COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE ANALYTICAL DOCUMENT Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Towards a Quality Framework on Traineeships Second-stage consultation of the social partners at European level under Article 154 TFEU
Date: 2012-12-05
Institutions: European Commission
Subjects: Internet site, access to a profession, job access, job creation, labour mobility, quality standard, traineeship, youth unemployment

EUROPEAN 
COMMISSION 

Brussels, 5.12.2012  
SWD(2012) 408 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE ANALYTICAL DOCUMENT 

Accompanying the document 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS  

Towards a Quality Framework on Traineeships 

Second-stage consultation of the social partners at European level 
under Article 154 TFEU  

{COM(2012) 728 final} 
{SWD(2012) 407 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE ANALYTICAL DOCUMENT 

Accompanying the document 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS  

Towards a Quality Framework on Traineeships 

Second-stage consultation of the social partners at European level 
under Article 154 TFEU  

This  staff  working  document  summarizes  the  analysis  supporting  the  second  stage 
consultation  of  the  European  social  partners  on  a  possible  EU  initiative  on  a  Quality 
Framework for Traineeships. The consultation will gather the opinions of the European social 
partners, pursuant to Articles 154-155 of the Treaty on the Functioning of the European Union 
(TFEU),  on  the  content  of  a  potential  EU  initiative  on  this  issue.  It  follows  a  public 
consultation  carried  out  between  19  April  and  11  July  2012  and  a  first  stage  Social  Partner 
consultation  on  the  possible  direction  of  an  EU  initiative,  which  took  place  between  11 
September and 23 October 2012.  

1. 

PROBLEM DEFINITION 

Currently over five million young people in the EU under the age of 25 cannot find a job: in 
some  Member  States  unemployment  among  young  people  exceeds  50%.  In  this  context, 
increasing  the  access  of  young  people  to  the  labour  market  and  enhancing  transitions  from 
education to work is a top priority for the EU. Traineeships – defined as a limited period of 
work  practice  spent  at  business,  public  bodies  or  non-profit  institutions  by  students  or  by 
young  people  having  recently  completed  their  education,  in  order  to  gain  some  valuable 
hands-on  experience  in  a  work  environment,  ahead  of  taking  up  regular  employment  –  can 
have a crucial role in this context. Traineeships can provide a possible stepping stone to more 
productive  employment  careers,  they  can  help  foster  sustainable  job  creation,  reduce  youth 
unemployment and eventually contribute to raise the employment rate – one of the headline 
targets  of  the  Europe  2020  Strategy.  It  has  to  be  noted  however  that  traineeships  –  unlike 
apprenticeships  –  are  not  covered  by  employment  contracts  in  most  Member  States,  also 
meaning that they are in general less regulated. 

Despite the fact that traineeships have a number of benefits not only for trainees, but also for 
employers  and  the  society  as  a  whole,  concerns  about  the  effectiveness  and  quality  of 
traineeships  have  been  recognized  by  European  Institutions.  Open-market  traineeships  in 
particular  (where  apart  from  the  trainee  and  the  host  organization  no  other  institution  is 

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involved  in  the  definition,  organisation  and  monitoring  of  the  traineeship  and  its  learning 
content and other conditions; this is typically – but not exclusively – the case of post-graduate 
traineeships),  being  the  least  regulated  type  in  most  countries,  are  the  object  of  particular 
attention. In 2010 the European Parliament adopted a Resolution calling specifically for better 
and secured internships and for a European Quality Charter setting out minimum standards for 
internships  to  ensure  their  educational  value  and  avoid  exploitation.  In  2011,  the  European 
Commission foresaw in its Youth Opportunity Initiative the launch of a Quality Framework 
on Traineeships by the end of 2012. Furthermore, the June 2012 European Council concluded 
that  "It  is  crucial  to  address  youth  unemployment,  in  particular  through  the  Commission's 
initiatives  on  youth  guarantees  and  the  quality  framework  for  traineeships".  Finally,  the 
European cross-sectoral social partners (BusinessEurope, UEAPME, CEEP, ETUC) agreed to 
"promote  more  and  better  apprenticeship  and  traineeship  contracts"  and  "ensure  the  right 
working  conditions  to  welcome  and  support  new  entrants  in  the  enterprise"  as  key  actions 
under their 2010 Framework Agreement on Inclusive Labour Markets. 

Quality problems 

Studies and surveys show that quality problems related to traineeships are mostly linked to the 
lack  of  learning  content,  the  lack  of  or  insufficient  compensation/remuneration,  and 
unsatisfactory  working  conditions.  A  further  problem  –  to  a  large  extent  related  to  the 
previous ones – is the low level of intra-EU trainee mobility.  

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Key quality elements identified in the Traineeship study1 

A  good  quality  traineeship  should  enable  the  trainee  to  acquire  practical  skills  geared  to  the  labour 
market needs and complementary to the trainee’s theoretical studies in order to enhance the trainee's 
employability. A good quality traineeship should be based on an agreement between the trainee and 
the host organisation. The traineeship agreement should cover the following elements:  

• Objectives, content and monitoring: Traineeships should enable the trainee to acquire practical skills 
complementary  to  his  or  her  theoretical  studies.  The  guidelines  require  that  educational  content  is 
ensured by assigning a personal supervisor or mentor at the host organisation to each trainee. 

• Duration: Open-market traineeships should typically not be longer than 6 months. Mandatory post-
graduation  professional  training  of  doctors,  lawyers,  teachers  and  the  like  are  exempted  as  these 
traineeships tend to be highly regulated.  

• Remuneration/cost compensation: If there is a mutual benefit for both the host organisation and the 
trainee in terms of knowledge transfer and learning, unpaid traineeships may be appropriate. Hence the 
quality guideline should only stipulate that the written traineeship agreement clearly specifies what, if 
any, compensation and remuneration is offered. 

• Social security provisions: The social insurance provisions need to be clarified between the trainee 
and the employer. This includes health insurance and insurance against accidents at the workplace. 

Insufficient learning content may mean that the host organization is not providing (enough) 
learning  sessions  for  the  trainees  to  explain  its  work/operations  etc.,  or  does  not  ensure  a 
mentor.  This  is  quite  frequent  in  the  case  of  traineeships  where  trainees  have  to  execute 
mundane work.  

A second group of concerns relate the lack of or the low level of compensation. The EYF 
survey indicates that only 25% of trainees were remunerated enough to cover living expenses. 
Lack  of  compensation  explains  concerns  about  equity  of  access,  and  raises  issues  about 
employers using traineeships as a form of unpaid employment with ‘cheaper’ trainees being 
used for entry level jobs and/or other job vacancies instead of regular staff. Nevertheless, it is 
important  to  note  that  remuneration/compensation  issues  have  to  be  dealt  at  Member  State 
level or by social partners because the EU Treaties do not provide a legal basis for EU action 
in this respect (see also in section 4 – Legal basis and subsidiarity). 
A  third  group  of  problems  relate  to  working  conditions  other  than  compensation,  such  as 
long  working  hours,  substandard  working  conditions,  lack  of  coverage  for  health  or 
occupational risks, lack of clarity on the applicable legal regimes, fairness aspects and so on.  

Finally, a fourth group of problems of concern in  terms  of  the  integration  of  the  EU  labour 
market  is  the  low  level  of  intra-EU  mobility  for  trainees.  This  has  important  negative 
consequences for the integration of the EU labour markets, and prevents young people living 

1 

Study on a comprehensive overview of traineeship arrangements in the EU Member States, European 
Commission (2012), henceforth “the Traineeship study”. 

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in countries with a bad traineeship offer to profit from better opportunities in the EU single 
market. 

2. 

CONSULTATION OF STAKEHOLDERS 

Public consultation and consultation of the European social partners 

The public consultation received over 250 responses. Trade unions, as well as NGOs, youth 
organisations,  educational  institutions,  agencies  involved  in  transnational  traineeships  and 
most  individual  respondents  largely  agreed  to  the  Commission's  analysis,  definition  of  key 
elements of quality traineeships, problem definition and objectives and generally supported a 
Commission  initiative  in  this  area  (some  asking  for  a  binding  legal  instrument,  others 
preferring non-binding  recommendations); employers' organisations,  chambers  of  commerce 
and  industry  –  while  acknowledging  the  positive  role  of  traineeships  in  school-to-work 
transitions  and  in  acquiring  skills  –adopted  a  more  sceptical  stance,  raising  concerns  as  to 
whether remuneration and social protection issues could be covered in this context and some 
further questioning the need for an EU initiative. 

Both employer organisations and Member States referred to the need to keep the framework 
sufficiently  flexible  so  that  diversity  of  national  systems  and  practices  can  be  taken  into 
account. Opponents of EU action argued that minimum requirements for traineeships should 
not be set at the European level, due to a lack of EU competence particularly on the issue of 
remuneration. Concerns were also raised about traineeship schemes becoming overburdened 
with  legal  or  administrative  procedures  that  could  discourage  companies  from  taking  on 
trainees,  thus  depriving  young  people  of  valuable  work  experience  opportunities.  Opinions 
about the scope of a possible initiative were varied, too, notably with regard to the possibility 
of limiting the scope to 'open market' traineeships only.  

The responses to the 1st stage consultation of the European social partners have confirmed the 
above positions without contributing any new elements. 

3. 

OBJECTIVES OF THE INITIATIVE 

The general objectives of an initiative in this domain are  

(1) to facilitate education-to-work transitions 

High  quality  traineeships  contribute  to  increasing  the  employability  of  young  people. 
Traineeships as a form of labour market entry for graduates should be stepping stones in the 
progression  to  a  regular  employment,  ensure  a  rapid  increase  in  workers’  productivity  and 
help reduce precarious employment. The objective should therefore be increasing the number 
of good quality traineeships and reducing the extent of low-quality instances and abuse.  

(2) to promote mobility in order to reduce mismatches in the European labour market 

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To  reduce  structural  unemployment,  the  promotion  of  learners'  and  of  workers'  geographic 
mobility  within  the  EU  should  be  stepped  up,  given  the  existence  of  marked  skill  and 
demand/supply  mismatches  in  the  labour  market.  Developing  transnational  traineeships  is  a 
key tool for this. Prospective trainees who consider undertaking their training in another EU 
Member State should have a clear reference to check quality criteria and not be discouraged 
by uncertainty about administrative formalities; legal concerns, or contractual obligations. 

In order to meet these general objectives, the following specific objective has been identified: 

To improve the quality of traineeships in the EU.  

The operational objectives would be 

(1)  To  encourage  host  organisations  to  offer  traineeships  providing  good  quality  learning 
content,  decent  working  conditions  and  which  are  a  good  stepping  stone  for  entering  the 
labour market.  

(2) To increase the transparency and quality of information on traineeship positions. 

4. 

LEGAL BASIS AND SUBSIDIARITY 

According  to  Article  153  TFEU,  the  Union  shall  support  and  complement  Member  States 
activities in the field of, inter alia, working conditions, social security and social protection of 
workers,  and  also  the  integration  of  persons  excluded  from  the  labour  market  and  the 
combating  of  social  exclusion.  Pursuant  to  Article  153  para.  2.  b)  TFEU,  the  European 
Parliament  and  the  Council  may  adopt  Directives  in  the  field  of  employment  and  social 
policy.  

Alternatively, according to Article 292 TFEU, the Council can adopt recommendations on the 
basis  of  a  Commission  proposal.  Occupational  Safety  and  Health  legislation  considers 
trainees  and  apprentices  as  covered  by  the  scope  of  the  Directives  based  on  framework 
Directive of 1989, whose basis is Art 153 TFEU.  

However,  it  should  be  noted  that  the  provisions  of  Article  153  TFEU  do  not  apply  to  pay 
(Article 153 para. 5 TFEU). Hence, the problems relating to low trainee compensation have to 
be dealt with at another level, notably by Member States and social partners. 

Mobility  in  education  and  training  forms  a  central  objective  in  the  EU's  educational  policy 
and is an integral part in of the freedom of movement of persons under Article 45 TFEU – a 
fundamental freedom protected by the Treaty.  

Subsidiarity  

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Generally,  great  diversity  of  situations  among  Member  States,  or  very  different  societal 
preferences  are  arguments  in  favour  of  decentralised  solutions,  as  they  can  be  tailored  to 
national  or  even  local  needs  and  preferences.  However,  in  the  case  of  traineeships,  the 
difference of labour market institutions does not seem to play a major role, as the nature of the 
complaints  and  concerns  put  forward  is  very  similar  everywhere,  and  quality  problems  in 
traineeships  are  frequent  even  in  the  Member  States  where  the  labour  market  situation  of 
young people is more favourable.  

In addition, an EU-wide solution would present several operational advantages.  

(1) 

(2) 

(3) 

The  quality  guidelines  adopted  or  proposed  so  far  generally  look  very  similar, 
irrespective  of  the  organisation  drafting  them.  This  suggests  that  there  is  no  great 
need of adaptation of quality standards to local conditions. 

An  EU  wide-solution  would  have  clear  benefits  in  terms  of  intra-EU  mobility  of 
trainees. Young people would find it easier to accept a traineeship in another country 
if standard or harmonised rules gave them a clear knowledge of what they can expect 
in  another  country.  Greater  trainee  mobility  would  contribute  to  achieving  a  more 
integrated EU labour market through better matching and sustainable job creation. 

that,  owing 

Experience  shows 
the  definition  of 
internationally  accepted  quality  standards  can  be  faster  if  supranational  institutions 
coordinate and support. The EU is best placed for this, as there seems to be little or 
no movement towards spontaneous development of international quality standards.  

to  coordination  problems, 

Through an initiative in this sense, the EU could concretely support Member States to meet 
the  EU  2020  employment  guideline  nr  8.  Providing  guidance  to  the  Member  States  that  is 
operational  and  can  be  readily  implemented  at  national  level  appears  all  the  more  useful, 
given the acuteness of the crisis and past delays in tackling traineeships problems. It is also 
fully in line with the spirit of the European Semester. 

Despite  frequent  calls  to  promote  high-quality  traineeships  action  from  Member  States  has 
been patchy and the regulatory framework generally remains fragmented and unsatisfactory. 

The  traditional  European  employment  strategy  approach  could  be  used  to  induce  Member 
States to reform traineeship regimes, but would lead to greater differentiation in the resulting 
framework than instruments such as recommendations or legislation determining the content 
of traineeship regimes. This would be suboptimal particularly in terms of the need to address 
existing barriers to trainee mobility.  

Finally, an EU solution seems to be a pre-condition for extending EURES to apprenticeships 
and traineeships, as requested by the European Council. This is needed to prevent the risk that 
support  supplied  through  EURES  is  provided  to  low-quality  traineeships  that  do  not  help 
smooth education-to-work transitions. 

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5. 

POSSIBLE AVENUES FOR EU ACTION 

In  respect  of  the  autonomy  of  the  social  partners,  no  possible  actions/options  have  been 
discarded at this stage, nor has the reflection been limited to particular types of traineeships. 
Actions could be taken, depending on the types of traineeships, at different levels, involving 
different actors and different tools. For example the EU could:  

• 

• 

• 

• 

• 

improve  the  transparency  of  traineeship  regulation  through  more  accessible 
information,  

encourage voluntary action by stakeholders (host organisations, social partners etc.) 
to  enhance  the  quality  of  traineeships,  for  instance  through  the  establishment  of 
quality labels,  

launch actions under the European employment strategy to encourage Member States 
to improve the quality of traineeships, 

introduce non-binding instruments (recommendations or guidelines) or  

introduce binding legislation.  

Scope and measures 

Market failure in delivering quality can generally be tackled in two ways, either by enhancing 
the  quality  and  availability  of  information  on  the  market,  or  by  imposing  quality  standards. 
Either approach could enhance the effectiveness of traineeships in ensuring good transitions 
from  education  to  work.  In  the  following,  a  number  of  measures  based  on  the  first  or  the 
second approach are explored. 

Open-market  traineeships  seem  to  represent  an  obvious  candidate  for  initiatives,  but 
alternatives  exist:  the  scope  of  the  measures  could  be  restricted  to  apply  to  cross-border 
traineeships only, or to traineeships with a duration above three months. 

The  social  partners  may  wish  to  consider  one  or  more  of  the  below  measures,  requiring 
different  levels  of  engagement  of  EU  institutions.  Several  of  these  measures  could  be 
combined together. The analysis of impacts is only indicative at this stage and will be further 
elaborated in a future impact assessment. 

i) No initiative at EU level (baseline scenario) 

Description: The Commission will continue to pursue the objective of improving mobility and 
labour  market  transitions  of  young  people  without  any  specific  instrument/tool  focusing  on 
traineeships. The Traineeships study provides a first overview of the traineeship arrangements 
in the Member States and lays a basis for more transparency of arrangements. 

Discussion: While it is possible that there are further national initiatives in order to enhance 
the quality of traineeships, the overall share of low quality traineeships could easily increase: 

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the crisis may lead businesses to scale back new hirings, which are one of the main reasons 
for offering high-quality traineeships, and new labour market entrants may revise downwards 
their expectations accordingly. 

ii) Creation of an information website  

Description: Setting up a website with a traineeship panorama (containing regularly updated 
information on traineeship conditions and the legal framework in each Member State) would 
constitute a non-regulatory approach to increase the availability of general information about 
traineeships.  As  a  bolder  option,  the  website  could  also  allow  trainees  to  give  feedback  on 
their individual traineeship experience with a host organisation, transforming the nature of the 
information from purely general to specific. 

Discussion:  A  properly  designed,  user-friendly  website  would  allow  easier  access  to 
information  on  national  legislation  of  traineeships,  on  the  availability  of  different  types  of 
traineeships  in  Member  States.  This  would  reduce  search  costs  for  trainees,  could  improve 
matching and could also have a positive effect on increasing the availability of candidates for 
transnational traineeships.  

While  there  is  no  compliance  cost  for  Member  States  or  host  organisations,  there  would  be 
some budgetary implications for the organisation running the website. 

This  tool  addresses  part  of  the  lack  of  information  problem,  i.e.  the  lack  of  general 
information  on  standards,  but  does  not  provide  information  on  the  quality  of  specific 
traineeship positions on offer. Hence, though positive, the impact of this option on traineeship 
quality is modest. The option of allowing trainees to assess or rate their traineeship experience 
would  instead  create  a  fairly  strong  incentive  for  hosts  to  improve  the  quality  of  their 
traineeships,  as  their  reputation  would  benefit  from  being  shown  to  offer  high  quality 
traineeship conditions.  

iii) Quality label for traineeships 

Description:  A  set  of  quality  principles  for  traineeships  could  be  elaborated  in  cooperation 
with  social  partners,  specifying  minimum  quality  guidelines  for  the  format  and  learning 
content  of  the  traineeship  (see  the  quality  elements  identified  in  the  Traineeship  study). 
Companies, educational institutions, employment services and/or other relevant actors could 
voluntarily commit to respect the guidelines for trainees, and in exchange for that, publicise 
themselves as ‘fair to trainees’ or similar. The quality label for traineeships could also include 
a  commitment  by  the  host  organisation  on  providing  remuneration  and  social  security 
treatment. Furthermore, it is possible to launch a quality label specifically in certain sectors. 

To achieve minimal compliance costs, the quality label could be attributed to all organisations 
that  would  commit  to  it  without  advance  inspection  or  screening.  A  certain  number  of  duly 
justified complaints could lead to the withdrawal of the label. Such a light organisation would 
allow the label to be managed by the companies concerned, or by a small external office. 

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Discussion:  This  solution  can  encourage  and  guide  host  organisations  by  providing  a 
reference  for  quality,  while  its  voluntary  nature  ensures  that  it  is  bearable  for  host 
organisations.  It  goes  some  way  into  providing  a  positive  incentive  for  adoption,  given  that 
one of the motives for organisations to offer traineeships is improving their reputation, which 
could  be  enhanced  by  a  quality  label.  This  option  might  also  stimulate  cross-border 
traineeships.  

The voluntary nature of the commitment seems to make sure that the compliance burden for 
businesses would be acceptable. However, there is a risk that only few organisations apply for 
the  label,  particularly  as  at  present  demand  for  traineeships  outstrips  supply.  Furthermore, 
many of those that apply probably will be those that offer high quality traineeships already.  

iv) European Quality Framework for Traineeships  

Description:  This  measure  would  consist  in  a  social  partner  agreement  or  a  Commission 
proposal on quality elements, to be transposed by Member States in national practice and/or 
the  national  legal  system.  The  quality  framework  could  include  the  elements  listed  in  the 
Traineeship  study,  providing  clear  indications  to  trainees  on  objectives,  content  and 
monitoring; duration; compensation; and social security coverage. 

Discussion:  The  strength  of  this  approach  is  that  the  quality  framework  would  be  the  same 
framework in all (adopting) Member States. This would therefore address the negative impact 
of the diversity of regulations on the development of international mobility.  

The elements identified in the study could be complemented with a limitation of successive 
traineeships,  and/or  with  a  requirement  to  register  traineeships.  Similar  measures  have  been 
adopted in certain Member States. Limiting the repetition of traineeships by the same person 
in the same organisation, or, more boldly, prescribing that host organisations need, over the 
medium term, to hire a certain (limited) percentage of the trainees it engages would address 
the  problem  of  young  people  having  to  do  several  traineeships  before  finding  regular 
employment. Instruments similar to a quality framework already exist within the EU (e.g. UK 
Code of Best Practice for Quality Internships). 

Overall, a reasonable improvement on the quality and transparency of traineeships could be 
expected  in  the  medium  term  from  a  quality  framework  endorsed  at  European  and  national 
level. A limitation of successive traineeships could be effective in limiting replacement risk. 
Furthermore,  a  compulsory  registration  of  traineeships  would  allow  having  better  statistics 
about traineeships and support effective enforcement of rights. Regarding the impact on the 
availability of traineeship places, this option would include a certain risk that some employers 
will refrain in the future from providing traineeship places, most likely because they realise 
that the traineeship places they offered so far were not of good quality.  

While  most  of  the  costs  of  this  option  would  have  to  be  borne  by  host  organisations, 
compliance  costs  would  mainly  be  related  to  ensuring  a  proper  learning  content.  Host 

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organisations  that  already  provide  learning  content  would  merely  need  to  give  it  the 
appropriate level of formality by listing learning objectives and some other key characteristics 
of the traineeship on paper. Hence the reduction of traineeships offered can be considerably 
limited if the additional workload for compliant businesses is communicated as manageable.  

An  important  question  however  remains  the  effectiveness  of  the  impact  on  bad  quality 
traineeships as regulatory solutions may work least in Member State with weaker enforcement 
mechanisms. As regards proportionality, the quality framework for traineeships can contribute 
to achieving the intended objectives while EU level action is not disproportionate.  

6. 

FINAL OVERVIEW 

The options and sub options presented above could be variously combined together.  

The following table summarises the avenues for action presented above in terms of possible 
impacts and compliance costs.  

Option 

law 

Voluntary 
(V)/Soft 
(SL)/Regulat
ory  solution 
® 

Potential 
Impact 
quality 
traineeship  

on 
of 

on 
for 

Impact 
demand 
traineeships 
positions 
(D  – 
domestic  –  CB  – 
cross-border) 

Impact 
on 
compliance  costs 
for  businesses  = 
impact  on  supply 
of 
traineeship 
positions 

on 

Impact 
compliance 
costs 
SMEs 

for 

Information 
website 
trainees 

for 

na 

0 

D: 0 

CB: + 

Quality label  

V/SL 

0/+ 

D: + 

CB: ++ 

0 

0 

0 

0 

Flexible 
solution 

Yes 

Fairly 

Quality label + 
remuneration 

V/SL 

0/+ 

D: + 

0/(-) 

0(-) 

Fairly 

CB: ++/+++ 

Quality 
framework  for 
traineeships 
(QFT), 

QFT  for  long, 
crossborder 
traineeships 

® 

® 

Key:  

0 : zero or negligible impact 

++ 

D: ++ 

0/(-) 

-/-- 

No 

CB: ++/+++ 

+/++ 

D: ++ 

0/(-) 

-/-- 

No 

CB: ++/+++ 

(+) / (-) :slight positive (negative) but uncertain impact 

+ / -: possible positive/ negative impact 

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++ / -- : likely positive/ negative impact 

+++/--- : very likely positive/ negative impact 

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