Recent years have seen a proliferation of initiatives designed to improve operational and governance performance, yet implementation varies widely. This reflects the complex interplay of regulatory requirements, market incentives, ownership structures and corporate governance. Understanding what drives companies to adopt, ignore or resist responsible business conduct, transparency and traceability systems is increasingly important. This section explores how the regulatory and non-regulatory measures available to policymakers are influenced by market conditions, company-level ownership models and governance structures.
Enhancing Resilience Through Traceability
5. Enablers and obstacles for responsible business conduct and traceability
Copy link to 5. Enablers and obstacles for responsible business conduct and traceabilityAbstract
5.1. Context
Copy link to 5.1. ContextUnderstanding what drives companies to adopt traceability and RBC initiatives is as important as understanding their uptake, as it illustrates where policy can be most effective. The survey findings suggest that market forces, particularly customer demand and brand reputation, are the primary motivation for traceability uptake, with regulatory requirements a close second. This has important implications for policymakers: regulations that align with or anticipate market expectations appear more likely to drive meaningful adoption, while measures that operate in isolation from commercial incentives may have limited reach. At the same time, the fact that the majority of respondents report it is too early to say or were unable to identify tangible benefits from traceability underscores the importance of reducing implementation costs and demonstrating the business case, particularly for smaller actors who may lack the resources to absorb upfront investment.
The uptake of RBC, transparency and traceability initiatives is increasingly driven by a mix of regulatory requirements, voluntary standards, and market measures. Governments apply diverse policy tools: some impose mandatory transparency or traceability obligations, while others rely on incentives to encourage adoption. Many regulatory frameworks build on the OECD’s risk‑based due diligence approach, tailoring traceability expectations to the level of risk within a company’s supply chain. Certain policies are particularly far‑reaching, for example, the EU Batteries Regulation and the EU Ecodesign for Sustainable Products Regulation, which introduce digital product passports, as well as China’s Battery ID system and its Rare Earth Management Regulation.
In addition to direct regulations, indirect mechanisms have also become significant drivers of traceability. In the United States, measures such as tax credits under the Inflation Reduction Act and import restrictions imposed by the Uyghur Forced Labor Prevention Act illustrate how incentives and enforcement actions can prompt industry‑wide alignment on traceability practices, even in the absence of explicit traceability mandates. The survey conducted as part of this study explored the key drivers of RBC adoption and traceability from the perspective of companies in mineral supply chains.
5.2. Key drivers of RBC and traceability initiatives
Copy link to 5.2. Key drivers of RBC and traceability initiatives5.2.1. Market and regulatory pressure as drivers of RBC uptake
Anticipation of regulatory changes and market access considerations appear to be the primary forces driving company engagement with RBC along the supply chain. As shown in Figure 5.1, anticipation of regulatory or customer demands, and market access considerations are the most frequently cited drivers of company implementation of RBC due diligence and for participation in multi-stakeholder and industry initiatives on RBC, with motivations varying across supply chain segments. Miners’ and smelters’ high number of responses for anticipation of regulatory demands and regulatory compliance in country of operation or exports may be explained by the developing regulatory infrastructure on supply chain due diligence that has targeted these supply chain stages over the last ten years. Many of these regulations are based on the OECD Due Diligence Guidance for Responsible Mineral Supply Chains, which identifies smelters and refiners as the “control point” in the supply chain – the stage in which a high volume of minerals passes through a low number of actors, which have good visibility upstream – hence the point where audits of due diligence systems take place.
Motivations for participation in multi-stakeholder and industry initiatives on due diligence vary across sectors. While traders have been traditionally not in scope of supply chain due diligence regulations, anticipation of regulatory demand and customers’ demands features in 92% of traders’ survey responses (11 out of 12). This may be due to the supply chain scope of regulatory expectations being cascaded up to traders, pointing to this supply chain stage as a sector with the same characteristics of a control point, in an even more concentrated form. Another explanation is that many of the traders in the survey are vertically integrated (spanning mining, smelting, recycling and transporting activities) and are thus preparing for future or existing market requirements. Access to finance seems to be a more important factor for miners and traders (close to 50%) compared to other sectors. Manufacturers’ reported motivation of increased visibility over supply chains stands out compared to other supply chain segments. As explained in the section below, increased visibility over the supply chain may entail different kinds of tangible benefits for downstream actors.
Figure 5.1. Primary drivers of company participation in multi-stakeholder and industry initiatives on RBC
Copy link to Figure 5.1. Primary drivers of company participation in multi-stakeholder and industry initiatives on RBC
Note: This figure presents responses to survey Question 34 (“What are the primary factors influencing your company's participation in one or more of the above sustainability initiatives?”). Percentages refer to the share of respondents selecting each factor (answers restricted to top three factors). Based on a subsample of 40 miners, 36 smelters/refiners, 42 manufacturers/end-users and 12 traders, irrespective of whether they reported implementing a traceability system. Recyclers and transporters are excluded; manufacturers and end-users are grouped into a single category. “Other” response options are not shown in the figure. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
Although regulatory frameworks on waste and products affect company behaviour, their impact on the selection and implementation of multi-stakeholder and industry initiatives on RBC remains variable. Extended producer responsibility schemes and recycling targets place the responsibility for collecting and recycling products on manufacturers. Eco‑design requirements may also introduce recycled-content mandates, including the verification of recycled-content claims, an obligation that is difficult to fulfil under current traceability frameworks, in particular due to the varying waste and by-product classifications of materials and products. However, less than half of survey respondents (42%) indicate that waste legislation and product standards impact their selection and implementation of multi-stakeholder and industry initiatives to a moderate or large extent. Approximately two-thirds (68%) of these respondents engage in downstream activities such as manufacturing, recycling and/or are end-users, and over a third (37%) are involved in smelting/refining activities. Nearly half of respondents engaged in mining activities report that such considerations do not apply to them.
Recent scholarly work mapping the development timeline of voluntary sustainability standards in the minerals space suggests that their accelerated adoption since 2018 has been primarily driven by growing environmental and social pressures, including from investors and original equipment manufacturers, as well as regulatory alignment (Zhang et al., 2026[1]).
5.2.2. Market incentives as drivers of traceability uptake
When it comes to the uptake of traceability systems, market incentives such as brand reputation and customer demand appear to be the strongest driving factor (Figure 5.2). Regulatory requirements, which have sometimes anticipated those same market requirements, follow closely behind. More than 60% of survey respondents identify brand reputation or customer demand as the primary reasons for setting up traceability. Compliance with regulatory requirements and adherence to ethical sourcing commitments are reported to be the primary reasons in 40% of the responses. Investor expectations and geopolitical risk management are each referenced in about one in ten answers. Obtaining fiscal incentives such as tax credits is referenced in only one answer.
Figure 5.2. Primary drivers for pursuing traceability in mineral supply chains
Copy link to Figure 5.2. Primary drivers for pursuing traceability in mineral supply chainsCustomer demand, brand and reputation considerations and regulatory compliance are the most frequently cited drivers for traceability.
Note: This figure presents responses to survey Question 27 (“What are the primary drivers for pursuing traceability in your organisation?”). Percentages refer to the share of respondents selecting each factor (answers restricted to top three drivers). Based on a subsample of 40 miners, 36 smelters/refiners, 42 manufacturers/end-users and 12 traders, irrespective of whether they reported implementing a traceability system. Recyclers and transporters are excluded; manufacturers and end-users are grouped into a single category. “Other” response options are not shown in the figure. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
Research also shows that investors’ screening of portfolios cascades pressure upstream on mining companies to align with selected industry standards (Agapova, Filatovab and Yuk, 2025[2]). This is underscored by the Global Investor Commission – Mining 2030, an ambitious initiative by some of the world's leading pension funds to establish consensus expectations for a responsible mining sector (Mining 2030, 2025[3]). This also aligns with the decision of Norway’s sovereign wealth fund to divest from Eramet over the environmental and social performance of the PT Weda Bay Nickel project, which illustrated investor pressure acting as a driver for stronger alignment with RBC standards.
5.2.3. Link between traceability and participation in multi-stakeholder and industry initiatives
There is also evidence of a link between participation in multi-stakeholder and industry initiatives on RBC and progress in traceability. As shown in Figure 5.3, companies participating in initiatives on RBC more frequently report full or partial traceability systems. Given the correlation between the two it is not possible to draw firm conclusions on the relationship between participation in initiatives and uptake of traceability. As mentioned above, some multi-stakeholder and industry initiatives provide protocols for traceability information to be passed on through supply chains.
Figure 5.3. Participation in multi-stakeholder and industry initiatives on RBC and status of supply chain traceability systems
Copy link to Figure 5.3. Participation in multi-stakeholder and industry initiatives on RBC and status of supply chain traceability systems
Note: This figure presents 86 responses to survey Question 7 (“Does your company currently use, or participate in, any traceability system?”)
and Question 33 (“Are you a member of one or more of the following sustainability initiatives?”), including 69 respondents reporting participation in one or more sustainability initiatives and 17 respondents reporting no such participation. “No traceability system” combines the response options “No, but we are planning to” and “No current plans”. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
5.2.4. Early evidence on the benefits of traceability
While the benefits of traceability are not yet fully tangible, early evidence points to a range of operational and reputational gains for companies that have invested in systems. Close to half of the respondents who set up traceability systems stated that it was too early to indicate any benefit, and 14% found no tangible positive impact in running a traceability system. Among the 31% who did report tangible benefits, respondents identified reputation management, customers’ trust and improved market access, in line with responses related to incentives guiding them to set up a system in the first place.
Other respondents indicated that better visibility over the supply chain allowed them to optimise performance in logistics between supply chain actors, develop better supplier engagement strategies, and make changes within their supply chains to adapt to market and regulatory developments. As a concrete example, one respondent cites that when international sanctions were introduced in certain importing markets due to the Russian Federation (“Russia”)'s war of aggression against Ukraine, the company had all the relevant information at hand to comply.
5.3. Main gaps and shortcomings of existing multi-stakeholder and industry initiatives on RBC and traceability systems
Copy link to 5.3. Main gaps and shortcomings of existing multi-stakeholder and industry initiatives on RBC and traceability systemsTraceability systems face real barriers to effective implementation. Cost and lack of interoperability are the most commonly cited obstacles, alongside data reliability concerns and limited leverage over suppliers. For policymakers, the survey points to a clear set of priorities: financial incentives, shared data infrastructure, and more consistent regulations across jurisdictions are the measures companies most want to see. The overall outlook is encouraging, with nearly three quarters of respondents planning to increase investment in traceability over the next three years, but policy action will be key to turning that intent into practice.
5.3.1. Uneven capacity across supply chain actors
Industry, transparency and traceability initiatives are not always designed to accommodate the significant diversity in scale, resources, and awareness across supply chain actors. Literature shows that smaller companies, especially artisanal and small-scale miners (ASM), face numerous barriers to meeting operational and governance benchmarks, due to lack of access to formal infrastructure for digital technology, finance and insurance (Levin Sources, 2025[4]) (World Bank, 2023[5]). In contrast, large companies or multinationals generally fare better due to internal policies and processes focused on meeting regulatory requirements and investor scrutiny. Nevertheless, this often has to do with the way RBC initiatives are designed. An OECD study comparing over 2 000 RBC metrics from eight major rating products found that 68% of all metrics measure company policies and activities rather than their impacts. This emphasis is particularly pronounced for topics such as labour rights (81%), human rights (89%), and biodiversity (82%) (OECD, 2025[6]).
5.3.2. Data scarcity and fragmentation
Data scarcity, fragmentation and reliability remain major obstacles. Several critical minerals have large data limitations, in particular with regard to trade and production data across the entire supply chain, which makes tracing these minerals challenging (NRGI-EITI-OECD, 2025[7]). This is also evident in lithium and nickel supply chains, as mentioned in chapters 3 and 4, as data at certain segments of the supply chain can be obscure or publicly not available. Moreover, data for some end-of-life products containing critical minerals, such as e-waste, are difficult to obtain due to waste collection challenges and leakage. Existing trade codes also do not differentiate between minerals and their compounds sourced from primary sources as opposed to recycling. The reliability of traceability systems depends heavily on the accuracy of the data entered; if false information is entered, the entire system can be compromised. This risk is especially high in jurisdictions with weak governance.
5.3.3. Fiscal governance
For government-led systems, similar challenges persist, which creates multiple entry points for fiscal revenue erosion, for example through reductions in corporate income tax and royalties that are volume or valued based. In the development and production phases, technical, management, and engineering services charged within mining groups can be overstated or duplicated, eroding the tax base. These services are often difficult to verify and may include exaggerated mark-ups not aligned with value creation. At the extraction stage, production volumes may be underreported through limited or outdated equipment, insufficient technical expertise to operate advanced systems, and a lack of independent verification of the data entered. Following extraction, mineral grade and quality can be understated through selective sampling, testing in affiliated laboratories, or weak state assay capacity. Pricing and its adjustments depend heavily on grade, purity, moisture content, and impurities contained in the mineral with even small differences in the grade or quality potentially having a significant fiscal impact.
Logistics costs, including freight and insurance, are another area of vulnerability. Inflated freight rates, captive insurance arrangements, and bundled logistics contracts routed through investment hubs can significantly reduce taxable profits. Finally, financing arrangements remain one of the most persistent BEPS risks especially in the extractive sector given the significant capital requirements associated with a mining project. The mining sector is generally characterised by thinly capitalised capital structures through intra-group funding arrangements with detrimental terms and conditions, particularly, excessive interest rates and quantum of debt. These allow for excessive interest deductions throughout the project lifecycle, reducing the profit base in mining countries and subsequently reducing the taxes paid to the host state.
5.3.4. Credibility of multi-stakeholder and industry initiatives
The quality of implementation of multi-stakeholder and industry initiatives depends on their credibility. Where industry initiatives and audit programmes evaluate sites, company risk management practices or products, they vary considerably in the quality of their assessment methodologies and teams, robustness of their monitoring and oversight systems, levels of independence, accountability and transparency of decisions (Manuel C. Kathan, 2025[8]; Ellen Pei-yi Yu, 2020[9]; OECD, 2024[10]). The inclusiveness of initiatives’ governance models (especially with regards to non-industry stakeholders, such as Indigenous Peoples), levels of independence, accountability, transparency of decisions and impact on local communities have emerged as key indicators for the credibility of these initiatives (OECD, Forthcoming[11]).
5.3.5. Cross-border regulatory inconsistencies
Cross-border regulatory inconsistencies may further complicate traceability requirements especially for secondary supply chains. For example, the varying classification of battery waste and black mass as hazardous or non-hazardous materials, or even as waste or products, across jurisdictions creates significant verification challenges. In countries such as Argentina and Chile, classifications and guidance for how battery waste should be handled, disposed or recycled is not yet clearly defined, despite an increasing recognition of the risks that incorrect handling can result in (Boletín Oficial de la República Argentina, 2025[12]). Large portions of black mass trade fall outside open-access reporting frameworks and are declared under multiple Harmonised System codes, limiting transparency and creating regulatory arbitrage risks (Institut Français de Relations Internationales, 2024[13]; GAIA, 2025[14]). Without explicit classification under existing frameworks, companies face uncertainty in documenting and verifying the origin of recycled content when materials cross borders (IEA-OECD, 2025[15]). Given the documented exposure of other waste and secondary material flows to trafficking, informality, and corruption at the recycling and trading stages, traceability risks associated with black mass warrant closer examination (Isarin, 2023[16]).
5.4. Barriers to scaling up traceability – insights from the survey
Copy link to 5.4. Barriers to scaling up traceability – insights from the surveyDespite growing momentum, significant barriers to effective implementation remain: Cost and lack of interoperability are the most commonly cited obstacles, while confidentiality concerns, limited supplier leverage and data reliability issues constrain ongoing operations. The proliferation of overlapping standards adds further complexity, particularly for smaller producers. Nevertheless, most respondents plan to increase investment in traceability over the coming years, pointing to an important window for policy intervention.
5.4.1. Gaps between audits and customer expectations
Participation in RBC initiatives that verify performance, such as audits or assessments, may not exhaust customers’ expectations regarding suppliers’ performance on RBC, pointing to a need for more credible and comprehensive verification processes. Over 60% of survey respondents reported undergoing at least one RBC-related audit in the past year. At the same time, 70% also reported that they had received at least one RBC-related enquiry from individual customers. While 45% of respondents reported receiving between one and ten enquiries annually, eight respondents reported receiving more than one hundred individual requests over the same period. There are also inconsistencies in exposure to responsible sourcing requirements and requests. One quarter of respondents reported neither receiving individual enquiries nor undergoing any audit. This variation is only partially explained by their supply chain position, as upstream companies are typically more exposed to audit requirements by downstream companies. The complexity of multiple, sometimes overlapping, standards can become a barrier, especially for smaller producers with little insight on standard implementation and recognition by stakeholders.
5.4.2. Implementation and operational barriers
Companies face a distinct but overlapping set of barriers at both the implementation and operational stages of traceability adoption. As shown in Figure 5.4, more than half of the respondents to the survey identified the cost of implementation and lack of interoperability as the main obstacles to setting up traceability systems. The vast majority of respondents had not, however, undertaken a cost estimate at the time of the survey. The cost of implementation of a traceability system varies based on the technology used, the complexity of the supply chains as well as the availability of existing infrastructure and systems (IEA-OECD, 2025[15]). Adherence to traceability systems is not costless, even if systems are in place both at the company and institutional level which makes data easier to collect and report. However, these costs will be more substantial where there are no pre-existing reporting systems. Traders, miners and smelters appear to be most impacted by the cost of implementation, reflecting the need for data collection more upstream. Interoperability between different systems is necessary for an efficient data exchange across the supply chain.
When asked about operational limitations companies faced when maintaining and operating effective traceability systems, business confidentiality, limited leverage, and limited credibility of collected data were identified as the main obstacles. This appears to be a general concern as beyond issues of having the ability to collect traceability data, companies may also be reluctant to participate in traceability systems on the basis that product design and composition is considered proprietary information which they do not wish to disclose (Mewangi, 2025[17]).
Figure 5.4. Main challenges in setting up and operating traceability systems
Copy link to Figure 5.4. Main challenges in setting up and operating traceability systemsImplementation challenges centre on cost and interoperability, while ongoing operation is constrained by confidentiality concerns, supplier leverage and data quality issues.
Note: This figure presents responses to survey Question 21 (“What are the main challenges, if any, that your company has faced in setting up traceability tools?”) and Question 22 (“What are the main obstacles or limitations, if any, that your company has faced in maintaining and operating an effective traceability system?”). Respondents could select up to three options. Based on a subsample of 40 miners, 36 smelters/refiners, 42 manufacturers/end-users and 12 traders, irrespective of whether they reported implementing a traceability system. Recyclers and transporters are excluded; manufacturers and end-users are grouped into a single category. “Other” and "None" response options are not shown in the figure. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
5.4.3. Industry appetite for investment into traceability
Notwithstanding the challenges outlined above, industry's appetite for traceability investment appears strong. Despite shortcomings of existing traceability systems and challenges with their implementation, nearly three quarters of respondents to the survey across all supply chain segments indicate they are likely to increase investment in traceability over the next three years (Figure 5.5).
Figure 5.5. Likelihood of increased investment in traceability over the next three years
Copy link to Figure 5.5. Likelihood of increased investment in traceability over the next three yearsNearly three quarters of surveyed companies indicate they are likely to increase investment in traceability over the next three years.
Note: This figure presents responses to survey Question 30 (“Over the next 3 years, how likely is your company to increase its investment in traceability?”). Based on a subsample of 40 miners, 36 smelters/refiners, 42 manufacturers/end-users and 12 traders, irrespective of whether they reported implementing a traceability system. "Other" includes two open-ended responses indicating continued or targeted investment approaches. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
5.5. Factors for scaling implementation
Copy link to 5.5. Factors for scaling implementationSurvey respondents broadly agree on what would most support the scaling of traceability efforts: greater regulatory consistency across jurisdictions, financial incentives, and interoperable data infrastructure are the most frequently cited priorities (Figure 5.6). These insights align with previous OECD-IEA research on the role of traceability in critical mineral supply chains (IEA-OECD, 2025[15]). They also align with information collected during site visits, which highlighted the potential for greater financial incentives in particular to drive uptake of traceability.
Figure 5.6. Ranked preferences for support measures to scale traceability efforts
Copy link to Figure 5.6. Ranked preferences for support measures to scale traceability effortsRegulatory consistency is most frequently ranked as the top priority, while financial incentives and shared data infrastructure follow as secondary enablers.
Note: Based on survey Question 31 (“What kind of support would most help your organisation scale traceability efforts? (Rank in order of importance)”). Percentages are calculated using the total number of respondents (n = 90) as the denominator. Respondents were asked to rank five support options from 1st (most important) to 5th (least important); each percentage reflects the share of respondents assigning a given rank to each option. Survey data was collected between late 2025 and early 2026. Please refer to the methodology section for further detail.
Source: OECD-IEA Survey on Traceability in Critical Mineral Supply Chains
5.5.1. Market incentives and price premia
Market incentives alone are unlikely to be sufficient in the near term. Although provenance can enhance reputational value, evidence that RBC-linked certification consistently delivers a price advantage is limited, though emerging evidence suggests it can be a factor in some circumstances. Prior to introducing responsible sourcing requirements, for example, LME cobalt traded at a discount compared to spot transactions (Bernards, 2021[18]). Some traders have noted that clients are increasingly insisting on certified material, especially when sourcing from locations with high-risk profiles. While this has not led to discernible price premia for certified minerals, it conceivably could in a tight market. Due to these developments, traceability has increasingly become an important tool to distinguish responsibly produced material in a market that increasingly accords importance to operational and governance factors in the supply chain, even if it does not always provide sufficient competitive differentiation to command a price premium. Additionally, under OECD Transfer Pricing Guidelines, pricing of minerals between related parties must reflect market conditions and the terms and conditions that independent parties in comparable circumstance would agree to. As every commodity is different with its own unique supply and demand dynamics, it is important for any transfer pricing analysis to thoroughly evaluate the particular critical mineral (OECD & IGF, 2023[19]).
Greenhouse gas (GHG) emissions are generally more quantifiable and verifiable than other dimensions, which has enabled the piloting of so-called “green” premia defined as the price differential between commodities produced with a low versus high carbon footprint. According to an industry survey, the share of traded volumes qualifying as “green” remains relatively limited, ranging from 9% to 12% of respondents’ sourcing for battery-grade lithium and nickel, but is expected to grow as companies strengthen commitments to reducing Scope 3 emissions and as downstream demand for lower-carbon inputs increases (McKinsey, 2024[20]). In October 2025, the London Metal Exchange (LME) announced a roadmap to develop RBC metal premium pricing for LME-approved brands, including a proposed maximum carbon-footprint threshold of 20 tonnes of CO₂ per tonne for nickel, with relevant RBC data disclosed through the LME passport (London Metal Exchange, 2025[21]). It is important to note that LME-approved brands are required to comply with the LME’s Responsible Sourcing requirements, which are aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, thereby establishing a baseline level of compliance. Lithium RBC premia exist in selective commercial arrangements and premium product niches, but they are not yet widely reflected in fungible benchmark prices or exchange-level pricing mechanisms, and overall uptake remains limited.
The nascent premium landscape is confirmed by survey responses, with over 70% of respondents indicating that they did not observe any price differentiation for material produced by a mine certified by an audit programme. Those that did report around the same rate (10%) of discount for non-certified material, a price differential only depending on origin, and a premium based on social audit certificates and a premium based on low greenhouse gas emissions.
5.6. Implications for policymakers
Copy link to 5.6. Implications for policymakersTaken together, these findings point to a clear set of priorities for policy action. Market forces and regulatory expectations are driving uptake, but cost, interoperability and fragmented regulatory environments remain significant barriers. Most companies have yet to see tangible returns on investment in traceability, indicating that its business case is still maturing. At the same time, nearly three-quarters of respondents plan to increase that investment, suggesting that policy intervention at this stage could have an outsized impact in shaping how traceability systems develop. The recommendations that follow respond directly to these findings, setting out a targeted and phased approach that works with existing market momentum.
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