Retail Safety & Security Best Practices
Retail Safety & Security Best Practices
SECURIT Y GUIDE
TABLE OF CONTENTS
About the Retail Safety & Security Guide...................................................3
Overview........................................................................................................4
Making Your Business Less Vulnerable to Crime...................................................................... 4
Management Guide......................................................................................5
Strategic Data Collection and Analysis.................................................................... 5
Policy Development.................................................................................................. 5
Regular Risk Assessment......................................................................................... 5
Types of Incidents.........................................................................................6
Robbery...................................................................................................................................... 6
Break and Enter.......................................................................................................................... 8
Fraud..........................................................................................................................................10
Shoplifting..................................................................................................................................12
Intoxicated Person.....................................................................................................................15
Suspicious Individual.................................................................................................................17
Evacuation.................................................................................................................................19
Lockdown................................................................................................................................. 20
Active Shooter.......................................................................................................................... 21
Employee Guide..........................................................................................23
Supportive Services...................................................................................37
Resources...................................................................................................39
Appendices.................................................................................................40
Checklists and risk assessment tools are provided in the Appendices section of the Guide to help
businesses put in place the approaches discussed.
The following is a list of the most frequently mentioned tips for retailers and staff to help improve
safety, reduce retail criminal incidents and make any commercial or retail business less vulnerable to
incidents of crime and disorder:
• Use LED lighting inside and outside the business by all entrances/exits as well as continuous
lighting from inside the business to the end of the business’ exterior property line.
• Have a visible street address.
• Ensure there are no obstructed sightlines from the street or within the store.
• Position CCTV cameras to view all cash registers and entrances/exits at a minimum with data being
stored for 30 days before being deleted. Recommendation is 90 days of recording.
• Display signs indicating the business is monitored on the outside of the building.
• Install a security alarm system.
• Use a time-delayed safe.
• Remove all cash from the registers after close and lock it in a safe or make a [Link],
cash registers that are visible from the street should be left empty and open at close to show
potential perpetrators that there is nothing in them.
• Lock all doors and windows after closing or when they are not in use.
• Ensure there are no items surrounding the building that may be used to gain access.
• Treat external windows with a commercial grade film that prevents breakage.
• Place gift cards by cashiers or behind a counter within the store that is accessible only to store
employees.
• Situate point of sale (POS) machines as well as Automatic Teller Machines (ATMs) close to cashiers
or other workstations (no more than 20 feet away), in a sightline of a CCTV camera, and in a highly
visible part of the store that is well lit.
• Install security stands or place security cables on each POS machine.
• Ensure that there are no obstructions placed in front of gift card stands, POS machines, or ATMs for
employees or CCTV cameras.
Policy Development
Policies help provide a framework that improves clarity for staff on how to address retail safety issues
as well as standardize approaches and behaviour. Regarding retail safety issues, it is important to:
ROBBERY
When it comes to robberies, some studies have found that a lack of training and inexperienced
staff members may contribute to higher victimization rates. As a result, proper training that
includes theoretical and scenario-based training for staff is a valuable investment to reduce the
potential injury of staff. Topics covered in the chosen training should include how to respond
during a robbery as well as what the roles and responsibilities are of staff, management, and loss
prevention officers or private security.
Depending on the size of the business, an individual should be made responsible to regularly
check the building to ensure all of the lights, security system, and CCTV cameras are operational.
1. Lock the door to the business and do not allow anyone in until the police arrive
2. Call 911
4. If there are witnesses, ask them to stay to make a statement for the police or provide you with
their contact information to provide to police
5. Ensure that no one touches or tampers with any potential evidence (i.e., anything the
perpetrator touched)
Following the incident, a debriefing session should be scheduled with the staff involved.
Corporate policies should be established that specify when these sessions should be
held with the staff member(s).
The duration of the debriefing session will vary depending on a variety of factors: the severity
of the incident; the impacts felt by the staff member(s) involved; and the time required by
management to review existing policies and assess if there are ways to improve the response and
prevent further incidents.
To aid in this process, a retail crime problem solving assessment and Crime Prevention Through
Environmental Design checklist should be complete (Appendix A and Appendix E). It is important
to note that a debriefing session should be made available to all staff that were impacted by the
incident, which could include witnesses and direct victims.
The purpose of the debriefing session is to improve prevention and future responses as well as
answer questions and support the staff member(s) involved. A debriefing session is not meant
to find fault or establish blame. During the session, policies should be reviewed and input about
challenges and possible opportunities for improvement should be welcomed and recorded.
Following the debriefing session, all staff members should be made aware of the steps taken
to address the incident and any applicable policy changes or new/updated measures being
implemented (i.e., a CCTV camera or training for staff).
• Treat windows with a commercial grade film that makes them very difficult to breach. The use of
bars should be carefully evaluated and used when the situation calls for it, such as in high crime
areas. Bars on windows and doors visually reinforce to lawful customers the store has a crime
problem, possibly reducing comfort levels of customers to shop there.
• Post on doors/windows: an alarm company monitors the premises and no money is kept onsite.
Include the local police non-emergency number to call, if a witness sees something not urgent
yet out of place/suspicious.
• Keep some lighting on inside the building to help with video surveillance quality and enable
witnessing of activity, and consider placing lights on timers, if possible, to simulate activity.
• Remove anything on the exterior which could be used to gain entry to your premises (bricks,
ladders, poles, construction materials).
• Ensure backs of businesses are clear and free of debris and do not allow for stacked items
(such as refuse containers, boxes, etc.) to remain that can be climbed upon to gain access to
the roof or can be easily set on fire.
• Ensure all doors and windows are properly locked and secure during regular business hours
and afterwards.
• Once the business has closed, remove all cash from tills, leave the cash tray open and visibly
empty. Also remove all valuables from visible storefront displays.
Assign one individual to handle the following process from start to finish:
4. Complete a retail crime problem solving assessment as well as a Crime Prevention Through
Environmental Design checklist to identify what happened, an approach to address the issue,
and ways to prevent the incident in the future.
Assuming that no staff member is present during a break and enter, a debriefing session should
be scheduled with management and loss prevention officers. The purpose of the debriefing
session will be to determine if all policies and procedures were followed and then begin the
process to establish ways to prevent the occurrence from happening in the future.
To aid in this process, a retail crime problem solving assessment and Crime Prevention Through
Environmental Design checklists should be completed (Appendix A and Appendix E).
The outcomes of the debriefing session should be shared with staff members to outline what
happened, what was taken and/or damaged, how the individuals entered the building, and any
applicable policy/procedural changes to prevent similar incidents in future.
The purpose of the debriefing session is to improve prevention and future responses as well as
answer questions and support the staff member(s) involved. A debriefing session is not meant
to find fault or establish blame. During the session, policies should be reviewed and input about
challenges and possible opportunities for improvement should be welcomed and recorded.
Following the debriefing session, all staff members should be made aware of the steps taken
to address the incident and any applicable policy changes or new/updated measures being
implemented (i.e., a CCTV camera or training for staff).
It’s important to ensure staff are trained to spot counterfeit bills/cheques, gift card fraud, and
credit card/debit fraud. Knowledge and scenario-based training is preferable with photos of real
examples being easily referenced by staff during their shifts at each cash register.
• Place gift cards by cashiers or behind a counter within the store that is accessible only to
store employees.
• Situate point of sale (POS) machines as well as Automatic Teller Machines (ATMs) close to
cashiers or other workstations (no more than 20 feet away), in a sightline of a CCTV camera,
and in a highly visible part of the store that is well lit.
• Only operate chip enabled POS machines.
• Install security stands or place security cables on each POS machine.
• Ensure that there are no obstructions placed in front of gift card stands, POS machines, or
ATMs for employees or CCTV cameras.
• Complete a report identifying all relevant information of the transaction using Appendix D and
Appendix E. All potential evidence should be covered (i.e., POS machine) or placed in a secure
area of the business (i.e., gift card) for police.
• For repeat offenders or incidents, consider submitting the information collected to Crime
Stoppers to identify the suspect.
• Support services should be offered to staff members that have been negatively impacted by the
situation.
• Staff members should be debriefed on the situation regarding lessons learned and any changes
in policies/procedures.
Shoplifting is a crime of opportunity and effective practices to reduce shoplifting are most likely to
be realized when efforts are focused on the following techniques:
• Place items that are more expensive further into the store, away from any exit/entrance. This will
deter shoplifters and make them more conspicuous.
• Keep products that are high value/high risk in a locked inventory room with display boxes kept
empty on the sales floor.
• Ensure shelving throughout the store does not create any blind spots for employees or CCTV
cameras.
• Keep storefront windows as open and uncovered as possible. This is to permit informal
surveillance of the sidewalk and street from inside the business and to allow internal viewing of
business interiors from the sidewalk and street. Two-way observability and transparency can
create visual interest, activity, and safety. In this regard, avoid placing large posters or having
excessive frosting/tinting of storefront windows that block sightlines. If posters are required,
they should not cover more than 20 per cent of available window surfaces.
• Post on doors/windows: an alarm company monitors the premises and no money is kept onsite.
Include the local police non-emergency number to call, if not urgent and thus requiring a 911
call, should any witness notice a break-in or damage has occurred.
• Have and maintain a CCTV system for your business and its immediate physical surroundings.
Images captured are an effective tool used by police that greatly increase both suspect
apprehension and the probability of a crime getting solved. It is important the area to be
captured has sufficient lighting, otherwise images produced may be unreliable and not show
enough detail to identify suspects, evidence, etc. It is equally important to use higher
resolution cameras and have a minimum image retention/storage period of at least 30 days,
with 90 days being the recommendation. Inside the store, camera placement should not be
limited to overhead installations. This is because many criminals pull hoods or other clothing
items over their heads to try and avoid facial capture of their image. If additional cameras are
discreetly installed at counter height and pointed up slightly, the suspect’s face is more likely to
be recorded, increasing the probability of arrest by police.
• Report the incident to the police non-emergency line to ensure that they are able to record the
incident and add it to their criminal statistics to improve analysis or aid ongoing investigations.
• Report the incident to Crime Stoppers after all of the available information is gathered to
transition the case from a private security investigation to a criminal investigation. For repeat
offenders, this may be a preferred option as it provides a way to get the police involved and
helps staff members feel as though they are being proactive in addressing the issue.
The frequency of shoplifting, potential danger in apprehending/detaining perpetrators, and
investment to build a prosecution case may influence a business in choosing to call the police.
Considering these factors, the following criteria are examples to help differentiate shoplifting
instances that can be addressed by loss prevention officers (by issuing a Notice to Appear to
perpetrators) without the assistance of police:
This approach provides an expedited solution for loss prevention officers, removing the need to
detain perpetrators on the premises. Furthermore, this type of approach enables police officers to
focus on repeat or organized retail criminals.
Training employees will help to ensure the safety of staff, customers, and the intoxicated person.
Specifically, active listening and de-escalation training will provide staff with a set of tools to
address the situation in a non-confrontational manner. The ultimate goal of de-escalation is to
avoid physical confrontation and achieve a peaceful resolution for the individuals involved.
The purpose of the debriefing session is to improve prevention and responses in the future.
These sessions are a way to answer questions and support the staff member(s) involved.
The purpose of any debriefing session is not to find fault or establish blame. During the
session, policies should be reviewed and input about challenges and possible opportunities
for improvement should be recorded. Following the debriefing session with the staff members
involved in the incident (i.e., witnesses as well as direct victims), all staff members should be made
aware of the steps taken to address the incident and any applicable policy changes or measures
being implemented (i.e., a CCTV camera or training for staff).
• Blood shot eyes, excessive sweating, or pacing in a particular area of the store.
• Asking questions that go beyond merchandise and curiosity such as asking about shift
changes, personnel, security procedures, etc.
• Paying unusual attention to the activities of employees, looking for security cameras, exits.
• Putting a large amount of high value items into their shopping cart or basket, without taking
time to look at price or the item(s).
• Loitering outside the store or close to the cash registers without purchasing any items from
the store.
Training in active listening, de-escalation techniques, and unconscious biases will provide staff
members with the tools to effectively address suspicious individuals. Specifically, de-escalation
training will provide staff with a set of tools to address the situation in a non-confrontational
manner, while unconscious bias training will help to mitigate any potential issues involving
ungrounded accusations of minorities or individuals from vulnerable populations.
A report will help to identify patterns or specific individuals that are perceived to be suspicious by
multiple employees.
The information from these reports may also provide beneficial information for investigations into
more serious matters such as shoplifting or other types of retail crime.
• Accounting for of all individuals at a designated assembly point to determine who, if anyone, is
missing and potentially injured.
• Contact emergency services for anyone who appears to be in distress or injured.
• Encourage those involved in the incident to use the Employee Assistance Program (EAP) or
seek out health care assistance.
Active shooter situations are unpredictable and evolve quickly. Typically, the immediate
deployment of law enforcement is required to stop the shooting and mitigate harm to victims.
Knowing what to do can save lives.
Because active shooter situations are often over within 10 to 15 minutes, before law enforcement
arrives on the scene, individuals must be prepared both mentally and physically to deal with an
active shooter situation.
These policies should also specify tabletop drills and debriefing sessions with staff to help ensure
there is an opportunity to continue to learn and improve. According to those policies, management
should ensure that staff receive the training required.
Set up a Command Centre. This should be a central communication post. Assign a Crisis Lead.
Direct any media inquiries to senior management within the location or corporate office.
After the active shooter has been incapacitated and is no longer a threat, management should
engage in post-event assessments and activities, including:
• Accounting for all individuals at a designated assembly point to determine who, if anyone, is
missing and potentially injured.
• Determining a method for notifying families of individuals affected by the active shooter,
including notification of any casualties.
• Encourage those involved in the incident to use the Employee Assistance Program (EAP) or
seek out health care assistance.
• Identifying and filling any critical personnel or operational gaps left in the organization as a
result of the active shooter.
1. Remain Calm: to the best of your ability, ensure that you do not make any sudden movements and
assure the perpetrator that you will cooperate with them and listen to their instructions.
2. Follow Instructions: do not argue with the perpetrator and only provide them what they are asking
you to provide.
3. Put Your Personal Safety First: do not engage the perpetrator physically or chase after the
perpetrator following the incident.
1. Put Your Personal Safety First: do not engage the perpetrator physically or chase after the
perpetrator. Alternatively, find a safe place (i.e., a room with a lockable door) and stay there until
police arrive.
However, if a security alarm is not installed or it was not triggered during the break and enter then you,
as a staff member, may be the first on scene.
If you are the first to arrive at the business and notice that it has been broken into, do not enter the
store, or leave the store if you believe the perpetrator(s) may still be inside. Call the police to report the
incident noting that you believe the perpetrator is still in the building.
If you do not believe that the perpetrator is still in the store, then call the non-emergency line for the
police to report the incident.
2. Gift card fraud: increasingly, gift card fraud is becoming more prevalent as a target of crime itself
(i.e., placing fake gift cards on store shelves) as well as part of other frauds (i.e., CRA telephone
scam). The reason for this is that gift cards are easily liquidated by criminals into legitimate forms of
cash. To prevent gift card fraud, the following steps are suggested:
• If a customer is buying a large amount of gift cards, kindly and in a non-confrontational or
accusatory way, ask the purpose of purchasing the gift cards. In some cases, fraudsters will
be instructing an individual to purchase the gift cards on their behalf. This is known as Victim
Assisted gift card fraud.
• Cashiers need to inspect all gift cards purchased to ensure the packing has not been tampered
with and that it is a legitimate gift card. Specifically, make sure there are no spelling mistakes,
fuzzy graphics, broken seals, or bar codes/PINs that have been tampered with.
• Cashiers should ensure that the gift card being purchased is reflected in the POS machine
(i.e., an Amazon gift card is identified as an Amazon gift card). If a fraudulent gift card is being
purchased, then the POS system will not recognize the proper gift card. Another check would be
to confirm “successful activation” on the receipt.
• Cashiers should not accept payment for gift cards by a customer that is using a credit card
or debit card that does not have a chip and PIN option or the chip and PIN functions are not
working if they are present on the card.
• All employees should be aware of fraudulent phone calls from individuals claiming to be from
a gift card provider or an IT company that asks them to activate gift cards as a test. These
companies will not make requests like this and employees should be made aware that they are
indications of an attempted fraud.
Incidents of online order and pick-up fraud have increased in recent years. This is a process in which
individuals are able to buy a product online and then pick the item up in-store. To address this issue,
the following steps should be considered:
• If financially viable, consider purchasing an online fraud management system. Alternatively, or to
augment the online fraud management system, manually review online orders involving high-
value or a high-volume of items.
• If manually monitoring online sale orders, be cautious when:
– A high number of orders from the same billing address, payment information, and/or email
address is placed in a short period of time.
– If the location of pick-up is changed from previous orders with the same billing address,
payment information, and/or email address.
– If the billing address and email have different payment information.
• Record and track phone numbers, email addresses, billing information, and payment information,
and IP addresses that are associated with problematic transactions in the past.
• If the online payment system allows, flag customers that use multiple credit cards before having
a payment approved and show limited browsing time on the site (i.e., did they just get on and
order a high volume of high-risk products or did they search the site, look at reviews, and
compare prices of items).
• Have an application available for customers to use to notify when their package is available for
pickup and when a customer has arrived to pick-up their purchase.
• Ensure the pickup area is well lit and has CCTV cameras. Train employees to lockup purchases
in a secure room prior to pick-up and ensure the contents match the purchase order before
providing to the customer.
• At the time of pick-up, make sure the information provided matches the billing information. If not,
request that the purchase be made in-store at a POS machine.
4. POS machines: perpetrators may tamper with a business’s POS machine(s) by installing devices
that can read credit/debit card information including Personal Identification Numbers (PINs)
or cameras to record this information. To prevent his type of fraud, the following steps are
suggested:
• Inspect POS machines at the beginning and end of every shift to verify that they have not been
tampered with. Look for things like, missing screws, cracks, and any new holes in addition to
verifying the serial number of the machine.
• Look for cameras or unauthorized recording devices in and around the POS machine.
• Approach the customer in a friendly manner and ask if they want a flyer or if you could help them
find something they need on sale. If they do not have a basket or shopping cart, offer one to them
to use while they shop.
• While, you are talking with the individual make note of the following:
• approximate weight, height, age, hair and eye colour, build (i.e., skinny, muscular, overweight)
• any distinguishing features (i.e., tattoos, scars, piercings, clothing).
• If they decline all of your assistance, inform them where all of the check-out counters are in the
store and that the lines are short right now. This can be a simple reminder to the customer to pay
for their items on their way out.
• If the CCTV camera system is capable, the individual may also be monitored by video as they shop
to verify:
• what they look like and if they operated alone or in a group
• how they entered the store (i.e., if it was by car then you can record the licence plate)
• what items they took and the method they used to leave the store with the items
• how they exited the store with the item(s).
All of this information will be helpful for investigating and hopefully catching the perpetrator as well as
establish how to prevent a similar incident from happening in the future.
• If at any time the perpetrator becomes violent or threatens staff members with violence,
call 911 immediately.
• Approach the individual with open body language (i.e., in a non-confrontational) and speak in a calm
manner with a low tone of voice. Introduce yourself and let the individual know what position you
have at the store.
• Maintain at least six feet between you and the individual at all times.
• Ask for their name and tell them what you see (i.e., they look upset or that they are yelling).
• Tell the individual that you are there to help them and reassure them that you do not want to argue
or debate with them if they are verbally confrontational.
• Use active listening to understand what the individual is going through and how you can help them.
Primarily this is accomplished by reflecting what the individual is saying to you by paraphrasing and
asking them if you understand them correctly.
• When speaking with the individual remember to be simple, clear, and focus on building a rapport.
• Be aware of the physical space around you. For example, ask the intoxicated individual to move
away from others being mindful as to not block an exit for them and using counters or furniture/
displays to keep as a barrier between you and the individual.
• After speaking with them, the individual may decide on their own to leave the store. If not,
ask if there is a family/friend that can come help them, call a community service that offers
help to individuals under the influence, or if you ever feel threatened or at-risk of violence then call
911 immediately.
• Keep your personal safety in mind at all times – this means do not argue/accuse, threaten physically
engage with the individual or prevent them from leaving the store.
• Offer customer service assistance to a suspicious person as you would any normal customer. Doing
this right up front can prevent an incident from occurring and a situation from escalating.
• Maintain six feet between you and the individual using physical barriers such as counters and
display cases to ensure a safe distance.
• If you are able to, take note of the following pieces of information:
• the number of individuals
• length of time in the business
• approximate weight, height, age, hair and eye colour, build (i.e., skinny, muscular, overweight)
• any distinguishing features (i.e., tattoos, scars, piercings, clothing)
• where the individual(s) were in the business.
• If you feel there is a threat of violence then contact your manager, loss prevention officers,
private security or colleagues if there are no other options. Upon contacting one or more of these
individual(s), begin the conversation by describing the scenario and the individual, how long they
have been in the store, and what is making you concerned about the individual.
2. Make an announcement that the building is being evacuated and direct everyone to the
nearest exit.
3. If fire wardens are not pre-determined, all managers (and coordinators as needed) will be the fire
wardens.
4. Head to the external assembly area; advise all staff and contractors of the closest emergency exit
and ask them to come with you.
5. Check in with your manager or fire warden upon arrival to the assembly area.
6. Only if safe to do so, management/fire wardens/security should conduct a sweep of the facility to
ensure all contractors, employees and visitors have exited the building.
7. Complete a head count of all employees, contractors and notify fire warden/management.
8. Provide the location of rooms/areas that are used in the building to provide “Shelter in Place” to
the emergency services when they arrive on site.
9. HR / Management on site shall communicate any employees who they anticipate could use the
shelter in place location during an evacuation, i.e., modified work restrictions, disability, etc.
10. The facility will not re-open until authorities have deemed it appropriate to do so and given the
all clear.
I. Shelter in place: Generally, an environmental threat (i.e., flood) is present outside and it is not
possible or advisable to evacuate the store. Provide the location of shelter in place rooms/areas
to the police.
a. HR / Management on site shall communicate any employees who they anticipate could
use the shelter in place location during an emergency (i.e., modified work restrictions,
disability, etc.).
II. Hold and secure: Ensure the door(s) leading to the outside of the building are locked and
people may not exit or enter the building. This is a partial lock down for danger due to physical /
environmental threat outside the store.
III. Full lock-down: Seek protective cover. Close and lock doors if possible, barricade behind
lockable areas. Turn off lights and close blinds and shades. Keep quiet and act as if no one
is in the room. Wait for public safety or police to assist you out of the building.
Ignore fire alarms unless instructed to leave the building by police or fire department.
REACT – Determine the location of the shooter (inside or outside store). Based on your assessment,
react to the situation at hand in the safest possible method for you and those around you. There may
be danger from the gunfire of the attacker and responding police officers. You must decide which
action to take:
RUN
• If it is safe to do so and you have an accessible escape path, leave the location you are in,
moving away from the area of risk.
• Go away from the sound of the shooting.
• Exit quickly but cautiously and do not waste time trying to gather your belongings.
• Evacuate regardless of whether others agree to follow.
• Help others escape, if possible.
• Get to an area of safety outside and prevent others from entering the area of risk.
• Keep your hands open and visible.
• Show police your hands and listen for commands.
• Offer any information you can – description, location of shooter, number of gunmen, type(s) of
weapons, etc.
• Follow the police officers’ instructions.
FIGHT
As a last resort, and only when your life is in imminent danger, attempt to disrupt and/or incapacitate
the active shooter by:
Once you have reached a safe location, do not leave until law enforcement authorities have instructed
you to do so.
• Runyan, C., M. Bowling, M. Schulman, S. Gallagher. (2005). Potential for violence against teenage
retail workers in the United States. Journal of Adolescent Health, Vol. 36. no.3. pp. 267.
• Centre for Problem-Oriented Policing. (2007). Robbery of Convenience Stores. Arizona State
University Centre for Problem-Oriented Policing.
[Link]
• SAFE Work Manitoba. (2020). Safety and Health Guide for New Retail Workers.
[Link]
• Work SAFE BC. (2012). Preventing, Violence, Robbery and Theft: A Guide for Retail Owners,
Managers, and Workers.
[Link]
violence-robbery-and-theft?lang=en.
• Centre for Problem-Oriented Policing. (2002). Burglary of Establishments. Arizona State University
Centre for Problem-Oriented Policing.
[Link]
• Centre for Problem-Oriented Policing. (2012). The Problem of Shoplifting. Arizona State University
Centre for Problem-Oriented Policing. [Link]
• Blackhawk Network: Gift Card Best Practices and Fraud Prevention Techniques
[document sent to distribution partners and retailers during the holiday season].
• Canadian Bankers Association. (2020). Protecting Against Credit Card and Debit Fraud.
[Link]
• Visa. (2020). Fraud Prevention Best Practices for BOPIS (Buy Online Pickup in Store).
[Link]
• Mental Health Commission of Canada. (2021). Tips on Talking to Someone in Crisis During
Covid-19. [Link]