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A Ropes & Gray (RopesTalk) podcast series from the R&G Insights Lab that is a curiosity-driven hunt for good ideas and better ways to tackle organizational challenges.
Zach Coseglia: Welcome back to the Better Way? podcast, brought to you by R&G Insights Lab. This is a curiosity podcast, where we ask, “There has to be a better way, right?” There just has to be. I’m Zach Coseglia, the co-founder of R&G Insights Lab, and I am joined, as always, by my friend, Hui Chen. Hi, Hui. We are joined, for the first time, by someone from government, right, Hui?
Hui Chen: Hi, Zach. Yes, and he’s also a very dear friend. We have Joe Poux with us today.
Zach Coseglia: Joe, as we often ask folks at the outset of the Better Way? podcast: Who is Joe? Tell us about yourself.
Joe Poux: I’m Joe Poux—I’m currently deputy chief of the Environmental Crimes Section at the Department of Justice, where I work with a group of 35 criminal prosecutors who prosecute purely environmental crimes across the country. My night job is I am a chair of INTERPOL’s Pollution Crime Working Group, which is a collateral duty but a labor of love. Prior to coming to the Department, I was a public defender in Maryland for 10 years.
Hui Chen: Joe and I know each other from my time at DOJ, when Joe so kindly invited me to a training workshop on environmental crimes, specifically to talk about, I think, how to choose a monitor at that time. I remember Joe emailing me, saying, “Give me a call and let me convince you that you should come to this training.” And I said, “Joe, no convincing needed.” It really was my honor and pleasure to be part of that training session that you organized. I was also just really fascinated to learn more about the work of the Environmental Crimes Section. So, maybe you can also just fascinate our audience, and tell us more about the work that the section does.
Joe Poux: The Environmental Crimes Section is located within the Environment and Natural Resources Division at DOJ. We’re one of seven litigating divisions that operate out of Washington, D.C. The Environment Division, where I am, was started in 1909, so goes back quite a way. The Environmental Crimes Section, or “ECS,” as we refer to it, is one of nine sections within the Environment Division. We’re the only criminal section within the Environment Division, so we’re the only office that does criminal prosecutions in the environmental area. As I’m sure you are aware, every district or federal district of the country has a U.S. Attorney’s office, and they’re the lead federal prosecutor for all crimes in their district. But, as you can imagine, they have a lot of work on their plate, not just environmental cases. So, the idea is that my section works with those U.S. Attorneys’ offices to prosecute environmental crimes because we have the experience and the resources to drill down on these resource-intensive cases. We are able to practice in all 94 districts across the country, with, as I said, the 35 prosecutors in my office. When I started, “environmental crime” basically was “pollution”: Twenty-three years ago, on my first day, those were the cases we did under “environmental crime.” In that time our portfolio has grown: We now handle illegal wildlife trafficking; illegal timber trafficking; animal welfare crimes, such as dogfighting we picked up a few years ago; and worker-safety violations, including death cases. So, the portfolio we have now probably goes beyond what people think are traditional environmental crimes.
Zach Coseglia: What drew you to environmental crime originally?
Joe Poux: It’s not a traditional path. As I said, I was a public defender in Maryland for 10 years. One of my close friends and supervisors, who got me into the public defender’s office, went over and joined the Environmental Crimes Section herself: Deborah Harris, who’s the current chief of the section. So, after a few years in the public defender’s office, when I was looking to do something else, she was talking about this great office that she had joined, the Environmental Crimes Section, and so that’s what piqued my interest, when she described the work and the mission that they do.
Hui Chen: You started off saying that in the beginning, at least of your tenure there, there were really just pollution cases. I assume there are still pollution cases, so tell us what kind of pollution cases that you guys prosecute.
Joe Poux: There’s a gamut: Clean Air Act cases; Clean Water Act cases; dumping, illegal discharges; illegal emissions from factories. And, again, the cases we do, being crimes, have a certain mental element to them. These aren’t just pure accidents in most cases—there’s some kind of intentional conduct that’s going on. But on the pollution side, anything that threatens or harms the environment or public health, such as burning drums of hazardous waste in a field to taking the monitors off your smokestacks at the factory. When we have our cases, it’s important to punish past conduct or bad behavior, and that’s where our fines and jail come in, in terms of sentences. But we also like to affect or impact future behavior, both to make sure these violations don’t happen again, and, in many cases, to make things better. And that’s where, for most of our corporate cases, as part of the sentence, we generally require the defendants to impose what we call an “environmental compliance plan.” In broad strokes, what that means is they have to pay to hire an expert to come in and evaluate their environmental management; make recommendations on how things could be done better; and then, put those improvements in as a condition of probation. If the monitor says, “You have to do X, Y, and Z,” and they don’t do it, they have to go back to court and answer to the judge—and if the judge is not happy, they can be resentenced. So, it’s a compliance plan with teeth, we hope.
Hui Chen: In this area, particularly of pollution, what are some of the root causes that you’ve seen?
Joe Poux: Many of the cases that we do, we end up in the corporation or the corporate officer we’re talking with saying, “How could this have happened?” If you do a hot-wash or walk backwards, you see very easily how they got into the situation they were in, and a couple steps could have prevented that very expensive mistake or crime from happening. And so, what we see is, in many cases, companies have, in theory, an environmental policy or environmental program—and in many cases, it’s very long and it sits on a shelf, and when we ask to see it, it’s covered in three inches of dust. But it’s not something that they actually take seriously until we’re calling, and then, suddenly, “environmental compliance is an important program” to them. So, I would say, in a lot of cases, it’s just indifference or lack of attention on the environmental program, that gets a lot of these companies in trouble.
Zach Coseglia: We talk a lot about the role that data and analytics can play in a more effective ethics and compliance program, broadly speaking. One of the challenges that we often see, though, is that, for most crimes or most areas of interest when it comes to business ethics and integrity—it’s hard to actually measure whether folks are making good decisions; it’s hard to actually measure the behaviors that support ethics and integrity. My hypothesis is that, in the environmental crime space, it may actually be easier to measure some of this stuff, particularly when it comes to something like pollution or emissions. And so, I’m wondering what you’ve seen in terms of the role that data plays in both prosecuting these crimes, but also driving better decision-making on the part of companies going forward, and what potential lessons we may be able to learn, from a business ethics and integrity perspective more broadly, through the work that you do?
Joe Poux: I think, theoretically, in the environmental area, the issue of data does provide you with some answers or some clues ahead of time, where you might be able to head off some of these problems. The problem is if no one’s looking at the data, it’s not really very helpful. At least a quarter of all corporate prosecutions the Department does are environmental cases. And what we have seen, pretty consistently, is a focus on the bottom line, a focus on profit, and keeping the system going. I don’t mean to imply some sort of nefarious, “We don’t care if we’re polluting—it’s all about the bottom line,” but that’s how it generally shakes out. When people are looking at putting money into environmental compliance, they’re looking at that as a cost, and no one’s thinking that, “If something goes wrong, we could be sitting here looking at a million-dollar fine or a corporate prosecution.” It’s hard to prioritize environmental compliance in the abstract, and so, the challenge that we’ve seen is getting companies and individuals to think of it as a problem proactively. Some of our best pollution prosecutions that we’ve done, there’s a lot of data there if somebody wanted to dig in, and we do it after the case comes up about, “Where’s the waste going? How is it being managed?” But no one’s asking those questions. What they’re worried about is how much fuel is being expended, how much each voyage is costing, and so, when we go in afterwards, it’s clear to us that they could have found the data and, if they asked the right questions, actually pretty cheaply found out that there were problems. But there’s no incentive for individuals to find problems in many cases, if that makes sense?
Zach Coseglia: It does. And it’s, I think, a narrative that we hear and talk about a lot in this space, where our colleagues and friends who are in-house ethics and compliance professionals are often challenged by the fact that their role, their function, is viewed as a cost center, as opposed to a “revenue-generator” or a “business component.” I’m wondering, from your perspective, if there is a way to shift that mindset: from thinking about compliance or thinking about doing good as something that isn’t just a “cost of doing business,” but that actually can be “a value-add” in and of itself?
Joe Poux: I think a lot of that happens with leadership from the top. The “Andon Cord” with Toyota, for example: There’s an incentive that anybody in the company, anybody in the production line, can pull the cord and stop everything as soon as they see a problem. In fact, it’s not only they can, but it’s encouraged—that’s part of their job. If there’s a problem, they see a problem, they raise it—and that’s from the top. That’s the corporate culture that, I think, needs to be encouraged. As I said, we see many cases where there’s a four-binder environmental compliance policy that no one has ever seen, but when your manager’s telling you, “Don’t worry about that—get rid of this stuff,” that’s the policy that gets put in place. The other thing I will say is resources: You can usually tell with a company how much the environmental program is funded, if they have the resources, and also, who they report to. A lot of times, in good companies, the environmental person is reporting to the board or the chairman. If that’s happening, the chairman asks questions, and that signals to the company or the employees, “That’s something we take seriously.” If they’re buried way at the bottom of the org chart, sending in written reports once a year, that’s also a sign that perhaps the company doesn’t value the environmental program as much as they should.
Zach Coseglia: Yes, that resonates a lot. Operational excellence should include compliance, as opposed to things operating in siloes.
Joe Poux: When it comes to a lot of businesses and corporations, and certain types of crime, there’s compliance that has to do with ethics and putting things in place, in terms of business decisions, and making the right ethical decisions within a company. Environmental crime is a little different, because, in addition to the ethics, there are systems that need to be put in place and generating the data—that you referred to earlier—that will let companies assess whether things are being done the right way. There’s a lot of technical elements to an environmental compliance plan that you might not see in other corporate compliance plans. If you put a good person in a bad system, the system will win every time, so you need to have a program in place that’s going to be effective throughout the entire company, and be long-lasting. You might have a good person now, but if that person leaves, the system’s going to be what remains. And so, it is, I think, traditionally more complicated, with environmental cases, to have an effective compliance plan.
Hui Chen: I think it’s also interesting, when we start talking about data and the specifics of what people need to be monitoring and paying attention to: It really gets very specialized when you look at different areas of compliance. We’ve been talking about pollution, but the other area that you mentioned is worker safety. Now, safety is a very established industry, with a lot of indicators that are built into their industry norms. I also was very interested in a datapoint that you mentioned, that we don’t hear about enough, is that one quarter of the corporate cases prosecuted by DOJ are environmental cases. So, tell us more about the work that you guys do in the worker safety area: What kind of cases are being prosecuted there?
Joe Poux: We’ll have to give credit to Deborah, my boss, who actually brought the worker safety stuff to our program. What we had seen in the worker safety area, in terms of enforcement, the only real criminal penalties under the worker safety laws is if someone dies—and the maximum worker safety penalty when someone dies is, I think, six months. We were noticing, in a lot of our environmental cases that were coming up, there were also worker safety violations. Some of the big cases with some of the factories or manufacturing facilities—if they’re committing environmental crimes, they’re probably also violating worker safety standards. And so, we were able to work to bring worker safety violations within our portfolio. The violations that we do are cases involving worker deaths, and if you saw some of the facts, they would be quite traumatic in terms of the mistakes. But, again, it has to do with the compliance. If the maximum penalty you’re looking at, if the worst-case scenario happens, is six months, and your inspectors don’t have much authority, you’re not really going to prioritize that. And so, what we’ve tried to do is prosecute some of these cases to let companies and managers know that, “This is something that the government takes seriously, and there are consequences if you don’t do what you’re supposed to be doing”; and bring some of the more traditional criminal statutes that we do into play to try and ramp up the consequences when companies and people don’t do what they’re supposed to do.
Zach Coseglia: On that note, how much of your work is prosecuting corporations versus individuals? And what’s been the approach, in terms of bringing charges against individuals, in the environmental crime space?
Joe Poux: I would say, generally, our preferred approach is when we do a criminal prosecution, we both prosecute the corporation and the individual responsible for the conduct. Obviously, the individual is the person turning the wrench or making the decision, and there need to be some consequences there. Again, when we talk about “individuals,” we’re talking generally about people who have supervisory authority—the guy at the end of the line that’s being told to do something or he loses his job, that’s not the person we’re looking at to prosecute to effect change. So, it’d be a manager or someone with some responsibility, because we want other managers to know: “If you don’t do this, you could be prosecuted.” But it’s not just the individual. We also try and make sure the company is held accountable for what it did or, in most cases, what it didn’t do, because we think the company’s in the best position to effect change going forward. And it’s not just if an individual commits an offense and he works for the company that the company’s held liable—there’s got to be some connection that he or she is doing it to advance the company’s interests. But if that’s done as an agent of the company, we prosecute the company. So, the short answer to your question is, “Both.” The Department is also trying to emphasize individual accountability, because, sometimes, the reverse is true: The company’s willing to pay a couple extra thousand or a million, if we agree to let the individuals go. If it’s just a fine or a check that’s being written, sometimes that’s not a very effective deterrent for future conduct. And so, the Department’s very focused on making sure it’s not just a corporate-only prosecution, but the individuals responsible are being prosecuted.
Hui Chen: We talked a little bit about how certain types of compliance are ethics-driven, for lack of a better way to describe it, and some are much more system-driven. In my opinion, almost all the compliance programs really need to have a blend of the two. One of the things that I find interesting, and sometimes a little frustrating, is that different types of compliance in the companies are not really integrated. So, here are the people who are doing environmental compliance over here—they don’t even know the people who do other types of compliance, like anti-trust or anti-corruption, exist, and vice-versa. Some of the cases that you do, you see companies having challenges in more than just environmental compliance, and in some cases, they are facing departmental prosecution in multiple areas. What are your thoughts about how companies might be able to integrate these different types of compliance a little better?
Joe Poux: I think, generally, compliance, in broad strokes, can be consistent in many different areas. One of the reasons I kept bothering you when we first met was you actually had a systematic approach to compliance. One of the frustrating things in a lot of our cases is we encourage companies to come up with a compliance plan—they know their businesses and they know what they need to focus on. But the response we almost always get is, “What did the last defendant have to do? That’s our bare minimum we want to settle for.” And we try and say, “I think the last thing a company wants is a bunch of lawyers in Washington to come up with their compliance plan, because it’s not going to be perhaps very efficient, and they’re going to be spending money on something that might not be very effective.” I think compliance, as a concept, isn’t subject-matter specific—there are some things, as I said before, in the environmental area that are specific, but if you have a good plan or a good program, you can hire people to get you the information or set up something that’s environmental in particular. I think, whether it’s ethics or environmental, whatever other factors come into a compliance plan, being able to set up programs, accountability, and reporting, that’s the key part to make an effective compliance program, and that’s something that is not environmentally specific. So, just understanding that it’s a skillset, not just paying lip service to it, is a concept that, I think, is hard for a lot of companies. I’ll say many of the companies we face aren’t these “evil corporations” or people setting out to do harm or commit environmental crimes—they’re generally decent people. They just have not thought about this area until we show up at the door, and then are somewhat at a loss, and say, “What’s the least we can do to get the government off our back?,” as opposed to being proactive.
Hui Chen: I think one of the things that really frustrates me is the narrow use of the word “ethics” in the “ethics and compliance” space. To me, if I am going to be talking about “ethics” as your driving force, then not polluting my environment is part of my ethics. It certainly is for me. Not killing my workers? Certainly, part of my ethics. Wanting your colleagues to come to work and go home safely? How is that anything but ethical? Conceptually, to me, this is all “ethics,” and there’s not enough coverage, in terms of the way the word “ethics” is used in this space, to really think through these issues. So, there is that conceptual level, but then, there is the technical level: “How do you implement the safety rules and the waste disposal systems?” There’s really no contradiction to combining the two—that we are ethically motivated to care about these things, and then, we deploy proper resources and skillsets to make sure those things get done and our concerns get addressed.
Joe Poux: When people talk about “compliance and ethics,” and “putting a plan in place,” everyone talk’s a good game, and then, when someone shows up and says, “This is what we think needs to be done for compliance,” suddenly, people are like, “We don’t need to do that much,” or, “You’re asking for too much in the way of resources or a commitment.” And that’s the disappointing thing that you and I have both seen in many different contexts.
Hui Chen: I want to move off the corporate aspects a little bit, and I want to talk about something that’s certainly of interest to me, as a person—and, I imagine, among our listeners, a lot of people are animal lovers. I remember, sitting there in the training session that you organized, when the people were presenting on animal welfare, the pictures that were shown and the types of cases that you were doing, they really touched my heart. Both the animal welfare area and the wildlife trafficking area—it’s something that is near and dear to me. Tell us more about the work that you guys do in both of those areas.
Joe Poux: When I started, I mentioned my section did mainly pollution. There was another section in my division that handled wildlife offenses, and they had wildlife prosecutors. And the decision was made, “Let’s put all the prosecutors together.” So, the wildlife prosecutors and the pollution prosecutors all came together in the Environmental Crimes Section. I will say, in terms of the number of our cases, probably 40% to 50% of our cases now are wildlife prosecutions involving many offenses here in the U.S., but also the international illegal wildlife-trafficking offenses, which there were far more of than I ever thought I would know about. The animals are important, and that’s what gets people in the door, but when you start looking underneath it, you start seeing the amount of money in organized crime and international global criminal groups involved, it’s really a crime area that is very complex. But, as I said, it’s an important part of our practice that we didn’t have when I started—and similarly, with animal welfare.
With animal welfare, there’s a couple different components. Primarily what we do, most of our cases have to do with animal fighting. And what we had seen is there were cases that were coming up across the country, and different U.S. Attorneys’ offices had different resources to pay attention to it, but it was a disparate approach, with 94 different districts. Someone had come up with the idea—and there was a group within the Department that gets credit for this—to say, “We need a place to put these cases that’s going to have responsibility for tracking and doing them.” We’re not the only office that does them, but we have a national perspective, and so, we picked these up a few years ago, and, again, it’s a significant part of our practice. I mentioned we do cases with animal-fighting, and we’ve seen cases in every part of the country. You would think maybe it’s regional or it’s a one-off in this district, but, no, I think you can go to any district and find animal-fighting operations going on. Again, if you dig down, these are animal-fighting operations involving, in many cases, organized crime, gangs, guns, gambling, and so, more traditional crime areas than you might think of when you just think of “animal-fighting.”
Hui Chen: That was what I also found fascinating. I think most people wouldn’t have thought of that. Out of curiosity, I wanted to ask you: What kind of wild animals are being imported and exported, or trafficked around in the U.S. and the world?
Joe Poux: First of all, let me give a disclaimer: My wildlife colleagues would be aghast that I would be expressing any opinion in the wildlife area, because their immediate response would be, “You don’t know what you’re talking about.” But, for example, a lot of stuff with ivory. Rhino horn is a huge industry: In some cases, per ounce, it’s more valuable than gold, and so, there’s just a huge demand for this around the world. A lot of the stuff is being trafficked through the U.S., or coming into the U.S. There are other exotic species of reptiles and birds—there’s a huge trade. Whatever you can think of, there’s probably a trade in it—that’s what I’ve learned in the course of my work in the section. Stuff that you never thought would be of any use or value to anyone, there’s a market for it. The charismatic megafauna, as I’ve mentioned, with the rhinos and the elephants, people know about (shooting them to get the horns), but there’s also a whole industry with smaller, “less charismatic wildlife,” let’s say, that involves a lot of money that goes around the world—it’s very large on a financial scale.
Hui Chen: Joe, you mentioned that your nighttime job is working with INTERPOL. Just give us some sense of how the international law enforcement community collaborates in the area of environmental crime.
Joe Poux: It’s getting better. As you can imagine, the challenges within the United States, of coordinating with different agencies, can be immense, and if you multiply that by 194 different countries working with INTERPOL, the challenges are 194 times more challenging. INTERPOL has several different working groups in the area of environmental crime. As I said, I’m chair of the Pollution Crime Working Group—they have one with wildlife, illegal fishing, and illegal timber-forestry—and it brings together law enforcement agencies from different countries to work together. There’s no real role authority, no one has particular jurisdiction—it’s just more of a collaborative effort. What we’ve seen is, in all these areas—and my focus has been on the pollution side—that a lot of the crimes that are happening have an international or a trans-national effect, particularly with the export of hazardous waste (plastics is an issue that has come up). It’s a “tragedy of the commons,” to some extent, that “once it leaves our country, it’s not our problem anymore.” And so, the communication, law enforcement to law enforcement, has been a challenge. Hopefully this group has improved that. But we have seen, in a lot of these areas, organized crime becoming involved, because they’re not picky—their view is, “Can we make money off of it?” and “What are the chances of getting caught?” Unfortunately, in the environmental area, particularly with waste and pollution, right now, there’s a lot of money to be made, and the risk of getting caught and the consequences are not as high as we would like them to be. And so, we’re hoping, through these groups, to raise awareness, and make the penalty or decrease the incentive, because we want people to know that someone is watching.
Hui Chen: Alright, so now it’s that time of getting to know Joe Poux.
Zach Coseglia: I’ll start with question number one. Joe, you have a choice of two questions that you can answer here. The first is: If you could wake up tomorrow having gained any one quality or ability, what would it be? Or: Is there a quality about yourself that you’re currently working to improve, and, if so, what?
Joe Poux: I will give one answer because I think both questions lead to the same result. Again, being a lawyer, I will refuse to give just one answer to the question, and I will ask to do two. I would say first of all is “patience,” and, in particular, day-to-day patience with the bureaucracy. I would also say “humility.” Part of that is, again, having been in a place for 23 years, I think it’s natural you start to think, “I’ve seen this before—I know all the answers.” And every day coming in thinking like, “I don’t know the answer” is a skill that I’m still trying to work on.
Hui Chen: Next question is, again, also a choose one of two options. You can answer either: Who was your favorite mentor? Or: Who do you wish you could be mentored by?
Joe Poux: It might be semantics, but I’m a little nervous about saying “mentor” because I don’t want anybody to have to take responsibility with the final product being me, so I might phrase it another way, in terms of folks that I try and emulate. I’ll give three off the top of my head—they sound a little trite. My mom, who went to law school when I was in junior high or high school, who showed me that there is a career in the law, and that’s probably one of the reasons I went into it. I think I mentioned my friend and current boss, Deborah Harris, who is a tough boss, but has taught: “Being in government, ‘good enough’ isn’t necessarily good enough—you can do better,” and has held us in the office to a high standard. And then, I have a good friend, Willie Wilson, who has taught me a lot about thinking big-picture, both environmentally and personally, emphasizing maximum compliance, and trying to get the best result—not just the satisfactory result.
Zach Coseglia: The third question is: What is the best job, paid or unpaid, that you’ve ever had?
Joe Poux: I haven’t had that many, so I would say the choices aren’t that many. Obviously, I’ve been where I am now for 23, going on 24, years, so I would say currently working in the Crimes Section has been my best job. My 10 years in the public defender’s office—also a great job. And the common theme, I think, in both, is the people I’ve had the opportunity to work with and the mission-driven jobs. It’s not coming in, figuring, “How do I do my eight hours so I can go home?” It’s more of a calling or a passion.
Hui Chen: Alright, so next question is: What is your favorite thing to do?
Joe Poux: Watching Celtic Football Club play every week, particularly when they’re beating Rangers.
Zach Coseglia: What is your favorite place?
Joe Poux: Home, spending time with the family—that would be my favorite place.
Hui Chen: Number six is: What makes you proud?
Joe Poux: I kind of referred to it: One of the favorite job things is that I’ve been able to last 23-24 years in the Crimes Section. I work with excellent people, very committed people, and they allow me to come back every day. Being a poseur, the fact they let me come back, and accept me as one of their own, that’s what makes me proud. And coming in and be associated with the great people that I’ve met throughout my time at the Department, that’s what makes me proudest.
Zach Coseglia: We’ll go from the deep to the very shallow: What is the email signoff that you use most frequently?
Joe Poux: I heard this question in another context, and I just feel very unoriginal—it’s usually just, “Joe.” With my signoff, the thing that’s been most useful to me is I had to add a five-minute delay. Sometimes, with my emails, I can be a little intemperate, and so, I have found a very valuable lesson is to not go out until five minutes later, so I have a cooling-off period. The other part of it that’s interesting is I had originally a three-minute delay and learned that was not sufficient time, so I had to up it to five.
Zach Coseglia: That is such a wonderful Better Way that I hope lots of people will take to heart.
Joe Poux: Yes, you have to find your own time. That’s the edit I had to learn.
Hui Chen: The next one is: What trend in your field is most overrated?
Joe Poux: I would say a tendency to try and come up with short-term, easy, maybe trendy solutions to complicated, long-term problems. It’s nice to have a slogan or a catchphrase to approach a problem, but many of the problems, particularly in the environmental area, are complicated and long-lasting, and there aren’t necessarily “easy” solutions to them.
Zach Coseglia: The final question is, and I’m mindful that it’s not even 9:00 a.m., so this is going to be a real reflection on Hui and me: What word would you use to describe your day so far?
Joe Poux: “Enjoyable,” because I’m chatting with you guys. I will say there aren’t many people, besides Hui, that would get me to get up at 8:00 a.m. to do a podcast, so I’m happy to do it. This has been very enjoyable.
Hui Chen: Same here. Thank you so much, Joe.
Zach Coseglia: Thank you all for tuning in to the Better Way? podcast and exploring all of these Better Ways with us. For more information about this or anything else that’s happening with R&G Insights Lab, please visit our website at www.ropesgray.com/rginsightslab. You can also subscribe to this series wherever you regularly listen to podcasts, including on Apple and Spotify. And, if you have thoughts about what we talked about today, the work the Lab does, or just have ideas for Better Ways we should explore, please don’t hesitate to reach out—we’d love to hear from you. Thanks again for listening.