Erasmus+ project 2023-1-TR01-KA220-VET-000151966 (EcoRehabASD) — assessment of operational capacity, conflict-of-interest safeguards, and funding controls

The request was partially successful.

Dear Education, Youth, Sport and Culture,

This request is submitted under Article 2(1) and Article 6 of Regulation (EC) No 1049/2001, read in conjunction with:
• Regulation (EU, Euratom) 2018/1046 (EU Financial Regulation), in particular Articles 61, 136, 198
• Erasmus+ Programme Guide and Model Grant Agreement
• Article 325 TFEU (protection of EU financial interests)

1. Documents requested

I request access to documents held by the Commission (including DG EAC and any relevant services) concerning the award, implementation, and monitoring of Erasmus+ project 2023-1-TR01-KA220-VET-000151966, coordinated by Gazi University, managed by the Turkish National Agency.

A. Application and evaluation phase
1. The complete project application, including annexes.
2. Evaluation reports, score sheets, expert comments, and internal assessment notes.
3. Any conflict-of-interest declarations completed by evaluators or experts involved.
4. Documents relating to the verification of operational and financial capacity of all partner organisations at application stage.

B. Grant agreement and payments
5. The signed Grant Agreement and any amendments.
6. Documents concerning pre-financing decisions, payment schedules, and monitoring of fund distribution among partners.

C. Compliance and risk management
7. Internal risk assessments, red-flag analyses, or compliance notes concerning:
• links between partner organisations,
• shared management or governance structures,
• repeated participation of interconnected entities across Erasmus+ projects.
8. Any documents describing ex-ante or ex-post controls applied to this project under the Financial Regulation.

D. Inter-service coordination (without investigative content)
9. Any non-confidential correspondence or notes between DG EAC and other Commission services concerning:
• governance risks,
• operational-capacity concerns, or
• funding-control issues related to this project.

This request does not seek disclosure of investigative methods, evidence, or protected OLAF material. Where necessary, I request partial access pursuant to Article 4(6) of Regulation 1049/2001.

2. Public-interest justification

The documents requested concern:
• the use of EU public funds,
• compliance with conflict-of-interest rules,
• verification of operational capacity of project partners, and
• the effectiveness of financial-control mechanisms under the Erasmus+ framework.

Access would contribute to transparency and accountability in EU spending, without undermining any ongoing administrative or criminal investigations.

3. Proportionality and format

I accept:
• partial access,
• redaction of personal data,
• documents in electronic format,
• grouped responses by document category.

4. Time limit

In accordance with Article 7(1) of Regulation 1049/2001, I expect a reply within 15 working days.

Yours faithfully,

Monika Schwartz

EAC-ACCES-DOCUMENTS@ec.europa.eu, Education, Youth, Sport and Culture

1 Attachment

Dear Mrs Schwartz,

We are writing regarding your request for access to European Commission documents received by e-mail on 27/12/2025.

Since you have not indicated your postal address, we are not able to start handling your request. The 15 working days to reply to your reply will start running only when you send us your postal address.

You can send your postal address by replying to this e-mail or introduce your request for access to documents via EASE ( https://www.ec.europa.eu/transparency/do... ). The platform will guide you how to introduce your request and provide us with all necessary information.

If we do not receive your reply, we may close this case.

Why do we need your personal postal address?

The submission of a postal address is mandatory when submitting an application for access to Commission documents. We would like to explain why we need your postal address in order to register and handle your application for access to documents:

1. To verify whether you benefit from the right to access Commission documents. In accordance with Article 2(1) and (2) of Regulation (EC) No 1049/2001, read in conjunction with Article 1 of the European Commission’s Detailed rules for the application of Regulation (EC) No 1049/2001, only citizens of the Union and natural or legal persons residing or having their registered office in a Member State have the right to access to Commission documents. This requires an indication of a valid, individual (not generic) postal address.
2. To notify the Commission’s reply via registered mail with acknowledgement of receipt or via delivery service in case the notification by email is unsuccessful, i.e. you do not acknowledge the receipt of the reply by return message.
3. To protect the interest of other citizens and safeguard the principle of good administration. The Commission has to treat all citizens equally by ensuring that the legal framework for public access to documents is respected. For example, it has to verify whether Article 6(3) of Regulation (EC) No 1049/2001 concerning the handling of an application relating to a very long document or to a very large number of documents is being evaded by introducing simultaneously several requests under different identities. In an analogue application of the situation encountered in Case T-494/08, Ryanair v Commission, concerning the simultaneous submission of different applications relating to a large number of documents (EU:T:2010:511, see paragraph 34), Article 6(3) of Regulation (EC) No 1049/2001 might be evaded by splitting an application into several, seemingly separate, parts. In addition, the Commission has to make sure that the legal framework is respected and the right of access to documents is not abused by making requests under an invented identity.

The considerations above show that the request for, and the consequent processing of the applicant’s postal address, is not only appropriate, but also strictly necessary for the performance of tasks carried out in the public interest within the meaning of Article 5(1)(a) of Data Protection Regulation, namely providing a smooth and effective access to documents, and to comply with legal obligations to which the European Commission is subject within the meaning of Article 5(1)(b) of Data Protection Regulation. For further information, please consult the relevant Privacy Statement and Record of the personal data processing operation.

By replying to this request, you declare, on your honour, that all information provided is accurate and truthful and that you understand that false declarations may lead to legal consequences. Please note that, if deemed necessary, the Commission may request you to provide adequate evidence of the indicated postal address.

We would appreciate it if you could provide us the requested information within 5 working days. In the absence of a reply from your part during this deadline, we will close your request.

Thank you for your understanding.

Kind regards,
DG EAC ACCESS TO DOCUMENTS TEAM

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