EN Official Journal of the European Union C 291/1

SPECIAL REPORT No 5/2005

Interpretation expenditure incurred by the Parliament, the Commission and the Council, together with the institutions’ replies

(pursuant to Article 248(4), second subparagraph, EC)

(2005/C 000/01)

TABLE OF CONTENTS

I-VIII EXECUTIVE SUMMARY

1-12 INTRODUCTION

13-14 THE AUDIT OBJECTIVE AND SCOPE

15-81 OBSERVATIONS

15-29 The procedures applied to avoid providing interpretation services which exceed the real needs

16-21 Parliament

22-24 Commission

25-29 Council

30-32 The capacity to provide all the interpretation services needed

33-71 The cost of interpretation

33-38 Cost calculations

39-41 Analysis of the cost of interpretation

42-58 Other questions affecting the cost of interpretation

59-71 Specific observations concerning the expenditure for freelance interpretation

72-81 The quality of interpretation

72 Parliament

73-81 Commission and Council

82-95 CONCLUSIONS AND RECOMMENDATIONS

82 The procedures applied to avoid providing interpretation services which exceed the real needs

83-84 The capacity to provide all the interpretation services needed

85-92 The cost of interpretation

93 The quality of interpretation

94-95 Possible developments

ANNEX I: The specific provisions applying at the Parliament, the Commission and the Council

ANNEX II: The cost calculation method developed by the Court

The institutions’ replies

EXECUTIVE SUMMARY

I. Twenty-one languages have the status of official and working languages of the European institutions. The institutions which, because of the nature of their activities, need the largest volume of interpretation services are the Parliament, the Commission and the Council. The Parliament has its own interpretation department. The interpretation needs of the Council and the Commission are catered for by the Directorate-General for Interpretation of the Commission (DG Interpretation).

II. Because of the uneven spread of demand over the year the European institutions employ not only permanent staff interpreters (officials), but also freelance interpreters recruited as auxiliary staff (called ACIs: Auxiliary Conference Interpreters).

III. The purpose of the Court's audit was to assess the soundness of the financial management of interpretation services at the Parliament, the Commission and the Council. In particular, the audit aimed to establish whether these institutions have adequate tools and procedures to ensure that: — the interpretation services provided do not exceed the real needs, — all the interpretation services needed can be provided, — interpretation services are provided at the lowest possible cost, — interpretation is of high quality.

IV. The audit has shown that the quality of interpretation mostly meets needs and expectations, but that a number of measures need to be taken to reduce cost and to avoid the provision of interpretation that was requested but not used.

V. The institutions have adopted differing approaches in responding to requests for interpretation. Whereas the DG Interpretation examines, together with the requesting Commission DGs, which interpretation services are really needed and decides which requests are to be met, there is no such examination at the Parliament, where all requests which formally comply with the rules are accepted as far as resources are available. In 2004 the Council adopted a new procedure providing clear incentives to limit interpretation requests.

VI. A calculation made by the Court shows that in 2003 the total cost of interpretation was around 57 million euro at the Parliament and around 106 million euro at the Commission, the Council, the Committees and some agencies. The average cost per interpreter of an interpretation day was 1 476 euro at the Parliament and 1 046 euro at the Commission and the Council.

VII. While the institutions have been successful in limiting the interpretation, further savings could be made if late cancellations, last-minute meeting requests, unequal distribution of meetings over the course of the week and the year, and high travel costs for ACIs were avoided. As these elements are largely beyond the control of the interpretation departments, savings could only be achieved by more forethought on the part of the meeting organisers.

VIII. Session reports indicating which languages have been used during the meetings are a very useful tool for assessing whether the interpretation arrangements provided correspond to the needs of the meeting participants, but they are not prepared in a significant number of cases. Providing a statement of the cost of cancelled meetings to the meeting organisers, as the Council does, is good practice which should be extended to the other institutions.

INTRODUCTION

1. According to Article 290 of the Treaty establishing the European Community the Council is empowered to determine unanimously the rules governing the languages of the institutions of the Community.

2. Under Regulation No 1, updated after every accession of States to the European Union, the Council has given 21 languages (Czech, Danish, Dutch, English, Estonian, Finnish, French, German, Greek, Hungarian, Irish, Italian, Latvian, Lithuanian, Maltese, Polish, Portuguese, Slovak, Slovenian, Spanish and Swedish) the status of official languages and working languages of the institutions (1).

3. Based on Regulation No 1 interpretation services are necessary when various working languages are used at a meeting.

4. The institutions which, because of the nature of their activities, have to provide the largest volume of interpretation services are the Parliament, the Commission and the Council. In 2003 the total cost of interpretation was around 57 million euro for the Parliament and around 106 million euro for the Commission, the Council, the Committees and some agencies.

5. The Parliament's Directorate for Interpretation provides for all the interpretation needs of the Parliament itself (for meetings held in Brussels, Strasbourg or elsewhere), the Ombudsman, the Commission in Luxembourg and the Court of Auditors. Since the completion of the audit the Parliament also provides interpretation to the Committee of the Regions on certain days.

6. The Commission's Directorate-General for Interpretation (DG Interpretation) covers the interpretation needs of the Commission (about 40 % of the interpretation days provided) — except for meetings taking place in Luxembourg — the Council (more than 50 % of the interpretation days provided), the European Economic and Social Committee, the Committee of the Regions, the European Investment Bank and some European agencies.

7. The Council has only a small Conferences Unit that organises the meetings and orders interpretation services from the DG Interpretation.

8. Because of the uneven spread of demand over the year, depending on the frequency of meetings and the language combinations requested, the European institutions employ not only permanent staff interpreters (officials) (2) but also freelance interpreters recruited as auxiliary staff (called ACIs (3): Auxiliary Conference Interpreters). Working conditions, remuneration and reimbursement of expenses are governed, for ACIs, by the ‘Conditions of employment of other servants of the European Communities’ and by an Agreement signed between the largest professional organisation of interpreters, the International Association of Conference Interpreters (IACI), and the three EU institutions employing interpreters (i.e. the Commission, the Parliament and the Court of Justice); permanent staff interpreters are governed by the Staff Regulations (4).

9. In 2003 a total of about 150 000 interpretation days was provided to the European institutions. The Council accounted for approximately 39 % of this total, the Commission in Brussels 26 %, the Commission in Luxembourg 4 % and the Parliament 21 %. The other European institutions and bodies (the Court of Justice, the Court of Auditors, the European Economic and Social Committee, the Committee of the Regions, the European Investment Bank, the agencies, etc.) account for the remaining 10 %. On the providers’ side, the DG Interpretation represents about 70 %, the Parliament 27 % (5) and the Court of Justice 3 % of the interpretation services supplied. Table 1 The volume of interpreter/days provided to EU institutions (index 1998 = 100) (6), including the languages of the new Member States 1998 1999 2000 2001 2002 2003 2004 Council 100 96,8 96,3 105,6 109,1 103,9 89,9 Commission 100 101,5 100,4 94,7 85,8 85,1 85,1 Other DG Interpretation 100 95,2 102,7 112,3 91,0 88,8 95,8 Total DG Interpretation 100 98,5 98,5 101,8 98,2 95,0 88,9 Parliament 100 85,0 92,7 97,8 97,7 97,2 103,1 Total 100 93,8 96,5 100,4 98,0 95,8 93,9

10. Table 1 shows that in recent years the EU institutions managed to reduce the use of the interpretation services provided to them. The Council was the only one of the three largest institutions where the number of interpretation days increased between 1998 and 2003, but the new ‘on request’ system introduced as from 1 May 2004 appears to have reversed that trend (see paragraph 27). However, 2004 was a transitional year and may therefore not be representative.

11. The evolution in the use of interpretation services at the Council between 1998 and 2003 is explained not only by the increasing number of meetings, but also by the increasing number of active and passive languages (7) used for meetings at that institution.

12. Article 6 of Regulation No 1 states that ‘the institutions of the Community may stipulate in their rules of procedure which of the languages are to be used in specific cases’. This provision makes it possible to tailor language arrangements to the specific needs of each institution. The institutions have made use of this possibility to differing degrees, as shown in Annex I.

THE AUDIT OBJECTIVE AND SCOPE

13. The objective of the Court's audit was to assess the soundness of the financial management of interpretation services at the Parliament, the Commission and the Council. The audit covered 97 % of the supply of interpretation services (i.e. all supplies, except for the Court of Justice, which has its own interpretation service). In particular, the audit aimed to establish whether the institutions audited have adequate tools and procedures which ensure that: — the interpretation services provided do not exceed the real needs, — all the interpretation services needed can be provided, — interpretation services are provided at the lowest possible cost, — interpretation is of a high quality.

14. The audit covered expenditure during the 2003 financial year, but changes occurring in 2004 as a consequence of the most recent enlargement of the European Union have also been taken into consideration.

OBSERVATIONS

The procedures applied to avoid providing interpretation services which exceed the real needs

15. The actual use of languages at meetings shows that on occasions the interpretation services provided exceed the real interpretation needs (certain participants might prefer using, instead of their mother tongue, another more widely known official language; expected participants might be absent, making certain specific interpretation arrangements superfluous). The Court examined the extent to which the institutions audited have appropriate procedures in place in order to forecast as precisely as possible the expected use of languages and to monitor actual use, so as to dissuade meeting organisers from requesting interpretation services exceeding such forecasts.

Parliament

16. The rules of procedure (see Annex I), which state that each of its Members has the possibility of speaking in the official language of his/her choice and that interpretation is provided into the other official languages, oblige the Parliament to make large interpretation resources available.

17. In order to organise and control the provision of interpretation services, the Bureau of the European Parliament adopted in 1999 a ‘Code of Conduct on Multilingualism’, updated in 2004. The basic principles inspiring this code are that, while respecting the equal rights of the Members, the costs of multilingualism should be kept within acceptable budgetary limits, resources used more effectively and the users of language facilities should be made aware of the necessity for responsible use of language facilities, based on real needs.

18. Interpretation may be requested from the Parliament's Directorate for Interpretation only for the categories of meetings listed in the Code of Conduct (Parliament's plenary sessions, Parliament's governing bodies, committees, delegations, etc.). Interpretation is not available to Members acting individually or to outside bodies, but exceptions may be authorised by the Bureau. The Directorate for Interpretation provides the requested interpretation service according to the priorities and within the limits set in the Code of Conduct.

19. The Code of Conduct, as updated in 2004, states that every parliamentary body needing interpretation services (‘user’ in the wording of the Code) should draw up and regularly update an ‘interpretation language profile’ based on the languages requested and actually used by its Members. This is a very useful tool for ensuring that requests correspond to real needs. However, as no obligation exists for Members of the European Parliament (MEPs) to confirm their presence at a meeting in advance, the ‘interpretation language profile’ is not sufficient to prevent the provision of unnecessary interpretation, if MEPs for which specific interpretation services had been planned do not actually attend.

20. According to the Code of Conduct, at the end of each meeting the head of the team of interpreters is required, in agreement with the secretariat of the meeting, to draw up for the Director of Interpretation a list of the interpretation facilities requested but not used. A copy of that list has to be forwarded to the secretariat of the meeting concerned. In practice, this procedure has applied since September 2004 to committee and delegation meetings.

21. The resources provided in compliance with the Rules of Procedure exceed the real needs if, at a given meeting, not all the supposed official languages are used. The Parliament has never carried out a survey to assess the frequency and the consequences of such cases.

Commission

22. In each Directorate-General (DG) an administrative unit centralises the requests for interpretation support at specific meetings and transfers them electronically to the DG Interpretation, through the DOR (Demande d'Organisation de Réunion) system. Each DG proposes a desired language configuration and ranks the meetings requested for the same day by order of priority. At internal weekly ‘arbitration’ meetings, the DG Interpretation decides which requests can be met, taking into account the availability of interpreters and meeting rooms. At further coordination meetings, specific language configurations are assigned to each of the meetings scheduled to take place six weeks later. The number of active and/or passive languages assigned by the DG Interpretation is often lower than the number initially requested and is the result of negotiations between the DG Interpretation and the DG organising the meeting.

23. At the DG Interpretation, the interpretation team leader is required to draft a session report (rapport de séance), in which he/she indicates what languages have been used during the meeting. In 2004 such reports were drawn up in 82,5 % of the 8 107 meetings with interpretation. In 17,7 % of the reports the team leaders stated that passive interpretation had been requested and provided in excess of the real needs, for one or more of the following reasons: certain national delegations did not speak their official languages, did not speak at all, or were absent. Non-use of active interpretation requested and provided was mentioned in 7,2 % of the reports. These occurrences result in at least (8)1 750 interpreter days paid but not used, costing between 1,5 and 2 million euro.

24. Although the current procedures giving the DG Interpretation the final word in deciding between conflicting requests from different DGs contain the demand, it is difficult for an interpretation service to decide which meetings are more urgent or more important. Other international institutions have implemented systems that are more resource-management oriented: — the Council of Europe has introduced a system of internal billing, — Unesco applies a quota system, whereby the interpretation days exceeding the quota are charged back to the meeting requester. Among the European Union institutions, the Council has adopted the system mentioned in paragraph 27, which increases the cost awareness of national delegations. Under the new Activity Based Management system similar arrangements could be considered by the DG Interpretation.

Council

Procedures applied before the 2004 enlargement of the European Union

25. The nomenclature used before the enlargement to determine the language configuration provided for each meeting was based on tradition and was not regularly updated. There was no procedure to verify whether those attending meetings really needed interpretation into their mother tongue or whether they really expressed themselves in their own language.

26. An excess of languages on offer was shown by a 2001 survey of 799 Council and Commission delegates (9). Although 73 % of the delegates stated that they had the possibility of expressing themselves in their mother tongue, only 59 % of them said they had actually spoken that language. This would often have been the case of delegates who have as their mother tongue a not much diffused language and who are fluent in a more widely known official language. It is improbable that delegates who spoke an official language needed interpretation into their mother tongue from an official language which they used. It is therefore reasonable to consider that the languages for which interpretation is needed are the languages actually spoken at a meeting.

Procedures for the period after the enlargement

27. Decision No 56/04 of the Secretary-General of the Council (10) governing the language arrangements for the period after the enlargement has substantially changed the use of interpretation services. The new system adapts the language arrangements to the real needs of the delegations, increases their cost awareness and gives Member States an incentive to cut down on unnecessary interpretation requests, with a consequent reduction of interpretation costs.

28. As of 1 July 2004, interpretation is no longer provided for the meetings of 25 preparatory bodies (committees, groups and working parties). As a result, the average number of meetings with interpretation held at the Council has decreased from 13 to 11 per day. The full 20/20 language configuration is financed by the Council's budget for meetings of the Council, the European Council and a maximum of 20 preparatory bodies.

29. For other preparatory bodies, active or passive interpretation is only provided if requested by the national delegations. To cover these costs, delegations can draw on a financial allocation of 2 million euro per language. 66 % of any unused amount is transferred to the amount of the budget appropriations for delegates’ travel expenses allocated to the Member State concerned. National delegations have the possibility of adapting their requests every six months, with two months’ notice. As a result, during 2004 one or more languages were dropped from the language arrangements for a number of preparatory bodies.

The capacity to provide all the interpretation services needed

30. Requests for interpretation concerning the pre-enlargement official languages can generally be met. The situation is different for the new official languages, because of an insufficient number of interpreters satisfying the specific linguistic needs (11) of the European Union.

31. The European Personnel Selection Office's (EPSO) competitions for the recruitment of interpreters for the new official languages were not finalised until after the date of the enlargement. There were no successful candidates for Maltese and the number of successful candidates for the other official languages was not sufficient to cover the needs of the EU interpretation services.

32. Difficulties arose in 2004 at the Council, where demand for interpretation into some new official languages was even higher than for the other official languages. The DG Interpretation was not able to meet 37 % of the requests for meetings taking place from May to December 2004.

The cost of interpretation

Cost calculations

Cost calculations made by the audited institutions

33. In order to manage expenditure in accordance with the principles of sound financial management — economy, efficiency and effectiveness — it is necessary to know the full cost of services provided to serve as a basis for a rational allocation of resources.

34. The Parliament has no estimates of the average full daily cost of ACIs and permanent interpreters. It calculates the direct cost (essentially remuneration and reimbursement of travel expenses) only of interpretation services provided by ACIs and does not update its calculations on a regular basis.

35. Each year the DG interpretation calculates an average cost for an interpreter ‘Being Made Available’ (hereinafter: BMA) (12) for a full day or for half a day. This calculation is used as a basis for charging interpretation services to institutions and bodies (interinstitutional billing) to which the DG Interpretation provides interpretation services. As cancelled interpretation orders are also considered as BMA, this concept measures the cost of the interpretation services made available but not the cost of the interpretation services actually used. Moreover, the cost per BMA calculated by the DG Interpretation does not take into account all overhead costs or pension contributions for permanent staff. As all staff pensions are paid from the Commission budget, this method seems appropriate for interinstitutional price setting, but underestimates the full cost per BMA. The same goes for Community tax on the remuneration of permanent and freelance interpreters, which ought to be deducted from the cost, as it is revenue for the EU budget.

Cost calculations made by the Court of Auditors

36. The Court has developed the method described in Annex II for estimating the total cost of interpretation and the full cost per interpretation day performed by ACIs and by permanent staff. The same method was used to calculate the cost to both the Parliament and the DG Interpretation.

37. The results of the auditors’ calculations for 2003 are as follows: Table 2 The cost of an interpretation day provided by a permanent interpreter (euro) Parliament DG Interpretation (Commission + Council) before tax and pension after tax and pension before tax and pension after tax and pension Direct cost (13) 1 205 1 232 942 970 Indirect cost (14) 220 227 227 232 Full cost 1 425 1 459 1 169 1 202

Table 3 The cost of an interpretation day provided by an ACI (euro) Parliament DG Interpretation (Commission + Council) before tax after tax before tax after tax Direct cost 1 390 1 250 839 744 Indirect cost 245 245 168 171 Full cost 1 635 1 495 1 007 915

Table 4 The weighted average and total cost of interpretation provided by permanent interpreters and ACIs (euro) Cost per interpretation day per interpreter Parliament DG Interpretation (Commission + Council) before tax and pension after tax and pension before tax and pension after tax and pension Direct cost 1 292 1 240 886 847 Indirect cost 232 236 195 199 Full cost per interpretation day (15) 1 523 1 476 1 081 1 046 Total number of interpretation days (harmonised method) 38 803 38 803 101 331 101 331 Total cost of interpretation 59,1 mio 57,2 mio 109,5 mio 106,0 mio Total number of BMA calculated by the DG Interpretation n/a n/a 147 751 147 751 Full cost per BMA n/a n/a 742 718

38. At an average cost per interpretation day after tax and pension contributions of 1 476 euro at the Parliament and 1 046 euro at the DG Interpretation, a full-day meeting with full interpretation coverage cost about 40 000 and 34 500 euro respectively before enlargement (11/11 coverage with 3 interpreters per language booth or 33 interpreters in total) and about 88 500 and 63 000 euro respectively after enlargement (20/20 coverage with 3 interpreters per language booth or 60 interpreters in total). Where there are 4 interpreters per booth, which is not uncommon for meetings at the Parliament, the interpretation cost for a one-day meeting can amount to 118 000 euro (or 84 000 euro if the interpretation is provided by DG Interpretation). A meeting with a small 3/3 regime (English, French and German as passive and active languages, with 6 interpreters in total) costs just 8 900 euro at the Parliament and 6 300 euro at DG Interpretation. This illustrates the importance of basing requests for interpretation on real needs.

Analysis of the cost of interpretation

Parliament

39. Although the remuneration system of permanent and freelance interpreters is the same for both institutions, the Parliament's cost per interpretation day is much higher than at the DG Interpretation. The Court found that this difference is mainly due to a number of constraints on which the management has little influence, namely: (a) Unlike in Brussels, there are very few local (16) freelance interpreters in Strasbourg. This increases freelancers’ travel and hotel expenses. In 2003, these costs represented 22 % of all payments to ACIs. Two thirds of the ACIs hired by the European Parliament in 2003 were non-local, as against less than 40 % of those hired by the DG Interpretation. (b) As all staff interpreters are based in Brussels and 12 plenary session weeks a year are held in Strasbourg, the Parliament total travel costs for permanent staff are much higher than at the Commission. (c) Shorter working weeks with relatively little parliamentary activity on Mondays, Thursday afternoons and especially on Fridays, and a much higher demand for interpretation services during plenary session weeks in Strasbourg than during weeks in Brussels where only committee or political group meetings take place mean that many permanent interpreters spend up to 32 days a year without an assignment. (d) Late-evening or night meetings are frequent at the Parliament. The consequence is that the interpreters have a right to paid rest for the next morning or day and other interpreters must be recruited. At the Commission, and to a lesser extent at the Council, these kinds of meetings are exceptional.

The DG Interpretation

40. The ACIs hired by the DG Interpretation generally cost significantly less than permanent staff (see also paragraphs 59 to 62). As the number of interpretation days provided by permanent staff dropped by 4 % from 2002 to 2003 the cost difference between both categories of interpreters inevitably increased in 2003.

41. Most ACIs hired by the DG Interpretation are local or near-local (55 % of the contract days of ACIs in 2003 and 59 % in 2004) requiring little or no hotel and travel costs and allowances. As they are remunerated only for the days for which they have been contracted, local freelancers cost less than permanent interpreters. Non-local ACIs, on the other hand, are more expensive, as a study carried out on behalf of the Commission shows (17).

Other questions affecting the cost of interpretation

Parliament

Late requests and cancellations

42. Providing interpretation services at short notice is particularly costly, as travel expenses may have to be paid to ACIs for a short work assignment (for example, a single meeting), whereas requests made sufficiently in advance make it possible to plan the employment of freelance interpreters for a longer period (for example, a full week in which various meetings are held).

43. The audit showed that, in 2003, in a large number of cases the deadlines set by the Code of Conduct were not respected: 853 requests (an average of 17 per week) and 650 cancellations (13 a week on average) were made after the deadline.

44. Late cancellation of meetings, although sometimes unavoidable, causes a waste of financial resources if the interpreters assigned cannot be switched to other meetings. If the interpreters used are ACIs, their remuneration is a pure loss for the institution; if they are officials, they could have been employed for other meetings for which ACIs had been recruited on the assumption that permanent staff were not available. The ‘GERI’ (acronym for Gestion des Réunions et des Interprètes) computer system used at the Parliament in 2003 makes it possible to determine the number of half-days of interpretation requested and made available, but not needed due to the cancellation of meetings (18). In 2003, this totalled 6 298 half-days (2 864 half-days for permanent staff and 3 434 half-days for ACIs). This corresponds to about 8 % of the interpretation days performed and 7,5 % of those requested. As a result, about 4 million euro was spent on services made available but not used. Better planning could have allowed the staff interpreters assigned to the cancelled meetings to replace ACIs employed for other meetings (on this question see also paragraph 47).

Commission

Cancellation or short duration of meetings

45. The late cancellation and the short duration of meetings, together with DG Interpretation's need to hold a few interpreters per language in reserve, so as to cover last-minute meetings or unforeseen absences of interpreters, are the main reasons behind the high number of cases of so-called ‘implicit or explicit stand-by duty’ (19), i.e. interpreters who are present but have to be put on stand-by because their services are not needed. In 2003, permanent interpreters spent on average 33 days on ‘implicit stand-by duty’. A high number of cases of ‘implicit stand-by duty’ (about 130 interpreters per day, corresponding, in 2003, to more than a quarter of the number of the staff interpreters) occur in August when very few meetings take place. As a result, a total of 15 000 interpreter days, corresponding to around 15 % of the working days of the staff interpreters, were not used. ACIs had a total of more than 6 000 days of ‘implicit stand-by duty’. The total cost of ‘implicit stand-by duty’ in 2003, at an average cost of 865 euro per day, available for interpretation (20), can be estimated at about 18 million euro. While a significant portion of the standby costs may be unavoidable under the current working arrangements, every effort should be made to reduce those costs.

46. In 2003, 15 % of the interpreter days requested by Commission departments were cancelled, but no figures are available for the number of cases in which no resources were lost because the interpreters booked for the cancelled meetings could be assigned to other meetings.

47. In 2003, there were nine working days on which at least 100 permanent interpreters (or more than 20 % of the total number of permanent interpreters) assigned to cancelled meetings were on ‘implicit stand-by duty’ whilst at the same time more than 100 ACIs had been recruited.

48. Meetings lasting a very short time result in a kind of ‘implicit stand-by duty’, as interpretation is needed only for a small part of the interpreter day or half-day booked. One reason for very short meetings is that some working parties, whose meetings are scheduled at regular intervals, meet even when they have very few, non-urgent points on the agenda.

Council

Cancellation of meetings

49. In 2003, according to the Council's own estimates, more than 5 % of the Council's interpretation expenditure (2,4 out of 45,7 million euro) represented payments for cancelled meetings, where the interpreters could not be employed by the Council for other meetings held on the same day. This corresponds to a net yearly waste of almost 4 000 interpreter days.

Meetings invoiced at higher rates

50. Late requests for new meetings or for the addition of one or more languages, made fewer than six working days before the meeting, were invoiced in 2003 at the rate of 835 euro, that is about one third more than the normal rate of 632 euro. In 2003, these late requests corresponded to about 3 % of the total amount invoiced to the Council.

51. It is important to make meeting organisers aware of the high cost of cancellations and late requests. The statement of the cost of cancelled meetings sent at the end of each month to the Head of the central coordination unit of the Member State holding the rotating Council Presidency can be regarded as an example of good practice if exploited for management purposes.

The interinstitutional billing system of the DG Interpretation

52. In order that the DG Interpretation recovers the costs of the interpretation services provided to other institutions (costs that are to be charged to the administrative budget of these institutions) an interinstitutional billing system has been set up, based on ‘service level agreements’ between the DG Interpretation and the institutions concerned.

53. In 2003 the DG Interpretation invoiced the Council at a basic rate of 632 euro per day or 369 euro per half-day for interpreters ordered at least six weeks in advance for meetings held in Brussels. Higher rates were applied to missions and late orders.

54. The following points were noted with respect to the current billing: (a) The price structure is not based on the real cost of each type of request (timely requests, late requests, requests withdrawn, requests for languages with higher ACI travel costs, etc.). (b) For the DG Interpretation revenue standard rates based on an estimated level of activity are used. Most of the costs borne by the DG Interpretation are fixed costs (only the cost of the ACIs is entirely variable). As a result, if the volume or the composition of the actual demand for interpretation services is different from that forecast, the DG Interpretation incurs either a deficit or a surplus. (c) The price does not incorporate the full cost of the interpretation services, because, as mentioned in paragraph 35, it does not include all overheads. (d) The limitation of the number of interpreters and meetings per day specified in the Service Level Agreement prevents high peaks in demand, but does not prevent troughs (early January, August, etc.). (e) The lack of a link between the computer systems of the Council and the DG Interpretation makes the billing labour intensive and error prone. The downward corrections made to the 2002-2003 DG Interpretation invoices sent to the Council amounted to almost 6 % of the amount initially invoiced.

The interinstitutional cooperation

55. Based on the work of the Interinstitutional Committee on Translation and Interpretation (ICTI) and the ‘Chêne Report’ (21) of 2002, considerable progress was made towards more cooperation between the EU institutions in the area of interpretation. The main achievements include: — joint competitions for staff interpreters organised by EPSO, — a joint selection procedure and a joint list of accredited ACIs, — a common system and unit for payments to ACIs (since October 2004), — an exchange of interpreters for the new languages, who are in short supply.

56. Further savings and efficiency gains could be made in several other areas, but enhanced cooperation is hampered by the current organisation involving three independent interpretation service providers (the DG Interpretation, the Parliament and the Court of Justice).

57. The division of labour between the Parliament and the Commission (the DG Interpretation) is not efficient for the following reasons: (a) Both institutions are competing to recruit ACIs for meetings in Brussels. (b) The institutions do not systematically communicate their availability or need of resources to each other. The DG Interpretation recruits ACIs on days on which the Parliament still has permanent interpreters without any task assignment. Where meetings are cancelled or interpreters are only needed for half a day or less, the separate organisational structures combined with the lack of information flowing between both institutions make it almost impossible for the other institution to use these resources. During the European Parliament election period (from 10 May to 2 July 2004), dozens of permanent Parliament interpreters, especially from the smaller languages, had no task assignment. At the same time, the DG Interpretation hired on average 253 ACIs per day, resulting in significant costs charged to budget appropriations (more than 900 euro per day and per interpreter). (c) The current organisation makes it more difficult to reduce travel costs by taking advantage of the presence of non-local ACIs already contracted by the other institution for adjacent days. (d) Further economies of scale in human resources, financial, operational and IT management and the integration of IT systems could be achieved through a common organisation.

58. It should therefore be analysed whether the abovementioned problems could be solved by creating one single interinstitutional office or agency providing interpretation services to all EU institutions or by improving the interinstitutional cooperation. Centralising the provision of interpretation services would be compatible with the autonomy of each institution, as proven by the fact that the Council has relied on the Commission for the provision of interpretation for years, without any noteworthy disruptions. The Service Level Agreement signed between the Council and the DG Interpretation shows that it is perfectly feasible to guarantee the client institution an agreed number of interpreters per day.

Specific observations concerning the expenditure for freelance interpretation

The optimal ratio of permanent to freelance interpreters

The DG Interpretation

59. The appropriateness of employing ACIs instead of permanent staff depends on a large number of factors such as the way in which meetings are spread out over the year and the week, the availability of local freelance interpreters or the distance between the professional domicile of the interpreter and the meeting venue. The Court considers that the results of the study already mentioned made on behalf of the DG Interpretation (17) are generally valid. They indicate, as a global optimal ratio, 51 % of interpretation days to be performed by permanent interpreters. The share of interpretation days performed by permanent interpreters dropped from 53 % in 2000 to 46 % in 2002 and 2003, but went up to 50 % in 2004.

60. However, an overall target ratio of 51:49 is not suitable for all languages. The DG Interpretation has not calculated the optimal ratio for each language. For example, the ratio of Dutch-speaking freelancers (54 % in 2003) should be higher, as many ‘locals’ (ACIs living in or around Brussels) and not so costly ‘non-local’ (ACIs living not far from Brussels) freelancers are available.

61. On the other hand, more permanent interpreters might be recruited, for example, for Portuguese and Greek, as travel costs for Greek and Portuguese ACIs are above the average for all the ACIs. For these languages, the reliance on ACIs is relatively high (respectively 59 % and 67 % of the interpretation days in 2003), permanent interpreters have one of the highest workloads of all languages (116 and 108 days respectively, against 104 on average in 2003) and the percentage of local ACIs is the lowest (only 30 % for Portuguese and 42 % for Greek against an average of 56 % in 2003).

Parliament

62. The Parliament has not made any specific calculation in order to establish the optimal proportion of freelancers and permanent interpreters. In 2003, 57 % of the interpreter days were provided by ACIs. Notwithstanding the higher cost, a higher percentage of freelance interpretation than at the DG Interpretation seems justified because of more uneven demand. However, the five languages with the highest percentage of freelance interpretation (in decreasing order: Spanish, Italian, English, Finnish and Swedish) are languages for which the travel costs of ACIs are above average.

The allowances of ACIs

Reimbursement of travel expenses and daily allowances

63. The travel costs for ACIs are substantially higher than for permanent officials. Due to the Agreement, which grants ACIs a travel allowance, a daily allowance and reimbursement of travel and hotel costs, ACIs benefit from more favourable travel conditions than their permanent colleagues. For meetings held outside Brussels, this results in unequal travelling conditions for interpreters of the same level performing the same job. According to IACI Agreements with other international organisations, ACIs benefit from the same conditions for reimbursement of travel expenses as permanent staff of a similar level (22).

64. According to Article 10 of the Commission rules implementing the Agreement between the IACI and the EU institutions (23), an ACI is entitled to the reimbursement, on presentation of supporting documents, of an exchangeable and reimbursable IATA ticket at the lowest rate that is not subject to quotas. The implementing rules applicable to the ACIs working for the Luxembourg-based EU institutions (24) contain a similar clause.

65. The Agreement should be changed to ensure that an ACI is generally paid no more than the amount corresponding to the cost of a ticket with restrictions (i.e. a ticket at the lowest rate). This amount should, however, also be paid in the event of no show due to illness, cancellation of the meeting or any other reason beyond the ACI's control.

Parliament

66. An examination of a sample of payments made to ACIs showed that a majority of the ACIs travelling by plane obtained reimbursement of a business class ticket, without any evidence, in the file, of the necessity of buying such a ticket.

67. Contrary to the rules stating that an ACI is not entitled to a full daily allowance when a permanent official would get only part of such an allowance, a full daily allowance is granted even for a period of less than 12 hours (25).

The DG Interpretation

68. An examination of a sample of 17 payments made to ACIs who travelled by plane showed that four of them obtained reimbursement of a business class ticket, without any evidence, in the file, of the necessity of buying such a ticket.

Comparison with other international organisations

69. The daily fee paid by the European institutions in 2004 at a fixed rate of 483,98 euro per day for experienced interpreters is in line with current market conditions in the private sector. However, it is lower than the gross average rate paid by other international organisations, which have also signed Conventions with the IACI. The much higher volume of employment and the longer contracts that the EU institutions are able to offer, as well as the favourable tax treatment (ACIs pay a community tax and are as a consequence exonerated from national income taxes) explain the difference.

70. The effect of the favourable tax treatment is that, in spite of a lower gross rate, the net amount received by the freelance interpreter from DG Interpretation and the Parliament is higher than the net amount earned by working for the private sector or for other international organisations. This means that the EU institutions can afford to apply high standards in recruiting ACIs, but also have to carefully observe the market conditions in order to avoid overpaying their ACIs.

71. Contrary to the European institutions, the Organisation for Economic Cooperation and Development pays a reduced rate in the case of cancelled meetings, meetings which end early and general or non-technical meetings (26).

The quality of interpretation

Parliament

72. A survey performed by the Court amongst the political groups did not reveal any complaints about the quality, reliability or helpfulness of the interpretation service, but the limitation of interpretation sessions to three and a half hours was considered too restrictive.

Commission and Council

73. About 1,2 % of the session reports (27) in 2003, and 0,5 % in 2004, mentioned an informal complaint, mainly concerning the language arrangements. A 2001 evaluation of the quality of interpretation services provided by the DG Interpretation conducted by external consultants, including a survey among the delegates attending Commission and Council meetings with interpretation, showed that 91 % of these delegates were generally satisfied or very satisfied with the quality of the DG Interpretation's interpretation. The weakest point was considered to be the knowledge of the issues discussed at the meetings. This problem seemed to be linked to late distribution or unavailability of the meeting documents, which the interpreters’ survey pointed out as the biggest problem. More than half of the interpreters were dissatisfied with the documentation. Particularly the unavailability of the documentation in their active language was considered to be a problem.

74. Since the fourth quarter of 2003, the DG Interpretation has requested the meeting organisers to complete a short questionnaire after each meeting. 94 % of them have declared themselves very satisfied or satisfied with the DG Interpretation's services and the quality of interpretation.

75. This picture was largely confirmed to the auditors by various Heads of the central coordination unit created by each Member State holding the rotating Council Presidency (hereafter called Council Presidency Coordinator) and meeting requesters at the Commission. The quality of interpretation was almost unanimously mentioned as the main strength of the DG Interpretation.

76. As an aid to ensuring the quality and consistency of interpretation, the DG Interpretation's interpreters have at their disposal on-line multilingual glossaries for a large number of subjects. Meeting documentation, on the other hand, is often only available in English and has therefore to be supplemented by the interpreters themselves through database searches. Quality could also be further improved through more stable interpretation teams for successive meetings. This seems particularly appropriate for the most technical meetings.

77. The helpfulness of the officials of the DG Interpretation is also considered to be one of the DG Interpretation's main strengths. In the event of the interpretation request being partly or entirely turned down by the DG Interpretation during its weekly arbitration or coordination meetings, the requested meeting is normally rescheduled to the following week or held with a reduced language configuration. Any significant delays in the progress of committees or working groups are said to be exceptional.

78. The most frequently mentioned negative point during the Court's interviews with Commission and Council clients was, as in the Parliament, the limitation of interpretation sessions to three and a half hours.

79. The Council has no system for evaluating the quality of interpretation and measuring the satisfaction of the delegates.

80. The 2002-2003 Council Presidency Coordinators interviewed by the Court's auditors almost unanimously mentioned the quality of interpretation as the main strength of the DG Interpretation. Official complaints on the part of meeting organisers or delegations are exceptional. In both 2002 and 2003 the DG Interpretation received only four or five such complaints, of which each year only two were linked to the quality of the interpretation.

81. Council Presidency Coordinators also consider that the required six weeks’ advance notice imposed by the DG Interpretation is too long and inevitably entails a large number of changes. It was also suggested that clearer and more detailed written instructions addressed by the Secretariat-General to the Council Presidency Coordinator and to the meeting organisers would make it possible to improve the planning of meetings and to avoid the frequent cancellation of meetings especially during the first weeks of a new presidency.

CONCLUSIONS AND RECOMMENDATIONS

The procedures applied to avoid providing interpretation services which exceed the real needs

82. The audit found that the institutions have managed to contain expenditure on interpretation over the past five years despite an increase in the number of official languages from 11 to 20 in May 2004. Systems to ensure that interpretation is only provided when there is a real need have been set up by the Commission and the Council. The best practices observed in these institutions should be extended to the Parliament (paragraphs 15 to 29).

The capacity to provide all the interpretation services needed

83. The needs for interpretation concerning the official languages prior to enlargement are generally met, but an insufficient number of interpreters is available to interpret from the new official languages or into the new official languages (paragraphs 30 to 32).

84. The increase in the number of working languages raises practical and financial problems that can only be overcome by controlling the demand for interpretation services and the related costs. The accession of small countries creates a huge increase in demand in small interpretation markets, where supply is rather limited, making it increasingly difficult to meet all requests for interpretation. The EPSO competitions organised to select staff interpreters for the new languages were not finished until after the date of the enlargement and did not provide enough successful candidates to cover the needs of the EU interpretation services (paragraphs 30 and 31).

The cost of interpretation

85. Around 80 % of the cost of interpretation is accounted for by the remuneration of the interpreters. Additional costs relate to management, administration, training, information technology, etc. The Court estimates that in 2003 the full cost of the interpretation services provided by the Parliament and by the DG Interpretation was around 57 and 106 million euro respectively. Including the Court of Justice, the total cost of interpretation of the EU institutions before the enlargement of the Union can be estimated at about 170 million euro. The cost of an interpretation day at the Parliament is much higher than at the DG Interpretation, mainly because of the way in which the Parliament's meetings are organised (paragraphs 33 to 41 and Annex II).

86. Despite the measures taken to contain and reduce interpretation costs, there is still the potential for further savings through better management of meetings, in particular by ensuring that last-minute changes and cancellations are kept to a minimum (paragraphs 42 to 51).

87. Furthermore, the institutions should review their policy for the level of reserve interpretation resources kept on standby, in order to minimise the costs involved (paragraph 45).

88. As shown in paragraphs 44 and 49, in 2003 at the Parliament and the Council over 6 million euro was spent for interpretation services requested but not used because of the cancellation of meetings. Meetings were cancelled also at the Commission, but, for the reason set out in paragraph 46, the cost of the cancellations cannot be estimated.

89. The Commission provides interpretation services to itself and the Council and other institutions through DG Interpretation. Interpretation costs are billed to the other institutions — which represents an effective resource management tool — but the Court found that the billing rate does not take account of the full costs. While this has no net effect on the EU budget, it could result in inappropriate management decisions concerning the use of available resources.

90. Cost savings could also be achieved through a stricter application of the Agreement with the IACI, a further integration of computer systems and closer interinstitutional cooperation.

91. As to the Agreement with the IACI, consideration should be given to the possibility of negotiating an agreement to let them benefit from the same arrangements as exist for permanent staff. The example of the United Nations shows that a centralisation of travel arrangements for freelance interpreters is feasible (28). Consultations with the IACI could be started on the basis of Article 19 of the Agreement, with a view to amending the Agreement on this point (paragraphs 63 to 71). Consideration should also be given to the possibility of negociating special fares for ACIs with travel agencies, air companies, hotels, etc.

92. The general policy of providing interpretation either by permanent staff or by ACIs is not clear-cut, but depends on a large number of factors: the way in which meetings are spread out over the year and the week, the availability of local freelance interpreters, the required language combinations, the distance between the professional domicile of the interpreter and the meeting venue, etc. Local ACIs generally cost less than staff interpreters, whereas non-local ACIs are on average more expensive (paragraphs 39 to 41).

The quality of interpretation

93. The users are generally satisfied with the quality of the interpretation services provided (paragraphs 72 to 75), although many users have called for greater flexibility in the time limits established for meetings.

Possible developments

94. An independent evaluation should be made of the possible benefits of creating one single interinstitutional office providing interpretation services to all EU institutions, compared with those from an increased interinstitutional cooperation (paragraph 58).

95. Each enlargement of the European Union has led to an increase in the number of working languages and the complexity of demands for interpretation services. This report shows that, without calling into question the principle of multilingualism, the institutions have been able to take pragmatic steps to limit and control interpretation costs. The Court recommends that the institutions should continue such efforts.

This Report was adopted by the Court of Auditors in Luxembourg at its meeting of 22 September 2005. For the Court of Auditors Hubert WEBER President

(1) Council Regulation No 1 of 15 April 1958 determining the languages to be used by the European Economic Community (OJ 17, 6.10.1958, p. 385/58), as amended.

(2) Before the May 2004 EU enlargement, the DG Interpretation employed nearly 500 staff interpreters, the Parliament over 200 and the Court of Justice 33.

(3) Freelance interpreters are also known under the French acronym AIC (Auxiliaire Interprète de Conférence).

(4) The Staff Regulations of officials of the European Communities and the Conditions of employment of other servants of the European Communities are laid down in Council Regulation (EEC, Euratom, ECSC) No 259/68 (OJ L 56, 4.3.1968, p. 1), last amended by Regulation (EC, Euratom) No 723/2004 (OJ L 124, 27.4.2004, p. 1).

(5) For statistical purposes, the DG Interpretation defines an interpreter day as two half-days during which an interpreter really did at least some interpretation (i.e. excluding travelling and all other activities). Because the DG Interpretation, the Parliament and the Court of Justice use different methods to calculate the number of interpreter days provided, the auditors have adjusted the figures for the other institutions to make them comparable with the DG Interpretation's figures in order to calculate the share of each institution in the total consumption and to calculate the cost per interpretation day.

(6) To facilitate comparison, 1998 was chosen as the base year because 1998 and 2003 are both years preceding a year of Parliamentary elections and a renewal of the Commission. Moreover, both years had the same number of official languages (11), as the penultimate EU enlargement took place in 1995.

(7) Active languages are languages into which interpretation is provided. Passive languages are the languages which can be spoken at the meeting. If the number of active and passive languages is not the same, the meeting has an asymmetric language configuration. Example: a 7/6 configuration is a configuration with 7 passive and 6 active languages.

(8) Based on the prudent hypothesis that the problem affected only one delegation. The average cost of an interpreter day is shown in Table 4.

(9) Algoé Consultants, Evaluation de la qualité des prestations fournies par le SCIC en matière d'interprétation, Lyon-Ecully, 26 June 2001.

(10) Decision of the Secretary-General of the Council/High Representative for the Common Foreign and Security Policy No 56/04 of 7 April 2004 concerning interpretation for the European Council, the Council and its preparatory bodies, SN 1327/04 REV 1.

(11) To ensure high quality interpretation, EU interpreters are, in principle, requested to provide interpretation only into their mother tongue. The high number of working languages makes it very difficult to find interpreters for all language combinations.

(12) This is a translation of the French term mise à disposition (MAD) used at the DG Interpretation. All interpreters ordered and not cancelled at least six working days before the meeting are invoiced as BMA.

(13) Direct costs are the remunerations of staff interpreters and ACIs, including travel and subsistence allowances.

(14) Indirect costs are defined here as all other costs related to the interpretation activity: remunerations of management and staff responsible for planning, finance, human resources management and other administrative tasks, training, IT and office costs, etc.

(15) The figures for the average full cost per interpretation day in 2003 (1 081 euro before tax and pension or 1 046 euro after tax and pension) are much higher than the cost per BMA because they include more overhead costs than those considered by the DG Interpretation and take account only of full interpretation days (or two half-days) for meetings which actually took place, whilst, as set out in paragraph 35, cancelled meetings and half-day meetings also count for the calculation of the cost per BMA as such meetings are charged to the meeting organisers.

(16) Local ACIs have their declared professional domicile within less than 60 kilometres from the meeting venue.

(17) PriceWaterhouseCoopers, Etude sur le coût total des interprètes fonctionnaires et des interprètes A.I.C., 5 October 2001.

(18) In ‘GERI’ the unit of measurement of the employment of interpreters is the ‘half-day’. When a meeting is cancelled in GERI, the interpretation half-days allocated to that meeting are automatically shown as ‘suspended half-days’ (demi-journée suspendue) for each interpreter booked for the meeting. Should the available interpreter be reassigned to another meeting, then the ‘suspended’ code is replaced by the code of the new meeting. Hence, the sum of all the ‘demi-journées suspendues’ in GERI is the ‘net loss in interpretation resources’ expressed in half-days.

(19) ‘Implicit’ stand-by duty differs from ‘explicit’ stand-by duty in that the latter corresponds to reserve teams included in the planning to replace absent interpreters. According to the established working conditions (‘Provisions applicable to staff interpreters’, SCIC (87)25), interpreters can be assigned to meetings for a maximum of 18 sessions (half-days of 3,5 hours) per period of two weeks.

(20) The average cost per day available for interpretation is calculated as the total cost of the DG Interpretation after tax and pension calculated above (106 million euro) divided by the sum of interpreter days (101 000) and implicit stand-by duties (21 000).

(21) Report of the ad hoc Working Group of the CITI, Synergies et économies d'échelle susceptibles d'être obtenues grâce à la coopération entre les services d'interprétation et de traduction des institutions et des organes communautaires, Brussels, 22.4.2002.

(22) Article 15 of the Agreement governing the conditions of employment of conference interpreters remunerated by the day between the IACI and the Coordinated Organisations (Accord régissant les conditions d'emploi des interprètes de conférence rémunérés à la journée entre l’AIIC et les Organisations coordonnées) stipulates that, save as otherwise provided and mutually accepted, the rules governing travel expenses are to be those in force in each Organisation; this is confirmed by Article 2 of the Additional Agreement between the IACI and the Council of Europe, which stipulates that the conditions of travel and reimbursement of expenses applicable to Council of Europe staff on duty travel are to apply to interpreters.

Article 13 of the IACI-United Nations Agreement (2000-2005): ‘Except as may be otherwise provided in this Agreement, the travel rules applicable to the regular staff of the employing organisation on missions of similar duration shall be applicable to the travel of the freelance interpreters employed thereby. (…)’.

(23) European Commission, Rules for implementing certain provisions of the Agreement (Modalités d'application de certaines dispositions de la Convention).

(24) Provisions for implementing the Rules concerning freelance conference interpreters working for the Luxembourg-based institutions (Dispositions d'application relatives aux Réglementations concernant les interprètes de conférence free-lance travaillant pour les institutions de Luxembourg), § III. Travel expenses.

(25) Article 9§2 of the Agreement mentioned in paragraph 8 states that ‘the daily subsistence allowance and supplementary daily allowance for interpreters who are not staff members of an institution shall be equal to the mission allowance paid to LA4 and LA8 officials in the institution which applies the most favourable rate. For interpreters whose contracts are covered by Article 78 of the CEOS, the rate shall be that in force in the institution for which they have been recruited’.

(26) See ‘Terms and conditions of employment of free-lance interpreters at the OECD in 2003’.

(27) See paragraph 23.

(28) See also Article 14 of the IACI — United Nations Agreement (2000-2005): ‘When an organisation offers the interpreter a contract it shall endeavour to inform him of the arrangements it intends to make for transportation. If the interpreter accepts the contract, he shall accept whatever travel arrangements are made, unless his professional obligations prior to and subsequent to his contract are such as to render impractical, in the opinion of the organisation, participation in such arrangements. (…)’.

ANNEX I The specific provisions applying at the Parliament, the Commission and the Council Parliament 1. According to Rule 138 of the Parliament's Rules of Procedure, all Members have the right to speak in Parliament in the official language of their choice. Speeches delivered in one of the official languages are simultaneously interpreted into the other official languages. The same Rule also states that in committee and delegation meetings interpretation is provided from and into the official languages used and requested by the members of each committee or delegation. In practice, for all plenary sessions and a number of meetings of large political groups, interpretation is provided from and into all official EU languages (11 active and passive languages before enlargement, 19 after enlargement because of insufficient availability of Maltese interpreters). For parliamentary committee meetings, interpretation is provided for the languages of all committee members. Commission 2. As far as the use of languages is concerned, the Commission's Rules of Procedure (1) and their implementing rules (2) allow more flexibility. For meetings of the European Commission itself, there is interpretation in just three languages (English, French and German). For ‘Comitology Committees’ (3), the number of languages differs from one Committee to another, taking into account the requests of the national delegates. In most cases, these committee meetings are held with interpretation into between three and seven languages. Council 3. Pursuant to Regulation No 1 and Article 14 of the Council's Rules of Procedure, full interpretation (11 active and passive languages before enlargement, 20 languages after enlargement) is provided for Ministers’ meetings. Coreper (the Committee of Permanent Representatives) meetings are held with only three active and passive languages (English, French and German). For the numerous other preparatory bodies (committees, groups, working parties), a particular language configuration is agreed at the time each body is set up. The language configurations for each body are listed by the General Secretariat of the Council in a specific nomenclature. 4. When receiving meeting requests from the Council's Presidency, the Conference Unit of the General Secretariat of the Council automatically assigns a language configuration to each meeting request according to the nomenclature. All requests for meetings with interpretation are met by the DG Interpretation as long as the total number of meetings with interpretation and the number of interpreters per day do not exceed the ceilings set in a ‘Service Level Agreement’ (SLA), concluded between the Commission (the DG Interpretation) and the Council in December 2002 in order to formalise the main obligations of both parties. (1) Rules of Procedure of the Commission, C(2000) 3614 (OJ L 308, 8.12.2000, p. 26). (2) Rules to give effect to the Rules of Procedures of the Commission, C(2001) 1. (3) Advisory Committees, Management Committees and Regulatory Committees governed by Council Decision 1999/468/EC of 28 June 1999 laying down the procedures for the exercise of implementing powers conferred on the Commission (OJ L 184, 17.7.1999, p. 23) replacing Decision 87/373/EEC (OJ L 197, 18.7.1987, p. 33).

ANNEX II The cost calculation method developed by the Court 1. The full budgetary cost (cost before tax and pension) to the DG Interpretation, as calculated by the Court's auditors, is equal to the full cost used by the DG Interpretation to set the interinstitutional billing rates plus the overhead costs not included in the DG Interpretation calculations (cost of senior management and support staff involved in activities concerning budgetary and financial matters, human resources management and general administration). 2. By deducting the Community tax paid by staff interpreters and ACIs from the ‘cost before tax and pension’ and by adding the fictitious employer's pension contributions for staff interpreters (which are equal to twice the contribution paid by the official) (1), the cost to the Community budget is obtained (cost after tax and pension). For ACIs the full budgetary cost already includes the pension contributions paid by both the ACI and the EU institutions to an external body. (1) According to Article 83(2) of the Staff Regulations a contribution corresponding to one third of the cost of financing the pension scheme is deducted monthly from the salaries of officials. In consequence, the ‘employer's contribution’ is twice the official's contribution.

EUROPEAN PARLIAMENT'S REPLIES V. Within the Interpretation Directorate, the Meetings and Conferences Unit checks whether requests for meetings accord with the rules in force before agreeing to providing interpreting services. VII. The European Parliament stresses that, as a political institution, it must be capable of responding rapidly to political situations which by definition are in certain cases impossible to schedule. A code of conduct was adopted in 1999 and updated in 2004 in order to establish rules to provide a better framework for the provision of interpreting services. While many meetings organised at the other two institutions referred to in this report may not require interpretation services, parliamentary meetings generally do (1). VIII. Session reports exist for meetings of committees and delegations; they will be extended to other types of meetings, including those of the political groups. Regular drafting of periodic reports to cultivate awareness among users has suffered on account of technical difficulties. The administration undertakes to improve the situation as from September 2005. 19. Even if Members were required to confirm in advance that they would be attending a particular meeting, numerous difficulties would be encountered in attempting to respect the language profile of a meeting, including the obligation to cover language needs arising from the attendance of Ministers, Commissioners and invited experts at meetings. 20 and 21. The interpreting services regularly check with user services the need for the resources requested; since September 2004, in order to ensure optimal use of resources, they have also been making use of the reports drawn up after committee and delegation meetings, and they will shortly also start to use those drawn up after political group meetings. User services (committees and delegations) keep the language profiles of their meetings up to date in order to enable the Interpretation Directorate to make optimal use of resources. This information will be periodically forwarded to Parliament's Bureau so that it can, if appropriate, decide on any changes that may be necessary. 30. The EP notes (Rule 139 of the Rules of Procedure) the fact that cover of the new official languages introduced at the time of the most recent enlargement is as yet incomplete, because of the lack of qualified personnel, whose training is a matter for the Member States. 31. Although the competition organised by EPSO to recruit Maltese interpreters was unsuccessful, Maltese is covered at part-sessions in Strasbourg by recruiting freelance interpreters; in 2006 it will also be covered at part-sessions in Brussels thanks to the availability of Maltese interpreters from a training programme financed by the institutions. 33 and 34. The EP's administration records the direct cost of interpreting services provided by freelance interpreters in accordance with the rules in force, and regularly updates the average cost of a day's interpretation provided by a freelance. It undertakes to study and possibly adopt the method of calculation proposed by the Court in order to improve knowledge of the overall cost of the services provided, including those provided by staff interpreters, and to make available the necessary resources for management of these data. 38. The difference observed between the costs of an interpretation day at the EP and DG Interpretation is explained well in the following point 39, where the Court indicates the specific constraints which characterise the EP's work. 39. The excessive concentration of meetings in one part of the week or day (point 39(c)) is mainly attributable to the need for political groups to respect deadlines for tabling amendments before their written translation. The introduction of nine new languages has made it necessary to bring this deadline forward from the Thursday morning to the Wednesday evening before a part-session, the corollary of which is a concentration of meetings on Wednesday. The interpretation services are aware of the need to improve the use of resources, and have therefore increased interinstitutional cooperation to mutually make permanent staff interpreters available, and hope to increase this practice, particularly during periods when there is little work at Parliament. In 2004, the departments responsible for organising parliamentary committee and delegation meetings succeeded in increasing the number of meetings scheduled for Thursday afternoons. Meetings are held at late hours at the EP (point 39(d)) as a result of decisions taken by the political bodies on the organisation of work; most are accounted for by meetings held during Strasbourg and Brussels part-sessions, certain meetings of the Committee on Budgets during the budget adoption period and certain meetings of conciliation committees. They represent a very small proportion of the total volume of work and are an integral part of the work pattern proper to the parliamentary institution of the 25 Member States. 42. The high cost of providing interpretation services at short notice reflects the organisational flexibility required within the EP. As indicated in the reply to point VII above, meetings may be requested at short notice as Parliament is called upon to respond to political events. 43. The late cancellation of meetings to which interpreters have been assigned and the scope for perfecting the planning of work are cost factors which the administration regularly draws to the attention of users. It has been decided that their awareness should be fostered more by regularly informing them of the cost of these late cancellations. However, the figures quoted by the Court should be placed in perspective in order to avoid any misunderstanding. Many meetings consist of a series of sub-meetings held in the course of a single day (coordinators, chairman and vice-chairmen, working groups, etc.): the cancellation of one or more of these sub-meetings does not have any budgetary implications if the interpreters have worked during other sub-meetings. Moreover, the figures for cancellations of meetings also include ‘technical’ cancellations which do not have any impact on the interpretation budget because they merely entail rescheduling the same meeting which has already been requested while altering the timing, meeting room, place of work or languages requested. 44. In managing interpretation, it is necessary to reconcile the budgetary approach, which focuses on payments to freelances (freelances are paid a fixed daily amount, even if they work only during one brief meeting), and the timetabling of Parliament's work, where half-day slots or even shorter periods apply. Consequently, the budgetary impact of interpretation costs is only limited, or even non-existent, when a ‘sub-meeting’ or working group meeting is cancelled but the interpreters concerned have worked during other meetings the same day (on average, it is possible for 70 % of interpreters who become available because of cancellation of a meeting to be reassigned to other meetings). This being so, Parliament estimates that the cost of interpretation services scheduled but not used in 2003 amounted to less than 5 % of all the interpreting resources mobilised (56 298 interpreter days), or just over half the percentage and cost mentioned by the Court. 55. The EP welcomes the progress made in interinstitutional cooperation in the field of interpreting. This is not confined to the recommendations made in the ‘Chêne report’: in particular, it also includes ad hoc exchanges of permanent staff interpreters working in the old official languages. Certain differences between the institutions as regards the working conditions of interpreters still hamper exchanges of staff interpreters. This subject is under consideration. 56. Irrespective of the savings and gains in efficiency which might be possible, it should be noted that the existence of three interpretation services corresponds to the particular characters and specific needs of these institutions. The calendars of work of the institutions could be harmonised more in order to improve the efficiency and availability of the interpreting service, particularly in the case of the enlargement languages. 57. The concept of competition is not in any way applicable to pay, which is set at the same level for all the EU institutions by agreement with the profession. The Secretaries-General of the institutions, being aware of the need to make better use of the human resources available (see point 57(b)), have very significantly stepped up interinstitutional cooperation and have initiated a programme of mutual provision of staff interpreters; they are determined to increase cooperation in this field. Joint management of the list of freelance interpreters and greater consultation between scheduling departments is already making it possible to share travel expenses (point 57(c)) to an extent which could undoubtedly still be improved. 58. The European Parliament's political and operational autonomy could not be reconciled with an organisational practice whereby the EP would have to submit its requests for official meetings for administrative arbitration, which would become unavoidable in connection with the management of the resources available, and in sum would make the holding of Parliament's meetings subject to such technical arbitration. Thus the European Parliament cannot endorse the idea of setting up a single agency responsible for providing interpretation services to all the institutions. Incidentally, the conclusions of the ‘Chêne report’, formulated in 2002 for the Secretaries-General of the institutions after a detailed study, advocated increasing synergy rather than merging services. Lastly, in economic terms, the setting-up of a single agency responsible for providing interpreting services to all the institutions would not reduce the additional costs arising from the organisation of the EP's meetings (costs of missions to Strasbourg, more missions, objective factors which the Court describes as being justified). Nor would it make it possible to reduce the shortage of qualified interpreters for certain languages. 62. The European Parliament has always aimed for a 50/50 ratio between freelance interpreters (ACIs) and permanent staff interpreters; this ratio is of course favourable to ACIs at peak times, but in 2004 the ratio stabilised at 52 % permanent staff to 48 % ACIs. 63. Particularly since the setting-up of a single department responsible for all payments to ACIs, the EP's administration has sought to verify more carefully the travel expenses incurred by ACIs. The aim is to apply the lowest rates possible while complying with the rules in force and as far as possible bringing the payments into line with the criteria which apply to permanent staff interpreters. The EP is willing to renegotiate the Agreement with the IACI. 64 and 65. The type of plane ticket referred to in Article 10 of the rules implementing the Agreement currently in force (an exchangeable and reimbursable IATA ticket at the lowest rate that is not subject to quotas) does not correspond to a ticket ‘subject to restrictions’ [the phrase used in the French text of the Court of Auditors’ preliminary observations where the English version has ‘subject to quotas’ — translator's note]. If appropriate, however, Parliament's administration agrees to reimburse travel expenses on the basis of a reduced rate subject to restrictions, undertaking to reimburse interpreters for any penalty incurred for reasons arising from their work for Parliament. The administration encourages ACIs to use this formula, and to systematically call upon the services of the travel agency contracted to the EP, which is instructed to apply the negotiated rates or the best available rates. In certain cases and on certain lines (e.g. Brussels-Strasbourg during the EP's part-sessions), no exchangeable ticket is available at less than business class rate. 66. In cooperation with the new single department responsible for paying ACIs which was set up in October 2004, the EP's administration has established a unit to monitor expenses arising from the commitments of ACIs. 67. It is true that Parliament has always applied Article 9(2) of the Agreement with the profession, considering that its purpose was to ensure that the same scales were applicable, rather than the rules on payment of fractions of daily allowances. The provisions of the new Staff Regulations currently distinguish between the daily subsistence allowance and the accommodation allowance. Renegotiation of the Agreement with the IACI would make it possible to clarify these provisions. 72. The duration of interpretation sessions is set at three and a half hours for customary meetings. However, if the user service so requests, it can easily be increased to four hours or more, the teams of interpreters being enlarged for the purpose. 82. The best practices observed at the other institutions will be studied by EP departments which use interpreting services with the aim of improving the planning of work while respecting the political imperatives referred to in the reply to point VII. 83 and 84. The cover of needs for interpretation concerning the new official languages is progressing in step with the considerable efforts which the institutions are making to find new interpreters and to provide supplementary training. However, the new Member States have a prime role to play in training linguists. 85 and 86. Full multilingualism, which the EP desires, entails substantial costs, which can be controlled better on the basis of the type of organisation of parliamentary work and optimal planning of meetings. These costs also arise from political decisions relating to the organisation of work (calendars and places of work). 87. The EP's Interpretation Directorate pursues a minimalist policy on reserve interpretation teams. Only one reserve team per day is programmed, and that only on days of peak work; in the end, the reserve team is always used, either fully or in large part. 88. See Parliament's reply to point 44. 90 and 91. The EP's administration is currently in the process of applying the Agreement with the IACI more strictly, increasing the integration of IT systems and intensifying interinstitutional cooperation; it undertakes to continue these efforts. The EP is open to the possibility of renegotiating the Agreement. 92. The EP considers that it should have a body of staff interpreters to guarantee the EP's independence and autonomy in this respect. Ad hoc use of freelance interpreters as needs dictate makes it possible to cope with peaks of work while keeping the budget under control. A 50/50 ratio seems a reasonable compromise between autonomy and flexibility of the service. 93. The duration of meetings is decided by the political and parliamentary bodies; it may exceed the duration laid down by agreement, namely three and a half hours, as mentioned at 72. The interpreting service is required to comply with all requests which accord with the rules; to this end it assigns interpreters to meetings in accordance with the rules in force concerning working conditions. 94. It is up to the EP's political authority to determine whether it wishes to have its own autonomous interpreting service, albeit involved in extensive interinstitutional cooperation, or whether it prefers to work towards the establishment of a single agency to provide interpreting services to all the institutions. (1) Rule 138 of the Rules of Procedure of the European Parliament reads: ‘1. All documents of Parliament shall be drawn up in the official languages. 2. All Members shall have the right to speak in Parliament in the official language of their choice. Speeches delivered in one of the official languages shall be simultaneously interpreted into the other official languages and into any other language the Bureau may consider necessary. 3. Interpretation shall be provided in committee and delegation meetings from and into the official languages used and requested by the members and substitutes of that committee or delegation. 4. At committee and delegation meetings away from the usual places of work interpretation shall be provided from and into the languages of those members who have confirmed that they will attend the meeting. These arrangements may exceptionally be made more flexible where the members of the committee or delegation so agree. In the event of disagreement, the Bureau shall decide.’

REPLIES BY THE COUNCIL The General Secretariat of the Council welcomes the European Court of Auditors’ report on interpretation expenditure of the EU institutions, which could serve as a basis for further rationalisation of the use of interpretation facilities in the future. Remarks on some individual points of the report 10 and 11. Table 1 and following analyses in points 10 and 11 do not give a full explanation on the increase of interpreter days in the Council between 1998 and 2002 (+9 %). The main reason for this increase is the significant growth of the Council's activities and the number of meetings (+39 %) held within the Council during that period (see Table 1). Table 1 The volume of interpreter days provided to the Council, including the languages of the new Member States, compared to the number of meetings (index 1998 = 100) 1998 1999 2000 2001 2002 2003 2004 Council meetings 100 105,8 112,2 132,7 139 135,8 124,8 Interpreter days provided for the Council 100 96,8 96,3 105,6 109,1 103,9 89,9 As for the decrease of –13 % in interpretation days in the Council in 2004, it should be noted that the number of meetings went down by –8 % in 2004. Moreover the following factors must be taken into account: — Since 1 May 2004 there have been fewer meetings with interpretation based on SG/HR decision No 56/04. — The old Member States (former EU-15) made fewer requests for interpretation in 2004 than before. — DG Interpretation could not provide all the requested interpretation for the new languages. 28. It should be added that the Council's budget also finances 50 % of the Coreper meetings’ interpretation expenditure. 35. The fact that the definition of the ‘MAD’ is not clear and has frequently changed over the years makes every analysis based on this concept highly questionable. 49. It should be mentioned that even if the Council cancels a meeting for which interpretation has been booked and has to be paid, it does not mean that the interpreters would stay idle. According to the Council's experience, DG Interpretation can and has assigned some of these interpreters to other meetings held in the Commission or in other institutions serviced by DG Interpretation. 94. The General Secretariat of the Council supports the idea of carrying out an independent evaluation on the possible benefits of creating one single interinstitutional office providing interpretation services to all EU institutions.