Response to the Commission consultation on the Enterprise Europe Network

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Position Paper

October 2012

Response to the

Commission

consultation on the

Enterprise Europe

Network

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Introduction

The Chamber network welcomes the set-up of the Consultative Forum of the Enterprise Europe Network (EEN) which demonstrates the Commission’s commitment to involve the host organisations in the governance of the network.

The Chambers stress the importance to clarify the focus and aims of the Consultative Forum so as to avoid confusion between the responsibility of the Forum and that of the steering groups involving network partners.

The Chambers believe that the Consultative Forum should contribute to the policy and strategic direction of the network, while operational aspects should be discussed with the network partners. As such, the consultations targeting the host structures through the Forum and the consultation involving the EEN members should be different. The Chambers regret that the present consultation did not follow this approach and hope that the parameters of the Forum will be made clear in the near future.

Key messages

• There should be no expansion of the range of activities, except through signposting, unless combined

with an appropriate increase in budget.

• The focus should be on increasing the quality of the current set of services and guaranteeing a more

coherent and integrated approach to SME support.

The network partners should be given the flexibility to modulate their service portfolio according to the

needs of the SMEs on the territory.

• Access to the internal market, support to internationalisation and innovation should be the priorities of

the network for the period 2014-2020.

• Supporting and encouraging SMEs to fully enjoy the benefits of the European marketplace should

remain the first pillar of activities and focus of the EEN.

• The results of the mapping of existing support services and the assessment of the EU portfolio of

business support for SMEs in third countries should help define the EEN role in internationalization post-2014.

• The network can provide mentoring and coaching services on the H2020 programme. However, the

in-depth support and technical expertise that SMEs will require as they proceed through the three phases of the new SME Instrument should be provided by a range of specialist structures. These may or may not be involved in the EEN, so it is critical that the process for the delivery of the SME Instrument allows the involvement of a range of stakeholders at European, national and regional level. The Chambers nevertheless stress the importance to first establish a simple and user-friendly SME Instrument before assigning specific tasks to the EEN.

• Cooperation at local level is imperative to reach clients, ensure complementarity and offer a coherent

SME support structure to the business community. A platform gathering the EEN consortium members and the local stakeholders could be established to identify synergies and possible gaps in local SME support activities, define possible joint initiatives and pool expertise.

• The existence of the Consultative Forum should be formalised in the legal base for the new funding

period and become a governance board with genuine strategic decision-making powers.

• The visibility of the services offered by the EEN should be improved; not the visibility of the network

itself. The EEN brand should be positioned as a quality label promoted by the host organisations and certifying that the services are co-funded by the EU and fulfil specific quality standards.

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Specific comments

1. Promoting the EEN network to SMEs

1.1. Do you have any suggestions for improving the visibility of the network?

The Chambers believe that the Commission should focus on improving the visibility of the services offered by the network rather than improving the visibility of the network itself. The EEN is a tool of the Commission used by the host organisations and integrated in their portfolio of services. The EEN is not a stand-alone brand; it is closely linked to the host organisation, which is usually better known by the SMEs. The host organisations, as co-owners of the EEN, have a legitimate interest in presenting themselves towards the companies and are not willing to offer a pure EEN service since they co-finance at least half of the costs.

Hence, the issue of visibility is above all a question of positioning of the EEN brand. The Chambers believe that the EEN brand should be positioned as a “quality label” promoted by the host organisations, which would certify that the services are co-funded by the EU and fulfill specific quality standards.Raising awareness of the EEN services is a shared responsibility between the host organisations and the Commission, as they together co-own the network.

Experience within the Chamber network showsthat the most relevant and efficient promotion needs to be done locally to reach SMEs. Improving the visibility of the EEN services is therefore also linked with the selection of the host organizations. The visibility of the EEN services is particularly limited when the host organizations represent and/or reach only a few SMEs. The more the host organizations are rooted within the regional business communities, the more the EEN services will be visible.

The network partners also have an important role to play to communicate more and better the EEN services. They should notably inform their clients that the services they provide are possible due to European funding. The opportunity of running PR campaigns to promote the EEN services should be decided by the host structure in line with its own overall press and communicaton strategy. Those host structures that consider it to be of added value to their overall promotional efforts should be given the adequate financial means to carry out this task.

Duplication at national level should also be avoided and the pooling of resources encouraged for the development of common promotional material or activities such as national EEN folders, joint EEN stands at national fairs and a national EEN website.

Using multipliers is a cost-effective and efficient mean of promoting the EEN services. The network partners should therefore cooperate more with the local stakeholders.

Finally, the Commission should play a role in strengthening the profile of the EEN at EU level. The EEN suffers from a lack of visibility among the EU Institutions - notably across the various DGs of the Commission - and other relevant EU organisations. DG Enterprise should promote the network and its results much more, showing that the network is a successful tool which delivers tangible benefits to SMEs in relation to a range of policy priorities (e.g. innovation, research, internal market, environment, etc) and a useful instrument to facilitate the participation of SMEs in other funding programmes and initiatives such as Horizon 2020 and the Structural Funds.

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2. Target Group for the network's services

2.1. Do you have any specific comments and suggestions on the target group of SMEs that the network should aim to provide services to?

The Chambers believe that the EEN services should be open to all SMEs, regardless of their size and sector or whether they are already involved in innovation projects or active on international markets. The EEN partners should have the flexibility to adapt the services according to the specific demand and needs of their clients, thus reaching some particular subgroups of SMEs.

2.2. Do you have any specific comments on possible quantitative objectives to reach a specific number or percentage of SMEs (eventually for specific target groups)?

The Chambers stress that total market penetration is not possible as all SMEs are not fit to receive EEN services. Having said that, quantitative objectives are important but they should be realistic and based on an evaluation of the current programming period (i.e. 2007-2013) taking into account that any increase in quantitative objectives has to be accompanied by additional resources.

Quantitative objectives should be carefully selected so as to guarantee a high level of quality of the services. The aim of the network is to help SMEs, not to tick boxes. Individual support, for instance, has a greater impact than answering a one-off question. The focus should therefore be put on quality before quantity, leaving more time to the actual delivery of services to SMEs.

Furthermore, the Chambers believe that the performance indicators need to reflect more accurately the activities of the EEN. In this respect, the Chambers strongly support the addition of the indicator “Advisory Services Outcomes” and calls for a revision of the definition of “Partnership Agreement“ (PA) as not all successful agreements are registered as PA since they do not match the terms and guidelines as defined by the Commission. The definition should be better defined and broadened in order to notably include international support and background work leading to PAs.

Please refer to EUROCHAMBRES’ position paper “Chambers’ views on the EEN services post 2014” for detailed comments on the performance indicators and targets set for the network in the COSME proposal1.

3. Range of Services

3.1. In addition to the current service range of the Enterprise Europe Network do you have any suggestions for other activities that the network should move into as part of the integrated services offered to SMEs, bearing in mind the need to ensure additionality and EU added value?

The EEN services must be EU-focused and demand-driven, responding rapidly and professionally to trends in the SME community, which can be different from a region to another one.

The network currently covers a wide range of services. The broader the range of activities is, the more resources will be needed from both the Commission and the host organisations, which co-fund the network. A lot of host organisations are currently under financial pressure and must rationalise the scope of their activities. Financing a bigger amount will be an issue for many of them. At EU level, the budget allocated to COSME and Horizon2020 might be seriously reduced further to the Council’s push for a limited overall EU budget for 2014-2020. Therefore, the Chambers believe that there should be no

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expansion of the range of activities, except through signposting, as long as no additional budget is available. The focus should be on increasing the quality of the current set of services and guaranteeing a more coherent and integrated approach to SME support.

EEN core services

The Chambers think that the current scope of activities of the EEN offers already a vast potential of services and that access to the internal market, support to internationalisation and innovation should be the priorities of the network for the period 2014-2020.

The Single Market is still not complete and is constantly developed further. Every year, dozens of EU directives with immediate relevance to businesses are adopted. SMEs have to comply with these rules, but need assistance, especially small businesses that have no access to sectorial associations. The EEN plays a unique role in informing SMEs on the Internal Market via seminars and individual advice on EU regulatory aspects, non-harmonised legislation and EU funding opportunities.

Typical questions are:

• How to undertake a conformity assessment for the toys directive?

• What does an EU-importer need as conformity documents for a Chinese product? • How to find EU harmonised technical standards for machinery?

• How to notify a posting of workers to another country? • How to charge VAT to a client in another member state? • How to find EU-funding for an innovation-related investment?

Furthermore, the EEN is a valuable partner to the Commission for the communication of EU policies to SMEs through the organisation of awareness raising events for businesses. It also helps SMEs to solve the problems they encounter when trading cross-border (e.g. VAT refund, the recognition of a product, etc...) and submits cases to SOLVIT.

The EEN contributes to make the Internal Market a reality for the SMEs in Europe and is the only European network providing that kind of services in the EU. The Chambers therefore believe that supporting and encouraging SMEs to fully enjoy the benefits of the European marketplace should remain the first pillar of activities and focus of the EEN in order to stimulate growth and competitiveness in Europe.

Please refer to question 3.3 and 3.4 for our comments on support to internationalisation and innovation. More coherent and integrated approach to SME support

The EEN services must be fully embedded in the regional eco-system. The network is an “add-on“ to existing national/regional structures and its justification is the European added value. The EEN services should thus complement rather than duplicate existing systems established at national and regional level to avoid deviation from the “single access point” approach and ensure cost effectiveness. This implies that the host organizations should maintain the flexibility to work with their own networks and cooperation partners when delivering the EEN services.

There is however no “one-size fits all” solution regarding the respective activities of the network partners because of the local particularities and the different field(s) of expertise of the host structures.

Hence, the Chambers advocate that the network partners should be given the flexibility to modulate their service portfolio according to the needs of the SMEs on the territory. Concretely, the EEN partners would all deliver the same set of basic services and have the possibility to offer advanced services in relation to the EEN core activities..

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Furthermore, cooperation with local actors and signposting in areas important to foster growth (e.g. access to finance, research & innovation, etc...) should be privileged in order to ensure complementarity and offer a coherent SME support structure to the business community. Please also refer to the chapter 5 for more detailed comments.

3.2. Do you have any other suggestions that can help maximize the relevance to SMEs of services provided by the network?

Maintaining a clear European profile: the network should not lose its specificity which is to facilitate the EU for SMEs.

Integrated range of services: a balance between the various services provided by the network that corresponds to SMEs’ needs – be it a high-growth company or not – should be maintained. • High-quality services: addressing quality issues is of highest priority to increase the relevance of

the services to SMEs. The more customized the service is (i.e. demand-driven), the higher the quality will be and thus the more benefit the client will draw from it.

Complementarity: the services should always be in complementarity to existing initiatives. Cooperation with local players and signposting avoid duplication and creates synergies leading to higher quality and efficiency of services..

Recognition of the diversity of the network: regional particularities and needs should be taken into account by giving the flexibility to each EEN partner to set its own service portfolio and decide on the level of advisory services to be provided (i.e. basic or advanced).

3.3. Do you have any specific comments on activities in the area of internationalization? Please also give comments on the conditions under which more specialised internationalization services could/should be provided (limitation to specialized members, measures to improve signposting, measures to train network members, etc…)

The Chambers believe that the EEN should play a complementary role to existing support structures in the internationalisation post-2014, in particular in preparing European SMEs for internationalisation in their respective regions and countries and in providing information on international aspects of EU policy. The Chambers advocate that complementarity of internationalisation actions and coherence should be the key factors in internationalisation post-2014. In this respect, the Commission should wait for the results of the mapping of existing support services and the assessment of the EU portfolio of

business support for SMEs in third countries2 before taking any action.

The EEN should remain a European network. If the results of the evaluation exercise mentioned above conclude that the EEN should be extended outside the EU, the Commission should have a clear vision of the target countries. Furthermore, the extension of the network should be done through EU bodies located in third countries, whose mandate is to serve the interests of EU SMEs. In India for instance, the European Business and Technology Centre (EBTC) has become the Indian EEN contact point and is working in cooperation with local Indian organisations. This approach would reinforce the much needed coherence between different instruments such as the EEN, the EU SME Centres and Invest programmes;

Finally, allowing 3rd country organisations (e.g. CCPIT in China) to become “member” of EEN dilutes that ownership. A better system would be to create “EEN Recognised Partners”, instead of “members”.

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3.4. Do you have any specific ideas on the type of services that network members could provide in the area of innovation and R&D? Please also give comments on the conditions under which more specialised innovation and R&D services could be provided (limitation to specialized members, measures to improve signposting, measures to train network members, etc...)

The Chambers agree that innovation services should be in the range of the EEN services post-2014. The role of assistance of the network in this field could be enhanced provided that the new tasks are funded under Horizon 2020 (H2020).

The EEN could certainly play an important role in raising awareness of the SME Instrument and providing advice to potential applicants. However, EUROCHAMBRES argues that it is unrealistic to expect the EEN host structures – which vary considerably from one member state to another – to effectively deliver the Horizon 2020 SME Instrument from start to finish. This strategy would also fail to capitalize on the potentially valuable contributions of many actors across the EU that are not involved in the EEN and have, for example, a thematic or sectorial focus.

The Chambers therefore believe that the role of the EEN host structures in relation to the SME Instrument should be to act as an intermediary between the SMEs and a variety of technical experts, directing the SME to the most relevant source of support, whether within or beyond the particular consortium. While in some cases, this expertise may lie within the EEN consortium, in others it may not.

The EEN could also been involved in the identification of topics for the RTD call for proposals due to their geographical coverage and proximity with SMEs and local stakeholders as well as the identification of experts for the evaluation of the projects. The Chambers also stress that the EEN should be mentioned in the RTD call for proposals to inform participants about the support from the network they can get for the exploitation activity.

4. Quality

4.1. Please give concrete examples of the types of service / areas of activity where there are quality issues?

Use of the network by the Commission for policy consultation

The Commission uses more and more the EEN for pre-consultations - thereby leaving out the more representative business stakeholders – as well as to get replies that fit its aims.

Example 1: the Commission launched a consultation via the EEN on the proposal for a Common European Sales Law because the replies it got from the public consultation did not fit its position on the issue.

Example 2: the Commission decided to initially consult the SME Panel via the EEN on the 10 most burdensome pieces of legislation for SMEs before the public consultation.

The Chambers are not per se against the Commission gathering feedback from the SME Panel but we believe that this should be complementary to, rather than instead of, feedback from organisations at EU level representing the interests of several million SMEs and that the results should accordingly be weighted.

Furthermore, there is a need for more transparency in relation to the procedures and rules used for the formation of an SME Panel, its representativeness, the topics, periods, results and use in impact

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assessments. An improvement of the methodology and communication procedures should be foreseen in the near future and discussed by the EEN Consultative Forum.

Examples of other types of services or areas of activity where there are quality issues

• Brokerage events: in terms of number of initiatives, scarce preparation and poor feedback from participating companies

• Quality of the BCD and BBS profiles (responsibility: EEN partners) and the validation time (responsibility: EACI)

• Targeted information on EU legislation: EC marking, Reach, Recycling, Invoicing within the EU, customs and trade, etc ...

Quality of services provided by non EU partners

Lack of follow up of the code of conduct especially among those partners who have signed it • Lack of feedback from the Commission to the host organizations regarding their input in the SME

feedback database

4.2. Improving the quality of the integrated services offered to SMEs:

4.2.1. Do you have any suggestions for improving/ensuring the quality of services?

Focus on the core EEN activities while allowing the EEN partners to define the level of advisory services to be provided. More tasks could complicate the efficiency and profundity of the service offered.

Careful selection of the host organisations for the next call for proposals: locally rooted,proximity to SMEs and possessing as necessary expertise and know-how in the EEN field of activities.

Better integration of the EEN services within the host structure: the EEN-branded services should be an integral part of the host organization’s portfolio of services. Chambers of Commerce and other business organisations already offer a one stop shop for business services and where Chambers act as host organization this represents an excellent synergy since the EEN services are fully in line with the Chambers’ mission.

Use the expertise and know-how of the host organisations in quality management. Quality is an essential preoccupation of Chambers. Their services are evaluated by their customers (i.e. the companies) on daily basis. Additionally a number of Chambers have a national Chamber accreditation or have implemented the ISO standards and other quality systems. “Excellence Awards” with regard to their performance and services have been granted to public law Chambers of Commerce putting them on par with the most efficient and larger businesses. • Reinforcement of the training activities for the network staff (i.e. central and decentralised

training, staff exchanges, mentoring, etc…). The introduction of new services (e.g. information on access to finance, launching new MFF programmes, etc…) will necessitate the provision of training by the Commission for most host organisations.

Closer monitoring of the performance of the network partners, correct application of the Code of Conduct, which should become part of the contract,and audits of consortia without increasing the administrative burden for the host organizations..

Assessment of the activities of the EACI: the reflection on improving the functioning and efficiency of the EEN should also cover the way the network is managed and the role of the EACI in order to determine the kind of administrative structure that should be there and how much it should cost. The EEN Consultative Forum would be a good platform to discuss these issues.

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• Facilitation of exchange of experience and best practices among the EEN partners regarding the core activities of the network by providing more flexible guidelines for the setting up of ad-hoc and long term working groups.

4.2.2. Please give specific suggestions for improving/ensuring the quality of Internationalization services

Effective and coherent cooperation of the EEN partners with various actors/organisations (already established outside the EEN) in the EU and in third countries that have a track record of expertise in the field of internationalisation.

See also answer above

4.2.3. Please give specific suggestions for improving/ensuring quality of innovation and R&D services

See answer above

4.3. Do you have any best practice to share for improving quality of services?

• The Chamber of Commerce of Milan decided to apply its Quality Management System to the EEN services in order to enhance the quality and better serve the companies.

• Follow up of the clients with a profile in BCD or having participated to a brokerage event.

• Continuous best practice exchange between the Consortium partners (exchange of information, peer pressure).

• Within the network: learn from the best (best practice, staff exchange, training,…)

5. Local ecosystem of SMEs and signposting

5.1 Do you have any comments on this suggestion?

The Chambers support the extension of the “no wrong door” approach used among the network partners to the regional dimension. Cooperation at local level is imperative to reach clients and offer a coherent and integrated approach to SME support with no overlap but complementarity activities.

This approach becomes even more essential that money is limited (i.e. both from the host organisations and Commission’s side) and pressure is put on the EEN to provide additional services such as the mentoring and coaching scheme of the H2020 SME Instrument, while appropriate level of expertise is missing.

To make this regional “no wrong door” happen, the Chambers suggest introducing a regional dimension in the work programmes, whereby the EEN consortia would be asked to promote and facilitate cooperation and access to complementary expertise among the local players (i.e. national/local agencies for innovation or export, research promotion agencies, Chambers of Commerce, bilateral Chambers, business agencies, export agencies, funding administrations, banks, etc..).

Furthermore, the host organization should be able to continue to use their own networks and cooperation partners when delivering the EEN services.In Europe, Chambers of Commerce are united into different associated structures at various levels (national, European, transnational) such as the national Chamber association, EUROCHAMBRES, the Baltic Sea Chambers of Commerce, etc…. This network effect amplifies the potential of a single Chamber (including the hosted EEN) through the pooling of resources

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and created synergies. The Chambers therefore ask the Commission to take into consideration these activities and accept them as eligible in the work programme.

5.2 Any other concrete suggestions on how to improve cooperation and signposting between network members and other service providers in the local business support ecosystem?

Each EEN consortium should determine the best approach to boost cooperation between the network members and other service providers according to the specific situation (i.e. existing structures and conditions in the region/country).

One approach could be - under the coordination of the consortium leader - to establish a platform gathering the members of the EEN consortium and the local stakeholders to meet on a regular basis. This would enable to:

• Raise awareness of the service portfolio of each player on the territory

• Avoid duplication, identify synergies and possible gaps in local SME support activities • Devise possible joint initiatives/activities

• Pool expertise and competences for a more effective division of labour

Local partners can also be key multipliers for the promotion of the network services and signposting to the EEN.

6. Host organisations

The Chambers regret that there is no reference to the added value brought by the host organisations in the Commission’s paper “Enterprise Europe Network 2.0. – Challenges for the future”. The success of the EEN is precisely the result of the synergies created with the activities of the host organisations and their financial investment. The efficiency of the EEN derives from the host organisations’ targeted SME focus.

6.1 Do you have concrete suggestions for how to ensure a high level of engagement/contribution of host organisations across the board?

Involve the host organisations in the strategic decisions of the network: the EEN services must find their place in coherence with the strategic plans of the host organisations. As such, the Chambers welcome the setting up by the Commission of the EEN Consultative Forum involving the host structures in the governance of the network, which we consider as a good step in the right direction. The Chambers now ask the Commission to formalise the role of the governance body for the next programming period 2014-2020 (i.e. the Forum is currently set up temporarily) and to reinforce the structure of the new body, which should have decision-making powers in defining the network strategy and priorities. The Chambers believe that the Commission would benefit from having a stronger network with a reinforced legitimacy.

Ensure that the future EEN structures and cooperation agreements provide for sufficient flexibility vis-à-vis the organisational structure, defined functions and role at local/regional/national level and regional particularities of the respective host organisations. A major issue of concern for some Chambers is linked to their institutional identity and independence, which they feel, is affected by the EEN guidelines.

Position the EEN brand as a “quality label” will modify the perception that the senior executives of the host organisations have about the network. They will not see the EEN as a project anymore but as a tool for the development of innovative services in their own organisation.

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Realise synergies between the EEN services and the activities of the hosts and joint activities with new partners should be promoted to demonstrate the benefits gained from an EEN membership and ensure support of the host senior executives.

6.2 Do you have any suggestion on how the service level and quality of the network services provided by the host organisations can be monitored and enhanced across the network?

Improving the monitoring systems already in place (i.e. reporting, monitoring visits, regular contacts with project officer, etc…) without increasing the administrative burden for the host organizations and bearing in mind the heterogeneity of the EEN.

Careful selection of the host organisations for the next call for proposals. The Chambers believe that the host organisations should demonstrate that they are deeply rooted at local/regional level and have a close and trustful relationship with SMEs (e.g. through membership, networking activities, services, etc...). These two criteria are fundamental to the operation of the EEN in order to offer adapted services to the needs of the local SME community.

7. Reducing the administrative burden on network members

7.1 Do you have any specific suggestions for reducing the administrative burden for network members?

The time spent on reporting, eligibility discussions, running surveys and SME panels, etc… is growing in an inverse manner compared to the time spent on providing the services to SMEs.

The working procedures should be simplified: reporting a partnership agreement should not be so complicated, validation of partner proposals should be faster and easier, communication with EACI should be more direct.

Efforts to simplify the reporting procedures should be continued. As such, the Chambers suggest establishing a common online reporting tool for the network. All activities performed during a period would be registered continuously and directly by the network partners in a central online database. Instead of burdensome time sheets and personal salary details, flat rates for staff categories could be used (expert, assistant, head, etc...).

Finally, it does not make sense at all to reduce the number of performance indicators and at the same time increase so-called Deliverables in the Description of Work. It is only a different name, resulting in high administrative burden.

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For further information about the contribution paper: Ms Typhaine Beaupérin

beauperin@The Chambers.eu

Direct tel.: +32 2 282 08 80

EUROCHAMBRES is the sole European body that serves the interests of every sector and every size of European business and the one closest to business. EUROCHAMBRES has member organisations in 45 countries representing a network of 2000 regional and local Chambers of Commerce with over 20 million

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