WRITTEN QUESTION E-1565/03

by Eija-Riitta Korhola (PPE-DE) to the Commission

(8 May 2003)

Subject: Anomalous aspects of the new Career Development Review (CDR) system

Does the Commission acknowledge that there is considerable disquiet among a large number of its officials about the new Career Development Review (CDR) system which has been introduced this year?

Will the Commission explain the following anomalous aspects of the new system?

If promotion is supposed to be primarily on the basis of merit, and if merit is properly reflected in the staff reports and the number of points awarded, why then do Director-Generals have the possibility of awarding up to 10 additional priority points per member of staff on the basis of criteria which are neither clear nor objective? Does this not encourage favouritism rather than merit?

Joint answerto Written questions E-1562/03, E-1563/03, E-1564/03 and E-1565/03given by Mr Kinnock on behalf of the Commission

(27 June 2003)

It was natural, in the Commission as in other organisations, for the introduction of a new appraisal system to be viewed with a degree of reticence and concern by some members of staff. However, the Commission observes that much of that initial concern has now been dispelled as

staff have participated in the Career Development Review. Overall, Directorates General (DGs) across the Commission carried out their appraisals seriously and productively, particularly in terms of the required systematic dialogue which, in itself, was recognised to be a positive development for staff and management.

The appraisal system was put in place by the Commission after a long reflection and after extensive consultation with all interested parties. It was not conceived or presented as a scientific instrument for measuring performance simply because such an instrument does not exist anywhere. However, the system employs a series of elements and mechanisms which involve uniform criteria, standards, and procedures, as well as checks and balances. Together, these contribute to arrangements which are as objective as possible and capable of producing reliable assessments of merit.

The Honourable Member's four questions are inter-related.

In answer to Written Question E-1563/03: the Commission recalls that, under the existing Staff Regulations, promotion must be based on a comparison of the relative merits of all the Commission staff who are in a given grade. This principle has been regularly reiterated in European case law.

Against this background, the Commission introduced, as an integral part of its new methodology, the notion of a target average expressed in terms of merit points. This target, which was pitched at 14/20, applies within each grade and to all DGs across the Commission and corresponds to a score which indicates a very good overall level of performance.

There are also other reasons for setting a target average: The system encourages managers to make individual assessments based on demonstrated merits. Simultaneously, and associated with this principle, there is need to ensure that an appraisal system does not develop inflationary tendencies i.e. overgenerous markings which devalue staff appraisal methodologies and outcomes and work to the disadvantage of the great majority of staff.

The target average system takes into account the well established and widely recognised reality that, at a sufficiently aggregate level, the distribution of staff according to performance follows a pattern which reflects what is known as a normal distribution (or bell-type) curve. A normal distribution around the target average of 14 merit points is, therefore, what could reasonably be expected as a result of the appraisal exercise.

In answer to Question E-1562/03 it must be noted that the system described in answer to Question 1563/03 offers a certain margin of flexibility, so as to allow for an appropriate recognition of merit (in particular in those cases where the population involved represents too small a sample to reflect the uniform and normal distribution mentioned above). Firstly, DGs are allowed to exceed the target average by one point, i.e., to bring it up to 15 merit points (and not, as suggested by the Honourable Member, 14,5), without suffering any negative consequence. Beyond that level, a penalty applies, with a reduction in the package of priority points made available to the DG for the grade concerned. Even in this case, though, there is scope to take account of special situations in given grades so as not to penalise groups whose staff are all very good performers: provided the DG argues its case appropriately, the Promotion Committees can decide to cancel or to reduce the penalty.

In answer to Written Question E-1564/03 the Commission wishes to underline the fact that, in relation to the possibility of pre-attribution of merit points before the individual appraisal dialogues have actually taken place, the appraisal interview should include a significant prospective element which provides the opportunity for managers to discuss with staff their developmental needs and their potential for improved professional performance.

The new appraisal system and the obligation to respect the target average in terms of merit points means that, within each DG, a concerted effort is required to ensure consistency of appraisal results across Directorates and Units and equitable distribution of merit points.

It is normal, therefore, that as a matter of good practice, some preparatory work should take place within the DG. A reference to this co-ordination exercise in preparation for the formal appraisal stages is contained in Article 3, Article 6 of the General Implementing Provisions of

Article 43 of the Staff Regulations(1). The primary aim of the exercise is for assessors to agree on a set of common standards for interpreting assessment criteria, so that individual appraisals can be conducted on the strength of a uniform understanding of the system and the method.

Having said this, the co-ordination meetings should always include reporting and countersigning officers. Moreover, they should not result in a predetermined allocation of merit points to each official before the individual assessments have taken place. These meetings should aim at obtaining an estimate of the distribution of merit points, based on a broad comparison of all members of staff in the same grade, and provided that such an estimate derives from the judgements made by reporting officers about the performance and merits of their staff. In this case, a certain margin of flexibility should be maintained in order to take account of the situations where there are differences between the estimates and the results in terms of individual Career Development Reviews (CDR).

If the arrangements were not followed, reporting officers (in most cases, Heads of Unit, as immediate managers of staff) would be denied the means of fulfilling their duty and prerogative of carrying out genuine appraisals of the staff that they manage. That would be a very serious distortion of the system, and the Commission would be grateful if the Honourable Member would provide any information about any specific instance where it is alleged to have happened so that appropriate action can be taken.

In answer to Written Question E-1565/03: priority points, like merit points, can only be awarded on the basis of considerations of particular performance. Furthermore, the attribution of these additional points to officials deemed most deserving is governed by the rules laid down in Article 6 Article 3 of the General Implementing Provisions of Article 45 of the Staff Regulations(2) which set out clear attribution criteria that can be summarised as follows: Priority points are given to officials in recognition inter alia of their contribution to the attainment of wider goals than those directly related to their individual work plan and/or as a reward for special efforts and outstanding results. In order to allow for a meaningful differentiation of staff on grounds of merit, half of the available package of priority points has to be shared out among the very best performers in a given grade (this corresponds to broadly 15 % of the population in the grade considered).

Directors and Directors-General are in charge of making the proposals for granting priority points for the very obvious reason that their position gives them a broader view of the department and of its staff.

In addition to these principles, DGs have adopted a few simple guidelines relating to the distribution of priority points and these guidelines have been brought to the attention of the staff.

The decision on the award of priority points is taken collegially and not by the Director General alone (since he/she will adopt the decision on the basis of the information received from, and on the proposals made by, managers) and with the involvement of staff representatives.

All these factors contribute to ensuring that decisions on promotion are taken on the basis of objective elements and as a result of a fair and transparent process.

(1) Adopted by the Commission on 26 April 2002.

(2) also adopted by the Commission on 26 April 2002.