oversight

Inspectors General: Joint Investigation of Personnel Actions Regarding a Former Defense Employee

Published by the Government Accountability Office on 1997-07-10.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

GAO
      United States
      General Accounting Office
      Washington, D.C. 20548

      Accounting and Information
      Management Division


      B-276950

      July 10, 1997

      The Honorable Strom Thurmond
      Chairman
      The Honorable Carl Levin
      Ranking Minority Member
      Committee on Armed Services
      United States Senate

      Subject:    Inspectors General: Joint Investigation of Personnel Actions
                  Regarding a Former Defense Emplovee

      This letter responds to the request by Senator Strom Thurmond and former
      Senator Sam Nunn that we review a 1993 joint investigation by the Inspectors
      General (IGs) at the Departments of Defense (DOD) and State, and the Central
      Intelligence Agency (CIA). The investigation reviewed DOD actions to
      terminate the employment of a probationary’ employee and to suspend the high-
      level security clearance necessary for his position as a Foreign Affairs
      Specialist. The employee alleged that these actions were a reprisal for DOD’s
      concern that he would make unauthorized disclosures of national security
      information to the Congress. The joint investigation concluded that these
      actions did not constitute a reprisal covered under the Whistleblower Protection
      Act2 and that DOD’s termination actions were legally and factually sufficient.
      We were asked to determine (1) whether the investigative report’s conclusions
      were adequately supported and (2) the basis for the former State IG’s3
      disagreement with the joint investigative report’s conclusions section.




      ‘In general, federal career service employees serve up to 1 year in a
      probationary status before their appointment in the competitive service
      becomes final.

      *The purpose of the Whistleblower Protection Act, as amended, is to strengthen
      protection for the rights of federal employees, prevent reprisals, and help
      eliminate prohibited personnel practices.
      3The former State IG retired from State in 1994.
                             GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950

SCOPE AND METHODOLOGY

We reviewed the joint IGs’investigative files to determine if there was adequate
documentation to support the investigative report’s conclusions. We also
reviewed the provisions of the Whistleblower Protection Act and the protections
it provided to whistleblowers. We interviewed IG officials from DOD and State,
the DOD employee, and other individuals involved with the results of the joint
investigation. We also interviewed the former State IG to determine the basis
for his disagreement with the investigative report’s conclusions section and
obtained written responses to our questions from the CIA IG. We did not
reinvestigate the matters reviewed by the investigation and do not express an
opinion on the legality of the personnel actions taken. We performed our
review from March 1996 through March 1997 in accordance with generally
accepted government auditing standards.

RESULTS IN BRIEF

We found that the investigative report and files did not fully support the report’s
conclusions that there was no reprisal and that the proposed termination notice
was legally sufficient. In addition, the former State IG told us that he objected
to the lack of emphasis in the investigative report’s conclusions section
regarding the potential effect of suspending the employee’s security clearance.

BACKGROUND

In August 1989, DOD issued a termination notice to the employee citing
performance deficiencies related to the employee’s work. The
investigative files included a memorandum written by the supervisor that
explained the basis for the employee’s proposed termination. In addition to
discussing the performance deficiencies, the memorandum indicated that the
employee’s supervisor perceived that the employee might make an unauthorized
disclosure of national security information to congressional staff. The
memorandum states the following.

       Tinally, I have major concerns about [the employee’s] reliability
       and judgment. . . regarding sensitive national security issues. . . .
       [The employee] told me he intended to meet and talk to two
       House Foreign Affairs Committee staff members concerning an
       Administration briefing given the previous week. He said he had
       learned that CIA and State representatives had created a
       misleading picture. . . . I told him he was not authorized to
       discuss intelligence information with them. He argued strenuously
       that because CIA and State had given him intelligence information,
       he too could discuss the information on the Hill. He said I would

2                     GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950
       have to order him not to talk to Hill staff to prevent him. I
       obliged him, however, I am not confident he will not contact them
       in spite of my clear instructions. Providing intelligence
       information without an authorization would be in direct violation
       OfCIA... restrictions and DOD instructions.”

In August 1989, DOD suspended the employee’s high-level security clearance,
denied the employee continued access to “sensitive compartmented
information,“4 and performed a security investigation. The employee resigned
his position and was reassigned by DOD as a program specialist on a temporary
basis. In March 1990, DOD concluded that it did not have a basis to suspend
the employee’s security clearance and subsequently provided the employee with
a top secret security clearance5 but did not employ him as a Foreign Affairs
Specialist. The employee resigned from DOD in 1992.

In March 1993, a member of the United States Senate asked the DOD IG to
investigate the circumstances surrounding the proposed termination of the
employee’s employment. The investigation was led by the DOD IG who was
assisted by the State and CIA IGs. The investigation reviewed whether the
action taken against the employee constituted reprisal under the Whistleblower
Protection Act, and whether the termination action was legally and factually
sufficient.

The investigation concluded that there was no reprisal and that DOD’s
termination actions were legally and factually sufficient. The investigation’s
conclusions were based, in large part, on the view that the employee did not
disclose or, notwithstanding the supervisor’s written comments in the
investigative files, threaten to disclose any information to the Congress. The
investigation further concluded that even if such a disclosure had been
threatened, it would not have been protected by the Whistleblower Protection
Act if disclosure was made to the House Foreign Affairs Committee without the
“appropriate clearances.“”



4Sensitive compartmented information refers to classified information
concerning or derived from intelligence sources, methods, or analytical
processes requiring handling exclusively within formal access control systems
established by the Director of Central Intelligence.

5A top secret security clearance provides access to national security information
that is at a lower security level than “sensitive compartmented information.”
‘Appropriate clearances were not defined by the joint investigation.

3                    GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950
LACK OF ADEQUATE SUPPORT FOR
INVESTIGATIVE REPORT CONCLUSIONS

Qualitv Standards for Investigations, which are guidelines developed by the
President’s Council on Integrity and Efficiency7 for the IGs’ investigative efforts,
and DOD’s Snecial Inauiries Investigative Policies and Procedures apply to the
joint investigation. These standards require that objective evidence be gathered
and reported without bias in an effort to support all the facts developed to
prove or disprove an issue. Conclusions must be supported by the facts
presented, and the investigator is required to continually evaluate whether
 sufficient facts and evidence have been collected to reach conclusions. In
 addition, the investigative report is to be logically organized and the information
 should be adequately verified to establish its validity. The investigative report is
 to depict the flow of logic, demonstrating the sorting, weighing, and ordering of
 facts for the sole purpose of reaching a conclusion. All notes taken by an
 investigator are to be retained in the case file.

The investigative report concluded that there was no reprisal against the
employee for a protected disclosure under the Whistleblower Protection Act,
and that the personnel actions against the employee were legally sufficient for
termination of a probationary employee. The investigative report also
concluded that DOD was not sufficiently diligent in assessing the credibility of
security allegations before referring those allegations for investigation.

The Whistleblower Protection Act is part of the Civil Service Reform Act of
1978 (CSRA), which was a comprehensive reform of the federal civil service
system. The Whistleblower Protection Act provides that employees who have
the authority to affect personnel actions shall not use this authority for
prohibited personnel actions.8 An example of a prohibited personnel action is
reprisal9 against an employee for certain disclosures of information if such
disclosures are not specifically prohibited by law and the information is not
required by executive order to be kept secret in the interest of national defense
or the conduct of foreign affair~.~~ The act further provides that this

‘The President’s Council on Integrity and Efficiency, established by executive
order, includes Presidentially appointed inspectors general.

 *5 U.S.C. 2302 (b).

 ‘Reprisal, in a broad sense, includes any action designed to punish an employee
 for exercising his/her protected rights or to deter that employee from exercising
 those rights.
 “5 U.S.C. 2302 (b)(8).

 4                     GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950
subsection” shall not be construed to authorize the withholding of information
from the Congress or the taking of any personnel action against an employee
who discloses information to the Congress. The conference report for the act
states that it is not to be inferred that an employee is unprotected if statutorily
protected information is disclosed to the appropriate unit of the Congress.

The legislative history of the Whistleblower Protection Act also makes clear that
the act’s protections are intended to cover not only individuals who make actual
protected disclosures, but also those who threaten to make such disclosures.
F’urther, our review of Merit Systems Protection Board (MSPB)12case law
indicates that a threat of disclosure perceived by the employee’s supervisor
receives the same protection as does an actual disclosure or threat of disclosure
made by the employee. Accordingly, the MSPB has concluded that the act’s
protections apply when a retaliatory personnel action is taken against an
employee believed to have engaged in a protected activity, even though the
employee may not have actually done so.13

We found that the investigative report and files lacked documentation to
support the investigation’s conclusion that there was no reprisal against the
employee for a protected disclosure under the Whistleblower Protection Act.
For example, the report states that there was no disclosure; but neither the
report nor the files address how the threat of disclosure perceived by the


“5 U.S.C. 2302 (b).

‘*CSRA established an independent agency, the MSPB, to protect the merit
system principles and adjudicate conflicts between federal workers and their
employing agencies, including reprisals against statutorily defined
whistleblowers. CSRA also established an independent Special Counsel to
investigate and prosecute, among other things, prohibited personnel practices
within the federal civil service. The Whistleblower Protection Act Amendments
of 1989 significantly amended CSRA to require more aggressive prosecution of
certain prohibited personnel practices by the Special Counsel. The amendments
also provide an individual right of action to employees victimized by reprisal as
a result of whistleblowing. The type of action brought by the employee will
determine the jurisdiction of the MSPB or the Office of Special Counsel, and the
respective statute of limitations.


‘3Soecial Counsel v. Dept. of Nav-v 46 M.S.P.R. 274 (1990). See also Zimmerman
v. DHUD, 61 M.S.P.R. 75 (1994); &e&al Counsel v. Harvey, 28 M.S.P.R. 595,
rev’d on other grounds, Harvev v. Merit Svstems Protection Board, 802 F.2d 537
(D.C.Cir.1986).

5                     GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950
supervisor affected the employee’s protections under the act. Also, while the
report stated that the act did not protect a disclosure to the House Foreign
Affairs Committee without appropriate clearances, neither the report, the files,
nor other documentation provided by officials we interviewed describe what is
meant by “appropriate clearances” or discuss how such clearances as a matter
of law relate to the act’s protection of disclosures to the Congress.

Further, because the investigative report and files did not present adequate
support to conclude that the perceived disclosure was not protected under the
Whistleblower Protection Act, the investigation did not fully support its
conclusion that DOD’s personnel actions were legally sufficient or that DOD’s
actions did not constitute a reprisal under the act.

BASIS FOR THE FORMER STATE IG’S DISAGREEMENT WITH THE
INVESTIGATIVE REPORT’S CONCLUSIONS SECTION

The former State IG disagreed with the investigative report’s conclusions
section. In his opinion, it should have included and emphasized information on
the repercussions of suspending the employee’s security clearance. The report
did include a statement that the suspension of an employee’s security clearance
can have devastating and long-lasting implications to the employee even after a
clearance has been restored, but the former State IG believed this statement
should have also been included in the conclusions section. The former DOD
IGi4 acknowledged that a few minor changes could have been made to the
report’s conclusions section, but believed that the conclusions section was
consistent with the body of the report.

AGENCY COMMENTS AND OUR EVALUATION

In response to a draft of our report, we received written comments from the
current DOD IG, the current State IG, and the former State IG. The CIA IG
declined to comment. The text of alI the responses, except for an enclosure to
the former State IG’s response that he wrote in September 1993, are reprinted in
this letter in their entirety in enclosures I, II, and III.

In responding to our draft, the current DOD IG said that there was no actual
disclosure of information to the Congress, that the employee denied that he
intended to make such disclosure, that there was no reprisal for any threatened
disclosure because the chronology of events indicated that actions to terminate
the employee began prior to any such threat, and that as a result, given the
standards for terminating a probationary employee, the proposed termination


 14Theformer acting DOD IG retired from DOD in 1995.

 6                   GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950

notice was legally sufficient. The current State IG agreed with the comments of
the current DOD IG.

In her comments, the current DOD IG did not address how the threat of
disclosure perceived by the DOD supervisor affected the employee’s protections
under the Whistleblower Protection Act, did not describe what was meant by
“appropriate clearances” in the investigative report, and did not explain how
such clearances as a matter of law relate to the act’s protection of disclosures
to the Congress. Further, the DOD supervisor perceived a threatened disclosure
prior to the date of the proposed termination notice, and the current DOD IG
did not address how actions of the supervisor prior to the perceived threatened
disclosure constituted a personnel action under the Whistleblower Protection
Act. Accordingly, we continue to believe that the investigative report and files
do not fully support the report’s conclusions that there was no reprisal and that
the proposed termination notice was legally sufficient.

The former State IG confirmed our conclusion that he objected to the
investigative report’s lack of emphasis on the career and personal impact
regarding the suspension of the employee’s security clearance. The former IG
also stated that the joint investigation failed to adequately address the meaning
of “appropriate clearances” in the case of perceived threats of disclosure of
classified information to the Congress, and the degree to which such disclosures
are protected against reprisal. The former IG provided us with a copy of a
memorandum he wrote in September 1993 in which he expressed his initial
disagreement with the investigative report’s conclusion that the termination was
legally sufficient.




                    GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
B-276950
As agreed with your office, unless you publicly announce its contents earlier,
we plan no further distribution of this report until 7 days from the date of this
letter. At that time, we will send copies to the Departments of Defense and
State Inspectors General; the Central Intelligence Agency Inspector Generti, and
the Director of the Office of Management and Budget.

If you would like to discuss these issues, please contact me at (202) 512-3029,
or Jackson Hufnagle, Assistant Director, at (202) 512-9470.


                        l0
                                    w\
   77
Theodore C. Barreaux
Associate Director, Audit Oversight and Liaison




 (911751)


 8                   GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
     ENCLOSURE I                                                                                           ENCLOSURE I

         COMMENTS FROM THE DEPARTMENT OF DEFENSE INSPECTOR GENERAL


                                              INSPECTOR            GENERAL
                                                 DEPARTMENT       OF DEFENSE
                                                   400 ARMY     NAVY DRIVE
                                            ARLINGTON,     VIRGINIA   22202-2884




                                                                                   JUN-6 I997
             Mr. Gene L. Dodaro
             Assistant Comptroller General
             Accounting and formation ManagementDivision
             U.S. GeneralAccounting Office
             Washington,D.C. 20548

            Dear Mr. Dodaro:

                     This is the Departmentof Defense(DOD) responseto the General Accounting Office
            (GAO) draft report, “Joint Investigation ofPersonnel Actions Regarding a Former Defense
            Employee,”dated May 1997 (GAO Code B-276950/OSD Case 1355). The GAO reviewed DOD
            actions to terminate the employmentof a probationary employee and suspendhis security
            clearancesin order to determineif there was adequatedocumentationto support the joint
            investigative report’s conclusions. The GAO review was also for the purpose of determining the
            basis for the State DepartmentInspectorGeneral’s disagreementwith the conclusions section in
            the joint investigative report
I                   The GAO draft report concludedthat the joint investigative report and files lacked
            documentationto support the conclusion that there was no reprisal. We would like to address
            this finding.
I
                    The joint investigation establishedthat there was no actual disclosure of information by
            the employee(unlike the prior 1991DOD investigation, the joint investigation concludedthat the
            discussionsbetmen the employeeand his supervisor did not constitute a discIosure of
            information). We agreethat the “threat” of a disclosure can form the basis for a reprisal
            complaint. However, the investigative file contains documentationthat the employee, in his own
            statements,steadfastlydenied that he ever intendedto make a disclosure to Congress. Finally,
I           the investigative report concludedthat the matter was not within the ambit of the Whistleblower
!           Protection Act at the end of page6, wherein the report states:
I
!                  Fiy,   the chronoIogy of events indicated that [the supervisor’s] actions to terminate the
                   employment of [the employee]had begun prior to their discussion of the testimony to
                   congress.

            Clearly, there can be no reprisal for a %reatened” disclosure where the termination action is
            effected or initiated prior to the communication of such ‘threatened”disclosure. We
            acknowledgetbat our report could have beenmore thorough in its analysis and documentationof
            the reprisal issue.

i-




    9                                    GAO/AIMD/OSI-97431RJoint Inspector General Investigation
    ENCLOSURE I                                                                                          ENCLOSLJREI


r                                                                                                                  1



                  Instead,we devoteda significant portion of the report to a discussion of the employment
           termination and revocationof the security clearance. In our view, the employee’s performance
           deficiencies, as documentedby his supervisors,provided an adequateindependentbasis for
           terminating the probationaryemployee’semployment. The joint investigative report statedon
           page 11:

                  We concludedthat there was no reprisal, and the termination was legally
                  sticient given the minimal regulatory standa& required to terminate a
                  probationary employee.

           We believe this conclusionis fully supportedin the report and the investigative file and do not
           find any basis in the GAO draft report to call the conclusion into question.

                  Thank you for the opportunity to review and comment on the draft report.

                                                             Sincerely,




                                                           Inspector General




     10                                  GAO/AIMD/OSE97-81RJoint Inspector General Investigation
ENCLOSURE II                                                                                                           ENCLOSURE II

     COMMENTS FROM THE DEPARTMENT OF STATE INSPECTOR GENERAL




         Mr. chlcL.uodaro
         Assistmt compuouer Gened
         U.S. General Accounting Office
         ~uouating and Warmotion
            ManagementDivision
         Wa&ington, D.C. 20548



                 Thank you ibr the oppomnity to comment on the GAO drzdtreporttitled, “Joiot
         Investigation of PersonnelActitms Uqarding aFormer Dcfcnsc~ployes”.

                   with rupu%Lot)eismoof adquacy
                                              of supportfor the invwigative                        report’s
         COllChSiO~,    WC    UldCJISC   and    SUppO~   ChU UJJJJlJWl&   Of the e   Of &lS~cnOr   hlrmi      Of ChC
         Depnrtmeptof        Defeosa


                With reqect to the ~~ncemsaxpmsed by the (then) StateDepartmutt Tnqctor -zJ.
         WChave no information to offar in addition LOthat disar~sadin the GAO draft We undaatand
         that GAO has cmum&md &ectSy with rhe @a~) fpepcczorGmuai on this issue.




11                                             GAO/AIMD/OSI-97-81RJoint Inspector General Investigation
ENCLOSURE III                                                                                      ENCLOSURE III

                 COMMENTS FROM THE DEPARTMENT OF STATE’S
                        FORMER INSPECTOR GENERAL


                                     SHERMAN           M.~?UYNK
                                       5000BATTERY     IA.NZ #SO4
                                   BETHESDA.     MD   20814.2645   -USA




          June 5, 1997

          Mr. David L. Clark
          Director, Audit Oversight and Liaison
          U.S. General Accounting Office
          Washington, DC 20548

          Dear Mr. Clark:

          With the exceptions noted below, I concur with and commend the findings            and
          conclusions of the draft report, “Joint investigation of Personnel Actions
          Regarding a Former Defense Employee.” [GAO/AIMD-97-81            R]

          I particularly commend the material relating to the Whistleblower          Protection
          Act. This clearly indicates that the 1993 joint investigation failed to adequately
          address either the meaning of “appropriate          clearances” in the case of
     ..   perceived threats to disclose sensitive classified information to the Congress,
          or the degree to which such perceived threats are protected against reprisal
          when they involve potential disclosure to the Congress. It is my strong hope
          that this report will trigger legislative clarification.

          Because unauthorized disclosure of sensitive classified information, even to the
          Congress, is a matter that must never be taken lightly, I suggest that any such
          legislation should specify:

                 (1)   A limited number of individuals in the Congress to whom
                       unauthorized disclosures may be made, e.g., the chairs and ranking
                       minority members, and/or the staff directors and senior minority
                       staff members of the Senate and House intelligence committees
                       and of the Senate and House armed services committees. These
                       four committees regularly handle classified information and have
                       procedures in place to assure its protection. (If material under the
                       normal jurisdiction of another committee is involved, I suggest it
                       should go to one of the intelligence committees, which should then
                       determine whether it is appropriate to be passed on to the chair of
                       that committee and, if so, under what safeguards.)

                  (2) The limited conditions under which unauthorized disclosures can be
                      mode to the above individuals, e.g., when a government employee




12                                 GAO/AIMD/OSI-97-81R               Joint Inspector General Investigation
ENCLOSURE III                                                                                     ENCLOSURE III




                                                                                                  2


                     has reason to believe that:

                        (a) the very act of requesting permission to disclose the classified
                             information to the Congress will generate reprisal action
                            against the employee, and/or

                        (b) the supervisors who must approve the disclosure to the
                            Congress are involved in, or are attempting to cover up,
                            illegal activity by themselves or other officials, or activities
                            which are contrary to established administration      or expressed
                            congressional policy.

          Regarding my disagreement as (then) State IG with the conclusions in the joint
          investigation report, I believe it is misleading to say that the “State IG did not
          obiect to the facts presented in the report....”   In my memorandum      dated
          September 17, 1993 (well before publication of the report) to the Deputy IG of
          Defense, I specifically questioned the report’s conclusion that the termination
          of the Defense employee was both justified and legally sufficient. After a
          detailed discussion of the three reasons advanced by the employee’s
          supervisor for dismissal, I concluded that “... of the three deficiencies cited in
          the termination notice, the report itself concedes by clear implication that two
          were not intrinsically supportable and the third was, at very least,
          questionable.”    I went on to say “I therefore am baffled by the report’s
          conclusion...that   the termination was ‘legally sufficient.‘”

          My wording at the end of this section of the memorandum          was unequivocal:
          “...the truth of [the Defense employee’s] termination,      as borne out by the
          report is - simply put and without circumlocution     - that it was unfair and
          unwarranted.”     (A copy of this memorondum     is enclosed.)

          In view of these documented reservations, it is manifestly unfair to say that the
          “State IG did not object to the facts presented in the report.” Such a
          statement, without any qualifiers, clearly implies that I agreed with that part of
          the language in the report’s Summary and Conclusions which says: ‘The
          employment termination of [the Defense employee] for performance
          deficiencias was supported by the evidence. . ..lf That is a “factual” statement
          and is false; the evidence in the report leads to no such conclusion.

          To be sure, the major thrust of my disagreement        with the report focused on its
          failure to cite the severe career and personal impact when an intelligence
          analyst (which the employee was, despite the formal job titie of Foreign Affairs
          Specialist) unjustifiably lost his security clearances, in particular his access to
          compartmented      data. This emphasis reflected the prevailing opinion then of
          personnel experts that a probationary employee lacked the protections
          accorded to a career employee and therefore virtually any dismissal, except




                                  GAO/AIMD/OSI-97-81R Joint Inspector General Investigation
ENCLOSURE III                                                                                   ENCLOSURE IIt




                                                                                                3


          for those explicitly based on illegal discrimination,   was “legally sufficient.”
          Had I been aware at the time of Special Counsel v. Dept of Navy (cf footnote
           73 in the GAO Report), I would have reacted even more strongly to the
          alleged “legal sufficiency“ of the termination,    inasmuch as that decision opens
          the door, even to a probationary employee, of possible corrective action by the
          Merit Systems Protection loard.

           Nevertheless, my opinions about the questionable nature of the Defense
           employee’s termination are a matter of record, clearly set forth in my
           September 17,1993 memorandum.           Because one of the two stated purposes
           of the GAO review was to determine “the basis for the State IG’s
           disagreement with the joint investigotive report’s conclusions section,” I
           recommend that the language of your final report be adjusted accordingly and
           thot this letter be included in the appendix to the report.

           Thank you for the opportunity to comment on the report. Again,       I want to
           commend the GAO and the authors of the report. In addition to       identifying a
           procedural barrier to the receipt by the Congress of what might     be important
           and needed sensitive classified information, you have flagged a     grave inequity
           which has been allowed to stand for too long.

                                                        Sincerely,



                                                        Sherman      M. Funk

           cc:
           Honorable Jackie Bridger-Williams
           Inspector General, Dept of State

           Honorable Fred Hitz
           Inspector General, CIA

           Honomble Eleanor Hill
           Inspector General, Dept of Defense

           Jackson Huf’nagle
           Arst Director, Audit Oversight   & Liaison
           GAO

           Encl.




 14                                 GAO/AIMD/OSI-97-81R               Joint Inspector General Investigation
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