Monitoring and evaluation on traineeship policies eng

MONITORING AND EVALUATION REPORT

ON PUBLIC POLICIES

THAT REGULATES TRAINEESHIP IN MONTENEGRO

"Zaštita radnih prava mladih na tržištu rada kroz aktivne mjere zapošljavanja“ Projekat finansira EU

MONITORING AND EVALUATION REPORT ON PUBLIC POLICIES THAT REGULATES TRAINEESHIP IN MONTENEGRO

Content: Monitoring report ..........................................................3 Evaluation report .................................................. ....10 Introduction.................................................................13 Relevance ..................................................................15 Coherence ................................................................. 21 Effectivity and impact‌..‌........................................ 40 Efficiency and sustainability ...................................... 56

MONITORING REPORT MONITORING REPORT ABOUT THE IMPLEMENTATION OF THE LAW ON VOCATIONAL TRAINIG

INTRODUCTION Association for Democratic Prosperity (ADP) - Zid, in cooperation with the Union of Free Trade Unions of Montenegro (USSCG) is implementing a program called "Protection of labor rights of young people in the labor market through active employment measures" as of January 2013. In a joint collaboration, these two entities prepared a monitoring report about the level of implementation of the Law on Vocational Training. The Law on vocational training for persons with acquired higher education, which was proposed to the Parliament for approval in June 2012 by a shortened procedure, anticipates the possibility for these persons to gain competencies for independent work and is recognized as a prerequisite for taking the professional exam. The law as it is will either encourage or reduce possibilities of youth for employment, given that obligations and criteria for employers who might employ the youth from the bureau for professional development are not defined. Is there staff who will, as mentors, train these young people? Is someone going to keep track if the employers, based on accepting fresh graduates and firing employees, perform mobbing over employees and persons engaged in vocational training, will their labor rights be respected and how will they be treated?

This monitoring report shows a low level of understanding of the Law on vocational training, both by beneficiaries, employers, and specifically by state bodies responsible for its implementation.

Lack of knowledge level of beneficiaries and employers particularly influenced the low understanding level as well.

Trying to find answers to above displayed questions and the reasons for the low level of awareness and understanding by all involved parties, ADP-Zid and USSCG used a methodology based on content analysis and analysis of documents. The right to free access to information according to the Law on Free Access to Information was used. In addition, the method of surveying a representative sample of all target groups (beneficiaries and employers) was used, as well as interviews mainly with the public authorities.

MONITORING REPORT

BASIC DETAILS ABOUT THE RESEARCH Association for democratic prosperity – Zid and Union of Free Trade Unions of Montenegro IMPLEMENTER OF St. Gojka Radonjića 32, 81000 Podgorica; THE MONITORING +382 20 207 130 1. The Law on vocational training of persons with acquired SUBJECT OF higher education; MONITORING 1. Monitoring of the level of implementation of the Law on GOALS OF vocational training of persons with acquired higher education; MONITORING TIME PERIOD BEING January 15th 2013 – October 15th 2013 MONITORED • Program beneficiaries; • Employers (public, private and civic sector); TARGET GROUPS • Institutions coordinating the programs and making decisions regarding the program;

METHODOLOGY

• • • • •

Document analysis, Content analysis of the documents; Surveys; Request for free access to information; Interviews

This monitoring covered articles of the Law on vocational training of persons with acquired higher education.

ARTICLES OF THE LAW: RESEARCH QUESTIONS: TARGET GROUP METHODOLOGY RESULT

ARTICLES OF THE LAW: RESEARCH QUESTIONS TARGET GROUPS METHODOLOGY RESULT

ARTICLES OF THE LAW:

RESEARCH QUESTION TARGET GROUP METHODOLOGY RESULT

ARTICLE 2, paragraph 1 Vocational training, in terms of this law, is a continuous, programmatic and systematic activity for acquiring knowledge, skills and competencies for independent tasks and duties performance.

1. Did young people on vocational training acquire competencies, and if yes, which ones?

2. Do beneficiaries feel trained for independent performance of tasks and work assignments?

Program beneficiaries Surveying Competencies were increased by Âź compared to to the level of development prior to the beginning of the program. An extensive analysis of the data is given in the evaluation document, chapter effectiveness.

ARTICLE 2, paragraph 2 Vocational training is carried out without commencing employment, according to the program for vocational training for a specific area of expertise, which was adopted in accordance with special laws.

1. Did the employers harmonize and establish the training programs in accordance with the Law? Employers and beneficiaries Surveying Around 30% of young people did not have a program of the training, and most of the employers did not even harmonize the programs. Specifically, what is noticeable is that some of the rulebooks recognize exclusevily interns and volunteers, but not persons on the program for vocational training, while those which indicate they relate also to persons on vocational training, remain uncompletely defined in the sense of length of duration of the training for the beneficiary of the vocational training.

ARTICLE 5, paragraph 2 For carrying out the vocational training, the administrative body responsible for managing human resources, i.e. the Agency publishes a public call and directs beneficiaries to the vocational training with employers in accordance with the established criteria.

1. Have the deadlines for submitting the public call been met?

Institutions implementing the program Content analysis of the documents The Rulebook anticipated that the public call for vocational training is published on the website of the National Employment Agency, Directorate for Human Resources, and in at least one daily newspaper, no later than September 10th of the current year, which was respected in the instant case, at least when it comes to ZZZ, since that on the website of the Directorate for Human Resources at the moment it is impossible to find an ad from the 2012, as well as on the electronic portal of the daily newspapers Pobjeda, which on the indicated date had an article published about the program and an announcement of the advertisment for vocational training. In the public call, the authorities responsible for its publication referred exclusively to the Law, but not on Article 3, paragraph 3 of the Rulebook.

On the website of UZK, the published ad was promptly released according to the information we acquired, but its content was not available to us.

ARTICLES OF THE LAW:

RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

ARTICLES OF THE LAW:

RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

ARTICLE 5, paragraph 3 The way of publication of the public call, the process of registering beneficiaries, the criteria for referring the beneficiaries to employers, deadlines and other issues important for the performance of vocational training of beneficiaries is regulated by a provision of the governing bodies of the state administration responsible for affairs of education.

ARTICLE 18, paragraph 5 The regulation of the article 5, paragraph 3 of this law will be passed within 30 days from the day of entry into force of this law. (bylaws) Were bylaws brought in the indicated period?

Institutions implementing the program Document analysis The Rulebook on the way of publication of the public call, procedure and criteria for vocational training (''Official Gazette of Montenegro'', no. 46/2012), came into force on September 3rd 2013, or 38 days after entry into force of the Law, i.e. 8 days after the projected deadline.

ARTICLE 8 The contract of the vocational training is signed by the beneficiary and the employer. The contract from paragraph 1 of this article is signed in written form and it contains: 1) name and residence of the employer; 2) name and surname and unique citizen number of the beneficiary; 3) location, i.e. place of residence of the beneficiary 4) level of degree, i.e. level of National frame of qualifications; 5) jobs and tasks for which the vocational training is being done; 6) place in which the vocational training is being done; 7) length of duration of the contract on vocational training; 8) date of start of the vocational training; 9) amount of remuneration for the vocational training; 10) way of termination of the contract; 11) Other questions of significance for the vocational training 1. Did all employers and beneficiaries conclude the contract on vocational training?

2. Did the employers closely define item 11 of the contract?

Institutions implementing the program Document analysis/Interview According to our findings, all beneficiaries and employers concluded the Contract on vocational training. According to results from the Round Table which ADP-Zid and USSCG organized with private sector employers on November 28th 2013, it is clear that most employers use a standard contract for vocational training, which was, in order to assist employers, posted on the website of ZZZ and UZK before the beginning of program implementation, which led to that the mutual rights and obligations were not completely defined, as well as that a description of the positions in which the beneficiaries will be vocationally trained was not specified, which led to the creation of many doubts regarding the implementation and realization of obligations and exercise of rights of both beneficiaries and employers.

ARTICLES OF THE LAW:

RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

ARTICLES OF THE LAW: RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

ARTICLES OF THE LAW:

RESEARCH QUESTIONS

TARGET GROUP METHODOLOGY RESULT

Article 10, paragraph 1 During the vocational training, the beneficiary is entitled to a monthly remuneration in the net amount of 50% of the average net salary in Montenegro in the year preceding the conclusion of contracts on vocational training, according to the data from the administrative body in charge of statistics.

1. Did the beneficiaries receive an amount which corresponds to the 50% of the average net salary in Montenegro for 2012; Beneficiaries, the Ministry of Finance Request for access to information USSCG to date, has not received access to information held by the Ministry of Finance, upon request of September 2013, which refers to: - financial statements on paid remunerations to persons in vocational training, by months (February 2013 - September 2013); - explanation for any deviations, i.e. differences in monthly payments; - The total number of customers to whom the remuneration was paid.

Taking into account the large number of customers who were with us in direct contact, contact through the helpline and FB page, we have not recognized that there was a problem of non-payment of fees or transgression in payment.

The employer is obliged to notify the administrative authority for personnel management, i.e. the Agency to deliver reports about beneficiaries' performance of the vocational training no later than the end of the month for the current month.

Did the employers regularly deliver reports; Was the report form brought on time?

Institutions implementing the program Interview with employers; document analysis; Almost all employers delivered reports according to the set deadline to the authority in charge. There were some discrepancies, but it did not happen that the deadline was broken for more than 1-2 days. In the evaluation document more information can be found about the quality of the reports.

The remuneration is paid to the beneficiary no later than the tenth day of the month for the previous month based of the report referred to in paragraph 3 of this article. The employer can independently provide funds for payment of the remuneration under Article 10, paragraph 1 of this Law. In the case referred to in paragraph 1 of this Article, the amount paid, at the request of the employer, is recognized as overpaid tax from which obligations of the employer regarding other taxes can be settled, in accordance with the regulations of the state administration in charge of finance. For the remuneration referred to in paragraph 1 of this Article and Article 10 of this Law, taxes, fees and other duties regulated by the law are not paid; The regulation referred to in Article 11 paragraph 2 of this Law shall be passed within 90 days of the date of entry into force of this law (bylaw).

8.1. Were the remunerations regular?

8.2. Did any employer pay the remuneration to the beneficiary independently?

8.3 Were the regulations of the law which facilitates the provision of tax relief to those who pay remunerations from their own budget passed on time? Document analysis Institutions implementing the program, employers Interview with UZK, ZZZ and employers ZSPI Pursuant to Article 11 paragraph 2 of the Law on Vocational training for persons with acquired higher education ("Official Gazette", No. 38/12), the Ministry of Finance issued a Rulebook on the way of recognition of paid remunerations to

beneficiaries of vocational training as overpaid taxes. The Rulebook was published in the Official Gazette of Montenegro on October 9th 2013, and entered into force eight days after its publication in the Official Gazette. So, in this particular case, the date until which the Rulebook was adopted was not in accordance with the deadline set by the law, which is 90 days from the date of entry into force of the Act. However, by Article 5 of the Rulebook, it is anticipated that its provisions start applying starting on February 15th 2013. If the employer uses the opportunity provided by the law, to independently provide funds for payment of remuneration to the beneficiary performing the vocational training, the paid funds can be recognized as overpaid taxes for the employer. The amount of the financial compensation paid to the beneficiary of the vocational training, can be recognized as overpaid taxes for employers for settlement of payments arising from: - Value added tax, - Income Tax Law, and - Excise.

By information obtained from the Tax Authorities, and in accordance to the submitted claim, we were infomred that the number of claims filed by employers was 4, and that by the same employer for 4 accounting-periods months in the municipality of Podgorica, while other municipalities did not have requests on this basis by employers. Data about requests from other municipalities were obtained by telephone from the regional offices, because the above mentioned do not exist united in the central unit.

ARTICLES OF THE LAW: RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

ARTICLES OF THE LAW:

RESEARCH QUESTIONS TARGET GROUP METHO RESULT

In relation to their rights, duties and responsibilities during the vocational training, to beneficiaries are applied general rules of labor, if this is not otherwise regulated by law.

Were general rules about labor applied to the beneficiaries?

Employers, beneficiaries Survey, SOS phone line A key problem in the implementation of the program was entered by a collision present in the text of the law, i.e. the fact that by the law, vocational training is recognized as traineeship (work engagement without employment), and that to the beneficiaries of the Program of vocational training the same general rules of labor are applied with respect to their rights, duties and responsibilities. This hardened the implementation of the Law in practice and the Ministry of Education publicaly spoke up in order to give an interpretation of certain rights and responsibilities of young people. More details can be found in the evaluation document, chapter coherence.

For the needs of the Program of Vocational Training, the information system is provided to beneficiaries by the state authority responsible for information society.

A record of beneficiaries who have completed the program of vocational training, based on data from the information system referred to in paragraph 1 of this Article, is led by the administration in charge of human resource management and the Agency of Employment.

Are there records in ZZZ and UZK? ZZZ and UZK Interview In both institutions, records of persons who have completed the vocational training program is kept. There were individual cases in which employers refused to issue certificates to beneficiaries. The reason for this was lack of knowledge of regulations, but these cases were processed and at the end every beneficiary who

completed the program, received a confirmation.

ARTICLES OF THE LAW: RESEARCH QUESTIONS TARGET GROUP METHODOLOGY RESULT

Inspection supervision over the implementation of this law is carried out by the inspector in charge for the field of labor.

11.1. Did the labor inspection get involved in one of the cases; 11.2. Did they have ant request, if yes, how many and which questions?

Beneficiaries, Labor inspection ZSPI; SOS phone line; Directorate for Inspection Administration, by Decision No: UP 0801-03-97/3 of October 17th 2013, refused the request of USSCG which sought access to information regarding the number of requests that, pursuant to Section 15 of the Law, were filed by the beneficiaries of the Program, because, as noted, the Department of Labour Inspection did not have requests for inspection submitted by a program beneficiary. However, it is a fact that over the SOS helpline for young people which started working within USSCG, a lot of beneficiaries of the Program called, where they said that they verbally addressed the Labour Inspection (regional unit Budva, regional unit Herceg Novi), while the legal department of USSCG assisted in the preparation of the written request for the protection of the person who performed the vocational training in Budva, which was not processed.

ARTICLES OF THE LAW: RESEARCH QUESTIONS TARGET GROUP METHO RESULT

Existing programs of vocational training for certain fields of activity will be adjusted within 60 days of the date of enactment of this Act in terms of their duration.

Was it harmonized in time? / Document analysis Most of the regulations and other articles that were supposed to be harmonized with the law on vocational training were not harmonized or in some cases when they were harmonized, a smaller scope of rights for beneficiaries in relation to the classical apprentices was set.

EVALUATION REPORT

SUMMARY OF FINDINGS This document represents a Report on the assessment of the effects of policies which regulate traineeships in Montenegro. The research most detailed included the Government’s program for vocational training of university graduates, since the information about this program was mostly available. Other trainseeships were analyzed in ratio to a smaller sample of respondents and by content analysis of available documents.

This document covers an analysis of six criteria that characterize the principles of good governance: 1) relevance (justification) of the policy-making, 2) internal and external coherence (compliance) of the proposed policy solutions, 3) effectiveness (efficacy), 4) the impact of policies on target groups, 5) efficiency (cost-effectiveness) and 6) sustainability of the policies.

Conclusions and guidelines for improvement of existing solutions:

Relevance: •

•

•

•

The intervention is partly relevant to the current policies at EU level, given the fact that Government of Montenegro proposes part of measures, outlined in the “Youth Employment Guarantee” package, which is related just to the practice/ training after graduation, but no measures relating to the creation of opportunities for employment.

The intervention is relevant to its specific goal, given the fact that young university graduates are able to gain certain competences and experiences in order to become more competitive in the labor market; The intervention is not relevant to the main objective of policy - the increase of youth employment in Montenegro, because it is necessary in a synchronized manner to work on the policy of job creation and compliance of education policy to labor market needs; The intervention is not relevant in terms of target groups and addressing the main causes of the problem of youth unemployment in Montenegro, because it is necessary to establish similar programs for high school graduates, and thereby create jobs for a population with a high school diploma;

Coherence: • • • •

The external coherence of policies that govern normative traineeship is not completely fulfilled; The internal coherence of policies that govern normative traineeship is not completely fulfilled; Manifestation of traineeship in the open market in private sector is not regulated by law; There is a need to create systemic laws that will regulate all the forms of traineeship, in order to ensure the quality of training, protection of labor rights, unified monitoring of policy development effects and sustainability goals at the level of policies.

Effectivenes and impact: • • • •

Creation of a framework for the quality of implementation of the program (selection, mentorship, reporting, level of competence, work conditions), Creation of a good quality monitoring and evaluation system, Improvement of competencies of all institutions implementing the program, Improvement of quality of the level of information about the measures proposed in the Law.

Efficiency and sustainability> • • • • • •

•

Introducing a mandatory paid/unpaid practice for high school students and university students throughout the duration of studies, Adaption of the educational system to the needs of the labor market, which would lower the number of unemployed young people, Creation of conditions for youth engagement on the open market which would provide them protection of work rights , Payment of participation and usage of international programs (ex. Leonardo da Vinci, EVS), through which many young people can get work experience in the EU, Creation of incentives for employers who give services of vocational training, Creation of a fond for vocational training – remuneration for the training program which is realized by the state can be treated as a student loan, where beneficiaries would, after getting a job, return a certain amount of the remuneration into the fond, Optimization of criteria for youth entrepreneurship, in order that young people could, after gaining competencies, have the possibility to start their own business.

INTRODUCTION Sampling and validity of the research A total of 904 or 22% of the entire population was surveyed, i.e. the total number of highly educated young people who were involved in the program. The analysis included 901 surveys that fulfilled validity criteria. The surveying was done electronically. Practically, there was no strict sampling – surveys were filled out by those who found enough motivation to do so. From the point of size and basic structure of the sample (i.e. self sampled individuals), the sample meets the basic requirements for the execution of valid research and for expansion of findings on the overall surveyed population.

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-Every fifth participant of the program was tested (22%); - A sufficient number of young people in basic occupations in which the Program was performed were surveyed. In the structure of the sample we have two-thirds (65%) of unemployed university graduates who performed the Program in the public sector ("public sector - public institutions" - 56% and "local government or public enterprise (utilities, etc." - 9%), 30% in the private sector and 5% in the civil sector (NGOs, the media, trade unions, political parties); - Gender structure: 67% women and 33% men; - Age structure: up to 24 years old - 35%, 25-29 years old - 48%, and 30 years old and over - 17%; - Type of completed faculties: economics, management, shipping, customs etc. - 24%; Faculty of Arts (languages, history, geography, philosophy, sociology, psychology, etc.) 19%; technical colleges (civil engineering, electrical engineering, machinery, technology, geodesy and so on.) and Faculty of Science - 17%; Faculty of Law, Political Science, Faculty of Dramatic Arts, Faculty of Security etc.. - 15%; Faculty of Maritime Studies, tourism, maritime management etc.. - 10% and other faculties - 15%; - Regional structure: Coastal Region - 20%, Northern Region - 20%, Central region 60% (Podgorica - 37%, Niksic and the rest of the region - 23%); - Length of unemployment: one year and less - 61% more than a year - 39%.

The main problem of the sample for this research remains "self choice", or that the organizer of the research could not have significant influence on who will and who will not complete the survey. Namely, there was a possibility that the disappointed Program participants will more often occur as respondents than other Program participants. Or the contrary, that only those who are extremely satisfied with the program will respond, or only those who had employment clear on sight. To prevent these (somewhat expected obstacles) we included in the survey a number of "control questions" - those were two, and in one case also three similar questions, which to some might have looked "absolutely the same" and that were "scattered" throughout the survey.

Consistency of answers to these questions which did not follow one another, suggests that "self choice’’ was not weighted by the emotional state of the Program participants.

About the validity of responses and the self weighed sample, evidences also the number of nonresponses to questions for which we knew in advance that all respondents will not be able to respond because they just did not have enough information about that (if it was responded "spontaneously", if it was "tipped", those questions would be responded as well).

RELEVANCE

SUBJECT OF ANALYSIS AND RESEARCH METHODOLOGY SUBJECT OF ANALYSIS Relevant subject of analysis are different types of traineeship arrangements in Montenegro, with special emphasis on the Law on vocational training of Persons with Acquired Higher Education Degree. Relevance criteria should give an insight into timeliness and necessity of adopting different policies with regard to traineeship. The study was conducted to estimate the suitability of policies in relation to the existing problem in society, its impact on target groups, political acceptability and broader social and economic context.

Evaluative issues to be answered in this case study are the following: • • • •

Is the intervention relevant to existing policies that address the issue of increasing the employability of young people at the national, regional and EU level?

How urgent was this policy intervention from the beneficiary’s perspective?

Is the appropriate intervention chosen to solve specific problems?

Does the proposed intervention eliminate solving the main causes of problems?

METHODOLOGY - Document analysis (representation analysis and content analysis) - Conducting surveys with beneficiaries and employers.

CONCLUSIONS: •

•

•

•

The intervention is partly relevant to the current policies at EU level, given the fact that Government of Montenegro proposes part of measures, outlined in the “Youth Employment Guarantee” package, which is related just to the practice/ training after graduation, but no measures relating to the creation of opportunities for employment.

The intervention is relevant to its specific goal, given the fact that young university graduates are able to gain certain competences and experiences in order to become more competitive in the labor market; The intervention is not relevant to the main objective of policy - the increase of youth employment in Montenegro, because it is necessary in a synchronized manner to work on the policy of job creation and compliance of education policy to labor market needs; The intervention is not relevant in terms of target groups and addressing the main causes of the problem of youth unemployment in Montenegro, because it is necessary to establish similar programs for high school graduates, and thereby create jobs for a population with a high school diploma;

ANALYSIS

SUBJECT OF ANALYSIS 1 – POLICY RELEVANCE IN RELATION TO NATIONAL AND EU POLICY WHICH REGULATE TRAINISHEEP

ANALYZE ISSUE 1 • Relevance to the current policies in EU and Montenegro; • How urgent was the policy intervention in this field from beneficiary’s perspective?

Relevance to the EU policies Youth unemployment is a worldwide problem nowadays. It is a problem of the most developed countries, as well as in the EU countries. Montenegro is not an exception either. The normal reaction to such a state of things is to take a number of different measures to solve the problem of unemployment, or at least to mitigate it. Thus, for instance, the Council of Employment, Social Policy, Health and Consumer Affairs of the European Union (EPSCO) agreed acceptance of European Youth Guarantee. The European Union will allocate the budget of six billion euro for the young unemployed people, as a guarantee that young people in Europe will be offered a job, further education and professional practice to be provided no later than four months after finishing formal education or of losing their jobs. "Youth Guarantee" is a package of measures proposed by the European Commission to all Member States.

At the EU level in 2012, qualitative consultations started within the framework for the traineeship.

These activities are proposed in the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions -Towards Quality Framework on Traineeships.

According to this document, in all EU countries, youth unemployment rates are much higher than in the rest of the working-age population - it is two times higher on average. A large number of reasons that influence this, especially the lack of work experience of persons who enter the labor market for the first time. This highlights the importance of traineeship in facilitating their schoolto-work transition and reducing youth unemployment. Effective quality framework should provide guidance to assist employers in creating new workplaces for trainees, which would be beneficial for employers themselves and simultaneously it would also be a good jumping-off point for young people to enter the labor market.

During the European Semester 2012, 22 Member States received specific recommendations to improve situation of young people in the labor market. High-quality traineeship helps increase the employability of young people and presents an important support in the progression towards regular employment.

EU action will support Member States in implementing the Employment Guidelines 2020 No.8, particularly the adoption of schemes to help recent graduates to find initial employment or continue their education and training. In addition, the definition of internationally accepted quality

standards can be accelerated if supranational institutions accept the role to coordinate and provide support.

Given the fact that Montenegro is in the EU integration process and that there is relevance of action for a strategic approach to address this issue at the national level, it can be concluded that the adoption of policies in this area, which is in line with European standards, is the justification of the action in terms of relevance. Montenegro ought to deal with issues concerning different types of traineeships which occur in practice, and are not regulated by European standards. In the first place, this refers to traineeship in the open market, traineeship as a part of academic curricula and traineeship as mandatory professional training.

Given that there is no quality framework, which is one of the EU recommendations in this field, the need to encourage this issue in Montenegro has emerged.

Relevance to Montenegro policies Currently, average waiting period for employment in Montenegro is 3,7 years. Economic crisis has influenced job market indicators to be more unfavorable. At the end of 2010, age structure still shows high involvement of population aged between 25 and 30, with 27,2% of total amount of the unemployed, whereas the percentage of young population decreased from 20% at the end of 2009, to 18,9% in the middle of November 2010. According to the analysis of the Employment Agency of Montenegro, about 40% of high school graduates registered at the Labor Bureau, while the others continue their education of the same, similar or other occupations at a higher level. Out of the total number of young people who finished four years of high school in 2011, about 95% enrolled into university. Therefore, there is a trend to reduce high school unemployment while the number of unemployed people with a university degree increased by 55.2% from 2007 to 2010 (2388 unemployed university graduates in 2007 compared to 3705 in 2010). This figure was around 4500 in 2012. Lately, there has been a common observation of the number of young people in the official records of the unemployed, especially young people with a university degree, has been growing rapidly. Thus, according to the data of the Employment Agency of Montenegro as unemployed aged under 25 at the end of September 2013 there were 5720 persons, an increase of 14.72% compared to the same period last year.

An even greater increase of 50.72% was recorded for the 'older' young people aged 25-30.

Participation of young people aged up to 30 in total registered unemployment in 2013 exceeded one third. In the record of the Employment Agency there were 10,532 university graduates at the end of November 2013, which presents 30.5% of the total number of unemployed persons (34.445), while in the same period of the year 2012, the percentage was 21.8 (6706) and, for example, at the end of 2008, there were 8.8% (2,547). Simultaneously, the number of unemployed university graduates in the period January-October compared to the same period in 2012 increased by 15.9% (8127 : 7,012) and the number of those without work experience, or who come from the formal education system increased by 9.7% (2800: 2,552) In order to reduce the youth unemployment, in the previous period, the Government of Montenegro and the Employment Agency of Montenegro initiated a series of active employment measures, which were rapidly reduced during the economic crisis. In order to compensate the active measures of self-employment - professional orientation, providing loans for entrepreneurship, programs for gaining job competencies, fostering entrepreneurs and civil society to engage young people, apprenticeship and other similar measures on which a big

emphasis had been placed before the economic crisis, there was an attempt to encompass traineeship by different legislation. Unfortunately, these attempts were done in unsynchronized manner, without mutual consultations and comparative practices which led to dissatisfaction among stakeholders including the risk of violation of the fundamental rights of workers.

On the other hand, in the labour market there is a trend of starting a so-called "internship" programme in various companies as a result of the mutual needs of employers to train future staff on one hand, and of young people to gain their first work experience on the other. This need for young people to gain work experience arose as a response to the deficit of jobs and opportunities for apprenticeship which consequently results in a highly competitive labor market.

These trends in the Montenegrin labor market were the impulse to response of Government, in a way, to start solving the issue and thus the policy of increasing the employability of young people was placed on the political agenda.

The first steps of the Government in setting up the traineeship programme went into direction of making amendments to the Law on Volunteer Work - Article 12a. The amendments introduced the category of the volunteer under a specific contract on voluntary work, which is a possibility to do traineeship as employed under a volunteer contract. Two more laws, proposed by the Ministry of Education and Sports, and which regulate traineeship are the Law on Adult Education and the Law on vocational training of Persons with Acquired Higher Education Degree.

ANALYZE ISSUE 2 •

Is the appropriate intervention for addressing specific issue chosen?

It is evident that the employment policy should be created parallel line to development policy of Montenegro (economic policy), market trends and education policy. Current policies, which enable traineeship to be carried out, are created out of the following reasons: •

• • •

Reducing youth unemployment in Montenegro by facilitating the transition of young people with university degree from the sphere of education to the sphere of work, appreciating the fact that this category of people usually do not possess practical experience, what is the reason why they are not capable to perform work independently and efficiently after graduation; Providing opportunities for all persons with acquired higher degree, without work experience at this level of education to acquire knowledge, skills and competencies that will enable them to perform work independently, not being formally employed.

Allow young people to gain relevant work experience and meet the requirements for taking appropriate qualification exam; Allow employers in public and private sectors to identify users that will possibly be interested in work engagement, by the end of the traineeship.

These measures, which were regulated by legislation and initiated by various ministries, are not fully compliant with EU standards, but only partially. This problem predominantly arises from the group of specific challenges, such as:

- The low level of understanding of the issues within the state institutions and their ability to evaluate the effects of the proposed measures. The reasons for such a situation are associated with the lack of a thorough analysis of comparative experiences from the EU, as well as with the fact that the results of their implementation not followed.

- The lack of critical attitude and reaction to youth labour rights violations and abuse of status of persons in vocational training programme. The reason for this is related to the fact that the lack of capacity of the structures of civil society organizations that represent the interests and rights of young people in entering the labor market, but also ignorance of the real effects of active measures to increase employability and expectations of families young people are coming from.

- Regulation of different forms of work placements in state of urgency due to emerging problems, or current practice which is to be regulated by law. The main reason is the lack of communication and intersection cooperation of civil sectors (including NGOs and trade unions).

The lack of offer of expert concept of active employment measures does not contribute to this challenge, and it would give directions to the unique regulation of all forms of traineeship.

By addressing these challenges, certain consequences will be annulled, such as exposure of young people to manipulation due to unclear procedures, by which benefits of traineeship work under contract on volunteering can be recorded, then the violation of labour rights and mobbing experience at work by permanent workers who see them as competition.

A common explanation for the increase of the number of unemployed university graduates is associated with an increase of the number of high school students who enroll and complete university. However, this presents one side of the phenomenon. This suggests that programs of traineeship should be set up also for persons with high school degree, which would reduce the number of university graduates and balance the dispersion of relations of labor force in the labor market.

Other side of employment should be linked to the lack of adequate working places where unemployed university graduates could employ. This explains the fact that the problem of youth unemployment and their finding the first job are high on the list of challenges for young people in Montenegrin society, as it is the case with entire EU. There are many factors that affect the youth unemployment rate: the presence of gray markets, non-compliance of the educational system and the labor market, as well as inadequate knowledge acquired during training, what directly causes a low level of motivation of young people to acquire knowledge during their studies.

COHERENCE OF POLICIES

SUBJECT OF ANALYSIS AND RESEARCH METHODOLOGY

SUBJECT OF ANALYSIS: Coherence analysis treats policies, which are completely or partly related to the traineeship.

Public policies shall provide a framework for the implementation of programs which aim at increasing employability of young people and provide opportunity to gain their first workplace experience. However, the question is whether legal framework set up in such a manner defines the minimum criteria that should ensure the quality of the implementation of these programs, based on which each of them should fullfil their primary purpose, and provide knowledge and application of the rights and obligations of both parties, program beneficiaries and employers who provide them with engagement.

Evaluative questions to be answered in this analysis are the following: Internal coherence: 1 Is the intervention (public policy) ambiguous or are its measures clearly defined?

External coherence: 1. Does the intervention (public policy) comply with other relevant policies at national level?

2. Are other policies complied with intervention (in case of lex specialis laws)?

METHODOLOGY: • • • • •

The research used a variety of research methods: Analysis of documents and their contents; Information taken from SOS and on-line counseling; Action Research; Conducting surveys with beneficiaries and employers.

CONSLUSIONS: • The external coherence of policies that govern normative traineeship is not completely fulfilled; • The internal coherence of policies that govern normative traineeship is not completely fulfilled; • Manifestation of traineeship in the open market in private sector is not regulated by law; • There is a need to create systemic laws that will regulate all the forms of traineeship, in order to ensure the quality of training, protection of labor rights, unified monitoring of policy development effects and sustainability goals at the level of policies.

ANALYZE LAW ON VOCATIONAL TRAINING OF PERSONS WITH AQUIRED HIGHER EDUCATION DEGREE (Official Gazette of Montenegro, No 38/2012) This law regulates the Government's program of vocational training of university graduates.

INTERENAL COHERENCE After the first year of implementation of the Law on vocational training of Persons with Acquired Higher Education Degree (hereinafter referred to as: the Law on Vocational Training), in practice there have been different interpretations of its certain provisions, which has pointed to the internal incoherence of the policy. The analysis of the content and implementation of this policy was carried out by the institutions responsible for its implementation, as well as by beneficiaries and organizers of traineeship. In addition, it was based on the feedback received through SOS lines and on-line counseling services, which were provided for this purpose. Its results indicate the necessity of immediate and precise standardization of certain articles of the Law. In this way, it will contribute to the improvement of the quality of programs and effective implementation of the policy..

ANALYZE ISSUE 1 – Subject of the Law Article 1 of the Law provides that, in accordance with this Law on Vocational Training, university graduates who have no work experience in a particular level of education need to undergo training. Such a set of norms implies different interpretations, which can lead to confusion in terms of the purpose and possibilities of implementing the very program.

By analysing the content of this norm, there are two questions: 1. Does the beneficiary who has attended and completed a vocational training programme at the undergraduate level, have the right to apply for the program again after the completion of the specialist, master's and other studies? If it was possible, it would be inconsistent with the provisions of Article 7, Paragraph 1 of the Law which provides that only once user be beneficiary of vocational training programme (except in specific areas), and after completion of training can not use the apprenticeship (mne: pripravnički) 2. Simultaneously, there is a dilemma if a person who completed an vocational training programme in line of undergraduate studies, after completion of specialist and master’s degree, can enter into employment as a apprenticeship (mne: pripravnički).

Apart from the ambiguity of the subject of the law, the analysis pointed to the third possibility for misinterpretation of Article 1 of the Law, which provides that a person who acquired higher education, and who has no work experience at a particular level of education "undergoes vocational training in compliance with the Law." In this way dilemma may be created whether professional development is recognized as an obligation or as the matter of choice of people with university diploma. Such definition of the norm does not affect the quality and implementation of the programme, but it could spark off a debate.

ANALYZE ISSUE 2 – Rights of users Article 2, Paragraph 2 of the Law defines that "vocational training is performed without employment contract, according to the training program for a specific area, which has been adopted in accordance with the special law." However, in Article 13, the Law provides that to the users of vocational training in relation to his/her rights, obligations and responsibilities, the general labour legislation shall be applied, unless otherwise provided by this Law. Given that the vocational training is performed without employment contract, another provision of the Law which provides that general labour regulations such as the Labour Law, the General Collective Agreement, etc. shall be applied to the beneficiaries. It represents the collision of regulations and norms as these documents (Labour law etc.) do not recognize in its content vocational training or any other kind of traineeship arrangements.

This collision of norms brings uncertainties both in the implementation of the Law, and in the recognition of beneficiaries’ rights and obligations. For the sake of more detailed clarification of the issues and challenges of this regulation, we will deal with the users’ right to annual leave as a case study example.

Practice: Bearing in mind that general labour legislation is applied to users when the rights that are not defined by this Law on vocational training, it means that users, according to the Labor Law, shall be entitled to 1/12 of the annual leave (proportion part) for each month of work with an employer.

At first, however, the rights of many users were denied, precisely because they were not formally employed, which means that the Labour Law and the General Collective Agreement do not recognize them as their target group. Apart from doubts if they are entitled to one of the fundamental labor rights - the right to annual leave, a question of the length of the right was raised, especially by the users engaged in education area. The holiday season is defined as the longest lasting leave and in consistent practice it means that users engaged in education are necessarily entitled to annual leave during the collective holidays.

Users emphasized that competent institution referred them to the UFTUM SOS-line to obtain information on the right to annual leave, which brought additional confusion due to the fact that UFTUM could not give an official position on this matter, just an opinion. It turned out that for a long time the relevant subjects were not sure how to determine this issue, so that, until the beginning of July, it was publicly announced that users of vocational training programs in accordance with Article 13 of the Law and in accordance with Article 65 and 66 of the Labour Law exercised the right to annual leave for a period of 15 working days. However, in this announcement, though affirmative in certain parts, consistent application of general labour legislation can not be perceived, given the fact the days of annual leave are counted as duration of 9 months of training programme, and not after traineeship programme is terminated. This leads to dilemma which regulations competent institutions referred to in the announcement.

Calculation of annual leave would be carried out according to the following formula:

AL= 20 (number of minimum working days according to Labour Law, Brench agreement etc) / Xmonths (number of months spent at work till the day when users submit holedaz leave request) We should also note the additional challenge of interpreting this standard, i.e. when calculating the days of annual leave, taking into account the existence of different collective agreements that also fall into the general labor legislation. In this case number of minimum 20 annual leave days proposed in the Labour Law could increase to 21, 22, 25, etc. if annual leave based on branch and individual collective agreements. In that way annual leave will be calculated differently in different branches of industry.

On the other hand, the problem in the application of general labour legislation has encountered a different application in practice by educational institutions. It is well known that not all schools terminated traineeship of users during the holidays, after 15 days of regular holiday. A number of university graduates who performed vocational training in education were deprived of some days of traineeship. Actually, given the specificity of this sector, pursuant to labor regulations, annual leave in education is the longest. Given the fact that the program lasted during the summer holidays, program users were deprived of vocational training for nearly a month in comparison to other university graduates who underwent training in other sectors. In that regard, the reaction of part of employers from education sector was justified, which was directed towards the considering the possibility to start the program of vocational training in September, so that its duration could overlap with duration of school year, and in that way avoid doubts about the (non)mandatory extending the programme for the period when institutions did not perform activities during the holiday and provide all program users with equal rights when it comes to the annual leave.

ANALYZE ISSUE 3 - Duration of traineeship and the right to an apprenticeship (mne: pripravnički) Articles 6, 7 and 9 of the Law set out the following cases of: a) Return to the same employer, b) Transfer to another employer under certain circumstances, c) Exception to the rule that users of vocational training can not be employed as a apprentice (mne: pripravnik).

However, none of the above-mentioned articles define criteria and conditions the rights are exercised.

Article 6 of the Law – Duration of training and return with another employer: Paragraph 1 defines the length of vocational training. According to this Paragraph vocational training of users shall last nine months, and is recognized as work experience for a period of 12 months as a condition for taking appropriate qualification exam with acquired higher education.

Practice has shown that the majority of users, especially those who undergo training in the field of education, could not get appropriate answers from the competent institutions about taking a qualification exam for teachers. Great number of them got the following answer – that they will get a certificate on traineeship, but schools do not have any responsibility for their passing the qualification exam and perform According to the obtained information, a majority of schools does not consider users of programme to have the right to take the qualification exam given that the Rulebook on taking the qualification exam states that this right shall be exercised after 12 months of vocational training. This indicates that the application of this Article of the Law is inconsistent in practice. According to the obtained information, there are serious indications that the cause of the discrepancy lies in the insufficient knowledge of the contents of this policy, which states the necessity to harmonize other regulations with this Law. This issue will be addressed more thoroughly in ”external policy coherence.”

On the other hand, many graduated teachers underwent vocational training in private schools,

which offer extracurricular activities. For that reason it was questionable in what way they should pass the qualification exam, especially its practical part. Particularly aggravating circumstances for programme users who faced the above-mentioned problems (not only in education but in other occupations), remains the fact that the Law explicitly provides that vocational training users after completing the program can not be employed under an apprenticeship/traineeship training contract, and are thus completely unable them to pass a qualification exam and meet requirements for further work in educational institutions.

Paragraph 2 provides the opportunity to continue traineeship with another employer. The paragraph accurately states that a user who did not spend nine months of vocational training is entitled to continue vocational training with another employer under the same program he/she began vocational training. It is not clear how the User continues vocational training for another employer on vocational training, or whether he/she is bound to wait for a new cycle of vocational training and apply for it once again. As a consequence, the user is either treated as other applicants and is paired with an appropriate employer, or finds an employer in the open market who will enable him to continue the program until the fulfillment of 9 months as prescribed by the programme.

Article 7 – Exception to the rule for exercising right to apprenticeship (mne: pripravnički) The law provides an exception to the rule that vocational training shall last 9 months, and that the user who underwent traineeship can not be employed as a apprentice (mne: pripravnik). In fact there is a possibility that the user who underwent vocational training in the court, at the state prosecutor's office, attorney at Law, public executors and notaries is entitled to further vocational training as an apprentice.

Based on content analysis of documents, it was concluded that conditions were not clearly defined with respect to the possibility of continuing training of users who were trainee in the court, the state prosecutor's office, Attorney at Law, public executors and notaries. It is assumed that these people, after 9 months are left to the free market on their own to find a possibility to continue training until the requirements for taking appropriate qualification exam are met. Also, they do not bind the entities where they spent nine months to keep them until such requirements are met.

Furthermore, in addition to the aforementioned, there were also doubts related to the question: "Are users of vocational training programme who are currently involved in, or completed vocational training, completed a new study program, have the right to get employed as trainees or to apply again for the program after gaining a new qualification (finish new faculty)? ".

Immediately after the process of employers’ and users’ application for another cycle of vocational training programme, website of the Human Resources Management Authority announced that the persons who gained another university diploma are entitled to apply for another round of programme with new qualification and gain experience to work independently on the jobs of the occupation they studied. However, the following remains unclear: "Can users who are in the first qualification traind, instead of vocational training, be employed as a apprentice after acquiring new title?'.

Article 9 - Continued training with the same employer under certain conditions Paragraph 2 stipulates that vocational training is prolonged in case of user’s absence due to temporary inability to work on regulations on health care and health insurance and maternity leave, and that in such cases shall not be entitled to wage compensation. As in the previous analysis (Article 7 – transfer to another employer), it remains unclear how this Paragraph can be

applied in practice, i.e. what criteria for continuation of vocational training are there and if the user has to wait the beginning of the next round in that case, and whom to address.

On the other hand, hypothetically speaking, if a female user who exercised her right to maternal leave should continue vocational training, and if in the meantime there were changes in terms of employer’s status, there is uncertainty on her exercise of rights? In this as well as in the previous case the following remains unclear: "Does the period of training with the first employer count when continue with training with another employer, and whether users who did not meet the quota of nine months, however, are an exception and have the right to get employed as a trainee?”

ANALYZE ISSUE 4 – Inspection of the Law application Article 15 of the Law stipulates that the inspection of its implementation is performed by labour inspector, which presents another example of where vocational training persons are equalized with formally employed persons, despite the provisions of Article 2, Paragraph 2 of the Law. A number of users of the vocational training on several occasions addressed the UFTUM Youth Section and ADP ZID, to consult with them and get a legal aid with regard to submitting a petition to inspection bodies for the protection of violated rights. What is evident is that this provision of the Law is not consistently applied in practice, considering the fact that users of programs who addressed this body did not get a positive response from them, because the representatives of the state bodies, in cases UFTUM is familiar with, emphasized that they can not provide protection because they are "not formally employed". Apart from the fact that UFTUM possessed information about users’ addressing Labour inspection, at least orally, the reply of the inspection upon the request for free access to information, reads that this body has not recorded a single case of users’ report that refers to the violation of rights, and therefore not a single case was prosecuted.

ANALYZE ISSUE 5 - Incentives Article 11 of the Law stipulates that if the employer seizes this opportunity to independently provide funds for wage compensation to a vocational training user, and the paid amount may be considered as paid tax. Pursuant to Article 11 Paragraph 2 of the Law on Vocational training on University Graduates ("Official Gazette of Montenegro", No. 38/12), the Ministry of Finance issued the Rulebook on the recognition of paid compensation to users of vocational training users as overpaid taxes. Answer of Human Resources Administration to a Request for free access to information, showed that the number of submitted requests for recognition of paid compensations as paid tax by employers - 4 and by the same employer for 4 -month period in the municipality of Podgorica while in other municipalities there have not been such requests by employers.

In practice, there were examples of employers providing additional costs (reimbursement for travel expenses) for users in addition to compensation provided in the Budget, there are no additional tax reliefs or other incentives to employers who allocate means for the benefit of users.

ANALYZE ISSUE 6 - The quality of program implementation and evaluation The Law as such was created exclusively for the purpose of university graduates undergoing vocational training, with an aim to prepare them for the labor market, improve their competencies to work independently and supplement theoretical education with practical, and therefore it is surprising that not a single article of the Law is dedicated to the manner of undergoing vocational training, which is entirely left to its regulation within certain acts at the level of employers.

The Law does not contain a certain minimum quality requirements that this program has to meet, and in details it can be regulated by either secondary legislation or employers’ acts in order to ensure a high quality, comprehensive and useful program and impose the obligation of implementing it in a way that employers develop quality human resources, and enable users to be competitive in the labour market.

The only employer’s administrative responsibility toward the state is defined by Art. 10 of the Law, which imposes an obligation of sending monthly statements. Practice has shown that this obligation imposed on employers has no purpose, except for the counting of users who are still engaged in training. On the other hand, these statements are neither functional nor efficient and can not provide a realistic insight into the development of competencies of program users.

EXTERNAL COHERENCE ANALYZE ISSUE 1 - Explanation of establishment and harmonisation On the occasion of its adoption, this policy was verified in compliance with the EU acquis, which was supported by the text of exposition and harmonization of the Law. The law is adopted pursuant to Article 16, item 5 of the Constitution of Montenegro, which provides that the law regulates the issues of interest for Montenegro.

This law was passed as lex specialis, so there is no need to harmonize it with the existing laws except the Constitution of Montenegro. Conversely, it is necessary to comply with this Law with other laws and secondary legislation, which regulate traineeship arrangements of university graduates.

However, if the vocational training is subsumed under active employment policy measures implemented by the Employment Agency, in that case, there is a question on the reason why the vocational training of university graduates is defined by the systemic law, while the other measures of active employment policy, aimed at education and training, are implemented through projects implemented by the Employment Agency in collaboration with other relevant stakeholders, as it was the case with, for instance, Work practice for university students which proved to be more successful than vocational training programme.

ANALYZE ISSUE 2 - Law on vocational training – General labour legislation In addition to the noncompliance of the Law with existing programmes in certain industies, the abovementioned coalision of norms, concerning the persons on traineeship programme, on whom general labour legislation which are not regulated by this Law are applied, raises a question on the very application of the Law, given that the general labour legislation of procedure, the Labour Law and the General Collective Agreement, relates to employees and do not include traineeship arrangements. Hence, no wonder many practices caused dilemma and the lack of adequate responses, when it comes to issues of rights to increased earnings compensation during official and religious holidays, overtime pay, right to annual leave and day break, paid time-off days, as well as the very important issues related to the termination of vocational training, which are not mentioned in any article of the Law. Termination of the relationship

between the employer was only specified in the standard contracts of vocational training posted on the website of the Employment Agency of Montenegro and Human Resources Administration as a sample for employers to use it as their own contract template.

ANALYZE ISSUE 3 - Compliance of regulations and training programs The biggest problem of this area is the external policy coherence of vocational training and the very problem field that is related to other policies compliance with the Law on Vocational Training. The whole issue lies in the lack of promotion and control of the implementation of Article 17, which reads that the existing programs of vocational training in a particular field of activity should be complied in terms of their duration within the period of 60 days of the date of entry into force of the Law. Practice has shown that the employers’ ignorance of these provisions led to their assurance that they did a favour to programme users by allowing them to continue training for another 3 months without being paid, in order to meet condition of 12 months for passing vocational exam.

Law on Courts, Law on Notaries, Public Executors, through its rulebooks (for example. Rulebook on acquiring the title of teacher etc.. are not aligned as required in Article 17 of the Law on Vocational Training, what confuses programme users and employers. During the round table discussion with employers, a couple of examples have emerged. Employers highlighted additional importance of the program - an opportunity to provide users with three months of training in order to meet requirements for passing qualification exam. These are only some of the problematic fields that have emerged during the monitoring of the application of the Law. Out of the laws that have been analyzed, the Law on Health Insurance is the only in its secondary legislation that regulated the opportunity to acquire practical knowledge through vocational training. But the question is why persons in vocational training have unequal position in comparison to trainees in terms of getting specialization. According to the analysis of the norm, persons who underwent vocational training can not get specialization regularly, if they did not undergo classic apprenticeship. In that case, the possibility of obtaining specialization depends solely on the will of the competent Ministry. The interpretation of this provision would be that persons who enter into employment (apprentice) have the advantage over those who are not employed (trainee). As a consequence, these young people at the very beginning have to give up on their right to specialization because of the fact that the Law on Vocational training do not allow trainee to use apprentice possibility (or any other) after traineeship programme. So, despite the fact that the Rulebook is comprehensive when it comes to the length of training for specific occupations, the method of training, mentor responsibilities, the application for and passing qualification exam, the composition of the Commission, and other factors necessary for the implementation of quality training, there is a dilemma about the different treatment of trainees and those in engaged in apprenticeship.

The main problem with this Rulebook, is Paragraph 2, Article 1, which states that the provisions of this Rulebook may be applied to highly educated persons who undergo vocational training in medical institutions, or perform volunteer work, in accordance with the law, which is not a binding norm, the proposed plan on the method of performing vocational training and opportunities of getting specialization, may or may not be applied to these persons.

SEPERATE SYSTEMIC LAWS INTERNAL COHERENCE Law on courts Rulebooks on the plan and method of recruitment and training of apprentices and „volunteers” Article 116 and Article 117 of the Law on Courts ("Official Gazette of Montenegro", No. 5/2002 49/2004 and Official Gazette of Montenegro ", No. 22/2008 and 39/2011), are related to a) "judicial apprentice” and b) "judical volunteer".

As a judicial trainee, law graduates who meet the general requirements for employment in state bodies may be admitted to employment for a period of two years. There is a second case that court may admit law graduates to practice without remuneration, for the purpose of vocational training, and upon which the court president shall decide. However, the criteria for the court president’s decision on applicants who will be admitted practice as a judical trainee or a voluneer trainee is not defined in the Law and secondary legislation. The practice recognizes a situation in which a person who has started training as a volunteer, after one year of training, gains the status of trainees, as well as when he/she does not acquire the status of trainees. In addition, the trainee or volunteer, after 2 years of training (it lasts 2 years), is allowed to stay in the court for at least one more year without compensation. All these situations are realized without clearly defined criteria and procedures of the possibilities and manner of status change. And at this point, there is a question of unequal status of apprentice and „judical volunteers”, as it is expected that in the course of the apprenticeship person exercises labor rights and has a full protection, whereas this is not the case with the „volunteers”, because it is not completely clear on what basis and how he/she becomes a volunteer, especially since the Law on courts does not propose the signing contract for volunteers..

The Law of State Prosecutor's Office, Article 121 of this Law defines who may have the status of volunteers, duration of voluntary traineeship and two main criteria crucial for his/her employment to be extended after the expiry of the training period for an additional year. The criteria are that the person who has passed the bar exam within three months after the end of the internship and if he/she distinguishes himself/herself through outstanding performance during the course of the training.

The State Prosecutor's Office, as the Law on Courts, in Article 122 stipulates that a law graduate who meets the general requirements for employment in public bodies, for the purpose of acquiring required knowledge and meeting conditions for taking the bar exam, shall be admitted to practice in the State Prosecutor's Office as a volunteer. As in the Law on Courts, the criteria which determine whether a person will be accepted as trainee or volunteers are not defined.

The Law on Health Care The Law on Health Care do not contain provisions related to „volunteering“ and traineeship, but refers to the detailed conditions for performing training and passing qualification exam to be defined by secondary legislation. However, the possibility to practice not only through the internship program, but also through vocational training and volunteer work is regulated by secondary legislation. But the question is why in the above-mentioned rulebook the persons engaged in vocational training are treated unequally in terms of getting specialisation in comparison to trainees. This was discussed in the framework of external

coherence of the Law on vocational training of Persons with Acquired Higher Education Degree.

EXTERNAL COHERENCE Terminology - volunteer according to the Law on Courts / the Law on Volunteering Article 12a of the Law on Amendments to the Law on volunteering introduced a separate contract on the voluntary work that can be concluded with a person who wants to be engaged in vocational training as a „volunteer” and acquire required knowledge and skills to work in their profession. Furthermore, volunteering shall be recognized as work experience and as a condition for taking the qualification exam. Amended in such a manner, volunteering is equalised with formal employment in terms of duration, thus it may last 40 hours per week. Such amendments made volunteerism senseless and abused in practice, it is to say, the active participation of citizens is equalised with unpaid work. Bearing in mind that this is Lex specialis law, and the fact that the very Law on Courts is Lex specialis, the question is whether so-called volunteers in the courts perform volunteering in accordance with the Law on Volunteering or the Law on Courts. This dilemma appears in practice and data on some courts who engage volunteers under the Law on Volunteerism, while others do so by the Law on Courts. The same dilemma rises in terms of the application of the Law on State Prosecutor's Office. This situation creates a dilemma, whether volunteers in judiciary are those volunteers who are regulated by the Law on Volunteerism, which, among other things, provides the required contents of their contract, possessing a volunteer’s booklet, compulsory insurance against accident at work, the rights and obligations of volunteers, information on expenses in connection with performing volunteer work and other issues important for performing volunteer work. If not, then there is a question of whether there should be a mandatory signing of the contract with the volunteers in the court, since the Law on Courts and the Law on State Prosecutor's Office do not provide such an obligation. In practice it is known that volunteers do not sign any contract when they enter court. Only the beginning of their voluntary work is recorded, what completely questions the scope, and the way of exercising their rights and obligations.

Alignment of secondary legislation with the Law on Vocational Training Having an insight into available courts’ rulebooks on the plan and method of recruitment and training of trainees and „volunteers” in 2013, it is clear that they are not fully complied with the Law on vocational training of Persons with Acquired Higher Education Degree. What is noticeable is that in some of the rulebooks only trainees and volunteers are mentioned, but it is not the case with persons engaged in vocational training according to Law on Vocational Training. However, those which indicate that they relate to persons in vocational training, remain incompletely defined in terms of the length of training programs for vocational training users. The above-mentioned rulebooks, which were available for inspection, clearly prescribe the manner of vocational training of trainees and volunteers, in terms of content, method of implementation, mentorship, their rights and obligations; but even the rulebooks which mentioned users of vocational training program, did not specify a gap in the Law on Vocational Training, which refers to the manner and conditions under which persons in vocational training after 9 months continue vocational development, and their status after the 9th month. Moreover, whether a person will have the status of trainees or volunteers depends only on the decision of the president of the court, without clearly defined criteria for making above-mentioned difference,

except that it is known that it is also depends on the available budget for a year. What should be emphasized is that a number of the rulebooks provides that the method of training of trainees and volunteers, in the future, shall be carried out according to the Law on Vocational Training of University Graduates.. In this way, the rulebooks suggest that the provisions of this Law shall apply to the training of trainees and volunteers. By its nature it can not be the basis for the training of these two categories, since their training is stipulated by different laws and secondary legislation and its characteristics significantly differ from vocational training which is the subject of the Law on Vocational Training of University Graduates.

Other laws Other systemic laws, as well as rulebooks for acquiring a title/obtaining a license in specific professions (Law on Notaries, the Law on Civil Servants and State Employees, etc.), in its content do not mention the persons in vocational training as a specific category, which is contrary to the Article 17 of the Law on Vocational Training of University Graduates. In fact, it is proposed by law or secondary legislation that every industry is required to provide graduates with work experience, so that they could exercise the right to take certain qualification/vocational exams or obtain a work licence, should recognize vocational training as a special form of arrangement. In some of the abovementioned examples we saw that the programs and regulations are not aligned, but also that the institutions / companies are not well informed and acquainted with the provisions of the Law on Vocational Training of University Graduates (especially Article 17).

LAW ON EMPLOYMENT AND EXERCISING RIGHTS WITH RESPECT TO UNEMPLOYMENT INSURANCE ("Official Gazette of Montenegro", No. 14/2010 and 45/2012) INTERNAL COHERENCE The economic crisis has caused a significant reducton of amount of funds to finance the AEP (Active Employment Policy measure) from 12 million euros in 2008 to 4.3 million euros in 2012.

Some of the measures of Active Employment Policy are: intermediate roles in employment, professional orientation, financing the salaries of trainees, subsidy for employment, education and training of adults, etc. In the previous period, the Employment Agency has implemented a number of programs aiming at increasing the employability of young people, motivation for selfemployment, seasonal employment and entrepreneurship.

In the legal framework for the first time the Law on Employment and Exercising Rights with respect to Unemployment Insurance ("Official Gazette of Montenegro", No. 14/2010 and 45/2012) have introduced the National Strategy for Employment and Human Resource Development which determines strategic priorities and objectives of employment policy at the four-year level. This Law also stipulates that the Government annually, in accordance with the strategy shall adopt annual action plans for employment, based on which the Steering Board of the Employment Agency of Montenegro adopts the annual work plan. The main priority of the Strategy is to increase employment and reduce unemployment, and increase efficiency of activation policies with special emphasis on the integration of long-term unemployed persons and young people in the labor market. In addition, improvement of knowledge, skills and competences is identified as a second, it priority increases employment opportunities and increases competitiveness through formal and informal education and training, with an attempt to strengthen links between education and the labor market .

Active employment measures in Montenegro are proposed by the Law on Employment, and more clearly defined in the Employment Action Plan. This includes information on the possibilities and conditions of employment, intermediate roles in employment, professional orientation, financing the salaries of apprentice, support for self-employment, subsidy for employment, education and training of adults, professional rehabilitation of hard-to-employ persons, public works, scholarships and other measures directed at increasing employment, i.e. at reducing unemployment.

By analyzing the content of the documents it can be concluded that the internal coherence of this policy is at satisfactory level if only parameters of active employment measures are considered, as there are no major barriers that could significantly affect its implementation.

EXTERNAL COHERENCE As mentioned in the previous paragraph, the internal coherence of this policy is considered to be at satisfactory level. However, more significant effect in terms of purpose and/or other policies that set norms for similar content is achieved if we analyze the external coherence.

Employment- vocational training If we look at the broader context and compare the Law on Employment with the Law on Vocational Training, we can draw a conclusion that vocational training according to their characteristics and purpose may belong to the domain of active employment policy. The entire program is implemented by the State, and on the other hand its content can be classified as a measure of "education and training of adults" or "other measures directed at increasing employment, i.e. at reducing unemployment“. This conclusion is supported by experience from practice. By analysing some of the Employment Agency’s projects, which are part of the active measures, such as: "A Chance for Young Managers", "Preparing Students for the Labor Market", etc., one can see that they are focused exactly on what is the basic objective of the Law on Vocational Training, that of acquiring skills and competences.

If we take the abovementioned premise into consideration, further analysis of Article 44 of the Law on Employment, showed that the conditions, methods, criteria and scope of the implementation of active measures are proposed by the competent Ministry. This provision indicates that the second legislation regulates the issue of active employment measures implementation, or through a variety of programs and projects, but also through specific laws such as the Law on Vocational Training.

Therefore, whether the vocational training program shall be regulated by seperate Law or through a project of the Employment Agency of Montenegro, such as "Work practice for university graduates", which is also aimed at university graduates to enter the labor market, immediately after graduation, to gain work experience through practice and employment.

Employment - Education of Adults The second analysis could be carried out by comparing the Law on Employment and the Law on Adult Education. The Law on Employment states that education and training of adults is one of the active measures of employment, whereas the Law on Adult Education indicates one of basic principles of the correlation between work and education, in order to acquire knowledge, skills and competencies or gaining relevant qualifications for successful living, work and personal development.

Comparison of the two laws raises the question of accuracy in terminology, i.e. whether the "adult education and training" is the same term. Given that it is the subject of two different laws, there is a question how it should be regulated If they are completely different terms, should they be separately regulated? If it is the same term, there is a question why it is regulated by two laws in differentl manner.

LAW ON ADULT EDUCATION ("Official Gazette of Montenegro ", No 20/2011 from 15 April 2011) INTERNAL COHERENCE The Law on Adult Education is comprehensive as it relates to how adult education is conducted, principles underlying adult education, education programs, adult education, mode of financing and other factors relevant to the implementation of the Law. One of the fundamental principles, the adult education is based on, is the link between work and education. Education programs implemented through practical work can be accomplished with employers and other organizers of education. If practical work is executed within the premises not in possession of an organizer of education, the mutual rights and obligations of the organizer of education and the employer with which the practical training is executed shall be regulated by a contract, whereas the mutual rights of attendants and the employer shall be regulated by a contract on practical work. However, only one article is dedicated to the rights of attendents (Article 25), which among other things suggests that the mutual rights and obligations between the attendent and employer shall be regulated by the contract (the place of education, duration of education, compensation, etc.). In this way, given the fact that the content of the contract is not fully specified, there are many doubts, when it comes to the way practice is performed, minimum quality of the practice, and other rights and obligations of the organizer or person who is educated. Difference between education and vocational training remains insufficiently defined, which once again points to insufficiantly precise or adequate terminology.

EXTERNAL COHERENCE If we start from the above-mentioned not clearly defined terms of certain programs (vocational training, or acquisition of key skills, training, etc.), there is a question of the differences between adult training and vocational training of university graduates. In fact, if they are the same or similar programs, the question is why uniform programs are not accredited in a way to be valid in all areas, but the same things are regulated by different legal solutions.

In the previous section there was a dilemma on coherence, or difference between active employment measures such as the "adult education and training", and adult education prescribed by the Law on Adult Education.

LAW ON VOLUNTEERING (“Official Gazette of Montenegro", 26/2010, “Official Gazette of Montenegro", 14/2012) INTERNAL COHERENCE Volunteering is voluntary and free investment of time, knowledge and skills for performing of services or activities in favor of another person or for the general welfare of society. Article 168 of the Labor Law provides that employer may conclude the contract of volunteer work with the unemployed person, in accordance with the special law. In this way, the possibility to start drafting a separate law which would deal with this matter has arisen. However, the Law on Voluntary Work, particularly its amendments of 2012, provides space for the many abuses of this institute, whose meaning and character lies in the fact that volunteers invest their time and work for welfare of society, and does not present a substitute for formal work.

Article 12a of the Amendments to the Law on Voluntary Work stipulates that contract on the volunteering may also be concluded with a person who wants to gain professional education and special knowledge and skills to work in his/her profession. Volunteering performed in such a way shall be recognized as work experience and as a prerequisite for taking the qualification exam, and by signing the contract they do not lose their rights of unemployed persons. The article formulated in such a way nullifies the whole purpose of the Law, as it is non-compliant with the rest of the text, particularly with Article 1, which defines volunteering as a voluntary and free investment of time, knowledge and skills for performing of services or activities in favor of another person or for the general welfare of society, not as a possibility to have labour force for unpaid work as defined by this Article

EXTERNAL COHERENCE Rulebook on Training of Trainees, Professional Exam and Vocational Training on Civil Servants involves the term volunteer - trainee and suggests that the provisions of the Rulebook apply to these persons pursuant to a separate contact. Terminology which contains two completely different and separate institutes is not fully applicable, and thus causes confusion in people who act as volunteers, in terms of their rights and duties, as unlike people under a traineeship contract, they are not employed. Beside trainees and volunteers, the same Rulebook does not involve the category of persons on vocational training i.e. it did not go through any necessary amendments in order to comply with the Law on Courts, the Law on State Prosecutor's Office and the Law on Vocational Training of University Graduates.

When it comes to external coherence laws related to the training of judicial trainees, volunteers and persons in vocational training, it was discussed the lack of a clear distinction between volunteers engaged under a separate contract on the voluntary work, in accordance with the Law on Volunteering, and volunteers engaged pursuant to the Law on Courts, which does not provide the obligation of signing of the contract with the volunteers undergoing vocational training .

LAW ON VOCATIONAL EDUCATION INTERNAL COHERENCE In accordance with this Law, vocational education is acquired at the lower, middle and higher levels of vocational education. Article 3 of the Law on Vocational education („Official Gazette of Montenegro“, No.64/2 ) defines the following: „vocational education Vocational education shall be provided by: schools (school form of education), or by other legal or natural persons (hereinafter referred to as “ the employer”) in cooperation with school (dual form of education). The conditions the employer must fulfill for the performance of vocational education regarding the space and the equipment shall be defined by the Ministry competent for the affairs of education.“ This law also stipulates that in dual form of schooling, mutual rights and obligations of students (apprentices) and of employers shall be regulated by a contract on education, which shall be concluded between the employer and the student.

This law defined the content of contract on education, responsibilities of students, responsibilities of employer, obligation of school, remuneration, and conditions for the termination of contract, employment rights, and protection of students at work, insurance period, and supervision.

Provisions of the Law on Vocational education („Official Gazette of Montenegro“, No. 64/2 ) are prescribed as follows: - Schools and employers shall assess the level of practical education of students, who are educated with the employer, at the end of each school year.

- A student shall have the right of remuneration during the duration of contract on education with the employer; - If the contract on education has terminated because the employer has not fulfilled his obligations, the school shall take over the obligation to conclude a new contract with another employer; - A student shall exercise the rights stemming from employment during the course of practical education with the employer, in line with the labor legislation; - A school and an employer shall be in obligation to train the student in basic measures and means for the protection at work during the practical education delivery; The supervision of the application of the provisions of this Law relating to the status of a student with the employer shall be carried out by the competent labor inspection.

During the period of dual education, the Centre for Vocational Education and Training analized dual form of education aiming at improvement of this type of education.

- Weaker employer’s interest in allowing students to be involved in the dual form of education and reluctance to pay remuneration and contributions to the students are noticable; - Employers complained of unfair competition, i.e. the grey market, and in order to continue to participate in the dual form of education they asked for those who take the students into the dual form of education the package of incentives to be set out (lower tax rate on supplies, equipment and tools ,since they are used as teaching aids); - Employers asked for their responsibility to provide remuneration and contribution payments to students to be terminated, but only to provide meal compensation and transportation;

-

There were no interested students in enrolling dual form of education in school years of 2007/2008 and 2008/2009.

7. Financing Provisions of the Law on Vocational education („Official Gazette of Montenegro“, No 64/2, Articles 46, 49, 54 and 56 ) are prescribed as follows: - An employer shall especially be responsible that the student is regularly paid obligatory monthly remuneration; - A student shall have the right of remuneration during the duration of contract on education with the employer. The amount of remuneration shall be 15% for the first and for the second year of the schooling at least, whereas it shall amount to 20% of the average gross salary of the employees in the industry sector of the Republic for the third and for the fourth year of education at least. .

- A student shall have the right to pension and health insurance for the period of education with the employer, in line with the law. The contributions for pension and health insurance shall be paid by the Republic for the first year of education on the - whole, and both employer and the Republic shall pay the amount of 50% for the next years; In order to support the establishment of dual form of schooling and reduction of employers’ responsibilities, the Ministry of Education and Science, in addition to paying contributions, took over responsibility to pay remuneration in the amount of 15% of the gross salary in the industry sector of Montenegro for the first grade students of the first generation (2004/2005) in all schools. Average gross earnings of employees in industry sector for the year 2013 was 271,03 euros.

In accordance with the letters of the Center for Vocational Education and Training from April 8, 2005, and 4 May 2005, the Ministry of Education and Science paid a total of 39,245.12 euros to bank accounts of schools. Their first payment in the amount of 16,986.36 euros was for the months of September, October and Novembar 2004. The second payment in the amount of 22,258.76 euros for the months of December 2004 and January, February and March 2005.

Schools were paid for remuneration and contributions of students. Vocational high school "Spasoje Raspopović" in Podgorica was paid 10,495.79 euros for 23 students; Vocational high school "Ivan Uskoković" from Podgorica was paid 8,670.39 euros for 19 students. Vocational high school in Nikšić (22 students) and Secondary mixed school "Ivan Goran Kovacic" from Herceg Novi (22 students) were paid 10039.47 euros each. Monthly remuneration per student was 40.65 euros, and amount of monthly contribution per student was 24.54 euros. For each of the 86 students in the dual form of education in school year of 2004/2005 the Ministry of Education and Science paid 456.34 million - 284.55 euros for remuneration and 171.78 euros for contributions.

During the period of dual education of students, employers did not fullfil their obligations towards students in terms of either remuneration or contribution payments.

Students who enrolled in first grade in 2005 / 2006 (in Vocational High School "Ivan Uskoković" in Podgorica - 13 students graduated and Vocational High School "Spasoje Raspopović" in Podgorica - 19 students graduated) and in 2006 / 2007 (in the Vocational High School "Ivan Uskoković" in Podgorica – in the third grade there were 16 pupils) were not paid remuneration and contributions.

In the Contract defined by the Centre for Vocational Education, which was signed by an employer and a student , i.e. a parent, Item 10 states that the Ministry of Education and Science

pays remuneration even for the year 2005/2006. In the Ministry of Education and Science do not possess a document proving this fact.1 From the above it can be concluded that the dual form of education, even though regulated as a special form of employment yet is implemented as traineeship. Therefore, legislation in this area should be reconsidered and thus find more efficient and effective models of organizing training during secondary vocational education Regarding high schools, they are not included in the dual form of schooling, even though this form of education is significant for the professional orientation of high school students.

1

Informacija za Vladu CG o dualnom obliku obrazovanja

EFFECTIVENESS AND IMPACT

SUBJECT OF ANALYSIS AND METHODOLOGY OF RESEARCH SUBJECT OF ANALYSIS Effectiveness of public policies indicates the level of fulfillment of given objectives of the public policy, while the impact indicates the positive and negative changes which emerged and/or which are a consequence of implementation of a certain policy. The analysis involves in detail the Program for vocational training, considering that other programs do not include a large number of beneficiaries which could significantly affect the decrease of the level of unemployment of young people in Montenegro.

Research questions which were answered to in detail during the process of evaluation are: EFFECTIVENESS: (program objectives and expected outcomes with regard to achieved effects and outcomes) 1. To which extent did the changes occur after the intervention compared to planned results, specific and overall objective? (are the results achieved, specific and overall policy objective)?

2. To which extent did external factors (assumptions) affect the achievement of results of the public policy?

3. What are the reasons for achieving or not achieving results and the purpose of the public policy?

IMPACT: 1. Which are the expected and unexpected positive effects of the public policy to beneficiaries, institutions and the labor market?

2. Which are the expected and unexpected negative effects of the public policy to beneficiaries, institutions and the labor market?

3. How does the logic of intervention of the policy affect the well being of all stakeholders of the public policy?

4. According to the opinion of beneficiaries and stakeholders of the public policy, what is the impact of the policy to their position in the system (do they have or not benefits from the policy and does it harm them or not)?

5. What impact did the logic of intervention of the policy to the institutions which participated in its implementation and whether capacity building and institutions empowerment occurred? (quality of the model for the coordination of the program) 6. What would have happened if an intervention of the policy in this area did not exist?

7. To which extent can be measured the changes which emerged throughout the 9 months of the duration of the program for vocational training?

8. Are there capacities inside the institutions which will measure the effects of the policy to beneficiaries after one year from program implementation?

Methodology: • Surveying of beneficiaries and employers, consultation with employers, analysis of documents and of their content.

Conclusions and guidelines: • Creation of a framework for the quality of implementation of the program (selection, mentorship, reporting, level of competence, work conditions), • Creation of a good quality monitoring and evaluation system, • Improvement of competencies of all institutions implementing the program, • Improvement of quality of the level of information about the measures proposed in the Law.

ANALYSIS Impact of external factors to achievement of policy objectives As mentioned earlier, the policy was not created in accordance with the principles of good governance. In Montenegro, a recorded number of policies which were created this way does not exist, and it is assumed that a minor number of institutions use these mechanisms in the process of decision making. According to the principles of good governance, the policy makers should have done a comprehensive analysis of this area before the very creation, which would cover all criteria of the ex ante evaluation, and afterwards analyze the practice of the EU and SEE in this area.

This kind of approach would ensure a more realistic evaluation about the achievements of the policy itself and would create conditions for later evaluation of long term impact on the problem of youth unemployment in Montenegro. That would assume more established mechanisms of realistic assessment of youth progress during the program for vocational training and the rest of the existing traineeship programs, unlike the present state which leaves the possibility of personal experience of the program. By assessing the improved competencies, the youth has been left with a space to evaluate their achievement on their own, which does not always have to be realistic.

In other words, the surveying of beneficiaries, which was conducted by UZK and ZZZ, gave information about the level of satisfaction by the program from a personal angle, but not the real improvement and the competence of the youth based on certain criteria. Satisfaction could have come from a ‘’friendly’’ relation of the employer to the young people, then from obtaining a chance to instead of sitting at home, being included in work assignments.

The claim that every work experience is useful, regardless of the quality, level and complexity of the tasks being carried out is not questioned. However in this case we have to have in mind that the state invested a lot of funds for beneficiaries to gain knowledge and competencies, and which is hard to objectively measure due to the lack of mechanisms which would provide it. In order to do this analysis in a good quality way, it is necessary to develop M&E instruments which would provide an overview of the competencies

for a specific work position and develop models of measurement of implementation of those competencies. In this part, the Center for Vocational education would have a big role, considering that besides the model of measurement it is also necessary to develop programs for mentors who will know how to use the proposed model.

In addition to the specified assumption that was realized, there is also the problem of lack of analysis of this area which caused the adoption of the Law on short notice, and therefore there is a high degree of incoherence of the solution itself (see coherence). It is also necessary to mention that the existing criteria for the application and selection of candidates do not contribute in a large extent to the preparation of young people for the market and to the increasing of their competencies in the area of job search, which will result in young people who do not have experience in job search (sending a CV, cover letter and interview). For this purpose, it is necessary to create a model that will enable young people to select a number of employers, as currently is the case, and afterwards be required to apply directly to the employer and pass through the process of applying for a job.

OVERALL POLICY OBJECTIVE – The increase of the level of employment of youth in Montenegro By initiating measures in 2012 which regard the launch of the Program for vocational training of persons with acquired university education, the Government has made it possible to include a larger number of young people who do not have the required work experience, and therefore are not competitive in the labor market. The impact of these measures can be measured at least two years after the first generation of people in vocational training, with regard to the fact that young people in Montenegro on average wait for employment for 3.7 years and also if an M&E mechanism exists. For this reason, it is impossible to give an insight now about the impact of the policy on increasing the employment rate of young people in Montenegro.

On the other hand, to achievement of this goal contribute synchronized actions in different areas such as the economical policy of Montenegro, the educational and the employment policy, which also includes achieving specific objectives of these individual policies. However, if the analysis shows that from the perspective of the beneficiaries, this policy achieved its specific objective, the government can still draw conclusions and gain additional incentive for more constructive reacting in other areas that also strongly affect the achievement of the overall objective of this policy - economical policy.

Besides the aforementioned, it should be noted that there is no precise record about the increase in employment rate of young people through the use of other forms of traineeships. But this fact would not statistically make big deviations in the reduction of unemployment given that a very small number of young people were engage in this way compared to the total number of young people in the labor market and the number of young people who took part in the Government's program for vocational training of university graduates.

In order to measure the achievement of the overall objective of the policy in the future, the following indicators were proposed: -

-% of reduction of the rate of youth unemployment in Montenegro compared to the % from 2012 - By 2018 the level of youth unemployment reduced to the average for that age group;

-% of young people who, after a year of use of program for vocational training, have found employment compared to the total number of young people who have gone through the program; -% of young people who, after two years of use of the program found employment compared to the total number of young people who have gone through the program; -% of young people who found employment after two years, and have not used any other program to gain work experience;

As a part of the conducted research however, we looked at the indications of the program beneficiaries in the direction of their expectations for employment after the program, in order to provide input for future research.

There is no doubt that the possibility of finding/coming to or "getting" a job was still the main motive for beneficiaries to enter the program. With the beginning of the program, the hope became more realistic, and the expectations of employment at least a little more clear. There is also no doubt that the program participants had higher hopes for employment than it was pointed out to them and more than it was indicated to them. To this "excess of Hope�, participants of the program were chased by unemployment itself and the desire to come to employment as soon as possible.

To the question "Are there any indications you will get a job after the program you are attending?" obtained were, in our opinion, quite optimistic responses (see table). Of ten highly educated unemployed young people, three of them states that there are indications of possible employment, while seven of them have nothing on the horizon. The proportion of 3:7 can be assessed differently, but the fact that 30% of young people involved in the program have indications of possible employment, is very disturbing in the case those expectations are not met. Appearance of big disappointment must be anticipated, and a large passivation in job search is certain.

Indications about possible employment more often than others have those who were on the program in the public sector/public institutions (45%), followed by those who were on the program in the private sector (39%). These results are primarily worrying if you take the fact of the burden on the public sector and the current need to reduce the workforce in it.

Men have indications of employment more often than women; more often those who are 23-26 years old than those younger than or older than that age; those whose permanent place of residence and/or place of training is Podgorica and Niksic; those who have graduated Economics, Management, etc.., then technical faculties (Mechanical, Electrical Engineering...) and the Faculty of Law, Faculty of Political Science.

With the short-term unemployed, every third has an indication of possible employment, and with the long-term unemployed - one in five. Apparently, those seeking a job for a longer period of time (long term unemployed) have fewer job opportunities or are more realistic compared to those who are looking for a job for less than a year.

Three-quarters of those with indications for employment expect a job with the employer with who they are in the Program, and a quarter of them expect a job with another employer.

Table Existence of indications for employment after the Program and the length of waiting for employment (in %) Indication A year and less A year and more Average Indications for employment 65 80 70 do not exist Indications for employment exist Total

35

20

30

100

100

100

SPECIFIC OBJECTIVE - Increased employability and competence of the youth on the Montenegrin market and facilitation of the process of transition of young people from the educational system to the labor market; At the outset it should be noted that the policies for traineeship are not designed according to the principles of good governance, which in turn does not mean that it reduces/does not reduce their efficiency. Good governance principles provide the basis for a quality analysis of the intervention logics of the policy, but in this case, the researchers are obliged, based on the written laws, to reconstruct and create an intervention logic the Government intended.

Indicators of the specific objective are: 1. Increased level of development of key competencies with beneficiaries before the start and after the completion of the program for vocational training for level 1; 2. percent of fulfillment of the purpose of the program; 3. % of young people who believe that the program fulfilled its purpose compared to the % of those who understand the purpose of the program; 4. % of policy stakeholders who understand the purpose of the program; 5. % of young people who, after the completion of the program feel qualified to work independently in the position they were trained for; 6. % of young people who, after training, acquired the necessary competencies for the job;

Participants of the Program see its essence in two functions: 1) employment function and 2) the function of acquiring knowledge, skills and abilities to enhance employment opportunities.

Through a synthetic evaluation of the effects of the program, we tried to combine these two functions into a single score through perception of the effects of the Program. By summing the 10 indicators of the perception of the effects of the program, we found they had, on average, a mediocre score - a 3.14. The most common are the ratings that hover around that average 16% of them said they had little or no effect, 54% said they are medium, and 30% of them said they are large.

Within the framework of the synthetic indicator of the perception of the effects of the program, we used the following 10 indicators: knowledge and skills acquisition, assisstance to employers in finding good quality workers, knowledge of rights and obligations from the program, contribution to the reduction of unemployment, transparency of the selection of candidates for the Program, the transparency of the selection process of employers, clarification of ways of coming to a job, compliance of the Program with the needs of the labor market, contribution in increase of employment opportunities and optimism in finding employment. From a total of 10 indicators, three were assessed with fours, six with threes and one with a two. The best rated are: knowledge and skills acquisition, assistance to employers in finding good quality workers and knowledge of rights and obligations during the work engagement. On the other hand, the worst rated was contribution to increasing chances for employment. At the same time, it is the only indicator with the majority of poor reviews (1+2).

Further on, we will give an overview of specific indicators which entered this summative assessment of evaluation of the effects of the program for vocational training.

The purpose of the program from the perspective of beneficiaries’ personal motives Three-fifths (64%) of the surveyed educated unemployed young people see the purpose of the program as the acquisition of knowledge, skills and abilities for future work, and 26% in potential employment. On the contrary, every ninth of the total number of respondents, who in turn, did not know exactly what the purpose of the program was, nor were they able to specify their motivations for joining the program; are somehow "found" in the program, without understanding of their own need for employment and additional knowledge and skills in order to find jobs.

Institutional purpose of the program from the perspective of respondents – to the question about institutional goals of the Program (the word is, therefore, about understanding the state’s reasons for starting the program), 65% of respondents cited high unemployment and only 6% cited lack of appropriate knowledge and skills of young people in Montenegro. Here, the state is attributed another reason for starting the program. It is about political reasons - "primarily gaining favor of young people immediately before elections" - the offered response was accepted by 16% of the respondents. Finally, 12% of the respondents said "I cannot estimate the state’s reasons for launching this Program," and only 1% cited the labor market needs.

By linking the answers to these two questions – to the question about understanding the objectives of the Program mostly from a personal point of view (indicating personal motives of accession to the Program) and to the question about understanding the institutional purposes of the program (state’s reasons for organizing the program) - we come to important findings. The key finding of this comparison is the lack of overlap of individual motives of Program participants, and institutional goals of the program seen by the participants. Our respondents believe that the institutional reason for organizing the program, i.e. state’s reason for the program is recruitment - bringing employment opportunities closer (as we have said, the two-thirds of respondents thought). In contrast, among the personal motives dominates the educational function of the program - that function of the program is present in two thirds of the respondents in personal motivation.

The educational function of the program and capacity for future work: By a strong three (3.30) was assessed the contribution of the Program to increase the knowledge and training for job for which the young people were previously educated (question 22). 10% of the respondents

believe it is about a complete and 41% it is about a quite a contribution to increasing knowledge and training, then exactly 26% speak about partial contribution, 13% about small contribution and 10% about no kind of contribution.

The young people who participated in the program are mostly satisfied with the contribution of the Program to their acquisition of knowledge for future work (question 17). The average mark is a "poor" four (3.52). In particular, 17% of respondents is completely satisfied, 40% very, 25% somewhat, a little or not at all. The fact that every sixth person is dissatisfied, and largely satisfied are nearly three-fifths, it certainly represents a pretty good assessment of the Program.

This rating is even more important as the level of competence (knowledge, skills) before the Program was evaluated as relatively low (average score 2.86). Even 37% of Program participants said their previous qualification was little or unexisting, 28% said it was partial, and 35% that it was quite or complete (Question 21).

Of the total number of respondents who rated their previous competence as small or non-existent, 22% did not see any improvement of their competence, 23% raised their capacity for one level, 43% for two levels, and 11% for three levels.

The highest praise for the Program is that 36% of respondents said either that they are fully qualified to work independently, then 34% of them quite, which adds up to a total of 70% of young people who believe they are satisfied with their competence; 19% said they were partly trained and 11% they were little or not at all trained (question 23). Average proficiency of competence is 4.03.

In the context of previous assessment, to an extent surprise the answers to the question of how well the Program met its primary purpose (question 24). There is an average score of 3.27. Good marks about fulfillment of the purpose of the Program gave 44% of the respondents, 35% stated that the program somewhat fulfilled its purpose, and 16% believe the program did not fulfill its purpose (5% were not able to assess).

The explanation for this difference in assessment is that the program appears to still primarily be seen as a chance to get a job, and only then, in the background, as an opportunity for empowerment and skill acquisition. So although above it is stated that young people understand the purpose of the Program, this suggests that their motivation to join the program

was primarily to obtain employment. This is also confirmed by the assessment of the idea of the Program (average rating 3.76): 60% of Program participants gave a very good score, 26% spoke about the average quality of the idea, a10% about poor idea of the Program.

The effect of the program in terms of its contribution to the development of "specific, soft’’ skills and abilities in the average is assessed with a four (3.95). Each of the ten indicators was rated with a four, "stronger" or "weaker" (see table). The best assessed is the contribution of the Program to the development of work ethics and responsibility, and the capacity to adapt to new inter human relations (4.05, 4.04 respectively), and worse from the rest was assessed contribution to the development of usage and management of information (3.72).

Table Self-assessment of the contribution of the Program to the development of skills and abilities (composite score 3) Items – marks from 1 to 5 1+2 3 4+5 Total* AS BO** Work ethics and responsibility 6 14 80 100 4,05 3 Adaption to new inter human relations 5 15 80 100 4.04 3 Team work and communication 7 17 76 100 3,99 3 competencies Coping skills in the new environment 6 16 78 100 3,98 2 Flexibility and adaptability 6 17 77 100 3,98 4 Appreciation of the importance of loyalty to 8 18 74 100 3,91 4 the company Efficient usage of materials, equipment, 9 18 73 100 3,91 6 tools Organizing, management, planning 10 19 71 100 3,83 3 Problem solving and decision making 8 24 68 100 3,81 3 The ability to use and manage information 9 27 64 100 3,72 6 * Percentages in the 2-5 colon were calculated in relation to the total number of answers ** Percentage was calculated in relation to the total number of respondents

Level of development of 8 key competencies for lifelong learning with beneficiaries before the start and after the completion of the program for vocational training: Given that in our system there is no system of evaluation of acquired knowledge in certain workplaces, in our research, we investigated the self-evaluation of competencies of the beneficiaries before the program and a self-evaluation of competencies upon completion of the program. The following competencies were evaluated: digital competency; social competencies relationships, activism, conflict resolution; competency of learning how to learn; communication in the native language; entrepreneurial competency; competencies of cultural/artistic expression; mathematical, scientific and technological competency and communication competency in a foreign language (see Annex 1).

On average, before using the program the beneficiaries evaluated their competencies with 3.85, while the score after the program was 4.11. The greatest progress was made in the case of entrepreneurial competence - the number of fives increased by 22%, with an average score of 0.46 (see table); then in the case of competence learning how to learn – the number fives is higher by 19% and the increase of the average score is 0.39; In third place are social competencies - relationships, activism, etc. and there the number of fives increased by 12%, and the average score increased by 0.38. On average, the score of each competency increased by a

quarter (0.26). The least progress was made in communication in native language (the score was high in the start) where the number of fives increased by 5%, and the average score rose for 0.14, and a little more in the case of communication competence in a foreign language - the number of fives increased by 3%, and the average score increased by 0.04. From this we can draw two conclusions. The first is that users already have a well-developed language competency in the native language. On the other hand, however, the little difference in the development of this competency after the program is still surprising, which may suggest a failure to identify the skills of business correspondence and presentational skills as part of this competency. Regarding competency - communication in a foreign language, it can be seen that it is in tight correlation with the place of the vocational training and if the beneficiary has not already developed it, thereby it is expected that employers did not organize a special training in this field.

Table 1. Evaluation of competencies before and after the Program - from 1 to 5 (in %) Comentencies/when Digital competency

4

21

75

2

11

87

AS befor e 4,14

Social competencies – MLJO, activism Competency learning how to learn Communication in native language Entrepreneurial competency Competency of cultural/artistic expression Mathematical, scientifical and technological competency Communication competency in a foreign language

6 6 4 10 10 10

24 29 20 34 32 34

70 65 76 56 58 56

2 2 4 4 6 7

12 14 15 18 25 30

86 84 81 78 69 63

3,96 3,88 4,13 3,66 3,72 3,64

4,34 4,27 4,27 4,12 3,92 3,79

11

32

57

11

29

60

3,71

3,75

Marks

BEFORE 1+2 3 4+5

AFTER 1+2 3 4+5

AS after 4,41

Table 2. Distribution of competencies’ marks before and after the Program (in %)

Mark 1 and 2 Mark 3 Mark 4 Mark 5 Total Arithmetic average

Competencies before the Program 4% 25% 48% 23% 100% 3,85

Competencies after the Program 1% 13% 52% 34% 100% 4,11

Difference - 3% - 12% + 4% + 11% + 0,26

Chart 1. - Graphic view of beneficiaries’ self evaluation is the following2 (red is before/blue is after):

2

Research about the effects of traineeship to target groups and policy stakeholders – Srećko Mihajlović 2013, Belgrade

EMPLOYERS As it was mentioned in the introduction that we do not have a representative sample of employers who participated in the program and the research, in this document we will list indications of employers' perception related to the purpose of the program and its fulfillment.

These allegations are the product of a round table that was organized with the employers on the topic "Quality of programs of traineeship’’.

Employers, as well as beneficiaries, see the purpose of the program in providing opportunities for young people to gain work experience, new knowledge and skills, to prepare for the first real job. They point out that somewhere through the program, they also have the opportunity to test the young staff they could later employ. In this section, however, they point out a flaw was that they were not given the opportunity to choose their candidates themselves, because in their opinion in that case it would be more likely to keep the candidates after the Program. This claim they justify with the fact they do not have any mechanism to replace the candidate and on the other hand, candidates cannot "feel" what true competition in the labor market is. As a positive example, they point out the program of work practice for university students realized by the ZZZCG, which gave them the mentioned possibility and provided them with constant support in their work.

There are conflicting opinions of employers on the quality of the training of personnel, but they all agreed on one, and that is that the level of training depends on the personal motives of the candidates, and only after that on the quality of the training. This suggests that the program left a lot of room for free will of the candidates, and that this part should be further influenced.

RESULTS OF THE POLICY: The intervention logic identifies 3 priority results of the traineeship. Below, each result will be processed individually.

RESULT 1 - Creating a favorable legal environment for increasing utilization and the number of programs that contribute to increasing the employability of young people in Montenegro.

In the chapter of coherence is given a more detailed insight into the field of regulated/poorlyregulated/unregulated various forms of traineeship. Therefore, in this chapter we

will not deal with this topic in detail, but only conclude that all three levels of regulation, poor regulation and unregulation exist of this form of engagement in Montenegro.

RESULT 2 – To ensure good quality implementation of programs in order to increase the employability of young people.

Analysis of the quality of framework of different traineeships implies to a certain regularity.

Programs involving up to 500 beneficiaries were much better than programs that had beneficiaries over this number. A smaller number of beneficiaries makes the work easier and ensures a higher level of supervision over the implementation of the program and vice versa.

The framework of good quality traineeship included a set of indicators, of which the most important are: the quality of selection and matching of candidates and employers, the quality of program implementation, mechanisms for monitoring the implementation of the program, the protection of labor rights of young people, the valuation of the engagement, law enforcement etc.

These indicators were constructed; each of them was tested through a series of sub-indicators.

The quality of the application, selection and matching of candidates was interpreted differently by different stakeholders. Beneficiaries of the program were mostly satisfied with the electronic matching mode with employers in the sense that there were minimal chances for manipulation. Criticism of the program in this section only refers to the fact that in some cases a sufficient number of positions for each profession was not offered, and therefore beneficiaries were limited, and in some cases, the competition was big for certain employers.

At the very beginning, the institutions issued a call for employers to participate in the program, but this was not preceded by an analysis of the supply of university educated personnel, which would help set priorities i.e. which positions are most wanted. On the other hand, a market analysis was not done which also made the matching difficult in the process of selection.

Employers were not satisfied with the selection process because they were not left with space to choose candidates themselves. These analyzes have been made after the first generation, but the results were not used for the next round of training.

The analysis of the quality of conditions for program implementation from the perspective of beneficiaries shows the following: • 67% of young people were familiar with and/or had a plan and program of the training while 33% did not get to review the plan, although this segment was prescribed by the Law as an obligation, • 75% did work what they were educated for, and 25% other activities • 74% stated that they had everyday tasks, while 26% said that they did not have enough task constantly; • 91% of beneficiaries did not have problems with colleagues at workplace, while only 9% had a problem, • 90% of beneficiaries had working conditions provided, as opposed to 10% who did not, • 8% of beneficiaries did not have a mentor, as opposed to 92% who did, and who rated their work with 4 and 5, while 13% of beneficiaries rated poorly the work of their mentors.

Results of monitoring of the implementation of the program and the protection of labor rights of young people in the labor market are analyzed through a number of indicators. The institutions responsible for the implementation of the program conducted surveys of beneficiaries about the level of satisfaction with the program. The survey results showed that beneficiaries

were mostly satisfied with the program, and a small percentage said they would like to be visited in the workplace by the coordination team. There is no information whether these visits happened in practice, and on the other hand there is the question: "Why did the coordinating body take on the role of the Labour Inspectorate, although it was not considered that additional oversight was redundant?"

The findings of the survey conducted by ADP - Zid and USSCG show the following: • 33% of beneficiaries worked less than 8 hours per day, 59% worked 8 hours, and 8% more than 8 hours, • 90% of the beneficiaries had a break during the day, versus 10% of which did not, • 87% used a vacation, while 13% did not, • 77% believe they were respected, 6% that they were not and 17% did not know what their labor rights were exactly, • at the start of the program 60% of beneficiaries were introduced to their rights and obligations, while 40% of beneficiaries were either partially or not at all introduced to their rights by the employer.

It can be concluded that the rights of young people in most cases were respected, however the fact that 40% of young people were unaware of their rights at the start of the program is concerning. On the other hand, the fact that one-third of young people worked less than 8 hours represents a fact which is interesting from the standpoint of efficiency and which will be addressed in this chapter. The monitoring report showed that there were also cases where young people contacted the Labor Inspectorate, but, in the official data of this institution there are no cases of violation of rights of persons in vocational training.

At the end of the analysis of this result, the observation of employers should be mentioned: they pointed out that the program of work practice was better in quality then the program for vocational training for university students. The reason for this is the fact that beneficiaries engaged in work practices had a preparation for work, organized by the National Employment Agency and constant supervision by the staff employed in the Agency and by mentors at employers’.

On that line, a recommendation to decision-makers would be to implement measures conducted during the work practice program to the program for vocational training.

RESULT 3 - Increasing interest of employers and beneficiaries to participate in the implementation of various programs of increasing the employability of the youth.

The institutions responsible for the implementation of vocational training programs conducted an intensive campaign of the Law on vocational training. Based on the analysis of documents Information for the Government about the implementation of vocational training for university students, it can be concluded that in quantitative terms, the promotion of the program was satisfactory. This is evidenced by the following findings: For the purpose of promotion of the Program for vocational training for persons with acquired higher education, organized were presentations of the program in Montenegrin municipalities about which was reported in the electronic and printed media, guest appearances on TV were provided, brochures with information for employers and beneficiaries were printed, while in Podgorica billboards that included a call to employers and customers to get involved in its implementation were set. By monitoring the media content over a period from September 1st

2012 till February 12th 2013, a total of 277 posts containing information about the project "Vocational training of university graduates" were recorded, which means that every other day, the media placed an announcement. During the monitored period, the media placed 141 announcements that had an overall positive impression in relation to the project "Vocational training for university graduates", 119 neutral and 17 negative announcements.

Showed in percentage, over 50% of the announcements were positive, while the negative ones were 6%.3 In a qualitative sense, however, there is still room for improvement of the promotion of the program. The activities were mostly focused on the presentation of the possibility to use the program, while a small emphasis was put on the promotion of the provisions of the Law of the vocational training of university students. Although the law was transparent and accessible to citizens, institutions should still have counted on a low level of awareness of young people and created conditions for effective use of the information set. In the future, institutions should find a model that provides that the information about rights and crucial provisions of the Law come to each beneficiary in order to ensure that young people protect their rights and enforce them in practice. There is also space for promotion of trade unions and presentation of the roles and functions of trade unions primarily in the society from the perspective of labor rights protection.

Negative aspects of the program By research, we tested ten possible negative aspects in the preparation and implementation of the Program.

Table. Perception of the negative aspects of the Program (composite score) Items Uncorrect Mixed Correct Total* There were layoffs of employees due to 79 6 15 100 particpants’ engagement in the Program There were cases of mobbing of Program 67 20 13 100 participants There were violations of professional and 66 11 23 100 personal dignity of Program participants Parents were more interested in the Program 55 22 23 100 than their children The program is not economically profitable 59 20 21 100 More was spent for the Program than the 62 18 20 100 Program brought benefits Some employers abused the Program 39 23 38 100 Employers saw cheap work force in Program 35 25 40 100 participants Employees see Program participants as 29 26 45 100 competition Program participants were seen as 23 21 56 100 replacement for paid work force Overall, nearly two-thirds of respondents more or less rejected negative assertions about the program (25% totally, and 39% mostly dismissed negative claims about the Program). On the other hand, a "strong" third more or less confirmed negative statements about the program (27% of respondents predominantly and 9% fully confirmed negative statements about the program).

3

 Information for the Government about conducting the Program for vocational training of university graduatesÂ

Of the 10 indicators that were developed through negative statements about the program, six were rejected by a simple majority, one statement with relative majority, while two claims have been accepted, one with a relative and one with an absolute majority, and that is the claim that the program participants were seen as a substitute for paid work force and were seen as competition for that reason by the employees. This could point to turbulence of relations in the labor market and to a burden of all stakeholders in the process, of young people to get jobs, and of employees to keep their jobs.

During the process of creating the program, there was public pressure that the program was being implemented for political reasons. When asked about the motives of the state to run the program, 16% of respondents said they believed that they were political in nature, "gaining favor of young people immediately before elections," while the rest of the young people still believed that the state had other motives, including

EFFICIENCY AND SUSTAINABILITY

SUBJECT OF ANALYSIS AND METHODOLOGY OF RESEARCH An analysis of efficiency implies an analysis of cost-effectiveness of the implementation of the policy itself. The expenses do not only include financial resources, but also the allocation of human resources for implementation of certain measures, which leads to the conclusion that the benefits are not only financial but also have a broader social significance which besides the economical can also have a social character.

EFFICIENCY (or input-output and input -outcomes) 1. Is it the implementation of the intervention reasonable in terms of efficiency (cost-benefit ratio)?

2. Which measures were taken during the planning and implementation of the policy in order to ensure that resources are spent efficiently?

3. Could the policy be implemented with less invested funds, and without distorting quantity and quality?

4. Could better results have been achieved with the same investments?

5. Would different intervention logics solve the same problem with less investment?

6. Is the intervention economically profitable considering possible alternatives and available resources?

7. Could the funds used for the intervention have been used for other, more profitable purpose?

SUSTAINABILITY 1. Does the intervention fit the needs of the market?

2. Is the program long term supported by the institutions?

3. Were the beneficiaries and the stakeholders of the policy included and consulted in the period of planning, implementation and evaluation of the public policy?

4. Does the intervention fit in the environment in which it is implemented (cultural, social aspects) i.e. is it applicable in that environment?

5. Does the technology used in the implementation of the policy fit the level of IT education of the youth in Montenegro; 6. Do institutions implementing the program function on the principle of good governance including effective management and organization?

7. Do institutions coordinating and implementing the program have satisfying human and resource capacities?

8. Do employers have the financial capacities to continue program usage if financial aid from the state stops; 9. Is the intervention in accordance with sustainable usage of natural resources or it is harmful for the environment?

10. Does the intervention have financial sustainability?

ANALYSIS Real expenses of the implementation of the program for vocational training include the following: • remuneration for 4211 beneficiaries for 9 months of work in amount of 50% of the average salary in Montenegro for the previous year (approximately 10 000 000 Euros), • expenses of uncollected tax on traineeship, • additional work expenses of staff implementing the program, • expenses of beneficiaries who are being trained out of territory of their residence, • expenses of promotion of the vocational training program • unpredicted program expenses (purchase of additional work equipment), • additional burdening of existing work force in institutions implementing the program and also burdening of mentors in companies, • expenses based on unemployment of persons who are beneficiaries during and after program usage, • creation of an internet platform for application of candidates and employers.

Benefits of the program for vocational training include the following indicators: • young people became more competitive on the labor market, gained experience, new knowledge and skills; • life standard of young university educated people improved in the period of 9 months due to obtaining remuneration for engagement with employer, • employers got a chance to train and employ new staff, • people got jobs after the implementation of the program.

With a simple analysis of expenses and benefits it can be concluded that this program cost Montenegro a lot more then 10 000 000 Euros which were granted to it in the start.

This information was supposed to encourage the country to reconsider the model of functioning of the program before its start and to consider different alternatives which would lead to achieving the same specific objective of the policy. The current model of the program presents a big burden for the labor market and the budget of Montenegro. In the implementation of the project are included the cabinet of the Vice President of the Government, the Ministry of Education, National Employment Agency (and bureaus of labor), Directorate for Human Resources, Program coordination team, Ministry for Information Society. This kind of massively set coordination model can bring both beneficiaries and employees in a situation which will not give an efficient response to the existing needs. The present approach represents a reaction of the country to the consequences, and not on the suppression of the cause of the problem.

If financial justification is to be pointed out, this scope of investment in the policy should have much larger effects from the achieved (which are not negligible, if perceived separately from the finances).

Possible alternative models which could have been implemented for solving the problem: • Introducing a mandatory paid/unpaid practice for high school students and university students throughout the duration of studies, • Adaption of the educational system to the needs of the labor market, which would lower the number of unemployed young people,

• • • •

•

Creation of conditions for youth engagement on the open market which would provide them protection of work rights , Payment of participation and usage of international programs (ex. Leonardo da Vinci, EVS), through which many young people can get work experience in the EU, Creation of incentives for employers who give services of vocational training, Creation of a fond for vocational training – remuneration for the training program which is realized by the state can be treated as a student loan, where beneficiaries would, after getting a job, return a certain amount of the remuneration into the fond, Optimization of criteria for youth entrepreneurship, in order that young people could, after gaining competencies, have the possibility to start their own business.

With this kind of diverse approach in the process of solving the problem of youth unemployment, the market would not be over loaded with persons on vocational training, because they would be engaged in different periods and time intervals (2, 3, 5, 9 months) in the country and abroad.

Therefore, the work force which is currently on the market would also be relaxed and would not see young people as competition, but would give them full support in professional development.

The young people would have the opportunity to use more programs which would at the same time increase their competencies, and therefore their competitiveness. Policy sustainability is viewed through three main aspects: 1) financial sustainability 2) sustainability on policy level 3) ecological sustainability.

Financial sustainability – If for a longer period of time it would be invested in this amount, after a certain number of years the expense would accumulate which could, with previous smart management, be a strategical project which would offer a possibility for new job positions.

Appropriation of funds with this intensity would affect the GDP as well, since these investments make a large portion of the budget of Montenegro. Based on the stated it can be concluded that in that sense, this policy is financially unsustainable for a longer period of time (more then 2-3 years).

Sustainability on policy level is tightly connected to harmonizing the educational policy with the needs of the labor market and employment policy. It is necessary for Montenegro to smartly plan the development of human resources and to make a balance between supply and demand of different levels of education on the labor market. Besides that, it is very important that the state simultaneously plans the economical policy and implements measures which contribute to opening of new job positions in Montenegro. Otherwise, the effects of the policy for increasing employability will not have any significant effect on the Montenegrin society simply because the young people will not have the opportunity to get a job due to the deficit in job positions. For the sake of sustainability on policy level, it is very important that the broader society, the social council and all stakeholders significant for this issue are consulted when policies are being created.

From the aspect of ecological sustainability, the realization of the policy does not have too big of an impact on the environment, but there is place for improvement on this field. The internet platform for matching candidates and employers is a good base for achieving ecological sustainability. However, the fact that application forms, as well as monthly reports, have to be delivered in hard copy as well, leads to the conclusion that a rationalization of paper usage should be done and the whole process be redirected to online communication and bureaucracy.

This publication was made with the help of the European Union. The publication does not contain a formal statement and does not necessarily represent the attitude of the European Union.

ADP-Zid Gojka Radonjica 32 P. fah 370 Tel/fax: 020 207 130/ 207 131 Mob: 067 210 848; 069 073 381 email: info@zid.org.me www.zid.org.me www.angazujse.info

"Ova brošura je nastala uz pomoć Evropske unije. Publikacija ne sadrži formalno saopštenje i ne predstavlja nužno službeni stav Evropske unije."