EU 2013 2013 Policy Priorities Banking Regulation & Financial Markets This report outlines the EU policies in the field of banking and financial regulation throughout 2013.
The report offers an overview of the stand points of the European Greens on these specific policies, and points to the national contexts where these policies are likely to stir most discussions. This report is researched and drafted by Jonas Hirschnitz.
Overview Relevant Commissioners: Michel Barnier (France, Single Market, MARKT) Relevant Committee: Economic and Monetary Affairs (ECON) Main Green Actors in the European Parliament: Sven Giegold (Coordinator of Greens in ECON committee, Germany), Jean-Paul Besset (France), Philippe Lamberts (Belgium), Substitute Members: Bas Eickhout (Netherlands), Eva Joly (France), Emilie Turunen (Denmark) During the financial crisis, bank failures and the meltdown of financial markets led to many European citizens losing savings, investments, and even their jobs. Massive government bailouts of banks in trouble also meant taxpayers took over the risks incurred by private investors on an unprecedented scale. This put severe pressure on the finances of several countries, large and small. It also clearly revealed that the regulation of financial markets and banks was insufficient. As international standards and national legislation were not able to provide for a stable scheme, 2013 will see further work of European banking and financial market regulation. Although the EU does not have direct
competence to regulate Member States’ fiscal policy and economic governance, it can introduce financial market and banking standards through Internal Market Directives and Regulations. The EU Commission had previously been mostly occupied with harmonising European financial markets, paying less attention to their regulation. Yet, this approach was radically turned around after 2009. Through the crossborder character of financial flows and the involvement of banks in European and international markets during the crisis, the European Commission now has a strong mandate to propose further regulation in this regard. While the new Commissioner for the Directorate General Internal Market, Michel Barnier, in 2010 took office with his personal vision to properly regulate “every financial actor, financial market, financial activity and product�, the far-reaching measures like the European Banking Union or the financial transaction tax were only brought on the way when agreements were reached in the European Council of heads of state and government. Consequently, most regulatory initiatives have been put forward under the Single Market provisions under Article 114 of the Lisbon Treaty (Treaty on the Functioning of the European Union, TFEU). The first major advancement was the installation of a European System of Financial Supervisors (ESFS), comprising three specialised European supervisory authorities and the European Systemic Risk Board (ESRB). Among the three supervisory authorities1, the European Banking Authority (EBA) is the most prominent. It gained this status as it was principally banks and not market infrastructure or insurance companies that were responsible for the crisis. Until now, the scope of action of those Authorities does yet not go far beyond assisting and advising the national authorities. But aside from this, a plethora of more than 20 separate but more or less interacting initiatives have been initiated by the Commission, such as regulation proposals on deposit guarantee schemes, capital requirements for banks, bank resolution regimes, and the financial transaction tax. Furthermore, the Commission has started taking belated and tentative action in the fight against tax havens and shadow banking. Currently in the debate is also the general structural reform of banks. All of these initiatives will be briefly described in this paper, highlighting the Green responses to these proposals.
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The other two organs are the European Insurance and Occupational Pensions Authority (EIOPA), and the European Securities and Markets Authority (ESMA).
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Key Measures – Banking Union In an ordinary economy, banks are the most important actors in the financial markets. They administrate the savings of millions of citizens, they lend out money to conventional customers and businesses, and they are an essential source for loans to businesses and enterprises. In this regard, they are one of the most essential building blocs of the economy. Yet, the financial crisis showed that imprudent bank conduct can have devastating consequences for the whole society. As a result, European decision-makers realised that the conduct of banks had to be put in a clear framework, avoiding excessive risks in banks, and separating banks from states to avoid that bank failures become a burden to state budgets. The measures to achieve this are summarised in the concept of the banking union. Any future banking union has three pillars: > a single bank supervisor, which prevents excessive risk taking of banks > a common deposit guarantee scheme, which guarantees the savings of ordinary bank customers; and > coherent resolution system which acts as an emergency mechanism allowing intervention in should a systemically important bank tumble into crisis and which allows for a structured resolution of failed banks All three pillars could theoretically be steered by the same entity, and the consensus among the Eurozone members so far is that this entity should be the European Central Bank (ECB). Yet, as there is already a European bank supervisory authority installed – the EBA – competences between the ECB and the EBA would have to be defined.
1. Single Supervisory Mechanism The Single Supervisory Mechanism (SSM) has been the central and most important issue in the discussions on the banking union in 2012. The general idea is to install an entity, which monitors the business of the banks, and prevents them from engaging in too risky large scale activities, which could have implications beyond the frontiers of the bank. The Commission has brought forward two proposals among which the first designates the ECB to be the European supervisory authority, and the second governs the relations between ECB and the European Banking
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Authority (EBA). Should both proposals be accepted as such, the ECB would be the highest organ, and would be complemented by the European Banking Authority (EBA), which is mandated to develop a single rulebook for all European Banks and to police the implementation of EU supervisory rules. The scope of the ECB’s supervisory powers is likely to be limited to those European banks with assets worth at least €30 billion or more than 20% of national GDP. This was defined in the last Council of finance ministers on 12-13 December 2012. In fact this means that only circa 150 of the 6,000 European banks – at least three from each participating state – could fall under the regime. The ECB, being an independent institution overseeing the monetary policy of the Eurozone since more than ten years, is certainly an institution with vast expertise. Yet, concerns have been raised that an unelected institution, both overseeing monetary policy of the Euro, and supervising national banks, could develop excessive powers and be in a position to resolve important tensions between monetary and supervisory policy (the latter having important fiscal consequences). Another critical point concerns the ECB’s governance structure. Banking regulation becomes more effective the more countries participate. If more powers are conferred on the ECB, whose executive board only features members of the states of the Eurozone, there is a danger of excluding non-Eurozone states wanting to opt into the banking union. Therefore, the European Council foresees a reform of the internal structures of the ECB. This reform proposal gives the supervisory board competence to prepare decisions on supervisory tasks, and attributes equal voting powers to countries opting in. Nevertheless, the ultimate authority under the Treaties rests with the Governing Council of the ECB – a pure Eurozone body. The partial opening up of the ECB’s regime had been a result of the pressure exerted by the European Parliament’s Economic Affairs committee (ECON), which called for a decision-making structure which would not discriminate non-Eurozone Member States. The ECON committee, for example, would like to see the Chair of the ECB’s supervisory board being approved by the European Parliament or have national parliaments and the European Parliament entitled to hold hearings with representatives of the ECB’s Supervisory Board. Currently so-called “trialogue” negotiations are going on between the Council, the Commission and the Parliament and it will be crucial to see how many of the far-reaching points in the position of the Parliament’s ECON committee will find their way into a final compromise. As
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the two Commission proposals for regulation are to be seen as a package, the European parliament has considerable influence in the decision-making.
Green Response The Greens have been very engaged in the discussions on who should supervise and how this arrangement should be designed. Based on a strong vision of inclusion and democracy, any Green solution must imply nondiscrimination of the countries not opting in into the new supervision, and be bound to close democratic oversight. This results in two demands: a reform of the ECB’s governing board and as much European Parliament oversight over the work of the supervisory body as possible. The Greens have strongly advocated those points in the ECON committee, and partly those demands are reflected in the Committee’s position. Yet, the original Green position set out to limit the powers of the ECB even further as is now reflected in the ECON position. The Greens wanted to clearly define that the ECB cannot act as a legislator and as executive at the same time, that is to say that it cannot issue regulations for banks and at the same time act as supervisory authority over those rules. The Greens were strongly in favour of designating the EP and the Council as ‘legislator’, assisted by the expertise of the EBA, and equipping the ECB as the executing institution. The Greens see a democratic problem in delegating too much power to an unelected body. While they were not able to uphold this strong stance, they were able to introduce several checks in the legislation, which work in this interest. For example they stressed that the ECB’s executive board is not totally independent in its conduct where supervisory tasks are concerned, but is acting in the scope defined by the European Council. Moreover, although it was agreed that the supervisory board inside the ECB should be open for any Member State opting in into the SSM, the Greens criticise that the governing board of the ECB still has the last say under the ‘object and complain’ procedure. Another object of criticism of the Greens is that they see the regulation of commercial banks and the regulation of investment banks or non-bank entities being involved in the same kind of risk taking (shadow banks) as nonseparable issues. The exposure to risk should be the guiding principle when regulating an entity, and not its legal character. This ‘same risk, same rule’ approach, according to the Greens should be directly included in a
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proposal on bank regulation. However, the Treaty explicitly forbids the ECB to have a supervisory role with regard to insurance undertakings and many financial groups are retail bank, investment banks, and insurance or investment management conglomerates. In general, the Greens thus evaluate the outcome of the negotiations so far as ‘quick, but dirty’ fix. This expresses the dissatisfaction that the ‘same risk, same rule’ necessity was not implemented in the final text, and that delegating more supervisory powers to the ECB is an easy and quick solution, but that a more thorough policy package had been desirable, especially from a democratic point of view.
2. Deposit guarantee scheme (DGS) Deposit Guarantee Schemes (DGS) reimburse a limited amount of deposits to depositors whose bank has failed. From the depositors' point of view, this protects a part of their wealth from bank failures. From a financial stability perspective, this promise prevents depositors from making panic withdrawals from their bank, thereby preventing severe economic consequences. Under the 1994 Deposit Guarantee Scheme Directive, it was already agreed that every EU Member State has to have such a scheme in place. However, the crisis in 2008 showed that the fragmented regulations throughout the member states pose substantial risks to the stability of the system. Therefore, harmonisation under one scheme with common rules seemed inevitable. The proposed Reform of the Deposit Guarantee Scheme (2010), is currently still frozen in the co-decision procedure awaiting the first debate in the Council of Ministers. Yet, it is likely to be warmed up in the upcoming year. The most important points the proposal is supposed to amend are 1) the move towards a harmonised European Deposit Guarantee Scheme (DGS), including a time-table for a pan-European DGS, 2) a confirmation of the coverage level of up to €100,000, 3) better information for consumers on their rights, and 4) an enhancement of the financing of such schemes by bank contributions to ensure their workability. Especially the time-table for a European DGS has raised most controversy in the Council and has led to a standstill of the process. Member States are still not able to achieve consensus on European solidarity for deposit guarantee schemes between the different countries.
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Green Response The Greens original position is to favour a European Deposit Guarantee Scheme. In the early stages of the negotiations, this position was taken up by the European Parliament’s ECON committee. During the negotiations with the Council, however, it became clear that this position was irreconcilable with the Council’s. Thus, the ECON committee watered down its position on 24 May 2012, proposing that the deposit guarantee schemes should remain national, but should be subject to common European standards. Those standards are for example the deposit guarantee up to €100,000, the obligation for banks to have ex-ante capital financing for 1.5% of the guaranteed deposits, and risk-adequate contributions towards the guarantee system by financial institutions. As this still represents a strong defence of the consumer, in this case ordinary depositors, this position can be seen as strongly reflecting Green preferences and the Greens will continue to push into this direction in 2013.
3. Bank Resolution & (Common) Resolution Fund When banks tumbled through the shocks of the financial crisis, their situation was often aggravated through panic-stricken bank runs, meaning that investors and in some cases depositors in fear of losing their money withdrew it as fast as they could. This suddenly removed liquidity from the ailing institutions, depriving them of any opportunity to lift themselves out of their dilemma. In the case of systemically relevant institutes, the nation states had to intervene through large scale bail-outs in an attempt to keep banks in “intensive care” while confidence was restored, thus transforming private (bank) debt into public (taxpayer) debt. Had a structured bank resolution mechanism existed, accompanied by a resolution fund, this situation could have been averted by early, decisive action and there is a good chance that a credit crunch would not have developed into such a large scale shock. Therefore, the Commission’s proposal for a Recovery and Resolution Directive (June 2012) set out to clearly define a European-wide three step mechanism for dealing with ailing banks. First, banks’ risk taking should be controlled in order to limit their likelihood of bankruptcy in case of market disruptions. Secondly, non-specified authorities, likely to be national, are mandated to intervene into bank affairs, should they detect grave
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problems. Thirdly, in case those steps still cannot prevent that a bank is on the verge of bankruptcy, a coherent mechanism for bank resolution is defined. A resolution can include measures such as the recapitalisation of banks via bail-ins2, the restructuring of banks implying a separation into good banks and bad banks, and the sale of part of the business. Long-term visions, such as the latest van Rompuy paper of 5 December 2012, project the creation of a European Resolution Fund, but this will have to be debated between the heads of state in the upcoming year. The Recovery and Resolution Directive is supposed to receive a first reading by the EP’s ECON committee in March 2013 where discussions are currently based on the draft report by Gunnar Hoekmark (EPP).
Green Response The Greens have clear priorities for an outcome of the negotiations: the principle that the taxpayer should not pay the bill should a bank fail is paramount. In this regard, it is likely that the Greens will support that resolution funds will be financed by the banks, that investors who knowingly invested in risky products should accepts losses (bail-ins) and that deposits of clients of retail banking should be guaranteed. To make the system more transparent, the Greens are currently working towards a separation of debt into debt that is explicitly earmarked for bail-in, and debt which even in a crisis, should have a much lower probability of being endangered if the cushion of capital and explicit bail-in debt is adequately sized. This would give investors more information on the risk they potentially take.
National Considerations on Banking Union: Countries outside the European Banking Union have raised several concerns as its structures are putting nonmembers in a dilemma. On the one hand, banks under the new European regime are upgraded, and become
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A bail in usually imposes losses on bondholders, meaning that they those who knowingly invested in risky business contribute first to the recapitalisation of banks.
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more interesting for ordinary bank customers. This is a particular problem for Eastern European countries, where Austrian, German and Italian banks own large shares of the banking sector. This problem is connected to the provisions in the legislative proposal, which make opt-ins unattractive. Non-euro countries can opt into the banking union, but would have no say in the governing council of the ECB which is made up of Eurozone members only and basically has the last word on all decisions. Therefore, states prefer to maintain sovereignty over their banks rather than surrendering it to an unaccountable authority. The UK is traditionally against any regulatory measure, which could potentially reduce the attractiveness of the City of London as a financial marketplace. A strict control of its bank practices could be such a measure. Lastly, also the UK has concerns on a lack of influence in the ECB’s Governing Council. However, there is also a compelling argument of the Banking Union states to keep the Brits out of the regime: its aggregate bank assets are simply too large, currently standing at €10.2 trillion – four times the size of the German economy. Although almost certainly not forming part of the Banking Union in the near future, the UK is expected to consent to the new enhanced cooperation. A particularly interesting case is Estonia, member of the Banking Union. Its whole banking sector is under Swedish control, yet Sweden is not part of the Banking Union, which in turn means that Estonian banks will not be subject to the Banking Union controls.
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from ordinary retail bank customers or in the form of long term debt issues to investors or, increasingly in the years leading up to the crisis as short term loans from other banks or financial institutions. In order to maximise gains, a bank will always lend and invest the maximum amount of money. In a prudent bank, though, investment and lending follow certain rules such as careful selection of the borrower and the financial product, careful matching of the profile of liabilities and assets, and diversification of the investments. Therefore, risks are supposedly low and the diversity of investments prevents that failure of certain investments results in large scale shocks on banks. Yet, the financial crisis has shown that bank’s conduct is not always prudent, and that financial risk at times is hard to assess and easy to spread. As shocks can not be ruled out entirely, a possible remedy is to increase the obligation of the capital banks have to hold. This capital acts as a buffer for banks to still be able to meet liabilities when investments fail. To upgrade the European capital requirements for banks, the Commission adopted an updated legislative package (CRD IV package, July 2011, including a Directive and a Regulation). These two legislative measures are the European implementing acts of the international Basel III recommendations. This legislative package also increases the EU’s supervisory power by equipping EU supervisors with the competence to fine institutions which breach EU requirements. Implementing the Basel III requirements, lenders are supposed to hold significantly more capital of a much better quality than they were obliged to hold under the old scheme. Together with the new capital buffers, this is supposed to create a strong emergency mechanism in case of large bank losses. Yet, the Commission proposal falls short in proposing concrete indebtedness limits for banks, so-called leverage ratios.
SUPPLEMENTARY MEASURES 4. Capital Requirements for Banks One central activity of banks is to lend money and to invest money; money which it has received as deposit
A breakthrough deal in the trialogue negotiations between the Parliament, Council and Commission was obtained at the end of February 2013, after months of stagnation. The deal will provide for an EU cap on bank bonuses, for provisions to ensure greater transparency for banks' accounts, on top of key provisions ensuring banks are properly capitalised. Commenting on the outcome, Green negotiator and finance spokesperson Philippe Lamberts (MEP, Belgium) said: "MEPs were able, in the final round of negotiations, to obtain three crucial points from the Council, namely a cap on
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bonuses, on transparency of banking activities and on capital surcharge for systemic banks. These concessions from the Council were almost unimaginable when we started negotiations over seven months ago." This agreement still needs formal approval by the European Parliament and the Council. Most member states of the EU are firmly behind the proposals, with the notable exception of the UK that points to fears from the City of London that these rules would drive away talent and restrict growth.
Green Response The Greens, also in this initiative follow their core conviction that all has to be done to protect the citizens from excessive risks imposed by the financial sector and the banks. Therefore, they support the position formed in the EP’s ECON committee on 14 May 2012, which followed exactly this line and which is the result of intensive Green involvement. The position called for an extension of the Basel III rules in implementing even higher capital levels and setting concrete leverage limits and liquidity standards, whereas a particular focus should lie on systemically important banks. To make this possible, besides minimum standards, the committee position foresees a greater leeway for member states in imposing higher requirements for bank capital. The ECON position reflects the general approach of the Greens to set binding requirements which cannot be circumvented easily. Last but not least the Greens were responsible for the ECON position having strong provisions on the benchmarking of the internal models banks use to asses capital requirements for credit and market risk and country-by-country reporting of financial information to improve transparency around the nature of banks profit generating activities. Going beyond the ECON position, the Greens criticise that a long term stable funding requirement designed to stop banks relying too much on volatile short term funding has been absent from the legislative proposal, and could not be introduced in the ECON text. Although a short term liquidity buffer "LCR" - another key Basel III proposal - did feature in the Commission’s proposal, it has already been watered down during negotiations, much to the regret of the Greens.
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5. Structural Reform: separation of investment and retail banking On October 2, 2012 the Liikanen group presented its report to the European Commission. It had been mandated to assess whether investment banking and retail banking had to be separated to protect the European taxpayers from further bail-outs, and retail banking customers from the risks of losing their bank deposits. The result was a recommendation to legally separate the different types of banking and to limit the extent of risk taking by the parts involved in investment banking. For example, bank bonus payments should be paid out in debt shares which can be bailed-in in case of the bank getting into trouble, which is supposed to limit bank managers’ willingness to take risks as own assets would be concerned. Whereas the report as a whole will most likely not be transposed into a legislative proposal, it proposes some interesting ideas on how to shield European retail bank customers from risks they are not aware of. Moreover, whereas some proposals such as the higher capital requirements for banks have already been picked up in individual proposals, the debate on how to separate risky investment banking from commercial banking will certainly continue in 2013.
Green Response For the Greens the protection of the ordinary bank clients through a clear separation between risky investment banking and commercial or retail banking is a priority. Therefore, they applaud the recommendations of the Liikanen group to clearly separate those activities, but – as the Greens’ finance spokesperson Philippe Lamberts expressed-deplored that the group had not considered the option of a clear physical separation of investment banks and retail banks – a more radical, but equally easier to enforce policy measure. Another problem which had been central in the crisis had also not been addressed sufficiently, namely the problem that some banks were simply ‘too big too fail’, which resulted in the large scale bail-outs financed by the European taxpayers. To resolve this problem once and for all, the European Greens defend “cap limits on the size of assets that a bank can hold […] to reduce the systemic footprint of the banking industry”. Besides those large scale reforms, Lamberts also pointed out
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that all loopholes created by exceptions would have to be closed to make the proposal workable. The Greens also maintain that strict bans on bonuses that exceed fixed remuneration are absolutely necessary to limit bank risk taking.
6. Shadow banking regulation The past has shown that stronger regulation of banks often leads to increased efforts to circumvent the regulatory regime. Shadow banking refers to a variety of less regulated financial activities that perform similar activities to deposit taking and lending without the same safeguards. Through shadow banking many banks have effectively outsourced excessive risk taking to related offbalance sheet vehicles and via these to investment funds and other money and capital market actors. In this way the regulated banks offload risky investments to non-banks in return for cheap short term cash that they can reinvest in even more precarious products. The prevailing danger is that in case the risky investments blow up this does not only affect the shadow bank directly taking the risk, but also its related bank. This sudden risk puts the deposits of bank clients in danger. In addition, as the practice can occur at such a large scale the failure of the shadow banking market can constitute a systemic risk. In the context of the financial crisis, bank regulation can thus not function without a regulation of the shadow banking sector as well. On this note, the parliament’s ECON committee on 22 October 2012 adopted an initiative report on the matter, which could lead to a motion for a resolution by the EP plenary. The report calls for centralised information sharing and data collection to better map the risks and liquidities of banks throughout Europe. This should be underpinned by common accounting standards throughout Europe. Furthermore, the report also calls for rules for banks, which prevent them from passing on securities they received to a third party. In this way, the relation between lender and borrower would remain direct and easier to oversee and control - a situation which totally went out of hand throughout the crisis. A novel and far-reaching proposal is that rules for ‘exchange traded funds’ should be introduced, which could work towards containing speculation on resources.
Green Response
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The Greens have been calling for a regulation of shadow banks for many years, as they undermine the effective regulation of risky financial activities putting to risk the savings of conventional bank customers. Many points in the own initiative report have been defended by the Greens in the ECON committee, such as the transparency requirements, common standards, and stronger control of opaque funds. Yet, the Greens also defended a strengthening of the European supervisory bodies such as the European Securities and Markets Authority (ESMA) and the Occupational Pensions Authority (EIOPA) to monitor risky investment vehicles and markets. Besides increased analytical capacities, the Greens even envisaged the delegation of the competence to take products constituting high and destabilising risks from the market to those authorities. However, this position could not be defended in the committee. Nevertheless, as the Commission is now urged to present a legislative proposal, the debates will continue once this proposal is tabled.
What is missing? Direct Recapitalisation of banks through the ESM Direct Recapitalisation of banks through the ESM has been circulating as an idea since the banking union entered the agenda. The prevalent argument (not least defended by Germany) is that direct recapitalisation of banks on the verge of failure through the ESM will require a preceding introduction of a clear supervisory scheme for banks. This follows the principle of carrotand-stick. If banks apply for recapitalisation by the ESM, they will have to accept that a supervisor is imposed on them. As outlined above, currently the discussions on banking union are defining this supervisory mechanism, the SSM. Yet, apart from the political discourse, there is no link between the SSM and recapitalisation of banks through the ESM. For the Greens, the recapitalisation of banks is a very inevitable obligation to bring the economy back on track in the current context. After all, key policies such as the Green New Deal rely on investments to bring about change in the economy and banks cannot act as lender if they are lot liquid. Supervision does not change this situation. Currently, banks are recapitalised by
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taxpayers’ money. Establishing clear-cut mechanisms with earmarked fund under the ESM would alleviate this pressure from the ordinary clients. Therefore, the Greens call for a sunset clause to define a legal link between the SSM and the ESM.
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Green MEP Philippe Lamberts runs a website on the 7 sins of banks (in French) The website of the Tax Justice Network has a lot of coverage on tax havens and tax avoidance
Additional Information:
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The Greens/EFA group in the European Parliament has a section on its website dedicated to Economic and Social policies, where press releases, documents, and events can be found
This text is the result of an original research carried out by Jonas Hirschnitz for the Green European Foundation. Warm thanks to Greens/EFA advisors David Kemp and Michael Schmidt for their advice on the issues at stake. © Green European Foundation > Green MEP Sven Giegold currently runs a competition forinthe The views expressed this most article dangerous are those offinancial the authors’ alone. and an article in The Telegraph been They product do not necessarily reflect the views of thehas Green European Foundation. With published support ofon thethis. European Parliament. > The Green New Deal website, developed and promoted GEF for the Greens/EFA group, and Green EuropeanbyFoundation asbl 1, rueuniting du Fortmaterials Elisabethfrom GEF, the Greens/EFA and EGP, has a particular section on the Green 1463 the Luxembourg Economy Brussels Office: 15 rue d’Arlon, 1050 Brussels, Belgium Phone: +32 2 234 65 70 - Fax: +32 2 234 65 79 E - mail: info@gef.eu - Web: www.gef.eu