Football Governance: time for an independent commission

CEL speaking LDConf 2014

(click image for video)

Speaking at the Liberal Democrat conference in Glasgow, I called for the establishment of an independent commission, representative of the whole game, to comprehensively review football’s governance to make it more effective, inclusive, and no longer subject to conflicting vested interests.

Moving an amendment to the party’s policy on football, I focused my fire particularly on the FA and the Premier League, drawing on recent experience of their failure to tackle discrimination at high levels in the game:

“So why is the English FA so incapable of addressing this kind of misconduct by leaders within football? It is because their governance is so fatally flawed that it no longer works.”

Of the Premier League, their “governance is so totally woeful, with no proper board structure, no independent oversight, no way to keep under control the man who uttered those vile sexist remarks”

The full text of my speech, which will appeared live on BBC Parliament is:
“Gash”, “Big Titted Broads”, “Klunt”

This is the kind of atrocious sexist language that the Chief Executive of the Premier League used in emails with colleagues.

“You looked rather tanned”, “have you been down a coal mine?”

That is what the chairman of the English FA’s Referees Committee said to a black official at a conference in June.

“Darkie”

That is how the Director of Football at a Premiership side referred to one of his colleagues at their training ground.

And then we had the tirade of racist, sexist, homophobic, and antisemitic language used in texts by former Cardiff City manager Malky Mackay.

Four instances of extreme discrimination by leaders in our national game.

Four examples showing the unreconstructed views still prevalent at the top level of football.

So what did the FA – the governing body and regulator of football in England – do to discipline these senior figures, and demonstrate that their conduct was unacceptable?

What did they do?

Nothing. Absolutely nothing.

They ducked, they dived, they used every excuse, and in each case, they refused to charge these powerful people.

And what happened when one of their independent inclusion advisers dared question the FA’s commitment to fighting discrimination at the top of the game?

They sacked him.

That’s right. The FA did nothing to tackle the institutionalised racism, sexism, homophobia, and antisemitism amongst football’s leaders, but they dismissed the whistleblower who spoke out of his concern about their inaction.

And how do I know?

Because I am the adviser they removed from their inclusion board three weeks ago.

I am the one who addressed Greg Dyke and Heather Rabbatts over the course of nine months pleading for the FA to do more, to allow the inclusion board to lead, to advocate for equality.

I’m the one they ignored, until I was quoted in an interview with a national newspaper comparing failures in football to positive steps taken in other sports.

That’s when they sacked me.

So why is the English FA so incapable of addressing this kind of misconduct by leaders within football?

It is because their governance is so fatally flawed that it no longer works.

The FA is a mass of conflicted interests that are so busy fighting each other that they are unable to properly regulate the sport that is part of the lives of countless millions of people in these islands.

The money brokers of the Premier League want control.

Control so they can continue to dominate the game, bringing in billions of pounds to the top twenty clubs and then occasionally offering a few crumbs from their table to those in the Football League and the grassroots game.

And yet this is the Premier League whose governance itself is so totally woeful, with no proper board structure, no independent oversight, no way to keep under control the man who uttered those vile sexist remarks.

Desperately trying to balance the power of the Premiership are the County Football Associations – the traditional blazer wearing spokesmen for grassroots football. Wonderful well-meaning volunteers who do so much to keep the game going at local level, but who in many cases lack the experience or business savvy to counter the slick money men.

And where are the players and supporters in all of this; those without whom there would be no football?

Well they are relegated to having one seat each on the 120 member FA Council and none on the Board.

And what of women, for whom football is the fastest growing and biggest team sport? Well there are six of them on the FA Council – a whole five percent! There are less than a handful of minority ethnic faces, and there is one man who is openly gay.

That is the wonderfully diverse nature of English football’s leadership.

Riven by conflicting interests.

Totally unrepresentative of society or even the game it regulates.

Completely incapable of tackling discrimination at the top level or even selecting an England men’s team that can win against Costa Rica!

That Conference is why we have brought this amendment before you today.

It calls for a comprehensive independent review of football’s governance.

To provide our national game with strong, effective leadership, no longer tied to the conflicted interests that have constrained it for so long.

I hope I have demonstrated why it is necessary.

Edward Lord is Chair of the London FA Inclusion Advisory Group and a former member of the Football Association’s Inclusion Advisory Board. He is speaking at the Liberal Democrat conference in a personal capacity as a party member and representative of its LGBT equality group. 

Promoting Inclusion in Football: My response to The FA IAB Statement

I am mystified and shocked by the FA’s vituperative statement regarding my removal from its Inclusion Advisory Board, which seems to impugn my personal integrity. As an experienced non-executive director, I have always sought to work in an open and collaborative way with my colleagues both within the FA and beyond. To say otherwise is distressing, defamatory, and wrong.

It is deeply disappointing that the FA, when faced with critical and challenging insights, have chosen to close ranks, exclude, and attack. At a time when the very best of British business is holding a mirror up to itself to ensure the very best talent is reflected at every level of their organisations, the FA remains insular and aloof. Their defensiveness and hostility speaks volumes.

Promoting Inclusion in Football, a statement by Edward Lord

In an astonishing feat of athleticism, Lord actually makes contact with the ball in his first ever attempt at a goal kick. St George's Park. November 2013

Responding to a demand that he stand down from the FA’s Inclusion Advisory Board following his recent interview with the Daily Telegraph, Edward has issued the following statement:

The Football Association should welcome constructive criticism rather than try to silence it. There is no point in appointing external independent advisers and then gagging them from speaking out when controversial issues arise. The FA needs to embrace these challenges as an opportunity to change the culture in our national game, tackling discrimination head on and not being afraid to stand-up to anyone who is sexist, racist, or homophobic, regardless of their position in football.

On that basis, I will not be resigning from the FA’s Inclusion Advisory Board (IAB). I have done nothing wrong and I remain committed to promoting equality and challenging discrimination in football and in all sports and want to carry on doing the job I was appointed to do and for which I remain qualified.

I am saddened that IAB members say they have lost confidence in me.. They took their decision yesterday without having followed any reasonable or just procedure and without having had the benefit of my own testimony in person or the ability to question me directly. Their meeting was called with less than three working days notice and I was already committed to seeing a senior sports regulator at the time the IAB was being held at Wembley.

If it is suggested that I have in any way breached the FA’s rules then this should be independently investigated and then follow the correct procedure set out in the IAB terms of reference, which is either a vote of the full FA Board or a disciplinary hearing under the terms of the FA Council Code of Conduct.

Either way, I would hope to have the courtesy of a full personal hearing before a qualified judicial panel at which I can answer any charges with the benefit of my legal representatives being present. Anything else would be unfair and potentially discriminatory.

In light of these events, I have therefore asked for an urgent meeting with Greg Dyke, Chairman of the FA to discuss these issues. As I said in my Telegraph interview, I regard Greg, who himself is a champion of diversity, as the hope for the future of the FA.

Edward Lord OBE is a member of the Football Association’s Inclusion Advisory Board and Chairman of the London FA’s Inclusion Advisory Group, a role to which he was unanimously re-elected two days ago. He is also Chairman of the Group Board of the Amateur Swimming Association, an Ambassador and Role Model for LGBT charity Stonewall, and has held a number of senior national roles promoting equality and diversity, for which he was appointed an OBE in 2011.

Background

The Chairman of the London FA issued the following statement on Tuesday evening (16 September 2014) supporting Edward’s position on behalf of the county FA’s Inclusion Advisory Group:

“Earlier this evening the London Football Association Inclusion Advisory Group met. At this meeting were people representing a number of different organisations within London as well as the Chairman and Deputy Chairman of the London Football Association and members of its Council, one of whom is also the London FA representative to the Football Association.

This being the first meeting of the season for this group, elections take place and Edward Lord was unanimously elected unopposed to continue his Chairmanship of this group. The group were anxious to place on record their continuing admiration and gratitude for the interest, work and commitment he shows towards their cause.

The recent article in the Daily Telegraph was brought to everyone’s attention by a member of the group and Edward Lord was extensively questioned on this.  Edward  was then requested to leave the meeting for the discussion to continue without him, which he graciously agreed to.  The group then had a full and frank discussion on the article and unanimously endorsed Edward’s explanations as well as fully supporting his remarks.  It is the understanding of the LFA IAG that Edward’s remarks will be discussed by the FA IAB tomorrow and wish you to advise the members of this group of the feelings of the London FA IAG.

Without Edward, and his contributions, the LFA IAG would not be in the very positive position, having completed a number of ground breaking projects that indeed, it is believed, already act as a role model for the rest of the country.”

 

 

Equal in Soccer? As the World Cup reaches its climax, the diversity challenge facing the world’s most popular sport

Originally published on 11 July 2014 by San Francisco based Out & Equal Workplace Advocates, the world’s largest nonprofit organization specifically dedicated to creating safe and equitable workplaces for lesbian, gay, bisexual and transgender people.

By Edward Lord, member of the English Football Association’s Inclusion Board

Association Football (or soccer) is the world’s favourite sport, played by more than 240 million players in 1.4 million teams and 300,000 clubs across the world and that is before you even consider the over a billion fans who support their local and national sides. With that kind of extraordinary reach, it might be assumed that soccer must by its very nature be incredibly inclusive. After all, as a global sport, soccer is played and supported by people representing the vast majority of the world’s nationalities, religions, and racial groups.

And yet, despite this, soccer remains embroiled in controversy for its failure to embrace diversity and make all people feel welcome on the pitch or as spectators in stadia. Accusations of racism on the field and exhibitions of racist and ultra nationalist conduct by fans often discourage people from getting involved in the game as players or supporters.

The FARE Network has just published its report on incidents that took place during the FIFA World Cup in Brazil. It describes 14 occasions in which visiting fans brought their own prejudices, attitudes and ways of supporting football that most fair-minded people would categorise as discriminatory.

The incidents include homophobic abuse, racism, and references to far-right ideologies. In other areas of diversity, soccer is also seriously lacking. With the obvious exception of the United States, women’s football is very much a second class sport compared to the men’s game in most countries. It doesn’t attract anywhere near the same level of media exposure, which has a knock on detrimental impact on public support and commercial sponsorship.

Perhaps this is at least in part due to the sexist attitudes of senior soccer administrators. Who can forget FIFA President Sepp Blatter’s suggestion in 2004 that women footballers should “play in different and more feminine garb than the men, in tighter shorts for example”, let alone the leaked emails of the English Premier League Chief this year in which he referred to women as “gash”.

Disability football is so little thought of that it doesn’t even fall within the ambit of FIFA as soccer’s world governing body, despite blind and cerebral palsy football both being Paralympic sports.

As for LBGT involvement in soccer, we remain in a position where male gay and bisexual professional footballers are too afraid to come out for fear of adverse reaction by fans and their fellow players. Whilst things have certainly moved on since Justin Fashanu’s suicide in 1998, there was certainly not universal acclaim when Thomas Hitzlsperger and Robbie Rogers came out, both after they had retired from the top flight. Similarly, whilst LGBT fan groups are becoming increasing visible, like Arsenal’s Gay Gooners group marching in the London Pride Parade, soccer stadiums often remain intimidating venues for queer supporters.

So it seems that despite its global reach, soccer still has much to do to in order to be a really open and welcoming sport. As in many industries, things will only improve if diversity role models and allies become visible and proactive in their promotion of inclusion within the game. At the same time football authorities need to adopt a zero tolerance approach to discrimination, implementing effective reporting and disciplinary systems that give people confidence that misconduct will be taken seriously and perpetrators will be punished. Team administrators, managers and coaches also have a role to play and will need training so that they can serve as advocates for diversity, creating an inclusive team environment. Only by taking these steps will football be able to justify its claim that it is for everyone.

Edward Lord OBE is a senior sports administrator and an active equality campaigner. He serves on the Inclusion Advisory Board of the English Football Association and is Chair of the Board of the ASA, England’s governing body for swimming, diving, water polo and other aquatic disciplines. He was recognised by Her Majesty Queen Elizabeth II for his work on inclusion in 2011, being made an Officer of the Order of the British Empire

The FA Cup – still football’s best knock-out competition

FA Cup Final 2014

Yesterday’s FA Cup final reminded me what football is all about – not the politics or boardroom intrigue, nor the business wheeling and dealing. Football is about the players and the fans, their passion and determination.

As I travelled to and from Wembley crushed together on the Metropolitan Line amid a sea of folk in amber and black or red and white, I saw their eager anticipation, followed later by the great joy of victory, the resigned courage of defeat, and the genuine happiness of just being at a cup final.

For Arsenal, victory has brought a long awaited return of silverware to their trophy cabinet. For Hull, despite losing 3-2 after being ahead 2-0, they had the excitement of their first ever appearance in an FA Cup Final.

As Premiership sides, both clubs joined the competition in January’s third round proper to get to today’s finals. In total though 737 clubs have participated in the 2013-14 campaign starting with the extra preliminary round in August last year, including some classic giant-killing clashes along the way.

And that is what makes the FA Cup so very special. The opportunity it allows teams at every level of the game to battle it through to meet the ‘big boys’ of the Football League and Premier League and, in some cases, beat them.

Throughout the 885 games in this season’s FA Cup competition it has been the tactics, the skill, the sheer endurance of twenty two players over 90 (or in yesterday’s case almost 130) minutes that made it so attractive, especially as ultimately there must be a winner, be it after a replay, extra time or penalties. The joy of knock-out competitions is that there is everything to play for and there are rarely guaranteed victors and games frequently see surprise results.

The glory of the Premiership and the Champions League – and the huge spoils available to their participants – may have put the FA Cup, once the pinnacle of English football, in the shade. I remain convinced however that the FA Cup remains the greatest club knock-out competition in football and the joyful faces of the fans said that loud and clear to me on this cup final day. Long may it continue.


 

One further thought from the Cup Final, and a very positive one, was how wonderfully diverse the crowd was at Wembley, especially amongst the Arsenal fans. People of all ethnicities, of differing social backgrounds, and with a much improved gender balance were visible in a well behaved and cheerful audience for the match. As a champion of equality and inclusion in football, that made me very happy.

Sexism in Football: Scudamore apology ‘insincere’ and ‘unsustainable’ – is his position now untenable?

In his column in today’s Daily Mail, Charlie Sale reveals not only the names of the other dramatis personae in the Scudamore email saga, but also exposes the text of a message the premier league chief executive sent to his club chairs last Saturday warning them of the forthcoming Sunday Mirror story.

In his note to clubs, Scudamore says of the Sunday Mirror’s story that it:

‘had been obviously timed for our last day for it to cause maximum embarrassment to me and therefore the Premier League. The newspaper is asserting that some of the content is sexist and inappropriate. You will be the judge.”

This seeming refusal to accept that the content of his emails were in fact sexist and inappropriate to my mind completely undermines his public apology, and leads to only one conclusion: that it was insincere and therefore unsustainable in the court of public opinion.

If it is that Richard Scudamore didn’t believe that what he had written was wrong less than a week ago, I think that it is highly unlikely that he has come to that conclusion in any reality since. On that basis it appears to me that his position is now looking untenable.

If Scudamore doesn’t accept the heinous nature of his sexist remarks and the impact they have had, not only on women in the game, but on the perception they create of football’s commitment to equality and inclusion in general, then regrettably I must reach the conclusion that he may be in the wrong job.

Edward Lord is a member of the Football Association’s Inclusion Advisory Board and Chair of the London FA Inclusion Advisory Group, writing in a personal capacity. 

Sexism in Football: Dyke and Fry – what action are you going to take on Scudamore?

As a follow-up on my blog post, I have now written an open letter to the Chairmen of the FA and the Premier League asking what action they are going to take regarding Richard Scudamore’s emails which he has accepted were “inappropriate”.


 

Greg Dyke Esq.

Chairman

The Football Association

 

Anthony Fry Esq.

Chairman

The FA Premier League Limited

 

Dear Chairmen,

Yesterday evening I published a blog post questioning whether the Premier League Chief Executive  Richard Scudamore should face FA disciplinary charges in light of the sexist and discriminatory content of a series of emails reported in the Sunday Mirror.

It appears to me that Richard’s comments must be in breach of FA Rules E3 and E4 and also of the Premier League’s own Anti-Discrimination Policy:

“1. … Football belongs to, and should be enjoyed by, everyone equally. The League shares with the FA a commitment to confront and eliminate discrimination, whether by reason of sex, sexual orientation, race, nationality, ethnic origin, colour, religion of disability.

2.  The League is an equal opportunities employer. It is committed to equality of opportunity within its organisation and to encouraging similar commitment from every other organisation or individual acting within the game.

3. Equality of opportunity means that in none of its activities will the League discriminate against, or in any way treat less favourably, any person on grounds of sex, sexual orientation, race, nationality, ethnic origin, colour, religion or disability. …

4. The League will not tolerate sexual or racially-based harassment or other discriminatory behaviour, whether physical or verbal, and the Board will ensure that such behaviour is met with appropriate disciplinary action whenever it occurs

Moreover, the attitudes that his comments demonstrate beg a series of questions about his own and the Premier League’s commitment to diversity in general and specifically about the role of women in football as players, coaches, officials and leaders.

As a member of the FA’s Inclusion Advisory Board, charged with verifying and monitoring the delivery of English Football’s Inclusion and Anti-Discrimination Action Plan, I would like to ask you both what steps the FA and Premier League intend to take:

  1. To ensure appropriate disciplinary action is taken regarding Richard’s inappropriate and discriminatory remarks; and
  2. To assure women in football that Richard’s comments do not represent institutional sexism within the game and to demonstrate that women are welcome at every level of football, from the dressing room to the boardroom?

I look forward to hearing from you and would, of course, be happy to meet if you would find that to be helpful.

With best wishes,

Yours sincerely,

Edward Lord

Edward Lord is a member of the Football Association’s Inclusion Advisory Board and Chair of the London FA Inclusion Advisory Group, writing in a personal capacity. 

Sexism in Football: “Should Scudamore face FA charges?” asks Inclusion Board Member

This morning’s Sunday Mirror revealed shocking remarks made by Richard Scudamore, Chief Executive of the Premier League and arguably English football’s most powerful leader. Scudamore’s private emails contain a series of totally inappropriate comments about female colleagues and other women which appear to completely undermine his credibility as an advocate for women’s football and draw into question his true views on the role of women in the game.

Others in football, most notably players and coaches, have faced FA charges of bringing the game into disrepute by making discriminatory comments. It will be a test of the Football Association’s strength as a regulator to see if it has the courage to take steps against a figure as significant as Richard Scudamore.

FA Rule E3 states as to the conduct of anyone involved in football:

“(1) A Participant shall at all times act in the best interests of the game and shall not act in any manner which is improper or brings the game into disrepute or use any one, or a combination of, violent conduct, serious foul play, threatening, abusive, indecent or insulting words or behaviour.”

“(2) A breach of Rule E3(1) is an “Aggravated Breach” where it includes a reference to any one or more of the following :- ethnic origin, colour, race, nationality, religion or belief, gender, gender reassignment, sexual orientation or disability.”

FA Rule E4 states:

“A Participant shall not carry out any act of discrimination by reason of ethnic origin, colour, race, nationality, religion or belief, gender, gender reassignment, sexual orientation, disability, age, pregnancy, maternity, marital status or civil partnership….”

On a plain reading of those Rules, there must surely be a case to answer, making Scudamore potentially liable to a charge of improper conduct, aggravated by the clearly discriminatory nature of his comments.

It will now be interesting to see what, if any, steps the FA takes to challenge his conduct. Whether a charge is raised or not, some action must be taken to demonstrate that women are welcome in football, on the field of play, as coaches and officials, and in the leadership of clubs, leagues, and the FA.

Edward Lord is a member of the Football Association’s Inclusion Advisory Board and Chair of the London FA Inclusion Advisory Group, writing in a personal capacity. 

Hughton: Possibly the right decision for Norwich, but definitely a disaster for football’s diversity

The decision to sack a manager is always one of the hardest for a football club board. How many matches without a win do we give him (and regrettably it is always ‘him’) before the axe falls? What will the fans’ and players’ reactions be? Who do we get to replace him in the short and long term? How much is it going to cost to pay him and his coaching team off?

I am sure all of those thoughts will have gone through the minds of directors at Carrow Road in recent days. Ultimately, it has to be the board’s call or that of the owner, depending upon the club’s individual circumstances. And for that, I have no criticism of the Norwich City directors in their decision to call it a day on the management of Chris Hughton. As their statement said “The decision has been taken to give the club the maximum chance of survival.”, an understandable position given Norwich’s standing in the Premiership.

The tragedy of his departure is naturally for Hughton himself, but it is much broader than that. It now leaves English football without a single black or Asian manager in any of the 92 professional clubs. When Chris Powell left Charlton Athletic last month there was natural concern that we had lost a key role model for BAME football coaches who aspire to manage at the highest level. With Hughton’s sacking, there is now no one in the top flight that people can look to and say “Yes, I want to be him.”

I know that around the UK and beyond we have some first class black coaches, many of them former top flight footballers, who would make great club managers. Let’s hope that as chairmen start to look around the talent pool at the end of the season to decide who could bring success to their side in 2014-15, they are willing to embrace diversity in the dug-out as we have embraced it on the pitch. We need Chris Hughton and Chris Powell back in management roles and with them we need to see an ever more diverse group of leaders in our national game.

And thinking of hope, I’m keeping my fingers’ crossed that a chairman somewhere will be offering their manager’s job to the fabulous Hope Powell. I certainly would were I in charge in a club boardroom.

Edward Lord is a member of the Football Association’s Inclusion Advisory Board and chair of the London FA’s Inclusion Advisory Group, writing in a personal capacity.

Another victory for the Lionesses, yet still women’s football remains vastly undervalued

140405 ENG V MTO Brighton FIFA WWC

Yesterday – Saturday 5 April 2014 – I had the privilege of watching England beat Montenegro 9-0 in their FIFA Women’s World Cup qualifier at Brighton’s Amex Community Stadium. It was an exceptional match, full of entertaining and skillful football, played in a spirit of friendship and good humour. Despite the appearance of the scoreline, Montenegro tried hard, with some very effective players, all the more remarkable as their women’s side has only been competing internationally for two years.

The sadness for me was that even with remarkably cheap ticket prices (£5 for adults, £2.50 for concessions), the match attendance was only 8,900, filling a little over a third of the seats in the Amex. Admittedly it was also being covered live on BBC2 and I look forward to learning the viewing figures. But it begs the question, why aren’t these first class international matches attracting the crowds they could? Particularly so when women’s football in the Olympic Games was very popular, with matches almost filling Wembley Stadium. What has happened to those crowds? Why don’t they come to watch England play, let alone the same players in the FA Women’s Super League? The answer is, to my mind, twofold – culture and investment, the latter probably being a follow-on from the former.

The culture of football, and sport generally, is heavily influenced by the press and broadcasters. The British media still don’t regard women’s football – or any women’s sport for that matter – as seriously as they do men’s. In today’s Sunday Times if you were looking for mention of England Women’s victory, you had to wait until page 6 of the Sport section to find – at the bottom of the page – a few hundred words and a small picture of hat-trick scoring Toni Duggan. Now imagine if the England men’s first team had scored such a remarkable victory. Would that have been on page six? No, of course not. It would have occupied two or three pages of the Sports section and probably have been splashed across the front page of the main newspaper as well. It really is time for this outrageous gender bias in sport coverage to be challenged and to change.

But for the media to change their approach to women’s sport, other factors need to change too, not least the way in which national governing bodies demonstrate their commitment to diversity. In 2012, the FA published Game Changer its plan for women’s football 2013-18. This ambitious plan says all the right things and I have absolute faith in its author, the Director of National Game and Women’s Football, Kelly Simmons, ably supported by Head of Women’s Development, Rachel Pavlou, and Head of Women’s Leagues and Competitions, Katie Brazier. What I have less faith in is the FA’s financial investment in the women’s game compared to the men’s. For example, how much was the marketing budget for yesterday’s match? Surely, with a bit more money and imagination, Brighton – known for its liberal culture and diverse population – could have produced more than 8,900 folk in the crowd?

Part of the difficulty though is that the FA’s own stakeholders aren’t overly enthused by women’s football. Even now I’m told that not all 92 professional clubs support women’s and girls’ football through their development activities, let alone have a women’s side bearing the club’s name. Of those that do, far too few invest any serious money in their women’s team, though slowly but surely this appears to be changing with at least Liverpool and Manchester City joining Arsenal in committing proper funding this season. At grassroots level there remain institutional barriers to promoting gender (or any other form of) equality. The leadership of most county FAs is male, pale, and stale and that is then reflected in the membership of the FA’s ruling Council which has only four women out of its over 100 members.

I’m pleased that, through my roles in the FA Inclusion Board and the London County FA, I may have the opportunity to have some influence on changing the culture that undervalues women’s football and the role that women themselves can play in governing our national game. I’m passionate about the vision of Football for Everyone. Now let’s make it a reality.

Edward Lord is a member of the Football Association’s Inclusion Advisory Board and Chair of the London FA Inclusion Advisory Group, writing in a personal capacity.