Friday, June 5, 2015

Workers consider Supreme Court writ

By Kyaw Phone Kyaw   |   Friday, 05 June 2015

More than 150 fired workers from a Yangon garment factory have threatened to petition the Union Supreme Court to get their jobs back, after the national Arbitration Council overturned a decision by the Yangon council ordering their former employer to take them back.

The 158 workers from the Costec garment factory in Yangon’s Shwe Pyi Thar Industrial Zone were fired after going on strike for a K1000-a-day pay rise in January.

They submitted their case to Yangon Region Arbitration Council, which ordered Costec to rehire them. The factory appealed the ruling, however, and on May 28 the national Arbitration Council ruled against the workers because they had been given the opportunity to return to work between February 4 and 6 but turned the offer down.

As a result, the employer does not have a responsibility to rehire them, the council said. It also cited financial problems at the factory as another reason.

The workers say they will ask the council to reconsider the case and if it refuses they will submit a writ of certiorari to the Union Supreme Court in Nay Pyi Taw in order to have the decision reviewed.

Worker Ma Kyal Sin said the workers believed that the council had been unfairly influenced by their employer to overturn the decision by the Yangon council.

She said they did not think the council would overturn its decision, but wanted to avoid a lengthy court case.

“Some of us are facing difficulties with living costs so we want to get back our job at the factory as quick as possible,” Ma Kyal Sin said.

Ko Ye Naing Win, a labour representative on the Arbitration Council, said he was “sad” about the decision but it could not be reversed by the council.

“If they are confused about our decision they can ask questions or they can appeal to the Supreme Court,” he said.

He said that it would be the first time workers had submitted such a writ to the country’s highest legal institution.

A legal adviser to the workers, Ko Saw Kyaw Kyaw Min, said he was working to build a case to support the writ.

Costec factory manager Ma Saw Yu May declined to comment yesterday, saying that the official with the authority to speak to the media was “very busy”.
@kyawphonekyaw

Friday, May 29, 2015

Government to warn ‘illegal’ futures brokers

By Kyaw Phone Kyaw   |   Wednesday, 22 April 2015

The  government is to issue a formal warning to “illegal” online futures trading companies to stop trading once offices reopen at the end of the Myanmar new year holidays today, according to U Maung Maung Thein, deputy minister for finance.
 
Deputy Minister for Finance, Dr. Maung Maung Thein (photo-globalnewlightofmyanmar.com)

“They are not operating in accordance with related laws. And we are seriously afraid that people would be cheated. There is no regulator for futures exchanges. So if people have problems, they can’t sue anybody,” the deputy minister said in an interview with reporters.

According to an investigation by The Myanmar Times, five or six futures exchange brokerage companies operate in Myanmar and most have been established since around mid-2014. They say they provide a service to Myanmar clients to invest in futures exchanges of foreign countries.

Each company serves futures exchanges in individual countries, including New Zealand, Hong Kong, Taiwan and Indonesia. Futures trading is mostly conducted in contracts for commodities such as gold, oil and gas, and timber, as well as foreign currencies.

Experts have warned that online trading in futures contracts is gaining ground in Myanmar without proper regulation and that investors are not fully aware of the potential for large losses.

The deputy minister said the government would serve serious warning notices to the brokerage companies personally. If they did not then stop their business then the government would instruct police to launch criminal investigations and prosecute them, he said.

Futures trading is not provided for under the law in Myanmar which has only enacted the July 2013 securities exchange law. In the prohibition and punishment chapter of the law, section 22 states that no one may operate a business of a stock exchange without permission from the Security Exchange Commission Myanmar, which is chaired by U Maung Maung Thein.

Ma Myat Myat, assistant business manager of Asian E-Trade Consultant (ATC) which acts as a futures exchange broker for the New Zealand Futures Exchange, said the company had both a licence from Myanmar’s Directorate of Investment and Company Administration (DICA) and the recognition certificate from the New Zealand exchange.

Financial advisor Ko Mynn Nyi Nyi of Inter Pan Myanmar, a broker for Indonesia Futures Exchange, also said they had a licence from DICA since August 2014, and that their company provided good opportunities for Myanmar investors.

“Our parent company from Indonesia is 29 years old and is in the top three of ASEAN’s most profitable broker companies for clients,” he added.

The deputy director of DICA, Daw Nilar Mu, said the company licence issued by the department only applies to the use of the company name and is just a form of registration. These licences can be used to compete in tenders, she said. But she noted that such companies also require permission from relevant government organisations, in this case the finance ministry.

Ma Myat Myat from ATC brokerage said the company had made financial deposits with the government, but she did not say how much.

The deputy minister for finance rejected that. “If they give a deposit, I must know about that. But I have never heard about that.”

Two clients who invested through ATC, but asked not to be identified, told reporters they had been able to earn about US$2000 within two or three months. But Ma Myat Myat cautioned that some clients had lost all their investments, up to $10,000.

U Maung Maung Thein warned, “I want to give a message to the people not to give their trust easily and not to be greedy.” He said the ministry would warn the public about the illegal nature of futures trading companies.
 @kyawphonekyaw

DICA licences not enough to allow futures trading, official says

By Kyaw Phone Kyaw   |   Thursday, 09 April 2015

The  Directorate of Investment and Company Administration is registering companies to trade futures online, but it is not responsible for oversight of the business, according to deputy director Daw Nilar Mu.

A number of companies have set up futures brokerages in Myanmar. They allow clients to trade through online platforms on international futures markets though some say the legal situation of some of these businesses are unclear and should be more strictly regulated.

Brokerage companies have said they are cleared to run in Myanmar as they have business registration from the Directorate, but Daw Nilar Mu said yesterday that this is not strictly the case.

“Our department only provides permits for a company’s name and then completes registration. If they want to run their business, they must apply for permission from the relevant government organisation,” she said.

In the case of financial services companies, this generally means permission from a body such as the Central Bank of Myanmar or the Securities and Exchange Commission of Myanmar.

The Securities and Exchange Commission of Myanmar is currently preparing policies and reviewing applicants for the planned Yangon Stock Exchange, which is to launch later this year. Senior commission members could not be reached for comment yesterday.

Businesses involved in online futures trading say they have permission to operate through their Directorate of Investment and Company Administration licences.

Ma Myat Myat, an assistance business manager with Asian E-Trade Consultant Company, a company allowing Myanmar people to trade on the New Zealand futures market, says it has both a business licence from the Directorate of Investment and Company Administration as well as an authorisation letter from New Zealand.

She also said that her firm is not a broker, but merely providing a service for the financial market.

“If someone has K10 million, it is not enough to set up a company. But in our business, it’s enough to invest,” she said. “If clients are able to control their desire, they might profit by K200,000 or K300,000 a day – but it’s not a sure thing.”

Ma Myat Myat said that some of her clients have lost all of their deposit money, as much as US$10,000.

“Some of our clients power off their phone or switch to silent mode, so we can’t tell them market information. At that moment, they lose,” she said. “But we also provide avenues to recover money. It is an advantage of our business.”

She also declined to reveal how many customers she has.
 @kyawphonekyaw

Online futures trading grows along with industry fears

By Kyaw Phone Kyaw   |   Wednesday, 08 April 2015

Online futures trading is taking hold, though the potential for losses is large and trading should be properly regulated, experts warn.

Myanmar people with internet access are able to sign up with a number of local companies that provide online trading platforms. Users can then make trades on futures markets in foreign countries, such as Thailand, Singapore and New Zealand.

At their most basic, futures contracts are agreements to buy an item, such as a commodity, at an up-front price, with delivery at a later, specified date. The contracts are then often heavily traded on international markets, as the underlying item changes in value before the delivery date.

U Zaw Min Tun, managing director of Myanmar Golden Link Trade Company, said there are now five or six local companies that are allowing trading on international futures markets.
When signing up, clients must deposit a start-up amount, usually between US$3000 to $10,000, with the broker companies.

The firms then allow electronic trading on international commodities markets including Indonesia, New Zealand, Thailand, Taiwan and Singapore via mobile apps and computer software.
“Sometimes they [the brokers] say they are authorised by foreign countries, but the question is how they are authorised and whether their mother company from overseas is really operating legally or not,” said U Zaw Min Tun.

Some companies are indeed legal subsidiaries from foreign companies, though clients must be careful to make sure they are covered and that they have legal recourse, he said.
“If the clients invest in them before they ask these questions, problems come when they lose all their money,” he said.
U Zaw Min Tun said he would like to establish a futures market broker named Victory International Future Company, but added he wants legal certainty for the futures market sector and a regulatory body to be formed.
He also highlighted problems, such as a company in Mandalay claiming that for every K150,000 invested by its clients, it would repay K10.8 million, which collapsed shortly afterward.
The growth in these companies allowing clients to trade futures comes as some say the business is largely unregulated.
U Ngwe Thein, a business consultant, said the futures market can be very complicated to understand, with many people not having enough knowledge of how it operates to take part.

“People might be cheated,” he said. “The government has to regulate the rules and laws, and also increase awareness and conduct a lot of training and workshops.

“Now there is no transparency at broker companies. If the government doesn’t make specific and concrete laws and raise public awareness, they [brokers] may cheat the law.”
Myanmar is still at the early stages of setting up modern markets. It has created some of the legal background necessary to launch the Yangon Stock Exchange later this year, though the YSX is intended for selling company shares rather than buying and selling commodity futures.
Private companies have also announced plans to start modern commodities markets in the country, though they will be some time coming.
The local establishment of brokers allowing online commodities trading in foreign markets is a new phenomenon.
The Myanmar Times spoke with representatives from two private companies, Inter Pan Myanmar and Asian E-Trade Consultant Company, which offer these services.
Inter Pan Myanmar financial adviser Ko Mynn Nyi Nyi said they have been providing services to Myanmar clients to invest in Myanmar’s futures market since receiving a company licence from Myanmar’s Directorate of Investment and Company Administration in August 2014.
Ma Myat Myat, an employee of Asian E-Trade Consultant, said it provides access to New Zealand’s futures market for its local clients.
Clients who have jointed Asian E-Trade Consultant say it has been a difficult business.
Two clients, requesting anonymity, told The Myanmar Times they made $10,000 deposits to set up their accounts, and had generated $2000 in profit within two or three months – however, sometimes they see sharp losses. One client said he also pays steep service charges for having the account.
Inter Pan’s Ko Mynn Nyi Nyi said there is a distinction between investing in securities and investing in commodities, arguing that futures trading is more secure.
“If the client invests in a security exchange, after that they can only pray to their God,” he said. “Investments in futures is not like that. The decision is up to themselves and is just like playing a game.”
Ko Myin Nyi Nyi said he was looking for clients looking to make money, rather than “buying a car or opening a restaurant”.
Others urged more caution, however.
U Zaw Min Tun said it is even unclear if their deposits are actually being invested into futures markets or if results are merely replicated and paid out locally.
He also said that there should be more oversight and knowledge regarding futures trading.
“There is no approval,” he said. “But in Myanmar there aren’t always lots of opportunities for investments – that’s why we throng to every investment opportunity.”
While many people are joining up, others say they are more cautious.
Daw Mya Kyin is interested in investment opportunities, such as the futures market, but has decided to watch the situation and has not made a final investment decision just yet.
Several government officials declined to comment on official oversight of these online brokerage companies when contacted.
 @kyawphonekyaw

‘Brain waste’ a fear for Myanmar migrant community

By Kyaw Phone Kyaw   |   Wednesday, 29 April 2015

Myanmar’s skilled and educated are pouring out of the country in search of better-paying jobs, leading to fears of “brain drain and brain waste”, according to the International Labour Organisation.


The results of the ILO’s latest survey, which was based on interviews over two months with 625 people of different races, hometowns and ages, revealed that 22pc of potential migrants have attained a university degree. They expect their qualifications to reap higher dividends abroad, even in low-skill industries.
“It is concern for the country,” the report said.

According to the survey released on April 28, Myanmar’s average migrant falls between the ages of 18 and 24. Only 8pc are over 35 years old.

“Fifty-three percent of potential migrants already had a job,” but found their employment situation to be unfavourable compared to overseas options. The survey took into account three migration-heavy areas: Mandalay, Tanintharyi Region and Shan State. Those from Tanintharyi Region and Shan State were more likely to be jobless prior to migrating, Ben Harkins of the ILO said.

The migrants and would-be migrants looked abroad not only for a higher income, but also for new job opportunities and stable sources of income.

Over half of the potential migrants surveyed intend to go to Thailand or Malaysia, where they expect to earn between $105 and $415 a month. Many of those with a high school degree anticipated salaries upwards of $520.

An overwhelming number of survey respondents (73pc) learn about labour migration options from friends or family members, eschewing labour officials’ assistance.

“Only 1pc of migrants believe that they could obtain correct information from the regional labour office,” the report said.


When faced with problems in the labour migration process, almost half said they would inform family and friends about any grievances. Only 19pc would inform the police, and just 10pc would bother with labour officials.


In search of more information about Myanmar’s migration trends, the ILO opened more than t10 Migrant Resource Centres in Myanmar, according to Jackie Pollock, a technical officer at the ILO in Yangon.

“We need to conduct more research to understand why Myanmar’s young-graduates go overseas for low-level jobs, and if we can put them to work in any jobs better suited to them. If they need more skills, which skills do they need?” she said.

According to the official government figures, more than 3 million Myanmar migrants currently work in Thailand and Malaysia.
 @kyawphonekyaw

ရန္ကုန္၌ ညေဈးတန္း ႏွစ္ခု ဖြင့္မည္

ေက်ာ္ဖုန္းေက်ာ္   |   Wednesday, 13 May 2015



ရန္ကုန္ၿမိဳ႕၌ ညပုိင္း သြားလာလည္ပတ္စရာ နည္းပါးေနမႈကို တစ္စိတ္တစ္ပိုင္းေျဖရွင္းသည့္
အေနျဖင့္ ညေဈးတန္းေလးခုဖြင့္လွစ္ရန္ ၿမိဳ႕ေတာ္စည္ပင္က စီစဥ္ေနေၾကာင္း ရန္ကုန္ၿမိဳ႕ေတာ္
စည္ပင္သာယာေရး ေကာ္မတီ၏ ေဈးမ်ားဌာနမွ သိရသည္။


လက္ရွိတြင္ မဂၤလာေတာင္ညြန္႔ၿမိဳ႕နယ္ရွိ စံျပညေဈးႏွင့္ ၾကည့္ျမင္တိုင္ညေဈးတို႔ကို ဖြင့္လွစ္ထားၿပီး
သဃၤန္းကြ်န္းၿမိဳ႕နယ္ သံသုမာလမ္းႏွင့္ ေလးေထာင့္ကန္လမ္းေထာင့္တြင္ တစ္ခုႏွင့္ ေဒါပံုၿမိဳ႕နယ္
႐ႈခင္းသာလမ္းမေပၚတြင္ တစ္ခုကို ထပ္မံဖြင့္လွစ္ရန္ ၿမိဳ႕ေတာ္စည္ပင္က စီစဥ္ေနသည္။


"ကြ်န္ေတာ္တို႔ ၿမိဳ႕ေတာ္စည္ပင္အေနနဲ႔ အဲဒါေတြ အေကာင္အထည္ေပၚလာဖို႔ ႀကိဳးစားေနပါတယ္။
ဒါေပမဲ့ အခက္အခဲတခ်ဳိ႕ေတာ့ ရွိေနပါတယ္။ အဲဒါကေတာ့ ေရြးခ်ယ္ထားတဲ့ေနရာေတြက
သင့္မသင့္နဲ႔ တခ်ဳိ႕ေဈးသည္ေတြက လာေရာင္းမွာလား မေရာင္းဘူးလား မေသခ်ာတာမ်ဳိးေပါ့။
ေဈးသည္ေတြ လုိအပ္တာေတြကို အကုန္ လုပ္ေတာ့ ေပးေနတာပဲ"ဟု ေဈးမ်ားဌာန၏ ဌာနမႉး
ဦးစံေရႊထြန္းက ေျပာသည္။


ေရာင္းခ်မည့္ ေဈးသည္မ်ားက လွ်ပ္စစ္မီး ေကာင္းမြန္စြာရရွိရန္ႏွင့္ အျခားေသာ အေျခခံ
လိုအပ္ခ်က္မ်ားကို ျဖည့္ဆည္းေပးရန္ လိုလားလ်က္ရွိသည္ဟု သိရသည္။


ထို႔ေၾကာင့္ ျပင္ဆင္ရာတြင္ ညေဈးတန္း တစ္ခုလွ်င္ က်ပ္ သိန္း ၈၀၀ ခန္႔ကုန္က်ခဲ့ရာ
လွ်ပ္စစ္မီးသြယ္တန္းမႈအတြက္ပင္ က်ပ္သိန္း ၃၀၀ ခန္႔ ကုန္က်ေၾကာင္း ဦးစံေရႊထြန္းက ေျပာသည္။
ညေဈးမ်ားဖြင့္လွစ္ရန္ ေနရာေရြးခ်ယ္ရာတြင္ လာေရာက္၀ယ္ယူသူမ်ား လြယ္ကူအဆင္ေျပေရးကို
ဦးစားေပးဆံုးျဖတ္ၿပီး အဆိုပါညေဈးမ်ားေၾကာင့္ ကားလမ္းမ်ား ပိတ္ဆို႔မႈ မရွိႏုိင္ရန္လည္း
ထည့္သြင္းစဥ္းစားခဲ့ရသည္ဟု ဆိုသည္။


ၾကည့္ျမင္တိုင္ ညေဈးတန္း၌ ဖြင့္လွစ္ထားသည့္ ဆိုင္တစ္ဆိုင္ကို ယခုလ ပထမပတ္က ေတြ႕ရစဥ္။ ေအာင္ျမင္ရဲေဇာ္/ျမန္မာတိုင္း(မ္)
သဃၤန္းကြ်န္းၿမိဳ႕နယ္တြင္ ေနထုိင္သည့္ ကိုသန္းထုိက္က ယခုလက္ရွိတြင္ လမ္းေဘးေဈးသည္
မ်ားက ပလက္ေဖာင္းေပၚတြင္ ေဈးေရာင္းေနသျဖင့္ လူမ်ားက ကားလမ္းေပၚတြင္ လမ္းေလွ်ာက္
ေနရသည္ကို ညေဈးတန္းမ်ားက အတုိင္းအတာတစ္ခုအထိ ေျဖရွင္းေပးႏုိင္ရန္ ေမွ်ာ္လင့္ေၾကာင္း
ေျပာသည္။

"ၿမိဳ႕ေတာ္စည္ပင္အေနနဲ႔ ညေဈးတန္းေတြမွာ လူဆိုး၊ လူရမ္းကားေတြ မလာေအာင္၊ မႀကီးစိုးေအာင္
ဘယ္လိုလုပ္မလဲဆိုတာေတာ့ ထည့္စဥ္းစားဖို႔လိုတယ္။ အခု သီရိမဂၤလာေဈးမွာဆုိရင္
အဲဒီလူမိုက္ေတြ ျပႆနာက ခဏခဏျဖစ္ေနေတာ့ ညေဈးတန္းေတြမွာ အဲလိုျဖစ္လာမွာေတာ့
စိုးရိမ္တယ္။
သူတို႔အေနနဲ႔ ရဲေတြနဲ႔ တိုင္ပင္ၿပီး ေသခ်ာအစီအစဥ္ခ်ထားတာမ်ဳိး လုပ္သင့္တယ္"ဟု
၎ကေျပာသည္။

ျမန္မာႏုိင္ငံ ခရီးသြားလုပ္ငန္းရွင္အသင္းမွ အေထြေထြအတြင္းေရးမႉး ဦးေနာင္းေနာင္းဟန္က
ငယ္ရြယ္သည့္ ႏုိင္ငံျခားခရီးသြားမ်ားကို ယခုထက္ ပိုမိုဆြဲေဆာင္ႏုိင္ရန္ ရန္ကုန္ၿမိဳ႕တြင္
သန္႔ရွင္းသပ္ရပ္သည့္ ညေဈးတန္းမ်ားကဲ့သို႔ ညဘက္ လည္ပတ္သြားလာစရာေနရာ
အမ်ားအျပားရွိရန္ လိုအပ္ေနေၾကာင္း ေျပာၾကားခဲ့ဖူးသည္။
@kyawphonekyaw

Developer warns against rumours on paused project

By Myat Nyein Aye, Kyaw Phone Kyaw   |   Wednesday, 13 May 2015

MARGA Landmark has issued a statement clarifying its mixed-use Dagon City One project and warned against what it calls critics spreading wrong information and engaging in groundless speculation.

Dagon City One is one of five projects that have been temporarily suspended by government authorities since February, following public concern that the projects may affect the view of nearby Shwedagon Pagoda or disturb its foundation.

Marga is made up of a number of international and local investors, and is the owner of perhaps the most prominent of the five paused projects in Dagon township. Four other projects – by Thu Kha Yadanar, Shwe Taung Hyday, Shwe Taung Development and Adventure Myanmar – have also been temporarily suspended.
Marga said in the statement that while its plans have been publicly known since receiving Myanmar Investment Commission approval in March 2014 and opening a temporary gallery in June 2014, it only started facing harsh comments and baseless accusation in January 2015, raised by a small number of individuals and parties.
“These individuals and parties had not contacted or reached out to us to find out and clarify the facts,” it said. “They continued telling wrong information and making groundless speculations and allegations in spite of the fact that Dagon City One has been and is following and abiding by the law and the approved plans.”
It added the board of directors of Marga Landmark is prepared to take legal action against individuals who have repeatedly made personal defamatory comments with inaccurate information and prejudice, causing losses to Marga.
While Marga did not name any person or entity in particular in the statement, one of their foremost critics has been U Khin Hlaing, an elected member of Yangon City Development Committee.
He has been one of the most outspoken figures opposing the project, criticising the project in local media. Besides being a YCDC committee member, he is also a publisher, sells religious robes and owns the Myanmar Big Shops Shopping Mall near Shwedagon Pagoda. He told The Myanmar Times on May 11 that he “would absolutely not allow” the project to move forward.
U Khin Hlaing said he is responsible for the district of Yangon containing the project.
“I am vested with authority from the people, and I say no through this authority,” he said. Asked whether he was concerned he may be at risk for legal action as outlined by Marga, he said it was his duty as an elected representative to voice the public’s concerns.
U Khin Hlaing said he was appealing directly to the Tatmadaw to reconsider the long-term lease it had given Marga and the other four developers.
“Please, Tatmadaw, love your land, take back what’s yours and make a beneficial project for the people or for the Tatmadaw that will save Shwedagon Pagoda,” he said.
U Khin Hlaing also said that it was not only Dagon City One but the other four projects that are the target of his criticism.
The five projects are temporarily paused until YCDC gives approval to move forward. Marga says it received initial permission from the Myanmar Investment Commission in March 2014, including for the master plan and height limit of Dagon City One.
“All works have been prepared according to what we have been approved [to do],” it said.
Authorities subsequently paused the five projects in February, and the Myanmar Investment Commission had industry body the Myanmar Engineering Society conduct a review. The society’s review confirmed Dagon City One’s plans are compliant with what has been approved by the Myanmar Investment Commission and YCDC, according to Marga. It added that a special task force was appointed to focus on water drainage and on road systems.
YCDC Department of Engineering deputy director U Nay Win said on May 11 he would not comment on the five suspended projects, as they are still under analysis.Other experts have entered the debate. U Thant Myint-U, a noted historian as well as founder and chair of the Yangon Heritage Trust, tweeted in February that it was a “brave decision” for Yangon government to suspend a project near Shwedagon.
Yesterday, Yangon Heritage Trust vice chair and director Daw Moe Moe Lwin said the organisation welcomed the regional government and MIC’s decision to stop the current works in order to make a full reassessment of the Marga project.
“Being next to the nationally significant Shwedagon Pagoda and other historic religious sites, this project should be considered very carefully for its potential impacts before any decision is made,” she said.
“Any proposed project in the vicinity of the Shwedagon or other important cultural heritage sites must be carefully assessed for their heritage, environmental and social impacts before any decision is made.”
Daw Moe Moe Lwin also said the trust would like to see careful assessments of the long-term impacts of the project. She added that no YHT staff or management has met with representatives of Dagon City or provided advice to the project.
Independent experts said that while the five projects are near sensitive Shwedagon Pagoda, there are many similar instances around the world where construction has taken place near important structures.
U Zaw Zaw Aye, managing director of SEAFCO (Myanmar), a firm with experience building large projects on a contract basis, said experienced designers and firms can build foundations in a way that does not affect other nearby structures. The five paused projects are about 500 metres (1640 feet) from Shwedagon at their closest point.
“If they build near sensitive buildings, care must taken and there must be good plans and designs done with skilled technical engineering – then the projects can be built,” he said.
“In the world, there are so many buildings that are near important buildings, but sensitive construction is still completed.”
He added Shwedagon Pagoda is not only iconic, but a religious site, meaning there are many emotions tied to the project, which may also affect decisions .

Additional reporting by
Jeremy Mullins