Report on the annual accounts of the Clean Sky Joint Undertaking for the financial year 2013, together with the Joint Undertaking’s replies 2014/C 452/03
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Address https://gelex.eu/eli/EU/notice/oj/C/2014/452/03@2014-10-21/en
Paragraph Page Introduction 1-4 18 Information in support of the statement of assurance 5 18 Statement of assurance 6-13 18 Opinion on the reliability of the accounts 11 19 Opinion on the legality and regularity of the transactions underlying the accounts 12 19 Comments on budgetary and financial management 14-16 19 Implementation of the budget 14-16 19 Comments on key controls of the Joint Undertaking’s supervisory and control systems 17-20 20 Other matters 21-32 20 Legal framework 21 20 Internal audit function and the Commission’s Internal Audit Service 22-26 21 Monitoring and reporting of research results 27 21 Conflicts of interest 28-29 21 The Commission's Second Interim Evaluation 30-31 21 Follow-up of previous observations 32 22 The Clean Sky Joint Undertaking, located in Brussels, was set up in December 2007 for a period of ten years and started working autonomously on 16 November 2009. The objective of the Clean Sky Joint Undertaking is to accelerate the development, validation and demonstration of clean air-transport technologies in the EU for earliest possible deployment. The research activities coordinated by the Joint Undertaking are divided into six technological areas or Integrated Technology Demonstrators (ITDs). The founding members of the Joint Undertaking are the European Union, represented by the Commission, and industrial partners as the leaders of the ITDs, together with the associate members of the ITDs. The maximum EU contribution to the Clean Sky Joint Undertaking, to cover running costs and research activities, is 800 million euro to be paid from the budget of the Seventh Framework Programme. Other members of the Joint Undertaking are to contribute resources at least equal to the EU contribution, including in-kind contributions. The audit approach taken by the Court comprises analytical audit procedures, testing of transactions at the level of the Joint Undertaking and an assessment of key controls of the supervisory and control systems. This is supplemented by evidence provided by the work of other auditors (where relevant) and an analysis of management representations. Pursuant to the provisions of Article 287 of the Treaty on the Functioning of the European Union (TFEU), the Court has audited:
(a) the annual accounts of the Clean Sky Joint Undertaking, which comprise the financial statements and the reports on the implementation of the budget for the financial year ended 31 December 2013, and
(b) the legality and regularity of the transactions underlying those accounts.
In accordance with Articles 33 and 43 of Regulation (EC, Euratom) No 2343/2002, the management is responsible for the preparation and fair presentation of the annual accounts of the Joint Undertaking and the legality and regularity of the underlying transactions:
(a) The management’s responsibilities in respect of the Joint Undertaking's annual accounts include designing, implementing and maintaining an internal control system relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error, selecting and applying appropriate accounting policies on the basis of the accounting rules adopted by the Commission’s accounting officer, and making accounting estimates that are reasonable in the circumstances. The Director approves the annual accounts of the Joint Undertaking after its accounting officer has prepared them on the basis of all available information and established a note to accompany the accounts in which he declares, inter alia, that he has reasonable assurance that they present a true and fair view of the financial position of the Joint Undertaking in all material respects.
(b) The management’s responsibilities in respect of the legality and regularity of the underlying transactions and compliance with the principle of sound financial management consist of designing, implementing and maintaining an effective and efficient internal control system comprising adequate supervision and appropriate measures to prevent irregularities and fraud and, if necessary, legal proceedings to recover funds wrongly paid or used.
The Court’s responsibility is, on the basis of its audit, to provide the European Parliament and the Council with a statement of assurance as to the reliability of the annual accounts and the legality and regularity of the underlying transactions. The Court conducts its audit in accordance with the IFAC International Standards on Auditing and Codes of Ethics and the INTOSAI International Standards of Supreme Audit Institutions. These standards require the Court to plan and perform the audit to obtain reasonable assurance as to whether the annual accounts of the Joint Undertaking are free from material misstatement and the underlying transactions are legal and regular. The audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the accounts and the legality and regularity of the underlying transactions. The procedures selected depend on the auditor’s judgement, which is based on an assessment of the risks of material misstatement of the accounts and material non-compliance by the underlying transactions with the requirements in the legal framework of the European Union, whether due to fraud or error. In assessing these risks, the auditor considers any internal controls relevant to the preparation and fair presentation of the accounts, as well as the supervisory and control systems that are implemented to ensure the legality and regularity of underlying transactions, and designs audit procedures that are appropriate in the circumstances. The audit also entails evaluating the appropriateness of accounting policies, the reasonableness of accounting estimates and the overall presentation of the accounts. The Court considers that the audit evidence obtained is sufficient and appropriate to provide a basis for its statement of assurance. In the Court’s opinion, the Joint Undertaking’s annual accounts present fairly, in all material respects, its financial position as at 31 December 2013, and the results of its operations and its cash flows for the year then ended in accordance with the provisions of its financial rules and the rules adopted by the Commission’s accounting officer. In the Court’s opinion, the transactions underlying the annual accounts for the year ended 31 December 2013 are, in all material respects, legal and regular. The comments which follow do not call the Court’s opinion into question. The 2013 final amending budget included commitment appropriations of 250,4 million euro and payment appropriations of 158,2 million euro. The utilisation rate for commitment appropriations was 90,6 %, while the rate for payment appropriations was 87,7 %. The lower rate for payment appropriations, although better than in 2012 (75 %), still reflects delays in the implementation of the budget. These result mainly from delays in the implementation of activities and the length of time that elapses between the publication of calls for proposals and the signature of grant agreements. The maximum European Union contribution to the Clean Sky Joint Undertaking covering running costs and research activities is 800 million euro. In accordance with the Council Regulation setting up the Joint Undertaking, the other members of the Joint Undertaking contribute resources of at least 600 million euro, including their contributions to cover running costs. At the time of the audit (April 2014), the European Union contribution committed amounted to 713 million euro, while resources from the other members amounted to 409 million euro. During 2013 the Joint Undertaking continued to improve its management, administrative, financial and accounting procedures. The Grant management tool (GMT tool) was completed by introducing the adjustments to cost claims. Full information related to the ex-post audit exercises has still to be integrated in the system. In addition, the accounting officer tested the functioning of the GMT tool and identified several weaknesses, in particular with regard to the function used to enter comments made by the financial and verifying officers. This function is essential to the validation procedure and the Joint Undertaking needs to follow up on this weakness. With regard to the ex-ante control on activities performed by Clean Sky members, in one case (contrary to the provisions of the Joint Undertaking's financial rules and its manual of procedures) the same staff member performed the procedure for validating the commitment in the capacity of both verifying agent and authorising officer; there was one payment in whose case the verifying agent was also the authorising officer; in another case the technical assessment report (an essential part of the operational verification procedure) was not available in the GMT tool. The following weaknesses were noted in respect of the ex-ante control of cost claims submitted by Clean Sky partners:
the checklists used for the ex-ante control of cost claims were not always complete;
in one case the financial and operational verification tasks and authorisation were performed by the same staff member, which is contrary to the provisions of the financial procedures manual and the principle of segregation of duties; in three other cases, the tasks of the financial and authorisation officers were performed by the same staff member;
in another case the grant agreement with the partner was signed five months after the activities had started in the absence of the requisite declaration justifying the need to begin the activities prior to signature of the grant agreement;
the Joint Undertaking’s partners are often late in submitting cost claims. At 31 December 2013, at least 56 out of 163 cost claims had not been submitted to the Joint Undertaking on time. In 15 cases, the delay exceeded one year.
The new Financial Regulation applicable to the general budget of the Union was adopted on 25 October 2012 and took effect on 1 January 2013. However, the model financial regulation for public-private partnership bodies referred to in Article 209 of Regulation (EU, Euratom) No 966/2012 did not enter into force until 8 February 2014. The financial rules of the Joint Undertaking were amended on 3 July 2014 to reflect these changes. In 2013 the internal auditor started an audit, in cooperation with an external audit firm, of the Joint Undertaking's business processes related to Coordination and monitoring of the ITD activities and Management of the Partners’ activities. The Final Audit Report was not available at the time of the Court’s audit. On 28 March 2013 the Joint Undertaking adopted an action plan in response to the observations raised by the Commission's Internal Audit Service with regard to Grant Management — Annual Planning. At the time of the audit, the implementation of these actions was not fully completed. On 14 March 2014, the Commission’s Internal Audit Service presented the results of the audit concerning the adequacy and effectiveness of the internal control system with regard to Grant Management and its financial implementation. The conclusion following the audit was that the internal control system in place gave reasonable assurance as to the achievement of the business objectives set by the Joint Undertaking for Grant Management and its financial implementation, except in the case of four important observations and two very important observations. Additionally, the IAS performed an IT risk assessment of the common IT infrastructure that the Clean Sky Joint Undertaking shares with the FCH, IMI, Eniac and ARTEMIS Joint Undertakings. The mission charter of the Commission’s Internal Audit Service was adopted by the Governing Board on 31 March 2011. However, the Joint Undertaking’s financial rules have not yet been amended to include the provisions of the framework Regulation referring to the powers of the Commission’s internal auditor. The Seventh Framework Programme (FP7) Decision establishes a monitoring and reporting system covering the protection, dissemination and transfer of research results. The Joint Undertaking has developed procedures but this monitoring does not fully meet the provisions of the Decision, in particular as regards the dissemination of the research results and their integration in the Commission system. On 13 December 2013 the Joint Undertaking adopted the Code of Conduct for the prevention and mitigation of conflicts of interest applicable to private members of the Governing Board. The adoption of the corresponding Code of Conduct for the prevention and mitigation of conflicts of interest applicable to the staff members of the Joint Undertaking and other actors (including experts) was still pending at the time of the audit. The Joint Undertaking has not yet developed a database to record the conflicts of interest, incompatibilities, declarations and related documents. The Commission’s Second Interim Evaluation was carried out between early March and the end of October 2013 and assessed the Joint Undertaking in terms of effectiveness, efficiency and research quality. The report contains several recommendations regarding the inadequate number of technical staff to carry out its activities, the need for harmonisation of progress activity reports and technical evaluation reports across the Joint Undertaking’s ITDs members and the need for improvements in the procedures for selecting subcontractors. The Joint Undertaking should also better document the course of Grant Agreements, so as to improve overall compliance and performance. The Joint Undertaking’s business continuity plan was adopted by the Executive Director on 29 November 2013. It covers disaster recovery, immediate steps to be taken thereafter, recovery arrangements and the maintenance of activities. It is due to be updated by the end of 2014. This Report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, Member of the Court of Auditors, in Luxembourg at its meeting of 21 October 2014. For the Court of Auditors Vítor Manuel da Silva Caldeira President
ANNEX
(1) The Clean Sky Joint Undertaking shall contribute to the implementation of the Seventh Framework Programme and in particular Theme 7, Transport (including aeronautics) of the Specific Programme Cooperation; (2) accelerating in the EU the development, validation and demonstration of clean Air Transport Technologies for earliest possible deployment; (3) ensuring coherent implementation of European research efforts aiming at environmental improvements in the field of Air Transport; (4) creating a radically innovative Air Transport System based on the integration of advanced technologies and full scale demonstrators (ITDs), with the target of reducing the environmental impact of air transport through significant reduction of noise and gaseous emissions, and improvement of the fuel economy of aircrafts; (5) accelerating the generation of new knowledge, innovation and the uptake of research proving the relevant technologies and fully integrated system of systems, in the appropriate operational environment, leading to strengthened industrial competitiveness. Anx. annex. Source: Information supplied by the Clean Sky Joint Undertaking. Areas of Union competence deriving from the Treaty (Articles 187 and 188 of the Treaty on the Functioning of the European Union) Decision No 1982/2006/EC of the European Parliament and of the Council of 18 December 2006 concerning the Seventh Framework Programme provides for a Community contribution to the establishment of long-term public-private partnerships in the form of Joint Technology Initiatives which could be implemented through Joint Undertakings within the meaning of Article 187 of the Treaty. Council Regulation (EC) No 71/2008 of 20 December 2007 setting up the Clean Sky Joint Undertaking (OJ L 30, 4.2.2008, p. 1). Competences of the Joint Undertaking (Council Regulation (EC) No 71/2008) Objectives Governance The JU’s governing body is the Governing Board. The Executive Team is led by an Executive Director. Industry is represented through various means, such as ITD steering committees and the National States Representative Group. Resources available to the Joint Undertaking in 2013 Budget 306 043 097 euro Staff at 31 December 2013 24 posts provided for in the establishment plan (18 temporary staff and six contract staff), of which 23 posts were occupied; these were assigned to operational activities (17) and mixed tasks (six). Activities and services provided in 2013 See the Clean Sky Joint Undertaking’s annual activity report 2013 at www.cleansky.eu
ANNEX Clean Sky Joint Undertaking (Brussels) Competences and activities
Source: Information supplied by the Clean Sky Joint Undertaking. Areas of Union competence deriving from the Treaty (Articles 187 and 188 of the Treaty on the Functioning of the European Union) Decision No 1982/2006/EC of the European Parliament and of the Council of 18 December 2006 concerning the Seventh Framework Programme provides for a Community contribution to the establishment of long-term public-private partnerships in the form of Joint Technology Initiatives which could be implemented through Joint Undertakings within the meaning of Article 187 of the Treaty. Council Regulation (EC) No 71/2008 of 20 December 2007 setting up the Clean Sky Joint Undertaking (OJ L 30, 4.2.2008, p. 1). Competences of the Joint Undertaking (Council Regulation (EC) No 71/2008) Objectives Governance The JU’s governing body is the Governing Board. The Executive Team is led by an Executive Director. Industry is represented through various means, such as ITD steering committees and the National States Representative Group. Resources available to the Joint Undertaking in 2013 Budget 306 043 097 euro Staff at 31 December 2013 24 posts provided for in the establishment plan (18 temporary staff and six contract staff), of which 23 posts were occupied; these were assigned to operational activities (17) and mixed tasks (six). Activities and services provided in 2013 See the Clean Sky Joint Undertaking’s annual activity report 2013 at www.cleansky.eu (1) The Clean Sky Joint Undertaking shall contribute to the implementation of the Seventh Framework Programme and in particular Theme 7, Transport (including aeronautics) of the Specific Programme Cooperation; (2) accelerating in the EU the development, validation and demonstration of clean Air Transport Technologies for earliest possible deployment; (3) ensuring coherent implementation of European research efforts aiming at environmental improvements in the field of Air Transport; (4) creating a radically innovative Air Transport System based on the integration of advanced technologies and full scale demonstrators (ITDs), with the target of reducing the environmental impact of air transport through significant reduction of noise and gaseous emissions, and improvement of the fuel economy of aircrafts; (5) accelerating the generation of new knowledge, innovation and the uptake of research proving the relevant technologies and fully integrated system of systems, in the appropriate operational environment, leading to strengthened industrial competitiveness.
The Clean Sky Joint Undertaking shall contribute to the implementation of the Seventh Framework Programme and in particular Theme 7, Transport (including aeronautics) of the Specific Programme Cooperation;
accelerating in the EU the development, validation and demonstration of clean Air Transport Technologies for earliest possible deployment;
ensuring coherent implementation of European research efforts aiming at environmental improvements in the field of Air Transport;
creating a radically innovative Air Transport System based on the integration of advanced technologies and full scale demonstrators (ITDs), with the target of reducing the environmental impact of air transport through significant reduction of noise and gaseous emissions, and improvement of the fuel economy of aircrafts;
accelerating the generation of new knowledge, innovation and the uptake of research proving the relevant technologies and fully integrated system of systems, in the appropriate operational environment, leading to strengthened industrial competitiveness.
THE JOINT UNDERTAKING’S REPLIES
The JU has improved its budget implementation in 2013. The remaining delays, while partly attributable to the delay in GAP signatures are also related to the actual re-orientation of some of the operational activities as the research work continues. When certain milestones are not achieved on time, this can be due to normal contingencies and setbacks of some research activities, for which more time and effort is needed within the ITDs but after the 2012 reporting period. This is part of the challenge managed by the JU for such a large-scale and complex programme. The European Union committed amount will always be higher than the private members’ resources as the latter only takes into account the validated cash contribution — while the (EU) commitment covers some multiannual grant agreements not yet fully implemented. It can also be noted, that the European Commission had the obligation to commit the full programme value before the end of 2013 due to it being the last year of the FP7 programme. The JU is making the commitment with the private members once the technical activity foreseen for the coming period(s), is agreed by the JU through the grant agreements. The details of this activity for the last years of the programme will only be finalized in 2015 and therefore is not yet committed or validated. A specific function for the ex post audit exercise was developed in GMT in April 2014. This function will be further enhanced to allow the integration of ex post audit data in the system this year. Following the developments already made during the first half of 2014, a new release of GMT will be implemented by end of this year and will fix several of the weaknesses identified. This will include, in particular, the in-depth review of the function allowing the financial and project officers to provide comments within the validation workflow. With respect to the ex-ante control of the validated commitment, the two functions (Financial Verifier Agent and Authorising Officer) were taken exceptionally under the responsibility of the Head of Administration and Finance which was acting as a back-up of the Authoring Officer during the annual leave of the Executive Director. As CS is a small team, during the annual leave of many actors, the absence of segregation of duties can happen in exceptional cases. In this respect and in order to ensure the sound functioning of the control system, the JU has updated the financial back-up system by introducing new actors to perform the roles of financial verifier and authorising officer by delegation and is now closely monitoring the continuity of operations during absences. It should be however noted, that even in these cases, the initiation and verification/authorisation functions are kept separate. The single case relating to the absence of the assessment report has since been rectified in the GMT tool. The Joint Undertaking takes note of the weaknesses identified and will endeavor to further insist on consistency of application of the applicable rules and procedures. With regard to the delays in submission of cost claims, the JU is monitoring this issue and in all cases had issued reminders and where appropriate had taken follow-up actions to insist on this reporting. It will endeavor to improve this part of the process further during 2014. No comment. The final audit report has been signed on 26th March 2014 and has been brought to the attention of the Chair of the Clean Sky Governing Board and Executive Director. Actions have been agreed with the JU’s management to mitigate the 4 very important and 4 important findings. The implementation of the actions will be monitored by the Internal Audit Officer in the course of the year 2014. For the 4 important recommendations of the IAS, the JU has continued to implement the actions according to the agreed timetable. The implementation is still ongoing. The implementation of the actions regarding the 2 very important recommendations is almost complete. Guidance documents for the validation of cost claims for GAMs have been further developed for Financial Officers and Project Officers, checklists have been further improved and a template for the technical assessment report of the annual reporting exercise for GAMs has been developed and disseminated to the POs. Concerning the approval of deliverables from Partners, a clarification on role and tasks of the Topic Managers as support for the JU’s Financial Officers has been integrated in the CSJU Management Manual. Clean Sky JU has developed an action plan to address the recommendations of the IAS IT Risk Assessment and will implement these actions by year end 2014. The provisions of the presently applicable Framework Regulation referring to the powers of the Commission’s internal auditor have been applied by CSJU in practical terms since 2011 and are now integrated in the newly adopted Financial Rules of the JU. The JU has taken note of the Court’s findings and has updated its monitoring tools as a response to this already in 2014. In the meantime, it has requested and received consolidated results from the private members in this regard including their dissemination plans. The JU is using the Commission system CORDA for publishing summaries of GAP projects and these are already online. In addition, 4 out of 7 GAM annual report summaries from 2013 are already available on the JU website. The remaining 3 will be available by mid-September 2014. New rules have been adopted by the Governing Boards of all Jus regarding confidentiality and conflict of interest in early July 2014 following a model proposed by the European Commission. In order to keep a register of the Clean Sky Governing Board declarations, the JU will establish a register on conflicts of interest, incompatibilities and other related documents and will set up an electronic database to monitor this. This will be implemented by the end of the year 2014. At the time of the audit, the database for staff did not exist. It is envisaged to have it populated by end of October 2014. The database will allow the JU to update it where appropriate and be able to dispose of all information and elements to be considered in case of a potential case of conflict of interest and take appropriate measures. The JU prepared a summary of the SWOT analysis that was performed by the evaluators and their recommendations for the GB meeting in December 2013. The GB agreed with the recommendations and asked the JU to follow up the implementation of relevant items. An action plan is being followed by JU management. Most of the implementing actions will go through the Annual Reviews, the Management Manual, GAMs or GB rules of procedure. The JU will also take the lessons learned from this assessment for an improved management of both programmes. Concerning the staffing situation, as reported in both the Annual Implementation Plan 2012 and 2013 and in the Annual Activity Reports 2012 and 2013, the JU continued not to be at the staffing level needed to perform all expected tasks from either a technical or financial point of view. Since the adoption of the new establishment plan in July 2014 the JU will be allowed to recruit 18 new posts — of which the majority will be dedicated to technical roles. This will enable the JU to improve overall compliance and performance of grant agreements going forward.
The JU has improved its budget implementation in 2013. The remaining delays, while partly attributable to the delay in GAP signatures are also related to the actual re-orientation of some of the operational activities as the research work continues. When certain milestones are not achieved on time, this can be due to normal contingencies and setbacks of some research activities, for which more time and effort is needed within the ITDs but after the 2012 reporting period. This is part of the challenge managed by the JU for such a large-scale and complex programme. The European Union committed amount will always be higher than the private members’ resources as the latter only takes into account the validated cash contribution — while the (EU) commitment covers some multiannual grant agreements not yet fully implemented. It can also be noted, that the European Commission had the obligation to commit the full programme value before the end of 2013 due to it being the last year of the FP7 programme. The JU is making the commitment with the private members once the technical activity foreseen for the coming period(s), is agreed by the JU through the grant agreements. The details of this activity for the last years of the programme will only be finalized in 2015 and therefore is not yet committed or validated. A specific function for the ex post audit exercise was developed in GMT in April 2014. This function will be further enhanced to allow the integration of ex post audit data in the system this year. Following the developments already made during the first half of 2014, a new release of GMT will be implemented by end of this year and will fix several of the weaknesses identified. This will include, in particular, the in-depth review of the function allowing the financial and project officers to provide comments within the validation workflow. With respect to the ex-ante control of the validated commitment, the two functions (Financial Verifier Agent and Authorising Officer) were taken exceptionally under the responsibility of the Head of Administration and Finance which was acting as a back-up of the Authoring Officer during the annual leave of the Executive Director. As CS is a small team, during the annual leave of many actors, the absence of segregation of duties can happen in exceptional cases. In this respect and in order to ensure the sound functioning of the control system, the JU has updated the financial back-up system by introducing new actors to perform the roles of financial verifier and authorising officer by delegation and is now closely monitoring the continuity of operations during absences. It should be however noted, that even in these cases, the initiation and verification/authorisation functions are kept separate. The single case relating to the absence of the assessment report has since been rectified in the GMT tool. The Joint Undertaking takes note of the weaknesses identified and will endeavor to further insist on consistency of application of the applicable rules and procedures. With regard to the delays in submission of cost claims, the JU is monitoring this issue and in all cases had issued reminders and where appropriate had taken follow-up actions to insist on this reporting. It will endeavor to improve this part of the process further during 2014. No comment. The final audit report has been signed on 26th March 2014 and has been brought to the attention of the Chair of the Clean Sky Governing Board and Executive Director. Actions have been agreed with the JU’s management to mitigate the 4 very important and 4 important findings. The implementation of the actions will be monitored by the Internal Audit Officer in the course of the year 2014. For the 4 important recommendations of the IAS, the JU has continued to implement the actions according to the agreed timetable. The implementation is still ongoing. The implementation of the actions regarding the 2 very important recommendations is almost complete. Guidance documents for the validation of cost claims for GAMs have been further developed for Financial Officers and Project Officers, checklists have been further improved and a template for the technical assessment report of the annual reporting exercise for GAMs has been developed and disseminated to the POs. Concerning the approval of deliverables from Partners, a clarification on role and tasks of the Topic Managers as support for the JU’s Financial Officers has been integrated in the CSJU Management Manual. Clean Sky JU has developed an action plan to address the recommendations of the IAS IT Risk Assessment and will implement these actions by year end 2014. The provisions of the presently applicable Framework Regulation referring to the powers of the Commission’s internal auditor have been applied by CSJU in practical terms since 2011 and are now integrated in the newly adopted Financial Rules of the JU. The JU has taken note of the Court’s findings and has updated its monitoring tools as a response to this already in 2014. In the meantime, it has requested and received consolidated results from the private members in this regard including their dissemination plans. The JU is using the Commission system CORDA for publishing summaries of GAP projects and these are already online. In addition, 4 out of 7 GAM annual report summaries from 2013 are already available on the JU website. The remaining 3 will be available by mid-September 2014. New rules have been adopted by the Governing Boards of all Jus regarding confidentiality and conflict of interest in early July 2014 following a model proposed by the European Commission. In order to keep a register of the Clean Sky Governing Board declarations, the JU will establish a register on conflicts of interest, incompatibilities and other related documents and will set up an electronic database to monitor this. This will be implemented by the end of the year 2014. At the time of the audit, the database for staff did not exist. It is envisaged to have it populated by end of October 2014. The database will allow the JU to update it where appropriate and be able to dispose of all information and elements to be considered in case of a potential case of conflict of interest and take appropriate measures. The JU prepared a summary of the SWOT analysis that was performed by the evaluators and their recommendations for the GB meeting in December 2013. The GB agreed with the recommendations and asked the JU to follow up the implementation of relevant items. An action plan is being followed by JU management. Most of the implementing actions will go through the Annual Reviews, the Management Manual, GAMs or GB rules of procedure. The JU will also take the lessons learned from this assessment for an improved management of both programmes. Concerning the staffing situation, as reported in both the Annual Implementation Plan 2012 and 2013 and in the Annual Activity Reports 2012 and 2013, the JU continued not to be at the staffing level needed to perform all expected tasks from either a technical or financial point of view. Since the adoption of the new establishment plan in July 2014 the JU will be allowed to recruit 18 new posts — of which the majority will be dedicated to technical roles. This will enable the JU to improve overall compliance and performance of grant agreements going forward.