Report of the Working Group on Public Audit Deficits

Access of Supreme Audit
Institutions to the main
financial supervisors in EU
Member States

Audit Department II
European Affairs & Government-wide Performance Audit Division
Netherlands Court of Audit, Lange Voorhout 8, P.O. Box 20015, 2500 EA The Hague, The Netherlands

Access of Supreme Audit Institutions to financial
supervisors

Contents

Executive summary

1

1

Introduction

2

1.1

Mandate

2

1.2

Goals

2

1.3

Participating SAIs

3

1.4

Activities of the Working Group and this report

3

2

Overview pilot project

4

3

Main results of the pilot study

6

3.1

Country comparative overview

6

3.2

Main result by country

7

4

Discussion

13

5

Proposals to the Contact Committee

15

Appendix 1 Contact Committee Resolution 2011

17

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Access of Supreme Audit Institutions to financial
supervisors

Executive summary

The Working Group on Public Audit Deficits was established by Contact
Committee resolution CC-R-2011-05. The Working Group carried out in a
pilot project a parallel assessment of prudential supervision on banks in
the EU Member States. The assessment mainly concerned the scope of
the mandate of Supreme Audit Institutions

(SAIs) and its proper

functioning with respect to the main financial supervisor (FSA) for
prudential oversight on banks. This report provides results from thirteen
SAIs from EU Member States and the European Court of Auditors.

The results show that of these fourteen SAIs, seven lack the mandate to
conduct an audit on the performance of the FSA in their country. Of the
other seven SAIs that do have the mandate to audit the FSA in their
country, five have full access to the requested documents. In their
reporting confidential information such as trade secrets and names of
financial institutions have to be excluded. The remaining two SAIs that do
have the mandate in practice only either get partial access or no access
to the requested documents.

The Working Group proposes to the EU Contact Committee to publish the
results of this pilot project on its website, on the websites of national
SAIs, and to bring the results to the attention of national stakeholders
with regard to financial supervision, i.e. the national parliament, the
ministry of Finance and the main financial supervisor for prudential
oversight. Furthermore it is proposed to bring the results to the attention
of European stakeholders, i.e. the European Parliament, the Council and
the European Commission.
Finally, it is proposed that SAIs closely monitor the developments
regarding the new Capital Requirements Directive IV and the possible
establishment of a Banking Union, and examine the implications –
including new opportunities – for SAIs regarding their mandate to audit
the functioning of the supervisory activities of the FSA, the access to all
information of FSAs and for reporting possibilities of SAIs.

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Access of Supreme Audit Institutions to financial
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1

Introduction

1.1

Mandate
The Supreme Audit Institutions (SAIs) of the EU decided in their annual
meeting on 14 October 2011 (Resolution CC-R-2011-05) to undertake a
limited parallel assessment of prudential supervision on banks in the EU
Member States.1 To this end, the working group on public audit deficits
was founded.

1.2

Goals
The working group met in The Hague on 18 January 2012. The
participants in the working group agreed to perform a pilot study, for
which the Contact Committee gave the mandate. The Working Group also
agreed on the goals of the project.

The internal goal for the participating SAIs of the pilot study was
threefold:
-

Testing scope of mandate of SAIs and its proper functioning with
respect to the main financial supervisor for prudential oversight on
banks

-

Identifying possible complications regarding access rights of SAIs that
are the result of national regulations or interpretations of EU- or Eurospecific legislation.

-

Drafting a country comparative report to the Contact Committee in
2012 in which the results of the pilot study are presented.

The external goal of the pilot study was twofold:
-

Assessing completeness of files kept by supervisor for purpose of
prudential oversight by means of a sample check on the index of the
files.

-

Using results to increase potential for parliamentary scrutiny of
financial supervisors for prudential oversight on banks.

1

The Contact Committee resolution is included in this report in Appendix 1.

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Access of Supreme Audit Institutions to financial
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1.3

Participating SAIs
Twelve SAIs participated actively in the Working Group. These are the
SAIs of Denmark, Estonia, Finland, France, Germany, Italy, Latvia,
Lithuania, Netherlands (Chair), Poland, Portugal and the European Court
of Auditors.
The Swedish SAI did not participate in the pilot study. However, based on
a presentation about the Swedish experiences with auditing their financial
supervisor during the first meeting of the Working Group, and after
approval of the Swedish SAI, the results for Sweden have been retrieved
from their presentation. The SAI of Slovakia sent the results for Slovakia
in reaction to our draft report. These results have also been included in
the final report. Hence, this report contains the results from thirteen EU
Members States as reported by their national SAIs and of the European
Court of Auditors.

1.4

Activities of the Working Group and this report
The Working Group on Public Audit Deficits met on 18 January 2012 in
The Hague. On proposal of the Chair, a simple and efficient approach to
carry out the pilot study was agreed upon by the members of the Working
Group.
Between March and June 2012 each member of the Working Group
carried out the pilot study in its own country. In June and July 2012 each
participating SAI sent a country report to the Chair, based on a reporting
format developed by the Chair. The Chair compiled a draft report for the
Working Group as a whole. The draft report was sent to all participating
SAIs, whose comments and remarks are incorporated in the final report.

Paragraph 2 of this report gives an overview of the pilot project as carried
out by the members of the Working Group on Public Audit Deficits.
Paragraph 3 describes the main results: first for all countries combined,
and secondly – briefly – for each country separately. Paragraph 4
discusses the results in a broader context, and Paragraph 5 concludes this
report with a proposal to the Contact Committee.

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Access of Supreme Audit Institutions to financial
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2

Overview pilot project

The pilot study was conducted in four steps. Each participating SAI
started with the selection of the main financial supervisor for prudential
oversight in their own country. ECA selected the European Banking
Authority (EBA).2 After the selection, each SAI checked whether they
have a mandate to audit the main financial supervisor in their country,
including the bank files they keep. In case the SAI has a (partial)
mandate, a limited number of banks was selected to test the mandate by
auditing the completeness of the supervisory files on these banks. The
graph below gives a global outline of the four steps of the pilot study.

2

EBA does not conduct direct supervision of banks but participates in supervisory colleges of the

largest cross border banks in the EU.

4

Access of Supreme Audit Institutions to financial
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5

Access of Supreme Audit Institutions to financial
supervisors

3

Main results of the pilot study

3.1

Country comparative overview
The diversity of mandates within the Supreme Audit Institutions of the
working group is large. Table 1 below illustrates this and what this means
for the possibility of SAIs to audit the main financial supervisor of their
country.

Table 1 – Main results pilot study
SAI

Main financial supervisor

Mandate SAI to audit

Actual access SAI to

Test SAI on

(Step 1)

supervisory role of

audit bank files of

completeness of

main financial

supervisor (Step 3)

files (Step 4)

Yes, with condition of

Full access based on

confidentiality.

previous audits.

supervisor (Step 2)
Denmark

Danish Financial Supervisory

Yes.

Authority
Estonia

Financial Supervision Authority

No.

No.

-

Finland

Financial Supervisory Authority

No.

No.

-

Financial Markets Authority &

Yes.

France

Prudential control Authority
Germany

Federal Financial Supervisory

Yes.

Authority

Yes, with condition of

All files had an index

confidentiality.

and were complete.

Yes, with condition of

Index equals actual

confidentiality.

number of
documents in files.

Italy
Latvia

Bank of Italy

No.

Financial and Capital Market

No.

Commission

No.

-

No answer, so no

-

request at banks.

Lithuania

Bank of Lithuania

No.

No.

-

Netherlands

Bank of the Netherlands

Yes.

No.

-

Poland

Polish Financial Supervision

Yes.

Partially. No data

Question not

concerning bank

applicable according

secrecy.

to Polish SAI.

Authority

Portugal

Bank of Portugal

No.

No.

-

Slovakia

National Bank of Slovakia

No

No

-

Sweden

Financial Supervisory Authority

Yes

Yes, with condition of

Full access based on

confidentiality

previous audits

Yes, agreed to

No index. Only

confidentiality

digital files.

ECA

European Banking Authority

Yes

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Access of Supreme Audit Institutions to financial
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The results show that seven SAIs have the mandate to audit the main
financial supervisor in their country. Of the 14 SAIs, seven do not have
the mandate to conduct audits at the main financial supervisor.

Of the seven SAIs that have a mandate, the Polish SAI has only partial
access to documents because it does not get access to data concerning
the bank secrecy. The Netherlands SAI does not get actual access to audit
bank files, despite of its mandate. The other five SAIs do get actual
access to the requested documents. However, all of these five SAIs are
bound by some level of confidentiality. The Danish, French and Swedish
SAI can publish their results without confidential information such as
trade secrets and names of financial institutions. The European Court of
Auditors can publish all results under certain conditions. The German SAI
does not publish, but reports to the auditee, the Ministry of Finance and
in some cases to the Budget Committee of their parliament.
Two of the SAIs with the mandate to audit the main financial supervisor
were able to successfully test the completeness of the bank files that are
kept by the supervisor.

In four countries where the SAI has no mandate to audit the main
financial supervisor, the national central bank is this supervisor. In two
other

countries

(Estonia

and

Finland),

the

financial

supervisor

is

operationally or administratively connected to the central bank. Only in
Latvia, the seventh country where the SAI has no mandate, the main
financial supervisor is a separate institution. Also in The Netherlands,
where the SAI has the mandate but no actual access, the central bank
operates as the main financial supervisor.
In comparison, of the countries where the SAI gets access to audit the
main financial supervisor, the financial supervisor is always a separate
institution unrelated to the national central bank.

3.2

Main result by country
The results

of

the pilot

study

differ per country

and are briefly

summarized below.

Denmark (Rigsrevisionen)
The Danish Financial Supervisory Authority (FSA) performs supervision of
financial

institutions

and

the

securities

market.

In

addition,

they

contribute to the preparation of financial legislation and the collection and
dissemination of statistics about the financial market. The Danish SAI has
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Access of Supreme Audit Institutions to financial
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the mandate to audit the FSA, including the bank files kept by the FSA. In
previous audits on specific banks, the Danish SAI had full access to the
files containing information about the supervision of the FSA before the
bankruptcy of both banks. However, confidential files must remain
confidential.

Estonia (Riigikontroll)
The Estonian Financial Supervisory Authority (FSA) is independent in its
supervision

activities,

which

includes

banks,

insurance

companies,

pension funds as well as other financial institutions. It operates at the
Bank of Estonia. The Estonian National Audit Office analysed the National
Audit Office Act and discussed this with the FSA. The FSA is not in the list
of entities the National Audit Office can audit. However, the Bank of
Estonia is in the list. In the Financial Supervision Authority Act, the
National Audit Office is not in the list of entities to whom the FSA has to
disclose information. Based on this, the National Audit Office concluded
they have an insufficient mandate and hence, they have no access to the
information required.

Finland (Valtiontalouden tarkastusvirasto)
In

Finland

the

Financial

Supervisory

Authority

is

administratively

connected to the Bank of Finland. The Finnish National Audit Office has no
mandate to audit the Bank of Finland. Hence, the Audit Office also lacks
the mandate to audit the Financial Supervisory Authority.

France (Cour des Comptes)
The Financial Markets Authority (FMA) controls information given on
securities,

regulates

market

infrastructures

and

ensures

that

no

undisclosed information is used on the market. In addition, the Prudential
Control Authority (PCA) controls the capital requirements of French banks
and insurance companies and determines the solvency and liquidity ratios
for the financial institutions. The Cour des Comptes indicates that they
have the mandate to audit the main financial supervisor. In a previous
audit, they got access to every required document, including minutes
from meetings of the Board of Directors in the period 2009-2010. The
Cour des Comptes has to comply with terms of confidentiality, which
means that they do not report confidential data in their report. These
subjects were reported to the auditee and the Ministry of Finance. There
was also a hearing by the French parliament, so parliamentarians could
ask complementary questions. All audited banks received public money
and the audited files had an index and were complete.

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Access of Supreme Audit Institutions to financial
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Germany (Bundesrechnungshof)
The Federal Financial Supervisory Authority (FSA) is the main financial
supervisor in Germany. Its primary objective is to ensure the proper
functioning, stability and integrity of the German financial system
including banking, insurance and securities supervision. The German
National Audit Office has the mandate to audit the Federal FSA. This
includes the mandate to audit bank files kept by the Federal FSA. The
German Audit Office has actual access to the files requested, but they
have to be kept confidential in accordance with German law. Therefore,
the German National Audit Office reports only to the auditee and in some
cases the Budget Committee of the German Parliament. The result of the
test on the completeness of files showed a clear index with complete files.

Italy (Corte dei Conti)
In Italy the Financial Supervisory Authority is the Bank of Italy, the
Italian Central Bank. The Corte dei Conti has no mandate to audit the
Bank of Italy. Hence, the Corte also lacks the mandate to audit the
Financial Supervisory Authority.

Latvia (Valsts kontrole)
The main financial supervisor in Latvia, the Financial and Capital Market
Commission (FCMC), is responsible for the supervision of Latvian banks,
insurance companies, private pension funds, etc. The FCMC ensures
stability, competitiveness and the development of the financial and capital
market, including the protection of interests of investors, depositors and
insured persons. According to the Latvian National Audit Office, they
cannot audit the FCMC, because the FCMC is not financed by the state
budget or local government budget resources. The FCMC is financed by
payments from participants of the financial and capital market. However,
the Audit Office has the mandate to directly request bank files at banks.

Lithuania (Valstybès kontrole)
The main financial supervisor in Lithuania is the Bank of Lithuania. Price
stability is its main objective. According to the law on the Bank of
Lithuania, the National Audit Office of Lithuania may perform an audit of
the activities carried out by the Bank of Lithuania including activities
related to financial market supervision, as long as this is not in
contradiction with European law and the objectives and tasks of the
European System of Central Banks. In 2009 the European Central Bank
gave the opinion that “the audit of the National Audit Office of Lithuania
shall be limited to the management, usage and disposal of real estate,
equipment and capital of the Bank of Lithuania”. As such, the Law on the
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Access of Supreme Audit Institutions to financial
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Bank of Lithuania, the National Audit Office indicates that they have no
mandate to audit the Bank of Lithuania.

Netherlands (Algemene Rekenkamer)
A primary task of The Bank of the Netherlands (DNB), is the supervision of
financial institutions (e.g. banks) in order to maintain financial stability. The
Netherlands Court of Audit (NCA) has a mandate to audit this supervisory task
of DNB according to the Dutch Audit Bill. The Dutch Minister of Finance and
DNB have the opinion that this mandate is limited by European legislation. In
their interpretation NCA has no access to information about individual
financial institutions in files (or otherwise) of DNB. Therefore, the NCA does
not get access to the documents required. Subsequently, it was not able to
test the completeness of the files.

Poland (Najwyzsza Izba Kontroli)
The Polish Financial Supervision Authority (FSA) is the main financial
supervisor, aiming for the proper functioning of the financial market,
including its stability, safety and transparency. The Supreme Audit Office of
Poland indicates that they have the mandate to audit the Polish FSA, including
files on bank sector entities.3 However, data concerning the bank secrecy and
professional secrecy of the staff of the Polish FSA is not made available,
unless the data is made available with the banks consent or data is made
anonymous. On the contrary, the Supreme Audit Office of Poland has access
to the bank secrecy during the course of performing its audits at the bank as
far as this is necessary to conduct the audit. The Supreme Audit Office of
Poland is of the opinion that the test on the completeness of files is not
pertinent, because it is their experience that files received during the
inspection of the FSA are largely returned to the bank after using them in the
examination.

Portugal (Tribunal de Contas)
One of the main tasks of the Bank of Portugal is prudential and market
conduct supervision. It carries out the prudential supervision of credit
institutions and financial companies. According to Portuguese law, the
Bank of Portugal is not subject to control by the Portuguese Court of
Audit. Hence, the Court of Audit has no mandate and was not able to
conduct the pilot study.

3

Article 29 (2) of the Act on the NIK, that entered into force in June 2012, stipulates that the NIK’s

access to the files and materials needed to establish the factual state of audited activity, containing
information being statutory protected secrecy, can be excluded or limited only on basis of other
laws. It means that the exclusion of the NIK’s access to the statutory secrecy must explicitly result
from the laws.

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Access of Supreme Audit Institutions to financial
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Slovakia (Najvyšší kontrolný úrad Slovenskej republiky)
The National Bank of Slovakia (NBS) acts as the Financial Supervision
Authority (FSA). In cooperation with the European Central Bank and
central banks of the euro area countries, it maintains price stability. It
carries out a whole range of various tasks like monetary policy, foreign
exchange operations and reserves and the collection and dissemination of
statistics about the financial market. Every six months, it prepares a
prognosis related to the economic development in the country. In
addition, it contributes to the preparation of legislation related to the
financial framework and gives an opinion to that. Next to that, it issues a
range of regulations, permits, licenses, guidelines and directives and
supervises

the financial

institutions

and financial market

to attain

financial stability of the Slovak banking system and activities contributing
to sustain price stability. The Supreme Audit Office of the Slovak Republic
(SAO SR) has no access to information on financial institutions on NBS
files and according to relevant laws governing the NBS and SAO SR, the
SAO SR is not an entity to which NBS is obliged to reveal any information
related to the pilot study topic.

Sweden (Riksrevisionsverket)
The Financial Supervisory Authority (FSA) is the main financial supervisor
in Sweden. They are concerned with supervision and analyses, regulations
and guidelines, permits, licenses and notifications and sanctions. The
Swedish National Audit Office has the mandate to audit the FSA and
performed several recent audits. In these audits they had actual access to
all relevant data necessary to perform the audit. The Swedish SAI can
publish its findings, but is bound by the same level of confidentiality that
applies to the auditees.
European Court of Auditors
The European Banking Authority (EBA) has the task to safeguard the
stability of the financial system, the transparency of markets and financial
products and to protect depositors and investors. In particular the EBA
participates in the supervisory colleges of the largest cross-border banks
in the EU as well as coordinates the EU-wide stress tests. As the EBA is
financed in part from the EU Commission’s budget, the ECA has the right
to audit the efficiency and effectiveness of the activities of the EBA based
on its general competence to audit the value-for-money of activities
financed by the EU budget (so-called performance audit). In addition, the
ECA carries out an annual financial audit of the EBA’s accounts. The ECA

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Access of Supreme Audit Institutions to financial
supervisors

can publish all the results under certain conditions4, but the auditors
agreed to treat all information received confidentially for a recently
conducted audit visit related to an on-going performance audit. ECA does
not intend to publish names of any individual financial institutions for this
audit. Paper files were not available and there was no index in the digital
files. The ECA counted the number of documents in the files for ten
selected banks and considered the files to be complete.

4

The conditions are specified in the so called “Ismeri Case” (Case C-315S/99 P. Judgement of 10

July 2001). ECA is allowed to mention by name in its reports 3rd persons if it is necessary and
proportionate to the objective pursued. Persons concerned must be enabled to make observations
before the report is definitively drawn up.

12

Access of Supreme Audit Institutions to financial
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4

Discussion

The Financial Supervision Authorities (FSAs) are the central institutions to
control and supervise banks and other financial institutions in the EU
Member States. The FSAs are crucial for prudential oversight and to
maintain macroeconomic stability. The financial crisis showed that not all
FSAs have been able to successfully conduct their tasks. With this in
mind, it is remarkable that out of fourteen SAIs that participated in this
pilot project, only six have actual access to FSA documents (including
bank files). More than 50% of the SAIs that participated in this pilot
project are not able to determine how the FSA in their country functions
in practice when fulfilling its supervisory tasks.

Of the SAIs that do have access to the FSA, in all cases this is only
possible under certain confidentiality clauses. Most of these SAIs are able
to publish results, but without confidential information such as names of
financial institutions and bank secrecies. The results that cannot be
published are usually reported to the auditee, the Ministry of Finance and
in some cases to parliament.

Because of the important position of banks in the financial crisis, the
European Commission recently proposed a new Capital Requirements
Directive (CRD IV) on the access to the activity of credit institutions and
the prudential supervision of credit institutions and investment firms.5 It
requires banks, among other things, to hold more and better capital and
includes a new governance framework giving supervisors new powers to
monitor banks more closely and take action through possible sanctions
when they spot risks. 6

The CRD IV also proposes that Member States may authorise the
disclosure of certain information related to the prudential supervision of
institutions to the SAI in their country. However this can only be done
under the condition that these SAIs have a specific mandate defined by
5

Proposal of the European Commission on a directive on the access to the activity of credit

institutions and the prudential supervision of credit institutions and investment firms (COM(2011)
453 final).
6

The negotiations on CRD IV between the Council and the European Parliament are currently still

on-going.

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Access of Supreme Audit Institutions to financial
supervisors

national law to investigate or scrutinize the actions of authorities
responsible for the supervision of banks and other financial institutions
(COM(2011) 453 final, article 60 2(a)).
In most cases where SAIs have no mandate to audit the FSA at this
moment, the specific mandate in national law is lacking. Hence, the CRD
IV will most likely provide no solution for these SAIs. In the cases where
SAIs are able to audit the FSAs but cannot publish confidential results, it
is the question whether CRD IV will lead to a change. Hence, most likely
CRD IV wilt not affect access of SAIs nor enhance transparency.

Another development that might play a role in the near future are the
proposals by the European Commission to establish a Banking Union.7 It
is proposed that the European Central Bank should be the institution in
charge of supervising the euro area banking system. If that becomes the
case, then this could create new complications for the possibility of SAIs
to audit and report about financial supervisors. The impact on the
European Court of Auditors’ audit rights is also unclear. Currently the
European Court of Auditors has the mandate to audit the operational
efficiency of the management of the ECB.

7

On 12 September 2012 the European Commission published its proposals for a single supervisory

mechanism. The proposal can be viewed at
http://ec.europa.eu/internal_market/finances/committees/index_en.htm

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Access of Supreme Audit Institutions to financial
supervisors

5

Proposals to the Contact
Committee

This pilot project shows that there are differences in mandate and access
of SAIs with regard to the possibility to audit the performance of financial
supervisors in the EU Member States. The importance of being able to
carry out such audits is evident, especially in times of financial crisis in
which not all FSAs have successfully conducted their supervisory activities
on banks.

The Working Group

proposes to the Contact Committee to accept the

following recommendations:
-

To publish the results of this pilot project on the Contact Committee
website and on the websites of SAIs of EU member States;

-

To invite SAIs to bring the results of this pilot project to the attention
of the national stakeholders with regard to financial supervision in
each of the EU member States, i.e. national parliament, ministry of
Finance and the main financial supervisor for prudential oversight;

-

To mandate the chair of the Working Group to bring the results of the
pilot project to the attention of European stakeholders, i.e. the
European Parliament, the Council and the European Commission;

-

To call upon SAIs to closely monitor – in accordance with their national
audit remit – the developments regarding the Capital Requirements
Directive IV and a possible Banking Union, and to examine the
implications, including new opportunities, for SAIs regarding their
mandate to audit the functioning of the supervisory activities of FSAs,
the access

of SAIs to all information of FSAs, and for reporting

possibilities of SAIs.

The Working Group on Public Audit Deficits has fulfilled the tasks laid
down in Contact Committee resolution CC-R-2011-05. The Working Group
also

proposes

to

the

Contact

Committee

to

accept

the

following

recommendations:
-

To end the mandate of the Working Group on 31 December 2012
considering that its task has been fulfilled, and continue exchange of
experiences on audits of financial supervisors in the Fiscal Policy Audit
Network of the Contact Committee;
15

Access of Supreme Audit Institutions to financial
supervisors

-

To invite SAIs to indicate whether they would be interested in sharing
knowledge

and

experience

in

the

future,

and

to

explore

the

possibilities of a parallel audit in this area.

16

Access of Supreme Audit Institutions to financial
supervisors

Appendix 1

Contact Committee Resolution 2011

RESOLUTION
on setting up a working group to undertake a pilot study to identify
possible public audit deficits
CC-R-2011-05

The Contact Committee,
in view of the Statement of the Contact Committee on the Impact of the
European Semester (the ‘Statement’) and other recent developments in
EU economic governance on the Supreme Audit Institutions of the
Member States of the European Union and the European Court of
Auditors, adopted at its meeting in Luxembourg on 14 October 2011;

considering:
a) the reference in the Statement to an increased risk of gaps in
accountability and public audit in respect of the new arrangements and
instruments set up at national, EU and intergovernmental level;
b) the intention set out in the Statement to further develop cooperation
between EU SAIs and the ECA in this area through activities established
for this purpose;

decides to establish a working group on public audit deficits in the area of
new arrangements, measures and instruments set up at national, EU and
intergovernmental level in response to the financial and economic crisis;

mandates the Liaison Officers of the Supreme Audit Institutions of the
Member States of the European Union and the European Court of Auditors
to take the necessary steps to establish this new working group and to
undertake a pilot study consisting of an information request to financial
supervisors in order to identify possible public audit deficits related to SAI
mandate coverage and information access rights;

requests the working group to report back to the Contact Committee on
the results of the pilot study at its next meeting in 2012.
Luxembourg, 14 October 2011
SAI Rapporteur: SAI of the Netherlands

17