EIB CRECHE Conclusions Report - SG/G/2020/03
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
COMPLAINTS MECHANISM
SG/G/2020/03
EIB CRECHE
Conclusions Report
14 June 2021EIB Group Complaints Mechanism
EIB Crèche Conclusions Report
14 June 2021
Complaint confidential
No
External distribution
Complainant
Internal distribution
Management Committee
Secretary General
Inspector General
Relevant EIB services
Disclaimer
The conclusions presented in this report are based on the information available to the EIB Group
Complaints Mechanism up to 10 March 2021.
iEIB Crèche
The EIB Group Complaints Mechanism
The EIB Group Complaints Mechanism is a tool enabling resolution of disputes in case any member of
the public feels that the European Investment Bank might have done something wrong, i.e. if it has
committed an act of maladministration. The Complaints Mechanism is not a legal enforcement
mechanism and will not substitute the judgement of competent judicial authorities.
Maladministration means poor or failed administration. It occurs when the EIB fails to act in accordance
with a rule or principle that is binding upon it, including its own policies, standards and procedures. The
concept of maladministration includes failure by the EIB to comply with human rights, with applicable
law, or with the principles of good administration. Maladministration may relate to the EIB Group’s
decisions, actions or omissions. This may include the environmental or social impacts of the EIB’s
projects and operations.
One of the main objectives of the EIB Group Complaints Mechanism is to ensure the right to be heard
and the right to complain. For more information on the EIB Group Complaints Mechanism please visit:
http://www.eib.org/about/en/accountability/complaints/index.htm.
iiEIB Group Complaints Mechanism
Contents
EXECUTIVE SUMMARY ........................................................................................................................ 1
1. BACKGROUND............................................................................................................................... 2
a. The complaint .............................................................................................................................. 2
b. Background information .............................................................................................................. 3
2. Work performed by the EIB-CM ...................................................................................................... 4
3. Regulatory Framework .................................................................................................................... 4
a. The EIB Group Complaints Mechanism Policy ........................................................................... 4
b. EIB guidelines on internal communication .................................................................................. 5
c. EIB’s Corporate & Technical Assistance Procurement Guide .................................................... 5
4. Findings ........................................................................................................................................... 6
5. Conclusions ..................................................................................................................................... 8
6. Outcomes ........................................................................................................................................ 9
iiiEIB Group Complaints Mechanism
EXECUTIVE SUMMARY
This report concerns a complaint regarding the decision of the European Investment Bank (EIB) to close
the Crèche l’Abeille (the “Crèche”), the EIB’s communication about this decision, the tendering process
and the impacts of the Crèche’s closure.
The report presents only the findings and conclusions of the EIB Group Complaints Mechanism (EIB-
CM) with regard to the following admissible allegations made in the complaint:
1. Alleged poor communication from the Bank with its staff about the decision to close the Crèche.
2. Allegedly unfair evaluation of the bid submitted by the company Crèche Attitude S.à.r.l. (the
“Service Provider”) due to failure to fulfil the stipulated minimum criterion regarding financial
stability of the service provider.
With regard to the first allegation, the EIB-CM found that:
- Immediately following the decision to close the Crèche, EIB staff were informed via an announcement
on the EIB’s intranet of the decisions on the staff allowances review (phase 1) and the implementation
measures, including the introduction of the new Child Assistance Allowance and the resulting
cancellation of the “crèche subsidy.”
- This initial communication announced that more detailed information would be provided beginning of
January 2020. Furthermore, the EIB services had worked on a plan to communicate to EIB staff about
the changes in staff allowances, including the closure of the Crèche. The Roadshow took place as
planned and the EIB’s relevant services developed various materials to provide information to EIB staff
on the changes to the allowances and the implementation measures.
- The EIB provided targeted communication and support to the parents affected by the termination of
the “crèche subsidy” between January and June 2020.
Based on the above findings, the EIB-CM concluded that the first allegation is ungrounded.
With regard to the second allegation, the EIB-CM found that based on the information provided in the
tender, the mother company of the Service Provider was in possession of the requisite financial capacity
at the time of the tender evaluation. Nevertheless, the EIB-CM found no satisfactory evidence in the
EIB’s file concerning the commitment of the mother company, which is required if a bidder relies on
other entities for the fulfilment of the economic and financial capacity criterion.
The EIB-CM concluded that the second allegation is grounded insofar as the formal requirement of the
fulfilment of the financial capacity is concerned. In this context, the EIB-CM noted that the time of
submission of the second allegation did not allow the EIB to rectify the oversight identified as part of the
EIB-CM’s inquiry. It is worth noting that the oversight resulted only in formal non-compliance, as it did
not affect the execution of the contract and its performance by the Service Provider was satisfactory to
the Bank.
Suggestions for
Allegation Outcome
improvement
Alleged poor communication from No grounds No
the Bank with EIB staff about the
decision to close the Crèche
Allegedly unfair evaluation of the bid Recommendation: No
submitted by the company Crèche The EIB-CM recommends that the competent EIB
Attitude S.à.r.l. due to failure to fulfil services amend the relevant procedures by providing
the stipulated minimum criterion further guidance about the collection and archiving of
regarding financial stability of the the documentary evidence necessary to prove
service provider successful bidders’ capacity to meet selection criteria.
1EIB Crèche
1. BACKGROUND
a. The complaint
1.1 On 19 April 2020, the EIB Group Complaints Mechanism (EIB-CM) received a complaint from
the staff delegation of Crèche l’Abeille (the “complainant”) regarding the decision of the
European Investment Bank (EIB) to close the Crèche l’Abeille 1 (the “Crèche”), the EIB’s
communication about this decision, the tendering process and the impacts of the Crèche’s
closure.
1.2 Table 1 provides an overview of the complainant’s allegations as identified by the EIB-CM on
the basis of the complaint and subsequent communication with the complainant.
Table 1 – Overview of allegations made by the complainant
Allegation Sub-allegations
Alleged poor communication from the 1. Alleged poor communication with the Crèche
Bank about the intention/decision to manager and staff.
close the Crèche 2. Alleged poor communication with EIB
beneficiaries/staff.
Alleged irregularities in the tendering 3. Allegedly unfair evaluation of the bid
and contracting process for childcare submitted by the company Crèche Attitude
services Luxembourg S.à.r.l. due to failure to fulfil the
stipulated minimum criterion regarding financial
stability of the service provider.
4. Amendment of the contract with Crèche
Attitude Luxembourg S.à.r.l. (compared to
previous contracts for provision of the same
services) done by the Bank with purpose to
allow closure of the Crèche, whilst avoiding that
the Bank would have to assume responsibility
for the staff of the Crèche in the event of its
closure.
Alleged negative impacts resulting from 5. Alleged negative impacts of the decision to
the Bank’s decision to close the Crèche close the Crèche and failure of EIB to take
responsibility.
1.3 During its inquiry, the EIB-CM was informed that Crèche Attitude Luxembourg S.à.r.l. had
initiated legal proceedings at national level against the EIB concerning the latter’s decision to
close the Crèche. As a result, on 16 December 2020, the EIB-CM informed the complainant
that, based on Article 4.3.8 of the EIB-CM Policy2, the EIB-CM was not in a position to deal with
the allegations/sub-allegations that overlapped with the court case and could only deal with the
following allegations:
1. Alleged poor communication from the Bank with EIB staff about the decision to close the
Crèche.
2. Allegedly unfair evaluation of the bid submitted by the company Crèche Attitude
Luxembourg S.à.r.l. due to failure to fulfil the stipulated minimum criterion regarding
financial stability of the service provider.
Therefore, this conclusions report focuses on the two above-mentioned allegations.
1 Crèche l’Abeille provided on-site childcare services to EIB employees based on a service contract between the
EIB and Crèche Attitude. More details about Crèche l’Abeille can be found in paragraphs 1.4 and 1.5.
2 “[w]here the complaint (i) has already been brought against a member of the EIB Group before other administrative
or judicial review mechanisms, or (ii) is brought subsequently, or (iii) is already settled by the other administrative
or judicial review mechanisms, the EIB-CM cannot handle it.”
2EIB Group Complaints Mechanism
b. Background information
General context
1.4 Following a decision by its governing bodies in 1993, the EIB started to make on-site childcare
services available to its staff in 1995, when the first crèche was opened. During its
approximately 25 years of operation, the crèche exclusively accommodated children of EIB
employees. From the start, the childcare services were provided through a service contract
between the EIB and successive service providers. On average, the crèche accommodated 80
children of crèche age3.
1.5 The last contract for the provision of crèche services (the “Service Contract”) was signed in
February 2019 with Crèche Attitude Luxembourg S.à.r.l. (the “Service Provider”). The Service
Contract states that the Service Provider commits to delivering complete management services
(administrative, pedagogical, alimentary, security, and hygienic) of a crèche. See paragraphs
1.6 to 1.11 on relevant information about the procurement procedure and contract for more
information.
Relevant information related to the procurement procedure and contract
1.6 On 4 September 2018, the EIB published a prior information notice in the Supplement to the
Official Journal of the EU for the “Management of an external crèche in a building of the EIB.”4
1.7 Among other things, the procurement documents specified the selection criterion related to the
economic and financial standing to ensure that companies participating in the procurement
procedure had the financial capacity to perform the contract to be awarded.
1.8 Specifically, the procurement documents specified the following (section 5.2 of Annex 4, Cahier
des charges - Gestion externe d’une crèche dans un bâtiment du Groupe BEI):
5.2. Capacité économique et financière
Le Soumissionnaire doit avoir une capacité économique et financière suffisante
pour assurer le service.
Lorsqu'un Soumissionnaire s'appuie sur les capacités d'autres entités (membres du
groupe et / ou soustraitants) pour satisfaire à ce critère, la Banque exigera que le
Soumissionnaire et ces entités soient conjointement responsables de l'exécution du
contrat.
Dans de tels cas, la règle de Pass/Fail peut être satisfaite dans le cadre d’une
évaluation consolidée.
Critère Pass/Fail: Le chiffre d’affaires total annuel du Soumissionnaire réalisé pour
chacun des 3 derniers exercices clôturés ne pourra pas être inférieur à 4.000.000 euro.
[…]
Pièce justificative 2
a) Bilans des 3 derniers exercices disponibles en fonction de la date de création de
l’entreprise ou du début d’activités de l’opérateur économique, dans la mesure où les
informations sur ces chiffres d’affaires sont disponibles ou autres pièces justificatives ;
[…]
b) Annexe 7 aux Clauses administratives générales et de soumission – Déclaration de
capacité économique et financière dûment remplie et signée.
1.9 In summary, section 5.2 of Annex 4 quoted above states that a tenderer must have an annual
turnover of at least €4 000 000 for each of the past three financial years.
3 This is based on the average occupation in the last two years that the crèche was fully operational.
4 Ref. 2018/S 169-383842; https://ted.europa.eu/udl?uri=TED:NOTICE:383842-2018:TEXT:EN:HTML.
3EIB Crèche
1.10 Section 5.2 of Annex 4 quoted above also states that where an economic operator relies on the
capacities of other entities with regard to criteria relating to economic and financial standing,
the EIB will require the economic operator and those entities to be jointly liable for the execution
of the contract.
1.11 The EIB awarded5 and signed the Service Contract with the Service Provider (Crèche Attitude
Luxembourg S.à.r.l., see paragraph 1.5 above) on 25 February 2019.
EIB’s decision to close the Crèche
1.12 The closure of the Crèche is the result of a comprehensive package of changes to the EIB’s
staff allowances. The EIB has been working on a review of the allowance system in a two-stage
process. The rationale behind the review was to develop an allowance system that is simpler,
clearer and easier to manage for EIB staff and the EIB services.
1.13 On 17 December 2019, the EIB’s governing bodies approved the first stage of the staff
allowances review. One of the key changes relates to the introduction of a new allowance, the
Child Assistance Allowance, effective 1 September 2020. The new allowance merges different
allowances and benefits related to dependent children previously provided separately (the
“crèche subsidy,” the Dependent Child Allowance and the Education Allowance and related
weightings). Thus, one of the consequences of moving to the new allowances system was the
discontinuation of the “crèche subsidy,” including the termination of all contracts with external
crèche providers and the closure of the Crèche from the implementation date of the new Child
Assistance Allowance.
2. WORK PERFORMED BY THE EIB-CM
2.1 Once it received the complaint, the EIB-CM conducted an initial meeting with the EIB services
concerned.
2.2 The EIB-CM reviewed the available information and documents relevant to the complaint. The
team working on the case has had various telephone calls with the complainant to get further
clarification on the concerns raised in the complaint. In addition, the EIB-CM liaised on various
occasions with the relevant EIB services to gather information. On the basis of the collected
and analysed information, the EIB-CM prepared this conclusions report.
3. REGULATORY FRAMEWORK
a. The EIB Group Complaints Mechanism Policy
3.1 The EIB Group Complaints Mechanism Policy6 tasks the EIB-CM with handling complaints
concerning alleged maladministration by the EIB7. Maladministration means poor or failed
administration8.
3.2 The policy specifies that the EIB-CM reviews the EIB’s activities with a view to determining
whether maladministration attributed to the EIB has taken place9.
5 Ref. 2019/S 063-145400; https://ted.europa.eu/udl?uri=TED:NOTICE:145400-2019:TEXT:EN:HTML.
6 Available at: https://www.eib.org/attachments/strategies/complaints_mechanism_policy_en.pdf.
7 Paragraph 5.1.3 of the EIB Group Complaints Mechanism Policy.
8 Paragraph 3.1 of the EIB Group Complaints Mechanism Policy.
9 Paragraph 5.3.3 of the EIB Group Complaints Mechanism Policy.
4EIB Group Complaints Mechanism
b. EIB guidelines on internal communication
3.3 The 2019-2021 Personnel Communication Strategy (hereinafter “the Strategy”) sets out how
Personnel aims to communicate more effectively across Personnel and with EIB staff in general.
It outlines Personnel’s communication mandate, communication principles, approach and target
audiences. The Strategy is implemented through yearly communication plans.
3.4 The Strategy refers, as part of Personnel’s communication mandate, to the aim of delivering
timely, relevant and consistent communication to support Personnel and the EIB’s strategic
objectives. One of the guiding communication principles is to prioritise face-to-face
communication opportunities over online communication for topics that have a significant
change impact on day-to-day work or EIB staff’s rights and obligations. It proposes to do so
through info sessions.
3.5 The Strategy also states that whenever there is a significant change for staff, for example,
resulting in monetary impact, those impacted will be informed in writing (via email).
c. EIB’s Corporate & Technical Assistance Procurement Guide10
3.6 The EIB’s Corporate & Technical Assistance Procurement Guide of July 2017 (hereinafter “the
Guide”)11 sets out the procedures to be followed by the EIB when procuring services, supplies,
works and concessions for its own account. The Guide establishes that the principles and
procedures developed at EU level in respect of public procurement, i.e. Directive 2014/24/EU
of the European Parliament and of the Council of 26 February 2014 on public procurement
(hereinafter “the Directive”)12, shall be followed by the EIB, subject to certain adaptations 13.
3.7 Section 4.3.3 of the Guide (titled “Selection criteria”) cross-references Article 58 of the Directive,
which states the following:
1. Selection criteria may relate to:
[…]
(b) economic and financial standing;
[…]
Contracting authorities may only impose criteria referred to in paragraphs 2, 3 and 4 on
economic operators as requirements for participation. They shall limit any requirements
to those that are appropriate to ensure that a candidate or tenderer has the legal and
financial capacities […] to perform the contract to be awarded. All requirements shall
be related and proportionate to the subject matter of the contract.
[...]
3. With regard to economic and financial standing, contracting authorities may impose
requirements ensuring that economic operators possess the necessary economic and
financial capacity to perform the contract. For that purpose, contracting authorities may
require, in particular, that economic operators have a certain minimum yearly turnover,
including a certain minimum turnover in the area covered by the contract. In addition,
contracting authorities may require that economic operators provide information on their
annual accounts showing the ratios, for instance, between assets and liabilities. They
may also require an appropriate level of professional risk indemnity insurance.
[...]
3.8 Section 4.3.8 of the Guide (titled “Reliance on the capacity of other entities”) cross-references
Article 63 of the Directive, which states the following:
10 EIB’s Corporate & Technical Assistance Procurement Guide – Guide for the procurement of services, supplies,
works and concessions managed by the EIB, July 2017. Available at https://www.eib.org/en/publications/eib-s-
corporate-and-technical-assistance-procurement-guide.
11 See footnote 10.
12 The Directive is available at https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32014L0024&from=EN.
13 See footnote 10.
5EIB Crèche
1. With regard to criteria relating to economic and financial standing as set out pursuant
to Article 58(3) […], an economic operator may, where appropriate and for a particular
contract, rely on the capacities of other entities, regardless of the legal nature of the
links which it has with them.
[...]
Where an economic operator wants to rely on the capacities of other entities, it shall
prove to the contracting authority that it will have at its disposal the resources
necessary, for example, by producing a commitment by those entities to that effect.
[...]
4. FINDINGS
a. Alleged poor communication from the Bank with EIB staff about the
decision to close the Crèche
4.1 Following the decision of the EIB’s governing bodies referred to in paragraph 1.13, a notice was
published on 18 December 2019 on the EIB intranet, accessible to all staff, with an update on
the decisions on the staff allowances review (phase 1) and the implementation measures. This
announcement consisted of a video presentation and a brochure. In the announcement, the EIB
referred, among other things, to the following: (i) its plan to meet with staff in early 2020 during
dedicated sessions to explain the changes in detail, and (ii) its plan to reach out individually to
certain colleagues via email in January 2020 (such as “colleagues receiving crèche subsidy”).
4.2 The announcement of 18 December 2019 was the first of a series of communication activities
planned by the relevant EIB services for EIB staff to inform them of the decisions concerning
the allowances review phase 1. The services had actually worked on a communication plan in
November 2019 entailing a series of activities to duly inform staff of the changes to allowances,
including the new Child Assistance Allowance, and to inform the affected EIB staff of their
impact.
4.3 The communication plan, which is based on the Strategy referred to in paragraphs 3.3 to 3.5,
included an update to be published on the EIB’s intranet on 17/18 December to share decisions
and implementation details for the allowances reviewed as approved by the EIB’s governing
bodies. In line with the Strategy, the communication plan also included a targeted email to be
sent to impacted staff between 6 and 10 January 2020 about changes with regard to the “crèche
subsidy.” Finally, the communication plan also included presentations about the allowances
review project in EIB directorates (hereinafter “the Roadshow”) to be given in January and
February 2020.
4.4 While the announcement containing the video and brochure on the EIB intranet did not make a
direct reference to the closure of the Crèche per se, it referred to changes to the “crèche
subsidy” with the introduction of the new Child Assistance Allowance.
4.5 On 20 December 2019, information about the closure of the Crèche was shared among staff
members on the EIB intranet. At the beginning of January 2020, employees of the Crèche were
approached by parents who had questions about a possible closure of the Crèche.
4.6 Following the announcement referred to in paragraph 4.1 and the informal information sharing
among staff members referred to in paragraph 4.5, the EIB invited the parents14 concerned to
attend dedicated information sessions through another announcement made on the intranet
14EIB colleagues whose children were enrolled or would shortly start/were on the waiting lists for the Crèche or
one of the subsidised external crèches.
6EIB Group Complaints Mechanism
on 13 January 2020. The competent EIB services organised information and Q&A sessions with
parents of children affected by the Crèche closure on 16 January, 6 February and
28 February 2020.
4.7 Based on the information reviewed as part of its inquiry, the EIB-CM understands that the
competent EIB services established and maintained individual contact (either via conference
calls or face-to-face meetings) with the parents concerned between January 2020 and
June 2020. As per the information reviewed, the EIB offered targeted support to beneficiaries
of the EIB Crèche and of the subsidy in the context of external crèche providers, and mitigating
measures were implemented, such as providing help to the affected parents in finding a new
crèche.
4.8 The Roadshow took place between January and May 2020. The presentations to each EIB
department included information on the termination of the “crèche subsidy,” including the
closure of the Crèche.
4.9 Various materials were developed by the EIB’s relevant services to raise awareness and
provide information to EIB staff on the changes to the allowances and the implementation
measures. In addition to the communication materials already mentioned above, a series of
documents were developed and made accessible to all staff. These include a presentation to
the EIB’s beneficiaries on the “crèche subsidy”, a note to staff, a Q&A document, and updated
information on the dedicated internal staff allowances review webpage.
b. Allegedly unfair evaluation of the bid submitted by the Service
Provider due to failure to fulfil the stipulated minimum criterion
regarding financial stability
4.10 By reviewing the tender of the Service Provider, the EIB-CM verified whether the tenderer was
able to demonstrate fulfilment with the requirement referred to above in paragraph 1.9 of this
report. A letter dated 19 November 2018, sent as part of its tender 15, mentions that the Service
Provider is a “Filiale à 100% de CRECHE ATTITUDE SAS qui se porte garante des
engagements de sa filiale […] [et qui] apporterait les garanties financières garantissant à la BEI
la continuité et la qualité du service proposée dans notre offre en cas de difficultés financières
rencontrées par la filiale.” The Service Provider thus proposed to rely on the mother company
in order to meet the financial capacity criterion. Furthermore, the Service Provider submitted
with its tender information on the annual accounts showing that the mother company was in
possession of the requisite financial capacity at the time of the tender evaluation.
4.11 Considering that the regulatory framework permits the combining of capacities of more than one
economic operator to satisfy minimum capacity requirements, the EIB-CM reviewed whether
the letter referred to in paragraph 4.10 constituted a requisite commitment by the mother
company. In this respect, and while it seems that the person who provided the letter of
19 November 2018 might have been authorised to commit the mother company, the EIB-CM
found no documentary evidence in the EIB’s file concerning the person’s capacity to do so. In
the EIB services’ view, the existence of a satisfactory ongoing relationship (since 2011) with the
mother company may have played a role in this.
15Partie 3 - 2) capacité économique et financière – letter titled Courier explicatif relatif à l’organisation du groupe
Crèche Attitude of the tender.
7EIB Crèche
5. CONCLUSIONS
a. Alleged poor communication from the Bank with EIB staff about the
decision to close the Crèche
5.1 The EIB-CM found that:
- Immediately following the decision taken by the EIB’s governing bodies on
17 December 2019, the EIB staff were informed on 18 December 2019 via an
announcement on the EIB’s intranet of the decisions on the staff allowances review
(phase 1) and the implementation measures. This announcement included information
about the introduction of the new Child Assistance Allowance, and the resulting cancellation
of the “crèche subsidy.”
- The EIB’s services had worked on a plan to communicate to EIB staff about the changes in
staff allowances, including about the closure of the Crèche to the parents concerned, and
in its initial communication of 18 December 2019 had announced that more detailed
information would be provided beginning of January 2020. The Roadshow took place
between January and May 2020. The EIB’s relevant services developed various materials
to raise awareness and provide information to EIB staff on the changes to the allowances
and the implementation measures.
- The EIB provided targeted communication and support to the parents affected by the
termination of the “crèche subsidy” between January and June 2020.
5.2 Therefore, and based on the findings referred to in paragraphs 4.1 to 4.9, the EIB-CM concludes
that this allegation is ungrounded.
b. Allegedly unfair evaluation of the bid submitted by the Service
Provider due to failure to fulfil the stipulated minimum criterion
regarding financial stability
5.3 The EIB-CM did not find the necessary evidence proving that the person providing the
tenderer’s letter mentioned in paragraph 4.10 could also commit on behalf of the mother
company. Therefore, the EIB-CM concludes that the allegation is grounded insofar as the formal
requirement of the fulfilment of the financial capacity is concerned.
5.4 The EIB-CM notes that the timing of the allegation does not allow the EIB to meaningfully
address the oversight identified as part of the present inquiry. In this context, it is worth
emphasising that the failure to verify the validity of the commitment purportedly given by the
mother company resulted only in formal non-compliance. It is to be noted that this oversight did
not affect the execution of the contract and that its performance by the Service Provider was
satisfactory to the Bank.
8EIB Group Complaints Mechanism
6. OUTCOMES
6.1 Considering its conclusion in relation to the second allegation (see paragraph 5.3), the EIB-CM
recommends that the competent EIB services amend the relevant procedures by providing further
guidance about the collection and archiving of the documentary evidence necessary to prove
successful bidders’ capacity to meet selection criteria.
6.2 Table 2 below summarises the outcome of the EIB-CM’s inquiry for each of the two allegations.
Table 2 – Outcome of the EIB-CM’s inquiry
Suggestions for
Allegation Outcome improvement
Alleged poor communication from the
Bank with EIB staff about the decision No grounds No
to close the Crèche
Allegedly unfair evaluation of the bid
submitted by the company Crèche Recommendation
Attitude S.à.r.l. due to failure to fulfil (see paragraph 6.1) No
the stipulated minimum criterion
regarding financial stability of the
service provider
Head of Division Senior Complaints Officer
Complaints Mechanism
14.06.2021 14.06.2021
9EIB Crèche
Available remedy
Complainants that are not satisfied with the conclusions report may file a complaint of maladministration
against the EIB Group with the European Ombudsman16.
16 Available at: https://www.ombudsman.europa.eu/en/home.
10You can also read
