Opinion of the Economic and Social Committee on the 'Proposal for a European Parliament and Council Directive on certain legal aspects of electronic commerce in the internal market'
Date: 1999-04-29
Institutions: European Economic and Social Committee
Subjects: EC Directive, commercial law, distance selling, electronic equipment, proposal (EU), trade regulations

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3.7.
The Committee feels that the scope for international
cooperation provided for under Article 7.2 of the Com-
mission’s proposal
is far too restricted in terms of which
countries may participate.

4. Conclusion

4.1.
In conclusion, the Committee would stress that, subject
to the above reservations, it welcomes the programme as a

whole. However, it would also point out that the scope of the
amended version is more restrictive. Clearly, there is an urgent
need to put into place measures to combat all mistreatment
such as violence, abuse and sexual exploitation; however, we
must not ignore the need to tackle the causes of violence. A
shortcoming of the programme is also its failure to regard
violence, abuse and sexual exploitation as infringements of
human rights.

Brussels, 28 April 1999.

The President

of the Economic and Social Committee

Beatrice RANGONI MACHIAVELLI

Opinion of the Economic and Social Committee on the ‘Proposal for a European Parliament and
Council Directive on certain legal aspects of electronic commerce in the internal market’ (1)

(1999/C 169/14)

On 23 April 1999 the Council decided to consult the Economic and Social Committee, under Article
100a of the Treaty establishing the European Community, on the above-mentioned proposal.

The Section for the Single Market, Production and Consumption, which was responsible for preparing
the Committee’s work on the subject, adopted its opinion on 15 April 1999. The rapporteur was
Mr Glatz.

At its 363rd plenary session (meeting of 29 April 1999), the Economic and Social Committee adopted
the following opinion by 115 votes to two, with six abstentions.

1.

Introduction

For the people of Europe and for European business,
1.1.
electronic commerce can create opportunities in terms of
stronger economic growth, job creation, development pros-
pects for new products and markets, more competitive Euro-
pean companies and a wide supply of goods and services for
European consumers.

1.1.1.
However, whether electronic commerce actually has
the impact outlined above, for example on the jobs front, is
contingent on various different factors. The Committee urges
the Commission to carry out more intensive studies into this
issue, particularly with regard to employment.

1.1.2.
Benefits will be felt in particular if Europe manages
to secure a strong global position in this field, especially in

(1) OJ C 30, 5.2.1999, p. 4.

relation to the USA. As things stand, however, around 80% of
electronic commerce is, according to OECD figures, US-
generated. It is therefore vital that Europe take steps to ensure
that, in future, it can utilize the opportunities presented by
electronic commerce, rather than trailing behind the dynamic
performance of the United States.

1.2.
it is
To bring the possible benefits fully to bear,
necessary both to eliminate legal constraints on electronic
commerce and to create conditions whereby potential users of
electronic commercial services (both consumers and business-
es) can have confidence in e-commerce. An optimum balance
must be found between these two requirements. Given the
wide scope of the directive under review and its complex
interrelationship with other areas of regulation, a very careful
and responsible approach will be needed.

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1.3.
The aim of the directive is to promote the spread of
electronic commerce by helping break down legal barriers to
trade. If, however, new distance selling methods are to gain
broad acceptance among customers (both consumers and
businesses), consideration will clearly also have to focus on
ensuring that the consumer and data protection standards
which apply to traditional
trade are also maintained in
the technical environment of electronic commerce and are
enforceable in practice.

1.4.
The vast majority of people in society are currently
without fullaccess to information services. Some sections of
the public, particularly older people, cannot be reached by
electronic means, or opt exclusively for personal contact with
the parties with whom they do business. The Committee feels
that non-electronic access to important everyday services (such
as running a bank account) must be retained, so that certain
groups within society are not precluded from using them.
Also, the use of new technologies must not create barriers for
certain sections of society, hindering or preventing them from
using electronic commerce. European policy must therefore
seek to ensure that no sections of society are denied access to
information society services because they lack the technology
or know-how or because of their economic position.

1.4.1.
For consumers, education and training are also
essential elements in facilitating wider risk-free access to
information society services.

1.5.
Global solutions are undoubtedly needed for forms of
distribution which, thanks to technology, can so easily tran-
scend national borders; hence the intensive discussion which
has emerged recently at various international levels. A whole
range of international conferences and forums have been held
between governments and interested parties to tackle this
issue. These include the OECD conferences held in Turku in
November 1997 and Ottowa in October the following year,
the G7 ministerial conference in Brussels in February 1995
and the June 1997 ministerial conference in Bonn. Much work
in this field has also been initiated under WTO auspices. Of
course progress has been made at these levels, but the outcome
of the talks and negotiations has currently often been confined
to general principles.

1.6.1.

These schemes include:

•

•

•

•

•

•

the Communication on a European initiative in electronic
commerce, (1)

the Communication from the Commission to the Council,
the European Parliament, the Economic and Social Com-
mittee and the Committee of the Regions — ensuring
security and trust in electronic communication — towards
a European framework for digital signatures and encryp-
tion, (2)

the Proposal
for a European Parliament and Council
Directive on a common framework for electronic signa-
tures, (3)

the Communication — globalization and the information
society — the need for strengthened international coordi-
nation, (4)

the proposed action plan on promoting safe use of the
internet (5) which aims, through a range of measures, to
boost trust in the networks and is thus an element in the
drive to promote electronic commerce,

a recent European Parliament resolution of 14 May 1998
also calls on the Commission to submit, as quickly as
possible, a proposal for a directive to address these issues
in a coherent way.

2. The Commission proposal

The proposed directive seeks to eliminate legal uncer-
2.1.
tainties and obstacles caused by national legal differences by
finding solutions in five key areas. The aim is to establish a
coherent framework for electronic commerce.

2.2.

The five areas tackled in the proposal are as follows:

Establishment of providers of information society
2.2.1.
services: The place of establishment is defined. Special author-
ization regulations for information society services are to be
prohibited. Providers must fulfil certain information require-
ments in order to ensure the transparency of their activities.

1.6.
This is why European-level initiatives are also essential
if we are to exploit the economic and social opportunities
open to Europe. Since electronic commerce profoundly alters
business relations and the way in which people live together,
Europe has launched a number of schemes designed largely to
establish a clear framework for the continued development of
this type of commerce. The aim is to promote investments in
electronic commercial services which will have a positive
impact on EU growth, competitiveness and employment.

(1) COM(97) 157 final, 16.4.1997; ESC Opinion, OJ C 019,

21.1.1998, p. 72.

(2) COM(97) 503 final, 8.10.1997; ESC Opinion, OJ C 157,

25.5.1998, p. 1.

(3) COM(98) 297 final, 13.5.1998, OJ C 325, 23.10.1998, p. 5; ESC

Opinion, OJ C 40, 15.2.1999.

(4) COM(98) 50 final, 4.2.1998; ESC Opinion OJ C 284, 14.9.1998,

p. 6.

(5) COM(97) 582 final, OJ C 48, 13.2.1998; ESC Opinion OJ C 214,

10.7.1998, p. 29.

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Commercial communications

2.2.2.
(advertising, direct
marketing, etc.): The proposal defines what constitutes a
commercial communication and makes it subject to certain
communications
transparency requirements. Commercial
must, for example, be clearly recognizable as such, and the
parties on whose behalf
they are made must be clearly
identifiable. Unsolicited commercial communications must
also be clearly identifiable as such by the user.

2.2.3.
Contracts: Member State are to adjust their national
legislation to ensure in particular that formal requirements do
not hamper the use of electronic contracts in practice. The
proposal also seeks to remove legal uncertainties by clarifying
in certain cases the moment at which the contract is deemed
to be concluded.

2.2.4.
Liability of intermediaries: The aim is to clarify the
responsibility of on-line service providers for transmitting and
storing third party information. The proposal establishes a
‘mere conduit’ exemption and limits service providers’ liability
for other intermediary activities.

crucial that electronic commerce should not be promoted at
the expense of consumer protection standards.

3.4.
Basically, unless warranted on practical grounds, there
should be no difference in the legal environment of electronic
commerce and established trade. In terms of technology, there
should be a level playing field. Discrimination and distortions
of competition may arise because established trade, by its very
nature, may need to be subject to other specific regulations
such as building standards. The Committee feels that this
factor must be borne in mind when considering how to
improve the environment for electronic commerce.

3.5.
This directive is distinctive in that, although wide in
scope, covering areas such as commercial communications and
electronic contracts, only partial harmonization is provided for
in individual fields. More far-reaching rules may be adopted at
national level only on completion of a committee procedure
(Article 22).

2.2.5.
Implementation: The proposal encourages the devel-
opment of Community-level codes of conduct and administrat-
ive cooperation between Member States.
facilitates the
establishment of effective cross-border alternative dispute
resolution systems and opens up the possibility of dispute
settlement out of court.

It

3.6.
The country-of-origin principle applies to those areas
which, although not harmonized by the directive, still fall
within its scope. This means that the legal arrangements of the
country in which the service provider is established apply. The
point of departure is the view that it is difficult for providers
to be guided by the law of the countries in which they do
business.

3. General comments on the draft directive

3.1.
Electronic commerce is undoubtedly hampered by
differences and lack of clarity in the legal framework, which
prevent its benefits from being fully felt. Moves to offer more
legal certainty to providers and users are therefore to be
welcomed.

3.1.1.
The Commission has shown good timing in its
submission of the proposed directive since, in most Member
States, legal transactions and commerce by electronic means
are a live issue. There is a clear material link, particularly with
the electronic signatures directive (1).

3.2.
The main aim of the Commission proposal for a
directive on certain legal aspects of electronic commerce in the
internal market is to remove legal barriers which could impede
the spread of electronic services across Europe.

3.3.
The Committee expressly welcomes the accompanying
consumer protection measures set out in the proposal (e.g.
information to be furnished by the provider, development of
out-of-court dispute settlement). The Committee feels it is

3.6.1.
The present directive does not change existing Com-
munity law. However, that in no sense rules out possible
conflict with Community law as implemented in the Member
States. Some consumer protection directives lay down only
minimum provisions. For instance, Article 14 of the Directive
on the protection of consumers in respect of distance con-
tracts (2) allows Member States to introduce or maintain a
higher level of consumer protection, including bans, in the
general interest, on the distance marketing of certain goods
and services (such as medicinal products).

The Committee broadly endorses the idea behind the
3.6.2.
country-of-origin principle. It cuts the legal costs of infor-
mation society service providers and thus works to their
advantage, essentially as desired.
It also makes for better
implementation of protective measures by the appropriate
authorities in the country of origin.

3.6.3.
On the demand side, however, and for consumers in
particular, the application of this principle means grappling
with various legal systems which determine the content,
quality and legal certainty of information society services.
National systems differ and conditions often vary quite con-
siderably as a result. In practice, therefore, this principle may
pose risks to users in cases where their own countries’
arrangements no longer afford the requisite protection.

(1) COM(97) 503 final, 8.10.1997; ESC Opinion, OJ C 157,
25.5.1998, p. 1; COM(98) 297 final, OJ C 325, 23.10.1998, p. 5,
ESC opinion 1444/98, OJ C 40, 15.2.1999, p. 5.

(2) Directive 97/7/EC, 20.5.1997, OJ L 144, 4.6.1997, p. 19; ESC

Opinion, OJ C 19, 25.1.1993, p 11.

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3.6.4.
Since the consumers of one Member State may be
unfamiliar with their rights under the law of another State
where the service provider is based, the Member States and the
European Commission should ensure the rapid establishment
of a cross-border network of consumer protection agencies or
ombudsmen to act as conduits and possibly arbitrators in the
event of disputes between consumers in one country and
service suppliers based in another. Such a network would
preserve the concept of the single market while providing
simpler, cheaper and more effective means of redress for
consumers than litigation, although their rights to initiate
litigation if they remained dissatisfied would remain.

3.6.5.
Thus, while fully understanding simplification as far
as the provider is concerned, the Committee feels that, as
long as high-level harmonization is lacking, an extremely
responsible approach is called for here and further consider-
ation is required. The draft directive backs such an approach,
setting out areas in which the general principle is not fully
brought to bear.

the country-of-origin principle,

3.6.6.
The Committee would suggest that further exemp-
tions may be justified where Member States’ legal systems vary
widely or in areas considered highly sensitive by public opinion
in the Member States (e.g. advertising directed at children,
games designed for advertising purposes, medicinal products
sold by mail order, regulated professions). The blanket appli-
cation of
for example in
advertising, could expose consumers to advertising practices
which they have never before encountered. In sensitive areas
especially, ‘forum shopping’ i.e. where the choice of location
is based on where the rules are most favourable for the
provider, would raise difficulties, particularly since SMEs have
only limited scope in this regard. Principles should therefore
be established as a guide for determining areas in which the
country-of-origin principle applies and areas where, as yet, this
is not possible. No-one disputes that such considerations
should not be allowed to generate obstacles to the single
market. Beyond that, the aim over time should be to achieve
high harmonized standards.

3.7.
The Committee notes that the wording of many of the
provisions set out in the proposal are unclear and must be
reworked in more precise terms.

4. Specific comments

4.1. Article 2: Definitions

The Committee would point out

4.1.1.
that, with the
increasing convergence of technologies, definitions may rap-
idly be superseded. As the Green Paper on the convergence of
the telecommunications, media and information technology
sectors (1) makes clear, converging markets are set to spawn

(1) COM(97) 623 final, ESC Opinion, OJ C 214, 10.7.98, p. 79.

hybrid services which combine features of different classic
categories of service. In the case of multi-media applications,
such as television sets with integrated internet browsers,
computers able to receive television and radio transmissions
(radiotelephony and internet voice telephony), it will gradually
become impossible to draw clear boundaries between individ-
ual and mass communication.

The Committee feels, therefore, that this factor should be
borne in mind in the ongoing consideration of the draft
directive and that the final definitions should accommodate
possible new developments, thus ensuring that they are not
very quickly superseded.

4.1.2.
The definition of ‘information society services’ in
particular raises a whole range of borderline issues, which are
not fully resolved even taking account of Directive 98/48 (2)
and especially Annex V thereof. For clearer understanding and
to avoid any ambiguity, the Commission should, as in Annex
V of the said directive, draw up negative and/or positive lists
for existing services.

4.1.3.
Similar ambiguities apply to the definitions of ‘coor-
dinated field’, ‘commercial communication’ and ‘established
service provider’.

4.1.4.
The term ‘consumer’ should be defined as follows: A
consumer is any physical person resident in the Community
dealing under contracts covered by this directive for purposes
which cannot be regarded as forming part of that person’s
commercial or professional activity.

As the scope of

this directive will raise many
4.1.5.
questions and is highly relevant, precision in this regard will
be particularly necessary.

4.2. Article 3: Internal market

Article 3 stipulates that each Member State is to
4.2.1.
ensure that the information society services provided by a
service provider established on its territory comply with legal
provisions (country-of-origin principle). The impact of the
country-of-origin principle has already been discussed in point
3.6 above.

4.3. Article 4: Principle excluding prior authorization

4.3.1.
This article stipulates that access to information
society services is not subject to any special requirements.
However, as set out in the proposal, this should not affect
other general authorization arrangements.

(2) Directive 98/48/EC of the European Parliament and of the Council
of 20 July 1998 amending Directive 98/34/EC laying down a
procedure for the provision of information in the field of technical
standards and regulations OJ L 217, 5.8.1998, p. 18.

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4.4. Article 5: General information to be provided

The Committee is glad that the information require-
4.4.1.
ments are to include details of the service provider. The
Committee would also recommend that explicit reference be
made to the minimum information requirements laid down in
Directive 97/7/EC on distance contracts (1). Article 4 of this
directive sets out all the information which must be provided
to the consumer before a contract is concluded. In particular,
this also includes the requirement to give consumers, prior
to the arrangement of any contract, clear, accurate and
comprehensive information on the law to be applied to that
contract and on the provisions of Article 6 giving customers
the right of withdrawal.

4.6.2.
The draft directive stipulates that unsolicited elec-
tronic communication by e-mail must be identified as such.
This is designed to give both recipient and provider the
opportunity to use software to filter out unwanted e-mail
advertising (‘opt-out’). That said, it is the recipient who has to
take the initiative here.

These arrangements are not perfect, however. Pro-
4.6.3.
viders cannot filter mail unless requested to do so by the user
— except in the case of obvious spammers — since otherwise
those users desiring the information would not receive it.
Secondly, users finding their mailbox full after being absent
for any length of time are denied access to their desired (e.g.
private) mail.

However, the Committee feels that other, additional
4.4.2.
information would be useful, without, however, overburdening
consumers and providers with a surfeit of data (e.g. regions in
which the services are available, period of validity, probable
delivery time, insurance, general conditions of sale).

For this reason,

4.6.4.
the Committee would propose
considering another possibility, namely user opt-in, where
users exercise self-determination by expressing an explicit
interest in receiving information. This opt-in option is available
to Member States (see Annex II), but should be provided for
across the board.

4.4.3.
In addition, specific warnings should be given about
product safety. Alerting customers to possible risks (e.g. by
notices on goods or instructions for use) is an important factor
in any decision to buy.

4.7. Article 8: Regulated professions

4.4.4.
Customers should also be informed about restrictions
on distribution, download times (where possible) and licensing
conditions for software products.

4.5. Article 6: Commercial communications

In the traditional media,

4.5.1.
there is a fairly clear
distinction between advertising and editorial content. However,
this dividing line risks becoming blurred, making it all the
more essential to counter such trends in electronic commerce.

Purchasers (whether trade or final consumers) can
4.5.2.
adequately assess advertising and marketing only if they can
clearly recognize it as such. The Committee therefore expressly
endorses the obligations to provide information set out in
Article 6.

4.6. Article 7: Unsolicited commercial communication

4.6.1.
For recipients of commercial communications, the
point is often not only the unsolicited nature of electronic
advertising, but also, thanks to technology, its sheer volume,
and the resulting costs in terms of telephone charges and
storage capacity. Volume also presents difficulties for pro-
viders.

4.7.1.
Here, the directive touches on a development which
is widely observed in the regulated sectors, i.e. the emergence
of an open, positive attitude towards information society
services. In this regard, the directive recognizes the continued
need for regulation in order to ensure that general interests are
afforded the requisite protection (protection of consumers and
other parties involved, reliable service provision, prevention of
abuses etc.) This is broadly to be welcomed. However,
in
specific cases, care will be needed to determine the extent to
which Member States’ express regulatory remit and the
subsidiarity principle make it possible to act at European level.
The Committee would point out the flaw in providing for
codes of conduct to be drawn up by professional associations
and organizations without laying down appropriate criteria on
which to base them.

4.8. Article 9: Electronic contracts

4.8.1.
to formal
Certain types of contract are subject
requirements, not only under national rules but under EU
legislation as well (e.g. the consumer credit directive (2)). In
certain cases, therefore, there is a recognized need for rules
stipulating that the contract should be in writing to facilitate
proof and to make the parties aware of the significance of the
contract they are entering into. Article 9 of the directive
instructs the Member States to remove any legal requirements
which ‘prevent the effective use of electronic contracts’ or
which result in such contracts ‘being deprived of legal effect
and validity.’

4.8.2.
It is beyond dispute that, as a matter of principle,
electronic agreements should be effective. In sensitive areas of

(1) Directive 97/7/EC, 20.5.1997, OJ L 144, 4.6.1997, p. 19.

Opinion, OJ C 30, 30.1.1997, p. 94.

(2) Directive 98/7/EC, 16.4.1998, OJ L 101, 1.4.1998, p. 17; ESC

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business, however, there must be scope to attach certain
conditions to legal validity. Parties to an electronic commerce
contract are no less in need of protection than those entering
into traditional contracts. In the case of sensitive contracts or
declarations drawn up or delivered electronically, therefore,
the Committee would stress the need for arrangements equiva-
lent to existing formal requirements.

providers to be assessed separately; assessment is based on
providers’ degree of involvement with the content transmitted
and their scope for monitoring content. The Committee
welcomes efforts to establish clear rules on the responsibility
of service or information society providers and shares the view
that the ‘manufacturer’ of information should bear primary
responsibility for its content.

4.8.3.
This is why, logically, the draft electronic signatures
directive (1) does not touch on the legal validity of contracts.
The Member States are thus free to make certain encryption
features mandatory for some types of contract. Member States
are also at
liberty to exclude certain types of contract
completely from the scope of the electronic signatures direc-
tive, or to lay down additional requirements — such as an
electronic signature with special safety features — for the
validity of formal contracts concluded by electronic means.
Together with the framework established by this directive, the
use of electronic signatures is a key element needed to boost
electronic commerce.

4.9. Article 10: Information to be provided

A clear introduction to how services are used makes
4.9.1.
for transparency and prevents misunderstandings and the
undesirable legal consequences they involve. It is therefore
wholeheartedly welcomed.

4.10. Article 11: Moment at which the contract is concluded

To conclude a contract with legal effect, the service
4.10.1.
provider must issue an acknowledgement of receipt, which
must be reconfirmed by the buyer. The Committee welcomes
the clear arrangements for determining the moment at which
a contract is concluded, and the proposal to establish a
mechanism enabling the user of the service to identify and
correct handling errors. The Committee would point out that
the term ‘offer’ must be clearly defined to prevent loopholes.
For example, in some Member States, an ‘offer’ on a website
may be understood by the customer as an ‘invitation to
prepare an offer’. Clarification is needed here.

4.10.2.
It is not clear who would be held responsible for
the loss of a message as the result of a technical defect.
Moreover, it is in any case doubtful whether final consumers
are yet sufficiently aware that all electronic terminals have to
be checked regularly for messages which may have a legal
bearing.

4.11.2.
Articles 12 to 15 partially exempt intermediaries
from liability for the information transmitted. For the sake of
clarity, it should be expressly stated that, although, in the
circumstances described, the provider is not liable for lack of
content control, liability for conduct relevant to data protection
under data protection and telecommunications law remains
unaffected.

4.12. Article 17: Out-of-court dispute settlement

4.12.1.
Access to legal redress in the event of dispute is
crucial to people’s acceptance of electronic commerce. For
minor legal proceedings especially, alternative dispute settle-
ment arrangements can be an ideal complement to legal
protection via the courts. In taking account of out-of-court
dispute settlement procedures, the draft directive addresses an
issue which, given the courts’ excessive workload, is becoming
increasingly important everywhere. Speeding up dispute settle-
ment at moderate cost contributes significantly to ensuring
that ordinary people have equal access to the law, but can only
succeed if (i) a certain minimum level of quality is guaranteed
and (ii) the complete range of available options is used to the
full.

4.12.2.
In this context, the Committee would also encour-
age a role for existing European consumer information offices.

4.13. Article 18: Court actions

4.13.1.
Interim injunctions have without doubt proved a
valuable tool. The Committee is pleased that they are also to
be used in conflicts relating to electronic distance contracts.
Extending the scope of the injunctions directive (2) to cover
infringements of the present directive is also appropriate.

4.14. Article 19: Cooperation

4.11. Articles 12-15: Liability of intermediaries

4.11.1. With regard to liability,
the introduction of a
graduated system of exemptions and restrictions establishes a
common framework, allowing the diverse activities of internet

4.14.1. Member States may comply with the obligation to
provide assistance and meet requests for information only
within the framework of existing laws on confidentiality and
data protection.

(1) COM(1998) 297 final, ESC Opinion CES 1444/98, 2.12.1998, OJ

(2) Directive 98/27/EC, 19.5.1998, OJ L 166, 11.6.1998, p. 51, ESC

C 40, 15.2.99.

Opinion, OJ C 30, 30.1.1997, p. 112.

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4.15. Article 22: Derogations

4.16. Annexes

4.15.1.
The draft provides for various types of derogation.
‘measures’ must pass through the Commission’s
National
committee procedure. The proposed committee procedure
means that the Commission can subsequently amend the
scope of the directive without further ensuring the appropriate
involvement of the Member States and the European Parlia-
ment under the co-decision procedure pursuant to Article
189b of the Treaty establishing the European Community.
Furthermore, the power to be vested in the Commission under
Article 22(3)(d) to decide on the compatibility of measures
with Community law may affect the remit of the European
Court of Justice.

4.15.2. Moreover, only court decisions are clearly excluded
from these arrangements. Clarification should be given as to
whether the word ‘measures’ in the third paragraph refers to
administrative measures or also includes legislation.

Brussels, 29 April 1999.

Annex I should be reviewed to check whether
4.16.1.
games of chance and pyramid games are also excluded from
the scope of the directive, particularly Article 3.

4.16.2.
The legal areas listed in Annex II are excluded from
the scope of the country-of-origin principle. These include
‘contractual obligations concerning consumer contracts’. It
should however be ensured that this derogation applies not
only to contractual, but also of course to legal obligations in
relation to consumer contracts. These include, for example,
the obligation to warn of risks and to act with due care and
attention. However, some way will have to be found to
distinguish commercial communications, where requirements
are not subject to precontractual obligations in the narrow
sense.

The President

of the Economic and Social Committee

Beatrice RANGONI MACHIAVELLI