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EUROPEAN COMMISSION
Directorate-General for Justice and Consumers
JUST.H – Horizontal Affairs
H.3 – Budget, Programmes and Financial Management
GRANT AGREEMENT
Project 101191193 — Palk
PREAMBLE
This Agreement (‘the Agreement’) is between the following parties:
on the one part,
the European Union (‘EU’), represented by the European Commission (‘European Commission’ or
‘granting authority’),
and
on the other part,
1. ‘the coordinator’:
MAJANDUS JA KOMMUNIKATSIOONIMINISTEERIUM (MKM), PIC 963638450,
established in SUUR-AMEERIKA 1, TALLINN 10122, Estonia,
and the following other beneficiaries, if they sign their ‘accession form’ (see Annex 3 and Article 40):
2. TOOINSPEKTSIOON (LI), PIC 889079400, established in MAEALUSE TN 2/3, TALLINN
12618, Estonia,
3. SOOLISE VORDOIGUSLIKKUSE JA VORDSE KOHTLEMISE VOLINIKU
KANTSELEI (VOLINIK), PIC 917673448, established in Kiriku 4, TALLINN 10130, Estonia,
Unless otherwise specified, references to ‘beneficiary’ or ‘beneficiaries’ include the coordinator and
affiliated entities (if any).
If only one beneficiary signs the grant agreement (‘mono-beneficiary grant’), all provisions referring
to the ‘coordinator’ or the ‘beneficiaries’ will be considered — mutatis mutandis — as referring to
the beneficiary.
The parties referred to above have agreed to enter into the Agreement.
By signing the Agreement and the accession forms, the beneficiaries accept the grant and agree to
implement the action under their own responsibility and in accordance with the Agreement, with all
the obligations and terms and conditions it sets out.
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The Agreement is composed of:
Preamble
Terms and Conditions (including Data Sheet)
Annex 1 Description of the action1
Annex 2 Estimated budget for the action
Annex 3 Accession forms (if applicable)2
Annex 3a Declaration on joint and several liability of affiliated entities (if applicable)3
Annex 4 Model for the financial statements
Annex 5 Specific rules (if applicable)
1 Template published on Portal Reference Documents.
2 Template published on Portal Reference Documents.
3 Template published on Portal Reference Documents.
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TERMS AND CONDITIONS
TABLE OF CONTENTS
GRANT AGREEMENT.................................................................................................................................................... 1
PREAMBLE........................................................................................................................................................................1
TERMS AND CONDITIONS...........................................................................................................................................3
DATASHEET...................................................................................................................................................................... 8
CHAPTER 1 GENERAL..............................................................................................................................................12
ARTICLE 1 — SUBJECT OF THE AGREEMENT ..................................................................................... 12
ARTICLE 2 — DEFINITIONS........................................................................................................................12
CHAPTER 2 ACTION................................................................................................................................................. 13
ARTICLE 3 — ACTION................................................................................................................................. 13
ARTICLE 4 — DURATION AND STARTING DATE...................................................................................13
CHAPTER 3 GRANT...................................................................................................................................................13
ARTICLE 5 — GRANT...................................................................................................................................13
5.1 Form of grant......................................................................................................................................13
5.2 Maximum grant amount..................................................................................................................... 14
5.3 Funding rate........................................................................................................................................14
5.4 Estimated budget, budget categories and forms of funding.............................................................. 14
5.5 Budget flexibility................................................................................................................................14
ARTICLE 6 — ELIGIBLE AND INELIGIBLE CONTRIBUTIONS............................................................ 14
6.1 and 6.2 General and specific eligibility conditions........................................................................... 14
6.3 Ineligible contributions.......................................................................................................................15
6.4 Consequences of non-compliance...................................................................................................... 15
CHAPTER 4 GRANT IMPLEMENTATION............................................................................................................ 15
SECTION 1 CONSORTIUM: BENEFICIARIES, AFFILIATED ENTITIES AND OTHER
PARTICIPANTS........................................................................................................................................ 15
ARTICLE 7 — BENEFICIARIES................................................................................................................... 15
ARTICLE 8 — AFFILIATED ENTITIES....................................................................................................... 17
ARTICLE 9 — OTHER PARTICIPANTS INVOLVED IN THE ACTION................................................... 17
9.1 Associated partners.............................................................................................................................17
9.2 Third parties giving in-kind contributions to the action.................................................................... 17
9.3 Subcontractors.....................................................................................................................................18
9.4 Recipients of financial support to third parties..................................................................................18
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ARTICLE 10 — PARTICIPANTS WITH SPECIAL STATUS....................................................................... 18
10.1 Non-EU participants......................................................................................................................... 18
10.2 Participants which are international organisations...........................................................................19
10.3 Pillar-assessed participants............................................................................................................... 19
SECTION 2 RULES FOR CARRYING OUT THE ACTION...........................................................................21
ARTICLE 11 — PROPER IMPLEMENTATION OF THE ACTION............................................................ 21
11.1 Obligation to properly implement the action................................................................................... 21
11.2 Consequences of non-compliance.................................................................................................... 21
ARTICLE 12 — CONFLICT OF INTERESTS.............................................................................................. 22
12.1 Conflict of interests.......................................................................................................................... 22
12.2 Consequences of non-compliance.................................................................................................... 22
ARTICLE 13 — CONFIDENTIALITY AND SECURITY............................................................................ 22
13.1 Sensitive information........................................................................................................................22
13.2 Classified information...................................................................................................................... 23
13.3 Consequences of non-compliance.................................................................................................... 23
ARTICLE 14 — ETHICS AND VALUES...................................................................................................... 23
14.1 Ethics.................................................................................................................................................23
14.2 Values................................................................................................................................................ 23
14.3 Consequences of non-compliance.................................................................................................... 24
ARTICLE 15 — DATA PROTECTION.......................................................................................................... 24
15.1 Data processing by the granting authority....................................................................................... 24
15.2 Data processing by the beneficiaries............................................................................................... 24
15.3 Consequences of non-compliance.................................................................................................... 25
ARTICLE 16 — INTELLECTUAL PROPERTY RIGHTS (IPR) — BACKGROUND AND RESULTS —
ACCESS RIGHTS AND RIGHTS OF USE................................................................................ 25
16.1 Background and access rights to background..................................................................................25
16.2 Ownership of results.........................................................................................................................25
16.3 Rights of use of the granting authority on materials, documents and information received for
policy, information, communication, dissemination and publicity purposes...................................25
16.4 Specific rules on IPR, results and background................................................................................ 26
16.5 Consequences of non-compliance.................................................................................................... 26
ARTICLE 17 — COMMUNICATION, DISSEMINATION AND VISIBILITY............................................ 27
17.1 Communication — Dissemination — Promoting the action........................................................... 27
17.2 Visibility — European flag and funding statement......................................................................... 27
17.3 Quality of information — Disclaimer..............................................................................................28
17.4 Specific communication, dissemination and visibility rules............................................................28
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17.5 Consequences of non-compliance.................................................................................................... 28
ARTICLE 18 — SPECIFIC RULES FOR CARRYING OUT THE ACTION............................................... 28
SECTION 3 GRANT ADMINISTRATION......................................................................................................... 28
ARTICLE 19 — GENERAL INFORMATION OBLIGATIONS.................................................................... 28
19.1 Information requests......................................................................................................................... 28
19.2 Participant Register data updates..................................................................................................... 28
19.3 Information about events and circumstances which impact the action............................................28
19.4 Consequences of non-compliance.................................................................................................... 29
ARTICLE 20 — RECORD-KEEPING............................................................................................................ 29
20.1 Keeping records and supporting documents.................................................................................... 29
20.2 Consequences of non-compliance.................................................................................................... 29
ARTICLE 21 — REPORTING........................................................................................................................ 30
21.1 Continuous reporting........................................................................................................................ 30
21.2 Periodic reporting: Technical reports and financial statements....................................................... 30
21.3 Currency for financial statements and conversion into euros..........................................................31
21.4 Reporting language...........................................................................................................................31
21.5 Consequences of non-compliance.................................................................................................... 31
ARTICLE 22 — PAYMENTS AND RECOVERIES — CALCULATION OF AMOUNTS DUE................. 31
22.1 Payments and payment arrangements.............................................................................................. 31
22.2 Recoveries.........................................................................................................................................32
22.3 Amounts due.....................................................................................................................................32
22.4 Enforced recovery.............................................................................................................................36
22.5 Consequences of non-compliance.................................................................................................... 37
ARTICLE 23 — GUARANTEES....................................................................................................................38
23.1 Prefinancing guarantee..................................................................................................................... 38
23.2 Consequences of non-compliance.................................................................................................... 38
ARTICLE 24 — CERTIFICATES................................................................................................................... 38
ARTICLE 25 — CHECKS, REVIEWS, AUDITS AND INVESTIGATIONS — EXTENSION OF
FINDINGS..................................................................................................................................... 38
25.1 Granting authority checks, reviews and audits................................................................................ 38
25.2 European Commission checks, reviews and audits in grants of other granting authorities..............40
25.3 Access to records for assessing simplified forms of funding.......................................................... 40
25.4 OLAF, EPPO and ECA audits and investigations........................................................................... 40
25.5 Consequences of checks, reviews, audits and investigations — Extension of findings...................41
25.6 Consequences of non-compliance.................................................................................................... 42
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ARTICLE 26 — IMPACT EVALUATIONS................................................................................................... 42
26.1 Impact evaluation............................................................................................................................. 42
26.2 Consequences of non-compliance.................................................................................................... 42
CHAPTER 5 CONSEQUENCES OF NON-COMPLIANCE.................................................................................. 43
SECTION 1 REJECTIONS AND GRANT REDUCTION.................................................................................43
ARTICLE 27 — REJECTION OF CONTRIBUTIONS..................................................................................43
27.1 Conditions......................................................................................................................................... 43
27.2 Procedure.......................................................................................................................................... 43
27.3 Effects............................................................................................................................................... 43
ARTICLE 28 — GRANT REDUCTION........................................................................................................ 43
28.1 Conditions......................................................................................................................................... 43
28.2 Procedure.......................................................................................................................................... 44
28.3 Effects............................................................................................................................................... 44
SECTION 2 SUSPENSION AND TERMINATION............................................................................................44
ARTICLE 29 — PAYMENT DEADLINE SUSPENSION............................................................................. 44
29.1 Conditions......................................................................................................................................... 44
29.2 Procedure.......................................................................................................................................... 44
ARTICLE 30 — PAYMENT SUSPENSION...................................................................................................45
30.1 Conditions......................................................................................................................................... 45
30.2 Procedure.......................................................................................................................................... 45
ARTICLE 31 — GRANT AGREEMENT SUSPENSION..............................................................................46
31.1 Consortium-requested GA suspension............................................................................................. 46
31.2 EU-initiated GA suspension.............................................................................................................46
ARTICLE 32 — GRANT AGREEMENT OR BENEFICIARY TERMINATION......................................... 47
32.1 Consortium-requested GA termination............................................................................................ 48
32.2 Consortium-requested beneficiary termination................................................................................ 48
32.3 EU-initiated GA or beneficiary termination.................................................................................... 50
SECTION 3 OTHER CONSEQUENCES: DAMAGES AND ADMINISTRATIVE SANCTIONS............... 53
ARTICLE 33 — DAMAGES...........................................................................................................................53
33.1 Liability of the granting authority....................................................................................................53
33.2 Liability of the beneficiaries............................................................................................................ 53
ARTICLE 34 — ADMINISTRATIVE SANCTIONS AND OTHER MEASURES....................................... 53
SECTION 4 FORCE MAJEURE.......................................................................................................................... 53
ARTICLE 35 — FORCE MAJEURE.............................................................................................................. 53
CHAPTER 6 FINAL PROVISIONS...........................................................................................................................54
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ARTICLE 36 — COMMUNICATION BETWEEN THE PARTIES...............................................................54
36.1 Forms and means of communication — Electronic management................................................... 54
36.2 Date of communication.................................................................................................................... 54
36.3 Addresses for communication.......................................................................................................... 55
ARTICLE 37 — INTERPRETATION OF THE AGREEMENT.....................................................................55
ARTICLE 38 — CALCULATION OF PERIODS AND DEADLINES..........................................................55
ARTICLE 39 — AMENDMENTS.................................................................................................................. 55
39.1 Conditions......................................................................................................................................... 55
39.2 Procedure.......................................................................................................................................... 55
ARTICLE 40 — ACCESSION AND ADDITION OF NEW BENEFICIARIES........................................... 56
40.1 Accession of the beneficiaries mentioned in the Preamble............................................................. 56
40.2 Addition of new beneficiaries.......................................................................................................... 56
ARTICLE 41 — TRANSFER OF THE AGREEMENT................................................................................. 57
ARTICLE 42 — ASSIGNMENTS OF CLAIMS FOR PAYMENT AGAINST THE GRANTING
AUTHORITY.................................................................................................................................57
ARTICLE 43 — APPLICABLE LAW AND SETTLEMENT OF DISPUTES.............................................. 57
43.1 Applicable law..................................................................................................................................57
43.2 Dispute settlement............................................................................................................................ 57
ARTICLE 44 — ENTRY INTO FORCE.........................................................................................................58
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DATA SHEET
1. General data
Project summary:
Project summary
The project addresses the pressing issue of gender pay inequality, which persists despite existing legislation and initiatives aimed at
promoting gender equality in the EU. Estonia has one of the largest gender pay gaps in the EU (21.3% in 2022). The research in Estonia
suggests that pay transparency measures and gender-neutral job evaluation could contribute to the reduction of gender pay gap; at the
same time there is a lack of freely available up-to-date national guidelines to conduct such evaluations required by the Pay Transparency
Directive. The project's primary objective is to facilitate the implementation of the Pay Transparency Directive, and more specifically
the job evaluation requirement, via various interventions. These include the analysis of potential methodologies for job evaluation and
adapting one to Estonian context, offering comprehensive training to employers, and building institutional competencies on this topic
via training, guidelines and learning from selected EU MS. The target groups of the project are employers and key national institutions
responsible for the implementation and enforcement of the Directive. The project is carried out by the Ministry of Economic Affairs and
Communication, Labour Inspectorate and the Gender Equality and Equal Treatment Commissioner.
Keywords:
– pay transparency, training, awareness raising, gender pay gap, institutional capacity, gender-neutral job evaluation,
equal pay
Project number: 101191193
Project name: Supporting the implementation of Pay Transparency Directive in Estonia
Project acronym: Palk
Call: CERV-2024-GE
Topic: CERV-2024-GE
Type of action: CERV Lump Sum Grants
Granting authority: European Commission-EU
Grant managed through EU Funding & Tenders Portal: Yes (eGrants)
Project starting date: fixed date: 1 January 2025
Project end date: 31 December 2026
Project duration: 24 months
Consortium agreement: Yes
2. Participants
List of participants:
N° Role Short name Legal name Ctry PIC Max grant amount
1 COO MKM MAJANDUS JA KOMMUNIKATSIOONIMINISTEERIUM EE 963638450 323 471.25
2 BEN LI TOOINSPEKTSIOON EE 889079400 8 233.65
3 BEN VOLINIK SOOLISE VORDOIGUSLIKKUSE JA VORDSE KOHTLEMISE EE 917673448 3 900.15
VOLINIKU KANTSELEI
Total 335 605.05
Coordinator:
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– MAJANDUS JA KOMMUNIKATSIOONIMINISTEERIUM (MKM)
3. Grant
Maximum grant amount, total estimated eligible costs and contributions and funding rate:
Maximum grant amount Maximum grant amount
(Annex 2) (award decision)
335 605.05 335 605.05
Grant form: Lump Sum
Grant mode: Action grant
Budget categories/activity types: Lump sum contributions
Cost eligibility options: n/a
Budget flexibility: No
4. Reporting, payments and recoveries
4.1 Continuous reporting (art 21)
Deliverables: see Funding & Tenders Portal Continuous Reporting tool
4.2 Periodic reporting and payments
Reporting and payment schedule (art 21, 22):
Reporting Payments
Deadline
Reporting periods Type Deadline Type
(time to pay)
RP No Month from Month to
30 days from
entry into force/
financial guarantee
Initial prefinancing
(if required)
– whichever
is the latest
1 1 24 Periodic report 60 days after end Final payment 90 days from
of reporting period receiving
periodic report
Prefinancing payments and guarantees:
Prefinancing payment Prefinancing guarantee
Guarantee
Type Amount Division per participant
amount
Prefinancing 1 (initial) 268 484.04 n/a 1 - MKM n/a
2 - LI n/a
3 - VOLINIK n/a
Reporting and payment modalities (art 21, 22):
Mutual Insurance Mechanism (MIM): No
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Restrictions on distribution of initial prefinancing: The prefinancing may be distributed only if the minimum number of
beneficiaries set out in the call condititions (if any) have acceded to the Agreement and only to beneficiaries that have
acceded.
Interim payment ceiling (if any): 100% of the maximum grant amount
No-profit rule: n/a
Late payment interest: ECB + 3.5%
Bank account for payments:
EE891010220034796011 EEUHEE2X
Conversion into euros: n/a
Reporting language: Language of the Agreement or other EU official language, if specified in the call conditions
4.3 Certificates (art 24): n/a
4.4 Recoveries (art 22)
First-line liability for recoveries:
Beneficiary termination: Beneficiary concerned
Final payment: Coordinator
After final payment: Beneficiary concerned
Joint and several liability for enforced recoveries (in case of non-payment):
Limited joint and several liability of other beneficiaries — up to the maximum grant amount of the beneficiary
Joint and several liability of affiliated entities — n/a
5. Consequences of non-compliance, applicable law & dispute settlement forum
Applicable law (art 43):
Standard applicable law regime: EU law + law of Belgium
Dispute settlement forum (art 43):
Standard dispute settlement forum:
EU beneficiaries: EU General Court + EU Court of Justice (on appeal)
Non-EU beneficiaries: Courts of Brussels, Belgium (unless an international agreement provides for the
enforceability of EU court judgements)
6. Other
Specific rules (Annex 5): Yes
Standard time-limits after project end:
Confidentiality (for X years after final payment): 5
Record-keeping (for X years after final payment): 5 (or 3 for grants of not more than EUR 60 000)
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Reviews (up to X years after final payment): 5 (or 3 for grants of not more than EUR 60 000)
Audits (up to X years after final payment): 5 (or 3 for grants of not more than EUR 60 000)
Extension of findings from other grants to this grant (no later than X years after final payment): 5 (or 3 for grants of
not more than EUR 60 000)
Impact evaluation (up to X years after final payment): 5 (or 3 for grants of not more than EUR 60 000)
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CHAPTER 1 GENERAL
ARTICLE 1 — SUBJECT OF THE AGREEMENT
This Agreement sets out the rights and obligations and terms and conditions applicable to the grant
awarded for the implementation of the action set out in Chapter 2.
ARTICLE 2 — DEFINITIONS
For the purpose of this Agreement, the following definitions apply:
Actions — The project which is being funded in the context of this Agreement.
Grant — The grant awarded in the context of this Agreement.
EU grants — Grants awarded by EU institutions, bodies, offices or agencies (including EU executive
agencies, EU regulatory agencies, EDA, joint undertakings, etc.).
Participants — Entities participating in the action as beneficiaries, affiliated entities, associated
partners, third parties giving in-kind contributions, subcontractors or recipients of
financial support to third parties.
Beneficiaries (BEN) — The signatories of this Agreement (either directly or through an accession
form).
Affiliated entities (AE) — Entities affiliated to a beneficiary within the meaning of Article 187 of
EU Financial Regulation 2018/10464 which participate in the action with similar rights
and obligations as the beneficiaries (obligation to implement action tasks and right to
charge costs and claim contributions).
Associated partners (AP) — Entities which participate in the action, but without the right to charge
costs or claim contributions.
Purchases — Contracts for goods, works or services needed to carry out the action (e.g. equipment,
consumables and supplies) but which are not part of the action tasks (see Annex 1).
Subcontracting — Contracts for goods, works or services that are part of the action tasks (see Annex 1).
In-kind contributions — In-kind contributions within the meaning of Article 2(36) of EU Financial
4 For the definition, see Article 187 Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council
of 18 July 2018 on the financial rules applicable to the general budget of the Union, amending Regulations (EU)
No 1296/2013, (EU) No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013,
(EU) No 223/2014, (EU) No 283/2014, and Decision No 541/2014/EU and repealing Regulation (EU, Euratom)
No 966/2012 (‘EU Financial Regulation’) (OJ L 193, 30.7.2018, p. 1): “affiliated entities [are]:
(a) entities that form a sole beneficiary [(i.e. where an entity is formed of several entities that satisfy the criteria for
being awarded a grant, including where the entity is specifically established for the purpose of implementing an
action to be financed by a grant)];
(b) entities that satisfy the eligibility criteria and that do not fall within one of the situations referred to in Article 136(1)
and 141(1) and that have a link with the beneficiary, in particular a legal or capital link, which is neither limited to
the action nor established for the sole purpose of its implementation”.
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Regulation 2018/1046, i.e. non-financial resources made available free of charge by
third parties.
Fraud — Fraud within the meaning of Article 3 of EU Directive 2017/13715 and Article 1 of the
Convention on the protection of the European Communities’ financial interests, drawn
up by the Council Act of 26 July 19956, as well as any other wrongful or criminal
deception intended to result in financial or personal gain.
Irregularities — Any type of breach (regulatory or contractual) which could impact the EU
financial interests, including irregularities within the meaning of Article 1(2) of EU
Regulation 2988/957.
Grave professional misconduct — Any type of unacceptable or improper behaviour in exercising one’s
profession, especially by employees, including grave professional misconduct within
the meaning of Article 136(1)(c) of EU Financial Regulation 2018/1046.
Applicable EU, international and national law — Any legal acts or other (binding or non-binding)
rules and guidance in the area concerned.
Portal — EU Funding & Tenders Portal; electronic portal and exchange system managed by the
European Commission and used by itself and other EU institutions, bodies, offices
or agencies for the management of their funding programmes (grants, procurements,
prizes, etc.).
CHAPTER 2 ACTION
ARTICLE 3 — ACTION
The grant is awarded for the action 101191193 — Palk (‘action’), as described in Annex 1.
ARTICLE 4 — DURATION AND STARTING DATE
The duration and the starting date of the action are set out in the Data Sheet (see Point 1).
CHAPTER 3 GRANT
ARTICLE 5 — GRANT
5.1 Form of grant
5 Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight against fraud to
the Union’s financial interests by means of criminal law (OJ L 198, 28.7.2017, p. 29).
6 OJ C 316, 27.11.1995, p. 48.
7 Council Regulation (EC, Euratom) No 2988/95 of 18 December 1995 on the protection of the European Communities
financial interests (OJ L 312, 23.12.1995, p. 1).
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The grant is an action grant8 which takes the form of a lump sum grant for the completion of work
packages.
5.2 Maximum grant amount
The maximum grant amount is set out in the Data Sheet (see Point 3) and in the estimated budget
(Annex 2).
5.3 Funding rate
Not applicable
5.4 Estimated budget, budget categories and forms of funding
The estimated budget for the action (lump sum breakdown) is set out in Annex 2.
It contains the estimated eligible contributions for the action (lump sum contributions), broken down
by participant and work package.
Annex 2 also shows the types of contributions (forms of funding)9 to be used for each work package.
5.5 Budget flexibility
Budget flexibility does not apply; changes to the estimated budget (lump sum breakdown) always
require an amendment (see Article 39).
Amendments for transfers between work packages are moreover possible only if:
- the work packages concerned are not already completed (and declared in a financial statement)
and
- the transfers are justified by the technical implementation of the action.
ARTICLE 6 — ELIGIBLE AND INELIGIBLE CONTRIBUTIONS
6.1 and 6.2 General and specific eligibility conditions
Lump sum contributions are eligible (‘eligible contributions’), if:
(a) they are set out in Annex 2 and
(b) the work packages are completed and the work is properly implemented by the beneficiaries
and/or the results are achieved, in accordance with Annex 1 and during in the period set out
in Article 4 (with the exception of work/results relating to the submission of the final periodic
report, which may be achieved afterwards; see Article 21)
They will be calculated on the basis of the amounts set out in Annex 2.
8 For the definition, see Article 180(2)(a) EU Financial Regulation 2018/1046: ‘action grant’ means an EU grant to
finance “an action intended to help achieve a Union policy objective”.
9 See Article 125 EU Financial Regulation 2018/1046.
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6.3 Ineligible contributions
‘Ineligible contributions’ are:
(a) lump sum contributions that do not comply with the conditions set out above (see Article 6.1
and 6.2)
(b) lump sum contributions for activities already funded under other EU grants (or grants awarded
by an EU Member State, non-EU country or other body implementing the EU budget), except
for the following case:
(i) Synergy actions: not applicable
(c) other:
(i) country restrictions for eligible costs: not applicable.
6.4 Consequences of non-compliance
If a beneficiary declares lump sum contributions that are ineligible, they will be rejected (see
Article 27).
This may also lead to other measures described in Chapter 5.
CHAPTER 4 GRANT IMPLEMENTATION
SECTION 1 CONSORTIUM: BENEFICIARIES, AFFILIATED ENTITIES AND OTHER
PARTICIPANTS
ARTICLE 7 — BENEFICIARIES
The beneficiaries, as signatories of the Agreement, are fully responsible towards the granting authority
for implementing it and for complying with all its obligations.
They must implement the Agreement to their best abilities, in good faith and in accordance with all
the obligations and terms and conditions it sets out.
They must have the appropriate resources to implement the action and implement the action under
their own responsibility and in accordance with Article 11. If they rely on affiliated entities or other
participants (see Articles 8 and 9), they retain sole responsibility towards the granting authority and
the other beneficiaries.
They are jointly responsible for the technical implementation of the action. If one of the beneficiaries
fails to implement their part of the action, the other beneficiaries must ensure that this part is
implemented by someone else (without being entitled to an increase of the maximum grant amount
and subject to an amendment; see Article 39). The financial responsibility of each beneficiary in case
of recoveries is governed by Article 22.
The beneficiaries (and their action) must remain eligible under the EU programme funding the grant
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for the entire duration of the action. Lump sum contributions will be eligible only as long as the
beneficiary and the action are eligible.
The internal roles and responsibilities of the beneficiaries are divided as follows:
(a) Each beneficiary must:
(i) keep information stored in the Portal Participant Register up to date (see Article 19)
(ii) inform the granting authority (and the other beneficiaries) immediately of any events or
circumstances likely to affect significantly or delay the implementation of the action (see
Article 19)
(iii) submit to the coordinator in good time:
- the prefinancing guarantees (if required; see Article 23)
- the financial statements and certificates on the financial statements (CFS): not
applicable
- the contribution to the deliverables and technical reports (see Article 21)
- any other documents or information required by the granting authority under the
Agreement
(iv) submit via the Portal data and information related to the participation of their affiliated
entities.
(b) The coordinator must:
(i) monitor that the action is implemented properly (see Article 11)
(ii) act as the intermediary for all communications between the consortium and the granting
authority, unless the Agreement or granting authority specifies otherwise, and in
particular:
- submit the prefinancing guarantees to the granting authority (if any)
- request and review any documents or information required and verify their quality
and completeness before passing them on to the granting authority
- submit the deliverables and reports to the granting authority
- inform the granting authority about the payments made to the other beneficiaries
(report on the distribution of payments; if required, see Articles 22 and 32)
(iii) distribute the payments received from the granting authority to the other beneficiaries
without unjustified delay (see Article 22).
The coordinator may not delegate or subcontract the above-mentioned tasks to any other beneficiary
or third party (including affiliated entities).
However, coordinators which are public bodies may delegate the tasks set out in Point (b)(ii) last
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indent and (iii) above to entities with ‘authorisation to administer’ which they have created or which
are controlled by or affiliated to them. In this case, the coordinator retains sole responsibility for the
payments and for compliance with the obligations under the Agreement.
Moreover, coordinators which are ‘sole beneficiaries’10 (or similar, such as European research
infrastructure consortia (ERICs)) may delegate the tasks set out in Point (b)(i) to (iii) above to one of
their members. The coordinator retains sole responsibility for compliance with the obligations under
the Agreement.
The beneficiaries must have internal arrangements regarding their operation and co-ordination, to
ensure that the action is implemented properly.
If required by the granting authority (see Data Sheet, Point 1), these arrangements must be set out in
a written consortium agreement between the beneficiaries, covering for instance:
- the internal organisation of the consortium
- the management of access to the Portal
- different distribution keys for the payments and financial responsibilities in case of recoveries
(if any)
- additional rules on rights and obligations related to background and results (see Article 16)
- settlement of internal disputes
- liability, indemnification and confidentiality arrangements between the beneficiaries.
The internal arrangements must not contain any provision contrary to this Agreement.
ARTICLE 8 — AFFILIATED ENTITIES
Not applicable
ARTICLE 9 — OTHER PARTICIPANTS INVOLVED IN THE ACTION
9.1 Associated partners
Not applicable
9.2 Third parties giving in-kind contributions to the action
Other third parties may give in-kind contributions to the action (i.e. personnel, equipment, other goods,
works and services, etc. which are free-of-charge), if necessary for the implementation.
Third parties giving in-kind contributions do not implement any action tasks. They may not charge
contributions to the action (no lump sum contributions) and the costs for the in-kind contributions are
not eligible (may not be included in the estimated budget in Annex 2).
10 For the definition, see Article 187(2) EU Financial Regulation 2018/1046: “Where several entities satisfy the criteria
for being awarded a grant and together form one entity, that entity may be treated as the sole beneficiary, including
where it is specifically established for the purpose of implementing the action financed by the grant.”
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The third parties and their in-kind contributions should be set out in Annex 1.
9.3 Subcontractors
Subcontractors may participate in the action, if necessary for the implementation.
Subcontractors must implement their action tasks in accordance with Article 11. The beneficiaries’
costs for subcontracting are considered entirely covered by the lump sum contributions for
implementing the work packages (irrespective of the actual subcontracting costs incurred, if any).
The beneficiaries must ensure that their contractual obligations under Articles 11 (proper
implementation), 12 (conflict of interest), 13 (confidentiality and security), 14 (ethics), 17.2
(visibility), 18 (specific rules for carrying out action), 19 (information) and 20 (record-keeping) also
apply to the subcontractors.
The beneficiaries must ensure that the bodies mentioned in Article 25 (e.g. granting authority, OLAF,
Court of Auditors (ECA), etc.) can exercise their rights also towards the subcontractors.
9.4 Recipients of financial support to third parties
If the action includes providing financial support to third parties (e.g. grants, prizes or similar forms of
support), the beneficiaries must ensure that their contractual obligations under Articles 12 (conflict of
interest), 13 (confidentiality and security), 14 (ethics), 17.2 (visibility), 18 (specific rules for carrying
out action), 19 (information) and 20 (record-keeping)also apply to the third parties receiving the
support (recipients).
The beneficiaries must also ensure that the bodies mentioned in Article 25 (e.g. granting authority,
OLAF, Court of Auditors (ECA), etc.) can exercise their rights also towards the recipients.
ARTICLE 10 — PARTICIPANTS WITH SPECIAL STATUS
10.1 Non-EU participants
Participants which are established in a non-EU country (if any) undertake to comply with their
obligations under the Agreement and:
- to respect general principles (including fundamental rights, values and ethical principles,
environmental and labour standards, rules on classified information, intellectual property
rights, visibility of funding and protection of personal data)
- for the submission of certificates under Article 24: use qualified external auditors which
are independent and comply with comparable standards as those set out in EU Directive
2006/43/EC11
- for the controls under Article 25: allow for checks, reviews, audits and investigations (including
on-the-spot checks, visits and inspections) by the bodies mentioned in that Article (e.g. granting
authority, OLAF, Court of Auditors (ECA), etc.).
11 Directive 2006/43/EC of the European Parliament and of the Council of 17 May 2006 on statutory audits of annual
accounts and consolidated accounts or similar national regulations (OJ L 157, 9.6.2006, p. 87).
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Special rules on dispute settlement apply (see Data Sheet, Point 5).
10.2 Participants which are international organisations
Participants which are international organisations (IOs; if any) undertake to comply with their
obligations under the Agreement and:
- to respect general principles (including fundamental rights, values and ethical principles,
environmental and labour standards, rules on classified information, intellectual property
rights, visibility of funding and protection of personal data)
- for the submission of certificates under Article 24: to use either independent public officers or
external auditors which comply with comparable standards as those set out in EU Directive
2006/43/EC
- for the controls under Article 25: to allow for the checks, reviews, audits and investigations
by the bodies mentioned in that Article, taking into account the specific agreements concluded
by them and the EU (if any).
For such participants, nothing in the Agreement will be interpreted as a waiver of their privileges or
immunities, as accorded by their constituent documents or international law.
Special rules on applicable law and dispute settlement apply (see Article 43 and Data Sheet, Point 5).
10.3 Pillar-assessed participants
Pillar-assessed participants (if any) may rely on their own systems, rules and procedures, in so far as
they have been positively assessed and do not call into question the decision awarding the grant or
breach the principle of equal treatment of applicants or beneficiaries.
‘Pillar-assessment’ means a review by the European Commission on the systems, rules and procedures
which participants use for managing EU grants (in particular internal control system, accounting
system, external audits, financing of third parties, rules on recovery and exclusion, information on
recipients and protection of personal data; see Article 154 EU Financial Regulation 2018/1046).
Participants with a positive pillar assessment may rely on their own systems, rules and procedures,
in particular for:
- record-keeping (Article 20): may be done in accordance with internal standards, rules and
procedures
- currency conversion for financial statements (Article 21): may be done in accordance with
usual accounting practices
- guarantees (Article 23): for public law bodies, prefinancing guarantees are not needed
- certificates (Article 24):
- certificates on the financial statements (CFS): may be provided by their regular internal
or external auditors and in accordance with their internal financial regulations and
procedures
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- certificates on usual accounting practices (CoMUC): are not needed if those practices
are covered by an ex-ante assessment
and use the following specific rules, for:
- recoveries (Article 22): in case of financial support to third parties, there will be no recovery if
the participant has done everything possible to retrieve the undue amounts from the third party
receiving the support (including legal proceedings) and non-recovery is not due to an error or
negligence on its part
- checks, reviews, audits and investigations by the EU (Article 25): will be conducted taking
into account the rules and procedures specifically agreed between them and the framework
agreement (if any)
- impact evaluation (Article 26): will be conducted in accordance with the participant’s internal
rules and procedures and the framework agreement (if any)
- grant agreement suspension (Article 31): certain costs incurred during grant suspension are
eligible (notably, minimum costs necessary for a possible resumption of the action and costs
relating to contracts which were entered into before the pre-information letter was received and
which could not reasonably be suspended, reallocated or terminated on legal grounds)
- grant agreement termination (Article 32): the final grant amount and final payment will be
calculated taking into account also costs relating to contracts due for execution only after
termination takes effect, if the contract was entered into before the pre-information letter was
received and could not reasonably be terminated on legal grounds
- liability for damages (Article 33.2): the granting authority must be compensated for damage
it sustains as a result of the implementation of the action or because the action was not
implemented in full compliance with the Agreement only if the damage is due to an
infringement of the participant’s internal rules and procedures or due to a violation of third
parties’ rights by the participant or one of its employees or individual for whom the employees
are responsible.
Participants whose pillar assessment covers procurement and granting procedures may also do
purchases, subcontracting and financial support to third parties (Article 6.2) in accordance with their
internal rules and procedures for purchases, subcontracting and financial support.
Participants whose pillar assessment covers data protection rules may rely on their internal standards,
rules and procedures for data protection (Article 15).
The participants may however not rely on provisions which would breach the principle of equal
treatment of applicants or beneficiaries or call into question the decision awarding the grant, such as
in particular:
- eligibility (Article 6)
- consortium roles and set-up (Articles 7-9)
- security and ethics (Articles 13, 14)
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- IPR (including background and results, access rights and rights of use), communication,
dissemination and visibility (Articles 16 and 17)
- information obligation (Article 19)
- payment, reporting and amendments (Articles 21, 22 and 39)
- rejections, reductions, suspensions and terminations (Articles 27, 28, 29-32)
If the pillar assessment was subject to remedial measures, reliance on the internal systems, rules and
procedures is subject to compliance with those remedial measures.
Participants whose assessment has not yet been updated to cover (the new rules on) data protection
may rely on their internal systems, rules and procedures, provided that they ensure that personal data is:
- processed lawfully, fairly and in a transparent manner in relation to the data subject
- collected for specified, explicit and legitimate purposes and not further processed in a manner
that is incompatible with those purposes
- adequate, relevant and limited to what is necessary in relation to the purposes for which they
are processed
- accurate and, where necessary, kept up to date
- kept in a form which permits identification of data subjects for no longer than is necessary for
the purposes for which the data is processed and
- processed in a manner that ensures appropriate security of the personal data.
Participants must inform the coordinator without delay of any changes to the systems, rules and
procedures that were part of the pillar assessment. The coordinator must immediately inform the
granting authority.
Pillar-assessed participants that have also concluded a framework agreement with the EU, may
moreover — under the same conditions as those above (i.e. not call into question the decision awarding
the grant or breach the principle of equal treatment of applicants or beneficiaries) — rely on provisions
set out in that framework agreement.
SECTION 2 RULES FOR CARRYING OUT THE ACTION
ARTICLE 11 — PROPER IMPLEMENTATION OF THE ACTION
11.1 Obligation to properly implement the action
The beneficiaries must implement the action as described in Annex 1 and in compliance with the
provisions of the Agreement, the call conditions and all legal obligations under applicable EU,
international and national law.
11.2 Consequences of non-compliance
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If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 12 — CONFLICT OF INTERESTS
12.1 Conflict of interests
The beneficiaries must take all measures to prevent any situation where the impartial and objective
implementation of the Agreement could be compromised for reasons involving family, emotional life,
political or national affinity, economic interest or any other direct or indirect interest (‘conflict of
interests’).
They must formally notify the granting authority without delay of any situation constituting or likely
to lead to a conflict of interests and immediately take all the necessary steps to rectify this situation.
The granting authority may verify that the measures taken are appropriate and may require additional
measures to be taken by a specified deadline.
12.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28) and the grant or the beneficiary may be terminated (see Article 32).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 13 — CONFIDENTIALITY AND SECURITY
13.1 Sensitive information
The parties must keep confidential any data, documents or other material (in any form) that is identified
as sensitive in writing (‘sensitive information’) — during the implementation of the action and for at
least until the time-limit set out in the Data Sheet (see Point 6).
If a beneficiary requests, the granting authority may agree to keep such information confidential for
a longer period.
Unless otherwise agreed between the parties, they may use sensitive information only to implement
the Agreement.
The beneficiaries may disclose sensitive information to their personnel or other participants involved
in the action only if they:
(a) need to know it in order to implement the Agreement and
(b) are bound by an obligation of confidentiality.
The granting authority may disclose sensitive information to its staff and to other EU institutions and
bodies.
It may moreover disclose sensitive information to third parties, if:
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(a) this is necessary to implement the Agreement or safeguard the EU financial interests and
(b) the recipients of the information are bound by an obligation of confidentiality.
The confidentiality obligations no longer apply if:
(a) the disclosing party agrees to release the other party
(b) the information becomes publicly available, without breaching any confidentiality obligation
(c) the disclosure of the sensitive information is required by EU, international or national law.
Specific confidentiality rules (if any) are set out in Annex 5.
13.2 Classified information
The parties must handle classified information in accordance with the applicable EU, international or
national law on classified information (in particular, Decision 2015/44412 and its implementing rules).
Deliverables which contain classified information must be submitted according to special procedures
agreed with the granting authority.
Action tasks involving classified information may be subcontracted only after explicit approval (in
writing) from the granting authority.
Classified information may not be disclosed to any third party (including participants involved in the
action implementation) without prior explicit written approval from the granting authority.
Specific security rules (if any) are set out in Annex 5.
13.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 14 — ETHICS AND VALUES
14.1 Ethics
The action must be carried out in line with the highest ethical standards and the applicable EU,
international and national law on ethical principles.
Specific ethics rules (if any) are set out in Annex 5.
14.2 Values
The beneficiaries must commit to and ensure the respect of basic EU values (such as respect for
12 Commission Decision 2015/444/EC, Euratom of 13 March 2015 on the security rules for protecting EU classified
information (OJ L 72, 17.3.2015, p. 53).
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human dignity, freedom, democracy, equality, the rule of law and human rights, including the rights
of minorities).
Specific rules on values (if any) are set out in Annex 5.
14.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 15 — DATA PROTECTION
15.1 Data processing by the granting authority
Any personal data under the Agreement will be processed under the responsibility of the data
controller of the granting authority in accordance with and for the purposes set out in the Portal Privacy
Statement.
For grants where the granting authority is the European Commission, an EU regulatory or executive
agency, joint undertaking or other EU body, the processing will be subject to Regulation 2018/172513.
15.2 Data processing by the beneficiaries
The beneficiaries must process personal data under the Agreement in compliance with the applicable
EU, international and national law on data protection (in particular, Regulation 2016/67914).
They must ensure that personal data is:
- processed lawfully, fairly and in a transparent manner in relation to the data subjects
- collected for specified, explicit and legitimate purposes and not further processed in a manner
that is incompatible with those purposes
- adequate, relevant and limited to what is necessary in relation to the purposes for which they
are processed
- accurate and, where necessary, kept up to date
- kept in a form which permits identification of data subjects for no longer than is necessary for
the purposes for which the data is processed and
- processed in a manner that ensures appropriate security of the data.
13 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of
natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies
and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC
(OJ L 295, 21.11.2018, p. 39).
14 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural
persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive
95/46/EC (‘GDPR’) (OJ L 119, 4.5.2016, p. 1).
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The beneficiaries may grant their personnel access to personal data only if it is strictly necessary
for implementing, managing and monitoring the Agreement. The beneficiaries must ensure that the
personnel is under a confidentiality obligation.
The beneficiaries must inform the persons whose data are transferred to the granting authority and
provide them with the Portal Privacy Statement.
15.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 16 — INTELLECTUAL PROPERTY RIGHTS (IPR) — BACKGROUND AND
RESULTS —ACCESS RIGHTS AND RIGHTS OF USE
16.1 Background and access rights to background
The beneficiaries must give each other and the other participants access to the background identified
as needed for implementing the action, subject to any specific rules in Annex 5.
‘Background’ means any data, know-how or information — whatever its form or nature (tangible or
intangible), including any rights such as intellectual property rights — that is:
(a) held by the beneficiaries before they acceded to the Agreement and
(b) needed to implement the action or exploit the results.
If background is subject to rights of a third party, the beneficiary concerned must ensure that it is able
to comply with its obligations under the Agreement.
16.2 Ownership of results
The granting authority does not obtain ownership of the results produced under the action.
‘Results’ means any tangible or intangible effect of the action, such as data, know-how or information,
whatever its form or nature, whether or not it can be protected, as well as any rights attached to it,
including intellectual property rights.
16.3 Rights of use of the granting authority on materials, documents and information
received for policy, information, communication, dissemination and publicity purposes
The granting authority has the right to use non-sensitive information relating to the action and
materials and documents received from the beneficiaries (notably summaries for publication,
deliverables, as well as any other material, such as pictures or audio-visual material, in paper or
electronic form) for policy information, communication, dissemination and publicity purposes —
during the action or afterwards.
The right to use the beneficiaries’ materials, documents and information is granted in the form of a
royalty-free, non-exclusive and irrevocable licence, which includes the following rights:
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(a) use for its own purposes (in particular, making them available to persons working for the
granting authority or any other EU service (including institutions, bodies, offices, agencies,
etc.) or EU Member State institution or body; copying or reproducing them in whole or in part,
in unlimited numbers; and communication through press information services)
(b) distribution to the public (in particular, publication as hard copies and in electronic or digital
format, publication on the internet, as a downloadable or non-downloadable file, broadcasting
by any channel, public display or presentation, communicating through press information
services, or inclusion in widely accessible databases or indexes)
(c) editing or redrafting (including shortening, summarising, inserting other elements (e.g.
meta-data, legends, other graphic, visual, audio or text elements), extracting parts (e.g. audio
or video files), dividing into parts, use in a compilation)
(d) translation
(e) storage in paper, electronic or other form
(f) archiving, in line with applicable document-management rules
(g) the right to authorise third parties to act on its behalf or sub-license to third parties the modes
of use set out in Points (b), (c), (d) and (f), if needed for the information, communication and
publicity activity of the granting authority and
(h) processing, analysing, aggregating the materials, documents and information received and
producing derivative works.
The rights of use are granted for the whole duration of the industrial or intellectual property rights
concerned.
If materials or documents are subject to moral rights or third party rights (including intellectual
property rights or rights of natural persons on their image and voice), the beneficiaries must ensure
that they comply with their obligations under this Agreement (in particular, by obtaining the necessary
licences and authorisations from the rights holders concerned).
Where applicable, the granting authority will insert the following information:
“© – [year] – [name of the copyright owner]. All rights reserved. Licensed to the [name of granting authority]
under conditions.”
16.4 Specific rules on IPR, results and background
Specific rules regarding intellectual property rights, results and background (if any) are set out in
Annex 5.
16.5 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such a breach may also lead to other measures described in Chapter 5.
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ARTICLE 17 — COMMUNICATION, DISSEMINATION AND VISIBILITY
17.1 Communication — Dissemination — Promoting the action
Unless otherwise agreed with the granting authority, the beneficiaries must promote the action and its
results by providing targeted information to multiple audiences (including the media and the public),
in accordance with Annex 1 and in a strategic, coherent and effective manner.
Before engaging in a communication or dissemination activity expected to have a major media impact,
the beneficiaries must inform the granting authority.
17.2 Visibility — European flag and funding statement
Unless otherwise agreed with the granting authority, communication activities of the beneficiaries
related to the action (including media relations, conferences, seminars, information material, such as
brochures, leaflets, posters, presentations, etc., in electronic form, via traditional or social media, etc.),
dissemination activities and any infrastructure, equipment, vehicles, supplies or major result funded
by the grant must acknowledge the EU support and display the European flag (emblem) and funding
statement (translated into local languages, where appropriate):
The emblem must remain distinct and separate and cannot be modified by adding other visual
marks, brands or text.
Apart from the emblem, no other visual identity or logo may be used to highlight the EU support.
When displayed in association with other logos (e.g. of beneficiaries or sponsors), the emblem must
be displayed at least as prominently and visibly as the other logos.
For the purposes of their obligations under this Article, the beneficiaries may use the emblem without
first obtaining approval from the granting authority. This does not, however, give them the right to
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exclusive use. Moreover, they may not appropriate the emblem or any similar trademark or logo, either
by registration or by any other means.
17.3 Quality of information — Disclaimer
Any communication or dissemination activity related to the action must use factually accurate
information.
Moreover, it must indicate the following disclaimer (translated into local languages where
appropriate):
“Funded by the European Union. Views and opinions expressed are however those of the author(s) only
and do not necessarily reflect those of the European Union or [name of the granting authority]. Neither
the European Union nor the granting authority can be held responsible for them.”
17.4 Specific communication, dissemination and visibility rules
Specific communication, dissemination and visibility rules (if any) are set out in Annex 5.
17.5 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 18 — SPECIFIC RULES FOR CARRYING OUT THE ACTION
Not applicable
SECTION 3 GRANT ADMINISTRATION
ARTICLE 19 — GENERAL INFORMATION OBLIGATIONS
19.1 Information requests
The beneficiaries must provide — during the action or afterwards and in accordance with Article 7 —
any information requested in order to verify eligibility of the lump sum contributions declared, proper
implementation of the action and compliance with the other obligations under the Agreement.
The information provided must be accurate, precise and complete and in the format requested,
including electronic format.
19.2 Participant Register data updates
The beneficiaries must keep — at all times, during the action or afterwards — their information stored
in the Portal Participant Register up to date, in particular, their name, address, legal representatives,
legal form and organisation type.
19.3 Information about events and circumstances which impact the action
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The beneficiaries must immediately inform the granting authority (and the other beneficiaries) of any
of the following:
(a) events which are likely to affect or delay the implementation of the action or affect the EU’s
financial interests, in particular:
(i) changes in their legal, financial, technical, organisational or ownership situation
(including changes linked to one of the exclusion grounds listed in the declaration of
honour signed before grant signature)
(ii) linked action information: not applicable
(b) circumstances affecting:
(i) the decision to award the grant or
(ii) compliance with requirements under the Agreement.
19.4 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 20 — RECORD-KEEPING
20.1 Keeping records and supporting documents
The beneficiaries must — at least until the time-limit set out in the Data Sheet (see Point 6) — keep
records and other supporting documents to prove the proper implementation of the action (proper
implementation of the work and/or achievement of the results as described in Annex 1) in line with the
accepted standards in the respective field (if any); beneficiaries do not need to keep specific records
on the actual costs incurred.
The records and supporting documents must be made available upon request (see Article 19) or in the
context of checks, reviews, audits or investigations (see Article 25).
If there are on-going checks, reviews, audits, investigations, litigation or other pursuits of claims under
the Agreement (including the extension of findings; see Article 25), the beneficiaries must keep these
records and other supporting documentation until the end of these procedures.
The beneficiaries must keep the original documents. Digital and digitalised documents are considered
originals if they are authorised by the applicable national law. The granting authority may accept
non-original documents if they offer a comparable level of assurance.
20.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, lump sum contributions insufficiently
substantiated will be ineligible (see Article 6) and will be rejected (see Article 27), and the grant may
be reduced (see Article 28).
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Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 21 — REPORTING
21.1 Continuous reporting
The beneficiaries must continuously report on the progress of the action (e.g. deliverables,
milestones, outputs/outcomes, critical risks, indicators, etc; if any), in the Portal Continuous
Reporting tool and in accordance with the timing and conditions it sets out (as agreed with the granting
authority).
Standardised deliverables (e.g. progress reports not linked to payments, reports on cumulative
expenditure, special reports, etc; if any) must be submitted using the templates published on the Portal.
21.2 Periodic reporting: Technical reports and financial statements
In addition, the beneficiaries must provide reports to request payments, in accordance with the
schedule and modalities set out in the Data Sheet (see Point 4.2):
- for additional prefinancings (if any): an additional prefinancing report
- for interim payments (if any) and the final payment: a periodic report
The prefinancing and periodic reports include a technical and financial part.
The technical part includes an overview of the action implementation. It must be prepared using the
template available in the Portal Periodic Reporting tool.
The financial part of the additional prefinancing report includes a statement on the use of the previous
prefinancing payment.
The financial part of the periodic report includes:
- the financial statement (consolidated statement for the consortium)
- the explanation on the use of resources (or detailed cost reporting table): not applicable
- the certificates on the financial statements (CFS): not applicable.
The financial statement must contain the lump sum contributions indicated in Annex 2, for the work
packages that were completed during the reporting period.
For the last reporting period, the beneficiaries may exceptionally also declare partial lump sum
contributions for work packages that were not completed (e.g. due to force majeure or technical
impossibility).
Lump sum contributions which are not declared in a financial statement will not be taken into account
by the granting authority.
By signing the financial statement (directly in the Portal Periodic Reporting tool), the coordinator
confirms (on behalf of the consortium) that:
- the information provided is complete, reliable and true
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- the lump sum contributions declared are eligible (in particular, the work packages have been
completed, that the work has been properly implemented and/or the results were achieved in
accordance with Annex 1; see Article 6)
- the proper implementation and/or achievement can be substantiated by adequate records and
supporting documents (see Article 20) that will be produced upon request (see Article 19) or
in the context of checks, reviews, audits and investigations (see Article 25).
In case of recoveries (see Article 22), beneficiaries will be held responsible also for the lump sum
contributions declared for their affiliated entities (if any).
21.3 Currency for financial statements and conversion into euros
The financial statements must be drafted in euro.
21.4 Reporting language
The reporting must be in the language of the Agreement, unless otherwise agreed with the granting
authority (see Data Sheet, Point 4.2).
21.5 Consequences of non-compliance
If a report submitted does not comply with this Article, the granting authority may suspend the
payment deadline (see Article 29) and apply other measures described in Chapter 5.
If the coordinator breaches its reporting obligations, the granting authority may terminate the grant or
the coordinator’s participation (see Article 32) or apply other measures described in Chapter 5.
ARTICLE 22 — PAYMENTS AND RECOVERIES — CALCULATION OF AMOUNTS
DUE
22.1 Payments and payment arrangements
Payments will be made in accordance with the schedule and modalities set out in the Data Sheet (see
Point 4.2).
They will be made in euro to the bank account indicated by the coordinator (see Data Sheet, Point 4.2)
and must be distributed without unjustified delay (restrictions may apply to distribution of the initial
prefinancing payment; see Data Sheet, Point 4.2).
Payments to this bank account will discharge the granting authority from its payment obligation.
The cost of payment transfers will be borne as follows:
- the granting authority bears the cost of transfers charged by its bank
- the beneficiary bears the cost of transfers charged by its bank
- the party causing a repetition of a transfer bears all costs of the repeated transfer.
Payments by the granting authority will be considered to have been carried out on the date when they
are debited to its account.
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22.2 Recoveries
Recoveries will be made, if — at beneficiary termination, final payment or afterwards — it turns out
that the granting authority has paid too much and needs to recover the amounts undue.
The general liability regime for recoveries (first-line liability) is as follows: At final payment, the
coordinator will be fully liable for recoveries, even if it has not been the final recipient of the undue
amounts. At beneficiary termination or after final payment, recoveries will be made directly against
the beneficiaries concerned.
Beneficiaries will be fully liable for repaying the debts of their affiliated entities.
In case of enforced recoveries (see Article 22.4):
- the beneficiaries will be jointly and severally liable for repaying debts of another beneficiary
under the Agreement (including late-payment interest), if required by the granting authority
(see Data Sheet, Point 4.4)
- affiliated entities will be held liable for repaying debts of their beneficiaries under the
Agreement (including late-payment interest), if required by the granting authority (see
Data Sheet, Point 4.4).
22.3 Amounts due
22.3.1 Prefinancing payments
The aim of the prefinancing is to provide the beneficiaries with a float.
It remains the property of the EU until the final payment.
For initial prefinancings (if any), the amount due, schedule and modalities are set out in the
Data Sheet (see Point 4.2).
For additional prefinancings (if any), the amount due, schedule and modalities are also set out in
the Data Sheet (see Point 4.2). However, if the statement on the use of the previous prefinancing
payment shows that less than 70% was used, the amount set out in the Data Sheet will be reduced by
the difference between the 70% threshold and the amount used.
Prefinancing payments (or parts of them) may be offset (without the beneficiaries’ consent) against
amounts owed by a beneficiary to the granting authority — up to the amount due to that beneficiary.
For grants where the granting authority is the European Commission or an EU executive agency,
offsetting may also be done against amounts owed to other Commission services or executive
agencies.
Payments will not be made if the payment deadline or payments are suspended (see Articles 29 and
30).
22.3.2 Amount due at beneficiary termination — Recovery
In case of beneficiary termination, the granting authority will determine the provisional amount due
for the beneficiary concerned.
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This will be done on the basis of work packages already completed in previous interim payments.
Payments for ongoing/not yet completed work packages which the beneficiary was working on before
termination (if any) will therefore be made only later on, with the next interim or final payments when
those work packages have been completed.
The amount due will be calculated in the following step:
Step 1 — Calculation of the total accepted EU contribution
Step 1 — Calculation of the total accepted EU contribution
The granting authority will first calculate the ‘accepted EU contribution’ for the beneficiary, on the
basis of the beneficiary’s lump sum contributions for the work packages which were approved in
previous interim payments.
After that, the granting authority will take into account grant reductions (if any). The resulting amount
is the ‘total accepted EU contribution’ for the beneficiary.
The balance is then calculated by deducting the payments received (if any; see report on the
distribution of payments in Article 32), from the total accepted EU contribution:
{total accepted EU contribution for the beneficiary
minus
{prefinancing and interim payments received (if any)}}.
If the balance is negative, it will be recovered in accordance with the following procedure:
The granting authority will send a pre-information letter to the beneficiary concerned:
- formally notifying the intention to recover, the amount due, the amount to be recovered and
the reasons why and
- requesting observations within 30 days of receiving notification.
If no observations are submitted (or the granting authority decides to pursue recovery despite the
observations it has received), it will confirm the amount to be recovered and ask this amount to be
paid to the coordinator (confirmation letter).
22.3.3 Interim payments
Interim payments reimburse the eligible lump sum contributions claimed for work packages
implemented during the reporting periods (if any).
Interim payments (if any) will be made in accordance with the schedule and modalities set out the
Data Sheet (see Point 4.2).
Payment is subject to the approval of the periodic report and the work packages declared. Their
approval does not imply recognition of compliance, authenticity, completeness or correctness of their
content.
Incomplete work packages and work packages that have not been delivered or cannot be approved
will be rejected (see Article 27).
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The interim payment will be calculated by the granting authority in the following steps:
Step 1 — Calculation of the total accepted EU contribution
Step 2 — Limit to the interim payment ceiling
Step 1 — Calculation of the total accepted EU contribution
The granting authority will first calculate the ‘accepted EU contribution’ for the action for the
reporting period, by calculating the lump sum contributions for the approved work packages.
After that, the granting authority will take into account grant reductions from beneficiary termination
(if any). The resulting amount is the ‘total accepted EU contribution’.
Step 2 — Limit to the interim payment ceiling
The resulting amount is then capped to ensure that the total amount of prefinancing and interim
payments (if any) does not exceed the interim payment ceiling set out in the Data Sheet (see Point 4.2).
Interim payments (or parts of them) may be offset (without the beneficiaries’ consent) against amounts
owed by a beneficiary to the granting authority — up to the amount due to that beneficiary.
For grants where the granting authority is the European Commission or an EU executive agency,
offsetting may also be done against amounts owed to other Commission services or executive
agencies.
Payments will not be made if the payment deadline or payments are suspended (see Articles 29 and
30).
22.3.4 Final payment — Final grant amount — Revenues and Profit — Recovery
The final payment (payment of the balance) reimburses the remaining eligible lump sum contributions
claimed for the implemented work packages (if any).
The final payment will be made in accordance with the schedule and modalities set out in the
Data Sheet (see Point 4.2).
Payment is subject to the approval of the final periodic report and the work packages declared. Their
approval does not imply recognition of compliance, authenticity, completeness or correctness of their
content.
Work packages (or parts of them) that have not been delivered or cannot be approved will be rejected
(see Article 27).
The final grant amount for the action will be calculated in the following steps:
Step 1 — Calculation of the total accepted EU contribution
Step 2 — Limit to the maximum grant amount
Step 3 — Reduction due to the no-profit rule
Step 1 — Calculation of the total accepted EU contribution
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The granting authority will first calculate the ‘accepted EU contribution’ for the action for all reporting
periods, by calculating the lump sum contributions for the approved work packages.
After that, the granting authority will take into account grant reductions (if any). The resulting amount
is the ‘total accepted EU contribution’.
Step 2 — Limit to the maximum grant amount
Not applicable
Step 3 — Reduction due to the no-profit rule
Not applicable
The balance (final payment) is then calculated by deducting the total amount of prefinancing and
interim payments already made (if any), from the final grant amount:
{final grant amount
minus
{prefinancing and interim payments made (if any)}}.
If the balance is positive, it will be paid to the coordinator.
The final payment (or part of it) may be offset (without the beneficiaries’ consent) against amounts
owed by a beneficiary to the granting authority — up to the amount due to that beneficiary.
For grants where the granting authority is the European Commission or an EU executive agency,
offsetting may also be done against amounts owed to other Commission services or executive
agencies.
Payments will not be made if the payment deadline or payments are suspended (see Articles 29 and
30).
If the balance is negative, it will be recovered in accordance with the following procedure:
The granting authority will send a pre-information letter to the coordinator:
- formally notifying the intention to recover, the final grant amount, the amount to be recovered
and the reasons why
- requesting observations within 30 days of receiving notification.
If no observations are submitted (or the granting authority decides to pursue recovery despite the
observations it has received), it will confirm the amount to be recovered (confirmation letter),
together with a debit note with the terms and date for payment.
If payment is not made by the date specified in the debit note, the granting authority will enforce
recovery in accordance with Article 22.4.
22.3.5 Audit implementation after final payment — Revised final grant amount — Recovery
If — after the final payment (in particular, after checks, reviews, audits or investigations; see
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Article 25) — the granting authority rejects lump sum contributions (see Article 27) or reduces the
grant (see Article 28), it will calculate the revised final grant amount for the beneficiary concerned.
The beneficiary revised final grant amount will be calculated in the following step:
Step 1 — Calculation of the revised total accepted EU contribution
Step 1 — Calculation of the revised total accepted EU contribution
The granting authority will first calculate the ‘revised accepted EU contribution’ for the beneficiary,
by calculating the ‘revised accepted contributions’.
After that, it will take into account grant reductions (if any). The resulting ‘revised total accepted EU
contribution’ is the beneficiary revised final grant amount.
If the revised final grant amount is lower than the beneficiary’s final grant amount (i.e. its share in the
final grant amount for the action), it will be recovered in accordance with the following procedure:
The beneficiary final grant amount (i.e. share in the final grant amount for the action) is calculated
as follows:
{{total accepted EU contribution for the beneficiary
divided by
total accepted EU contribution for the action}
multiplied by
final grant amount for the action}.
The granting authority will send a pre-information letter to the beneficiary concerned:
- formally notifying the intention to recover, the amount to be recovered and the reasons why and
- requesting observations within 30 days of receiving notification.
If no observations are submitted (or the granting authority decides to pursue recovery despite the
observations it has received), it will confirm the amount to be recovered (confirmation letter),
together with a debit note with the terms and the date for payment.
Recoveries against affiliated entities (if any) will be handled through their beneficiaries.
If payment is not made by the date specified in the debit note, the granting authority will enforce
recovery in accordance with Article 22.4.
22.4 Enforced recovery
If payment is not made by the date specified in the debit note, the amount due will be recovered:
(a) by offsetting the amount — without the coordinator or beneficiary’s consent — against any
amounts owed to the coordinator or beneficiary by the granting authority.
In exceptional circumstances, to safeguard the EU financial interests, the amount may be offset
before the payment date specified in the debit note.
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For grants where the granting authority is the European Commission or an EU executive
agency, debts may also be offset against amounts owed by other Commission services or
executive agencies.
(b) by drawing on the financial guarantee(s) (if any)
(c) by holding other beneficiaries jointly and severally liable (if any; see Data Sheet, Point 4.4)
(d) by holding affiliated entities jointly and severally liable (if any, see Data Sheet, Point 4.4)
(e) by taking legal action (see Article 43) or, provided that the granting authority is the European
Commission or an EU executive agency, by adopting an enforceable decision under Article 299
of the Treaty on the Functioning of the EU (TFEU) and Article 100(2) of EU Financial
Regulation 2018/1046.
The amount to be recovered will be increased by late-payment interest at the rate set out in
Article 23.5, from the day following the payment date in the debit note, up to and including the date
the full payment is received.
Partial payments will be first credited against expenses, charges and late-payment interest and then
against the principal.
Bank charges incurred in the recovery process will be borne by the beneficiary, unless
Directive 2015/236615 applies.
For grants where the granting authority is an EU executive agency, enforced recovery by offsetting or
enforceable decision will be done by the services of the European Commission (see also Article 43).
22.5 Consequences of non-compliance
22.5.1 If the granting authority does not pay within the payment deadlines (see above), the
beneficiaries are entitled to late-payment interest at the reference rate applied by the European
Central Bank (ECB) for its main refinancing operations in euros, plus the percentage specified in the
Data Sheet (Point 4.2). The ECB reference rate to be used is the rate in force on the first day of the
month in which the payment deadline expires, as published in the C series of the Official Journal of
the European Union.
If the late-payment interest is lower than or equal to EUR 200, it will be paid to the coordinator only
on request submitted within two months of receiving the late payment.
Late-payment interest is not due if all beneficiaries are EU Member States (including regional and
local government authorities or other public bodies acting on behalf of a Member State for the purpose
of this Agreement).
If payments or the payment deadline are suspended (see Articles 29 and 30), payment will not be
considered as late.
15 Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment
services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU)
No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, p. 35).
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Late-payment interest covers the period running from the day following the due date for payment (see
above), up to and including the date of payment.
Late-payment interest is not considered for the purposes of calculating the final grant amount.
22.5.2 If the coordinator breaches any of its obligations under this Article, the grant may be reduced
(see Article 28) and the grant or the coordinator may be terminated (see Article 32).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 23 — GUARANTEES
23.1 Prefinancing guarantee
If required by the granting authority (see Data Sheet, Point 4.2), the beneficiaries must provide (one
or more) prefinancing guarantee(s) in accordance with the timing and the amounts set out in the
Data Sheet.
The coordinator must submit them to the granting authority in due time before the prefinancing they
are linked to.
The guarantees must be drawn up using the template published on the Portal and fulfil the following
conditions:
(a) be provided by a bank or approved financial institution established in the EU or — if requested
by the coordinator and accepted by the granting authority — by a third party or a bank or
financial institution established outside the EU offering equivalent security
(b) the guarantor stands as first-call guarantor and does not require the granting authority to first
have recourse against the principal debtor (i.e. the beneficiary concerned) and
(c) remain explicitly in force until the final payment and, if the final payment takes the form of a
recovery, until five months after the debit note is notified to a beneficiary.
They will be released within the following month.
23.2 Consequences of non-compliance
If the beneficiaries breach their obligation to provide the prefinancing guarantee, the prefinancing
will not be paid.
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 24 — CERTIFICATES
Not applicable
ARTICLE 25 — CHECKS, REVIEWS, AUDITS AND INVESTIGATIONS — EXTENSION
OF FINDINGS
25.1 Granting authority checks, reviews and audits
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25.1.1 Internal checks
The granting authority may — during the action or afterwards — check the proper implementation of
the action and compliance with the obligations under the Agreement, including assessing lump sum
contributions, deliverables and reports.
25.1.2 Project reviews
The granting authority may carry out reviews on the proper implementation of the action and
compliance with the obligations under the Agreement (general project reviews or specific issues
reviews).
Such project reviews may be started during the implementation of the action and until the time-limit
set out in the Data Sheet (see Point 6). They will be formally notified to the coordinator or beneficiary
concerned and will be considered to start on the date of the notification.
If needed, the granting authority may be assisted by independent, outside experts. If it uses outside
experts, the coordinator or beneficiary concerned will be informed and have the right to object on
grounds of commercial confidentiality or conflict of interest.
The coordinator or beneficiary concerned must cooperate diligently and provide — within the deadline
requested — any information and data in addition to deliverables and reports already submitted.
The granting authority may request beneficiaries to provide such information to it directly. Sensitive
information and documents will be treated in accordance with Article 13.
The coordinator or beneficiary concerned may be requested to participate in meetings, including with
the outside experts.
For on-the-spot visits, the beneficiary concerned must allow access to sites and premises (including
to the outside experts) and must ensure that information requested is readily available.
Information provided must be accurate, precise and complete and in the format requested, including
electronic format.
On the basis of the review findings, a project review report will be drawn up.
The granting authority will formally notify the project review report to the coordinator or beneficiary
concerned, which has 30 days from receiving notification to make observations.
Project reviews (including project review reports) will be in the language of the Agreement, unless
otherwise agreed with the granting authority (see Data Sheet, Point 4.2).
25.1.3 Audits
The granting authority may carry out audits on the proper implementation of the action and compliance
with the obligations under the Agreement.
Such audits may be started during the implementation of the action and until the time-limit set out in
the Data Sheet (see Point 6). They will be formally notified to the beneficiary concerned and will be
considered to start on the date of the notification.
The granting authority may use its own audit service, delegate audits to a centralised service or use
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external audit firms. If it uses an external firm, the beneficiary concerned will be informed and have
the right to object on grounds of commercial confidentiality or conflict of interest.
The beneficiary concerned must cooperate diligently and provide — within the deadline requested —
any information (including complete accounts, individual salary statements or other personal data)
to verify compliance with the Agreement. Sensitive information and documents will be treated in
accordance with Article 13.
For on-the-spot visits, the beneficiary concerned must allow access to sites and premises (including
for the external audit firm) and must ensure that information requested is readily available.
Information provided must be accurate, precise and complete and in the format requested, including
electronic format.
On the basis of the audit findings, a draft audit report will be drawn up.
The auditors will formally notify the draft audit report to the beneficiary concerned, which has 30 days
from receiving notification to make observations (contradictory audit procedure).
The final audit report will take into account observations by the beneficiary concerned and will be
formally notified to them.
Audits (including audit reports) will be in the language of the Agreement, unless otherwise agreed
with the granting authority (see Data Sheet, Point 4.2).
25.2 European Commission checks, reviews and audits in grants of other granting
authorities
Where the granting authority is not the European Commission, the latter has the same rights of checks,
reviews and audits as the granting authority.
25.3 Access to records for assessing simplified forms of funding
The beneficiaries must give the European Commission access to their statutory records for the periodic
assessment of simplified forms of funding which are used in EU programmes.
25.4 OLAF, EPPO and ECA audits and investigations
The following bodies may also carry out checks, reviews, audits and investigations — during the
action or afterwards:
- the European Anti-Fraud Office (OLAF) under Regulations No 883/201316 and No 2185/9617
- the European Public Prosecutor’s Office (EPPO) under Regulation 2017/1939
16 Regulation (EU, Euratom) No 883/2013 of the European Parliament and of the Council of 11 September 2013
concerning investigations conducted by the European Anti-Fraud Office (OLAF) and repealing Regulation (EC)
No 1073/1999 of the European Parliament and of the Council and Council Regulation (Euratom) No 1074/1999 (OJ
L 248, 18/09/2013, p. 1).
17 Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996 concerning on-the-spot checks and inspections
carried out by the Commission in order to protect the European Communities' financial interests against fraud and other
irregularities (OJ L 292, 15/11/1996, p. 2).
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- the European Court of Auditors (ECA) under Article 287 of the Treaty on the Functioning of
the EU (TFEU) and Article 257 of EU Financial Regulation 2018/1046.
If requested by these bodies, the beneficiary concerned must provide full, accurate and complete
information in the format requested (including complete accounts, individual salary statements or
other personal data, including in electronic format) and allow access to sites and premises for
on-the-spot visits or inspections — as provided for under these Regulations.
To this end, the beneficiary concerned must keep all relevant information relating to the action, at
least until the time-limit set out in the Data Sheet (Point 6) and, in any case, until any ongoing checks,
reviews, audits, investigations, litigation or other pursuits of claims have been concluded.
25.5 Consequences of checks, reviews, audits and investigations — Extension of findings
25.5.1 Consequences of checks, reviews, audits and investigations in this grant
Findings in checks, reviews, audits or investigations carried out in the context of this grant may lead to
rejections (see Article 27), grant reduction (see Article 28) or other measures described in Chapter 5.
Rejections or grant reductions after the final payment will lead to a revised final grant amount (see
Article 22).
Findings in checks, reviews, audits or investigations during the action implementation may lead to a
request for amendment (see Article 39), to change the description of the action set out in Annex 1.
Checks, reviews, audits or investigations that find systemic or recurrent errors, irregularities, fraud
or breach of obligations in any EU grant may also lead to consequences in other EU grants awarded
under similar conditions (‘extension to other grants’).
Moreover, findings arising from an OLAF or EPPO investigation may lead to criminal prosecution
under national law.
25.5.2 Extension from other grants
Findings of checks, reviews, audits or investigations in other grants may be extended to this grant, if:
(a) the beneficiary concerned is found, in other EU grants awarded under similar conditions, to
have committed systemic or recurrent errors, irregularities, fraud or breach of obligations that
have a material impact on this grant and
(b) those findings are formally notified to the beneficiary concerned — together with the list of
grants affected by the findings — within the time-limit for audits set out in the Data Sheet (see
Point 6).
The granting authority will formally notify the beneficiary concerned of the intention to extend the
findings and the list of grants affected.
If the extension concerns rejections of lump sum contributions: the notification will include:
(a) an invitation to submit observations on the list of grants affected by the findings
(b) the request to submit revised financial statements for all grants affected
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(c) the correction rate for extrapolation, established on the basis of the systemic or recurrent errors,
to calculate the amounts to be rejected, if the beneficiary concerned:
(i) considers that the submission of revised financial statements is not possible or practicable
or
(ii) does not submit revised financial statements.
If the extension concerns grant reductions: the notification will include:
(a) an invitation to submit observations on the list of grants affected by the findings and
(b) the correction rate for extrapolation, established on the basis of the systemic or recurrent
errors and the principle of proportionality.
The beneficiary concerned has 60 days from receiving notification to submit observations, revised
financial statements or to propose a duly substantiated alternative correction method/rate.
On the basis of this, the granting authority will analyse the impact and decide on the implementation
(i.e. start rejection or grant reduction procedures, either on the basis of the revised financial statements
or the announced/alternative method/rate or a mix of those; see Articles 27 and 28).
25.6 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, lump sum contributions insufficiently
substantiated will be ineligible (see Article 6) and will be rejected (see Article 27), and the grant may
be reduced (see Article 28).
Such breaches may also lead to other measures described in Chapter 5.
ARTICLE 26 — IMPACT EVALUATIONS
26.1 Impact evaluation
The granting authority may carry out impact evaluations of the action, measured against the objectives
and indicators of the EU programme funding the grant.
Such evaluations may be started during implementation of the action and until the time-limit set out
in the Data Sheet (see Point 6). They will be formally notified to the coordinator or beneficiaries and
will be considered to start on the date of the notification.
If needed, the granting authority may be assisted by independent outside experts.
The coordinator or beneficiaries must provide any information relevant to evaluate the impact of the
action, including information in electronic format.
26.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the granting authority may apply
the measures described in Chapter 5.
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CHAPTER 5 CONSEQUENCES OF NON-COMPLIANCE
SECTION 1 REJECTIONS AND GRANT REDUCTION
ARTICLE 27 — REJECTION OF CONTRIBUTIONS
27.1 Conditions
The granting authority will — at interim payment, final payment or afterwards — reject any lump sum
contributions which are ineligible (see Article 6), in particular following checks, reviews, audits or
investigations (see Article 25).
The rejection may also be based on the extension of findings from other grants to this grant (see
Article 25).
Ineligible lump sum contributions will be rejected.
27.2 Procedure
If the rejection does not lead to a recovery, the granting authority will formally notify the coordinator
or beneficiary concerned of the rejection, the amounts and the reasons why. The coordinator or
beneficiary concerned may — within 30 days of receiving notification — submit observations if it
disagrees with the rejection (payment review procedure).
If the rejection leads to a recovery, the granting authority will follow the contradictory procedure with
pre-information letter set out in Article 22.
27.3 Effects
If the granting authority rejects lump sum contributions, it will deduct them from the lump sum
contributions declared and then calculate the amount due (and, if needed, make a recovery; see
Article 22).
ARTICLE 28 — GRANT REDUCTION
28.1 Conditions
The granting authority may — at beneficiary termination, final payment or afterwards — reduce the
grant for a beneficiary, if:
(a) the beneficiary (or a person having powers of representation, decision-making or control, or
person essential for the award/implementation of the grant) has committed:
(i) substantial errors, irregularities or fraud or
(ii) serious breach of obligations under this Agreement or during its award (including
improper implementation of the action, non-compliance with the call conditions,
submission of false information, failure to provide required information, breach of ethics
or security rules (if applicable), etc.), or
(b) the beneficiary (or a person having powers of representation, decision-making or control, or
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person essential for the award/implementation of the grant) has committed — in other EU grants
awarded to it under similar conditions — systemic or recurrent errors, irregularities, fraud or
serious breach of obligations that have a material impact on this grant (extension of findings;
see Article 25.5).
The amount of the reduction will be calculated for each beneficiary concerned and proportionate to the
seriousness and the duration of the errors, irregularities or fraud or breach of obligations, by applying
an individual reduction rate to their accepted EU contribution.
28.2 Procedure
If the grant reduction does not lead to a recovery, the granting authority will formally notify the
coordinator or beneficiary concerned of the reduction, the amount to be reduced and the reasons why.
The coordinator or beneficiary concerned may — within 30 days of receiving notification — submit
observations if it disagrees with the reduction (payment review procedure).
If the grant reduction leads to a recovery, the granting authority will follow the contradictory procedure
with pre-information letter set out in Article 22.
28.3 Effects
If the granting authority reduces the grant, it will deduct the reduction and then calculate the amount
due (and, if needed, make a recovery; see Article 22).
SECTION 2 SUSPENSION AND TERMINATION
ARTICLE 29 — PAYMENT DEADLINE SUSPENSION
29.1 Conditions
The granting authority may — at any moment — suspend the payment deadline if a payment cannot
be processed because:
(a) the required report (see Article 21) has not been submitted or is not complete or additional
information is needed
(b) there are doubts about the amount to be paid (e.g. ongoing extension procedure, queries
about eligibility, need for a grant reduction, etc.) and additional checks, reviews, audits or
investigations are necessary, or
(c) there are other issues affecting the EU financial interests.
29.2 Procedure
The granting authority will formally notify the coordinator of the suspension and the reasons why.
The suspension will take effect the day the notification is sent.
If the conditions for suspending the payment deadline are no longer met, the suspension will be lifted
— and the remaining time to pay (see Data Sheet, Point 4.2) will resume.
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If the suspension exceeds two months, the coordinator may request the granting authority to confirm
if the suspension will continue.
If the payment deadline has been suspended due to the non-compliance of the report and the revised
report is not submitted (or was submitted but is also rejected), the granting authority may also terminate
the grant or the participation of the coordinator (see Article 32).
ARTICLE 30 — PAYMENT SUSPENSION
30.1 Conditions
The granting authority may — at any moment — suspend payments, in whole or in part for one or
more beneficiaries, if:
(a) a beneficiary (or a person having powers of representation, decision-making or control, or
person essential for the award/implementation of the grant) has committed or is suspected of
having committed:
(i) substantial errors, irregularities or fraud or
(ii) serious breach of obligations under this Agreement or during its award (including
improper implementation of the action, non-compliance with the call conditions,
submission of false information, failure to provide required information, breach of ethics
or security rules (if applicable), etc.), or
(b) a beneficiary (or a person having powers of representation, decision-making or control, or
person essential for the award/implementation of the grant) has committed — in other EU grants
awarded to it under similar conditions — systemic or recurrent errors, irregularities, fraud or
serious breach of obligations that have a material impact on this grant (extension of findings;
see Article 25.5).
If payments are suspended for one or more beneficiaries, the granting authority will make partial
payment(s) for the part(s) not suspended. If suspension concerns the final payment, the payment (or
recovery) of the remaining amount after suspension is lifted will be considered to be the payment that
closes the action.
30.2 Procedure
Before suspending payments, the granting authority will send a pre-information letter to the
beneficiary concerned:
- formally notifying the intention to suspend payments and the reasons why and
- requesting observations within 30 days of receiving notification.
If the granting authority does not receive observations or decides to pursue the procedure despite the
observations it has received, it will confirm the suspension (confirmation letter). Otherwise, it will
formally notify that the procedure is discontinued.
At the end of the suspension procedure, the granting authority will also inform the coordinator.
The suspension will take effect the day after the confirmation notification is sent.
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If the conditions for resuming payments are met, the suspension will be lifted. The granting authority
will formally notify the beneficiary concerned (and the coordinator) and set the suspension end date.
During the suspension, no prefinancing will be paid to the beneficiaries concerned. For interim
payments, the periodic reports for all reporting periods except the last one (see Article 21) must
not contain any financial statements from the beneficiary concerned (or its affiliated entities). The
coordinator must include them in the next periodic report after the suspension is lifted or — if
suspension is not lifted before the end of the action — in the last periodic report.
ARTICLE 31 — GRANT AGREEMENT SUSPENSION
31.1 Consortium-requested GA suspension
31.1.1 Conditions and procedure
The beneficiaries may request the suspension of the grant or any part of it, if exceptional circumstances
— in particular force majeure (see Article 35) — make implementation impossible or excessively
difficult.
The coordinator must submit a request for amendment (see Article 39), with:
- the reasons why
- the date the suspension takes effect; this date may be before the date of the submission of the
amendment request and
- the expected date of resumption.
The suspension will take effect on the day specified in the amendment.
Once circumstances allow for implementation to resume, the coordinator must immediately request
another amendment of the Agreement to set the suspension end date, the resumption date (one day
after suspension end date), extend the duration and make other changes necessary to adapt the action
to the new situation (see Article 39) — unless the grant has been terminated (see Article 32). The
suspension will be lifted with effect from the suspension end date set out in the amendment. This date
may be before the date of the submission of the amendment request.
During the suspension, no prefinancing will be paid. Moreover, no work may be done. Ongoing work
packages must be interrupted and no new work packages may be started.
31.2 EU-initiated GA suspension
31.2.1 Conditions
The granting authority may suspend the grant or any part of it, if:
(a) a beneficiary (or a person having powers of representation, decision-making or control, or
person essential for the award/implementation of the grant) has committed or is suspected of
having committed:
(i) substantial errors, irregularities or fraud or
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(ii) serious breach of obligations under this Agreement or during its award (including
improper implementation of the action, non-compliance with the call conditions,
submission of false information, failure to provide required information, breach of ethics
or security rules (if applicable), etc.), or
(b) a beneficiary (or a person having powers of representation, decision-making or control, or
person essential for the award/implementation of the grant) has committed — in other EU grants
awarded to it under similar conditions — systemic or recurrent errors, irregularities, fraud or
serious breach of obligations that have a material impact on this grant (extension of findings;
see Article 25.5)
(c) other:
(i) linked action issues: not applicable
(ii) additional GA suspension grounds: not applicable.
31.2.2 Procedure
Before suspending the grant, the granting authority will send a pre-information letter to the
coordinator:
- formally notifying the intention to suspend the grant and the reasons why and
- requesting observations within 30 days of receiving notification.
If the granting authority does not receive observations or decides to pursue the procedure despite the
observations it has received, it will confirm the suspension (confirmation letter). Otherwise, it will
formally notify that the procedure is discontinued.
The suspension will take effect the day after the confirmation notification is sent (or on a later date
specified in the notification).
Once the conditions for resuming implementation of the action are met, the granting authority will
formally notify the coordinator a lifting of suspension letter, in which it will set the suspension
end date and invite the coordinator to request an amendment of the Agreement to set the resumption
date (one day after suspension end date), extend the duration and make other changes necessary to
adapt the action to the new situation (see Article 39) — unless the grant has been terminated (see
Article 32). The suspension will be lifted with effect from the suspension end date set out in the lifting
of suspension letter. This date may be before the date on which the letter is sent.
During the suspension, no prefinancing will be paid. Moreover, no work may be done. Ongoing work
packages must be interrupted and no new work packages may be started.
The beneficiaries may not claim damages due to suspension by the granting authority (see Article 33).
Grant suspension does not affect the granting authority’s right to terminate the grant or a beneficiary
(see Article 32) or reduce the grant (see Article 28).
ARTICLE 32 — GRANT AGREEMENT OR BENEFICIARY TERMINATION
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32.1 Consortium-requested GA termination
32.1.1 Conditions and procedure
The beneficiaries may request the termination of the grant.
The coordinator must submit a request for amendment (see Article 39), with:
- the reasons why
- the date the consortium ends work on the action (‘end of work date’) and
- the date the termination takes effect (‘termination date’); this date must be after the date of the
submission of the amendment request.
The termination will take effect on the termination date specified in the amendment.
If no reasons are given or if the granting authority considers the reasons do not justify termination,
it may consider the grant terminated improperly.
32.1.2 Effects
The coordinator must — within 60 days from when termination takes effect — submit a periodic
report (for the open reporting period until termination).
The granting authority will calculate the final grant amount and final payment on the basis of the
report submitted and taking into account the lump sum contributions for activities implemented before
the end of work date (see Article 22). Partial lump sum contributions for work packages that were not
completed (e.g. due to technical reasons) may exceptionally be taken into account.
If the granting authority does not receive the report within the deadline, only lump sum contributions
which are included in an approved periodic report will be taken into account (no contributions if no
periodic report was ever approved).
Improper termination may lead to a grant reduction (see Article 28).
After termination, the beneficiaries’ obligations (in particular Articles 13 (confidentiality and
security), 16 (IPR), 17 (communication, dissemination and visibility), 21 (reporting), 25 (checks,
reviews, audits and investigations), 26 (impact evaluation), 27 (rejections), 28 (grant reduction) and
42 (assignment of claims)) continue to apply.
32.2 Consortium-requested beneficiary termination
32.2.1 Conditions and procedure
The coordinator may request the termination of the participation of one or more beneficiaries, on
request of the beneficiary concerned or on behalf of the other beneficiaries.
The coordinator must submit a request for amendment (see Article 39), with:
- the reasons why
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- the opinion of the beneficiary concerned (or proof that this opinion has been requested in
writing)
- the date the beneficiary ends work on the action (‘end of work date’)
- the date the termination takes effect (‘termination date’); this date must be after the date of the
submission of the amendment request.
If the termination concerns the coordinator and is done without its agreement, the amendment request
must be submitted by another beneficiary (acting on behalf of the consortium).
The termination will take effect on the termination date specified in the amendment.
If no information is given or if the granting authority considers that the reasons do not justify
termination, it may consider the beneficiary to have been terminated improperly.
32.2.2 Effects
The coordinator must — within 60 days from when termination takes effect — submit:
(i) a report on the distribution of payments to the beneficiary concerned
(ii) a termination report from the beneficiary concerned, for the open reporting period until
termination, containing an overview of the progress of the work
(iii) a second request for amendment (see Article 39) with other amendments needed (e.g.
reallocation of the tasks and the estimated budget of the terminated beneficiary; addition of
a new beneficiary to replace the terminated beneficiary; change of coordinator, etc.).
The granting authority will calculate the amount due to the beneficiary on the basis of the reports
submitted in previous interim payments (i.e. beneficiary’s lump sum contributions for completed and
approved work packages).
Lump sum contributions for ongoing/not yet completed work packages will have to be included in the
periodic report for the next reporting periods when those work packages have been completed.
If the granting authority does not receive the report on the distribution of payments within the deadline,
it will consider that:
- the coordinator did not distribute any payment to the beneficiary concerned and that
- the beneficiary concerned must not repay any amount to the coordinator.
If the second request for amendment is accepted by the granting authority, the Agreement is amended
to introduce the necessary changes (see Article 39).
If the second request for amendment is rejected by the granting authority (because it calls into question
the decision awarding the grant or breaches the principle of equal treatment of applicants), the grant
may be terminated (see Article 32).
Improper termination may lead to a reduction of the grant (see Article 31) or grant termination (see
Article 32).
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After termination, the concerned beneficiary’s obligations (in particular Articles 13 (confidentiality
and security), 16 (IPR), 17 (communication, dissemination and visibility), 21 (reporting), 25 (checks,
reviews, audits and investigations), 26 (impact evaluation), 27 (rejections), 28 (grant reduction) and
42 (assignment of claims)) continue to apply.
32.3 EU-initiated GA or beneficiary termination
32.3.1 Conditions
The granting authority may terminate the grant or the participation of one or more beneficiaries, if:
(a) one or more beneficiaries do not accede to the Agreement (see Article 40)
(b) a change to the action or the legal, financial, technical, organisational or ownership situation
of a beneficiary is likely to substantially affect the implementation of the action or calls into
question the decision to award the grant (including changes linked to one of the exclusion
grounds listed in the declaration of honour)
(c) following termination of one or more beneficiaries, the necessary changes to the Agreement
(and their impact on the action) would call into question the decision awarding the grant or
breach the principle of equal treatment of applicants
(d) implementation of the action has become impossible or the changes necessary for its
continuation would call into question the decision awarding the grant or breach the principle
of equal treatment of applicants
(e) a beneficiary (or person with unlimited liability for its debts) is subject to bankruptcy
proceedings or similar (including insolvency, winding-up, administration by a liquidator or
court, arrangement with creditors, suspension of business activities, etc.)
(f) a beneficiary (or person with unlimited liability for its debts) is in breach of social security
or tax obligations
(g) a beneficiary (or person having powers of representation, decision-making or control, or person
essential for the award/implementation of the grant) has been found guilty of grave professional
misconduct
(h) a beneficiary (or person having powers of representation, decision-making or control, or person
essential for the award/implementation of the grant) has committed fraud, corruption, or is
involved in a criminal organisation, money laundering, terrorism-related crimes (including
terrorism financing), child labour or human trafficking
(i) a beneficiary (or person having powers of representation, decision-making or control, or person
essential for the award/implementation of the grant) was created under a different jurisdiction
with the intent to circumvent fiscal, social or other legal obligations in the country of origin
(or created another entity with this purpose)
(j) a beneficiary (or person having powers of representation, decision-making or control, or person
essential for the award/implementation of the grant) has committed:
(i) substantial errors, irregularities or fraud or
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(ii) serious breach of obligations under this Agreement or during its award (including
improper implementation of the action, non-compliance with the call conditions,
submission of false information, failure to provide required information, breach of ethics
or security rules (if applicable), etc.)
(k) a beneficiary (or person having powers of representation, decision-making or control, or person
essential for the award/implementation of the grant) has committed — in other EU grants
awarded to it under similar conditions — systemic or recurrent errors, irregularities, fraud or
serious breach of obligations that have a material impact on this grant (extension of findings;
see Article 25.5)
(l) despite a specific request by the granting authority, a beneficiary does not request — through
the coordinator — an amendment to the Agreement to end the participation of one of its
affiliated entities or associated partners that is in one of the situations under points (d), (f), (e),
(g), (h), (i) or (j) and to reallocate its tasks, or
(m) other:
(i) linked action issues: not applicable
(ii) additional GA termination grounds: not applicable.
32.3.2 Procedure
Before terminating the grant or participation of one or more beneficiaries, the granting authority will
send a pre-information letter to the coordinator or beneficiary concerned:
- formally notifying the intention to terminate and the reasons why and
- requesting observations within 30 days of receiving notification.
If the granting authority does not receive observations or decides to pursue the procedure despite
the observations it has received, it will confirm the termination and the date it will take effect
(confirmation letter). Otherwise, it will formally notify that the procedure is discontinued.
For beneficiary terminations, the granting authority will — at the end of the procedure — also inform
the coordinator.
The termination will take effect the day after the confirmation notification is sent (or on a later date
specified in the notification; ‘termination date’).
32.3.3 Effects
(a) for GA termination:
The coordinator must — within 60 days from when termination takes effect — submit a
periodic report (for the last open reporting period until termination).
The granting authority will calculate the final grant amount and final payment on the basis
of the report submitted and taking into account the lump sum contributions for activities
implemented before termination takes effect (see Article 22). Partial lump sum contributions
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for work packages that were not completed (e.g. due to technical reasons) may exceptionally
be taken into account.
If the grant is terminated for breach of the obligation to submit reports, the coordinator may
not submit any report after termination.
If the granting authority does not receive the report within the deadline, only lump sum
contributions which are included in an approved periodic report will be taken into account (no
contributions if no periodic report was ever approved).
Termination does not affect the granting authority’s right to reduce the grant (see Article 28)
or to impose administrative sanctions (see Article 34).
The beneficiaries may not claim damages due to termination by the granting authority (see
Article 33).
After termination, the beneficiaries’ obligations (in particular Articles 13 (confidentiality
and security), 16 (IPR), 17 (communication, dissemination and visibility), 21 (reporting), 25
(checks, reviews, audits and investigations), 26 (impact evaluation), 27 (rejections), 28 (grant
reduction) and 42 (assignment of claims)) continue to apply.
(b) for beneficiary termination:
The coordinator must — within 60 days from when termination takes effect — submit:
(i) a report on the distribution of payments to the beneficiary concerned
(ii) a termination report from the beneficiary concerned, for the open reporting period
until termination, containing an overview of the progress of the work
(iii) a request for amendment (see Article 39) with any amendments needed (e.g.
reallocation of the tasks and the estimated budget of the terminated beneficiary;
addition of a new beneficiary to replace the terminated beneficiary; change of
coordinator, etc.).
The granting authority will calculate the amount due to the beneficiary on the basis of the
reports submitted in previous interim payments (i.e. beneficiary’s lump sum contributions for
completed and approved work packages).
Lump sum contributions for ongoing/not yet completed work packages will have to be included
in the periodic report for the next reporting periods when those work packages have been
completed.
If the granting authority does not receive the report on the distribution of payments within the
deadline, it will consider that:
- the coordinator did not distribute any payment to the beneficiary concerned and that
- the beneficiary concerned must not repay any amount to the coordinator.
If the request for amendment is accepted by the granting authority, the Agreement is amended
to introduce the necessary changes (see Article 39).
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If the request for amendment is rejected by the granting authority (because it calls into question
the decision awarding the grant or breaches the principle of equal treatment of applicants), the
grant may be terminated (see Article 32).
After termination, the concerned beneficiary’s obligations (in particular Articles 13
(confidentiality and security), 16 (IPR), 17 (communication, dissemination and visibility),
21 (reporting), 25 (checks, reviews, audits and investigations), 26 (impact evaluation), 27
(rejections), 28 (grant reduction) and 42 (assignment of claims)) continue to apply.
SECTION 3 OTHER CONSEQUENCES: DAMAGES AND ADMINISTRATIVE
SANCTIONS
ARTICLE 33 — DAMAGES
33.1 Liability of the granting authority
The granting authority cannot be held liable for any damage caused to the beneficiaries or to third
parties as a consequence of the implementation of the Agreement, including for gross negligence.
The granting authority cannot be held liable for any damage caused by any of the beneficiaries or
other participants involved in the action, as a consequence of the implementation of the Agreement.
33.2 Liability of the beneficiaries
The beneficiaries must compensate the granting authority for any damage it sustains as a result of the
implementation of the action or because the action was not implemented in full compliance with the
Agreement, provided that it was caused by gross negligence or wilful act.
The liability does not extend to indirect or consequential losses or similar damage (such as loss of
profit, loss of revenue or loss of contracts), provided such damage was not caused by wilful act or
by a breach of confidentiality.
ARTICLE 34 — ADMINISTRATIVE SANCTIONS AND OTHER MEASURES
Nothing in this Agreement may be construed as preventing the adoption of administrative sanctions
(i.e. exclusion from EU award procedures and/or financial penalties) or other public law measures,
in addition or as an alternative to the contractual measures provided under this Agreement (see,
for instance, Articles 135 to 145 EU Financial Regulation 2018/1046 and Articles 4 and 7 of
Regulation 2988/9518).
SECTION 4 FORCE MAJEURE
ARTICLE 35 — FORCE MAJEURE
18 Council Regulation (EC, Euratom) No 2988/95 of 18 December 1995 on the protection of the European Communities
financial interests (OJ L 312, 23.12.1995, p. 1).
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A party prevented by force majeure from fulfilling its obligations under the Agreement cannot be
considered in breach of them.
‘Force majeure’ means any situation or event that:
- prevents either party from fulfilling their obligations under the Agreement,
- was unforeseeable, exceptional situation and beyond the parties’ control,
- was not due to error or negligence on their part (or on the part of other participants involved
in the action), and
- proves to be inevitable in spite of exercising all due diligence.
Any situation constituting force majeure must be formally notified to the other party without delay,
stating the nature, likely duration and foreseeable effects.
The parties must immediately take all the necessary steps to limit any damage due to force majeure
and do their best to resume implementation of the action as soon as possible.
CHAPTER 6 FINAL PROVISIONS
ARTICLE 36 — COMMUNICATION BETWEEN THE PARTIES
36.1 Forms and means of communication — Electronic management
EU grants are managed fully electronically through the EU Funding & Tenders Portal (‘Portal’).
All communications must be made electronically through the Portal in accordance with the Portal
Terms and Conditions and using the forms and templates provided there (except if explicitly instructed
otherwise by the granting authority).
Communications must be made in writing and clearly identify the grant agreement (project number
and acronym).
Communications must be made by persons authorised according to the Portal Terms and Conditions.
For naming the authorised persons, each beneficiary must have designated — before the signature of
this Agreement — a ‘legal entity appointed representative (LEAR)’. The role and tasks of the LEAR
are stipulated in their appointment letter (see Portal Terms and Conditions).
If the electronic exchange system is temporarily unavailable, instructions will be given on the Portal.
36.2 Date of communication
The sending date for communications made through the Portal will be the date and time of sending,
as indicated by the time logs.
The receiving date for communications made through the Portal will be the date and time the
communication is accessed, as indicated by the time logs. Formal notifications that have not been
accessed within 10 days after sending, will be considered to have been accessed (see Portal Terms
and Conditions).
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If a communication is exceptionally made on paper (by e-mail or postal service), general principles
apply (i.e. date of sending/receipt). Formal notifications by registered post with proof of delivery will
be considered to have been received either on the delivery date registered by the postal service or the
deadline for collection at the post office.
If the electronic exchange system is temporarily unavailable, the sending party cannot be considered
in breach of its obligation to send a communication within a specified deadline.
36.3 Addresses for communication
The Portal can be accessed via the Europa website.
The address for paper communications to the granting authority (if exceptionally allowed) is the
official mailing address indicated on its website.
For beneficiaries, it is the legal address specified in the Portal Participant Register.
ARTICLE 37 — INTERPRETATION OF THE AGREEMENT
The provisions in the Data Sheet take precedence over the rest of the Terms and Conditions of the
Agreement.
Annex 5 takes precedence over the Terms and Conditions.
The Terms and Conditions take precedence over the Annexes other than Annex 5.
Annex 2 takes precedence over Annex 1.
ARTICLE 38 — CALCULATION OF PERIODS AND DEADLINES
In accordance with Regulation No 1182/7119, periods expressed in days, months or years are calculated
from the moment the triggering event occurs.
The day during which that event occurs is not considered as falling within the period.
‘Days’ means calendar days, not working days.
ARTICLE 39 — AMENDMENTS
39.1 Conditions
The Agreement may be amended, unless the amendment entails changes to the Agreement which
would call into question the decision awarding the grant or breach the principle of equal treatment
of applicants.
Amendments may be requested by any of the parties.
39.2 Procedure
19 Regulation (EEC, Euratom) No 1182/71 of the Council of 3 June 1971 determining the rules applicable to periods, dates
and time-limits (OJ L 124, 8/6/1971, p. 1).
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The party requesting an amendment must submit a request for amendment signed directly in the Portal
Amendment tool.
The coordinator submits and receives requests for amendment on behalf of the beneficiaries (see
Annex 3). If a change of coordinator is requested without its agreement, the submission must be done
by another beneficiary (acting on behalf of the other beneficiaries).
The request for amendment must include:
- the reasons why
- the appropriate supporting documents and
- for a change of coordinator without its agreement: the opinion of the coordinator (or proof that
this opinion has been requested in writing).
The granting authority may request additional information.
If the party receiving the request agrees, it must sign the amendment in the tool within 45 days of
receiving notification (or any additional information the granting authority has requested). If it does
not agree, it must formally notify its disagreement within the same deadline. The deadline may be
extended, if necessary for the assessment of the request. If no notification is received within the
deadline, the request is considered to have been rejected.
An amendment enters into force on the day of the signature of the receiving party.
An amendment takes effect on the date of entry into force or other date specified in the amendment.
ARTICLE 40 — ACCESSION AND ADDITION OF NEW BENEFICIARIES
40.1 Accession of the beneficiaries mentioned in the Preamble
The beneficiaries which are not coordinator must accede to the grant by signing the accession form
(see Annex 3) directly in the Portal Grant Preparation tool, within 30 days after the entry into force
of the Agreement (see Article 44).
They will assume the rights and obligations under the Agreement with effect from the date of its entry
into force (see Article 44).
If a beneficiary does not accede to the grant within the above deadline, the coordinator must — within
30 days — request an amendment (see Article 39) to terminate the beneficiary and make any changes
necessary to ensure proper implementation of the action. This does not affect the granting authority’s
right to terminate the grant (see Article 32).
40.2 Addition of new beneficiaries
In justified cases, the beneficiaries may request the addition of a new beneficiary.
For this purpose, the coordinator must submit a request for amendment in accordance with Article 39.
It must include an accession form (see Annex 3) signed by the new beneficiary directly in the Portal
Amendment tool.
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New beneficiaries will assume the rights and obligations under the Agreement with effect from the
date of their accession specified in the accession form (see Annex 3).
Additions are also possible in mono-beneficiary grants.
ARTICLE 41 — TRANSFER OF THE AGREEMENT
In justified cases, the beneficiary of a mono-beneficiary grant may request the transfer of the grant to
a new beneficiary, provided that this would not call into question the decision awarding the grant or
breach the principle of equal treatment of applicants.
The beneficiary must submit a request for amendment (see Article 39), with
- the reasons why
- the accession form (see Annex 3) signed by the new beneficiary directly in the Portal
Amendment tool and
- additional supporting documents (if required by the granting authority).
The new beneficiary will assume the rights and obligations under the Agreement with effect from the
date of accession specified in the accession form (see Annex 3).
ARTICLE 42 — ASSIGNMENTS OF CLAIMS FOR PAYMENT AGAINST THE
GRANTING AUTHORITY
The beneficiaries may not assign any of their claims for payment against the granting authority to
any third party, except if expressly approved in writing by the granting authority on the basis of a
reasoned, written request by the coordinator (on behalf of the beneficiary concerned).
If the granting authority has not accepted the assignment or if the terms of it are not observed, the
assignment will have no effect on it.
In no circumstances will an assignment release the beneficiaries from their obligations towards the
granting authority.
ARTICLE 43 — APPLICABLE LAW AND SETTLEMENT OF DISPUTES
43.1 Applicable law
The Agreement is governed by the applicable EU law, supplemented if necessary by the law of
Belgium.
Special rules may apply for beneficiaries which are international organisations (if any; see Data Sheet,
Point 5).
43.2 Dispute settlement
If a dispute concerns the interpretation, application or validity of the Agreement, the parties must bring
action before the EU General Court — or, on appeal, the EU Court of Justice — under Article 272
of the Treaty on the Functioning of the EU (TFEU).
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For non-EU beneficiaries (if any), such disputes must be brought before the courts of Brussels,
Belgium — unless an international agreement provides for the enforceability of EU court judgements.
For beneficiaries with arbitration as special dispute settlement forum (if any; see Data Sheet, Point 5),
the dispute will — in the absence of an amicable settlement — be settled in accordance with the Rules
for Arbitration published on the Portal.
If a dispute concerns administrative sanctions, offsetting or an enforceable decision under Article 299
TFEU (see Articles 22 and 34), the beneficiaries must bring action before the General Court — or, on
appeal, the Court of Justice — under Article 263 TFEU.
For grants where the granting authority is an EU executive agency (see Preamble), actions against
offsetting and enforceable decisions must be brought against the European Commission (not against
the granting authority; see also Article 22).
ARTICLE 44 — ENTRY INTO FORCE
The Agreement will enter into force on the day of signature by the granting authority or the
coordinator, depending on which is later.
SIGNATURES
For the coordinator For the granting authority
[--TGSMark#signature-963638450_75_210--] [--TGSMark#signature-service_75_210--]
Eva Liina Kliiman with ECAS id n00gxam2 signed in the Participant Signed by Maria TOMASSETTI with ECAS id tomasma as an authorised
Portal on 14/11/2024 at 13:49:31 (transaction id SigId-9248-l84TUH representative on 15-11-2024 19:34:40 (transaction id SigId-30794-0F
Xcs81ssXRHYNWcc817MndUWezaPMwiRzN9XYZi9qzf0JzwzefyNwz 6gc0LaBNQkGZ9ezVX5aGLWHFtzy4UyBS4Obwplo9zPzzsqzPxS96I9yzt
Whn9zrnvBl1Il5H5xgw4kuqZ5Rjw4-rS0vSrmBGYCzv7Kvwzf0JpW-K jvZFroKPypiNmOqyAztPjXchtEC9f-rS0vSrmBGYCzv7Kvwzf0JpW-WpBp
NrnXnVe87UEzzpzHtRJHUpdzroGIRqqNaJNRqSzscHrzyrzzNBI5nelzt CTrAtijkclRdzqXBivgqQW3t8poocyOWZAppNbBn8wfUcTuCDQXHDCFf
zRrCRH9zYiX0zScsqZGp5zfj6zy8bSlO). Timestamp by third party at srogmJ87xrgI5zWcI9g3hK62ezW)
2024.11.14 13:49:34 CET 2024.11.15 19:34:51 CET
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ANNEX 1
Citizens, Equality, Rights and
Values Programme (CERV)
Description of the action (DoA)
Part A
Part B
Project: 101191193 — Palk — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
DESCRIPTION OF THE ACTION (PART A)
COVER PAGE
Part A of the Description of the Action (DoA) must be completed directly on the Portal Grant Preparation screens.
PROJECT
Grant Preparation (General Information screen) — Enter the info.
Project number: 101191193
Project name: Supporting the implementation of Pay Transparency Directive in Estonia
Project acronym: Palk
Call: CERV-2024-GE
Topic: CERV-2024-GE
Type of action: CERV-LS
Service: JUST/H/03
Project starting date: fixed date: 1 January 2025
Project duration: 24 months
TABLE OF CONTENTS
Project summary ......................................................................................................................................................3
List of participants .................................................................................................................................................. 3
List of work packages .............................................................................................................................................4
Staff effort ............................................................................................................................................................... 7
List of deliverables ..................................................................................................................................................8
List of milestones (outputs/outcomes) .................................................................................................................. 15
List of critical risks ............................................................................................................................................... 16
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PROJECT SUMMARY
Project summary
Grant Preparation (General Information screen) — Provide an overall description of your project (including context and overall
objectives, planned activities and main achievements, and expected results and impacts (on target groups, change procedures,
capacities, innovation etc)). This summary should give readers a clear idea of what your project is about.
Use the project summary from your proposal.
The project addresses the pressing issue of gender pay inequality, which persists despite existing legislation and initiatives
aimed at promoting gender equality in the EU. Estonia has one of the largest gender pay gaps in the EU (21.3% in 2022).
The research in Estonia suggests that pay transparency measures and gender-neutral job evaluation could contribute to
the reduction of gender pay gap; at the same time there is a lack of freely available up-to-date national guidelines to
conduct such evaluations required by the Pay Transparency Directive.
The project's primary objective is to facilitate the implementation of the Pay Transparency Directive, and more
specifically the job evaluation requirement, via various interventions. These include the analysis of potential
methodologies for job evaluation and adapting one to Estonian context, offering comprehensive training to employers,
and building institutional competencies on this topic via training, guidelines and learning from selected EU MS.
The target groups of the project are employers and key national institutions responsible for the implementation and
enforcement of the Directive. The project is carried out by the Ministry of Economic Affairs and Communication, Labour
Inspectorate and the Gender Equality and Equal Treatment Commissioner.
LIST OF PARTICIPANTS
PARTICIPANTS
Grant Preparation (Beneficiaries screen) — Enter the info.
Number Role Short name Legal name Country PIC
1 COO MKM MAJANDUS JA EE 963638450
KOMMUNIKATSIOONIMINISTEERIUM
2 BEN LI TOOINSPEKTSIOON EE 889079400
3 BEN VOLINIK SOOLISE VORDOIGUSLIKKUSE JA VORDSE EE 917673448
KOHTLEMISE VOLINIKU KANTSELEI
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Project: 101191193 — Palk — CERV-2024-GE
LIST OF WORK PACKAGES
Work packages
Grant Preparation (Work Packages screen) — Enter the info.
Work Work Package name Lead Beneficiary Effort Start End Deliverables
Package No (Person- Month Month
Months)
WP1 Project management and coordination 1 - MKM 0.00 1 24 D1.1 – Inception report
D1.2 – Mid-term report
WP2 Selection, adaptation, and publishing of job 1 - MKM 0.00 1 12 D2.1 – Research and analysis report
evaluation methodology D2.2 – Adapted methodology and
guidelines
WP3 Employers’ capacity building 1 - MKM 0.00 9 24 D3.1 – E-training course for employers
D3.2 – Final Report on Training Outcomes
WP4 Institutional capacity building 1 - MKM 0.00 9 18 D4.1 – Training and guiding materials
D4.2 – Training materials for awereness
raising
D4.3 – Study Trip Report
WP5 Communication and dissemination 1 - MKM 0.00 1 24 D5.1 – Communication and dissemination
plan
D5.2 – Project web-page
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Work package WP1 – Project management and coordination
Work Package Number WP1 Lead Beneficiary 1 - MKM
Work Package Name Project management and coordination
Start Month 1 End Month 24
Objectives
The objective of WP1 is to ensure the overall management, administration, coordination and execution of the project is
in accordance with the expectations of the call and
Grant Agreement (GA) and to guarantee the highest ethical and quality standards in the execution and deliverables.
Description
This WP includes: Project inception, Managing consortium operations, Financial and administrative management,
Quality, data and ethics management.
Work package WP2 – Selection, adaptation, and publishing of job evaluation methodology
Work Package Number WP2 Lead Beneficiary 1 - MKM
Work Package Name Selection, adaptation, and publishing of job evaluation methodology
Start Month 1 End Month 12
Objectives
The objective of WP2 is to find a suitable methodology for job evaluation and classification, to adapt it to Estonian
context and make it available to employers.
Description
This WP includes: Procurement for developing the methodology and support materials, Developing the methodology
and support materials, Selecting the methodology for Estonia, Securing the licenses and permissions for the adoption of
the methodology, Making the materials available for the employers.
Work package WP3 – Employers’ capacity building
Work Package Number WP3 Lead Beneficiary 1 - MKM
Work Package Name Employers’ capacity building
Start Month 9 End Month 24
Objectives
The objective of WP3 is to equip employers with the knowledge and skills needed to address the gender pay gap and
implement gender-neutral job evaluation and
classification methods. Through targeted training, employers will learn to recognize and mitigate wage disparities,
fostering a culture of pay transparency and equity in the
workplace.
Description
This WP includes: Procurement of the training activities and In-person and e-training to employers.
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Work package WP4 – Institutional capacity building
Work Package Number WP4 Lead Beneficiary 1 - MKM
Work Package Name Institutional capacity building
Start Month 9 End Month 18
Objectives
The objective of WP4 is to build institutional capacity within the Ministry of Economic Affairs and Communication
(MKM), Labour Inspectorate (TI) and the Gender Equality
and Equal Treatment Commissioner (Volinik) on gender pay gap, gender-neutral job assessment, classification and pay
setting and on the selected methodology so they can
provide more informed guidance and support to employers, thereby contributing to the successful implementation of
the Pay Transparency Directive.
Description
This WP includes: Awareness raising training for institutions, Specific procedural training for the Labour Inspectorate,
Guidance materials for the Labour Inspectorate, Study trip.
Work package WP5 – Communication and dissemination
Work Package Number WP5 Lead Beneficiary 1 - MKM
Work Package Name Communication and dissemination
Start Month 1 End Month 24
Objectives
The objective of WP5 to disseminate the project information and results to stakeholders and public and increase the
awareness of the target group of the methodology,
guidelines and e-training developed during the project and thus also of the Pay Transparency Directive.
Description
The WP includes: development of communication and dissemination plan, communication and dissemination
management, Creating project website
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Project: 101191193 — Palk — CERV-2024-GE
STAFF EFFORT
Staff effort per participant
Grant Preparation (Work packages - Effort screen) — Enter the info.
Participant WP1 WP2 WP3 WP4 WP5 Total Person-Months
Total Person-Months 0.00 0.00 0.00 0.00 0.00 0.00
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Project: 101191193 — Palk — CERV-2024-GE
LIST OF DELIVERABLES
Deliverables
Grant Preparation (Deliverables screen) — Enter the info.
The labels used mean:
Public — fully open ( automatically posted online)
Sensitive — limited under the conditions of the Grant Agreement
EU classified —RESTREINT-UE/EU-RESTRICTED, CONFIDENTIEL-UE/EU-CONFIDENTIAL, SECRET-UE/EU-SECRET under Decision 2015/444
Deliverable Deliverable Name Work Lead Beneficiary Type Dissemination Level Due Date
No Package (month)
No
D1.1 Inception report WP1 1 - MKM R — Document, report SEN - Sensitive 1
D1.2 Mid-term report WP1 1 - MKM R — Document, report SEN - Sensitive 12
D2.1 Research and analysis report WP2 1 - MKM R — Document, report PU - Public 10
D2.2 Adapted methodology and guidelines WP2 1 - MKM R — Document, report PU - Public 12
D3.1 E-training course for employers WP3 1 - MKM DEC —Websites, patent PU - Public 24
filings, videos, etc
D3.2 Final Report on Training Outcomes WP3 1 - MKM R — Document, report SEN - Sensitive 24
D4.1 Training and guiding materials WP4 2 - LI R — Document, report SEN - Sensitive 18
D4.2 Training materials for awereness raising WP4 1 - MKM R — Document, report SEN - Sensitive 16
D4.3 Study Trip Report WP4 1 - MKM R — Document, report SEN - Sensitive 15
D5.1 Communication and dissemination plan WP5 1 - MKM R — Document, report SEN - Sensitive 1
D5.2 Project web-page WP5 1 - MKM DEC —Websites, patent PU - Public 3
filings, videos, etc
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Deliverable D1.1 – Inception report
Deliverable Number D1.1 Lead Beneficiary 1 - MKM
Deliverable Name Inception report
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 1 Work Package No WP1
Description
Inception report includes the updated project plan and timetable, and minutes of the inception meeting. The document
is a MS Word or PDF document in Estonian.
Deliverable D1.2 – Mid-term report
Deliverable Number D1.2 Lead Beneficiary 1 - MKM
Deliverable Name Mid-term report
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 12 Work Package No WP1
Description
Mid-term report includes the project progress review, outcome review, risk and issue overview, if any issues has been
encountered as well as the steps to resolve them.
Deliverable D2.1 – Research and analysis report
Deliverable Number D2.1 Lead Beneficiary 1 - MKM
Deliverable Name Research and analysis report
Type R — Document, report Dissemination Level PU - Public
Due Date (month) 10 Work Package No WP2
Description
The aim of the report is to assist in deciding which job evaluation methodology could be made available to all employers
in Estonia and used as the foundation for future training programs. The report can be used also by the empoyers in
deciding which methodology to use in their organsation.
The report will include:
- A detailed explanation of the criteria and process used to select the foreign practices included in the research
- The descriptions of the foreign methodologies (at least 3 international methodologies will be covered): identified pros
and cons, implementation problems, results of the implementation
- The analysis of the Estonian public sector methodology.
Objective: The goal of the report is to assist in deciding which job evaluation methodology could be made available to
all employers in Estonia and used as the foundation for future training programs.
The report will be in Estonian and will be disseminated directly to the stakeholders, though projects webpage as well as
in partners webpages and other channels. The report is at minimum 40 pages.
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Deliverable D2.2 – Adapted methodology and guidelines
Deliverable Number D2.2 Lead Beneficiary 1 - MKM
Deliverable Name Adapted methodology and guidelines
Type R — Document, report Dissemination Level PU - Public
Due Date (month) 12 Work Package No WP2
Description
The aim of the methodology and the guidelines is to: 1) provide comprehensive description of the methodology and
its implementation; 2) to provide employers with a clear, practical, and accessible tool for practical implementation of
gender-neutral job evaluations.
The adapted and translated job evaluation methodology, along with guidelines, will be published on the Labour
Inspectorate, project’s and the www.tooelu.ee website. The methodology and guidelines will be provided in Estonian.
The methodology and guidelines are intended for the employers, especially the managers and HR personnel.
The methodology will be provided in a written form covering the comprehensive overview of the methodology including
definitions and principles for job evaluation. The guidelines will be at a minimum provided in written form, but depending
on the methodology should include elements such as checklists, step-by-step guidance, videos, tables etc. The guidelines
will provide practical assistance, examples and instructions how to integrate the methodology into organisation’s human
resources practices.
Deliverable D3.1 – E-training course for employers
Deliverable Number D3.1 Lead Beneficiary 1 - MKM
Deliverable Name E-training course for employers
Type DEC —Websites, patent Dissemination Level PU - Public
filings, videos, etc
Due Date (month) 24 Work Package No WP3
Description
E-training of up to 8 academic hours of self-paced learning in video, text and exercises format in Estonian with English
subtitles available at https://digiriigiakadeemia.ee/
It is aimed at HR specialists and managers, preparing them to assess job value, create equitable pay systems, and report
on gender pay gaps. The goal is to reach 500 HR specialists and managers with the course by 2028.The objective of
the e-training is to provide tools and knowledge for fair job evaluation, transparent pay systems, and gender pay gap
reporting, with a practical focus on implementation.
The topics, that the e-training covers: gender pay gap, Pay Transparency Directive, gender-neutral job evaluation,
methodology implementation, and reporting on pay gaps.
Deliverable D3.2 – Final Report on Training Outcomes
Deliverable Number D3.2 Lead Beneficiary 1 - MKM
Deliverable Name Final Report on Training Outcomes
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 24 Work Package No WP3
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Description
The final report will provide a comprehensive overview of the training sessions conducted, summarizing key insights,
achievements, and recommendations for future steps. It is aimed at training organizers within governments and also
other organizations, as well as trainers who are involved in developing and delivering similar programs. The report
will include a detailed summary of all training sessions, covering topics topics, and the number of participants. The
mimimum numbers of participants in the training is 450 (planned number of participants is 500). It will also analyze
participant feedback, presenting both quantitative data on satisfaction levels and qualitative comments on the content
and delivery of the training.
Additionally, the report will assess the extent to which the training objectives were met. Key insights and lessons learned
will be highlighted, including challenges faced and best practices identified during the training. Based on these findings,
the report will offer at least five key recommendations for further development of training content, methodologies, and
participant engagement strategies.
The report will be in Estonian and will be disseminated among project partners and stakeholders. The report will be at
minimum 8 pages long.
Deliverable D4.1 – Training and guiding materials
Deliverable Number D4.1 Lead Beneficiary 2 - LI
Deliverable Name Training and guiding materials
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 18 Work Package No WP4
Description
The aim of the training, training and guidance materials is to equip Labour Inspectorate officials with the comprehensive
knowledge and practical tools necessary to effectively monitor compliance with pay transparency regulations and provide
employers with accurate guidance and support. The target group for the training is 15-20 persons. The materials are
designed to enable self-directed learning to ensure sustainability and ongoing capability development within the Labour
Inspectorate.
The training and guiding materials will be primarily provided in a written format (MS Word, PDF, PPT slides) with
potential links to relevant videos if needed. The materials will be available in Estonian.
These materials are designed specifically for Labour Inspectorate officials who will be responsible for conducting
oversight and providing guidance to employers on the implementation of pay transparency policies and job evaluation
practices.
The materials will cover key areas to support officials in their supervisory and advisory roles, including:
• Overview of Pay Transparency requirements in Estonia and its implications for employers.
• Guidance on conducting inspections and assessing compliance with pay transparency requirements.
• Step-by-step procedures for advising employers on gender-neutral job evaluation and classification systems.
• Best practices for identifying and addressing non-compliance.
• Frequently asked questions (FAQs) and practical scenarios to assist officials in handling common issues.
Deliverable D4.2 – Training materials for awereness raising
Deliverable Number D4.2 Lead Beneficiary 1 - MKM
Deliverable Name Training materials for awereness raising
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 16 Work Package No WP4
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Description
The training materials will be primarily provided in written format (MS Word, PDF, PPT slides) and may include links
to relevant videos if necessary. The materials will be available in Estonian or English, depending on the trainers.
These materials are specifically designed for public officials involved in the development and implementation of
pay transparency policies. The aim of the training is to raise awereness on pay transparancy policies among civil
servants involved in pay transparancy policy development and implementation in Ministry of Economic Affairs and
Communications, Labour Inspectorate and Gender Equality and Equal Treatment Comissioner. The target goup is 10-15
participants. Additionally the trainig aims to facilitate and support discussions on pay transparancy and pay equity.
The training materials aim to raise awareness among public officials about key principles of pay transparency policies
with practical examples, including:
• Gender-neutral job evaluation and its importance in creating equitable pay systems.
• Salary structures and their role in ensuring pay transparency.
• Gender pay gap assessment: methods and best practices for evaluating and addressing pay gaps.
• Reporting requirements for pay gaps and compliance with relevant legislation.
• Relevant case law and legal precedents related to pay transparency.
Deliverable D4.3 – Study Trip Report
Deliverable Number D4.3 Lead Beneficiary 1 - MKM
Deliverable Name Study Trip Report
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 15 Work Package No WP4
Description
The study visit is designed for public officials involved in the development and implementation of pay transparency
policies from the Ministry of Economic Affairs and Communications, the Labour Inspectorate, and the Gender Equality
and Equal Treatment Commissioner’s Office. The target group of the study visit is 8-10 persons.The study trip report
is intended mainly for the same group of organizations, as well as a broader circle of colleagues involved in policy
development and implementation.
The aim of the report is to capture and disseminate the knowledge gained during the study trip, providing concrete
recommendations for adapting effective practices to the Estonian context. The report will serve as a resource for project
stakeholders, supporting the continuous development of job evaluation and pay transparency policies.
The study trip report will provide a comprehensive account of the visit, documenting the key activities, learnings, and
outcomes. It will include:
• Overview of Activities: A detailed itinerary of the study trip, including descriptions of the institutions visited,
presentations attended, and discussions held.
• Key Learnings: Summarized insights and best practices observed during the trip, specifically related to job evaluation
methodologies, pay transparency policies, and compliance mechanisms used in the host country.
• Outcomes and Recommendations: key recommendations for implementing or improving similar practices in Estonia.
The raport will be in written format in Estonian and will be at minimum 8 pages.
Deliverable D5.1 – Communication and dissemination plan
Deliverable Number D5.1 Lead Beneficiary 1 - MKM
Deliverable Name Communication and dissemination plan
Type R — Document, report Dissemination Level SEN - Sensitive
Due Date (month) 1 Work Package No WP5
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Description
At the outset of the project, a specific communication and dissemination plan is developed that states the specific
activities, channels and KPI-s for the communication and dissemination activities. The plan is prepared in Estonian and
in a written format (Word or PDF).
The Communication and Dissemination plan will be a comprehensive document outlining the strategy, methods, and
channels for communicating and disseminating the project's activities, results, and impacts to relevant stakeholders,
target groups, and the general public. The plan aims to maximize the visibility and outreach of the project, ensuring
that all key messages are effectively conveyed and that the benefits of the project are understood and recognized by the
main target groups (employers).
The plan will include the following key components:
- Objectives and Goals: define the specific objectives of the communication and dissemination activities, such as
raising awareness of the Pay Transparency Directive, promoting gender-neutral job evaluation practices, and informing
employers about the new guidelines and training opportunities.
Set clear, measurable goals for reach and impact, including quantitative and qualitative indicators (e.g., number of articles
published, social media engagement rates, participant feedback).
- Target Audience Analysis: Identify and categorize the main target groups, such as employers, HR professionals,
policymakers, key national institutions (MKM, TI, Volinik). Analyze their information needs, preferred communication
channels, and potential barriers to engagement to ensure the plan is tailored and effective.
- Key Messages and Content Strategy: Develop key messages that will be used consistently across all communication
materials, emphasizing the importance of pay transparency, equal pay for equal work, and the use of gender-neutral job
evaluation systems. Outline the types of content to be developed, including articles, social media posts, press releases,
newsletters, and training materials. Ensure all content uses inclusive language and visual representations.
- Dissemination Channels and Tools: List the specific channels that will be used for dissemination, such as the Tööelu
Portaal, social media platforms (LinkedIn, Facebook), the Labour Inspectorate’s magazine ‘Tööelu’, and traditional
media.
- Stakeholder Engagement and Partnerships: detail the strategies for engaging with key stakeholders and partners,
including social partners like the Estonian Employers Confederation and the Estonian Human Resource Management
Association PARE. Describe how these partners will be involved in disseminating information through their networks
and supporting the outreach efforts.
- Implementation Timeline: Provide a timeline for the development and implementation of communication and
dissemination activities, aligning with key project milestones and events.
The plan will serve as a dynamic document, updated regularly throughout the project to reflect progress, feedback, and
changing needs. It will be shared with all project partners and stakeholders to ensure a coordinated and effective approach
to communication and dissemination.
Deliverable D5.2 – Project web-page
Deliverable Number D5.2 Lead Beneficiary 1 - MKM
Deliverable Name Project web-page
Type DEC —Websites, patent Dissemination Level PU - Public
filings, videos, etc
Due Date (month) 3 Work Package No WP5
Description
The project web page will be created as a sub-page on the Ministry of Economic Affairs and Communications (MKM)
website, with content available in both Estonian and English.
The web page is intended for all stakeholders, including public officials, employers, and the general public, providing
transparent and accessible information about the project and its outcomes.
Content:
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• Project Overview: A comprehensive project summary, including the main objectives, activities, and expected
outcomes.
• Project Timeline: A visual timeline detailing key milestones and deliverables throughout the project duration.
• Coordinator Contact Details: Contact information for the project coordinator to facilitate communication and inquiries.
• List of Participants: the main project partners.
• Funding Statement: A clear statement acknowledging the funding source, featuring the European flag and a link to
the European Union’s project results page.
• Project Results: A dedicated section providing access to project deliverables and key outcomes, such as research
reports, training materials, and the study trip report.
Format and Features:
• The web page will include both Estonian and English versions, ensuring accessibility for a wider audience.
• Regular updates will be made to the web page to reflect the latest developments and results of the project.
The objective of the page is to provide a centralized, accessible platform for disseminating information about the project,
promoting transparency, and engaging stakeholders with up-to-date project details and results.
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Project: 101191193 — Palk — CERV-2024-GE
LIST OF MILESTONES
Milestones
Grant Preparation (Milestones screen) — Enter the info.
Milestone Milestone Name Work Package No Lead Beneficiary Means of Verification Due Date
No (month)
1 Project inception meeting WP1 1 - MKM Meeting minutes, inception report 1
2 Project review meeting H1 WP1 1 - MKM Meeting minutes 6
3 Project review meeting H2 WP1 1 - MKM Meeting minutes 12
4 Project review meeting H3 WP1 1 - MKM Meeting minutes 18
5 Final review meeting WP1 1 - MKM Meeting minutes 24
6 Selected methodology for Estonia WP2 1 - MKM Research and analysis report 9
7 Methodology and guidelines prepared and WP2 1 - MKM Webpages’ links with published materials 12
published
8 Employers’ in-person trainings carried out WP3 1 - MKM Attendance lists 24
9 Employers’ e-training available for use WP3 1 - MKM Link to e-training in Digiriigi Akadeemia 24
platform
10 Staff of the key institutions enforcing the Pay WP4 2 - LI Attendance lists, Guiding materials 18
Transparency Directive have been trained and
guided
11 Study trip has been carried out WP4 1 - MKM Attendance list, Photos of the group in the 15
selected country
12 Execution of the communication and WP5 1 - MKM At least 90% of the KPI-s are reached, verified by 24
dissemination action plan posts, press releases, articles’ reach.
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Project: 101191193 — Palk — CERV-2024-GE
LIST OF CRITICAL RISKS
Critical risks & risk management strategy
Grant Preparation (Critical Risks screen) — Enter the info.
Risk Description Work Package Proposed Mitigation Measures
number No(s)
1 Coordination issues or disagreements among project WP5, WP1, WP2, The partners have a history of cooperation, which mitigates the risk already. At the beginning
partners or between different stakeholders could WP3, WP4 of the project, the partners sign a Cooperation Agreement that regulates the goals, methods
lead to miscommunication, duplication of efforts, and work organization of the project, communication channels, and regulates the resolution
conflicting priorities or implementation difficulties. of disagreement. Regular monitoring and meeting practices are in place to discuss the
Impact: High Likelihood: Low progress. All issues and disagreements are discussed and mitigated immediately when they
arise. Every six months, a project review meeting is held between the project team to discuss
the progress, risks and any issues and risks.
2 A member of the core project team leaves the project WP5, WP1, WP2, Consortium partners teams teams consist of multiple individuals capable of substituting for
or falls ill Impact: low Likelihood: medium WP3, WP4 one another. There is continuous exchange of information between the project team, with
crucial data stored in a server accessible to the entire team. Due to the transparency of project
activities, decisions, and information, as well as the close communication among project
members, swift replacement of a project team member due to departure or illness poses no
threat to the successful implementation of the project.
3 Procurement activities take longer than excepted or WP2, WP3 The coordinator has extensive experience in procurement activities and thus can foresee
fail (no subcontract found to perform the planned any potential risks and have institutional competencies to deal with the risks. The key
tasks) Impact: medium Likelihood: low is early planning, i.e the procurement processes will be initiated as early as possible.
The requirements and specifications for procurement will be clearly defined to avoid
misunderstandings or revisions later in the process. Transparency and fairness throughout
the procurement process is maintained to encourage competition and attract qualified
subcontractors. The activities have been planned with a margin, to ensure the project timeline
can withstand unexpected delays. Prior experiences and market research confirm there are
several potential subcontractors available in the market to perform the required tasks. In case
no subcontractors are found, the project partners are in principle capable (based on available
skills and experiences) to carry out the activities themselves.
4 Inability to find a suitable methodology adaptable to WP2 Drawing from prior research, multiple methodologies are expected to be available for
the Estonian context. Impact: medium Likelihood: consideration. Engaging a specialized research organization will provide access to experts
low with the necessary knowledge and skills to conduct comprehensive research and analysis
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Project: 101191193 — Palk — CERV-2024-GE
Critical risks & risk management strategy
Grant Preparation (Critical Risks screen) — Enter the info.
Risk Description Work Package Proposed Mitigation Measures
number No(s)
to identify a suitable methodology. In the event that no suitable methodology is found, the
project team will leverage previous research, utilize the guidelines outlined in the Directive,
and apply their extensive expertise to develop a methodology tailored to the Estonian context.
5 Challenges in establishing adequately robust WP4 At the project outset, an extensive mapping of potential cooperation contacts will be
international cooperation contacts for the purpose of conducted. Each project partner possesses established international networks, which can be
arranging a study visit Impact: low Likelihood: low leveraged to facilitate the cooperation in this project.
6 The costs of project implementation are WP5, WP1, WP2, The project budget is planned based on experiences of executing part projects. In
considerably higher than estimated Impact: medium WP3, WP4 case of unexpected increases in prices (accommodation, travel, subsistence, services and
Likelihood: low subcontracting), in-kind contributions from the project partners can be used, given the
importance of the project at the state level.
Cost optimization principles and methods are used throughout the project to keep the costs
of the implementation low, but reasonable for reaching the goals.
7 Limited participation from a diverse range of WP3 Prior to developing the training sessions, an assessment will be conducted by the Ministry to
employers in the in-person training sessions map the needs and readiness of the target group. This will be done by establishing cooperation
with empoyer's and HR organisations. Regular communication and feedback channels will
be established to keep them engaged and ensure that the content and format of the courses
are aligned with their expectations. A dedicated communication plan will be developed to
attract the potential participants in cooperation with the stakeholders.
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Associated with document Ref. Ares(2024)8072160 - 13/11/2024
ANNEX 1
Citizens, Equality, Rights and Values
Programme (CERV)
Description of the action (DoA)
Part B
Version 1.0
01 April 2021
Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
PROJECT
Project name: Supporting the implementation of Pay Transparency
Directive in Estonia
Project acronym: PALK
Coordinator contact: Eva Liina KLIIMAN, Ministry of Economic Affairs and
Communication (MKM)
TABLE OF CONTENTS
ANNEX 1 ......................................................................................................................... 1
1. RELEVANCE ........................................................................................................................................................... 3
1.1 Background and general objectives .................................................................................................................... 3
1.2 Needs analysis and specific objectives ............................................................................................................... 3
1.3 Complementarity with other actions and innovation — European added value .................................................... 5
2. QUALITY ................................................................................................................................................................. 6
2.1 Concept and methodology .................................................................................................................................. 6
2.2 Consortium set-up............................................................................................................................................... 7
2.3 Project teams, staff and experts .......................................................................................................................... 8
2.4 Consortium management and decision-making................................................................................................... 9
2.5 Project management, quality assurance and monitoring and evaluation strategy .............................................. 10
2.6 Cost effectiveness and financial management .................................................................................................. 11
3. IMPACT ................................................................................................................................................................. 12
3.1 Impact and ambition.......................................................................................................................................... 12
3.2 Communication, dissemination and visibility...................................................................................................... 12
3.3 Sustainability and continuation .......................................................................................................................... 13
Subcontracting (n/a for prefixed Lump Sum Grants) ......................................................................................... 15
Timetable ......................................................................................................................................................... 17
5. OTHER .................................................................................................................................................................. 20
5.1 Ethics and EU values ........................................................................................................................................ 20
5.2 Security............................................................................................................................................................. 21
6. DECLARATIONS ................................................................................................................................................... 21
ANNEXES ..................................................................................................................................................................... 22
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1. RELEVANCE
1.1 Background and general objectives
Background and general objectives
Describe the background and rationale of the project.
How is the project relevant to the scope of the call? How does the project address the general objectives of the call?
What is the project’s contribution to the priorities of the call?
Which target groups will be supported/assisted by/in the project. Why have you chosen to focus on them?
The project addresses the pressing issue of gender pay inequality, which persists despite existing
legislation and initiatives aimed at promoting gender equality in the EU. Despite the principle of equal
pay for equal work being enshrined in EU law since 1957, women across the EU continue to earn less
than men, with the gender pay gap standing at an average of 12.7% in 2022 (Eurostat, sdg_05_20).
Recognizing the importance of addressing this issue, the EU has prioritized gender equality as a
fundamental value and a key principle of the European Pillar of Social Rights. The EU's Gender Equality
Strategy 2020-2025 underscores the need to ensure equal pay for equal work or work of equal value,
with a specific focus on addressing the gender pay gap. In line with these objectives, the EU adopted
the Pay Transparency Directive on April 24, 2023, with the aim of achieving pay equality between
women and men.
The project directly aligns with the scope of the call by supporting, advancing, and implementing the EU
policies to promote women's full enjoyment of rights and gender equality, including equal pay between
women and men. Specifically, the project contributes to the second priority of the call, which focuses on
supporting the implementation of the provisions of the Pay Transparency Directive. By developing
national guidelines for gender-sensitive job evaluation and classification systems, raising awareness
among employers and building institutional competencies, the project addresses the general objectives
of the call.
Estonia has one of the largest gender pay gaps in the EU (21.3%). The research in Estonia suggests
that pay transparency measures and gender-neutral job evaluation could contribute to the reduction of
gender pay gap; at the same time there are no national guidelines available for private sector to conduct
such evaluations required by the Directive (see section 1.2).
The project's primary objective is to facilitate the implementation of the Pay Transparency Directive, and
more specifically the job evaluation requirement, via various interventions. These include the analysis of
potential methodologies for job evaluation and adapting one to Estonian context, offering
comprehensive training to employers, and building institutional competencies on this topic via training,
guidelines and learning from selected EU MS.
The target groups of the project are:
- Employers, as they will be directly implementing the Directive requirements and the Directive
calls MS to ensure that analytical tools or methodologies are made available and are easily
accessible to support and guide the assessment and comparison of the value of work in
accordance with the criteria set out in the Directive,
- Key national institutions responsible for the implementation and enforcement of the Directive,
namely the Ministry of Economic Affairs and Communication (MKM), responsible for
employment policy making; the Labour Inspectorate (TI), which exercises supervision over
employment legalisation implementation in companies and providing guidance to employers;
and the Gender Equality and Equal Treatment Commissioner (Volinik) who monitors
compliance with the requirements of the Gender Equality Act and the Equal Treatment Act, as
well as provides guidance both the public and private sector.
1.2 Needs analysis and specific objectives
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Needs analysis and specific objectives (n/a for Programme Contact Points)
Provide a needs assessment. A need is a gap between what is and what should/ would be helpful or useful.
The needs assessment should be your starting point. Specify what needs will be addressed and how they have been
identified. It should be specific and focus on the actual needs of the target group. It should include relevant, reliable
data and, a robust analysis clearly demonstrating the need for the action (therefore, avoid references to generic
statements and information about the problems and needs of the target group). The needs assessment should
incorporate gender equality issues and non-discrimination considerations that identify the differences between and
among women and men, girls and boys, in terms of their relative position in society and the distribution of resources,
opportunities, constraints and power in a given context. The data supporting the needs assessment should be
dissaggregated by sex, as well as age or disability, whenever possible. You can refer to existing research, studies
and previous projects that already demonstrate the need for action.
If your project is supported by a public authority, annex the Letter of support.
Estonia, despite continuous advancements in economic growth and gender equality, faces a significant
gender pay gap within the European Union, standing at 21.3% in 2022 (Eurostat, sdg_05_20), well
above the EU average (12.7%). This gap highlights the pressing need for targeted measures to enhance
Local research (e.g. Anspal et al., 2010; Espenberg et al., 2014) has attributed Estonia's pay gap mainly
to labour market segregation, with a significant portion remaining unexplained. The research project
"Reducing the Gender Wage Gap" (REGE), co-funded from European Regional Development Fund,
offered more detailed analysis. One of the studies (Täht, 2019) of the project explained 40% of the
known wage gap and found that factors like occupation, company, sector, education level, location, and
age primarily influence hourly wages for both genders, but these factors better explain women's wages
than men's, thus suggesting that the large wage gap is driven by highly paid men whose wage levels
cannot be explained by (standard) factors included in the analysis. The study also showed that common
misconceptions and unconscious biases perpetuate the wage gap, with employers often believing they
cannot influence salary levels dictated by the market. The research in Estonia thus suggests that pay
transparency measures and gender-neutral job evaluation could contribute to the reduction of gender
pay gap.
The REGE project also included a study on gender pay gap in job application process, replicating a
previous study from 2014. Räis et al (2022) compared reservation, desired, and paid wages based on
data from Estonia's public job portal from 2018 to 2020. Men's desired salary was 22% higher than
women's, with the largest gap seen among inexperienced candidates (nearly 40%) and in case of higher
salary levels. It also became evident that including the employer's salary offer in job ads reduced the
gender gap between desired and paid salaries. Candidates with prior experience in state institutions,
where salary transparency is higher, also exhibited a smaller salary gap. This underscores the
significance of salary transparency in diminishing wage disparities and promoting equality in
negotiations.
The need for measures to enforce the principle of equal pay for equal work of work of equal value is well
addressed in international and Estonian policy priorities. The OECD (2022) has recommended for
Estonia to implement pay transparency policies, i.e. company-level reporting of gender composition and
pay differences building on existing legislation, and supplementing this with measures promoting equal
pay for work of equal value, like mandate reporting alongside a gender-neutral job classification system
and establish a Pay Competence Centre at the Labour Inspectorate to validate such systems; also
online training courses for employers could be provided to enhance awareness and promote gender
equality. The Estonian Welfare Development Plan 2023-2030 outlines labour and social policy goals
aligning with the European Pillar of Social Rights and UN sustainable development goals. A key focus of
the plan is gender equality and equal treatment, with a target to reduce the gender pay gap to 8.5% by
2030 (down from 14.9% in 2021) (based on national statistics). Proposed actions include enhancing
sectoral law enforcement, increasing the capacity of national institutions, and promoting economic
equality through measures such as improving pay transparency and supporting employers in addressing
pay gaps.
Thus, there is clearly a need in Estonia to develop measures to narrow the gender pay gap with
measures required by the Pay Transparency Directive. However, there are no tools used in Estonia in
private sector for it, and the only potential tool available is in use in public sector. In Estonian public
sector, the wages of the public servants are public and the pay levels are set according to the job
classification. Position evaluation is a method aimed at determining the hierarchy of positions within the
institution, being one of the foundations for determining basic salaries in the conditions of decentralized
salary management of the public service. The evaluation aims to decrease subjectivity while assessing
the value of work and tasks and to create a fair and reasoned pays system. However, the evaluation
guidelines were developed in 2006, and the latest changes were introduced 6 years ago.
Anspal, S., Kraut, L., & Rõõm, T. (2010). Sooline palgalõhe Eestis: empiiriline analüüs. Uuringuraport.
Tallinn: Eesti Rakendusuuringute Keskus CentAR, Poliitikauuringute Keskus PRAXIS,
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Sotsiaalministeerium.
Espenberg, K., Aksen, M., Lees, K., & Puolokainen, T. (2014). Palgaerinevuste statistika parem
kättesaadavus. Soolise palgaerinevuse analüüs. Tartu: Tartu Ülikooli sotsiaalteaduslike
rakendusuuringute keskus RAKE.
OECD (2022), The Economic Case for More Gender Equality in Estonia, Gender Equality at Work,
OECD Publishing, Paris, https://doi.org/10.1787/299d93b1-en.
Räis, M.-L., Täht, K., Unt, M. Do desired wages explain the gender wage gap in Estonia? An
examination of desired wages in job applications. 2022. TLÜ RASI
Täht, K. (Toim.) (2019). Soolise palgalõhe kirjeldamine ja seletamine – tehniline ülevaade. RASI
toimetised nr 10. Tallinn: Tallinna Ülikool.
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1.3 Complementarity with other actions and innovation — European added value
Complementarity with other actions and innovation (n/a for Programme Contact Points)
Explain how the project builds on the results of past activities carried out in the field and describe its innovative
aspects. Explain how the activities are complementary to other activities carried out by other organisations.
Illustrate the European dimension of the activities: trans-national dimension of the project; impact/interest for a
number of EU countries; possibility to use the results in other countries, potential to develop mutual trust/cross-border
cooperation among EU countries, etc.
Which countries will benefit from the project (directly and indirectly and why have you chosen them)? Where will the
activities take place?
Clarify to what extent the project builds on synergies with other EU projects. If applicable, explain to what extent your
project builds on previous project results in this field (state of play, relation to existing/recent developments,
approaches, achievements, other EU programmes).
Note: The project should also complement or add benefits to the EU Member States' interventions in the area of
gender equality and non-discrimination mainstreaming.
The project addresses the Pay Transparency Directive's requirements, which mandate employers to
implement pay setting systems based on gender-neutral job evaluation and classification practices
ensuring equal pay for work of equal value. In Estonia, there is currently a lack of methodologies and
tools for the private sector to comply with this requirement, necessitating among other activities the
consultation of EU best practices.
Building on initiatives across Europe the project foresees evaluation of various methodologies and
selection one suitable for adaptation to the Estonian context. There are only a few EU countries that
have so far embedded pay reporting requirements within more comprehensive equal pay auditing
processes and explicitly require the use of gender-neutral job classification systems (OECD, 2023).
For instance, Belgium has one of EU's lowest gender pay gaps – 5% in 2022 (Eurostat, sdg_05_20).
Since 2006, initiatives like the Equal Value Project, collective agreements, and laws that date back to
decades, aim to promote gender-neutral job evaluation schemes and combat employment
discrimination, which are compulsory for medium-sized and large companies as of 2012. Job evaluation
schemes incorporating attributes of female-dominated roles, like emotional demands in care work, are
recognized as essential for achieving equal pay and narrowing the gender pay gap. However,
enforcement gaps exist, particularly concerning Social Balance Sheets completion and the National
Bank's inability to sanction employers. (University of Greenwich, 2021; Pillinger, 2021)
As of 2021, according to Royal Decree 902/2020 of October 13, 2020, Spanish companies must
evaluate jobs to follow the principle of equal pay for work of equal value, and the evaluation requires the
application of the criteria of adequacy, completeness and objectivity. For this, the Spanish job evaluation
tool and guidelines, co-financed by the European Social Fund, ensure objective job classification and
can be voluntarily used by the companies.
In 2018, Portugal adopted Law no 60/2018 to promote equal pay between genders, requiring
employers to establish transparent pay policies grounded on the evaluation of the components of the
functions, based on objective criteria, common to men and women. Initiatives by social partners have
led to projects promoting equality, such as the "Revaluing Work to Promote Equality" initiative funded by
the EQUAL Initiative. This project developed methodologies for assessing the value of work free from
gender bias, and has been implemented in various sectors since. (Perista and Casaca, 2021),
There is no universal method or model available for gender-neutral job assessment, evidenced also by
various methods used in the EU MS. Our project seeks to build upon the lessons learned and best
practices identified from past initiatives by:
- Conducting a comprehensive analysis of different job evaluation methodologies used EU MS to
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develop a methodology adapted to fit the Estonian context;
- Developing tailored training materials and resources to support employers in implementing the
Pay Transparency Directive; and
- Collaborating with relevant stakeholders from EU countries, to leverage existing expertise to
build capacity in Estonia, share experiences and promote mutual learning. Within the project
direct framework this can be done via study visit and awareness raising training to civil
servants, but as the project team is involved in various international networks, the synergies
can be even further increased by enhancing its impact by integrating proven approaches.
Through these efforts, our project contributes to the effective implementation of the Pay Transparency
Directive by addressing gaps and challenges identified from past activities and building upon existing
knowledge in Estonia and across the EU.
OECD (2023), Reporting Gender Pay Gaps in OECD Countries: Guidance for Pay Transparency
Implementation, Monitoring and Reform, Gender Equality at Work, OECD Publishing, Paris,
https://doi.org/10.1787/ea13aa68-en.
Perista, H., Casaca, S. F. (2021). Beyond a progressive normative framework: challenges to increase
pay transparency and tackle the gender pay gap. Peer Country Paper – Portugal. Mutual Learning
Programme, DG Employment, Social Affairs and Inclusion,
Pillinger, J. (2021). Pay transparency and role of gender-neutral job evaluation and job classification in
the public services. EPSU, ETUI.
University of Greenwich (2021). International Mechanisms to Revalue Women’s Work: Research
exploring and evaluating international mechanisms that aim to revalue or result in the revaluation of
women’s work. Social Research Series, ISBN: 9781802015485
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2. QUALITY
2.1 Concept and methodology
Concept and methodology
Outline the approach and methodology behind the project. Explain why they are the most suitable for achieving the
project’s objectives. Include ethical and safety considerations to ensure that target groups are not subjected to harm
in any way.
Note: Methodology is not a list of activities but are instruments, approaches that will be used, applied and created.
The project will be carried out in cooperation of the key stakeholders responsible for the enforcement of
the Pay Transparency Directive, including providing guidance to employers and exercising supervision.
The project brings together evidence-base knowledge and practical experience and aims at building on
both to create change and improve gender equality. The key components of the project are the
following:
1) Selection and adaptation of gender-neutral job evaluation and classification methodology: A
comparative analysis of 3-4 job evaluation and classification methodologies used in other
countries (e.g BE, ES, PT) will be conducted and considered as basis for national system. In
addition, analysis of the methodology used in Estonian public sector to classify jobs will be
conducted from the point of view of the directive’s requirements (i.e whether the methodology uses
the required criteria: skills, effort, responsibility and working conditions). The next step is to adapt
the selected methodology to fit Estonian context, considering the legal framework, labour
market structure, characteristics of organisational structures, gender segregation in occupations,
cultural norms, etc. Given the nature and complexity of these activities, it is imperative to enlist the
expertise of a specialized research organization through a formal procurement process. This will
ensure access to the best expertise and mitigates the risk of bias or conflict of interest.
2) Preparing guidelines and publishing the methodology and materials: Necessary materials and
guidelines will be developed to facilitate the implementation of the methodology and accessibility for
employers. The materials include, for example, the explanation of gender pay gap, the need for
gender-neutral job assessment and classification, explanation of the methodology and practical
examples, considering the diversity of organisation (e.g. large companies with complex structures;
NGOs with flat structures, etc). By choosing appropriate contents, wording, illustrations, etc, the
materials will adhere to the core EU values and will reinforce equal treatment and non-
discrimination. The materials will be published on the website of the Labour Inspectorate and in the
‘Work Life Portal’ (www.tooelu.ee) which is a webpage created by the Inspectorate to gather
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information on employment relations and working conditions.
3) Training for employers: To increase the employers’ understanding of the need for job evaluation
and classification and the methodology and competency to use the methodology, the project
foresees designing and providing comprehensive training. 20 groups of employers consisting of up
to 25 persons per group will be trained via in-person trainings (up to 8 academic hours). Diversity
of participants (in terms of company characteristics as well as the characteristics of the company
representatives) will be encouraged and necessary arrangements will be done, including providing
the training in various places all over Estonia, ensuring physical accessibility and necessary aids, if
needed. To ensure the training opportunity is available longer and accessible to the entire target
group allowing self-paced studying, an e-training (up to 8 academic hours) will also be developed.
This will be available free of charge on national e-training platform (www.digiriigiakadeemia.ee), in
Estonian (with English subtitles), adhering to accessibility standards. To ensure compliance with
ethical standards, it will be made sure the contents of the trainings are accurate, unbiased, and
gender and diversity sensitive. Given the complexity and volume of developing and carrying out the
trainings, the activities will be procured externally. By engaging external providers, we can leverage
their experience, knowledge, and resources in delivering effective training, ensuring high-quality
content, solutions and engagement.
4) Institutional capacity building: The project will focus on enhancing the capacity of the key
national institutions, who play pivotal roles in overseeing the implementation of the Pay
Transparency Directive within workplaces and serve as primary points of contact for employers
seeking guidance and clarification, including on the gender-neutral job evaluation, classification,
and pay-setting practices. An awareness raising training for MKM, TI and Volinik (up to 15
participants) will be designed and carried out, to better understand the concept and principles of
equal pay for equal work or work of equal value. An external moderator with expertise in the field
(local or foreign) will ensure a moderated discussion on these topics. For TI, a specific procedural
training will be carried out (for up to 20 staff members) and guiding reference materials will be
developed. These will increase the knowledge and ability of the TI staff in relation to exercising
supervision over the requirement of the Pay Transparency Directive on the usage of gender-neutral
job evaluation and classification systems in companies. The materials will be developed by TI.
Finally, a study trip to a MS with established job evaluation and classification practise will be carried
out to gain knowledge on the principles, implementation, enforcement, monitoring and supervision
practice, and to form connections for mutual learning. The institutional competence building will
ensure that the institutions will have the necessary skills and resources to support employers
without causing harm or unfair treatment.
An integral part of the project are communication and dissemination activities to ensure the created
knowledge and materials reach the target group. These activities are described in section 3.2.
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2.2 Consortium set-up
Consortium cooperation and division of roles (if applicable) (n/a for Town Twinning and Programme
Contact Points)
Describe the participants (Beneficiaries, Affiliated Entities and Associated Partners, if any) and explain how they will
work together to implement the project. How will they bring together the necessary expertise? How will they
complement each other?
In what way does each of the participants contribute to the project? Show that each has a valid role and adequate
resources to fulfil that role.
Note: When building your consortium you should think of organisations that can help you reach objectives and solve
problems.
The project consortium includes three partners – MKM as the lead partner and project coordinator, TI
and Volinik as partners.
MKM is responsible for implementing and transposing the Pay Transparency Directive in Estonia, as
well as overseeing employment and equality policies in the country. The ‘Area of Work’ within the MKM,
serves as a centre of professional expertise and competence in matters related to employment, working
conditions and work environment and equal opportunities and gender equality.
TI supervises the implementation of employment legislation in companies and offers guidance to
employers and employees on employment relations and working conditions matters.
Volinik monitors compliance with the requirements of the Gender Equality Act and the Equal Treatment
Act and provides guidance to both public and private sector employers and employees. In addition, they
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facilitate communication from other stakeholders and maintain a wide network of connections within the
EU with other equality bodies.
As public bodies working towards common objectives, they have a history of collaboration and
leveraging each other's strengths to develop, communicate, and implement changes in Estonia. In this
project, MKM will lead the Work Packages and will carry out the procurement activities. TI will contribute
its expertise and resources to various tasks, and will additionally lead activities aimed at enhancing its
own capacity. Volinik will provide input at various stages of the project, drawing on their experience and
knowledge in gender equality and non-discrimination, as well as their extensive network within the EU.
2.3 Project teams, staff and experts
Project teams and staff
Describe the project teams and how they will work together to implement the project.
List the staff included in the project budget (budget category A) by function/profile (e.g. project manager, senior
expert/advisor/researcher, junior expert/advisor/researcher, trainers/teachers, technical personnel, administrative
personnel etc. and describe briefly their tasks. Provide CVs of all key actors (if required).
Note: Please ensure a gender-balanced representation in the composition of project teams and staff performing the
action.
Name and Organisation Role/tasks/professional profile and expertise
function
To be recruited, MKM Overall coordination and management of the project, including
Project manager consortium relations management, financial and ethics
management, and procurement management. The position is yet to
be filled, the role description (in Estonian) states that at least 3 years
of project management experience is required, preferably the
person should have previous experience in the field of gender
equality and/or compensation policies as well as experience in
procurement processes.
Lee Maripuu, MKM Lee Maripuu is the head of gender equality policy in Ministry of
expert Economic Affairs and Communication and is contributing to the
project as expert in all stages of the project.
Eva Liina MKM Eva Liina Kliiman is advisor on gender equality in Ministry of
Kliiman, expert Economic Affairs and Communication and is contributing to the
project as expert in all stages of the project.
Kristel Plangi, TI Kristel Plangi works as the head of the Prevention Department in
partner Labour Inspectorate and will act as the partner coordinator for TI in
coordinator (TI) the project. The role entails coordinating activities in TI and acting
as the contact point between TI, project manager and consortium.
Art Peeter Volinik Art Peeter Roosve has years of experience working as an advisor at
Volinik, where he has contributed to advising on potential
Roosve, partner discrimination cases, participated in various projects, and
coordinator maintained international connections. He will act as the partner
coordinator for Volinik in the project, i.e. coordinating activities in
Volinik and acting as the contact point between Volinik, project
manager and consortium.
Outside resources (subcontracting, seconded staff, etc)
If you do not have all skills/resources in-house, describe how you intend to get them (contributions of members,
partner organisations, subcontracting, etc).
If there is subcontracting, please also complete the table in section 4. Moreover, ensure that subcontractors are
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Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
aware of gender mainstreaming and non-discrimination mainstreaming.
To To ensure efficient and high-quality implementation of the project, a full-time project manager will be
hired by MKM via a public, transparent hiring process. This ensures focused attention on project success
and leverages specialized project management skills. The role description for this position is included in the
application (in Estonian.
Given the nature of the applicants (public bodies) and Estonian anti-corruption regulations, certain project
activities, such as the analysis, evaluation, and adaptation of pay evaluation methodologies, as well as the
design, development, and implementation of training sessions for employers, must undergo public
procurement procedure. Also, by engaging external providers, we can leverage their experience, knowledge,
and resources in delivering high-quality and efficient outputs. Due to the time constraints in relation to the
call for proposals, it was not possible for MKM to carry out a transparent procurement process prior to the
call deadline, therefore it will be carried out once the funding decision has been made.
2.4 Consortium management and decision-making
Consortium management and decision-making (if applicable) (n/a for Town Twinning and Programme
Contact Points)
Explain the management structures and decision-making mechanisms within the consortium. Describe how decisions
will be taken and how regular and effective communication will be ensured. Describe methods to ensure planning and
control.
Note: The concept (including organisational structure and decision-making mechanisms) must be adapted to the
complexity and scale of the project.
The project consortium includes three partners – MKM as the lead partner and project coordinator, TI
and Volinik as partners. MKM will lead the Work Packages (WP) and is responsible for procurement. TI
contributes to various tasks and in addition will lead tasks related to their capacity building. Volinik will
contribute to the project in various stages with relevant experience and knowledge.
The consortium partners have a history of collaboration, but as the planned project is more
comprehensive, both, in terms of duration and activities, a Cooperation Agreement, establishing the
consortium management, decision-making, working and reporting procedures not addressed in the EC
Grant Agreement, will be concluded.
The main decision-making body is the Project Management Team (PMT), composed of
representatives from each of the three organisations. The project coordinator facilitates a collaborative
decision-making process within the PMT. Decisions are reached through consensus among team
members. In urgent cases or for day-to-day management issues, the project manager takes
responsibility and informs the PMT accordingly. The consortium partners are committed to resolve any
potential conflicts in a consensual manner. If a conflict arises among partners, it will be discussed
among the PMT at the nearest project meeting or ad-hoc meeting; if the matter cannot be satisfactorily
resolved in this way, the project coordinator shall have the final say.
The day-to-day communication is done via e-mail and virtual meetings. All consortium parties are
highly responsive, thereby enabling a fast consultation and decision-making process. In addition,
monthly project meetings to review the progress, plan and adjust timelines take place, and PMT is also
expected to meet once every half year during the project (including inception meeting and final review
meeting) for in-depth discussions. These meetings allow for regular exchange of experiences and views,
proper monitoring and reporting of project delivery and impact, sound discussion on the detailed
workplan and collaborative strategic direction of the project. The project manager drafts the agenda and
the minutes of the PMT meetings and distributes these materials among the PMT members, who can
make suggestions and propose changes. The minutes of the meetings will be approved via e-mail. The
project manager is responsible for archiving the minutes of the project meetings. Reporting to the EC
according to the requirements of the Grant Agreement is the responsibility of the project manager. All
partners have the duty to provide the project manager with the necessary information for the completion
of these reports.
Monitoring and quality control procedures are of utmost importance and will be extensively
described in the next section (2.5).
#§CON-SOR-CS§# #@PRJ-MGT-PM@#
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EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
2.5 Project management, quality assurance and monitoring and evaluation strategy
Project management, quality assurance and monitoring and evaluation strategy
Describe the measures planned to ensure that the project implementation is of high quality and completed in time.
Describe the methods to ensure good quality, monitoring, planning and control.
Describe the evaluation methods and indicators (quantitative and qualitative) to monitor and verify the outreach and
coverage of the activities and results (including unit of measurement, baseline and target values). The indicators
proposed to measure progress should be relevant, realistic and measurable.
Note: The monitoring and evaluation strategy should also incorporate gender and non-discrimination considerations
in order to measure changes and assess impact on gender equality issues. The indicators should be gender
responsive so that they can measure gender equality changes over time. For instance, a gender responsive indicator
can measure the increase in women’s rate of employment or changes in social attitudes towards gender roles in
work-life balance. The evaluation should be participatory and inclusive to all stakeholders, ensuring that women’s and
men’s voices are prevalent throughout the entire evaluation process.
Throughout the project, a quality assurance system is used to ensure that the execution of tasks and
activities meet the CERV programme requirements, are performed without defects and/or errors in a
timely and cost-effective manner, possible risks impacting the course or outcome of the project are
identified and mitigated early and effectively, and in compliance with EU values, ethics and data
protection. The system entails the preparation and compliance with relevant documents, guidelines and
standards, communication, and risk management, monitoring and evaluation measures.
Documents: The final project plan and timetable will be prepared at the beginning of the project,
which will be agreed by the whole consortium to ensure common understanding of the goals, activities,
timeframe and roles. Cooperation Agreement will be set as an inner agreement on work organization,
feedback mechanisms, and information channels among the consortium partners, as well as common
principles of contract management and principles to ensure highest quality, ethical and data standards
and requirements accepted in EU and set out by CERV.
Communication: The project review meeting is organized once every six months by the project
Coordinator between the consortium partners and any relevant stakeholders to evaluate the progress of
the project, identify potential risks, and adjust the project execution plan. Regular internal check-ups
and reports (monthly ‘health checks’) about the development of WPs and tasks will be carried out. At
the beginning of each task, a detailed plan will be prepared and agreed upon with clear responsibilities
allocated to all participants. Progress of ongoing tasks will be monitored. Evolving deliverables will be
followed based on project's internal review process to identify possible problems well in advance of
deadlines. The project timetable will be updated at least monthly with the advancement and completion
of individual subtasks. The Project coordinator will ensure continuous communication with CERV.
Risk management, monitoring and evaluation: Part of the project management and quality
assurance is risk management, monitoring and evaluation. These activities will be embedded within the
project management throughout the project. The activities will entail the identification, assessment and
monitoring of the risks, threats and opportunities, and the implementation of selected mitigating
measures. The project manager will be responsible for monitoring the process, but it will be
implemented in co-operation with all team members during project meetings or ad hoc if needed. The
monitoring and evaluation scheme will cover in- and output-related aspects and will include concrete
quantitative and qualitative indicators and a system to collect, interpret and reflect data along defined
targets. The specific indicators are set in the beginning of the project during the development of
Inception Report and Cooperation Agreement and will cover at least the following:
• Number of participants of the employers’ in-person training activities (disaggregated by
participants’
• Number of TI personnel participating in the TI competence building training activities
• Information on communication activities’ coverage (such as number of articles, reach of media,
etc)
Continuous monitoring is essential for evaluating the project's advancement vis-à-vis its objectives
and milestones, as well as identifying any deviations from the initial plans and targets. Regular
communication, meetings, and adjustments to the timeline will contribute to the monitoring process. The
project manager will maintain comprehensive records of project progress, which will inform the project
evaluation. Evaluation plays a pivotal role in appraising the project outcomes, discerning successful
strategies and areas requiring improvement, assessing the efficacy and impact of activities and
measures, and ensuring adherence to standards, guidelines, processes, and values. Evaluations will be
conducted biannually in the context of the project review meetings, led by the project manager.
To ensure that gender equality and non-discrimination are considered throughout the project
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implementation, evaluation and monitoring, the following principles are followed:
• Setting gender-sensitive indicators: developing evaluation criteria and monitoring indicators that
capture the differential experiences and needs of diverse genders and marginalized groups.
• Data disaggregation: collecting and analysing data disaggregated by gender, region, main language
and other relevant factors to identify disparities and ensure that the project benefits all groups
equally
• Addressing barriers: identifying and addressing barriers that prevent certain groups from accessing
project benefits or participating fully in project activities, such as discriminatory practices or unequal
distribution of resources.
• Participatory approaches: engaging diverse stakeholders and groups in the evaluation process to
ensure their perspectives and experiences are considered and valued.
• Using gender and diversity sensitive language, visuals, examples etc in the training and knowledge
raising activities and throughout the project communication.
#§PRJ-MGT-PM§# #@FIN-MGT-FM@#
2.6 Cost effectiveness and financial management
Cost effectiveness and financial management (n/a for prefixed Lump Sum Grants)
Describe the measures adopted to ensure that the proposed results and objectives will be achieved in the most cost-
effective way.
Indicate the arrangements adopted for the financial management of the project and, in particular, how the financial
resources will be allocated and managed within the consortium.
Do NOT compare and justify the costs of each work package, but summarize briefly why your budget is cost
effective.
When planning the project budget, the priority has been optimization. This ensures that sufficient funds
are allocated to implement the project effectively, while resource efficiency is emphasized by avoiding
unnecessary expenses. Essential resources, such as venues, transportation, catering, and travel, are
sourced through a competitive bidding process or offered by project partners as in-kind contributions.
Additionally, as public sector organizations, the partners have extensive experience in adhering to
legislative and internal rules to ensure cost-effectiveness.
The following measures will be implemented:
▪ Resource optimization: Careful planning and allocation of resources will be undertaken to
maximize efficiency. Public sector organizations are required to adhere to resource optimization
principles.
▪ Streamlined processes: Implementation of efficient workflows to reduce overhead costs and
increase productivity. A dedicated project manager is recruited to lead the streamlined
implementation of the project.
▪ Regular monitoring and evaluation: Project progress will be monitored regularly to identify
potential cost overruns or inefficiencies early on and take corrective actions promptly as described
above.
For financial management, the following arrangements have been adopted:
▪ Transparent budgeting: A detailed budgeting process outlines the allocation of financial resources
to different project activities and work packages.
▪ Robust financial management procedures: Implementation of strict controls to ensure
compliance with budgetary allocations and regulatory requirements.
▪ Regular financial reporting: Ongoing monitoring of expenditure against budget to ensure
accountability and transparency.
▪ Flexibility: Provision for adapting to unforeseen circumstances or changes in project requirements
while maintaining cost-effectiveness.
#§FIN-MGT-FM§# #@RSK-MGT-RM@#
#§RSK-MGT-RM§# #§QUA-LIT-QL§# #@IMP-ACT-IA@#
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3. IMPACT
3.1 Impact and ambition
Impact and ambition
Define the short, medium and long-term effects of the project.
Who are the target groups? How will the target groups benefit concretely from the project and what would change for
them? In what way will the gap identified be reduced? How will the activities contribute to improve the situation
(difference between starting point/state of play and the situation after the end of the project?) How will the activities
contribute to the promotion and advancement of gender equality and non-discrimination mainstreaming?
Does the project aim to trigger change/innovation? If so, describe them and the degree of ambition (progress beyond
the status quo).
Note: Results/outcomes are immediate changes that materialise for the target groups after the end of the project
(e.g. improved knowledge, increased awareness). Results/outcomes are different to deliverables. Deliverables are
activities undertaken and outputs produced with the resources allocated to the project, e.g. training courses,
conferences, manuals, video etc.
When defining expected results/outcomes and deliverables please consider if and how they will reduce, maintain, or
increase inequalities between women and men, boys and girls, in all their diversity. What gender, age and disability
differentiated results can be expected? How expected results will affect women and men, boys and girls from a range
of diverse social groups, differently?
The primary target groups include employers, who will receive guidance to enhance organizational
practices and reduce discrimination risks, and national institutions, which will gain expertise to enforce
compliance and guide employers effectively. The project indirectly benefits employees by providing
transparent wage information, empowering them to advocate for fair compensation and address gender-
based disparities. The project aims to trigger change and innovation by introducing novel approaches
to job evaluation and pay transparency in Estonia, fostering stakeholder collaboration to address
systemic gender equality barriers, and promoting cultural shifts towards transparent wage-setting
practices.
Short-term effects: 1) Increased awareness among employers about the requirements of the Wage
Transparency Directive; 2) Enhanced capacity of relevant institutions to provide guidance and support to
employers; 3) Adoption and adaptation of a suitable job evaluation methodology tailored to the Estonian
context.
Medium-term effects: 1) Improved transparency in wage systems and reduced gender wage gap within
organizations; 2) Strengthened enforcement of the Wage Transparency Directive through effective
monitoring and reporting mechanisms; 3) Greater engagement of employers in gender equality
initiatives and commitment to addressing gender pay disparities.
Long-term effects: 1) Sustained reduction of the pay gap in Estonia by establishing industry-standard
practices, which addresses gender and other forms of discrimination, fostering a more equitable society;
2) Establishment of a culture of pay transparency in the workplace, contributing to a more inclusive and
equitable society; 3) Enhanced institutional capacity to address gender and other inequalities in the
labour market, leading to broader societal benefits.
#§IMP-ACT-IA§# #@COM-DIS-VIS-CDV@#
3.2 Communication, dissemination and visibility
Communication, dissemination and visibility of funding
Describe the communication and dissemination activities which are planned in order to promote the activities/results
and maximise the impact (to whom, which format, how many, etc.). Clarify how you will reach the target groups,
relevant stakeholders, policymakers and the general public and explain the choice of the dissemination channels.
Describe how the visibility of EU funding will be ensured.
Communication and dissemination activities should also contribute to the promotion of gender equality and non-
discrimination. Communication materials should use gender inclusive language and positive visual representations.
E.g.: when developing videos or leaflets ensure that women and men, in all their diversity, are equally represented in
a non-stereotypical fashion and portrayed in active empowered roles. In addition, consider using communication
channels that they are accessible to general audience, in particular to persons with disabilities, or people from
marginalised groups.
Communication and dissemination of results are integral parts of the project since its main activities are
oriented towards awareness raising, increasing knowledge, and deeper understanding of the equal pay
for equal work or work of equal value principle. At the inception of the project, a communication and
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Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
dissemination plan will be developed to guide the communication and dissemination activities and
ensure reaching relevant target groups, promoting the project activities, and ensuring the visibility of EU
funding throughout the project.
The main target group for the communication and dissemination activities are employers, as they will be
directly implementing the Directive requirements, i.e. ensuring equal pay for their employees, by among
other things making use of job evaluation and classification systems to ensure pay transparency and
non-discrimination. The communication activities consolidate necessary steps to reach various target
audiences, and rely on existing collaborative contacts and support from organizations working with
different target groups. To reach employers attention and increase their awareness, the strategy will
mostly concentrate on targeted communication via most appropriate channels. This includes, for
example:
• Utilising the social partners: information will be shared to employers’ and HR associations, who will
then disseminate it further to their members. The list includes for example Estonian Employers
Confederation, Estonian Chamber of Commerce and Industry, Estonian Association of SME’s,
Estonian Human Resource Management Association PARE.LinkedIn will be used for social media
communication, utilising potentially the help of the Estonian HR Society - an Estonian LinkedIn
society consisting of around 1,400 persons working in HR.
• LinkedIn will be used for social media communication, utilising potentially the help of the Estonian
HR Society - an Estonian LinkedIn society consisting of around 1,400 persons working in HR
• At least one article will be written to Labour Inspectorate’s magazine ‘Tööelu’ (‘Work Life’)
(available online and on paper). There are 500 subscribers for digital version and 500 for paper
version, while it is also available online for everyone.
• All the project partners will disseminate the relevant information via their webpages and social
media accounts. The main source of information will ultimately be the Tööelu Portaal
(www.tooelu.ee), which had around 1,3 million visits in 2023.
• At least 3 press-releases will be issued to gain additional attention via traditional media to inform
the public about the project, the methodology, the in-person training activities and the e-training.
The specific communication activities related to in-person training activities, i.e attracting employers
attention and recruiting participants, will be designed and implemented by the subcontractor in
cooperation with the project partners.
In addition, the key national institutions responsible for the implementation and enforcement of the
Directive (MKM, TI and Volinik) are a target group of communication and dissemination activities, to
ensure the training and guiding materials will reach the necessary persons who will ultimately be
responsible for monitoring the compliance with the Directive and providing guidance and advice to the
employers. The project partners will ensure the necessary information dissemination in their respective
organisations.
Gender equality, diversity, and equal treatment will be prioritised in all communication activities,
including using inclusive language and visuals, refraining from creating and enforcing stereotypes based
on gender, ethnicity, age, or disability. We ensure accessibility for information by following standards
like WCAG 2.2 and EU standard EN 301 549 (such as adding subtitles to videos). EU funding is clearly
highlighted in all activities to ensure compliance with regulations.
#§COM-DIS-VIS-CDV§# #@SUS-CON-SC@#
3.3 Sustainability and continuation
Sustainability, long-term impact and continuation
Describe the follow-up of the project after the EU funding ends. How will the project impact be ensured and
sustained?
What will need to be done? Which parts of the project should be continued or maintained? How will this be
achieved? Which resources will be necessary to continue the project? How will the results be used?
Are there any possible synergies/complementarities with other (EU funded) activities that can build on the project
results?
The project's sustainability and long-term impact will be ensured through a multifaceted approach.
Continuous support and guidance will be extended to employers to uphold the established practices
beyond the project's duration. This includes ongoing training and capacity-building initiatives to maintain
compliance with the Wage Transparency Directive. The job evaluation methodology and guidelines and
e-training materials will be regularly reviewed and updated as necessary, with resources allocated from
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the national budget to sustain these efforts.
The e-training platform, planned for completion by project's end, will remain accessible and actively
promoted thereafter. Additionally, employee awareness initiatives will be funded through the national
budget to ensure sustained engagement and empowerment.
As part of its sustainability strategy, the project will facilitate a study visit to an EU country where similar
practices have proven successful. This exchange will facilitate knowledge sharing, reinforcement and
establishment of valuable contacts, and insights into best practices for sustaining project outcomes.
Leveraging these connections and fostering collaboration with other EU initiatives will further augment
the project's impact, ensuring its continued effectiveness beyond the funding period. Through strategic
partnerships and network expansion, the project will contribute to fostering a lasting culture of pay
transparency and gender equality in Estonia and beyond.
#§SUS-CON-SC§#
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#@WRK-PLA-WP@#
Subcontracting (n/a for prefixed Lump Sum Grants)
Subcontracting
Give details on subcontracted project tasks (if any) and explain the reasons why (as opposed to direct implementation by the Beneficiaries/Affiliated Entities).
Subcontracting — Subcontracting means the implementation of ‘action tasks’, i.e. specific tasks which are part of the EU grant and are described in Annex 1 of the Grant Agreement.
Note: Subcontracting concerns the outsourcing of a part of the project to a party outside the consortium. It is not simply about purchasing goods or services. We normally expect that the participants
have sufficient operational capacity to implement the project activities themselves. Subcontracting should therefore be exceptional.
Include only subcontracts that comply with the rules (i.e. best value for money and no conflict of interest; no subcontracting of coordinator tasks). Make sure that subcontractors are aware of the
principles of gender mainstreaming and non-discrimination mainstreaming.
Work Package No Subcontract No Subcontract Description Estimated Costs Justification Best-Value-for-Money
(continuous Name (including task number and (EUR) (why is subcontracting (how do you intend to
numbering linked to (subcontracted BEN/AE to which it is linked) necessary?) ensure it?)
WP) action tasks)
2 S1.1 Subcontractor Research, analysis, 60 000 EUR To ensure access to Via a transparent, public
for research, adaptation of gender- experts with specialized procurement process
analysis, neutral job evaluation and It is estimated that the knowledge in gender pay following national
methodology classification methodology cost of analyses will be gap analysis, job legislation and
adaptation and and accompanying guiding 55 000 euros and evaluation methodologies, procurement practices.
developing materials developing of the and comparative research;
necessary guidance material will to mitigate any risks of bias The value for money is
reports and be 5 000 euros. or conflict of interest; to ensured by selecting the
materials use the resources most economically
efficiently. advantageous bid in the
procurement process.
Due to legal regulations for This means that different
avoiding corruption it is not criteria are set during the
possible for a public sector procurement regarding
organization (MKM) to the content of the work,
include a private sector its quality, the
actor with relevant skills as competence of the team,
a partner in the project and other aspects
preparation phase. Thus, necessary to ensure the
the services have to be quality of the work, as
procured during the project well as criteria for the
implementation via a public price. When evaluating
bids, a weighting system
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procurement procedure. is used: 30% for the price
of the bid and 70% for
the substantive quality of
the bid. The first step is
to develop detailed
tender documentation
that outlines the scope
and principles of work,
evaluation criteria, and
expected deliverables.
This will ensure that all
potential bidders have a
clear understanding of
the project requirements
and the evaluation
process. The second
step is to evaluate the
received proposals based
on predefined criteria.
And thirdly the
cooperation in
establishing a monitoring
mechanism (which is
already described in the
tender documents) to
oversee the
implementation of
subcontracted activities.
This will ensure that the
services provided are of
high quality and in line
with the project’s
objectives.
3 S1.2 Subcontractor Design, development and 150 000 EUR Due to the technical Via a transparent, public
for creating in- conduction of in-person complexity of developing procurement process
person and e- and e-training for It is estimated that the and conducting the training following national
trainings for employers, including cost of in-person activities. By engaging legislation and
employers communication activities for training will be approx. external providers, we can procurement practices.
115 000 euros and e- leverage their experience,
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in-person training training 35 000 euros. knowledge, and resources Same process is followed
in delivering effective as described under WP2.
training, ensuring high-
quality content, solutions
and engagement of
participants.
Due to legal regulations for
avoiding corruption it is not
possible for a public sector
organization (MKM) to
include a private sector
actor with relevant skills as
a partner in the project
preparation phase. Thus,
the services have to be
procured during the project
implementation via a public
procurement procedure.
Other issues: Due to legal regulations for avoiding corruption it is not possible for a public sector organization (MKM) to
include a private sector actor with relevant skills for the required tasks as a partner in the project
If subcontracting for the project goes beyond 30% of the total eligible
costs, give specific reasons. preparation phase. Thus, the services have to be procured during the project implementation via a public
procurement procedure
Timetable
Timetable (projects up to 2 years)
Fill in cells in beige to show the duration of activities. Repeat lines/columns as necessary.
Note: Use the project month numbers instead of calendar months. Month 1 marks always the start of the project. In the timeline you should indicate the timing of each activity per WP.
MONTHS
ACTIVITY
M M M M M M M M M M M M M M M M M M M M M M M M
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Task 1.1 - Project
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inception
Task 1.2 - Managing
consortium operations
Task 1.3 - Financial and
administrative
management
Task 1.4 - Quality, data
and ethics management
Task 2.1 - Procurement
for developing the
methodology and
support materials
Task 2.2 - Developing the
methodology and
support materials
Task 2.3 - Selecting the
methodology for Estonia
Task 2.4 - Securing the
licenses and permissions
for the adoption of the
methodology
Task 2.5 - Making the
materials available for
the employers
Task 3.1 - Procurement
of the training activities
Task 3.2 - In-person and
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e-training to employers
Task 4.1 - Awareness
raising training for
institutions
Task 4.2 - Specific
procedural training for
the Labour Inspectorate
#§WRK-
Task 4.3 - Guiding PLA-
WP§#
materials for the Labour
Inspectorate
Task 4.4 - Study trip
Task 5.1 - Development
of communication and
dissemination plan
Task 5.2 -
Communication and
dissemination
management
Task 5.3 - Creating
project website
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Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
#@ETH-ICS-EI@#
5. OTHER
5.1 Ethics and EU values
Ethics and EU values
Describe ethics issues that may arise during the project implementation and the measures you intend to take to
solve/avoid them.
Describe how you will ensure gender and non-discrimination mainstreaming in the project cycle. This means
integrating gender equality and non-discrimination considerations in the design, implementation, monitoring and
evaluation of project activities. Projects activities should be pro-active and contribute to the equal empowerment of
women and men, girls and boys, in all their diversity, and ensure that they achieve their full potential, enjoy the same
rights and opportunities. Gender and non-discrimination mainstreaming are a key mechanism for achieving gender
equality and combating multiple and intersecting discrimination. In the delivery of project activities gender
mainstreaming shall be ensured by systematically monitoring access, participation, and benefits among different
genders, and by incorporating remedial action that redresses any gender inequalities and discriminatory effects in
implementation of planned activities. The activities shall also seek to reduce levels of discrimination suffered by
particular groups (as well as those at risk of multiple discrimination) and to improve equality outcomes for individuals.
If your project has a direct or indirect impact on children and their rights, indicate it clearly here. Make sure that your
project is based on a child rights approach, i.e. that all the rights of the EU Charter of Fundamental Rights and the
United Nations Convention on the Rights of the Child (UNCRC) and the Optional protocols, are promoted, respected,
protected and fulfilled. The project should address children as rights holders and should ensure their participation in
the design and implementation of the project. If you will have direct contacts with children you will have to provide a
child protection policies in line with the Keeping Children Safe Child Safeguarding Standards.
Explain how you intend to address privacy/data protection issues related to data collection, analysis and
dissemination.
Outline measures to be taken and the policies in place to guarantee full compliance with the EU values mentioned in
Article 2 of the Treaty on the European Union and Article 21 of the EU Charter of Fundamental Rights.
The project aims to promote equal treatment and gender equality by contributing to the narrowing of the
gender pay gap, aligning with the EU values (human dignity, freedom, democracy, equality, the rule of
law, and human rights, as well as ensuring non-discrimination) articulated in Article 2 of the Treaty on
the European Union and Article 21 of the EU Charter of Fundamental Rights. The following measures
will ensure strict adherence to these values throughout the project and in relation to the project
outcomes.
Ethic issues:
Bias and fairness: The process of selecting the job evaluation methodology may inadvertently
introduce bias if not conducted rigorously. To mitigate this, the expertise of an outside subcontractor
(procured via transparent process) carrying out the research on potential methodologies will be used.
Comprehensive selection criteria will be established by team with diverse backgrounds and extensive
knowledge on gender equality and non-discrimination. The adaptation of the methodology will consider
the diversity of Estonian labour market and organisation, the cultural norms and applicable legislation.
Equity in access to competence building activities: There might be challenges in ensuring equal
access to training opportunities and receiving information and guidelines, potentially favouring larger
companies, those members of associations or those with more resources. To tackle this, in-person
training will be carried out in various places all over Estonia and a specific communication plan will be
developed to ensure information reaches the entire potential target group. The training will be arranged
in a way to ensure accessibility. In addition, an e-training will be developed to ensure wide reach.
Information related to the outputs of the project will be disseminated in various channels (see section
3.2) with the aim of covering the entire target group. Training materials will accessible and inclusive,
including translations, ensuring compatibility with assistive technologies for individuals with disabilities,
and including examples for various types of companies.
Confidentiality, privacy and safety: Participants' personal information will be safeguarded, ensuring
confidentiality throughout the project (e.g. including training participants names as well as any sensitive
information shared during discussions; consent will be asked when displaying pictures taken during the
project activities). Project partners, as public sector organisations, will strictly adhere to the institutional,
national and EU-level data protection policies and standards and require the same from subcontractors.
Accessibility and catering to the specific physical, cognitive, dietary, and mental needs of the
participants in various project activities is considered in the choice of training and study visit locations,
accommodation arrangements, meal planning and travel arrangements.
Gender and non-discrimination mainstreaming is integral part the project. In fact, the main objective
of the project is to develop outputs that help employers to implement gender mainstreaming activities
into their workplaces. By increasing the competencies of the key national institutions responsible for
20
Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
employment relations and working conditions (thus including equality and non-discrimination in work
life), the project will contribute to gender mainstreaming among the key personnel of the organisations.
All of the project outputs will strive for inclusivity, diversity and equality, with prioritising refraining from
creating and enforcing gender, ethnicity, age, disability and other group-based stereotypes and strive to
debunk said stereotypes. Gender distribution and non-discrimination will be monitored throughout the
project as part of the monitoring and evaluation activities, by setting gender-sensitive indicators and
collecting and analysing data by gender, region, language, etc., to address disparities and ensure
equitable benefits.
#§ETH-ICS-EI§# #@SEC-URI-SU@#
5.2 Security
Security
Not applicable.
#§SEC-URI-SU§# #@DEC-LAR-DL@#
6. DECLARATIONS
Double funding
Information concerning other EU grants for this project
Please note that there is a strict prohibition of double funding from the EU budget (except YES/NO
under EU Synergies actions).
We confirm that to our best knowledge neither the project as a whole nor any parts of it have Yes
benefitted from any other EU grant (including EU funding managed by authorities in EU
Member States or other funding bodies, e.g. EU Regional Funds, EU Agricultural Funds, etc).
If NO, explain and provide details.
We confirm that to our best knowledge neither the project as a whole nor any parts of it are Yes
(nor will be) submitted for any other EU grant (including EU funding managed by authorities
in EU Member States or other funding bodies, e.g. EU Regional Funds, EU Agricultural
Funds, etc). If NO, explain and provide details.
Financial support to third parties (if applicable)
If in your project the maximum amount per third party will be more than the threshold amount set in the Call document,
justify and explain why the higher amount is necessary in order to fulfil your project’s objectives.
NA
#§DEC-LAR-DL§#
21
Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
ANNEXES
LIST OF ANNEXES
Standard
Detailed budget table/Calculator (annex 1 to Part B) — mandatory for Lump Sum Grants (see Portal Reference
Documents)
CVs (annex 2 to Part B) — mandatory, if required in the Call document
Annual activity reports (annex 3 to Part B) — mandatory, if required in the Call document
List of previous projects (annex 4 to Part B) — mandatory, if required in the Call document
Special
Other annexes (annex 5 to Part B) — mandatory, if required in the Call document
22
Project: 101191193— PALK — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
EU Grants: Description of the action (DoA) — Annex 1 (JUST): V1.0 – 25.02.2021
HISTORY OF CHANGES
PUBLICATION
VERSION CHANGE
DATE
1.0 09.04.2024 Initial version.
2.0 19.09.2024 As per the feedback:
• To address the feedback on deliverables, we have made
updates to include additional deliverables for WP1 (mid-term
report), WP3 (final report on training outcomes), and WP4
(training materials for awareness-raising and study trip report),
as well as refined the descriptions for these and other
deliverables to make them more measurable.
• The timeline has been slightly altered to give more flexibility to
conduct research in WP2. However, it must be acknowledged
that the timeline in WP2 is tight to ensure the opportunity to
conduct a sufficient number of training sessions based on the
results of WP2 activities. We take this into account and will
involve the entire team in the preparation of the methodology
procurement to ensure adherence to the schedule. The
timetable in WP3 has been also slightly altered to ensure the
continuation from WP2.
• Budget: the budget under WP1 has been reduced and
distributed to WP2-4 for better reflection of the workload under
each WPs (the project management cost units in WP1 has
been reduced from 12 to 6, units in WP2, WP3, WP4 has been
increased by 2 units. Therefore, now the WP1 represents 7%
of the budget.
• The synergies with similar projects are further explained.
• The subcontracting process is further explained in
subcontracting table and the estimated costs are separated.
• The risk mitigation of Limited participation from a diverse range
of employers in the in-person training sessions is further
explained.
23
Grant Agreement number: 101191193 — Palk — CERV-2024-GE
CERV
Associated Lump
with Sum Ref.
document MGAAres(2024)8072160
— Multi & Mono:-v1.0
13/11/2024
ANNEX 2
ESTIMATED BUDGET (LUMP SUM BREAKDOWN) FOR THE ACTION
Estimated EU contribution
Estimated eligible lump sum contributions (per work package)
WP2 Selection, adaptation, and
WP1 Project management and coordination WP3 Employers’ capacity building WP4 Institutional capacity building WP5 Communication and dissemination Maximum grant amount1
publishing of job evaluation methodology
Forms of funding Lump sum contribution Lump sum contribution Lump sum contribution Lump sum contribution Lump sum contribution
a b c d e f=a+b+c+d+e
1 - MKM 24 315.00 82 095.85 168 765.85 33 448.27 14 846.28 323 471.25
2 - LI 0.00 0.00 0.00 8 233.65 0.00 8 233.65
3 - VOLINIK 0.00 0.00 0.00 3 900.15 0.00 3 900.15
Σ consortium 24 315.00 82 095.85 168 765.85 45 582.07 14 846.28 335 605.05
1 The 'maximum grant amount' is the maximum grant amount fixed in the grant agreement (on the basis of the sum of the beneficiaries' lump sum shares for the work packages).
Page 1 of 1
Grant Agreement number: 101191193 — Palk — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
ANNEX 3
ACCESSION FORM FOR BENEFICIARIES
TOOINSPEKTSIOON (LI), PIC 889079400, established in MAEALUSE TN 2/3, TALLINN
12618, Estonia,
hereby agrees
to become beneficiary
in Agreement No 101191193 — Palk (‘the Agreement’)
between MAJANDUS JA KOMMUNIKATSIOONIMINISTEERIUM (MKM) and the European
Union (‘EU’), represented by the European Commission (‘European Commission’ or ‘granting
authority’),
and mandates
the coordinator to submit and sign in its name and on its behalf any amendments to the Agreement,
in accordance with Article 39.
By signing this accession form, the beneficiary accepts the grant and agrees to implement it in
accordance with the Agreement, with all the obligations and terms and conditions it sets out.
SIGNATURE
For the beneficiary
[--TGSMark#signature-889079400_75_210--]
1
Grant Agreement number: 101191193 — Palk — CERV-2024-GE
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
ANNEX 3
ACCESSION FORM FOR BENEFICIARIES
SOOLISE VORDOIGUSLIKKUSE JA VORDSE KOHTLEMISE VOLINIKU KANTSELEI
(VOLINIK), PIC 917673448, established in Kiriku 4, TALLINN 10130, Estonia,
hereby agrees
to become beneficiary
in Agreement No 101191193 — Palk (‘the Agreement’)
between MAJANDUS JA KOMMUNIKATSIOONIMINISTEERIUM (MKM) and the European
Union (‘EU’), represented by the European Commission (‘European Commission’ or ‘granting
authority’),
and mandates
the coordinator to submit and sign in its name and on its behalf any amendments to the Agreement,
in accordance with Article 39.
By signing this accession form, the beneficiary accepts the grant and agrees to implement it in
accordance with the Agreement, with all the obligations and terms and conditions it sets out.
SIGNATURE
For the beneficiary
[--TGSMark#signature-917673448_75_210--]
2
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
ANNEX 4 XXX LUMP SUM MGA — MULTI & MONO
FINANCIAL STATEMENT FOR THE ACTION FOR REPORTING PERIOD [NUMBER]
EU contribution
Eligible lump sum contributions (per work package)
WP1 [name] WP2 [name] WP3 [name] WP4 [name] WP5 [name] WP6 [name] WP7 [name] WP8 [name] WP9 [name] WP10 [name] WP [XX]
Requested EU contribution
[ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum [ Lump sum
Forms of funding contribution][ Financing not contribution][ Financing contribution][ Financing contribution][ Financing contribution][ Financing not contribution][ Financing contribution][ Financing not contribution][ Financing contribution][ Financing not contribution][ Financing not contribution][ Financing not
linked to costs] not linked to costs] not linked to costs] not linked to costs] linked to costs] not linked to costs] linked to costs] not linked to costs] linked to costs] linked to costs] linked to costs]
Status of completion COMPLETED COMPLETED COMPLETED COMPLETED COMPLETED COMPLETED COMPLETED PARTIALLY COMPLETED PARTIALLY COMPLETED COMPLETED NOT COMPLETED
a b c d e f g h i j k l = a + b+ c + d+ e+ f+ g+ h+ i+ j+ k
1 – [short name beneficiary]
1.1 – [short name affiliated entity]
2 – [short name beneficiary]
2.1 – [short name affiliated entity]
X – [short name associated partner]
Total consortium
The consortium hereby confirms that:
The information provided is complete, reliable and true.
The lump sum contributions declared are eligible (in particular, the work packages have been completed and the work has been properly implemented and/or the results were achieved; see Article 6).
The proper implementation of the action/achievement of the results can be substantiated by adequate records and supporting documentation that will be produced upon request or in the context of checks, reviews, audits and investigations (see Articles 19, 21 and 25).
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
ANNEX 5
SPECIFIC RULES
INTELLECTUAL PROPERTY RIGHTS (IPR) — BACKGROUND AND RESULTS —
ACCESS RIGHTS AND RIGHTS OF USE (— ARTICLE 16)
Rights of use of the granting authority on results for information, communication,
dissemination and publicity purposes
The granting authority also has the right to exploit non-sensitive results of the action for
information, communication, dissemination and publicity purposes, using any of the
following modes:
- use for its own purposes (in particular, making them available to persons working for
the granting authority or any other EU service (including institutions, bodies, offices,
agencies, etc.) or EU Member State institution or body; copying or reproducing them
in whole or in part, in unlimited numbers; and communication through press
information services)
- distribution to the public in hard copies, in electronic or digital format, on the
internet including social networks, as a downloadable or non-downloadable file
- editing or redrafting (including shortening, summarising, changing, correcting,
cutting, inserting elements (e.g. meta-data, legends or other graphic, visual, audio or
text elements extracting parts (e.g. audio or video files), dividing into parts or use in a
compilation
- translation (including inserting subtitles/dubbing) in all official languages of EU
- storage in paper, electronic or other form
- archiving in line with applicable document-management rules
- the right to authorise third parties to act on its behalf or sub-license to third parties,
including if there is licensed background, any of the rights or modes of exploitation set
out in this provision
- processing, analysing, aggregating the results and producing derivative works
- disseminating the results in widely accessible databases or indexes (such as through
‘open access’ or ‘open data’ portals or similar repositories, whether free of charge or
not.
The beneficiaries must ensure these rights of use for the whole duration they are protected by
industrial or intellectual property rights.
If results are subject to moral rights or third party rights (including intellectual property rights
or rights of natural persons on their image and voice), the beneficiaries must ensure that they
1
Associated with document Ref. Ares(2024)8072160 - 13/11/2024
comply with their obligations under this Agreement (in particular, by obtaining the necessary
licences and authorisations from the rights holders concerned).
COMMUNICATION, DISSEMINATION AND VISIBILITY (— ARTICLE 17)
Additional communication and dissemination activities
The beneficiaries must engage in the following additional communication and dissemination
activities:
- present the project (including project summary, coordinator contact details, list of
participants, European flag and funding statement and project results) on the
beneficiaries’ websites or social media accounts
- for actions involving publications, mention the action and the European flag and
funding statement on the cover or the first pages following the editor's mention
- for actions involving public events, display signs and posters mentioning the action and
the European flag and funding statement
- upload the public project results to the Rights and Values Project Results platform,
available through the Funding & Tenders Portal.
2
Digitally sealed by the European Commission
Date: 2024.11.13 22:20:21 CET
This electronic receipt is a digitally signed version of the document submitted by your
organisation. Both the content of the document and a set of metadata have been digitally
sealed.
This digital signature mechanism, using a public-private key pair mechanism, uniquely
binds this eReceipt to the modules of the Funding & Tenders Portal of the European
Commission, to the transaction for which it was generated and ensures its full integrity.
Therefore a complete digitally signed trail of the transaction is available both for your
organisation and for the issuer of the eReceipt.
Any attempt to modify the content will lead to a break of the integrity of the electronic
signature, which can be verified at any time by clicking on the eReceipt validation
symbol.
More info about eReceipts can be found in the FAQ page of the Funding & Tenders
Portal.
(https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/support/faq)
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Koostöökokkulepe nr 8-2/92-1
Majandus- ja Kommunikatsiooniministeerium, registrikood 70003158, asukoht Suur-
Ameerika 1, Tallinn 10122, mida esindab majandus- ja tööstusminister Erkki Keldo (edaspidi
MKM),
Tööinspektsioon, registrikood 70001969, asukoht Mäealuse 2/3, Tallinn 12618, mida esindab
peadirektor Kaire Saarep (edaspidi TI), ja
Soolise võrdõiguslikkuse ja võrdse kohtlemise voliniku kantselei, registrikood 70009155,
asukoht Kiriku 4, Tallinn 10130, mida esindab soolise võrdõiguslikkuse ja võrdse kohtlemise
volinik Christian Veske (edaspidi VOL),
edaspidi nimetatud koos Pooled ja eraldi Pool, sõlmivad alljärgnevas koostöökokkuleppe (edaspidi
leping).
1. Lepingu objekt
1.1. Lepingu objekt on Poolte vahel kohustuste jaotamine viimaks tähtaegselt ja tulemuslikult ellu
projekti „PALK“ (edaspidi projekt) vastavalt Euroopa Liiduga (edaspidi rahastaja) sõlmitud
toetuslepingule, mis on lepingu lisa. Projekti rahastatakse Euroopa Liidu kodanike,
võrdõiguslikkuse, õiguste ja väärtuste programmi CERV 2021-2027 (edaspidi programm)
vahenditest. Grandi kood 9N10-MU21-CERV-PALK.
1.2. Projekt viiakse ellu perioodil 01.01.2025 kuni 31.12.2026.
1.3 Projekti eelarve on 372 895.44 eurot, millest 335 605.05 eurot (90% projekti eelarvest)
moodustavad programmi vahendid ning ülejäänud osa riigieelarvelised vahendid.
2. MKM-i kohustused
2.1. MKM vastutab projektitegevuste koordineerimise ja elluviimise eest.
2.2. MKM vastutab aruandluse esitamise eest rahastajale.
2.3. MKM vastutab projekti elluviimiseks vajalike riigihangete läbiviimise eest.
2.4. MKM korraldab suhtlust Poolte vahel.
2.5. MKM vastutab projekti kommunikatsiooniplaani täitmise eest.
2.6. MKM vastutab info uuendamise eest oma organisatsiooni kohta Portal Participant Registeris.
3. TI kohustused
3.1. TI annab sisendi projektitegevuste elluviimise jaoks.
3.2. TI viib vastavalt projekti ajakavale ellu koolituse TI ametnikele, kes hakkavad tegema
järelevalvet Euroopa Parlamendi ja nõukogu direktiivi (EL) 2023/970, millega tasustamise
läbipaistvuse ja õiguskaitsemehhanismide kaudu tugevdatakse meeste ja naiste võrdse või
võrdväärse töö eest võrdse tasu maksmise põhimõtte kohaldamist (ELT L 132, 17.05.2023, lk 21
–44) nõuete täitmise kohta.
3.3. TI osaleb projektitiimi kohtumistel kord kuus ja pikemal arutelukohtumisel iga poole aasta
tagant.
3.4. TI annab vajadusel sisendi projekti aruandluse jaoks.
2
3.5. TI osaleb projekti kommunikatsiooniplaani täitmises.
3.6. TI vastutab info uuendamise eest oma organisatsiooni kohta Portal Participant Registeris.
3.7. TI kohustub MKM-i teavitama kõikidest temale teadaolevatest asjaoludest, mis võivad
takistada lepingu täitmist.
4. VOL kohustused
4.1. VOL annab sisendi projektitegevuste elluviimise jaoks.
4.2. VOL osaleb projektitiimi kohtumistel kord kuus ja pikemal arutelukohtumisel iga poole aasta
tagant.
4.3. VOL annab vajadusel sisendi projekti aruandluse jaoks.
4.4. VOL osaleb projekti kommunikatsiooniplaani täitmises.
4.5. VOL vastutab info uuendamise eest oma organisatsiooni kohta Portal Participant Registeris.
4.6. VOL kohustub MKM-i teavitama kõikidest temale teadaolevatest asjaoludest, mis võivad
takistada lepingu täitmist.
5. Poolte õigused
5.1. MKM-il on õigus saada TI-lt ja VOL-ltelt projektitegevuste elluviimiseks ja rahastajale
aruannete esitamiseks vajalikku teavet esitatud tähtajaks.
5.2. TI-l ja VOL-l on õigus saada Pooltelt projektis osalemiseks vajalikku informatsiooni.
6. Pooltevahelised teated ja kontaktisikud lepingu täitmisel
6.1. Pooled edastavad kõik lepinguga seotud teated ja ettepanekud Pooltele vähemalt kirjalikku
taasesitamist võimaldavas vormis (e-posti teel).
6.2. Lepinguga seotud informatiivseid teateid võivad Pooled edastada telefoni teel.
6.3. MKM kontaktisik on Helen Talalaev, telefon: +372 5396 7691, e-post:
[email protected].
6.4. TI kontaktisik on Kristel Plangi, telefon: +372 5742 0087, e-post:
[email protected].
6.5. VOL kontaktisik on Kaisa Knight, telefon +372 5556 1326, e-post:
[email protected].
7. Lõppsätted
7.1. Lepingu lahutamatu osa on Lisa: Toetusleping (Grant Agreement).
7.2. Leping kehtib kuni Poolte kõikide lepinguliste kohustuste täitmiseni.
7.3. Pooled lahendavad kõik lepinguga seotud omavahelised erimeelsused ja vaidlused
kokkuleppeliselt.
(allkirjastatud digitaalselt)
3
Majandus- ja Kommunikatsiooniministeerium
Erkki Keldo
(allkirjastatud digitaalselt)
Tööinspektsioon
Kaire Saarep
(allkirjastatud digitaalselt)
Soolise võrdõiguslikkuse ja võrdse kohtlemise volinik
Christian Veske