This chapter presents the country profile for Cambodia. It provides an overview of the current de jure requirements for the institutions, tools and processes of regulatory governance and, where possible, how these have been implemented in practice. The profile focus on three aspects of regulatory governance pertinent to the past, present and near future of regulatory reforms in the ASEAN region. The first is whole-of-government approaches to regulatory policy making, including national and international commitments to better regulation that are driving domestic reform processes. The second is the use of good regulatory practices, including regulatory impact assessments (RIAs), stakeholder engagement and ex post review. The third is approaches to digitalisation, or how countries are using digital tools to respond to regulatory challenges, and is the newest frontier for better regulation reforms in both ASEAN and OECD communities. The information contained in this and the other profiles serves as the basis for the analysis of trends in regulatory reform presented in Chapter 1.
Supporting Regulatory Reforms in Southeast Asia
4. Cambodia
Abstract
Whole-of-government perspective
Regional focus
Cambodia is a signatory to several treaties that aim to promote trade and investment by reducing unnecessary burdens in trade and investment procedures, and improving regulatory compliance. In 2016, Cambodia ratified the WTO Trade Facilitation Agreement (TFA), which entered into force on 22 February 2017 (ASEAN, 2021[1]). The TFA contains provisions for expediting the movement, release and clearance of goods, as well as measures for effective co-operation between customs and other appropriate authorities on trade facilitation and customs compliance issues (ASEAN, 2021[1]). It is being implemented through ASEAN Regional Integration Support from the European Union (ARISE) Plus Cambodia, which is the Cambodian component of the ARISE Plus 2017-2022 Regional Programme1. This is translated to Cambodia via three components, each with elements of better regulation embedded (ASEAN, 2021[1]):
1. Improving customs, trade facilitation and standards: Project work streams include the Cambodia National Single Window (CNSW), Authorised Economic Operators, pre-arrival processing and product risk management.
2. Strengthening institutional capacities and improving regulatory practices for international trade: Focuses on capacity development of Cambodian government officials for the co-ordination, formulation and implementation of trade-related policies, negotiations and reforms.
3. Enhancing private sector engagement in trade, notably of SMEs: Seeks to enhance the Cambodian private sector’s integration into regional and global value chains by providing SMEs with better access to trade information and public-private dialogue mechanisms, as well as assisting individual SMEs (especially in rural and semi-urban areas) with targeted technical support.
Cambodia has made efforts to integrate the Cambodia National Single Window (CNSW) into the ASEAN Single Window (ASW). The National Single Window Blueprint for the development and implementation of the National Single Window was completed with support of the World Bank in 2014. Since then, Cambodia has conducted a demonstration of the CNSW and required ATIGA e-Form D front-end applications and submitted a request to install ASW Gateway software in 2017 (ASEAN Single Window, n.d.[2]). ATIGA e‑Form D is a certificate of origin for exports and imports within ASEAN, with the objective of expediting the cargo clearance process, reducing costs and time, and of enhancing trade efficiency and competitiveness among ASEAN members through the ASW (Vannak, 2019[3]). Following this procedure, Cambodia joined the ASW Live Operation in December 2019, enabling preferential tariff treatment based upon ATIG E-Form D. Furthermore, in 2020 Cambodia exchanged the ASEAN Customs Declaration Document (ACDD), the next trade document following the success of ATIGA e-Form D aimed at facilitating exchange of Export Declaration Information among AMS, live with Myanmar and Singapore (ASEAN Single Window, 2020[4]).
Cambodia is also a signatory to the Regional Comprehensive Economic Partnership (RCEP), which includes provisions on the use of better regulation and standards. Cambodia ratified RCEP in 2021.
At a ministry level, Cambodia has taken various initiatives to reduce costs of doing business for international traders. These include: 1) Cambodia’s national trade repository (NTR) established by Cambodia’s Ministry of Economy and Finance in 2015, allowing traders to access trade-related information on a comprehensive online portal; 2) www.cambodiaip.gov.kh, the website launched by the Ministry of Commerce in 2014 which allows the public to search for trademarks registered in Cambodia and ASEAN; and 3) the Intellectual Property Automation System (IPAS), which enables trademark examiners to store and search trademark data (WTO, 2017[5]).
National focus
OECD (2018) notes that Cambodia’s Industrial Development Plan 2015-25 aims to improve the regulatory framework for areas including trade facilitation, export promotion, industrial standards, property rights, tax payment, labour market development and industrial relations. As part of the Plan, the government has supported the improvement of customs systems as well as the rollout of Cambodia’s One Window Service Offices (OWSO) (OECD, 2018[6]). The OWSO is an initiative to promote good governance at the sub‑national level, including by bringing public services closer to citizens, providing a platform for complaints, promoting local participation in decision-making, promoting local development and responding to demands for more efficient, transparent and accountable local government. It began in the early 2000s in two trial municipalities, expanding in both 2009 and 2017, now being established in 52 of 197 target localities (Royal Government of Cambodia, 2019[7]). According to the Ministry of the Interior, there are plans to expand the OWSO to all districts nationwide and they have noted positive effects in reducing corruption and facilitating service delivery (Samean, 2021[8]).
The Cambodian National Action Plan for Public Administration Reform 2019-2030 aims to improve public service delivery by instilling a citizen-centric approach.
The Political Platform of the Royal Government of the Sixth Legislature of the National Assembly2 defines strategic goals, prioritised policies, sectoral development policies, and specific measures to be implemented from 2019 onwards to guide the activities of the Royal Government of Cambodia(RGC) in the Sixth Legislature 2018-2023 of the National Assembly. For the Sixth Legislature, the RGC has focused on (Royal Government of Cambodia, 2018[9]):
1. Institutional reform and capacity building,
2. Strengthening accountability and integrity in the public administration,
3. Strengthening of work effectiveness, and
4. Strengthening of private sector governance.
Improving the regulatory framework is a cross-cutting objective. Much of the focus on regulatory reform is in regard to sectoral applications of regulatory policy, with regulatory improvement mentioned as a critical component of areas such as: institutional reform and capacity building; integration into the regional and global economy; preparing for the Digital Economy and the Fourth Industrial Revolution; ensuring environmental sustainability; arranging and implementing the public-private partnership mechanism; and strengthening urban planning and management (Royal Government of Cambodia, 2018[9]).
Improvement of regulatory frameworks is also mentioned in other strategic plans such as the Health Strategic Plan 2016-2020 and the Financial Sector Development Strategic Strategy 2016-2025. More recently, the Small and Medium Enterprise Development Policy and Five-year Implementation Plan 2020‑2024 stipulates enhancing policy and the regulatory environment as one of its objectives. Other objectives of the Plan include promoting productivity, technology and innovation, promoting entrepreneurship and human capital development, enhancing foreign market access and internalisation, and increasing access to finance. (ADB, 2020[10])
Cambodia’s Rectangular Strategy3 guides implementation of the agenda of the Royal Government and selects key elements from the Millennium Development Goals, the Cambodia Socio-Economic Development Program, the Cambodia National Poverty Reduction Strategy, and the various policies, strategies, plans and other important reform programs, all of which have been formulated through broad consultation with all national and international stakeholders – including government ministries and institutions, representatives of civil society and the donor community (Cambodian Corner, n.d.[11]). The Rectangular Strategy currently in progress is the Rectangular Strategy Phase 4, which was published in 2018.
The National Strategic Development Plan (NSDP) 2019-2030 has been formulated for the implementation of the Rectangular Strategy Phase 4 with the objectives of gaining high benefits from ASEAN Economic Integration, moving from a Lower-Middle Income Country to an Upper-Middle-Income Country in 2030 and contributing to the achieving the Cambodian Sustainable Development Goals 2016-2030 (Royal Government of Cambodia, 2019[12]). The NSDP outlines policies and priority actions for 2019-2023 for each relevant ministry to carry out, and presents estimated values as well as the framework for monitoring and evaluation for 2019-2023 Plan (Open Development Cambodia, 2020[13]). The NSDP clearly attaches significant importance to regulations, especially the need for updates to regulations and improve regulatory frameworks. These mostly pertain to priorities in specific policy sectors, as opposed to a whole-of-government approach to improving regulatory policy making.
Good regulatory practices
Regulatory impact assessments
A Regulatory Executive Team was created under the management of Cambodia’s Economic, Social and Cultural Council (ECOSOCC), housed within the Office of the Council of Ministers (OCM). This team is currently co-ordinating the implementation of regulatory impact assessment (RIA) in Cambodia, specifically by providing advocacy information to line ministries on the principles of good practice in regulatory policy making, assist with training of the RIA methodology, and support line ministries in their implementation of RIAs.
The guideline entitled “Procedure and Rule of Draft Law and other Regulations of the Royal Government of Cambodia,” dated 10 May 2013, notes that a draft law contain a Problem Statement, which shall include:
The purpose and spirit of the draft laws and regulations, clearly explaining the essential content and benefits of the introduction of the draft or the reasons for the amendment of laws or regulations.
Reasons and assessment of possible consequences.
Contribution of the draft laws and regulations to the achievements of the Constitution, existing laws, action plans and political programs of the Royal Government and the actual situation of the nation.
Summarise the main chapters, especially the penalties for the draft law.
RIA has gradually been introduced across Ministries in a step-by-step approach and on a voluntary basis, with a scope potentially covering primary and subordinate regulation, such as laws, Royal decrees, sub-decrees and Prakas4 (OECD, 2018[6]). Currently, 18 ministries voluntarily undertake RIA, an increase from 13 at the end of 2016. In addition, 13 300 people have taken part in RIA workshops and conferences, representing government, businesses and community members. Further, 66 RIAs have been completed in Cambodia. Further, Cambodia notes that the pace of implementation of RIAs has slowed down somewhat due to the COVID-19 pandemic. The 2016 Decision to establish RIA working groups in all ministries mandated ECOSOCC to produce an annual report on RIA to the government (OECD, 2018[14]). ECOSOCC provides training and coaching to the line ministries to support the implementation of RIA. Furthermore, the RIA Working Group at the level of line ministries are responsible for implementing RIA.
In addition to formal requirements for RIA, guidelines for impact assessment have also been produced in Cambodia. A Regulatory Impact Assessment Handbook describes the RIA process that applies in Cambodia and the requirements for completing each element of regulatory impact analysis adequately. Moreover, a RIA Pilot Program was in place from October 2011 to December 2018 under ADB funding.
Stakeholder engagement
The “Procedure and Rule of Draft Law and other Regulations of the Royal Government of Cambodia,” dated 10 May 2013, also notes that consultation should be conducted, as needed, with civil society, NGOs and the private sector on technical, social, cultural and political aspects of proposed laws. OECD (2018) notes that the PAS/RIS process intends that the submitted documents may be subject to public consultation. There is also a website for the publication of PAS/RIS, which includes a comment and feedback option and thus provides a mechanism for online consultation, although this is not yet common practice (OECD, 2018[6]).
In Cambodia, two specific mechanisms have been identified for stakeholder consultation for the overall trade and transport facilitation initiatives (Khieng, 2009[15]). The first is the Government Private Sector Forum (G-PSF), which was established in 1999 at the initiative of the Prime Minister of Cambodia to help carry out public consultations on regulatory issues. It was intended to provide a reliable dialogue mechanism for consultation between the government and the private sector on investment climate issues ranging from structural policies to day-to-day operations to encourage private sector initiatives. (CAMFEBA, n.d.[16]) There are ten private sector working groups (PSWGs) that meet to identify common problems and to negotiate solutions with the Government, with the tourism working group being the most developed to date. G-PSF meetings, with the status of an enlarged Cabinet meeting and chaired by the Prime Minister, have generally been held bi-annually (Khieng, 2009[15]).
The second is the Steering Committee for Private Sector Development (SCPSD), composed of seven ministers and chaired by the Minister of Economy and Finance. It was established in 2004 with three Sub‑Steering Committees (SSC): SSC on Investment Climate and Private Participation in Infrastructure, SSC on Trade Development and Trade Related Investment and SSC on SMEs (Khieng, 2009[15]). The Private Sector Development Steering Committee provides opportunities for ongoing dialogue involving the government, private sector, development partners, civil society, and the academic community on the economic reform agenda and ways development partners can assist with implementation (ADB, n.d.[17])
Public consultations to support regulatory policy development nevertheless are neither formalised nor consistent across all sectors.
Ex post review
Administrative burden reduction in Cambodia has been a focus at both the national and regional level. In 2017, Cambodia joined the UNESCAP Framework Agreement on Facilitation of Cross-border Paperless Trade in Asia and the Pacific, which has the objective of promoting cross-border paperless trade by enabling exchange and mutual recognition of trade-related data and electronic documents, and facilitating interoperability among national and sub-regional single windows (WTO, 2017[5]).
Reducing unnecessary regulatory burdens is included as one of the development objectives identified by the RGC in its 2013 Rectangular Strategy, Phase 3, and its National Strategic Development Plan 2014‑2018 (ERIA, 2018[18]). The Rectangular Strategy Phase 4 and the National Strategic Development Plan 2019-2023 also pay attention to cutting unnecessary procedures, particularly to facilitate trade. The Industrial Development Policy 2015–2025 has emphasised improving both the legal environment to enhance competitiveness and the investment climate by promoting trade facilitation, providing market information, and reducing business transactional fees. It specifically set a target to reduce and abolish repetitive and non-transparent procedures (ERIA, 2018[18]).
While there is a general focus on reducing unnecessary regulatory burdens, there is yet to be a specific policy in Cambodia regarding administrative simplification. Nonetheless, OECD (2018) notes that administrative simplification is implemented in a targeted, regulation by regulation way that is driven by identifying needs and is mostly focused on customs clearance and business registration. Development partners have also aided with support for administrative simplification efforts (OECD, 2018[6]).
OECD (2018) notes that there is a methodology for measuring administrative burden in the PAS/RIS process, but this is not how areas of focus are identified. Those have come from international benchmarking or from consultations with development partners that support global best practice areas (OECD, 2018[6]). There is a checklist of compliance costs for PAS/RIS, which includes both costs for the government and costs for businesses.
Monitoring and evaluation of regulatory reduction initiatives have been undertaken on a project-by-project basis (OECD, 2018[6]). There have been examples where progress monitoring has shown significant regulatory improvements resulting from the implementation of good regulatory practice, such as the One Window Service Office. Monitoring mechanisms are also in place in the form of internal audits for the National Strategic Development Plan and the IDP (OECD, 2018[6]).
Digital
The RGC aims to make Cambodia an ICT-driven upper middle-income country by 2030, with several ICT‑related policies, such as the ICT Master Plan (2020), the Industrial Development Policy 2015–2025, the Law on e-Commerce (2019), and Consumer Protection Law (2019) currently in force (ADB, 2020[19]). More recently, the Cambodia Digital Economy and Society Policy Framework was introduced in 2021. The framework sets out the vision of “building a vibrant digital economy and society to accelerate new economic growth and promote social well-being based on the path of new normal" in line with the three principles of 1) building digital foundations; 2) digital adoption; and 3) digital transformation. (Royal Government of Cambodia, 2021[20]) Regulation is mentioned substantially throughout the document. Creating regulatory frameworks is mentioned as a way to enhance reliability and confidence and to create interoperable digital systems of line ministries and institutions, while the power of regulatory sandboxes to drive innovation is mentioned for start-ups and the FinTech sector.
Cambodia continues to put forth policies that promote the use of digital tools to support a better regulatory environment. The ICT development agenda is embodied in its Rectangular Strategy Phase 4 and the National Strategic Development Plan (NSDP) 2019-2023. In the Rectangular Strategy, the government has set a plan to prepare for the digital economy and the Fourth Industrial Revolution (Rectangle II: Economic Diversification and Competition strengthening) through mechanisms such as sufficient and effective laws and regulations, ICT and internet infrastructure, ICT in education and skill development, tech entrepreneurship and ecosystem, and research and development. (OECD, 2018[6]) The NSDP stipulates preparing for digital economy and the Fourth Industrial Revolution as one of its actions to achieve the key policy priority of economic diversification. The priorities of the RGC of the sixth Legislature aims to further update and implement the telecommunication and ICT development policy, Master Plan for Information and Communication Technology as well as Law on Telecommunication, and relevant regulations, along with the development and implementation of a long-term ICT strategic framework. (Royal Government of Cambodia, 2019[12])
Efforts to both improve the regulatory environment to promote digitalisation and to utilise digital tools to improve regulatory outcomes have also been carried out by different ministries. The NSDP 2019-2023 stipulates actions by separate ministries to implement the RGC’s priority policies in the Sixth Legislature of the National Assembly. Viewed from a regulatory angle, the key activities set out by separate ministries in particular focus on improving regulatory outcomes using digital tools. Key activities by ministries to promote ICT development that may improve regulatory outcomes include (Royal Government of Cambodia, 2019[12]) (see Table 4.1).
Table 4.1. Key activities by ministries to promote ICT development in Cambodia
|
Ministry of Post and Telecommunication (MPTC) |
Developing the policy on digital government; Creating new management software system and creating a common national website; Expanding server capability, website, e-mail server, and setting up a digital signature certification mechanism for ministries and agencies, capital/provinces, and the national and sub-national authorities; and Setting up a licensing mechanism, digital signature for businesses, and registering permits for businesses in ICT. |
|
Ministry of Commerce |
Developing policy, both legal and regulatory, in the field of trade, while responding to digital economy and industrial revolution 4.0: 1) developing trade policies in line with national, regional and global context, 2) promoting the establishment of a law on Ecommerce, 3) co-ordinating, strengthening and promoting the implementation of laws and regulations related to business activities through electronic system and management of market activities by issuing licenses and monitoring of risks, 4) continuing to manage system and filling of notices of secure transaction (www.setfo.gov.kh) to be more effective, safe, secure and reliability, and 5) developing the establishment, analysis, and evaluation of laws and legal regulations related to trade in line with the global context; Developing entrepreneurship and business practices in the digital economy and responding to the Industrial Revolution 4.0: 1) strengthening the work of the Chamber of Commerce in all centers and disseminating the benefits of organizing and forming business associations through regulatory documents as well as strengthening the capacity of existing business associations, 2) continuing to promote and attract local and foreign traders and investors to participate in developing and producing of potential products, and 3) strengthening and expanding the number of workshops or training on packaging quality, base price, standards, and trademarks which showcase the idea of creating new products and how products circulate in the market. |
Cambodia has also introduced several databases for regulations, including the ECOSOCC database, which includes laws, decrees and sub-decrees (OECD, 2018[6]). However, OECD (2018[6]) notes that legislation at the level of Prakas or below is not included, meaning that a significant body of regulatory and procedural information is omitted.
The Cambodian National Single Window (CNSW) is an initiative of the RGC. Cambodia engaged in preparations for the CNSW to fulfil its obligations under the ASEAN Single Window agreement signed in 2006 and requested assistance from the ASEAN Secretariat to develop a legal analysis that focused on identifying potential gaps in its domestic legal framework to be addressed for the full implementation of the National Single Window and its cross-border interoperability in an electronic environment (USAID, 2015[21]).
A blueprint was created for the CNSW by the Prime Minster Group in 2014, followed by establishment of the CNSW Steering Committee in 2015 and a Cambodia Needs Assessment Technical Assistance (TA) IN 2016. (CNSW Secretariat, 2019[22]) In the Needs Assessment TA Report, the recommended approach in establishing the full-fledged CNSW was to implement it in the following three phases (USAID, 2015[21]):
Phase 1- Connect to the ASEAN Single Window by 2017
Phase 2- Integrate the Line Agencies by 2018
Phase 3- Implement the Full CNSW by 2021
The implementation of the CNSW has resulted in better regulatory outcomes. Key benefits resulting from the CNSW include (CNSW Secretariat, 2019[22]):
reduced time in applying for licenses, permits and certificates due to electronic submission
reduced costs as a result of no need to travel between the office of various departments and agencies during submission
familiarity due to the standardisation of forms across departments and agencies, as well as reduction of complexity of the application processes
increased transparency of issuance processes
regulatory and data conformance ensured by immediate validation during the submission process.
References
[19] ADB (2020), Kingdom of Cambodia: Supporting Digital Cambodia for Inclusive Development Project, Asian Development Bank.
[10] ADB (2020), SME Monitor 2020 Database, Asia Development Bank.
[17] ADB (n.d.), Promoting Economic Diversification Program- Subprogram 3.
[23] ARISE+ (2022), ARISE+ Background, https://ariseplus.asean.org/about/ (accessed on 17 August 2022).
[1] ASEAN (2021), WTO Trade Facilitation Agreement (TFA), https://www.cambodia-ariseplus.asean.org/reports/wto-tfa.
[4] ASEAN Single Window (2020), Cambodia, Myanmar and Singapore start Exchanging the ASEAN Customs Declaration Document (ACDD), https://asw.asean.org/index.php/news/item/live-operation-of-the-asean-customs-declaration-document-acdd.
[2] ASEAN Single Window (n.d.), ASEAN Single Window Portal, https://asw.asean.org/index.php/nsw/cambodia/cambodia-general-information.
[11] Cambodian Corner (n.d.), Cambodian Corner for Policy Repository and Research, https://cambodiancorner.com/policies/rectangular-strategies/.
[16] CAMFEBA (n.d.), Cambodian Federation of Employers and Business Associations, https://www.camfeba.com/representative.html.
[22] CNSW Secretariat (2019), Cambodia National Single Window.
[18] ERIA (2018), Reducing Unnecessary Regulatory Burdens in ASEAN: Country Studies, Economic Research Institute for ASEAN and East Asia.
[24] Government of Cambodia (2008), Cambodia 1993 (rev. 2008) Constitution, https://www.constituteproject.org/constitution/Cambodia_2008?lang=en (accessed on 22 August 2022).
[15] Khieng, S. (2009), Towards a better understanding of the political economy of regional integration in the GMS: Stakeholder coordination and consultation for subregional trade facilitation in Cambodia, UNESCAP.
[25] Law Insider (n.d.), Prakas Definition, https://www.lawinsider.com/dictionary/prakas (accessed on 17 August 2022).
[6] OECD (2018), Good Regulatory Practices to Support Small and Medium Enterprises in Southeast Asia, OECD Publishing, Paris, https://doi.org/10.1787/9789264305434-en.
[14] OECD (2018), OECD Investment Policy Reviews: Cambodia 2018, OECD Investment Policy Reviews, OECD Publishing, Paris, https://doi.org/10.1787/9789264309074-en.
[13] Open Development Cambodia (2020), Open Development Initiative, https://data.opendevelopmentcambodia.net/laws_record/national-strategic-development-plan-nsdp-2019-2023/resource/bb62a621-8616-4728-842f-33ce7e199ef3.
[20] Royal Government of Cambodia (2021), Cambodia Digital Economy and Society Policy Framework 2021-2035, Supreme National Economic Council.
[7] Royal Government of Cambodia (2019), Effects of One Window Service on Public Service Delivery and Good Governance: Case stufy of Cambodia OWSO, http://era.gov.kh/eraasset/uploads/2019/12/Effect-of-OWSO-Bali-13-15-March19pptpaper.pdf.
[12] Royal Government of Cambodia (2019), National Strategic Development Plan 2019-2023, Royal Government of Cambodia.
[9] Royal Government of Cambodia (2018), Rectangular Strategy for Growth, Employment, Equity and Efficiency: Building the Foundation Toward Realizing the Cambodia Vision 2050 Phase IV of the Royal Government of Cambodia of the Sixth Legislature of the National Assembly, Royal Government of Cambodia.
[8] Samean, L. (2021), ‘One Window’ service to go national, http://era.gov.kh/eraasset/uploads/2019/12/Effect-of-OWSO-Bali-13-15-March19pptpaper.pdf.
[21] USAID (2015), Assessment of the Legal Framework for the Cambodia National Single Window, Nathan Associates Inc.
[3] Vannak, C. (2019), Khmer Times, https://www.khmertimeskh.com/619318/cambodia-launches-national-single-window/.
[5] WTO (2017), Trade Policy Review Cambodia, World Trade Organization.
Notes
← 1. ARISE Plus has three components: i) high level capacity building; ii) support to the realisation of the single market for goods; and iii) ASEAN Secretariat capacity building and was funded by a global EU contribution of 22 million (ARISE+, 2022[23]).
← 2. The legislative term of Cambodia’s National Assembly is of five years and terminates on the day when the new National Assembly convenes (Government of Cambodia, 2008[24]). The sixth legislative term began in 2018 and is referred to as the “Sixth Legislature of the National Assembly”, or “Sixth Legislature”, in governmental documents.
← 3. The Rectangular Strategy is the successor of the Triangular Strategy of the Royal Government in the Second Legislature of the National Assembly, and thereby establishes the key facets of the Royal Government of Cambodia’s development strategy. (Cambodian Corner, n.d.[11])
← 4. Prakas is a Cambodian term which means official proclamation. It is a ministerial or inter-ministerial decision signed by the relevant Minister(s). A proclamation must conform to the Constitution and to the law or sub-decree to which it refers (Law Insider, n.d.[25]).