Responses to EU Ecolabel for Financial Products: 1st Stakeholder Questionnaire on the product scope and criteria definition

La demande est partiellement réussie.

Rebecca Vaughan

Dear Joint Research Centre,

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:

Responses to the consultation 'EU Ecolabel for Financial Products: 1st Stakeholder Questionnaire on the product scope and criteria definition' which ended on Friday 25th January 2019.

Yours faithfully,

Rebecca Vaughan
40 Bermondsey Street,
London

Centre commun de recherche

Dear Madam,

Thank you for your e-mail dated 2 August 2019. We hereby acknowledge receipt of your application for access to documents, which was registered on 5 August 2019 under reference number GestDem 2019/4539.

In accordance with Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, your application will be handled within 15 working days. The time limit will expire on 27 August 2019. In case this time limit needs to be extended, you will be informed in due course.

You have lodged your application via the AsktheEU.org website. Please note that this is a private third-party website which has no link with any institution of the European Union. Therefore, the European Commission cannot be held accountable for any technical issues or problems linked to the use of this system.

Please note that the private third party running the AsktheEU.org website is responsible and accountable for the processing of your personal data via that website, and not the European Commission. For further information on your rights, please refer to the third party’s privacy policy.

We understand that the third party running that website usually publishes the content of applicants’ correspondence with the European Commission on that website. This includes the personal data that you may have communicated to the European Commission (e.g. your private postal address).

Similarly, the third party publishes on that website any reply that the Commission will send to the email address of the applicants generated by the AsktheEU.org website.

If you do not wish your correspondence with the European Commission to be published on the AsktheEU.org website, you can provide us with an alternative, private e-mail address for further correspondence. In that case, the European Commission will send all future electronic correspondence addressed to you only to that private address.

Yours faithfully,

JRC Access Documents

Afficher les sections citées

Centre commun de recherche

Dear Madam,

Subject: Your application for access to documents – Ref GestDem No 2019/4539

We refer to your e-mail dated 2 August 2019 in which you make a request for access to documents, registered on 5 August 2019 under the above mentioned reference number.

The responses are documented in "ANNEX I. detailed results from the questionnaire and bilateral interviews" (pages 65-79) of the document "EU Ecolabel criteria for financial products – Preliminary report – First draft".

The document is publicly accessible at https://susproc.jrc.ec.europa.eu/Financi....

Please note that this document is a preliminary draft which does not reflect the position of the Commission and cannot be quoted as such.

Yours faithfully,

JRC Access Documents

Afficher les sections citées

Rebecca Vaughan

Dear Joint Research Centre,

Thank you for your response. However, what I am seeking are the original responses from each respondent to the questionnaires and interviews. I look forward to your reply.

Yours faithfully,

Rebecca Vaughan

Centre commun de recherche

Dear Mrs Vaughan,

We are processing your further request. As we will send an official reply also by registered mail, could you please provide us with your postal code as there seems to be more than one Bermondsey Street in London.

Yours faithfully

JRC Access to Documents team

Afficher les sections citées

Dear Joint Research Centre,

Thank you for your response. Full address is:

40 Bermondsey Street
London
SE1 3UD

Yours faithfully,

Rebecca Vaughan

Dear Joint Research Centre,

I am still awaiting a response to my request to access the original responses from each respondent to the questionnaires and interviews regarding 'EU Ecolabel for Financial Products: 1st Stakeholder Questionnaire on the product scope and criteria definition'. Please let me know when I should expect a response.

Yours faithfully,

Rebecca Vaughan

Centre commun de recherche

Dear Ms Vaughan,

Thank you for your email.

We apologize for the delay in communication due to the holiday period.

Please note that as we consider your previous request (our ref. GestDem 2019/4539) closed through our reply on August 8, we assigned to this request a new administrative reference, Gestdem 2019/5308, registered on August 12, with a deadline for our reply of September 24, extended due to the extensiveness of the request and the need for consultation of the relevant department.

In the meantime we have concluded our consultation with the department responsible for the survey and we note the following: There are 117 replies to the questionnaire, with a maximum of 110 entries per respondent, which makes almost 13.000 potential entries.

In order to allow for a frank exchange of opinions, the survey was not designed to have the raw data (entries) published as the default option. Therefore, all the entries would have to be checked individually in line with the applicable legislation (Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents), in order to blank out any personal data (e.g. any statement linked to an individual person is considered their personal data), commercially sensitive information and for other possible reasons not allowing the disclosure of the (part of the) document (see Article 4 of Regulation 1049/2001).

While not all entries contain substantial text, there are still many thousands of entries that would have to be reviewed and the respondents contacted for their opinion on the possibility for disclosure. The treatment of your request would thus necessitate a large amount of resources to be devoted to this task and would thus impair the normal functioning of the relevant department (as there are no specific administrative resources to process such requests, the request are treated by the scientists responsible for the survey).

Therefore, we would kindly ask you to consider whether your interests could be addressed in another way, in line with the third paragraph of Article 6 of Regulation 1049/2001 (which states: "In the event of an application relating to a very long document or to a very large number of documents, the institution concerned may confer with the applicant informally, with a view to finding a fair solution."), esp. as a very detailed summary of the survey has been published and provided to you already.

We would suggest e.g. if you could inform us what are your concrete interests which we would then provide to the responsible department, allowing them to reply to you in line with the Code of good administrative behaviour (https://ec.europa.eu/info/sites/info/fil...), i.e. reply to a request for information (rather than to a request for access to documents).

Thank you.

Yours sincerely,

JRC Access Documents

Afficher les sections citées

Dear Joint Research Centre,

Thank you for your response. I appreciate that there is significant amount of information involved. If you could provide me with a full list of respondents to the questionnaire I could then provide shorter list of the subset I am interested in accessing.

Yours faithfully,

Rebecca Vaughan

Dear Joint Research Centre,

I am still awaiting a response to this, which is now long overdue. Could you please let me know when I can expect a response?

Yours faithfully,

Rebecca Vaughan

Centre commun de recherche

Dear Ms Vaughan,
 
Thank you for your kind reminder.
 
As the respondents to the survey were informed in the survey questionnaire
that "[a]ll responses will be treated confidentially and will only be used
as background information to this study. All reference to results from
the questionnaire in the study will be anonymised", we were unable to
accept your proposal for a fair solution (i.e. to have the full list of
respondents in order to select a smaller set of responses).
 
Therefore, we have contacted the respondents and asked for their consent
with the disclosure of their responses, which would allow us to offer you
these responses as a fair solution to your original larger request (all
responses to the survey). The answers are now coming in and we will
contact you shortly with the list of responses.
 
We would like to apologize again for the delay in treating your request,
which is motivated by our efforts to satisfy your request at least
partially.
 
Yours sincerely,
 
JRC Access Documents
 

Afficher les sections citées

Centre commun de recherche

Dear Ms Vaughan,
 
Following the feedback received from the respondents of the survey, we are
pleased to offer to you as a “fair solution” (i.e. a solution to your
request in line with the third paragraph of Article 6 of Regulation
1049/2001) full responses of 20 organisations and 1 individual. The list
of the organisations is here below:
 
Sycomore
Financite
Danskebank
Ispra Ambiente (Italian CB)
Finance Denmark
Efama
World Wide Fund for Nature (WWF) 
Triodos
Blackrock
Deutscher Derivate Verband (DDV)
EuroBio - The European Association for Bioindustries
Ministère de l’Environnement, Luxenburg
GERMAN ASSOCIATION OF BIOTECHNOLOGY INDUSTRIES
Responsible Development - Candriam
CB Norway
Associação Portuguesa para a Defesa do Consumidor - DECO
Schroders
Union Asset Management Holding AG
Caissedes depots
Erste Group Bank AG
 
Could you please confirm that this solution is agreeable to you? Following
your confirmation, we will send you the responses.
 
Thank you.
 
Yours sincerely,
 
JRC Access Documents
 

Afficher les sections citées

Dear Joint Research Centre,

Yes, the proposed solution is fine and I look forward to receiving the responses. Many thanks for your assistance in this.

Yours faithfully,

Rebecca Vaughan

Centre commun de recherche

1 Attachment

Dear Ms Vaughan,

Thank you for your kind acceptance of the proposed solution.

Please find attached a copy of the responses.

Please note that the response from an individual, mentioned in our previous email, has been now correctly categorized as a response from an organisation - Nordic Swan Ecolabelling (Miljömärkning Sverige AB). In addition, due to the correction of a mistake in the list of stakeholders communicated to you earlier the number of responses is now 19. We hope that this our reply to your request is nevertheless helpful for you.

Yours sincerely,

JRC Access Documents

Afficher les sections citées