CAI0049
Written evidence submitted by Galaxy Digital UK
Dear Members of the Treasury Committee,
We thank you for the opportunity to respond to this Call for Evidence (CFE). Galaxy Digital supports the UK Parliament in conducting this enquiry into cryptoassets, at what is such a pivotal time for the industry and the UK’s place in global markets.
Galaxy Digital UK is the UK arm of Galaxy Digital, the leading digital asset and blockchain enterprise helping institutions, startups, and qualified individuals shape a changing economy. Galaxy Digital is a technology-driven financial services and investment management firm that provides institutions and direct clients with a full suite of financial solutions spanning the digital assets ecosystem. Galaxy Digital operates in the following businesses: Trading, Asset Management, Investment Banking, Mining and Principal Investments. Galaxy Digital's CEO and Founder is Mike Novogratz. The Company is headquartered in New York City, with offices in Chicago, Jersey City, London, Amsterdam, Tokyo, Hong Kong, and the Cayman Islands (registered office). The UK has so far taken a measured approach to collective regulatory solutions in the cryptoasset marketplace, which we believe has been largely vindicated given turbulence in the cryptoasset market over the past year. Galaxy believes that the UK's approach of placing a premium on investor protection was a wise choice and, despite some recent market failures, policymakers should consider these events within the broader context of volatility in the global financial markets, far beyond the remit of the cryptoasset market.
As the cryptoasset economy continues to develop and mature, so must the UK’s regulatory approach. Policymakers need to focus on the objectives they wish to achieve - consumer protection, market integrity, and competition in the gross sense (i.e., extending beyond just financial services), duly accounting for the realities of today’s modern global market environment, and investing behaviours. Particularly in the context of consumer protection, regulators’ responsibility cannot end at the legal perimeter, it must extend to the entire UK market. Regulators must assess harm across the whole market, and then look to bring products and services within their legal purview if protection concerns are identified. This CFE is an excellent example of how Government should be using industry as a barometer to ensure policies, interventions, and guardrails remain appropriate and do not become paternalistic, or at worst deterministic.
We are encouraged by the FCA’s introduction of the Consumer Duty and its re-emphasis on ‘outcomes-focussed’ policy and supervision as a way of continuing a principles-based approach to regulation. We believe this can form the perfect foundation for an adaptive, innovative regulatory framework for cryptoassets. We hope that this foundation can be administered in good faith, and in a way that accounts for the realities and potential benefits that new technologies can bring, rather than becoming mired in legalities and technical minutia.
Thank you again for this opportunity and we would be delighted to discuss any aspects of this feedback further.
Yours sincerely
[Galaxy Digital UK]
In their current form, we do not anticipate that digital currencies, including stablecoins, will replace traditional currencies as this would require mass adoption on a scale that is currently unlikely. However, we do believe that the two will increasingly be used in parallel.
We have already seen this journey begin as some vendors started accepting Bitcoin at the point of sale. This is then converted, and the sale is ‘booked’ in fiat. This could change in time, assuming general tax and business accounting standards can evolve as appropriate.
Cryptoassets, in particular stablecoins, have the potential to bring transformative benefits to the payments ecosystem. The most widely cited benefit of stablecoins is their ability to facilitate faster and more secure peer-to-peer and cross border payments, allowing for near-instant settlement and considerably lower fees than traditional options. Stablecoins may also support longer term financial inclusion, by lowering payment barriers and exerting pressure on incumbents to provide faster, cheaper, and more accessible services. This is especially important for cross-border transfers, which are slow and carry high fees, but which are also disproportionately relied upon by low and middle-income families for financial support.[1] However, cryptoassets can be more transformative than just improving outcomes for incumbent consumers, as important as that is. Stablecoins can remove barriers to entry for the unbanked population who currently rely on cash and provide safer and more diverse alternatives.
Public confidence in cryptoassets will continue to be a key marker of mass adoption. However, regulatory clarity, an established path to market for cryptoasset firms, as well as appropriate guardrails against bad actors will bolster public confidence and reduce risks. Bad actors are not unique to the cryptoasset market; such actors will prey on regulatory uncertainty, which then regrettably risks the market being associated with criminality, prompting a restrictive, anti-innovation regulatory reaction. Proactive, forward-thinking regulation now can break this cycle by supporting legitimate, regulated actors to enter the marketplace.
We applaud the declarations of MPs John Glen earlier in the year and Richard Fuller more recently that the UK is “open for crypto businesses'', as well as the forward leaning Financial Services and Markets Bill,[2] and believe that the government must continue to take decisive leadership regarding cryptoasset policy to ensure digital currencies do form an appropriate part of the UK payments landscape.
The opportunities and risks associated with a central bank digital currency (CBDC) will depend on the technical design choices made by the Bank of England (BoE).
However, speaking in broad terms there could be a number potential advantages: including faster, cheaper, and more efficient cross-border payments systems; greater financial access and inclusivity as transacting with CBDC does not require a traditional bank account; reduced consumer and SMB/merchant transaction costs; easier regulation and transmission of monetary policy directly to citizens; avoiding the risks of new forms of private money creation, including private cryptocurrencies or stablecoins; and fostering increased programmability, including both business and compliance logic, and automation of economic activity.
There could also be a number of risks associated with CBDCs, including the difficulty in balancing privacy interests with law enforcement objectives, for example a fully autonomous CBDC could compromise know-your-customer and anti-money laundering rules; managing the CBDC payment system under certain circumstances including when systems are offline and incapable of communicating with the ledger; and managing the risks from cyber-attacks, which could quickly trigger panics, as well as undermine public faith in the payments system.
As noted by the World Economic Forum, “blockchain technology and the cryptocurrencies that use it are creating open, democratic financial systems”.[3] The World Bank estimates that almost 1.7 billion adults globally are unbanked, meaning they are excluded from mainstream financial services or do not have a bank account.[4] Unbanked individuals, meaning those without a current or savings account, are reliant on cash, and likely have no insurance, pension or other aspects of a financial safety net. Key barriers to accessing mainstream financial services include physical distance (the World Bank consistently identifies rural populations as disproportionately impacted), cost, and lack of connectivity. While cryptoassets rely on the individual being able to access an internet connection, as the world becomes increasingly digital and mobile phones grow more prevalent, this will become less of a challenge.
Distributed Ledger Technology (DLT) can have a transformative impact on reducing these entry barriers. DLT payment networks can allow customers to send and receive money instantly and at a fraction of the cost of traditional banks. Much of this is achieved by removing the dependence on third party intermediaries and fostering direct relationships between counterparties. Some applications, which are built on blockchain networks, allow users to transfer money with a telephone number or an email address, removing the need for a bank account and thereby making physical proximity to a bank irrelevant. Similarly, DLT brings with it the potential for lending activities to be done peer to peer, removing the need for expensive intermediaries.
However, we also encourage the Government to take a step back and consider the future of social inclusion and its intersection with technology. Currently, we define inclusion within the existing (traditional) financial system and larger societal norms that are influenced by not only our collective history but also legacy systems and designs—and inclusion is partially measured by reducing cost and access barriers. Within historical constructs, many incorrectly are resigned to accept that there will always be a cadre of society that is simply unable to access mainstream financial services. Technology such as cryptoassets and DLT have the potential to upend this understanding and revise the definition of social inclusion, making it possible for everyone to be included.
This potential is predicated on a system that no longer centrally relies on intermediaries and gatekeepers, and instead allows any individual with a computer or mobile device to plug into a decentralised financial services network. Whether through peer-to-peer economic transactions or through mission-oriented services, the range and reach of those offering financial services and support can broaden. This will help democratise access to products and services but will also increase equality of access in our capital markets any beyond What is seen as progress today might therefore be viewed as unacceptable in the future; as such, policymakers, governments, and firms have a societal imperative to realise this goal if it is possible.
It is important to start this answer by noting the different purviews of the Government and regulators. As such, we will consider each party separately.
Regarding the Government - Galaxy believes that DLT and blockchain, the essential building blocks of cryptoassets, reach far beyond the boundaries of financial services. So too do their potential benefits - they could have transformative impacts on healthcare, property management, and the legal system to name a few. While we do not consider the Government to be unprepared, and indeed this inquiry demonstrates positive steps being taken to further its understanding, Galaxy believes there needs to be more attention and efforts given to the cross-sectoral benefits and impacts of DLT. To date, financial services has been the front line for considering these issues, however we would encourage the Government to focus more cross-party efforts on considering how DLT and blockchain may impact the broader UK. For example, DLT could be transformative for property markets in terms of maintaining land registers and property deeds; developing a national ID infrastructure; and distribution of welfare payments.
With regards to the regulators, we would welcome more coordination with industry. A regulator like the Financial Conduct Authority (FCA) has a broad remit and cannot expect to have all the in-house expertise to deal with a complex technical subject like cryptoassets alone. The FCA should leverage industry to bring the business model and technology acumen to overlay with its legal and policy expertise. We were heartened by the efforts of the Cryptoasset Taskforce, and the FCA ‘cryptosprint’ more recently, however for true cross pollination to occur, regulators should establish a more durable process or mechanism to demonstrate its continued interest in incubating progressive policy changes to accept this new industry. Specifically, Galaxy believes there is considerable benefit in establishing a Cryptoasset Steering Committee, which should include industry representation, that would advise and report to the FCA, and which would provide thoughtful and detailed advice on policy and supervisory challenges, reforms, and other important policy matters.
As discussed in Q4, cryptoassets can bring transformative opportunities to the UK economy. At Galaxy, we believe there are five key pillars which industry, Government and policymakers need to focus on to realise these benefits and mitigate risks.
Design a Privacy-Centric Future of Finance: Digital asset infrastructure—which is predicated on decentralisation—can enable the development of financial infrastructure and be combined with privacy enhancing technologies (PETs) to promote user control over personal information and enhance privacy. These developments can help counter the ongoing growth and scale of large, centralised platforms (both public and private) that pose challenges to personal privacy. Smart policy frameworks must nurture the benefits of digital asset infrastructure as core consumer protections in the coming decades to protect individuals from surveillance and invasions of privacy by bad actors, including rogue nation states.
Leverage New Technologies to Enhance Consumer Protection: Cryptoassets can promote consumer protection by removing complex layers of intermediaries, increasing transparency, and placing greater choice and autonomy in the hands of customers. For example, if we had blockchain infrastructure in place prior to the financial crisis, we would have been better able to track concentrations of systemic risk and measure counterparty exposures. Policymakers must recognise these benefits and tailor regulatory frameworks to reflect the digital reality of cryptoassets in terms of how they are transacted in order to balance needed protections with the benefits of continued innovation.
Supporting Stablecoin Development to Enhance Access and Competition: Stablecoins, specifically those backed one to one with fiat currency, hold huge potential for the UK economy. They can reduce payment friction, domestically and globally, that presently exists in our economy; they are functional and effective stores of value in a digital, tokenized format; they disintermediate unnecessary actors or functions within our payments systems; and they combine the stability of the fiat currency on which they are based with the transformative features of a decentralised blockchain.
The primary risks posed by a fiat-backed stablecoin, therefore, involve the safety of these investments, run risk if many customers sought token redemptions at the same time, and security and operational risks related to the operation of a crypto-token, which are similar to those associated with any cryptocurrency. Galaxy believes that a regulatory framework should exist to manage these risks, which allows any lawful business to secure a licence to issue and operate a regulated fiat-backed stablecoin with clear rules, market structure, oversight, and legal standards. Such a licence should include the functional ability to issue the stablecoin; should provide oversight authority to the regulator; and must include both prudential and consumer protection requirements.
Implement Smart Custody Regulation to Underpin Digital Asset Markets: Custodians are central to the digital asset ecosystem as the safekeepers of tokenized value and assets. These new intermediaries will underpin future digital economic activity and regimes that ensure their safety will hold a competitive advantage relative to other jurisdictions. To this end, sensible frameworks need to be established to manage risks posed by custodians, including with respect to safekeeping of private keys and heightened cybersecurity considerations.
Clarify Digital Asset Taxonomy and Applications: Tokenization of financial instruments and assets combined with public blockchain infrastructure will transform how we transact and engage in economic activity. Key to advancing the responsible development of this space is developing a shared digital asset taxonomy that provides clarity to regulators, consumers, and industry. Such definitional clarity will help all stakeholders better understand use cases and applications of digital assets, related opportunities and risks, and appropriate policy responses. A failure to advance shared digital asset taxonomy will cause ongoing confusion and undermine effective application of regulatory regimes that are tailored to mitigate identifiable risks.
As referenced in Q3, some key benefits of DLT stem from their ability to reduce the reliance on often costly and inefficient intermediaries that exists in the current (legacy) financial system. By fostering direct relationships and trust, this could reduce transaction costs, create better incentives between consumers and institutions, and rebuild trust. It could also allow consumers to better use, control, and own their own financial data.
The potential list of opportunities for DLT in financial services is endless; although all these potential use cases come with risks and uncertainties that would need to be addressed, and political considerations. As such, we want to highlight three primary use cases.
Regulatory compliance and reporting is a substantial cost for all financial institutions. It requires a lot of manual input and manual review, making it only possible to identify risks after the reporting period has elapsed. DLT could revolutionise risk management, by allowing for real-time data sharing and making trend monitoring easier and more robust.
Interbank reconciliation is still heavily reliant on centralised systems and third parties to help match data and underscore exceptions. DLT can be effectively used to perform reconciliations thereby creating an intermediary-free ecosystem enabling greater efficiency and reduced costs; a trustless process removing all human verification; and process standardisation which again can reduce costs and increase efficiency.
DLT has the potential to make clearing and settling processes far more efficient. Currently, sending and receiving money especially across international borders is slow and expensive, in part because of the intermediaries which the process relies upon. Leveraging DLT can make intermediaries redundant meaning settlements can be near real-time, and at a fraction of the cost.
Galaxy is heartened by the efforts of Government and regulators to try to better understand the cryptoasset market. However, as we have explained in Q4, such efforts cannot be isolated or irregular; the Government must develop a long term and meaningful relationship with industry if it is to keep pace with the quickly evolving cryptoasset market and develop principles based, forward leaning regulation which maintains the UK’s global competitive position.
We also believe that the UK’s principles-based approach to regulation creates an ideal basis for current, and preparation for future, cryptoasset regulation. This approach allows for more flexibility and proactivity, which is crucial to balance the fostering of innovation with the protection of consumers in a rapidly evolving market. We strongly encourage that the Government maintains this principles-based approach in its future deliberation of cryptoasset policy.
To date, tax policies around cryptoassets, to the extent they have been considered, have been implemented ex-post. This approach does not embrace the industry with durable policy solutions, and will only result in gaps, overlaps, and confusion for market participants.
Any policy regime needs to work hand in glove with the associated tax regime to ensure incentives are aligned. Given the UK Government’s commitment to cryptoassets and its statements that the UK is ‘open for cryptoasset business’, Her Majesty's Revenue and Customs (HMRC) needs to continue to engage with HMT policymakers to understand how the ecosystem is developing now, and where it might evolve to in the future. This will allow HMRC to consider at the outset whether the cryptoasset tax regimes will be designed to be adoptive, seek to drive equivalence, or be restrictive. By ensuring that tax policy aligns with the broader Government aim of pro-competition, the UK can establish its overarching policy aims in this space; without this alignment, even an agnostic tax policy could serve to undermine the broader objective.
Tax is not the only area where Government processes need to adapt to - and could be benefitted by - cryptoassets. Essentially any Government process through which money, assets, or information changes hands, particularly when being passed between civil servants and members of the public, could benefit from the immutability, auditability, and transparency of DLT. This could include payments made to citizens, healthcare records, property title deeds, and legal documents. DLT reduces the likelihood of fraud and can be faster and cheaper than many of the manual processes that exist today.
Consumer protection understanding and requirements need to be reimagined in a world of DLT enhanced finance; attempting to amend what already exists to fit this space in many instances will not be sufficient. Advertising is an excellent example of this. Social media and online advertising (e.g., online games and banner ads) are the most common channels through which consumers see cryptoasset advertising.[5] These adverts may be from products and companies based anywhere in the world (or indeed, without any official base), agnostic to regulated status, and are largely uncensored by the numerous global platforms on which they operate.
With such advertising, we acknowledge that there is a consumer protection objective to be considered. Crypto marketing is increasingly prevalent, and it can be hard for a retail consumer to understand what they are purchasing and what protections may be afforded to them in the event of failure.
However, Galaxy has some concerns regarding the Government and FCA’s proposed regulatory measures surrounding cryptoasset promotions.
The FCA has proposed, following Treasury’s confirmation to bring certain cryptoassets into the scope of the financial promotion regime, to apply the same rules that currently apply to other high‑risk investments, classified as Restricted Mass Market Investments (RMMI). This categorization, rather than the less stringent ‘Readily Realisable Securities’, was cited by the FCA as being due to concerns about consumer protection. Under the RMMI approach, the recipient of a cryptoasset promotion must be categorised as either a certified high net worth investor, a certified sophisticated investor, a self-certified sophisticated investor, or a certified “restricted” investor. Promoting cryptoassets to consumers who are not in those categories would be prohibited. However, leaving the category of self-certified investor creates an obvious loophole for customers and firms. Additionally, the broad territorial scope of these rules will make them almost impossible to supervise ex-ante and give limited scope for recourse ex-post.
Our concern is that the policy outcome will be to raise the bar for legitimate actors, who duly target their marketing appropriately, leaving only illegitimate/unknowing actors continuing to push their products to unwitting consumers through social media and other platforms which the FCA have minimal hope of supervising effectively. It also risks providing false comfort to consumers who are aware of the FCA intervention, who then assume that advertising they do receive must be appropriate to them.
Regarding the regulatory measures around anti-money laundering, these have been more proportionate, but the implementation has been slow and cumbersome, again resulting in a potential mismatch between the stated outcome and the real outcome. We also believe there needs to be more clarity for consumers, potentially in the form of an updated cryptoasset taxonomy, regarding the difference between registered and unregistered firms, and what that means for ex-post protections.
We believe that the role of the Government should be to define and adopt an appropriate cryptoasset framework that encourages legitimate cryptoasset actors to operate within, encourages broader UK businesses to participate in, and provides benefits to UK consumers. While the Government will need to consider the interests of citizens in any policy making, consumer protection specifically is the purview of the regulator, and the Government should bestow the appropriate powers upon the regulator for it to meet that mandate independently. However, this does not mean Government and regulators should operate in isolation as the Government works to promote innovation and the regulator works to protect consumers.
From this perspective, the Government needs to take decisive and thoughtful action; a failure to act resulting in the UK losing its competitive advantage may be as damaging for innovation and the economy as overly prescriptive regulation.
Similarly, to the concept of consumer protection discussed in Q9, consumer trust and resilience is different in the cryptoasset space than it is in traditional finance. Regulators currently place most expectations on the firm - from how they engage with consumers and what they can sell them at the front end, to how they protect their assets and return them at the back end. In the UK, consumers broadly speaking can pick any large bank at random and engage with them, confident that the bank should offer them only the most fitting products and services, explain any processes clearly, custody any assets appropriately and return them safely when the customer requires. In the event of an issue, the customer knows they are protected and has avenues through which to complain. The cryptoasset market in many ways represents a sea change against this somewhat paternalistic approach, in favour of giving customers more choice and more control. However, this has also created a self-reliant marketplace in which consumers are responsible for their own financial and technological literacy, and the decisions they make using that information. It is important that the Government and regulators acknowledge and understand this difference, as significant consumer harm could be created because of individuals entering this new space with the expectations of traditional finance.
As with any major shift in the way society interacts with technology, adoption is not linear. The uptake of digital assets is no different. Uptake will be slowed by high profile failures and bolstered by societal shifts for example because of the move to cashless payments during the COVID pandemic. The cryptoasset industry needs support to mature - which needs to come both from incumbents and Government - and to properly embed financial risk management. Ultimately, the same economic tools should be used to judge risk ex-ante; the underlying technology should not intrinsically change the system for identifying risk, it should only potentially impact on the level of risk and the management techniques.
For consumers, the biggest barriers to the mass adoption of digital currencies include the purchasing procedure being complicated, not knowing where to buy them, and too few options to use them.[6] Regulation can be a crucial tool in overcoming all these barriers by providing the right entry points and incentives for use. By reducing consumer barriers in this way, regulation can therefore encourage cryptoasset adoption, which will be of benefit to cryptoasset start-ups.
However, regulation compliance is costly, often disproportionately so for start-ups who may lack the in-house expertise and so are reliant on external advisors. Regulation needs to be conscious of this and be proportionate to the firms to which it applies.
Galaxy is also cautious of encouraging a simple narrative that demarks regulated firms as ‘good’ and ‘trustworthy’ and those which are not as bad. This is particularly true in the cryptoasset space, where there is more nuance around firms which are ‘registered’ and ‘regulated’. Such simple rhetoric will only encourage firms to use their regulatory/registration status as a tool to promote their brand. The industry needs to mature to a place where being regulated is simply a cost of doing business; however, regulators and Government have a role to play here insofar as the process to get registered/regulated should simply be the start of an ongoing regulatory relationship rather than a bar to meet at a single point in time.
Consumer choice is also key in promoting trust and resilience, so overly prescriptive regulation that restricts consumers ability to interact with the ecosystem will not promote trust overall, as the trust in this system will be directly derived from consumer’s trust in the Government. Again, clarity is how the Government can support this process - retaining customer choice but also affording them protections through knowledge and education.
At Galaxy, we have observed many different regulatory approaches to cryptoassets around the world as the market has grown. These approaches vary wildly, from bans and prohibitions, to cryptoassets being recognised as national currency. Each approach will be introduced with the local consumer population, market conditions, broader financial services landscape, and Government agenda in mind. None of these approaches are a panacea and all bring risks with them.
As such, we are cautious to hold any one regime out as an example for the UK to follow. Instead, the UK needs to be looking inward and considering its own priorities in the context of its own unique set of circumstances. Once the UK Government and regulators have a clear approach, then it can consider engaging with other jurisdictions to ensure the implementation of this approach is done in a way that is conducive to business with other strategically important nations for example. However, the UK needs to establish its own position first.
Digital assets have many different types of consensus mechanisms, with trade-offs around security and decentralisation depending on the design. The most popularly criticised network surrounding energy usage is Bitcoin. Because Bitcoin is an open-sourced system, it is extremely transparent with its energy usage, allowing for a biased conversation debating the utility of Bitcoin, in relation to the energy it consumes. To be clear, the global Bitcoin network consumes 0.15% of the world’s energy production, this translates to less energy than air conditioning in the United States.
The industry joined forces to tackle the inaccuracies surrounding the energy question and like other industries like Gold, formed a Bitcoin Mining Council (“BMC”), a voluntary global forum of Bitcoin mining companies. As of the last Q2 2022 survey, the council represented 50% of the Bitcoin network. The results of this survey show that the members of the BMC and participants in the survey[7] are currently utilising electricity with a 66.8% sustainable power mix.
Because miners are economically incentivised to use the cheapest form of energy, they have begun to become creative with energy sources. We have seen miners using flared methane gas capture methods to mine bitcoin, using landfill methane to mine bitcoin, and setting up companies completely dedicated to focusing on renewable sources of power. Additionally, miners are location agnostic, allowing flexibility for operations. On the grid, bitcoin mining provides a flexible demand load which can be turned off (in seconds) during periods of congestion. This provides more reliability to the grid as more intermittent sources of energy (renewables) supply the grid. Furthermore, bitcoin mining computing infrastructure (‘ASICs’) - the computer chips the bitcoin network is secured by - contain no toxic chemicals and are almost entirely recyclable.
Just like any other industry, miners simply try to find energy that is available. However, thanks to its unique characteristics, bitcoin mining can have a positive impact on energy and the environment in parallel to securing the Bitcoin network.
September 2022
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[1] Board of Governors of the Federal Reserve System, Stablecoins: Growth Potential and Impact on Banking, Jan 2022, https://www.federalreserve.gov/econres/ifdp/files/ifdp1334.pdf
[2]UK Parliament official website, Financial Services and Markets Bill, accessed August 2022, https://publications.parliament.uk/pa/bills/cbill/58-03/0146/220146.pdf
[3] World Economic Forum, Cryptocurrencies can enable financial inclusion. Will you participate?, June 2021, https://www.weforum.org/agenda/2021/06/cryptocurrencies-financial-inclusion-help-shape-it/
[4]The World Bank, Financial Inclusion, accessed August 2022, https://www.worldbank.org/en/topic/financialinclusion/overview
[5] FCA, Research Note: Cryptoasset consumer research 2021, June 2021, https://www.fca.org.uk/publications/research/research-note-cryptoasset-consumer-research-2021#lf-chapter-id-results-public-awareness
[6]Economist Impact, Digimentality 2022: fear and favouring of digital currency, May 2022, https://impact.economist.com/projects/digimentality-2022/wp-content/uploads/2022/05/ECO154-Crypto-Digimentality-2022-11.pdf
[7] https://bitcoinminingcouncil.com/bitcoin-mining-electricity-mix-increased-to-59-5-sustainable-in-q2-2022/