Transcription complète de The Creative Truth, with Steve Mayer

think if you're sort of entrepreneurial, you have a creative mindset and you think out of the box and you don't accept this is that and that's why, you can you can do a lot. 00:06:01.279 --> 00:06:12.800 And there's a great many ideas that have never come to fruition through a lack of business acumen or the ability to promote them. 00:06:12.959 --> 00:06:23.920 And we were taking old science and and actually proven science and actually tweaking it and then looking at it from a different perspective, saying, How can we fit this into that? 00:06:24.000 --> 00:06:25.600 And how can we do this and that? 00:06:25.759 --> 00:06:29.439 And and and and that became it becomes very challenging and very interesting. 00:06:29.519 --> 00:06:40.399 And you sort of you're sitting there, you know, people look at you strangely because you've just got a blank look on your face, but you're deconforced about all these things you've read, and you come up with these ideas. 00:06:40.639 --> 00:06:45.839 And and as a team, we sort of discuss them and we we get excited by them. 00:06:46.000 --> 00:07:07.439 So that's really how we sort of got into it, and then we sort of moved into seagrass meadows and how we could develop those as a uh as an economic force as a carbon sink and actually uh provide uh a human capital as well, and you know, implanting and creating uh environments around them. 00:07:07.600 --> 00:07:11.600 So that's sort of how it all could have developed out a few years ago. 00:07:11.680 --> 00:07:16.560 And we've been plodding away at that, making proposals to different governments. 00:07:16.800 --> 00:07:28.480 Uh one of the biggest problems with seagrass meadows and even mangrove installations is that the coastline and the seabed is generally government controlled, and there's a great deal of red paint that goes along with that. 00:07:32.399 --> 00:07:41.040 And unfortunately, most governments, regardless of their public-facing comments, are really working on election cycles. 00:07:41.279 --> 00:07:54.879 So if they're concerned about a four-year election and a seagrass meadow doesn't really come to fruition and produce a financial award until say year seven to ten, they're not really that interested. 00:07:55.120 --> 00:07:58.560 Publicly they are, privately, we've seen a different face. 00:07:58.959 --> 00:08:01.120 So yeah, it's been a bit of a challenge. 00:08:01.439 --> 00:08:02.240 So long question, Steve. 00:08:02.480 --> 00:08:12.480 I mean, before we get into eco-apraise, I want to talk about that, but just for anybody who hasn't encountered blue carbon, because given the fact that we're a sustainability podcast, we hope all of everybody has. 00:08:12.959 --> 00:08:18.800 Of course they have, but people will know about tree planting to offset carbon offsets. 00:08:18.879 --> 00:08:31.759 But blue carbon is the sort of seagrass, mangroves, that portfolio of nature-based solutions that in many cases they absorb carbon at a much higher level, don't they, than planting trees, for example? 00:08:32.240 --> 00:08:33.120 Absolutely. 00:08:33.279 --> 00:08:40.720 The the questation rate in mangroves can be ten times greater than that of a chest field forest. 00:08:41.200 --> 00:08:44.879 So it it it's a significant carbon sink. 00:08:45.120 --> 00:08:48.159 And they store the carbon for a millennia. 00:08:48.399 --> 00:09:01.200 Where uh the conventional tree, for example, i is like a lung and it breathes in and breathes out and dispels carbon, which most people don't seem to know, every 40 or 50 years. 00:09:01.360 --> 00:09:11.039 So it's sort of breathing in and breathing out, whereas the mangrove and the seagrass are carbon thinks, and they could literally draw it into the root structure. 00:09:11.279 --> 00:09:30.240 So it's uh it's quite exciting in terms of the opportunity, and it's part of looking at how nature has created all of these amazing kinnadies that work together in unison to combat all of the problems we have. 00:09:30.320 --> 00:09:40.480 And and unfortunately, people aren't aware or they're not focused on them, and then you know, it's not as sexy as planting a tree for a dollar, and you know that kind of thing. 00:09:40.559 --> 00:09:42.399 So yeah, yeah, yeah, yeah, exactly. 00:09:42.639 --> 00:09:46.799 Well, for the record, Steve, I think blue carbon is sexy. 00:09:46.879 --> 00:09:48.480 So let's just get that out of the way. 00:09:48.879 --> 00:09:51.440 Yes, and we sexy, hugely frustrated. 00:09:53.360 --> 00:10:08.159 So let's let's get on to eco-apraise, because that's that's gonna be really uh really pertinent uh to certainly the work that we our network of agencies do, because we are involved in loads of green claims campaigns and and loads of ESG type reporting. 00:10:08.399 --> 00:10:21.360 So so before we talk about this tool that you're developing, that you've developed and have that you've developed, and on your website for it, there's a really cool headline that says Truth in Environmental Claims, the New Reality. 00:10:21.440 --> 00:10:28.399 And before we d delve into it, and because you're using tech and AI to look at it, what how do you feel? 00:10:28.480 --> 00:10:36.320 Where where are we in this era of truth being told in a post-truth age that's sort of breaking out in the comms space? 00:10:36.480 --> 00:10:39.759 What do you feel about sort of even the idea of truth at the moment? 00:10:39.919 --> 00:10:44.000 Because it's really troubled, it's really tricky territory to work with in, isn't it? 00:10:44.639 --> 00:10:55.840 Well, I mean, that that's the interesting thing, and this is why we feel it very timely, because I think we're entering an era where truth has to be operational, not just moral. 00:10:56.080 --> 00:11:06.080 The post-truth vibe still exists, but regulators and consumers are raising the cost of vague or inflated claims. 00:11:06.399 --> 00:11:16.000 So the new reality is you can still tell ambitious sustainability stories, but

you need proof, boundaries, and precision. 00:11:16.240 --> 00:11:23.039 And in the last couple of years there's been tremendous legislation or enforcement action. 00:11:26.799 --> 00:11:29.440 The significant penalties and fine. 00:11:29.759 --> 00:11:36.240 And this is redating the environmental and public relations people. 00:11:36.320 --> 00:11:54.159 We're getting more and more requests for reviews of documents because a lot of these people aren't genuinely trying to mislead, but it's become part of a uh a a game where if they're not misleading, they're being hushed. 00:11:54.720 --> 00:12:11.600 So uh you know, i they they want to still show they're in the game, but they they they're they're fearful of the regulators, and the the the reality of that uh in the UK can be as much as a ten percent fine of your global turnover. 00:12:11.919 --> 00:12:14.559 This is a significant um hammer. 00:12:14.799 --> 00:12:25.600 And the these these these these new rules, I mean uh the the EU uh commented in September of 2026. 00:12:26.399 --> 00:12:30.720 India is incredibly active right now. 00:12:30.960 --> 00:12:44.320 They had a a new guideline finalized in October 24, and they're they're issuing heavy penalties, and even in extreme cases, there's the the threat of criminal prosecution. 00:12:44.639 --> 00:12:52.879 So, you know, Canada also this year do finalize their private right of action. 00:12:53.120 --> 00:13:02.480 So there's there's a lot of a lot of jurisdictions that are coming in to say, look, we're not happy about this, we're not gonna put up with this, we need change. 00:13:03.120 --> 00:13:08.080 And I guess that's consumer-driven, because there's a lot of people out there that are actually asking questions. 00:13:08.320 --> 00:13:09.360 Thank goodness. 00:13:09.600 --> 00:13:12.240 You know, who would say, you know, what does that mean? 00:13:12.320 --> 00:13:16.320 You see a leaf on a box and it says 100% recyclable. 00:13:16.639 --> 00:13:17.679 What does that mean? 00:13:17.840 --> 00:13:23.440 Or or fully sustainable or recycled, or and and people really don't know what they mean. 00:13:23.600 --> 00:13:27.360 And in a lot of cases, they don't mean very much. 00:13:27.759 --> 00:13:37.600 So we do need regulation, and I'm delighted to see it coming in to actually clear the wood from the trees so we actually get truth. 00:13:37.759 --> 00:13:38.960 And that's all this is about. 00:13:39.039 --> 00:13:53.840 We're not trying to at least think we're trying to give people a an opportunity to tell their story in a truthful, uh clear, concise way, and that's how eco-appraiser was born. 00:13:54.080 --> 00:14:00.559 We were we were seeing so many false claims and and people weren't paying attention to them. 00:14:00.720 --> 00:14:06.799 We would even tell people, look, you know, this is technically no good, and they weren't that interested. 00:14:06.879 --> 00:14:13.200 And then because of the regulations that are developing and introduced, suddenly people are paying attention. 00:14:13.279 --> 00:14:14.799 And that's very encouraging. 00:14:14.879 --> 00:14:25.919 I I feel uh I'm really happy to see that we're gonna we're cleaning up, you know, for 20 years the sustainability industry has gone a little bit berserted, a bit a bit like the Wild West. 00:14:26.639 --> 00:14:34.240 If you can speak uh uh if you can articulate well and if you can write well, then hey, have access. 00:14:34.720 --> 00:14:44.159 Before working in the sustainability area, we have worked in heavily regulated communication spaces like pharma, for example. 00:14:44.399 --> 00:14:49.519 So can we ask the question around creativity versus safety? 00:14:49.759 --> 00:14:52.559 Do you think there is a dilemma here? 00:14:53.039 --> 00:15:06.879 Well, I mean, if we define creativity as exaggeration, I mean how you know the real creative challenge is to say something compelling that's also defensible. 00:15:07.440 --> 00:15:12.480 I mean, as you mentioned in Pharma, you learn the discipline early. 00:15:12.799 --> 00:15:15.279 Sustainability is heading that way. 00:15:16.399 --> 00:15:21.840 The best teams treat compliance as a creative grief and not a constraint. 00:15:22.159 --> 00:15:37.279 So I I I think uh I I I believe that the the the quality players in the in in the game actually celebrate it and and and don't see it as a constraint. 00:15:37.519 --> 00:15:42.639 Because if we have a level playing field, uh we're we're all better off. 00:15:43.279 --> 00:15:43.600 Yeah. 00:15:43.759 --> 00:15:46.320 And so so tell us a bit more about the actual methodology. 00:15:46.480 --> 00:15:55.279 So you're you you convert statements that are made into a sort of defensible naught to zero, zero to a hundred credibility score, don't you? 00:15:55.360 --> 00:15:58.000 So t talk us through how eco-apraise works. 00:15:58.960 --> 00:16:03.840 Well, we score based on clarity, evidence, scope, and risk figures. 00:16:04.799 --> 00:16:20.799 We look for measurable claims, define boundaries, uh accessible substantiation, we flag common danger zones like planet-friendly, net zero, uh or vague uh sustainable claims that are unsupported. 00:16:21.120 --> 00:16:26.960 Then we give paper rewrites so teams can keep the message but reduce exposure. 00:16:30.000 --> 00:16:37.600 It's a risk-based credibility read, not a legal verdict, but it's designed to help com teams ship with confidence. 00:16:37.679 --> 00:16:39.840 I mean that's that that's our goal. 00:16:40.480 --> 00:16:59.600 It is AI as you said, but we uh unless you've got teenage kids, but if you raise teenagers, you you know, I liken AI to a teenager, it's a bit wilk, not always honest, and a bit defiant. 00:16:59.919 --> 00:17:11.759 And so while we were developing this, we realized very early, and we were the early days of AI, that you had to be incredibly careful with AI because it it's not consistent. 00:17:11.920 --> 00:17:19.359 Like a teenager, you

know, it'll tell you it's done its homework and it happens, you know, and you're like, but you said you had, and it's like, well, you know. 00:17:19.680 --> 00:17:34.400 So we we we developed a rubric as our scoring method and an algorithm as guardrail so that our scans are consistent, reliable, up to date. 00:17:34.720 --> 00:17:37.119 We update those every week. 00:17:37.440 --> 00:17:42.559 We cross-check against uh legislation, well uh not legislation, I'm sorry. 00:17:42.720 --> 00:17:52.960 We cross-check against recent litigation to see whether any new caveats have come in based on you know common law evolution through case law. 00:17:53.119 --> 00:18:05.920 And and so we update very consistently and we daily check what our AI is saying to make sure at some point that it's not just like, okay, here's your AI, have at it. 00:18:06.079 --> 00:18:12.960 We we're very we're very careful that we, you know, that we we know how teenagers can be. 00:18:13.200 --> 00:18:17.200 So we we we we want to raise a good kid, if you like. 00:18:17.519 --> 00:18:18.480 Oh, that's amazing. 00:18:18.640 --> 00:18:22.400 I've you know, that is one of the best analogies for AI I've heard for ages. 00:18:22.480 --> 00:18:33.839 And I do have I do have teenagers in the house, so I'm now gonna see them as you know, are sort of downloaded in the house, in the snug, large language model teenager. 00:18:34.160 --> 00:18:41.119 So greenwashing is a huge trap in sustainability communications, but another one is green hushing. 00:18:41.599 --> 00:18:48.880 Sometimes brands and institutions are so afraid to make a mistake, they fall into a complete silence. 00:18:49.119 --> 00:18:53.599 So, can a coi praise also ease that fear a little bit? 00:18:54.079 --> 00:18:55.279 Well, and that's the goal. 00:18:55.359 --> 00:18:56.880 We're like a QA level. 00:18:56.960 --> 00:19:05.519 Uh the our goal isn't to scare brands into silence, because that stocks been evolving and trying, and that's how we grow. 00:19:05.680 --> 00:19:09.359 So we want to give them a safe route to communicate. 00:19:10.640 --> 00:19:17.119 When you can pressure test wording and tighten evidence, you're far less likely to overcorrect into saying nothing. 00:19:17.279 --> 00:19:24.160 So yeah, i i we feel that it actually helps people get the message out there in a much safer way. 00:19:24.400 --> 00:19:34.000 And, you know, like our teenage kids, we want them to go down the street safely and and not zigzag across the road and get run over by a car. 00:19:34.079 --> 00:19:36.480 You know, this is that's basically what we're doing. 00:19:36.880 --> 00:19:37.519 Absolutely. 00:19:37.759 --> 00:19:42.480 So before we I mean, I want to ask about sort of which market you're reaching out to, and I think it's really interesting. 00:19:42.720 --> 00:19:53.039 Also, I mean, I I think the EU is in a fascinating space at this moment because politically the EU's been a little bit fluid in terms of bringing some of these regulations in. 00:19:53.119 --> 00:19:58.079 And and you know, some regulation recently has been pushed back at the as part of the Green New Deal in the EU. 00:19:58.319 --> 00:19:59.839 So it's an interesting marketplace for you to work. 00:20:00.160 --> 00:20:01.200 But we'll come back to that in a minute. 00:20:01.440 --> 00:20:08.319 Before we do that, you mentioned there sort of updating your criteria according to new claims that you are coming across. 00:20:08.400 --> 00:20:12.720 And I just wonder whether I've got a particular one I really hate at the moment. 00:20:12.880 --> 00:20:15.920 Can I do you mind if I unburden myself and and tell me? 00:20:16.799 --> 00:20:19.359 So made from ocean plastic. 00:20:19.599 --> 00:20:23.039 I mean what's wrong with people? 00:20:23.200 --> 00:20:26.559 It's like, you know, it's like I see it all the time at the moment. 00:20:26.640 --> 00:20:35.039 And obviously the criteria is it's waste, it's plastic that might have ended up in the ocean if it hasn't been recycled. 00:20:35.200 --> 00:20:37.680 It's just are there any ones that really bug you? 00:20:37.839 --> 00:20:39.279 That's one my that's my worst. 00:20:39.759 --> 00:20:53.680 You know, I I I the the the ones that really get me are the ones that sort of stick the leaf on boxes and products and and and put eco-friendly. 00:20:53.839 --> 00:21:00.240 That's uh that really bothers me because it's unsubstantiated, unverified in any way. 00:21:00.400 --> 00:21:02.559 And these are big companies, some of them. 00:21:02.960 --> 00:21:08.799 And and they're they're they're they're selling emotions, you know, they're trading off people's emotions. 00:21:09.039 --> 00:21:17.279 People that do care and do want to make a difference, and they're drawn to those products because of that symbolism, and it simply isn't true. 00:21:17.440 --> 00:21:25.680 And I was having a conversation with a buddy of mine the other day, and he said, you know, you know, since we talked, I started to look around and think, well, what does that mean? 00:21:25.920 --> 00:21:27.599 Because people don't question it. 00:21:27.680 --> 00:21:33.839 They don't they don't automatically say, Well, what does eco-friendly mean and good for the planet mean? 00:21:34.000 --> 00:21:37.200 And I remember, do you know that British TV show AdPap? 00:21:37.759 --> 00:21:38.799 Oh yeah, yeah, yeah, yeah. 00:21:39.599 --> 00:21:44.240 I remember years ago watching a scene from there that's always stuck with me. 00:21:44.480 --> 00:21:54.480 The mother says to the daughter, she's selling her these plastic glasses, awful things, and they come in a bag that said kind to trees. 00:21:54.640 --> 00:21:57.519 And the mother said to the daughter, now how about that? 00:21:57.680 --> 00:21:59.200 And it says, kind to trees. 00:21:59.279 --> 00:22:01.599 And the daughter says, How is it kind to trees? 00:22:01.759 --> 00:22:04.880 And the mother says, Well, it ain't made of wood, is it? 00:22:05.119

--> 00:22:07.839 But this is kind of the the the crazy. 00:22:08.000 --> 00:22:09.039 Did you get that? 00:22:09.440 --> 00:22:10.000 Yep. 00:22:10.480 --> 00:22:10.960 Yeah. 00:22:11.200 --> 00:22:22.400 So this is the kind of craziness that we see that that isn't just simple it's just simply nonsense, but it really is as nonsensical as that. 00:22:22.640 --> 00:22:25.440 Yeah, no, like big bottles from the ocean. 00:22:25.839 --> 00:22:26.799 I know it's absolutely madness. 00:22:27.200 --> 00:22:30.079 The logo version I really hate because there's loads of them. 00:22:30.240 --> 00:22:46.079 And the one I really hate is when it's a sort of made of a round with the two hands cupping the the earth as a kind of eco-logo, and it's like, oh that that that's the zip-art thing that you can get for free everywhere. 00:22:47.440 --> 00:22:48.559 Just slap it on. 00:22:48.720 --> 00:22:49.680 Oh, that would great. 00:22:49.920 --> 00:22:51.039 So exactly. 00:22:51.599 --> 00:22:59.359 The uh so, in terms of the markets that you reach, so currently you're operating EU, India, UK, US, and Canada at the moment. 00:22:59.440 --> 00:23:08.079 So, do you see any common themes emerging when you look at sustainability communications, the claims that people are making across those borders and cultures? 00:23:08.160 --> 00:23:12.880 What are the what what are the kind of stories that people are telling at the moment that you come across? 00:23:13.440 --> 00:23:16.720 I could also add that we also cover Australia and New Zealand. 00:23:16.799 --> 00:23:22.400 So Canada, Australia, New Zealand, India, UK, US, and EU. 00:23:22.720 --> 00:23:28.000 So those are the uh markets that we currently have baked into our system. 00:23:28.799 --> 00:23:41.200 What one of the interesting things you'll probably find about what we've or the data that we've come up with is that India is one of our biggest customers. 00:23:41.759 --> 00:23:45.599 It it surpasses the EU, the UK. 00:23:46.559 --> 00:23:47.759 It's quite incredible. 00:23:47.920 --> 00:23:52.559 We we get more interest from India than we do from every other jurisdiction. 00:23:52.799 --> 00:23:59.759 And and there that may be because their enforcement is becoming very, very aggressive. 00:24:00.000 --> 00:24:13.279 And and so they're since October 2024, I think it was, heavy fines and even potential imprisonment for repeat offenders who are deemed criminally minded. 00:24:13.440 --> 00:24:18.559 So there's really severe consequences, and it seems to be making a difference. 00:24:18.720 --> 00:24:32.720 But I think it might also be, and we we debate this, that in in India you have the cities where the air is so poor, the quality of air is so poor that they're really feeling these things uh first hand. 00:24:33.359 --> 00:24:42.240 And when you really live a climate nightmare, if you like, on a daily basis, you do start to pay a lot more attention. 00:24:42.400 --> 00:24:52.640 And even though we have extreme temperatures in Europe and the UK, and we have flooding and we have different weather events, they're not as extreme as they're experiencing. 00:24:52.799 --> 00:24:56.799 So I think that and that'd be part of what drives drives them. 00:24:56.880 --> 00:25:00.880 And I'm sorry, I forgot what your original question was, and I don't think I answered it. 00:25:01.759 --> 00:25:09.759 No, well, I was just I was just asking about because you work across all these different jurisdictions and it's and I guess it was really interesting for you. 00:25:10.079 --> 00:25:27.680 You have the unique opportunity to look at whether there's any commonality of the kind of claims that people are making, and for whether it be New Zealand right away through to India, you know, whether whether you're seeing new came claims coming up or whether they're changing a little bit, and uh if there's any commonality across all those territories. 00:25:28.799 --> 00:25:30.480 There's a lot of commonality. 00:25:31.839 --> 00:25:38.480 Different jurisdictions are picking different things, but they all seem to be funneling into the same area. 00:25:38.960 --> 00:25:49.119 Currently, recyclability of packaging and and claims of recyclable are very popular in just about all the jurisdictions. 00:25:50.079 --> 00:25:57.519 Canada took, I think, two or four over a claim of recyclable pods, which was technically true. 00:25:57.599 --> 00:26:00.559 They were recyclable, but the facilities didn't exist. 00:26:01.200 --> 00:26:11.839 So if the facilities only exist in major hubs and it's only fifteen percent of your market, then they said they were it was a deceptive advertising crack. 00:26:12.240 --> 00:26:26.160 So we're we're seeing this sort of like deeper look into uh these claims in a way that you don't necessarily expect because if it is recyclable, well it's recyclable. 00:26:26.319 --> 00:26:31.599 But no, if you don't have the facility, then it's not, so you can't make that claim. 00:26:31.920 --> 00:26:44.400 So th that we each of them are sort of picking different ideas within the the genre, but they're all seem to be funneling in the same direction. 00:26:44.720 --> 00:26:52.400 They're always getting they want scope, they want boundaries, they want baselines, and they want clear KPI. 00:26:52.559 --> 00:26:56.079 So i i i i it's going in the same direction. 00:26:56.160 --> 00:27:11.279 Uh and we're getting larger brands coming to us now saying, look, we need a map across the multiple jurisdictions with, you know, show us the highest risk because it's coming anyway. 00:27:11.920 --> 00:27:17.119 So I think people are accepting that we're moving in that direction across the board. 00:27:17.440 --> 00:27:27.759 And our final question on network is ironically called do not smile, because we need to make sustainability a subject that brings happiness into the world. 00:27:28.000 --> 00:27:32.400 What object, place, or person always makes you smile? 00:27:32.720 --> 00:27:51.359 Well, when I see someone who's actually created something that means something and they actually get backing, that is really happy day because we we we see a lot of applause, but we don't see real backing. 00:27:51.440 --> 00:28:11.039 And so when you see someone that's actually, you know, maybe in their basement or their garage or they've they've developed something and created something that makes a difference to us all, that has a real-world impact, that's positive, and they actually get the wherewithal to take that out and do something with it, that makes me uh that makes me smile. 00:28:11.119 --> 00:28:15.279 I'm always like, okay, right when I'm feeling oh, there's no point. 00:28:15.440 --> 00:28:18.880 You know, you say, well, that that really is a good day. 00:28:19.119 --> 00:28:20.319 Oh, I love that, Steve. 00:28:20.480 --> 00:28:25.440 You get you basically when good ideas and good people thrive and get on. 00:28:25.519 --> 00:28:27.519 That's that's a lovely, lovely thing. 00:28:27.680 --> 00:28:33.759 Oh, well, listen, it's Steve, it's been so great to hear about eco-praise and about and and now everybody knows about blue carbon as well. 00:28:33.839 --> 00:28:36.960 It's been a double hit in this podcast episode. 00:28:37.359 --> 00:28:38.880 I hope I haven't bored everyone. 00:28:38.960 --> 00:28:40.160 You've probably got no listeners now. 00:28:40.240 --> 00:28:44.079 They're all perfectly they're all not investing in mangroves. 00:28:44.240 --> 00:28:45.519 Honestly, that's right. 00:28:46.720 --> 00:28:50.240 They're probably snoring and like, oh, let's make that guy up already. 00:28:50.640 --> 00:28:51.279 Not at all. 00:28:51.440 --> 00:28:53.279 So listen, I'm gonna wrap this up now. 00:28:53.359 --> 00:28:58.960 So thanks to everyone who's listened to our good guys podcast brought to you by the Do Not Smile Network of Agencies. 00:28:59.039 --> 00:29:06.799 And make sure you listen to future episodes where we'll be talking to more amazing people about how we can work together to create a more sustainable future. 00:29:07.119 --> 00:29:12.400 So thanks to everyone who has listened to our good guys podcast, even with my voice. 00:29:13.039 --> 00:29:16.960 And brought to you by the Do Not Smile Network of Agencies.