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        PG&E Corporate Responsibility and Sustainability Report 2018

        PG&E Chapter 11 Update

        Global Reporting Initiative

        PG&E is committed to continuous improvement when it comes to how we report our impacts and sustainable business strategies, and we use the Global Reporting Initiative (GRI) as an important guide and reference point. The table below shows how this report aligns with GRI’s Sustainability Reporting Guidelines, and was developed in accordance with a core adherence level. While we are working to meet the GRI reporting protocols, we currently only partially meet the recommended standard for several indicators below.

        General Standard Disclosures

        G4 Indicator Description 2019 Report Location
        Strategy and Analysis
        G4-1 Statement from the most senior decision-maker Message from the CEO and President
        G4-2 Description of key impacts, risks, and opportunities Materiality
        Key Sustainability Indicators
        Organizational Profile
        G4-3 Name of the organization Home Page
        G4-4 Primary brands, products, and/or services PG&E Overview
        G4-5 Location of organization’s headquarters PG&E Overview
        G4-6 Countries in which the company has operations PG&E Overview
        G4-7 Nature of ownership and legal form PG&E Overview
        G4-8 Markets served PG&E Overview
        G4-9 Scale of the reporting organization PG&E Overview
        PG&E Corporation and Pacific Gas and Electric Company 2018 Annual Report (PDF)
        G4-10 Gender breakdown of employees Diversity & Inclusion
        G4-11 Percentage of employees covered by collective bargaining agreements Employee Engagement
        G4-13 Significant changes during reporting period of organization’s size, structure, ownership or supply chain PG&E Chapter 11 Update
        G4-EU1 Installed capacity (MW) PG&E Overview
        G4-EU2 Net energy output (GWh) PG&E Overview
        G4-EU3 Number of residential, industrial, institutional, and commercial customer accounts PG&E Overview
        G4-EU4 Length of transmission and distribution lines PG&E Overview
        G4-EU5 Allocation of CO2-e emissions allowances PG&E Corporation’s Climate Change 2018 Information Request response, pgs. 96-97
        Commitments to External Initiatives
        G4-14 Explanation of whether and how the precautionary approach or principle is addressed by the organization Risk Management
        Ethics and Compliance
        G4-15 Externally developed economic, environmental, and social charters Engaging Stakeholders
        G4-16 Memberships in associations Public Policy Engagement
        Climate Change
        Identified Material Aspects and Boundaries
        G4-17 Operational structure of the organization PG&E Overview
        G4-18 Process for defining report content Materiality
        G4-19 Material aspects identified Materiality
        G4-20
        G4-21
        Boundaries of material aspects Throughout the report, when we refer to “PG&E” we are discussing all of PG&E Corporation and its subsidiaries, including Pacific Gas and Electric Company. For specific issues, data and discussion about other entities—such as suppliers or customers—may be disclosed.
        G4-22 Explanation of the effect of any re-statements of information provided in earlier reports No significant re-statements of information
        G4-23 Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report No significant changes in scope, boundary or measurement methods
        Stakeholder Engagement
        G4-24 Stakeholder groups engaged by the organization Engaging Stakeholders
        G4-25 Identification and selection of stakeholders Engaging Stakeholders
        G4-26 Approaches to stakeholder engagement Engaging Stakeholders
        Integrating Sustainability
        Materiality
        G4-27 Key topics and concerns raised through stakeholder engagement Engaging Stakeholders
        Integrating Sustainability
        Materiality
        Report Profile
        G4-28 Reporting period Home Page; 2018–2019
        G4-29 Date of most recent previous report October 2018
        G4-30 Reporting cycle Integrating Sustainability; Annual
        G4-31 Contact point for questions regarding the report Feedback
        G4-32 GRI index GRI Index
        This report contains Standard Disclosures from the GRI Sustainability Reporting Guidelines.
        G4-33 Policy and current practice with regard to seeking external assurance for the report PG&E has not sought external assurance of its Corporate Responsibility and Sustainability Report. However, some data (such as greenhouse gas emissions) are third-party verified; where this is the case, it is noted in the report.
        Governance
        G4-34 Governance structure of the organization, including committees overseeing sustainability Corporate Governance
        Integrating Sustainability
        G4-35 Process for delegating sustainability authority from board to executives Integrating Sustainability
        G4-36 Executive-level position over sustainability efforts Integrating Sustainability
        G4-37 Stakeholder consultation process on sustainability topics Engaging Stakeholders
        G4-38 Composition of the highest governance body and committees 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 35
        G4-39 Indicate whether the Chair of the highest governance body is an executive officer 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 33
        G4-40 Process for determining the composition, qualifications, and expertise of the members of the highest governance body. 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 36–38
        G4-41 Processes for the highest governance body to ensure conflicts of interest are avoided 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 37
        G4-42 Roles in updating company sustainability statements and goals Integrating Sustainability
        G4-44 Processes for evaluating the highest governance body’s own performance PG&E Corporate Governance Guidelines (PDF)
        G4-46 Board oversight of sustainability risk management Integrating Sustainability
        G4-47 Frequency of the highest governance body’s review of sustainability issues Integrating Sustainability
        G4-48 Highest committee or position that formally reviews and approves the organization’s sustainability report This report has been approved by PG&E Corporation’s CEO and President, as well as the company’s officers.
        G4-51 Linkage between compensation and the organization’s performance Integrating Sustainability
        G4-52 Process for determining remuneration 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 46–75
        G4-53 How stakeholders’ views are sought and taken into account regarding remuneration Corporate Governance
        G4-56 Corporate mission and values, codes of conduct and principles Integrating Sustainability
        Risk Management
        Corporate Governance
        Ethics and Compliance
        G4-57 Mechanisms for seeking advice on ethical and lawful behavior Ethics and Compliance
        PG&E Compliance and Ethics
        G4-58 Mechanisms for reporting concerns about unethical or unlawful behavior Ethics and Compliance
        PG&E Employee Code of Conduct—How to Raise Concerns

        Specific Standard Disclosures

        Material Aspect G4 Indicator Description 2019 Report Location
        Economic
        Economic Performance Disclosure of Management Approach (G4-DMA) PG&E Corporation and Pacific Gas and Electric Company 2018 Annual Report (PDF)
        G4-EC1 Direct economic value generated and distributed PG&E Overview
        G4-EC2 Financial implications and other risks and opportunities for the organization’s activities due to climate change Climate Change
        G4-EC3 Coverage of the organization’s defined benefit plan obligations PG&E Corporation and Pacific Gas and Electric Company 2018 Annual Report (PDF), p. 135–137
        Indirect Economic Impacts Disclosure of Management Approach (G4-DMA) Integrating Sustainability
        Energy Affordability
        Community Investments
        G4-EC7 Development and impact of infrastructure investments and services provided primarily for public benefit Community Investments
        G4-EC8 Understanding and describing significant indirect economic impacts, including the extent of impacts Community Investments
        Nuclear Operations
        Availability and Reliability Disclosure of Management Approach (G4-DMA) Renewable Energy
        G4-EU10 Planned capacity against projected electricity demand over the long term Renewable Energy
        Demand-Side Management Disclosure of Management Approach (G4-DMA) Customer Energy Efficiency
        Demand Response
        Research and Development Disclosure of Management Approach (G4-DMA) Electric Operations
        Plant Decommissioning Disclosure of Management Approach (G4-DMA) Nuclear Operations
        Environmental
        Energy Disclosure of Management Approach (G4-DMA) Renewable Energy
        Customer Energy Efficiency
        Buildings and Facilities
        G4-EN3 Energy consumption within the organization PG&E Overview
        Renewable Energy
        Buildings and Facilities
        G4-EN4 Energy consumption outside of the organization PG&E Overview
        Renewable Energy
        G4-EN6 Energy saved due to conservation and efficiency improvements Customer Energy Efficiency
        Buildings and Facilities
        G4-EN7 Initiatives to provide energy-efficient or renewable-energy-based products and services, and reductions in energy requirements as a result of these initiatives Engaging Customers
        Energy Affordability
        Customer Energy Efficiency
        Demand Response
        Solar and Distributed Generation
        Renewable Energy
        Water Disclosure of Management Approach (G4-DMA) Water
        G4-EN8 Total water withdrawal by source Water
        G4-EN9 Water sources significantly affected by withdrawal of water Water
        Hydroelectric Operations
        Natural Resource Stewardship
        Biodiversity Disclosure of Management Approach (G4-DMA) Natural Resource Stewardship
        G4-EN12 Description of significant impacts of activities, products, and services on biodiversity Natural Resource Stewardship
        G4-EN13 Habitats protected or restored Natural Resource Stewardship
        Emissions Disclosure of Management Approach (G4-DMA) Climate Change
        Buildings and Facilities
        G4-EN15 Direct greenhouse gas emissions (Scope 1) Climate Change
        G4-EN16 Indirect greenhouse gas emissions (Scope 2) Climate Change
        G4-EN17 Other relevant indirect greenhouse gas emissions (Scope 3) Climate Change
        G4-EN18 Greenhouse gas emissions intensity Climate Change
        G4-EN19 Reduction of greenhouse gas emissions Climate Change
        G4-EN21 NOX, SOX, and other significant air emissions by type and weight Buildings and Facilities
        Effluents and Waste Disclosure of Management Approach (G4-DMA) Compliance
        Buildings and Facilities
        G4-EN22 Total water discharge by quality and destination Water
        G4-EN23 Total weight of waste by type and disposal method Buildings and Facilities
        G4-EN24 Total number and volume of significant spills Compliance
        G4-EN25 Weight of transported, imported, exported or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III and VIII Buildings and Facilities
        Products and Services Disclosure of Management Approach (G4-DMA) Renewable Energy
        G4-EN27 Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation Renewable Energy
        Hydroelectric Operations
        Conventional Sources
        Nuclear Operations
        Customer Energy Efficiency
        Demand Response
        Solar and Distributed Generation
        Natural Resource Stewardship
        Compliance Disclosure of Management Approach (G4-DMA) Compliance
        G4-EN29 Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations Compliance
        Transport Disclosure of Management Approach (G4-DMA) Greening Our Fleet
        G4-EN30 Significant environmental impacts of transporting products and other goods and materials used for the organization’s operations, and transporting members of the workforce Greening Our Fleet
        Supplier Environmental Assessment Disclosure of Management Approach (G4-DMA) Supply Chain Sustainability
        G4-EN32 Percentage of new suppliers screened using environmental criteria Supply Chain Sustainability
        Social
        Employment Disclosure of Management Approach (G4-DMA) Employees
        Career Pathways
        Workforce Safety
        G4-LA1 Total number and rate of employee turnover by age group, gender and region Career Pathways
        G4-LA2 Benefits provided to full-time employees that are not provided to temporary or part-time employees Health and Wellness
        Our Benefits
        G4-EU15 Percentage of employees eligible to retire in the next five years Career Pathways
        Labor/Management Relations Disclosure of Management Approach (G4-DMA) Employee Engagement
        Occupational Health and Safety Disclosure of Management Approach (G4-DMA) Safety Culture
        Workforce Safety
        G4-LA6 Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region Workforce Safety
        Training and Education Disclosure of Management Approach (G4-DMA) Career Pathways
        G4-LA10 Programs for skills management and lifelong learning Career Pathways
        Employees - Introduction
        Diversity and Equal Opportunity Disclosure of Management Approach (G4-DMA) Diversity and Inclusion
        G4-LA12 Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity Diversity and Inclusion
        2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement (PDF), p. 20–29
        Local Communities Disclosure of Management Approach (G4-DMA) Engaging Stakeholders
        Anti-Corruption Disclosure of Management Approach (G4-DMA) Ethics and Compliance
        G4-SO4 Communication and training on anti-corruption policies and procedures Ethics and Compliance
        G4-SO5 Confirmed incidents of corruption and actions taken Ethics and Compliance
        Public Policy Disclosure of Management Approach (G4-DMA) Public Policy Engagement
        G4-SO6 Total value of financial and in-kind contributions to political parties, politicians, and related institutions Public Policy Engagement
        Compliance Disclosure of Management Approach (G4-DMA) Ethics and Compliance
        G4-SO8 Monetary value of significant fines for noncompliance with laws and regulations PG&E Overview
        Disaster/Emergency Planning and Response Disclosure of Management Approach (G4-DMA) Public Safety
        Customer Health and Safety Disclosure of Management Approach (G4-DMA) Public Safety
        Product and Service Labeling Disclosure of Management Approach (G4-DMA) Customers and Communities
        G4-PR5 Results of surveys measuring customer satisfaction Engaging Customers
        Customer Privacy Disclosure of Management Approach Public Safety
        Access Disclosure of Management Approach (G4-DMA) Energy Affordability
        G4-EU28 Power outage frequency Electric Operations
        G4-EU29 Average power outage duration Electric Operations
        G4-EU30 Average plant availability factor by energy source Conventional Sources
        Nuclear Operations
        Provision of Information Disclosure of Management Approach (G4-DMA) Public Safety
        Engaging Customers

        Economic

        Economic Performance
        Disclosure of Management Approach (G4-DMA)
        PG&E Corporation and Pacific Gas and Electric Company 2018 Annual Report (PDF)
        G4 Indicator
        G4-EC1
        Description
        Direct economic value generated and distributed
        2019 Report Location
        PG&E Overview
        G4 Indicator
        G4-EC2
        Description
        Financial implications and other risks and opportunities for the organization's activities due to climate change
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EC3
        G3.1 Indicator
        EC3
        Description
        Coverage of the organization’s defined benefit plan obligations
        2019 Report Location
        PG&E Corporation and Pacific Gas and Electric Company 2018 Annual Report (PDF), p. 135–137
        Indirect Economic Impacts
        Disclosure of Management Approach (G4-DMA)
        Integrating Sustainability
        Energy Affordability
        Community Investments
        G4 Indicator
        G4-EC7
        Description
        Development and impact of infrastructure investments and services provided primarily for public benefit
        2019 Report Location
        Community Investments
        G4 Indicator
        G4-EC8
        Description
        Understanding and describing significant indirect economic impacts, including the extent of impacts
        2019 Report Location
        Community Investments
        Nuclear Operations
        Availability and Reliability
        Disclosure of Management Approach (G4-DMA)
        Renewable Energy
        G4 Indicator
        G4-EU10
        Description
        Planned capacity against projected electricity demand over the long term
        2019 Report Location
        Renewable Energy
        Demand-Side Management
        Disclosure of Management Approach (G4-DMA)
        Customer Energy Efficiency
        Demand Response
        Research and Development
        Disclosure of Management Approach (G4-DMA)
        Electric Operations
        Plant Decommissioning
        Disclosure of Management Approach (G4-DMA)
        Nuclear Operations

        Environmental

        Energy
        Disclosure of Management Approach (G4-DMA)
        Renewable Energy
        Customer Energy Efficiency
        Buildings and Facilities
        G4 Indicator
        G4-EN3
        Description
        Energy consumption within the organization
        2019 Report Location
        PG&E Overview
        Renewable Energy
        Buildings and Facilities
        G4 Indicator
        G4-EN4
        Description
        Energy consumption outside of the organization
        2019 Report Location
        PG&E Overview
        Renewable Energy
        G4 Indicator
        G4-EN6
        Description
        Energy saved due to conservation and efficiency improvements
        2019 Report Location
        Customer Energy Efficiency
        Buildings and Facilities
        G4 Indicator
        G4-EN7
        Description
        Initiatives to provide energy-efficient or renewable-energy-based products and services, and reductions in energy requirements as a result of these initiatives
        2019 Report Location
        Engaging Customers
        Energy Affordability
        Customer Energy Efficiency
        Demand Response
        Solar and Distributed Generation
        Renewable Energy
        Water
        Disclosure of Management Approach (G4-DMA)
        Water
        G4 Indicator
        G4-EN8
        Description
        Total water withdrawal by source
        2019 Report Location
        Water
        G4 Indicator
        G4-EN9
        Description
        Water sources significantly affected by withdrawal of water
        2019 Report Location
        Water
        Hydroelectric Operations
        Natural Resource Stewardship
        Biodiversity
        Disclosure of Management Approach (G4-DMA)
        Natural Resource Stewardship
        G4 Indicator
        G4-EN12
        Description
        Description of significant impacts of activities, products, and services on biodiversity
        2019 Report Location
        Natural Resource Stewardship
        G4 Indicator
        G4-EN13
        Description
        Habitats protected or restored
        2019 Report Location
        Natural Resource Stewardship
        Emissions
        Disclosure of Management Approach (G4-DMA)
        Climate Change
        Buildings and Facilities
        G4 Indicator
        G4-EN15
        Description
        Direct greenhouse gas emissions (Scope 1)
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EN16
        Description
        Indirect greenhouse gas emissions (Scope 2)
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EN17
        Description
        Other relevant indirect greenhouse gas emissions (Scope 3)
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EN18
        Description
        Greenhouse gas emissions intensity
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EN19
        Description
        Reduction of greenhouse gas emissions
        2019 Report Location
        Climate Change
        G4 Indicator
        G4-EN21
        Description
        NOX, SOX, and other significant air emissions by type and weight
        2019 Report Location
        Buildings and Facilities
        Effluents and Waste
        Disclosure of Management Approach (G4-DMA)
        Compliance
        Buildings and Facilities
        G4 Indicator
        G4-EN22
        Description
        Total water discharge by quality and destination
        2019 Report Location
        Water
        G4 Indicator
        G4-EN23
        Description
        Total weight of waste by type and disposal method
        2019 Report Location
        Buildings and Facilities
        G4 Indicator
        G4-EN24
        Description
        Total number and volume of significant spills
        2019 Report Location
        Compliance
        G4 Indicator
        G4-EN25
        Description
        Weight of transported, imported, exported or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III and VIII
        2019 Report Location
        Buildings and Facilities
        Products and Services
        Disclosure of Management Approach (G4-DMA)
        Renewable Energy
        G4 Indicator
        G4-EN27
        Description
        Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation
        2019 Report Location
        Renewable Energy
        Hydroelectric Operations
        Conventional Sources
        Nuclear Operations
        Customer Energy Efficiency
        Demand Response
        Solar and Distributed Generation
        Natural Resource Stewardship
        Compliance
        Disclosure of Management Approach (G4-DMA)
        Compliance
        G4 Indicator
        G4-EN29
        Description
        Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations
        2019 Report Location
        Compliance
        Transport
        Disclosure of Management Approach (G4-DMA)
        Greening Our Fleet
        G4 Indicator
        G4-EN30
        Description
        Significant environmental impacts of transporting products and other goods and materials used for the organization’s operations, and transporting members of the workforce
        2019 Report Location
        Greening Our Fleet
        Supplier Environmental Assessment
        Disclosure of Management Approach (G4-DMA)
        Supply Chain Sustainability
        G4 Indicator
        G4-EN32
        Description
        Percentage of new suppliers screened using environmental criteria
        2019 Report Location
        Supply Chain Sustainability

        Social

        Employment
        Disclosure of Management Approach (G4-DMA)
        Employees
        Career Pathways
        Workforce Safety
        G4 Indicator
        G4-LA1
        Description
        Total number and rate of employee turnover by age group, gender and region
        2019 Report Location
        Career Pathways
        G4 Indicator
        G4-LA2
        Description
        Benefits provided to full-time employees that are not provided to temporary or part-time employees
        2019 Report Location
        Health and Wellness
        Our Benefits
        G4 Indicator
        G4-EU15
        Description
        Percentage of employees eligible to retire in the next five years
        2019 Report Location
        Career Pathways
        Labor/Management Relations
        Disclosure of Management Approach (G4-DMA)
        Employee Engagement
        Occupational Health and Safety
        Disclosure of Management Approach (G4-DMA)
        Safety Culture
        Workforce Safety
        G4 Indicator
        G4-LA6
        Description
        Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region
        2019 Report Location
        Workforce Safety
        Training and Education
        Disclosure of Management Approach (G4-DMA)
        Career Pathways
        G4 Indicator
        G4-LA10
        Description
        Programs for skills management and lifelong learning
        2019 Report Location
        Career Pathways
        Employees - Introduction
        Diversity and Equal Opportunity
        Disclosure of Management Approach (G4-DMA)
        Diversity and Inclusion
        G4 Indicator
        G4-LA12
        Description
        Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity
        2019 Report Location
        2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy Statement, (PDF), p. 20–29
        Local Communities
        Disclosure of Management Approach (G4-DMA)
        Engaging Stakeholders
        Anti-Corruption
        Disclosure of Management Approach (G4-DMA)
        Ethics and Compliance
        G4 Indicator
        G4-SO4
        Description
        Communication and training on anti-corruption policies and procedures
        2019 Report Location
        Ethics and Compliance
        G4 Indicator
        G4-SO5
        Description
        Confirmed incidents of corruption and actions taken
        2019 Report Location
        Ethics and Compliance
        Public Policy
        Disclosure of Management Approach (G4-DMA)
        Public Policy Engagement
        G4 Indicator
        G4-SO6
        Description
        Total value of financial and in-kind contributions to political parties, politicians, and related institutions
        2019 Report Location
        Public Policy Engagement
        Compliance
        Disclosure of Management Approach (G4-DMA)
        Ethics and Compliance
        G4 Indicator
        G4-SO8
        Description
        Monetary value of significant fines for noncompliance with laws and regulations
        2019 Report Location
        PG&E Overview
        Disaster/Emergency Planning and Response
        Disclosure of Management Approach (G4-DMA)
        Public Safety
        Customer Health and Safety
        Disclosure of Management Approach (G4-DMA)
        Public Safety
        Product and Service Labeling
        Disclosure of Management Approach (G4-DMA)
        Customers and Communities
        G4 Indicator
        G4-PR5
        Description
        Results of surveys measuring customer satisfaction
        2019 Report Location
        Engaging Customers
        Customer Privacy
        Disclosure of Management Approach (G4-DMA)
        Public Safety
        Access
        Disclosure of Management Approach (G4-DMA)
        Energy Affordability
        G4 Indicator
        G4-EU28
        Description
        Power outage frequency
        2019 Report Location
        Electric Operations
        G4 Indicator
        G4-EU29
        Description
        Average power outage duration
        2019 Report Location
        Electric Operations
        G4 Indicator
        G4-EU30
        Description
        Average plant availability factor by energy source
        2019 Report Location
        Conventional Sources
        Nuclear Operations
        Provision of Information
        Disclosure of Management Approach (G4-DMA)
        Public Safety
        Engaging Customers

        Forward-Looking Statements

        This Corporate Responsibility and Sustainability Report contains forward-looking statements regarding our plans, expectations, objectives and forecasts that are based on assumptions and information currently available to management.

        These plans, expectations, objectives and forecasts, and the underlying assumptions on which they are based, are necessarily subject to various risks and uncertainties, the realization or resolution of which may be outside of management’s control. Actual results could differ materially from those expressed or implied in the forward-looking statements. For a discussion of some of the factors that could cause actual results to differ materially, please see our reports filed with the Securities and Exchange Commission (SEC), including our Annual Report on Form 10-K for the year ended December 31, 2018 (the “2018 Annual Report”) our most recent quarterly report on Form 10-Q for the quarter ended June 30, 2019, and our subsequent reports filed with the SEC.

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