Opinion of the European Economic and Social Committee on the Proposal for a regulation of the European Parliament and of the Council laying down the rules for the participation of undertakings, research centres and universities in actions under the Seventh Framework Programme and for the dissemination of research results (2007-2013) COM(2005) 705 final — 2005/0277 (COD)
Date: 2006-07-05
Institutions: European Economic and Social Committee
Subjects: EU financing, EU programme, cooperation policy, research and development, research body, research policy, research programme, type of business, university

16.12.2006

EN

Official Journal of the European Union

C 309/35

Opinion of the European Economic and Social Committee on the Proposal for a regulation of the
European Parliament and of the Council laying down the rules for the participation of undertak-
ings, research centres and universities in actions under the Seventh Framework Programme and
for the dissemination of research results (2007-2013)

COM(2005) 705 final — 2005/0277 (COD)

(2006/C 309/08)

On 1 March 2006 the Council decided to consult the European Economic and Social Committee, under
Articles 167 and 172(2) of the Treaty establishing the European Community, on the abovementioned
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 31 May 2006. The rapporteur was Mr Wolf.

At its 428th plenary session, held on 5-6 July 2006 (meeting of 5 July), the European Economic and Social
Committee adopted the following opinion by 152 votes to 1, with 3 abstentions:

1. Summary

1.7

See chapter four for further details.

The Commission proposal concerns

1.1
the conditions,
rules and procedures according to which undertakings, univer-
sities, research centres and other legal persons receive support
from the Seventh R&D Framework Programme.

2. Introduction

1.2
The Committee welcomes the majority of the proposed
regulations and views them as improvements with the potential
to bring about a considerable simplification of the administra-
tive procedures.
In that connection, the Committee recom-
mends that there also be greater standardisation and more
consistent application as regards the Commission's internal
implementing rules, which are still pending (in the applicable
criteria, for example).

However, since the Commission's internal implementing
1.3
rules are still pending, some of the specific outcomes of the
proposed regulations cannot yet be assessed.
In such cases
(e.g. reimbursement of additional costs), the Committee recom-
mends retaining the existing rules at least for the time being, so
that grant recipients do not lose out.

1.4
The Committee welcomes the planned new support ceil-
ings for grant recipients and their respective areas of activity. In
particular,
lead to
improvements in support for SMEs.

it also welcomes the fact

this will

that

1.5
The Committee recommends the equal treatment of all
research institutes that receive their core funding from the
State, irrespective of their legal status.

The Committee recommends that in the future parties
1.6
freedom in the contractual
to contracts be given greater
arrangements, but also in the choice of
instruments. This
concerns in particular access rights to foreground and/or back-
ground owned by one of the parties. Royalty-free access rights
should be offered here as an option, but not unconditionally —
as has been proposed for certain cases.

for

In its proposal

the Seventh R&D Framework
2.1
Programme (2007–2013) (1), abbreviated as
the
Commission outlined the objectives, content,
themes and
budget for its support of research, technological development
and demonstration activities during this period. The Committee
has already adopted opinions on the framework programme (2)
and on the preparatory and accompanying proposals in par-
ticular for the specific programmes (3).

the FP7,

2.2
The Commission proposal discussed here concerns the
conditions, rules and procedures which apply to the participa-
tion of undertakings, universities, research centres and other
legal persons in actions under the Seventh R&D Framework
Programme, in the sense of their receiving support from the
programme.

thus enhancing the effectiveness of

2.3
An important point which should be noted here is that
the Commission intends to simplify the administrative proce-
dures associated with research funding. This intention was
welcomed and endorsed by previous opinions; for its part, the
Committee reiterates its previous recommendation that admin-
istrative procedures should be made simpler and less burden-
some,
the European
research programme: ‘as they stand, the application and approval
procedures involve too much work and are too expensive, causing diffi-
culties for scientific and industrial users. The European research
programme must be a worthwhile venture for those taking part in it,
including in terms of the risk involved in making the application.
This also applies in particular to smaller players, such as SMEs or
smaller research groups from universities and research centres’ (4).
According to the Commission's statements, the proposed rules
for participation are intended to bring about such simplifica-
tion.

(1) COM(2005) 119 final.
(2) COM(2005) 439, 440, 441, 442, 443, 444, 445 final.
(3) OJ C 65, 17.3.2006 and CESE 583/2006.
(4) OJ C 65, 17.3.2006.

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2.4
The Commission proposal thus explains the applicable
rules aimed at ensuring that Community funding for research
and development under FP7 is as effective, efficient and fair as
possible.

2.5
The proposed rules for the participation of undertakings,
research centres and universities should therefore ‘provide a
coherent and transparent framework to ensure efficient imple-
mentation and ease of access for all participants in the Seventh
Framework Programme’. They are intended to promote a wide
range of undertakings, research centres and universities and
enable participation from the outermost regions of the Com-
munity.

3. Gist of the Commission document

3.1
The Rules for Participation for the Seventh Framework
Programme proposed by the Commission are intended to
implement many aspects of that simplification and to build
upon principles established in the Sixth Framework Programme
(FP6). A few important points are briefly summarised in this
chapter.

covers

The Commission's proposal

3.2
following
aspects: introductory provisions, conditions for participation in
indirect actions and the relevant procedures, the Community
financial contribution, rules for dissemination and use of find-
ings, access rights to and protection of background and fore-
ground, and the role of the European Investment Bank.

the

3.3 Conditions for participation in indirect actions

3.3.1
At least three legal entities must participate in indirect
actions, each of which is established in a Member State or asso-
ciated country, and no two of which are established in the
same Member State or associated country.

3.3.2
For coordination and support actions, and actions in
favour of training and career development of researchers, the
minimum condition is the participation of one legal entity.

For

indirect actions to support

3.3.3
investigator-driven
‘frontier’ research projects funded in the framework of the
the minimum condition is the
European Research Council,
participation of one legal entity established in a Member State
or in an associated country.

3.4 Community financial contribution

3.4.1
For research and technological development activities,
the Community financial contribution may reach a maximum
of 50 % of the total eligible costs.

However,

3.4.1.1
in the case of public bodies, secondary
and higher education establishments, research organisations (5)
and SMEs,
it may reach a maximum of 75 % of the total
eligible costs.

3.4.2
contribution may reach a maximum of 50 % of
eligible costs.

For demonstration activities, the Community financial
the total

(5) The term ‘research organisation’

is defined in Article 2.3 of the
Commission proposal; the terms ‘research institute’ and ‘research
centre’ are also used elsewhere in the proposal as synonyms.

3.4.3
For activities supported by frontier research actions,
coordination and support actions, and actions for the training
and career development of researchers, the Community finan-
cial contribution may reach a maximum of 100 % of the total
eligible costs.

For management and audit certificates, and other
3.4.4
activities not covered by paragraphs 1, 2 and 3 of Article 33,
the Community financial contribution may reach a maximum
of 100 % of the total eligible costs.

For Networks of Excellence, a special

3.4.5
lump sum is
proposed. The amount of the lump sum is established by the
rules for participation as a fixed amount calculated according
to the number of researchers to be integrated in the Network
of Excellence and the duration of the action.

3.5 Other rules

— The Rules identify the procedures for issuing calls for
proposals, for submission, evaluation, selection, award and
support for proposals.

— The evaluation process developed for previous framework
programmes is continued without major changes. A model
grant agreement will be established by the Commission that
will establish the rights and obligations of participants vis-
à-vis the Community and each other.

— Three forms of grants are proposed: reimbursement of
eligible costs, lump sums, and flat-rate financing. For fron-
tier
the European Research Council's
Scientific Council will propose appropriate funding arrange-
ments.

research actions,

3.6
There should be as much continuity as possible in the
rules for dissemination and use and access rights (ownership,
protection, publication, dissemination and use, and access
rights to background and foreground). The changes should
allow participants more flexibility as their projects progress.
The option of excluding background and of defining terms and
conditions other than those established by the Rules remains.
The coherence of dissemination and publication requirements
has been improved.

3.7
As in the Sixth Framework Programme (FP6), partici-
pants in a consortium will have the responsibility to fully carry
out the tasks entrusted to them even if one of the participants
fails to comply with assigned tasks. However, the principle of
financial collective responsibility established in FP6 for most
actions is not continued. Depending on an assessment of the
risks inherent in European research funding to the Community
budget, a mechanism may be introduced to cover the financial
risk of a participant's failure to reimburse any amount due to
the Community. Therefore, bank guarantees are only to be
requested in the rare case in which pre-financing represents
over 80 % of the grant.

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4. The Committee's comments

4.1
Simplification. The Committee supports the extremely
important objective of simplifying all of the procedures that
the Commission had been using until now or that the Commis-
sion has requested of R&D actors. The Committee sees its
comments as a constructive contribution to their achievement
and is aware that achieving this objective is not straightforward,
given the general budgetary rules and the call for transparency
— a call which the Committee itself subscribes to. It would be
particularly useful to try out administrative procedures which
have been simplified even further, within the limits of what is
legally possible, on selected pilot projects; the resulting experi-
ences could help in reaching decisions on future measures.

4.1.1
Improvements. The Committee recognises that the
Commission has made efforts to achieve this aim and to ensure
that the Community provides the best possible support for
research. In that connection, it regards many points in these
proposals as clear improvements to the existing procedures, for
example with regard to reimbursement of costs (Articles 30
and 31), to forms of grant, as well as to grant agreements,
contracts and appointment
(Articles 18 and 19);
however, in the latter case the new rules will only represent an
improvement if payment and above all reporting arrangements
are also simplified. In that connection, the Committee would
also refer to its earlier recommendations on simplification (6),
which, among other things, concern the harmonisation of the
procedures requested by the Commission with those of other
funding or supervisory bodies in terms of content and time-
table (7).

letters

4.1.2
Standardisation. Efforts to standardise the procedures
followed or requested by the Commission — e.g. costing or
credit rating — more closely also serve to meet the objective of
simplification. In the interests of the Single Market and also of
the Committee fully concurs with
greater
this (8). Unfortunately, full standardisation will not be achieved
unless the various recipients of grants, such as universities, in
the different Member States for their part apply standardised or
aligned accounting systems.

legal certainty,

4.2 Other rules and measures. To achieve simplification
and standardisation,
the Commission will need to adopt
further measures, which are as yet only outlined in the
proposal, for example in Article 16.4:
‘The Commission shall
adopt and publish rules to ensure consistent verification of the exis-
tence and legal status of participants in indirect actions as well as
their financial capacity’. Since these other rules, referred to hence-
forth as ‘the Commission's internal implementing rules’, are still
pending, in certain cases it is still too early to assess what the
impact of the corresponding proposals of the Commission will
be.

(6) OJ C 110, 30.4.2004.
OJ C 157, 28.6.2005.
OJ C 65, 17.3.2006.

(7) OJ C 157, 28.6.2005: Preventing overlap and parallelism of

administration and governing bodies.

(8) Going beyond what is envisaged by the Commission's proposal, it
would even be desirable to standardise payment procedures for all
Community support measures — including the CIP programme and
Structural Funds — more closely.

expects

consistent

interpretation of

4.2.1
Consistent interpretation and criteria. Furthermore,
the Committee
the
Commission's internal
implementing rules, especially those
in all
concerning the legal and financial aspects of projects,
relevant Commission departments, enabling further progress
towards simplification and standardisation and ensuring that
the respective R&D actors do not lose out by comparison with
existing arrangements. In general, the Committee recommends
imple-
additional clarification in the Commission's internal
menting provisions to close any remaining loopholes in the
Commission's proposal, in the interests of legal certainty.

Support measures. However,

4.2.2
the helpdesks and
‘clearing houses’ proposed or already provided by the
Commission should ensure that the messages given out by the
Commission are consistent and uniform. The Committee sees
this as a important and useful measure. However, it should also
be ensured that a consistent approach is followed in internal
Commission procedures and in the requirements and decisions
of project officers.

to avoid situations, apart

it
from in well

Reporting requirements. For example,

is also
4.2.3
justified
important
exceptional cases, in which project officers request mid-term
reports over and above what is required by the rules, and in
which several versions of
information have to be
identical
included in various reports (9). It is also important to standar-
formal
dise reporting requirements, not only in terms of
requirements but also in terms of content.

4.2.4 Mid-term assessment. In view of the fact that the 7th
Framework Programme will run for seven years, the Committee
also recommends that a mid-term assessment of both the
programme and the rules for participation be carried out
halfway through this period in order to make any necessary
adjustments.

Project officers. Another important requirement for
4.2.5
simplification, standardisation and for effective administrative
procedures in general, which also serves to maintain the neces-
sary continuity (see next point), is for project officers to have
detailed specialist knowledge of the subject in question and to
know the persons concerned; project officers cannot confine
themselves to a purely administrative role unless they have in-
depth subject and background knowledge. The Committee
would refer to its recommendations (10) on this point (11), which
it has reiterated on several occasions.

4.3
Continuity. Given that any change in the rules means a
break in continuity and additional friction, it is important to
carefully consider whether the Commission's proposed changes
would actually translate into significantly enhanced efficiency
so as to outweigh such disruption, or whether it would be
better to retain the existing rules. The Committee acknowledges

(9) See also the previous two footnotes.
(10) e.g. point 9.8.4 in C 204 of 18.7.2000.
(11) See footnote 6.

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that the Commission's proposal envisages retaining many rules
which have proved effective. However,
in the case of some
proposed changes it is not clear whether they would actually
represent an improvement on existing rules. In such cases the
Committee recommends that continuity should be the primary
consideration.

4.4
Community financial contribution — reimburse-
ment and forms of support. Subject to a satisfactory resolu-
tion of the questions which are still open (e.g. in point 4.5), the
Committee sees
the relevant Commission proposals as a
substantial improvement and supports them.

4.4.1
SMEs. In particular, the Committee welcomes (Article
33-1, second sentence) the increase in support ceilings, e.g. (12)
for SMEs from 50 % to 75 %. It sees this partly as a reflection
of its earlier recommendation to offer more and better incen-
tives for greater SME participation in the Seventh R&D Frame-
work Programme and also to promote closer networking of
SMEs and research institutes (13).

etc.

Higher

education

establishments

4.4.2
The
Committee also welcomes the fact that support ceilings will
rise to 75 % in public bodies, secondary and higher education
establishments and research organisations as well (also Article
33-1, second sentence). In that connection, it recommends that
Article 33 be worded more clearly so that it is possible to
distinguish more easily between profit and non-profit making
parties.

4.4.3
Average rates for personnel costs. The Committee
believes that giving participants the option of applying average
rates for personnel costs could help to achieve simplification
(Article 31-3 (a)).

4.4.4 Management costs. In the interests of maintaining
the necessary continuity, the Committee also welcomes the fact
that 100 % reimbursement of management
costs will
continue. However, the proposal to unconditionally do away
with the previous ceiling of 7 % for this type of expenditure
could cause problems, unless stringent standards are applied to
the necessary management costs in some other way. Admit-
tedly, the previous 7 % ceiling was found to be too low, given
that administration, coordination, etc. required a great deal of
expenditure, and it should therefore be raised. However, unlim-
ited reimbursement of all administrative costs should not be

(12) And also for public bodies, secondary and higher education estab-

lishments and research organisations.

(13) In this connection, the Committee would refer to its recommenda-
tion on the introduction of a grace period for patents; however, it
would not be necessary to associate a right of priority with the
scientific publication. See CESE 319/2004, points 2.5 ff., OJ C 110,
30.4.2004.

allowed to result in an unwelcome inflation rather than reduc-
tion in management costs.

4.5
Additional costs for universities. Under the Commis-
sion proposal, universities and similar research institutions
should no longer be able to have 100 % of their so-called addi-
tional costs (14) reimbursed. Although other accounting models
are proposed, the Committee feels that the proposal could
cause problems, given that such institutions do not usually
have suitable analytical accounting procedures to calculate full
costs (15). What is more, it is too early to tell if the possible
alternative of a flat rate proposed by the Commission will
make them significantly worse off, as the Commission's internal
implementing rules for this proposal are still pending (see
if full cost accounting is not available to
above). Therefore,
these institutions, the Committee recommends retaining the
existing rule on 100 % reimbursement of additional costs, at
least until it is certain that other accounting models (16) will not
result
in these institutions losing out by comparison with
existing arrangements.

Legal status of research organisations. The Committee
4.6
feels that research organisations which are mainly State-funded
should receive equal treatment in all respects (and in all articles
of the regulation, for example Article 33-1 and Article 38-2),
irrespective of their legal status. This means for example that
non-profit making research organisations or research centres
established under private law which receive their core funding
from the State (17) should also be placed on an equal footing
with public-law organisations. Ultimately, the choice of most
appropriate legal status for such research institutes lies within

(14) Additional cost model: calculation of reimbursable direct additional
costs of parties to the contract, plus a flat rate for indirect costs,
according to the additional cost model. In the Seventh R&D Frame-
work Programme (RP6), this flat rate corresponds to 20 % of all
direct additional costs, minus costs for subcontracts.

(15) Full cost model: calculation of reimbursable direct and indirect
costs of parties to the contract according to the full cost model; full
cost flat-rate model: calculation of reimbursable direct costs of
parties to the contract; plus a flat rate for indirect costs, according to
the full cost flat-rate model. The flat rate amounts to 20 % of all
direct costs, minus costs for subcontracts. In all three cost models in
RP6 (FC, FCF and AC), total costs are calculated simply as the sum
of direct and indirect costs.

(16) In any case, as far as R&D activities are concerned, the possible flat
rate to cover indirect costs (overhead) in Article 32 should be at
least 20 % of reimbursable direct costs, minus subcontracts. This rule
applied to the Sixth R&D Framework Programme for full cost flat-
rate and additional cost accounting systems and should be retained
for the sake of continuity and above all to be fair to the different
accounting systems of participating organisations.
such as
Fraunhofer-Gesellschaft,

(17) In Germany,
the Helmholtz-
Leibniz-
Gemeinschaft,
Gemeinschaft or the Max-Planck-Gesellschaft. In the Netherlands
e.g. The Netherlands Organisation for Scientific Research — Neder-
landse Organisatie voor Wetenschappelijk Onderzoek (NWO).

research organisations

the

the

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the legislative competence of the Member States, and should
certainly not
in any differentiation of Community
research funding.

result

able to reach the most appropriate agreement. It may make
sense, for example, to also grant R&D actors royalty-free access
rights.

4.7
Intellectual property. The rules proposed in Articles
39-43 are intended to ensure that rights to intellectual property
derived from findings financed by EU taxpayers' money cannot
be transferred to companies outside Europe without being
subject to any controls.

4.7.1 Open source software. In general, the only chance
that software developed within the framework of Community
funded research projects currently has of becoming widely
available and widely used and of therefore producing spin-off
commercial versions or services,
is if it is offered as ‘open
source’. For this purpose, the consortium should be granted as
much freedom as possible as regards license conditions.

Access rights. Access rights (Articles 48-52) (18) to fore-
4.8
ground and/or background owned by the parties do not
concern all foreground and background owned by one of the
parties (e.g. a university or research centre), but only to fore-
ground and background derived from the work or preparatory
activity of organisational entities or groups involved in the rele-
vant joint project and which are needed by the other partici-
pants in the indirect action to complete their work. The
Committee therefore welcomes Article 48 which enables this
issue to be clarified separately for each project through the
drawing up of positive and/or negative lists (19) agreed by all
parties to the contract. Furthermore, positive lists can also be
used to prevent any disclosure of the existence of background
which is to be kept confidential. However, in order not to slow
down the start of the project unnecessarily,
it would make
sense to set a deadline of e.g. up to six months after the begin-
ning of the project for these lists to be drawn up.

Royalty-free access to foreground and background.
4.9
The Committee has reservations about regulations that will
grant unconditional access to foreground and background on a
royalty-free basis. In general, it recommends that project part-
ners be granted as much freedom as possible so that they are

(18) The Committee would like to point out that, when compared with
the English version, it is apparent that there are translation errors
in Articles 50-1 and 51-1 of the German version of the Commis-
sion proposal. This Committee opinion refers to the correct English
version.

(19) Positive list: list of knowledge or areas of knowledge to be made
accessible. Negative list: list of knowledge or areas of knowledge
NOT to be made accessible.

4.9.1
Background for the implementation of a measure.
The proposal to always grant R&D actors royalty-free access
rights to background, as long as it is essential for the imple-
mentation of an indirect measure, is to be welcomed in prin-
ciple. In certain cases, however, an exclusive regulation of this
type
relevant actors. The
for
Committee therefore recommends modifying the final sentence
of Article 50-2 (20).

can cause difficulties

the

4.9.2
Background for the use of foreground. However,
the proposal to always grant R&D actors access rights to back-
ground royalty-free, as long as it is essential for the use of fore-
ground, could cause problems. Background was acquired using
R&D actors' own resources, the resources of former funding
bodies or with the public resources of the respective Member
States, and is subject to relevant obligations and conditions (21).
Should the proposed Commission regulation be applied, there
is a risk that especially powerful R&D actors, and those actors
with a high level of know-how potential would not be able or
even willing to participate, and therefore would be excluded
from participating. The Committee therefore recommends
deleting or modifying Article 51-5 (22).

4.9.3
‘Frontier’ research. Although most of the research
and development activity envisaged as part of ‘frontier’ research
is in the field of basic research, the distinction between basic
and applied research is often (23) blurred, as the Committee has
pointed out on several occasions. Therefore the same negative
outcomes mentioned above are to be expected here. This
should be avoided at all costs and thus taken into account in
the regulations. The Committee therefore recommends deleting
Article 52-1 or modifying it accordingly (24).

(20) A possible suggestion for the final sentence of Article 50-2 would
be ‘However, RTD Performers shall grant access rights to back-
ground on a royalty-free basis, unless for justified exceptions other-
wise agreed by all participants before their accession to the grant
agreement’.

(21) In Germany, for example, the Employees' Inventions Act as well.
(22) A possible suggestion would be ‘RTD-Performers shall grant access
rights to background needed to use the foreground generated in
the indirect action on a royalty-free basis unless otherwise agreed
by all participants before their accession to the grant agreement’.

(23) e.g. in microbiology, laser technology and ICT.
(24) Article 52-1 could read as follows, ‘In the case of frontier research
actions, access rights to foreground for the implementation of the
project shall be granted royalty-free. Access rights to foreground
for use shall be under fair and reasonable conditions or royalty-free
as agreed by all participants before their accession to the grant
agreement’.

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Specific Groups. There is no definition in the
4.9.4
Commission proposal of
It
should certainly not be confused with the definition for ‘fron-
tier’ research, or even considered to be the same.

the work for Specific Groups.

4.10
Free choice of instruments. The Committee reiterates
its recommendation (25) that projects should not be tied in
advance to particular instruments, but that ‘applicants must be
able to adjust the structure and size of projects to best suit the task at
hand. Otherwise, projects will be established whose size and structure
are determined by the prescribed policy tools rather than by optimum
scientific and technical
requirements. The tools must serve R&D
working methods and objectives — never the reverse.’ To this end,
the option of Specific Targeted Research Projects (STREPs)
should be continued, as they are a particularly suitable instru-
ment
supporting participation by SMEs and smaller
for
research groups.

4.11 Discontinuation of the principle of financial collec-
tive responsibility. The Committee is pleased that the prin-
ciple of financial collective responsibility is to be discontinued;
it would point out that it has already referred to the problems
arising from this in its recommendations on the sixth frame-
work programme (26).

4.11.1
Risk fund. The Committee therefore supports the
proposal to establish a risk fund to cover possible defaults,
with a small percentage of the financial contribution to indirect
actions being paid into the fund (Article 38(1)). However,
it
would be advisable for the Commission to specify the proposed
range of percentages when publishing the proposal, depending
on the estimated level of risk. The Committee is also pleased
that possible surpluses from amounts set aside to cover risks
will be reimbursed to the framework programme and constitute
earmarked revenue.

4.11.2
Exemption. However, the Committee would recom-
mend that Article 38(2) exempt all research institutes which
receive their core funding from the State, irrespective of their
legal status, from this requirement (27).

Brussels, 5 July 2006.

4.11.3
Project abandonment. The Committee would also
refer to the proposed technical collective responsibility of
project participants (see Article 18(4)).
In the Committee's
opinion, even a consortium should have the option of deciding
to abandon a project if excessive expenditure or scientific or
technical considerations mean that continuation ceases to be
worthwhile or reasonable. Articles 18(4) and 18(5) should be
amended accordingly.

Programme committees. Under

4.12
the Commission's
proposal, programme committees responsible for stream-
lining procedures will no longer have the task of approving
funding for proposed projects. In the Committee's view, this
should only happen if the Commission selects projects on the
basis of assessors' evaluations. Otherwise, work programmes
and budget allocation should remain subject to approval by the
relevant programme
compromise
would be to submit a ‘call implementation plan’ after comple-
tion of evaluation to the programme committee for it
to
discuss and formally adopt.) This would not slow the process
down in any way as the programme committee would no
longer be taking decisions on individual projects.

(A possible

committee.

Grant agreement. The relevant Article here (19-8)
4.13
makes reference to the Charter for Researchers and the Code of
Conduct for the Recruitment of Researchers. The Committee
would like to point out that this Charter is only a recommenda-
tion and is therefore not binding. Furthermore, the Committee
notes that it actually welcomes many elements of the Charter
but that it has also recommended that it be revised, in particu-
lar because it contains too many regulations and certain criteria
are not clear (28).

The

Bank.

European

Investment

4.14
Committee
welcomes the proposal for a grant for the European Investment
Bank to cover risks arising from loans in support of
the
research objectives of the Seventh R&D Research Framework
Programme, and the proposed accompanying rules. Such loans
should be provided for demonstration projects (e.g. in the fields
of energy or security research) in particular.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

(25) Point 3.4, OJ C 157, 28.6.2005.
(26) OJ C 94, 18.4.2002.
(27) See above, equal treatment of all research institutes which receive

their core funding from the State.

(28) OJ C 65, 17.3.2006.