## sipea2024022

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---

### Introduction: role and scope
- About 700 SOEs, defined as firms in which the central government or sub-national government levels own a minimum stake of 50.1 percent.
- SOEs’ value added is about 5 percent of GDP.
- SOEs account for about 4.1 percent of total employment.
- Analysis covers aggregate fiscal risks and firm-level risks for 15 large SOEs in energy and transportation that together account for about 70 percent of the total liabilities and assets of all SOEs over 2015–21.

### Aggregate perspective: guarantees, contingent liabilities, and fiscal flows
- State-guaranteed debt of SOEs:
  - Explicit state-guaranteed debt averaged 0.5 percent of GDP over 2010–21.
  - Comparison benchmarks: EU average 9 percent of GDP, CESEE average 3.5 percent of GDP (average over 2010–21).
  - Since COVID, EU’s state guarantees of SOEs (as percent of GDP) increased by almost 2 percentage points during 2019–21; Bulgaria’s corresponding increase was 0.3 percentage points.
- Information gaps:
  - Aggregated information on guarantees issued by SOEs themselves is not available; SOE-issued guarantees do not require approval or monitoring by the Ministry of Finance.
- Contingent liabilities:
  - Total outstanding liabilities of government-controlled entities classified outside general government averaged about 12 percent of GDP over 2013–21.
- Government support vs. SOE contributions:
  - Average government support to SOEs over 2017–19 was about 1.5 percent of GDP annually (direct support includes subsidies, equity investments, capital transfers; indirect support includes deferred taxes and exempted dividends; indirect support data not available for 2020).
  - Annual contribution of SOEs to the budget was about 0.2 percent of GDP in 2017–19 — implying a net fiscal support of about 1.3 percent of GDP.
  - In 2020, direct support increased to about 2.5 percent of GDP while revenue contribution fell to less than 0.1 percent of GDP, leading to a deficit of about 2.5 percent of GDP.
- Dividend policy:
  - Budget 2023 increased the dividend ratio to 100 percent from 50 percent, expected to boost budget revenues by 670 million leva (or 0.35 percent of GDP).
  - Budget 2024 maintains a 100 percent dividend policy; the 100 percent assumption is also in the 2025–26 medium-term budget framework.
  - High dividend ratios can improve short-term fiscal revenue but may reduce incentives to improve productivity and profitability and curtail SOEs’ investment capacity.

### Firm-level analysis: profitability, efficiency, liquidity, solvency
- Sample and coverage:
  - Focus on 15 large SOEs (8 energy, 7 transportation). Twelve of these are among the top 15 largest SOEs by assets.
- Profitability metrics:
  - Return on Assets (ROA):
    - Average ROA across these SOEs over 2015–21 varies between -1 percent and 2 percent.
    - Average ROA for private firms in the comparator sample is 10 percent.
    - In 2022, average ROA for SOEs rose to 9 percent vs. 11 percent for private firms (driven by high ROAs for National Electric Company, Kozloduy NPP, and TPP Maritsa Iztok 2); excluding those three, SOE average ROA in 2022 was 2 percent.
    - Median ROA gap between SOEs and private firms remains a 6-percentage point difference over the sample.
  - Return on Equity (ROE):
    - SOEs’ ROE was on average 20 percentage points lower than private firms’ ROE over the sample period.
    - The ROE gap in Bulgaria is larger than the 4 percentage-point gap documented in countries with better governance scores.
- Persistent losses:
  - Over 2015–22, about 6 SOEs made losses on average, including TPP Maritsa Iztok 2, Transport Construction and Recovery, BDZ – Passenger Services, BDZ – Cargo Services, Bulgarian Port Infrastructure, and NRIC.
  - The National Electric Company and other SOEs showed profit spikes in 2021–22 due to high energy prices, but excluding 2021–22 the National Electric Company is another loss-making SOE over 2015–22.
- Efficiency measures:
  - Return on Capital Employed (ROCE): SOEs lag the private sector in efficiency of capital use.
  - Labor costs:
    - Average cost of employees is higher in SOEs than in private firms (gap is getting smaller).
    - Cost of SOEs’ employees is more than 20 percent of operating revenues, which is double the corresponding value in private firms.
- Liquidity and solvency concerns:
  - Current ratio (average 2015–22): about six of the considered SOEs had a current ratio of less than 1, indicating insufficient liquid assets to meet short-term liabilities. These include National Railway Infrastructure Company, TPP Maritsa Iztok 2, National Electric Company, BDZ – Passenger Services, BDZ – Cargo Services, and Transport Construction and Recovery.
  - Consequences of low current ratios and arrears:
    - Accumulation of supplier arrears that were then paid by (bridge) loans and/or state aid.
    - Risk of contagious liquidity problems across SOEs and impact on banking system nonperforming loans (historical precedent referenced).
    - Example: Bulgargaz faced a liquidity crisis in mid-2022 due to low collection of receivables and debt arrears from the Sofia district heating company (high debt/credit turnover time reported in detailed tables).
- Overall assessment:
  - Low profitability and inefficient resource allocation in several key SOEs likely negatively impact overall economy productivity and competitiveness.
  - Liquidity and solvency risks are evident in several key SOEs despite low levels of explicit state-guaranteed debt.

### Solvency risks and observed dynamics (section 15)
- Insolvency and debt dynamics:
  - SOEs with liabilities greater than assets (indicator greater than 100 percent) have negative equity and are technically insolvent.
  - The debt-to-assets ratio has increased over time in several SOEs, including Bulgartransgaz, National Railway Infrastructure Structure, Bulgaria Energy Holding, and Electricity System Operator.
  - Debt-to-assets dynamics can change abruptly: Bulgargaz's ratio rose from about 45 percent in 2019 to above 90 percent in 2022.
  - Combining high debt with low profitability raises concern about ability to service debt and associated fiscal risks.
  - Several SOEs consistently incur heavy losses and have difficulties managing short-term debts, signaling liquidity risks.

### IMF State-Owned Enterprise Health Check Tool and thresholds
- Tool overview:
  - The IMF State-Owned Enterprise Health Check Tool (IMF, 2021) provides a firm-level comprehensive assessment of fiscal risks using metrics of profitability, liquidity, and solvency.
  - Twelve indicators are associated with the three metrics.
  - The tool uses thresholds to define five risk categories for each indicator: Category 1 (low risk) to Category 5 (high risk).
- Key thresholds and benchmark values (as applied in the tool):
  - Profitability thresholds:
    - Return on assets: greater than 7% (low risk); 2% (low-moderate); 0% (moderate); -5% (moderate-high);
    - Return on equity: greater than 18% (low risk); 5% (low-moderate); 0% (moderate); -10% (moderate-high)
    - Cost recovery: greater than 1.5 (low risk); 1.3 (low-moderate); 1.0 (moderate); 0.8 (moderate-high)
  - Liquidity thresholds:
    - Current ratio: greater than 2.0 (low risk); 1.5 (low-moderate); 1.3 (moderate); 1.0 (moderate-high)
    - Quick ratio: greater than 1.2 (low risk); 1.0 (low-moderate); 0.8 (moderate); 0.7 (moderate-high)
    - Debtor turnover days: less than 30.0 (low risk); 40.0 (low-moderate); 50.0 (moderate); 75.0 (moderate-high)
    - Creditor turnover days: less than 30.0 (low risk); 60.0 (low-moderate); 90.0 (moderate); 120.0 (moderate-high)
  - Solvency thresholds:
    - Debt to assets: less than 30% (low risk); 50% (low-moderate); 80% (moderate); 100% (moderate-high)
    - Debt to equity: less than 50% (low risk); 100% (low-moderate); 150% (moderate); 200% (moderate-high)
    - Debt to EBITDA: less than 1.5 (low risk); 2.0 (low-moderate); 3.0 (moderate); 5.0 (moderate-high)
    - Interest coverage: greater than 2.0 (low risk); 1.5 (low-moderate); 1.2 (moderate); 1.0 (moderate-high)
    - Cash interest coverage: greater than 3.0 (low risk); 2.0 (low-moderate); 1.5 (moderate); 1.0 (moderate-high)
    - Debt coverage: greater than 0.8 (low risk); 0.6 (low-moderate); 0.4 (moderate); 0.3 (moderate-high)
- ROE and ROA benchmarking specifics:
  - ROE: SOEs classified in lowest risk category where ROE exceeds median return of private firms, which is about 18 percent on average over 2015–22.
  - Low-to-moderate risk (Category 2) for ROE is set at 5 percent (average of first quartile private ROEs about 7.2 percent and effective rate on government debt 2.9 percent over 2015–21).
  - ROA thresholds for Categories 1 and 2 are the median and the first quartile of private ROA.

### Pre-COVID and post-COVID assessments (firm-level findings)
- Pre-COVID (selected years):
  - About 30 percent of considered SOEs had risk rating above moderate.
  - Sustained low profitability was a concern in six or seven SOEs over the three selected years.
  - About half of SOEs were at high liquidity risks based on current and quick ratios.
  - Solvency risk was a concern for most SOEs, particularly debt-to-EBITDA indicating a risk of inability to service debt.
  - Several SOEs faced low interest cover or high debt-to-equity.
  - Pre-COVID, about five SOEs were identified with moderate to high fiscal risk: National Electric Company (NEK), TPP Maritsa Iztok 2, National Railway Infrastructure Company (NRIC), BDZ – Cargo Services, and Transport Construction and Recovery (TSV).
- COVID period and 2022:
  - COVID shock worsened SOE profitability, but fiscal measures mitigated the effect.
  - SOEs with moderate-to-high risk in 2020–21 are mainly the same as pre-COVID.
  - In 2022, financial performance of almost all SOEs improved significantly, leading to favorable overall rankings of moderate or low-to-moderate risk due to improved profitability.
  - Higher energy prices helped improve positions of previously loss-making energy SOEs.
  - Transportation sector SOEs showed improved profitability, suggesting ability to pass costs to customers.
  - Bulgargaz was the only SOE with moderate-to-high risk ranking in 2022 due to deterioration of profitability caused by impairment of inventories and accrued losses from trade receivables.
  - Data not available for Port Varna and Bulgarian Port Infrastructure (BPI) for 2022.

### Aggregate fiscal implications and key figures
- Despite low state-guaranteed debt, negative net budgetary flows from SOEs coupled with a contingent liability of 12 percent of GDP could lead to long-term fiscal challenges.
- Profitability of major SOEs is far below that of private firms, partially due to resource allocation inefficiencies.

### Key policy implications and recommendations
- Monitor and improve SOEs’ financial performance across profitability, liquidity, and solvency metrics.
- Collect and publish data on guarantees issued by SOEs themselves to ensure proper monitoring of potential fiscal risks.
- Reassess dividend policy:
  - Recognize that sustained 100 percent dividend payout can boost near-term fiscal revenue (670 million leva or 0.35 percent of GDP in 2023) but may undermine SOEs’ investment capacity, productivity, and long-term fiscal sustainability.
  - Improve predictability of dividend policy to avoid dampening investment incentives.
- Address efficiency and governance:
  - Implement measures to improve SOEs’ allocative efficiency (capital and labor), reduce persistent losses among loss-making SOEs, and enhance corporate governance to narrow profitability gaps with private firms.
  - Emphasize reforms in management, oversight, and transparency to increase worker productivity and lower costs, particularly in the electricity sector.
- Strengthen contingency planning and fiscal-risk management:
  - Establish a (digital) unified database, publicly available and frequently updated, on the financial performance of SOEs.
  - Make the budgetary flows between SOEs and the government more transparent.
  - Collect and publish information on guarantees issued by SOEs themselves.
  - Balance dividend policies between government fiscal revenue needs and SOEs’ financial sustainability and productivity; consider enterprises’ need to retain earnings for reinvestment to achieve a solid capital structure and long-term investments.

*Source: BULGARIA: FISCAL RISKS FROM STATE-OWNED ENTERPRISES (International Monetary Fund), content units "1. Shares of SOEs in the Economy" and "15. Several major SOEs have a high debt-to-asset ratio, thus posing a concern on solvency" from sipea2024022.*

### 1. Shares of SOEs in the Economy ______________________________________________________ 3

### 1. Shares of SOEs in the Economy

### Introduction: role and scope
- About 700 SOEs, defined as firms in which the central government or sub-national government levels own a minimum stake of 50.1 percent.
- SOEs’ value added is about 5 percent of GDP.
- SOEs account for about 4.1 percent of total employment.
- Analysis covers aggregate fiscal risks and firm-level risks for 15 large SOEs in energy and transportation that together account for about 70 percent of the total liabilities and assets of all SOEs over 2015–21.

### Aggregate perspective: guarantees, contingent liabilities, and fiscal flows
- State-guaranteed debt of SOEs:
  - Explicit state-guaranteed debt averaged 0.5 percent of GDP over 2010–21.
  - Comparison benchmarks: EU average 9 percent of GDP, CESEE average 3.5 percent of GDP (average over 2010–21).
  - Since COVID, EU’s state guarantees of SOEs (as percent of GDP) increased by almost 2 percentage points during 2019–21; Bulgaria’s corresponding increase was 0.3 percentage points.
- Information gaps:
  - Aggregated information on guarantees issued by SOEs themselves is not available; SOE-issued guarantees do not require approval or monitoring by the Ministry of Finance.
- Contingent liabilities:
  - Total outstanding liabilities of government-controlled entities classified outside general government averaged about 12 percent of GDP over 2013–21.
- Government support vs. SOE contributions:
  - Average government support to SOEs over 2017–19 was about 1.5 percent of GDP annually (direct support includes subsidies, equity investments, capital transfers; indirect support includes deferred taxes and exempted dividends; indirect support data not available for 2020).
  - Annual contribution of SOEs to the budget was about 0.2 percent of GDP in 2017–19 — implying a net fiscal support of about 1.3 percent of GDP.
  - In 2020, direct support increased to about 2.5 percent of GDP while revenue contribution fell to less than 0.1 percent of GDP, leading to a deficit of about 2.5 percent of GDP.
- Dividend policy:
  - Budget 2023 increased the dividend ratio to 100 percent from 50 percent, expected to boost budget revenues by 670 million leva (or 0.35 percent of GDP).
  - Budget 2024 maintains a 100 percent dividend policy; the 100 percent assumption is also in the 2025–26 medium-term budget framework.
  - High dividend ratios can improve short-term fiscal revenue but may reduce incentives to improve productivity and profitability and curtail SOEs’ investment capacity.

### Firm-level analysis: profitability, efficiency, liquidity, solvency
- Sample and coverage:
  - Focus on 15 large SOEs (8 energy, 7 transportation). Twelve of these are among the top 15 largest SOEs by assets.
- Profitability metrics:
  - Return on Assets (ROA):
    - Average ROA across these SOEs over 2015–21 varies between -1 percent and 2 percent.
    - Average ROA for private firms in the comparator sample is 10 percent.
    - In 2022, average ROA for SOEs rose to 9 percent vs. 11 percent for private firms (driven by high ROAs for National Electric Company, Kozloduy NPP, and TPP Maritsa Iztok 2); excluding those three, SOE average ROA in 2022 was 2 percent.
    - Median ROA gap between SOEs and private firms remains a 6-percentage point difference over the sample.
  - Return on Equity (ROE):
    - SOEs’ ROE was on average 20 percentage points lower than private firms’ ROE over the sample period.
    - The ROE gap in Bulgaria is larger than the 4 percentage-point gap documented in countries with better governance scores.
- Persistent losses:
  - Over 2015–22, about 6 SOEs made losses on average, including TPP Maritsa Iztok 2, Transport Construction and Recovery, BDZ – Passenger Services, BDZ – Cargo Services, Bulgarian Port Infrastructure, and NRIC.
  - The National Electric Company and other SOEs showed profit spikes in 2021–22 due to high energy prices, but excluding 2021–22 the National Electric Company is another loss-making SOE over 2015–22.
- Efficiency measures:
  - Return on Capital Employed (ROCE): SOEs lag the private sector in efficiency of capital use.
  - Labor costs:
    - Average cost of employees is higher in SOEs than in private firms (gap is getting smaller).
    - Cost of SOEs’ employees is more than 20 percent of operating revenues, which is double the corresponding value in private firms.
- Liquidity and solvency concerns:
  - Current ratio (average 2015–22): about six of the considered SOEs had a current ratio of less than 1, indicating insufficient liquid assets to meet short-term liabilities. These include National Railway Infrastructure Company, TPP Maritsa Iztok 2, National Electric Company, BDZ – Passenger Services, BDZ – Cargo Services, and Transport Construction and Recovery.
  - Consequences of low current ratios and arrears:
    - Accumulation of supplier arrears that were then paid by (bridge) loans and/or state aid.
    - Risk of contagious liquidity problems across SOEs and impact on banking system nonperforming loans (historical precedent referenced).
    - Example: Bulgargaz faced a liquidity crisis in mid-2022 due to low collection of receivables and debt arrears from the Sofia district heating company (high debt/credit turnover time reported in detailed tables).
- Overall assessment:
  - Low profitability and inefficient resource allocation in several key SOEs likely negatively impact overall economy productivity and competitiveness.
  - Liquidity and solvency risks are evident in several key SOEs despite low levels of explicit state-guaranteed debt.

### Key policy implications and recommendations
- Monitor and improve SOEs’ financial performance across profitability, liquidity, and solvency metrics.
- Collect and publish data on guarantees issued by SOEs themselves to ensure proper monitoring of potential fiscal risks.
- Reassess dividend policy:
  - Recognize that sustained 100 percent dividend payout can boost near-term fiscal revenue (670 million leva or 0.35 percent of GDP in 2023) but may undermine SOEs’ investment capacity, productivity, and long-term fiscal sustainability.
  - Improve predictability of dividend policy to avoid dampening investment incentives.
- Address efficiency and governance:
  - Implement measures to improve SOEs’ allocative efficiency (capital and labor), reduce persistent losses among loss-making SOEs, and enhance corporate governance to narrow profitability gaps with private firms.
- Strengthen contingency planning:
  - Given contingent liabilities (~12 percent of GDP) and the possibility of large ad hoc fiscal support during shocks (e.g., 2.5 percent of GDP support in 2020), reinforce frameworks for fiscal risk identification, reporting, and management for SOEs.

*Source: BULGARIA: FISCAL RISKS FROM STATE-OWNED ENTERPRISES (International Monetary Fund), content unit "1. Shares of SOEs in the Economy".*

### 15.      Several major SOEs have a high debt-to-asset ratio, thus posing a concern on solvency

### 15.      Several major SOEs have a high debt-to-asset ratio, thus posing a concern on solvency

### Solvency risks and observed dynamics
- SOEs with liabilities greater than assets (indicator greater than 100 percent) have negative equity and are technically insolvent.
- Two salient features:
  - The debt-to-assets ratio has increased over time in several SOEs, including Bulgartransgaz, National Railway Infrastructure Structure, Bulgaria Energy Holding, and Electricity System Operator.
  - Debt-to-assets dynamics can change abruptly: Bulgargaz's ratio rose from about 45 percent in 2019 to above 90 percent in 2022.
- Combining high debt with low profitability raises concern about ability to service debt and associated fiscal risks.
- Several SOEs consistently incur heavy losses and have difficulties managing short-term debts, signaling liquidity risks.

### IMF State-Owned Enterprise Health Check Tool (IMF, 2021)
- The tool provides a firm-level comprehensive assessment of fiscal risks using metrics of profitability, liquidity, and solvency.
- Twelve indicators are associated with the three metrics.
- The tool uses thresholds to define five risk categories for each indicator: Category 1 (low risk) to Category 5 (high risk).
- Applying common benchmarks ensures consistent comparisons across SOEs despite industry differences.

### Key thresholds and benchmark values (as applied in the tool)
- Profitability thresholds:
  - Return on assets: greater than 7% (low risk); 2% (low-moderate); 0% (moderate); -5% (moderate-high); (high risk threshold implied beyond listed)
  - Return on equity: greater than 18% (low risk); 5% (low-moderate); 0% (moderate); -10% (moderate-high)
  - Cost recovery: greater than 1.5 (low risk); 1.3 (low-moderate); 1.0 (moderate); 0.8 (moderate-high)
- Liquidity thresholds:
  - Current ratio: greater than 2.0 (low risk); 1.5 (low-moderate); 1.3 (moderate); 1.0 (moderate-high)
  - Quick ratio: greater than 1.2 (low risk); 1.0 (low-moderate); 0.8 (moderate); 0.7 (moderate-high)
  - Debtor turnover days: less than 30.0 (low risk); 40.0 (low-moderate); 50.0 (moderate); 75.0 (moderate-high)
  - Creditor turnover days: less than 30.0 (low risk); 60.0 (low-moderate); 90.0 (moderate); 120.0 (moderate-high)
- Solvency thresholds:
  - Debt to assets: less than 30% (low risk); 50% (low-moderate); 80% (moderate); 100% (moderate-high)
  - Debt to equity: less than 50% (low risk); 100% (low-moderate); 150% (moderate); 200% (moderate-high)
  - Debt to EBITDA: less than 1.5 (low risk); 2.0 (low-moderate); 3.0 (moderate); 5.0 (moderate-high)
  - Interest coverage: greater than 2.0 (low risk); 1.5 (low-moderate); 1.2 (moderate); 1.0 (moderate-high)
  - Cash interest coverage: greater than 3.0 (low risk); 2.0 (low-moderate); 1.5 (moderate); 1.0 (moderate-high)
  - Debt coverage: greater than 0.8 (low risk); 0.6 (low-moderate); 0.4 (moderate); 0.3 (moderate-high)
- ROE benchmarking specifics:
  - SOEs classified in lowest risk category where ROE exceeds median return of private firms, which is about 18 percent on average over 2015–22.
  - Low-to-moderate risk (Category 2) for ROE is set at 5 percent, defined as the average of (i) return of the first quartile of private ROEs (about 7.2 percent) and (ii) the effective rate on government debt (2.9 percent) over 2015–21.
- ROA thresholds for Categories 1 and 2 are the median and the first quartile of private ROA.

### Pre-COVID and post-COVID assessments (firm-level findings)
- Pre-COVID (selected years):
  - About 30 percent of considered SOEs had risk rating above moderate.
  - Sustained low profitability was a concern in six or seven SOEs over the three selected years.
  - About half of SOEs were at high liquidity risks based on current and quick ratios.
  - Solvency risk was a concern for most SOEs, particularly debt-to-EBITDA indicating a risk of inability to service debt.
  - Several SOEs faced low interest cover or high debt-to-equity.
  - Pre-COVID, about five SOEs were identified with moderate to high fiscal risk: National Electric Company (NEK), TPP Maritsa Iztok 2, National Railway Infrastructure Company (NRIC), BDZ – Cargo Services, and Transport Construction and Recovery (TSV).
- COVID period and 2022:
  - COVID shock worsened SOE profitability, but fiscal measures mitigated the effect.
  - SOEs with moderate-to-high risk in 2020–21 are mainly the same as pre-COVID.
  - In 2022, financial performance of almost all SOEs improved significantly, leading to favorable overall rankings of moderate or low-to-moderate risk due to improved profitability.
  - Higher energy prices helped improve positions of previously loss-making energy SOEs.
  - Transportation sector SOEs showed improved profitability, suggesting ability to pass costs to customers.
  - Bulgargaz was the only SOE with moderate-to-high risk ranking in 2022 due to deterioration of profitability caused by impairment of inventories and accrued losses from trade receivables.
  - Data not available for Port Varna and Bulgarian Port Infrastructure (BPI) for 2022.

### Aggregate fiscal implications and key figures
- Despite low state-guaranteed debt, negative net budgetary flows from SOEs coupled with a contingent liability of 12 percent of GDP could lead to long-term fiscal challenges.
- Profitability of major SOEs is far below that of private firms, partially due to resource allocation inefficiencies.

### Conclusions and policy recommendations
- Findings indicate SOE-related factors that can contribute to fiscal risks: low profitability, liquidity constraints, and high liabilities relative to assets raising solvency concerns.
- Recommended actions:
  - Closely monitor SOEs’ financial performance and identify mitigation measures, including:
    - Establishing a (digital) unified database, publicly available and frequently updated, on the financial performance of SOEs.
    - Making the budgetary flows between SOEs and the government more transparent.
    - Collecting and publishing information on guarantees issued by SOEs themselves.
  - Implement reforms to improve SOEs’ financial performance, emphasizing SOE governance—management, oversight, and transparency—to increase worker productivity and lower costs, particularly in the electricity sector.
  - Balance dividend policies between government fiscal revenue needs and SOEs’ financial sustainability and productivity:
    - Consider enterprises’ need to retain earnings for reinvestment to achieve a solid capital structure and long-term investments.
    - Set dividend policy in a predictable manner to reduce uncertainty and increase firms’ incentives to invest.

*Source: IMF staff analysis in "sipea2024022 - 15.      Several major SOEs have a high debt-to-asset ratio, thus posing a concern on solvency."*

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_Source: https://www.imf.org/-/media/files/publications/selected-issues-papers/2024/english/sipea2024022.pdf_