This article is written by Lavanya. B of BA. LLB of 5^th Year of Ramaiah College of Law, an intern under Legal Vidhiya

ABSTRACT

This article explores the significance of cultural diversity in corporate governance, highlighting its impact on decision-making processes and organizational dynamics. It defines cultural diversity as the presence of various cultural and ethnic groups within society and emphasizes its importance in fostering inclusivity and innovation in the workplace.

The importance of cultural diversity in the workplace is discussed, emphasizing its role in creating a more productive and cohesive environment. Various types of cultural diversity are identified, including gender, education, religion, LGBTQ+, race and ethnicity, age, disabilities, and mental health. The benefits of cultural diversity are outlined, including skill development, recruitment improvement, talent retention, enhanced creativity, increased engagement, improved reputation, and higher productivity.

The concept of corporate governance is introduced as the set of regulations, procedures, and mechanisms guiding the direction and oversight of companies. Legal perspectives on cultural diversity in corporate governance are examined, with a focus on legal frameworks and compliance requirements, board composition and diversity policies, challenges in implementation, the role of corporate law, jurisdictional variances and global standards, compliance and regulatory considerations, and risk management and litigation.

Finally, best practices and recommendations for promoting cultural diversity within corporate governance structures are provided. These include implementing diversity training programs, establishing clear diversity policies and objectives, fostering inclusive leadership, encouraging diverse talent pipeline development, conducting regular diversity audits and assessments, promoting cross-cultural collaboration and mentorship, leveraging employee resource groups (ERGs), ensuring accountability and transparency, and continuously educating and adapting to evolving diversity issues and legal requirements.

KEYWORDS

Cultural Diversity, Corporate Governance, legal frameworks, compliance, board composition, challenges, risk management, best practices, and recommendations.

INTRODUCTION

As globalization continues to shape the business landscape, the importance of cultural diversity within corporate governance structures has grown significantly. This section provides an in-depth overview of how cultural diversity influences decision-making processes and organizational dynamics within corporate governance.

Cultural diversity encompasses a wide range of factors, including but not limited to ethnicity, nationality, religion, language, and socio-economic background. Recognizing and embracing this diversity is crucial for companies operating in today’s interconnected world. It not only reflects the diverse nature of society but also brings a multitude of perspectives and experiences to the table, enriching the decision-making process.

Within corporate governance, cultural diversity impacts various aspects, including board composition, leadership styles, and corporate policies. Boards with diverse backgrounds and perspectives are better equipped to understand and address the needs of a diverse workforce and customer base. Additionally, cultural diversity fosters innovation and creativity by encouraging the exploration of new ideas and approaches.

However, while cultural diversity presents numerous opportunities, it also poses challenges. Differences in cultural norms, communication styles, and values can sometimes lead to misunderstandings and conflicts within corporate governance structures. Addressing these challenges requires a proactive approach that promotes inclusivity, respect, and open dialogue among all stakeholders.

Overall, understanding and embracing cultural diversity is essential for promoting effective corporate governance. By recognizing the significance of cultural diversity and its impact on decision-making processes and organizational dynamics, companies can position themselves for long-term success in an increasingly diverse and interconnected world.

WHAT IS CULTURAL DIVERSITY?

Culture shapes our beliefs, behaviors, and identity. Cultural diversity refers to the presence of various cultural and ethnic groups within society.

In a workplace context, cultural diversity involves including employees from diverse backgrounds, races, sexual orientations, and political views. This term emphasizes creating an inclusive environment where individuals from different backgrounds collaborate as a unified team.

While discussing the theory and definitions of cultural diversity is straightforward, achieving it within an organization largely depends on the hiring practices employed.[1]

WHY IS CULTURAL DIVERSITY IMPORTANT IN WORKPLACE?

IMPORTANCE

Cultural diversity holds significant importance within workplaces as it fosters a more productive and cohesive environment. When individuals from diverse backgrounds collaborate, they can leverage their unique perspectives to develop innovative solutions, contributing to increased productivity and harmony.

TYPES OF CULTURAL DIVERSITY

Under the umbrella of workplace diversity, various categories play crucial roles:

1. Gender: Incorporating both male and female perspectives enriches decision-making processes and enhances communication and teamwork.

2. Education: A diverse range of educational backgrounds brings valuable insights and skills to companies.

3. Religion: Respect for diverse religious beliefs promotes inclusivity and fosters a respectful workplace environment.

4. LGBTQ+: Creating an inclusive space for LGBTQ+ individuals encourages openness and acceptance, enhancing workplace culture.

5. Race and Ethnicity: Embracing individuals from different cultural backgrounds improves communication and promotes diverse perspectives and values.

6. Age: Addressing age-related biases reduces conflicts and encourages collaboration among employees of different age groups.

7. Disabilities: Ensuring accessibility and valuing unique insights from individuals with disabilities enhances workplace inclusivity.

8. Mental Health: Prioritizing employee well-being fosters better performance and morale, contributing to overall productivity.[2]

BENEFITS

The benefits of cultural diversity in the workplace are manifold:

1. Skill Development: Encouraging diverse perspectives facilitates skill enhancement, boosting efficiency and morale.
   1. Recruitment Improvement: Diverse perspectives aid in identifying new talent and creating an inclusive recruitment process.
   1. Talent Retention: Valuing diversity promotes employee loyalty and longevity within the company.
   1. Enhanced Creativity: Cultural diversity sparks creativity by offering varied perspectives and fostering collaboration.
   1. Increased Engagement: Employees feel more connected to the company’s mission in a diverse environment, leading to greater engagement and innovation.
   1. Improved Reputation: Businesses with diverse workforces are viewed positively and attract top talent.
   1. Higher Productivity: Culturally diverse teams are more productive due to their ability to share ideas and solve problems effectively, leading to increased efficiency and fulfillment.[3]

CORPORATE GOVERNANCE

Corporate governance encompasses the set of regulations, procedures, and mechanisms guiding the direction and oversight of companies. It involves managing relationships among various stakeholders, such as shareholders, management, directors, employees, customers, and the wider community.[4]

According to the Cadbury Report[5], corporate governance is defined as the structure through which companies are managed and overseen, emphasizing principles like accountability, fairness, transparency, and responsibility.

The World Bank[6] defines corporate governance as concerning the structure through which companies are managed and supervised, aiming for increased accountability, efficiency, and transparency to build trust and confidence. This perspective highlights the roles of boards, shareholders, and stakeholders in promoting sustainable business practices.

Overall, corporate governance aims to enhance business integrity, reinforce investor confidence, and stimulate sustainable growth by promoting ethical behavior, accountability, and prudent decision-making within organizations.

LEGAL PERSPECTIVES ON CULTURAL DIVERSITY IN CORPORATE GOVERNANCE

LEGAL FRAMEWORKS AND COMPLIANCE

Delving into the multitude of legal frameworks and compliance requirements concerning cultural diversity within corporate governance, it becomes evident that companies must adeptly navigate and adhere to these regulations and guidelines to ensure fairness and inclusivity in their operations.

A notable example of such regulation can be found in the Companies Act of India, where Section 149[7] mandates diversity initiatives within corporate boards. This includes the requirement for certain classes of companies to appoint at least one woman director, underscoring the importance of gender diversity. Additionally, the Securities and Exchange Board of India (SEBI) has issued guidelines urging listed companies to disclose their diversity policies and report on their implementation.

Similar regulations exist in other countries worldwide. For instance, the United States Securities and Exchange Commission (SEC) mandates companies to disclose board diversity information in their annual proxy statements. In Australia, the Australian Securities Exchange (ASX) Corporate Governance Principles and Recommendations[8] encourage the adoption of diversity policies and the reporting of progress in achieving diversity objectives.

For companies operating in culturally diverse environments, navigating these diverse legal frameworks and compliance mechanisms is crucial. Adhering to relevant regulations and guidelines enables companies to foster inclusivity, fairness, and transparency within their corporate governance structures, ultimately bolstering their reputation and sustainability.

BOARD COMPOSITION AND DIVERSITY POLICIES

The importance of diverse board compositions and the establishment of diversity policies within corporate governance are critical considerations from a legal perspective, impacting the organizational structure and decision-making processes of companies globally.

In India, regulations like Section 149[9] of the Companies Act, 2013, require certain companies to appoint at least one woman director to their board, promoting gender diversity. Additionally, SEBI urges listed firms to disclose diversity policies covering gender, ethnicity, age, and expertise, fostering diverse perspectives in boardrooms. Internationally, similar initiatives exist to promote diversity in board composition. For instance, in the United States, the Securities and Exchange Commission (SEC)[10] requires companies to disclose information about board diversity in their annual proxy statements.

In Europe, directives proposed by the European Commission aim to enhance gender balance on corporate boards, with countries like Norway implementing quotas for female representation. The UK Corporate Governance Code[11] also emphasizes the significance of diversity within board composition and encourages companies to report on diversity policies and targets.

Addressing issues such as quotas and disclosure requirements, diversity policies play a crucial role in shaping board compositions and ensuring equitable representation across different cultural backgrounds. By adhering to legal mandates and proactively implementing diversity initiatives, companies can strengthen their governance structures, enhance decision-making processes, and foster a culture of inclusivity and transparency within their organizations.

CHALLENGES IN IMPLEMENTATION

Identifying and addressing legal challenges in implementing cultural diversity initiatives within corporate governance structures is essential for ensuring effective integration and adherence to regulatory requirements.

• Recruitment, training, and promotion practices pose significant challenges in fostering cultural diversity within organizations. Legal considerations arise concerning fair hiring practices to avoid discrimination based on cultural background or ethnicity.
• Implementing diversity training programs requires careful navigation of legal frameworks to ensure compliance with anti-discrimination laws and regulations.
• Moreover, promoting diversity in promotion practices entails mitigating biases and ensuring equitable opportunities for advancement across cultural backgrounds. Legal safeguards are necessary to prevent discriminatory practices in performance evaluations and succession planning processes.

Addressing these challenges requires proactive measures and strategic interventions aligned with legal requirements and best practices. Companies may need to revise recruitment policies, enhance diversity training programs, and implement robust monitoring mechanisms to ensure compliance with legal standards.

Additionally, legal considerations extend to the development and enforcement of diversity policies. Companies must navigate legal frameworks to establish effective diversity policies that promote inclusivity while adhering to regulatory requirements and industry standards.

Overall, recognizing and overcoming legal challenges in implementing cultural diversity initiatives within corporate governance structures is imperative for fostering an inclusive and equitable organizational culture. By addressing these challenges proactively and in accordance with legal frameworks, companies can promote diversity, enhance organizational dynamics, and foster sustainable growth.

ROLE OF CORPORATE LAW

Corporate law plays a pivotal role in shaping diversity initiatives within corporate governance, ensuring equitable representation across different cultural backgrounds. In India, corporate legislation mandates certain requirements aimed at promoting diversity and inclusivity within corporate boards and structures.

Under the Companies Act, 2013, specific provisions address board composition and diversity. For instance, Section 149 mandates the appointment of at least one woman director on the board of certain classes of companies, aiming to enhance gender diversity and representation. This statutory requirement reflects the legislative intent to foster gender inclusivity and equitable participation of women in corporate decision-making processes.[12]

Furthermore, corporate law in India provides guidelines and regulations pertaining to disclosure requirements related to board diversity policies. The Securities and Exchange Board of India (SEBI) has issued guidelines urging listed companies to formulate and disclose their diversity policies, covering aspects such as gender, ethnicity, age, and expertise. Compliance with these disclosure requirements ensures transparency and accountability in promoting diversity within corporate governance structures.

Additionally, Indian corporate law addresses issues of corporate governance and accountability, which are integral to diversity initiatives. By enforcing principles of transparency, fairness, and accountability, corporate law reinforces the importance of diversity in enhancing board effectiveness and decision-making processes.

Moreover, case law and precedent-setting decisions further shape the role of corporate law in regulating diversity initiatives. Legal precedents serve as guiding principles for interpreting and applying diversity-related regulations, ensuring consistent enforcement and adherence to legal standards across corporate entities.

In summary, corporate law in India plays a crucial role in regulating diversity initiatives within corporate governance, promoting equitable representation, transparency, and accountability in decision-making processes. Compliance with legal requirements and adherence to best practices contribute to fostering a culture of inclusivity and diversity within Indian corporate entities.

JURISDICTIONAL VARIANCES AND GLOBAL STANDARDS

Exploring jurisdictional variances in legal approaches to managing cultural diversity in corporate governance reveals a diverse landscape influenced by regional regulations and emerging global standards.

In different parts of the world, countries have implemented varying legal frameworks addressing cultural diversity within corporate governance. For example, European countries like Norway have adopted quotas for female representation on corporate boards, aiming to promote gender diversity.[13] In contrast, other jurisdictions may prioritize voluntary diversity initiatives over regulatory mandates.

Furthermore, emerging global standards, such as those outlined by the International Organization for Standardization (ISO), provide guidelines for promoting diversity and inclusion within organizations worldwide. ISO standards, such as ISO 26000 on social responsibility, emphasize the importance of diversity and non-discrimination in corporate governance practices, encouraging companies to adopt inclusive policies and practices.[14]

Despite efforts to promote global standards, jurisdictional variances persist, reflecting differences in cultural norms, legal systems, and socio-economic contexts. For example, countries with robust anti-discrimination laws may approach cultural diversity differently than those with less stringent regulations.

Navigating these jurisdictional variances requires companies to adapt their diversity initiatives to comply with local legal requirements while aligning with broader global standards. By understanding regional regulations and emerging global trends, companies can develop tailored strategies to promote cultural diversity within their corporate governance structures while mitigating legal risks and ensuring compliance with applicable laws.

COMPLIANCE AND REGULATORY CONSIDERATIONS

In the United States, the legal landscape regarding cultural diversity in corporate governance is primarily shaped by federal laws, state regulations, and industry-specific guidelines. While federal laws such as the Civil Rights Act of 1964[15] prohibit discrimination based on race, color, religion, sex, or national origin, there are no specific federal mandates regarding board diversity. However, regulatory bodies like the Securities and Exchange Commission (SEC) require companies to disclose information about board diversity in their annual proxy statements, encouraging transparency and accountability.

Similarly, in the United Kingdom, regulatory bodies such as the Financial Reporting Council (FRC)[16] oversee corporate governance practices, including diversity initiatives. The UK Corporate Governance Code emphasizes the importance of diversity within board composition and encourages companies to report on their diversity policies and targets. Additionally, the UK government has set voluntary targets for increasing female representation on corporate boards, aiming to address gender disparities in leadership positions.

In India, corporate governance regulations address board composition and diversity through provisions in the Companies Act, 2013. Section 149 mandates the appointment of at least one woman director on the board of certain classes of companies, promoting gender diversity. Additionally, the Securities and Exchange Board of India (SEBI) has issued guidelines urging listed companies to disclose their diversity policies and report on their implementation, fostering transparency and accountability.

While the regulatory landscape varies across jurisdictions, companies operating in culturally diverse environments must navigate compliance issues and regulatory considerations to promote inclusivity and equity within their corporate governance structures. By adhering to relevant regulations and guidelines, companies can demonstrate their commitment to diversity and contribute to a more inclusive business environment.

RISK MANAGEMENT AND LITIGATION

In the realm of corporate governance, managing cultural diversity entails recognizing and mitigating associated risks, including those related to potential litigation.

• Companies face legal liabilities if they fail to address cultural diversity challenges adequately, which can manifest in various forms, such as discrimination lawsuits, reputational damage, and regulatory penalties.
• Discrimination lawsuits may arise if employees or stakeholders perceive unfair treatment based on cultural backgrounds, leading to legal action against the organization.
• Reputational damage can occur if a company’s diversity practices are perceived as inadequate or discriminatory, resulting in negative publicity and loss of stakeholder trust.
• Regulatory penalties may be imposed if companies violate anti-discrimination laws or fail to comply with diversity-related regulations, leading to fines or sanctions from regulatory authorities.

To mitigate these risks, organizations must adopt proactive risk management strategies tailored to address cultural diversity challenges effectively.

• These strategies may include implementing robust diversity training programs, establishing clear diversity policies and procedures, and fostering an inclusive corporate culture that values and respects cultural differences.
• Additionally, companies should conduct regular audits and assessments to identify potential areas of risk and take corrective actions promptly.

By prioritizing risk management in the context of cultural diversity, organizations can minimize legal liabilities, safeguard their reputation, and promote a more inclusive and equitable workplace environment.

Ultimately, proactive risk management efforts contribute to enhancing corporate governance practices and ensuring compliance with legal requirements while fostering a culture of diversity and inclusion within the organization.

BEST PRACTICES AND RECOMMENDATIONS

Cultural diversity presents both opportunities and challenges within corporate governance structures. To effectively navigate these complexities, companies can adopt best practices and recommendations informed by legal frameworks and industry insights. The following points outline key strategies for promoting cultural diversity and inclusion within organizations:

1. Implement Comprehensive Diversity Training Programs: Effective diversity training programs are essential for promoting cultural understanding and inclusivity within corporate governance. These programs should be tailored to the specific needs of the organization and provide education on topics such as unconscious bias, cultural sensitivity, and respectful communication.
2. Establish Clear Diversity Policies and Objectives: Companies should develop transparent diversity policies that outline their commitment to fostering a diverse and inclusive workplace. These policies should set measurable objectives for achieving diversity goals, such as increasing representation of underrepresented groups in leadership positions.
3. Foster Inclusive Leadership: Leadership plays a crucial role in promoting diversity and inclusion within corporate governance. Executives and board members should actively champion diversity initiatives, led by example, and create an environment where all voices are heard and valued.
4. Encourage Diverse Talent Pipeline Development: Companies should prioritize building a diverse talent pipeline through targeted recruitment strategies, partnerships with diversity-focused organizations, and outreach programs aimed at underrepresented groups. This ensures a pool of qualified candidates from diverse backgrounds for leadership positions.
5. Conduct Regular Diversity Audits and Assessments: Regular audits and assessments of diversity initiatives help companies identify areas for improvement and track progress towards diversity goals. These evaluations should involve collecting data on workforce demographics, analyzing promotion and retention rates, and soliciting feedback from employees.
6. Promote Cross-Cultural Collaboration and Mentorship: Encouraging cross-cultural collaboration and mentorship programs can foster understanding and support among employees from different backgrounds. Pairing employees with mentors from diverse backgrounds can provide valuable guidance and opportunities for professional development.
7. Leverage Employee Resource Groups (ERGs): Employee resource groups (ERGs) provide forums for employees to connect, share experiences, and advocate for diversity and inclusion within the organization. Companies should support and leverage ERGs to amplify diverse voices and drive meaningful change.
8. Ensure Accountability and Transparency: Companies should hold themselves accountable for diversity goals and progress by regularly reporting on diversity metrics and initiatives to stakeholders. Transparency builds trust and demonstrates a commitment to creating an inclusive corporate culture.
9. Continuously Educate and Adapt: Cultural diversity is dynamic and requires ongoing education and adaptation. Companies should stay informed about emerging diversity issues, evolving legal requirements, and best practices in diversity management to remain proactive and responsive to changing societal norms and business imperatives.

CONCLUSION

In conclusion, cultural diversity in corporate governance is not just a matter of compliance but a strategic imperative for businesses in today’s globalized world. Embracing diversity fosters innovation, enhances decision-making processes, and promotes inclusivity, ultimately driving organizational success. Despite the legal complexities and challenges involved, companies can leverage best practices and recommendations to navigate these issues effectively.

By prioritizing diversity training, establishing clear policies, fostering inclusive leadership, and embracing cross-cultural collaboration, companies can create environments where diversity thrives. Continuous education, adaptation, and accountability are key to sustaining diversity efforts and ensuring long-term success in corporate governance. Ultimately, by recognizing the significance of cultural diversity and its profound impact, companies can position themselves as leaders in fostering inclusive and equitable workplaces for the future.

REFERENCES

1. Jayson Darby, The Importance of Cultural Diversity in the Workplace, THOMAS (Apr. 22, 2024), https://www.thomas.co/resources/type/hr-blog/importance-cultural-diversity-workplace.
2. What is the Importance of Cultural Diversity in the Workplace?, BARRAISER (Apr. 22, 2024), https://www.barraiser.com/blogs/cultural-diversity-in-the-workplace#:~:text=Cultural%20diversity%20in%20the%20workplace%20has%20been%20shown%20to%20improve,a%20more%20collaborative%20work%20environment.
3. What is corporate governance? Your 2024 guide!, IMD (Apr. 08, 2024), https://www.imd.org/reflections/what-is-corporate-governance-the-ultimate-guide.
4. The Cadbury Report, ICAEW, (Apr. 08, 2024), https://www.icaew.com/-/media/corporate/files/library/subjects/corporate-governance/financial-aspects-of-corporate-governance.ashx?la=en.
5. Corporate Governance, THE WORLD BANK (Apr. 08, 2024), https://www.worldbank.org/en/topic/financialsector/brief/corporate-governance#:~:text=The%20corporate%20governance%20group%20is,strengthening%20their%20corporate%20governance%20frameworks.
6. The Companies Act, 2013, § 149, No. 18, Acts of Parliament, 2013 (India).
7. ASX Corporate Governance Council, Corporate Governance Principles and Recommendations,  4th ed. (2019), https://www.asx.com.au/documents/asx-compliance/cgc-principles-and-recommendations-fourth-edn.pdf.
8. Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Securities and Exchange Commission – Frequently Asked Questions, SEC (Apr. 23, 2024), https://www.sec.gov/files/OMWI-DAR-FAQ.pdf.
9. UK Corporate Governance Code (2024), FRC (Apr. 23, 2024), https://www.frc.org.uk/library/standards-codes-policy/corporate-governance/uk-corporate-governance-code/.
10. The Norwegian Code of Practice for Corporate Governance, Section 9, NUES  Social responsibility – Discovering ISO 26000 (2010), ISO (Apr. 23, 2024), https://www.iso.org/publication/PUB100258.html.
11. Civil Rights Act of 1964; 7/2/1964; Enrolled Acts and Resolutions of Congress, 1789 – 2011; General Records of the United States Government, Record Group 11; National Archives Building, Washington, DC.

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[1] Jayson Darby, The Importance of Cultural Diversity in the Workplace, THOMAS (Apr. 22, 2024), https://www.thomas.co/resources/type/hr-blog/importance-cultural-diversity-workplace.

[2] What is the Importance of Cultural Diversity in the Workplace?, BARRAISER (Apr. 22, 2024), https://www.barraiser.com/blogs/cultural-diversity-in-the-workplace#:~:text=Cultural%20diversity%20in%20the%20workplace%20has%20been%20shown%20to%20improve,a%20more%20collaborative%20work%20environment.

[3] Ibid,

[4] What is corporate governance? Your 2024 guide!, IMD (Apr. 08, 2024), https://www.imd.org/reflections/what-is-corporate-governance-the-ultimate-guide.

[5]   The Cadbury Report, ICAEW, (Apr. 08, 2024), https://www.icaew.com/-/media/corporate/files/library/subjects/corporate-governance/financial-aspects-of-corporate-governance.ashx?la=en. 

[6]   Corporate Governance, THE WORLD BANK (Apr. 08, 2024), https://www.worldbank.org/en/topic/financialsector/brief/corporate-governance#:~:text=The%20corporate%20governance%20group%20is,strengthening%20their%20corporate%20governance%20frameworks.

[7] The Companies Act, 2013, § 149, No. 18, Acts of Parliament, 2013 (India).

[8]  ASX Corporate Governance Council , Corporate Governance Principles and Recommendations,  4th ed. (2019), https://www.asx.com.au/documents/asx-compliance/cgc-principles-and-recommendations-fourth-edn.pdf.

[9] Supra note 7.

[10] Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Securities and Exchange Commission – Frequently Asked Questions, SEC (Apr. 23, 2024), https://www.sec.gov/files/OMWI-DAR-FAQ.pdf.

[11] UK Corporate Governance Code (2024), FRC (Apr. 23, 2024), https://www.frc.org.uk/library/standards-codes-policy/corporate-governance/uk-corporate-governance-code/.

[12] Supra note 7.

[13] The Norwegian Code of Practice for Corporate Governance, Section 9, NUES (Apr. 23, 2024), https://nues.no/eierstyring-og-selskapsledelse-engelsk/#:~:text=In%20the%20case%20of%20a,company%20subject%20to%20specific%20rules.&text=Both%20genders%20must%20be%20represented%20on%20the%20board%20of%20directors.&text=The%20chief%20executive%20of%20a,of%20its%20board%20of%20directors.

[14] Social responsibility – Discovering ISO 26000 (2010), ISO (Apr. 23, 2024), https://www.iso.org/publication/PUB100258.html.

[15] Civil Rights Act of 1964; 7/2/1964; Enrolled Acts and Resolutions of Congress, 1789 – 2011; General Records of the United States Government, Record Group 11; National Archives Building, Washington, DC.

[16] Supra note 11.

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