Corporate Equality Index 2021

Key Findings

Unwavering Commitment: Record Number of Top Scoring Companies

Over six hundred and twenty major businesses have adopted gender transition guidelines to establish best practices in transgender inclusion for managers and teams.

Businesses' Commitment to LGBTQ Employees

14 of the Top 20 Fortune-Ranked Companies Received 100% Ratings

Accelerating Global Equality

The business case for equality knows no borders

OVER THE NEARLY 20 YEAR HISTORY OF THE CORPORATE EQUALITY INDEX, ONE thing is patently clear: equality is good business. Being an LGBTQ-inclusive¹ employer is good for recruitment, retention, engagement and - ultimately - the bottom line. What began as largely U.S. and European efforts to create LGBTQ-inclusive workplaces is now a much larger conversation among international stakeholders. In a global marketplace, equality knows no borders.

Working hand-in-hand with businesses, HRC elevated the case that inclusion efforts could not stop at any one border. Employee mobility alone necessitates that LGBTQ employees have confidence that they are valued and protected members of the workforce wherever they are assigned. As multinational companies adopted inclusive policies and practices in the U.S. and elsewhere, HRC encouraged them to consider how this impacted the workforce in countries less friendly - both in terms of the law and the culture - to LGBTQ people. In 2016, the Corporate Equality Index criteria were expanded to require that companies with global operations extend their nondiscrimination policies across all their operations. This change helped drive wider adoption of nondiscrimination policies that include sexual orientation and gender identity protections. In 2016, 54% of CEI-rated companies had global operations and 95 percent of those extended their LGBTQ-inclusive nondiscrimination policies globally. With the 2021 CEI, 57 percent of rated companies have global operations and 99 percent extend those protections globally.

And the progress does not stop with nondiscrimination policies. Companies continue to double down on their global LGBTQ inclusion efforts through the expansion of equitable benefits and inclusive practices. Globally, companies are adopting critical benefits such as domestic partner recognition and transgender-inclusive healthcare benefits and deepening employee engagement efforts such as the expansion of employee resource groups for LGBTQ workers and their allies. While the CEI criteria do not currently assess these efforts, the CEI survey does collect information on global efforts to provide domestic partner benefits and transgender-inclusive benefits, support for global chapters of employee resource groups, and whether companies engage externally with LGBTQ communities outside the U.S.

Across all categories, a majority of companies report extending these benefits and inclusive practices beyond U.S. borders.

^{1 At HRC we use the acronym “LGBTQ” for the greater lesbian, gay, bisexual, transgender and queer communities. We recognize this acronym is U.S.-centric and that communities around the world recognize different identities and acronyms. When working in different communities, we adjust our language to reflect local customs (i.e., our Mexico- and Chile-based workplace inclusion programs use LGBT rather than LGBTQ).}

Criteria 1: Workforce Protections

THE WORKFORCE PROTECTIONS CRITERIA OF THE CEI CALL FOR A WRITTEN employment nondiscrimination policy that includes both “sexual orientation” and “gender identity” across all operations. For companies with operations outside of the U.S., the policy must be extended across the global workforce. Lesbian, gay, bisexual, transgender and queer people continue to face discrimination in employment because of their sexual orientation and/or gender identity, creating a need for explicit nondiscrimination policies.

Clearly enumerated nondiscrimination protections based on sexual orientation and gender identity are essential to LGBTQ workforce equity and inclusion. The policies help to ensure:

• Equal opportunity for all employees;
• Diverse talent acquisition and retention for broader economic growth; and,
• Keeping the employer apace with changing legal and public opinion landscapes.

Furthermore, these policies represent minimal upfront costs and rates of litigation upon implementation are consistent with other protected classes.

A Changing Landscape: Nineteen Years of Driving Adoption of Inclusive Policies

Criteria 2: Inclusive Benefits

IN THE U.S. EMPLOYER-PROVIDED HEALTH INSURANCE IS THE SINGLE LARGEST source of healthcare coverage. Competitive employer-provided benefits packages are critical to attracting and retaining talent. Widespread employer adoption of such packages helps to ensure that offering LGBTQ-inclusive benefits to employees and their families is a low-cost, high-return proposition for businesses. In addition, equitable benefits structures align with the principle of equal compensation for equal work. Apart from actual wages paid, benefits account on average for approximately 30 percent of employees’ overall compensation (BOL 2019). By amending their benefits structures, employers ensure that they extend this valuable bundle of benefits to their workforce equitably, irrespective of sexual orientation and gender identity.

Most employers have reported an overall increase of less than 3.5 percent in total benefits costs when they implement partner benefits and marginal increases related to transgender-inclusive healthcare coverage (i.e. a fraction of a decimal point of cost calculations).

The HRC Foundation rates and gives guidance on two key components of equal health insurance benefits:

• Parity between benefits available for employees’ spouses and partners; and,
• Affirmative transgender-inclusive healthcare benefits and removal of all broad exclusions to coverage across plan offerings.

In addition, employers are rated on having full parity across their entire suite of benefits – including non-healthcare benefits such as leave, retirement and others – between spouses and partners.

LGBTQ-inclusive benefits packages are:

• Necessary for talent acquisition and retention and broader economic growth;
• Equal compensation for equal work;
• Helping employers keep pace with changing legal landscape and workforce expectations; and,
• Minimal upfront costs (on average 1% increase for corporate employers’ overall health insurance costs).

The premise of parity underlies the inclusive benefits section of the CEI criteria. In its CEI scoring, the HRC Foundation does not penalize an employer if a particular benefit is not offered to any employees but holds employers accountable to provide LGBTQ employees and their families with the same benefits available to other employees across available benefits packages. For example, where routine care, hormone therapies and medically necessary surgeries are available to cisgender people (people who are not transgender), these same healthcare benefits must also be extended to transgender people covered by the plan. Many employers have begun to comprehensively address health insurance coverage for transgender individuals, and most have experienced insignificant or no premium increases as a result.

Continued Need for Partner Benefits

Since 2002, the CEI has required parity between spousal and partner benefits. After the United States v. Windsor and before the Obergefell v. Hodges Supreme Court rulings, HRC released a position paper cautioning against a marriage-only standard for accessing healthcare coverage, which is an unreasonable standard given the many other legal vulnerabilities that continue to affect LGBTQ individuals’ freedom beyond their right to marry.

Since the 2015 U.S. Supreme Court decision in Obergefell v. Hodges, which brought marriage equality nationwide by ruling that marriage is a fundamental right to which same-sex couples should have the same access as opposite-sex couples, employers have sought to do the right thing in the name of equality and provide spousal benefits to both same- and different-sex married couples. Many employers assumed that the marriage ruling obviated the need for partner benefits; however, this is not true. While marriage equality is undoubtedly a monumental step toward full equality, LGBTQ individuals remain at risk for discrimination in many other aspects of daily life and these vulnerabilities continue to create barriers for many LGBTQ Americans to exercising their legal right to marry. In the absence of sexual orientation and gender identity protections through federal and consistent state law, LGBTQ individuals remain vulnerable to discrimination in housing, access to public places, federal funding, credit, education, jury service, and, in some cases, employment (for employees not covered under Title VII). While LGBTQ Americans can get legally married, this lack of guaranteed protection in other domains means a newly married LGBTQ couple are at risk for eviction from their home by a discriminatory landlord that sees their wedding photos on social media. Until LGBTQ Americans have full equality through the federal Equality Act, domestic partner benefits will remain an essential CEI standard that helps to fill the void left by federal and state law and ensure LGBTQ workers and their families receive equitable benefits whether married or partnered.

While marriage equality is undoubtedly a monumental step toward full equality, LGBTQ individuals remain at risk for discrimination in many other aspects of daily life and these vulnerabilities continue to create barriers for many LGBTQ Americans to exercising their legal right to marry.

Domestic partner benefits do not only serve same-sex couples. In fact, over the last decade most businesses that have offered same-sex partner benefits also extended these to different-sex partners. In other words, businesses have increasingly recognized the value of decoupling benefits from the legal definition of marriage to meet the needs of their diverse workforces.

While HRC never changed its partner benefits mandate, a small number of companies moved to spousal benefits-only policies in the middle of the 2016 CEI season. Out of an abundance of understanding for participating companies, credit was given for spousal equivalent benefits in the 2016-18 CEIs. After wide-scale education and outreach efforts, the 2019 CEI resumed enforcement of the standard for both same- and different-sex domestic partner benefits. 732 businesses met the standard in 2019, 836 in 2020, and 893 in 2021. The CEI continues to reflect best practices for LGBTQ workers and their families.

Understanding Transgender-Inclusive Healthcare Coverage

In 2004 the HRC Foundation identified transgender-inclusive healthcare coverage as a focus area for educational outreach and as a scored component of the CEI criteria.

From 2006 through 2011, a top CEI score meant businesses needed to mitigate at least one exclusion among five critical categories of transgender healthcare, namely: mental health; pharmacy benefits for hormone therapy; medical visits and lab procedures related to hormone therapy; surgical procedures; and short-term leave for surgical procedures. While awareness of barriers to transgender healthcare coverage steadily increased, a majority of CEI-rated businesses plateaued in offering mental healthcare coverage and/or short-term leave for surgical procedures and did not mitigate exclusions related to other medically necessary treatments.

In 2009 the HRC Foundation announced a major change to what would be the 2012 CEI criteria: to earn a top rating of 100 percent, a business needed to not just mitigate one or more exclusions but address the root problem of transgender exclusion in coverage and fully affirm healthcare coverage for medically necessary transition-related care and other routine and chronic conditions. The HRC Foundation embarked on a massive campaign of educational and consultative efforts to address healthcare and insurance disparities for the transgender population and their families, including: outreach to leading health insurance companies; direct consultation with both fully- and self-insured employers to modify their health insurance plans; and collection and dissemination of cost and utilization data from leading businesses.

Growth of Trans Benefits Over Time

Criteria 3: Supporting an Inclusive Culture & Corporate Social Responsibility

Equitable policies and benefits are critical to LGBTQ inclusion in the workforce but alone are not sufficient to support a truly inclusive culture within a workplace. Employers recognize that beyond the letter of a policy, additional programming and educational efforts are necessary.

Ultimately, businesses invest in organizational competency programs because:

• Policy does not equal practice;
• Despite progress, 46% of LGBTQ workers nationwide remain closeted on the job;
• Invisible diversity requires unique training focus and defined safe space programs and resources;
• Senior level buy-in and accountability metrics effect change quickly and for the long term; and,
• Retaining workers is largely about everyday experiences on the job.

Many employers integrate educational programs into already existing diversity and inclusion programs. To obtain full credit in this criterion, employers must show at least three types of organizational competency programming. This comprehensive metric is provided as accountability for employers to devote resources to creating and maintaining a climate of inclusion.

• Some of the most common forms of LGBTQ inclusion efforts are:
• Diversity training programs such as new hire, manager and professional development training;
• LGBTQ metrics through self-identification programs;
• Performance evaluation mechanisms for senior leadership; and,
• Gender transition guidelines.

LGBTQ Employee Resource Group or Diversity Council

Many large employers have formally recognized employee resource groups (also known as an employee network, business resource or affinity groups) for diverse populations of their workforce, including women, people of color, veterans, parents, people of varied abilities and LGBTQ & Allied people. These groups’ purpose is two-fold:

• To foster a sense of community and visibility of these diverse populations within a business; and
• To leverage each unique populations’ networks and skills to help accomplish business goals such as market innovation, recruitment and retention of talent.

ERGs are great platforms for leadership opportunities for LGBTQ and allied employees to better their own work environments. In addition, the reach of many ERGs extends beyond the everyday affairs of an employer to policymaking, representing the employer at professional events and external activities, participating in prospective employee recruitment efforts, mentoring, and other retention-focused programming.

LGBTQ/A ERGs empower employees as change agents and promote inclusion for LGBTQ employees within the workplace. Recognizing the differences in businesses rated in the CEI, this criterion can also be met with an organization wide diversity council or working group with a mission that specifically includes LGBTQ diversity and inclusion.

Employees who do not identity as LGBTQ themselves, but are invested in equality and workplace inclusion are increasing their numbers within ERG ranks. While ERGs’ mission statements are specific to LGBTQ inclusion, increasingly ally-identified colleagues are encouraged to join as membership is not limited to those who are LGBTQ but open to all supporters of equality.

ERGs have embraced Allies as critical supporters of the full LGBTQ community, as Allies bring their own unique voice and vantage point to workplace equality. The profile and impact of an employee resource groups is greatly enhanced by an active executive champion for the group.

Outreach or Engagement with LGBTQ Community

Despite the disruption of the COVID-19 epidemic with cancellation of in-person events worldwide, CEI-rated businesses followed-through on their commitments to LGBTQ community engagement throughout the year largely by leveraging online and virtual engagement platforms.

Businesses have extensive programs to engage with key markets and the communities in which they operate. Public commitment in the CEI is measured through a number of individual engagements, namely through:

• Marketing, advertising and sponsorship efforts;
• LGBTQ-specific recruiting efforts;
• Philanthropic contributions;
• LGBTQ supplier diversity programs; and,
• Public policy weigh-in.

Additionally, the CEI includes a set of standards around foundational giving to fully align a business’s actions with its core values and to raise the bar for corporate social responsibility.

Businesses see advantages in going public with their commitment to equality, including:

• Reputational benefits to supporting equality groups and programs;
• Corporate case for LGBTQ legal equality: they are on right side of history and eliminate barriers to investment;
• Attracting and retaining next generation of workers and consumers – the importance of communicating pro-equality messages to millennials; and,
• LGBTQ public support is seen as a bellwether for broader issues of diversity and inclusion.

Recruiting

Professional events such as the annual Out & Equal Workplace Summit, Lavender Law conference and the Reaching Out MBA Conference and career expo are filled with highly rated CEI employers looking to attract diverse employees. Employers’ presence at these and other events sends a clear message to potential employees that LGBTQ diversity is part of company culture, and that LGBTQ candidates are valued as the best and the brightest across industries, geographies and trades. While many of these recruiting events went to virtual platforms in 2020, CEI-rated businesses remained engaged.

Marketing & Advertising

Ad campaigns and sponsorships further this message of company values to the public. Increasingly, ads with authentic images of LGBTQ people are featured in both LGBTQ media outlets and general press alike. Corporate philanthropic activities ranging from financial support to in-kind donations of products or services can bolster a business’s profile in the LGBTQ community.

Philanthropy

Corporate giving to organizations promoting LGBTQ health, education or political efforts further demonstrates this commitment to broader LGBTQ equality. Typically, these efforts have a strategic connection to the core mission of a business, such as a law firm’s pro bono legal support of organizations tasked with direct legal representation of LGBTQ individuals.

Supplier Diversity

Supplier diversity programs ensure that the procurement process includes specific opportunities for minority-owned businesses, including women-owned, veteran-owned and, more recently, LGBTQ-owned businesses. Supplier diversity initiatives have existed in the business community for at least three decades, going back to the inception of such groups as the National Association of Women Business Owners and the National Minority Business Council, both founded in the early 1970s to promote the inclusion of these under-utilized entrepreneurial groups. Furthermore, there are federal initiatives such as the Center for Veterans Enterprise that is designed to assist U.S. veterans in launching and thriving in private business. These initiatives intend to give more equitable opportunities to those would be small business owners who are more likely to face social and practical barriers to success.

The National LGBT Chamber of Commerce began certifying LGBTQ-owned small businesses in 2002, a process that requires substantiation of majority LGBTQ ownership in a business and verification of a business’ good standing in the community. Supplier diversity initiatives are a win-win relationship

These businesses are enjoying a multitude of benefits, including a supply chain that better reflects the diverse communities in which they operate, and in turn garnering sharper innovation and business solutions.

Corporate Social Responsibility

A business’s nondiscrimination policies should not be limited to human resources or diversity and inclusion. The CEI’s Corporate Social Responsibility criteria ensure that sexual orientation and gender identity protections apply to those standards that businesses require their vendors or suppliers to adhere to, as well as recipients of their philanthropic funds.

Supplier/Vendor Standards Include LGBTQ Nondiscrimination

Large businesses typically rely on other businesses for goods or services, and businesses of the size included in the CEI typically have set standards and guidelines already embedded in their procurement. In order to ensure that suppliers act in a manner that adheres to a business’s own standards, it is necessary for businesses to establish standards of conduct that set expectations for behavior of their suppliers.

Philanthropic Giving Guidelines

The HRC Foundation has always held businesses accountable for the types of organizations receiving their philanthropic dollars. Historically, the CEI had a mechanism to account for foundational corporate giving to any organization whose explicit mission included efforts to undermine LGBTQ equality. This framework was widened in 2016 to hold companies accountable for any giving to a non-religious organization with an explicit policy of discrimination against LGBTQ people. This requirement sets the standards around responsible foundational giving and ensures that a top rated business does not provide philanthropic support to organizations whose values do not align with theirs.

The requirement is that a top-rated business must implement internal requirements prohibiting company or law firm philanthropic giving to nonreligious organizations that have a written policy of discrimination on the basis of sexual orientation and gender identity or have a policy explicitly permitting its own chapters, affiliates, etc. to discriminate.

Spotlight:

Equality in the Public Square

SINCE 2015, THE RATES OF CORPORATE ENGAGEMENT ON MATTERS OF LGBTQ EQUALITY UNDER the law and LGBTQ-related public policy have skyrocketed. Ever since the historic Obergefell decision enshrining marriage equality as the law of the land, state legislators across the country have responded with a proliferation of hundreds of anti-LGBTQ bills.

Businesses, however, decidedly oppose these discriminatory bills. Over the last six years, businesses have repeatedly spoken out and rebuked attempts from state-to-state to undermine LGBTQ civil rights at record rates. Corporate leaders are driven not only by principle but also by the understanding that anti-LGBTQ bills that attempt to curb access to public services for transgender people, or deny basic services to LGBTQ families, or preempt local nondiscrimination ordinances put their employees, their employees’ families, and their customers at risk. Plainly, they are bad for business.

CEI-rated employers are on record supporting broad issues of LGBTQ equality at the local, state and federal levels as well as through amicus briefs with the courts because they know equality is good for business.

HRC’s Business Coalition for the Equality Act is a group of over 320 leading U.S. employers that support the Equality Act, federal legislation that would provide the same basic protections to LGBTQ people as are provided to other protected groups under federal law. Coalition member companies represent nearly every industry, employ over 12.3 million people in the U.S., command over $5.7 trillion in revenue and have operations in all 50 states.

The Equality Act creates clear, consistent protections to prohibit discrimination on the basis of sexual orientation and gender identity in employment ensuring that LGBTQ employees are hired, fired, and promoted based on their performance. In addition, the bill provides protections from discrimination for LGBTQ people in housing, credit, and jury service. The bill would also prohibit discrimination in public spaces and services, and federal funding on the basis of sex, sexual orientation, and gender identity.

Private sector support for the federal Equality Act surged in the last year. At present, over 320 major employers are signatories on HRC’s Business Coalition for the Equality Act.

Corporate Equality Index 2021

Rating System and Methodology

The HRC Foundation’s CEI rating system is designed for mid to large businesses (500 full time employees and above) and divided into three key categories of criteria:

• Nondiscrimination policies across business entities;
• Equitable benefits for LGBTQ workers and their families;
• Supporting an inclusive culture and corporate social responsibility.

Launched in 2002, the CEI is the first internationally recognized benchmarking report for businesses to gauge their level of LGBTQ workplace inclusion against competitors. In addition to growing the number of highly-rated employers, the CEI has seen success in the reach of the survey. The number of employers officially rated from the first CEI to the present has expanded from 319 to 1,142, encompassing all major industry sectors. Invitations and Participation

The largest and most successful U.S. employers are invited to participate in the CEI and are identified through the following lists*:

• Fortune magazine’s 1,000 largest publicly traded businesses (2019 Fortune 1000) and
• American Lawyer magazine’s top 200 revenue grossing law firms (2019 AmLaw 200).

Additionally, any private-sector, for-profit employer with 500 or more full-time U.S. employees can request to participate, including those that are privately held.

*Note on timing of the lists. Due to the staggered timelines of the ranking lists and when contact lists are made available, the ranking year lags the CEI survey year by one year and the publication year by up to two years

How We Obtain the Information

The primary source of information for the Corporate Equality Index rating each business received is the CEI survey sent every year to previous and prospective respondents. The web-based survey included links to sample policies and other guidance on the HRC Foundation website.

HRC Foundation staff provided additional assistance and direct consultation throughout the process and reviewed submitted documentation (required within each section) for appropriate language and consistency with survey answers.

Invitations for the CEI 2021 survey were emailed and mailed in June 2020 and responses were due back September 2020. If a business had previously participated in the CEI, surveys were first sent to the individuals responsible for prior submissions. If a business had not previously participated in the CEI, surveys were sent to the chief executive officer or managing partner of the firm, as well as the highest-level executive/s responsible for human resources, diversity, communications or community engagement when it was possible to obtain their contact information. The information required to generate CEI ratings for businesses is difficult to ascertain from public records alone. In addition to the self-reporting provided through the CEI survey, we investigated and cross-checked the policies and practices of the rated businesses, any connections with organizations that engage in antiLGBTQ activities and news accounts of efforts that undermine LGBTQ equality writ-large (e.g. through case law efforts or public policy lobbying actions). Employers were not rated until all appropriate information had been gathered and verified to the extent possible. Businesses were invited to provide HRC Foundation staff with any additional information or updates before this report was published.

In total, the sources used include:

• The HRC Foundation’s CEI survey;
• Internal Revenue Service 990 tax filings reviewed for any business foundation’s gifts to anti-LGBTQ groups;
• Case law and news accounts regarding findings of discrimination and corporate responsibility and the LGBTQ community at-large; and,
• Individuals that report information to HRC Foundation.

If a business was found to have a connection with an anti-LGBTQ organization or activity, the HRC Foundation contacted the business and provided an opportunity to respond and ensure, to the best of its ability, that no such action would occur in the future and to mitigate the harm done. Businesses unwilling to do so are penalized 25 points from their overall rating through Criterion 4.

Official and Unofficial Ratings

The HRC Foundation may rate businesses that have not submitted a survey this year if the business had submitted a survey in previous years and the information is determined to be accurate, or if the HRC Foundation has obtained sufficient information to provide an individual rating. In both cases, the HRC Foundation notified the business of the official rating and gave them an opportunity for any updates or clarification prior to the report release.

Fortune 500-ranked businesses that after multiple invitations have never responded to the CEI survey were evaluated independently and have designated unofficial ratings listed in gray in Appendix A. The HRC Foundation proactively evaluates these 113 Fortune-ranked companies for two key reasons:

• To provide the public with accurate information on these key employers; and
• To ensure the CEI is truly a benchmarking report among peers.

No matter the rating, any business that participates in the CEI is taking on a transparent, credible process of LGBTQ inclusion. Because LGBTQ workers and prospective employees must navigate the gaps in federal and state protections that affect their employment decisions, our staff views the research on these businesses through this same lens, ascertaining what we can from publicly available information and applying those findings to our CEI criteria.

The HRC Foundation commends those employers that have committed to the public and transparent process of the CEI survey and we invite these 113 companies to do the same.

In total, the CEI 2021 contains official ratings for 366 Fortune 500 businesses, 476 Fortune 1000 businesses, 166 law firms and 500 additional major businesses. With the additional 113 Fortune 500 businesses that have unofficial ratings, the total of rated businesses is 1,255. Findings in the 2021 CEI report are based on the 1,142 officially rated businesses.

Scoring Criteria

Best Places to Work for LGBTQ Equality 2021

All official and unofficial ratings for the 2021 Corporate Equality Index in alphabetical order. To view employer score detail, please visit www.hrc.org/cei/search.

About the Workplace Equality Program

The Corporate Equality Index. is a project of the Workplace Equality Program at the Human Rights Campaign Foundation. In addition to the CEI, the Workplace Equality Program researches, develops and advocates for greater equity and inclusion for LGBTQ workers at the federal, state and local levels, and provides support to employers seeking to enhance LGBTQ inclusion via education, training, policy and consulting assistance.

Special Thanks

Thank you to Jay Brown, Senior Vice President for Programs, Research and Training at the Human Rights Campaign Foundation for his leadership and stewardship of the Workplace Equality Program.

Thank you to HRC staff Elizabeth Bibi, Aryn Fields, Jon Groat, Wes Jones, Savonne Pearson, Tarine Wright, Emily Simeral Roberts, Carolyn Simon and Kelli Stam for communication, press and media guidance.

Thank you to Alec Carrasco, Sam Putnam and Katie Wetstone for their database knowledge and expertise. They always find a way to make everything work.

Thank you to Robert Villaflor and Ashley Sudney for editorial and design guidance.

Thank you to Asia Arminio, Molly Meegan, Cathryn Oakley, David Stacy and Sarah Warbelow for legal and policy guidance.

We would like to express our gratitude for all our HRC colleagues for their collaboration, teamwork and support.

The Corporate Equality Index 2021 was beautifully and efficiently designed by Tony Frye Design.