# IMMC.EESC-2018-01470-AC.ENG.xhtml.EESC-2018-01470-00-01-AC-TRA-EN.docx

EN

European Economic and Social Committee

European Economic and Social Committee

NAT/737

NAT/737

Indicators better suited to evaluate the SDGs – the civil society contribution

Indicators better suited to evaluate the SDGs – the civil society contribution

OPINION


  European Economic and Social Committee


  Indicators better suited to evaluate the SDGs – the civil society contribution

  (own-initiative opinion)

OPINION

European Economic and Social Committee

Indicators better suited to evaluate the SDGs – the civil society contribution

(own-initiative opinion)

Rapporteur: Brenda KING (UK-I)

Rapporteur: Brenda KING (UK-I)

Co-rapporteur: Thierry LIBAERT (FR-III)

Co-rapporteur: Thierry LIBAERT (FR-III)

Plenary Assembly decision

| Plenary Assembly decision | 15/02/2018 |
| --- | --- |
| | |
| Legal basis | Rule 29(2) of the Rules of Procedure |
| | Own-initiative opinion |
| Section responsible | Agriculture, Rural Development and the Environment |
| Adopted in section | 05/09/2018 |
| Adopted at plenary | 19/09/2018 |
| Plenary session No | 537 |
| Outcome of vote

  (for/against/abstentions) | 194/2/3 |

Plenary Assembly decision

15/02/2018

15/02/2018

Legal basis

Legal basis

Rule 29(2) of the Rules of Procedure

Rule 29(2) of the Rules of Procedure

Own-initiative opinion

Own-initiative opinion

Section responsible

Section responsible

Agriculture, Rural Development and the Environment

Agriculture, Rural Development and the Environment

Adopted in section

Adopted in section

05/09/2018

05/09/2018

Adopted at plenary

Adopted at plenary

19/09/2018

19/09/2018

Plenary session No

Plenary session No

537

537

Outcome of vote

  (for/against/abstentions)

Outcome of vote

(for/against/abstentions)

194/2/3

194/2/3

1.Conclusions and recommendations

1.

Conclusions and recommendations

1.1Ever since the adoption of the UN 2030 Agenda for Sustainable Development by the European Institutions in 2015, the EESC has been calling on the Commission to establish an overarching European Sustainable Development Strategy with concrete objectives, targets and actions in order to achieve the 17 Sustainable Development Goals (SDGs). Despite the fact that the EU played a leading role in the adoption of the 2030 Agenda and that the SDGs reflect EU core values which are to promote greater social, political, economic and environmental harmony, the European Commission has failed to develop an overarching strategy. The Reflection Paper "Towards a Sustainable Europe by 2030" to be published by the end of 2018 is an opportunity to emphasise the importance of adopting an overarching European strategy.

1.1

Ever since the adoption of the UN 2030 Agenda for Sustainable Development by the European Institutions in 2015, the EESC has been calling on the Commission to establish an overarching European Sustainable Development Strategy with concrete objectives, targets and actions in order to achieve the 17 Sustainable Development Goals (SDGs). Despite the fact that the EU played a leading role in the adoption of the 2030 Agenda and that the SDGs reflect EU core values which are to promote greater social, political, economic and environmental harmony, the European Commission has failed to develop an overarching strategy. The Reflection Paper "Towards a Sustainable Europe by 2030" to be published by the end of 2018 is an opportunity to emphasise the importance of adopting an overarching European strategy.

1.2The current lack of a European Sustainable Development Strategy is a risk for the coherent implementation of the 2030 Agenda in the EU and at national level. Divergences in the approach to addressing the SDGs may occur, as several Member States are already preparing their national sustainable development strategies while there is no European strategic framework or common implementation guidelines.

1.2

The current lack of a European Sustainable Development Strategy is a risk for the coherent implementation of the 2030 Agenda in the EU and at national level. Divergences in the approach to addressing the SDGs may occur, as several Member States are already preparing their national sustainable development strategies while there is no European strategic framework or common implementation guidelines.

1.3The EESC welcomes Eurostat's first annual 2017 Monitoring Report of the SDGs
  1
  , which is based on a set of 100 indicators using rigorous data criteria. However, the EESC identified a number of deficiencies regarding the current set of indicators, which future publications of Eurostat's annual SDG Monitoring Report should consider.

1.3

The EESC welcomes Eurostat's first annual 2017 Monitoring Report of the SDGs
  1

, which is based on a set of 100 indicators using rigorous data criteria. However, the EESC identified a number of deficiencies regarding the current set of indicators, which future publications of Eurostat's annual SDG Monitoring Report should consider.

1.4The EESC calls for indicators that can provide a basis for policy planning and policy shaping. The current set of indicators fails to measure the distance to targets or to provide an appropriate progress review. Specific EU policy targets for SDGs need to be established and indicators need to be able to monitor their achievement. In the absence of specific EU policy targets, the EU could assess national performance in comparison with best and average performance.

1.5The EESC also identifies certain technical limitations that need to be addressed in order to ensure the best indicators are used. For example, the use of cross-cutting indicators remains insufficient to provide information about synergies and dilemmas among the goals. The spill-over effects on partner countries' sustainable development and monitoring policy coherence between important external and domestic policy objectives are also not fully integrated.

1.6Eurostat and the national statistical offices need to ensure they are applying a coherent framework of indicators. A comprehensive and integrated system of indicators should be in place to guarantee that the monitoring exercise on SDG implementation at European and national level is reliable.

1.7Eurostat and national statistical offices have limited human and financial resources for collecting new data and therefore it is not always possible to produce new and more targeted indicators. The EESC calls for adequate resources to be ensured to overcome this relevant limitation.

1.8EESC calls for the major involvement of civil society in the definition of indicators and in assessing the EU’s progress towards the goals. The cross-cutting nature of the SDGs requires integrated multi-stakeholder cooperation.

1.9The EESC recommends that the set of indicators is complemented by a qualitative shadow report, developed in close collaboration with civil society organisations to increase all stakeholders' sense of ownership of SDGs. Qualitative information can highlight trends that would otherwise not be captured solely with quantitative metrics. The EESC proposes to take the lead on coordinating the preparation of the complementary qualitative report. In addition, the EESC proposes that the European Commission cooperate in the organisation of a European SDG Summit as a stocktaking exercise involving all relevant stakeholders.

1.10A coherent strategic framework also requires that other EU indicators (e.g. the indicators included in the Social Scoreboard or the European Biodiversity indicators) need to be coherent with the 2030 Agenda framework. An overarching strategy should provide this overview of the interlinkage between the SDGs, EU policies and the different sets of indicators.

1.11The EESC calls for the current EU governance system to be adapted to the implementation of the 2030 Agenda. An overarching, sustainable EU development strategy fully aligned with 2030 Agenda would guarantee that SDGs are mainstreamed into all EU policies and provide the framework for coordination and monitoring of EU and national implementation of the SDGs. For example, the European Semester machinery should be monitoring and contributing to the implementation of the SDGs. Additionally, EU policy formulation and evaluation (e.g. The Better Regulation agenda) should be adapted to fully incorporate the SDGs into the policy cycle. A sustainability test should be applied to all legislation and policy proposals in order to estimate the impact on SDGs and decide on the appropriateness of the proposal.

1.12The EESC recommends that within the Commission, a Vice-President, with a dedicated team, specific budget and working structure with all Commissioners and Commission departments, should be in charge of mainstreaming the SDGs into EU policies. Furthermore, the president of the European Commission should present progress made and outline further action needed to implement the SDGs in the annual State of the European Union speech.

1.13Finally, the EESC calls for an agreement on an EU budget that makes sustainable development the core objective. The EESC recalls that the final Multi-annual Financial Framework (MFF) for the 2021-2027 period will signal whether the EU will be able to achieve its 2030 Agenda commitments. The Commission's proposal of May 2018 goes in the right direction, but ultimately misses the opportunity to make the 2030 Agenda the priority of the European agenda.

2.Lack of EU strategy

2.1The EU should commit to a greater extent to its leading role in ensuring and promoting sustainable development. In fact, the UN 2030 Agenda is directly in line with the fundamental purpose of the European Union, which is to promote greater social, political, economic and environmental harmony both within Europe and around the globe. However, although the EU and its Member States signed the global Agenda, Europe is lagging behind. So far the EU and a number of Member States have failed to implement a sustainable development strategy to ensure the achievement of the SDGs.

2.2Recalling Article 3 of the Treaty of the European Union, a reference to sustainable development states: "In its relations with the wider world, the Union shall (...) contribute to, the sustainable development of the Earth (...)". While there are some growing elements of sustainability in various EU policies, such as industrial policy, transport and energy, there remains a lack of ambition and a lack of funding. Overall, the EESC regrets the evident lack of strategy, policy coherence and integration into overall EU policy coordination.

2.3The EESC is the only institution at the European level that has made sustainable development a main priority. The European Parliament has no structure in place to address sustainable development, though some political groups are including the 2030 Agenda in their political priorities for the European elections of May 2019. Meanwhile, the European Commission has set up the Multi-Stakeholder Platform for the implementation of the SDGs, which is a step in the right direction, but it is not clear whether this platform will continue beyond this Commission. In addition, the EESC advocated in the past a more ambitious and larger civil society forum than the one finally created
  2
  .

2.4At national level, the degree of SDG planning and implementation is dissimilar
  3
  . Some Member States have already adopted comprehensive national sustainable development strategies, and in some cases, regional and local authorities, as well as concerned stakeholders are also running SDG initiatives to raise awareness. There is the risk of incoherence between national approaches as there is no European framework. The EESC calls for the integration of sustainable development into national policies and for organised civil society to be fully involved in design and implementation in line with an overarching EU strategy.

3.What lies ahead

3.1On 13 September 2017, President Juncker announced a Reflection Paper "Towards a Sustainable Europe by 2030, on the follow-up to the UN Sustainable Development Goals, including on the Paris Agreement on Climate Change", which will be published during the winter of 2018. In the preparation phase, the Commission is considering the views of the members of the Multi-Stakeholder Platform on the SDGs. The Platform's members are proposing suggestions on how to improve EU governance in relation to SDGs (e.g. adopting an overarching strategy), policy recommendations and how an EU toolbox should evolve to coordinate policies, monitoring and accountability.

3.2The implementation of the SDGs includes economic, social, political and environmental objectives that will require fundamental changes in European societies and within the EU institutions.

3.3Debates about the future of Europe ahead of the 2019 European elections are crucial to raise awareness among citizens on sustainable development. European political parties must take a stand and address sustainable development within their manifestoes for the elections.

3.4Moreover, the EESC considers that the future European Commission and the new European Parliament emerging from the 2019 European elections should make it a priority to better mainstream the SDGs into EU policies. The EESC urges the European Parliament to strengthen its capacity to monitor and supervise SDG progress and to take responsibility for the goals. With regard to the Commission, reinforcing the leadership of the Vice-President in charge of sustainable development and restructuring the portfolios of the DGs to make it clear who is accountable for each of the SDGs are also recommended.

3.5The final decision on the Multi-annual Financial Framework (MFF) for the 2021-2027 period will signal whether the EU will be able to achieve its 2030 Agenda commitments. The MFF is crucial to ensuring mainstreaming of the SDGs. The European Commission's proposal published in May 2018 goes in the right direction, but misses the opportunity to make the 2030 Agenda the priority of the European agenda. Beyond the limited proposed increase in the climate mainstreaming target, the new MFF should allocate relevant financial resources for sustainable development and also ensure that no funding undermines the implementation of the SDGs. Funding needs to be made available to SDG implementers, including Member States, local authorities, business and NGOs for innovative, scalable projects.

3.6The EU is undergoing a major political and institutional crisis and faces challenges such as growing social inequalities; environmental problems; and loss of trust in government and the EU
  4
  . To overcome this situation, the EU needs to develop a new narrative that is able to provide tangible solutions to the challenges our societies are facing. The ongoing debates on the future of Europe should contribute to this new narrative, taking the 2030 Agenda and the 6th Scenario of Europe
  5
  into account, so that the EU becomes a driver for sustainability. Greater leadership from the European Heads of State to make the SDGs a central part of their political discourse and vision for Europe is required.

3.7The 2030 Agenda is based on Europe's core values of democracy and participation, social justice, solidarity and sustainability, respect for the rule of law and human rights, both within Europe and around the globe. The new sustainable development narrative should provide citizens with answers on how public administrations and organised civil society plan to address their aspiration of economic, social and environmental wellbeing.

4.The issue of indicators

4.1The EESC considers that the approach taken with the EU SDG indicators must go beyond mere evaluation by contributing to policy formulation and policy shaping, rather than just being a reporting tool. The indicators should help EU policy-makers in defining future policies and planning how to better achieve the SDGs. The indicators must also help policy-makers to identify deviations in progress towards the SDGs and introduce necessary policy changes on time in order to achieve the goals by 2030.

4.2From the EESC's perspective, Eurostat's 2017 Monitoring Report of the Sustainable Development Goals in an EU context is a good start, but there is room for improvement. It needs to be built on by improving the indicators. The current method of evaluating progress (i.e. 1% positive change) in the absence of EU quantified targets is potentially misleading, as it provides no information about the distance to the SDGs, unlike other reports. For example, while Eurostat concludes that there is significant progress in Europe on SDG12
  6
  , others sources, such the OECD, come to different conclusions
  7
  . The monitoring report needs to do more to make clear the integrated nature of the agenda, where efforts need to reinforce each goal rather than undermine any of them. While valuable, the use of cross-cutting indicators remains insufficient to provide information about synergies and dilemmas among the goals. Moreover, the report should assess the spill-over effects on partner countries' sustainable development and monitor policy coherence between important external and domestic policy objectives. Finally, indicators should be able to show comparisons between European countries, identify divergences in MS implementation and be frequently updated so that they are based on the best available science/knowledge/information.

4.3In order to have a coherent set of indicators providing a clear overview of SDG implementation at EU level, it is crucial to create a comprehensive system of indicators covering the European and national level. First, the current indicators used for different policy areas at EU level need to be harmonised or at least interlinked with the EU SDG indicators. For example, relevant sets of indicators such as the Social Scoreboard or the European Biodiversity indicators need to be linked to the EU SDG indicators and their relationship needs to be clearly defined. Secondly, national sustainable development strategies should use the same indicators or at least indicators comparable to the EU SDG indicators. If this is not the case, there will be a high risk of inconsistency between the different approaches taken among Member States. Thirdly, the EU needs to ensure a comprehensive process for reporting to the UN High-Level Political Forum on Sustainable Development. The European Commission should be able to provide a clear overview of SDG implementation at EU level and in all Member States.

4.4The EESC considers that certain limitations need to be addressed regarding the process of defining indicators. Eurostat and national statistical offices have limited human and financial resources for collecting new data and therefore it is not always possible to produce new and more targeted indicators. According to the 2017 Annual Report by the European Statistical Governance Advisory Board to the European Parliament, the cost of Europe’s statistical system amounts to 0.02% of GDP, and following cuts to human resources linked with budgetary austerity, the number of staff has not returned to pre-economic crisis levels
  8
  . To improve the set of indicators, greater priority must be given to developing sustainability indicators, and adequate funding for sustainability indicators must be allocated to Eurostat and national statistical offices, in line with targets concerning SDG17. This will make it possible to add new indicators that could require additional data collection.

4.5On the current set of indicators from Eurostat, the EESC identifies a number of deficiencies, which need to be addressed, ideally by the publication of Eurostat's 2018 Monitoring Report on progress towards the SDGs. Areas of improvement include:

-A more objective visual presentation of overall results, to avoid a mistaken impression of Europe being mostly on track with the SDGs, contradicting other qualitative or thematic research as well as perceptions from citizens;

-Greater attention to the spillover effects of Europe's current development model, for instance by building on Eurostat’s existing work on footprints, as well as Europe's contribution to supporting partner countries in achieving the SDGs;

-A more innovative approach to grasping the indivisibility of the SDG agenda, beyond cross-cutting indicators, which on their own do not indicate imbalances and contradictions between the different dimensions of sustainability and lack an appropriate framework to assess policy coherence;

-More data regarding business, local authority and NGO performance;

-More information regarding Member States' performance on the SDGs, as averages provide an incomplete picture. Providing national level information is also important given that Member States have exclusive competence regarding a number of SDGs;

-Better indicators of accountability for delivery on SDGs, in line with SDG16
  9
  and 17
  10
  , for instance regarding civil society space in Europe
  11
  and innovative partnerships;

-More robust methodology for measuring progress for the SDGs where there is no European target, by for instance comparing average performance with the best performers among European Member States or proxy targets derived from other international commitments or available research.

4.6While long time series are useful, indicators should be reviewed and improved based on the identification of new challenges and the progress of scientific knowledge, including new data. While Eurostat's efforts to include new indicators in 2018 go in the right direction, clarity about the process and timelines for including "on hold" indicators is crucial. For instance, there should be an action plan and timeline indicated for the proposed indicator "Extent of homelessness in the EU", recommended by FEANTSA (European Federation of National Organisations Working with the Homeless), which is currently listed as "on hold".

4.7The role of organised civil society in relation to the Eurostat annual report needs to be enhanced. Eurostat should consult more with civil society on the process of defining indicators and on assessing the progress of the indicators. Generally, civil society needs to be consulted early enough in the process for recommendations to be taken on board and Eurostat needs to explain why the recommendations of civil society have, or have not, been taken on board.

4.8What is monitored and what is not monitored, in particular, the design and choice of indicators, has substantial political implications
  12
  . Therefore, the process by which Eurostat prepares the annual report should allow civil society to contribute with a qualitative interpretation of the indicators. This should be accompanied by a frequent survey from Eurobarometer, to assess citizens' perceptions of the progress being made.

4.9The EESC realises that civil society has limited statistical capacity to propose new indicators that can meet Eurostat statistical robustness criteria. Civil society is, however, capable of defining useful indicators that use other sources beyond Eurostat data. An example of this is the indicators that are being developed by the Sustainable Development Solutions Network. Nevertheless, the EESC considers that it is necessary to support civil society organisations with capacity-building measures to ensure that they are able to contribute better to the discussion with Eurostat.

4.10In order to ensure the strong new narrative based on sustainable development mentioned above, the EESC calls for an improvement in the way the European Commission and Eurostat communicate on the SDGs' progress. The Eurostat report is not fully reader-friendly and has not been widely communicated, and therefore new ways should be explored to raise awareness of it among non-specialised audiences and citizens. Other research and communication products should also be explored as part of an ambitious awareness-raising strategy. For example, providing a "civil society monitoring" section on the Eurostat SDG website would allow for interactive co-ownership of the monitoring of the goals.

4.11The EESC acknowledges that Eurostat's annual report does not and cannot incorporate qualitative information. In order to cover this gap (as well as to enhance civil society involvement), the EESC proposes that the monitoring of SDG implementation should be complemented by a separate, independent qualitative shadow report, developed in close collaboration with civil society stakeholders. This shadow report should focus on: a) providing a reflection on and analysing the Eurostat report; b) complementing the Eurostat report with qualitative information coming from organised civil society; and c) providing organised civil society's interpretation of the progress towards implementation of the SDGs. The EESC is currently conducting a study on civil society involvement in SDG monitoring (expected to be finalised by November 2018), which will specifically explore and propose a methodological approach for the preparation of this complementary report to Eurostat's annual report.

4.12Accountability is at the heart of the SDG agenda. An ambitious SDG strategy needs to be complemented by a strong accountability framework where organised civil society plays a key role. This requires raising the awareness of citizens across the Union as well as opinion surveys and other citizen feedback mechanisms. In this regard, the European Commission (in collaboration with the EESC) should organise an SDG Summit to carry out an annual stocktaking event with Member States, the European Parliament, civil society, businesses and regional and local authorities, and to commit to an inclusive and regular dialogue with stakeholders. Finally, the exchange of good practices of civil society involvement in SDG assessment should be promoted. The EESC could play a key role in supporting civil society organisations in exchanging these types of experience, creating synergies, increasing knowledge and raising awareness, and promoting collaboration.

5.Integration of the SDGs into EU governance

5.1The current EU governance system should be adapted so that it contributes to the implementation of the 2030 Agenda. In order to achieve this, all EU institutions should take steps to ensure coordinated work on progressing towards the SDGs.

5.2In spite of the leadership of the Vice-President of the European Commission, it is apparent that there is a low level of buy-in among several Commission departments, which hampers progress. The same is true of the Parliament, which must establish a credible process across committees to discuss SDG implementation. Finally, the working party on SDGs within the European Council, which is welcomed, needs to ensure adequate mainstreaming of the SDGs in all matters of the European Council, e.g. the future of the CAP, the cohesion policy, the transport policy
  13
  , external relations
  14
   and the next MFF for 2021-2027.

5.3A future overarching EU sustainable development strategy should play a crucial role in mainstreaming the SDGs into all EU policy and provide the framework for coordination and monitoring of EU and national implementation of the SDGs. As mentioned, the strategy should establish targets, the means to address them and a coherent set of indicators to be used to monitor progress. The EESC agrees with the Council on the need to develop "a reference indicator framework"
  15
  .

5.4As mentioned, this reference indicator framework should integrate all relevant European indicators currently used in different policy areas and define the interlinkages between the existing indicators and the SDG indicators. For example, the European Commission should ensure complete alignment and coherence between the Social Scoreboard and the EU SDG indicators. Currently, of the 12 indicators of the Social Scoreboard; eight are included completely or partially in the EU SDG set.

5.5The coordination and monitoring of the SDGs should be integrated into the European Semester process, as the EESC has repeatedly called for (e.g. EESC opinions NAT/693
  16
  , NAT/700
  17
  , SC/047
  18
  , SC/050
  19
  ). This should include a scrutiny process for the adequacy of SDG implementation strategies at the Member State level. National authorities should receive common guidelines and should be monitored so all efforts go in the same direction. Moreover, exchanging best practices among Member States should be promoted. The European Semester should fully extend its scope beyond the traditional economic dimension and completely integrate the social and environmental dimensions at the same level of importance in the context of a future overarching sustainable development strategy. Consequently, the country-specific recommendations should be consistent with the SDGs as well as the analysis carried out in the country reports within the European Semester process.

5.6The recently created Structural Reform Support Programme (SRSP) aims to help Member States implement institutional, structural and administrative reforms. It is expected that the SRSP will play a relevant role in the next years. As already stressed by the EESC
  20
  and the Falkenberg report
  21
  , the SRSP should assume that any supported reform needs to be coherent with the 2030 Agenda and the SDGs.

5.7In order to ensure that the SDGs are mainstreamed in all EU policies, the Better Regulation agenda needs to be adapted accordingly to ensure a comprehensive and holistic approach to the SDGs. The EESC considers that the SDG principles should be explicitly referred to in the Better Regulation guidelines and toolbox. Additionally, Better Regulation methodologies should be revised to ensure that they are capable of assessing long-term objectives and measuring the distance towards achieving the SDGs. Finally, greater attention needs to be paid to policy coherence as a tool for SDG implementation, by using, for instance, the OECD's framework on Policy Coherence for Sustainable Development (PCSD).

5.8When proposing new legislative or policy initiatives, the European Commission should clearly indicate which SDG is targeted and run a sustainability test to assess the expected impact on the SDGs (as part of the impact assessment process, aimed at assessing the economic, social and environmental dimensions of proposals). The main problems in the implementation of the SDGs that the proposed policy aims to tackle should be identified. As well, the monitoring and evaluation of ongoing EU policies need to be adapted to measure the progress towards achieving the SDGs and to recommend policy modifications that have a larger impact in promoting the SDGs.

5.9The Commission's Regulatory Fitness and Performance (REFIT) programme should also integrate the sustainable development perspective. The REFIT programme work should ensure that any simplification and update of EU law proposed is coherent and contributes to the SDGs.

Brussels, 19 September 2018

Luca JAHIER

  The president of the European Economic and Social Committee

_____________

"Sustainable development in the European Union: Monitoring report on progress towards the SDGs in an EU context. 2017 edition".

EESC opinion on the transition towards a more sustainable European future, SC/047,
  OJ C 81, 2.3.2018, p. 44

(5)

(6)

(7)

See for instance OECD. 2017.
  Measuring Distance to the SDG Targets: an assessment of where OECD countries stand.

See for instance OECD. 2017.

(8)

Report, 2017, pp. 25-26.

(9)

(10)

(11)

(12)

EESC opinion on the next steps for a sustainable European future, NAT/700,
  OJ C 345, 13.10.2017, p. 91

(13)

.

.

(14)

REX/485,

.

(15)

https://www.consilium.europa.eu/media/23989/st10370-en17.pdf

(16)

,

(17)

EESC opinion on the next steps for a sustainable European future, NAT/700,

(18)

EESC opinion on the transition towards a more sustainable European future, SC/047,

(19)

,

.

(20)

EESC opinion on the Structural Reform Support Programme,
  ECO/398, OJ C 177, 18.5.2016, p. 47
  .

(21)

Sustainability Now! EPSC Strategic Notes. Issue 18 (2016)

  https://www.eesc.europa.eu/sites/default/files/files/rapport_kff.pdf