The latest entity to come into the fold among NATO's hybrid units is the Counter-Hybrid Support Teams. The need for such a unit arises from member states' requests to combat hostile hybrid campaigns that (potentially) threaten community cohesion, (critical) infrastructures, stability of government and decision-making processes, and essential services. As Montenegro dreaded a repeat of its calamatious 2016 parliamentary elections, NATO deployed its first Counter-Hybrid Support Team there in late 2019 upon the government’s request. Considering that information regarding the first NATO Counter-Hybrid Support Team’s mission to Montenegro is general and scarce, this article proposes a realistic and forward-looking course of action and endeavours to contribute to the discussion by elaborating on a four-pronged practical model aimed to inform, deter, debunk and denouce, disrupt, attribute, sanction (ID4AS).
By Nico Segers
Since the early 2010s, a series of events prompted the EU and NATO to enhance cooperation and address the increase of ‘hybrid’ activities threatening the strategic interests of its member states.
The inception point came in 2014 with the military occupation of the Donbas and Luhansk regions (Ukraine) by Russian irregular forces. A cascade of non-military actions prompted more investment in Allied resilience to hybrid threats: Russia’s interference in the 2016 US elections, the nerve agent attack on Sergei and Yulia Skripal in Salisbury, UK, and a subversive campaign to prevent Montenegro from joining NATO along with a ploy to overthrow its government.
In 2015 NATO adopted its first counter-hybrid strategy, based on three principles: prepare, deter, and defend.[i]
In parallel with the hybrid operations element, NATO was also confronted with the need to consider offensive cyber operations as a threat to itself. In 2014, NATO increased the scope of its collective defence commitment to include cyber-attacks, while in 2016, it declared cyber an operational domain.[ii] This means that, between 2014 and 2016, NATO’s defence and security pledge towards its member states enlarged to include both the hybrid and cyber domains.
The link between cyber and actual kinetic damage became apparent in 2010 when the STUXNET worm infiltrated the control system and critically damaged over 1,000 centrifuges of the Natanz uranium enrichment plant in Iran. Considering that this was brought about via an ‘inside job’ (allegedly an Iranian double-agent), this STUXNET attack was not purely cyber in execution but a covert, hybrid operation.
Prior to this, the massive cyberattack in Estonia in 2007, which heavily disrupted digital infrastructure in the Estonian parliament, ministerial servers and mailboxes, banking systems, as well as electronic newspapers and broadcaster services, showed how concerted attacks may effectively weaken states and serve as the prelude to a wider hybrid operation. It is no surprise that NATO Cooperative Cyber Defence Centre of Excellence (CCD COE) was set up as a research and training facility in Estonia one year after this high-scale cyberattack. Currently, Allied Member States improve their online systems and responsiveness through realistic exercises, for instance, at the NATO Cyber Range in Tartu, Estonia, and via the annual Cyber Coalition exercise, held since 2008.
In academic and military literature and debate, the topic of unconventional or hybrid operations and threats began to surge in response to two phenomena: first, the 2014 illegal invasion in Crimea and insurgency in the Donbass and Luhansk regions; second, the advanced ISIS/Da’esh campaigns involving a sophisticated, expanded, and performant information warfare far beyond operational theatres in Syria and Iraq. From Spring 2014 until early December 2017, ISIS, a non-state armed actor, developed and utilized hybrid informational assets to influence, seduce, and recruit would-be jihadists not only in the Middle East but also across Europe and North America. This led to a further rapprochement between the EU and NATO and the will to develop effective counterstrategies to respond more boldly and effectively to hybrid menaces.
In 2015 the NATO Parliamentary Assembly sought to chart how this somewhat ‘amorphous’ phenomenon affects the Alliance as a whole, and its Defence and Security Committee spawned a report called Hybrid Warfare: NATO’s New Strategic Challenge?[iii] It pushed for increased strategic awareness, force mobilisation, increased political will and investment in the Readiness Action Plan (RAP) to cope with hybrid threats, divesting a modicum of authority to SACEUR in the event of a crisis (to prepare while awaiting NAC-level decisions), the sharing and pooling of cyber capabilities amongst member states (“Robust Cyber Defences”), and economic solidarity.
One year later came a quantum leap year for NATO in addressing hybrid security challenges, with the creation of more specialized entities, activities, and programmes:
· NATO Crisis Management Exercises (CMX) began to include “hybrid scenarios, comprising disinformation, threats to critical infrastructure, and “grey zone” situations”.[iv]
· In July 2017, a new branch for hybrid analysis was established in the reorganized Joint Intelligence and Security Division (JISD). Its mandate is “to analyse the full spectrum of hybrid actions, drawing from military and civilian, classified and open sources.”[v]
· In October 2017, a Centre of Excellence for Countering Hybrid Threats was inaugurated in Finland as a tenet of the renewed NATO-EU Cooperation process.[vi] Its threefold mission is to:
“- be a platform for nations to come together to share best practices, build capability, test new ideas and exercise defence against hybrid threats.
- be a neutral facilitator between the EU and NATO through strategic discussions and exercises.
- lead the conversation on countering hybrid threats through research and sharing of best practices.”[vii]
Then, in 2018, NATO revealed plans to transform cyber capabilities at SHAPE Headquarters (Belgium) into a Cyberspace Operations Centre to “support military commanders with situational awareness to inform our operations and missions” and coordinate and assist member states with cyber threats.
The latest entity to come into the fold is the Counter-Hybrid Support Teams, which consist of experts tasked to “provide tailored, targeted assistance to Allies, upon their request, in preparing for and responding to hybrid activities”.[viii] The need for such requests arises from hostile hybrid campaigns that (potentially) threaten community cohesion, (critical) infrastructures, stability of government and decision-making processes, and essential services.
Their establishment was decided during the NATO Summit in Brussels on 11 July 2018 following the conclusion that hybrid threats had, as Secretary-General Jens Stoltenberg again acknowledged in a press meeting on 11 February 2020, “become more and more a reality for more and more NATO Allied countries.”[ix]
During parliamentary elections in October 2016, Montenegro was targeted by foreign adversaries of Serbian and Russian origin via a sophisticated disinformation and disruption campaign in order to prevent the country from joining NATO as the 29th member. The reportedly unusual and brutal attacks amounted to a foiled coup attempt that shook up Podgorica.[x] Following judicial investigation, the Montenegrin Higher Court indicted 14 persons. In May 2019, the Higher Court found 13 of them, including Russian military intelligence operatives and Montenegrin opposition politicians linked to the Kremlin, guilty of “terrorist acts″ and undermining the constitutional order of Montenegro.[xi]
As Montenegro dreaded a repeat of the 2016 calamities, NATO deployed its first Counter-Hybrid Support Team there in late 2019 upon the government’s request. Citing security consultant Zoran Kusovac:
Having learned from experience, Montenegro is working on improving its national capabilities to counter contemporary security challenges. (…) The coup attempt in 2016 shows that Montenegro is not new to unconventional and hybrid threats (…). So it’s no surprise that NATO is taking steps to ensure that the campaign and elections will be democratic and peaceful.[xii]
SUBVERSIVE ACTIVITIES BY FOREIGN ELEMENTS UNDER SCRUTINY
Prior to the August 2020 parliamentary elections in Montenegro, the Crime and Corruption Reporting Network LUPA and Balkan Investigative Reporting Network reported eyebrow-raising oddities in voting numbers. The joint investigation concluded, upon comparing available data from the Statistical Office and the Interior Ministry, that in some Montenegrin municipalities, the number of registered voters exceeded the actual population (there were 52,294 more registered voters than actual adults in the country) and more than half of the names on the electoral roll were listed without valid addresses.[xiii] This raises the question of whether this was an intended ‘fix’ set in place by the ruling Democratic Party of Socialists to manipulate poll differences and stymie the opposition or a vote rigging operation set up by a NATO adversary.
In the wake of ubiquitous reports on election interference in the United States, Germany, France, and the UK, commonly attributed to Russia, and the recent attempt to eliminate opposition figures such as Alexei Navalny,[xiv] this type of threat is no longer a fringe occurrence. The act of establishing and keeping up (counter-) hybrid capabilities has become indispensable in a more layered, multi-domain battlespace in which one’s foe can target virtually anything, from energy infrastructure, sea lines of communication, election processes, media stories, the cohesion and trust between groups in society, to the essential values and belief systems that people live by.
All NATO members face the systemic challenge of securing the integrity and proper functioning of their domestic democratic processes and harnessing the public’s trust in their institutions. To ‘inoculate’ Euro-Atlantic countries against malign actors, it requires the enhancement of multi-level resilience and the reorganization and specialization of the intelligence apparatus to predict, assess, and analyse the threat landscape and respond to a complex arsenal of overt and covert, military, and non-military means.
Without attempting to offer an exhaustive list of what is to be understood by ‘hybrid’, this involves disinformation and misinformation; cyber intrusion, disruption, and espionage; disruption of energy supplies or financial services; provoked incidents or (quasi)accidents (such as the Kerch Strait incident in November 2018); meddling in sovereign politics such as election interference and enlistment of Manchurian candidates; illicit pressure (e.g., suspending energy supplies); and support to separatist forces.[xv]
Then, there are specific operations geared towards psychological warfare (PSYOPS) to discourage, weaken morale and loyalty to military command hierarchy, and provoke internal dissidence or opposition within military units. Ample examples are documented among units on rotation at NATO’s Enhanced Forward Presence (eFP) in Poland and the Baltic states.[xvi] Men and women in uniform have been targeted, often via electronic handheld devices, to undermine their morale, pride, or belief systems.[xvii]
The traditional make-up of a military apparatus with an army, navy, air force, and cyber and space command no longer cuts it. Highly sought-after, highly-skilled profiles in digital networks and infrastructure (incident) investigations, including advanced cyber programmers and cyber vulnerability testers, as well as professionals honing skills and talents in relevant areas like big data, election, and media ecosystem analysis are in great need in order to reinforce the Alliance’s overall 360-degree security. Such people and cutting-edge technological capabilities shall remain at the forefront to prepare against, better withstand, and fend off NATO’s adversaries’ determination to weaken it. Conflicts are no longer fought only by means of kinetic power but rather, too, through political or diplomatic acts (e.g., bandwagoning, economic and trade sanctions), by employing other coercive measures, or through lawfare.[xviii]
A REFINED SOLUTION KIT TO PREPARE AND ACT AGAINST HYBRID THREATS
Information regarding the first NATO Counter-Hybrid Support Team’s mission to Montenegro is general and scarce. For obvious reasons, there is a level of discretion and secrecy regarding the teams’ precise activities, outcomes, and modus operandi.
At the pre-ministerial press conference ahead of the NATO Defence Ministers meetings in Brussels in February 2020, the NATO Secretary General briefly commented that the Counter-Hybrid Support Team went to Montenegro in November 2019 “for some days” and then left.[xix]
Considering what was at stake (the state’s executive integrity and, more gravely, the country’s stability), the first Counter-Hybrid Support Team collected and analysed available intelligence about the parties of interest (at the political level, civil society, politically connected business owners, etc.) and the information domain (media, opinion-shapers and influencers, trolls, etc.) which were affecting the electoral process and, consequentially, threatened Montenegro’s stability and national security. Hereafter, matters were discussed at the cabinet level within several ministries. A report containing the findings of the Counter-Hybrid Support Team was prepared, containing a section with recommendations for the government to make improvements on items such as critical and digital infrastructures, individuals and groups of concern, and the (digital) information space, all areas to be addressed to safeguard Montenegro’s democratic institutions and national security.
Anything beyond superficial knowledge would allow NATO’s adversaries to better prepare for another malign hybrid campaign. Following counter-intelligence logic, it goes without saying that revealing too much about elements of surprise, or the technologies and tactical superiority that a Counter-Hybrid Support Team can unleash from its toolbox, compromises its mission.
Members of the first Counter-Hybrid Support Team’s mission quite likely have profiles in cyber security, data analysis, (digital) forensics, electoral monitoring, crisis management, (counter)intelligence, critical and investigative media methods, and (para)legal affairs.
Upcoming missions may include expert practitioners with backgrounds in the fields of Chemical, Biological, Radiological, Nuclear (CBRN) defence,[xx] social and political sciences, behavioural sciences, and social media ecosystems (including botnets and ‘troll factories’). Members of a Counter-Hybrid Support Team could also be trained professionals in scenario-building and strategic foresight analysis. Those are needed skills to predict adversarial activity and prepare and test countermeasure plans to deter and respond to this.
CONSTANTLY IMPROVING THE COUNTER-HYBRID RESPONSE CYCLE(S)
Quoting NATO’s first Assistant Secretary General for Intelligence and Security Mr. Freytag von Loringhoven:
It is all about connecting the dots, reflecting the growing need to take a holistic approach. Cyber security will play an increasingly important part in this (…) Hybrid defence is not a static conventional defence. We need to deepen our knowledge of new methods and tools. Another aspect is that we need to expand the awareness of hybrid practices among EU and NATO societies.[xxi]
The author cannot agree more with this realistic and forward-looking course of action and endeavours to contribute to the discussion by elaborating on a practical model, which he labels the ID4AS approach. An acronym, in appropriate tradition with diplomatic and defence jargon, consisting of the following tenets:
Let the public know that unconventional activities are being anticipated, identified, and deterred. Amplify visibility of the debate on the need to not be paralyzed by events but to face them and shape them (ownership). Efforts must be geared towards restoring sufficient trust in state institutions and to restoring and/or preserving intra-society cohesion and concord. The very premise of ‘national unity’ is not self-evident within each country.
To establish the idea of a collective identity or even a shared future requires patience, effort, leadership, and also a willingness to cure and soothe (potential) inequalities, cleavages, and issues in which different groups may have opposing feelings or beliefs on how they (a) are to be defined and (b) if and how they should be addressed. Offering perspective and ensuring an environment that allows all voices to speak without fear and, when necessary, calling out actors who seek to dominate and ‘spoil’ perspective, matters. An accessible, transparent information space with responsible reporters and fact-checkers vetting and pointing out deceptive and unvalidated claims and hoaxes masquerading as ‘information’, helps to sanitize the information space.
Jointly demonstrate a level of preparedness and mobilise (overt and covert) countermeasures at the right time. Discourage the adversary by making it harder to target certain elements of society, the political class, the security services, and intelligence apparatus, and by investing in education and assuring open and balanced information reaches all civilian strata. Staffers of the NATO Emerging Security Challenges Division can provide constructive recommendations, such as helping a ‘targeted’ allied government to determine priorities and allocation of resources to address (the threat of) hybrid activities undertaken by known and unknown adversaries.
Debunk and Denounce
Call out the authors and their accomplices. Support investigations (parliamentary or judicial) and legal proceedings’ ‘due process’. Avoid counteractions to be branded as politicized purges. Debunk untrustworthy media, trolls, and remind media consumers to check and vet before sharing or liking. Denounce the acts as harmful to the legal order, the state, and the people of the member state.
In the area of digital infrastructure and networks:
While NATO observes a resolute policy to not help its members to develop or employ offensive cyber capabilities, improving domestic cyber digital infrastructures is key. Disruption may still occur in the physical electronic domain.
In the area of human activity:
Judges should enact legal provisions to (temporarily) restrict the movement of persons who unequivocally intend to sabotage political or electoral processes, engineer a “scandal story” in a move to provoke a cabinet falling, or overthrow a government. Under well-defined legal provisions, such persons deemed “dangerous to the state’s interest” could be placed under house arrest or given a restraining order by the appropriate court of law.
Identify authors, proxy agents, and networks abetting the latter. Determine what legal action to take and assert the credibility and legitimacy thereof in the media.
It remains vitally important to (re)examine legal enforcement mechanisms prior to legal action to be decided upon by each member state government.
Depending on the request of the issuing Alliance member, broader civil-military affairs, the (quality of) political education, state-church relations, as well as government-diaspora and government-church relations would influence the scope of any preparedness, monitoring, and resilience-building operations.
The author further recommends the NATO Emerging Security Challenges Division, NATO JISD, and NATO Intelligence Fusion Center (NIFC), in their respective roles and mandates, to:
Firstly, enhance holistic intelligence analysis and dissemination of products through the ID4AS approach.
Secondly, to regularly consult with and inform the NATO Parliamentary Assembly, the EU Hybrid Fusion Cell, and the EU Committee for Civilian Aspects of Crisis Management (CIVCOM) on vulnerabilities and capability gaps in the hybrid domain.
(1) a Legal Guidance manual to allow national legislators and parliamentarians to adapt and expand national legislation, sanction mechanisms, and rules and procedures on evidence collection on hybrid activities. It should also assess if a larger legal framework for the Counter-Hybrid Support Teams is required.
(2) a ‘NATO Secret’-level Good practices/Key lessons learned repository accessible to the NATO intelligence community and the Counter-Hybrid Support Teams. The repository acts as a reference point to support operatives in their activities.
Thirdly, encourage members of the NATO Parliamentary Assembly and European Parliament, to educate citizens and stakeholders on hybrid threats and empower them to become security enablers.
GRADUAL SPECIALISATION AND ADAPTATION OF COUNTER-HYBRID SUPPORT TEAMS?
In April, US Ambassador to NATO Kay Hutchinson stated that the spread of disinformation in North Macedonia about COVID-19 and NATO’s logistical assistance (equipment) there was rampant. She hinted that NATO would welcome any signal from Skopje to send Counter-Hybrid Support Teams to “train the people there to repel these disinformation campaigns.”[xxii] So far, the government in Skopje has not sent word.
Considering the novelty of this capability, it is too soon for a definitive or comprehensive review thereof.
About the Author
Nico works as an Investigator (Advisor) with the Internal Supervision department of the Federal Police of Belgium. He investigates transgressions of laws, police directives, deontology, and principles and values underpinning police work. He prepares and runs disciplinary procedures to penalize federal law enforcement employees found in breach of the above, and to prevent recidivism.
Previously, he was a consultant at GS1 Belgium & Luxembourg, part-time teacher in Applied Security (post-secondary school), and candidate-researcher at Inholland University of Applied Sciences Rotterdam. Nico’s first immersion in the security and defence field was an internship at the Parliamentary Assembly of the Western European Union (Paris) and as freelancer at the Brussels-based conference platform ESRT.
In 2014 he was admitted to a specialized international course at the Geneva Centre for Security Policy, which he fulfilled with success. He holds a Master of Advanced Studies in International and European Security, University of Geneva; MA in International Relations and Diplomacy, Antwerp University; and MA (Licentiaat) in History, KU Leuven.
[i] Michael Rühle, “NATO’s Response to Hybrid Threats,” RealClear Defense, November 5, 2019, https://www.realcleardefense.com/articles/2019/11/05/natos_response_to_hybrid_threats_114832.html.
[ii] “Nato announces start of Cyber Coalition exercise”, Army-technology.com, 17 November 2020, https://www.army-technology.com/news/nato-announces-start-of-cyber-coalition-exercise/.
[iii] General Report (166 DSC 15 E) by the NATO Parliamentary Assembly Defence and Security Committee, “Hybrid Threats: NATO’s New Strategic Challenge?”, 10 October 2015, https://www.nato-pa.int/document/2015-166-dsc-15-e-bis-hybrid-warfare-calha-report.
[iv] Eitvydas Bajarūnas and Vytautas Keršanskas, “Hybrid Threats: Analysis of Content, Challenges Posed and Measures to Overcome,” Lithuanian Annual Strategic Review 16 (Summer 2018): 162.
[v] Arndt Freytag von Loringhoven, “Adapting NATO intelligence in support of “One NATO””, NATO Review, 8 September 2017, https://www.nato.int/docu/review/articles/2017/09/08/adapting-nato-intelligence-in-support-of-one-nato/index.html.
[vi] Joint Declaration on EU-NATO Cooperation, endorsed by the Council of the European Union and the North Atlantic Council on 6 December 2016, https://www.nato.int/cps/en/natohq/official_texts_156626.htm.
[viii] Bajarūnas and Keršanskas, “Hybrid Threats: Analysis of Content, Challenges Posed and Measures to Overcome”: 162-163.
[ix] NATO, “Brussels Summit Declaration,” 11 July 2018, https://www.nato.int/cps/en/natohq/official_texts_156624.htm. See also the response given by NATO Secretary General Jens Stoltenberg during the pre-Ministerial press conference on 11 February 2020, of which a transcript can be found here: https://www.nato.int/cps/en/natohq/opinions_173290.htm
[x] “Montenegro tops the list of countries affected by hybrid warfare,” Cafe del Montenegro (CDM), 9 September 2019, https://m.cdm.me/english/montenegro-tops-the-list-of-countries-affected-by-hybrid-warfare/.
[xi] The two Russian intelligence officers, however, were given prison sentences in absentia. Dusica Tomovíc, “Montenegro Court Sentences 13 In ‘Coup’ Case,” BalkanInsight.com, 9 May 2019, https://balkaninsight.com/2019/05/09/montenegro-court-sentences-13-in-coup-case/.
[xii] Slobodan Lekic, “First NATO counter-hybrid warfare team to deploy to Montenegro,” Stars and Stripes webpage, 8 November 2019, https://www.stripes.com/news/first-nato-counter-hybrid-warfare-team-to-deploy-to-montenegro-1.606562.
[xiii] Jovo Martinovic and Stanko Radulovic, “Army of ‘Phantom Voters’ Casts Doubt over Fairness of Montenegro Vote,” BalkanInsight.com, 23 July 2020, https://balkaninsight.com/2020/07/23/army-of-phantom-voters-casts-doubt-over-fairness-of-montenegro-vote/.
[xiv] Oleg Kashin, “Why Would Vladimir Putin Want to Get Rid of Aleksei Navalny Now?,” NewYorkTimes.com, 21 August 2020, https://www.nytimes.com/2020/08/21/opinion/navalny-russia-poison.html.
[xv] In this respect it is useful to compare definitions of hybrid threats by the EU and NATO, as laid out respectively in the 2016 NATO Warsaw Summit Communique and the Joint Communication of the EU from the same year: European Commission, Joint Communication to the European Parliament and the Council, Joint Framework on countering hybrid threats: a European Union Response, JOIN (2016) 18 final, 6 April 2016, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016JC0018&from=LT and NATO, Warsaw Summit Communiqué issued by the Heads of State and Government participating in the meeting of the North Atlantic Council in Warsaw 8-9 July 2016, 9 July 2016, https://www.nato.int/cps/en/natohq/official_texts_133169.htm.
[xvi] NATO SHAPE, Enhanced Forward Presence. Estonia, Latvia, Lithuania and Poland, https://shape.nato.int/efp. See also: NATO Topics, “Boosting NATO’s presence in the east and southeast,” https://www.nato.int/cps/en/natohq/topics_136388.htm.
[xvii] Joseph Trevethick, “Russia Breaks into US Soldiers' iPhones in Apparent Hybrid Warfare Attacks,” United States Army Asymmetric Warfare Group webpage, 4 October 2017, https://www.awg.army.mil/AWG-Contributions/AWG-Recruiting/Article-View/Article/1809240/russia-breaks-into-us-soldiers-iphones-in-apparent-hybrid-warfare-attacks/. “German troops taught to resist cyber attacks in Lithuania,” Lithuanian Radio and Television (LRT) English, 16 December 2019, https://www.lrt.lt/en/news-in-english/19/1125722/german-troops-taught-to-resist-cyber-attacks-in-lithuania.
[xviii] Lawfare describes a method of warfare where law is used as a means to achieve a military objective. Contributions to the literature on lawfare have caused confusion about the concept and watered down its essential meaning. According to the Council on Foreign Relations, the first type of lawfare between conflicting parties is asymmetrical (akin to hybrid warfare). See Council on Foreign Relations, “Lawfare, the Latest in Asymmetries”, 18 March 2003, www.cfr.org/defense-and-security/lawfare-latest-asymmetries/.p5772. A useful starter on lawfare is: https://www.sciencespo.fr/enjeumondial/fr/conflits/part4-1.html.
[xix] Transcript of the statement and answers given by the NATO Secretary General at the pre-ministerial press conference on 11 February 2020, https://www.nato.int/cps/en/natohq/opinions_173290.htm.
[xx] Chemical, Biological, Radiological and Nuclear. See: Bernd Allert, “NATO’s Response to CBRN Events,” in Cyber and Chemical, Biological, Radiological, Nuclear, Explosives Challenges: Threats and Counter Effort, ed. Maurizio Martellini and Andrea Malizia (Berlin: Springer, 2017): 35-47.
[xxi] Freytag von Loringhoven, “Adapting NATO intelligence in support of “One NATO”,” NATO Review, 8 September 2017, https://www.nato.int/docu/review/articles/2017/09/08/adapting-nato-intelligence-in-support-of-one-nato/index.html.
[xxii] “FPC Press Briefing with Kay Bailey Huthison,” U.S. Mission to NATO webpage, 14 April 2020, https://nato.usmission.gov/april-14-2020-press-briefing-with-kay-bailey-hutchison/.