GRANT NUMBER TF0B3363 Jordan Inclusive Growth and Economic Opportunities Multi-Donor Trust Fund Grant Agreement (Emergency Cash Transfer COVID-19 Response Project) between HASHEMITE KINGDOM OF JORDAN and INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT INTERNATIONAL DEVELOPMENT ASSOCIATION acting as administrator of the Jordan Inclusive Growth and Economic Opportunities Multi-Donor Trust Fund GRANT NUMBER TF0B3363 JORDAN INCLUSIVE GROWTH AND ECONOMIC OPPORTUNITIES MULTI- DONOR TRUST FUND GRANT AGREEMENT AGREEMENT dated as of the Signature Date between HASHEMITE KINGDOM OF JORDAN (“Recipient”); and INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT and INTERNATIONAL DEVELOPMENT ASSOCIATION (“World Bank”), acting as administrator of the Jordan Inclusive Growth and Economic Opportunities Multi-Donor Trust Fund. The Recipient and the Bank hereby agree as follows: Article I Standard Conditions; Definitions 1.01. The Standard Conditions (as defined in the Appendix to this Agreement) apply to and form part of this Agreement. 1.02. Unless the context requires otherwise, the capitalized terms used in this Agreement have the meanings ascribed to them in the Standard Conditions or in the Appendix this Agreement. Article II The Project 2.01. The Recipient declares its commitment to the objective of the project described in Schedule 1 to this Agreement (“Project”). To this end, the Recipient shall, and shall cause the National Aid Fund (“NAF”) to carry out Parts 1 and 2 of the Project in accordance with the provisions of Article II of the Standard Conditions and Schedule 2 to this Agreement. Article III The Grant 3.01. The Bank agrees to extend to the Recipient a grant in an amount not to exceed Twenty Four Million One Hundred Seventy Thousand United States Dollars ($24,170,000) (“Grant”) to assist in financing the Project. 2 3.02. The Recipient may withdraw the proceeds of the Grant in accordance with Section III of Schedule 2 to this Agreement. 3.03. The Grant is funded out of the abovementioned trust fund for which the Bank receives periodic contributions from the donors to the trust fund. In accordance with Section 3.02 of the Standard Conditions, the Bank’s payment obligations in connection with this Agreement are limited to the amount of funds made available to it by the donors under the abovementioned trust fund, and the Recipient’s right to withdraw the Grant proceeds is subject to the availability of such funds. Article IV — Remedies of the Bank 4.01. The Additional Events of Suspension consist of the following: (a) NAF’s Legislation has been amended, suspended, abrogated, repealed or waived so as to affect materially and adversely the ability of NAF to perform any of its obligations under the Project Agreement. (b) NAF has failed to comply with any of its obligations under the Subsidiary Agreement. 4.02. The Additional Event of Acceleration consists of the following, namely, that either of the events specified in Section 4.01 of this Agreement has occurred. Article V — Effectiveness 5.01. The Additional Condition of Effectiveness consists of the following: (a) the Subsidiary Agreement referred to in Section I.B of Schedule 2 to this Agreement has been duly authorized by the Recipient and NAF and is legally binding upon the Recipient and NAF in accordance with its terms; (b) the Recipient, through NAF, has finalized, adopted, and publicly disclosed the Rapid Social Assessment, in form and substance acceptable to the Bank; (c) the Recipient, through NAF, has finalized, adopted, and publicly disclosed Labor Management Procedures, in form and substance acceptable to the Bank 3 5.02 The Effectiveness Deadline is the date ninety (90) days after the date of this Agreement. Article IV Recipient’s Representative; Addresses 4.01. The Recipient’s Representative referred to in Section 7.02 of the Standard Conditions is its Minister responsible for planning and international cooperation. 4.02. The Recipient’s Address referred to in Section 7.01 of the Standard Conditions is: Ministry of Planning and International Cooperation Post office Box 555 Amman, 11118 The Hashemite Kingdom of Jordan Facsimile: 962-6-464 9341 4.03. For purposes of Section 7.01 of the Standard Conditions: (a) the Bank’s address is: International Bank for Reconstruction and Development/ International Development Association 1818 H Street, N.W. Washington, D.C. 20433 United States of America; and (b) the Bank’s Electronic Address is: Telex: Facsimile: 248423 (MCI) or 1-202-477-6391 64145 (MCI) 4 AGREED as of the Signature Date. HASHEMITE KINGDOM OF JORDAN By _____________________________________ Authorized Representative Nasser Shraideh Name: __________________________ Minister of Planning and International Cooper Title: __________________________ 26-Oct-2020 Date: __________________________ INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT INTERNATIONAL DEVELOPMENT ASSOCIATION acting as administrator of the Jordan Inclusive Growth and Economic Opportunities Multi-Donor Trust Fund By _____________________________________ Authorized Representative Saroj Kumar Jha Name: __________________________ Country Director Title: ___________________________ 25-Oct-2020 Date: ___________________________ 5 SCHEDULE 1 The objective of the Project is to provide cash support to poor and vulnerable households affected by the COVID-19 pandemic in Jordan. The Project consists of the following Parts: Part 1: Cash support to poor and vulnerable households affected by COVID-19 Part 1.1 Temporary Cash Transfers to vulnerable households Provision of unconditional Cash Transfers to Beneficiaries not otherwise benefiting from the NAF Programs, to provide time-limited livelihood support to vulnerable households. Part 1.2 Takaful Cash Transfer Program Provision of unconditional Cash Transfers to Takaful Beneficiaries to provide complementary livelihood support to vulnerable households on a quarterly basis. Part 1.3 Temporary benefit top-up for Takaful beneficiaries Provision of unconditional Top-Up Cash Transfers to Takaful Beneficiaries to provide additional, time-limited livelihood support to vulnerable households. Part 2: Project management, monitoring and evaluation Provision of support for the PMU in managing and overseeing Project activities, including: (a) staffing; (b) data collection and verification, aggregation and periodic reporting on the Project’s implementation progress; (c) software and hardware requirements for NAF and relevant institutions necessary for the expansion of the data exchange platform of the National Unified Registry (NUR); (d) monitoring of the Project’s key performance indicators and periodical evaluation; (e) communication and outreach; (f) digitization of payments; (g) recertification of Beneficiaries of the monthly and Takaful cash transfer programs; (h) costs associated with maintenance of the GRM; and (i) overall Project Operating Costs, audit costs, including independent verification of the Cash Transfers, monitoring and compliance with ESCP. Part 3: Contingent Emergency Response Component Provision of immediate response to an Eligible Crisis or Health Emergency. 6 SCHEDULE 2 Project Execution Section I. Institutional and Other Arrangements A. Institutional Arrangements 1. For the purposes of Project implementation, the Recipient shall: (a) Cause Parts 1 and 2 of the Project to be carried out by NAF in accordance with the Project Operations Manual and the Project Agreement; (b) Cause NAF to enter into a Project Agreement with the Bank for purposes of carrying out Parts 1 and 2 of the Project; (c) No later than thirty (30) days from the Effective Date, cause NAF to establish and maintain, throughout Project implementation, a Project Management Unit (“PMU”) in charge of overall coordination of the Project. The PMU shall be headed by a Project Manager responsible for: (i) coordinating implementation and ensuring the overall technical coherence of the Project activities; and (ii) coordinating all technical, operational, M&E, financial management, procurement and environmental and social safeguards aspects within the respective units and departments at NAF, all in form and with terms of references, functions, composition, staffing, including financial officer to be hired not later than thirty (30) days after the Effective Date, and communications officer and GRM officer, to be assigned not later than sixty (60) days after the Effective Date, as well as adequate resources acceptable to the Bank, and as further described in the project operation manual (“Project Operation Manual” or “POM”). B. Subsidiary Agreement 1. To facilitate the carrying out of the Project, the Recipient shall make the proceeds of the Grant available to NAF under a subsidiary agreement between the Recipient and NAF, under terms and conditions approved by the Bank (“Subsidiary Agreement”). 2. The Recipient shall exercise its rights under the Subsidiary Agreement in such manner as to protect the interests of the Recipient and the Bank and to accomplish the purposes of the Grant. Except as the Bank shall otherwise agree, the Recipient shall not assign, amend, abrogate or waive the Subsidiary Agreement or any of its provisions. 7 C. Project Operations Manual 1. Not later than thirty (30) days after the Effective Date, the Recipient shall cause NAF to adopt the POM, satisfactory to the Bank, which shall include the rules, methods, guidelines, standard documents and procedures for the carrying out of the Project, including the following: (a) administration and coordination, monitoring and evaluation, financial management, procurement and accounting procedures, environmental and social safeguards, corruption and fraud mitigation measures; (b) a grievance redress mechanism; (c) personal data collection and processing in accordance with the applicable national guidelines; (d) eligibility criteria and procedures in selecting Beneficiaries for receiving Cash Transfers and Top-Up Cash Transfers, including schedules and modalities for delivering Cash Transfers and Top-Up Cash Transfer; (e) detailed arrangements for verification of achievement of the PBCs (including the Verification Protocol); (f) roles and responsibilities for Project implementation; and (g) such other arrangements and procedures as shall be required for the effective implementation of the Project, in form and substance satisfactory to the Bank. 2. In the event that any provision of the POM shall conflict with this Agreement, the terms of this Agreement shall prevail. 3. The Recipient shall cause NAF to ensure that the POM is not amended without the prior written agreement of the Bank. D. Cash Transfers 1. The Recipient shall cause NAF to select Beneficiaries and make Safety Net Transfers to eligible Beneficiaries, in accordance with the eligibility criteria, requirements and procedures acceptable to the Bank, as described in the POM. 2. The Recipient shall cause NAF to ensure that the amount of each Safety Net Transfer is used by the Beneficiary for its intended purpose. 3. Any revision to the eligibility criteria or a decision to conduct a recertification of Beneficiaries under Part 1.1 of the Project shall be conducted based on the methodology and procedures satisfactory to the Bank. E. Verification of Safety Net Transfers 1. Not later than 30 days after the Effective Date, the Recipient, through NAF, shall appoint a Verification Agent to carry out, under the terms satisfactory to the Bank, a verification review of Project implementation, including, inter alia, accuracy of Safety Net Transfer payments, eligibility of Beneficiaries, and confirmation of receipt of funds by Beneficiaries; 8 2. The Recipient shall cause NAF to submit to the Bank, not later than six (6) months after the Effective Date, Verification Agent’s verification review report satisfactory to the Bank related to the use of the proceeds of the first set of Safety Net Transfers, and thereafter, shall submit the verification review report every six months. The final independent verification report shall be furnished to the Bank not later than four (4) months after the end of last withdrawal of the proceeds of the Grant allocated to Safety Net Transfers under Category (3) of the table set forth in Section III.A.1 of Schedule 2 to this Agreement. F. Annual Work Plan and Budget 1. The Recipient shall cause NAF, through the PMU, to prepare and furnish to the Bank, not later than January 31 of each year, starting January 1, 2021, an Annual Work Plan and Budget containing all activities proposed to be included in the Project and a proposed financing plan for expenditures required for such activities, setting forth the proposed amounts, sources of financing and eligible costs. 2. The Recipient shall cause NAF, through the PMU, to afford the Bank a reasonable opportunity to exchange views with the PMU on such proposed Annual Work Plan and Budget and thereafter ensure that the Project is implemented in accordance with such Annual Work Plan and Budget as shall have been approved by the Bank. 3. The Recipient may revise Annual Work Plans and Budgets as needed during Project implementation subject to the Bank’s prior written approval. G. Environmental and Social Standards 1. The Recipient shall, and shall cause NAF to ensure that the Project is carried out in accordance with the Environmental and Social Standards, in a manner acceptable to the Bank. 2. Without limitation upon paragraph 1 above, the Recipient shall, and shall cause NAF to ensure that the Project is implemented in accordance with the Environmental and Social Commitment Plan (“ESCP”), in a manner acceptable to the Bank. To this end, the Recipient shall, and shall cause NAF to ensure that: (a) the measures and actions specified in the ESCP are implemented with due diligence and efficiency, and as further specified in the ESCP; (b) sufficient funds are available to cover the costs of implementing the ESCP; (c) policies, procedures and qualified staff are maintained to enable it to implement the ESCP, as further specified in the ESCP; and 9 (d) the ESCP or any provision thereof, is not amended, revised or waived, except as the Bank shall otherwise agree in writing and the Recipient has, thereafter, disclosed the revised ESCP. 3. In case of any inconsistencies between the ESCP and the provisions of this Agreement, the provisions of this Agreement shall prevail. 4. The Recipient shall, and shall cause NAF to: (a) take all measures necessary on its part to collect, compile, and furnish to the Bank through regular reports, with the frequency specified in the ESCP, and promptly in a separate report or reports, if so requested by the Bank, information on the status of compliance with the ESCP, all such reports in form and substance acceptable to the Bank, setting out, inter alia: (i) the status of implementation of the ESCP; (ii) conditions, if any, which interfere or threaten to interfere with the implementation of the ESCP; and (iii) corrective and preventive measures taken or required to be taken to address such conditions; and (b) promptly notify the Bank of any incident or accident related to or having an impact on the Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, in accordance with the ESCP, the instruments referenced therein and the Environmental and Social Standards. 5. The Recipient, and shall cause NAF to maintain and publicize the availability of a Grievance Redress Mechanism, in form and substance satisfactory to the Bank, to hear and determine fairly and in good faith all complaints raised in relation to the Project, and take all measures necessary to implement the determinations made by such mechanism in a manner satisfactory to the Bank. Section II. Project Monitoring, Reporting and Evaluation A. Documents; Records In addition, and without limitation to the obligations set forth in Section 2.05 of the Standard Conditions, the Recipient shall ensure that: (a) all records evidencing expenditures under the Project are retained for seven years and six months after the Closing Date, such records to include: (i) this Agreement, all addenda thereof, and any amendments thereto; (ii) the Recipient’s financial and narrative progress reports submitted to the Bank; (iii) the Recipient’s financial information related to the Grant, including audit reports, invoices and payroll records; (iv) the Recipient’s implementation documentation (including sub-agreements, procurement 10 files, contracts, purchase orders); and (v) the corresponding supporting evidence referred to in Section 3.04 of the Standard Conditions; and (b) the representatives of the Bank are: (i) able to examine all records referred to above in paragraph (a); (ii) provided all such information concerning such records as they may from time to time reasonably request; and (iii) able to disclose such records and information to the Donor(s). B. Project Reports The Recipient shall cause NAF to furnish to the Bank each Project Report not later than 45 days after the end of a calendar quarter, covering the calendar quarter. Section III. Withdrawal of Grant Proceeds A. General 1. The Recipient may withdraw the proceeds of the Grant in accordance with the provisions of: (a) Article III of the Standard Conditions; and (b) this Section; to finance Eligible Expenditures in the amount allocated and, if applicable, up to the percentage set forth against each Category of the following table: Category Amount of the Percentage of Expenditures to be Grant Allocated Financed (expressed in (inclusive of Taxes) USD) (1) Goods, works, non- 150,000 such percentage as agreed to by the consulting services, Bank under the Annual Work Plan consulting services, Training and Operating Costs under the Project (2) Cash Transfers under 0 N/A Part 1.2 of the Project (3) Safety Net Transfers 24,020,000 such percentage as agreed to by the under Parts 1.1 and 1.3 of Bank under the Annual Work Plan the Project TOTAL AMOUNT 24,170,000 11 B. Withdrawal Conditions; Withdrawal Period 1. Notwithstanding the provisions of Part A of this Section, no withdrawal shall be made: (a) for payments made prior to the date of this Agreement, except withdrawals up to an aggregate amount not to exceed $9,660,000 may be made for payments made on or after March 1, 2020, but prior to the date of this Agreement, for Eligible Expenditures under Category (3) of the Project. (b) for payments under Category (3) unless: i. NAF adopts the POM, on terms satisfactory to the Bank; ii. NAF has identified Beneficiaries eligible to receive Safety Net Transfers under Parts 1.1 and 1.3 of the Project in accordance with criteria and procedures set forth in POM; and iii. payments for Safety Net Transfers under Parts 1.1 and 1.3 of the Project have been made to Beneficiaries in accordance with criteria, procedures and arrangements set out in the POM. 2. Notwithstanding the foregoing, if the Bank determines, at any time, that any portion of the amounts disbursed by the Recipient under Category (1) was made for payment of expenditures that are not eligible, the Recipient shall promptly refund any such amount to the Bank as the Bank shall specify by notice to the Recipient. 3. If, at any time, the Bank determines that any portion of the amounts disbursed by the Bank to the Recipient under Category (3) was: (i) made for payment of expenditures which are not eligible under the NAF programs; or (ii) not in compliance with the provisions of Section I.D and the provisions of the POM, the Recipient shall promptly refund any such amount to the Bank as the Bank shall specify by notice to the Recipient. 4. The Closing Date is June 30, 2022. 12 APPENDIX Section I. Definitions 1. “Annual Work Plan and Budget” means the work plan and budget approved by the Bank and adopted by the Recipient in accordance with the provisions of Section I.F of Schedule 2 of this Agreement, as said work plan and budget may be modified from time to time with the written agreement of the Bank. 2. “Anti-Corruption Guidelines” means, for purposes of paragraph 2 of the Appendix to the Standard Conditions, the “Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants”, dated October 15, 2006, and revised in January, 2011, and as of July 1, 2016. 3. “Beneficiary” means an individual or a household eligible to receive Safety Net Transfer under Part 1.1 of the Project, as per criteria, amount, and procedures described in the POM; “Beneficiaries” means the plural thereof. 4. “Cash Transfer” means a transfer of funds, either in cash or electronically, in the form of grants on behalf of the Recipient to a Beneficiary, made or to be made under Parts 1.1 and 1.2 of the Project in accordance with the provisions of the POM. 5. “Category” means a category set forth in the table in Section III.A of Schedule 2 to this Agreement. 6. “COVID-19” means the coronavirus disease caused by the 2019 novel coronavirus (SARS-CoV-2). 7. “Environmental and Social Commitment Plan” or the acronym “ESCP” means the Recipient’s environmental and social commitment plan, acceptable to the Bank, dated May 31, 2020 which sets out a summary of the material measures and actions to address the potential environmental and social risks and impacts of the Project, including the timing of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and any instruments to be prepared thereunder; as the ESCP may be revised from time to time, with prior written agreement of the Bank, and such term includes any annexes or schedules to such plan. 8. “Environmental and Social Standards” means, collectively: (i) “Environmental and Social Standard 1: Assessment and Management of Environmental and Social Risks and Impacts”; (ii) “Environmental and Social Standard 2: Labor and Working Conditions”; (iii) “Environmental and Social Standard 3: Resource Efficiency and Pollution Prevention and Management”; (iv) “Environmental and Social Standard 4: Community Health and Safety”; (v) “Environmental and Social 13 Standard 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement”; (vi) “Environmental and Social Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources”; (vii) “Environmental and Social Standard 7: Indigenous Peoples/Sub-Saharan Historically Underserved Traditional Local Communities”; (viii) “Environmental and Social Standard 8: Cultural Heritage”; (ix) “Environmental and Social Standard 9: Financial Intermediaries”; (x) “Environmental and Social Standard 10: Stakeholder Engagement and Information Disclosure”; effective on October 1, 2018, as published by the Bank at https://projects-beta.worldbank.org/en/projects- operations/environmental-and-social-framework/brief/environmental-and-social- standards. 9. “GRM” means the Grievance Redress Mechanism referred to in Section I.G.5 of Schedule 2 to this Agreement. 10. “Labor Management Procedures” or “LMP” means the document to be prepared by the Recipient, in form and substance satisfactory to the Bank, and in accordance with Environmental and Social Standard 2, setting out inter alia the overview of the labor use in the Project, an assessment of potential Project-related labor risks, the types of Project workers and their terms and conditions of employment, the age of employment, the details of the Project dedicated grievance mechanism to be provided to direct workers and contracted workers, and occupational health and safety requirements for Project workers; as the LMP may be revised from time to time, with prior written agreement of the Recipient, and such term includes any annexes or schedules to such LMP. 11. “MOPIC” means the Recipient’s Ministry of Planning and International Cooperation, or its legal successor. 12. “National Aid Fund” or “NAF” means a national safety net fund established in accordance with National Aid Fund Law No. 36 (1986), as amended, or its legal successor. 13. “NAF’s Legislation” means National Aid Fund Law No. 36 (1986), as amended. 14. “NAF Program” means social safety net programs of the Recipient designed to provide protection to the poor through income support, which include Regular Monthly Cash Transfer Program and Takaful Cash Transfer Program. 15. “PMU” means the Project management unit within NAF, referred to in Section I.A.1 of Schedule 2 to this Agreement. 16. “POM” means the project operations manual for the Project, to be adopted by the Recipient and satisfactory to the Bank, and referred to in Section I.C. of Schedule 2 to this Agreement, describing and setting forth procedures for implementation of 14 the Project and institutional arrangements, consistent with the provisions of this Agreement and including, among other things, the fiduciary, technical and operational aspects and procedures for implementation of the Project, including the financial management procedures, procurement procedures, monitoring and evaluation arrangements, verification arrangements, other fiduciary and administrative arrangements, as the same may be amended from time to time by agreement with the Bank. 17. “Procurement Plan” means the Recipient’s procurement plan for the Project, dated April 25, 2020 and provided for under Section IV of the Procurement Regulations, as the same may be updated from time to time in agreement with the Bank. 18. “Procurement Regulations” means, for purposes of paragraph 20 of the Appendix to the Standard Conditions, the “World Bank Procurement Regulations for IPF Borrowers”, dated July 2016, revised November 2017 and August 2018. 19. “Project Operating Costs” means reasonable incremental expenses incurred by the Recipient (including NAF and the PMU) and approved by the Bank attributable to the Project implementation, management and monitoring, and establishment of the project management unit and a grievance redress mechanism, including costs related to: office supplies and consumables, stationary and sundries, maintenance of office equipment, communication, advertising, office rentals, utility costs, operation and maintenance of office vehicles, per diem and travel costs for Project staff (including NAF and the PMU), reasonable bank charges, allowances and salaries of Project staff (excluding the salaries of Recipient’s civil servants). 20. “Rapid Social Assessment” means a systematic examination of the social risks and impacts, associated with the Recipient’s Program supported by the Project. The examination includes (a) consideration of the full range of social impacts included in ESS1; (b) whether vulnerable individuals or groups have access to the development benefits resulting from the Program; and (c) proposal of appropriate mitigation and monitoring measures 21. “Regular Monthly Cash Transfer Program” means the national program under NAF which has been functioning since the NAF establishment to provide unconditional Cash Transfers to Beneficiaries to provide income support aimed at the protection and inclusion of poor households with children, the poor elderly (above age 65), persons with permanent disability, and other categories. 22. “Safety Net Transfer” means, collectively, Cash Transfers under Parts 1.1 and 1.2 and Top-Up Cash Transfers under Part 1.3 of the Project. 23. “Takaful Beneficiary” means a Beneficiary participating in the Takaful Cash Transfer Program. 15 24. “Takaful Cash Transfer Program” means the national targeted program established in May 2019 under NAF to provide unconditional Cash Transfers to Beneficiaries to provide income support aimed at the protection and inclusion of poor households using a pro-poor targeting criteria. 25. “Top-Up Cash Transfer” means a transfer of funds, either in cash or electronically, in the form of grants on behalf of the Recipient to a Takaful Beneficiary, made or to be made under Part 1.3 of the Project in accordance with the provisions of the POM. 26. “Training” means costs incurred by the Recipient on account of approved workshops, and training of Recipient personnel involved in implementation of the Project, including study tours, travel and subsistence costs for training participants, costs associated with securing the services of trainers, rental of training facilities, preparation and reproduction of training materials, and other costs directly related to course preparation and implementation, all on the basis of budgets acceptable to the Bank. 27. “Verification Agent” means an independent entity to be appointed by the Recipient to carry-out performance audits of the Project and verification of BPCs, as referred to in Section I.E(1) of Schedule II to this Agreement. 28. “Signature Date” means the later of the two dates on which the Recipient and the Bank signed this Agreement and such definition applies to all references to “the date of the Grant Agreement” in the Standard Conditions. 29. “Standard Conditions” means the “International Bank for Reconstruction and Development and International Development Association Standard Conditions for Grant Financing Made by the Bank out of Trust Funds”, dated February 25, 2019. 16