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EaSI Programme - Transaction cost support for social enterprise finance - VP/2018/017
Deadline: Mar 21, 2019  
CALL EXPIRED

 Entrepreneurship and SMEs
 Microfinance
 Social Innovation
 Corporate Finance
 Business Management
 Financial Management
 Financial analysis

1. INTRODUCTION – BACKGROUND

1.1. Programme/Legal base

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 annual work programme2 C(2017) 8347 was published on 13/12/2017.

The European Programme for Employment and Social Innovation "EaSI" 2014-20203 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 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

Social enterprises as vehicles for job creation and social innovation

Boosting Jobs, Growth and Investment is one of the main priorities of the European Union. In its Start-up and Scale up Initiative, the Commission has in particular recognised the potential of social enterprises for innovation and their positive impact in economy and society at large. Social enterprises develop innovative approaches, models or practices for resolving societal challenges in an entrepreneurial way to promote inclusive, socially fair and environmentally sustainable economic development and social change. Their economic operations cover a broad spectrum of activities (including in particular social and economic integration of the disadvantaged and excluded, social assistance and care services of general interest, education and training, community development, reducing emissions and waste, or producing renewable energy).

However, poor access to finance is still a significant barrier for starting up a social enterprise, ensuring its sustainability and growth. Due to their size, the financing amounts that the majority of social enterprises need are relatively small: the most important financing gap in the market is between EUR 100 000 and EUR 500 000 for early-stage social enterprises.4 As the transaction costs for these relatively small tickets are comparatively high, social impact fund managers have an incentive to focus on higher amounts in order to preserve the fund's sustainability. This leads to a mismatch between the demand for smaller ticket sizes and the higher ticket sizes on offer, thereby resulting in a market failure.5

1.3. Main Purposes

One of the objectives of the EaSI programme is to promote employment and social inclusion by improving access to finance for social enterprises and supporting the development of the social enterprise finance market.

Under the EaSI Microfinance and Social Entrepreneurship axis, at least 58 million EUR are earmarked for this purpose. Several financial instruments have been deployed under or with support from EaSI:

  •   The EaSI Guarantee scheme was launched in June 2015 to cover loans (of up to EUR

    500 000) to social enterprises. This risk-sharing mechanism gives incentives to social enterprise investors to reach out to entrepreneurs they would not have been able to finance otherwise.

  •   The EaSI Capacity-Building Investments window was launched in December 2016. It aims at building up the institutional capacity of selected social enterprise finance providers in Europe primarily through equity or quasi-equity investments.

Both EaSI financial instruments are implemented by the European Investment Fund.6

  •  In addition, a set of pilot social impact equity instruments was launched in October 2016 under the European Fund for Strategic Investment (EFSI) (with a first-loss piece from EaSI and Innovfin): they include a facility for financial intermediaries linked to incubators, accelerators, and/or that provide incubation services for social enterprises in their early stages (at least EUR 25 million) and a Business Angel Facility (at least EUR 25 million) that will make investments alongside business angels or in business angel funds, including private individuals or non-institutional investors who invest into social enterprises at seed, early stage as well as expansion and growth stage.7

4 Subject Paper of GECES Working Group 1: “Improving access to funding” available at:

http://ec.europa.eu/DocsRoom/documents/21252/attachments/5/translations/en/renditions/native

 

This call is intended to complement EU-level financial instruments under the EaSI programme and EFSI8 with a grant component to further promote the development of the social enterprise finance market and facilitate access to finance for social enterprises.

 

2. OBJECTIVE(S) – PRIORITIES – TYPES OF ACTIONS - EXPECTED RESULTS

2.1. Objectives – Priorities

The objective of the call is to develop the social enterprise finance market. It will catalyse risk capital investments below EUR 500 000 that otherwise would not happen in the area of social finance, by supporting transaction costs linked to these investments. This transaction cost support scheme takes the form of a grant and can be combined with financial instruments as a means to address the mismatch of needed and sustainable ticket sizes.

The grant is aimed at financial intermediaries that undertake long-term risk capital investments in ticket sizes of less than EUR 500 000 in the form of equity, quasi-equity, or hybrid financing (see annex II for a glossary) to social enterprises in the EaSI Participating Countries9. It will serve to lower the transaction costs for these small investment tickets and thus help overcome a market failure in the social enterprise finance market.

2.2. Description of the activities to be funded / Type of actions

Activities related to the preparation, conclusion and follow-up of long term risk capital investments into social enterprises may be funded under this call for proposals.

This may include a mix of activities such as:

  •   travelling to meet (potential) investees;

  •   screening and processing investment applications;

  •   preparing legal documents, potentially with a lawyers' advice;

  •   carrying out the due diligence, including assessing (potential) impact of the investment;

  •   providing investment readiness, scaling readiness or business restructuring support;

  •   bringing in co-investors;

  •   managing the investments and monitoring social impact.

The long term risk capital investments may take the form of equity, quasi-equity or hybrid financing (see Annex II for a glossary) of a maximum of EUR 500 000 per investment. If a second investment in a social enterprise takes place within less than 18 months from the first investment and this raises the cumulative amount invested above the EUR 500 000 limit, the activities related to the first investment become ineligible for grant support, and any related payments already made by the Commission may be subject to recovery.

In relation to the investees, the following conditions apply:

8 Such as the EFSI equity incubator/accelerator pilot supporting social enterprises as defined in accordance with EU Regulation 1296/2013

9 Please refer to section 6.1 for a list of the EaSI Participating Countries. -4-

  •   The selected investees must be social enterprises in the sense of the EaSI Regulation. Please refer to annex II (Glossary) for the definition and to annex III for the detailed requirements.

  •   The social enterprises must be established / in the process of being established and active in one or more of the EaSI participating countries (see section 6.1).

  •   The social enterprises must have an annual turnover not exceeding EUR 30 million, or an annual balance sheet total not exceeding EUR 30 million and they must not themselves be collective investment undertakings.

The total transaction cost should not exceed 10% of the total expected amount of investments in social enterprises

The selected beneficiaries shall participate in up to four workshops organised by the Commission in a location to be defined, with the aim of sharing practices and experience gained in implementing the action and lessons learnt. The costs of the participation to the workshops (travel, accommodation and subsistence allowances, and staff costs) of at least one participant for each action should be included in the budget of the proposal (one night/workshop). The workshops will bring together organisations supported under this call and other competent organisations.

2.3. Expected outputs/results

The expected result is an increased number of risk-capital investments of below EUR 500 000 in social enterprises.

2.4. Monitoring

The Commission, with the support of an external contractor, will monitor regularly the EaSI Programme. Therefore, beneficiaries 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 will be provided.

In setting up the action, beneficiaries must foresee the necessary funding for monitoring and reporting to the Commission.
As the monitoring of the EaSI Programme involves the collection and further processing of personal data, Regulation (EC) 45/2001, of the European Parliament and of the Council of 18 December 2000 on the protection of individuals with regard to the processing of personal data by the Community Institutions and bodies and on the free movement of such data, is applicable.10

 

3. TIMETABLE

a) Publication of the call

11/2018

b) Deadline for questions and requests for clarification

11/03/2019

c) Deadline for submitting proposals

21/03/2019

Swim, Courier and Post : 24:00 Brussels' time (CET)

Hand deliveries 16:00 Brussels' time (CET)

d) Evaluation period (indicative)

Submission deadline + 6 weeks

e) Information to applicants (indicative)

Submission deadline + 3 months11

f) Signature of the grant agreements (indicative)

Submission deadline + 4 months12

 

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 date of submission of the application.

An action grant may be awarded for an action which has already begun only where the applicant can demonstrate in the grant application the need to start the action before the grand agreement is signed

The project's duration should be between 12 months and 24 months.

 

4. AVAILABLE BUDGET AND CO-FINANCING RATE

Available Budget and Grant Amounts

total budget earmarked for the EU co-financing of projects under this call is estimated 000 000 EUR.

EU grant requested should indicatively be between EUR 300 000 and EUR 1 million. Commission reserves the right not to distribute all the funds available.
Commission reserves the right to increase the amount of the funds and distribute them

 

4.2. Co-financing rate

Under this call for proposals, the EU grant may not exceed 80 % 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 sources other than the European Union budget13.

 

5. ADMISSIBILITY REQUIREMENTS

  •   Applications must be sent no later than the deadline for submission referred to in section 3(b)

  •   Applications (meaning, the application form, including budget and description of the action including work plan) must be submitted using the electronic submission system available at https://webgate.ec.europa.eu/swim, and by sending a signed, printed version of the complete application form by post or courier service (one original dossier and one copy; see section 12).

Failure to comply with the above requirements may 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 submitted in any of the official languages of the EU will be accepted. In this case, applications should be accompanied by an executive summary in English (see section 14, checklist).

 

6. ELIGIBILITY CRITERIA
6.1. Eligibility of the applicants (lead and co-applicants) and affiliated entities14

Please be aware that eligibility criteria must be complied with for the entire duration of the grant. If the United Kingdom withdraws from the EU during the grant period without concluding an agreement with the EU ensuring in particular that British applicants continue to be eligible, British beneficiaries will cease to receive EU funding (while continuing, where possible, to participate) or be required to leave the project on the basis of Article II.7.2.1(a) (for mono-beneficiary) and Article II.17.3.1(a) (multi-beneficiary) of the grant agreement.

a) Place of establishment

Legal entities properly established and registered in the following countries are eligible as lead applicant, co-applicants:

  •   EU Member States;

  •   Iceland and Norway in accordance with the EEA Agreement

     Albania, the former Yugoslav Republic of Macedonia, Montenegro, Serbia and Turkey15

    b) Type of entities
    To be eligible, the lead applicant, co-applicant and affiliated entity must be:

    1. An investment fund, a Fund-of-Funds, a special purpose vehicle, in any form, established or to be established

    In this case, there are 2 options:

  •   Either the legal entity of the investment fund, the Fund-of-Funds or the special purpose vehicle can be an applicant.

  •   Or the (future) manager of the investment fund, of the Fund-of-Funds or the special purpose vehicle (established or to be established) can be applicant.

    For the avoidance of doubt, the (future) manager must already be an established and registered legal entity at the time of the submission of the application.

2. A (co-) investment scheme in any form (including managed accounts and other types of contractual arrangements) established or to be established.

  1. 14  See section2 of the Financial Guidelines for definitions.

  2. 15  Other candidate and potential candidate countries would also participate in accordance with the general

principles and the general terms and conditions laid down in the framework agreements concluded with them on their participation in Union programmes. However, it is not yet confirmed, therefore applicants and co- applicants from those countries should check with the secretariat of the call (empl-vp-2018- 017@ec.europa.eu) their eligibility.

In this case, either the (future) manager of the (co-) investment scheme / the managed accounts must be applicant or the parties of the (future) contractual arrangements must be applicants (in a consortium).

The (future) manager or the parties (applicant or lead applicant and co-applicants) to the (future) grant agreement arrangements must already be established and registered legal entities at the time of the submission of the application.

c) Consortia16
Actions may involve consortia.

For proposals submitted by only one applicant, if the single applicant is considered not to be eligible, the application will be rejected.

For consortia, if the lead applicant is considered not 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.

d) Affiliated entities

1. 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.

2. Sole beneficiary: where several entities satisfy the criteria for being awarded a grant and together form one entity, that entity may be treated as the sole beneficiary, including when the entity is specifically established for the purpose of implementing the action to be financed by the grant.

For that purpose, applicants shall identify such affiliated entities in the application form.

6.2. Eligible activities

a) Geographical Location

To be eligible, actions must be fully carried out in eligible participating EaSI countries (see section 6.1)

b) Types of activities
The grant will finance the activities indicated in section 2.2 c) Core activities

16 Letters of mandate, authorising the lead applicant to submit the proposal and to sign any Grant Agreement on their behalf must be submitted by each co-applicant. Letters of commitment must be submitted by each co-applicant, affiliated entity, certifying that they are willing to participate in the project with a brief description of their role and indicating any financial contribution where applicable (see section 14, checklist points 5 and 6. Letters of commitment are also required from any associate organisations (participation on a no-cost basis and no financial contribution).

The following activities are considered to be core activities and may not be subcontracted:  Management of the project

 

7. EXCLUSION CRITERIA

7.1. Exclusion

Applicant(s) (applicant or lead applicant and each co-applicant) must sign a declaration on their honour signed in their name (and on behalf of the affiliated entities, should they be part of the application), certifying that they are not in one of the situations referred to in article 136 and 141 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.

7.2. Rejection from the call for proposals

The Commission shall not award a grant to an applicant who:

a. is in an exclusion situation established in accordance with Article 136; or

b. has misrepresented the information required as a condition for participating in the procedure or has failed to supply this information; or

c. was previously involved in the preparation of calls documents used in the award procedure where this entails a breach of the principle of equality of treatment, including distortion of competition, that cannot be remedied otherwise.

The same exclusion criteria apply to any affiliated entities which must, therefore, be included in the above-mentioned declaration(s).

Administrative sanctions may be imposed on applicants, or affiliated entities where applicable, if any of the declarations or information provided as a condition for participating in this procedure prove to be false.

 

8. SELECTION CRITERIA

The applicant or lead applicant and each co-applicant must have the financial and operational capacity to complete the activities for which funding is requested. Only organisations with the necessary financial and operational capacity may be considered for a grant.

For sole applicants (See Section 6.1. d) 2.), the selection criteria will apply to the affiliated entities (not only to the sole applicant).

8.1. Financial capacity

The applicant or lead applicant and each co-applicant 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 applicant's or lead applicant's and each co-applicant's or affiliated members' of a sole beneficiary (see Section 6.1. d) 2.) 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 14, checklist point 4);

  •   Annual balance sheets and profit and loss accounts for the last financial year available (see section 14, checklist point 15). For newly-created entities, the business plan will replace the closed accounts;

  •   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 14, checklist point 16). For newly-created entities, this will be replaced by an explanatory note accompanying the business plan;

  •   For grants exceeding EUR 750 000 per beneficiary or affiliated entity, an audit report produced by an approved external auditor certifying the accounts for the last financial year available, where it is available and always in cases where a statutory audit is required by Union or national law. In all other cases, a self-declaration signed by the authorized representative (see section 14, checklist point 17).

    If the applicant or lead applicant is considered not to have an acceptable financial capacity, the application as a whole will be rejected.

    If a co-applicant or several co-applicants are considered not to have an acceptable financial capacity, the Commission will also take into account any other relevant information on the financial capacity provided by the applicant and in particular the information provided in section "Financial Resources" of the SWIM application form.

    After this further analysis, the Commission will take various proportional measures

depending on

  • the level of weaknesses identified, which may be to:
  • reject the whole application;
  • remove the co-applicant from the consortium and re-evaluate the proposal without this co-applicant;
  • propose a grant agreement without pre-financing;
  • propose a grant agreement with a pre-financing paid in several instalments; propose a grant agreement with pre-financing payment(s) covered by (a) financial guarantee(s);
  • propose a grant agreement with joint financial liability of 2 or more applicants/co-applicants;
  • propose a grant agreement with a mix of the measures 4, 5 and 6;

for sole applicants (See section 6.1. d) 2.) : request the affiliates to act as guarantors.

8.2. Operational capacity

Applicants or lead applicants and each co-applicant or affiliated entities of a sole beneficiary (see Section 6.1. d) 2.) must have the professional competencies as well as appropriate qualifications necessary to complete the proposed action.

The operational capacity of the applicant, lead applicant and co-applicant(s) to complete the proposed action must be confirmed by the submission of the following supporting documents:

  •   A list of investments17 / investment projects in social enterprises or other forms of social impact investing or impact first investing in the last three years (see section 14, checklist point 14). The list should include at least 5 investments per application (i.e. applicant or consortium (lead applicant and co-applicant(s) together)) and provide details such as the type of investment, type of investees, amounts; For newly-created entities, the list of investments can be replaced by a description of the competences transferred from the staff members to the newly-created entity and the mechanism through which this will be done;

  •   The CVs of the project manager of the applicant or of the consortium, and of the persons who will perform the main tasks, detailing all their relevant professional experience (see section 14, checklist point 12); For newly-created entities, the CVs of the persons who will perform the main tasks can be replaced by a recruitment plan which includes details concerning the professional profile of the staff to be selected and the timeline for the hiring to be completed within 4 months from the start of the project;

    The minimum CV requirements are the following:
    - The project manager must have been engaged in social enterprise finance or social impact finance for at least three years.
    - The other members of the team must have been engaged in social enterprise finance or social impact finance for at least one year.

  •   Declaration on honour signed by the legal representative (including operational capacity to carry out the activity) (see section 14, checklist point 4);

  •   A declaration by the project manager/coordinator of the lead applicant certifying the professional competence and appropriate qualification of the team to carry out the required tasks (see section 14, checklist point 13).

If the applicant or lead applicant is considered not to have the required operational capacity, the application as a whole will be rejected. If a co-applicant is considered not to have the required operational capacity, this co-applicant will be removed from the consortium and the application will be evaluated without this co-applicant18. In addition, the costs that are allocated to the non-selected co-applicant will be removed from the granted budget. If the application is selected, the work programme may have to be slightly adjusted.

 

9. AWARD CRITERIA

The proposals which fulfil the eligibility and operational capacity criteria will be assessed according to the following award criteria:

 Relevance for the objectives of the call and added value (Min 19.5 points; Max. 30 points)

Under this criterion, the extent to which the planned investments will contribute to the objective of increasing finance for social enterprises in need of investment tickets up to EUR 500 000 will be assessed as well as the added value that the grant support will provide in easing this kind of investments, going beyond the applicant's current activities.

This includes a re-evaluation of the eligibility of the modified consortium. 

  •   Quality of the activities and expected outcomes (Max. 30 points)
    In this respect, the coherence of the activities in relation to the needs of the market and how the grant will be used to reduce transaction costs will be part of the assessment

  •   Development potential and sustainability (Max. 20 points)

    Under this criterion, the potential of the proposed model to further develop (e.g. in size) and reach sustainability in the future will be taken into account, as well as how the experience curve effects will be monitored.

  •   Cost effectiveness (Min 11 points; Max. 20 points)
  • In this respect, the coherence of the overall budget breakdown, clarity and consistency of the estimated budget description and justification of costs will be assessed, as well as the degree to which the cost of the action is proportionate to the overall size of the financial instrument dedicated to investments in social enterprises, the level of output and impact of the action.

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 65% of the maximum possible mark;

  •   the score for the criterion on Relevance and added value is at least 65% of the maximum possible mark for that criterion;

  •   the score for the criterion on Cost effectiveness is at least 55% of the maximum possible mark for that criterion.

The proposals with the highest evaluation total score will be selected for award. If multiple proposals with the same territorial coverage are received, the Commission will first award the proposal with the highest score for each specific territory. Depending on budget availability, the best proposals of the general ranking will then be awarded until the maximum budget earmarked for the co-financing of this call has been reached.

 

10. LEGALCOMMITMENTS

In the event of a grant being awarded by the Commission, a Grant Agreement, drawn up in euros 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 shall 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 them last.

The Commission may have made relevant corrections and deletion of ineligible costs or activities in the Grant Agreement sent to the applicant – therefore the applicant should carefully read the whole agreement before signing and returning the copies to the Commission.

 

Further to the entry into force of the new Financial Regulation, the updated versions of the model Grant Agreement(s) will be shortly uploaded on the Europa website http://ec.europa.eu/social/main.jsp?catId=629&langId=en.

In the meantime, the former model Grant Agreement(s) are made available for information purposes, but the new models are the ones which will have to be signed and there is no alternative to these models in the context of this call. In specific cases, international agreements conditions may also apply.

Please note that the award of a grant does not establish an entitlement for subsequent years.

10.1. SourcesofFunding

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:

http://ec.europa.eu/dgs/communication/services/visual_identity/pdf/use-emblem_en.pdf

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.

 

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:

http://ec.europa.eu/employment_social/calls/pdf/swim_manual_en.pdf

Once the application form is filled in, applicants must submit it both electronically and in hard copy, by the deadline set in section 3

 

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 3 copies (one marked “original” and two marked “copy”), including all documents listed in section 14, by the deadline set in section 3(c), either by registered post, express courier service or hand delivery.



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