VettedCauses

Karma: 164

VettedCauses Apr 21, 2025, 2:40 PM
2 points
0 ∶ 0
in reply to: MichaelDickens’s comment on: Sinergia (ACE Top Charity) is Committing Fraud
Hi Michael,
Thank you for your comment.
Here is the relevant quote from Sinergia Post 1 (note: we didn’t add the bracketed part in this quote, Sinergia did): ^[1]
the latter [number of piglets affected] was stated incorrectly because they didn’t include the same discount. In other words: Sinergia never said the number of piglets was correct. It was an unintentional mistake of Sinergia’s team to leave all piglets, and not only male piglets on the spreadsheet that estimates the number of animals.
To further clarify:
- ACE gave Sinergia credit for helping female piglets through surgical castration commitments — even though female piglets can’t be surgically castrated.
- This issue is what led ACE to reduce Sinergia’s impact calculation from 354 piglets per dollar to 285.
As stated in the ACE Post:^[2]
Vetted Causes states that, “ACE gave Sinergia credit for helping over 30 million female piglets through surgical castration commitments that Sinergia allegedly secured.”
[...]
the impact estimate has been reduced from 354 piglets affected per dollar to 285 piglets affected per dollar.
1. ^
  Sinergia Post 1 - See “Female Piglets Surgical Castration”
2. ^
  ACE Post - See “Issue 3”

VettedCauses Apr 19, 2025, 2:22 AM
−7 points
0 ∶ 4
in reply to: Carolina Galvani - Sinergia Animal’s comment on: Addressing Sinergia’s Response: Factual Corrections
1. JBS Ear Notching—Non-existent commitment, according to Vetted Causes
SINERGIA’S RESPONSE:
Sinergia already explained this is a valid commitment and Vetted Causes was mistaken to classify it as a non-existing commitment. We acknowledge and regret the deadline error in our spreadsheet shared with ACE.
There are two JBS ear notching commitments Sinergia has claimed existed:
- Commitment 1: A commitment from JBS to stop ear notching by 2023.
- Commitment 2: A commitment from JBS to stop ear notching by 2027.
It appears Sinergia and Vetted Causes agree that Commitment 1 never existed.
Note: Sinergia is currently being credited for Commitment 1 even though it never existed.
2. JBS Gestation Crates—Pre-existing Policy Presented As a New Commitment, according to Vetted Causes
SINERGIA’S RESPONSE:
[...]
2021 Report:
“New projects adopt the ‘cobre e solta’ system, allowing the sows, after being artificially inseminated, to be housed in group housing.”
It appears Sinergia and Vetted Causes agree that this is a pre-existing policy being presented as a new commitment. The policy was already in place in 2021, yet Sinergia claimed it as a new 2023 win.
It’s also worth noting that many of the commitments Sinergia takes credit for don’t use definitive language like “100%” or “all farms.” For example, Alibem’s surgical castration commitment from Row 4 states Alibem will: “Maintain immunocastration instead of surgical castration – a procedure that was voluntarily eliminated from the Company’s protocols in 2010.” (translated from Portuguese to English).
Sinergia took 70% credit for this 2010 policy even though Sinergia didn’t exist until 2017. Further, there is no mention of “100%” or “all farms.”
Additionally, Sinergia’s own “Upper bound” for how many companies will actually follow through on their commitments is just 65% (see Cell B14), which shows many of these commitments are not reliable or permanent. JBS themselves has already walked back their ear notching commitment (see Page 42) .
3. Teeth Clipping—Practice Was Already Illegal Prior to Alleged Commitments, according to Vetted Causes
SINERGIA’S RESPONSE:
[...]
It is also important to clarify that Sinergia Animal did not, at any point, discourage ACE from considering IN 113 as a basis for assessing legal deadlines
It appears Sinergia and Vetted Causes agree teeth clipping was already illegal prior to the alleged commitments. Here is a quote from Sinergia’s Pigs in Focus report: “According to Normative Instruction 113/2020 (IN 113/2020), teeth clipping is prohibited”.
4. Aurora—Pre-Existing Policy Presented as a New Commitment, According to Vetted Causes
SINERGIA’S RESPONSE:
[…]
The claim that Aurora had a formal and exclusive immunocastration policy prior to 2023 does not align with the timeline of documented changes to the company’s website. On October 24, 2022, Aurora’s webpage underwent two rapid edits, according to Web Archive.
The first edit, at 16:44, introduced the phrase cited by Vetted Causes: “The Cooperative only chooses to adopt immunocastration, as it is a less invasive practice.” However, this version was online for just one minute (if Web Archive is right). At 16:45, the page was edited again, and that second version—which does not contain the language cited by Vetted Causes—is the one that remained publicly available and is the one we referenced in Sinergia’s 2022 Pigs in Focus report.
This is factually incorrect, the edits Sinergia describes did not occur. Every archive of the webpage from October 24, 2022 states: “The Cooperative only chooses to adopt immunocastration, as it is a less invasive practice.” (translated from Portuguese to English)
Here is a screen recording proving this to be the case.
5. BRF—Pre-Existing Policy Presented as a New Commitment, According to Vetted Causes
SINERGIA’S RESPONSE:
[…]
the current 5% is likely to increase in future years.
It appears Sinergia and Vetted Causes agree that Sinergia should not have taken credit for helping 100% of BRF’s sows in 2023 through this commitment when only ~5% were impacted.
6. Female Piglets Surgical Castration
SINERGIA’S RESPONSE: […] Sinergia never said the number of piglets was correct. It was an unintentional mistake of Sinergia’s team to leave all piglets
It appears Sinergia and Vetted Causes agree that:
- ACE’s impact calculations were not correct
- Sinergia and ACE didn’t account for female piglets not being surgically castrated
- Sinergia was incorrectly credited for helping millions of female piglets through surgical castration commitments

VettedCauses Apr 10, 2025, 4:43 PM
3 points
0 ∶ 0
on: Request for Guidance: Following Timeline After Charity Didn’t Object
@Jeff Kaufman 🔸, @Jason, @Toby Tremlett🔹,

Thank you for providing your opinions on this situation. Do you think it is reasonable for us to post our response on April 17? If so, we will notify Sinergia by email.

VettedCauses Apr 10, 2025, 4:01 PM
1 point
1 ∶ 0
in reply to: Jeff Kaufman 🔸’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Thanks for the tip! We’ve implemented it.

VettedCauses Apr 10, 2025, 3:53 PM
1 point
0 ∶ 0
in reply to: Jeff Kaufman 🔸’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Thanks for letting us know! Thankfully there was nothing that important that we covered in black bars.

VettedCauses Apr 10, 2025, 2:40 PM
8 points
0 ∶ 0
in reply to: Jeff Kaufman 🔸’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
How did you get the text of the emails? We didn’t think we posted it or share it with you, and you’ve included information we didn’t think we posted, including the name of a previously anonymous member of Vetted Causes.

VettedCauses Apr 10, 2025, 2:21 PM
−1 points
0 ∶ 0
in reply to: Toby Tremlett🔹’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Maybe I am misunderstanding, I took this email as saying that you were sending them the post before posting in order for them to review, and clarify anything that needs clarifying
The clarifications refers to the 3 clarifying questions we sent (referenced in Email 7):
We didn’t include this image in the list of emails before, but we’ve added it now. Sorry for the confusion!

VettedCauses Apr 10, 2025, 1:02 PM
−2 points
0 ∶ 0
in reply to: Toby Tremlett🔹’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
The assumption is that since you are asking for their response, it’s in their court to tell you how long a response would take.
We think there is a misunderstanding. We never asked Sinergia for a response to our article. We simply told Sinergia we would send them our article before publication.

VettedCauses Apr 10, 2025, 12:47 PM
−2 points
0 ∶ 0
in reply to: Toby Tremlett🔹’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Hi Toby, thank you for your reply.
Here’s the request you’re looking for:
“after reviewing them, we will inform you of the time required to provide our response”.
We’re a bit confused, because the quoted statement — “after reviewing them, we will inform you of the time required to provide our response” — does not request anything from us. It simply says Sinergia will do something.

VettedCauses Apr 10, 2025, 11:48 AM
5 points
0 ∶ 0
in reply to: Jason’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Hi Jason, thank you for your insights. We have decided not to post the article today to respect the charity’s wishes as reasonably as we can.
We did not mention this in our initial post since we did not yet have permission from the charity (Sinergia) to post the emails. Now that we have permission, the full context regarding the “request to check on deadlines” can be found here (we don’t want to strawman what Sinergia meant when they said this).
To me, that is enough to forbear from publishing tomorrow without getting into the lost e-mail issue at all.
Also, to clarify, Sinergia has indicated to us that no email was lost.

VettedCauses Apr 10, 2025, 11:33 AM
0 points
0 ∶ 0
in reply to: Toby Tremlett🔹’s comment on: Request for Guidance: Following Timeline After Charity Didn’t Object
Hi Toby, thank you for your thoughtful reply.
We did not mention this in our initial post since we did not yet have permission from the charity (Sinergia) to post the emails. Now that we have permission, here is additional context.
Our article is about factual corrections to Sinergia’s response to our review of them. We believe our organization has been suffering reputational harm from factually incorrect claims in Sinergia’s response, and we’ve been trying to move quickly to correct the record.
Here’s a brief timeline:
- On March 26, we emailed Sinergia informing them of our plan to publish an article responding to them.
- On March 27, we scheduled a call with Carolina (Sinergia’s director) after she accepted our offer to do one.
- On April 2, we informed Carolina we would need consent to record the call. In response Carolina canceled the call.
- On April 3 (now knowing we wouldn’t be able to ask our clarifications on the call with Carolina), we sent three written clarification questions.
- On April 4, we told Carolina about our plan to publish our response on April 10th, noting that we “want to post our response soon since people are likely wondering why we haven’t responded yet.”
Between April 4 and the morning of April 9, we received no replies from Sinergia to any of our emails. We then sent Sinergia the draft article for their review on the morning of April 9, reiterating the planned April 10 publication date.
It was only after receiving the article that Sinergia responded, stating
we do plan to share in the forum our disappointment that our request to check on deadlines was not accepted. We are likely not to respond to further requests if they are done in the same manner.
However, in our email history, no such request was ever made.
We’d also like to note:
- We offered to show the article to Sinergia more than 24 hours prior to publication, but Sinergia never told us they wanted this.
- Sinergia showed us their response to our review only 24 hours prior to publication, and their response was much longer than our upcoming article.
- Vetted Causes is a small, volunteer-run organization. Sinergia is a multimillion-dollar organization with paid staff. If 24 hours was sufficient for our volunteers, we believed it would be fair for Sinergia as well.
That said, we have decided not to post the article today to respect Sinergia’s wishes as reasonably as we can. We are working with them to coordinate a reasonable timeline for publication.
Thanks again for your feedback — we really appreciate it as we continue improving our process.

VettedCauses Mar 25, 2025, 11:22 PM
1 point
0 ∶ 0
in reply to: akash 🔸’s comment on: Sinergia (ACE Top Charity) Makes False Claims About Helping Millions of Animals
All good, happy to clarify things!

VettedCauses Mar 25, 2025, 9:02 PM
3 points
0 ∶ 0
in reply to: akash 🔸’s comment on: Sinergia (ACE Top Charity) Makes False Claims About Helping Millions of Animals
Hi Akash, thank you for your reply.
In the comment we were responding to, we were asked two questions by @MichaelStJules.
Question 1. Do you think Sinergia and ACE almost certainly have no information you don’t that could lead to different conclusions or interpretations of claims, in ways more favourable to Sinergia and/or ACE?
There are two possible answers to this question:
- Yes, we do think Sinergia and ACE almost certainly have no information we don’t that could lead to different conclusions or interpretations of claims, in ways more favourable to Sinergia and/or ACE.
- No, we do not think Sinergia and ACE almost certainly have no information we don’t that could lead to different conclusions or interpretations of claims, in ways more favourable to Sinergia and/or ACE.
We answered “No.” Could you explain how this suggests we are pre-committed to the belief “Sinergia bad.”?
Question 2. Do you think there’s no room for reasonable disagreement about whether the claims you call false are actually false?
There are two possible answers to this question:
- Yes, we think there’s no room for reasonable disagreement about whether the claims you call false are actually false.
- No, we do not think there’s no room for reasonable disagreement about whether the claims you call false are actually false.
We answered “No.” Could you explain how this suggests we are pre-committed to the belief “Sinergia bad.”?
Finally, if we had answered “Yes” to both of these questions, would you no longer believe we are pre-committed to the belief “Sinergia bad.”? We are confused on what you believe an appropriate response to the questions would have been.

VettedCauses Mar 24, 2025, 6:17 PM
−3 points
1 ∶ 0
in reply to: Rebecca’s comment on: Sinergia (ACE Top Charity) Makes False Claims About Helping Millions of Animals
Hi Rebecca, thank you for your reply.
If this was a “typo” as you suggest:
- Why did Sinergia say the “Transition deadline” for JBS’s alleged ear notching commitment is 2023 in Cell R10?
- Why did Sinergia say JBS “Committed to banning ear notching by 2023” in Cell K10?
- Why did Sinergia take credit for helping millions of JBS’s pigs that they did not (i.e. JBS pigs who have their ears notched from 2023 to 2026)? ^[1]
- Why did ACE not catch this “mistake” when making their calculations and evaluating Sinergia’s work?
- Why did Sinergia not catch this “mistake” when validating ACE’s calculations? In their response, Sinergia claims they validated ACE’s calculations.
- Why is Sinergia now indicating this “mistake” has been fixed, when it has not?
- And most importantly, why did Sinergia/ACE delete Column W (where Sinergia stated that “JBS published in 2023 the commitment to banning ear notching by 2023”) right before publishing their response, and not add any note stating that this cell had been deleted?^[2] Sinergia/ACE added notes for every other edit that was made to Sinergia’s spreadsheet after February 20th, 2025, and this was by far the biggest edit (Column W contained more text than any other column in the spreadsheet, and was completely deleted).
We believe these pervasive issues point towards this not being a typo.
Finally, we’d like to clarify what we think the biggest issue is here. Sinergia’s response states:
- “Sinergia’s Brazilian team, which is native in Portuguese but not English, made a minor mistake in the spreadsheet shared with ACE. It stated “Committed to banning ear notching by 2023,” when it should have said “Committed to banning ear notching in 2023.””
Right before Sinergia published their response, Sinergia/ACE deleted Column W from their spreadsheet, in which Sinergia claimed: “JBS published in 2023 the commitment to banning ear notching by 2023.”^[2] This evidence that was deleted suggests that Sinergia’s “mistake” was not a translation issue like they indicate.
It is completely inappropriate for Sinergia/ACE to delete this evidence right before Sinergia published their response, and not note that this evidence was deleted. Sinergia/ACE added notes for every other edit that was made to Sinergia’s spreadsheet after February 20th, 2025, and this was by far the biggest edit (Column W contained more text than any other column in the spreadsheet, and was completely deleted).
Destruction of evidence is completely inexcusable.
1. ^
  Pig Welfare Commitments Sinergia Allegedly Secured in 2023 - See Cells R10 Through Y10
2. ^
  Sinergia/ACE deleted Column W (which contained Cell W10) shortly before Sinergia published their response. We know that Column W had not been deleted as of 3/15/2025, as we took a screen recording of the spreadsheet on that date (skip to 1:39, notice Column W has not been deleted yet). We know that Column W had been deleted as of 3/20/2025 (the day before Sinergia published their response) since we downloaded the spreadsheet on that date. We also have a recording of Sinergia’s spreadsheet from 3/21/2025 where Column W has been deleted. Sinergia published their response on 3/21/2025.

VettedCauses Mar 22, 2025, 8:28 AM
1 point
0 ∶ 0
in reply to: Carolina Galvani - Sinergia Animal’s comment on: Sinergia (ACE Top Charity) Makes False Claims About Helping Millions of Animals
JBS clearly states in Brazilian Portuguese on its website: “100% da mossa abolida até 2027,” which translates to “100% of ear cropping will be abolished by 2027.”
[...]
Sinergia’s Brazilian team, which is native in Portuguese but not English, made a minor mistake in the spreadsheet shared with ACE. It stated “Committed to banning ear notching by 2023,” when it should have said “Committed to banning ear notching in 2023.” Sinergia acknowledges that this mistake shifts the meaning of the sentence and it has since been corrected.
Although Sinergia downplays this as a “minor mistake,” it results in Sinergia receiving credit for helping millions of JBS’s pigs who were not impacted (i.e. JBS pigs who have their ears notched from 2023 to 2026)..^[1] This is not a “minor mistake.” Further, Sinergia claims that this mistake has been corrected, but all that was fixed was changing the phrase “by 2023” to “in 2023” in Cell K10.^[2] The impact calculations were not fixed, and still incorrectly credit Sinergia for helping millions of JBS’s pigs who were not impacted.^[1]
Sinergia/ACE (meaning Sinergia or ACE) also deleted evidence that suggests this was not a mistake/translation issue. Sinergia’s original spreadsheet contained a cell that included the following statement: “JBS published in 2023 the commitment to banning ear notching by 2023.” This was in Cell W10, but it was deleted right before Sinergia responded. ^[3]
If this was a mistake/translation issue, why did Sinergia know how to use “by” and “in” in Cell W10, but not in the Cell with the alleged mistake? Additionally, why did Sinergia/ACE delete Cell W10 right before you published your response, and not make any note stating Cell W10 was deleted? Column W is the only part of the spreadsheet that has been deleted, and all other changes in the spreadsheet have been explicitly noted in the spreadsheet.
Note: Cell R10 of the spreadsheet further suggests this was not a mistake/translation issue, as it states the “Transition deadline” for the JBS’s alleged ear notching commitment is 2023.
1. ^
  Pig Welfare Commitments Sinergia Allegedly Secured in 2023 - See Cells R10 Through Y10
2. ^
  Pig Welfare Commitments Sinergia Allegedly Secured in 2023 - See Row 10
3. ^
  Sinergia/ACE deleted Column W (which contained Cell W10) shortly before Sinergia published their response. We know that Column W had not been deleted as of 3/15/2025, as we took a screen recording of the spreadsheet on that date (skip to 1:39, notice Column W has not been deleted yet). We know that Column W had been deleted as of 3/20/2025 (the day before Sinergia published their response) since we downloaded the spreadsheet on that date. We also have a recording of Sinergia’s spreadsheet from 3/21/2025 where Column W has been deleted. Sinergia published their response on 3/21/2025.

VettedCauses Mar 3, 2025, 9:17 PM
−2 points
0 ∶ 0
in reply to: conflictaverse’s comment on: Should every strategy be publicly intelligible?
Sorry if it came across like this post was intended to be feedback for you specifically—your post was just one of the most recent examples that came to mind of charity evaluation being done publicly. I have no idea if anything I’m saying here applies in the case of Sinergia.
No worries! The reason we thought you were saying this applies to Sinergia (and our review of them) is because your post says:
people have criticized charities for having publicly facing messages that don’t always align with what the critic thinks is right. This group Vetted Causes (example) is just one recent example of this sort of pattern.
Could you clarify what you meant when you said Vetted Causes is an example of this pattern?
If you think it is always unacceptable to provide false information to the public, even if that’s a part of an organization’s theory of change, I do disagree.
What we asked was if you think it is acceptable for Sinergia to provide the false information that they did about Alibem’s surgical castration practices. Could you please clarify this specific point before we move on to broader points?

VettedCauses Mar 3, 2025, 8:47 PM
−5 points
0 ∶ 2
on: Should every strategy be publicly intelligible?
Hello,
Thank you for your input regarding our Sinergia review.
I would just encourage people to wonder, before they criticize groups whose strategies they don’t understand, if they don’t really have the full picture.
We have criticized Sinergia for providing false information to the public. For example, here is some of the false information Sinergia provided related to Alibem:
On page 30 of Alibem’s 2023 Sustainability Report, Alibem states they will “Maintain immunocastration instead of surgical castration – a procedure that was voluntarily eliminated from the Company’s protocols in 2010.”
However, on page 20 of Sinergia’s Pigs in Focus 2023 Report, Sinergia indicates that in 2022 Alibem had not banned surgical castration, but in 2023 Alibem had banned surgical castration. Further, Sinergia took credit for getting Alibem to ban surgical castration “by 2023” (see Cell K4).
Even if providing this false information to the public leads to strategic advantages (such as more funding for Sinergia), we do not think it is acceptable; especially since this false information is being used to promote Sinergia and encourage donations. We are curious if you disagree.

VettedCauses Feb 24, 2025, 6:37 PM
0 points
0 ∶ 2
in reply to: Dan Wahl’s comment on: Sinergia (ACE Top Charity) Makes False Claims About Helping Millions of Animals
Hi Dan, thank you for your reply.
Alegra’s rating in Pigs in Focus changed from one to three points between 2022 and 2023, so it seems at least plausible that Sinergia helped persuade them to end grinding.
Page 40-41 of Pig Watch 2024 indicates Alegra has not banned teeth grinding, and plans to follow Normative Instruction 113 (which allows teeth grinding in certain circumstances). Alegra is legally required to follow Normative Instruction 113.
Additionally, we noticed that you reference Sinergia’s Pigs in Focus quite a lot, and wanted to caution you that from what we’ve found, Pigs in Focus is not a reliable source.
For example, on page 30 of Alibem’s Sustainability Report, Alibem states they will “Maintain immunocastration instead of surgical castration – a procedure that was voluntarily eliminated from the Company’s protocols in 2010.”
However, on page 20 of Pigs in Focus 2023, Sinergia indicates that in 2022 Alibem had not banned surgical castration, but in 2023 Alibem had banned surgical castration. Further, Sinergia took credit for getting Alibem to ban surgical castration “by 2023” (see Cell K4).

VettedCauses Feb 23, 2025, 8:44 AM
−5 points
1 ∶ 3
in reply to: Jason’s comment on: Sinergia Animal review by Vetted Causes / Animal Charity Evaluators—looking for opinions
Thank you for your feedback, Jason. We may do this in the future, but at this time believe it is best not to.
In the first review we published, ACE admitted to 4 of the problems we identified, and denied 2 of them. These 2 denials were based on the claim that ACE had hidden evaluation criteria that we did not consider in our analysis. ACE’s claim means:
- ACE gave the public incorrect formulas for calculating Achievement Quality Scores, and by extension, Normalized Achievement Scores and Cost-Effectiveness Scores.
- ACE chose to not reveal that these were the incorrect formulas until significant problems with their publicly disclosed formulas were raised.
Giving the public incorrect formulas isn’t just misleading, it’s making false claims. The formula for the circumference of a circle is C = 2 × π × r. If someone claims the formula is C = π × r, this is a false claim.

Additionally, the hidden evaluation criteria ACE has currently disclosed does not even fully address the 2 problems they denied. However, it is possible ACE has additional hidden evaluation criteria they could point to if anyone raised this issue. Unfortunately, there is no limit on how much alleged hidden information a charity could have, and it is impossible for us to determine if alleged hidden information is actually just fabricated evidence.
During the 90 days between ACE’s response to our critique and our Sinergia Review, zero people (other than ourselves) made a comment or a post pointing out any of these issues with ACE’s response. Instead, ACE’s response was upvoted, and we were criticized on our Sinergia Review for not pre-disclosing our critiques with charities. We suspect the criticism was harsher because ACE denied 2 of the problems in our first review as described above.
We would like to avoid these issues coming up again should Sinergia/ACE decide to respond. Thus, at this time we believe it is best to not disclose every problem we are currently aware of. This way if Sinergia/ACE wants to dispute anything on the basis of hidden evaluation criteria, it will have to properly address all of the undisclosed problems we are aware of. This makes it less likely for the excuse of hidden evaluation criteria to work.

VettedCauses Feb 22, 2025, 10:21 PM
−1 points
0 ∶ 0
in reply to: David T’s comment on: Sinergia Animal review by Vetted Causes / Animal Charity Evaluators—looking for opinions
Thanks for your input David!
If it’s true^[1] that some of their figures come from commitments they should have known do not exist and laws they should have known were already changed it would be absolutely fair to characterise those claims as “false”, even if it comes from honest confusion
We would like to clarify something. Sinergia wrote a 2023 report that states “teeth clipping is prohibited” under Normative Instruction 113/2020. Teeth clipping has been illegal in Brazil since February 1, 2021^[1]. In spite of this, Sinergia took credit for alleged commitments leading to alleged transitions away from teeth clipping (see Row 12 for an example).
We prefer not to speculate about whether actions were intentional or not, so we didn’t include this in our report. We actually did not include most of our analysis or evidence in the review we published, since brevity is a top priority for us when we write reviews. The published review is only a small fraction of the problems we found.
1. ^
  See Article 38 Section 2 and Article 54 of Normative Instruction 113/2020.