 So, good afternoon to those of you in the UK. Good evening to anyone in the Far East. And I don't know if there's anyone joining us from the US or anywhere like that. Good morning to you. It's really great to have a global audience here to hear these three distinguished speakers from Singapore talk about the corporate restructuring initiatives that are likely to have consequences all over the world though obviously we're focusing today on on Asia. I'm sure many of you who are know about it will agree that restructuring and solvency law is always of course important, but it has become much, much more significant in the last year, even more significant because of the economic effect of the pandemic and of course the pandemic is a global phenomenon so it affects everyone around the world. And the two projects that are subject to today's presentation. I think they both predate the pandemic in at least in their planning stages, and they are the result of the vision of amongst others two of our speakers today. So first we're going to hear from Justice Canon Ramesh to talk about the Asian principles of business restructuring project. This is a project which is jointly undertaken by the Asian Business Law Institute, and the International Insolvency Institute. I heard about it as because of the member of the International Insolvency Institute as I think one or two of our entities are. And I became a little bit involved in this project through triple I. So we're delighted that Justice Ramesh is able to be with us to talk about that. After a distinguished career in practice in Singapore he became a judicial commissioner in 2015 the judge of the High Court of Singapore in 2017. And but he not only is he a judge but he's very active in law reform and and in the global discussion about insolvency and restructuring. So Justice Ramesh is going to kick off. We're then going to hear from Dr Aurelio Greia Martinez. Aurelio is an assistant professor at SMU Singapore Management University. He studied in Spain, Oxford and Stanford. I got to know him when he was at Oxford. And he's going to talk about the work of another restructuring initiative in Asia, the Singapore Global Restructuring Initiative. And he founded that Singapore Management University last year so he's going to talk about what he's been doing there. And then we have to comment on both of these presentations we have Mr. Sushil Nair. And Sushil is the Deputy Chief Executive Officer of Drew and Napier and also heads up its corporate restructuring and workout practice group that's all in Singapore. He chairs the insolvency subcommittee of the Law Society of Singapore, and he was named Singapore's restructuring law of the year 2019. So with our distinguished speakers I hope there'll be time for some questions and discussion after the presentation, just a few nuts and bolts instructions. If you'd like to ask a question or make a comment. If you can raise your hand, but I think I think you're meant to put it in the Q&A, and then I can call upon you there. And what we will do is, unless you don't want to, we'll make your panelists everyone can see you when you're asked your question and make your comment. So that's my, all I'm going to say, by way of introduction. And now I'd like to hand over with many, many thanks to Justice Ramesh. Thank you. Thank you very much for the warm introduction, Louise. Good morning. Good afternoon. Good evening to everyone. I am grateful for the kind invitation from Professor Califer and Dr. Saffek to join you today for this presentation on an important project of the Asian Business Law Institute, or AB for short, and the International Insolvency Institute. The physical borders remain largely closed due to the pandemic that I'm able to join all of you in the United Kingdom and from other parts of the world from Singapore, despite the time difference and global separation speaks to the fact that our borders have never been more open. Cross-border collaboration has never been easier, thanks to technology and our common desire to stay connected. We must continue to leverage technology and harness our collective will as the pandemic unfortunately still has some legs to run. International cooperation and collaboration are important, if not essential ingredients in achieving effective solutions in cross-border insolvency. Fragmentation in philosophy and approach results in inconsistent decisions and compromise in unproductive outcomes. This goes against the grain of international comedy, which is at the heart of modified universalism. So, you rightly expressed by Lord Hoffman in HIH and many other of his judgments. Uncetral realized the importance of reducing fragmentation very early on and anchored its efforts on modified universalism. Working Group 5 sterling reform work has resulted in the formulation of seminal instruments, such as the 1997 model of cross-border insolvency. There has not been an overstatement to say that Working Group 5's work has done much to facilitate a common foundation for the resolution of cross-border insolvencies. However, much more is needed. Solutions are required to meld our philosophies and iron out our differences so that insolvencies are resolved on a common footing. How do we do this? It is very self-evident that convergence in philosophy and approach is key. For this to happen, the principles and ground rules must at the very least be similar. While the model law is a step in this direction, as Panchalara and Rubin in Eurofinance, it is a procedural tool only. As such, it is not designed to synchronize philosophies and can only take us so far. It is our collective responsibility as members of the global insolvency community to walk down the path of convergence. Globalization demands that we do. It is a fact that globalization has caused a paradigm change in the global economic order. Trade and investments flow across borders and economic zones largely seamlessly and unfettered. Whether we end up with a unified world economic order or a bipolar US-China world order, as BlackRock suggests in a report released last week, or for that matter some other option, globalization in some shape or form is here to stay. As a case in point, the Asian growth story has been written on the back of the phenomenal growth in trade and investment flows into and out of Asia and within Asia. Much ink has been spilled on analyzing the economic ramifications of the Asian growth story. Perhaps less has been spilled on considering whether Asia's legal architecture has kept abreast with the pace of its economic change. We cannot begin said that economic growth needs to be allied with the regeneration of the legal landscape to be sustainable in the long term. This then is the backdrop for the project which I will share with you today, the Asian principles for business restructuring. The seeds of the project was sown in 2016 when the Abley was launched in Singapore. This mission is the removal of, and I quote, unnecessary or undesirable differences between Asian legal systems that pose obstacles to free and seamless trade. The Abley seeks to achieve this by, and I quote again, initiating research with a view to providing practical guidance in the field of Asian legal development and promoting the convergence of Asian business laws. I quote, the Abley was therefore the right platform for the project. At the same time, it was important that the Abley found an outstanding thought leader to partner. In the AAA, the Abley found that partner that the project was therefore born. It is gratifying that so many legal luminaries, such as Professor Gallifer from all over the world, Asia included, have accepted the invitation to contribute to the project. This report is a ringing endorsement of the mission of the project and the direction the Abley and the AAA have taken. Let me say a little bit more about the conception of the project. Insolvency is often associated with images of collapse businesses, lost jobs, distraught families, and other societal economic disruptions. Sadly, these unfavorable images have only been reinforced by the pandemic. Just last week, I read with sadness the appointment of the official receiver as a liquidator of governance, a 243 year old institution in England. The economic malaise and social upheaval that insolvency causes needs to be managed by an effective insolvency process. A proper insolvency regime plays a critical long term role in driving economic development by ensuring that a country and indeed a region is attractive to investment. Private investors are more drawn to regions where the rules are predictable, transparent and broadly consistent across jurisdictions, as they have the assurance of a fair and efficient exit in a multi-jurisdictional work out. Without convergence, there's a real risk of jurisdictional arbitrage. A large number of international organizations are dedicated to addressing this issue, such as Working Group 5, the World Bank, Asian Development Bank, Insol International, and the triple I, to name a few. This signals a desire to reduce and where possible, remove fragmentation and insolvencies. The case for convergence is particularly compelling for Asia. Based on ADB estimates, Asia will need US $1.7 trillion in investment every year until 2030 in order to maintain a strong growth momentum, respond to climate change, and tackle poverty. Asia's total infrastructure needs alone are estimated to be around US $2.8 trillion from 2016 to 2030, or an annual requirement of US $184 billion equivalent to 7% of ASEAN's GDP in 2016. There is therefore a huge investment gap that awaits filling by private investors who may choose to watch and wait rather than invest if there isn't a consistent framework for exit in distress situations. Over the years, many of the multilateral organizations mentioned earlier have made tremendous progress on this march to harmonization. These examples come to mind. I really mentioned the outstanding work of Working Group 5 in formulating seminal model laws. Working Group 5 is presently developing an insolvency framework for micro, small, and medium-sized enterprises, a necessary development in my view to address the unique challenges posed by the insolvencies of MSMEs. Also by 2016, the judicial insolvency network was formed to facilitate court-to-court communication and cooperation and introduce best practices in cross-border insolvency cases. Many Asian judiceries are represented in the gym. In the gym, this is a big positive. However, much work remains to be done, and in the case of Asia, the need is pressing. The reason that the Board of Governors of the ABLY decided in 2016 that insolvency and restructuring was a project topic that merited serious pursuit. The Board also felt that international expertise was crucial, following detailed discussions with the leadership of the triple I, the project was conceived. As his name suggests, the project has, as its ultimate aim, the issuance of a set of principles or shared best practices or guides that cover both in-court and out-of-court workouts. The Asian principles, as I shall call them, are meant to be a reference tool for judges and practitioners, as well as legislators, regulators and policymakers in the Asia-Pacific region on a suggested common philosophy and approach to insolvency workouts. The ABLY formed an advisory committee and a working committee to guide the project. Professor Gallagher is an advisory committee, by the way. The committees felt that the project should proceed in two phases. A phase one to map the existing business reorganization landscape in Asia, and a phase two to formulate the Asian principles. Phase one was conceived as an understanding of the status quo was regarded as necessary before a common approach could be recommended. The positions were identified for the phase one mapping exercise, namely all 10 ASEAN member states, as well as ASEAN's major training partners, such as the People's Republic of China, India, South Korea, Australia, and Japan, to name a few, just to name a few. The backdrop of phase one was a questionnaire issued in February 2019. The questionnaire was a massive undertaking, drawing to over 200 questions, covering the full spectrum of issues that arise in the workout. Dr. Paul Oma, who many of you here would know, was its principal architect. He crafted the questions in close consultation with the two committees. The questionnaire is available on Avery's website for download, and I commend it to you for both its depth and as a template for future similar questionnaires. With the release of the questionnaire began the work of drafting reports for each of the 16 jurisdictions. 26 jurisdictional reporters were enlisted, condensing responses to 200 questions in a coherent report, complete with footnotes and appendices was a mammoth task. A number of reports were reviewed subsequently by a group of international experts. Thanks to the work of all reporters and the review panel over a 13 month period, phase one saw the publication in April 2020 of an 804 page compendium titled Corporate Restructuring and Insolvency in Asia 2020. The personal reports provide a comprehensive picture of the current regime in each jurisdiction and explain in detail, not only the law is written, but also as practice. It is the first publication of its kind for a number of ASEAN jurisdictions, such as Brunei, Laos and Myanmar, all of which have recently implemented reforms. The timing of the compendium was opportune as the economic fallout from the pandemic had just started to be felt. The compendium has received considerable interest from Asia and beyond since its release. In September and October last year, Abley partnered with Insol's Regional Hub in Singapore to introduce the compendium to Insol's members in Asia. The release saw very encouraging take up. The publication has also been reported on various media, such as LexisNexisBlog and the Australasian Lawyer. Most recently, the Chief Justice of Singapore, Sandesh Menon, referred to the compendium in his response to the opening of the legal year 2021 as one of the examples of the work carried out to, and I quote, advance multilateralism and the rule of law. Just last month, Abley and the Triple I were delighted to learn that a group of young judicial officers from the Shenzhen Bankruptcy Court of the PRC had started work on translating the compendium into simplified Chinese to make it more accessible to readers in the PRC. This is a particularly exciting development. As the first specialist bankruptcy court in the PRC, the Shenzhen Bankruptcy Court is at the forefront of developments in insolvency in the country. The fact that young insolvency judges from that court have found the compendium insightful and one-two in their own words, and I quote, introduce overseas practices to the PRC on code, bodes well for the goals of the project. The publication of the compendium and the warm reception it has received serve as added impetus to press ahead with the next stage of the project. Phase two promises to be an even more exacting task as distilling and synthesizing the essence of the jurisdictional reports into a set of principles is an ambitious undertaking. Let me explain why. A review of the compendium reveals the diversity in approach taken by the 16 jurisdictions. This is hardly surprising given the different legal traditions of the jurisdictions. Seven are common law, eight are civil law and the remaining one is a hybrid of the two. The diversity is compounded by the fact that legal systems of these jurisdictions are in different stages of evolution. I illustrate the challenge with two and if time permits three examples. First, out of court workouts. The most common approach seems to be to leave out of court workouts to the parties. There are no legislative regulatory interventions with the parties free to negotiate any arrangement amongst themselves. The validity of such arrangements is governed by general laws of contract, not insolvency law. In some of these jurisdictions, however, organs of the government or industry associations have taken the step of issuing policy documents or guidelines to facilitate out of court restructuring of corporate debts owed to financial institutions. For example, in Hong Kong, debtors of banks may invoke the Hong Kong approach to corporate difficulties, which is a set of principles governing corporate debt restructuring and workouts involving multiple banks. The institution of banks in Singapore has similarly issued a set of principles for facilitating out of court workouts through its principles and guidelines for restructuring of corporate debts. The Bank of Thailand, Thailand's central bank has issued policies and workouts for financial institution creditors as well. The PRC on the other hand, has issued policy documents focusing on general economic measures and the setting up of bailout funds to facilitate out of court workouts. The category includes jurisdictions where formal legal structures are in place to promote out of court workouts. In Japan, the Act on Strengthening Industrial Competitiveness has introduced a regime called Turn-Around ADR. This regime facilitates the workout of debts owed to financial creditors by requiring the appointment of a mediator specializing company turnarounds. Out of court restructuring in South Korea has its roots in an agreement called the Corporation Restructuring Agreement reached by 210 local banks after the 1997 Asian financial crisis. The Corporate Restructuring Promotion Act now regulates such arrangements by enacting into law the workout procedures developed by the financial institutions. At the other end of the spectrum, several jurisdictions have neither any formalized rule nor any guideline or policy document in relation to out of court workouts. Brunei, Cambodia, Laos, Myanmar and Vietnam fall into this category. With the termination in 2003 of the Jakarta Initiative, Indonesia also falls into this category. The Jakarta Initiative was a government agency constituted following the 1997 Asian financial crisis to facilitate out of court corporate debt workouts. Next, I turn to the issue of recognition of foreign insolvency proceedings and insolvency representatives. The model law of course provides the most efficient and certain root for the recognition of foreign insolvency proceedings and representatives. However, only 30% of the jurisdictions studied by the project have adopted the model law. A silver lining is that India is actively considering adopting the model law. The remaining non-model law jurisdictions may be divided into three groups. The first group comprises jurisdictions that lean in favor of the model law or concepts of comedy. India and Hong Kong fall into this group. The courts in Hong Kong have a long tradition of recognizing the authority of a foreign liquidator appointed in proceedings that are substantially similar to the insolvency regime there. The second group comprises jurisdictions that as a principle do not recognize any foreign proceedings including foreign insolvency judgments. Indonesia and Thailand are amongst the jurisdictions that fall into this group. The position of the third group is legislation specific. Almost all reporters for jurisdictions in this group pointed out that while the jurisdictions have not adopted the model law and have no clear roadmap to do so, foreign insolvency judgments may be recognized according to domestic legislation or applicable bilateral treaties. For example, the PRC recognizes bankruptcy judgments from Italy, France and Germany based on bilateral treaties. However, bilateral treaties take years to negotiate and the threshold that one needs to satisfy under domestic legislation for recognition is usually high. The divergence in these areas illustrates the challenges that a multi-jurisdictional workout in Asia presents. It also underscores the need for convergence. In the absence of convergence, how will a cross-jurisdictional workout be managed without fragmentation? If cross-jurisdictional workout is a mix of in-court and out-of-court workouts, what principles will apply for the recognition of any voluntary arrangement that is entered into in the former? In our foreign insolvency proceedings are represented in the latter. Without shared principles, solutions may be hard to find. These are just some of the difficult questions that phase two must grapple with. Finally, there is dip financing. Dip financing is important as it offers distressed companies access to working capital while a restructuring plan is developed. Several Asian jurisdictions such as Japan and South Korea recognize dip financing as a common benefit claim that warrants higher priority. However, as a concept, dip financing is unfamiliar to most developing Asian jurisdictions and information on this form of rescue financing, not to mention its practice is thus limited. That being said, a trend is discernible from the jurisdictional reports. Many jurisdictions that have recently implemented varying degrees of law reform have moved dip financing up the priority list to above unsecured creditors in order to encourage post-partition financing. For example, Brunei now allows lenders who furnish unsecured financing after the commencement of insolvency proceedings to enjoy priority over other insecure creditors. The judicial interpretation issued by the BRC in 2019 converse dip financing priority over unsecured ordinary creditors. Having principles that address the treatment of dip financing in Asia, including issues of priority and valuation of secure interest may encourage funders to focus on special situation strategies to allocate capital to rescue viable Asian businesses in distress. So how is, how are we shaping phase two? Several meetings have taken place to discuss the shape of the Asian principles. It is important that industry associations such as banking associations and practitioner bodies are consulted during the initial draft review process of the Asian principles so that their concerns and feedback are taken on board. I guess then that to this end, the ABD will invite representatives from those associations to be part of a consultation group before road testing the Asian principles with the wider public. I digress briefly at this stage to mention another project that the ABDs are taking, the data privacy project. By adopting an identical architecture to the project, the data privacy project focuses on the framework for cross-border transfers of personal data in Asia. This project produced a companion of 14 jurisdictional reports in early 2018. Last year, a comparative study of those reports led to the publication of a comparative review and table title, transferring personal data in Asia, a path to legal certainty and regional convergence, which analyzes both the main differences and areas of convergence in Asian laws in the sphere of transfers of personal data. The data privacy project has garnered extensive global interest. Last November, it was selected from 850 submissions from 115 countries to be presented the Third Paris Peace Forum. An annual conference where heads of states, international organizations, top industry leaders, and nonprofit organizations meet to construct new forms of collective action regarding global governance issues. Recently, the comparative review and table was honored with the Privacy Papers for Policymakers Award by the Future of Privacy Forum, a leading privacy think tank in the United States. This is the first time in the 10-year history of the award that a paper focused on Asian laws has been selected. I mentioned the data privacy project only to illustrate why there's cause for optimism for the project. In conclusion, the pandemic has dramatically changed how most people live and work, perhaps permanently. To those whose work involves insolvency, the pandemic has brought perhaps brought an added dimension. It has brought the need for reform and insolvency and restructuring into sharp focus. The need for shared principles has never been greater. It is our hope that the Asian principles will make a difference. I mean, thank you very much for having me today. And now it gives me my great pleasure to invite Professor Oradeo Machines from the Singapore Management University University to speak about the Singapore Global Restructuring Initiative. Thank you very much. Thank you so much, Justice Ramesh, for this kind introduction. I would like also to thank Professor Luis Gallifer for putting together such a fantastic webinar. I would also like to thank my colleague, Professor Philip Stefik. So thank you all for being able to join us. I know that some of you are joining us from the United States. Some of you are joining us from Asia, many others from Europe. So thank you all for being able to be here with us, sharing a few thoughts about the Asian Business Restructuring Project and the Singapore Global Restructuring Initiative, which is what I'm going to talk about. The Singapore Global Restructuring Initiative is a global platform launched by Singapore Management University's Center for Commercial Law in Asia with the support of the Ministry of Law. And we try to achieve four main goals. The first one is to promote cutting edge research and restructuring and corporate insolvency. The second one is to contribute to the local, regional and international debate on corporate insolvency. As Justice Ramesh has just mentioned, we need more research and more policy and academic debates in the region, in Asia, and also in other parts of the world, especially in emerging economies. So hopefully with the work conducted by the initiative, as well as the support of many of the leading practitioners, academic judges and policymakers joining us for this exciting project, we will be able to help regulators and policymakers in promoting these type of discussions. Thirdly, we are also planning to promote awareness in the insolvency space because also we have realized that, as most of you know, insolvency is often understood as a bunch of procedural rules to deal with a financially distressed firm. And of course that's true, but actually the role of insolvency law in the real economy is much broader. In fact, insolvency law can often be more important for solvent company than for insolvent firms because of the ability of insolvency law to affect the way debtors and creditors make decisions. So that's why we want to promote this type of awareness to try to make the business and legal community realize that insolvency law is part of the entrepreneurial system and has a significant role in the real economy. And finally, we thought that this important mission needs to necessarily be conducted in collaboration with all the relevant stakeholders. So that's why, even though the initiative has been launched by an academic institution, we have made sure to put together and learn from leading practitioners, from judges, from regulators, and from policymakers from all over the world. So the way to achieve this challenging but also exciting goals is by putting together a fantastic group of insolvency experts from Singapore in our advisory board. An advisory board kindly chaired by Justice Ramesh, to whom I would like also to publicly thank for his invaluable support in this exciting mission. Also, we have created an international advisory council comprising leading scholars, prominent judges, and regulators and policymakers from all over the world. And then also we have a group of talented students from SMU interested in pursuing a career in insolvency and restructuring, also supporting our research team. Also, we are creating different alliances. So one of them is with the University of Cambridge Center for Corporate and Commercial Law. So I would like to thank also publicly to Professor Luis Gallifer and Professor Felix Stefik also for their support and the opportunity to work together on several projects. We are also launching with Insol International several initiatives with the Asian Business Law Institute. So that's why we're trying to collaborate with many different stakeholders and institutions. We are organizing a variety of activities. So we are planning as soon as the COVID-19 crisis allow us to organize something physically, we are planning to organize a major global conference of corporate restructuring where everybody here is very much welcome to join us for this exciting event. We have also created a visiting professorship for a global expert on corporate insolvency to be able to join us and stay in Singapore for a couple of weeks to help us contribute to the local and regional debate on corporate restructuring. We are organizing a variety of webinars, seminars, round table, one of them again in collaboration with University of Cambridge. We have created a blog for insolvency news around the world. Again, I would like to encourage everyone to please contribute to our blog by submitting articles dealing with insolvency reforms, new academic papers, insolvency decisions, any judgment that can be particularly useful for the local, regional or international communities. Very much welcome. And then we are also working on seven research projects. So some of them are also conducted in collaboration with some external colleagues. For example, one of our project is about comparative insolvency law. So Professor Felix Pepe from Cambridge and I are editing a book on comparative insolvency law from an economic and functional perspective. And we have managed to put together a group of experts from Japan, from China, from Europe, from the UK, from the United States, from Latin America, and we're working together on that. Also, we are working with some leading practitioners from Singapore, also in another book and a variety of articles analyzing the new insolvency restructuring and the Solution Act in Singapore. We are also working on a variety of projects dealing with SME insolvency, with impact of new technologies on insolvency, also emerging economies as Justice Ramesh has mentioned. The Asian Business Restructuring Principles have shown that some of the major weaknesses in the insolvency regimes in the region are found in many emerging economies. And that's probably because these countries still need a more active academic and policy debate. So that's why we have decided also to conduct a variety of projects on insolvency law in emerging economies. And in fact, in our website, we are publicizing some of the research paper that we have been conducting so far in this space. And finally, we have also been doing some research, of course, because of these unfortunate times, we have been doing some research on insolvency and so in particular, we have focused on how insolvency law can help. If so, to minimize the harmful economic effects generated by the pandemic. And we are also observing how countries are amending their insolvency laws around the world and whether some of these reforms are going to be permanently adopted after the COVID pandemic. We have published a variety of blog posts, journal articles, working papers, reports dealing with our work on COVID-19 and insolvency, including the reports prepared by the World Bank and Insol that I drafted along with two colleagues, one of them from the UK and one from India. We have also prepared the Singapore report for the World Bank and Insol report on legal and economic measures to support businesses. And we have organized a variety of events dealing with insolvency law and COVID-19, including events where we have been presenting research on that at the University of Sydney, Indian Institute of Corporate Affairs, Insol International, Tripoli and many others. And what have we found in our research on insolvency law in times of COVID? Well, I think it's important and something that we are observing is that we can clearly distinguish two main stages in the COVID-19 pandemic. The first stage where most countries decided to put their economies into hibernation and in order to do that, some amendments were introduced to their insolvency frameworks, mainly with the purpose of suspending or restricting creditors' rights to initiate insolvency proceedings. This is something that was adopted, for example, in the Asia-Pacific region by Australia and by Singapore, among others. Also, suspension or relaxation of directors' duties and liability in insolvency. This is another temporary reform adopted in Singapore, Australia and many others. Also, the promotion of workouts is essential, not only for the hibernation phase, but also for the recovery phase. Not only because the significant cost that can be saved by not initiating formal insolvency and restructuring procedures, but also because we are all overseeing also a way of insolvency cases. So that's why it's important also not to overwhelm the judiciary, particularly in some of the emerging countries existing in the region where maybe the judiciary doesn't have the level of sophistication existing in other countries such as Singapore, the UK, the United States and many others. But then, as I mentioned, we are observing a new wave of insolvency reforms, and this new wave of insolvency reforms are more focused on the recovery phase of the pandemic. So these reforms include again the promotion of workouts. This is incredibly essential also. But more importantly, we are observing in many jurisdictions in the Asia-Pacific region and internationally the adoption of simplified insolvency framework for micro and small firms. So in Singapore, for example, starting last Friday, we have adopted this simplified insolvency program where small and medium-sized companies can apply for our simplified insolvency program. And companies applying for this program will have access, as it happens in Australia as well, to simplify restructuring procedures, which is mainly inspired in our pre-back scheme. So that's why by reducing some of the costs of the procedure, we can make an efficient restructuring tool for SMEs facing financial trouble, but SMEs that are still viable. And also we have adopted a simplified liquidation procedures for those businesses that are no longer viable, and therefore they need a quick exit. So in Singapore, also these procedures and actually one of the main concerns with SMEs that we have found is how to fund the remuneration of insolvency practitioners and how to fund the procedure itself. So something innovative also that this insolvency program in Singapore has adopted is that the program subsea dices part of the remuneration fee. So that's why this is something that is also very much welcome. So as you guys can see, we have a lot of work ahead. I've been just describing one of the many projects that we are currently conducting. And in order to achieve this mission, we need your help. So that's why please feel free to join us to our events. Feel free to reach out to me for any idea for projects or collaborations. Feel free to submit a blog post because we really need to learn from the international insolvency community. We have a lot of work ahead and that's why it's important to have the expertise, the feedback and the support of all of you, because I am seeing many leading practitioners, judges, regulators and policymakers, kindly joining us today. So everybody's welcome to this exciting project. Thank you so much, Professor Black-Gallifer and also Professor Stefec and Justice Kanan-Ramich. Thank you, Araleo. And finally, we want to hear from, we're going to hear from Sushil Nair and before we have, I hope, some time for some questions. Sushil, over to you. Thank you very much, Louise, and I'm very grateful to you for making me a part of this event, this presentation. It is daunting to follow on presentations made by the likes of Justice Ramesh and Professor Martinez, but I will do what I can. The area of discussion is one which I consider of critical importance to the economic well-being of Asian economies. Asia has become a magnet for investment and over the past decade, the FDI levels flowing into Asia as a percentage of global FDI has grown from some 12% in 2003 to 23% in 2017 and is still growing. In 2019, it was at about 30%. And that would be given that 2020 was the pandemic year, a fair reflection of what Asia could expect in terms of FDI in a normal economic year. Investment into Asian economies remains a cornerstone of the investment stratagems of a number of the larger funds and investment houses. And what is interesting is within Asia, 60% of the investment in Asian economies comes from other Asian companies. So Asia draws global FDI, but also is a major investor in itself with one state investing in the other and no prizes for guessing who the major investor is. Given the substantial amount of investment. It is in the best interests of all stakeholders in Asia's legal systems to work together in a way that minimizes uncertainty for investors, both from outside Asia and from within. The level of investment in Asia can only be enhanced when investors are able to take a view of the level of risk they take when pursuing Asian investments. This is especially relevant now in the face of the current pandemic and the inherent economic issues it throws up. Given the extent of existing investment into Asia, both from outside Asia and from within Asia, it is inevitable that the level of distress debt and distressed entities will rise. Restructuring regimes in the various Asian jurisdictions will have to deal with the fallout. Speaking broadly, different Asian countries have different roles. Certain states are financial centers with legal and administrative systems that enjoy a certain global trust. Others have significant natural resources and domestic industry that are extremely attractive to investors. For many years, financing is raised in the financial centers and often subject to the laws of those centers and on lent to the entities of the countries with the industries and related resources. So bonds are raised or financing subject to the particular jurisdictions taken out and then on lent. Usually you'll have SP these set up in the financial centers that will be the data in so far as the raising of money is a concern. And that data then on lens the money is raised to operating companies, which are in the countries with the raw materials and the countries with the industries. Investors are consistently concerned about how in the case of their investments running into difficulty, a restructuring can be worked out that encompasses the jurisdiction where the money was dispersed to. And that where the assets in business is physically located. We are unable to show these investors a practical way in which restructuring can be carried out across jurisdictions in Asia without considerable uncertainty risk and added costs as a result of multiple processes over jurisdictions. The investment climate will suffer. I have dealt with Asian cross border restructuring involving countries in Southeast Asia, South Asia and North Asia. In these cases we have had to deal with concurrent processes in different jurisdictions with significantly different restructuring regimes. And yet what you're trying to do is get to the same commercial deal. But because you have different regimes, and you have regimes that don't necessarily recognize each other with systems that are not harmonized, you're looking to do the same thing in different jurisdictions, resulting in increased costs. And the degree of uncertainty because you're not sure how the different jurisdictions will view the deal that's being put forward. Despite our best efforts and the efforts of the lawyers in the various jurisdictions where we do those cross border those cross jurisdictional restructurings, it, there is always going to be a degree of uncertainty. Investors recognize this and it is a significant deterrent to investment. It is therefore in the collective interest of all insolvency stakeholders to work together to achieve a degree of certainty, and how an Asian cross jurisdictional restructuring exercise is carried out. The truth is that with the reduction of uncertainty, investment can only increase and that benefits all of Asia. Justice Ramesh is absolutely right when he says that it is our collective responsibility to walk down the path of convergence. This is not going to be a simple process. It will take time and will require a common will from all Asian insolvency stakeholders. But the Asian principles of business restructuring project project that justice Ramesh discussed is a vital step in the right direction. When one considers the mammoth effort already undertaken to prepare and release the corporate restructuring and insolvency in Asia 2020 compendium covering 16 jurisdictions. It is clear that there are people with the knowledge and the will to move us down the path where convergence can over time take root. There is already much in the Asian culture that is common and consistent with the philosophy of compromise so necessary for restructuring to work. When there is a clear recognition that convergence and cooperation will inevitably enhance the environment investment climate for Asian countries. It opens the door for each of us to do what we can to lobby for the various jurisdictions to agree to certain shared principles when it comes to restructuring exercises. As justice Ramesh has indicated one such area for consideration is dip financing. An area which could provide significant benefits to all Asian jurisdictions, but which will not succeed on a multi jurisdictional basis without the certainty that a degree of legal convergence would bring. There is considerable interest in dip financing in Asia from distress fund players, but they seek security and certainty, where they are asked to involve themselves in financing that extends to multi jurisdictional restructuring exercises. A common set of principles for the treatment of dip finance would encourage players to take a far more significant role in Asian restructuring exercises than they currently do. Dip financing is a critical player restructuring exercises in the United States. It can have the effect of saving businesses and jobs across the board, working together on arriving at a common set of principles. Asia can tap into this critical resource. I would therefore urge all who have an interest in Asian restructuring to throw your weight behind the Asian principles of business restructuring project. It is an ambitious and important step towards achieving a level of harmony between the restructuring regimes of the various Asian jurisdictions that will stand us all in good stead as a natural haven for investments. On a global scale, working group five has done so much to put in place a framework for the resolution of cross border insolvencies. The gym initiative has also put in place processes to allow for cross border judicial cooperation with the view to achieving the best possible outcomes in cross border restructuring exercises. These steps have made global restructuring cooperation a reality. It is time now for all Asian insolvency stakeholders to step up and work together to help harmonize our restructuring regimes. The project that Rajesh Justice Ravish has spoken of gives us the path forward and we should all seize that opportunity and walk down that path together. Thank you very much. Thank you very much social and thank you for all our speakers. I have one question but I would have just a few minutes at least for questions.