European Economic and Social Committee
Section for Employment, Social Affairs and Citizenship
Report to the Ad-hoc group "Europe 2020 Steering Committee"
Two study visits as a follow-up to the opinion on the
European platform against poverty and social
exclusion (SOC/405)
SOC/405
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INDEX
1 – Introduction .....................................................................................................................
2
2 – Background .....................................................................................................................
2
3 – Platform against Poverty and Social Exclusion ..............................................................
3
4 – EESC recommendations .................................................................................................
4
5 – Indicators agreed by the Council ....................................................................................
4
6 – Structure of the visits ......................................................................................................
5
7 – PORTUGAL ...................................................................................................................
6
7.1 – Stakeholder involvement..................................................................................
7.2 – Targets..............................................................................................................
7.3 – Education .........................................................................................................
7.4 – Labour market ..................................................................................................
7.5 – Funding ............................................................................................................
7.6 – The Platform against Poverty ...........................................................................
6
7
7
8
8
8
8 – DENMARK ....................................................................................................................
10
8.1 – Stakeholder involvement..................................................................................
8.2 – Targets..............................................................................................................
8.3 – Education .........................................................................................................
8.4 – Labour market ..................................................................................................
8.5 – Funding ............................................................................................................
8.6 – The Platform against Poverty ...........................................................................
10
10
11
11
12
12
9 – Conclusions .....................................................................................................................
14
Appendix I ............................................................................................................................
15
Appendix II ...........................................................................................................................
17
SOC/405
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1.
Introduction
The Platform against Poverty and Social Exclusion is one of the seven flagship initiatives in
the EU 2020 Strategy. It followed an EU year on Combating Poverty and Social Exclusion
(2010) in which the EESC played a strong role in engaging with the various stakeholders and
in the organisation of different events.
The EESC Steering Committee of the 2020 Strategy takes a holistic view of the flagship
initiatives contained in the strategy, part of which involves assessing progress made over the
ten year period. As an initial follow-up, it was agreed that two study visits should be made to
different Member States to meet with stakeholders in order to ascertain the initial impact that
this flagship initiative was making on poverty reduction.
It was agreed that visits take place to Denmark and to Portugal to find out more about their
poverty targets and progress being made in the areas for action set out for the Platform. The
rationale for the choice was that Portugal is facing particular economic issues and is subject to
support within the Euro Zone, whereas Denmark is exhibiting more stability. The two
countries offered contrasts in how the current financial crisis had affected public services and
how it impacted on their populations.
The visits were undertaken in October 2011 by three representatives of the EESC – Brenda
King (Group I), Daiva Kvedaraite (Group II) and Maureen O’Neill (Group III, who was also
the rapporteur).
2.
Background
"People are said to be living in poverty if their income and resources are so inadequate as to
preclude them from having a standard of living considered acceptable in the society in which
they live. Because of their poverty they may experience multiple disadvantages through
unemployment, low income, poor housing, inadequate health care and barriers to lifelong
learning, culture, sport and recreation. They are often excluded and marginalised from
participating in activities (economic, social and cultural) that are the norm for other people
and their access to fundamental rights may be restricted"1.
More than 80 million people across the EU live below the poverty line2 of which more than
50% are women and 20 million are children. Whilst statistical data on material poverty is
important, the existence of immaterial poverty, such as, for instance, illiteracy, must also be
1
2
Joint Report by the European Commission and the European Council on Social Inclusion, March 2004.
The risk of poverty is set at 60% of the national median equivalised disposable income after social transfers particular to each
Member State.
SOC/405
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-4recognised. The current economic crisis has hit the most vulnerable and disadvantaged
members of our communities the hardest.
The EU Commission has put the reduction of poverty at the heart of its economic,
employment and social agenda – The Europe 2020 Strategy 3 . The Heads of State and
Government reached political agreement on a common target to lift at least 20 million people
out of poverty and social exclusion in the next decade. The flagship initiative of the Platform
against Poverty forms an integral part of the Strategy, together with Guideline 10 of the
Integrated Guidelines to implement the Strategy, which will underpin the contribution of
Member States to tackle poverty and social exclusion within the National Reform
Programmes.
The European Year for Combating Poverty and Social Exclusion highlighted the complexity
and multi-dimensional aspects of tackling poverty and the urgent need for action to counter
poverty in the face of the economic crisis and austerity measures.
Young people, migrants and the low skilled face worsening unemployment, the "working
poor" are unable to earn a sufficient wage to cover daily necessities, and older people and
families on reduced incomes face increasing material deprivation which affects 8% of
Europeans and up to 30% in some Member States4.
The European Council has agreed that the headline target for the reduction of poverty in the
context of the 2020 Strategy should be based on three indicators: the at-risk-of poverty rate,
severe material deprivation and the percentage of people living in jobless households. Poverty
reduction targets should relate to local and regional priorities
3.
Platform against Poverty and Social Exclusion
The aim of the Platform is to create a joint commitment among the Member States, European
Institutions and key stakeholders to fight poverty and social exclusion, by setting out a
dynamic framework for action for social and territorial cohesion to ensure that jobs, growth
and social inclusion are shared more equally across Member States.
The Commission identified five key areas for action:
3

Delivering actions across the policy spectrum

Greater and more effective use of EU funds to support social inclusion
2010 Update of the Joint Assessment by the Social Protection Committee (SPC) and the European Commission of the social
impact of the economic crisis and of policy responses (Nov 2010).
COM(2010) 2020 – Europe 2020 – A European strategy for smart, sustainable and inclusive growth.
4
Material deprivation is defined as experiencing at least four out of nine deprivations. People are not able to afford to: pay the rent
or utility bills; keep their home adequately warm; face unexpected bills; eat fish, meat or protein or equivalent every second day;
a week of holiday away from home once a year; have a car; a washing machine; a colour TV or a telephone.
SOC/405
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4.

Promoting evidence-based social innovation

Working in partnership and harnessing the potential of the social economy

Enhanced policy coordination among the Member States.
EESC recommendations
In its response to the Commission’s proposals the EESC stated:
5.

As poverty represents a violation of human rights, governments, the social partners and
civil society must take shared responsibility for its eradication;

There must be policy coherence between economic, financial, employment and social
measures in the 2020 Strategy and all should contribute to social cohesion;

Austerity measures should not increase the risk of poverty and an effective social impact
assessment must be made and debated;

The Active Inclusion Strategy should be implemented as an integrated approach to ensure
adequate income support, an inclusive labour market and access to quality work and
services;

There must be a stronger emphasis on reducing inequalities and enforcing fundamental
human rights, including through fairer income distribution and implementing the
horizontal social clauses set out in the Lisbon Treaty;

There should be increased emphasis on investing in human capital through lifelong
learning in education and training, including improved skills training matched to needs in
and outside the labour market;

The participation of civil society stakeholders in the Platform, including people
experiencing poverty, NGOs and social partners, should be reinforced through structured
dialogue at EU and national level and supported through appropriate EU funding. The
EESC should play an active and collaborative role in this dialogue and in the Annual
Convention;

EU funding, particularly the Structural Funds, targeted at reducing poverty, needs to be
increased and the emphasis given to simplifying procedures, increasing transparency and
monitoring effective delivery;

The Social Open Method of Coordination (OMC) must be strengthened, which includes
the development of National Strategies for Social Protection and Social Inclusion and
action plans at national and local level. Its link to the flagship initiative on poverty needs
to be clarified.
Indicators agreed by the Council
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


6.
The relative risk of poverty
Low intensity of labour in a household
Material deprivation
Structure of the visits
The basis for the discussions was taken from the EESC response to the Commission’s
Proposal for the Platform and a questionnaire was drawn up (appendix I) and sent to the
stakeholders who had agreed to participate. We are very grateful to the Commission for the
use of their offices in both Lisbon and Copenhagen and to the ESC in Portugal for enabling a
meeting in its office. We appreciated the time given to us by a range of stakeholders and for
their informed and enthusiastic support (appendix II).
*
*
SOC/405
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-77.
PORTUGAL
‘On 23rd March 2011 the Portuguese government submitted a Stability Programme for 201114 to the national government which rejected it. In April 2011 the Portuguese Government
submitted a National Reform Programme which was overtaken by a Memorandum of
Understanding signed in May 2011 which saw the Council adopting an implementing
decision to make available to Portugal medium term financial assistance for three years
2011-14.’
The Commission stressed the urgency of implementing the planned measures to comply with
the decision.
National reform targets







Reduction of public deficit to 4.6% in 2011, 3% in 2012 and 2% in 2013
Increase in exports by 40% by 2020
Increase in R&D
Reduction in school dropout rate by 10% by 2020; increase in graduates by 40% by 2020
Increases in energy efficiency by 20%
75% employment rate 20y-64y by 2020
A decrease of 200,000 people in poverty by 2020.
The responses
7.1
Stakeholder involvement
There was strong feeling from all those participating, whether from business, unions or
NGOs, that there was a lack of involvement in the development of the National Reform
Programme, the Emergency Plan or other action plans.
Some public forums were held but it was not felt that there had been a real opportunity to
influence outcomes. Each sector through its lobbying capacity exerted its views, but the
importance of social and civil dialogue in times of crisis was continually emphasised so that
alternative views could be considered. As a result, the following issues were raised:





SOC/405
There was an increasing imbalance between economic and social measures and the
austerity measures were having an impact on the most vulnerable;
There was a lack of clarity about the financial provision to implement the proposed
measures;
Inequalities, particularly in income distribution, were high and growing;
More discussion on the targets and their impact was lacking;
More involvement might have enabled a better focus in fostering cross cutting
measures between tax, justice and income systems;
.../...
-8

7.2
A belief that the NRP was outdated;
A belief that the external force of the TROIKA in determining the NRP was
detrimental, as investment in Portugal might be discouraged as a result.
Targets
Implementing the targets was creating difficulties, in particular:










The austerity measures were hitting the poorest;
600,000 children had been removed from benefits and child poverty is increasing;
The loss of social protection was affecting the increasing number of people who were
becoming unemployed;
Very few new jobs were being created;
Salaries were cut back, increasing the prospect of the ‘in-work poor’;
Consequences of the austerity measures on older people who had fixed incomes;
The impact of increases in indirect taxes, e.g. VAT, on the poorest, particularly in
relation to the cost of electricity, which has risen from 6% to 23%. Transport costs
were also increasing;
The lack of investment in business and the lack of access to credit, which impacted on
employment potential;
There was insufficient investment in infrastructure, housing and regeneration;
There was no common strategy across Europe to tackle poverty, as each Member
State could chose its own target (see above), which made meaningful data collection
problematic.
There were doubts about meeting the target of removing 200,000 people from poverty given
the increase in unemployment, reduction in benefits, increased indebtedness, the use of
savings to meet rising costs and the estimated decrease of around 20% in household income.
7.3
Education
The issue of education was given great importance and key challenges were being faced.






SOC/405
The school dropout rate in Portugal was higher than the EU average and there was
agreement that this had to be reduced, but there was also concern that the investment
in education and training was also threatened by the reduction in public expenditure;
The issues of illiteracy needed to be tackled and skills and qualifications improved in
order to enable an entry into the labour market and an entrepreneurial approach;
The fact that young qualified people were leaving Portugal with the loss of their skills
and expertise to the country;
The need to emphasise the importance of lifelong learning;
The integration of immigrants through education;
The reduction of funding to NGOs, which run a range of schools, kindergartens and
support groups, which leaves a deficit of provision.
.../...
-97.4
Labour market
With increasing levels of unemployment, there was considerable concern about the ability of
Portugal to reach the proposed target of 75% of the adult population in employment by 2020
(20-64y).







7.5
Retaining the minimum wage had proved difficult and the aim to raise it slightly had
not been fulfilled;
Salary cut backs were being experienced, creating the ‘in-work poor’;
The minimum insertion benefit rate was inadequate;
Portugal was not an industrialised country and was dependent upon trade, agriculture
and tourism as a source of wealth, so the migration of people from inland Portugal
was of considerable concern for the development of agriculture, but also an increased
pressure on urban areas;
The loss of skilled workers to other countries and the lack of investment in housing,
infrastructure and business all had an impact on the ability to meet the proposed target
and the benefit to the population;
The growth in the informal economy was a major concern because of low wages, lack
of security for the employees who could benefit from social protection and lack of
contribution from the State to fund public services;
There needed to be a stronger focus on active inclusion, which would embrace
adequate income support, inclusive labour market, and access to quality work and
services.
Funding
Access to EU Structural Funds was considered to be very important and the following issues
were highlighted:






7.6
Concern about the complexity of obtaining funding;
The importance of being able to access the funds to support training and other
services offered by NGOs;
The procedures involved made it difficult for smaller organisations to take up the
potential ESF funding;
The administrative burden attached to EU funding programmes;
The problems encountered in building partnerships or consortia in relation to
governance issues;
The predominance of government in such programmes and an inherent mistrust of
civil society organisations.
The Platform against Poverty
SOC/405
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- 10 The Platform had a role in bringing together the achievements against the poverty reduction
targets in each Member State, but there was a lack of clarity about how this function would be
implemented.







There was an absence of dialogue at a national level and no specific programmes to
follow through on the proposals;
There was little emphasis on social inclusion;
There were no apparent initiatives which encompassed other Member States;
Given the adoption of different indicators, it was difficult to get a coherent picture of
progress;
There were questions about how would the Commission monitor outcomes and
provide enforcement;
There was a lack of clarity about the Open Method of Co-ordination and a wish to see
it having a much stronger role;
The function of the Annual Convention of the Platform was not clear and concern
was expressed that the delegations were not chosen by the Member States.
*
*
SOC/405
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- 11 8.
DENMARK
‘The Council recommended that Denmark implement fiscal consolidation measures in 2011,
2012 and 2013 to ensure an average annual fiscal effort of 0.5% of GDP over the period
2011-13 as planned and correct the excessive deficit by 2013. It recommended to accelerate
the reduction of the general government deficit if economic conditions turn out better than
currently expected and to strengthen expenditure control by adopting binding multi annual
spending ceilings for local, regional and central government which are consistent with the
overall medium term budget targets.’
The national reform targets








Structural balance on public finances by 2020. Public debt accumulation was stopped;
Reforms to increase labour supply and ensure better management of public
expenditure;
By 2020 to have increased private employment by 125,000 people;
Increase growth potential by almost 2% per year;
Primary public expenditures share of GDP had to be less than 50% by 2020;
Reforms to create growth in public consumption by 0.8% per year in the period 20142020;
New spending policy was introduced based on binding spending ceilings for central
government, regions and municipalities. This was anchored in specific law on
spending ceilings;
Continued tax freeze to 2020.
The responses
8.1
Stakeholder involvement
The importance of national engagement was clearly stated. A network of civil society
organisations and social partners had been formed in 2010, but there were concerns that:





8.2
Very few people were involved in the development of the NRP;
Organisations were consulted but often only given a very short time to respond,
which made it difficult to canvas the opinions of members;
It was important for NGOs and Social Partners to have the opportunity of influencing
the NRP, but that it was difficult to do this;
There was no real culture of stakeholder involvement, but perhaps this might improve
with the new government;
The stakeholder group was widened, involving employers more.
Targets
SOC/405
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- 12 In spite of a poverty reduction target set at 20,000, there was no specific reference to the
reduction of poverty in the areas where it can be achieved, so there was expressed concern
that:







8.3
There was no consensus about what constituted poverty or how to measure it;
There needed to be agreement on the problem in order to tackle it;
There was a widening gap in inequalities, but little recognition of it;
Taking the indicators to reduce poverty (material deprivation, poverty defined as 60%
of median income and low work intensity households), the NRP targets made very
little reference to them;
Child poverty was increasing affecting families;
The migrant population formed a significant part of the population experiencing
poverty;
There needed to be a stronger balance between the fiscal and social measures, and
subsidies were important in the equation, not just a focus on employment.
Education
There was clear recognition of the importance of education and there was a government
commitment to ensure that the Danish Education system is of world class quality, but there
were some concerns that:







8.4
More needed to be done to prevent early dropouts from school;
There needed to be more emphasis on primary education to ensure that
individuals can progress through the education system with confidence;
There needed to be more support for migrants and marginalised groups within the
education system;
There needed to be more investment in teachers to enable flexibility of approach
and more engagement with families;
Schools were expensive;
There needed to be a stronger agreement on the way forward for the education
system;
There needed to be a stronger emphasis on skills and qualifications to improve
the labour market.
Labour market
The Danish economy slowed down around 2007 and unemployment was rising. In 2010 it had
reached 7.4% and it was predominantly young people who were affected. The target was for
80% employment in the group 20-64y. The following issues were highlighted:

SOC/405
There was a strong emphasis on providing incentives to work;
.../...
- 13 






8.5
People were not prepared to travel more than one hour to go to work or to move
their location;
The flexicurity system provided a level of security, but there were concerns about
the activation measures. These measures included advice on CVs and guidance
on job seeking. However, the system was viewed as complicated and resulted in
about 30% of young people not involving themselves in these measures;
It was believed that the investment in these activation measures had no effect on
relieving unemployment and that the programme needed to be overhauled. A
recent audit report showed that those who had participated in the activation
measures had a lower success rate in obtaining employment than those who
sought employment directly;
The deterrent was the loss of social assistance if one did not join the scheme;
Although there were no ‘working poor’, there was a lack confidence in the
proposed measures;
There was significant concern with the increasing number of people working in
the informal economy (without collective agreements), which undermined social
protection systems. There was a belief that regulatory issues created barriers to
people entering the formal economy – e.g. asking a taxi driver to demonstrate that
he/she has a vocational qualification – and there was a collision between
government and business on these issues, which increased the problem;
There was a concern that the restrictions on finance at a local level would have an
impact on the development of employment and on provision of training services.
Funding
Whilst there was a requirement for Denmark not to increase the current tax rate, which was a
very high one in relation to other EU States, there was a tension about how to maintain the
level of services provided. This gave rise to concerns that:




8.6
There was a loss of specialised services in health and education because of
cutbacks in local funding;
There needed to be more co-operation between different services in order to make
best use of resources available;
To achieve the NRP targets it was important to access EU funds but this was
based on a 25% contribution from Denmark and this required commitment from
the government;
The access to EU funding was complex and bureaucratic.
The Platform against Poverty
There was little familiarity with the proposed functions of the Platform and it was felt that
there should be more discussion. The following views were expressed:
SOC/405
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- 14 





Although the OMC did not function well, there needs to be a mechanism that could
provide a view of progress against the targets and obtain an EU wide perspective;
The fact that each Member State could determine its own indicators in measuring a
reduction in poverty did not lead to a coherent approach or to the collection of
meaningful data. There should be one common indicator for all Member States.
Denmark did not want to agree to the indicator of 60% of median income;
There should be ways to test the impact of the measures adopted on the poverty level
– e.g. the effect of cuts in benefits;
Governments needed to be part of the monitoring and sharing process in these
measurements;
There was a lack of clarity about the aim of the Annual Convention of the Platform in
bringing these issues together and about the effectiveness of national reform
programmes in Member States;
There should to be a system of accountability, which had to be an imperative at EU
and national level.
*
*
SOC/405
*
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- 15 9.
Conclusions
Whilst the social protection system in Denmark appears to be more robust than that in
Portugal, there is an underlying sense of insecurity in both countries. It is striking that there is
the same lack of real stakeholder involvement for all the rhetoric on this issue. It is also
evident that a consistent way of measuring the impact of strategies within the 2020 Strategy
and the country national reform programmes is essential to achieve real progress and that this
should be allied to a robust and coherent system of accountability if the poverty target agreed
by the Council is to be achieved.
March 2012
For the European Economic and Social Committee
Maureen O’Neill
Member of Group III, Rapporteur of the EESC opinion on the European Platform against Poverty and
Social Exclusion and former President of the EESC Standing Group on the EU Year on Combating
Poverty and Social Exclusion 2010
*
*
*
N.B.: Appendices overleaf.
SOC/405
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- 16 -
Appendix I – Questionnaire sent out to the hearings participants
PLATFORM AGAINST POVERTY
Thank you very much for assisting the EESC in obtaining a better understanding of the issues
relating to poverty reduction in your member state.
Before answering the questions it would be helpful if you could say a little about your
organization and its aims.
INVOLVEMENT
1.
Was there a stakeholder forum in your Member State to consider how reducing poverty
could best be achieved? If so what form did this take and which organizations were
involved?
How did you try to influence the approach your Government should take?
2.
THE TARGETS
3.
Do you agree with poverty reduction targets set in the Portuguese National Reform
Program (NRP) and do you consider that they will be achievable and effective in the
timescales set in relation to:




Fighting inequalities and furthering social justice
Promoting a new intergenerational contract
Guaranteeing a coherent network of social minimums
Fostering social inclusion
4.
What obstacles do you foresee in relation to achieving the targets?
5.
If you have alternative proposals what are they and why do you believe they would be
more effective?
FUNDING
6.
Are the funds available from the EU and national governments adequate to achieve the
proposed targets and are they sufficiently focused to be effective?
7.
Do you have alternative suggestions for the use of EU funds and how they might be better
administered?
SOC/405 – Appendix I
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- 17 8.
To what extent have the support measures from the EU Commission and the International
Monetary Fund (IMF) been successful?5
IMPLEMENTATION AND MONITORING
9.
What proposals would you like to see implemented in the monitoring and review of the
poverty targets and the direction of the 2020 Strategy?
10. How would you wish stakeholders (social partners, civil society organizations, those
experiencing poverty and local authorities) to be engaged in monitoring the outcomes of the
2020 strategy and how do you think this would contribute to achieving effective outcomes.
THE PLATFORM AGAINST POVERTY
11. What are your expectations of the Platform Against Poverty as a mechanism for promoting
and supporting poverty reduction at a national and EU level.
GOOD PRACTICE
12. What examples do you have of effective approaches to reducing poverty?
5
This question was not part of the questionnaire send to Denmark.
SOC/405 – Appendix I
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- 18 Appendix II – Lists of participants in the hearings
Hearing in Lisbon – 3 October 2011
Portuguese ESC
Mr José A. Silva Peneda – President
Portuguese ESC
Ms Catarina Braga – Secretary-General
Portuguese ESC
Ms Dina Lopes – Secretariat
CGTP-IN – Confederation of Portuguese
Workers
UGT – General Trade Union of Workers
Ms Maria do Carmo Tavares
CAP – Portuguese Confederation of Farmers
Ms Vanda Cruz
Ms Paula Bernardo
Ms Cristina Morais
CCP – Confederation of Trade and Services of Mr Pedro d'Almeida Freire
Portugal
Mr Nuno Biscaia
CIP – Business Confederation of Portugal
CTP – Confederation of Tourism
Mr Nuno Bernardo
CPCI – Confederation of Construction and
Real State
CNIS – Confederation of Charitable
Institutions
Portuguese Unions of Mutuals
Mr Luis Saraiva
Confederation of Family Associations
Confederation of Organisations for People
with Disabilities
Mr Eugénio Fonseca
Mr Alberto Ramalheira
Mr Luís Silva
Mr José Alarcão Troni
Mr Paulo Paleta Fernandes
Hearing in Lisbon – 4 October 2011
European
Commission
Representation
in
Mr Artur Furtado
Portugal
Social Security Ministry – Service of Strategy and
Ms Rita Guerra
Planning
National Agency for Educational/Professional
Ms Dora Santos
Qualification (ANQ)
SOC/405 – Appendix II
- 19 High Commissariat for Immigration and
Intercultural Dialogue (ACIDI)
Institute of Employment and Vocational Training
(IEFP)
Commission for Citizenship and Gender Equality
(CIG)
Ms Susana Antunes
Ms Ana Maria Rodrigues
Mr João Paiva
Maria do Rosário Fidalgo
Managing Institute of the European Social Fund
Ms Maria do Carmo Abreu
Portuguese Union of "Misericórdias"
Mr Manuel Lemos
EAPN Portugal
Ms Sérgio Aires
Ms Sandra Araújo
Ms Maria Costa
Hearing in Copenhagen - 28.10.2011
European Commission Representation in
Denmark – Head of Representation
European Commission, DG EMPL Official
Mr Jan Høst Schmidt
LO • The Danish Confederation of Trade Unions
- Consultant in Economic and Labour Market
issues
EAPN DK - Director
Mr Christian Sølyst
CASA - Experienced researcher of poverty
Mr Finn Kenneth Hansen
Kofoeds School - Humanitarian organization that
provides help to people with socio-economical
problems – International Chief Consultant
Socialpolitisk Forening - Chair of the
international committee
The Economic Council of the Labour Movement
(ECLM) – Economic policy institute and thinktank working to promote social justice in
Denmark - Senior researcher
The Council for Socially Marginalised People Governmental council of experts appointed by the
ministry of social affairs - Head of Secretariat
Think Tank CEPOS
Mr Ole Meldgaard
Mr Christian Aagaard
Mr Per K. Larsen
Mr Bjørn Christensen
Mr Jonas Schytt Juul
Mr Ole Kjærgaard
Mr Martin Ågerup
_____________
SOC/405 – Appendix II
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