Ref. Ares(2021)4424103 - 07/07/2021
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR JUSTICE AND CONSUMERS
– Programme and Financial management
mari-liis SEPPER
SIHTASUTUS POLIITIKAUURINGUTE
KESKUS PRAXIS
TARTU MNT 50
10115 TALLINN
ESTONIA
Subject: Rights, Equality and Citizenship Programme
Call: REC-RDIS-DISC-AG-2020
Project: 963357 — HEALTH
GAP invitation letter (from reserve list)
Dear Madam/Sir,
I am writing in connection with your proposal for the above-mentioned call.
As mentioned in our previous letter, your proposal was put on the reserve list. We are pleased to inform
you that we are now in a position to propose your proposal for grant preparation.
Invitation to grant preparation
Grant preparation will be based on the following:
1. Project: 963357 — HEALTH
2. Topic: REC-RDIS-DISC-AG-2020 — Call for proposals to promote the effective implementation of the
principle of non-discrimination
3. Type of action: REC Action Grant
4. Project officer: Natalia MEREANU
Programme and Financial management
Please always use the Funding & Tenders Portal messaging function (via your Portal account). Do NOT contact
us via other means (email, letter, etc.) — unless explicitly asked to do so.
5. Maximum grant amount:
Requested EU contribution (according to proposal): 80 094.20 EUR
Maximum grant amount (proposed amount, after evaluation): 80 094.20 EUR
Please note that the proposed amount may still be lowered during grant preparation.
6. Project duration: 24 months
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Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
7. Grant preparation:
Preparation of grant data & annexes: 3 weeks after receiving this letter
The annexes (description of the action, estimated budget, etc.) must be based on the proposal you submitted
and the clarifications provided (if any). You may normally NOT make changes to the project/project budget/
consortium composition (except if required by us). Please immediately inform the project officer if you need to
make a change (e.g. bankruptcy, etc.).
Please be aware that your proposal may still need to undergo an ethics review or security scrutiny (and the
results will then have to be implemented by you).
Once we have checked the information you have encoded, you will have 2 weeks to submit your final version
— to bring it in line with our comments.
Declaration of honour (DoH): 6 weeks after receiving this letter
Please note that each applicant should also submit a signed and scanned DoH for each one of their linked
third parties.
Signature: within 3 months after receiving this letter (planned date)
Please note that repeated failure to respect deadlines during grant preparation may lead to the rejection of your
proposal (or a consortium member). Lack of cooperation will be taken to mean that you are no longer interested.
8. Funding & Tenders Portal
Grant preparation (including signature) will be done exclusively through the Funding & Tenders Portal electronic
exchange system (login via your Portal account). Do NOT contact us via other means (email, letter, etc.) — unless
explicitly asked to do so.
Please be aware that linked third parties (if allowed) must be registered and validated as legal entities in the Portal
Participant Register. Register them immediately, if not already done.
Please note that some of your legal and financial data in the Participant Register is read-only and can be updated
only by a LEAR (via the Portal My Organisation(s) page). You will therefore be contacted soon to appoint a LEAR
(unless you already have one).
9. Other
Not applicable
For more information on grant preparation, see the Online Manual. You can refer to this document also for
programmes other than H2020 since the procedures are very similar.
Please note that this letter does NOT constitute a formal commitment for funding. The final
decision on your project will only be taken at a later stage, since it depends on the finalisation of
grant preparation and further checks which we still need to make (for instance, financial capacity,
non-exclusion, etc.).
For calls with a limited number of proposals to be funded: If a call can fund only a limited number of
proposals, grant preparation may be moreover be stopped if other proposals move up in the ranking
after a successful evaluation review and re-evaluation procedure.
I would be grateful if you could inform the other members of your consortium (if any) of this letter.
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Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
For any questions, please contact us via your Funding & Tenders Portal account.
Yours faithfully,
Irena MOOZOVA
Director
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Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
Associated with documentJUST/REC MGA — Multi:
Ref. Ares(2021)5425170 v2
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EUROPEAN COMMISSION
Directorate General Justice and Consumers
Programme and Financial management
GRANT AGREEMENT
NUMBER — 963357 — HEALTH
This Agreement (‘the Agreement’) is between the following parties:
on the one part,
the European Union (‘the EU’), represented by the European Commission ('the Commission'),
represented for the purposes of signature of this Agreement by Maria TOMASSETTI, Head of Unit,
Directorate-General for Justice and Consumers, Programme and Financial management,
and
on the other part,
1. ‘the coordinator’:
SIHTASUTUS POLIITIKAUURINGUTE KESKUS PRAXIS (PRAXIS), established in AHTRI
TN 6A, TALLINN 10151, Estonia, VAT number: EE100951538, represented for the purposes of
signing the Agreement by CEO, Urmo Kübar
and the following other beneficiaries, if they sign their ‘Accession Form’ (see Annex 3 and Article 40):
2. EESTI LGBT UHING (LGBT ASSOC.), established in KAARLI PST 5-1, TALLIN 10119,
Estonia,
3. SOTSIAALMINISTEERIUM (MSAE), established in Suur-Ameerika 1, TALLINN 10122,
Estonia,
Unless otherwise specified, references to ‘beneficiary’ or ‘beneficiaries’ include the coordinator.
The parties referred to above have agreed to enter into the Agreement under the terms and conditions
below.
By signing the Agreement or the Accession Form, 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 conditions it sets out.
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
Associated with documentJUST/REC MGA — Multi:
Ref. Ares(2021)5425170 v2
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The Agreement is composed of:
Terms and Conditions
Annex 1 Description of the action
Annex 2 Estimated budget for the action
Annex 2a Not applicable
Annex 3 Accession Forms
Annex 4 Model for the financial statements
Annex 5 Model for the certificate on the financial statements (CFS)
Annex 6 Not applicable
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
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TERMS AND CONDITIONS
TABLE OF CONTENTS
CHAPTER 1 GENERAL ............................................................................................................................................... 8
ARTICLE 1 — SUBJECT OF THE AGREEMENT ....................................................................................... 8
CHAPTER 2 ACTION ...................................................................................................................................................8
ARTICLE 2 — ACTION TO BE IMPLEMENTED ........................................................................................8
ARTICLE 3 — DURATION AND STARTING DATE OF THE ACTION .....................................................8
ARTICLE 4 — ESTIMATED BUDGET AND BUDGET TRANSFERS ....................................................... 8
4.1 Estimated budget .................................................................................................................................... 8
4.2 Budget transfers ..................................................................................................................................... 8
CHAPTER 3 GRANT .................................................................................................................................................... 8
ARTICLE 5 — GRANT AMOUNT, FORM OF GRANT, REIMBURSEMENT RATE AND FORMS OF
COSTS ............................................................................................................................................ 8
5.1 Maximum grant amount .........................................................................................................................8
5.2 Form of grant, reimbursement rates and forms of costs ........................................................................9
5.3 Final grant amount — Calculation ........................................................................................................ 9
5.4 Revised final grant amount — Calculation ......................................................................................... 10
ARTICLE 6 — ELIGIBLE AND INELIGIBLE COSTS ...............................................................................11
6.1 General conditions for costs to be eligible ..........................................................................................11
6.2 Specific conditions for costs to be eligible ......................................................................................... 12
6.3 Conditions for costs of affiliated entities to be eligible ...................................................................... 14
6.4 Ineligible costs ..................................................................................................................................... 14
6.5 Consequences of declaration of ineligible costs ..................................................................................15
CHAPTER 4 RIGHTS AND OBLIGATIONS OF THE PARTIES ........................................................................ 15
SECTION 1 RIGHTS AND OBLIGATIONS RELATED TO IMPLEMENTING THE ACTION ................ 15
ARTICLE 7 — GENERAL OBLIGATION TO PROPERLY IMPLEMENT THE ACTION ........................15
7.1 General obligation to properly implement the action ..........................................................................16
7.2 Consequences of non-compliance ........................................................................................................16
ARTICLE 8 — RESOURCES TO IMPLEMENT THE ACTION — THIRD PARTY INVOLVED IN THE
ACTION ....................................................................................................................................... 16
ARTICLE 8a — IMPLEMENTATION OF ACTION TASKS BY BENEFICIARIES NOT RECEIVING EU
FUNDING .....................................................................................................................................16
ARTICLE 9 — PURCHASE OF GOODS, WORKS OR SERVICES ...........................................................16
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
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9.1 Rules for purchasing goods, works or services ................................................................................... 16
9.2 Consequences of non-compliance ........................................................................................................17
ARTICLE 10 — IMPLEMENTATION OF ACTION TASKS BY SUBCONTRACTORS ...........................17
10.1 Rules for subcontracting action tasks ................................................................................................ 17
10.2 Consequences of non-compliance ......................................................................................................18
ARTICLE 11 — IMPLEMENTATION OF ACTION TASKS BY AFFILIATED ENTITIES .......................18
ARTICLE 11a — FINANCIAL SUPPORT TO THIRD PARTIES ................................................................18
11a.1 Rules for providing financial support to third parties ......................................................................18
11a.2 Financial support in the form of prizes ............................................................................................18
11a.3 Consequences of non-compliance .................................................................................................... 18
SECTION 2 RIGHTS AND OBLIGATIONS RELATED TO THE GRANT ADMINISTRATION .............. 18
ARTICLE 12 — GENERAL OBLIGATION TO INFORM .......................................................................... 18
12.1 General obligation to provide information upon request ...................................................................18
12.2 Obligation to keep information up to date and to inform about events and circumstances likely to
affect the Agreement ..........................................................................................................................19
12.3 Consequences of non-compliance ......................................................................................................19
ARTICLE 13 — KEEPING RECORDS — SUPPORTING DOCUMENTATION ....................................... 19
13.1 Obligation to keep records and other supporting documentation ...................................................... 19
13.2 Consequences of non-compliance ......................................................................................................20
ARTICLE 14 — SUBMISSION OF DELIVERABLES ................................................................................ 20
14.1 Obligation to submit deliverables ...................................................................................................... 20
14.2 Consequences of non-compliance ......................................................................................................21
ARTICLE 15 — REPORTING — PAYMENT REQUESTS ......................................................................... 21
15.1 Obligation to submit reports .............................................................................................................. 21
15.2 Reporting periods ............................................................................................................................... 21
15.2a Request(s) for further pre-financing payment(s) ..............................................................................21
15.3 Periodic reports — Requests for interim payments ...........................................................................21
15.4 Final report — Request for payment of the balance ......................................................................... 21
15.5 Information on cumulative expenditure incurred .............................................................................. 22
15.6 Currency for financial statements and conversion into euro ............................................................. 22
15.7 Language of reports ........................................................................................................................... 23
15.8 Consequences of non-compliance ......................................................................................................23
ARTICLE 16 — PAYMENTS AND PAYMENT ARRANGEMENTS ......................................................... 23
16.1 Payments to be made ......................................................................................................................... 23
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16.2 Pre-financing payment(s) — Amount ................................................................................................23
16.3 Interim payments — Amount — Calculation ................................................................................... 23
16.4 Payment of the balance — Amount — Calculation .......................................................................... 24
16.5 Notification of amounts due .............................................................................................................. 24
16.6 Currency for payments .......................................................................................................................24
16.7 Payments to the coordinator — Distribution to the beneficiaries ......................................................24
16.8 Bank account for payments ............................................................................................................... 25
16.9 Costs of payment transfers ................................................................................................................ 25
16.10 Date of payment ...............................................................................................................................25
16.11 Consequences of non-compliance ....................................................................................................25
ARTICLE 17 — CHECKS, REVIEWS, AUDITS AND INVESTIGATIONS — EXTENSION OF
FINDINGS ....................................................................................................................................26
17.1 Checks, reviews and audits by the Commission ............................................................................... 26
17.2 Investigations by the European Anti-Fraud Office (OLAF) ..............................................................28
17.3 Checks and audits by the European Court of Auditors (ECA) ..........................................................28
17.4 Checks, reviews, audits and investigations for international organisations ....................................... 28
17.5 Consequences of findings in checks, reviews, audits and investigations — Extension of findings
..............................................................................................................................................................28
17.6 Consequences of non-compliance ......................................................................................................30
ARTICLE 18 — EVALUATION OF THE IMPACT OF THE ACTION ...................................................... 30
18.1 Right to evaluate the impact of the action ........................................................................................ 30
18.2 Consequences of non-compliance ......................................................................................................30
SECTION 3 OTHER RIGHTS AND OBLIGATIONS .......................................................................................30
ARTICLE 19 — PRE-EXISTING RIGHTS AND OWNERSHIP OF THE RESULTS (INCLUDING
INTELLECTUAL AND INDUSTRIAL PROPERTY RIGHTS) ................................................ 31
19.1 Pre-existing rights and access rights to pre-existing rights ............................................................... 31
19.2 Ownership of results and rights of use ..............................................................................................31
19.3 Consequences of non-compliance ......................................................................................................31
ARTICLE 20 — CONFLICT OF INTERESTS ............................................................................................. 31
20.1 Obligation to avoid a conflict of interests ......................................................................................... 31
20.2 Consequences of non-compliance ......................................................................................................31
ARTICLE 21 — CONFIDENTIALITY ......................................................................................................... 32
21.1 General obligation to maintain confidentiality .................................................................................. 32
21.2 Consequences of non-compliance ......................................................................................................32
ARTICLE 22 — PROMOTING THE ACTION — VISIBILITY OF EU FUNDING ...................................32
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22.1 Communication activities by the beneficiaries .................................................................................. 32
22.2 Communication activities by the Commission .................................................................................. 33
22.3 Consequences of non-compliance ......................................................................................................34
ARTICLE 23 — PROCESSING OF PERSONAL DATA ............................................................................. 34
23.1 Processing of personal data by the Commission ............................................................................... 34
23.2 Processing of personal data by the beneficiaries ...............................................................................34
23.3 Consequences of non-compliance ......................................................................................................35
ARTICLE 24 — ASSIGNMENTS OF CLAIMS FOR PAYMENT AGAINST THE COMMISSION .......... 35
CHAPTER 5 DIVISION OF BENEFICIARIES’ ROLES AND RESPONSIBILITIES ....................................... 35
ARTICLE 25 — DIVISION OF BENEFICIARIES’ ROLES AND RESPONSIBILITIES ...........................35
25.1 Roles and responsibilities towards the Commission ......................................................................... 35
25.2 Internal division of roles and responsibilities ....................................................................................35
25.3 Internal arrangements between beneficiaries — Consortium agreement ...........................................36
CHAPTER 6 REJECTION OF COSTS — REDUCTION OF THE GRANT — RECOVERY — SANCTIONS
— DAMAGES — SUSPENSION — TERMINATION — FORCE MAJEURE ............................... 37
SECTION 1 REJECTION OF COSTS — REDUCTION OF THE GRANT — RECOVERY —
SANCTIONS .............................................................................................................................................37
ARTICLE 26 — REJECTION OF INELIGIBLE COSTS .............................................................................37
26.1 Conditions ...........................................................................................................................................37
26.2 Ineligible costs to be rejected — Calculation — Procedure ..............................................................37
26.3 Effects .................................................................................................................................................37
ARTICLE 27 — REDUCTION OF THE GRANT ........................................................................................ 37
27.1 Conditions ...........................................................................................................................................38
27.2 Amount to be reduced — Calculation — Procedure .........................................................................38
27.3 Effects .................................................................................................................................................38
ARTICLE 28 — RECOVERY OF UNDUE AMOUNTS ..............................................................................38
28.1 Amount to be recovered — Calculation — Procedure ......................................................................38
ARTICLE 29 — ADMINISTRATIVE SANCTIONS .................................................................................... 41
SECTION 2 LIABILITY FOR DAMAGES ........................................................................................................ 41
ARTICLE 30 — LIABILITY FOR DAMAGES ............................................................................................41
30.1 Liability of the Commission .............................................................................................................. 41
30.2 Liability of the beneficiaries ..............................................................................................................41
SECTION 3 SUSPENSION AND TERMINATION ............................................................................................41
ARTICLE 31 — SUSPENSION OF PAYMENT DEADLINE ...................................................................... 41
31.1 Conditions ...........................................................................................................................................41
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
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31.2 Procedure ............................................................................................................................................ 41
ARTICLE 32 — SUSPENSION OF PAYMENTS .........................................................................................42
32.1 Conditions ...........................................................................................................................................42
32.2 Procedure ............................................................................................................................................ 42
ARTICLE 33 — SUSPENSION OF THE ACTION IMPLEMENTATION .................................................. 43
33.1 Suspension of the action implementation, by the beneficiaries .........................................................43
33.2 Suspension of the action implementation, by the Commission .........................................................43
ARTICLE 34 — TERMINATION OF THE AGREEMENT OR OF THE PARTICIPATION OF ONE OR
MORE BENEFICIARIES ............................................................................................................ 44
34.1 Termination of the Agreement, by the beneficiaries ......................................................................... 45
34.2 Termination of the participation of one or more beneficiaries, by the beneficiaries ..........................45
34.3 Termination of the Agreement or of the participation of one or more beneficiaries, by the
Commission ........................................................................................................................................ 46
SECTION 4 FORCE MAJEURE ..........................................................................................................................49
ARTICLE 35 — FORCE MAJEURE .............................................................................................................49
CHAPTER 7 FINAL PROVISIONS .......................................................................................................................... 50
ARTICLE 36 — COMMUNICATION BETWEEN THE PARTIES ............................................................. 50
36.1 Form and means of communication .................................................................................................. 50
36.2 Date of communication ......................................................................................................................50
36.3 Addresses for communication ............................................................................................................51
ARTICLE 37 — INTERPRETATION OF THE AGREEMENT ................................................................... 51
37.1 Precedence of the Terms and Conditions over the Annexes ............................................................. 51
37.2 Privileges and immunities ..................................................................................................................51
ARTICLE 38 — CALCULATION OF PERIODS, DATES AND DEADLINES .......................................... 51
ARTICLE 39 — AMENDMENTS TO THE AGREEMENT ........................................................................ 51
39.1 Conditions ...........................................................................................................................................51
39.2 Procedure ............................................................................................................................................ 52
ARTICLE 40 — ACCESSION TO THE AGREEMENT .............................................................................. 52
40.1 Accession of the beneficiaries mentioned in the Preamble ............................................................... 52
40.2 Addition of new beneficiaries ............................................................................................................53
ARTICLE 41 — APPLICABLE LAW AND SETTLEMENT OF DISPUTES ............................................. 53
41.1 Applicable law ................................................................................................................................... 53
41.2 Dispute settlement .............................................................................................................................. 53
ARTICLE 42 — ENTRY INTO FORCE OF THE AGREEMENT ............................................................... 54
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
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Ref. Ares(2021)5425170 v2
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CHAPTER 1 GENERAL
ARTICLE 1 — SUBJECT OF THE AGREEMENT
This Agreement sets out the rights and obligations and the terms and conditions applicable to the grant
awarded to the beneficiaries for implementing the action set out in Chapter 2.
CHAPTER 2 ACTION
ARTICLE 2 — ACTION TO BE IMPLEMENTED
The grant is awarded for the action entitled ‘Health Equality, Attitudes towards LGBTQI+ People
and Trans Health Care — HEALTH’ (‘action’), as described in Annex 1.
ARTICLE 3 — DURATION AND STARTING DATE OF THE ACTION
The duration of the action will be 24 months as of 01/11/2021 (‘starting date of the action’).
ARTICLE 4 — ESTIMATED BUDGET AND BUDGET TRANSFERS
4.1 Estimated budget
The ‘estimated budget’ for the action is set out in Annex 2.
It contains the estimated eligible costs and the forms of costs, broken down by beneficiary and budget
category (see Articles 5, 6).
4.2 Budget transfers
The estimated budget breakdown indicated in Annex 2 may be adjusted — without an amendment
(see Article 39) — by transfers of amounts between beneficiaries, budget categories and/or forms of
costs set out in Annex 2, if the action is implemented as described in Annex 1.
However :
- the beneficiaries may not add costs relating to subcontracts not provided for in Annex 1, unless
such additional subcontracts are approved by an amendment or in accordance with Article 10;
- the transfers between budget categories must stay below 20% of the total costs for the action
set out in Annex 2, unless they are approved by an amendment.
CHAPTER 3 GRANT
ARTICLE 5 — GRANT AMOUNT, FORM OF GRANT, REIMBURSEMENT RATE AND
FORMS OF COSTS
5.1 Maximum grant amount
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Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
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The ‘maximum grant amount’ is EUR 80,094.20 (eighty thousand ninety four EURO and twenty
eurocents).
5.2 Form of grant, reimbursement rate and forms of costs
The grant reimburses 80% of the action’s eligible costs (see Article 6) (‘reimbursement of eligible
costs grant’) (see Annex 2).
The estimated eligible costs of the action are EUR 100,117.76 (one hundred thousand one hundred
and seventeen EURO and seventy six eurocents).
Eligible costs (see Article 6) must be declared under the following forms ('forms of costs' or ‘cost
forms’):
(a) for direct personnel costs: as actually incurred costs (‘actual costs’)
(b) for direct travel and subsistence costs: as actually incurred costs (actual costs);
(c) for direct costs of subcontracting: as actually incurred costs (actual costs);
(d) for direct costs of providing financial support to third parties: not applicable;
(e) for other direct costs: as actually incurred costs (‘actual costs’);
(f) for indirect costs: on the basis of a flat-rate applied as set out in Article 6.2.Point F (‘flat-rate
costs’);
5.3 Final grant amount — Calculation
The ‘final grant amount’ depends on the actual extent to which the action is implemented in
accordance with the Agreement’s terms and conditions.
This amount is calculated by the Commission — when the payment of the balance is made — in the
following steps:
Step 1 – Application of the reimbursement rate to the eligible costs
Step 2 – Limit to the maximum grant amount
Step 3 – Reduction due to the no-profit rule
Step 4 – Reduction due to substantial errors, irregularities or fraud or serious breach of obligations
5.3.1 Step 1 — Application of the reimbursement rate to the eligible costs
The reimbursement rate (see Article 5.2) is applied to the eligible costs (actual costs and flat-rate
costs; see Article 6) declared by the beneficiaries (see Article 15) and approved by the Commission
(see Article 16).
5.3.2 Step 2 — Limit to the maximum grant amount
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If the amount obtained following Step 1 is higher than the maximum grant amount set out in
Article 5.1, it will be limited to the latter.
5.3.3 Step 3 — Reduction due to the no-profit rule
The grant must not produce a profit.
‘Profit’ means the surplus of the amount obtained following Steps 1 and 2 plus the action’s total
receipts, over the action’s total eligible costs.
The ‘action’s total eligible costs’ are the consolidated total eligible costs approved by the
Commission.
The ‘action’s total receipts’ are the consolidated total receipts generated during its duration (see
Article 3).
The following are considered receipts:
(a) income generated by the action;
(b) financial contributions given by third parties to the beneficiary, specifically to be used for costs
that are eligible under the action.
The following are however not considered receipts:
(a) financial contributions by third parties, if they may be used to cover costs other than the eligible
costs (see Article 6);
(b) financial contributions by third parties with no obligation to repay any amount unused at the
end of the period set out in Article 3.
If there is a profit, it will be deducted in proportion to the final rate of reimbursement of the eligible
actual costs approved by the Commission (as compared to the amount calculated following Steps 1
and 2).
5.3.4 Step 4 — Reduction due to substantial errors, irregularities or fraud or serious breach of
obligations
If the grant is reduced (see Article 27), the Commission will calculate the reduced grant amount
by deducting the amount of the reduction (calculated in proportion to the seriousness of the errors,
irregularities or fraud or breach of obligations, in accordance with Article 27.2) from the maximum
grant amount set out in Article 5.1.
The final grant amount will be the lower of the following two:
- the amount obtained following Steps 1 to 3 or
- the reduced grant amount following Step 4.
5.4 Revised final grant amount — Calculation
If — after the payment of the balance (in particular, after checks, reviews, audits or investigations;
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see Article 17) — the Commission rejects costs (see Article 26) or reduces the grant (see Article 27),
it will calculate the ‘revised final grant amount’ for the action or for the beneficiary concerned.
This amount is calculated by the Commission on the basis of the findings, as follows:
- in case of rejection of costs: by applying the reimbursement rate to the revised eligible costs
approved by the Commission for the beneficiary concerned;
- in case of reduction of the grant: by deducting the amount of the reduction (calculated in
proportion to the seriousness of the substantial errors, irregularities or fraud or breach of
obligations, in accordance with Article 27.2) from the maximum grant amount set out in
Article 5.1 or from the maximum EU contribution indicated for the beneficiary in the estimated
budget (see Annex 2).
In case of rejection of costs and reduction of the grant, the revised final grant amount will be the
lower of the two amounts above.
ARTICLE 6 — ELIGIBLE AND INELIGIBLE COSTS
6.1 General conditions for costs to be eligible
‘Eligible costs’ are costs that meet the following criteria:
(a) for actual costs:
(i) they must be actually incurred by the beneficiary;
(ii) they must be incurred in the period set out in Article 3, with the exception of costs relating
to the submission of the final report (see Article 15);
(iii) they must be indicated in the estimated budget set out in Annex 2;
(iv) they must be incurred in connection with the action as described in Annex 1 and necessary
for its implementation;
(v) they must be identifiable and verifiable, in particular recorded in the beneficiary’s accounts
in accordance with the accounting standards applicable in the country where the beneficiary
is established and with the beneficiary’s usual cost accounting practices;
(vi) they must comply with the applicable national law on taxes, labour and social security, and
(vii) they must be reasonable, justified and must comply with the principle of sound financial
management, in particular regarding economy and efficiency;
(b) for unit costs: not applicable;
(c) for flat-rate costs:
(i) they must be calculated by applying the flat-rate set out in Annex 2, and
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(ii) the costs (actual costs) to which the flat-rate is applied must comply with the conditions for
eligibility set out in this Article;
(d) for lump sum costs: not applicable.
6.2 Specific conditions for costs to be eligible
Costs are eligible if they comply with the general conditions (see above) and the specific conditions
set out below, for each of the following budget categories:
A. direct personnel costs;
B. direct travel and subsistence costs;
C. direct costs of subcontracting;
D. not applicable;
E. other direct costs.
F. indirect costs.
‘Direct costs’ are costs that are directly linked to the action implementation and can therefore be
attributed to it directly. They must not include any indirect costs (see Point F below).
‘Indirect costs’ are costs that are not directly linked to the action implementation and therefore cannot
be attributed directly to it.
A. Direct personnel costs
Types of eligible personnel costs
A.1 Personnel costs are eligible if they are related to personnel working for the beneficiary under
an employment contract (or equivalent appointing act) and assigned to the action (‘costs for
employees (or equivalent)’). They must be limited to salaries, social security contributions, taxes
and other costs included in the remuneration, if they arise from national law or the employment
contract (or equivalent appointing act).
They may also include additional remuneration for personnel assigned to the action (including
payments on the basis of supplementary contracts regardless of their nature), if:
(a) it is part of the beneficiary’s usual remuneration practices and is paid in a consistent manner
whenever the same kind of work or expertise is required;
(b) the criteria used to calculate the supplementary payments are objective and generally
applied by the beneficiary, regardless of the source of funding used.
A.2 The costs for natural persons working under a direct contract with the beneficiary other than
an employment contract or seconded by a third party against payment are eligible personnel
costs, if:
(a) the person works under the beneficiary’s instructions and, unless otherwise agreed with
the beneficiary, on the beneficiary’s premises;
(b) the result of the work carried out belongs to the beneficiary, and
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(c) the costs are not significantly different from those for personnel performing similar tasks
under an employment contract with the beneficiary.
Calculation
Personnel costs must be calculated by the beneficiaries as follows:
{hourly rate
multiplied by
number of actual hours worked on the action}.
The number of actual hours declared for a person must be identifiable and verifiable (see Article 13).
The total number of hours declared in EU or Euratom grants, for a person for a year, cannot be higher
than the annual productive hours used for the calculations of the hourly rate. Therefore, the maximum
number of hours that can be declared for the grant are:
{number of annual productive hours for the year (see below)
minus
total number of hours declared by the beneficiary, for that person for that year, for other EU or Euratom grants}.
The ‘hourly rate’ is the calculated as follows:
{actual annual personnel costs for the person
divided by
number of individual annual productive hours}.
using the personnel costs and the number of annual productive hours for each full financial year
covered by the reporting period concerned. If a financial year is not closed at the end of the reporting
period, the beneficiaries must use the hourly rate of the last closed financial year available.
The ‘number of individual annual productive hours’ is the total actual hours worked by the person in
the year. It may not include holidays and other absences (such as sick leave, maternity leave, special
leave, etc). However, it may include overtime and hours spent in meetings, trainings and other similar
activities.
B. Direct travel and subsistence costs
Travel and subsistence costs (including related duties, taxes and charges, such as non-deductible
value added tax (VAT) paid by beneficiaries that are not public bodies acting as public authority) are
eligible if they are in line with the beneficiary’s usual practices on travel.
C. Direct costs of subcontracting (including related duties, taxes and charges, such as non-deductible
value added tax (VAT) paid by beneficiaries that areis not public bodies acting as public authority)
are eligible if the conditions in Article 10.1.1 are met.
D. Direct costs of providing financial support to third parties
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Not applicable
E. Other direct costs
E.1 The depreciation costs of equipment, infrastructure or other assets (new or second-hand)
as recorded in the beneficiary’s accounts are eligible, if they were purchased in accordance
with Article 9.1.1 and written off in accordance with international accounting standards and the
beneficiary’s usual accounting practices.
The costs of renting or leasing equipment, infrastructure or other assets (including related duties,
taxes and charges, such as non-deductible value added tax (VAT) paid by beneficiaries that are not
public bodies acting as public authority) are also eligible, if they do not exceed the depreciation
costs of similar equipment, infrastructure or assets and do not include any financing fees.
The only portion of the costs that will be taken into account is that which corresponds to the
duration of the action and rate of actual use for the purposes of the action.
E.2 Costs of other goods and services (including related duties, taxes and charges, such as non-
deductible value added tax (VAT) paid by beneficiaries that are not public bodies acting as public
authority) are eligible, if they are purchased specifically for the action and in accordance with
Article 9.1.1.
Such goods and services include, for instance, consumables and supplies, dissemination,
protection of results, certificates on the financial statements (if they are required by the
Agreement), translations and publications.
F. Indirect costs
Indirect costs are eligible if they are declared on the basis of the flat-rate of 7% of the eligible direct
costs (see Article 5.2 and Points A to E above).
Beneficiaries receiving an operating grant1 financed by the EU or Euratom budget cannot declare
indirect costs for the period covered by the operating grant.
6.3 Conditions for costs of affiliated entities to be eligible
Not applicable
6.4 Ineligible costs
‘Ineligible costs’ are:
(a) costs that do not comply with the conditions set out above (Article 6.1 to 6.3), in particular:
1 For the definition, see Article 121(1)(b) of Regulation (EU, Euratom) No 966/2012 of the European Parliament and
of the Council of 25 October 2012 on the financial rules applicable to the general budget of the Union and repealing
Council Regulation (EC, Euratom) No 1605/2002 (OJ L 218, 26.10.2012, p.1) (‘Financial Regulation No 966/2012’):
‘operating grant’ means direct financial contribution, by way of donation, from the budget in order to finance the
functioning of a body which pursues an aim of general EU interest or has an objective forming part of and supporting
an EU policy.
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(i) costs related to return on capital;
(ii) debt and debt service charges;
(iii) provisions for future losses or debts;
(iv) interest owed;
(v) doubtful debts;
(vi) currency exchange losses;
(vii) bank costs charged by the beneficiary’s bank for transfers from the Commission;
(viii) excessive or reckless expenditure;
(ix) deductible VAT;
(x) costs incurred during suspension of the implementation of the action (see Article 33);
(xi) in-kind contributions provided by third parties;
(b) costs declared under another EU or Euratom grant (including grants awarded by a Member
State and financed by the EU or Euratom budget and grants awarded by bodies other than the
Commission for the purpose of implementing the EU or Euratom budget); in particular, indirect
costs if the beneficiary is already receiving an operating grant financed by the EU or Euratom
budget in the same period;
(c) costs for staff of a national (or local) administration, for activities that are part of the
administration’s normal activities (i.e. not undertaken only because of the grant);
(d) costs (especially travel and subsistence costs) for staff or representatives of EU institutions,
bodies or agencies;
(e) costs for activities that do not take place in one of the eligible countries set out in the call for
proposals — unless approved by the Commission.
6.5 Consequences of declaration of ineligible costs
Declared costs that are ineligible will be rejected (see Article 26).
This may also lead to any of the other measures described in Chapter 6.
CHAPTER 4 RIGHTS AND OBLIGATIONS OF THE PARTIES
SECTION 1 RIGHTS AND OBLIGATIONS RELATED TO IMPLEMENTING THE
ACTION
ARTICLE 7 — GENERAL OBLIGATION TO PROPERLY IMPLEMENT THE ACTION
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7.1 General 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 and all legal obligations under applicable EU, international and national
law.
7.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 8 — RESOURCES TO IMPLEMENT THE ACTION — THIRD PARTY
INVOLVED IN THE ACTION
The beneficiaries must have the appropriate resources to implement the action.
If it is necessary to implement the action, the beneficiaries may:
- purchase goods, works and services (see Article 9);
- call upon subcontractors to implement action tasks described in Annex 1 (see Article 10).
In these cases, the beneficiaries retain sole responsibility towards the Commission and the other
beneficiaries for implementing the action.
ARTICLE 8a — IMPLEMENTATION OF ACTION TASKS BY BENEFICIARIES NOT
RECEIVING EU FUNDING
Not applicable
ARTICLE 9 — PURCHASE OF GOODS, WORKS OR SERVICES
9.1 Rules for purchasing goods, works or services
9.1.1 If necessary to implement the action, the beneficiaries may purchase goods, works or services.
The beneficiaries must make such purchases ensuring the best value for money or, if appropriate, the
lowest price. In doing so, they must avoid any conflict of interests (see Article 20).
The beneficiaries must ensure that the Commission, the European Court of Auditors (ECA) and the
European Anti-Fraud Office (OLAF) can exercise their rights under Articles 17 and 18 also towards
their contractors.
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9.1.2 Beneficiaries that are ‘contracting authorities’ within the meaning of Directive 2004/18/EC2 (or
2014/24/EU3) or ‘contracting entities’ within the meaning of Directive 2004/17/EC4 (or 2014/25/EU5)
must comply with the applicable national law on public procurement.
9.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under Article 9.1.1, the costs related to the contract
concerned will be ineligible (see Article 6) and will be rejected (see Article 26).
If a beneficiary breaches any of its obligations under Article 9.1.2, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 10 — IMPLEMENTATION OF ACTION TASKS BY SUBCONTRACTORS
10.1 Rules for subcontracting action tasks
10.1.1 If necessary to implement the action, the beneficiaries may award subcontracts covering the
implementation of certain action tasks described in Annex 1.
Subcontracting may cover only a limited part of the action.
The beneficiaries must award the subcontracts ensuring the best value for money or, if appropriate,
the lowest price. In doing so, they must avoid any conflict of interests (see Article 20).
The tasks to be implemented and the estimated cost for each subcontract must be set out in Annex 1 and
the total estimated costs of subcontracting per beneficiary must be set out in Annex 2. The Commission
may however approve subcontracts not set out in Annex 1 and 2 without amendment (see Article 39),
if:
- they are specifically justified in the technical report and
- they do not entail changes to the Agreement which would call into question the decision
awarding the grant or breach the principle of equal treatment of applicants.
The beneficiaries must ensure that the subcontracted work is performed in one of the eligible countries
set out in the call for proposals (‘place of performance obligation’) — unless otherwise approved by
the Commission.
2 Directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of
procedures for the award of public work contracts, public supply contracts and public service contracts (OJ L 134,
30.04.2004, p. 114).
3 Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and
repealing Directive 2004/18/EC (OJ L 94, 28.3.2014, p. 65).
4 Directive 2004/17/EC of the European Parliament and of the Council of 31 March 2004 coordinating the procurement
procedures of entities operating in the water, energy, transport and postal services sectors (OJ L 134, 30.04.2004, p. 1).
5 Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities
operating in the water, energy, transport and postal services sectors and repealing Directive 2004/17/EC (OJ L 94,
28.3.2014, p. 243).
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The beneficiaries must ensure that the Commission, the European Court of Auditors (ECA) and the
European Anti-Fraud Office (OLAF) can exercise their rights under Articles 17 and 18 also towards
their subcontractors.
10.1.2 The beneficiaries must ensure that their obligations under Articles 20, 21, 22 and 30 also apply
to the subcontractors.
Beneficiaries that are ‘contracting authorities’ within the meaning of Directive 2004/18/EC (or
2014/24/EU) or ‘contracting entities’ within the meaning of Directive 2004/17/EC (or 2014/25/EU)
must comply with the applicable national law on public procurement.
10.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under Article 10.1.1, the costs related to the subcontract
concerned will be ineligible (see Article 6) and will be rejected (see Article 26).
If a beneficiary breaches any of its obligations under Article 10.1.2, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 11 — IMPLEMENTATION OF ACTION TASKS BY AFFILIATED ENTITIES
Not applicable
ARTICLE 11a — FINANCIAL SUPPORT TO THIRD PARTIES
11a.1 Rules for providing financial support to third parties
Not applicable
11a.2 Financial support in the form of prizes
Not applicable
11a.3 Consequences of non-compliance
Not applicable
SECTION 2 RIGHTS AND OBLIGATIONS RELATED TO THE GRANT
ADMINISTRATION
ARTICLE 12 — GENERAL OBLIGATION TO INFORM
12.1 General obligation to provide information upon request
The beneficiaries must provide — during implementation of the action or afterwards and in accordance
with article 25.2 — any information requested in order to verify eligibility of the costs, proper
implementation of the action and compliance with the other obligations under the Agreement.
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12.2 Obligation to keep information up to date and to inform about events and circumstances
likely to affect the Agreement
Each beneficiary must keep information stored in the Participant Portal Beneficiary Register (via
the electronic exchange system; see Article 36) up to date, in particular, its name, address, legal
representatives, legal form and organisation type.
Each beneficiary must immediately inform the coordinator — which must immediately inform the
Commission and the other beneficiaries — of any of the following:
(a) events which are likely to affect significantly or delay the implementation of the action or the
EU’s financial interests, in particular:
(i) changes in its legal, financial, technical, organisational or ownership situation
(b) circumstances affecting:
(i) the decision to award the grant or
(ii) compliance with requirements under the Agreement.
12.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 13 — KEEPING RECORDS — SUPPORTING DOCUMENTATION
13.1 Obligation to keep records and other supporting documentation
The beneficiaries must — for a period of five years after the payment of the balance — keep records
and other supporting documentation in order to prove the proper implementation of the action and
the costs they declare as eligible.
They must make them available upon request (see Article 12) or in the context of checks, reviews,
audits or investigations (see Article 17).
If there are on-going checks, reviews, audits, investigations, litigation or other pursuits of claims under
the Agreement (including the extension of findings; see Articles 17), the beneficiaries must keep the
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 Commission may accept non-
original documents if they considers that they offer a comparable level of assurance.
13.1.1 Records and other supporting documentation on the technical implementation
The beneficiaries must keep records and other supporting documentation on the technical
implementation of the action, in line with the accepted standards in the respective field.
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13.1.2 Records and other documentation to support the costs declared
The beneficiaries must keep the records and documentation supporting the costs declared, in particular
the following:
(a) for actual costs: adequate records and other supporting documentation to prove the costs
declared, such as contracts, subcontracts, invoices and accounting records. In addition, the
beneficiaries' usual cost accounting practices and internal control procedures must enable direct
reconciliation between the amounts declared, the amounts recorded in their accounts and the
amounts stated in the supporting documentation;
(b) for unit costs: not applicable;
(c) for flat-rate costs: adequate records and other supporting documentation to prove the eligibility
of the costs to which the flat-rate is applied. The beneficiaries do not need to identify the costs
covered or provide supporting documentation (such as accounting statements) to prove the
amount declared at a flat-rate.
(d) for lump sum costs: not applicable.
In addition, for personnel costs (declared as actual costs), the beneficiaries must keep time records
for the number of hours declared. The time records must be in writing and approved by the persons
working on the action and their supervisors, at least monthly. In the absence of reliable time records
of the hours worked on the action, the Commission may accept alternative evidence supporting the
number of hours declared, if it considers that it offers an adequate level of assurance.
As an exception, for persons working exclusively on the action, there is no need to keep time records,
if the beneficiary signs a declaration confirming that the persons concerned have worked exclusively
on the action.
13.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, costs insufficiently substantiated
will be ineligible (see Article 6) and will be rejected (see Article 26), and the grant may be reduced
(see Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 14 — SUBMISSION OF DELIVERABLES
14.1 Obligation to submit deliverables
The coordinator must submit:
- a mid-term progress report on the implementation of the action, within 30 days after half of
the reporting period set out in Article 15.2 has passed;
- the ‘deliverables’ identified in Annex 1, in accordance with the timing and conditions set out
in it.
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14.2 Consequences of non-compliance
If the coordinator breaches any of its obligations under this Article, the Commission may apply any
of the measures described in Chapter 6.
ARTICLE 15 — REPORTING — PAYMENT REQUESTS
15.1 Obligation to submit reports
The coordinator must submit to the Commission (see Article 36) the technical and financial report(s)
set out in this Article. This report includes the request(s) for payment and must be drawn up using the
forms and templates provided in the electronic exchange system (see Article 36).
15.2 Reporting periods
The action has one ‘reporting period’:
- RP1: from month 1 to month 24
15.2a Request(s) for further pre-financing payment(s)
Not applicable
15.3 Periodic reports — Requests for interim payments
Not applicable
15.4 Final report — Request for payment of the balance
The coordinator must submit — within 60 days following the end of the reporting period — a final
report, which includes the request for payment of the balance.
The final report must include the following:
(a) a ‘final technical report’ containing:
(i) an explanation of the work carried out by the beneficiaries;
(ii) an overview of the implementation of the action, including milestones and deliverables
identified in Annex 1.
This report must include explanations justifying the differences between work expected
to be carried out in accordance with Annex 1 and that actually carried out;
(iii) a summary for publication by the Commission;
(iv) the answers to the ‘questionnaire’: not applicable;
(b) a ‘final financial report’ containing:
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(i) an ‘individual financial statement’ (see Annex 4) from each beneficiary, for the
reporting period.
The individual financial statement must detail the eligible costs (actual costs and flat-rate
costs; see Article 6) for each budget category (see Annex 2).
The beneficiaries must declare all eligible costs, even if — for actual costs and flat-
rate costs — they exceed the amounts indicated in the estimated budget (see Annex 2).
Amounts which are not declared in the individual financial statement will not be taken
into account by the Commission.
The individual financial statements must also detail the receipts of the action (see
Article 5.3.3).
Each beneficiary must certify that:
- the information provided is full, reliable and true;
- the costs declared are eligible (see Article 6);
- the costs can be substantiated by adequate records and supporting documentation
(see Article 13) that will be produced upon request (see Article 12) or in the context
of checks, reviews, audits and investigations (see Article 17), and
- that all the receipts have been declared (see Article 5.3.3);
(ii) an explanation of the use of resources and the information on subcontracting (see
Article 10) from each beneficiary, for the reporting period concerned;
(iii) not applicable;
(iv) a ‘final summary financial statement’, created automatically by the electronic exchange
system, consolidating the individual financial statement(s) for the reporting period and
including the request for payment of the balance;
(v) a ‘certificate on the financial statements’ (drawn up in accordance with Annex 5) for
each beneficiary, if:
- it requests an EU contribution of EUR 325 000 or more as reimbursement of actual
costs and
- the maximum EU contribution indicated, for that beneficiary, in the estimated
budget (see Annex 2) as reimbursement of actual costs is EUR 750 000 or more.
15.5 Information on cumulative expenditure incurred
Not applicable
15.6 Currency for financial statements and conversion into euro
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Financial statements must be drafted in euro.
Beneficiaries with accounting established in a currency other than the euro must convert the costs
recorded in their accounts into euro, at the average of the daily exchange rates published in the C series
of the Official Journal of the European Union, calculated over the corresponding reporting period.
If no daily euro exchange rate is published in the Official Journal of the European Union for the
currency in question, they must be converted at the average of the monthly accounting rates published
on the Commission’s website, calculated over the corresponding reporting period.
Beneficiaries with accounting established in euro must convert costs incurred in another currency into
euro according to their usual accounting practices.
15.7 Language of reports
All report(s) (including financial statements) must be submitted in the language of the Agreement.
15.8 Consequences of non-compliance
If the report(s) submitted do not comply with this Article, the Commission may suspend the payment
deadline (see Article 31) and apply any of the other measures described in Chapter 6.
If the coordinator breaches its obligation to submit the report(s) and if it fails to comply with this
obligation within 30 days following a written reminder, the Commission may terminate the Agreement
(see Article 34) or apply any of the other measures described in Chapter 6.
ARTICLE 16 — PAYMENTS AND PAYMENT ARRANGEMENTS
16.1 Payments to be made
The following payments will be made to the coordinator:
- a pre-financing payment;
- one payment of the balance, on the basis of the request for payment of the balance (see
Article 15).
16.2 Pre-financing payment(s) — Amount
The aim of the pre-financing is to provide the beneficiaries with a float.
It remains the property of the EU until the payment of the balance.
The amount of the pre-financing payment will be EUR 64,075.36 (sixty four thousand seventy five
EURO and thirty six eurocents).
The Commission will — except if Article 32 applies — make the pre-financing payment to the
coordinator within 30 days from the accession of all beneficiaries to the Agreement (see Article 40).
16.3 Interim payments — Amount — Calculation
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Not applicable
16.4 Payment of the balance — Amount — Calculation
The payment of the balance reimburses the remaining part of the eligible costs incurred by the
beneficiaries for the implementation of the action.
If the total amount of earlier payments is greater than the final grant amount (see Article 5.3), the
payment of the balance takes the form of a recovery (see Article 28).
If the total amount of earlier payments is lower than the final grant amount, the Commission will pay
the balance within 90 days from receiving the final report (see Article 15.4), except if Articles 31
or 32 apply.
Payment is subject to the approval of the final report. Its approval does not imply recognition of
compliance, authenticity, completeness or correctness of its content.
The amount due as the balance is calculated by the Commission by deducting the total amount of
pre-financing and interim payments (if any) already made, from the final grant amount determined
in accordance with Article 5.3:
{final grant amount (see Article 5.3)
minus
{pre-financing and interim payments (if any) made}}.
If the balance is positive, it will be paid to the coordinator.
The amount to be paid may however be offset — without the beneficiaries’ consent — against any
other amount owed by a beneficiary to the Commission or an executive agency (under the EU or
Euratom budget), up to the maximum EU contribution indicated, for that beneficiary, in the estimated
budget (see Annex 2).
If the balance is negative, it will be recovered from the coordinator (see Article 28).
16.5 Notification of amounts due
When making payments, the Commission will formally notify to the coordinator the amount due,
specifying that it concerns the payment of the balance.
For the payment of the balance, the notification will also specify the final grant amount.
In the case of reduction of the grant or recovery of undue amounts, the notification will be preceded
by the contradictory procedure set out in Articles 27 and 28.
16.6 Currency for payments
The Commission will make all payments in euro.
16.7 Payments to the coordinator — Distribution to the beneficiaries
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Payments will be made to the coordinator.
Payments to the coordinator will discharge the Commission from its payment obligation.
The coordinator must distribute the payments between the beneficiaries without unjustified delay.
16.8 Bank account for payments
All payments will be made to the following bank account:
Name of bank: SWEDBANK AS
Full name of the account holder: POLIITIKAUURINGUTE KESKUS PRAXIS SAPRAXIS
CENTER FOR POLICY STUDIES
Full account number (including bank codes):
IBAN code: EE942200221014881942
16.9 Costs of payment transfers
The cost of the payment transfers is borne as follows:
- the Commission 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.
16.10 Date of payment
Payments by the Commission are considered to have been carried out on the date when they are
debited to its account.
16.11 Consequences of non-compliance
16.11.1 If the Commission does not pay within the payment deadlines (see above), the beneficiaries
are entitled to late-payment interest at the rate applied by the European Central Bank (ECB) for its
main refinancing operations in euros (‘reference rate’), plus three and a half points. The reference rate
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
upon 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).
Suspension of the payment deadline or payments (see Articles 31 and 32) will not be considered as
late payment.
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.
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Late-payment interest is not considered for the purposes of calculating the final grant amount.
16.11.2 If the coordinator breaches any of its obligations under this Article, the grant may be reduced
(see Article 27) and the Agreement or the participation of the coordinator may be terminated (see
Article 34).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 17 — CHECKS, REVIEWS, AUDITS AND INVESTIGATIONS — EXTENSION
OF FINDINGS
17.1 Checks, reviews and audits by the Commission
17.1.1 Right to carry out checks
The Commission will — during the implementation of the action or afterwards — check the proper
implementation of the action and compliance with the obligations under the Agreement, including
assessing deliverables and reports.
For this purpose, the Commission may be assisted by external persons or bodies.
The Commission may also request additional information in accordance with Article 12. The
Commission may request the beneficiaries to provide such information to it directly.
Information provided must be accurate, precise and complete and in the format requested, including
electronic format.
17.1.2 Right to carry out reviews
The Commission may — during the implementation of the action or afterwards — carry out reviews
on the proper implementation of the action (including assessment of deliverables and reports) and
compliance with the obligations under the Agreement.
Reviews may be started up to five years after the payment of the balance. They will be formally
notified to the coordinator or beneficiary concerned and will be considered to have started on the date
of the formal notification.
If the review is carried out on a third party (see Articles 9 to 11a), the beneficiary concerned must
inform the third party.
The Commission may carry out reviews directly (using its own staff) or indirectly (using external
persons or bodies appointed to do so). It will inform the coordinator or beneficiary concerned of the
identity of the external persons or bodies. They have the right to object to the appointment on grounds
of commercial confidentiality.
The coordinator or beneficiary concerned must provide — within the deadline requested — any
information and data in addition to deliverables and reports already submitted (including information
on the use of resources). The Commission may request beneficiaries to provide such information to
it directly.
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The coordinator or beneficiary concerned may be requested to participate in meetings, including with
external experts.
For on-the-spot reviews, the beneficiaries must allow access to their sites and premises, including to
external persons or bodies, 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 ‘review report’ will be drawn up.
The Commission will formally notify the review report to the coordinator or beneficiary concerned,
which has 30 days to formally notify observations (‘contradictory review procedure’).
Reviews (including review reports) are in the language of the Agreement.
17.1.3 Right to carry out audits
The Commission may — during the implementation of the action or afterwards — carry out audits on
the proper implementation of the action and compliance with the obligations under the Agreement.
Audits may be started up to five years after the payment of the balance. They will be formally
notified to the coordinator or beneficiary concerned and will be considered to have started on the date
of the formal notification.
If the audit is carried out on a third party (see Articles 9 to 11a), the beneficiary concerned must inform
the third party.
The Commission may carry out audits directly (using its own staff) or indirectly (using external
persons or bodies appointed to do so). It will inform the coordinator or beneficiary concerned of the
identity of the external persons or bodies. They have the right to object to the appointment on grounds
of commercial confidentiality.
The coordinator or beneficiary concerned must provide — within the deadline requested — any
information (including complete accounts, individual salary statements or other personal data) to
verify compliance with the Agreement. The Commission may request beneficiaries to provide such
information to it directly.
For on-the-spot audits, the beneficiaries must allow access to their sites and premises, including to
external persons or bodies, 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 Commission will formally notify the draft audit report to the coordinator or beneficiary concerned,
which has 30 days to formally notify observations (‘contradictory audit procedure’). This period
may be extended by the Commission in justified cases.
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The ‘final audit report’ will take into account observations by the coordinator or beneficiary
concerned. The report will be formally notified to it.
Audits (including audit reports) are in the language of the Agreement.
The Commission may also access the beneficiaries’ statutory records for the periodical assessment
of flat-rate amounts.
17.2 Investigations by the European Anti-Fraud Office (OLAF)
Under Regulations No 883/20137and No 2185/968 (and in accordance with their provisions and
procedures), the European Anti-Fraud Office (OLAF) may — at any moment during implementation
of the action or afterwards — carry out investigations, including on-the-spot checks and inspections,
to establish whether there has been fraud, corruption or any other illegal activity affecting the financial
interests of the EU.
17.3 Checks and audits by the European Court of Auditors (ECA)
Under Article 287 of the Treaty on the Functioning of the European Union (TFEU) and Article 161 of
the Financial Regulation No 966/20129, the European Court of Auditors (ECA) may — at any moment
during implementation of the action or afterwards — carry out audits.
The ECA has the right of access for the purpose of checks and audits.
17.4 Checks, reviews, audits and investigations for international organisations
Not applicable
17.5 Consequences of findings in checks, reviews, audits and investigations — Extension of
findings
17.5.1 Findings in this grant
Findings in checks, reviews, audits or investigations carried out in the context of this grant may lead
to the rejection of ineligible costs (see Article 26), reduction of the grant (see Article 27), recovery of
undue amounts (see Article 28) or to any of the other measures described in Chapter 6.
Rejection of costs or reduction of the grant after the payment of the balance will lead to a revised final
grant amount (see Article 5.4).
7 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).
8 Council Regulation (Euratom, EC) No 2185/1996 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).
9 Regulation (EU, EURATOM) No 966/2012 of the European Parliament and of the Council of 25 October 2012 on
the financial rules applicable to the general budget of the Union and repealing Council Regulation (EC, EURATOM))
No 1605/2002 (OJ L 298, 26.10.2012, p. 1).
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Findings in checks, reviews, audits or investigations may lead to a request for amendment for the
modification of Annex 1 (see Article 39).
Checks, reviews, audits or investigations that find systemic or recurrent errors, irregularities, fraud or
breach of obligations may also lead to consequences in other EU or Euratom grants awarded under
similar conditions (‘extension of findings from this grant to other grants’).
Moreover, findings arising from an OLAF investigation may lead to criminal prosecution under
national law.
17.5.2 Findings in other grants
The Commission may extend findings from other grants to this grant (‘extension of findings from
other grants to this grant’), if:
(a) the beneficiary concerned is found, in other EU or Euratom 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 — no later than five years after the payment of the balance
of this grant.
The extension of findings may lead to the rejection of costs (see Article 26), reduction of the grant
(see Article 27), recovery of undue amounts (see Article 28), suspension of payments (see Article 32),
suspension of the action implementation (see Article 33) or termination (see Article 34).
17.5.3 Procedure
The Commission will formally notify the beneficiary concerned the systemic or recurrent errors and
its intention to extend these audit findings, together with the list of grants affected.
17.5.3.1 If the findings concern eligibility of costs: the formal 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;
(c) the correction rate for extrapolation established by the Commission 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.
The beneficiary concerned has 90 days from receiving notification to submit observations, revised
financial statements or to propose a duly substantiated alternative correction method. This period
may be extended by the Commission in justified cases.
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The Commission may then start a rejection procedure in accordance with Article 26, either on the
basis of the revised financial statements, the alternative method or the correction rate announced.
17.5.3.2 If the findings concern substantial errors, irregularities or fraud orserious breach of
obligations: the formal notification will include:
(a) an invitation to submit observations on the list of grants affected by the findings and
(b) the flat-rate the Commission intends to apply according to the principle of proportionality.
The beneficiary concerned has 90 days from receiving notification to submit observations or to
propose a duly substantiated alternative flat-rate.
The Commission may then start a reduction procedure in accordance with Article 27, either on the
basis of the alternative flat-rate or the flat-rate announced.
17.6 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, any insufficiently substantiated costs
will be ineligible (see Article 6) and will be rejected (see Article 26).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 18 — EVALUATION OF THE IMPACT OF THE ACTION
18.1 Right to evaluate the impact of the action
The Commission may carry out interim and final evaluations of the impact of the action measured
against the objective of the EU programme.
Evaluations may be started during implementation of the action and up to five years after the
payment of the balance. The evaluation is considered to start on the date of the formal notification
to the coordinator or beneficiaries.
The Commission may make these evaluations directly (using its own staff) or indirectly (using external
bodies or persons it has authorised to do so).
The coordinator or beneficiaries must provide any information relevant to evaluate the impact of the
action, including information in electronic format.
18.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the Commission may apply the
measures described in Chapter 6.
SECTION 3 OTHER RIGHTS AND OBLIGATIONS
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ARTICLE 19 — PRE-EXISTING RIGHTS AND OWNERSHIP OF THE RESULTS
(INCLUDING INTELLECTUAL AND INDUSTRIAL PROPERTY
RIGHTS)
19.1 Pre-existing rights and access rights to pre-existing rights
Where industrial and intellectual property rights (including rights of third parties) exist prior to the
Agreement, the beneficiaries must establish a list of these pre-existing industrial and intellectual
property rights, specifying the owner and any persons that have a right of use.
The coordinator must — before starting the action — submit this list to the Commission.
Each beneficiary must give the other beneficiaries access to any pre-existing industrial and intellectual
property rights needed for the implementation of the action and compliance with the obligations under
the Agreement.
19.2 Ownership of results and rights of use
The results of the action (including the reports and other documents relating to it) are owned by the
beneficiaries.
The beneficiaries must give the Commission the right to use the results for their communication
activities under Article 22.
19.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27).
Such a breach may also lead to any of the other measures described in Chapter 6.
ARTICLE 20 — CONFLICT OF INTERESTS
20.1 Obligation to avoid a conflict of interests
The beneficiaries must take all measures to prevent any situation where the impartial and objective
implementation of the action is compromised for reasons involving economic interest, political or
national affinity, family or emotional ties or any other shared interest (‘conflict of interests’).
They must formally notify to the Commission without delay any situation constituting or likely to
lead to a conflict of interests and immediately take all the necessary steps to rectify this situation.
The Commission may verify that the measures taken are appropriate and may require additional
measures to be taken by a specified deadline.
20.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27) and the Agreement may be terminated (see Article 34).
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Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 21 — CONFIDENTIALITY
21.1 General obligation to maintain confidentiality
During implementation of the action and for five years after the payment of the balance, the
parties must keep confidential any data, documents or other material (in any form) that is identified
as confidential at the time it is disclosed (‘confidential information’).
They may use confidential information to implement the Agreement.
The confidentiality obligations no longer apply if:
(a) the disclosing party agrees to release the other party;
(b) the information becomes generally and publicly available, without breaching any
confidentiality obligation;
(c) the disclosure of the confidential information is required by EU or national law.
21.2 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 22 — PROMOTING THE ACTION — VISIBILITY OF EU FUNDING
22.1 Communication activities by the beneficiaries
22.1.1 General obligation to promote the action and its results
The beneficiaries must promote the action and its results.
22.1.2 Information on EU funding — Obligation and right to use the EU emblem
Unless the Commission requests or agrees otherwise, any communication activity related to the action
(including at conferences, seminars, in information material, such as brochures, leaflets, posters,
presentations, etc., in electronic form, via social media, etc.) and any infrastructure, equipment or
major result funded by the grant must:
- display the EU emblem and
- include the following text:
“This [insert appropriate description, e.g. report, publication, conference, infrastructure, equipment, insert
type of result, etc.] was funded by the European Union’s Rights, Equality and Citizenship Programme
(2014-2020).”
When displayed in association with another logo, the EU emblem must have appropriate prominence.
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For the purposes of their obligations under this Article, the beneficiaries may use the EU emblem
without first obtaining approval from the Commission.
This does not, however, give them the right to exclusive use.
Moreover, they may not appropriate the EU emblem or any similar trademark or logo, either by
registration or by any other means.
22.1.3 Disclaimer excluding Commission responsibility
Any communication activity related to the action must indicate the following disclaimer:
“The content of this [insert appropriate description, e.g. report, publication, conference, etc.] represents the
views of the author only and is his/her sole responsibility. The European Commission does not accept any
responsibility for use that may be made of the information it contains.”
22.2 Communication activities by the Commission
22.2.1 Right to use beneficiaries’ materials, documents or information
The Commission may use information relating to the action, documents notably summaries for
publication and public deliverables as well as any other material, such as pictures or audio-visual
material received from any beneficiary (including in electronic form).
This does not change the confidentiality obligations in Article 21, which still apply.
The right to use a beneficiary’s materials, documents and information includes:
(a) use for its own purposes (in particular, making them available to persons working for the
Commission or any other EU institution, body, office or agency or body or institutions in EU
Member States; and copying or reproducing them in whole or in part, in unlimited numbers);
(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 for communication and publicising activities (including shortening,
summarising, inserting other elements (such as 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) giving access in response to individual requests under Regulation No 1049/200110, without
the right to reproduce or exploit;
(f) storage in paper, electronic or other form;
10 Regulation (EC) No 1049/2001 of the European Parliament and of the Council of 30 May 2001 regarding public access
to European Parliament, Council and Commission documents, OJ L 145, 31.5.2001, p. 43.
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(g) archiving, in line with applicable document-management rules, and
(h) the right to authorise third parties to act on its behalf or sub-license the modes of use set out
in Points (b), (c), (d) and (f) to third parties if needed for the communication and publicising
activities of the Commission.
If the right of use is subject to rights of a third party (including personnel of the beneficiary), the
beneficiary must ensure that it complies with its obligations under this Agreement (in particular, by
obtaining the necessary approval from the third parties concerned).
Where applicable (and if provided by the beneficiaries), the Commission will insert the following
information:
“© – [year] – [name of the copyright owner]. All rights reserved. Licensed to the European Union (EU)
under conditions.”
22.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under this Article, the grant may be reduced (see
Article 27).
Such breaches may also lead to any of the other measures described in Chapter 6.
ARTICLE 23 — PROCESSING OF PERSONAL DATA
23.1 Processing of personal data by the Commission
Any personal data under the Agreement will be processed by the Commission under Regulation
No 45/200111 and according to the ‘notifications of the processing operations’ to the Data Protection
Officer (DPO) of the Commission (publicly accessible in the DPO register).
Such data will be processed by the ‘data controller’ of the Commission for the purposes of
implementing, managing and monitoring the Agreement or protecting the financial interests of the
EU or Euratom (including checks, reviews, audits and investigations; see Article 17).
The persons whose personal data are processed have the right to access and correct their own personal
data. For this purpose, they must send any queries about the processing of their personal data to the
data controller, via the contact point indicated in the privacy statement(s) on the Commission websites.
They also have the right to have recourse at any time to the European Data Protection Supervisor
(EDPS).
23.2 Processing of personal data by the beneficiaries
The beneficiaries must process personal data under the Agreement in compliance with applicable EU
and national law on data protection (including authorisations or notification requirements).
11 Regulation (EC) No 45/2001 of the European Parliament and of the Council of 18 December 2000 on the protection
of individuals with regard to the processing of personal data by the Community institutions and bodies and on the free
movement of such data (OJ L 8, 12.01.2001, p. 1).
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The beneficiaries may grant their personnel access only to data that is strictly necessary for
implementing, managing and monitoring the Agreement.
The beneficiaries must inform the personnel whose personal data are collected and processed by the
Commission. For this purpose, they must provide them with the privacy statement(s) (see above),
before transmitting their data to the Commission.
23.3 Consequences of non-compliance
If a beneficiary breaches any of its obligations under Article 23.2, the Commission may apply any of
the measures described in Chapter 6.
ARTICLE 24 — ASSIGNMENTS OF CLAIMS FOR PAYMENT AGAINST THE
COMMISSION
The beneficiaries may not assign any of their claims for payment against the Commission to any
third party, except if approved by the Commission on the basis of a reasoned, written request by the
coordinator (on behalf of the beneficiary concerned).
If the Commission has not accepted the assignment or 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
Commission.
CHAPTER 5 DIVISION OF BENEFICIARIES’ ROLES AND RESPONSIBILITIES
ARTICLE 25 — DIVISION OF BENEFICIARIES’ ROLES AND RESPONSIBILITIES
25.1 Roles and responsibilities towards the Commission
The beneficiaries have full responsibility for implementing the action and complying with the
Agreement.
The beneficiaries are jointly and severally liable for the technical implementation of the action as
described in Annex 1. If a beneficiary fails to implement its part of the action, the other beneficiaries
become responsible for implementing this part (without being entitled to any additional EU funding
for doing so), unless the Commission expressly relieves them of this obligation.
The financial responsibility of each beneficiary is governed by Articles 28, 29 and 30.
25.2 Internal division of roles and responsibilities
The internal roles and responsibilities of the beneficiaries are divided as follows:
(a) Each beneficiary must:
(i) keep information stored in the Participant Portal Beneficiary Register (via the electronic
exchange system) up to date (see Article 12);
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(ii) inform the coordinator immediately of any events or circumstances likely to affect
significantly or delay the implementation of the action (see Article 12);
(iii) submit to the coordinator in good time:
- individual financial statement(s) for itself and, if required, certificates on the
financial statement(s) (see Article 15);
- the data needed to draw up the technical report(s) (see Article 15);
- any other documents or information required by the Commission under the
Agreement, unless the Agreement requires the beneficiary to submit this
information directly.
(b) The coordinator must:
(i) monitor that the action is implemented properly (see Article 7);
(ii) act as the intermediary for all communications between the beneficiaries and the
Commission (in particular, providing the Commission with the information described in
Article 12), unless the Agreement specifies otherwise;
(iii) provide a pre-financing guarantee if requested by the Commission (see Article 16.2);
(iv) request and review any documents or information required by the Commission and verify
their completeness and correctness before passing them on to the Commission;
(v) submit the deliverables and report(s) to the Commission (see Articles 14 and 15);
(vi) ensure that all payments are made to the other beneficiaries without unjustified delay (see
Article 16);
The coordinator may not subcontract the above-mentioned tasks.
25.3 Internal arrangements between beneficiaries — Consortium agreement
The beneficiaries must have internal arrangements regarding their operation and co-ordination to
ensure that the action is implemented properly. These internal arrangements must be set out in a written
‘consortium agreement’ between the beneficiaries, which may cover:
- internal organisation of the consortium;
- management of access to the electronic exchange system;
- distribution of EU funding;
- additional rules on rights and obligations related to pre-existing rights and results (see
Article 19);
- settlement of internal disputes;
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- liability, indemnification and confidentiality arrangements between the beneficiaries.
The consortium agreement must not contain any provision contrary to the Agreement.
CHAPTER 6 REJECTION OF COSTS — REDUCTION OF THE GRANT — RECOVERY
— PENALTIES — DAMAGES — SUSPENSION — TERMINATION —
FORCE MAJEURE
SECTION 1 REJECTION OF COSTS — REDUCTION OF THE GRANT — RECOVERY
— PENALTIES
ARTICLE 26 — REJECTION OF INELIGIBLE COSTS
26.1 Conditions
The Commission will — at the payment of the balance or afterwards — reject any costs which
are ineligible (see Article 6), in particular following checks, reviews, audits or investigations (see
Article 17).
The rejection may also be based on the extension of findings from other grants to this grant (see
Article 17.5.2).
26.2 Ineligible costs to be rejected — Calculation — Procedure
Ineligible costs will be rejected in full.
If the rejection of costs does not lead to a recovery (see Article 28), the Commission will formally
notify the coordinator or beneficiary concerned of the rejection of costs, the amounts and the reasons
why (if applicable, together with the notification of amounts due; see Article 16.5). The coordinator
or beneficiary concerned may — within 30 days of receiving notification — formally notify the
Commission of its disagreement and the reasons why.
If the rejection of costs leads to a recovery, the Commission will follow the contradictory procedure
with pre-information letter set out in Article 28.
26.3 Effects
If the Commission rejects costs at the payment of the balance, it will deduct them from the total
eligible costs declared, for the action, in the final summary financial statement (see Article 15.3 and
15.4). It will then calculate payment of the balance as set out in Article 16.3 or 16.4.
If the Commission rejects costs after the payment of the balance, it will deduct the amount rejected
from the total eligible costs declared, by the beneficiary, in the final summary financial statement. It
will then calculate the revised final grant amount as set out in Article 5.4. If the revised final grant
amount is lower than the final grant amount, the Commission will recover the difference (see Article
28).
ARTICLE 27 — REDUCTION OF THE GRANT
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27.1 Conditions
The Commission may — at the payment of the balance or afterwards — reduce the grant, if:
(a) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed:
(i) substantial errors, irregularities or fraud or
(ii) serious breach of obligations under the Agreement or during the award procedure
(including improper implementation of the action, submission of false information,
failure to provide required information, breach of ethical principles) or
(b) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed — in other EU or Euratom 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 from other grants to this grant; see
Article 17.5.2).
27.2 Amount to be reduced — Calculation — Procedure
The amount of the reduction will be proportionate to the seriousness of the errors, irregularities or
fraud or breach of obligations.
Before reduction of the grant, the Commission will formally notify a ‘pre-information letter’ to the
coordinator or beneficiary concerned:
- informing it of its intention to reduce the grant, the amount it intends to reduce and the reasons
why and
- inviting it to submit observations within 30 days of receiving notification
If the Commission does not receive any observations or decides to pursue reduction despite the
observations it has received, it will formally notify confirmation of the reduction (if applicable,
together with the notification of amounts due; see Article 16).
27.3 Effects
If the Commission reduces the grant at the time of the payment of the balance, it will calculate the
reduced grant amount for the action and then determine the amount due as payment of the balance
(see Articles 5.3.4 and 16.4).
If the Commission reduces the grant after the payment of the balance, it will calculate the revised
final grant amount for the action or for the beneficiary concerned (see Article 5.4). If the revised final
grant amount is lower than the final grant amount, the Commission will recover the difference (see
Article 28).
ARTICLE 28 — RECOVERY OF UNDUE AMOUNTS
28.1 Amount to be recovered — Calculation — Procedure
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The Commission will — at the payment of the balance or afterwards — claim back amount that
was paid but is not due under the Agreement.
The coordinator is fully liable for repaying debts of the consortium (under the Agreement), even if it
has not been the final recipient of those amounts.
In addition, the beneficiaries (including the coordinator) are jointly and severally liable for repaying
any debts under the Agreement (including late-payment interest) — up to the maximum EU
contribution indicated, for each beneficiary, in the estimated budget (as last amended; see Annex 2).
28.1.1 Recovery at payment of the balance
If the payment of the balance takes the form of a recovery (see Article 16.4), the Commission will
formally notify a ‘pre-information letter’ to the coordinator:
- informing it of its intention to recover, the amount due as the balance and the reasons why and
- inviting the coordinator to submit observations within 30 days of receiving notification.
If no observations are submitted or the Commission decides to pursue recovery despite the
observations it has received, it will confirm the amount to be recovered and formally notify to the
coordinator a debit note with the terms and the date for payment (together with the notification of
amounts due; see Article 16.5).
If payment is not made by the date specified in the debit note, the Commission will recover the
amount:
(a) by ‘offsetting’ it — without the coordinator’s consent — against any amounts owed to the
coordinator by the Commission or an executive agency (from the EU or Euratom budget).
In exceptional circumstances, to safeguard the EU’s financial interests, the Commission may
offset before the payment date specified in the debit note;
(b) not applicable;
(c) by holding the other beneficiaries jointly and severally liable — up to the maximum EU
contribution indicated, for each beneficiary, in the estimated budget (as last amended; see
Annex 2)
(d) by taking legal action (see Article 41) or by adopting an enforceable decision under
Article 299 of the Treaty on the Functioning of the EU (TFEU) and Article 79(2) of the
Financial Regulation No 966/2012.
If payment is not made by the date in the debit note, the amount to be recovered (see above) will be
increased by late-payment interest at the rate set out in Article 16.11, from the day following the
payment date in the debit note, up to and including the date the Commission receives full payment
of the amount.
Partial payments will be first credited against expenses, charges and late-payment interest and then
against the principal.
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Bank charges incurred in the recovery process will be borne by the beneficiary, unless
Directive 2007/64/EC applies.
28.1.2 Recovery of amounts after payment of the balance
If — after the payment of the balance — the Commission revised the final grant amount for the
action or for the beneficiary concerned (see Article 5.4), due to a rejection of costs or reduction of
the grant, and the revised final grant amount is lower than the final grant amount (see Article 5.3),
the Commission will:
- if the rejection or reduction does not concern a specific beneficiary: claim back the difference
from the coordinator (even if it has not been the final recipient of the amount in question)
or
- otherwise: claim back the difference from the beneficiary concerned.
The Commission will formally notify a pre-information letter to the coordinator or beneficiary
concerned:
- informing it of its intention to recover, the amount to be repaid and the reasons why and
- inviting it to submit observations within 30 days of receiving notification.
If no observations are submitted or the Commission decides to pursue recovery despite the
observations it has received, it will confirm the amount to be recovered and formally notify to the
coordinator or beneficiary concerned a debit note. This note will also specify the terms and the date
for payment.
If payment is not made by the date specified in the debit note, the Commission will recover the
amount:
(a) by ‘offsetting’ it — without the coordinator's or beneficiary’s consent — against any amounts
owed to the coordinator or beneficiary concerned by the Commission or an executive agency
(from the EU or Euratom budget).
In exceptional circumstances, to safeguard the EU’s financial interests, the Commission may
offset before the payment date specified in the debit note;
(b) by holding the other beneficiaries jointly and severally liable, up to the maximum EU
contribution indicated, for each beneficiary, in the estimated budget (as last amended; see
Annex 2);
(c) by taking legal action (see Article 41) or by adopting an enforceable decision under
Article 299 of the Treaty on the Functioning of the EU (TFEU) and Article 79(2) of the
Financial Regulation No 966/2012.
If payment is not made by the date in the debit note, the amount to be recovered (see above) will be
increased by late-payment interest at the rate set out in Article 16.11, from the day following the
date for payment in the debit note, up to and including the date the Commission receives full payment
of the amount.
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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 2007/64/EC applies.
ARTICLE 29 — ADMINISTRATIVE SANCTIONS
In addition to contractual measures, the Commission may also adopt administrative sanctions under
Articles 106 and 131(4) of the Financial Regulation No 966/2012 (i.e. exclusion from future
procurement contracts, grants and expert contracts and/or financial penalties).
SECTION 2 LIABILITY FOR DAMAGES
ARTICLE 30 — LIABILITY FOR DAMAGES
30.1 Liability of the Commission
The Commission cannot be held liable for any damage caused to the beneficiaries or to third parties
as a consequence of implementing the Agreement, including for gross negligence.
The Commission cannot be held liable for any damage caused by any of the beneficiaries or third
parties involved in the action, as a consequence on implementing the Agreement.
30.2 Liability of the beneficiaries
Except in case of force majeure (see Article 35), the beneficiaries must compensate the Commission
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.
SECTION 3 SUSPENSION AND TERMINATION
ARTICLE 31 — SUSPENSION OF PAYMENT DEADLINE
31.1 Conditions
The Commission may — at any moment — suspend the payment deadline (see Article 16.2 to 16.4)
if a request for payment (see Article 15) cannot be approved because:
(a) it does not comply with the provisions of the Agreement (see Article 15);
(b) the technical or financial report(s) have not been submitted or are not complete or additional
information is needed, or
(c) there is doubt about the eligibility of the costs declared in the financial statements and additional
checks, reviews, audits or investigations are necessary.
31.2 Procedure
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The Commission will formally notify the coordinator of the suspension and the reasons why.
The suspension will take effect the day notification is sent by the Commission (see Article 36).
If the conditions for suspending the payment deadline are no longer met, the suspension will be lifted
— and the remaining period will resume.
If the suspension exceeds two months, the coordinator may request the Commission if the suspension
will continue.
If the payment deadline has been suspended due to the non-compliance of the technical or financial
report(s) (see Article 15) and the revised report or statement is not submitted or was submitted but is
also rejected, the Commission may also terminate the Agreement or the participation of the beneficiary
(see Article 34.3.1(i)).
ARTICLE 32 — SUSPENSION OF PAYMENTS
32.1 Conditions
The Commission may — at any moment — suspend payments, in whole or in part for one or more
beneficiaries, if:
(a) a beneficiary (or a natural person who has the power to represent or take decision on its behalf)
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 the award procedure
(including improper implementation of the action, submission of false information,
failure to provide required information, breach of ethical principles), or
(b) a beneficiary (or a natural person who has the power to represent or take decision on its behalf)
has committed — in other EU or Euratom 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 from other grants to this grant; see
Article 17.5.2).
If payments are suspended for one or more beneficiaries, the Commission will make partial payment(s)
for the part(s) not suspended. If suspension concerns the payment of the balance, the payment (or
recovery) of the amount(s) concerned after suspension is lifted will be considered to be the payment
that closes the action.
32.2 Procedure
Before suspending payments, the Commission will formally notify the coordinator or beneficiary
concerned:
- informing it of its intention to suspend payments and the reasons why and
- inviting it to submit observations within 30 days of receiving notification.
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If the Commission does not receive observations or decides to pursue the procedure despite the
observations it has received, it will formally notify confirmation of the suspension. Otherwise, it will
formally notify that the suspension procedure is not continued.
The suspension will take effect the day the confirmation notification is sent by the Commission.
If the conditions for resuming payments are met, the suspension will be lifted. The Commission will
formally notify the coordinator or beneficiary concerned.
The beneficiaries may suspend implementation of the action (see Article 33.1) or terminate the
Agreement or the participation of the beneficiary concerned (see Article 34.1 and 34.2).
ARTICLE 33 — SUSPENSION OF THE ACTION IMPLEMENTATION
33.1 Suspension of the action implementation, by the beneficiaries
33.1.1 Conditions
The beneficiaries may suspend implementation of the action or any part of it, if exceptional
circumstances — in particular force majeure (see Article 35) — make implementation impossible or
excessively difficult.
33.1.2 Procedure
The coordinator must immediately formally notify to the Commission the suspension (see Article 36),
stating:
- the reasons why and
- the expected date of resumption.
The suspension will take effect the day this notification is received by the Commission.
Once circumstances allow for implementation to resume, the coordinator must immediately formally
notify the Commission and request an amendment of the Agreement to set the date on which the
action will be resumed, extend the duration of the action and make other changes necessary to adapt
the action to the new situation (see Article 39) — unless the Agreement or the participation of a
beneficiary has been terminated (see Article 34).
The suspension will be lifted with effect from the resumption date set out in the amendment. This
date may be before the date on which the amendment enters into force.
Costs incurred during suspension of the action implementation are not eligible (see Article 6).
33.2 Suspension of the action implementation, by the Commission
33.2.1 Conditions
The Commission may suspend implementation of the action or any part of it, if:
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(a) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
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 the award procedure
(including improper implementation of the action, submission of false declaration,
failure to provide required information, breach of ethical principles) or
(b) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed — in other EU or Euratom 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 from other grants to this grant; see
Article 17.5.2).
33.2.2 Procedure
Before suspending implementation of the action, the Commission will formally notify the coordinator
or beneficiary concerned:
- informing it of its intention to suspend the implementation and the reasons why and
- inviting it to submit observations within 30 days of receiving notification.
If the Commission does not receive observations or decides to pursue the procedure despite the
observations it has received, it will formally notify confirmation of the suspension. Otherwise, it will
formally notify that the procedure is not continued.
The suspension will take effect five days after confirmation notification is received (or on a later date
specified in the notification).
It will be lifted if the conditions for resuming implementation of the action are met.
The coordinator or beneficiary concerned will be formally notified of the lifting and the Agreement
will be amended to set the date on which the action will be resumed, extend the duration of the action
and make other changes necessary to adapt the action to the new situation (see Article 39) — unless
the Agreement has already been terminated (see Article 34).
The suspension will be lifted with effect from the resumption date set out in the amendment. This date
may be before the date on which the amendment enters into force.
Costs incurred during suspension are not eligible (see Article 6).
The beneficiaries may not claim damages due to suspension by the Commission (see Article 30).
Suspension of the action implementation does not affect the Commission's right to terminate the
Agreement or participation of a beneficiary (see Article 34), reduce the grant or recover amounts
unduly paid (see Articles 27 and 28).
ARTICLE 34 — TERMINATION OF THE AGREEMENT OR OF THE PARTICIPATION
OF ONE OR MORE BENEFICIARIES
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34.1 Termination of the Agreement by the beneficiaries
34.1.1 Conditions and procedure
The beneficiaries may terminate the Agreement.
The coordinator must formally notify termination to the Commission (see Article 36), stating:
- the reasons why and
- the date the termination will take effect. This date must be after the notification.
If no reasons are given or if the Commission considers the reasons do not justify termination, the
Agreement will be considered to have been ‘terminated improperly’.
The termination will take effect on the day specified in the notification.
34.1.2 Effects
The coordinator must — within 60 days from when termination takes effect — submit the final report
(see Article 15.4).
If the Commission does not receive the report(s) within the deadline (see above), no costs will be
taken into account.
The Commission will calculate the final grant amount (see Article 5.3) and the balance (see
Article 16.4) on the basis of the report(s) submitted. Only costs incurred until termination are eligible
(see Article 6). Costs relating to contracts due for execution only after termination are not eligible.
Improper termination may lead to a reduction of the grant (see Article 27).
After termination, the beneficiaries’ obligations (in particular, Articles 15, 17, 18, 19, 21, 22, 24, 26,
27 and 28) continue to apply.
34.2 Termination of the participation of one or more beneficiaries, by the beneficiaries
34.2.1 Conditions and procedure
The participation of one or more beneficiaries may be terminated by the coordinator, on request of
the beneficiary concerned or on behalf of the other beneficiaries.
The coordinator must formally notify termination to the Commission (see Article 36) and inform the
beneficiary concerned.
If the coordinator’s participation is terminated without its agreement, the formal notification must be
done by another beneficiary (acting on behalf of the other beneficiaries).
The notification must include:
- 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 termination takes effect. This date must be after the notification, and
- a request for amendment (see Article 39), with a proposal for reallocation of the tasks and the
estimated budget of the beneficiary concerned (see Annexes 1 and 2) and, if necessary, the
addition of one or more new beneficiaries (see Article 40). If termination takes effect after the
period set out in Article 3, no request for amendment must be included, unless the beneficiary
concerned is the coordinator. In this case, the request for amendment must propose a new
coordinator.
If this information is not given or if the Commission considers that the reasons do not justify
termination, the participation will be considered to have been terminated improperly.
The termination will take effect on the day specified in the notification.
34.2.2 Effects
The beneficiary concerned must submit to the coordinator:
(i) a technical report and
(ii) a financial statement covering the period to the date when termination takes effect.
This information must be included by the coordinator in the final report (see Article 15.4).
If the request for amendment is rejected by the Commission (because it calls into question the decision
awarding the grant or breaches the principle of equal treatment of applicants), the Agreement may be
terminated according to Article 34.3.1(c).
If the request for amendment is accepted by the Commission, the Agreement is amended to introduce
the necessary changes (see Article 39).
Improper termination may lead to a reduction of the grant (see Article 27) or termination of the
Agreement (see Article 34).
After termination, the concerned beneficiary’s obligations (in particular Articles 15, 17, 18, 19, 21,
22, 24, 26, 27 and 28) continue to apply.
34.3 Termination of the Agreement or of the participation of one or more beneficiaries, by the
Commission
34.3.1 Conditions
The Commission may terminate the Agreement 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 their legal, financial, technical, organisational or ownership situation is likely to
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substantially affect or delay the implementation of the action or calls into question the decision
to award the grant;
(c) following termination of participation for one or more beneficiaries (see above), the necessary
changes to the Agreement would call into question the decision awarding the grant or breach
the principle of equal treatment of applicants (see Article 39);
(d) implementation of the action is prevented by force majeure (see Article 35) or suspended by
the coordinator (see Article 33.1) and either:
(i) resumption is impossible, or
(ii) the necessary changes to the Agreement would call into question the decision awarding
the grant or breach the principle of equal treatment of applicants;
(e) a beneficiary is declared bankrupt, being wound up, having its affairs administered by the
courts, has entered into an arrangement with creditors, has suspended business activities, or is
subject to any other similar proceedings or procedures under national law;
(f) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has been found guilty of professional misconduct, proven by any means;
(g) a beneficiary does not comply with the applicable national law on taxes and social security;
(h) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed fraud, corruption, or is involved in a criminal organisation, money laundering
or any other illegal activity;
(i) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed:
(i) substantial errors, irregularities or fraud or
(ii) serious breach of obligations under the Agreement or during the award procedure
(including improper implementation of the action, submission of false information, failure
to provide required information, breach of ethical principles);
(j) a beneficiary (or a natural person who has the power to represent or take decisions on its behalf)
has committed — in other EU or Euratom 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 from other grants to this grant; see
Article 17.5.2);
(k) not applicable.
34.3.2 Procedure
Before terminating the Agreement or participation of one or more beneficiaries, the Commission will
formally notify the coordinator or beneficiary conerned:
- informing it of its intention to terminate and the reasons why and
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- inviting it, within 30 days of receiving notification, to submit observations and — in case of
Point (i.ii) above — to inform the Commission of the measures to ensure compliance with the
obligations under the Agreement.
If the Commission does not receive observations or decides to pursue the procedure despite the
observations it has received, it will formally notify to the coordinator or beneficiary concerned
confirmation of the termination and the date it will take effect. Otherwise, it will formally notify that
the procedure is not continued.
The termination will take effect:
- for terminations under Points (b), (c), (e), (g), (i.ii) and (k) above: on the day specified in the
notification of confirmation (see above);
- for terminations under Points (a), (d), (f), (h), (i.i) and (j) above: on the day after the notification
of the confirmation is received.
34.3.3 Effects
(a) for termination of the Agreement:
The coordinator must — within 60 days from when termination takes effect — submit a final
report (see Article 15.4).
If the Agreement is terminated for breach of the obligation to submit report(s) (see Articles 15.8
and 34.3.1(i)), the coordinator may not submit any report(s) after termination.
If the Commission does not receive the report(s) within the deadline (see above), no costs will
be taken into account.
The Commission will calculate the final grant amount (see Article 5.3) and the balance (see
Article 16.4) on the basis of the report(s) submitted. Only costs incurred until termination
takes effect are eligible (see Article 6). Costs relating to contracts due for execution only after
termination are not eligible.
This does not affect the Commission’s right to reduce the grant (see Article 27) or to impose
administrative sanctions (Article 29).
The beneficiaries may not claim damages due to termination by the Commission (see
Article 30).
After termination, the beneficiaries’ obligations (in particular Articles 15, 17, 18, 19, 21, 22,
24, 26, 27 and 28) continue to apply.
(b) for termination of the participation of one or more beneficiaries:
The coordinator must — within 60 days from when termination takes effect — submit a request
for amendment (see Article 39), with a proposal for reallocation of the tasks and estimated
budget of the beneficiary concerned (see Annexes 1 and 2) and, if necessary, the addition of
one or more new beneficiaries (see Article 40). If termination is notified after the period set out
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in Article 3, no request for amendment must be submitted unless the beneficiary concerned is
the coordinator. In this case the request for amendment must propose a new coordinator.
The beneficiary concerned must submit to the coordinator:
(i) a technical report and
(ii) a financial statement covering the period to the date when termination takes effect.
This information must be included by the coordinator in the final report (see Article 15.4).
If the request for amendment is rejected by the Commission (because it calls into question the decision
awarding the grant or breaches the principle of equal treatment of applicants), the Agreement may be
terminated according to Article 34.3.1(c).
If the request for amendment is accepted by the Commission, the Agreement is amended to introduce
the necessary changes (see Article 39).
After termination, the concerned beneficiary’s obligations (in particular Articles 15, 17, 18, 19, 21,
22, 24, 26, 27 and 28) continue to apply.
SECTION 4 FORCE MAJEURE
ARTICLE 35 — FORCE MAJEURE
‘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 third parties involved in the
action), and
- proves to be inevitable in spite of exercising all due diligence.
The following cannot be invoked as force majeure:
- any default of a service, defect in equipment or material or delays in making them available,
unless they stem directly from a relevant case of force majeure,
- labour disputes or strikes, or
- financial difficulties.
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.
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The party prevented by force majeure from fulfilling its obligations under the Agreement cannot be
considered in breach of them.
CHAPTER 7 FINAL PROVISIONS
ARTICLE 36 — COMMUNICATION BETWEEN THE PARTIES
36.1 Form and means of communication
Communication under the Agreement (information, requests, submissions, ‘formal notifications’, etc.)
must:
- be made in writing and
- bear the number of the Agreement.
Until the payment of the balance: all communication must be made through the electronic exchange
system and using the forms and templates provided there.
After the payment of the balance: formal notifications must be made by registered post with proof
of delivery (‘formal notification on paper’).
Communications in the electronic exchange system must be made by persons authorised according to
the Participant Portal terms & 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 his/her appointment letter (see Participant
Portal terms & conditions).
If the electronic exchange system is temporarily unavailable, instructions will be given on the
Commission websites.
36.2 Date of communication
Communications are considered to have been made when they are sent by the sending party (i.e. on
the date and time they are sent through the electronic exchange system).
Formal notifications through the electronic exchange system are considered to have been made when
they are received by the receiving party (i.e. on the date and time of acceptance by the receiving party,
as indicated by the time stamp). A formal notification that has not been accepted within 10 days after
sending is considered to have been accepted.
Formal notifications on paper sent by registered post with proof of delivery (only after the payment
of the balance) are considered to have been made on either:
- the delivery date registered by the postal service or
- the deadline for collection at the post office.
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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 electronic exchange system must be accessed via the following URL:
https://ec.europa.eu/research/participants/portal/desktop/en/projects/
The Commission will formally notify the coordinator and beneficiaries in advance any changes to
this URL.
Formal notifications on paper (only after the payment of the balance) addressed to the Commission
must be sent to the following address:
European Commission
Directorate General Justice and Consumers
Programme and Financial management (MO59, 4/021)
B-1049 Brussels
BELGIUM
Formal notifications on paper (only after the payment of the balance) addressed to the beneficiaries
must be sent to their legal address as specified in the Participant Portal Beneficiary Register.
ARTICLE 37 — INTERPRETATION OF THE AGREEMENT
37.1 Precedence of the Terms and Conditions over the Annexes
The provisions in the Terms and Conditions of the Agreement take precedence over its Annexes.
Annex 2 takes precedence over Annex 1.
37.2 Privileges and immunities
Not applicable
ARTICLE 38 — CALCULATION OF PERIODS, DATES AND DEADLINES
In accordance with Regulation No 1182/7112, 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.
ARTICLE 39 — AMENDMENTS TO THE AGREEMENT
39.1 Conditions
12 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 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
The party requesting an amendment must submit a request for amendment signed in the electronic
exchange system (see Article 36).
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 Commission may request additional information.
If the party receiving the request agrees, it must sign the amendment in the electronic exchange system
within 45 days of receiving notification (or any additional information the Commission 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 agreed by the parties or, in the absence of such an agreement,
on the date on which the amendment enters into force.
ARTICLE 40 — ACCESSION TO THE AGREEMENT
40.1 Accession of the beneficiaries mentioned in the Preamble
The other beneficiaries must accede to the Agreement by signing the Accession Form (see Annex 3) in
the electronic exchange system (see Article 36) within 30 days after its entry into force (see Article 42).
They will assume the rights and obligations under the Agreement with effect from the date of its entry
into force (see Article 42).
If a beneficiary does not accede to the Agreement within the above deadline, the coordinator must
— within 30 days — request an amendment to make any changes necessary to ensure proper
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implementation of the action. This does not affect the Commission's right to terminate the Agreement
(see Article 34).
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 in the electronic
exchange system (see Article 36).
New beneficiaries must assume the rights and obligations under the Agreement with effect from the
date of their accession specified in the Accession Form (see Annex 3).
ARTICLE 41 — APPLICABLE LAW AND SETTLEMENT OF DISPUTES
41.1 Applicable law
The Agreement is governed by the applicable EU law, supplemented if necessary by the law of
Belgium.
41.2 Dispute settlement
If a dispute concerning the interpretation, application or validity of the Agreement cannot be settled
amicably, the General Court — or, on appeal, the Court of Justice of the European Union — has sole
jurisdiction. Such actions must be brought under Article 272 of the Treaty on the Functioning of the
EU (TFEU).
If a dispute concerns administrative sanctions, offsetting or an enforceable decision under Article 299
TFEU (see Articles 28, 29 and 30), the beneficiaries must bring action before the General Court —
or, on appeal, the Court of Justice of the European Union — under Article 263 TFEU.
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ARTICLE 42 — ENTRY INTO FORCE OF THE AGREEMENT
The Agreement will enter into force on the day of signature by the Commission or the coordinator,
depending on which is later.
SIGNATURES
For the coordinator For the Commission
[--TGSMark#signature-998927632_75_210--] [--TGSMark#signature-service_75_210--]
Urmo Kübar with ECAS id n006o1yr signed in the Participant Portal Signed by Maria TOMASSETTI with ECAS id tomasma as an authorised
on 03/09/2021 at 08:47:25 (transaction id SigId-144535-HAnclOgPx representative on 03-09-2021 13:07:57 (transaction id SigId-147241-d
THpAParpzOOzeiY8XizbdIzfxairzKLlP5oLUcUgegNKzL8Dj4e1LfuI9T zTzeMhzlSgTsMAGGU2qXippDTgqt0zYSYj9vUROJTdACI9jbcPMhGLA0
K8mHyapJ7plZWeDsX5wWG-rS0vSrmBGYC4qPWkzdfTt3-OMvE20e dUmHUbBMy4rBUbMiiBFuZKIRMzZh1U-rS0vSrmBGYC4qPWkzdfTt3-2
Ash4RztRkN0CGzNjlVdMtRXSLcAbVyQN7OuCmZu3TMRqTgld7Zvtd jiGlWGxgYzHIHdoFFiPWobFMcQ6Mim2YanZ0Y61RwDXCvSOuKHekD6
GOUlf3yYe5azZVzUpSaYb9Lvxdm). Timestamp by third party at Hm9SnyOHJ7BAAHTuqVPQrQ7pejhCvc0)
2021.09.03 09:47:31 CEST 2021.09.03 13:08:01 CEST
54
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
EUROPEAN COMMISSION
Directorate-General for Justice and Consumers
JUST.4 – Programme and Financial management
ANNEX 1 (part A)
REC Action Grant
NUMBER — 963357 — HEALTH
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
Table of Contents
1.1. The project summary................................................................................................................................. 3
1.2. The list of beneficiaries..............................................................................................................................5
1.3. Workplan Tables - Detailed implementation..............................................................................................6
1.3.1. WT1 List of work packages........................................................................................................... 6
1.3.2. WT2 List of deliverables................................................................................................................ 7
1.3.3. WT3 Work package descriptions................................................................................................... 9
Work package 1........................................................................................................................... 9
Work package 2......................................................................................................................... 11
Work package 3......................................................................................................................... 13
Work package 4......................................................................................................................... 15
1.3.4. WT4 List of milestones................................................................................................................ 17
1.3.5. WT5 Critical Implementation risks and mitigation actions........................................................... 18
1.3.6 WT6 Summary of project effort in person-months........................................................................19
1.3.7. WT7 Tentative schedule of project reviews.................................................................................20
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
1.1. The project summary
Project Number 1 963357 Project Acronym 2 HEALTH
One form per project
General information
Project title 3
Health Equality, Attitudes towards LGBTQI+ People and Trans Health Care
Starting date 4 01/11/2021
Duration in months 5 24
Call (part) identifier 6 REC-RDIS-DISC-AG-2020
REC-RDIS-DISC-AG-2020
Topic Call for proposals to promote the effective implementation of the principle of non-
discrimination
Fixed EC Keywords
non-discrimination, equal access to health care, LGBTQI+ patients, trans health care
Free keywords
protocol
Abstract 7
LGBTQI+ people face various inequalities in health care settings. In EU several studies have explored these
disparities (e.g. FRA LGBT Survey, 2014; FRA “Professionally Speaking”, 2016) identifying different barriers,
including prejudicial attitudes and intolerant or discriminatory behaviour of medical personnel. There is, however,
hardly any data about these barriers in Estonian health care system. We do not know whether LGBTQI+ people´s
needs are not being recognised or met in Estonian public health system. The project´s aim is to fill in this knowledge
gap and study the barriers of healthcare professionals when treating LGBTQI+ people, including the attitudes
and awareness of the professionals. A study with combined research methods will be carried out to this end. The
evidence from the study will identify the main drivers and barriers affecting the implementation of laws that combat
discrimination and impact the policies of promotion of equal treatment of LGBTQI+ persons in health sector.
Project will provide health care professionals with tools and training to better respond to the needs of LGBTQI+
patients. Trainings, including an online training and information materials will be designed which will sensitize and
raise awareness of healthcare professionals about the needs of LGBTQI+ people.
Bearing in mind the specific health related needs and experiences of trans people a trans health care protocol will be
composed with the aim to improve the access to trans-specific healthcare and providing a guideline for health care
professionals on how to treat and serve trans people and respect their human rights in the age of depathologizing trans
identities.
The project contributes in creating more equal access to health care for LGBTQI+ people.
A study with combined research methods (online questionnaire and 15 in-depth individual interviews) will be carried
out to identify the barriers of Estonian healthcare professionals when treating LGBTQI+ people, including the
attitudes and awareness of medical professionals.
Project will provide at least 300 health care professionals with tools and at least 60 health care professionals a training
to better respond to the needs of LGBTQI+ patients. Trainings (1 in Tartu and 2 in Tallinn), including an online video-
training will sensitize and raise awareness of healthcare professionals on LGBTQI equality.
Information materials will be composed for health care professionals who choose to educate themselves on the matter
of LGBTQI equality through reading materials. The online and printed materials are targeted to Estonian health care
professionals and are estimated to reach at least 300 professionals.
Booklet targeting non-discrimination principle in health will be published for LGBTQI+ people. It will include
explanations on how to recognise discriminatory behaviours, how to seek for help and what are the legal remedies
available for the victims.
Trans health care protocol will be developed together with representatives of trans community, medical community,
policy officers of the Ministry of Social Affairs and experts from countries with best practices (Spain and Malta).
The work of developing the trans health care protocol will include one community meeting to consult with the trans
community on their needs and expectations. The cooperation work to develop the protocol will aim to bring together
relevant stakeholders who will continue to act as informal network of trans health care also after the project has ended.
The project will end with a conference where the results, including the new knowledge gained and the new tools will
be presented and widely discussed.
Page 3 of 20
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1.1. The project summary
As the result of the project activities the health care professionals and the wider Estonian public will be more aware
of the barriers in health sector that hinder the LGBTQI equality. They will know better the needs of LGBTQI+ people
and have tools to guide them to provide equal access to health care. Health care professionals will acquire capacities
needed to recognize and correspond to the needs of their LGBTQI+ patients.
Different target groups are actively engaged throughout the project, thus as a result, during the project they hear and
share experiences and exchange on how to overcome the barriers that LGBTQI+ people face when accessing health
care. While the project is targeted specifically at health care professionals, the knowledge collected and compiled
throughout this project will also be disseminated through different communication channels to wider media and wider
audiences and it is expected that project activities will have an impact on different stakeholders, including policy
makers, health sector civil servants, equality experts etc.
In the longer perspective the project, especially the Trans Health Care Protocol, will impact the access to health care
and quality of the care LGBTQI+ people receive in public health system.
Page 4 of 20
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1.2. List of Beneficiaries
Project Number 1 963357 Project Acronym 2 HEALTH
List of Beneficiaries
Project Project
No Name Short name Country entry exit
month8 month
SIHTASUTUS POLIITIKAUURINGUTE
1 PRAXIS Estonia 1 24
KESKUS PRAXIS
2 EESTI LGBT UHING LGBT ASSOC. Estonia 1 24
3 SOTSIAALMINISTEERIUM MSAE Estonia 1 24
Page 5 of 20
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1.3. Workplan Tables - Detailed implementation
1.3.1. WT1 List of work packages
WP Person- Start End
WP Title Lead beneficiary10
Number9 months11 month12 month13
WP1 Project management & coordination 1 - PRAXIS 5.40 1 24
Studying the barriers of healthcare
WP2 professionals when treating LGBTI 1 - PRAXIS 3.80 1 12
people
Raising Awareness on LGBTQI+
WP3 1 - PRAXIS 7.90 1 24
Equality in Health Care
Trans Healthcare Protocol for Public
WP4 1 - PRAXIS 2.18 4 22
Health system
Total 19.28
Page 6 of 20
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1.3.2. WT2 list of deliverables
Due
Deliverable WP Dissemination
Deliverable Title Lead beneficiary Type 15 Date (in
Number14 number9 level16
months)17
Confidential,
only for members
of the consortium
D1.1 Evaluation WP1 1 - PRAXIS Report 24
(including the
Commission
Services)
Confidential,
only for members
Websites,
Dissemination of 3 key of the consortium
D1.2 WP1 1 - PRAXIS patents 24
outputs in social media (including the
filing, etc.
Commission
Services)
Confidential,
only for members
of the consortium
D1.3 Progress report WP1 1 - PRAXIS Report 13
(including the
Commission
Services)
D2.1 Study report WP2 1 - PRAXIS Report Public 12
Policy
D2.2 WP2 1 - PRAXIS Report Public 12
recommendations
D3.1 Training module WP3 1 - PRAXIS Other Public 24
Websites,
D3.2 Online video training WP3 1 - PRAXIS patents Public 24
filing, etc.
D3.3 2 Info booklets WP3 1 - PRAXIS Report Public 24
Confidential,
only for members
of the consortium
D3.4 Conference WP3 1 - PRAXIS Other 24
(including the
Commission
Services)
Confidential,
only for members
Trainings for medical of the consortium
D3.5 WP3 1 - PRAXIS Other 24
professionals (including the
Commission
Services)
Confidential,
only for members
of the consortium
D3.6 Consortium meetings WP3 1 - PRAXIS Other 22
(including the
Commission
Services)
Guidelines Trans
D4.1 WP4 1 - PRAXIS Report Public 22
Health Care Protocol
Page 7 of 20
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Due
Deliverable WP Dissemination
Deliverable Title Lead beneficiary Type15 Date (in
Number14 number9 level16
months)17
Confidential,
only for members
Meetings to develop
of the consortium
D4.2 Trans Health Care WP4 1 - PRAXIS Other 22
(including the
Protocol
Commission
Services)
Page 8 of 20
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1.3.3. WT3 Work package descriptions
Work package number 9 WP1 Lead beneficiary 10 1 - PRAXIS
Work package title Project management & coordination
Start month 1 End month 24
Objectives
The first work package (WP1) focuses on project management and coordination and is aimed at ensuring the smooth
flow of the project plan and activities.
▪ The project´s activities are coordinated efficiently
▪ Project´s financial management is ensured
▪ There is an evaluation and monitoring system in place
Description of work and role of partners
WP1 - Project management & coordination [Months: 1-24]
PRAXIS, LGBT ASSOC.
1.1
Project management
Overseeing the planning and implementation of the activities, organizing meetings with the project partners (at least
3 times a year),
1.2
Financial management
CFO and the project coordinator manage the project financially by keeping track of the expenditure, reporting to the
EC etc.
1.3
Monitoring the implementation of activities and reporting
Monthly meetings with the project team to ensure smooth implementation of the activities, filing project related
documents etc.
Participation per Partner
Partner number and short name WP1 effort
1 - PRAXIS 3.80
2 - LGBT ASSOC. 1.60
Total 5.40
List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type15 Dissemination level16 Date (in
Number14
months)17
Confidential, only
for members of the
D1.1 Evaluation 1 - PRAXIS Report consortium (including 24
the Commission
Services)
Page 9 of 20
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List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type 15
Dissemination level 16 Date (in
Number14
months)17
Confidential, only
Websites, for members of the
Dissemination of 3 key
D1.2 1 - PRAXIS patents filing, consortium (including 24
outputs in social media
etc. the Commission
Services)
Confidential, only
for members of the
D1.3 Progress report 1 - PRAXIS Report consortium (including 13
the Commission
Services)
Description of deliverables
Evaluation and 1 Dissemination related deliverables.
D1.1 : Evaluation [24]
-The evaluation will focus on the outputs and outcomes of the project for which quantitative and qualitative targets
will be elaborated. -The sub-indicators may include: number of interviewees, applicability of the research results as
an input for the training design etc. - In Estonian - Pdf document - 15 pages - summary in EN
D1.2 : Dissemination of 3 key outputs in social media [24]
Project outputs will be regularly disseminated throughout the project. At least 3 key outputs of the project will be
disseminated in social media (FaceBook, Instagram) in Estonian. Main target groups are: decision makers, policy
makers, health professionals, LGBTQI community, wider public in Estonian society. Key messages that will be
communicated throughout this project will support and develop the principles of equality, non-discrimination and
LGBTQI rights in area of health care.
D1.3 : Progress report [13]
template to be downloaded from the FT Portal
Schedule of relevant Milestones
Due
Milestone
Milestone title Lead beneficiary Date (in Means of verification
number18
months)
Page 10 of 20
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Work package number 9 WP2 Lead beneficiary 10 1 - PRAXIS
Work package title Studying the barriers of healthcare professionals when treating LGBTI people
Start month 1 End month 12
Objectives
Increase understanding of barriers of healthcare professionals when treating LGBTQI+ people, including the attitudes
and awareness of the professionals and possible lack of training regarding the specific needs of LGBTQI+ people.
Description of work and role of partners
WP2 - Studying the barriers of healthcare professionals when treating LGBTI people [Months: 1-12]
PRAXIS
2.1 Develop study methodology
Adapting FRA study Speaking Professionally methodology to Estonian context. Designing the online survey
questionnaire, individual interview plan.
2.2 Executing the study
A study with quantitative and qualitative research methods will be carried out. 15 individual interviews will be
conducted. Online questionnaire will collect further data to map the barriers.
2.3 Preparation for publication
Designing, layout, publishing online the study report
Participation per Partner
Partner number and short name WP2 effort
1 - PRAXIS 3.80
Total 3.80
List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type 15
Dissemination level 16 Date (in
Number14
months)17
D2.1 Study report 1 - PRAXIS Report Public 12
D2.2 Policy recommendations 1 - PRAXIS Report Public 12
Description of deliverables
1 study report A4, in Estonian
D2.1 : Study report [12]
Output of the study on the barriers of healthcare professionals when treating LGBTQI+ people. - In Estonian with
English summary -30 pages - questionnaire target group are medical professionals - questionnaire will be developed
especially for this study adapting FRA studies
D2.2 : Policy recommendations [12]
-In Estonian - Digital document, published online - Target groups: policy makers, decision makers, medical
professionals -
Page 11 of 20
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Schedule of relevant Milestones
Due
Milestone
Milestone title Lead beneficiary Date (in Means of verification
number18
months)
Page 12 of 20
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Work package number 9 WP3 Lead beneficiary 10 1 - PRAXIS
Work package title Raising Awareness on LGBTQI+ Equality in Health Care
Start month 1 End month 24
Objectives
Raise awareness of health professionals
Provide health professionals with the tools and training to improve LGBTQI+ equality
Description of work and role of partners
WP3 - Raising Awareness on LGBTQI+ Equality in Health Care [Months: 1-24]
PRAXIS, LGBT ASSOC.
3.1 Training design and execution
Developing a training module and providing the training in 3 training events to at least 60 health professionals.
3.2 Producing and promoting the Online video training
Online based video training (at least 60 minutes) will be designed, produced and promoted
3.3 Printed info materials for health professionals
Information material (20-30 pages) for health professionals in Estonian will be developed and published with the aim
to raise awareness on LGBTQI+ equality.
3.4 Info materials for LGBTQI+ people
Information material (20-30 pages) for LGBTQI+ people (in Estonian) will be developed and published with the aim
to raise awareness on equal treatment and discrimination in health sector, legal remedies etc.
3.5 Final conference
The outputs of the project and the new learning will be presented and discussed at the 1-day conference with foreign
speakers directed to health care professionals, scholars, policy makers and other stakeholders.
Participation per Partner
Partner number and short name WP3 effort
1 - PRAXIS 4.50
2 - LGBT ASSOC. 3.40
Total 7.90
List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type15 Dissemination level16 Date (in
Number14
months)17
D3.1 Training module 1 - PRAXIS Other Public 24
Websites,
D3.2 Online video training 1 - PRAXIS patents filing, Public 24
etc.
D3.3 2 Info booklets 1 - PRAXIS Report Public 24
Confidential, only
D3.4 Conference 1 - PRAXIS Other for members of the 24
consortium (including
Page 13 of 20
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List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type 15
Dissemination level 16 Date (in
Number14
months)17
the Commission
Services)
Confidential, only
for members of the
Trainings for medical
D3.5 1 - PRAXIS Other consortium (including 24
professionals
the Commission
Services)
Confidential, only
for members of the
D3.6 Consortium meetings 1 - PRAXIS Other consortium (including 22
the Commission
Services)
Description of deliverables
D3.1 : Training module [24]
Presentation slides for the trainer, In Estonian
D3.2 : Online video training [24]
- Video to be published online and accessible for all. - In Estonian with Russian subtitles - Length: 60 min - At least 2
speakers - target groups to complete the training before the end of the project: 2 academia; 15 medical professionals;
3 policy makers
D3.3 : 2 Info booklets [24]
(1)Info Booklet for health professionals, A5, In Estonian, printed, 300 copies (2)Info booklet for LGBTQI, A5, In
Estonian, printed 300 copies
D3.4 : Conference [24]
In Tallinn 1 day event, in Estonian and English with interpretation Agenda: results of the project will be introduced
60 participants target group: academia, medical professionals, decision makers, community leaders Presentations in
Estonian and English
D3.5 : Trainings for medical professionals [24]
- 3 trainings in Estonia - Target group: health care professionals - 60 participants altogether
D3.6 : Consortium meetings [22]
2 meetings with partners to design the outputs of the WP 3 - Online or face to face - In Estonian
Schedule of relevant Milestones
Due
Milestone
Milestone title Lead beneficiary Date (in Means of verification
number18
months)
Page 14 of 20
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Work package number 9 WP4 Lead beneficiary 10 1 - PRAXIS
Work package title Trans Healthcare Protocol for Public Health system
Start month 4 End month 22
Objectives
Improving the access to trans-specific health care for trans people and providing a guideline for medical professionals
when treating or informing a trans person.
Description of work and role of partners
WP4 - Trans Healthcare Protocol for Public Health system [Months: 4-22]
PRAXIS, LGBT ASSOC.
4.1 Task - Trans Health Care Protocol
Developing Trans Health Care Protocol, meeting with the trans community for input and expectations; meetings with
the foreign expert and consortium members to develop the main structure, substance and other for the trans health care
protocol
Participation per Partner
Partner number and short name WP4 effort
1 - PRAXIS 1.80
2 - LGBT ASSOC. 0.38
Total 2.18
List of deliverables
Due
Deliverable
Deliverable Title Lead beneficiary Type15 Dissemination level16 Date (in
Number14
months)17
Guidelines Trans Health
D4.1 1 - PRAXIS Report Public 22
Care Protocol
Confidential, only
Meetings to develop for members of the
D4.2 Trans Health Care 1 - PRAXIS Other consortium (including 22
Protocol the Commission
Services)
Description of deliverables
D4.1 : Guidelines Trans Health Care Protocol [22]
(1) trans health care protocol to improve the access to trans-specific health care for trans people and providing (2)
guideline for medical professionals when treating or informing a trans person. In Estonian, 2 digital documents,10
pages
D4.2 : Meetings to develop Trans Health Care Protocol [22]
3 meetings with stakeholders, including trans community, and experts which will lead to the drafting of the Trans
Health Care Protocol Depending on COVID-19 pandemic the meetings are face to face or online - Each meeting will
have at least 5 participants - In Estonian or English
Page 15 of 20
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Schedule of relevant Milestones
Due
Milestone
Milestone title Lead beneficiary Date (in Means of verification
number18
months)
Page 16 of 20
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1.3.4. WT4 List of milestones
No milestones indicated
Page 17 of 20
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1.3.5. WT5 Critical Implementation risks and mitigation actions
Risk
Description of risk WP Number Proposed risk-mitigation measures
number
For avoiding risks related to process quality we
will ensure constant coordination and discussions
between team members and external experts to
prevent and manage any problems that might
emerge. This also guarantees that all team
members and external experts are aware of the
1 Process quality WP1 progress of the project, their tasks and resources.
In addition to the project manager, the progress,
quality and results' assessment is the responsibility
of quality manager who supervises the project
and advises project manager in adapting project
plan and resource allocation to guarantee smooth
project progress and good process quality.
To mitigate this risk a letter of support will
be obtained and sent to potential interviewees
together with a request for an interview; we will
contact all interviewees a few weeks in advance
with a request to propose the date and time for an
interview; we will send an interview questions
to all interviewees in advance. Alternative
Interviewees unavailable or
2 WP2 contacts/ persons for replacement will be reached
unwilling to be interviewed.
if necessary. Praxis has a wide range of networks
and contacts and Communications Manager
who in the preparation phase of the project
will also compile an internal communications/
disseminations plan considering and mitigating
risks related to project participants and target
groups.
To mitigate this risk we will contact the potential
Lack of interests of the target
participants well in advance and send the potential
group to participate in the
participants a brief summary of the research
training due to the fact of
3 WP3 results. Separate seminars will be organized
not admitting the problem
for politicians and journalists to assure a level
or being afraid of publicly
of anonymity for the politicians. Alternative
admitting the problem.
contacts/persons will be reached if necessary.
Page 18 of 20
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1.3.6. WT6 Summary of project effort in person-months
WP1 WP2 WP3 WP4 Total Person/Months per Participant
1 - PRAXIS 3.80 3.80 4.50 1.80 13.90
2 - LGBT ASSOC. 1.60 0 3.40 0.38 5.38
3 - MSAE 0 0 0 0 0
Total Person/Months 5.40 3.80 7.90 2.18 19.28
Page 19 of 20
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1.3.7. WT7 Tentative schedule of project reviews
Review Tentative Planned venue
Comments, if any
number 19 timing of review
RV1 24 tbc Reviews might be carried out.
Page 20 of 20
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1. Project number
The project number has been assigned by the Commission as the unique identifier for your project. It cannot be
changed. The project number should appear on each page of the grant agreement preparation documents (part A
and part B) to prevent errors during its handling.
2. Project acronym
Use the project acronym as given in the submitted proposal. It can generally not be changed. The same acronym should
appear on each page of the grant agreement preparation documents (part A and part B) to prevent errors during its
handling.
3. Project title
Use the title (preferably no longer than 200 characters) as indicated in the submitted proposal. Minor corrections are
possible if agreed during the preparation of the grant agreement.
4. Starting date
Unless a specific (fixed) starting date is duly justified and agreed upon during the preparation of the Grant Agreement,
the project will start on the first day of the month following the entry into force of the Grant Agreement (NB : entry into
force = signature by the Commission). Please note that if a fixed starting date is used, you will be required to provide a
written justification.
5. Duration
Insert the duration of the project in full months.
6. Call (part) identifier
The Call (part) identifier is the reference number given in the call or part of the call you were addressing, as indicated
in the publication of the call in the Official Journal of the European Union. You have to use the identifier given by the
Commission in the letter inviting to prepare the grant agreement.
7. Abstract
8. Project Entry Month
The month at which the participant joined the consortium, month 1 marking the start date of the project, and all other start
dates being relative to this start date.
9. Work Package number
Work package number: WP1, WP2, WP3, ..., WPn
10. Lead beneficiary
This must be one of the beneficiaries in the grant (not a third party) - Number of the beneficiary leading the work in this
work package
11. Person-months per work package
The total number of person-months allocated to each work package.
12. Start month
Relative start date for the work in the specific work packages, month 1 marking the start date of the project, and all other
start dates being relative to this start date.
13. End month
Relative end date, month 1 marking the start date of the project, and all end dates being relative to this start date.
14. Deliverable number
Deliverable numbers: D1 - Dn
15. Type
Please indicate the type of the deliverable using one of the following codes:
R Document, report
DEM Demonstrator, pilot, prototype
DEC Websites, patent fillings, videos, etc.
OTHER
ETHICS Ethics requirement
ORDP Open Research Data Pilot
DATA data sets, microdata, etc.
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
16. Dissemination level
Please indicate the dissemination level using one of the following codes:
PU Public
CO Confidential, only for members of the consortium (including the Commission Services)
EU-RES Classified Information: RESTREINT UE (Commission Decision 2005/444/EC)
EU-CON Classified Information: CONFIDENTIEL UE (Commission Decision 2005/444/EC)
EU-SEC Classified Information: SECRET UE (Commission Decision 2005/444/EC)
17. Delivery date for Deliverable
Month in which the deliverables will be available, month 1 marking the start date of the project, and all delivery dates
being relative to this start date.
18. Milestone number
Milestone number:MS1, MS2, ..., MSn
19. Review number
Review number: RV1, RV2, ..., RVn
20. Installation Number
Number progressively the installations of a same infrastructure. An installation is a part of an infrastructure that could be
used independently from the rest.
21. Installation country
Code of the country where the installation is located or IO if the access provider (the beneficiary or linked third party) is
an international organization, an ERIC or a similar legal entity.
22. Type of access
TA-uc if trans-national access with access costs declared on the basis of unit cost,
TA-ac if trans-national access with access costs declared as actual costs, and
TA-cb if trans-national access with access costs declared as a combination of actual costs and costs on the basis of
unit cost,
VA-uc if virtual access with access costs declared on the basis of unit cost,
VA-ac if virtual access with access costs declared as actual costs, and
VA-cb if virtual access with access costs declared as a combination of actual costs and costs on the basis of unit
cost.
23. Access costs
Cost of the access provided under the project. For virtual access fill only the second column. For trans-national access
fill one of the two columns or both according to the way access costs are declared. Trans-national access costs on the
basis of unit cost will result from the unit cost by the quantity of access to be provided.
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Part B
Contents
1. Project background, needs assessment & relevance ................................................. 2
2. Objectives, methodology & impact .................................................................................... 4
2.1 Objectives, impact & methodology .............................................................................................. 4
2.2. Cost effectiveness ...................................................................................................................... 5
2.3. European added value ............................................................................................................... 6
2.4 Timetable..................................................................................................................................... 7
3. Participants and project management ............................................................................. 9
3.1 Consortium cooperation & division of roles for multi-beneficiary grants ...................................... 9
3.2 Subcontracting .......................................................................................................................... 11
3.3 Project management ................................................................................................................. 12
3.4 Project teams and staff .............................................................................................................. 12
3.5 Monitoring and evaluation ......................................................................................................... 13
3.6 Dissemination, communication and visibility of EU funding ....................................................... 14
3.7 Ethics......................................................................................................................................... 14
3.8 Sustainability and continuation .................................................................................................. 15
4. History of changes between your proposal and Annex I to the Grant
Agreement "Description of the Action" .............................................................................. 16
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1. Project background, needs assessment & relevance
Background
Describe background and context behind the project, including your understanding of the relevant EU policies.
Needs Assessment
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 which 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).
You can refer to existing research, studies and previous projects that already demonstrate the need for action.
E.g. There is a lack of reporting for victims of gender-based violence. Therefore, there is a need to train professionals in understanding the reasons
behind this so they can empower victims.
Relevance
Explain how your project relates and contributes to the priorities of the call to which you are applying.
Describe the target groups of this project referring to the needs assessment. Which target group(s) need to be supported/ assisted by/in the project.
Why have you chosen to focus on their needs? What EU countries are directly targeted by the project and why have you chosen them?
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).
Background
LGBTQI+ people face serious inequalities in health care. In EU several studies have explored these disparities. FRA LGBT Survey 2014 found that
among trans respondents who accessed healthcare services in the 12 months preceding the survey, over one in five (22%) say that they felt
personally discriminated against by healthcare personnel because of being trans.
In Health4LGBTI report from 2017 it was established that LGBTQI + people are at significantly higher risk of experiencing mental distress with
LGB people twice to three times more likely to report an enduring psychological or emotional problem including suicidal ideation and
suicide, substance misuse, and deliberate self- harm compared to the general population. LGBTQI+ people experience minority stress, stigma,
prejudice and discrimination and are often subjected to hostile environments with stressful social exchange. Except for the FRA data there is hardly any
data on these barriers in Estonian health care system. In 2016 a study was published in Estonia in which a brief insight into area of health was given (Aavik
et al., 2016). The LGB interviewees expressed that their family doctors do not know their sexual orientation, trans people claimed that the awareness of
doctors of trans specific healthcare issues is low. There are no studies which would discuss LGBTQI+ health in detail.
We do not know whether and how LGBTQI+ people ś needs are being recognised or met in Estonian public health system. The project ś aim is to
fill in this knowledge gap and study the barriers of health care professionals when treating LGBTQI+ people, including the attitudes and
awareness of the professionals may have in relation to gender and sexual minorities. A study with combined research methods will be carried out
to this end. The evidence from the study will identify the main drivers and barriers affecting the implementation of laws that combat discrimination and
impact the policies of promotion of equal treatment of LGBTQI+ persons in health sector.
Needs Assessment
Institutional discrimination occurs where laws and policies in the public domain sustain in equalities or where laws do not protect against discrimination
based on sexual orientation, gender identity and sex characteristics. In order to overcome inequalities the barriers and disparities should be studied
in-depth. According to the literature the barriers that LGBTQI+ people face when accessing health care services are: prejudicial attitudes and
intolerant or discriminatory behaviour of medical personnel; needs not being recognised (e.g. lesbian women not being invited for cervical screening
due to wrongly being assumed that they are a ‘low- risk’ group); LGBTQI+ people being subjected to humiliation; denial of access to treatment (e.g.
assisted reproductive technology); or fear of disclosure of gender identity, sexual orientation or sex characteristics. For trans and intersex people,
health professionals use pathologizing language and incorrect pronouns.
FRA LGBTI survey (data from 2019) maps the experiences of LGBTI people, including in Estonia. In Estonia 11% of the LGBTI people felt that they were
discriminated because of being LGBTI when accessing healthcare or social services 12 months prior to the survey (results are based on too small number
of responses to bring out differences between lesbian women and gay men, bisexual women and bisexual men). In addition to this indicator Estonian
context is characterized by the Equal Treatment Act providing protection against discrimination on ground of sexual orientation only in the areas of
employment and education, access to services, including healthcare is not in the scope of the law leaving LGB people without protection. Debates over
widening the scope of the law have been going on since 2013 without much success. Moreover, in Estonia there is no comprehensive national strategy
for LGBTQI+ equality. Therefore, the advocacy to include health in the protected scope of the law and other policies should be enhanced.
Trans people are protected against discrimination in healthcare under the Gender Equality Act. However, the Ministry of Social Affairs and the Ministry of
Interior Affairs in Estonia have been debating since 2015 without success whether to move away from patronizing and pathologizing system which is at
the heart of the legal gender recognition system in Estonia. In June 2021 Praxis (COO) carried out an online poll among the trans people (19 respondents)
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asking what should change in Estonian healthcare system. Most votes got a proposition to abolish the “psychiatric commission” which gives out permissions
to start transition and process of legal gender recognition. Gender marker X and the need to have more doctors who would have no biases against trans
people were mentioned equal number of times. Number of proposals dealt with lack of information on trans specific healthcare, including surgeries,
healthcare insurance coverage and trans friendly doctors.
In order to avoid overlaps in data collection, this project will target the health care professionals and study their attitudes and knowledge. Currently only
very few trainings (mainly by the Estonian LGBT Association) in Estonia have targeted healthcare professionals regarding equality regardless of
patient ś sexual orientation, gender identity or sex characteristics. The topic is not part of the obligatory curriculum at the faculty of medicine. The awareness
of health care professionals of particular needs and sensitivities of LGBTQI+ people is presumably low and needs addressing with awareness
raising activities. Moreover, there are no information materials directed to LGBTQI+ people on the issue of non-discrimination principle in the
health care facilities. The awareness on one ś rights and available legal remedies is presumably low among these population groups. Trans people
need health care providers who treat them with respect and sensitivity. They also require clinicians who have knowledge and skills in providing gender-
affirming care, e.g. when providing hormone therapy. Moreover, transgender people often have complex needs outside the traditional bounds of health
care, such as social, and legal needs. Offering a transgender health program that supports the whole person by offering wrap-around medical,
mental health, and social care is a best practice. The best practices of informed consent based trans health care models are to be found in Spain
and Malta whose experiences will be informing and inspiring the work of developing the trans health care protocol for Estonia.
Relevance
According to the study by FRA (Professionally Speaking, 2016) only some training about issues affecting LGB persons is available in EU Member
States. Where training is available, it is usually voluntary and not systematically organised. In Estonia the training for healthcare professionals about the
needs of LGBTQI+ people has reached very marginal proportion of medics and is strictly voluntary(few trainings organised by the LGBT Association). The
project addresses the inequalities LGBTQI+ people face in health system and barriers that health care professionals may have and witness when
treating these groups of people. This approach is aligned with the European Commission ś efforts to abolish discrimination on any grounds and
to uphold and promote the fundamental rights of LGBTI people through the List of Actions for LGBTI Equality. The project constitutes a significant and
novel step toward alleviating LGBTQI+ inequality concerns in the context of Estonia. Such endeavours are already the stated goals of both the EU
and Estonia, but Estonia is yet to take meaningful effective action. The proposed activities will go a long way towards remedying LGBTQI+
inequalities in the Estonian society. The project actively engages the stakeholders and target groups, offers a platform for awareness-raising
(online training) and learning from best practices at the conference planned for 2021. The project is action-oriented and actively engages the target
groups and stakeholders in developing and disseminating information materials. No similar actions using the described approach has been taken in
Estonia previously. In sum, the project addresses the call priority Priority 2. Fighting against discrimination based on sexual orientation in
society and promoting the equality of LGBTI people through the implementation of the LGBTI List of Actions. The project aims to raise knowledge,
support networking, empower LGBTQI+ people and learn from European best practices (Malta and Spain). It also develops and disseminates practical
awareness raising tools. The project is planned to actively involve the stakeholders and to empower them to introduce changes to their
surroundings in order to guarantee the sustainability of the ideas beyond the duration of the project.
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2. Objectives, methodology & impact
2.1 Objectives, impact & methodology
Project approach
Describe the project approach. You will need to be specific and must use the headings below to structure your response.
Objectives
Define what the specific project objectives are and explain how they respond to the needs/issues/challenges/gaps of the respective cohort (actions to
be taken) highlighted in the needs assessment.
The objectives should be specific, measureable, realistic and achievable within the duration of the project. For example, a sample of 1000 professionals
was surveyed as part of the needs assessment and we will target 200 of these professionals as recipients of this project. They have a potential to
reach out to 5000 persons in the final target group. We aim to train at least 50% of them in understanding the reasons behind underreporting of
violence. This shall result in decreasing the underreporting rate and thus empowerment of victims.
For each objective, define appropriate indicators as you have listed in Annex 3, for measuring progress (including baseline value and target value).
Impact
Define the expected results (short, medium and long-term) of the project. What tangible and intangible impact will the project have on the target
groups? In what way the gap identified will be reduced? How the activities will contribute to improve the situation (difference between starting point/state
of play and the situation after the completion of the project?)
Results are immediate changes that materialise for the target groups after the completion of the project (e.g. improved knowledge, increased
awareness). Results 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.
Does the project bring innovative solutions?
Methodology
Describe your methodology to achieve the proposed project objectives. Why it is the most suitable approach for implementing the project throughout
its lifecycle.
Methodology is not a list of activities but are instruments, approaches that will be used, applied and created. For example, we will host a series of
workshops for the 200 professionals to help them to understand the reasons behind underreporting of gender-based violence.
Project approach
Objectives
The project addresses the inequalities LGBTQI+ people face in health system. This requires specific efforts by health systems and health
professionals, therefore the main target group of the awareness raising activities are the health care professionals who are in the key position to
uphold and promote the fundamental rights of LGBTQI+ people what comes to access to health care.
1. Increase understanding of barriers of healthcare professionals when treating LGBTQI+ people, including the attitudes and awareness of the
professionals and possible lack of training regarding the specific needs of LGBTQI+ people. A study with quantitative and qualitative research
methods will be carried out to this end. The evidence from the study will help to identify the main drivers and barriers affecting the
implementation of policies that combat discrimination and promote equal treatment of LGBTQI+ persons in health sector. The
results of the study will feed into the training module for health care professionals to be designed and implemented in this project (see objective
2). The study will also inform the work on developing the trans health care protocol (see objective 3).
Indicators:
1 study on LGBTQI+ barriers (baseline value 0)
1 set of policy recommendations (baseline value 0)
2. Provide 300 health care professionals with tools and 60 professionals a training to better respond to their LGBTQI patients and clients ́ needs.
Trainings, including an online training and info materials will be composed to sensitize and raise awareness of healthcare professionals on
needs of LGBTI people.
Indicators:
3 trainings events (baseline value in 2020 -0) for min 60 health care professionals as participants (for the 3 events together)
1 online training video (baseline value 0)
2 guidelines (baseline value 0)
1 conference for health care professionals (baseline value 0)
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3. Developing the trans health care protocol to improve the access to trans-specific healthcare for trans people and providing a guideline for
medical professionals when treating or informing a trans person. The Council of Europe Recommendation 2010(5) specifies, that ”transgender
persons [should] have effective access to appropriate gender reassignment services”. Moreover, according to this Recommendation,
“any decisions limiting the costs covered by health insurance for gender reassignment procedures should be lawful, objective and
proportionate”. The trans people often have complex needs outside the traditional bounds of health care, many of them have experienced
traumatic pathologizing by the health care systemin relation to their gender identity. This necessitates a systematic and separate
consideration of trans health care in the form of a separate health protocol for public health system.
Indicators:
1 Trans Health Care Protocol (baseline value 0)
Impact
As the result of the project activities the healthcare professionals will be more aware of the barriers in health sector that hinder the LGBTQI equality. They
will know better the needs of LGBTQI+ people and have tools to guide them to provide more equal access to health care.
Different target groups are actively engaged throughout the project, thus as a result, during the project they hear and share experiences and exchange on
how to overcome the barriers that LGBTQI+ people face when accessing healthcare.
While the project is targeted specifically at health care professionals, the knowledge collected and compiled throughout this project will also be
disseminated through different communication channels to wider media and wider audiences and it is expected that project activities will have an
effect to different stakeholders, including policy makers, civil servants, equality experts, scholars etc. We also believe that the project has a potential for
a spill-over effect as people who participate in this project will start to look at equality in health care through a different prism and can through their
everyday role influence attitudes and behaviour of people and colleagues they come in contact with.
Methodology
The approach and structure of the project is thoroughly and carefully designed taking into account the nature of the topic and the target groups. The project
brings together evidence-base knowledge and practical experience and aims at building on new knowledge (the study will inform the trainings to be
designed) and experiences of Malta and Spain when developing their trans health care models.
Through action of four WP over two years (2021-2023), the project will analyse the key barriers identified by the health professionals when
providing care for LGBTQI+ people. The aim is to raise awareness of the challenges and provide Estonian health professionals with the
tools to overcome these. The project is designed to give the target groups the right skills and knowledge to overcome the barriers, and thereby
contribute to the reduction of inequalities in health care.
Thus, to achieve the aims of the project and to initiate real change, project target groups are actively engaged in the project. The project is designed to
provide them the platform to acquire new knowledge, but also discuss and share their own experience and knowledge (e.g. via conference).
To collect data we will conduct 15 semi-structured in-depth interviews with the health care gatekeepers. For the study and interview questions in particular,
we shall adapt the method used by FRA in the Speaking professionally study (2016).
We will conduct an online survey, with maximum 20 questions to ensure at least 15-20% survey response rate(using an online survey tool
Alchemer to collect primary data).For qualitative data we use NVivo that has been designed for qualitative researchers working with very rich text-based
and/or multimedia information, where analysis of small or large volumes of data are required.
Training module and online training will be created based on outcomes of studying the barriers to ensure that these correspond to the actual needs of the
health care professionals.
2.2. Cost effectiveness
Demonstrate that your project represents good value for money and that you aimed for cost efficiency in the estimated budget. You may include any
comments of the horizontal nature in relation to the items presented in the estimated budget.
Praxis is in the best position to coordinate this type of project where the research element meets the advocacy work and awareness raising goals. As the
coordinator of the consortium we have eliminated all unnecessary activities, limited working days and number of people working with the project tasks.
The division of tasks among the partners is also guided by the cost effectiveness. The views and the contribution from the health care officials will
come from the Ministry of Social Affairs, the partner who will receive no funding under this grant. The organisational tasks of the project lie all with
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Praxis to ensure that the non-substantial work of preparing the trainings and the conference is done by an experienced professional with the most cost-
efficient way. The sole NGO –Estonian LGBT Association may target its limited resources to the most relevant tasks, that of designing and
carrying out the substantial part of the trainings.
2.3. European added value
European dimension
Illustrate the European dimension of the planned activities: trans-national dimension of the project; impact/interest for a number of countries;
possibility to use the results in other countries, potential to develop mutual trust/cross-border cooperation among EU countries, contribution to the
consistent and coherent implementation of EU law, and to public awareness about the rights deriving from it etc.
Which countries will benefit from the project (directly and indirectly)? Where will the activities take place?
The project supports the implementation of the EU laws and policies in regard to equality in health care provision across MS and for LGBTQI minority
groups. It will contribute to raising public awareness about the rights citizens can and should enjoy. The main benefit of the project activities will be acquired
by the Estonian society and project ś target groups. However, the project includes an important trans-national component by learning from the European
best practices in Maltese and Spanish (Catalonia) public health care setting for trans people. The Catalonian expert (organisation “Transit”) who will
be advising the project has expressed an interest to discuss and address equally their successes as well as challenges.
The project addresses the inequalities LGBTQI+ people face in health system and barriers that health care professionals may have and witness when
treating these groups of people. This approach is aligned with the European Commission´s efforts to abolish discrimination on any grounds and to uphold
and promote the fundamental rights of LGBTI people through the List of Actions for LGBTI Equality.
The online training to sensitize health care professionals on LGBTQI+ equality will feature Russian subtitles and can be used by the Russian speaking
medical personnel in other Baltic countries. The Estonian LGBT Association, the project ś Beneficiary 1, has close cooperation with similar
organisations in other Baltic countries and plans to disseminate the training among its peers.
By using the adapted version of the FRA study Speaking Professionally methodology (questions) we shall add the Estonian data to the pan-
European pool of knowledge on LGBTQI+ equality.
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2.4 Timetable
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
Activity 1. - Project
management & coordination
Activity 1.1 - Project
management
Activity 1.2 - Financial
management
Activity 1.3 - Monitoring the
implementation of activities
and reporting
Activity 2. - Studying the
barriers of healthcare
professionals when treating
LGBTI people
Activity 2.1- Develop study
methodology
Activity 2.2 - Executing the
study
Activity 2.3 - Preparation for
publication
Activity 3. - Raising
Awareness on LGBTQI+
Equality in Health Care
Activity 3.1 - Training design
and execution
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Activity 3.2 - Producing and
promoting the Online video
training
Activity 3.3 - Printed info
materials for health
professionals
Activity 3.4 - Info materials
for LGBTQI+ people
Activity 3.5 - Final
conference
Activity 4. - Trans
Healthcare Protocol for
Public Health system
Activity 4.1 - Trans Health
Care Protocol
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3. Participants and project management
The list of beneficiaries is included in annex 1 Part A section 1.2.
3.1 Consortium cooperation & division of roles for multi-beneficiary grants
Not applicable for mono-beneficiary grants (single applicants).
Describe the consortium (beneficiaries) and explain how they will work together to implement the project. How will they bring together the necessary
expertise? How do the members 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.
Mention how other third parties (subcontractors, partner organisations, third parties giving in-kind contributions, key stakeholders, etc) will be involved.
Note: When building your consortium you should think of organisations that can help you reaching an objective/solving a problem also in relation to
the EU countries they are located in.
Praxis will coordinate the consortium, the LGBT Assn. (BEN) will mostly provide expertise and community views, will contribute in various activities.
The associate partner, the Ministry of Social Affairs will contribute with the perspective and views of the public decision maker. The Ministry of Social
Affairs has in its portfolio the health and equality departments making it a valuable partner who can facilitate the project outputs to reach the target
groups.
The organisational tasks of the project lie all with Praxis to ensure that the non-substantial work of preparing the trainings and the conference is done by
an experienced professional with the most cost-efficient way. Praxis will contribute with its expertise in research and designing policy interventions. The
Estonian LGBT Association may target its limited resources to the most relevant tasks, that of designing and carrying out the substantial part of the
trainings and information material, as well as contribute to the development of the trans health protocol. LGBT Association is the key stakeholder in
Estonia to advocate for LGBTQI+ rights. The network and contacts of LGBT Association are the key for success to bring together LGBTQI+ people for
dialogue and learning. LGBT Association will bear the bulk of the burden of reaching out to LGBTQI+ people, disseminating information on project´s
events and outcomes.
Project set-up & division of roles for mono-beneficiary grants:
Not applicable for multi-beneficiary grants (multi-beneficiary consortium).
Describe how the beneficiary and third parties (subcontractors, third parties giving in-kind contributions, key stakeholders, etc) will be involved in the
project. How will they bring together the necessary expertise?
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N.A
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3.2 Subcontracting
Give details on subcontracted action tasks (if any) and explain the reasons why (as opposed to direct implementation by the participants).
Note: Subcontracting concerns the outsourcing of a part of the action to a party outside the consortium. It is not simply about purchasing goods or services. We normally expect that the consortium
participants to have sufficient operational capacity to implement the project activities themselves. Sub-contracting should therefore be exceptional.
Include only subcontracts that comply with the rules (i.e. best value for money and no conflict of interest; subcontracting is not possible for key coordinator tasks and may not cover the core of the
action; see art 10 of the Model Grant Agreement).
Participant name Description of the subcontracted action task Estimated costs Justification Best-value-for-money
(EUR)
(why is subcontracting necessary?) (how do you intend to ensure it?)
COO Illustrations, layout and design of the study 3600 Consortium does not have the capacity to complete the Requesting at least 2 different offers
report design tasks since we have no competence in the area from various service providers
BEN1 Fees of the national and foreign experts who 3150 In order to include mental health professionals and other Experts will be paid an average fee in
contribute in trainings for health care health care professionals as well as experts with a Estonia for similar type of work.
professionals background in andragogy to contribute in trainings,
experts outside of consortium must be subcontracted. Budgeted is 7 days of work. Number of
experts is minimum 2. The experts have
not been identified yet.
COO Foreign trans health care professional from 3500 In order to learn from the European best practices and Fees will reflect the average fees for
Spain will be consulted build on that high level medical expert in
corresponding geographical area. No. of
budgeted days to be confirmed.
Other issues:
If subcontracting for the entire project goes beyond 30% of the total
eligible costs, give specific reasons.
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3.3 Project management
Explain the overall project management concept, in particular how decisions will be taken and how permanent and effective communication will be
ensured.
Daily management of the project is achieved through regular exchange to anticipate any emerging problems in the project.
Project manager will organise and manage project activities to achieve the project goals, to ensure smooth and efficient communication with the
Commission, to carry out quality assurance, including process quality and risk management of the project.
She is assisted by the deputy project manager. She supervises the project and advises the project manager in adapting project plan and resource
allocation, guaranteeing that the execution of the project and evaluation of the project is not solely done by one person that could lead to overlooking
issues and risks. She will replace project manager if needed.
3.4 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 shortly their tasks.
Praxis will coordinate the consortium, the LGBT Assn. will mostly provide expertise and community views, will contribute in various activities. The
second BEN, the Ministry of Social Affairs will contribute with the perspective and views of the public decisionmaker. The Ministry of Social Affairs
has in its portfolio the health and equality departments making it a valuable partner who can facilitate the project outputs to reach the target groups.
The organisational tasks of the project lie all with Praxis to ensure that the non-substantial work of preparing the trainings and the conference is
done by an experienced professional with the most cost-efficient way. The Estonian LGBT Association may target its limited resources to the most relevant
tasks, that of designing and carrying out the substantial part of the trainings and information material, as well as contribute to the development of the trans
health protocol.
The project team of Praxis is composed keeping in mind the knowledge and experience required for the project tasks and assuring that the proposed
methodology and deliverables are conducted with the highest quality. The core project team includes 7people. One team member can fulfil several roles.
PROJECT MANAGER –MARI-LIIS SEPPER
Her role is to plan, organise and manage project activities to achieve the project goals, to ensure smooth and efficient communication with the Commission,
to carry out quality assurance, including process quality and risk management of the project.
INTERNAL EXPERTS –MARI-LIIS SEPPER, GERLI PAAT-AHI, MÄRT MASSO
The responsibility of the internal experts is to design the methodological framework for literature review, policy review, and to design the interview
guidelines. The experts will also work on interpretation and contextualization of the results of literature and policy review and qualitative analysis and
coordinate seminars on developing a toolkit to increase women’s participation in policy making.
FINANCIAL OFFICER–IRINA PUTŠKOVA
The financial manager manages project resources to achieve the project goals, regularly assesses project finances and ensures smooth and efficient
reporting.
DEPUTY PROJECT MANAGER (RESPONSIBLE FOR THE TRAININGS) – LIIS ALLMÄE
The task of the deputy project manager is to coordinate the trainings: to communicate with the speakers, to find suitable premises and to provide the
necessary resources. She supervises the project and advises the project manager in adapting project plan and resource allocation, guaranteeing that the
execution of the project and evaluation of the project is not solely done by one person that could lead to overlooking issues and risks. She will replace
project manager if needed.
COMMUNICATIONS OFFICER –LAURA MALLENE
The communications officer will ensure that the key results and messages are communicated in clear and concise manner. She will prepare messages
and media briefs that enable effective communication towards different stakeholders in the project. She will also edit materials published on Praxis
homepage ensuring that the language and the messages are clear and concise. In cooperation with the project manager will coordinate the organization
of seminars.
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PROJECT ASSISTANT – KRISTIN TAMMEOKS
The tasks of the project assistant in this project will be assisting project manager and the whole team in executing the project, preparation of project
documentation, technical editing of deliverables and creating and updating the project web page.
EXTERNAL AND FOREIGN EXPERTS:
AILI KALA (ESTONIAN LGBT ASSOCIATION, PARTNER ORGANISATION), LIINA KANTER (MINISTRY OF SOCIAL AFFAIRS,
PARTNER ORGANISATION);
The project organisation will include two partner organisations with their experts (external expert) and foreign experts. Aili Kala, the legal expert at the
LGBT assn. Liina Kanter in the role of the main contact and expert on behalf of the Ministry of Social Affairs who has in its mandate also the portfolio of
health and equality.
In addition, the project will benefit from the cooperation with experienced expert in creating an informed consent based trans health care protocol in
public healthcare in Europe. Maltese trans health care experts from the public health system will be invited to share their experiences on creating a
trans specific health care model.
3.5 Monitoring and evaluation
Describe how you intend to monitor and evaluate the progress of the project. This includes explaining which quantitative and qualitative indicators you
propose to use for the evaluation and coverage of the project activities and results.
Explain which quantitative and qualitative indicators you propose to use for the evaluation of the outreach and coverage of the project activities and
project results.
Note: We encourage participants to monitor and evaluate changes in attitudes and behaviour of the target group throughout and after the life of the
project. This includes examining the behavioural causes of the issue and its underlying determinants, identifying the encouraged behaviour(s) for each
target group, specifying which behavioural solutions will be tested, explaining how the expected results will be evaluated and whether the proposed
solutions will be pre-tested before full-scale implementation (see more detailed guidance).
The project manager will be responsible for monitoring process, but it will be implemented from a bottom-up approach i.e. the risks will be identified
and assessed in co-operation with all team members.
The monitoring 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 monitoring will include:
• Detailed project plan listing tasks and responsibilities for each team member involved, milestones and timetables as a basis for the monitoring system;
• guidelines for managing and implementing the project;
• arrangements for evaluation and monitoring of the project;
• assessing progress in reaching of qualitative and quantitative indicators;• assessing feedback from participant questionnaires;
• a system of documenting possible changes necessary due to the monitoring process.
The evaluation will be developed and conducted internally, mainly by the quality manager in cooperation with the project manager. The
evaluation will focus on the outputs and outcomes of the project for which quantitative and qualitative targets will be elaborated. The evaluation
will be conducted twice, in the middle and in the end of the project.
The mid-term evaluation will concentrate on the study report and individual interviews. The sub-indicators may include: number of interviewees and
people responding the survey, relevance of the data collected through the interviews, applicability of the research results as an input for the training design
etc.
The final evaluation will proceed with the questions raised in the mid-term evaluation also including new activities (trainings). For the evaluation
of the action research we will use the participation evaluation questionnaire provided by the Commission but may add a few questions if needed.
Additionally, the final evaluation will include a prospective evaluation concentrating on the following questions: How could the results of the
project be valorised? How sustainable is the project in other countries and on the EU level?
The results of the evaluation will be included to the final activities report to the Commission.
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3.6 Dissemination, communication and visibility of EU funding
Describe the dissemination and communication activities which are planned in the framework of the project in order to promote the project
activities/results and maximise the impact (to whom, which format, how many copies, etc.). Clarify how you will reach the target groups, the 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 of results are integral parts of the project since its main activities are oriented towards awareness raising.
Communication strategy is designed to support the project’s main goal. More specifically, the communication strategy will aim to: 1) establish a
better understanding of the project activities; 2) support discussions, engaging our target groups as well as wider audience to openly discuss and
understand the topic; 3) introduce the results of the projects main outcomes for our main target groups to improve the situation; 3) increase interaction and
engagement between our main target groups and stakeholders to help them facilitate the change, and 4) engage them as ambassadors in
dissemination of results and messages.
Communication strategy takes collaborative approach to communication and, in addition to communicating with direct target groups, we will
engage different key stakeholders and organizations to support our communication goals, multiply its results and provide network and platform
for sustainable communication and transferability of project results. Our stakeholders and multipliers include mainly (but are not limited to) other
non-governmental organizations that are responsible for enhancing open government and democracy-building.
Our aim in implementing communication strategy and increasing transferability of the results is to enhance both target groups’ and stakeholders’
ownership of and involvement in the project by making the results of the project relevant to them. To reach that goal it is important to engage them
early in the process.
Specific messages of different communication and dissemination deliverables will be crafted in the process, since it is important to leave room for time-
specific/contextual approaches.
Implementing our communication strategy starts from the very beginning of our project, being mainly designed to support our goals and activities
in two critically important dimensions: 1) to ensure that events attract our main target groups and key participants will attend our events; 2) to ensure that
the main results of the project will reach and be used by our target groups; to attract media attention to our events and deliverables.
To reach our communication goals we will use a combination of both interpersonal as well as mass communication tools and channels. Praxis (COO) and
BEN 1 are both active users of FaceBook, Instagram, and publish regularly on their web pages. All these channels will be also used in this project.
Main target groups of communication activities are decision makers, policy makers, health professionals, LGBTQI community, wider public in Estonian
society.
Key messages that will be communicated throughout this project will support and develop the principles of equality, non-discrimination and LGBTQI rights
in area of health care.
Visibility of EU funding will be ensured throughout the project when outputs are published, events organised or project results communicated (printed or
published materials will feature relevant logos and/or text about the source of funding).
3.7 Ethics
Ethics
Describe any ethical issues that may arise during the implementation of the project and the measures you intend to take to mitigate them, including
with regard to the interactions between projects staff, target groups and persons benefitting from the project.
Gender mainstreaming
Describe how you will ensure gender mainstreaming in the project activities. Gender mainstreaming means integrating a gender perspective in the
design, implementation, monitoring and evaluation of a project as appropriate. Project activities should be pro-active and contribute to the equal
empowerment of both genders, and ensure that they achieve their full potential, enjoy the same rights and opportunities. Gender mainstreaming goes
beyond counting the number of women and men in a room. In the delivery of project activities gender mainstreaming shall be ensured by monitoring
access, participation, and benefits among women and men, and by incorporating remedial action that redresses any gender inequalities in project
implementation.
Rights of the child mainstreaming
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
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Associated with document Ref. Ares(2021)5425170 - 02/09/2021
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. For more detailed explanation, see the text of the call.
If your project directly involves children during any of its phases or activities, you are required to provide your child protection policy as Annex 4 (every
organisation member of the project consortium whose work involves children needs to have one). In case your project does not involve children now,
but should that change during the implementation of the project, submit the child protection policy at the same time when requesting the approval for
the change in the project.
The child protection policy document will be carefully assessed and evaluated against the quality award criteria during the selection phase. If Annex 4
is not submitted, if it is very vague, or if it doesn’t constitute a proper child protection policy, the points your proposal will be awarded under the quality
criteria will be significantly reduced (by half). For more detailed explanation, examples and guidelines on the child protection policies, see the text of
the call.
As in every other research context the scientific principle of the project is based on the principles:
• Upholding scientific standards
• Confidentiality: Data protection and privacy
• Social responsibility (see Dench/Iphofen/Dews 2004).
The three mentioned principles call for an additional discussion. In the context where the study results are expected to inform an advocacy or awareness
raising activity there can be a risk of magnifying certain research results in order to justify action. The solid research track and experienced analysts of
Praxis will help to mitigate this ethical risk.
Estonia is a small country where the medical professionals of a certain urban area may easily be recognised based on their statements or experiences.
Additional caution and high researcher ethics is called for to protect the privacy and personal data of the interviewees.
Social responsibility implies that the focus of the research should be socially relevant and bear in mind that the study results and discoveries “are not
absolute, but bound to the values, beliefs and aspirations of the society from which they emanate” (Schuurbiers, 2010).
In addition, we will follow the principles of good scientific practice, taken into account from the stage of research design to dissemination of the
research outcomes:
1. Methodologically honest data generation;
2. Data transparency, especially faithful reproduction;
3. Incomplete publication of data must not falsify the result;
4. Respecting intellectual property, specifically through adhering to the citation rules;
5. No inappropriate attribution of authorship;
6. Conjecture and speculation must be clearly labelled as such;
7. These rules must also apply when the research project in question pursues economic interests.
Gender Mainstreaming
Gender mainstreaming aims to identify and integrate different circumstances and interests of men and women in every project with a social or
political context, both in advance of and at regular intervals during its implementation. In current project the study will look at the data and analyse it where
possible in the gender disaggregated manner.
The concerns of lesbian, bisexual and trans women will receive bigger attention since number of studies have shown that their experiences of discrimination
in various walks of life are more widespread when compared to gay men. The gender mainstreaming policy in the context of present project will entail
keeping in mind the gender component whenever making important decisions such as composing the sample of the study, determining the content of
trainings, reaching out to the target groups and individuals who are invited to the events or activities organised under this project etc.
The rights of the child mainstreaming
The project does not involve any child-aged subjects directly, but most likely the trans health care protocol will address health needs and
concerns of trans teens. The project indirectly contributes to mainstreaming trans children’s rights.
All the activities in the project are carried out keeping in mind the appropriate human rights prism and respecting the rights enshrined in the Carter of
Fundamental Rights of the EU.
3.8 Sustainability and continuation
Describe the follow-up of the project after the EU funding ends. How will the sustainability of the project impact be ensured?
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Which kind of resources/form of collaboration with other entities will be used to take up the project outputs and results? Are there any possible
synergies/complementarities with other activities/projects that could reinforce the long-term sustainability of the project?
We have undertaken this project to facilitate a shift towards more equal health system. By involving main stakeholders in various activities we
expect to reach a wide audience. Rather than offering set solutions, much of the focus during the project is on empowering the participants and
cooperation. We believe this approach will have a wider-reaching and longer-term effect that outlasts the project —it will encourage the participants to
notice situations that help inequality to prevail and to use and adapt appropriate tools to counter the discrimination and inequality in real-life
situations.
The formal structures responsible for health care personnel vocational training (e.g. training centre of Tartu Ülikooli Kliinikum) will be likely to take up
project outputs and we shall aim to collaborate with as many relevant stakeholders as possible in order to ensure that the activities reach the target groups
and that the outputs will be used also after the end of the project.
4. History of changes between your proposal and Annex I to the Grant
Agreement "Description of the Action"
Please state whether you have made any changes in the data entered in on-line forms in the
participant portal (which will become Part A of the Description of the Action) when compared to
Part B of the original proposal (Description of workpackages and activities).
Changes suggested in YES1 One partner (Ministry of Social Affairs) has no
the Evaluation budget under this project, therefore the Evaluation
Summary Report Summary Report suggested to change its role from
Beneficiary to an Associate Partner, and delete it
from the budget table in Part A.
Other changes YES/NO None
Please state whether you have made any changes in Part B of the Description of the Action when
compared to Part B of the original proposal (General Description of the project and applicant
organisation).
Changes suggested in 1. YES 1. Section 1. – References to Estonian situation
the Evaluation 2. YES was further developed (reference to a study,
Summary Report 3. NO legal and policy situation explained etc.).
4. YES 2. Section 2.3 – European added value was
5. YES specified by making references to EU laws
6. YES and policies, including the List of Action for
7. YES LGBTI Equality.
3. Section 3.1 – The roles and the profile of the
consortium members were further explained.
4. Section 3.4 – Project team members in
supportive roles have changed since 2
people have left Praxis since 2020 and new
staff members will be involved in the project.
5. Section 3.5 – Evaluation indicators were
further developed.
1
Delete what is not applicable
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Associated with document Ref. Ares(2021)5425170 - 02/09/2021
6. Section 3.6 – Communication strategy was
further developed to include target groups,
key messages, main channels and how the
visibility of EU funding is ensured.
7. Section 3.7 – The scientific principles were
discussed and elaborated. The gender
mainstreaming policy was further explained.
Other changes YES/NO No of section/page(s), concise description of the
change(s)
Note: Please note that changes to your original proposal should be limited to modifications
suggested in the Evaluation Summary Report (ESR). We strongly advise against any other changes
at this point as they may lead to the Commission considering the modified proposal as not compliant
with the one recommended for funding and terminating the grant agreement preparation. Should
you wish to introduce some modifications nevertheless (e.g. as a result of "force majeure" changes
that occurred since the date of your original proposal), these must be indicated in the table. Failure
to clearly signal any changes made to your proposal may lead to termination of the grant agreement
preparation or – at any point following the signature of a grant agreement – to the termination of the
grant agreement by the Commission. In accordance with Art. 34.3.1 (i)(ii).
17
Grant Agreement number: 963357 — HEALTH — REC-AG-2020 / REC-RDIS-DISC-AG-2020
ESTIMATED BUDGET FOR THE ACTION Associated with document Ref. Ares(2021)5425170 - 02/09/2021
Estimated eligible1 costs (per budget category) EU contribution2 Action's estimated receipts
Financial
C. Direct Reimbursement Maximum EU Maximum Income contributions
A. Direct [D. Direct costs E. Other Action's
B. Direct travel and subsistence costs costs of F. Indirect costs3 Total costs generated given by third
personnel costs of fin. support] direct costs rate %4 Contribution5 grant amount6 total receipts
subcontracting by the action parties to the
beneficiaries
A.1 Employees B.1 Travel B. Subsistence [D.1 Financial E.1 Equipment
(or equivalent) support]
E.2 Other goods
A.2 Natural [D.2 Prizes] and services
persons under
direct contract
and seconded
persons
Cost form7 Actual Actual Actual Unit8 Actual Actual Actual Flat-rate9
f= g=
flat-rate * (a a + b1 + [b2] +
a b1 [b2] No Total [b2] c [d] e h i=g*h j k l m=k+l
+ b1 + [b2] c + [d] + e + f
+ c + [d] + e)
1. PRAXIS 43 264.00 1 604.00 1 448.00 7 100.00 0.00 19 578.00 5 109.58 78 103.58 80.00 62 482.86 62 482.86 0.00 0.00 0.00
2. LGBT ASSOC. 17 424.00 0.00 0.00 3 150.00 0.00 0.00 1 440.18 22 014.18 80.00 17 611.34 17 611.34 0.00 0.00 0.00
3. MSAE 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 80.00 0.00 0.00 0.00 0.00 0.00
Σ consortium 60 688.00 1 604.00 1 448.00 10 250.00 0.00 19 578.00 6 549.76 100 117.76 80.00 80 094.20 80 094.20 0.00 0.00 0.00
1 See Article 6 for the eligibility conditions.
2 The consortium remains free to decide on a different internal distribution of the EU funding (via the consortium agreement; see Article 25.3).
3 The indirect costs claimed must be free of any amounts covered by an operating grant (received under any EU or Euratom funding programme). A beneficiary that receives an operating grant during the duration of the action cannot claim any indirect costs for the year(s) covered by the operating grant (see Article 6.2.F).
4 See Article 5.2 for the reimbursement rate.
5 This is the theoretical amount of the EU contribution, if the reimbursement rate is applied to all the budgeted costs. This theoretical amount is capped by the 'maximum grant amount'.
6 The 'maximum grant amount' is the maximum grant amount decided by the Commission. It normally corresponds to the requested grant, but may be lower.
7 See Article 5.2 for the cost forms.
8 See Annex 2a 'Additional information on the estimated budget' for the details (units, cost per unit).
9 For the flat rate, see Article 6.2.F.
Page 1 of 1
Grant Agreement number: 963357 — HEALTH
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
ANNEX 3
ACCESSION FORM FOR BENEFICIARIES
EESTI LGBT UHING (LGBT ASSOC.), established in KAARLI PST 5-1, TALLIN 10119,
Estonia, (‘the beneficiary’), represented for the purpose of signing this Accession Form by the
undersigned,
hereby agrees
to become beneficiary No (‘2’)
in Grant Agreement No 963357 (‘the Grant Agreement’)
between SIHTASUTUS POLIITIKAUURINGUTE KESKUS PRAXIS and the European Union
(‘the EU’), represented by the European Commission ('the Commission'),
for the action entitled Health Equality, Attitudes towards LGBTQI+ People and Trans Health Care
(HEALTH).
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 conditions it sets out.
SIGNATURE
For the beneficiary/new beneficiary/new coordinator
[--TGSMark#signature-942366059_75_210--]
Kristel Rannaääre with ECAS id n007gujg signed in the Participant
Portal on 06/09/2021 at 11:58:22 (transaction id SigId-157047-WHclf
mnqedH118k088xX2MNTyXuBoUVMRUrUV681Z4HbP0Y4J50EKzM954
zzWGGDTgM3UmG7zWk9V5b0XpgVzzcG-rS0vSrmBGYC4qPWkzdfTt3-
zIiq6sGxzvlzoOgvsikXkhHYrDe6K2aDc3ux8gBzOD7Z0jzrDtffxxyvDJaQ
KVSU6vzH1n5ziEYorh79NpFNfzf1). Timestamp by third party at
2021.09.06 12:58:26 CEST
1
Grant Agreement number: 963357 — HEALTH
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
ANNEX 3
ACCESSION FORM FOR BENEFICIARIES
SOTSIAALMINISTEERIUM (MSAE), established in Suur-Ameerika 1, TALLINN 10122,
Estonia, (‘the beneficiary’), represented for the purpose of signing this Accession Form by the
undersigned,
hereby agrees
to become beneficiary No (‘3’)
in Grant Agreement No 963357 (‘the Grant Agreement’)
between SIHTASUTUS POLIITIKAUURINGUTE KESKUS PRAXIS and the European Union
(‘the EU’), represented by the European Commission ('the Commission'),
for the action entitled Health Equality, Attitudes towards LGBTQI+ People and Trans Health Care
(HEALTH).
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 conditions it sets out.
SIGNATURE
For the beneficiary/new beneficiary/new coordinator
[--TGSMark#signature-998429731_75_210--]
Maarjo Mändmaa with ECAS id n007ln6k signed in the Participant
Portal on 21/09/2021 at 13:42:41 (transaction id SigId-9422-8KLZPH
a9EOC0KT7XlLwpWFEQovyoiRGKwvYk1neRKj1yyUGo0COcd2gYVSK
HQhEQgvgGRv7zoHZZy2qKwlJLZa-jpJZscgsw0KwfOyDFdfrEC-DCFzv
2izZIuxQYocsxrrZ0E4zOzYGWChbzRUVPxhOHcOdE3FYq6wluJbgAAF
RV3TKV3r8KqbSoboWjSaMZM6jqzG). Timestamp by third party at
2021.09.21 14:42:46 CEST
2
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
i print format A4
MODEL ANNEX 4 JUST MGA — MULTI
landscape
FINANCIAL STATEMENT FOR [BENEFICIARY [name] / AFFILIATED ENTITY [name]] FOR REPORTING PERIOD [reporting period]
1
Eligible costs (per budget category) Receipts EU contribution
Financial
C. Direct costs F. Indirect Income Reimburseme Maximum EU
A. Direct personnel [D. Direct costs of fin. E. Other direct contributions given Requested EU
B. Direct travel and subsistence costs of 2 Total costs generated by Total receipts 3 4
costs support] costs costs by third parties to nt rate % constribution contribution
subcontracting the action
the beneficiaries
A.1 Employees (or [D.1 Financial
B.1 Travel B.2 Subsistence E.1 Equipment
equivalent) support ]
A.2 Natural persons E.2 Other goods
[D.2 Prizes ]
under direct contract and services
and
seconded persons
5 Actual Actual Actual 6 Actual Actual Actual 7
Cost form Unit Flat-rate
f= g=
a b1 [b2] No Total [b2] c [d] e flat-rate * (a + b1 a+ b1 +b2 + c [+ d h i j= h + i k l m
+b2 + c [+d ] + e) ]+e+f
[short name beneficiary /
affiliated entity]
The beneficiary/affiliated entity hereby confirms that:
The information provided is complete, reliable and true.
The costs declared are eligible (see Article 6).
The costs 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 12, 13 and 17).
For the last reporting period: that all the receipts have been declared (see Article 5.3.3).
i Please declare all eligible costs, even if they exceed the amounts indicated in the estimated budget (see Annex 2). Only amounts that were declared in your individual financial statements can be taken into account lateron, in order to replace other costs that are found to be ineligible.
1
See Article 6 for the eligibility conditions.
2
The indirect costs claimed must be free of any amounts covered by an operating grant (received under any EU or Euratom funding programme). A beneficiary that receives an operating grant during the duration of the action cannot claim any indirect costs for the year(s) covered by the operating
grant (see Article 6.2.F).
3
See Article 5.2 for the reimbursement rate.
4
This is the theoretical amount of EU contribution that the system calculates automatically (by multiplying the reimbursement rate by the total costs declared). The amount you request (in the column 'requested EU contribution') may be less.
5
See Article 5.2 for the cost forms.
6
See Annex 2a 'Additional information on the estimated budget' for the details (units, cost per unit).
7
See Article 6.2.F for the flat-rate.
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
ANNEX 5
MODEL FOR THE CERTIFICATE ON THE FINANCIAL STATEMENT (CFS)
This document sets out:
- the objectives and scope of the independent report of factual findings on costs declared
under a EU grant agreement financed under the Rights equality and citizenship
Programme 2014-2020 or the Justice Programme 2014-2020 and
- a model for the certificate on the financial statement (CFS).
1. Background and subject matter
[OPTION 1 for actions with one RP and NO interim payments: Within 60 days of the end of
the reporting period, the coordinator must submit to the Commission a final report, which
should include (among other documents and unless otherwise specified in Article 15 of the
Grant Agreement) a certified financial statement (CFS; see proposed model below) for each
beneficiary and (if applicable) each affiliated entity, if:
- the cumulative amount of payments the beneficiary/affiliated entity requests as
reimbursement of actual costs is EUR 325 000 or more and
- the maximum EU contribution indicated for that beneficiary/affiliated entity in the
estimated budget (see Annex 2) as reimbursement of actual costs is EUR 750 000 or
more.]
[OPTION 2 for actions with several RPs and interim payments: Within 60 days of the end
of each reporting period, the coordinator must submit to the Commission a periodic report,
which should include (among other documents and unless otherwise specified in Article 15 of
the Grant Agreement) a certified financial statement (CFS; see proposed model below) for
each beneficiary and (if applicable) each affiliated entity, if:
- the cumulative amount of payments the beneficiary/affiliated entity requests as
reimbursement of actual costs is EUR 325 000 or more and
- the maximum EU contribution indicated for that beneficiary/affiliated entity in the
estimated budget (see Annex 2) as reimbursement of actual costs is EUR 750 000 or
more.
The CFS must be submitted every time the cumulative amount of payments requested (i.e.
including in previous financial statements) reaches the threshold (i.e. a first certificate once
the cumulative amount reaches 325 000, a second certificate once it reaches 650 000, a third
certificate once it reaches 975 000, etc.).
Once the threshold is reached, the CFS must cover all reporting periods for which no
certificate has yet been submitted.]
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The beneficiary must provide the CFS for itself and, if applicable, for its affiliated entity(ies).
The purpose of the audit on which the CFS is based is to give the Commission ‘reasonable
assurance’1 that costs declared as eligible costs under the grant (and, if relevant, receipts
generated in the course of the action) are being claimed by the beneficiary in accordance with
the relevant legal and financial provisions of the Grant Agreement.
The scope of the audit is limited to the verification of eligible costs included in the CFS. The
audit must be conducted in line with point 3 below.
Certifying auditors must carry out the audits in compliance with generally accepted audit
standards and indicate which standards they have applied. They must bear in mind that, to
establish a CFS, they must carry out a compliance audit and not a normal statutory audit. The
eligibility criteria in the Grant Agreement always override normal accounting practices.
The beneficiary and the auditor are expected to address any questions on factual data or
detailed calculations before the financial statement and the accompanying certificate are
submitted. It is also recommended that the beneficiary take into account the auditor’s
preliminary comments and suggestions in order to avoid a qualified opinion or reduce the
scope of the qualifications.
Since the certificate is the main source of assurance for cost claims and payments, it will be
easier to consider amounts as eligible if a non-qualified certificate is provided..
The submission of a certificate does not affect the Commission’s right to carry out its own
assessment or audits. Neither does the reimbursement of costs covered by a certificate
preclude the Commission, the European Anti-Fraud Office or the European Court of Auditors
from carrying out checks, reviews, audits and investigations in accordance with Article 17 of
the Grant Agreement.
The Commission expects the certificates to be issued by auditors according to the highest
professional standards.
2. Auditors who may deliver a certificate
The beneficiary is free to choose a qualified external auditor, including its usual external
auditor, provided that:
- the external auditor is independent from the beneficiary and
- the provisions of Directive 2006/43/EC2 are complied with.
1
This means a high degree of confidence.
2
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).
2
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Independence is one of the qualities that permit the auditor to apply unbiased judgement and
objective consideration to established facts to arrive at an opinion or a decision. It also means
that the auditor works without direction or interference of any kind from the beneficiary.
Auditors are considered as providing services to the beneficiary under a purchase contract
within the meaning of Article 9 of the Grant Agreement. This means that the costs of the CFS
may normally be declared as costs incurred for the action, if the cost eligibility rules set out in
Articles 6 and 9.1.1 of the Grant Agreement are fulfilled (especially: best value for money and
no conflict of interests; see also below eligibility of costs of other goods and services). Where
the beneficiary uses its usual external auditor, it is presumed that they already have an
agreement that complies with these provisions and there is no obligation to find new bids.
Where the beneficiary uses an external auditor who is not their usual external auditor, it must
select an auditor following the rules set out in Article 9.1.1.
Public bodies can choose an external auditor or a competent public officer. In the latter case,
the auditor’s independence is usually defined as independence from the audited beneficiary
‘in fact and in appearance’. A preliminary condition is that this officer was not involved in
any way in drawing up the financial statements. Relevant national authorities establish the
legal capacity of the officer to carry out audits of that specific public body. The certificate
should refer to this appointment.
3. Audit methodology and expected results
3.1 Verification of eligibility of the costs declared
The auditor must conduct its verification on the basis of inquiry and analysis,
(re)computation, comparison, other accuracy checks, observation, inspection of records and
documents and by interviewing the beneficiary (and the persons working for it).
The auditor must examine the following documentation:
the Grant Agreement and any amendments to it;
the periodical and/or final report(s);
for personnel costs
o salary slips;
o time sheets;
o contracts of employment;
o other documents (e.g. personnel accounts, social security legislation, invoices,
receipts, etc.);
o proofs of payment;
for travel and subsistence costs
o the beneficiary’s internal rules on travel;
o transport invoices and tickets (if applicable);
o declarations by the beneficiary;
o other documents (proofs of attendance such as minutes of meetings, reports,
etc.);
o proofs of payment;
for equipment costs
o invoices;
o delivery slips / certificates of first use;
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Associated with document Ref. Ares(2021)5425170 - 02/09/2021
o proofs of payment;
o depreciation method of calculation;
for subcontracting
o the call for tender;
o tenders (if applicable);
o justification for the choice of subcontractor;
o contracts with subcontractors;
o invoices;
o declarations by the beneficiary;
o proofs of payment;
o other documents: e.g. national rules on public tendering if applicable, EU
Directives, etc.;
for costs of other goods and services
o invoices;
o proofs of payment; and
o other relevant accounting documents.
General eligibility rules
The auditor must verify that the costs declared comply with the general eligibility rules set out
in Article 6.1 of the Grant Agreement.
In particular, the costs must:
be actually incurred;
be linked to the subject of the Grant Agreement and indicated in the beneficiary's
estimated budget (i.e. the latest version of Annex 2);
be necessary to implement the action which is the subject of the grant;
be reasonable and justified, and comply with the requirements of sound financial
management, in particular as regards economy and efficiency;3
have been incurred during the action, as defined in Article 3 of the Grant Agreement
(with the exception of the invoice for the audit certificate and costs relating to the
submission of the final report);
not be covered by another EU or Euratom grant (see below ineligible costs);
be identifiable, verifiable and, in particular, recorded in the beneficiary's accounting
records and determined according to the applicable accounting standards of the
country where it is established and its usual cost-accounting practices;
comply with the requirements of applicable national laws on taxes, labour and social
security;
be in accordance with the provisions of the Grant Agreement (see, in particular,
Articles 6 and 9-11a) and
have been converted to euro at the rate laid down in Article 15.6 of the Grant
Agreement:
o for beneficiaries with accounts established in a currency other than the euro:
Costs incurred in another currency must be converted into euros at the average
of the daily exchange rates published in the C series of the EU Official Journal
determined over the corresponding reporting period.
3
To be assessed in particular on the basis of the procurement and selection procedures for service providers.
4
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
If no daily euro exchange rate is published in the EU Official Journal for the
currency in question, the rate used must be the average of the monthly
accounting rate established by the Commission and published on its website;
o for beneficiaries with accounts established in euro:
Costs incurred in another currency should be converted into euros applying the
beneficiary’s usual accounting practice.
The auditor must verify whether expenditure includes VAT and, if so, verify that the
beneficiary:
- cannot recover the VAT (this must be supported by a statement from the competent
body) and
- is not a public body acting as a public authority.
The auditor should base his/her audit approach on the confidence level following a review of
the beneficiary's internal control system. When using sampling, the auditor should indicate
and justify the sampling size.
Specific eligibility rules
In addition, the auditor must verify that the costs declared comply with the specific cost
eligibility rules set out in Article 6.2 and Articles 9.1.1, 10.1.1, 11.1.1, 11a.1.1 and 11a.2.1 of
the Grant Agreement.
Personnel costs
The auditor must verify that:
personnel costs have been charged and paid in respect of the actual time devoted by
the beneficiary’s personnel to implementing the action (justified on the basis of time
sheets or other relevant time-recording system);
personnel costs were calculated on the basis of annual gross salary, wages or fees (plus
obligatory social charges, but excluding any other costs) specified in an employment
or other type of contract, not exceeding the average rates corresponding to the
beneficiary’s usual policy on remuneration;
the work was carried out during the period of implementation of the action, as defined
in Article 3 the Grant Agreement;
the personnel costs are not covered by another EU or Euratom grant (see below
ineligible costs);
for additional remunerations: the 2 conditions set out in Article 6.2.A.1 of the Grant
Agreement are met (i.e. that it is part of the beneficiary’s usual remuneration practices
and is paid in a consistent manner whenever the same kind of work or expertise is
required and that the criteria used to calculate the supplementary payments are
objective and generally applied by the beneficiary, regardless of the source of funding
used);
for in-house consultants: the 3 conditions set out in Article 6.2.A.2 of the Grant
Agreement are met (i.e. that the in-house consultant works under the beneficiary’s
instructions, that the result of the work carried out belongs to the beneficiary, and that
the costs are not significantly different from those for personnel performing similar
tasks under an employment contract).
5
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
The auditor should have assurance that the management and accounting system ensures
proper allocation of the personnel costs to various activities carried out by the beneficiary and
funded by various donors.
Travel and subsistence costs
The auditor must verify that travel and subsistence costs:
have been charged and paid in accordance with the beneficiary's internal rules or usual
practices (or, in the absence of such rules or practices, that they do not exceed the
scale normally accepted by the Commission4;
are not covered by another EU or Euratom grant (see below ineligible costs)
were incurred for travels linked to action tasks set out in Annex 1 of the Grant
Agreement;
were incurred in the eligible countries set out in the call for proposals.
Equipment costs
The auditor must verify that:
the equipment was acquired during the period of implementation of the action, as
defined in Article 3 of the Grant Agreement;
the equipment is purchased, rented or leased at normal market prices;
public bodies have complied with the national rules on public procurement;
the equipment is written off, depreciation has been calculated according to the tax and
accounting rules applicable to the beneficiary and only the portion of the depreciation
corresponding to the duration of the action has been declared and
the costs are not covered by another EU or Euratom grant (see below ineligible costs).
Costs of other goods and services
The auditor must verify that:
the purchase complies with best value for money (or lowest price) and that there was
no conflict of interests;
public bodies have complied with the national rules on public procurement;
the costs are not covered by another EU or Euratom grant (see below ineligible costs).
Subcontracting costs
The auditor must verify that:
the subcontracting complies with best value for money (or lowest price) and that there
was no conflict of interests;
the subcontracting was necessary to implement the action for which the grant is
requested;
the subcontracting was provided for in Annex 1 and Annex 2 or agreed to by the
Commission at a later stage;
4
See the Guide for Applicants — Action Grants.
6
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
the subcontracting is supported by accounting documents in accordance with national
accounting law;
public bodies have complied with the national rules on public procurement.
Ineligible costs
The auditor must verify that the beneficiary has not declared any costs that are ineligible
under Article 6.4 of the Grant Agreement:
costs relating to return on capital;
debt and debt service charges;
provisions for future losses or debts;
interest owed;
doubtful debts;
currency exchange losses;
bank costs charged by the beneficiary’s bank for transfers from the Commission;
excessive or reckless expenditure;
deductible VAT;
VAT incurred by a public body acting as a public authority;
costs incurred during suspension of the implementation of the action;
in-kind contributions from third parties;
costs declared under other EU or Euratom grants (including those awarded by a
Member State and financed by the EU or Euratom budget or awarded by bodies other
than the Commission for the purpose of implementing the EU or Euratom budget); in
particular, indirect costs if the beneficiary is already receiving an operating grant
financed by the EU or Euratom budget in the same period;
costs incurred for permanent staff of a national administration for activities that are
part of its normal activities (i.e. not undertaken only because of the grant);
costs incurred for staff or representatives of EU institutions, bodies or agencies;
costs for activities that do/did not take place in one of the eligible countries specified
in the call for proposals (unless approved by the Commission).
For more information on cost eligibility, see the Guide for applicants — Action Grants.
3.2 Verification of receipts
The auditor must verify that the beneficiary has declared receipts within the meaning of
Article 5.3.3 of the Grant Agreement, i.e.:
income generated by the action (e.g. from the sale of products, services and
publications, conference fees) and
financial contributions given by third parties, specifically to be used for costs that are
eligible under the action.
3.3 Verification of the beneficiary’s accounting system
The auditor must verify that:
the accounting system (analytical or other suitable internal system) makes it possible
to identify sources of financing for the action and related expenses incurred during
the contractual period and
7
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
expenses/income under the grant have been recorded systematically using a
numbering system that distinguishes them from expenses/income for other projects.
8
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
Certificate on the financial statement (CFS)
To
[Beneficiary/affiliated entity’s full name
address]
We, [full name of the audit firm/organisation], established in [full address/city/country],
represented for signature of this audit certificate by [name and function of an authorised
representative],
hereby certify
that:
1. We have conducted an audit relating to the costs declared in the financial statement of
[name of beneficiary/affiliated entity] (the [‘beneficiary’][‘affiliated entity’]), to which
this audit certificate is attached and which is to be presented to the European Commission
under Grant Agreement No [insert number] — [insert acronym], covering costs for the
following reporting period(s): [insert reporting period(s)].
2. We confirm that our audit was carried out in accordance with generally accepted
auditing standards in compliance with ethical rules and on the basis of the provisions of
the Grant Agreement and its Annexes (and in particular the audit methodology
described in Annex 5).
3. The financial statement was examined and all necessary tests of [all][[X]%] of the
supporting documentation and accounting records were carried out in order to obtain
reasonable assurance that, in our opinion and on the basis of our audit
total costs of EUR [insert number] ([insert amount in words]) are eligible, i.e.:
actual;
determined in accordance with the [beneficiary’s][affiliated entity’s]
accounting principles;
incurred during the period referred to in Article 3 of the Grant Agreement;
recorded in the [beneficiary’s][affiliated entity’s] accounts (at the date of this
audit certificate);
comply with the specific eligibility rules in Article 6.2 of the Grant Agreement;
do not contain costs that are ineligible under Article 6.4 of the Grant
Agreement, in particular:
costs relating to return on capital;
debt and debt service charges;
provisions for future losses or debts;
interest owed;
doubtful debts;
currency exchange losses;
bank costs charged by the [beneficiary’s][affiliated entity’s] bank for
transfers from the Commission
excessive or reckless expenditure;
9
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
deductible VAT;
VAT incurred by a public body acting as a public authority;
costs incurred during suspension of the implementation of the action;
in-kind contributions provided by third parties;
costs declared under other EU or Euratom grants (including those
awarded by a Member State and financed by the EU or Euratom budget
or awarded by bodies other than the Commission for the purpose of
implementing the EU or Euratom budget); in particular, indirect costs if
the [beneficiary][affiliated entity] is already receiving an operating
grant financed by the EU or Euratom budget in the same period;
costs incurred for permanent staff of a national administration, for
activities that are part of its normal activities (i.e. not undertaken only
because of the grant);
costs incurred for staff or representatives of EU institutions, bodies or
agencies;
costs for activities that do not take place in one of the eligible countries
specified in the call for proposals (unless approved by the
Commission);
[are claimed according to the euro conversion rate referred to in Article 15.6 of
the Grant Agreement;]
total receipts of EUR [insert number] ([insert amount in words]) have been declared
under Article 5.3.3 of the Grant Agreement and
the [beneficiary’s][affiliated entity’s] accounting procedures are in compliance with
the accounting rules of the state in which it is established and permit direct
reconciliation of the costs incurred for the implementation of the action covered by the
EU grant with the overall statement of accounts relating to its overall activity.
[However, our audit opinion is qualified for:
costs of EUR [insert number]
receipts of EUR [insert number]
which in our opinion do not comply with the applicable rules.]
4. We are qualified/authorised to deliver this audit certificate [(for additional information,
see appendix to this certificate)].
5. The [beneficiary][affiliated entity] paid a price of EUR [insert number]) (including VAT
of EUR [insert number]) for this audit certificate. [OPTION 1: These costs are eligible
(i.e. incurred within 60 days of the end of the action referred to in Article 3 of the Grant
Agreement) and included in the financial statement.][OPTION 2: These costs were not
included in the financial statement.]
Date, signature and stamp
10
Associated with document Ref. Ares(2021)5425170 - 02/09/2021
ANNEX 7
[OPTION 1 if further pre-financing payments foreseen in Article 15.2a:
MODEL FOR THE STATEMENT ON THE USE OF THE PREVIOUS
PRE-FINANCING PAYMENT
For fields in [grey in square brackets]: enter the appropriate data
STATEMENT ON THE USE OF THE FIRST PRE-FINANCING PAYMENT
(To be filled out by the coordinator)
The undersigned:
- declares that […] % of the first pre-financing payment of EUR [insert amount] paid for
Grant Agreement No [insert number] — [acronym] have been used,
- declares that this is based on substantiated data (bank slip/treasury account) provided by
each beneficiary,
- certifies that the information contained in the progress report is full, reliable and true,
and is substantiated by adequate supporting documentation that can be produced in the
context of checks, reviews, audits and investigations,
- requests a second pre-financing payment of EUR [insert amount].
SIGNATURE
For the coordinator:
[electronic signature]
Done on [electronic time stamp] ]
[OPTION 2: Not applicable]
1
Digitally sealed by the European Commission
Date: 2021.09.02 21:30:17 CEST
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
SOTSIAALMINISTEERIUMI, EESTI LGBT ÜHINGU JA SIHTASUTUS
POLIITIKAUURINGUTE KESKUS PRAXISE KOOSTÖÖKOKKULEPE
Eesti Vabariik, Sotsiaalministeeriumi kaudu (edaspidi SoM), registrikood
70001952, asukoht Suur-Ameerika 1, Tallinn 10122, mida esindab põhimääruse alusel
kantsler Maarjo Mändmaa,
ja
Eesti LGBT ühing (edaspidi LGBT ühing), registrikood 80275811, asukoht Kaarli pst
5–1, Tallinn 10119, mida esindab põhikirja alusel juhatuse liige Aili Kala,
ja
SA Poliitikauuringute Keskus Praxis (edaspidi Praxis), registrikood 90005952,
asukoht Ahtri 6a, Tallinn 10151, mida esindab põhikirja alusel juhatuse esimees Urmo
Kübar,
keda edaspidi nimetatakse käesolevas kokkuleppes eraldi pool või koos pooled,
sõlmisid käesoleva koostöökokkuleppe (edaspidi kokkulepe) alljärgnevatel tingimustel.
1. Sissejuhatus
Pooled on otsustanud ühiste vahendite toel viia ellu projekti „Health Equality,
Attitudes towards LGBTQI+ People and Trans Health Care — HEALTH’“ (edaspidi
projekt), (vastav projekti taotlus Euroopa Komisjonis (edaspidi EK) rahuldatud
7.07.2021).
Kokkuleppe sõlmimise alusteks on:
1.1 Ühiselt esitatud rahastamistaotlus Euroopa Komisjoni taotlusvoorus REC-RDIS-
DISC-AG-2020 — Call for proposals to promote the effective implementation of the
principle of non-discrimination.
1.2 Euroopa Komisjoniga sõlmitud toetusleping number: 963357 — HEALTH — REC-
AG-2020 / REC-RDIS-DISC-AG-2020
2. Kokkuleppe ese
2.1. Kokkulepe reguleerib poolte koostööd punktis 1 nimetatud projekti tegevuste
elluviimisel ja rahastamisel.
2.2. Kokkuleppe eesmärk on kindlaks määrata projekti rahastamine ja poolte vastutus.
3. Kokkuleppe kehtivus
3.1. Kokkulepe kehtib alates hilisemast allkirjastamise hetkest kuni projekti lõpuni 30.
oktoobril 2023.a või poolte kohustuste nõuetekohase täitmiseni.
4. Projekti rahastamine
4.1. Projekti viivad ellu Praxis ja LGBT ühing. SoM osaleb konsortsiumis nõuandvas ja
tegevuste mõju võimendavas rollis.
4.2. Projekti eelarve on 100 117, 76 eurot, millest: 80 094, 20 eurot moodustab
Euroopa Komisjoni poolt eraldatud toetus ja 20 023, 56 eurot kaasrahastus.
4.3. Projekti kaasrahastust summas 20 023, 56 eurot (ei lisandu käibemaksu) rahastab
SoM riigieelarve vahenditest 2021. aastal Praxise poolt esitatava maksenõude alusel.
4.4. Praxis teeb LGBT ühingule toetuse väljamakse summas 22 014,18 eurot (ei
lisandu käibemaksu) vastavalt toetuslepingule ja käesolevale kokkuleppele ning LGBT
ühingu poolt esitatava maksenõude alusel. Esimene väljamakse summas 17 611,34
eurot (80%) tehakse kahe nädala jooksul alates maksenõude esitamisest. Ülejäänud
toetus summas 4 402,84 eurot (20%) makstakse välja siis, kui Euroopa Komisjon on
projekti lõpparuande heaks kiitnud ja teinud Praxisele viimase väljamakse.
5. Poolte kohustused
5.1. Kokkuleppe raames kohustub SoM:
5.1.1. väljastatud maksenõude alusel maksenõude tasuma.
5.2. Kokkuleppe raames kohustuvad Praxis ja LGBT ühing:
5.2.1. vastutama projekti elluviimise eest tervikuna;
5.2.2. vastutama projekti juhtimise ja sellega kaasneva aruandluse eest tervikuna.
5.2.3. SoMi jooksvalt kursis hoidma ja teavitama projekti tegevuste, arengute ja
olulisemate tulemuste osas.
5.3. Kokkuleppe raames kohustub LGBT ühing:
5.3.1 edastama Praxisele Praxise kirjaliku palve esitamisest hiljemalt 7 tööpäeva
jooksul kõik projekti elluviimisega seotud dokumendid, mida on vaja projekti
aruandluse jaoks, sh kuludokumendid, tööajaarvestusetabelid, projekti elluviijate
töölepingud, palgamaksmise väljavõtted jms.
6. Poolte vastutus
6.1 Kokkuleppest tulenevate kohustuste täitmata jätmise või mittekohase täitmisega
teisele poolele tekitatud otsese varalise kahju eest kannavad pooled täielikku
vastutust selle kahju ulatuses.
6.2 Kui Praxis ja/või LGBT ühing rikub kokkuleppest tulenevat kohustust, on SOMil
õigus nõuda punktis 4.3 nimetatud summa tagastamist või vähendada kõnesoleva
summa hüvitamise määra.
6.3 Pooled ei vastuta käesoleva kokkuleppe täitmata jätmise või mittekohase täitmise
eest, kui see on tingitud tema tahtest sõltumatutest asjaoludest ehk vääramatu jõu
asjaoludest. Asjaolud peavad olema tõendatavad ja pooled kohustuvad võtma
tarvitusele vastavad abinõud tekkida võivate kahjude vähendamiseks. Pool, kelle
tegevus kokkuleppe järgsete kohustuste täitmisel on takistatud vääramatu jõu
asjaolude tõttu, on kohustatud sellest koheselt kirjalikku taasesitamist võimaldavas
vormis teatama teistele pooltele.
6.4 Vääramatu jõuna ei käsitata kokkuleppe sõlmimise aja seisuga koroonaviiruse
leviku tõkestamiseks õigusaktidega kehtestatud piiranguid. Vääramatu jõu
kohaldumise üheks eelduseks on asjaolu ettenägematus. Kokkuleppe sõlmimise
ajal kehtivad piirangud olid pooltele teada ning kõik tegevused planeeritakse,
arvestades leppe sõlmimise ajal kehtivat olukorda. Kui viiruse leviku tõkestamiseks
kehtestatakse lisapiiranguid, mis takistavad kokkuleppe täitmist, on pooltel õigus
tugineda vääramatule jõule.
7. Poolte esindajad
7.1. SoMi esindajaks kokkuleppe täitmisel on Kaisa Knight (tel 626 9139, e-post:
[email protected]).
7.2. LGBT ühingu esindajaks kokkuleppe täitmisel on Aili Kala (tel: 51911329, e-post:
[email protected])
7.3. SA Praxise esindajaks kokkuleppe täitmisel on Mari-Liis Sepper (tel 585 067 16,
e-post:
[email protected]).
8. Kokkuleppe muutmine ja lõpetamine
8.1. Kokkulepet saab muuta või lõpetada vaid poolte kirjaliku kokkuleppega.
8.2 Kokkuleppe muutmise soovist teatab muudatust teha sooviv pool teistele pooltele
kirjalikult vähemalt kaks nädalat ette, kui kokkuleppes ei ole sätestatud teisiti.
8.3. Kui õigusaktidega kehtestatud korras muudetakse toetuse andmist ja kasutamist
reguleerivaid õigusakte või dokumente ning sellised muudatused mõjutavad
kokkuleppe rahalist mahtu või hüvitamise aluseid või tingimusi, loetakse nimetatud
õigusakti või dokumendiga vastuolus olevad kokkuleppe sätted muudetuks ning alates
vastava õigusakti või dokumendi muudatuste jõustumise päevast lähtutakse selliste
sätete puhul toetuse andmist ja kasutamist reguleerivate õigusaktide ja dokumentide
muudetud tingimustest. Pooled käituvad õiguslike muudatuste osas heas usus ning
vajadusel teavitavad üksteist kirjalikku taasesitamist võimaldavas vormis hiljemalt viie
tööpäeva jooksul õigusakti muudatuse jõustumise päevast arvates. Kui mõni pool peab
vajalikuks, vormistatakse muudatused ka kirjalikult.
8.4 Pool võib kokkuleppe ennetähtaegselt lõpetada teatades sellest teistele pooltele
ette vähemalt 60 kalendripäeva.
8.5 Kokkuleppe tingimuste täitmata jätmisel või mittenõuetekohasel täitmisel on kõigil
pooltel õigus kokkulepe lõpetada.
9. Teadete edastamine
9.1 Pool edastab kokkuleppega seotud teated (märkused, juhised, tahteavaldused)
teistele pooltele kokkuleppes märgitud aadressil või e-posti aadressil.
9.2 Poolel on kohustus teavitada teisi pooli kirjalikku taasesitamist võimaldavas vormis
kokkuleppe täitmist takistavast asjaolust ja selle mõjust kokkuleppe täitmisele.
Teavitada tuleb viie tööpäeva jooksul arvates takistavast asjaolust teada saamisest.
10. Vaidluste lahendamine
10.1 Kokkuleppe täitmisel tekkinud vaidlused lahendatakse eelkõige vastastikusel
mõistmisel põhinevate ja avalikke huve arvestavate läbirääkimiste teel. Pooled
lähtuvad heast tahtest, eeldades, et pooled peavad silmas ühist eesmärki tagada
projekti tulemuslik ja nõuetekohane elluviimine ning kokkuleppe täitmisel ei ole ühelgi
poolel soovi teist poolt kahjustada.
10.2 Kokkuleppe mittesaavutamisel lahendatakse vaidlused vastavalt Eesti Vabariigi
õigusaktidele.
11. Lõppsätted
11.1 Kokkuleppe lahutamatuteks osadeks on lisa 1 Projekti rahastusotsus Euroopa
Komisjoni poolt ja lisa 2 Praxise, LGBT ühingu, SoMi ja Euroopa Komisjoni vahel
sõlmitud leping projekti elluviimiseks.
11.2 Kokkulepe on allkirjastatud digitaalselt.
Poolte allkirjad
/Allkirjastatud digitaalselt/ /Allkirjastatud digitaalselt/ /Allkirjastatud digitaalselt/
Maarjo Mändmaa Aili Kala Urmo Kübar
Kantsler Juhatuse liige Juhatuse esimees
E-post:
[email protected] E-post:
[email protected] E-post:
[email protected]