Landscaping the male & female condom and lubricant market in Cameroon - usaid

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Landscaping the male & female condom and lubricant market in Cameroon - usaid
Landscaping the male & female condom
          and lubricant market in Cameroon
                  Applying a total market approach lens to identify programmatic
                  gaps and sustainable solutions to support delivery of condoms,
                                    female condoms, & lubricant

October 7, 2016

Chris Jones, chris@jonesglobalinsights.com
Kuyosh Kadirov, kkadirov@usaid.gov
Landscaping the male & female condom and lubricant market in Cameroon - usaid
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              2
Project aim: Document the landscape for male and female condoms, lubricants in
Cameroon, through the lens of a total market approach
Landscaping of the condom market (public, commercial, and NGO/SM) will support the development of strategies supporting
sustainable condom use through equitable access to condoms outlined in the National Strategic Plan /Comprehensive Condom
Programming (NSP/CCP)

   Objectives:
         1.   Analyze existing condom/female condom/lubricant programming environment, capacity & resources in country. Map
              donor priorities, funding commitments, and partners’ reach in condom, FC, and lubricant procurement, distribution, & promotion.
         2.   Determine and assess support in Cameroon for a TMA to sustainable condom/FC/Lubricant delivery, exploring capacity
              to implement a TMA, and potential coordinating committee mechanisms to steward a TMA
         3.   Understand who the condom/FC/lubricant market is failing in Cameroon. Segmented by geography, gender, socio-economic
              status, risk profile (i.e., Key Population), quantification will identify total estimated NEED of condoms/FC/lubricants by KP, against
              existing use / coverage.
         4.   Understand how the market is failing vulnerable and key populations. Assess stage of market, analysis of actors on
              the core supply & demand function, and supportive market functions to dial in where and how the market is failing
              populations, and focus interventions of future
         5.   Fill existing gaps /activities outlined in the NSP/CCP
         6.   Cameroon is an opportunity to apply, test, and refine a TMA / Market Development Framework in support of
              sustainable delivery of key HIV prevention commodities, informing application in other countries and contexts.

                                                                                                                                                       3
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              4
The Donor Landscape supporting Condom, Female Condom, & Lubricant Interventions
Rapid phase out of subsidy for commodities next 2-3 years: KfW phasing out support for commodities by
2019; UNFPA ending support for commodities from 2018.
                      USAID/USG                                    KfW                                    UNFPA                      Global Fund
Key             Supporting Cascade of          HIV prevention through condom social             Technical Support and          HIV prevention among key
Objectives &    Prevention to Treatment        marketing. ACMS, a member of the PSI             Provision of Key FP & HIV      pops. PR and primary
description     through CHAMP. DoD support     network, implementing partner, managed           prevention Commodities.        implementing partner is
                to military. PEFPAR support    through PPSAC (HIV/AIDS prevention project                                      CAMNAFAW, an IPPF affiliate.
                (commodities) to CBCHS         in Central Africa, regional coordinating body)
                (FBO), CAMNAFAW (IPPF
                affiliate)
Funding         Funding and commitments        Designing ‘next and final phase of               From 2018 no further           New Funding model grant
Timelines &     made annually. Majority        support, ending 2019: 10 million Euros over      support for commodities.       running over 15 months.
levels          prevention commitment          3 years for region – 7m targeting Cameroon.      Cameroon classified as
                through 5 year CHAMP           Programming funding from summer 2017-19,         Category B country and shift
                program – ($18.8 m through     perhaps a year more. Next phase of budget is     to GoC financed, sustainable
                mid 2019).                     limited – no funding for Female Condom.          provision of commodities.
                                               ACMS could use PI to support SBCC, or
                                               procure FC.
Commodity       Commodities (condom, female    70 million condoms procured and                  Imported 15.6 m condoms in     5 million condoms through
Commitments     condom, lubricant) targeting   delivered through Dec 2020. No support for       2015, 14.84 m in 2016; 2.46    quarter 1 2018. Lubricant
                specific key populations       Female Condom. Condoms for SM running at         FC in 2016, 1.835 m FC in      support as well.
                through implementing           ~24-30mm condoms/year, 700k FC / year.           2015.
                partners. 2017 plans ~7
                million condoms, 1.5 million
                FC, lubricants
Priority Pops   Key Pops                       General Pop, Key Pops                            WRA, General pop, & KP         SW, MSM, male clients, youth.   5
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   23
                                     Market

                                     Readiness to Steward a TMA          27

                                     Recommendations Moving Forward      32
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             35
                                                                              6
Condom Use and Needs– Who is the market failing?
Total market size based on self reported use is 143 million units/year, against total need of ~250 million condoms / year. An estimated 105
million condoms/year are required to fill the gap between self-reported condom use today, and condoms needed to ensure every high risk sex
act is protected with a condom (Universal coverage).

                                                                                                    • Volumes of condom use and
                                                                                                      need driven by sex work;
                                                                                                      estimated more than 98,000 SW
                                                                                                      in Cameroon, many of them high
                                                                    105 million
                                                                                                      frequency SW (pop estimates &
                                                                                                       behavior data from JHU risk factors study).

                                                                                                    • An estimated 25% of men
                                                                                                      reported sex with more than one
                                                                                                      partner in last 12 months;
                                                                                                      condom use less than 50%. (2014
                                                                                                       MICR5)
                                                                                                    • The high proportion of WRA that
                                                                                                      rely on condoms for FP (33%+ of
                                                                                                      those using a modern method)
                                                                                                      contributes to total condom use.
                                                                                                       (2011 DHS cites 66% condom use in method
                                                                                                       mix, downward revision from Contraceptive
                                                                                                       quantification wkng group)

                                                                                                                                                     7
Condom Use – Who is the market failing?
•   Condom Use high during Higher Risk Sex:
    • 82% of SW report using a condom ‘every time’ or ’almost every
      time’ they use condom (JHU)                                                      70                                                           66.5
      • Bamenda, Bertoua, Ngaoundere lagging every time use.
    • 53% of MSM report condom use every time (Johns Hopkins U)                                                   57.4
                                                                                       60                      54.7
    • Anecdotally, Sex workers, MSM report increasing rates of use.
                                                                                       50       46.5                              46.5
                                                                                                                                                 43.0
•   Usage gaps & Concerns, driven by:                                                        40.5

                                                                         Pourcentage
                                                                                                                               37.3
    • Self-reported condom use among all women and men actually                        40
      declined between 2004 and 2011 - Waiting on 2016 DHS data.
    • Clients: For SW, clients often insist sex w/out condom. Offering                 30
      more for sex w/out condom. SW cite lack of ‘social support’ from                                                                                     15-49 ans
      peer group as client knows he can go to next SW if she refuses.                  20
    • SW condom use w/‘Boyfriends’ or protectors also low – just                                                                                           15-24 ans
      27.5% use condom ‘every’ or ‘almost’ every time. (JHU)                           10
    • Newer SW entering to profession reported vulnerable
    • MSM report conditional use for partners that look “healthy” or                    0
      strong.                                                                               Femmes            Hommes          Femmes            Hommes
    • Men w/Multiple Partners: Of those reporting sex with more than
                                                                                                       2004                              2011
      one partner in the 12 last months, just 43% of women and 49.5%
      of men reported condom use at last sex. (From 2014 MICS)                               Pourcentage ayant utilisé un condom au cours des derniers
•   DHS (dated) indicates significantly lower condom use by lower                           rapports sexuels à hauts risques parmi les personnes qui ont
    wealth quintiles.                                                                       eu des rapports sexuels au cours des 12 derniers mois ayant
•   FC valued as ‘back up’ method when male clients decline condom                                               précédé l'enquête
    use.
•   Lubricant’s highly valued by MSM and SW, and would like to see
    availability in retail outlets.
                                                                                                                                                                       8
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              9
Cameroon Male Condom Market Structure - 2016

                  Manufacturers/
Who pays                                      Importers                                 Distributors/ Wholesalers                    Providers                     Consumers
                    Marketers

                       Manix                                                                                                         Private
                                          Pharma Distributors: Ubipharm, Laborex (60%+                                            Hospital/Clinics                Consumers
                      Domino                                market)                                                                                                 (prestige
                                                                                                                                Registered Pharmacies               segment)
  Commercial/                             Campharm & other smaller distributors - < 40%                                               (450-500)
  SM - Pharma        Innotex
  Commercial/
  SM - FMCG             Sure                                                                                                           ~90k outlets                  76% mkt
  Free (public                                                                                                                          Drug Shops
  & other)            Prudence                                                                                                                                    Consumers: Gen
                        Plus                                                                                                       Super Markets / petrol
                                             ACMS (~30m/year + ~4m free?)                                                                 stations                Pop and KP:
                                                                                                                    Semi-                                         • SW
                         Kiss                                                                                                        Boutique / kiosks
                                      DKT (~2.5 m year, planned growth to 4.5m /year)                             Wholesalers                                     • MSM
                                                                                                  Whole-                                                          • Truckers
                     SM brands                                                                                                       Bars/clubs//hotels
     KfW                              Entrepreneurs / Wholesalers                                 salers                                                          • Military
                      (leakage)
                                                                                                                                                                  • Prisoners
                        Alex                                                                                                          Brothels/hostels
      dkt
                                                    FMCG Distributors
                      Other                                                                                                             street vender
                      brands

                                                              CAMNAFAW (~5m condoms)                                                   CBOs (106 -
                                                                                                                                         GF & 6          KP DIC
 Global Fund                                                                                 CHAMP (862k condoms)
                       Generic                                                                                                          CHAPMP)           OWs        Consumers
                      Condoms          USAID/PEPFAR                                                                                                                   24% Free
                                                                                        DOD (400k condoms), CDC/CBCHS (416k)
  USAID/USG                                                                                                                                      Mobile units       (small fee @
                     • GF ~5m;             UNFPA                                                CNLS (4.87m condoms )                                                   HC)
    UNFPA
                     • UNFPA 14.8m;                                 CENAME                                                               Public
                     • USAID: 4.3m
                                                                    (3.62 m)                               FSPS                         Hospitals
                                                                                                                                      Public Health
                                                                                                                                                                                10
                                                                                                                                        Centers
Overview of Cameroon Condom Market
 Market about to become more dynamic w/new entrants, although currently limited choice for lower income populations: Free, Prudence Plus, & Alex.

   Public Sector – Free & near free                            Social Marketing Sector                                             Commercial Market
                 ~31% market                                             ~34% of market                                               ~35% plus of market

                                                   ACMS: Prudence Plus largely flat sales over 10 years. Established
                                                   the condom market in Cameroon, creating widespread access and
                                                                                                                          • Commercial market volume doubled in
   • GoC has included a budget line item for
                                                   acceptability; continued promotion (generic & some branded).             size over last 10 years, perhaps more.
     contraceptive commodities last few years
                                                   Consumer price remained at 100 CFA since launch, although shifted
     but never spent on that line item
                                                   from 4 to 3 condom pack in 2011 and tightened trade margins.
                                                                                                                          • Very little to no investment in promotion.
     (reallocated)
                                                        o    PPSAC led qualitative brand research paints picture of       • ”Prestige Market’ in sophisticated
   • UNFPA, USG, & as of 2016, GF                            Prudence Plus as aging brand ‘of our father’.
     (CAMNAFAW) primary supporters of free
                                                                                                                            pharmaceutical sector stable – growth to
                                                        o    Revenues do not currently recover commodity +                  2014, steady since, focused on high value
     distribution.                                           packaging COGS (78% cost recovery).
   • Generally coordinated distribution coupled                                                                             & multiple SKUs. FMCG (Consumer
                                                        o    Plans in place to launch regional brand which will also
     w/outreach/promotion to KPs –                           enhance sustainability through improved cost recovery.         goods) market highly fractured, large #
     o USAID targets 11 districts through 6                  Broader sustainability strategy in development.                outlets, but effective & efficient at
        CBOs,                                      DKT just launched Kiss, a youth focused, regional (Central/West          distributing needed products, including
     o GF (through CAMNAFAW) 29 districts in       Africa) brand promising to shake the market up. Priced at 200 and        condoms.
        10 regions & 105 CBOs;                     250 CFA, with 4 variants (flavored / textured).
     o Most UNFPA supplied condoms target               o    Kiss is currently commodity/packaging cost recoverable,      • Continued punctuated presence of low
        health centers, .                                    supported by lean operations team. Marketing support,          end brands, but…
                                                             driven at regional level, rolling out later this year.
     o Coordinated distribution in overlapping               Revenues don’t cover operating costs.                        • Alex, recent addition to market, is
        districts. Support package consistent           o    Fiesta, an upscale brand planned for launch next year in a     affordable @ 200 CFA, and potentially of
        across KP (12 condoms, lube)                         strategic effort to cross-subsidize brands and                 reasonable quality . Now widely available.
   • Free distribution widely appreciated by KPs             programming.                                                   Found a niche and exploiting with
                                                     PPSAC currently undergoing market research to launch affordable        attractive product and margins to retail.
                                                          (~150 CFA) regional condom targeting youth
                                                                                                                                                                         11
Cameroon’s Commercial Market Structure
The distribution market works – while the consumer goods (FMCG) market is not sophisticated, it has broad, efficient reach. Qualified as
‘Nascent’ to ’Developing’ market using Abt. Associates market indicators.
A tale of two markets - there is little cross-over between the pharmaceutical and FMCG markets. Larger pharmaceutical distributors don’t sell
products available in the ‘open market’( FMCG)– largely because regulated margins make it difficult for pharma to compete.

 Pharmaceutical Sector – Low condom volumes, high                             FMCG – high condom volumes, lower value/price
                   value/quality                                                           questionable quality
 • Sophisticated market driven by larger players: Laborex and Ubifarm         •   Fragmented, less sophisticated then pharma, but it works in
   account for ~60+% of market. Sophisticated import, distribution / supply       efficiently and effectively distributing products to nearly 90k
   chain systems, from warehousing to fleet of trucks supporting delivery.        outlets.
 • Tightly regulated and controlled: sell to just ~450-500 registered         •   Larger players include a few (~3) emergent large distributers that
   pharmacies + clinics/hospitals / para pharmacies. Margins establishes by       also import, such as Henri & Bros, complimented by smaller
   law:                                                                           distributers connected to international FMCG brands (i.e., Nestle).
      •   customs clearance tax’ (confirm) – 2%                               •   Most FMCG distribution characterized by many dozens of
      •   Distributer mandated margin: 25%                                        regionally focused, passive wholesalers and many more semi-
      •   pharmacy mandated margin – 35%
                                                                                  wholesalers, selling product to more than 90k retailers that pick
      •   Condoms VAT exempt
                                                                                  up on sight. Credit little deployed.
 • The French based pharmaceutical system: Distributors do not ‘promote’
                                                                              •   Margins:
   or market specific products, but do focus on importation, distribution,
                                                                                     • Import: 5% value tax on good
   logistics, supply chain mgt.
                                                                                     • Wholesaler: 33%
 • Non pharma products small part of business: ‘Para-pharmaceuticals’
                                                                                     • Semi-wholesaler: 9-28% (depending on quantity, purchase
   (toiletries, feminine care, includes condoms) account for just 10% of
                                                                                         behavior)
   market.
                                                                                     • Retail: 40%
                                                                                     • Condoms VAT exempt
                                                                                                                                                        12
Depth of the Condom market– Total volume / size of the market
40% growth in Condom market in last 10 years, largely driven by commercial sector, and free distribution. SM sales largely flat over 10
year period. Robust commercial market, showing impressive growth, indicates potential.

                                                                 ~31%
               ~35%

                                                                   ~34%

                                                                                         •   The total estimated market size of ~70 million condoms/year
                                                                                             is considerably less than the 143 million estimated as used.
                                                                                         •   Likely size of commercial sector is underestimated: Condoms are
    Data compliments of ACMS & UNFPA’s RH interchange. Commercial market size                imported and not registered at customs. Commercial sector likely
    estimated through ACMS retail studies and analysis of customs data. ’Free’ aligned       larger than the 24 m estimated.
    to procurement in given year, not distribution. 2016 data estimated.
                                                                                                                                                                13
Market Structure
                                                                                                                                                      Breadth of
Breadth of Condom Market – Number of brands and activity on market                                                                                      Market
ACMS has 2 brands at 100                                                                  Gap in market w/ potential
                                                            PPSAC                         for affordable, cost
CFA – opportunity to                    Free /   Lover’s     youth     Kiss (dkt)
segment by price                                  plus                                    recoverable brands
                                        retail              condom
                           Free HC /             Prudence      ?                        Fiesta? (dkt)
Free & SM condoms          Outreach                plus                        Kiss variants
Private sector condom                               Intimy, Superlove Alex                                        Sure        Inotex           Mannix     Domino

Consumer Price CFA          0–5         17          100            150 -     200     250                  500      650          750            1200+       2400

                              Poorest                       Second                           Third                       Fourth                         Richest

                                                                                                                  Pharmaceutical Sector
                  “Open market” (FMCG consumer products)                                                            ‘Prestige’ Brands
            •   FMCG selling lower priced, sometimes lower quality products; not             •   Registered, tested, recognized international, high quality, high value
                registered & unknown testing                                                     brands. Multiple brands & SKUs with variants, packet sizes. Driven by
            •   Brands have a punctuated presence, indicating opportunistic,                     likes of Manix, Innotex, Domino, Sure. Targeting upper market, from
                sporadic purchasing by importers.                                                upwards of 650 CFA packet of 3. Prudence and Kiss present.
            •   ‘Super Alex’ however, was virtually omnipresent w/Prudence Plus.
                                                                                             •   Due to legally mandated margin requirements, pharmaceutical
                Alex favored throughout the distribution chain b/c of favorable margins
                                                                                                 distributors do not sell condoms also available on the ‘open market’ as
                it offered throughout, while still affordable to customers @ 150-200
                                                                                                 they can’t compete on price.
                CFA.
            •   Fewer SKUs, generally fewer choices than pharma (1-3 per outlet).
                Most outlets invest in no more than 2-3 brands.
            •   Prudence Plus widely available, generally offered only when Alex
                refused.
            •   Leakage of free condoms at times into retail – particularly around hot
                                                                                                                                                                           14
                spots.
Market Structure
                                                                                                                                                Affordability
Are Social Marketed Condoms affordable?

• ACMS has not adjusted consumer price                     The relative cost of social marketed condoms is decreasing
  since launch (did shift from 4 pack to 3
  pack in 2010, and recently tightened
  margins to trade).
• Both SW and MSM report (anecdotally)
  condoms are affordable.                                                                                                    Effective price
                                                                                                                                increase
  - ”they can easily afford buying for
  themselves, the condoms are everywhere’
  msm
  - “Prudence is affordable. If we don’t get
     free, we will go back to paying for them.”
• Priority: Need for Willingness to pay
  study to better understand purchase
  behavior in a changing market

                                                                                                                                                                  15
  GNI data per WB; relative cost of CYP determined by 100 condoms @ estimated CFA USD exchange rate relative to GNI/capita
Market Structure
                                                                                                                          Breadth of
Breadth of the Market: Condom Access and Availability                                                                       Market
Condoms widely available in urban areas, both for general population through pharmacies, shops, and KPs in
hotspots (bars, umbrella stalls, etc).

 100%
                                            90.40%
  90%   80.90%
                                                     77.80%
  80%            73.50%
  70%                     66.10%
                                   61.40%
  60%
  50%
  40%
  30%
  20%
  10%
  0%

                                                              • 86% of SW report it ‘easy’ to find condoms, 34% report easy to
ACMS Coverage of outlets – Condoms **(measured as               find Female condom, and 42% easy toit find lube. (JHU)
Prudence Plus in 2 or more outlets in a given geographic
territory)                                                    • Significant drop off of coverage in rural areas - which aligns
                                                                with lower reported condom use - although access aligns
                                                                with prevalence (high prevalence urban areas covered).
                                                              • SW more likely to buy then get free, with only 5% relying only
SW condom acquisition by outlet and where purchased             on free distribution.
from JHU study.                                                                                                                            16
The Public Sector (Free) Market
What’s wrong with free condom distribution?

• “Lumpy” binge and purge procurement
  leading to inconsistent condom supply -
  creating challenges for commercial &
  SM to sustain retail interest.                                                                                            2015 / 16 free
• Free condoms are impacting, to an                                                                                          distribution
                                                                                                                             3x’s that of
  extent, SM and Commercial markets -                                                                                        prior 7 year
  popping up at retail around hotspots,                                                                                       average
  price of 6 condoms for 100 CFA, or 144
  for 1,500.
• Subsidy wasted on those that can, and
  are willing to, pay
• Both SW and MSM report (anecdotally)
  condoms are affordable.
  - Willingness to Pay study required
    to confirm

    Free distribution data from UNFPA RH Interchange site. Procurement, rather than distribution, presented (distribution
                                                                                                                                             17
    presented inappendix).
Free Distribution – Recommendations
With imminent reduction in funding available for condoms, need to make the best use of scarce subsidy by
targeting those Cameroonians at risk.

  • Coordinate future procurement & distribution of free condoms                     Is it feasible to integrate CHAMP supported CBOs
    through quantification that builds in the contribution of SM and                 into more sustainable ACMS SM interventions?
    commercial market actors through the GTTP/TMA work group. Condom                 Aim to transition KP back to SM products, build on KP
    quantification and forecasting for HIV and FP could include support
    from Deliver/GHSC.                                                               work of ACMS.
                                                                                     Explore possibility:
  • Target free distribution to populations based on need through
    segmentation, such as geography (i.e., rural, where condoms are not               • Targeted interventions could enlist CBO staff to
    as accessible & affordable), ability and willingness to pay, and                     target outlets with Prudence Plus merchandizing
    preferences. Approaches could include:                                               (condom promo materials); identifying and linking
    o   Revisit standard distribution package (currently at 12 condoms/contact)          outlets w/ACMS sales teams at high risk areas;
        based on consumer segmentation strategies. e.g., high need (low ability to
        pay) segment receive package of 12; medium need 6 condoms, etc.                  linking KP to target outlets; targeted sales to
        Determine if outreach workers can be equipped to segment users by need.          specific outlets such as hostels.
    o   Position free condom distribution as behavior change / motivational tool      • Secondary benefit of empowering CBO staff, and
        rather than source of ‘free supply.’
    o   Leverage free consumers as ‘samples,’ linking beneficiaries to commercial
                                                                                         potential of program income to support operations.
        access points.                                                                • Feasibility would require training required for CBO
  • Lubricants: Continue to support targeted distribution of free lubricants.            staff, systems required to support targeted SM
    While demand was expressed for a commercially available lubricant,                   efforts, how to link KP strategies to social marketing
    unsure whether market would support such an introduction w/out                       efforts, funding to support. Request concept note
    investment – Recommend DKT or ACMS explore market potential
    and appetite to launch as variant.                                                   from ACMS within year.
  • Female Condom: Continue targeted free distribution. USAID to                      • Depends on ACMS sustainability strategy & future
    collaborate with KfW to determine how to support continued provision of              pricing decisions– will SM be affordable for KP?
    Female Condom in support of social marketing efforts.
                                                                                                                                                  18
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              19
A framework to analyze the ‘health’ of the Cameroon Condom market1
While market failure or weakness can often be explained by analyzing actors supporting the Supply & Demand function (from
commercial, SM, NGO, & public sector actors), systemic market failure or weaknesses can be understood by analyzing
supporting functions, rules, and financing functions.

                                                                        Partnerships                                                   The ’Donut’ draws attention to the range of
                                                                                                                                       actors supporting market functions.
                                                            Coordination
                                                                                   Subsidies                                           The framework distills the key factors
                                                   Commodity forecasting                                                               influencing how a market operates into four
                                                    R&D                                                                                categories:
                                           Information
                                                                                                           Credit facilities           1. Core supply & demand (the target of most
                                     Quality                                                                                              interventions, such as procurement of
                                   Assurance                                                                                              subsidized commodities, or demand
                                                                 Core Supply & Demand                                                     creation for consumers)
                                                                                                                                       2. Supporting Functions such as government
            Cause may                                            Distrib-                                                                 bodies assuring quality, access to market
                                                                                                                          Problem we
            lie here…                                            uters /        retail                                                    information, or coordinated efforts
                                                Importers                                  consumers                      see here
                                                               wholesalers                                                                between the public and private sector;
             Or here…                                                                                                                  3. Financing Functions in a market such as
                                                                                                                                          condoms generally boil down to how
                                                                                                                                          subsidy is delivered;
                                  Regulations                                                               Informal rules             4. Rules environment include regulations
                                                                                                               & norms                    and how products are licensed.

                                                                                                                                       The Donut helps distinguish underlying root
                                                 Taxes                                         Licensing                               causes of a market’s – why it may not be
                                                                                                                                       serving those in need.
1RefBarbara O’Hanlon, Ohealth
Consulting & Springfield Centre
                                                                        Rules
                                                                                                                                                                                20
Identified Market Constraints                                                                                Leveraging PSI’s Production to Use assessment tool

                                                                                                                          DISTRIBUTORS/
                                                                             IMPORTERS                                                                        Retailers                                                 CONSUMERS
                                                                                                                          WHOLESALERS

                                                 Lower priced condoms of unknown quality; punctuated presence                                                                          Consumers still have limited options for affordable product – Free,
                                  PRODUCT
                                                 in market.                                                                                                                            Prudence Plus, and Alex.
CORE SUPPLY & DEMAND FUNCTION

                                                                                                                      Trade is biased toward higher margin products, sometimes
                                                                                                                                                                                       Provider bias toward higher margin product (Alex). Condoms widely cited
                                    PRICE                                                                             of dubious quality (such as Alex over Prudence Plus);
                                                                                                                                                                                       as being affordable, including KP (SW, MSM).
                                                                                                                      Prudence not displayed, and generally not initially offered.
                                                                                                                      Coverage drops fairly dramatically in rural area. However, condoms widely available in urban, peri-urban areas and at / in hot spots.,
                                    PLACE
                                                                                                                      aligning w/epidemiology
                                                                                                                      Little business to business product promotion by importers
                                                                                                                                                                                           No harmonized national Social BCC / Category Promotion strategy to
                                                                                                                      (distributors/wholesalers to retailers) – Little to no brand
                                 PROMOTION                                                                                                                                                 address persistent barriers to consistent condom use – which continues
                                                                                                                      promotion / merchandising occurring (point of sale
                                                                                                                                                                                           to lag in key populations.
                                                                                                                      materials, etc)
                                                 Insufficient understanding, monitoring, and inter-sectoral coordination of the condom
                                INFORMATION /
                                                 market– sectors are not working in coordinated approach to achieve sustainability goals,
                                PROCUREMETN
                                COORDINATION     goals are not clear. Private sector not engaged; Little procurement coordination of free,
                                                 SM, and commercial sector results in leakag e of free into commercial markets, etc.
                                                 Free & SM condoms only condoms consistently tested. Quality
                                   QUALITY
SUPPORT

                                 ASSSURANCE
                                                 of condoms in commercial market largely unknown – particularly                                                                        .
                                                 lower end condoms such as Alex.
                                                 Inconsistent guidance and understanding on requirements to
                                  GUIDANCE       register and test condoms means condoms ‘registered’ at import
                                                 but not with DPML–no testing happening.
                                                 Low level of common understanding of TMA and how to translate
                                  CAPACITY
                                                 concept to reality.
                                                 While condoms are on the essential list of medicines, disconnect
                                                 between how condoms are registered for importation, and
                                 POLICY AND
                                REGULATIONS
                                                 requirements for registration. Insufficient to no guidelines exist
                                                 for either registration or testing. Most commercial condoms
RULES

                                                 currently not registered, fewer tested.

                                Informal Rules                                                                                                                                         Conditional Condom use by male clients driven by pleasure, potentially
                                  and norms                                                                                                                                            low risk perception.                                                         21
Identified Market Failures in the Cameroon Market
Areas highlighted in red indicate structural weaknesses in the condom market.

                                                         Partnerships
                                              Coordination
                                                                           Subsidies
                                     Commodity forecasting                                                       The market Landscaping
                                        R&D                                                                      exercise identified the
                            Information
                                                                                             Credit facilities   highlighted weaknesses, or
                        Quality                                                                                  inefficiencies, in the condom
                      Assurance                    Core Supply & Demand                                          market.

                                                                                                                 By addressing the root cause
                                                   Distrib-
                                  Importers        uters /
                                                                                                                 of each of these weaknesses,
                                                                  retail       consumers
                                                 wholesalers                                                     it’s possible to move beyond
                                                                                                                 traditional procurement and
                                                                                                                 delivery of condoms to
                                                                                                                 systemic, sustainable
                       Regulations                                                           Informal rules      improvements in the condom
                       – import &                                                               & norms          market.
                       quality

                                     Taxes                                       Licensing

                                                          Rules
                                                                                                                                                 22
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              23
The role of subsidy in the condom market
How much subsidy is currently required to support cost of condom commodity and packaging?

                                                                                    2015                              2016
      Male Condoms               (commodity & shipping)                                   $839,554                        $678,337
      Female Condoms                                                                    $1,539,842                     $2,223,455

      Total                                                                             $2,379,396                     $2,901,782

         • ACMS CSM is currently at ~ 78% commodity and packaging cost recovery. Subsidy estimates assume revenue generated
           from sale of condoms are re-invested in commodity. A 25% price adjustment would place the product at or near commodity
           cost recovery.
           • Important to note donor support / subsidy is required to support distribution, promotion and other programmatic
              support.
         • DKT’s Kiss condoms (commodity + packaging)) are fully cost recoverable at 200/250 CFA. Light presence in country, coupled
           with regionalized program management (from marketing through supply chain mgt.) indicate promising model to cost
           effectively support condom provision. Revenues from Kiss do not support operational costs.
         • Further analysis required to determine level of subsidy required to support distribution (including to KP), marketing
           /promotion efforts. While difficult to understand how subsidy is supporting every element of use (product, distribution/access,
           promotion/demand, overheads) it would be possible to make strategic investment decisions understanding.
         • Female condoms, at an estimated $0.57/unit, are nowhere near cost recovery; willingness and ability to pay indicate significant
           subsidy will be required to support affordable access in future.

Data for Female Condom and male condom extracted from UNFPA RH interchange
site, and SM data from ACMS and DKT interviews.                                                                                              24
Who Does, Who Pays?
How Subsidy is deployed in the Cameroon Condom Market: Current state of the market

                                                            Core Supply & Demand
                                                                      Players
          Functions and rules                           Who does?               Who pays?                       Why?
                                                                            Donors (KfW, UNFPA,
               Manufacture                                                                           Belief that condoms needed to
                                                       Manufacturers           USAID, GF) &
              (Procurement)                                                                                     subsidized
                                                                             commercial sector
                                                    UNFPA / USAID
                                                    GF/CAMNAFAW                Donors (mostly)
        Importers / Supply chain                                                                        Has long been this way
                                                         ACMS                   Private sector
                                                     Private sector
                                                         NGOs
                                                                                 Donors
       Wholesalers / Supply chain                 GoC (CENAME, FSPS)                                    Has long been this way
                                                                                Wholesalers
                                                      Wholesalers
                                                                                                     Margins presumed to support
                                                  Pharmacies, Retailers,    Pharmacies, Retailers,
     Retail / Pharmacies / Providers                                                                  sale and donors to support
                                                   CBOs, govt. Clinics            Donors
                                                                                                                CBOS

                                                                                                     Needed to address emergent
     Consumer (Demand Creation)               Social marketing, CBOs, GoC          Donors
                                                                                                            threat of HIV

 ‘Who does, Who pays’ is construct of Springfielde Centre
                                                                                                                                     25
Who Does, Who Pays?
How Subsidy is deployed in the Cameroon Condom Market: Future state of the market

                                      Core Supply & Demand Functions
                                                              Players

        Functions and rules                  Who does?                      Who pays?                        Why?

                                                                                                    Donor resources no longer
             Manufacture                                              GoC, donors (targeted) &
                                             Manufacturers                                           available, GoC commits
            (Procurement)                                             commercial & SM sector
                                                                                                      budget line to procure
                                            Private Sector               Donors (targeted)          Private sector and SM cost
                                                                      SM entities (cost recovery
                                          Donors (targeted)                                            recoverable, targeted
       Importers / Supply chain                                          Program Income)
                                        Sustainable SM entities                  GoC
                                                                                                   procurement of GoC / donors
                                                 GoC                    Commercial sector               to support free dist.
                                                                                                 Margins support distribution,
                                        GoC (CENAME, FSPS),              Donors (targeted),       except for targeted donor
     Wholesalers / Supply chain
                                             wholesalers                 Wholesalers, GoC         support for high risk pops.
                                                                                                  GoC pays for supply chain
                                                                                                 Margins presumed to support
                                      Pharmacies, retailers, CBOs,   Pharmacies, retailers, GoC,
    Retail / Pharmacies / Providers                                                              sale. Targeted donor support
                                             Govt clinics                 donors (targeted
                                                                                                   for dist to high risk pops.
                                                                         Donors (targeted)
                                                                                                Sustained support of demand
    Consumer (Demand Creation)                  NGOs                 Manufacturers / commercial
                                                                                                creation required by donors.
                                                                        sector, SM entities

                                                                                                                                 26
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    20

                                     How is the Market Failing –         10
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              27
Capability Assessment of Stewarding a TMA
The drafting of the NSP/CPP and formation of the GTTP are important first steps toward a coordinated approach supporting a
sustainable condom market. Both can and should be leveraged to move a TMA agenda forward. Membership composition of the
GTTP has ensured right people at the table.
The stewardship role involves collecting and analyzing data to better understand the market; engaging sectors and actors to coordinate efforts;
monitoring and regulating the quality of commodities; and monitoring progress along TMA indicators. The framework below was leveraged in the
rapid assessment of the readiness of the GoC and partners to steward markets*.
1                                                       2
            Understand the Market                                     Policy & Dialogue                          3                 Regulation

     • Data Collection                                       •    Mandate & Governance                               • Sufficient Funding Sources
     • Data Analysis                                         •    Sufficient Funding sources                         • Legal Framework
     • Data Management                                       •    Recognized Need                                    • Regulation
     • Data Quality                                          •    Monitoring & Evaluation
     • Data Dissemination & Application                      •    Human Resources

    * Adapted from the Abt Associates: Total Market Approach Stewardship Capacity Assessment Report.
    http://www.rhsupplies.org/uploads/tx_rhscpublications/Total_Market_Approach_Stewardship_Capacity_Assessment_Report_-_07_31_15.....pdf           28
Critical Components of Stewarding a TMA (I)
Understanding all components of the market – the public, social marketing, and commercial markets is a
critical step in coordinating the market response to support sustainable, equitable use of condoms.
                                  Data Collection / Data Analysis / Data Management / Data Quality / Data
                                                        Dissemination & Application
                              Key Findings & Insights
                              •   ACMS has been tracking key market indicators related to Health Impact, Equity, and efficient use of subsidy
      Understand the Market

                                  in Cameroon.
                              •   Data gaps remain - public sector distribution not fully integrated into analysis, while unregistered (‘dark
                                  market’) private sector data – a potentially large element of the market - is not being estimated or analyzed.
                              •   Significant opportunities exist to improve on data quality, dissemination, analysis to inform specific
                                  decisions.
                              Opportunities & Recommendations:
                              •   Include Understanding of the Market as an integral priority of the GTTP. In addition to core supply and
                                  demand market elements, build into analysis total current use against need, and holistic market elements
                                  such as support and financing functions, the role of rules and regulations in supporting markets.
                              •   Form a sub-working group to lead this important function – designating leadership, milestones, and
                                  supported by clear work plan. The role of the sub-working group will be to present findings to inform
                                  decisions to the broader TWG.
                              •   Adopt a uniform set of indicators to measure progress toward a TMA. New guidance outlining
                                  approaches can be found here Measure Evaluation - indicators measuring FP markets

                                                                                                                                                   29
Critical Components of Stewarding a TMA (II)
General Consensus the GTTP is ideal coordinating mechanism to support stewardship of TMA, but requires
 further investment in capacity development to deliver on the promise.
                             Mandate & legal framework / Sufficient funding sources / Recognized need /
                                                     Monitoring & Evaluation
                            Key Findings & Insights
                            • Little common understanding of TMA as concept, and specific activities to support the objectives of a
                               coordinated, sustainable, healthy condom market.
                            • Insufficient resources – financial and HR – raised repeatedly as a barrier, particularly by GoC representatives.
        Policy & Dialogue

                            • Consensus that partners would like to see more from the GTTP, focusing on actionable elements of the newly
                               implemented NSP/CCP to drive interventions forward.
                            Opportunities & Recommendations:
                            • Upstream advocacy important to ensure buy in and support for TMA, and implications in implementation
                               (particularly in relation to improved targeting of subsidy and pending price adjustments). Leverage urgency of
                               imminent donor pullout.
                            • Invest (capacity building, ongoing support) in aligning understanding of TMA, & guide activities.
                            • Prioritize actions around specific agreed activities identified in the NSP/CCP, leveraging resources members
                               already have in country for early wins.
                            • CNLS leadership critical, but requires the support of a community of champions. Cascade ownership &
                               implementation of tasks to members of the TWG. Appoint working groups tackling specific tasks (e.g., sub group
                               supporting ”Understanding of the market” & “policy & regulatory challenges”)
                            • “More frequent, less long” meetings. A regular cadence of meetings – monthly was suggested – would ‘make the
                               meetings more substantive.’
                            • Leverage M&E, using TMA indicators developed for Cameroon context, to move efforts forward.
                                                                                                                                                 30
Critical Components of Stewarding a TMA (III)
Regulations establishing quality condoms in market lacking

                                   Sufficient Funding Sources / Legal Framework / Regulation

                     Key Findings & Insights
                     •     While there are very few barriers to register condoms in Cameroon– a positive for commercial
                           brands – the quality of lower priced questions is questionable. What testing that is done is by
                           SM organizations, donors, and high end brands imported through pharmaceutical sector pre
                           shipment.
      Regulation

                     •     Condoms are classified as an essential medicine. However, no formal policy or guidelines exist that
                           outline requirements for testing or even registration of condoms. It’s therefore possible and
                           technically legal to import condoms w/out registering them with DPML, or testing them at
                           LANACOM.
                     •     Unknown and questionable quality of leading condom brands at low end of market.
                     Opportunities & Recommendations:
                         • Outreach to importers of Alex to encourage testing. If necessary, seed investment to support testing &
                           registration of Alex to ascertain quality (
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              32
Market Analysis and Recommendations (I)
                 Potential interventions to address identified Market weaknesses
                                   MARKET WEAKNESS / FAILURE                                             IMPLICATIONS                                              MITIGATION STRATEGY / RECOMENDATIONS

                                                                                                                                              Invest in evidence based generic category promotion of condoms to continue to
                                                                                    While targeted interventions reaching KP proving          support and grow consistent condom usage, complimenting targeted interventions
                       1. Promotion: No harmonized national Social BCC /            effective, emergent trends (to be confirmed with          reaching KP.
Core Supply & Demand

                       Category Promotion strategy to address persistent            research) suggests male clients are significant barrier   • Emergent affordable brands on market will benefit from category promotion- such
                       barriers to consistent condom use.                           to condom use with both SW and non-paying                     as Kiss, updated Prudence Plus, PPSAC regional condom, and commercial brands.
                                                                                    partners.                                                 • Confirm need, approach & messaging through evidence driven design (including
                                                                                                                                                  assumption confirmation category promotion needed)
                                                                                                                                              • Support / encourage intro of new brands to expand and sustain promising condom
                                                                                                                                                  market. Pending launch of DKT’s Kiss/Fiesta, ACMS regional brand is promising.
                                                                                                                                                  ACMS opportunity to rationalize Lover’s Plus brand, currently at the same price point
                       2 . Product: Consumers still have limited options for        •   One size fits all solutions limited in growing &
                                                                                                                                                  as Prudence Plus, as regional Prudence Plus introduced.
                       affordable condoms (Free, Prudence, and Alex).                   sustaining use
                                                                                                                                              • Given launch of Kiss, confirm need of PPSAC youth condom.
                                                                                                                                              • Bring importer / distributor of Alex to the table to benefit from TMA efforts.
                                                                                                                                              • Ensure new entrants have access to market info generated under initiative (7) below.
                                                                                                                                               Conduct national willingness to pay studies amongst market segments, including KPs,
                                                                                    •   SM sector (and the ~30m condoms provided in            to determine impact of pricing adjustments, and determine how quickly to phase out
                       3. Subsidy: Current level of subsidy is too high (part I)        Cameroon) not sustainable.                             / reduce reliance on subsidy of condoms.
                       ACMS has not had price adjustment to consumer since •            Harder for commercial brands to compete, &             ACMS to develop and share sustainability strategy that addresses cost structure &
                       launch. KfW entering into final phase of support for SM.         retailers to sell the product, reducing access.        transitions / repositions SM brands given pullout of KfW. The strategy should lay out
 Financing Functions

                       Commodity/packaging COGS not yet recovered.               •      Lack of product differentiation and one-size-fits-all incremental pricing changes leading to cost recovery, how coordination with free
                                                                                        approach to different consumer segments inhibits distribution to manage those unable to pay new pricing, and opportunities for cross
                                                                                        use                                                    subsidization of brands. Explore whether /how Lover’s Plus can be used to segment
                                                                                                                                               market.
                                                                                                                                              • Coordinate future procurement & distribution of free with SM, commercial sector;
                                                                                                                                                  Engage quantification support from GHSC Project/Deliver for compressive
                                                                                    •   Free condoms competing with SM and commercial
                       4. Subsidy: Current level of subsidy is too high (part II)                                                                 procurement integrating all sectors, shift in market
                                                                                        brands, impeding opportunities for sustainable
                                                                                                                                              • Target free distribution to consumer segment based on need (geography, ability and
                       Recent surge of free condoms to 18m, or 25% of                   market development
                                                                                                                                                  WtP, preferences).support from GHSC project/Deliver.
                       market, and can’t be sustained w/UNFPA support               •   Subsidy wasted on those that can afford to pay
                                                                                                                                              • Implement recommendations in support of improved targeting of free condoms,
                       declining.                                                   •   Markets / beneficiaries poorly prepared when
                                                                                                                                                  female condoms, and lubricants (slide 19)
                                                                                        UNFPA for condoms ends 2018.
                                                                                                                                              • Explore feasibility (based on addressing defined need) of integrating CHAMP           33
                                                                                                                                                  supported CBOs into more sustainable ACMS SM interventions
Market Analysis and Recommendations (II)
       Potential interventions to address identified Market weaknesses

                                MARKET WEAKNESS / FAILURE                                   IMPLICATIONS                                            MITIGATION STRATEGY / RECOMENDATIONS

                       5. Quality of condoms in commercial market                                                            • ST: Outreach to importers of Alex to encourage testing. If necessary, seed invest in
                       largely unknown – particularly lower end                                                                testing of Alex to ascertain quality (
Scope of Work & Purpose             3

                                     Donor Landscape                     5

                                     Condom Use & Need: Who is the       7
                                     Condom Market Failing?

                                     Condom Market Structure & Trends    10

                                     How is the Market Failing –         20
                                     Inefficiencies & Weaknesses

                                     The Role of Subsidy in the Condom   24
                                     Market

                                     Readiness to Steward a TMA          28

                                     Recommendations Moving Forward      33
Condom Market Landscape - Cameroon
                                     Information & Data Gaps             36
                                                                              35
Key Questions, Information and data gaps

• What will the impact of pricing adjustments, and rationalizing free distribution, have on use?
    o    Willingness & Ability to pay studies, by population segment (such as SW, MSM, socio-economic segments of general population) are
         required to better understand implications for price adjustments of social marketing segment, adjustments of quantities of condoms
         allocated for free distribution.
• What are underlying factors of conditional condom use by male clients, and men & women in high risk
  relationships (multiple partners)
    o    Qualitative research to improve understanding of risk perception and conditional condom use, particularly for male clients and men and
         women with multiple partners. Particularly important as SW anecdotally cite men as the factor of condom use.
• What is the true size and value of the commercial condom market?
    o    Continue to understand market value (indicating potential for private sector actors – ACMS began estimating but data lacks non registered private
         sector). Market value can be determined by applying sales volume estimates with estimated sales price. E.g., the estimated value of the social
         marketing sector is $1.48m per annum.
    o    Update number of condom imported from 2015 from customs.
    o    Data gaps in total market size – particularly unregistered private sector. Find importer of Alex condoms to determine quantities imported, strategy and
         plan for the condom, encourage registration and testing.
    o    Need to clarify purchase behaviors of larger fmcg wholesalers, and more fragmented FMCG importers- who do they purchase from, how decisions
         made, etc.
•       Further analysis required to determine level of subsidy required to support distribution (including to KP),
        marketing /promotion efforts. While difficult to understand how subsidy is supporting every element of use
        (product, distribution/access, promotion/demand, overheads) it would be possible to make strategic investment
        decisions understanding.
                                                                                                                                                               36
Free Male Condom & Female Condom Distribution by partner & channel

     2016                                                          IPPF /      UNFPA        Care /
  Distribution     MOH Units    CBCHS      CNLS      ACMS        CAMNAFAW       Units      CHAMP         DHAPP (DoD) Peace Corps    Other       TOTAL UNITS

Male Condoms
         UNFPA 2,603,600         216,000 4,869,912   2,786,400     4,146,088    216,000                                                           14,838,000

            USG
                    1,012,528    200,000             1,359,900      841,000                  862,000          400,000    150,000 150,000           4,975,428
           Total    3,616,128    416,000 4,869,912   4,146,300     4,987,088     216,000     862,000          400,000     150,000   150,000       19,813,428
Female
Condoms
          UNFPA       40,000               388,000     154,000      328,000      90,000                                                            1,000,000

            USG                    5,000               119,000      130,000                                    60,000     25,000                     339,000
Total                 40,000       5,000   388,000    273,000       458,000      90,000              0         60,000     25,000            0     1,339,000

                                                                                                                                                               37
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