1. INTRODUCTION – BACKGROUND 1.1. Programme/Legal Basis
This call for proposals is published under REGULATION (EU) No 1296/2013 of the European Parliament and of the Council of 11 December 2013 on a European Union Programme for Employment and Social Innovation ("EaSI")1 and amending Decision No 283/2010/EU establishing a European Progress Microfinance Facility for employment and social inclusion.
The European Programme for Employment and Social Innovation "EaSI" 2014-20202 is a European-level financing instrument managed directly by the European Commission to contribute to the implementation of the Europe 2020 strategy, by providing financial support for the Union's objectives in terms of promoting a high level of quality and sustainable employment, guaranteeing adequate and decent social protection, combating social exclusion and poverty and improving working conditions.
The EaSI Programme shall, in all its axes and actions, aim to:
(a) pay particular attention to vulnerable groups, such as young people;
(b) promote equality between women and men,
(c) combat discrimination based on sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation;
(d) promote a high-level of quality and sustainable employment, guarantee adequate and decent social protection, combat long-term unemployment and fight against poverty and social exclusion.
Hence, in designing, implementing and reporting on the activity, beneficiaries/contractors must address the issues noted above and will be required to provide detail, in the final activity report on the steps and achievements made towards addressing those aims.
1.2. Policy and economic background
Undeclared work is a central element in the Europe 2020 strategy, in particular the necessity to move from informal or undeclared work to regular employment. Within the context of this call for proposals and building up on the 1998 Communication from the Commission on Undeclared Work3 undeclared work is understood as "any paid activities that are lawful as regards their nature, but are not declared to the public authorities, taking into account the differences in the regulatory systems of the Member States".
The need for structural reforms in the areas of undeclared work, shadow economy, tax evasion has been addressed in several country-specific recommendations by the Council4.
Undeclared work takes a variety of forms ranging from undeclared work in a formal enterprise to clandestine work done by own account workers, but excludes those involving illegal goods or services. In fact, if the goods and services provided are unlawful (e.g., the production or trafficking of drugs, firearms, persons, etc.), it is part of the wider criminal economy (i.e., the ‘shadow economy’ is often defined as including both the undeclared economy and criminal economy), and if there is no monetary payment, it is part of the unpaid sphere.
Undeclared work constitutes a political challenge for various reasons:
from a macroeconomic perspective, it is a form of tax evasion undermining public finances; it also has an impact on working conditions and the quality of jobs with notably no access to lifelong learning, with consequences on potential growth in the long-run;
from a microeconomic perspective, it distorts competition among firms, paving the way for social dumping and causes productive inefficiencies by keeping companies in business that would otherwise probably be absent from the market. Informal businesses typically avoid access to formal services and have no adequate access to credit and therefore their growth is limited;
from a social perspective, it is characterised by poor working conditions, deficits in terms of health and safety requirements, lower income and the absence of social security.
Undeclared work is consequently a multifaceted phenomenon, it is not just the scale but also the structure of undeclared work that varies from one Member State to another; this is owing to differences in the productive structure, in the institutional strength of public bodies and regulatory systems, or in the extent of welfare state systems. The nature and incidence of undeclared work in a country can be seen as reflecting the imperfections of its formal labour market economy.
Undeclared work has been the object of attention by policy makers for a long time. The 2007 Commission communication on "Stepping up the fight against undeclared work5 proposes the following measures:
Reducing the financial attractiveness of undeclared work stemming from the design of tax and benefit systems, and the permissiveness of the social protection system with regard to the performing of undeclared work
Administrative reform and simplification, with a view to reducing the cost of compliance with regulations
Strengthening the surveillance and sanction mechanisms, with the involvement of labour inspectorates, tax offices and social partners
Cross-border cooperation within the EU and awareness raising
Tackling undeclared work is primarily a task of the Member States. Decision (EU) 2016/344 of 9 March 2016 established a European Platform to enhance cooperation in tackling undeclared work by bringing together Member States' authorities involved in the prevention and/or deterrence of undeclared work. The Platform has been launched in May 2016 and aims to improve cooperation between Member States through sharing information and best practices, developing expertise and promoting and facilitating cross-border cooperation. The main objective of the Platform is to improve the Member States' capacities to tackle undeclared work in its various forms, including bogus self-employment, and drive change at national level in order to promote better working conditions and the emergence of formal employment. The Platform is a tool to support Member States in their reform agendas, to better enforce laws and rules and a forum at EU level where the different actors involved can exchange information and good practices, develop knowledge and evidence, learn from each other and together and engage in closer cross-border cooperation and joint activities.
The Platform is composed of:
Members: representatives of the Member States, for example from federal ministries, labour and social inspectorates, tax and customs authorities or social insurance agencies, of EU level cross-industry social partners and of the Commission.
Observers: representatives of social partners representing the sectors most affected by undeclared work and organisations like Eurofound, the European Agency for Safety and Health at Work (EU-OSHA) and the International Labour Organisation (ILO) and representatives of member countries of the European Economic Area .
On the first plenary meeting on 10th October 2016, the Platform adopted the work programme for 2017-20186.
2. OBJECTIVES, TYPES OF ACTION AND EXPECTED OUTPUTS
The main objective of this call for proposals is to complement and add value to the activities indicated in the work programme of the European Platform tackling undeclared work. Other objectives are to develop and fund initiatives which shall contribute to enhancing the implementation, application, knowledge and better enforcement of EU and national law in the area of undeclared work, thus contributing to the reduction of undeclared work and to the emergence of the formal jobs. The knowledge gained from these projects should also help building up evidence-based knowledge for better policy design.
The priority is to co-finance actions fostering joint activities and cross-border projects of enforcement authorities improving their technical capacity in the field of preventing and deterrence of undeclared work.
This will further enhance on-going cooperation between Member States enforcement authorities in line with Decision (EU) 2016/344 of the European Parliament and of the Council of 9 March 2016 on establishing a European Platform to enhance cooperation in tackling undeclared work.
2.2. Description of the activities to be funded / Type of actions
The types of activities which may be funded under this call for proposals must address at least one of the areas of action identified below:
a) Common training courses for staff involved in enforcement activities: developing new or improving existing training programmes between officials of competent public authorities and/or between relevant social partners and stakeholders in the context of contributing to enhancing the implementation, application, knowledge and better enforcement of EU and national law in the area of undeclared work. Activities can include trainings focusing on common themes and challenges (e.g. how to address bogus self-employment) and how they are tackled by different national authorities, exchanges in the field (e.g. agriculture and construction sectors) or trainings focusing on how to foster cooperation/improve working relations between different national and other EU/EEA enforcement agencies. Activities supported should produce an output; a potential output of this type of activities could be a handbook of best enforcement practices used my member states to tackle undeclared work.
b) Joint inspections and exchange of staff of enforcement authorities: developing new or improving existing exchanges and peer learning between officials of competent public authorities in order to better cooperate across borders, and to develop tools that facilitate the work and to support capacity building. Activities can include: study visits to the authorities of the Member States, including a presentation of their coordinating work between agencies in addressing undeclared work at national level, field exchanges – exchange of staff for a limited period of time to enable exchange of information/best practices etc.
c) Provision of technical assistance to other EU/EEA enforcement bodies to contribute to capacity building, implementation of good practices, etc.
d) Information exchange systems: developing cross-border information exchange systems with the aim to facilitate administrative cooperation between enforcement bodies. Cross-border information exchange systems supported under this priority must add value to existing practices such as EESSI, IMI module on posting of workers, etc.).
e) Collaborative work in form of sharing of information and mutual learning between enforcement authorities: developing or upgrading online platforms for the collection and dissemination of quality, user-friendly, and specific information targeted at tackling undeclared work and facilitating the transition from undeclared work to formal work.
Members/observers of the European Platform tackling undeclared work receiving as result of this call for proposal a grant for an awareness-raising campaign will be able to benefit from the services under VT/2016/005 'Service contract to support the European Platform tackling undeclared work'7, 4.4.5 Support to communication and awareness-raising activities if the campaign promotes the European Platform or is in line with the activities of the European Platform. This could take the form of cost-free communication expertise. This possible support shall not be budgeted in the application under this call for proposals.
2.3. Expected outputs/results
Apart from the pure technical implementation of the proposals another deliverable of projects under this call for proposals is the capacity to spell out success and failure factors and parameters in an analytical evidence-based way.
a) Technical implementation
This includes facilitating and promoting training, good practice initiatives and innovative approaches, such as exchanges of staff and joint activities; exchange of information, mutual learning and awareness raising campaigns. Information exchange systems could be addressed through the joint establishment of protocols, agreements and the development of IT-based systems.
b) Analytical elements
In addition to implementing the activities described above, another deliverable of projects under this call for proposals is the capacity to spell out success and failure factors and parameters. These should be documented in the form of findings and conclusions deriving from a thorough evaluation of the actions undertaken. The evaluation shall help the beneficiaries to draw lessons learned and to establish, deriving from this experience, building blocks for a successful and sustainable cooperation between enforcement authorities and to contribute to the work of the European Platform. The proposal should detail how this output will be achieved.
The expected results are: improved transnational cooperation between Member States' different authorities to prevent and deter undeclared work, increased mutual trust among the stakeholders and increased public awareness on the urgency of action and encouraging Member States to step up their efforts in dealing with undeclared work.
The Commission, with the support of an external contractor, will monitor regularly the EaSI Programme. Therefore, beneficiaries/contractors will have to transmit qualitative and quantitative monitoring data on the results of the activities. These will include the extent to which the principles of equality between women and men has been applied, as well as how anti-discrimination considerations, including accessibility issues, have been addressed through the activities. Related templates are attached or will be provided.
In setting up the action, beneficiaries must foresee the necessary funding for monitoring and reporting to the Commission.
Publication of the call
Deadline for submitting proposals
12 June 2017
Evaluation period (indicative)
Information to applicants (indicative)
Signature of the grant agreement (indicative)
Starting date of the action (indicative)
As from November 2017
3.1. Starting date and duration of the projects
The actual starting date of the action will either be the first day following the date when the last of the two parties signs the grant agreement, the first day of the month following the date when the last of the two parties signs or a date agreed upon between the parties.
Applicants should note that if their project is selected, they may receive the grant agreement after the start date of the action that they have indicatively set in the application form. It is therefore advisable to number the months in the work programme instead of indicating the name of the month.
Any expenditure incurred before the signature of the Grant Agreement will be at the applicant’s risk. No expenditure can be incurred before the deadline for submission.
The project's duration should indicatively be between twelve (12) months and eighteen (18) month.
4. AVAILABLE BUDGET AND CO-FINANCING RATE 4.1. Available budget
The total budget earmarked for the EU co-financing of projects under this call is estimated at EUR 1,000,000.00.
For illustrative purposes, the Union funding per project is estimated to be not less than EUR 400,000.00. The Commission thus expects to award 2 – 3 grants.
The Commission reserves the right not to distribute all the funds available or to increase the budget if additional funds may be made available.
4.2. Co-financing rate
Under this call for proposals, the EU grant may not exceed 80.00% of the total eligible costs of the action. The applicants must guarantee their co-financing of the remaining amount covered by the applicants' own resources or from other sources other than the European Union budget10.
5. ADMISSIBILITY REQUIREMENTS
- Applications must be sent no later than the deadline for submission referred to in section 3(b)
Failure to comply with the above requirements will lead to the rejection of the application.
Applicants are encouraged to submit their project proposal in English, in order to facilitate the treatment of the proposals and speed up the evaluation process. It should be noted, however, that proposals in all official languages of the EU will be accepted. In this case, applications should be accompanied by an executive summary in English (checklist point 3).
6. Eligibility Criteria
6.1. Eligibility of the applicants (lead and co-applicants) and affiliated entities11
a) Place of establishment
Legal entities properly established and registered in the following countries are eligible as lead applicant and co-applicants:
EU Member States;
Iceland and Norway in accordance with the EEA Agreement;
Albania, the Former Yugoslav Republic of Macedonia, Montenegro, Serbia and Turkey12
b) Type of entities
To be eligible, applicants (sole/lead applicants, co-applicants) must:
Fall into one of the following categories:
i. Public enforcement authorities such as labour inspectorates, social security inspectorates, tax authorities, customs authorities, migration bodies, ministries in charge of tackling undeclared work, the police and the public prosecutor's office.
ii.Social partner organisation at European13, national or regional level (in derogation from point 6.1a), in application of Article 131 of the Financial Regulation, social partner organisations without legal personality are also eligible provided that the conditions of the Financial Regulation related thereto are met14). Social partner organisations may be sole or lead applicant if officially entitled by law or institutional agreements to carry out enforcement tasks15. Other types of social partner organisations may be co-applicants.
Be non-profit organisations (private or public);
Sole or lead applicants who are not officially appointed by Member States/EEA countries to the European Platform tackling undeclared work must present a letter of support issued by the respective senior representative in the Platform16.
Actions may involve consortia (lead and co-applicant(s)).
d) Affiliated entities
Legal entities having a legal or capital link with applicants, which is neither limited to the action nor established for the sole purpose of its implementation and which satisfy the eligibility criteria, may take part in the action as affiliated entities, and may declare eligible costs. For that purpose, applicants shall identify such affiliated entities in the application form.
In the case of a proposal submitted by one (sole) applicant, if that applicant is not considered to be eligible, the application will be rejected.
In the case of consortia, if the lead applicant is not considered to be eligible, the application will be rejected. If a co-applicant is considered not to be eligible, this organisation will be removed from the consortium and the proposal evaluated on that basis. In addition, the costs that are allocated to a non-eligible co-applicant will be removed from the budget.
6.2. Eligible activities
a) Geographical Coverage
To be eligible, actions must be carried out in EU Member States and other EaSI participating countries (see point 6.1a) and demonstrate that they will cover at least 3 EU Member States, e.g. coverage through a study, reach-out for communication activities, etc.
b) Types of activities
The grant will finance the activities indicated in section 2.2.
c) Core activities
The following activities are considered to be core activities and may not be subcontracted:
6.3. Ineligible activities
Financial support to third parties as defined in point 3 of the Financial Guidelines is not eligible under this call.
7. EXCLUSION CRITERIA
Applicants (lead and co-applicants) must sign a declaration on their honour certifying that they are not in one of the situations referred to in article 106(1) and 107.1(b) and (c) of the Financial Regulation concerning exclusion and rejection from the procedure respectively, using the relevant form attached to the application form available at https://webgate.ec.europa.eu/swim/external/displayWelcome.do.
The same exclusion criteria apply to any affiliated entities.
8. SELECTION CRITERIA
The applicant (lead and co-applicants) must have the financial and operational capacity to complete the activity for which funding is requested. Only organisations with the necessary financial and operational capacity may be considered for a grant.
8.1. Financial capacity
Applicants (lead and co-applicants) must have access to solid and adequate funding to maintain their activities for the period of the action and to help finance it as necessary.
The verification of financial capacity will not apply to public bodies or to international organisations.
The applicant's (lead and co-applicants) financial capacity will be assessed on the basis of the following supporting documents to be submitted with the application:
Declaration on honour (including financial capacity to carry out the activity) (see section 15, checklist point 4);
Annual balance sheets and profit and loss accounts for the last financial year available (see section 15, checklist point 16);
Summary balance sheet and profit and loss accounts using the template provided in SWIM (see section 12) and signed by the legal representative (see section 15, checklist point 17);
For grants of EUR 750,000.00 or more, an audit report produced by an approved external auditor certifying the accounts for the last financial year available (see section 15, checklist point 18).
8.2. Operational capacity
Applicant's (lead and co-applicants) must have the professional competencies as well as appropriate qualifications necessary to complete the proposed action. In particular, applicants must have:
Carried out projects in the fields of free movement of workers or labour mobility;
The necessary operational resources (technical, management) to carry out the action.
The operational capacity of the applicant (lead and co-applicant) to complete the proposed action must be confirmed by the submission in the proposal of the following:
A list of the main projects relating to the subject of the call carried out in the last three years (see section 15, checklist point 15);
The CVs of the proposed project co-ordinator and of the persons who will perform the main tasks, showing all their relevant professional experience (see section 15, checklist point 14);
In the case of a sole applicant, if that applicant is considered not to have the required financial or operational capacity, the application will be rejected.
In the case of consortia, if the lead applicant is considered not to have the required financial or operational capacity, the application as a whole will be rejected. If a co- applicant is considered not to have the required financial or operational capacity, this co-applicant will be removed from the consortium and the application will be evaluated without this co-applicant. In addition, the costs that are allocated to the non-selected co-applicant will be removed from the budget. If the application is accepted, the work programme will have to be adapted as appropriate.
9. AWARD CRITERIA
The proposals which fulfil the eligibility and selection criteria will be assessed according to the following award criteria18. The maximum total quality score is 100 points.
Relevance of the proposal to the call objectives, in particular its innovative character, 20/100
- Relevance of the proposal and its expected results to the objectives/priorities of the call for proposals
- The degree of relevance of the results for the priorities of European Platform tackling undeclared work
Quality of the methodology and of the activities proposed; 30/100
- Overall quality, clarity, coherence and soundness of the work plan and
- Appropriateness, feasibility, and soundness of the proposed analytical basis
Impact of the proposal; 20/100
- Impact on envisaged target group
- Sustainability of impact
Visibility of the proposed activities; 10/100
- Visibility at national and European level
Cost efficiency of the operation. 20/100
- Sufficiency and adequateness of resources and their allocation for the
different tasks to be performed
Applications will be ranked according to the total score awarded. Taking into account the available budget, the proposals with the highest total scores will be recommended for award, on condition that the total score reaches at least 70% of the maximum possible mark.
10. LEGAL COMMITMENTS
In the event of a grant being awarded by the Commission, a grant agreement, drawn up in euro and detailing the conditions and level of funding, will be sent to the beneficiary, or to the coordinator in the case of multi-beneficiary grant agreements.
The 2 copies of the original agreement must be signed by the beneficiary, or the coordinator in the case of multi-beneficiary grant agreements, and returned to the Commission immediately. The Commission will sign it last.
The grant agreement may include corrections and deletion of ineligible costs or activities made by the Commission – therefore the applicant should carefully read the whole agreement and the budget and work programme sections in particular, before signing and returning the copies to the Commission.
A model Grant Agreement is published on the Europa website under the relevant call: http://ec.europa.eu/social/main.jsp?catId=629&langId=en.
Please note that the award of a grant does not establish an entitlement for subsequent years.
10.1. Sources of funding
In addition to the obligations with regard to visibility of Union funding foreseen in the General conditions to the grant agreement, beneficiaries must acknowledge in writing that the project has been supported by the European Union Programme for Employment and Social Innovation ("EaSI") 2014-2020. In practice, all products (publications, brochures, press releases, videos, CDs, posters and banners, and especially those associated with conferences, seminars and information campaigns) must state the following:
This (publication, conference, video, xxx) has received financial support from the European Union Programme for Employment and Social Innovation "EaSI" (2014-2020). For further information please consult: http://ec.europa.eu/social/easi
The European emblem must appear on every publication or other material produced. Please see:
Every publication must include the following:
The information contained in this publication does not necessarily reflect the official position of the European Commission.]
11. FINANCIAL PROVISIONS
Details on financial provisions are laid out in the Financial Guidelines for Applicants and the model Grant Agreement, both published on the Europa website under the relevant call: http://ec.europa.eu/social/main.jsp?catId=629&langId=en.
a) Specific procurement procedures
Where the value of a foreseen procurement contract for subcontracting external expertise exceeds EUR 60 000, in addition to the rules indicated in the Financial Guidelines for applicants, the following shall apply:
the applicant must provide with the grant application a copy of the draft tender specifications. To assist applicants, a model for tender specifications is included in Annex to this call. The draft tender specifications should be submitted in English, French or German.
This requirement does not apply to public authorities which are already governed by a system of public procurement rules.
12. PROCEDURE FOR THE SUBMISSION OF PROPOSALS
The procedure to submit proposals electronically is explained in point 14 of the "Financial Guidelines for Applicants". Before starting, please read carefully the SWIM user manual:
Once the application form is filled in, applicants must submit it both electronically and in hard copy, before the deadline set in section 3.b above.
The SWIM electronic application form is available until midnight on the day of the submission deadline. Since the applicants must first submit the form electronically, and then print, sign and send it by post service or hand delivery by the submission deadline, it is the applicant's responsibility to ensure that the appropriate postal or courier services are locally available on the day of the deadline.
The hard copy of the proposal must be duly signed and sent in duplicate (one marked “original” and one marked “copy”), including all documents listed in sections14/15, by the deadline (the postmark or the express courier receipt date serving as proof) to the following address:
Call for proposals VP/2017/005 DG EMPL.D.1
Office: J-27 – 05/050 1049 Bruxelles Belgium
Please send your proposal by registered post, express courier service or by hand delivery only. Proof of posting or express courier receipt should be kept as it could be requested by the European Commission in cases of doubt regarding the date of submission.
Hand-delivered proposals must be received by the European Commission before 4 p.m. on the date of the deadline for submission as indicated in section 3(b) at the following address:
Service central de réception du courrier Call for proposals VP/2017/005
Avenue du Bourget, 1
At that time the European Commission's Mail Service will provide a signed receipt which should be conserved as proof of delivery.
If an applicant submits more than one proposal, each proposal must be submitted separately.
Additional documents sent by post, by fax or by electronic mail after the deadlines mentioned above will not be considered for evaluation unless requested by the European Commission.
The applicant's attention is also drawn to the fact that incomplete or unsigned forms, hand-written forms and those sent by fax or e-mail will not be taken into consideration.
The information contained in the present call document together with the Financial Guidelines for Applicants provides all the information you require to submit an application. Please read it carefully before doing so, paying particular attention to the priorities of the present call.
All enquiries must be made by e-mail only to:
For any technical problems please contact: email@example.com
Questions may be sent by to the above address no later than 10 days before the deadline for the submission of proposals.
The Commission has no obligation to provide clarifications to questions received after this date.
Replies will be given no later than 5 days before the deadline for submission of proposals. To ensure equal treatment of applicants, the Commission will not give a prior opinion on the eligibility of applicants, or affiliated entity(ies), an action or specific activities.
No individual replies to questions will be sent but all questions together with the answers and other important notices will be published (FAQ in EN) at regular intervals on the Europa website under the relevant call: http://ec.europa.eu/social/main.jsp?catId=629&langId=en.
The Commission may, on its own initiative, inform interested parties of any error, inaccuracy, omission or clerical error in the text of the call for proposals on the mentioned Europa website. It is therefore advisable to consult the above mentioned website regularly in order to be informed of the questions and answers published.
No modification to the proposal is allowed once the deadline for submission has elapsed. If there is a need to clarify certain aspects or to correct clerical mistakes, the Commission may contact the applicant for this purpose during the evaluation process.
Applicants will be informed in writing about the results of the selection process. Unsuccessful applicants will be informed of the reasons for rejection. No information regarding the award procedure will be disclosed until the notification letters have been sent to the beneficiaries.
14. INSTRUCTIONS FOR THE PRESENTATION OF THE APPLICATION AND REQUIRED DOCUMENTS
14.1. Instructions for the presentation of the application
The application comprises an application form including the budget, a description of the action and work plan plus a series of other required documents (see section 14.2).
The description of the action and work plan must be written using a free format document. All the information related to the description of the action and the work plan must be presented in one single document. The budget must be presented using the application form in SWIM.
Proposals should include inter alia the mandatory activities indicated in section 2.2 above in the description of the action, the work plan and foresee the corresponding expenditure in the budget estimate.
In case of subcontracting any tasks comprising part of the action (see the Financial Guidelines), the description of the action must provide details on the tasks to be subcontracted and the reasons for doing so and these tasks must be clearly identified in the budget. Core tasks as defined in section 6.2(c) of the call cannot be subcontracted.
14.2. Required documents
The table in annex includes the documents that should be provided in addition to the documents mentioned in 14.1 Except for items 8, 11 and 1219 which can be submitted only for successful applications, please note that all other documents are necessary either for the admissibility (see section 5) or for the analysis of the eligibility (see section 6) or selection criteria (see section 8). It also indicates where originals are required. We recommend that applicants use the table as a checklist in order to verify compliance with all requirements. While some information must be supplied using the templates available in the SWIM, other documents may need to be completed and/or attached electronically, usually either administrative documents or free format text descriptions. The SWIM application indicates in each section where SWIM templates should be used as well as which and where free format documents can be uploaded electronically.
Copies of the signed originals will be accepted for most of the documents to be submitted by the co-applicants. However, the lead applicant shall keep the original signed versions for its records, because originals may have to be submitted for certain documents at a later stage. If the lead applicant fails to submit these original documents within the deadline given by the Commission, the proposal will be rejected for lack of administrative compliance.
Regarding the compilation of the application file, it is recommended to:
1) follow the order of documents as listed in the checklist (and attach a ticked checklist as below to the proposal);
2) print the documents double-sided;
3) use 2-hole folders (do not bind or glue; stapling is acceptable).