The associates and lawyers Ms. Tamara Kek, Mr. Miha Kunič and Mr. Jorg Sladič, who on behalf of the PanSlovenian Shareholders' Association (VZMD) represent over a thousand expropriated holders of subordinated bonds and shares of Slovenian banks before the EU Court in Luxembourg, have - in the process of preparing responses for the Constitutional Court of the Republic of Slovenia as to whether the European Commission's Banking Communication is indeed binding(?) and whether it actually invalidates provisions of other legal acts pertaining to investor rights  – tabled the motions to the EU Court to hold oral proceedings in regard to this case.

In the written opinions provided to the EU Court, the Bank of Slovenia (BS), State Attorney's Office and the National Assembly of the Republic of Slovenia have stated a number of blatant falsehoods about the supposed extent of catastrophic situation in Slovenian banks in December 2013 and which is why - only then and only in Slovenia - the Banking Communication of the European Commission was deemed binding, whereby the entire cancellation of all subordinated bonds in all banks recapitalized by the state was supposed to be the only possible interpretation of the Communication. Thus in the written opinion provided to the EU Court in April 2015, the BS outlined the macroeconomic situation in Slovenia in December 2013 using the assumptions, which had already been used for the cancellation for its justification that is "clarification" of the cancellation – therefore along with continuation and even additional deepening of recession – whereby BS "overlooked" that, at the time of writing the opinion, it had been clear for more than a year that the assumptions were utterly unrealistic. What is more - as early as on December 4, 2013, which is two weeks before the BS had ordered cancellation, on the website of Eurostat, an official statement that the quarterly GDP of Slovenia remained stable in the middle of 2013 was published (http://ec.europa.eu/eurostat/documents/2995521/5168826/2-04122013-BP-EN.PDF)!

As if this had not sufficed for misleading the highest EU Court, in its written opinion, the BS also described the capital deficit of Slovenian banks during the fall of 2013 using highly unrealistic evaluations, whereby it "forgot" to mention that to make the evaluations it hired consulting companies which are not adhering to accounting standards and principles and had never before performed such tasks, and that the BS chose a "limited scope of information" which served as a basis for the consulting company to make the evaluations and provided - nevertheless for a fantastic fee (in excess of EUR 10 million) - even "clarifications" how they should be made (www.finance.si/8824165/). The claims of the BS, that in December 2013, both the situation in Slovenian banks and the macroeconomic situation in Slovenia were supposedly extremely poor, were also uncritically taken as a naked fact also by the National Assembly of the Republic of Slovenia and the State Attorney's Office in the written opinion and thus "itself reinforced the viewpoint" that the specific situation in Slovenia in December 2013 called for a specific legal interpretation of the European Commission's Banking Communication.

Albeit it is formally and legally clear that the question as to whether the European Commission's communications are to be treated as binding EU legal acts, and the GDP data of an EU member state and the capital deficit of certain banks in the state - even if they were credible - totally irrelevant, simultaneously reiterates a fact that the EU Court was provided with the information by the three important institutions in the Republic of Slovenia, whereby each of them claimed to have formulated the viewpoint by themselves and in a professional manner. For this reason, in the motion for the oral proceedings the authorized persons of expropriated holders stress that - in case the EU Court decides to consider the claims of the institutions in its judgment - the oral proceedings is all the more necessary as it will enable the expropriated holders, amongst other things, to present the Court official documents clearly indicating that the real situation in the Slovenian economy and Slovenian banks was significantly better than the one, which was claimed to be during the cancellation/expropriation by the Government of the Republic of Slovenia, and which is being referred to in written opinions.

In Brussels this year too, the European Federation of Investors and Financial Service Users (Better Finance) organized a high visibility press conference, and presented the only(!) objective report on real returns of European savings funds "Pension Savings: The Real Return" 2015 Edition.

The report, which was published for the third consecutive year with the support of the European Commission, is this time more comprehensive as it covers 15 European Union countries and shows that the lack of consumer trust is a direct consequence of the inability of many financial intermediaries to deliver decent long term returns. In addition to poor returns, excessive management costs, lack of information - both for savers and regulating authorities - about the real values of saved resources and the lack of comprehensive independent reports on real returns of such funds are particularly set out. 

The reforms of pension funds and savings across the EU, are espoused also by VZMD through the Better Finance – in so doing, the President, Mr. Kristjan Verbič, the Executive Board member of Better Finance, was also engaged in the last year's presentation (VIDEO), whereas this year he attended the important Annual meeting and conference of the World Federation of Investors (WFI), which simultaneously unfolded in Milan, Italy.

On Monday, the 12-member economic delegation from the Russian region of Yaroslavl arrived in Slovenia. This is a return visit of representatives of enterprises and institutions from the Russian Federation after more than year since the Slovenian economic delegation has paid visit to Yaroslavl with 30 representatives onboard from 21 enterprises and institutions, and among them - as part of the 7th international tour (VIDEO) of the PanSlovenian Investors' & Shareholders' Association (VZMD) business-investor programs - was the President, Mr. Kristjan Verbič, who already took part in the Business Forum in Ljubljana on Tuesday, and today in Nova Gorica as well.

Supported by Public Agency of the Republic of Slovenia for the Promotion of Entrepreneurship, Innovation, Development, Investment and Tourism - SPIRIT Slovenia, the participants were presented Slovenian and Yaroslavl business environments and a few enterprises, and were addressed by the President of the National Council of the Republic of Slovenia, Mr. Mitja Bervar, the Ambassador of the Russian Federation in Slovenia, His Excellency dr. Doku Zavgajev, President of the committee for the economic policy, investments, industry and entrepreneurship in the Yaroslavl parliament, Mr. Aleksandr Kučmenko, and the head of the delegation who is also the director of the Department of investment policy in the government of the Yaroslavl region, Mr. Andrej Zolotovskij, with whom Mr. Verbič met during B2B meetings.

Yesterday the economic delegation from Yaroslavl visited Koper and after the mayor's reception also the Port of Koper, Postojna airport and Godovič, where it paid visit to several enterprises and met with the representatives of local communities; however today the delegation is visiting Ajdovščina and Nova Gorica, where the Business Forum including B2B meetings is taking place after the mayor's reception.

Last weekend marked the closure of the three-day meeting of the World Federation of Investors (WFI) as well as numerous conferences, meetings and the general meeting of this reputable international organization, which has brought together over 60 national associations of shareholders and investors in four decades. The conference - as always since the acceptance of VZMD in Sao Paolo in 2008 - was attended by the VZMD President, Mr. Kristjan Verbič, who presented the association's activities whereby the greatest interest and attention was paid to the processes related to the expropriation of the holders of subordinated bonds and stocks of Slovenian banks. Just before the meeting, VZMD published the news stating that the EUROPEAN COMMISSION officially bolstered the position of VZMD.

One of the major topics was also the "Volkswagen scandal", whereby the prominent participants from 25 countries agreed upon collaboration options and joint action with the International Financial Litigation Network (IFLN), on behalf of affected investors and shareholders as well as users and suppliers, which was specifically pointed out by Mr. Verbič also in view of the potential interests of the Slovenian automotive industry and he suggested to organize the legal protection also for the suppliers. In view of the above, VZMD appeals to all shareholders, users and suppliers of Volkswagen in Slovenia and in the former Yugoslavia to let them know if interested in taking part in the pending procedures.

The meeting of the WFI was concluded with the visit to the high visibility World's Fair, EXPO Milano 2015, where VZMD, supported by SPIRIT Slovenia, provided free tickets for the guided tour and presentations at the Slovenian pavilion to the WFI delegation. The highest representatives of the WFI were personally welcomed by the General Commissioner of the EXPO Milano 2015 Section of the Republic of Slovenia, Ms. Jerneja Lampret, and they showed great interest in viewing the attractive presentation of Slovenia, its culture, history and knowledge and were thrilled at the offer and possibilities, which some of them learned about also during the WFI meeting in 2012 in Slovenia (VIDEO).

From the 1^st to 3^rd of October, Milan, Italy, was the venue of the annual general meeting and conference of the World Federation of Investors (WFI), which was also attended by Mr. Kristjan Verbič representing the Republic of Slovenia. The gathered representatives of investors from 25 countries in two days addressed the current problem areas and topics, such as financial literacy focused on the young, implications of the economic crisis for investments, banking systems, situation on the emerging markets, etc. Likewise, the situation and opportunities in each of the Member States and their significant ongoing legal proceedings to protect investors were presented. Here the WFI has closely collaborated also with the International Financial Litigation Network, representatives of investors associations (IFLN), with which also VZMD has fruitfully collaborated.

The prominent international federation - with an almost 40-year tradition - WFI brings toghether over 60 national associations of investors and shareholders from all over the globe, and VZMD became the full member in Sao Paolo, Brazil in 2007. VZMD has ever since managed to win the organization of the annual general meeting in Slovenia. The first meeting took placein 2008 (VIDEO), upon establishment of the Invest to Slovenia program and together with the first investor conference investo.si (VIDEO), whereas the second meeting took place in 2012 (VIDEO), and was the largest meeting of representatives of investors and shareholders on a global scale »Investors' Week« (VIDEO). It was the first time for the annual general meetings of three international associations, apart from WFI also EuroInvestors and Euroshareholders, to take place at one venue concurrently. 

Upon conclusion of the official part of the meeting, the WFI representatives visited the EXPO Milan 2015, where VZMD has managed to include the special visit to the Slovenian pavilion in the program and thus continue the fruitful collaboration with SPIRIT Slovenia, which hosted the WFI delegation.  

EU Court in Luxembourg has provided VZMD with the written position of all persons concerned in the case of C-526/14, Tadej Kotnik e.a., in which the court was asked by the Constitutional Court of the Republic of Slovenia to clarify the legal nature of the communication published by the European Commission – focusing on the question whether the Banking Communication as of August 1, 2013, with which the Ministry of Finance of the Republic of Slovenia and the Bank of Slovenia »justify« the cancellation of all shares and subordinated bonds in as many as six Slovenian banks, is legally binding. Apart from the European Commission, the Bank of Slovenia, the National Assembly of the Republic of Slovenia, and the Republic of Slovenia itself, represented by the State Attorney's Office, the brief written opinions on behalf of their countries were provided by the State Attorney's Offices of Ireland, Italy and Spain.

The European Commission (EC), the creator of the communications whose legal nature was subject to the question posed by the Constitutional Court of the Republic of Slovenia to the EU Court, did -in its written report submitted to the EU Court in the document with the reference number 988019 - explicitly and unequivocally bolster the position of VZMD and expropriated investors in Slovenian banks that its Banking Communication is not a legally binding act: "The Banking Communication shall not bind the Member States" (page 5, section 11), and "The Banking Communication is not binding on the Member States" (page 7, section 18).

VZMD has, on behalf of the expropriated investors in Slovenian banks, who it represents, repeatedly cautioned to the absurdityof the claims made by the senior officials of the Ministry of Finance of the Republic of Slovenia and the Bank of Slovenia (BS), saying that the cancellation of all subordinated bonds in the Republic of Slovenia was unavoidable as it was ordered through the EC Banking Communication, which is allegedly a legally binding EU act. The absurdity of such claims is clearly evident from at least two legal facts: Article 288 of the Treaty on the Functioning of the EU which is defining legal acts of the EU, has no mention of the EC communication whatsoever; in addition, all legal acts of EU are published in the regulatory part of the Official Journal of the EU (section L - Legislation), whereas the EC communication in the announcements (section C - Information and Notices). As the officials of the Ministry of Finance of the Republic of Slovenia and the Bank of Slovenia have persistently "relativized" mentioned facts, VZMD has frequently reiterated that even the EU Court has in all three legal wrangles so far, in which the EC reproached the EU Member States (also) for the failure to comply with the EC communications, dismissed the reproach as unfounded explicitly stating that the EC communications are not legally binding acts (judgments in the matters C-70/06, EC against Portugal, §34; C‑369/07, EC against Greece, §112; in C-270/11, EC against Sweden, §41).

Hence even the EC expressly agrees with the legal fact that its communications are not legally binding acts and this has been explicitly indicated twice in its written position. However, the opposite written position provided by the Bank of Slovenia unfortunately has anew confirmed that this is an institution which has already ages ago disregarded any objectivity by covering up its inadmissible conduct and by resorting to falsehoods and misleading statements without hesitation  - and if nothing works out, even to the utterly absurd ones. In so doing, in its written opinions provided to the EU Court in the document with the reference number 988072, the Bank of Slovenia stated: "The Banking Communication in terms of the interpretation of the EU primary law is only binding on the Commission but also on the national courts and other institutions in a Member State" (page 15, section 28)!

In view of the above, the VZMD President, Mr. Kristjan Verbič, stated: "As it seems, the Bank of Slovenia believes that it is highly competent to lecture the EU Court on withdrawal from its own - and the only reasonable - position on the unbinding legal nature of the European Commission communications, and as if this were not sufficiently arrogant and disgraceful, it also claims to understand the legal nature of the European Commission acts better than the European Commission itself!"

The legal experts, who have together with VZMD been preparing the materials for proceedings before the EU Court believe that such absurd statements by the Bank of Slovenia should in no way affect the ruling of the EU Court, but VZMD shall nevertheless submit a proposal to grant the oral proceedings in this matter at the Court. The EU Court normally institutes oral proceedings only in exceptional circumstances, but VZMD believes it to be useful in this case - also in the face of increasing non-credibility of the actions taken Bank of Slovenia, which is supposed to be the guardian of fairness.»Unfortunately in the Slovenian case, the Central bank has evidently focused majority of its efforts - together with certain representatives of the financial authorities - on the fight against its own citizens, which is a particularly alarming phenomenon we are compelled to deal with and "treat" abroad as well,« was how Mr. Verbič commented on the further steps of VZMD.

On Friday night, the round table on ownership restructuring and investment opportunities in Poland and Slovenia marked the beginning of the two-day program of the Polish-Slovenian Business Forum in Ljubljana which, under the authority of the Polish Ministry of Foreign Affairs, was attended by nearly 60-member delegation from Poland.

Besides numerous representatives of companies and institutions from both countries, among whom were also Secretary at the Ministry for the Economic Development and Technology, Mr. Metod Dragonja, CEO of the Bank Assets Management Company BAMC/DUTB, Mr. Torbjorn Mansson and Head of Client Relation Department at the Warsaw Stock Exchange, Mr. Pawel Czupryna, and at the invitation of the organizers the event was also attended by the PanSlovenian Shareholders' Association (VZMD) President, Mr. Kristjan Verbič, who seized the opportunity for the activities related to both the VZMD's international business-investor programs: Invest to Slovenia – investo.si and International Investors` Network – invest-to.net, and usual efforts of VZMD linked to the scandalous expropriation of Nova KBM shareholders. The latter was touched upon also by the participants of Monday's round table, as Nova KBM's shares also quoted on the Warsaw Stock Exchange, and the cancellation directly or indirectly affected also numerous investors and Polish citizens. In this regard, the participants stressed that unfortunately exactly this keeps tarnishing the reputation of Slovenia, the issue of which has ever since cancellation/expropriation been raised also by VZMD.

Yesterday the event went on with the official opening of the business forum, where the attendees were addressed by the Ambassador of the Republic of Poland in Slovenia, His Excellency Paweł Czerwiński, leader of the Polish delegation and the Under-Secretary at the Ministry of Foreign Affairs of the Republic of Poland,  Ms. Katarzyna Kacperczyk, Secretary at Ministry of Foreign Affairs of the Republic of Slovenia, Ms. Dragoljuba Benčina, Secretary at the Ministry for the Economic Development and Technology, Mr. Aleš Cantarutti, and the General Manager of the Chamber of Commerce and Industry of Slovenia, Mr. Samo Hribar Milič.

In addition to compelling presentations of business environments, opportunities and examples of best practices, the VZMD President was also actively engaged in B2B meetings, where almost  90 participants from both countries got together.

VZMD has so far excellently collaborated with partners from Poland. To name a few, in 2011, VZMD organized the high visibility »Slovenian day at the Warsaw Stock Exchange« (VIDEO), and last year, Mr. Verbič also attended the international conference »Warsaw Capital Market Summit 2014« at the Warsaw Stock Exchange and the conference of the National Bank of Poland and the International Monetary Fund »Building Market Economies in Europe: Lessons and Challenges after 25 Years of Transition«.

On Friday evening, the members of the National Assembly of the Republic of Slovenia adopted the amending act to the Book Entry Securities Act (ZNVP-1) in the third reading with 70 votes for and 4 against, and which to a large extent draws on the VZMD's proposals to alleviate the catastrophic impact of the amending act of the ZNVP-1, which namely brings with it the abolishment of the registry accounts for about 260,000 natural persons. Following the unanimous support to the amendment of the ruling coalition within the 2^nd reading on Wednesday September 23, 2015, the members also supported, with 69 votes for and 4 against, the additional amendment to the Article 48 of the ZNVP-1, tabled by the deputy group of the Slovenian Democratic Party (SDS), which by means of its additional 3^rd paragraph shall limit the annual costs of keeping accounts and the compensation for the balance maintenance on the trading account to the maximum of 0.5% of the average value of securities on the account..

Following the support to VZMD to limit such costs, which have too frequently accounted for the significant part of the minority shareholder portfolio value, such additional amendment also followed the VZMD's opinion on the coalition's amendment, delivered to the National Assembly of the Republic of Slovenia on September 17, 2015, which is why it was supported by VZMD immediately upon its tabling, on Thursday, September 24, 2015. On this occasion, the VZMD President, Mr. Kristjan Verbič, welcomed the significant progress in handling registry accounts abolishment problems, which »nevertheless reflects a certain extent of regard to uphold minority shareholders and regulate the status of investors - particularly those who are keen on being part of the Slovenian joint-stock companies, and in this manner maintain and increase effectiveness of tied up resources, save for their old age, healthcare services, education of their offspring, etc.« and was also pleased about the fact that the »the party politics was finally unified and responded to the VZMD's appeal to make slight additional efforts when formulating the definitive text of Article 48 of the ZNVP-1 proposal, and, after all already invested efforts and adjustments, to reach a solution which could be classified as acceptable and optimal in the usual context of the claimed urgency .«

Note that, ever since the drafting of the mentioned Act, VZMD has vigorously opposed the abolishment of the registry accounts at the Central Securities Clearing Corporation (KDD), where nearly 260,000 minority shareholder have their securities freely deposited, which have been largely acquired through ownership certificates. As it has been proved necessary that the abolishment of the registry accounts could not be avoided, VZMD, on September 4, 2015 put forward a compromise proposal, which represented to a large extent a foundation also for the amendment of the ruling coalition. The latter provided for the delay of the natural person registry account abolishment into 2017, and ushered in the direct reporting by the KDD. Thus, for at least 100,000 minority shareholders - who hold shares worth up to EUR 100 on their registry accounts at KDD - the amendment brings court fee exemption in the event that they do not transfer their shares to trading accounts at brokerage firms or banks which would consequently lead to transfer to the court deposit after January 1, 2017. In this regard, VZMD firmly raised the question of methods for valuation of shares on registry accounts and of the inappropriateness of the very low limit of EUR 100 up to which the shareholders are entitled to the court fee exemption.

However, as early as in February this year, VZMD sent to the Ministry of Finance of the Republic of Slovenia even an Urgency, with which they reiterated that Ministry, among other things was proposing abolishment of registry accounts at KDD, obscuring ownership structures, lowering the level of legal security, making it more difficult to attend meetings, additional financial and social burdens, explicitly reducing the number of minority shareholders and the proportion of local ownership in Slovenian companies etc. The first proposed amending act of the ZNVP-1 namely bore all the more serious consequences for the capital market, especially for over 260,000 Slovenian minority shareholders (natural persons), who might be the next year relentlessly deleted from the register of shareholders, that is, they might lose their shares in the face of abolishment of (their) registry accounts at the KDD, or »punished« with the court fees for the automatic court deposits of their shares. That is why VZMD has insisted on scathing criticism of such amending act of the ZNVP-1, which was anew pointed out by the VZMD President also in the meeting of the Finance and Monetary Policy Council of the National Assembly of the Republic of Slovenia on Wednesday, September 2, 2015. (RECORDING of the meeting – VZMD caveats and proposals from 51:40 minute onwards)

Even beforehand, VZMD had frequently voiced against the proposed abolishment of the registry accounts (inter alia also using the remarks and proposals regarding the ZNVP-1 on October 28, 2014, November 26, 2014 and February 5, 2015), in addition, VZMD has since October 2014 been actively engaged in harmonizing the text of the Proposed directive of the European Parliament and Council of the EU regarding changes to the 2007/36/ES directive regarding encouraging the long-term shareholder engagement and 2013/34/EU directive regarding specific elements of the declaration about corporate governance. Regarding the Proposed directive directly related to the Proposed amending act of the ZNVP-1, VZMD, as early as on October 6, 2014 sent its remarks and proposals - in line with the Better Finance proposals (European Federation of Financial Services, where Mr. Verbič is a member of the Executive Board) - also to directly to the Ministry for Economic Development and Technology.

It has been exactly three years since the beginning of the largest gathering of investor representatives and shareholders in the world »Investors' Week« (VIDEO), which took place in Slovenia with the support of the European Commission and organized by VZMDwithin its international business-investor programsInvest to Slovenia - investo.si & International Investors' Network - invest-to.net, from September 19th to 23rd, 2012.

Right after VZMD sent the compromise amendment and appeal to the National Assembly of the Republic of Slovenia on September 4 to alleviate the catastrophic impact of the proposed amending act of the Book Entry Securities Act (ZNVP-1) and following numerous conversations with the representatives of the Parliamentary groups, it was on September 15 that the Parliamentary groups of the ruling coalition tabled an amendment, which draws on and also includes the compromise proposals by VZMD to a large extent. In addition to the delay of the abolishment of registry accounts for natural persons until 2017 and mandatory direct reporting by the Central Securities Clearing Corporation (KDD), the new coalition's proposal would entitle at least approx. 100,000 shareholders - who hold shares worth up to EUR 100 on their registry accounts at KDD - to court fee exemption, in the event that they do not transfer their shares to trading accounts at brokerage firms or banks which would consequently lead to transfer to the court deposit after January 1, 2017.

Thus, the VZMD president, Mr. Kristjan Verbič, sent to the National Assembly of the Republic of Slovenia yesterday VZMD's opinion on the coalition's amendment regarding Article 48 of ZNVP-1 in which he welcomes the significant progress in addressing the issue of registry account abolishment, which reflects a certain degree of understanding for upholding minority shareholders in the Republic of Slovenia. On this occasion too, Mr. Verbič points out that »yet another step in the right direction unfortunately does not imply that the goal of the appropriate (related) solution for the status of minority shareholders has been reached - particularly of those who are keen on being part of Slovenian joint-stock companies, and in this manner maintain and increase effectiveness of tied up resources, save for their old age, healthcare services, education of their offspring, etc.« In this context, the VZMD President appeals to the deputies to make slight additional efforts when formulating the definitive text of Article 48 of the ZNVP-1 proposal as »it would be truly a pity, after all already invested efforts and adjustments, to be so near, yet so far from the solution which could be classified as acceptable and optimal in the usual context of the claimed urgency.«

However, the first, (still) proposed amending act of ZNVP-1, bears severe consequences for the capital market, particularly for over 260,000 Slovenian minority shareholders (natural persons), who might be the next year relentlessly deleted from the register of shareholders, that is, they might lose their shares in the face of abolishment of (their) registry accounts at the KDD, or »punished« with the court fees for the automatic court deposits of their shares. That is why VZMD has insisted on scathing criticism of such amending act of ZNVP-1, which was anew pointed out by the VZMD President, Mr. Kristjan Verbič, also in the meeting of the Finance and Monetary Policy Council of the National Assembly of the Republic of Slovenia on Wednesday, September 2. (RECORDING of the meeting – VZMD caveats and proposals from 51:40 minute onwards)

Note that VZMD sent an urgency, to the Ministry of Finance of the Republic of Slovenia in February, with which they reiterated that Ministry, among other things, was proposing abolishment of registry accounts at KDD, obscuring ownership structures, lowering the level of legal security, making it more difficult to attend meetings, additional financial and social burdens, explicitly reducing the number of minority shareholders and the proportion of local ownership in Slovenian companies etc.

Even beforehand, VZMD had  frequently voiced against  the proposed abolishment of the registry accounts (inter alia also using the remarks and proposals regarding the ZNVP-1 on October 28, 2014, November 26, 2014 and February 5,. 2015), in addition VZMD has since October 2014 been actively engaged in harmonizing the text of the Proposed directive of the European Parliament and Council of the EU regarding changes to the 2007/36/ES directive regarding encouraging the long-term shareholder engagement and 2013/34/EU directive regarding specific elements of the declaration about corporate governance.. Regarding the Proposed directive directly related to the Proposed amending act of ZNVP, VZMD sent its remarks and proposals as early as on October 2014 - in line with the Better Finance proposals ( European Federation of Financial Services, where Mr. Verbič is a member of the  Executive Board) - also directly to the Ministry for Economic Development and Technology.