CA/39/14 e 141350007

SUBJECT: HR Roadmap: update and plans

SUBMITTED BY: President of the European Patent Office

ADDRESSEES: Administrative Council (for decision)

SUMMARY

The HR Roadmap was presented in December 2011 to the Administrative Council. This document provides a summary of the achievements to date and an overview of the next steps.

CA/39/14

Orig.: en

Munich, 06.06.2014

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CA/39/14 e 141350007

TABLE OF CONTENTS

Subject Page

I.  STRATEGIC/OPERATIONAL 1 

II.  RECOMMENDATION 1 

III.  MAJORITY NEEDED 1 

IV.  CONTEXT 1 

A.  BACKGROUND AND OBJECTIVES 1 

B.  OBJECTIVES OF THE HR ROADMAP 2 

C.  ACHIEVEMENTS 2011-2014 5 

a)  Part Time Home Working (CA/99/11 – implemented on 01/01/2012) 5 

b)  Human Resources Transformation (31/07/2012) 5 c)  Reform of the Internal Appeals System (01/01/2013) 6 d)  Review of harassment procedure (01/01/2013) 6 e)  Code of Conduct (03/05/2013) 7 f)  Social Report (CA/55/13 – 07/06/2013) 7 g)  Strike regulations (Art. 30a and Cir. 347 - 01/07/2013) 7 h)  Well-Being (CA/56/13 and CA/D4/13, Circ. 22, Rule 13 amended -

Set 1 and 2 of measures implemented on 02/09/2013) 8 i)  Social Democracy (approved 27/03/2014 – implementation

01/07/2014) 8 j)  Salary adjustment method 9 k)  Policy management and continuous improvement of our

employment law legal framework 9 

D.  NEXT STEPS 9 

a)  Review and continuous improvements 9 b)  Well being 10 c)  Performance management, reward, incentives 11 d)  Attract and develop talent 13 e)  Sustainability and sound management of social security schemes 15 

E.  HR ROADMAP: TIMELINE AND OTHER CONSIDERATIONS 16 

V.  ALTERNATIVES 18 

VI.  FINANCIAL IMPLICATIONS 18 

VII.  LEGAL BASIS 18

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VIII.  DOCUMENTS CITED 18 

IX.  RECOMMENDATION FOR PUBLICATION 18 

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I. STRATEGIC/OPERATIONAL

Strategic.

II. RECOMMENDATION

1. The Administrative Council is requested to take note of the progress achieved in HR so far and approve the objectives and next steps set out in this this document.

III. MAJORITY NEEDED

2. Simple majority.

IV. CONTEXT

A. BACKGROUND AND OBJECTIVES

3. In December 2011, the Administrative Council unanimously supported the HR Roadmap (CA/110/11). This document, outlining the strategy of human resources management of the EPO for the period 2012-2015, set ambitious goals.

4. The projects deriving from the HR Roadmap have been designed and implemented to ensure a sustainable future for the EPO as a specific, self-financed and successful International Organisation. The reforms introduced have filled a legal vacuum, adapted and modernised our social framework and provided improvements for a more efficient management of the Office. Moreover, they have been conducted following benchmark and thorough impact analysis. This approach has been followed so to align with international standards and best practices at similar international level while fitting the specific needs of the Organisation. As required in the Service Regulations, they comply with the founding texts of the Organisation (European Patent Convention, PPI) and the general principles of law as applied by the Office and the ILOAT. They balance the need to ensure long term sustainability of the EPO model and the need to meet employees’ expectations in the context of a long-term career.

5. Strongly believing that reforms are better accepted when they are discussed, the Office is committed to continue inviting the Staff Representation to the discussion table and has increased the efforts to communicate and inform regularly the staff on the progress of the social agenda.. The structural changes introduced by the Social Democracy framework should give the opportunity to establish a renewed dialogue.

6. This report aims at providing a status quo of the HR roadmap achievements and of the projects which are still on-going (phase 1 of the HR roadmap, 2011-2015), while also presenting the next steps.

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B. OBJECTIVES OF THE HR ROADMAP

7. In line with the efficiency scenario approved by the Administrative Council in 2011 and confirmed through the findings of an independent study (PA study on support services 2012), the main Human Resources strategic objectives were defined as follows:

To strike the balance between the EPO needs (resources/competences) and employees expectations

To manage efficiently the life-cycle of the staff’s career and employment conditions

To align with the EPO’s overall strategic objectives

8. In order to achieve these ambitious objectives, the scope of HR roadmap is very broad and far-ranging. This complexity can best be represented visually as a construction articulated around four pillars which rely on four fundamental core values (see diagram 1 overleaf).

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Diagram 1 “The HR Roadmap: core values, objectives and workstreams”

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9. Four core values have been identified as necessary prerequisites to build up a solid Human Resources management:

Sustainability: enshrined in the efficiency scenario adopted by the EPO, Human Resources management should support the social, demographic and financial stability of the EPO in the long run

Transparency: all Human Resources information related to the EPO should be communicated internally and externally when needed in a comprehensive and objective manner in order also to set a common understanding

Accountability: a clear framework is set up to address the EPO expectations from international civil servants, in terms of specific conduct, responsibility of management and duties and rights of all EPO employees

Efficiency: the EPO is to improve its internal service orientated processes and tools as well as to deliver cost efficient and high quality services in a time-effective manner to its customers.

10. Based on these four fundamental core values, four pillars have been defined as improvement work-streams to conduct the necessary HR changes in order to achieve the HR strategic objectives:

Promote a good place to work through continuous improvement of working conditions

Optimise performance management, rewards and incentives

Attract, manage and develop talent

Reinforce social dialogue.

11. This up-dated version of the Human Resources roadmap intends to develop further the on-going efforts to modernise and adapt the human resources management, in order to support the EPO in achieving its missions and goals. From the initial 13 project comprised in the HR roadmap 2011-2015, 9 projects have been already fully completed and the remaining on-going four are planned to be completed before the end of 2015.These are detailed below in chronological order.

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C. ACHIEVEMENTS 2011-2014

a) Part Time Home Working (CA/99/11 – implemented on 01/01/2012)

12. Part Time Home Working, which aims at improving the working conditions of the employees, has been successfully implemented. As it implied a major change in the way of working together, the preparation of the project foresaw the provision of equipment infrastructure and comprehensive information and training for staff and their line managers. As of today, over 900 employees are participating in the PTHW and positive impacts have already been observed:

In productivity: an increase in the productivity equal to 1.7 products per year for examiners on PTHW (representing an increase of 2.1%)

In capacity: with an increase in paid examiner capacity amounting to an average of 2.3 products per examiner on PTHW leading to an increase in paid capacity equivalent to 4.8 FTE per year

In sick-leave reduction amongst PTHW participants with 15% reduction on average.

Moreover, in terms of employees’ satisfaction, 96% of PTHW participants report that the scheme has contributed favourably to their personal work/life balance. PTHW offers staff the opportunity to enjoy more flexibility and autonomy in organising their working lives. The chance to strike a healthier work-life balance comes to the mutual benefit of both staff and the Office.

b) Human Resources Transformation (31/07/2012)

13. Putting effective and efficient Human Resources services in place to support the Office in its operational efforts is the essential component of successfully managing its future, and is the driver of the Human Resources roadmap.

14. As part of the strategic objective to increase transparency and efficiency in Human Resources, a major restructuring of Human Resources organisation and structure was initiated in 2012 to strengthen service culture and customer orientation. One of the main expected outcomes was the creation of dedicated interlocutors to act as a first point of contact for any human resources query by staff (9,000 queries submitted to HR interlocutors in one year). Furthermore, the responsibilities of the Human Resources partners have been more clearly defined to serve the business in a more focused way. Placed in the same directorate, interlocutors and Human

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Resources Partners constitute the Human Resources customer interface, in order to support staff and management efficiently.

The liaison with expert services, working in back office, has been improved and formalised in order to ensure timeliness, harmonisation and quality of the service delivered.

15. Furthermore, the automation and possibility to submit online queries have been developed (26,000 HR requests, thereof 50% HR e-forms).

16. Communication on rules related to the conditions of employment has been improved through dedicated communication plans and the renewal of the intranet page dedicated to Human Resources area.

c) Reform of the Internal Appeals System (01/01/2013)

17. The reform of the settlement of disputes and internal appeals system (CA/D8/12, 9/12 and 10/12) and the introduction of the Management Review process, as part of the improvement of the social dialogue objective, is now fully implemented. It gives the opportunity to review the initial decision and prevent further litigation. It offers more possibilities to improve the dialogue and find amicable solutions. The first statistics concerning the Management Review process seem to indicate that 50% of the cases did not proceed to appeals. It is particularly effective concerning the appeals filed against individual decisions and complying with the internal appeals framework. These appeals represent half of the internal appeals backlog.

d) Review of harassment procedure (01/01/2013)

18. The harassment procedure (Cir. 341) has also been reviewed to provide a workable framework, bring greater clarity of workflows and more timely outcomes. It is based on a two-fold approach. On the one hand, a strong focus has been put on prevention through awareness campaigns and through the appointment of at least two confidential counsellors per place of employment to encourage amicable settlement and to restore and maintain professional relationship among staff members. On the other hand, if a formal complaint is introduced, the new legal framework regarding harassment complaints supported by a regulated fact finding process ensure a confidential and timely outcome, with respect of due process of law. In 2013, 63 were cases subject to informal conflict resolution. By the end of 2013, about 50% had been closed, 50% were still pending, and none of these was referred to the Investigation Unit for a formal procedure.

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In 2013, 22 requests for the formal harassment procedure had been launched. Of these 17 were referred to the Investigative Unit for further processing. Only one of the 22 has been found to be harassment.

e) Code of Conduct (03/05/2013)

19. A Code of Conduct has been introduced. It is to be considered as a repository of our professional rights and obligations. It defines core values such as respect for the individual, integrity and accountability, compliance with the rules of law to which any staff member in the EPO shall adhere to. It provides guidance on the behaviour expected from international civil servants, as well as examples of concrete cases they can face in the scope of their duties. The Code of Conduct provides a vision for the Office and its value will serve as references to define the core competencies of EPO´s employees within the new career framework.

f) Social Report (CA/55/13 – 07/06/2013)

20. In 2013 the Office published a comprehensive Social Report for the first time ever, which also contributes in increased transparency and efficiency. This report provides a comprehensive overview of data on employment and professional development, remuneration, social security scheme, working conditions in the Office, health, safety and welfare, social dialogue and conflict resolution. The report has been unanimously welcomed and has become a reference document. It is now published on a yearly basis.

g) Strike regulations (Art. 30a and Cir. 347 - 01/07/2013)

21. In the scope of the freedom of association acknowledged in the Service Regulations, the Office has filled a long standing legal vacuum and has specified the conditions under which the right to strike can be exercised, in order to better balance the interests of the service with the rights of employees. Therefore the scope and the duration of such action have been clarified, while formal requirements such as formal consent of a significant part of the staff through a secret ballot, prior notice and cooling down period before starting a strike have been introduced. Most of these requirements are not new, but are principles common to various legal frameworks ruling strikes including social agreements. Employees are obliged to inform the Office about their participation in a strike and the resulting deduction in salary has also been formalised. Freedom to participate to a strike action as well as the possibility for the employer to requisition a limited number of employees whose presence is required for ensuring service continuity have been formalised in the regulations.

22. Under the new legal framework, several days of strike took place in October 2013 and in March-April 2014.

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h) Well-Being (CA/56/13 and CA/D4/13, Circ. 22, Rule 13 amended - Set 1 and 2 of measures implemented on 02/09/2013)

23. Improving working conditions and well-being was one of the main priorities indicated in the HR roadmap. Besides the goal of bringing the EPO to be among the best in class with respect to a healthy environment, this project aims at:

Reducing the short- and long-term absences

Improving sickness management

Reviewing the invalidity scheme

24. An awareness campaign and better follow-up of sickness statistics started in 2012. In 2013 two sets of measures have been introduced. They provide for better support and involvement of management, staff and occupational health services in the management of absences due to sickness. The measures also aim to improve the communication between the parties involved, to help prevent difficult situations and, if needed, to offer verification of the sick leave with targeted controls. This comprehensive approach combining prevention and monitoring has already led to a decrease of sick leave with an average of 11.5 days by the end of 2013 (from 14.3 days in 2011). The latest figures available continue to show a decline (11.2 days currently). This is an indication that the balanced approach proposed by the Office and promoted through best practices bears fruits.

25. The second set of measures (“reinforce the cooperation between line managers and Occupational health and Safety”) has been fully implemented in June 2014. The third set of measures (the reform of the invalidity scheme) is still on-going (more details in section D of the document).

i) Social Democracy (approved 27/03/2014 – implementation 01/07/2014)

26. To ensure a fruitful social dialogue at the EPO, a consistent and representative social partner who exercises its full responsibility is needed. The Social Democracy project concerns the simple implementation of basic principles such as: direct election of the staff representatives by the employees through harmonised and transparent rules, representation at central and local level, fair representation and proportion of grades and sites.

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27. The main forum of discussions and formal consultation becomes the General Consultative Committee (GCC). The same elected staff representatives sitting in this Committee will be involved in the sub groups of the GCC (eg sub groups relating to remunerations, health insurance, training…) where technical discussions take place. This will ensure continuity between informal and formal steps of the social dialogue and a better preparation of the consultation phase.

28. Following the implementation of the reform, staff committee elections are to be held on the 18th of June. The GCC and the new elected staff representatives will enter in function on 1st of July. After a transitional period, the new framework will be fully operational by 30th of September.

j) Salary adjustment method

29. The new salary adjustment method which is submitted to the approval of the Administrative Council in CA/23/14 guarantees a reasonable adaption of salaries respecting the maintenance of purchasing parity and parallelism with the evolution of salaries of national civil servants, taking into account the economic realities of the member states. Despite the self-financed situation of the EPO, this has been implemented through the introduction of a crisis clause in the new salary method.

k) Policy management and continuous improvement of our employment law legal framework

30. A large multinational organisation such as the EPO calls for a systematic and consistent application of rules. Ensuring the consistency and clarity overtime of the legal framework will lead to an increased feeling of fairness.

31. The efficiency and accuracy of our legal framework and policies needs to be regularly assessed and realigned with the overall Office’s overall strategy. Initial work is already ongoing including the review of home leave regulations, of the framework for child care allowances, of data protection regulations, and duty travel policy.

D. NEXT STEPS

a) Review and continuous improvements

32. While completing the implementation of the HR roadmap, there is a need to review and improve reforms already put in place to enable the Office to reach the level of excellence in HR management. Therefore, all reforms are subject to close monitoring and periodic reviews. Lessons learned, statistic monitoring and feedback received from staff members and services in charge of the implementation may lead to further adaptation of the framework and correctives actions when needed.

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33. The investigation guidelines will be reviewed before end of 2014.The Office will also propose modifications in order to improve the management of internal appeals and the timeliness of the procedures. This includes the streamlining of the internal processes, the strengthening of prevention mechanisms (amicable settlements, management review); a continuous cooperation and dialogue with the ILOAT, as well as a reflection on the abuses of procedure.

34. The EPO will continue striving to improve the quality of the service, increasing the transparency of the regulations and adjusting identified issues (e.g. rules with regard to reckonable experience shall be addressed through the new career system). Based on external and internal audits findings as well as external studies, reflections are on-going to determine the level of internal and external resources needed in HR (after the outsourcing of pension files management, processes linked to salaries are to be reviewed in 2014).

35. PTHW will need to be consolidated and driven forward in the coming years. To that respect, technical improvements to enable more efficient home-working will need be developed. The impact of PTHW on office space has also to be assessed in order to optimise the working space in the EPO.

36. Finally, based on current EPO’s experience and best practices in other International Organisations, the productivity requested in the PTHW agreement has to be reviewed to improve the gains of efficiency for the Office.

b) Well being

(i) Invalidity

37. As part of the well-being project (third set of measure), the reform of the invalidity scheme is still to be implemented to align the EPO regulations with the international organisations and member states.

38. The needs for a reform stem from the following elements of analysis:

20-28 new cases per year (2005-2012)

In 75% of cases no alternative duties are considered

No re-examination of cases takes place in practice,

Cost of invalidity is in the range of 15 million Euro per year

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EPO’s rules on invalidity should be aligned with the other international organisations and member states.

39. The project foresees the introduction of partial invalidity and temporary invalidity as well as a regular review of the invalid’s situation (December 2014). The aim of this reform is to prevent invalidity situations, favour the return to work (part time) and maintain the link with employment as long as possible.

(ii) Adaptation of the occupational health policy of the Office

Following the implementation of the three sets of well-being measures, the occupational health policy of the Office will also need to be adjusted.

This will include proposals on:

The respective roles and responsibilities of the Medical Advisor, Occupational Health and management in the well-being of the staff

A review of the roles, responsibilities and functioning of the COHSEC and LOHSEC

The possibility to offer an adequate accessibility to external medical services through the creation of a network of external providers while ensuring price containment.

c) Performance management, reward, incentives

(i) Career

40. The creation of a new career system in the EPO is one of the HR roadmap’s major projects. Based on various internal and external audits and studies, staff satisfaction surveys, the new career management mainly foresees:

Introduction of an Office-wide competencies framework with harmonised job profiles and proficiency levels as a reference for recruitment, career advancement, performance management, professional development

Adjusted grading and step advancement structure to better reflect competence, performance and level of responsibility

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Revised promotion and appointment rules with stronger focus on competences and performance rather than time in post

Revised salary scales and creation of a single spine model in order to reflect the new job classification, introduce more flexibility and a better identification of the levels of responsibility.

Diversify the incentives schemes in order to take into account the various levels of contributions at individual and collective level.

The new career system should result in a closer link between the career opportunities and the fair contribution to the strategy and achievements of the Office. A specific budgetary monitoring of the rewards and incentives components of the career system will be implemented to ensure a balance between staff expectations and demographic, social and financial sustainability.

(ii) Performance management

41. The new career system project includes a reflection on career paths, technical and transversal careers and on maintaining motivation in the context of long-term employment. As part of the new career system, performance management and incentives are to be optimised during the second phase of the HR roadmap implementation. The performance management and promotion process will be redesigned to encourage more performance and competence-based decisions, have stronger involvement of managers and support continuous improvement.

42. Effective performance management is one of the conditions to ensure long term success of the EPO, reward fair contribution to the Office’s achievements and missions, as well as maintain staff’s motivation.

43. Based on objective settings Office-wide, yearly reports and increased timeliness (already introduced in 2014), the reviewed performance assessment exercise will better contribute to professional development and a more individualised career management.

44. Strongly linked to the new career system, the new framework for performance management is planned to be presented to the Administrative Council in December 2014.

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d) Attract and develop talent

45. Employees constitute a key asset for the EPO. Therefore talent management will be one of the cornerstones of the upcoming initiatives within the HR roadmap. The future talent management program will address each step of the career life cycle in order to:

Identify and attract the best people (workforce planning, recruiting strategy, promoting diversity)

Continuously develop employees’ skills (training and development)

Offer various and attractive career opportunities (mobility policy and career paths) and communicate them to the staff

(i) Strategic workforce planning

46. The need for a strategic and systematic workforce planning was already identified in 2011 in the HR roadmap and still needs to be implemented. The strategic workforce planning includes:

identifying the business needs (at least at mid-term, if possible for the next 10 years) and their consequences in terms of staffing and competences needed

Conducting a gap analysis between the existing situation and the target (staffing and competences)defined at the highest level of the management

Analysing the foreseen evolution of the ages pyramid over the period concerned and integrating these elements in the gap analysis.

Defining the transition plan and the staffing adaptations needed (headcount, training, talent acquisition….)

47. Efforts have been realised to recruit more than 500 examiners over the last 5 years and bring in more than 200 new examiners in 2014. These examiner posts will be filled without increasing our staff complement, in order to focus on core business and following increases of efficiency in the support services, as prescribed in the efficiency/quality scenario adopted in 2011.

48. As a modern organisation, which aims at having a leading and influential role in the international environment, the EPO needs to improve its attractiveness to recruit the best employees in all our fields of expertise. Based on a systematic strategic workforce planning, proactive recruitment policies will be developed:

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Diversify the recruitment channels by building long-term relationships with universities and technical schools and offering possibilities of secondment and career path to national patent experts

Improving candidate-selection methods. On the basis of the competencies framework and of identified business needs the recruitment department will develop methods, in cooperation with business areas, to better detect among the candidates those who present the higher employment guarantees.

More particularly, following the design of a new framework for leadership competencies developed through the new career system, a specific focus will be given to the detection, selection and training of managers.

(ii) Promoting diversity

49. In its comprehensive HR transformation process to modernise the EPO and enable it to be a HR model within the international organisations system, the Office shall become an equal opportunities employer committed to valuing everyone as an individual without discrimination and in a nationality and gender-balanced approach. The principles and policies to acknowledge the values of equality of treatment and diversity, as well as to encourage the recruitment, retention and professional development of a diverse workforce need to be set out to ensure diversity in the EPO.

(iii) Training and development

50. To be able to operate globally, adapt to the continuously changing international patent environment, the EPO has to rely on a well-structured training plan, directly oriented to the achievement of its missions and goals. Therefore, the training policy will be adapted to serve comprehensively with the EPO strategic missions and objectives stemming from its constitutive texts and the strategic roadmaps. It will be strongly linked to and the new career system and the competency framework.

(iv) Mobility policy and career paths

51. Mobility and career paths are a key component of a talent management strategy. As part of an individual’s career path, they need to be considered in the comprehensive objective of developing talent management. As part of the new career system, the EPO will describe the various career opportunities offered to staff, as well as the conditions to realise them.

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52. Incoming and outgoing secondments are a valuable way of providing staff with development opportunities and bring mutual win win for the Office and staff members. The EPO will therefore adapt its secondment policy as well as the unpaid leave possibility shall be reviewed to enable more mobility and flexibility while better identifying relevant and attractive positions in the interest of both the Office and the individual.

e) Sustainability and sound management of social security schemes

(i) Pensions

53. To ensure the long-term sustainability of the EPO model, a unified pension scheme is envisaged on which the discussions started already in 2011. At that time internal discussions have started around a global package that could unify the current two pension schemes. The discussions were led around technical set of measures and the introduction of an internal tax. Based on a defined benefits system better accepted by the staff, some technical measures have been identified: postponement of retirement age, possibility to work longer in the interests of the service, progressive decrease of accrual rate.

54. In parallel, the Office has to consider the outcome various litigations related to the introduction of the new pension scheme. Further efforts to solve the long-term liabilities linked to the partial compensation may have to be discussed internally and with the Member States.

(ii) Health insurance management

55. Due to the increasing costs, mainly driven by the demographic development of the EPO population and by medical inflation, the EPO moved from a "pay-as-you-go" system to a funded system in 2011 (cf. CA/D 7/10). Thus, the contribution rate is now calculated by spreading costs of life-long healthcare over time, allowing for money to be put aside today to avoid higher burdens on the budget in the future. In this context, the ceiling for staff contributions of 2.4% of basic salaries has been abolished.

Moreover, a general tender on health insurance components (administration of claims, insurance, advice in policy and medical decisions, monitoring of expenses, support in prevention and anti-fraud policy) is being prepared to ensure competition between the major players in health insurance, improve the level of services provided to the EPO at the best price available.

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E. HR ROADMAP: TIMELINE AND OTHER CONSIDERATIONS

56. The HR roadmap 2011-2015 aims at addressing long standing vacuum and immediate urgencies of the social agenda, as defined jointly with the staff representation. The reforms undertaken have set up the fundaments of a sound Human Resources management. The next steps should promote the EPO as a first class employer bearing in mind the need to ensure social, financial and demographic sustainability of the Organisation.

57. The first phase of the HR roadmap was focused on setting the basis of a sound and modern Human Resources management to preserve the EPO specific model and the attractive package and working conditions enjoyed by its employees. In parallel, the results of the EPO, its international reputation and influence have never been so high. A large part of this success and achievements have been shared with the staff: collective reward, application of the salary adjustment procedure despite the global economic crisis: collective reward, New Main building in The Hague, renovations of other buildings, transfers to stabilise the social security reserve funds..

58. It remains of paramount importance to continue to improve all the channels of the social dialogue towards staff representation, management and staff.

59. The HR roadmap is to be implemented in three phases (see diagram 2 overleaf):

The first phase, fixing the basis of a sound and efficient human resources management, has already been implemented

The second phase corresponds to a stabilisation phase. its goal is to settle the Human Resources architecture of the EPO with a reformed career system based on competence and performance optimisation, and the stabilisation of our social security framework

The last phase (as from 2016) will enable the Office to achieve a level of excellence and professionalism to bring it to the top international organisations

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Diagram 2 “The HR Roadmap: Timeplan”

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V. ALTERNATIVES

60. None

VI. FINANCIAL IMPLICATIONS

61. A general control of the costs and social expenses is expected through increased efficiency.

VII. LEGAL BASIS

62. Art 10 EPC

VIII. DOCUMENTS CITED

63. CA/110/11

IX. RECOMMENDATION FOR PUBLICATION

64. Yes.