Law enforcement cooperation Silk Road Migration Route - ISFP-2016-AG-SRMR-01

Deadline: Feb 28, 2017  
CALL EXPIRED

Call for proposals restricted to Member States for law enforcement cooperation between Member States and relevant third countries along the Silk Road Migration Route to better address and improve the detection and apprehension of migrant smugglers 

 

1. INTRODUCTION 

Article 67(3) of the Treaty on the Functioning of the European Union (TFEU) declares as the European Union’s objective ensuring a high level of security within an area of freedom, security and justice. 

To achieve this objective, enhanced actions at European Union level should be taken to protect people and goods from increasingly transnational threats and to support the work carried out by Member States’ competent authorities. Terrorism, organised crime, itinerant crime, drug trafficking, corruption, cybercrime, trafficking in human beings and arms, inter alia, continue to challenge the internal security of the Union. 

The Internal Security Strategy for the European Union (Internal Security Strategy), adopted by the Council in February 2010, constituted a shared agenda for tackling these common security challenges and identified the following relevant strategic objectives for 2010-2014: to disrupt international crime networks, to prevent terrorism and address radicalisation and recruitment, to raise levels of security for citizens and businesses in cyberspace and to increase Europe’s resilience in the face of crises and disasters. 

To promote the implementation of the Internal Security Strategy and to ensure that it becomes an operational reality, the Internal Security Fund (ISF Police) was set up. 

In April 2015 the European Commission adopted the European Agenda on Security (EAS) for the coming five years, which builds on the actions undertaken under the previous Internal Security Strategy, thus ensuring consistent and continued action. The EAS represents an effective and coordinated response at European level to new and complex threats and sets out how the European Union can bring added value to support the Member States in ensuring security. It has identified the following three priorities: tackling terrorism and preventing radicalisation, disrupting organised crime and fighting cybercrime. 

On the basis of the EAS, the Council adopted in June 2015 the renewed European Union Internal Security Strategy 2015-2020 confirming tackling and preventing terrorism, radicalisation to terrorism and recruitment as well as financing related to terrorism, preventing and fighting serious and organised crime and preventing and fighting cybercrime as the main priorities for European Union's actions. 

Legal basis of ISF Police are the following regulations: 3 

- Regulation (EU) No 513/2014 of the European Parliament and of the Council of 16 April 2014 establishing the Instrument for financial support for police cooperation, preventing and combating crime, and crisis management (OJ L 150 of 20 May 2014); 

- Regulation (EU) No 514/2014 of the European Parliament and of the Council of 16 April 2014 laying down general provisions on the Asylum, Migration and Integration Fund and on the instrument for financial support for police cooperation, preventing and combating crime, and crisis management (OJ L 150 of 20 May 2014). 

The ISF Police Regulation sets out two specific objectives, respectively: 

(i) crime prevention, combating cross-border, serious and organised crime including terrorism, and reinforcing coordination and cooperation between law enforcement authorities and other national authorities of Member States, including with Europol or other relevant Union bodies, and with relevant third countries and international organisations; 

(ii) enhancing the capacity of Member States and the Union for managing effectively security-related risks and crises, and preparing for and protecting people and critical infrastructure against terrorist attacks and other security-related incidents. 

In conformity with Regulation (EU) No 514/2014 Article 6.2, in order to implement the ISF Police, the Commission has adopted, on 26 July 2016, the 2016 Annual Work Programme for Union actions and emergency assistance1, which includes this Call for Proposals. 

Short overview of the policy context, reference to key policy documents (if applicable) and main objectives of the call. 

In light of the increase in mixed migration flows towards the EU and the increase in migrant smuggling activities, renewed efforts to engage with countries of origin and transit are being made in line with the EU Action Plan against migrant smuggling2 as well as through the new Partnership Framework with third countries under the European Agenda on Migration3. The largest migration flows in 2015 arrived to the Greek Islands of the Aegean Sea and subsequently through the Western Balkans. A large part of this mixed migration flows originated or transited the Silk Route Region. 

As part of the Budapest Process the Istanbul Ministerial Declaration on a Silk Routes Partnership for Migration was adopted in Turkey on 19th April 2013, whereby signatories identified priority goals for further dialogue and mutual cooperation. Amongst these priorities, agreement was reached on the necessity to prevent and counteract irregular migration, facilitate readmission of irregular migrants and combat criminal networks involved in the smuggling of migrants through coordination between agencies involved in preventing irregular migration and migrant smuggling at the national, regional and international level. Participants of the Budapest Process include amongst others Member States, countries of the Western Balkans and Afghanistan, Iraq and Pakistan, with Bangladesh and Iran with an observer status and participating in activities. The Joint Way Forward on migration issues between Afghanistan and the EU is a further step towards closer cooperation. 

This call for proposals aims to strengthen cooperation between Member States' and relevant third countries' law enforcement authorities along the Silk Route Region to better address the challenges posed by the activities of criminal organisations, engaged in the smuggling of migrants. This will be achieved through increased information sharing, cooperation and coordination activities. This is to be targeted at specific priority countries of irregular migration along the Silk Route Region, namely Pakistan and Afghanistan. 

Home Affairs funds will provide support to the launching and implementation of this initiative through a targeted action supporting the competent authorities of the Member States in their fight against the organised crime networks active in migrant smuggling 

along the Silk Route Region towards Europe. The activities supported through this project will have a direct impact in the EU by contributing to maintaining and improving the internal security of the EU. 

2. PRIORITIES OF THIS CALL FOR PROPOSALS 

The present Call for Proposals aims at funding projects in the area of law enforcement cooperation between one or more EU Member States and the respective law enforcement authorities of Pakistan and Afghanistan. 

Project applications submitted under the present Call for Proposals must address at least one of the following priorities: 

1. More effective prevention, detection, investigation and prosecution of migrant smuggling networks, through increased operational and strategic cooperation between Member State law enforcement authorities and law enforcement authorities of Afghanistan. (indicative amount 1.000.000 EUR) 

2. More effective prevention, detection, investigation and prosecution of migrant smuggling networks, through increased operational and strategic cooperation between Member State law enforcement authorities and law enforcement authorities of Pakistan. (indicative amount 500.000 EUR) 

Proposals consisting exclusively in studies and/or conferences will not be considered for funding under this Call for Proposals. 

Projects must be aiming to achieve one or more of the following operational outcomes related to the prevention and fight against organised criminal groups engaged in migrant smuggling, without duplicating existing projects or structures. The specific outcomes below can apply to action carried out both in Afghanistan (priority 1) or Pakistan (priority 2): 

 Increased exchange of operational and strategic information with the relevant third country allowing for more effective criminal investigations, with the possibility of setting up joint investigation teams or any other relevant law enforcement operations. 

 Networking, coordination and exchange of information between Member State liaison officers in the region as well as European Migration Liaison Officers in the region, by making use of existing platforms (e.g. ILO network, EU Cooperation Platform on migrant smuggling). Support to the deployment of Member States' liaison officers and short-term experts to the region. 

 Building trust, enhancing cooperation and exchange of information between Member State and law enforcement authorities in the relevant third country and with international organisations and EU agencies, such as Frontex, Europol, Eurojust and Interpol when relevant. 

 Develop and deliver training courses and mentoring on detection, investigation and prosecution methodologies in the area of migrant smuggling, including on financial investigation and the distinction between human trafficking and migrant smuggling. Common training curricula could be developed in cooperation with local training institutions. 

 Establishment of a database between Member States and relevant law enforcement authorities ensuring interoperability with Interpol databases and the regional database planned to be developed under the Budapest Process ICMPD project "Initiating Regional Police Cooperation". 

 Make use of existing reporting mechanisms for migrant smuggling related activity, and if necessary support the setting up of an information hub (e.g. 24/7 call centre) for reporting, as well as quick communication of operational 

 

information to relevant local law enforcement entities to prevent migrant smuggling. 

 Provision of relevant equipment, if directly linked to capacity building support and training. 

 Where not existing, support and guidance for establishing more effective inter-agency cooperation practices as well as improved procedures and organisational structures to allow for the optimal allocation of scarce resources, both at regional and national level. 

Any actions under this Call for Proposals shall respect and shall be implemented in line with the rights and principles enshrined in the Charter of Fundamental Rights of the European Union. Applications should pay appropriate attention to the effects of the project on individual rights and freedoms, as well as to possible remedies. In addition, any action under this Call for Proposals should comply with all relevant ethical principles and all applicable international, EU and national law on ethical issues while carrying out the project. 

During the implementation, complementarity with other ongoing or upcoming EU-funded project in the region has to be ensured, namely: 

- In the region: one project, currently ongoing on "Support to the Silk Routes Partnership for Migration" and another forthcoming on “Improving Migration Management in Silk Route Countries”, both being implemented by ICMPD; 

- In Afghanistan: one project on “Border Management in Northern Afghanistan" (BOMNAF) with Tajikistan and Uzbekistan, implemented by UNDP; 

- In Pakistan: one project on “Fight against Trafficking in Human Beings - Phase 2” (THB/IFS/2) contributing to the prevention of and fight against transnational organised crime, particularly in relation to trafficking in human beings (THB), by providing the participating countries with policy, legal and technical expertise, implemented by ICMPD; 

-In Pakistan: the Global Action against Trafficking in Persons and the Smuggling of Migrants (GloAct), aiming at assisting selected countries in developing and implementing comprehensive national counter-trafficking and counter-smuggling responses and focusing on prevention and protection, implemented by UNODC, IOM and UNICEF. 

 

3. TIMETABLE

a) Publication of the call 

24/11/2016 

b) Deadline for submitting applications 

28/02/2017 – 17:00 CET) 

c) Evaluation period 

March 2017 – April 2017 

d) Information to applicants 

May 2017 

e) Signature of Grant Agreement 

May/June 2017 

 

4. BUDGET AVAILABLE 

The total budget earmarked for the co-financing of projects is estimated at EUR 1 500 000. 

The Commission reserves the right not to distribute all the funds available. 6 

 

5. ADMISSIBILITY REQUIREMENTS 

Applications must be sent no later than the deadline for submitting applications referred to in section 3. 

Applications must be submitted using the Electronic Submission System of the Participant Portal originally developed for the Horizon 2020 Research programmes. 

Applications must be submitted using the standard Submission Form Part A and Part B. They must include all the mandatory information and be accompanied by the Forecast Budget Calculation and (if applicable) the Audit Report4 Annexes. 

Applications must be drafted in one of the EU official languages. English is preferred in order to speed up the evaluation procedure. 

Projects cannot be scheduled to last more than 24 months.5 Applications for projects scheduled to run for a longer period will be rejected. 

Failure to comply with these requirements will lead to the rejection of the application. 

6. ELIGIBILITY CRITERIA 

6.1. Eligible applicants and applications 

In order to be eligible for a grant, the Applicant and the Co-applicants must be: 

a) legal persons; applications from natural persons are not eligible; 

b) a public body; 

c) established in a Member State of the European Union participating in the ISF Police instrument6. In duly justified cases where their participation is necessary to achieve the objectives of the programme, entities (public bodies) established in third countries that are part of the Budapest Process, particularly Pakistan and Afghanistan can participate but only as co-applicants. 

 

In order to be eligible for a grant, applications must be: 

a) transnational, i.e. involving at least two entities established in two different EU Member States participating in the ISF Police instrument;7 

b) seeking EU co-funding of equal to or more than EUR 500.000. 

c) activities must not have started prior to the date of submission of the grant application. 

 

Union agencies can be neither Applicants nor Co-applicants. 

To prove these eligibility requirements, Applicants and Co-applicants will have to provide the relevant information and upload necessary documents showing their legal status in the Beneficiary Register. The information needs to be provided before the submission deadline. 

6.2. Eligible activities 

The following types of activities are eligible under this Call for Proposals: 

i. administrative, logistical and operational support to preventive actions, criminal investigations or any other relevant law enforcement operations, as well as joint investigation teams and cross-border joint operations; 

ii. preparatory, administrative and technical support to the deployment of Member States liaison officers and short-term experts to the region; 

iii. support to the networking, coordination and exchange of information between Member States liaison officers and the European Migration Liaison Officers (EMLOs) in the region, by making full use of already existing cooperation platforms and networks such as the Network of the Immigration Liaison Officers, and by ensuring that Europol and Frontex are fully involved in the exchange and analysis of information, whenever relevant; 

iv. networking, exchange of information, training, mentoring and other capacity-building activities between the competent authorities of Member States and partner countries in the region; 

v. provision of relevant equipment, if directly linked to capacity-building support and training. 

vi. development of common training curricula and training courses for relevant law enforcement agencies, possibly in cooperation with local training institutions; 

vii. development of awareness-raising material; 

 

A mechanism will be set to allow the Commission to monitor closely the implementation of the project, providing when necessary strategic guidance and ensuring due coordination with other relevant EU funded actions. Relevant EU agencies such as Europol and Frontex might also be invited to participate in the implementation of the action (on a no-cost basis). 

Coordination and complementarities with ongoing externally-funded projects in this area must be ensured (in particular those detailed in section 2) through timely information sharing between the relevant Commission services and amongst the different actions. 

For actions in relation to and in third countries the following types of activities are eligible under this Call for Proposals: 

a) actions improving police cooperation and coordination between law enforcement authorities and, where applicable, international organisations, including joint investigation teams and any other form of cross-border joint operation, access to and exchange of information and interoperable technologies; 

b) networking, mutual confidence, understanding and learning, identification, exchange and dissemination of know-how, experience and best practice, information sharing, shared situation awareness and foresight, contingency planning and interoperability; 

c) acquisition, maintenance, and/or further upgrading of technical equipment, including ICT systems and their components; 

d) exchange, training and education of staff and experts of relevant authorities, including language training; 

e) threat, risk and impact assessments; 

 

7. EXCLUSION CRITERIA 

Applicants will be excluded from participating in the Call for Proposals procedure and from the grant award if they are in any of the situations referred to in articles 131(4) of the EU Financial Regulation8, i.e. one of the following situations: 

7.1. Exclusion from participation in the Call for Proposals 

(a) they are bankrupt or being wound up, are having their affairs administered by the courts, have entered into an arrangement with creditors, have suspended business activities, are the subject of proceedings concerning those matters, or are in any analogous situation arising from a similar procedure provided for in national legislation or regulations; 

(b) they or persons having powers of representation, decision making or control over them have been convicted of an offence concerning their professional conduct by a judgment of a competent authority of a Member State which has the force of res judicata; 

(c) they have been guilty of grave professional misconduct proven by any means which the contracting authority can justify including by decisions of the EIB and international organisations; 

(d) they are not in compliance with their obligations relating to the payment of social security contributions or the payment of taxes in accordance with the legal provisions of the country in which they are established or with those of Belgium or those of the country where the action is to be implemented; 

(e) they or persons having powers of representation, decision making or control over them have been the subject of a judgment which has the force of res judicata for fraud, corruption, involvement in a criminal organisation, money laundering or any other illegal activity, where such an illegal activity is detrimental to the Union's financial interests; 

(f) they are currently subject to an administrative penalty for: being guilty of misrepresentation in supplying the information required by the Commission as a condition of participation in a procurement or grant award procedure or for failing to supply this information; or having been declared to be in serious breach of its obligations under grant agreements or contracts financed by the Union's budget. 

 

7.2. Exclusion from award 

Applicants will not be granted financial assistance if, in the course of the grant award procedure, they: 

(a) are subject to a conflict of interest in connection with the action; 

(b) are guilty of misrepresentation in supplying the information required by the Commission as a condition of participation in the grant award procedure or fail to supply this information; 

(c) find themselves in one of the situations of exclusion, referred to in section 7.1. 

 

Administrative and financial penalties may be imposed on Applicants and Co-applicants who are guilty of misrepresentation. 

8. SELECTION CRITERIA 

8.1. Financial capacity 

The verification of the financial capacity shall not apply to public bodies. 

8.2. Operational capacity 

The verification of the operational capacity shall not apply to public bodies. 

9. AWARD CRITERIA 

Eligible applications and their proposed action will be assessed on the basis of the following award criteria: 

- Relevance: applications will be assessed on the extent to which they match the priorities [and expected outcomes (if applicable)] as identified in this Call for Proposals (section 2 above) and in the relevant EU strategic documents and/or action plans (section 1 above), and on whether the expected impact will be significant on the selected priority(ies) (30 points). 

 

Applications receiving less than 21 points for the "relevance" criterion will not be evaluated further. 

- Quality: applications will be assessed with regards to the appropriateness of their design and planned implementation, taking into account the envisaged activities, methodology, organisation of work and strategy for project management, evaluation and dissemination (20 points); 

- Cost-effectiveness: applications will be assessed with regards to whether the costs of the proposed action are adequate to the activities and proportionate to the expected results (30 points); 

- European added value: the project activities, outcomes and impact should have a broad EU relevance; applications will be assessed on whether a suitable number of countries is involved in the project activities and on whether the expected impact will concern a significant number of countries (20 points). 

 

Applications that pass the threshold of minimum 65 points will be considered for funding within the limits of the available budget. 

10. LEGAL COMMITMENTS 

A Commission award decision does not represent a legal or financial commitment. The award of each grant is subject to the conclusion of a Grant Agreement in writing. 

The coordinators of projects proposed for funding will be invited to engage in a grant agreement preparation process, which will be carried out via an online IT system (SYGMA). If successful, it will conclude with the signature of a Grant Agreement, drawn up in euro and detailing the conditions and level of funding. 

The Grant Agreement must be signed electronically first by the coordinator on behalf of the consortium and then by the European Commission. All co-beneficiaries must accede to the Grant Agreement by signing electronically the accession form to the grant. 

Please note, that if international organisations are involved in the application, no other specific clauses applicable to international organisations than the ones already included in the Model Grant Agreement will be added. 

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

 

11. FINANCIAL PROVISIONS 

11.1. General Principles 

a) Non-cumulative award 

 

An action may only receive one grant from the EU budget. 

In no circumstances shall the same costs be financed twice by the Union budget. To ensure this, applicants shall indicate the sources and amounts of Union funding received or applied for the same action or part of the action or for its functioning during the same financial year as well as any other funding received or applied for the same action (Submission Form Part B, section 6). 

b) Non-retroactivity 

 

No grant may be awarded retrospectively for actions already completed. A grant may be awarded for an action which has already begun only where the Applicant can demonstrate the need to start the action before the Grant Agreement is signed. In any case, costs eligible for financing may not have been incurred prior to the date of submission of the grant application. 

c) Co-financing 

 

Co-financing means that the resources which are necessary to carry out the action may not be entirely provided by the EU grant. 

Co-financing of the action may take the form of: 

- the Beneficiary's own resources, 

- income generated by the action, 

- financial contributions from third parties. 

d) Balanced budget 

 

The Budget Estimate of the action is to be attached to the Application Form. It must have revenue and expenditure in balance and must be drawn up in euro. 

Beneficiaries with general accounts in a currency other than the euro shall convert costs incurred in another currency into euro at the average of the daily exchange rates published in the C series of Official Journal of the European Union, determined over the corresponding reporting period.9 Where no daily euro exchange rate is published in the Official Journal of the European Union for the currency in question, conversion shall be made at the average of the monthly accounting rates established by the Commission and published on its website, determined over the corresponding reporting period. 

9 For further guidance on exchange rate please consult the Guide for Applicants. 

Beneficiaries with general accounts in euro shall convert costs incurred in another currency into euro according to their usual accounting practices. 

Where the implementation of the action requires the award of procurement contracts (implementation contracts), the Beneficiary must award the contract to the bid offering best value for money or the lowest price (as appropriate), avoiding conflicts of interests and retaining the documentation for the event of an audit. Detailed information on subcontracting is provided in the Guide for Applicants. 

e) Financial support to third parties 

 

The applications may not envisage provision of financial support to third parties. 

f) Non-profit rule 

 

EU grants may not have the purpose or effect of producing a profit within the framework of the action. Profit shall be defined as a surplus of the receipts over the eligible costs incurred by the Beneficiary, when the request is made for payment of the balance. In this respect, where a profit is made, the Commission shall be entitled to recover the percentage of the profit corresponding to the Union contribution to the eligible costs actually incurred by the Beneficiary to carry out the action. 

11.2. Maximum amount requested 

The EU grant is limited to a maximum co-funding rate of 90% of the total eligible costs of the action. 

Consequently, part of the total eligible expenses entered in the Forecast Budget Calculation must be financed from sources other than the EU grant (see section 11.1.c). 

The Commission reserves the right to reduce the estimated costs in the Forecast Budget Calculation, if they are deemed as ineligible. 

11.3. Payment arrangements 

A pre-financing payment corresponding to maximum 80% of the EU grant amount will be transferred to the Coordinator after the signature of the Grant Agreement by both parties and in accordance with its terms. 

The Commission will establish the amount of the final payment to be made to the Coordinator on the basis of the calculation of the final grant amount. If the total of earlier payments is higher than the final grant amount, the Beneficiaries will be required to reimburse the amount paid in excess by the Commission through a recovery order. 

12. PROCEDURE FOR THE SUBMISSION OF APPLICATIONS 

12.1. How to apply 

Proposals must be submitted by the deadline indicated in section 3 via the Electronic Submission System. The list of available calls can be found at the calls for proposals page. 

Before submitting a proposal both the Applicant and Co-applicants must be registered via the Beneficiary Register and obtain the 9-digit Participant Identification Code (PIC) (one for each applicant). 

In submitting a proposal, the Applicant accepts the procedures and conditions as described in this Call for Proposals and in the documents to which it refers. 

No modification of the application is allowed once the deadline for submission has elapsed. However, if there is a need to clarify certain aspects or for the correction of clerical mistakes, the Commission may contact the Applicant for this purpose during the evaluation process10. 

Applicants will be informed in writing about the results of the evaluation process. 

12.2. Related documents: 

— Application form (Submission Form Part A and Part B) 

— Required annex – Forecast Budget Calculation and (if applicable) Audit Report11 

— Model Grant Agreement 

— Guide for applicants 

12.3. Applications for several projects 

The Applicant may submit more than one application under this call for proposals. 

The Applicant may be awarded more than one grant under this call for proposals. 

An organisation may participate as Applicant or Co-applicant in several applications. 

12.4. Several applications for the same project 

Only one application will be accepted and evaluated for any given project. In case there are several applications for the same project, the Applicant will be asked to clarify which application shall be evaluated. 

An action may receive only one grant from the EU budget. 

12.5. Contacts 

For questions on the online submission tools, please contact the IT helpdesk set-up for this purpose via the Participant Portal website. 

Non-IT related questions shall be sent to the following email address: HOME-ISF@ec.europa.eu. In order to ensure an efficient handling of any enquiry please indicate clearly the reference of this Call for Proposals. 

Questions will be answered as soon as possible. Questions received later than 7 calendar days before the deadline for submitting applications will not be answered. In the interest of equal treatment of applicants, the Commission cannot give a prior opinion on the eligibility of applicants or actions or on the outcome of the Call for Proposals before the official announcement of results. 

Applicants are advised to consult the Call's website regularly. The Commission will publish at this website any additional information relevant to the Call, such as responses to frequently asked questions (if appropriate) and the results of the selection procedure. 

 

13. PUBLICITY 

13.1. By the Beneficiaries 

Beneficiaries must clearly acknowledge the European Union’s contribution in all publications or in conjunction with activities for which the grant is used. Please refer to the Grant Agreement for more details. 

13.2. By the Commission 

All information relating to grants awarded in the course of a financial year shall be published on an internet site of the European Union institutions no later than the 30 June of the year following the financial year in which the grants were awarded. The Commission will publish the following information: 

- name and address of the beneficiary, 

- subject of the grant, 

- amount awarded. 

 

Upon a reasoned and duly substantiated request by the Beneficiary, the publication shall be waived if such disclosure risks threatening the rights and freedoms of individuals concerned as protected by the Charter of Fundamental Rights of the European Union or harm the commercial interests of the beneficiaries. 

 

14. DATA PROTECTION 

The reply to any call for proposals involves the recording and processing of personal data (such as name, address and CVs of individuals participating in the co-financed action). Such data will be processed pursuant to Regulation (EC) No 45/2001 of the European Parliament and of the Council 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. Unless indicated otherwise, the questions and any personal data requested in order to evaluate the application in accordance with the specifications of the Call for Proposal will be processed solely for that purpose by the Commission or third parties acting on behalf and under the responsibility of the Commission. Data subjects may be informed regarding further details of the processing operations, their rights and how they may be enforced by referring to the privacy statement published in the Legal Notice page of the Participant Portal. 

Applicants are invited to check the relevant privacy statement at regular intervals so as to be duly informed on possible updates that may occur by the deadline for submission of their proposals or afterwards. Beneficiaries assume the legal obligation to inform their staff on the relevant processing operations that are to be performed by the Research Executive Agency; in order to do so, they have to provide them with the privacy statements published by the Agency in the Participant Portal before transmitting their data to the Agency. Personal data may be registered in the Early Detection and Exclusion System (EDES) of the European Commission provided for in Articles 105a and 108 of the EU Financial Regulation according to the applicable provisions. 

15. MEANS OF REDRESS 

If, at any stage of the administrative treatment of grant applications, the persons or entities concerned consider that they have been affected by an instance of maladministration, they may, irrespective of any other means of redress, make a complaint to the European Ombudsman in accordance with Article 228(1) of the Treaty on the Functioning of the European Union and as provided by the Parliament Decision of 9 March 1994 on the regulations and general conditions governing the performance of the Ombudsman's duties published in Official Journal L 113 of 4 May 1994. 

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