Implementing an HRMS – Where Do You Begin Dino Nosella, PMP Thursday March 21, 2013 Agenda • Introduction • Definition of HRMS/HRIS • The life cycle of Implementing an HRMS/HRIS • Questions Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 1 Definition of HRMS/HRIS? A Human Resources Management System (HRMS) is a software application(s) that combines many human resources functions, including benefits administration, payroll, recruiting, learning management, and performance management. A Human Resources Information System HRIS is a system used by human resources departments to track employees and information about them. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 2 Getting Started May Feel Like Herding Cats Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 3 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 4 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 5 Need for HRMS Key Questions WHAT? • • What will the an HRMS do for the business? What pain points will it address? WHEN? • • will the HRMS project take place? Target go-live date? WHY? WHO? • • • • Why is an HRMS needed? Does it align with business goals? WHERE? • • in the business will it impact (departments) Geographical landscape Copyright at 2013 Ea Global Consulting Inc. All rights reserved Who is the project for who needs to help? HOW? • will the project get done? March 21, 2013 Confidential 6 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 7 Preparation Defining Business Goals & Objectives Establishing clear Goals & Objectives is critical! It drives decision-making Establishes metrics for success. What is the difference between Goals and Objectives? • • Goals are high-level and generic. May also be referred to as the “vision” and provides general guidance. Objectives are specific targets within the goal. They need to be SMART (Specific, Measurable, Achievable, Realistic, and Timely) Common Mistakes… • Insufficient time & attention is given to establish goals and objectives • Objectives are not SMART • Goals & Objectives are documented in the beginning and filed away – out of sight & out of mind Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 8 Preparation Preparing the Business Case The purpose to the Business Case is to get approval to implement an HRMS Must demonstrate business value: • Cost Reductions • Support for Business Growth • Improving Operations (efficiency, cycle times) • Regulatory Compliance (government, CBAs, etc) Requires high-level research and information: • High-level business requirements • Project cost estimates • Operational (on-going) cost estimates • Cost & Risks of maintaining status quo Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 9 Preparation Balancing Forces in the Business Case RISK ! RISK ? Project Barriers Need for Change Future State •Benefits Current State •Pain Points Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 10 Preparation Establishing A Steering Committee The Role of a Steering Committee • • • • • • • • Provides guidance and direction on scope, funding and timing Provides direction on communication to the organization Removes barriers to the success of the project Commits the required resources to the project Facilitates organization readiness and end-user adoption Monitors the progress and the organizational impacts of the project Resolves escalated issues and ensures decisions are carried out Sign-offs on key deliverables/project milestones Steering Committee Membership • Should be comprised of senior members of the organization (VP-level and above) • Representatives of key areas or key stakeholders impacted by the HRMS • Members need to commit to be active participants Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 11 Preparation Executive Sponsorship Sponsorship is a commitment by management to define, defend, and support projects throughout the project life cycle. Sponsor Activities: • • • • • • Approve budget, schedule and scope Define, communicate & champions the Project Vision throughout the organization Ensures alignment between competing strategic projects Sets expectations at the executive level Resolves escalated issues and ensures decisions are carried out Ensure necessary project and business resources are available Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 12 Preparation 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 10 Attributes of an Executive Sponsor Understands the problem(s) the project will resolve Ensures the solution fixes the problem(s) Provides the right resources at the right time Is an advocate, coach, and influencer for the project Understands and helps resolve the big issues Holds the team accountable for results Knows where “good enough” is Understands change impacts Acts as a change agent Makes tough decisions Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 13 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 14 Definition Gathering Business Requirements Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 15 Definition Requirements Matter Poor identification and documentation of requirements is often on “Top Reasons why Projects Fail” lists 1. Inadequately trained and/or inexperienced project managers 2. Failure to set and manage expectations 3. Poor leadership at any and all levels 4. Failure to adequately identify, document and track requirements 5. Poor plans and planning processes 6. Poor effort estimation 7. Cultural and ethical misalignment 8. Misalignment between the project team and the business or other organization it serves 9. Inadequate or misused methods 10. Inadequate communication, including progress tracking and reporting 1. Poor sponsorship 2. Unclear requirements 3. Unrealistic timescales or budgets 4. Scope creep 5. Poor risk management 6. Poor processes/documentation 7. Poor estimating 8. Poor communication/stakeholder engagement 9. Poor business case 10. Inadequate/incorrectly skilled resources source: pmstudent.com 1. 2. 3. 4. 5. 6. source: gantthead.com Copyright at 2013 Ea Global Consulting Inc. All rights reserved Lack of User Involvement Long or Unrealistic Time Scales Poor or No Requirements Scope Creep No Change Control System Poor Testing source:vwww.coleyconsulting.co.uk March 21, 2013 Confidential 16 Definition Process for Gathering Requirements Functionality Inputs Outputs Business Rules Data / Information What do people give you? What do you do? What rules apply? Why? What do you give people What do you need to keep track of? Enlist the help of a professional Business Analyst with HRMS knowledge & experience! Source: www.projectperfect.com.au Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 17 Definition I know nothing about software…Now What? Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 18 Definition Software Solutions: Integrated vs Best of Breed Best-of-Breed Systems • Designed specifically to address needs in specific functional areas. • Richer functionality, may be industry-specific • “Specialist” software Integrated Systems • Also referred to Enterprise Resourcing and Planning (ERP) systems • Provides a number of applications (or modules) to support multiple functional areas (Finance, Purchasing, HR, etc) • More generic / broader functionality aimed at a wider audience. • “Jack-of-all-trades” software Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 19 Definition Deciding Between Integration and Best of Breed This is a corporate (company-wide) decision and cannot be made by an individual department in isolation! Need to align to: • Corporate technology (or IT) roadmap • Software requirements from other areas of the organization • Business growth projections • Other business initiatives. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 20 Definition Integrated vs. Best of Breed – Things to Consider Integrated Best of Breed Advantages • One supplier to deal with • A unified interface, consistent operation across various functions • Seamless data flows. Single point of entry. • Minimal integration work. • Specialist - you'll be buying into their specific knowledge of this specific function • Less IT intensive implementations and maintenance • Faster implementation due to smaller scope Disadvantages • Can be cumbersome and complex to use and to understand • Will need to give-up functionality in favour of integration and data flow. • More complex Implementation and upfront costs • May be too complex for smaller organizations • Integration with other systems can be complex, ineffective, and costly. • Multiple points of entry for data. • Suppliers / vendors are often small and may not understand needs of large organizations. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 21 Definition Software Deployment Options Software-as-a-Service (SaaS) Hosted (Hybrid) On-Premise (Traditional) Software is off-site, Customer-specific version of software, offsite Software installed on-site Subscription-base (ie “leased”) Generally subscriptionbased fee structure Company “owns” software Less flexibility to customize the software Intermediate flexibility to customize.. Ability to configure and customize as needed Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 22 Definition SaaS vs On-Premise Software-as-a-Service (SaaS) On-Premise (Traditional) Implementation Shorter cycle but increased business demands on change aspects Longer cycle due to technical and infrastructure components Upfront Costs Only costs of montly /quaterly subscription and temporary hardware Higher costs due to hardware & software licenses Total Cost of Ownership (TCO) Slightly lower in long-term (7-10yrs) No asset ownership Slightly larger in long-term (7-10 yrs) Asset ownership Upgrades Controlled by vendor. On-going demands on customer to test and keep updated Controlled by customer. May utilize downlevel software. Customization Limited Flexible Integration Very challenging. Limited ability to tailor integrations and working with software vendor directly Integrations can be customized to system needs. May still require working with software vendor. Data Security Controlled by software vendor Controlled by customer Operational Transparency Little visibility into system health and vendor (business) health. Software owned and managed by customer. No impact Organizational Change Significant change impacts due to limited ability to customize software. Business must adopt software processes. Less change impacts if software customized to support current business practices. Source: Panorama Consulting Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 23 Definition When to Choose SaaS vs On-Premise Software-as-a-Service (SaaS) On-Premise (Traditional) Business Processes Simple or “vanilla”. Immature or undefined Complex or unique Business Model Stable, little change Volatile or constantly evolving Company Skills Small to mid-size Mid to large, global IT Skills Little to none Sophisticated IT infrastructure Little to none Well-established Integration with other systems Little to none Need for integration Control Little need or desire Require control Source: Panorama Consulting Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 24 Definition Researching Vendors Enlist the help of a professional with knowledge of HRMS Vendors & the Vendor Selection Process. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 25 Definition Request for Information (RFI) Used to collect information from different suppliers prior to formally sourcing products or services. Used where there are many potential suppliers and not enough information is known about them. It is a structured process that can be used to compare responses from potential vendors. Help reduce a long list of potential suppliers to a short list of those organizations that are willing and able to fulfill your requirements. RFIs are higher-level so they are often the first step and used in combination with a Request for Proposal (RFP) Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 26 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 27 Vendor Selection • • • • • • Selection Criteria Categories Software Vendor’s Corporate Vision Technology and System Architecture Product Functionality Product Cost Service and Support Supplier Longevity • Driven through: • • • • Vendor meetings RFP responses On-site demonstrations, and References Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 28 Vendor Selection 15-25 10-15 5-7 2-3 2 1 Narrowing Down The Vendors • Research potential vendors • Initial Review – Conduct Request for Information (RFI) • Greater detail on solution – Conduct Request for Proposal (RFP) • Conduct demonstration of solution • Top Two Vendors – Conduct Reference Checks • Select Vendor of Choice Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 29 Vendor Selection Request for Proposal (RFP) Used to receive detailed proposals from different suppliers prior to purchasing the software. It should provide all required information to make an informed purchasing decision, including: • Scope • Implementation timeline • Design information. Specifications • Budget • Vendor corporate & financial information It is a very structured process used to compare responses from potential vendors and demonstrate impartiality in the evaluation process. Clearly outlining your detailed requirements is critical to issuing a successful RFP Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 30 Vendor Selection Software Demonstration • Major objective of the demonstrations: What do I want to SEE the software do? • Well-organized scripted demonstration should include; • Seeing your company data • Viewing the software processes transactions that reflects your business • Viewing the features and functions within the core product • Evaluate other areas: • Technical infrastructure • Implementations • Post Implementations requirements Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 31 Vendor Selection Contract Negotiations • Software Contract • Licenses vs Subscriptions • Professional Services Contract • Vendor vs System Integrator (SI) Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 32 Vendor Selection Professional Services Contract • Scope/Deliverables • Clearly what is in scope and NOT in scope • Timeline • Understanding of the detail timing when things are to be completed • Resources • What is the vendor providing and what will you need to provide • Contract type • Time and Materials vs Fixed Price vs Milestone Billing Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 33 Vendor Selection • • • • • • • • • • • Vendor Selection Lessons Learned Set realistic expectations Get key decision makers on board Right team members No software package can cure all corporate problems Realistic return on investment (ROI) Understand the business requirements – functional needs and processes Force vendors to show the system Keep emotions out of the selection process Do reference checks Understand how the software solution is maintained and enhanced Understand the significance of change management Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 34 HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 35 Implementation Project Manager – Who is the it going to be? The P in PM is as much about PEOPLE management as it is about PROJECT management Persuasion and Influence Copyright at 2013 Ea Global Consulting Inc. All rights reserved Telling the truth March 21, 2013 Confidential 36 Implementation • • • • • • • Project Manager – Internal vs External Is business knowledge critical to the success of the project Does the required skill-set exist Seen as an expert – will they have authority Seen as a strong leader Do they have persuasion and influence Ability to say “NO” Will be able to deliver difficult news – will the truth be told Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 37 Implementation Use of Consultants Cons • Will leave after project is completed • Costly • Business knowledge is limited Copyright at 2013 Ea Global Consulting Inc. All rights reserved Pros • • • • Addresses skill-set gap Not Political Will be able to say NO Various experiences among projects, industries, and products March 21, 2013 Confidential 38 Implementation Project Governance – The Pillars People •Committee Membership •Organizational Roles Structure •Steering Committee •Stakeholder Groups •Program Board •Project Team Organization Copyright at 2013 Ea Global Consulting Inc. All rights reserved Information •Project Reports •Issues •Risks •Key Documents March 21, 2013 Confidential 39 Implementation Key Elements of Project Governance Framework • Establish the proper flow of information • Define procedures to review issues and risks • Establish mechanism to ensure required approvals are obtained • Re-enforce decisions to achieve the desired benefits • Define procedures to control scope, budget, and quality • Define an escalation process that will facilitate items to be resolved. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 40 Implementation Project Scope Elements • Software Application • Benefits, Performance Management, Absent Management, Payroll, etc • Functionality • Organization structures, position management, compensation packages, etc • RICE – Reports, Interfaces, Conversions, Enhancements • Business Processes • Hire, Terminate, Transfer, Demote, etc • Organizational • Departments in the organization that will be affected • Geographical • Location where the system will be used Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 41 Implementation Project Timeline, Framework and Deliverables DATA CHANGE MANAGE MENT Architect (Design) Configure & Prototype Test / Deploy Scope Management Project Plan Requirements TESTING SYSTEM BUILD PROJECT MANAGE MENT Project Planning Requirements Scope Statement Risk Management Detailed Requirements Configure Design Document Custom Coding Quality Management Transition Plan Rework Testing Scenarios Test Cases Test Cases Master Test List Test Test Upload Workbook Data Loads Go Live & Support Lessons Learned Support Fixes Test any Fixes Final Data Load Cleansing Stakeholders Training Plan Copyright at 2013 Ea Global Consulting Inc. All rights reserved Training Materials Training Support Communication and Business Readiness March 21, 2013 Confidential 42 Implementation Testing TESTING, TESTING, TESTING…… ………………………….and then some more TESTING • • • • • • • Testing takes time when done correctly Allow time to address issues Resource intensive so need to plan it Need to find issues Follow a process and stick to it Vendor must test against the requirements Various levels of testing • Unit, String testing, User acceptance testing, Interface testing, Integration testing Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 43 Implementation Data Migration and Conversion Data Cleansing • Multiple Data Sources • Organizational Impacts • Data Readiness Data Conversion • • • • Data Formats Look & Feel Fonts Structures / Groupings Data Management • Master Data Procedures • Data Owners • Lead Times • Forms • Overly-optimistic perceptions of data readiness • Under-estimation of cleansing efforts • Education of system data requirements Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 44 Implementation The Change Management Iceberg CHANGE COMPONENT PEOPLE TECHNOLOGY USERS Acceptance / Skills ROLES Jobs / Organization DATA Information SYSTEM FUNCTIONALITY PROCESS Tasks / Activities PROCESS STEPS Hand-Offs BUSINESS PROCESSES Organizational Structure Company Culture 45 Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential Implementation A Communications Strategy WHY IT’S IMPORTANT WHAT IT IS OBJECTIVES APPROACH • The purpose • Expected outcomes • Outline of process • Associated activities GUIDING PRINCIPLES • Overarching philosophy • Guide how objectives are achieved • The ‘Rules of the Game’ WHO IS INVOLVED ROLES & RESPONSIBILITIES KEY MESSAGES • Consistent messages • What stakeholders (audiences) need to know COMMUNICATION CHANNELS • Vehicles for delivering communications MEASUREMENT CRITICAL SUCCESS FACTORS • Effectiveness against intended communication objectives • Show stoppers • Decision points FEEDBACK PROCESS & MECHANISMS • Accountabilities and work effort associated with communication planning & development STAKEHOLDERS • Groups and individuals that are impacted by and have influence over initiatives • Steps to Initiate questions and make suggestions • Methods for soliciting and receiving feedback MAKING IT HAPPEN THE COMMUNICATION PLAN Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential Implementation Training • Start planning as early as possible • Often left to the end with little time to create the right materials • Create materials that are useful outside the training session • Reference guides, business processes, Quick reference sheets • Have training as close to the Go Live as possible • Greater impact if training is conducted by peers • Plan for training logistics • Schedule people into classes as early as possible • Allow for flexibility in schedule • Use technology when it makes sense Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 47 Implementation Tool for Assessing Business Readiness Low Level of Readiness Processes Technology People High Level of Readiness •High level flows and discussion •Discussions focused on different scenarios and how to handle them •Detailed •Uncomfortable with system •Struggle with system “lingo” and unable to link to existing systems and procedures •Comfortable •Unsure •High of roles and responsibilities. •Territorial behavior •Mixing roles in the system with job descriptions process discussions •New scenarios can be addressed quickly with the system, can describe screens, visualize •Can easily link system terminology to existing terminology comfort with roles and responsibilities. •Can see the big picture. Understand difference between system roles and business roles 48 Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential HRMS Project Life Cycle Need for HRMS • Business Drivers • Pain Points Preparation • Define goals & objectives • Business case • Steering Committee Project Definition Vendor Selection • Detailed Business requirements • SaaS vs Hosted vs On-Premise • Integrated vs Best of Breed • RFI • Research Vendors • Selection Criteria • RFP • Contract negotiations Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Implementation • Project Management • Scope • Timelines • Resources • Budget PostImplementation • Transition Plan • Realization of Benefits • On-going Performance Confidential 49 Post Implementation Transition Plan Describes the process to deliver the system from the project team to the support group that will maintain the system • Transition process: Outlines approval requirements and a schedule of transition activities • Documentation requirements: Documents to be prepared including contracts, training materials, and any other forms or legal documents. • Roles and responsibilities: Describes the roles and responsibilities of the project team and the receiving organization in the transition process. • Transition critical success factors: Describes the critical success factors that are considered essential to ongoing benefits sustainment and assurance. Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 50 Summary points • • • • • • • • • • • • Clear business objectives and goals Strong ownership Requirements matter See the solution in action Clear expectations of scope Strong Project Management Leadership Governance TEST, TEST, TEST, TEST Data efforts not to be under-estimated Consider Change Management impacts Clear communications Understand the end Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential 51 Dino Nosella Dino.Nosella@eagc.ca 647.268.8145 52 Copyright at 2013 Ea Global Consulting Inc. All rights reserved March 21, 2013 Confidential