is a case-by-case basis, and you come back to red tape. For whatever the exporter needs to be removed, they have to go to Customs to get it done. There’s a lot of red tape involved there.

Currency and exchange rate policy is a regulatory barrier. It is a price control, since you’re controlling the price of foreign exchange. That has an anti-export bias. Basically, you are favouring imports versus exports by keeping your currency at a rate that is not the market rate as we see it. Those regulatory barriers need to be addressed very quickly. Unless we improve exports, at least in the long term, we won’t able to come out of this macro situation that we are in.

There are also procedural barriers. The recent Budget tried to address some of these by identifying that particularly for start-ups, there are difficulties in registering a business. These are aspects that need to be addressed across the board, not on a piecemeal basis. There has to be across-the-board identification of these barriers and then addressing those. But it’s a start, in terms of some of the aspects addressed in the Budget.

Lack of information is another barrier for exporters; you don’t know what exports are available. The Chambers provide information. But from the regulatory authorities, there is a lack of information. There is a Trade Information Portal, but is it updated regularly, and is all the information accurate and available? These aspects can be adjusted and considered low-hanging fruit; they don’t cost a lot of money but would have a huge impact on exports.

Shiran: We often talk about retail agreements and such, but before getting into that, you need to put your own house in order. The biggest issue our trade negotiators face is the multiple para tariffs that are in place. How do you phase them out without disrupting trade? Given the contribution of taxes to overall fiscal revenue, how do you do it in a smart way?

It’s a bit of a chicken and egg situation, because we want to add FTAs, with the likes of China and Bangladesh, but we also need to look at the trade components.

There are tools being developed. The Trade Information Portal is being used, and the Chamber, together with institutions, is conducting workshops in the regions to educate SME exporters that these facilities are available, to get the knowledge out there, how to use it, what to look for and get feedback from them on the information they are looking for.

The concept of a one-stop shop or single window facilitation is part mindset and thought process. If a particular stakeholder does not wish to take the problems of others and solve them, no amount of process will assist that

There’s a role that chambers like ours and the private sector can play in getting more use for these tools. You also have other market access tools. The EDB has a tool to market products, but that’s more on a B2B basis and on trading products. How can you get more use for them among SME exporters like in other countries which have SME export portals?

There are piecemeal measures, connecting the dots between the two, so that when you go to the negotiating table, for these FTAs or any other strategic tool, we know what we’re negotiating with and what the advantages will be for the country, without always coming back and facing a backlash when they are signed.

Saliya: In terms of the trade aspect of Sri Lanka, we’ve always been pivotal. It is said that in the old days, we connected Rome with the king. From that point of view, Sri Lanka has lived on trade since the Middle Ages. As a by-product of that activity, there have evolved certain things we don’t look at closely enough and certain things we look at too closely. One thing we look at too closely is the fear in any trade activity that there is leakage into the local market.

When you consider the size of the local market, with respect to the potential activity that is being traded, the efforts expended at addressing those issues spawn huge amounts of red tape, which disincentivise anybody from coming into this business in Sri Lanka at all.

We are pretty significant in the world of shipping and maritime services, but provide less than 1% or about half a percent of the world’s bunker fuel sales. With the captive customer base that the Port of Colombo has, the fact that we’re not selling more bunkers implies several things. There’ll be justification when you ask the industry about it. But what it means is people haven’t spent enough time focusing on proactive policy intervention to bring the market potential up to what the potential indicates it could be.

There are many different reasons for that, primarily, people protecting their own positions within the industry. There’ll be people who perceive interventions as geopolitically laden. But all it needs is a very clear, simple, transparent national policy on how the industry as a whole can increase. The activity of trading brings with it all sorts of other different aspects that don’t get a holistic look at.

How do we increase coordination, not just within government, but also public and private partnerships?

Saliya: The concept of a one-stop shop or single window facilitation is part mindset and thought process. If a particular stakeholder does not wish to take the problems of others and solve them, no amount of process will assist that.

Part of it is encouraging the business of a good customer-oriented attitude, which is something we have lost over the over the years, because a lot of facilitation can be done informally. When you get to the formal part of it, I will speak for the Port City Act and what it purports to do, which is the introduction of a formal single window facilitation by legislating that regulatory authorities have a physical presence in the Port City Commission premises.

Anybody coming there will be able to have the conversations required, to get the approvals required that the agency would otherwise demand of the project. That’s a good approach. It is yet to be tested, but will be very soon, because ultimately, that’s not the final solution. It’s a means to get mindsets to that point where all our public facing officials have that desire to participate in solving an investor’s problems. It’s a team effort.

You can legislate it, and have the customs, immigration and other offices sitting here. But that’s not really going to force them to do their job. It’s something that must exist in the hearts and minds of the people involved in attempting to do so. It’s easy to have all the power and still not be interested in helping. So we must encourage places where service has to be seen.

In my limited experience here in Sri Lanka, there have been three or four centres of excellence – periodic, they come and they go – and one of them is the driving license or DVLC. There was a time when it was an absolutely humming machine. The other one was the Pensions Department, which is still a very customer-oriented place of call. And the third is the ID and passport office.

That again, went up and then went down. But we have been through periods of greatness where institutions that are not even mandated or required to cooperate, collaborate and assist have done so because of the mindset that has been inculcated within them. To a great deal, it requires putting the right people in the right places and giving them the freedom to act.

When we delegate to officials the responsibility of taking a decision, we must recognize that those who delegate must be responsible for the decision. Delegating to a manager and then holding them responsible for whatever happens isn’t the desired management style; you’ve got to be the boss that empowers your people and stands by them. We find that lacking because individual institutions have so many levels of hierarchy that everyone needs to go up.

If you talk to Sri Lanka Customs, you will find that officers do not wish to engage even with officers in another branch, because that’s not their job. We have compartmentalized ourselves by effectively truncating accountability and responsibility.

In Port City, we plan to remove the obstacles for any transaction we can possibly think of by keeping transparency using technology to accomplish certain objectives, while still making it as painless an experienced as possible. It’s taking a little time to compose that product, but when it comes out, will offer a different customer experience than we would expect to have outside.

Roshan: The incentive structure is very important. Government officials have a tendency to fear that they’re going to either lose a job or not going to be as important when they give over some of the responsibilities. You have to change the incentive structure and they need to understand the overall objective. What are we really aiming at? Are we aiming at keeping our turf and keeping that within the departments, or is there a higher objective? That needs to be inculcated in the entire government service or sector. It’s not only in government but a mindset change.

Give the right incentives. It’s not about salary, because salary is only a small part. There are so many other incentives. We need to look at case studies to see how those particular institutions transformed from what they were to where they are now, and how government officials do that job or make that transformation. Those are some lessons that we need to learn from and try to replicate or make more ubiquitous across all departments.

Shiran: With the passport offices and a few other agencies, there is an incentive to the process in place. It’s keeping those functional and alive. Institutions need to be well-led. If you have a very charismatic leader that people buy into and believe, the change will happen. But beyond that, you might need an institution person to continue these practices. There’s focus on the public sector and the need to do better.

Even in the recent Budget, you saw a focus on reducing wastage. Part of that is coming through better coordination and giving more ownership to come up with better plans, better budgets, the way they spend, how they staff. Hopefully, that culture is created so that you don’t need a person particularly to keep those practices going in.

How can we tackle labour market reforms?

Shiran: It’s about the way these issues are brought up. For example, in the last Budget, the private sector retirement age was extended. There wasn’t a public policy debate or anything like that, but post it, everyone had a view. Finally, the bill was passed with a few provisions. So it’s the way these things are put out.

We can take an example from other countries. Countries like singapore have a trade net. Its trade openness is 320%. Korea has a very good portal, a single window concept, and its trade openness is much higher than ours

Maybe it shouldn’t be from these statements but rather, using frameworks like the National Labour Advisory Council, to force upon it. Right now, it’s a great opportunity because post-COVID especially for the service industry, some of these regulations are not even applicable.

We’re looking at a Labour Act which is so many years back. There aren’t provisions for parttime work, contract work; there are a lot of grey areas. Other countries are moving forward towards four-day weeks as well. But it’s a slow process to get there.

That is also the opportunity to get more women into the labour force, because the pandemic highlighted and spotlighted the impact it does have on families and females who are working in the labour force, and even males, because they’re at home and have to play a bigger role as well.

These laws need to keep up. An economic situation like this highlights the need for these tools, which are cross-cutting. If you look at education or labour, these now need to move forward.

Otherwise, investors will think of another particular country.

What has made Sri Lanka attract a lot of IT firms is the skills, not necessarily on the labour side. But if the labour side gets sorted, there’ll be opportunity and more people willing to come in. Things like shift work in the IT industry are taking place. But those provisions are not even in these acts governing it.

There’s lot of discussion, but a roadmap of how we can get to that needs to be established, without being pre-empted in a budget speech or some other statement, which then arouses everything, and a lot of noise comes in and the end objective is lost.

Roshan: With an ageing population, we need to be mindful and that you have this huge pool of labour that’s outside the labour force, which is the female labour. It was disappointing that the Budget didn’t discuss that or have too much to address it. Particularly given the experience we’ve had with the pandemic with school closures and lockdowns, we need to have thought about this much more closely.

We don’t have to reinvent the wheel; there are other countries that have done this before. We can learn from their experiences and see how we can engage this huge pool of labour that is outside the labour force.

There is also a huge pool of informal labour very badly affected due to the lockdowns and the pandemic. We need to see what kind of protection can be given. Just as much as we need to tackle some of these labour regulations, we need to see what safety nets are available, because informal workers can be out there if there’s a shock. Those aspects also need to be looked at when we’re looking at labour regulation.

Saliya: Reforms are necessary, because they’re an essential part of overhead costing in terms of project financing from an investment point of view. However, we have to be mindful that our labour market, the actual individual workers, suffer protection.

At the same time, looking at where things are in the current state of the economy, we lost a couple of chances to affect effective reforms. The conflict years were one perhaps, and the COVID period was another. I’m simply hoping that there won’t be a recession that gives us a third opportunity. But whatever it is needs to be done fairly quickly, because the longer it’s kept, the more political will that will be required.

Digitalization has been used by many countries to remove a lot of red tape and bring about transparency and so on. What are your views on how that can be applied to Sri Lanka? What are the key areas to focus on to get some quick wins and build further on this?

Shiran: We’ve be talking about this concept of digital ID for about 15-20 years. Initially, the issue was whether you need a physical card, and that whole procurement process took a long time. But now, a lot of countries have done it without anything physical.

If that can come in, it can be a game changer in the sense of how we collect taxes, and look at healthcare, trade taxes, and give out welfare and targeted relief whenever things like the pandemic emerge. In that sense, there is a big opportunity.

The best example is how India has done it with their digital ID and many other things have been built off this. If the government decides it wants to give relief to a particular region or wants to build something, it gets built, because cash transfer is made to a particular household. That’s a key tool, and the government has realized and is prioritizing it, but it needs to get to the end of it.

Roshan: Getting the single window facility at customs is a game changer. That will facilitate cross-border trade. That needs to be looked at for many reasons, basically transparency and corruption. There’s also the time and cost of compliance. Exporters or importers have to spend a lot of time to clear goods or get approvals. Exporters still have to submit documents in hardcopy form and not all agencies are linked.

We can take an example from other countries. Countries like Singapore have a trade net. Its trade openness is 320%. Korea has a very good portal, a single window concept, and its trade openness is much higher than ours. These are examples of how something simple could affect a change in the entire international trade in Sri Lanka.

Saliya: Essentially, where the world is going is, the more its able to individualize information in terms of the digital ID, the more it is able to individualize intervention.

People are being treated very specifically. Medicine is being administered. It’s bespoke treatment to individuals now. It doesn’t take much to assume that eventually, tax collection and incentive granting to people who have been outperformers or outliers in the field of providing solutions to their customers can be and must be the end result of any attempt to digitalize. Otherwise, it ends up being a weapon of Orwellian nature.

Knowing isn’t the message or the reason; it should be less the security part and more the service part that we can expect. But we must move away from paper.