For best results when printing this announcement, please click on link below:
http://newsfile.refinitiv.com/getnewsfile/v1/story?guid=urn:newsml:reuters.com:20220331:nRSe7611Ga&default-theme=true
RNS Number : 7611G Kingfisher PLC 31 March 2022
31 March 2022
KINGFISHER PLC
(the "Company")
Publication of 2021/22 Annual Report and Accounts
The Company's Annual Report and Accounts for the year ended 31 January 2022
(the 'Annual Report') has today been published on the Company's website
www.kingfisher.com (http://www.kingfisher.com) .
In accordance with Listing Rule 9.6.1R of the UK Financial Conduct Authority
('FCA'), the Annual Report has been submitted to the FCA's National Storage
Mechanism and will shortly be available for inspection at
https://data.fca.org.uk/#/nsm/nationalstoragemechanism
(https://data.fca.org.uk/#/nsm/nationalstoragemechanism)
A hard copy version of the Annual Report, along with the Notice of Annual
General Meeting 2022 (the 'AGM Notice') will be sent to those shareholders who
have elected to receive paper communications on or around 8 April 2022. The
AGM Notice will be made available to shareholders who have not elected to
receive paper communications on the same date.
The final results for the year ended 31 January 2022, released by the Company
on 22 March 2022, include the information required pursuant to Rules 4.1 and
6.3.5R of the UK Disclosure Guidance and Transparency Rules, excepting
publication of the responsibility statement of the Directors in respect of the
Annual Report, a description of the principal risks and uncertainties facing
the Company, and the related party transactions carried out by the Company and
its subsidiaries during the year, which are detailed below:
1. Principal risks
The principal risks and uncertainties facing the Company are set out below.
1. Our People
Our colleagues are critical to the successful delivery of our 'Powered by
Kingfisher' strategy. We have rebalanced responsibilities between Group and
banners to set the right conditions for our individual banners to grow while
leveraging the Group's scale and expertise to meet customer needs.
Our accelerated investment programme requires an expansion of our technical
capabilities. More generally, the failure to attract, retain and develop
colleagues with the appropriate skills, capabilities and diverse backgrounds,
or to have adequate succession plans, could impact our ability to meet our
business objectives.
How our risks have changed
No change. Although recruitment has become increasingly competitive as
economies recover, we have successfully implemented our organisational
structure changes and have plans in place to
address our future resource requirements.
Link to strategic priorities
· Grow e-commerce sales
· Build a mobile-first and service orientated customer experience
· Differentiate and grow through own exclusive brands (OEB)
· Lead the industry in Responsible Business practices
How we manage and monitor the risk
· The Board has approved our Group strategy for people and culture,
with individual priorities agreed for each banner and function.
· The Group Executive and Board hold regular talent reviews focused
on ensuring the senior leadership group has the required capabilities to
deliver the strategy and on activities to strengthen our leadership succession
pipeline.
· We have a formal Technology Capability programme in place to
ensure continued focus and progress on acquiring and retaining critical
skills. A new Technology careers webpage has been launched, which has
increased the level of traffic to our site.
· We have refreshed the Employer Brand in the UK retail banners and
are in the process of extending and aligning this across the wider Group.
· We invest in tools and infrastructure to support our colleagues'
learning, including a leadership development portal for bite-size instant
learning and e-learning for our store teams on new products.
· We have identified and agreed the key leadership requirements and
behaviours to accelerate delivery of our strategy and target culture which we
define as agile, inclusive and led by trust. These behaviours will become the
cornerstone of our work on leadership hiring, talent management and leadership
development.
· Each banner has a tailored diversity and inclusion plan. Areas of
focus are our senior leadership, creating a culture of inclusion, our customer
proposition and learning for life. Relevant targets are linked to the
remuneration of senior leaders.
· The physical and mental wellness of our colleagues has remained a
priority during the year through communications and the provision of external
support (e.g. mental health awareness training for line managers). We continue
to check in on how colleagues are feeling through our annual colleague survey.
2. Level and Impact of Change
Under our strategic plan 'Powered by Kingfisher', the business is utilising
its core strengths and commercial assets, and 'powering' its distinct retail
banners to address the significant growth opportunities that exist within the
home improvement market. We have high ambitions and we are continuously
improving our offer, market positions, cost base and technology. In
particular, we are rolling out a Group-wide IT systems development programme.
Where relevant we may also consider complementary acquisitions, partnerships
and joint ventures to optimise our business activities and support our
strategy.
Failure to properly prioritise activity and manage change effectively could
result in weaker than
anticipated sales growth, reduced operating margins or insufficient cash being
generated to meet
our objectives.
How our risks have changed
Decreased. The planned organisational structure changes have been implemented
and we have made significant progress on our strategic priorities.
Link to strategic priorities
· Grow e-commerce sales
· Build a mobile-first, service orientated customer experience
· Differentiate and grow through own exclusive brands (OEB)
· Test compact store concepts and adapt our store footprint
· Source and buy better, reduce our costs and same-store inventory
· Lead the industry in Responsible Business practices
· Expand engagement with trade customers
How we manage and monitor the risk
· Our 'Powered by Kingfisher' strategy has been clearly articulated
to all colleagues and externally validated by a global consultancy business.
· A new balanced and simpler local-group operating model has been
implemented.
· The Board has approved three-year plans for each banner and Group
Function to deliver the strategy.
· A central Results Delivery Office provides monthly reporting to
the Group Executive and quarterly to the Board, based on a set of c.50 KPIs,
measuring the implementation and effectiveness of strategic initiatives.
· Each of our key strategic pillars is led and monitored by one of
our banners or Global Functions, with monthly review points with the Group
Executive sponsor.
· Annual in-depth strategic review and six-monthly strategic
performance updates performed with the Board, addressing the agreed priorities
and making changes where appropriate.
· Technology directors have been appointed in our retail banners to
provide more local flexibility while leveraging the scale of our wider Group
Technology organisation.
· Regular communication with all colleagues on the delivery of the
strategy, key changes being made and forthcoming business developments.
· Periodic reviews of governance and enabling activities undertaken
by Internal Audit.
· We have a dedicated M&A function, with accountability resting
with the CFO. M&A activity exceeding £10 million in value requires
Kingfisher plc Board scrutiny and approval.
3. Contagious Diseases
Over the past two years, Kingfisher has demonstrated its ability to navigate
the challenging operational impacts of the pandemic, retaining good product
availability and operating safely. With the emergence of new more
transmissible variants, the risk of a prolonged global health threat and
associated government restrictions remains, which could adversely affect our
operations and those of our partners and suppliers. This could cause a
significant reduction in footfall and consumer spending and could negatively
impact our ability to receive products from affected suppliers. High levels of
absence in either our workforce or our suppliers could impact our ability to
operate stores and warehouses, deliver products or provide appropriate
functional support to our business.
Such restrictions and/or reductions in demand could adversely affect our
financial results and the financial condition of the Group.
How our risks have changed
No change. There has been significant progress in the rollout of vaccines and
in medical treatments over the past year. We also have procedures in place to
protect our colleagues and customers while continuing to trade. However,
uncertainty still remains over new variants, and the possible
reimposition of Covid-related restrictions.
Link to strategic priorities
· Lead the industry in Responsible Business practices
How we manage and monitor the risk
· The health and safety of our colleagues and customers remains our
top priority, alongside supporting governments to limit the spread of the
virus. We have maintained strict hygiene and appropriate social distancing
measures in our stores. We significantly invested in PPE to ensure
availability for our staff, deep cleaned stores where required and allowed
staff to self-isolate while continuing to be paid.
· We have communicated regularly to colleagues and customers,
providing reassurance and responding to common concerns.
· Our Group Crisis Committee has met at least fortnightly
throughout the year in response to the pandemic, with representation from
banners and functions. The Committee monitors events, changes in governments'
approaches and response strategies. The Board provides regular oversight to
evaluate the impact of Covid-19 on Kingfisher.
· We have liaised closely with governments to ensure we can
continue to provide home improvement while playing our role to limit
transmission of the disease.
· We have ensured that our office-based colleagues are able to work
from home, in line with local governmental guidance, with access to
appropriate equipment. Ongoing line manager training and mental health
'wellness' awareness has been provided for working in this way.
· We have business continuity and crisis teams in each of our
markets, who we would mobilise in the event of any future significant
operational impact.
· If required, we are able to significantly reduce discretionary
spend (including freezing pay reviews, delaying bonus payments and/or
recruitment), stop all non-committed capital expenditure, reprioritise
sourcing requirements and adjust purchasing plans.
· We regularly monitor customer, colleague and stakeholder
sentiment through social media and colleague feedback. This output influences
the operational decisions we take.
4. Supply Chain Resilience
A resilient supply chain is key to our business and the achievement of our
strategic objectives. We are dependent on complex global supply chains and
fulfilment solutions to deliver our products to our customers. There has been
significant disruption caused by the pandemic with congestion at ports and an
increased demand for containers. The pandemic has also caused operational
difficulties for our suppliers, testing their ability to respond quickly to
changes in demand. Major disruption to our supply chain could result in
reduced levels of product available for sale, with an adverse financial and
reputational impact.
How our risks have changed
No change. There have been continued challenges to our supply chain as a
result of the pandemic.
However, capacity has increased and would be able to meet demand were it not
for disruption at key points in the network.
Link to strategic priorities
· Grow e-commerce sales
· Source and buy better, reduce costs and same‑store inventory
· Expand engagement with trade customers
How we manage and monitor the risk
· Our Supply and Logistics three-year roadmap was updated in
2021/22. It considers our future logistics capacity needs based upon the
various sourcing, inventory and sales generative strategies identified in the
Group's strategic planning activities.
· Business continuity plans are updated regularly, covering our
internal points of failure and key partner service-continuity plans. The
actions include a response to supplier and logistics failures, and plans were
tested live as part of our Covid response activities.
· We have established partnerships with key transportation and
logistics suppliers to align planning and secure capacity.
· Since the start of the pandemic, a weekly meeting of Supply Chain
Directors from across the Group has been held to identify and agree key
actions to respond to the changing supply needs.
· We have extended our demand forecasting to better anticipate
future sales requirements and worked with suppliers to ensure product
availability.
· We have continued the implementation of store-based fulfilment
for customer orders to support the business operation and the increased demand
since the pandemic started.
· We have an agreed supplier strategy which includes guidance on
choosing which regions to source from and when to use more than one factory or
supplier to increase resilience.
· There is a robust process for selecting individual suppliers.
This includes checks on financial strength, ethical and environmental risks
and their ability to manufacture the products to the agreed specification.
· We continually review key suppliers by category to establish
capacity and volumes and assess the impact of an interruption in supply.
5. Competition
Our competitors include both traditional store-based and pureplay online
retailers. The pandemic has accelerated changes in the market, with a sharp
rise in the use of online marketplaces and an increase in the number of
competitors in the home improvement market. Competitors are also developing
their offers, including both direct-to-customer operations and the services
offered.
Targeted actions or disruptive behaviour by competitors could negatively
impact our market share,
the value of our assets and our financial results.
How our risks have changed
No change. Our strategy has enabled us to continue to grow our Group sales and
profit and gain market share in the UK and France.
Link to strategic priorities
· Grow e-commerce sales
· Build a mobile-first, service orientated customer experience
· Differentiate and grow through own exclusive brands (OEB)
· Test compact store concepts and adapt our store footprint
· Source and buy better, reduce our costs and our same-store
inventory
· Expand engagement with trade customers
How we manage and monitor the risk
We are building a differentiated offer through:
· Clear positioning for each of our banners, with different
operating models to address diverse customer needs, such as general DIY needs,
trade-focussed and discounters.
· Centrally developing our OEB brands, with clearly defined range
principles and customer projects to create a differentiated and compelling
offer.
· Giving greater autonomy to local banners and allowing local
ranges, services and store formats that are tailored to customers' needs.
· Competing on price by using the scale of our Group to benefit
from volume and lower purchase prices.
· Tailoring trading actions to local markets, through distinct
customer communications (adverts, brochures), promotions and loyalty schemes
to increase sales and brand loyalty.
We regularly monitor our market share, our performance and that of our
competitors, to react quickly to targeted actions via:
· Comparison of price indices vs competition in our key categories
and measure customer price perception on a regular basis.
· Customer trend monitoring in all our markets to anticipate and
develop an appropriate offer.
· Monitoring Net Promotor Scores (NPS) scores, with targets to
improve the customer experience and satisfaction.
6. Changing Customer Preferences
The pace of change remains high, with a greater use of e-commerce solutions
for click & collect and home delivery. To make our products available to
customers where and when they want it, we have accelerated our investment
programme. This ensures we have innovative digital channels supported by an
agile and reliable infrastructure, including technology and logistics
capability, and an optimised property portfolio with in-store services.
Failure to identify new trends and optimise our channels quickly enough could
affect our ability to stimulate spend and adversely impact the value of our
assets and our financial results.
How our risks have changed
No change. The increased autonomy of the banners in our new commercial
operating model allows them to more quickly identify and react to changes in
customer trends. However, a significant risk
remains that we are not able to deliver the required changes quickly enough or
that the changes are not sufficiently compelling for our customers.
Link to strategic priorities
· Grow e-commerce sales
· Build a mobile-first, service orientated customer experience
· Test compact store concepts and adapt our store footprint
· Lead the industry in Responsible Business practices
· Expand engagement with trade customers
How we manage and monitor the risk
· A Group digital strategy has been developed and approved by the
Board, with various priority programmes underway.
· Our Customer & Market Intelligence team continuously monitors
and gathers insights, which is regularly shared with the Group Executive, the
Board and the wider business. We also have teams focused on customer data and
digital experience, so that we can better understand the behaviour of our
customers and provide them with personalised omnichannel experiences.
· We have an established Technology Product Council, meeting on a
quarterly basis, to monitor financial and project portfolio performance and to
prioritise upcoming digital initiatives.
· We have launched strategic programmes to grow e-commerce,
focusing on putting stores at the centre of our fulfilment model. We have
implemented a digital hub model to improve speed of delivery. Drive through
pick-ups are now in all medium and big stores in France and Poland and lockers
have been rolled out to all Castorama Poland stores.
· We are continuing to invest in developing our mobile consumer
apps so that they can be used in our stores for self-service ordering and
payment.
· We have also improved the customer proposition by broadening the
services we provide. This includes technology driven services to improve the
experience of buying online and making DIY projects more affordable.
· We have expanded the range of do-it-for-me services available to
customers to help them complete projects, including rolling out our NeedHelp
proposition in the UK and Poland. NeedHelp is the leading European home
improvement services marketplace.
· We have continued to test and develop our understanding of
compact store formats and concessions, with additional openings in the UK,
France and Poland. We now have 25 stores across four banners, providing us
with strong learnings for our future blueprint.
· We continue to review the best options to further expand product
choice, including our recently launched e-commerce marketplace proposition.
· To our focus on speed and convenience for customers, Screwfix has
launched 'Sprint', offering deliveries direct to site within one hour for a
third of UK postcodes.
7. Political and Market Volatility
Kingfisher operates in eight countries across Europe and relies on a global
supply base, exposing us to both geopolitical uncertainty and local
volatility. Disruption could include government restrictions on mobility,
strikes, work stoppages and/or our ability to receive products from affected
countries. Market volatility has increased since the pandemic began, resulting
in changing customer behaviours and reduced consumer confidence. If
governments try to reduce their budget deficits through taxation, this will
create additional burdens on businesses. These impacts could potentially
disrupt the day-to-day operations of our business and our ability to meet our
strategic objectives.
How our risks have changed
Increased. We have seen increased economic volatility across all our markets,
with higher material,
energy and labour costs driving higher inflation. A continued conflict in
Eastern Europe would negatively impact energy and commodity prices and could
limit the availability of certain raw materials.
Link to strategic priorities
· Source and buy better, reduce costs and same-store inventory
How we manage and monitor the risk
Monitoring and engagement activities
· Our Corporate Affairs team actively monitors the political and
economic situations in the countries in which we operate or which may impact
our operations. This is supported by membership of key business trade
associations in every market.
· Strategies are in place to identify, monitor and influence
changes to legislation that may impact our business.
· Crisis management processes and teams are in place to monitor and
manage situations as they arise.
· Our global buying offices and supply chain teams are focussed on
ensuring we maintain appropriate levels of product availability through
periods of disruption.
Mitigation activities
· We have strong and distinct banners, with each able to set the
right product offer and pricing to meet our customers' appetite for spending.
· We have banner and Group sourcing offices focused on securing
competitively priced supplies.
· The Group has access to significant committed liquidity
facilities and debt funding, through drawn term loans and the ability to issue
debt into the capital markets through its European Medium-Term Note (EMTN)
programme.
· Cash holdings are diversified across a number of financial
institutions (for which credit risk is closely monitored).
· We have an appropriate and prudent mix of hedging policies, cash
deposits and debt financing to minimise the impact of foreign exchange
currency volatility on the company.
· We are continually investing to reduce our energy usage and
increase our efficiency. Our Group Hedging policy reduces our exposure to
energy price fluctuations and provides regular reporting for oversight.
8. Legal and Regulatory
The Group's operations are subject to a broad range of regulatory requirements
in the markets in which it operates. A major corporate issue or crisis, a
significant fraud or material non-compliance
with legislative or regulatory requirements would impact our brands and
reputation, could expose us to significant fines or penalties and would
require significant management attention.
How our risks have changed
No change.
Link to strategic priorities
· Source and buy better, reduce our costs and same-store inventory
· Lead the industry in Responsible Business practices
How we manage and monitor the risk
Policies and procedures:
· Policies and procedures are in place, clearly stating our
expectation to carry out our business fairly and with complete integrity.
· Our Goods Not For Resale Vendor Engagement Assessment tool
increases the level of supplier due diligence covering business integrity,
data protection and information security.
· A new whistleblowing policy and hotline, facilitated by an
independent third party, were put in place throughout the Group in FY21/22,
with a communications campaign to raise awareness. Champions in all banners
received training to ensure that all calls are followed up and investigated
appropriately.
Training and communication:
· Revised Group-wide mandatory compliance training was rolled out
and delivered in 2021, with two modules for all colleagues (Code of Conduct,
including anti-bribery and corruption, and GDPR) and two for head-office staff
(Fair Competition & Market Abuse Regulation). Refresher training modules
were launched in January 2022 to be completed by all colleagues.
Oversight and reporting:
· Our Legal & Compliance network is well established, for teams
at Group and banners to work and communicate together.
· The Group Ethics and Compliance Committee (GECC) ensures that the
Group approach to ethics and compliance is adequate and effective. This
includes approving compliance training and reviewing the outcomes of
investigations. Local Ethics and Compliance Committees have been implemented
in all banners to ensure a consistent approach across the Group.
· We have a Disclosure Committee in place to address our Market
Abuse Regulation requirements.
· Whistleblowing statistics and trends are monitored in the local
Ethics and Compliance Committees and reported to the GECC, Audit Committee and
Board annually.
9. Cyber and Data Security
Cyber-attacks and security incidents continue to increase and the retail
sector has joined a number of industry sectors as a target due to it becoming
more data driven. As we increase our digital presence and develop smart
products and services our risk profile will continue to change.
Failure to protect data, detect breaches, and respond accordingly would
negatively impact our operations, profitability and reputation.
How our risks have changed
Increased. Alongside a continued acceleration in digital growth, there has
been a growing number of organisations affected over the past year, with a
wider availability of tools and techniques available to cause serious
disruption.
Link to strategic priorities
· Grow e-commerce sales
· Build a mobile-first, service orientated customer experience
How we manage and monitor the risk
· Cyber security continues to receive Group Executive-level
sponsorship and Board focus.
· Cyber security is an integral part of the IT strategy with a
clear three-year plan supporting the strategic priorities and will continue to
develop and evolve our capabilities to manage new threats.
· An independent maturity assessment has been completed and results
incorporated into the 3-year plan. There will be a continuous independent
assurance schedule to ensure we meet target maturity.
· We regularly review the cyber threats facing Kingfisher and work
with security partners to evaluate and implement appropriate controls.
· All technology development goes through a 'Secure by Design'
process to ensure solutions and data are secure and adhere to compliance and
regulation requirements.
· We perform security assurance of third parties that process our
data across all functions and banners.
· We have a continuous programme to enhance our protective and
defensive capabilities.
· There is a robust major incident management process and we
maintain a third-party retainer for incident response, breach and forensic
expertise.
10. Reputation and Trust
Our customers, colleagues, suppliers, investors and the communities we source
from and operate expect us to conduct our business in a way that is
responsible. One of the many ways we strive to ensure this is through our
publicly communicated Responsible Business strategy and targets, covering
topics such as climate change, responsible sourcing and diversity (for further
details please refer to Responsible Business on pages 23 to 29).
Failure to deliver on our obligations and commitments could undermine trust in
Kingfisher, damage our reputation and impact our ability to meet our strategic
objectives.
How our risks have changed
No change. The level of scrutiny and expectations from our stakeholders
remains high, particularly around our response to Covid-19 and the
environment.
Link to strategic priorities
· Lead the industry in Responsible Business practices
How we manage and monitor the risk
Governance:
· Our Code of Conduct establishes the core behaviours we expect of
ourselves and others, including our suppliers.
· The Responsible Business Committee leads and oversees the
delivery of the responsible business strategy. It is chaired by a
non-executive director and includes the Chief Executive Officer.
· Our approved science-based carbon reduction targets ensure we
have a short-term plan to 2025 decarbonise our full supply chain including
moving our property portfolio to renewable energy, lower carbon transport
solutions and editing our product ranges to offer customers the most energy
and water efficient products.
· Our annual reward measures help to ensure that environment,
social and governance (ESG) issues and stakeholder concerns are further
prioritised.
Stakeholder dialogue:
· Monitoring of external stakeholders' views of our company through
traditional and digital media for all our companies.
· For colleagues, we have forums and works' councils in all of our
businesses, including a collective forum that meets with the CEO and members
of the Board.
· Externally, we have regular engagement with a range of NGO
partners in our key markets, which helps to ensure that the company remains
close to social and environmental concerns.
Due diligence and external assurance:
· Our due diligence of suppliers covers a range of ESG issues, from
environment to modern slavery; and includes our policy framework and supplier
standards, which we expect suppliers to adhere to; supplier training and
capacity building; and auditing of high-risk suppliers.
· Our due diligence extends to the data we disclose. Selected ESG
data in the annual Responsible Business Report and Modern Slavery Statement is
independently audited by DNV.
· Independent ratings agencies also monitor and rate our ESG
performance throughout the year, including MSCI, CDP, Sustainalytics and ISS
ESG.
2. Related party transactions
During the year, the Group carried out a number of transactions with related
parties in the normal course of business and on an arm's length basis. The
names of the related parties, the nature of these transactions and their total
value are shown below:
2021/22 2020/21
£millions Income Receivable Income Receivable
Transactions with Koçtaş Yapi Marketleri Ticaret A.S. in which the Group
holds a 50% interest
Commission and other income
0.2 - 0.2 -
Transactions with Crealfi S.A. in which the Group holds a 49% interest
Provision of employee services
Commission and other income 0.2 - 0.2 -
4.9 0.1 4.8 0.2
Transactions with Kingfisher Pension Scheme
Provision of administrative services
0.8 0.3 0.7 0.3
Services are usually negotiated with related parties on a cost-plus basis.
Goods are sold or bought on the basis of the price lists in force with
non-related parties.
The remuneration of key management personnel is given in note 9 of the Annual
Report.
Other transactions with the Kingfisher Pension Scheme are detailed in note 28
of the Annual Report.
3. Directors' Responsibility Statement
The Directors confirm that to the best of their knowledge:
· The financial statements, prepared in accordance with the
relevant financial reporting framework, give a true and fair view of the
assets, liabilities, financial position and profit or loss of the parent
company and the undertakings included in the consolidation taken as a whole.
· The Strategic report includes a fair review of the development
and performance of the business and the position of the company and the
undertakings included in the consolidation taken as a whole, together with a
description of the principal risks and uncertainties they face.
· The Annual Report and financial statements, taken as a whole, are
fair, balanced, and understandable and provide the information necessary for
shareholders to assess the company's position, performance, business model and
strategy.
Chloe Barry, Group Company Secretary
Tel: +44 (0) 77688 06248
Kingfisher plc
3 Sheldon Square, London W2 6PX
- Ends -
This information is provided by RNS, the news service of the London Stock Exchange. RNS is approved by the Financial Conduct Authority to act as a Primary Information Provider in the United Kingdom. Terms and conditions relating to the use and distribution of this information may apply. For further information, please contact
rns@lseg.com (mailto:rns@lseg.com)
or visit
www.rns.com (http://www.rns.com/)
.
RNS may use your IP address to confirm compliance with the terms and conditions, to analyse how you engage with the information contained in this communication, and to share such analysis on an anonymised basis with others as part of our commercial services. For further information about how RNS and the London Stock Exchange use the personal data you provide us, please see our
Privacy Policy (https://www.lseg.com/privacy-and-cookie-policy)
. END ACSZZGFFLMNGZZG