Dear European Border and Coast Guard Agency,

On November 5th, 2021, Frontex started a Call for Proposals as part of its "Joint Reintegration Services" program [1]. Ultimately, 6 Reintegration Partners (RPs) out of 8 applicants were selected for the project [2].

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:

- which RPs have been allocated to which one of the 27 third countries listed in [2]
- copies of the certificate of official registration of the 6 RPs in the countries of return for which they were selected, as stated in Annex II of 2021/CFP/POST/01
- copies of the 200-word summary of actions submitted by each of the 8 applicant organizations in as part of Annex I of 2021/CFP/POST/01

Yours faithfully,

Anas Ambri

[1]: https://frontex.europa.eu/media-centre/n...
[2]: https://frontex.europa.eu/media-centre/n...

Dear Frontex Transparency Office,

Thank you for your reply. However, I am not able to access the link included in your reply under the hyperlink "Reintegration assistance (europa.eu)". Would you mind sharing it with me again, please, by spelling it out? That way, it will be easier for me to copy it, since I am not able to click on it in the attached PDF.

Additionally, I find your response to my application unsatisfactory. Therefore, I would like to file the following confirmatory application with regards to my access to documents request 'Frontex Joint Reintegration Services: list of allocated RPs per third country', specifically documents under indent 3.

Please recall that indent 3 is a request for copies of the 200-word summary of actions submitted by each of the 8 applicant organizations as part of Annex I of 2021/CFP/POST/01 [1].

In your reply, you state that:

a) all documents under intent 3
> "fall under a general presumption as they contain inter alia information relating to methodologies, know-how, specific pricing, breakdown of budgets, involvement of experts or partners, information on detailed operational aspects, business strategies, detailed descriptions of the proposed actions and other information carrying a commercial value"

b) Additionally, you add in your reply that:
> "Disclosure to the public of such information would undermine the protection of the respective legal person’s commercial strength and is thus precluded as also no evidence to justify the conclusion that such general presumption did not apply to the documents disclosure of which was requested has been brought forward."

I would like to submit that these two concerns do not apply here.

With regards to point a), I refer you to the Frequently Asked Questions for 2021/CFP/POST/01 [2], Question 13, which asks how specific the summary of actions need to be:

> "There are no specific criteria, it is a way to understand how the RP works and intends to achieve the
objectives.
The summary of actions is not the specific action plan[...]. It [the summary] is recommended to make it as short as possible but as long as everything is addressed. The summary of actions is just a short concise
summary of the whole plan."

It is therefore clear that the summaries of actions are not meant to be a replacement of the "whole plan", but simply short synopses, and therefore, do not contain the detailed information that point a) claims they contain.

This is rather confirmed by referring to the explanatory note included on Annex I itself [1], under the heading "Summary of Actions", which states:

> "For successful applications, this section may be published, as presented below, in publications used for the promotion and publicity of the Frontex Post-Return Unit Framework Partnership Agreements/grants"

This suggests that the applicant organizations, by filing their application, acknowledge the nature and function of the "Summary of Actions" they are including in their application, and have therefore foregone any protection derived from the need to protect their commercial strength, contrary to what was stated in point b) above.

Given the information above, I would like to request a release of the information requested under indent 3.

As always, I remain at your disposal for any questions.

A full history of my request and all correspondence is available on the Internet at this address: http://www.asktheeu.org/en/request/front...

Yours faithfully,

Anas Ambri

[1]: https://frontex.europa.eu/assets/About_F...
[2]: https://frontex.europa.eu/assets/About_F...