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As regards the penalty, the Commission recalls that, in accordance with the relevant provisions of the Implementing Regulation applicable at the time when the facts alleged occurred, it must, in order to determine the duration of exclusion in compliance with the principle of proportionality, take into account in particular the seriousness of the facts, including their impact on the European Union’s financial interests and image, the time which has elapsed since the facts at issue, the duration and recurrence of the breaches, the intent or degree of negligence of the entity concerned and the measures taken by the entity to remedy the situation. In the present case, after emphasising the seriousness of the facts, the Commission states that the production of documents which did not reflect the factual situation was a recurrent behaviour on the part of the applicant. It refers in that regard to practices, referred to in its letter of 31 August 2015, which the applicant allegedly used to overstate its true costs in various contracts and which were discovered by OLAF or other services. Responding to the various arguments put forward by the applicant to avoid a penalty, the Commission argues, inter alia: (i) that it is incorrect to deny that there was an adverse financial impact for the European Union, since if the tender procedures had been genuine the purchase price could have been lower; (ii) that the European Union’s image is inevitably affected by poor use of grants for cooperation in the development of third countries; (iii) that the time which has elapsed since the facts is a consequence of the fact that they were not discovered until 2012 by the Court of Auditors; (iv) that the concept of recurrence of acts referred to in the relevant provisions of the Implementing Regulation does not presuppose that there was an administrative penalty prior to some of them, nor even that they succeed one another in time, and it covers cases where the facts are not isolated events but fit within a body of similar facts attesting to the seriousness of the situation; (v) that in the present case the applicant had nevertheless already provided false information in the past seeking to overstate its costs; and (vi) that, contrary to the applicant’s claims, the manipulations at issue in the present case were intentional and no control mechanism could have prevented them. Furthermore, the Commission puts forward a firm and detailed rebuttal of the claim that it was the source of the media coverage concerning proceedings against the applicant, as well as the subsequent difficulties which may have affected it. The Commission draws attention to the very preponderant share of public, non-EU, funds in the applicant’s budget and the fact that, in the period from 2008 to 2014, EU grants to it accounted for a much smaller share. The exclusion penalty would not, therefore, according to the Commission, have a devastating impact on the applicant, contrary to the latter’s claim. Taking into account, however, the measures taken by the applicant to improve its internal controls and procedures, as well as the dismissal of the individual in charge of the project at issue, the Commission ultimately reduced the exclusion penalty to 18 months, applicable from the date when the decision imposing the penalty was notified.