Proposal for a DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the mobilisation of the European Globalisation Adjustment Fund in accordance with point 28 of the Interinstitutional Agreement of 17 May 2006 between the European Parliament, the Council and the Commission on budgetary discipline and sound financial management (application EGF/2009/024 NL/Noord Holland and Zuid Holland Division 58 from the Netherlands)
Date: 2010-10-01
Institutions: European Commission
Subjects: EU aid, Netherlands, budgetary discipline (EU), commitment of expenditure, dismissal, financial management, globalisation, interinstitutional agreement, reintegration into working life

EN 

EN 

   EN 

 
EUROPEAN COMMISSION 

Brussels, 1.10.2010 
COM(2010) 532 final 

Proposal for a 

DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the mobilisation of the European Globalisation Adjustment Fund in accordance with 
point 28 of the Interinstitutional Agreement of 17 May 2006 between the European 
Parliament, the Council and the Commission on budgetary discipline and sound 
financial management (application EGF/2009/024 NL/Noord Holland and Zuid Holland 
Division 58 from the Netherlands) 

EN 

   EN 

 
 
  
EXPLANATORY MEMORANDUM 

Point  28  of  the  Interinstitutional  Agreement  of  17 May  2006  between  the  European 
Parliament,  the  Council  and  the  Commission  on  budgetary  discipline  and  sound  financial 
management1  allows  for  the  mobilisation  of  the  European  Globalisation  Adjustment  Fund 
(EGF) within the annual ceiling of EUR 500 million over and above the relevant headings of 
the financial framework.  

The rules applicable to the contributions from the EGF are laid down in Regulation (EC) No 
1927/2006  of  the  European  Parliament  and  of  the  Council  of  20  December  2006  on 
establishing the European Globalisation Adjustment Fund2. 

On  30  December  2009,  the  Netherlands  submitted  application  EGF/2009/024  NL/Noord 
Holland and Zuid Holland Division 58, for a financial contribution from the EGF, following 
redundancies in eight enterprises operating in the NACE Revision 2 Division 58 (publishing 
activities)3 in the two contiguous NUTS II regions Noord Holland (NL32) and Zuid Holland 
(NL33) in the Netherlands. 

This  application  is  part  of  a  package  of  six  interrelated  applications,  all  of  which  concern 
redundancies in eight different NUTS II regions in the Netherlands in enterprises operating in 
the  graphics  sector,  the  activities  of  which  are  classified  under  two  different  NACE  2 
Revision 2 Divisions, namely Division 18 (printing and reproduction of recorded media) and 
Division 58 (publishing activities). 

After  a  thorough  examination  of  this  application,  the  Commission  has  concluded  in 
accordance  with  Article  10  of  Regulation  (EC)  No  1927/2006  that  the  conditions  for  a 
financial contribution under this Regulation are met. 

SUMMARY OF THE APPLICATION AND ANALYSIS 

Key data: 

EGF Reference no. 
Member State 
Article 2 
Enterprises concerned 
NUTS II regions 
NACE Revision 2 Division 
Reference period 
Starting date for the personalised services 
Application date 
Redundancies during the reference period: 
Redundant workers targeted for support 

EGF/2009/024 
Netherlands 
(b) 
8 
Noord Holland (NL32) and Zuid Holland (NL33) 
58 (publishing activities) 
1/4/2009 to 29/12/2009 
1/4/2009 
30/12/2009 
598 
598 

1 
2 
3 

OJ C 139, 14.6.2006, p. 1. 
OJ L 406 of 30.12.2006, p. 1. 
Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 
establishing the statistical classification of economic activities NACE Revision 2 and amending Council 
Regulation (EEC) No 3037/90 as well as certain EC regulations on specific statistical domains (OJ L 
393 of 30.12.2006, p. 1). 

EN 

2 

   EN 

                                                 
Personalised services: budget in EUR 
Expenditure for implementing EGF4: budget in EUR 
% expenditure for implementing EGF 
Total budget in EUR 
EGF contribution EUR (65 %) 

3 436 000,89 
143 166,70 
4 % 
3 579 168 
2 326 459 

1. 

2. 

The  application  was  presented  to  the  Commission  on  30  December  2009  and 
supplemented by additional information up to 31 May 2010. 

The application meets the conditions for deploying the EGF as set out in Article 2(b) 
of  Regulation  (EC)  No  1927/2006,  and  was  submitted  within  the  deadline  of  10 
weeks referred to in Article 5 of that Regulation.  

Link  between  the  redundancies  and  major  structural  changes  in  world  trade  patterns 
due to globalisation or the global financial and economic crisis 

3. 

In order to establish the link between the redundancies and the global financial and 
economic  crisis,  the  Netherlands  argues  that  the  economic  crisis  resulted  in  a 
substantial  decrease  in  demand  for  the  printing  and  publishing  sector.  The  orders 
from other economic sectors for printed advertising material, which represents 35 % 
of  the  total  turnover  of  the  printing  and  publishing  sector,  decreased  by  5,6 % 
between  2008  and  2009  due  to  the  reduction  of  budgets  for  media  and  advertising 
activities induced by the economic crisis. The application cites several examples. In 
the construction industry, the budget for information and publicity was cut by 36,8 % 
following  the  start  of  the  crisis,  in  the  financial  sector  by  33,3 %  and  in  consumer 
electronics  by  30,6 %.  In  addition,  the  economic  crisis  negatively  affected  demand 
for various types of printed media material: in the first six months of 2009, demand 
for  popular  magazines  decreased  by  18,2 %,  for  newspapers  by  7,5 %,  for 
commercial  newspapers  distributed  free  of  charge  by  16,4 %  and  for  professional 
magazines by 16,5 % compared to the same period in 2008. 

Demonstration  of  the  number  of  redundancies  and  compliance  with  the  criteria  of 
Article 2(b) 

4. 

5. 

The Netherlands submitted this application under the intervention criteria of Article 
2(b)  of  Regulation  (EC)  No  1927/2006,  which  requires  at  least  500  redundancies 
over  a  nine-month  period  in  enterprises  operating  in  the  same  NACE  Revision  2 
Division  in  one  region  or  two  contiguous  regions  at  NUTS  II  level  in  a  Member 
State. 

The  application  cites  598  redundancies  in  eight  enterprises,  operating  in  the  same 
NACE  Revision  2  Division,  during  the  nine-month  reference  period  from  1  April 
2009  to  29  December  2009,  all  located  in  the  contiguous  NUTS  II  regions  Noord 
Holland  (NL32)  and  Zuid  Holland  (NL33).  Thirty  redundancies  were  calculated  in 
accordance with the first indent and 568 redundancies in accordance with the second 
indent of the second paragraph of Article 2 of Regulation (EC) No 1927/2006. 

Explanation of the unforeseen nature of those redundancies 

4 

In accordance with the third paragraph of Article 3 of Regulation (EC) No 1927/2006. 

EN 

3 

   EN 

                                                 
6. 

The Dutch authorities argue that the financial and economic crisis and its impact on 
the  sector  could  not  be  foreseen.  The  application  states  that  before  the  crisis  the 
printing  and  publishing  industry  in  the  Netherlands  went  through  an  expensive 
restructuring process in order to remain technically competitive with enterprises from 
outside the EU, in particular in Turkey, China and India. The sector was transformed 
from a demand driven to a supply oriented industry. The current crisis bears the risk 
of  cancelling  out  the  benefits  of  the  heavy  investments  and  efforts  made  by  the 
sector. 

Identification of the dismissing enterprises and workers targeted for assistance 

7. 

The  application  cites  a  total  of  598  redundancies,  all  of  whom  are  targeted  for 
assistance, in the following eight enterprises: 

Enterprises and number of dismissals 

Audax Publishing BV, Amsterdam 

Keesing Nederland BV, Amsterdam 

PCM uitgevers BV, Amsterdam 
Reed Business BV, Amsterdam 
Total enterprises: 8 

11 

1 

27 
172 

TMG distributie BV, Amsterdam 
Kluwer BV Uitgeverij vestiging 
Alphen, Deventer 
Uitgeverij Lakerveld BV, Wateringen 
Sanoma Uitgevers, Hoofddorp 

337 

12 

2 
36 

Total dismissals: 598 

8. 

The break-down of the targeted workers is as follows: 

Category 
Men 
Women 
EU citizens 
Non EU citizens 
15 to 24 years old 
25 to 54 years old 
55 to 64 years old 
Over 65 years old 
There are 24 workers (4 %) with a longstanding health problem or disability included 
in the categories above. 

Number 
389 
209 
562 
36 
108 
329 
149 
12 

Percent 
65 
35 
94 
6 
18 
55 
25 
2 

9. 

In terms of professional categories, the break-down is as follows: 

Category 
Manager 
Professional 
Technicians 
Clerical support workers 
Service and sales workers 
Plant and machine operators and assemblers 

Number 
42 
119 
126 
72 
72 
167 

Percent 
7 
20 
21 
12 
12 
28 

10. 

In accordance with Article 7 of the Regulation (EC) No 1927/2006, the Netherlands 
has  confirmed  that  a  policy  of  equality  between  women  and  men  as  well  as  non-
discrimination has been applied, and will continue to apply, during the various stages 
of the implementation of and, in particular, in access to the EGF. 

Description of the territory concerned and its authorities and stakeholders 

EN 

4 

   EN 

 
11. 

12. 

The territory concerned covers the provinces Noord Holland and Zuid Holland. Both 
provinces  belong  to  the  Randstad,  the  most  densely  populated  area  in  the 
Netherlands.  Noord  Holland  is  also  concerned  by  the  redundancies  covered  by 
application  EGF/2009/026  NL/Noord  Holland  and  Utrecht  Division  18,  whereas 
Zuid  Holland 
redundancies  covered  by  application 
EGF/2009/027  NL/Noord  Brabant  and  Zuid  Holland  Division  18,  both  of  which 
relate  to  the  printing  activities  (NACE  Revision  2  Division  18)  of  the  graphics 
industry.  The  conurbations  with  the  highest  concentration  of  enterprises  in  the 
graphics sector are Amsterdam, Den Haag, Rotterdam, Leiden, Rijswijk and Alphen. 

is  concerned  by 

the 

The main authorities concerned are the Ministry for Social Affairs and the Training 
Fund  for  the  graphics  and  media  sector  (A&O  Fonds  Grafimedia)  by  order  of  the 
Council  for  consultation  in  the  graphics  and  media  sector.  Other  relevant 
stakeholders  are  the  Institute  for  creative  industry  (GOC),  the  public  organisation 
responsible for allowances (UWV werkbedrijf), UWV mobility centres Amsterdam, 
Haaglanden, the organisation for SMEs (MKB-ondernemingen), the regional training 
centres Amsterdam, Mondriaan, Zadkine, the municipalities Amsterdam, Rotterdam, 
Den  Haag,  and  the  social  partner  organisations:  FNV  Kiem  (trade  union),  CNV 
Media  (trade  union),  KVGO  (employers'  organisation)  for  the  district  Leiden, 
Haarlem, Amsterdam, Den Haag, NUV (employers' organisation). 

Expected impact of the redundancies as regards local, regional or national employment 

13. 

The  Dutch  authorities  argue  that  the  redundancies  in  the  graphics  sector  will 
aggravate the unemployment situation, which has already deteriorated as a result of 
the  economic  and  financial  crisis.  In  the  province  of  Noord  Holland,  which  is  also 
affected  by  the  redundancies  covered  by  application  EGF/2009/026  NL/Noord 
Holland  and  Utrecht  Division  18,  the  unemployment  rate  increased  from  5,7 %  in 
October 2008 to 6,5 % in October 2009. For Zuid Holland, which is also affected by 
the redundancies covered by application EGF/2009/027 NL/Noord Brabant and Zuid 
Holland  Division  18,  this  rate  increased  from  5,4 %  to  6,4 %  for  the  same  period. 
The  number  of  people  searching  for  a  job  increased  by  10,1 %  between  February 
2009  and  February  2010  in  Noord  Holland,  for  Zuid  Holland  the  increase  was 
16,1 %  for  the  same  period.  The  applicant  further  refers  to  the  fact  that  in  the 
graphics  sector  there  is  a  relatively  high  proportion  of  workers  in  the  older  age 
groups where unemployment is very high in the two provinces under consideration. 

Co-ordinated  package  of  personalised  services  to  be  funded  and  a  breakdown  of  its 
estimated  costs,  including  its  complementarity  with  actions  funded  by  the  Structural 
Funds 

14. 

The  following  types  of  measures  are  proposed,  all  of  which  combine  to  form  a 
coordinated package of personalised services aimed at re-integrating the workers into 
the labour market. They will be offered to the dismissed workers through a mobility 
centre, called C3: Centre Creative Careers (Centrum Creatieve Carrières). 

Preparatory activities 

–  Intake  and  registration:  covers  an  initial  interview  in  order  to  register  the 

dismissed worker and to identify the most suitable types of measures. 

EN 

5 

   EN 

–  Information and helpdesk: relates to collective meetings and a helpdesk function 
to provide information to the dismissed workers about the available measures. 

Accompaniment 

–  Job  to  job  accompaniment:  covers  an  individualised  programme  including 
screening, the establishment of a career and vocational action plan and short time 
mentoring at the new workplace. 

–  Outplacement:  seeks  to  give  active  support  to  dismissed  workers  in  their 

exploration of new job opportunities. 

–  Application  training:  covers  the  analysis  of  available  job  vacancies,  support  for 
the drafting of a CV and an application letter and preparation for job interviews. 

–  Accompaniment towards business creation: seeks to assist dismissed workers who 
envisage  creating  their  own  business.  This  covers  the  provision  of  legal  advice, 
assistance  for  the  elaboration  of  a  business  plan,  support  on  administrative 
requirements. 

Training 

–  Training and re-training: covers vocational training, management and social skills 
training and specific technical re-training for workers whose technical training has 
become obsolete. 

–  Recognition  of  prior  experience:  covers  the  evaluation  of  prior  knowledge  and 
experience of each individual worker as well as the identification of areas where 
further training is required. 

The  expenditure  for  implementing  EGF,  which  is  included  in  the  application  in 
accordance  with  Article  3  of  Regulation  (EC)  No  1927/2006,  covers  management 
and control activities as well as information and publicity. 

The personalised services presented by the Dutch authorities are active labour market 
measures  within  the  eligible  actions  defined  by  Article  3  of  Regulation  (EC)  No 
1927/2006.  The  Dutch  authorities  estimate  the  total  costs  of  these  services  at 
EUR 3 436 000,89  and  the  expenditure  for  implementing  EGF  at  EUR 143 166,70 
(= 4 %  of  the  total  amount).  The  total  contribution  requested  from  the  EGF  is 
EUR 2 326 459 (65 % of the total costs). 

Estimated 
number of 
workers 
targeted 

Estimated cost 
per worker 
targeted 
(in EUR) 

Total costs 
(EGF and 
national 
cofinancing) 
(in EUR) * 

15. 

16. 

Actions 

Personalised services (first paragraph of Article 3 Regulation (EC) No 1927/2006) 

1. Preparatory activities 

1.1. Intake and registration (intake en 

598

193,07 

115 456,32

EN 

6 

   EN 

 
registratie) 

1.2. Information and helpdesk 
(voorlichting en helpdesk) 

2. Accompaniment 

2.1. Job to job accompaniment (werk naar 
werk begeleiding) 

2.2. Outplacement 

2.3. Application training 
(solicitatietraining) 

598

85,81 

51 313,92

248

243

309

3 465,62 

859 474,70

4 465,44 

1 085 102,78

1 415,22 

437 302,55

2.4. Accompaniment towards business 
creation (begeleiding eigen onderneming) 

31

5 264,18 

163 189,72

3. Training 

3.1. Training and retraining (opleiding en 
omscholing) 

3.2. Recognition of prior experience 
(erkenning verworven competenties) 

195

172

2 488,45 

485 248,09

1 389,03 

238 912,82

Sub total personalised services 

3 436 000,89

Expenditure  for  implementing  EGF  (third  paragraph  of  Article  3  of  Regulation  (EC)  No 
1927/2006) 

Management 

Information and publicity 

Control activities 

Sub total expenditure for implementing 
EGF 

Total estimated costs 

EGF contribution (65 % of total costs) 

* Totals do not tally due to rounding 

35 791,68

35 791,68

71 583,35

143 166,70

3 579 168

2 326 459

17. 

The  Netherlands  confirms  that  the  measures  described  above  are  complementary 
with  actions  funded  by  the  Structural  Funds,  in  particular  with  a  number  of  ESF 
training  projects  for  workers  in  the  graphics  sector,  the  timing  of  which  coincides 
with the EGF implementation period. The managing authority for the EGF, which is 
also  managing  authority  for  the  ESF  has  put  in  place  the  necessary  control 
procedures to eliminate any risk of double funding. 

EN 

7 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Date(s)  on  which  the  personalised  services  to  the  affected  workers  were  started  or  are 
planned to start 

18. 

The Netherlands started the personalised services to the affected workers included in 
the co-ordinated package proposed for co-financing to the EGF on 1 April 2009. This 
date therefore represents the beginning of the period of eligibility for any assistance 
that might be awarded from the EGF. 

Procedures for consulting the social partners 

19. 

The  social  partners  were  consulted  through  the  Foundation  Labour  Market  and 
Training  Fund  for  the  graphics  and  media  sector  (Arbeids  &  Opleidingsfonds 
Grafimedia  branche),  which  in  the  light  of  the  crisis  agreed  on  the  creation  of  a 
mobility centre for the sector named C3 (Centrum Creatieve Carrières). The aim of 
this  mobility  centre  is  to  coordinate  the  various  active  labour  market  measures  in 
consultation with the social partners. 

20. 

The  Dutch  authorities  confirmed  that  the  requirements  laid  down  in  national  and 
Community legislation concerning collective redundancies have been complied with. 

Information  on  actions  that  are  mandatory  by  virtue  of  national  law  or  pursuant  to 
collective agreements 

21. 

As regards the criteria contained in Article 6 of Regulation (EC) No 1927/2006, the 
Dutch authorities in their application:  

•  confirmed that the financial contribution from the EGF does not replace measures 
which are the responsibility of companies by virtue of national law or collective 
agreements; 

•  demonstrated that the actions provide support for individual workers and are not 

to be used for restructuring companies or sectors; 

•  confirmed  that  the  eligible  actions  referred  to  above  do  not  receive  assistance 

from other Community financial instruments. 

Management and control systems  

22. 

The Netherlands has notified the Commission that the financial contribution will be 
managed  and  controlled  by  the  same  bodies  that  manage  and  control  the  European 
Social  Fund  (ESF)  funding  in  the  Netherlands.  The  Agency  for  Social  Affairs  and 
Employment  (Agentschap  SZW)  will  be  the  intermediate  body  for  the  managing 
authority. 

Financing 

23. 

On the basis of the application from the Netherlands, the proposed contribution from 
the  EGF  to  the  coordinated  package  of  personalised  services  is  EUR 2 326 459, 
representing 65 % of the total cost. The Commission's proposed allocation under the 
Fund is based on the information made available by the Netherlands. 

EN 

8 

   EN 

24. 

25. 

26. 

Considering the maximum possible amount of a financial contribution from the EGF 
under  Article  10(1)  of  Regulation  (EC)  No  1927/2006,  as  well  as  the  scope  for 
reallocating  appropriations,  the  Commission  proposes  to  mobilise  the  EGF  for  the 
total  amount  referred  above,  to  be  allocated  under  heading  1a  of  the  financial 
framework. 

The  proposed  amount  of  financial  contribution  will  leave  more  than  25 %  of  the 
maximum annual amount earmarked for the EGF available for allocations during the 
last  four  months  of  the  year,  as  required  by  Article  12(6)  of  Regulation  (EC)  No 
1927/2006. 

By  presenting  this  proposal  to  mobilise  the  EGF,  the  Commission  initiates  the 
simplified  trialogue  procedure,  as  required  by  Point  28  of  the  Interinstitutional 
Agreement of 17 May 2006, with a view to securing the agreement of the two arms 
of the budgetary authority on the need to use the EGF and the amount required. The 
Commission invites the first of the two arms of the budgetary authority that reaches 
agreement on the draft mobilisation proposal, at appropriate political level, to inform 
the other arm and the Commission of its intentions. In case of disagreement by either 
of  the  two  arms  of  the  budgetary  authority,  a  formal  trialogue  meeting  will  be 
convened.  

27. 

The Commission presents separately a transfer request in order to enter in the 2010 
budget specific commitment and payment appropriations, as required in Point 28 of 
the Interinstitutional Agreement of 17 May 2006. 

Source of payment appropriations 

28. 

29. 

In  the  current  state  of  implementation,  it  is  foreseeable  that  the  payment 
appropriations available in 2010 under the budget line 01.0404 "Competitiveness and 
Innovation  Framework  Programme  -  Entrepreneurship  and  innovation  programme" 
will not be fully used this year. 

This line covers expenditure related to the implementation of the financial instrument 
of this programme, the main objective of which is to facilitate the access of SMEs to 
finance. Some time lag exists between transfers to the trust accounts managed by the 
European Investment Fund and disbursement to the beneficiaries. The financial crisis 
has a major effect on the forecasts in terms of disbursements for 2010. As a result, in 
order  to  avoid  excessive  balances  on  the  trust  accounts,  the  methodology  for 
calculation  of  payment  appropriations  has  been  reviewed,  taking  into  account  the 
expected  disbursements.  The  amount  of  EUR 2 326 459  can  therefore  be  made 
available for transfer. 

EN 

9 

   EN 

Proposal for a 

DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the mobilisation of the European Globalisation Adjustment Fund in accordance with 
point 28 of the Interinstitutional Agreement of 17 May 2006 between the European 
Parliament, the Council and the Commission on budgetary discipline and sound 
financial management (application EGF/2009/024 NL/Noord Holland and Zuid Holland 
Division 58 from the Netherlands) 

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union, 

Having  regard  to  the  Interinstitutional  Agreement  of  17 May  2006  between  the  European 
Parliament,  the  Council  and  the  Commission  on  budgetary  discipline  and  sound  financial 
management5, and in particular point 28 thereof, 

Having  regard  to  Regulation  (EC)  No  1927/2006  of  the  European  Parliament  and  of  the 
Council  of  20 December  2006  establishing  the  European  Globalisation  Adjustment  Fund6, 
and in particular Article 12(3) thereof, 

Having regard to the proposal from the European Commission7, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

The  European  Globalisation  Adjustment  Fund  (EGF)  was  established  to  provide 
additional support for workers made redundant as a result of major structural changes 
in world trade patterns due to globalisation and to assist them with their reintegration 
into the labour market. 

The scope of the EGF was broadened for applications submitted from 1 May 2009 to 
include support  for workers made  redundant  as a direct result of the global financial 
and economic crisis. 

The Interinstitutional Agreement of 17 May 2006 allows the mobilisation of the EGF 
within the annual ceiling of EUR 500 million. 

The  Netherlands  submitted  an  application  to  mobilise  the  EGF,  in  respect  of 
redundancies  in  eight  enterprises  operating  in  NACE  Revision  2  Division  58 
(publishing activities) in the two contiguous NUTS II regions Noord Holland (NL32) 
and  Zuid  Holland  (NL33)  on  30  December  2009  and  supplemented  it  by  additional 
information up to 31 May 2010. This application complies with the requirements for 

5 
6 
7 

OJ C 139, 14.6.2006, p. 1. 
OJ L 406, 30.12.2006, p. 1. 
OJ C […], […], p. […]. 

EN 

10 

   EN 

                                                 
the 

determining 
in  Article  10  of 
Regulation (EC) No 1927/2006.  The  Commission,  therefore,  proposes  to  mobilise  an 
amount of EUR 2 326 459. 

financial  contributions  as 

laid  down 

(5) 

The EGF should, therefore, be mobilised in order to provide a financial contribution 
for the application submitted by the Netherlands. 

HAVE DECIDED AS FOLLOWS: 

Article 1 

For  the  general  budget  of  the  European  Union  for  the  financial  year  2010,  the  European 
Globalisation  Adjustment  Fund  (EGF)  shall  be  mobilised  to  provide  the  sum  of 
EUR 2 326 459 in commitment and payment appropriations. 

This Decision shall be published in the Official Journal of the European Union. 

Article 2 

Done at, 

For the European Parliament 
The President 

For the Council 
The President 

EN 

11 

   EN