Source: EURLEX
Language: en
Format: md

![european flag](./../../../images/eclogo.jpg)EUROPEAN COMMISSION

Brussels, 6.2.2017

COM(2017) 55 final

REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT

Ex post evaluation report on the Daphne Programme (2007-2013)

TABLE OF CONTENTS

1
   INTRODUCTION
   

1.1
   OBJECTIVE OF THE REPORT
   

1.2
   METHODOLOGY AND SOURCE OF INFORMATION
   

1.3
   OVERVIEW OF THE PROGRAMME
   

2
   EVALUATION RESULTS
   

2.1
   RELEVANCE OF THE DAPHNE III PROGRAMME
   

2.2
   COHERENCE AND COMPLEMENTARITY
   

2.3
   EFFECTIVENESS
   

2.4
   SUSTAINABILITY AND TRANSFERABILITY
   

2.5
   EFFICIENCY AND SCOPE FOR SIMPLIFICATION
   

2.6
   EUROPEAN ADDED VALUE
   

3
   CONCLUSIONS
   

1INTRODUCTION

1.1OBJECTIVE OF THE REPORT

[1](#footnote1)
[2](#footnote2)
The Decision establishing the Daphne III programme requires the Commission to present an ex post evaluation covering 2007-2013. The evaluation was carried out by an independent external evaluator assisted by the Commission staff.

This report is based on that evaluation. The programme's total planned budget for 2007-2013 was EUR 123.88m. The report is structured by the main evaluation criteria (and corresponding questions), including relevance, coherence and complementarity; effectiveness, impact and sustainability; efficiency and scope for simplification; and European added value.

1.2METHODOLOGY AND SOURCE OF INFORMATION

This final evaluation of the Daphne III programme is based on the following:

an extensive review of documentation on all 302 action or operating grants funded under the 2007-2013 programme;

a review of programme documents, e.g. the funding decision, annual work programmes and calls for proposals for both grants and public procurement contracts;

a review of other online information, e.g. EU policy documents, websites and funding decisions on related EU programmes;

a quantitative analysis of the 302 projects;

an analysis of 145 responses to the online survey from Daphne III grant beneficiaries;

write-ups of 30 follow-up interviews with coordinators of projects or organisations receiving Daphne III grants between 2007 and 2013 who took part in the online survey;

interviews with six Commission officials.

1.3OVERVIEW OF THE PROGRAMME

Daphne III was set up in 2007 by Decision No 779/2007/EC, following three Commission instruments with the same aims: the Daphne Initiative (1997-1999)
[3](#footnote3)
; the Daphne Programme (2000-2003)
[4](#footnote4)
; and the Daphne II Programme (2004-2008)
[5](#footnote5)
. It is managed by the Directorate-General (DG) Justice of the European Commission.

Article 2 of Decision No 779/2007/EC outlines its general objectives, which are:

to help protect children, young people and women against all forms of violence and to help them attain a high level of health protection, wellbeing and social cohesion;

to help develop Community policies (in public health, human rights and gender equality) and action to protect children’s rights and combat trafficking in human beings and sexual exploitation.

Article 3 states that the programme's specific objective is to help achieve the general objectives by supporting preventive measures and providing support and protection for victims and groups at risk. It also lists transnational actions and other types of actions to achieve the specific objective, namely:

assisting and encouraging NGOs and other organisations working in the field;

developing or implementing targeted awareness-raising;

disseminating the results of Daphne I and II, including their adaptation, transfer and use by other beneficiaries or in other geographical areas;

identifying and improving the treatment of people at risk of violence;

setting up or supporting multi-disciplinary networks involving NGOs and other organisations active in this field;

expanding evidence-based information and the knowledge base and exchanging, identifying and disseminating information and good practice, through research, training, study visits and staff exchanges, among other means;

designing, testing, supplementing and adapting awareness-raising and educational materials;

studying phenomena linked to violence and its impact on victims and society in general;

developing and implementing support programmes for victims and people at risk and intervention programmes for perpetrators.

Daphne III, like other programmes under DG Justice’s General Programme on Fundamental Rights and Justice (2007-2013), funds measures through three different mechanisms:

Action grants: co-funding (up to 80% of total costs) for specific projects designed and implemented by not-for-profit organisations and/or public institutions, which may run for a maximum of two years.

Operating grants: financial support (up to 80%) for the running costs of an organisation’s annual budget.

Tendered contracts or public procurement: funds are also available for specific actions initiated by the Commission (Commission’s initiatives), e.g. feasibility studies, research into specific topics, organising conferences or building IT systems.

[Table 1](#_Ref402727120)
[1](#_Ref402727120)
below lists the number of grants funded in each year of the period evaluated
[6](#footnote6)
.

Table 11 Number of grants funded annually

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  | 2007 | 2008 | 2009 | 2010 | 2011 | 2012 | 2013 [7](#footnote7) | TOTAL |
| Action grants | 41 | 42 | 83 | | 60 | | 0 | 226 |
| Operating grants | 9 | 12 | 7 | 5 | - | 6 | 5 | 44 |
| Specific action grants  (116 Missing Children Hotline, Child Abduction Alert Mechanism) | - | - | - | - | - | - | 21 | 21 |
| Specific operating grants  (116 Missing Children Hotline) | - | - | - | - | - | 14 | - | 14 |

Note: The figures in the table differ from the number of projects analysed for this evaluation (302), as documentation was not available for all projects (305).

The total budget earmarked for Daphne III (2007-2013) was almost EUR 124m, the average annual planned budget being just almost EUR 18m
[8](#footnote8)
. The lion's share of the budget (EUR 97,7m or just over 79%) was earmarked for action grants. As regards the extent to which the initial programme allocation was effectively committed, roughly EUR 60m was committed to action grants (in terms of grant agreements signed), EUR 4.5m euro to operating grants and EUR 1.2m to procurement between 2010 and 2013 (see 
[Table 1](#_Ref456352640)
[2 Planned budgetary breakdown for Daphne III (2007-2013)](#_Ref456352640)
).

Table 12 Planned budgetary breakdown for Daphne III (2007-2013)

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Year | Available budget for grants and contracts | | | | | | | |
|  | Action grants | | Operating grants | | Commission initiatives | | Total annual budget | |
|  | Value (EUR ) | % | Value (EUR ) | % | Value (EUR ) | % | Value (EUR ) | % |
| 2007 | 11 000 000 | 85% | 1 900 000 | 15% | 1 000 000 | 8% | 13 000 000 | 100% |
| 2008 | 11 944 160 | 81% | 2 000 000 | 14% | 800 000 | 5% | 14 744 160 | 100% |
| 2009 | 14 417 120 | 81% | 2 580 000 | 14% | 800 000 | 4% | 17 797 120 | 100% |
| 2010 | 15 393 600 | 83% | 2 500 000 | 14% | 560 000 | 3% | 18 453 600 | 100% |
| 2011 | 14 476 000 | 71% | 2 000 000 | 10% | 4 000 000 | 19% | 20 476 000 | 100% |
| 2012 | 14 007 000 [9](#footnote9) | 70% | 4 000 000 [10](#footnote10) | 20% | 2 000 000 | 10% | 20 007 000 | 100% |
| 2013 | 16 504 000 [11](#footnote11) | 90% | 1 000 000 [12](#footnote12) | 5% | 1 000 000 [13](#footnote13) | 5% | 18 504 000 | 100% |
| Total | 97 741 880 |  | 15 980 000 |  | 10 160 000 |  | 123 881 880 |  |

Source: DAPHNE III - annual work programmes (2007-2013)

Most Daphne III projects were led by national NGOs (including national platforms and networks) (47%), followed by universities (18%) and European networks, platforms and forums (13%)
[14](#footnote14)
.This is consistent with the programme's specific objectives, which state that these objectives are to be achieved by assisting NGOs and other organisations in the field.

Action grants were awarded to organisations working together in partnership. The involvement of partner organisations follows a similar structure to that of the lead organisations observed. The most common partners (56% of the total) are national NGOs, including national platforms and networks, while universities account for 15% of all partners. However, the distribution of partner organisations differs from that of lead organisations, with higher representation of public services (4%) among partner organisations than among lead organisations (0.33%)
[15](#footnote15)
. Again, this follows the requirements of the Programme’s specific objectives, as it is supposed to set up and support multidisciplinary networks, while also strengthening cooperation between NGOs and other organisations in the field.

As regards public procurement, almost 70% of the budget committed went on studies or research (e.g. the 2009 Eurobarometer survey on European citizens' perception of violence against women, young people and children), including the mid-term and final evaluations of the programme. A further 27% was spent on awareness-raising, including events, and almost 4% on maintaining the Daphne III website.
[16](#footnote16)

2EVALUATION RESULTS

2.1RELEVANCE OF THE DAPHNE III PROGRAMME

The relevance of a programme is assessed in terms of the extent to which its actions logically address its objectives, the wider EU policy needs and the needs of the target audiences.

2.1.1Relevance of measures to objectives

The measures implemented under the programme and the programme priorities were found to be relevant to the programme and its objectives. However, the analysis also showed that the alignment of priority areas on programme objectives was a weak indicator of 'relevance' (both of the priority areas and of the projects funded under those priorities). This was because both the programme's objectives and the priorities set were broad in nature and not clearly linked to specific EU policy objectives.
[17](#footnote17)
 This lack of targeting at programme level may have made it more challenging to achieve targeted and therefore relevant results in this EU policy area. Indeed, the strategic programming of the annual priorities in the first half of the programme was not determined by long-term policy analysis. Rather, it was based on an analysis of topics already covered by funded projects.

Nonetheless, the programme had funded many initiatives which informed and supported the development of policy and, to a lesser extent, legislation. Further, the Commission held wider internal consultations on policy priorities from 2011 and placed more emphasis on relevance as a selection criterion.
[18](#footnote18)
 The aim was to shape the results of the programme better and to boost its impact.

Reporting by grant beneficiaries suggests that end beneficiaries responded positively to the projects, indicating that they considered the measures relevant. However, this cannot be confirmed without gathering their views independently. Nonetheless, a review of the measures funded suggests that they were designed to respond to beneficiaries' identified needs and that most were developed on the basis of needs assessments.
[19](#footnote19)
 

2.1.2Relevance of the funded projects / work programmes to the objectives of the Programme

In all action grant and operating grant calls, relevance to the programme's general and specific objectives was a key criterion for selection. A review of the operational objectives and areas of activity of the 302 projects (out of 307 projects in total, see 
[Table 1](#_Ref402727120)
[1 Number of grants funded annually](#_Ref402727120)
) and work programmes funded through Daphne III shows that all were designed either to prevent violence against women, children and young people or to protect victims and people at risk. Their project and work programme objectives were therefore aligned on those of the Daphne III programme
[20](#footnote20)
. The types of activities covered by both are described below:

Projects designed to prevent violence, including those focusing on:

studies investigating the root causes of particular forms of violence;

awareness-raising among the general public, people likely to encounter victims or people at risk of falling victim to or perpetrating violence;

setting up positive treatment services for identified perpetrators;

developing policies to prevent violence more effectively.

Projects designed to protect victims or people at risk, including those focusing on:

training for professionals in contact with victims;

providing support services to victims;

evaluating support services or action to protect women, young people and children and/or disseminate good practices.

2.1.3Relevance to target group needs

Daphne III received 1921 applications in total, i.e. 6.36 applications for every grant awarded. Daphne had a high application rate compared to the other four DG Justice programmes. There are a number of possible reasons for its popularity: there are no other EU programmes focusing on violence and its prevention (grant beneficiaries interviewed reported that the Daphne programme was 'unique'); national funding has fallen as a result of the economic crisis; the programme targets interest groups and organisations, which are more used to identifying funding streams and applying for grants than public authorities, for example; and the priority areas were sufficiently broad to accommodate a wide range of eligible projects.
[21](#footnote21)

Most online respondents (96%) considered the priorities relevant both to the target group's specific needs and to those of their country. Moreover, of the 30 grant beneficiaries interviewed for the evaluation, almost all stated that the programme's conceptual framework (i.e. its objectives and priorities) had enabled them to develop their projects as originally envisaged. Only four had found some of the calls restrictive, and the main reason for this was the duration and/or size of the grant, not the conceptual framework.
[22](#footnote22)

2.2COHERENCE AND COMPLEMENTARITY

Article 11 of Council Decision No 779/2007/EC establishing the Daphne III programme outlines the scope for complementarity and creating synergies with the following EU financial instruments:

Security and Safeguarding Liberties (comprising two programmes, ‘Prevention and Fight against Crime (ISEC)’ and ‘Prevention, Preparedness and Consequence Management of Terrorism and other Security Related Risks’ (CIPS));

Solidarity and Management of Migration Flows (comprising the External Borders Fund (EBF), European Return Fund (RF), European Refugee Fund (ERF) and European Fund for the Integration of third-country nationals (EIF));

Seventh Research and Development Framework Programme;

Programmes on health protection, employment and social solidarity — PROGRESS;

Safer Internet Plus.

The Decision also provides that complementarity with the European Institute for Gender Equality (EIGE) and the Community Statistical Programme (Eurostat) will be sought. The rationale is that these may have objectives, target groups or end beneficiaries, and/or approaches that are similar or identical to those of the Daphne III programme.

Other EU instruments that could potentially complement or overlap with Daphne III include:

other DG Justice programmes, including Criminal Justice (JPEN), Fundamental Rights and Citizenship (FRC), Drug Prevention and Information Programme (DPIP) and Civil Justice (JCIV);

European Social Programme (ESP);

Lifelong Learning Programme (LLP).

There are several possible ways of ensuring that Daphne complements and is consistent with other EU programmes.
[23](#footnote23)
 Firstly, information is shared with other DGs through inter-service consultations and inter-service groups. For example, it was agreed that DG Home Affairs would be responsible for funding projects on trafficking in human beings and unaccompanied minors. Secondly, staff from different DGs also hold ad-hoc meetings with DG Justice on topics that offer the potential for discussing any complementarity and overlap issues.

2.2.1Objectives and thematic areas

Daphne III's objectives, as defined by the legislator, are fairly broad. In principle, this means there may be some overlap between EU programmes. Daphne has much in common with ISEC as regards objectives and thematic focus, as both seek to prevent and combat violence and to protect victims. However, Daphne is more victim-centred, whereas ISEC focuses mainly on perpetrators.

[Table 2](#_Ref456352726)
[1](#_Ref456352726)
 below illustrates the potential complementarity and overlap of Daphne’s objectives and themes with selected EU funding programmes. The analysis above and the table below indicate that, while Daphne III provided ample opportunities for creating synergies, it was also open to the risk of overlap with various other EU programmes - especially JPEN and Safer Internet+ - as regards objectives and themes. The same applied to Daphne III and FRC. This problem has been resolved in the current programming period by combining the objectives of both programmes in the Rights, Equality and Citizenship Programme for 2014-2020.

Table 21 Potential complementarity and overlap of types of thematic areas of Daphne III with other related EU programmes

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Preventing violence & protecting victims of violence | Gender equality & women’s rights | Protecting children's rights | Human trafficking & sexual exploitation | Protecting physical & mental health |
| Daphne III | Daphne III | Daphne III | Daphne III | Daphne III |
|  | FRC | FRC |  |  |
|  |  |  |  | DPIP |
| JPEN |  | JPEN | JPEN | JPEN |
|  | PROGRESS |  |  |  |
|  | ESF | ESF |  | ESF |
|  |  |  |  | Community action for public health |
| ISEC |  | ISEC | ISEC |  |
| ERF |  | ERF | ERF |  |
| Safer Internet + | Safer Internet + | Safer Internet + | Safer Internet + | Safer Internet + |
|  | LLP | LLP |  |  |

This evaluation concludes that the programme's general objectives could remain broad and general, enabling the Commission to respond to changing needs on the ground, or in innovative research or practices. However, each programme's specific objectives could be formulated in such a way as to differentiate it more clearly from others (e.g. theme, focus, approach, type of organisation involved).
[24](#footnote24)
 The evaluation also found that it was vital to translate these objectives into priorities for calls for proposals and into projects to be selected for funding, so as to avoid overlap and create synergies.

2.2.2Complementarity at project level

At project level, there was little risk of overlap between Daphne-funded projects addressing the same priorities or involving the same kind of actors or the same kind of activities, as DG Justice tended to select projects covering quite a broad range of activities. Similar projects (e.g. anti-bullying education projects) tended to be implemented in different countries, so there was no overlap in beneficiaries.
[25](#footnote25)
 However, those implementing the projects could have done more to incorporate lessons learned from previous projects, to improve the potential for creating a ‘critical mass’ of impacts.

2.3EFFECTIVENESS

The effectiveness of a programme refers to the extent to which the programme has been successful in achieving its objectives, and the extent to which Daphne projects were successful in achieving their own project objectives.

2.3.1Programme achievements

Overall, the evaluation found that most measures implemented through Daphne III contributed to the programme’s general objectives, although the significance of individual contributions was difficult to measure, as the programme's objectives were very broad.
[26](#footnote26)
 Most measures helped improve protection for victims of violence or groups at risk, and a significant number contributed to policymaking and lawmaking at EU or national level. It was Daphne III’s support to EU networks, research and innovation and direct support to victims and at-risk groups that did most to improve protection against violence. Grant beneficiaries managed to influence policymakers through targeted dissemination activities.
[27](#footnote27)
 

2.3.2Projects' achievements

Research, studies and other analytical activities funded by Daphne have contributed to policymaking and improvements to practice. They have improved understanding of the phenomenon of violence. A total of 217 of the 302 projects mapped by the evaluators (72%) carried out analytical activities of various kinds (see 
[Figure 2](#_Ref454885167)
[1 Number of action and operating grants for different activities](#_Ref454885167)
). A further 203 out of 302 (67%) carried out mutual learning activities, including networks. Networks, which integrate the perspectives of relevant parties, naturally have a wider geographic impact, which can give them greater visibility and leverage with policymakers. Daphne-funded networks have served as a readily identifiable focal point for new audiences, and have aggregated the work of their members into one central location (i.e. a website), again widening the channel for dissemination.
[28](#footnote28)
 

Over a quarter of Daphne III-funded projects (81) provided support and advice services. Direct support services, i.e. helplines and counselling services, but also training and educating victims and groups at risk, to help them protect themselves better, have directly improved protection for these groups. By contrast, the development of educational material and the training of practitioners appear to have had a smaller, more localised impact.
[29](#footnote29)
 Forty-nine of the 302 grants awarded supported key players - mainly NGOs - working to protect the main target groups (children, young people and women).
[30](#footnote30)

Figure 21 Number of action and operating grants for different activities

![](./../../../resource.html?uri=comnat:COM_2017_0055_FIN.ENG.xhtml.COM_2017_0055_FIN_ENG_06002.jpg)

Source: data mapping of the documentation of the 302 action grant and operating grant-funded projects and work programmes

2.4SUSTAINABILITY AND TRANSFERABILITY

It was analysed whether the results, outcomes and impact of the projects were sustainable beyond the project funding period. Three levels of sustainability were identified:

1.short-term sustainability, achieved mainly by disseminating project results;

2.medium-term sustainability, implying continuation of project results and/ or partnerships;

3.longer-term sustainability, achieved mainly by transferring projects’ results to other contexts, organisations and EU countries without additional funding (or with limited funding only).
[31](#footnote31)

2.4.1Continuing project activities and outputs implemented and dissemination

Overall, the dissemination of the projects’ results by the Commission was limited, since it mostly relied on its beneficiaries to disseminate the outputs directly to their target groups, and its own human resources were reserved mostly to the financial management. Therefore, even though the Commission had its own dissemination tool (Daphne toolkit), it was found to have been generally less effective at disseminating results. By contrast, grant beneficiaries appear to have planned and effectively disseminated the results of their projects to policymakers, practitioners and other organisations in the field.

As regards pursuing project activities, most grant beneficiaries said that although there were arrangements in some cases for the continued use and/or availability of the outputs (e.g. a website), additional funding was needed. Evidence regarding the sustainability of partnerships set up with programme funding is rather contradictory; while project documents suggested that very few were going to continue, most survey respondents said their partnerships would be sustainable beyond the project.
[32](#footnote32)
 

2.4.2Continuing partnerships after the project’s completion

Of the 216 projects for which final reports were available, two thirds (154) reported that the projects would be sustainable to some extent at least, in that the project activities and/or partnership would continue, either in full or in part. In most of these cases (105 out of 154), project activities would continue at least to some extent, while partnerships set up for the project would continue in just 29 out of 154 cases.

At the time of the online survey, a higher percentage, i.e. 68% (94 of 139 respondents) stated that the partnership set up for the purposes of their project would outlive the project. This significantly different figure may be due to timing (e.g. opportunities to extend the partnership may have been identified after the submission of the final report) or sampling (i.e. the sample responding to the online survey could be skewed).

Examples in the final reports included descriptions of activities already planned with partners; others mentioned that the outputs of the measures implemented had been incorporated into training or educational curricula (14 measures). Others again stated that outputs (e.g. websites, reports, leaflets) produced using programme funding would continue to be disseminated and/or available after the project had been wound up.

Overall, though, there is no strong evidence that the results of the projects were not only continued, but actually proved sustainable once project funding was no longer available. A total of 79% of online survey respondents (113 out of 143) said further funding was needed to guarantee the sustainability of the results of the project or activities.
[33](#footnote33)

2.4.3Potential sustainability and transferability of outputs

Data from the online survey show that most outputs could be transferred to other EU countries. This was confirmed by all grant beneficiaries interviewed. Out of 139 respondents, 82% reported that all or some outputs could be used unaltered in more than one country. Of the 135 respondents, 67% said outputs could be transferred with some minor changes to more than one country, while 10% said that was not possible. A few beneficiaries noted that the transferability of outputs or approaches could be significantly affected by progress made by other EU countries in a given policy area. Advanced social policies could make it easier to transfer innovative methods, whereas countries lagging behind in a given policy area were unable to adopt a new approach.
[34](#footnote34)

On the basis of an analysis of final reports and interviews with grant beneficiaries, some projects were found to include a higher transferability potential at the project design phase. For example, where a needs assessment or comparative research was conducted, as part of the project, into how a given issue was addressed in a number of EU countries, or into differences in legislation or policy, a product such as a guide could immediately be developed and adapted to the various known contexts. This is a more effective and efficient approach to ensuring transferability than trying to adapt an existing product to different contexts. Moreover, membership of a network or having a number of partners abroad helps encourage transferability.

2.5EFFICIENCY AND SCOPE FOR SIMPLIFICATION

The assessment of efficiency found that the funding made available for the implementation of the programme was possibly not sufficient considering the high level of ambition of some of the objectives, the very high demand for funding and the overall high absorption rate of grants. Moreover, the issues addressed by Daphne III are very 'popular', especially among those stakeholders that are more prone to dependency on external funding. The grants produced outputs that were commensurate with the inputs, and represented good value for money, given the close links between activities.
[35](#footnote35)

2.5.1Planned budget

Daphne III's general objectives were helping prevent violence; protecting women from violence; protecting children from violence; protecting young people from violence; and influencing the development of community policy.

The first four objectives are very ambitious and cannot be tackled effectively with just EUR 124m over seven years. This is why the wording of the founding decision specifies that the aim is to make a contribution towards tackling these issues. Nevertheless, the scale of the problems of abuse and violence overall call for far more funding. The last objective, which focuses on developing EU policies in support of the first four objectives, is more realistic and commensurate with the funding available.

The fact that the programme has now reached its third round and has been growing steadily with each financial perspective may indicate that demand is higher and that the funding earmarked for initiatives of this kind is inadequate (i.e. mostly transnational and/or provided at EU level). On the other hand, the Daphne programmes addressed very ‘popular’ themes for which there may have been relatively little national funding but with many stakeholders (e.g. NGOs) being dependent on external financing.

Compared to the initial allocations, action grants received approximately EUR 7m more than initially envisaged, whereas operating grants received EUR 7m less. In spite of this apparent transfer, the grants were in very high demand overall, and more funding could have been absorbed too.

2.5.2Extent to which the resources spent were reasonable in view of the impact

The evidence collected in the course of the evaluation may be insufficient to conclude that the resources spent on the programme were reasonable in view of the outcomes and the impact achieved, especially as just under 30% of the measures funded were still incomplete, and given that it takes time for certain outcomes and impacts to manifest themselves. However, the outcomes and the impact identified suggest that spending was reasonable in the light of what the projects achieved.
[36](#footnote36)

Daphne III provided about EUR 109m in funding for over 300 mainly transnational projects, representing over 1,000 lead and partner organisations. Analysis of the projects completed so far shows there is evidence of outcomes and effects for about 81% of finalised action grants (142) and operating grants (40). As expected, given the nature of the funding tool, 83% of action grants showed evidence of outcomes and effects, more than the 76% of operating grants to do so. There may be some bias, as these outcomes and impacts are based on self-reporting by grant beneficiaries. However, it also needs to be borne in mind that overall outcomes and impacts take time to manifest themselves; for many projects, these would not yet have been observable at the time the final reports were written.
[37](#footnote37)

Only EUR 2m of the EUR 10m earmarked for procurement were committed. This suggests that needs were overestimated. However, funding earmarked for procurement but not spent in this way was reallocated to grants following the principle of sound financial management.
[38](#footnote38)
 

2.5.3Scope for simplification

An analysis was made of documentation required from grant applicants at the application stage in the Daphne 2007, 2009-2010 and 2013 calls for proposals. In 2007, the application form was split into two parts – (i) a part asking for information on the project’s objectives, relevance, concrete outputs, sustainability and EU added value and (ii) a part on the applicants and partners. In addition to the Application Form, applicants were required to complete a number of annexes, including partner declarations, budget forms, a staff-cost analysis, legal entity forms, etc. In the 2009-2010 period, the application form was modified to also include a detailed description of project work streams, setting out activities, deliverables and outputs. Although the requirement to provide a detailed description of work streams and outputs increased the complexity and amount of effort required from the applicants, arguably this also increased the quality of the project design and project planning.

In the 2013 call, a single Guide for Applicants was provided for a number of programmes (all DG Justice five programmes, ISEC and PROGRESS) which also included step-by-step guidance on using the PRIAMOS system. The guide contributed to simplification for organisations which benefited from multiple programmes and increased the efficiency of the application process for both applicants and programme officers.

With regard to submitting an application, 58 out of 143 (40%) respondents reported that they knew of organisations/projects/ practitioners that did not respond to the call for proposals because it was considered too complex/difficult.
[39](#footnote39)
 Moreover, a number of grant recipients considered the application procedures as complex and burdensome, in particular the past two calls for proposals were regarded as “too technical” by the respondents. This might have prevented organisations from applying for funding or limited the access to entities with high levels of expertise in project management/planning (but not necessarily with knowledge of the field/policy area).

The assistance provided by the Commission to applicants was overall assessed as positive. Out of 137 responses to the survey, more respondents strongly agreed (49) or partially agreed (37) with the statement “We have received good support from the Commission during the application procedure”. Nevertheless, 24% of respondents did not know or did not express their opinion, possibly because they had never contacted the Commission during the application phase, or because they were not aware of the possibility to receive support from the Commission during this phase.

Detailed guidelines for Daphne III grant applicants were available on the DG Justice website and the data gathered through this evaluation indicates that information provided to applicants was perceived as clear and easy to understand. Out of 144 respondents to the survey, most grant recipients either strongly agreed (50%, or 72 respondents) or partially agreed (36% or 52) with the statement “the information in the calls for proposals was clear and easy to understand”. However, responses to the online survey indicated that in order to respond to the call, just over half of the respondents (54 out of 104 respondents to this question) had to request help from persons with specific expertise and knowledge on the procedures.

The PRIAMOS IT system worked well according to the overall majority of grant recipients consulted as part of this study. However, some project beneficiaries reported to have had issues with regard to the attachments.

Projects were required to report on their finances in order to obtain a payment. For Daphne III, such reporting was requested at project completion, in order to obtain final payment
[40](#footnote40)
. It can be observed that the number of documents needed for contractual reporting has increased over the funding period.From the first call for AGs (2007) until the 2009-2010 call, only a final financial statement was required to accompany the final request for payment. From the 2011-2012 call onwards a number of documents detailing financial expenditure where requested. In support of these new requirements, the Commission issued additional guidance on financial management and financial reporting
[41](#footnote41)
.Some of the new requirements, such as the submission of timesheets
[42](#footnote42)
, appear to put an unnecessary burden on organisations, which normally would not have a time recording system in place, and on Commission officials, who would have to verify these.

The monitoring and evaluation requirements in the first call for proposals were limited to a final report, whereas the request for some form of progress reporting, thus allowing the Commission to monitor the project during implementation, was introduced from the second call onwards.

The narrative progress reports introduced in the second call were very short and mainly asked for: implementation of the project so far, timetable, changes to the scope of the project and overall assessment and difficulties encountered. Significantly more detailed information was required, from the last call onwards, for projects lasting 24 months or more, asking grant beneficiaries to report, per work stream, on outputs, deliverables, and activities delayed or not implemented.

Grant beneficiaries considered the Commission’s monitoring arrangements as partially good and helpful during the implementation of the project/activities by about 68% of respondents (89 out of 131 respondents). Only, 14% (19 out of 131) partially disagreed with this view. Three interviewees consulted noted that the Commission’s monitoring visits to projects were rare and that some projects were not visited at all. This was considered a missed opportunity on both sides, as visits were considered as useful by grant recipients, being an effective tool to provide the Commission with a good understanding of activities implemented and overall project’s results, while at the same time allowing the project to use the visit to further promote its activities and Daphne III in general. It could be argued that the Commission therefore puts a disproportionate focus on the expenditure of the projects rather than progress made.

Similarly to the progress reporting requirements, there has been a significant increase in the level of detail requested from the grant beneficiaries. Whereas the 2007 call requested in this regard a simple final narrative report, this request became slightly more detailed in the 2009-2010 call, to a request for final reporting according to the separate work streams from the 2011-2012 call. An important additional feature was the introduction of the Annex on quantitative reporting from this call onwards.

In order to evaluate efficiency or scope for simplification, it is important to look at the balance between the resources required for reporting, both by the grant beneficiaries as well as for the Commission in terms of reviewing this information, and the usefulness of reporting in terms of being able to assess project performance, outputs and wider effects. While no data is available on the resources spent by the Commission on the review of project reports, the majority of grant beneficiaries surveyed were satisfied with the reporting requirements and moreover, as expressed several times during follow-up interviews, they found the Commissions’ monitoring of the project very important. In this regard, it seems also commensurate with the detailed financial reporting requirements. Obviously, the quality of this final reporting provided by the grant beneficiaries determines its ultimate effectiveness and usefulness for the Commission.

2.6EUROPEAN ADDED VALUE

EU added value refers to the extent to which the EU nature of the programme brings value to its stakeholders and the extent to which the EU has a comparative advantage over national and international actors working in the area. First, the EU nature of the programme and its geographical coverage is discussed. The EU added value is then analysed in terms of value brought to the EU and to beneficiaries. However, it has not yet been possible to identify and measure EU added value in terms of impacts.

In general, funding through financing programmes managed by DG Justice and covered by this evaluation was only available to activities with a clear European dimension. This means that activities must transcend national or local interests to become truly ‘European’, with relevance, coverage and impact at EU level.

The three main features of Daphne III that give it an ‘EU dimension’ are:

Programme objectives: Art. 2 of the founding decision stipulates that one of the programme's general objectives is to help develop ‘Community [now EU] policies’. Compared to the previous Daphne programmes, Daphne III now focuses on all forms of violence against women, children and young people (while DG HOME focuses more on combating paedophilia and trafficking in human beings). Its legal basis is the promotion and protection of fundamental rights, as recognised by the Charter of Fundamental Rights of the European Union.

Theme of projects: The founding Decision stipulated in Art. 4(b) that the action grants will fund projects of ‘Community [EU] interest’. The annual work programmes and calls for proposals subsequently required projects to cover a theme of relevance to the EU. These work programmes set out the annual priorities - involving the EU's efforts to combat violence against children, young people and women - and required the projects to complement these. The call for proposals stipulated that proposals must demonstrate that they would provide ‘added value at EU level as opposed to national or regional level’.

Transnational nature: The annual work programmes and calls for proposals laid down the requirement for action grant beneficiaries to form transnational partnerships between at least two partner organisations from at least two EU countries. Operating grant recipients were obliged to cover at least 12 EU/EFTA/EEA countries. Art. 9(6) of the founding Decision also states that one of the evaluation criteria for selecting operating grant applications is the ‘geographic impact of the activities carried out’. The transnational nature of the Daphne III programme was one of its key features, distinguishing it from the other EU funding programmes in the field of justice implemented at the same time (see section 3). For the EU, the aim of such partnerships was to encourage the sharing of information at EU level, an EU-wide dissemination of good practices, a coordinated and multidisciplinary approach and a greater scale or impact of the programme. By requiring partnerships to be transnational, the programme also adheres to the principle of subsidiarity set out in Article 5 of the Treaty on European Union, requiring that the Union shall act only if and in so far the objectives of the proposed action cannot be sufficiently achieved by the Member States or can be better achieved at Union level.

2.6.1Geographical coverage of projects

The number of lead organisations and thus the number of projects implemented differs significantly across EU countries. Italy was home to the largest number of participating organisations, followed by the UK and Spain, with most of these organisations being partner organisations. Malta, Ireland and Estonia were the countries with the lowest participation rates. Malta did not lead any projects, though Maltese organisations participated as partners.

Lead organisations were clustered within three EU countries: Italy, Belgium and the UK. In total, 43% (131) of all projects were led by one of these three. However, projects registered in Belgium include EU networks and platforms, which, though not led by national bodies, inflate the share of lead organisations based in Belgium.

As regards partner organisations, participation among EU countries is more evenly spread; 17 EU countries supplied more than 25 partner organisations. Non-EU countries were also involved, including Norway (with both lead and partner organisations), Turkey, Ukraine, Iceland, Switzerland and F.Y.R.O.M. (as associated – not funded – partners only).
[43](#footnote43)
 

The analysis demonstrates that the Daphne III programme did not cover all Member States equally. Coverage largely reflects the number of applications received by different countries. For example, Italy, one of the countries receiving most grants, submitted 537 grant applications in the course of the programme (see 
[Figure 2](#_Ref411253979)
[2 Number of applications per EU country](#_Ref411253979)
). This represents 28% of all applications (1921 received).

Overall, lead partners based in Italy did not have a very high success rate. Italy's success rate was 9%, as compared to the average of 19%. The UK's success rate was slightly above average at 21% (44 applications were accepted). The proportion of universities making successful applications was quite high in Italy and the UK: UK universities accounted for 39% (21 out of 54) of all those that received funding under Daphne III, while their Italian counterparts accounted for 20% (11 out of 54). Universities may have been better placed to apply for grants than other bodies, as academics are used to making such applications.
[44](#footnote44)
 The countries with the highest success rates were Denmark (43), Belgium (34%), Norway (33%), and Hungary and Austria (31% in both cases). Germany's success rate was 24%.
[45](#footnote45)

Figure 22 Number of applications per EU country

![](./../../../resource.html?uri=comnat:COM_2017_0055_FIN.ENG.xhtml.COM_2017_0055_FIN_ENG_06003.jpg)

As regards the partnership structures of the three countries with most lead organisations (Italy, the UK and Belgium), the figures show that lead organisations are always much more likely to partner with organisations from their own country than with those from other EU countries. For instance, Italian lead organisations formed partnerships with 38 Italian partners, 24 Spanish partners and 15 Bulgarian partners. Belgian lead organisations partnered with 15 Belgian partners, 8 Greek partners and 6 French partners. UK lead organisations partnered with 27 UK partners, 11 Bulgarian partners, 11 French partners and 11 Italian partners.

Given the strong link between the country of the lead organisation and that of the partner organisation, the top three countries for lead organisations are also among the top countries for partner organisations. However, Portugal and Slovenia had the highest ratio of partner to lead organisations. In other words, they accounted for a large number of partner organisations (Portugal 35 and Slovenia 31) despite low levels of lead organisations (1). As expected, both countries participated in projects run by the organisations from the main lead countries: the UK, Italy, Belgium and Germany.

2.6.2Added value for the EU and for grant beneficiaries

Consultations with the programme’s grant beneficiaries suggest there were a number of features of the programme that brought added value. These include the themes covered and the programme's ‘conceptual framework’, the availability of funding (when no other funding was available), and the opportunity to partner with organisations in other countries. A number of partners also found that by receiving EU funding, the credibility of their organisation / project grew, helping them to garner more support for their aims. Some grant beneficiaries mentioned that the ‘EU brand’ can also boost an organisation’s reputation. For certain funded actions, the EU nature of the programme was crucial to their endeavour – this was particularly true of projects which sought to create and/or maintain EU networks (e.g. EuroNet-FGM, the 116 network of organisations, Verein Autonome Österreichische Frauenhäuser) and those seeking to have an impact on EU issues (e.g. the rights of victims, missing children).

The results of the online survey indicate that projects added value in that they contributed to achieving EU objectives. For example, most survey respondents reported that the project and or activities carried out made a significant or major contribution to formulating and disseminating of best practices (86% of 144 respondents); creating practical tools and solutions that address cross-border or EU-wide challenges (75% of 140 respondents); improving cross-border cooperation (75% of 143 respondents); and developing mutual trust among countries (67% of 141 respondents).
[46](#footnote46)

3CONCLUSIONS

Relevance of the programme
[47](#footnote47)

In general, the initiatives carried out under the Daphne III programme were relevant to the programme and its objectives and priorities. The extent to which the priority areas were aligned on the programme's objectives proved to be a poor indicator of ‘relevance’, as both objectives and priorities were broad in nature and not clearly linked to specific EU policy objectives. Priority-setting was not a standardised process. There was minimal investment in the first half time of the programme in setting priorities as a strategy for influencing programme outcomes; however, this changed somewhat in the programme's later stages.

Despite this, the programme funded many initiatives which informed and supported policy and legislative development. Overall, initiatives appear to have been designed to respond to beneficiaries' identified needs and developed on the basis of needs assessments.

Reporting by grant beneficiaries also suggests that end beneficiaries responded positively to the projects, indicating that they considered the actions relevant; however, this cannot be confirmed without gathering end beneficiaries' independent views.

Coherence and complementarity

There was substantial scope for complementarity and thus also the risk of overlap between Daphne III and the Criminal Justice (JPEN) and Fundamental Rights and Citizenship (FRC) DG Justice programmes, as well as - to a lesser extent - the Safer Internet Plus programme (DG DIGIT). There was some overlap between the programmes’ objectives, so it was decided to bring Daphne III and FRC together for the current programming period (2014-2020).

Even though there is some overlap between Daphne III, FRC and JPEN, the stage of the process involving calls for proposals helped differentiate them to some extent.

Several types of synergies were created between projects under Daphne III, and between Daphne III projects and other organisations in the same field which were perceived as reinforcing each other's strengths.

Effectiveness

Evidence to date suggests that overall Daphne III was effective in achieving the programme objectives. Most measures helped improve protection for victims of violence or groups at risk, either directly or indirectly. A significant number also appear to have contributed to policymaking and lawmaking at national level – and to some extent at EU level.

The greatest contributions to protection from violence came from Daphne III’s support to EU networks, research and innovation and direct support to victims or at-risk groups; and grant beneficiaries managed to influence policymakers through targeted dissemination activities.

Most projects achieved their own objectives and there is already good evidence of positive results, as well as evidence of unexpected positive results.

Sustainability

It was found that the Commission, despite having its own dissemination tool, had been less successful in projects' outputs dissemination. This was mainly due to lack of human resources and emphasis on financial reporting and production of project outputs. By contrast, grant beneficiaries appear to have planned and effectively disseminated the results of their projects to policymakers, practitioners and other organisations in the field.

The fact that many grant beneficiaries have been successful in reaching policymakers, practitioners and/or in transferring their outputs and methods to other EU countries suggests that grant beneficiaries were reasonably effective at disseminating the results of their initiatives.

Although arrangements have been made in some cases to continue using the outputs and making them available (e.g. a website), grant beneficiaries say additional funding is needed to be able to continue project activities. On the other hand, a significant part of activities developed under the programme would have not been developed had the programme not existed, since the programme itself had created a demand for new activities.

Efficiency

Demand for Daphne III funding was high, mainly because of the nature of the programme and the type of eligible grant beneficiaries.

The funding made available was sufficient for grants to achieve their objectives. However, the needs of procurement as a funding tool were overestimated.

As regards scope of simplification, the level of detail required in the application form has increased from the 2010 call onwards and included the introduction of work streams. This has benefited both the Commission and the applicants. Reporting requirements were considered appropriate by the vast majority of the respondents. The Commission’s monitoring arrangements were at least partially considered as good and helpful during the implementation of the project/activities. The reporting requirements reflect a more balanced approach between financial justification on the one hand and evaluation of outputs on the other. Evaluation of the (potential) impacts of the projects is limited.

EU added value

The fact that the programme was carried out under the EU's auspices brought added value to most grant beneficiaries. Most found that the transnational partnerships required under the programme enabled them to learn from other countries. For many others, the chance to disseminate the outputs and results of their project at EU level was also a real advantage.

EU ‘branding’ also gave added momentum to some projects and greater leverage with policymakers and other key stakeholders.

For networks, such as EuroNet-FGM and Missing Children Europe, it is likely that only an EU programme would have enabled them to achieve their goals. For grant beneficiaries, the fact that the programme offered funding for projects focusing on human rights or social science at a time when little funding was available, particularly at EU level, was also very important.

However, the geographic coverage of the project was rather limited, with the main lead organisations being based in the UK, Italy, Germany and Belgium. Furthermore, it has not yet been possible to identify and measure EU added value in terms of impacts.

Key recommendations

Better define the priorities; the Commission should invest more time and human resources in setting priorities, to ensure that these help the programme to achieve specific objectives relevant to the programmes’ general objectives, and to DG Justice’s wider policy objectives.

Support the achievement of longer-term objectives, and to influence policymakers and target audiences; the Commission should utilise the budget available for procurement activities to collate the results and outputs of the Daphne III programme on its website and/or consider publicising the existing databases of results more effectively.

Realistic assessments of project risks and better risk mitigation strategies: the Commission should better monitor risks throughout the project duration, for example by asking for brief progress reports that identify any potential risks as they arise during the implementation of the project.

Increase focus on assessment of impacts at all levels and not merely on outputs, as regards monitoring and evaluation. This goes hand in hand with the need to collect, analyse and use objective and independent evidence in order to perform project and programme evaluations.

Explore ways of enhancing the uptake of project outputs, results and best practices by other organisations, including in other Member States, including more resources for translations, communication and dissemination. 

Sharpen the programme's intervention logic; further to the scope of the programme and its general and specific objectives and priorities, types of action and types of intervention and implementing measures, the Commission shall seek to sharpen the intervention logic
[48](#footnote48)
, and make the relations between the rationale, objectives, inputs, outputs, beneficiaries, expected outcomes and impacts articulate, precise and concrete in any future continuation of the programme.

:   [(1)](#footnoteref1)

    Article 15(3)d, Decision No 779/2007/EC of  20 June 2007 establishing for the period 2007-2013 a specific programme to prevent and combat violence against children, young people and women and to protect victims and groups at risk (Daphne III programme) as part of the General Programme on ‘Fundamental Rights and Justice’
:   [(2)](#footnoteref2)

    The ex post evaluation report of the external evaluator is published here: Main report: 
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
    , Annexes: 
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_annexes_1_2_4.pdf>
    , and 
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/dap_annex_3_quantitative_analysis.pdf>
    .

    The mid-term evaluation report of the Commission is published here: 
    <http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0254&from=EN>
:   [(3)](#footnoteref3)

    Evaluation report: 
    <http://ec.europa.eu/smart-regulation/evaluation/search/download.do;jsessionid=h594TThJ1lLxvM8Y501gLP7m8nMNv7c1kmY6vX59JJjGDJspS92q!1601440011?documentId=2882>
:   [(4)](#footnoteref4)

    Evaluation report: 
    <http://ec.europa.eu/smart-regulation/evaluation/search/download.do?documentId=1946>
:   [(5)](#footnoteref5)

     The evaluation report was not published.
:   [(6)](#footnoteref6)

    Calls for proposals for action grants were split across years from 2009 to 2010 and 2011 to 2012.
:   [(7)](#footnoteref7)

    Not considered within the scope of this evaluation, because the final reports were not submitted during this evaluation process.
:   [(8)](#footnoteref8)

    Decision No 779/2007/EC of 20 June 2007 establishing for the period 2007-2013 a specific programme to prevent and combat violence against children, young people and women and to protect victims and groups at risk (Daphne III programme) as part of the General Programme on ‘Fundamental Rights and Justice’
:   [(9)](#footnoteref9)

    This type of action includes action grants to specific transnational projects of EU interest (call for proposals) and action grants under Article 168 of the Implementing Rules.
:   [(10)](#footnoteref10)

    This type of action includes operating grants to support annual activity programme of non-governmental organisations or other entities (calls for proposals) and operating grants to support NGOs mandated to run the 116 000 hotline for missing children.
:   [(11)](#footnoteref11)

    This type of action includes action grants to specific transnational projects of Union interest (call for proposals), 116 000 Hotline (specific action grants) and Child Abduction Alert Mechanism – specific action grants.
:   [(12)](#footnoteref12)

    This type of action includes operating grants to support annual activity programmes of non-governmental organisations or other entities (calls for proposals).
:   [(13)](#footnoteref13)

    In 2013, this type of action consisted of public procurement only.
:   [(14)](#footnoteref14)

     Based on an extensive review of documentation on all 302 action and operating grants funded under the 2007-2013 programme. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, p. ii

    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
:   [(15)](#footnoteref15)

     Based on an extensive review of documentation on all 302 action or operating grants funded under the 2007-2013 programme. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Daphne quantitative analysis, ICF, 28 July 2015, pp. 24-27  
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/dap_annex_3_quantitative_analysis.pdf>
:   [(16)](#footnoteref16)

    Based on a review public procurement contracts. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, p. 3

    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
:   [(17)](#footnoteref17)

    Ibid., pp. 3-4
:   [(18)](#footnoteref18)

    Ibid., p. 4
:   [(19)](#footnoteref19)

    Needs assessment should include relevant and reliable data and should contain a robust analysis clearly demonstrating the need for the action. The applicant can refer to existing research, studies, previous projects which had already identified the need. The needs assessment must make it clear to what extent the action will meet the need and this shall be quantified. The applicant should be specific and focus on the actual needs that the project will aim to address and not limit the analysis to general statements and information about the problems and needs of the target group in general.

    Evidence collected during an extensive review of documentation on all 302 action or operating grants funded under the 2007-2013 programme. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, p. 4

    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
:   [(20)](#footnoteref20)

    Ibid., p. 6
:   [(21)](#footnoteref21)

    Ibid., pp. 8-10
:   [(22)](#footnoteref22)

    Ibid.
:   [(23)](#footnoteref23)

    Ibid., p. 11
:   [(24)](#footnoteref24)

    Ibid., pp. 14-15
:   [(25)](#footnoteref25)

    Ibid., pp. 15-16
:   [(26)](#footnoteref26)

    Ibid., p. 17
:   [(27)](#footnoteref27)

    Ibid.
:   [(28)](#footnoteref28)

    Ibid., pp. 17-18
:   [(29)](#footnoteref29)

    Ibid.
:   [(30)](#footnoteref30)

    Ibid., pp. 21-22
:   [(31)](#footnoteref31)

    Ibid., p. 27
:   [(32)](#footnoteref32)

    Ibid.
:   [(33)](#footnoteref33)

    Ibid.
:   [(34)](#footnoteref34)

    Ibid.
:   [(35)](#footnoteref35)

    Ibid., p. 32
:   [(36)](#footnoteref36)

    Based on an extensive review of documentation on all 302 action or operating grants funded under the 2007-2013 programme. Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, p. 40

    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
:   [(37)](#footnoteref37)

    Ibid.
:   [(38)](#footnoteref38)

    Ibid., p. 41
:   [(39)](#footnoteref39)

    Based on the fact that 38 respondents “strongly agreed” and 28 “partially agreed” with this statement in the online survey.
:   [(40)](#footnoteref40)

    The Commission can introduce an interim payment where necessary as specified in the guide for applicants.
:   [(41)](#footnoteref41)

    Management Guide for projects co-financed by EU action grants awarded in 2012 under the financial programmes managed by DG Justice.
:   [(42)](#footnoteref42)

    The use of these is extensively explained in the Management Guide for projects co-financed by EU action grants awarded in 2012 under the financial programmes managed by DG Justice.
:   [(43)](#footnoteref43)

    Ibid., p. 48
:   [(44)](#footnoteref44)

    However, NGOs, which were the main grant applicants in most Member States, should also be accustomed to applying for funding.
:   [(45)](#footnoteref45)

    Ibid., p. 50
:   [(46)](#footnoteref46)

     Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, p. 50 
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
    ,
:   [(47)](#footnoteref47)

    Ibid., pp. 52-54
:   [(48)](#footnoteref48)

    See for instance Ex post evaluation of five programmes implemented under the 2007-2013 financial perspective. Final Report to DG Justice – Specific programme evaluation: Daphne Programme, ICF, 28 July 2015, pp. 1-2 
    <http://ec.europa.eu/justice/grants1/files/expost_evaluations_2007_2013/daphne_programme_evaluation__final_report.pdf>
    .

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