Annual Activity Report

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EUROPEAN COMMISSION

DIRECTORATE-GENERAL FOR TRANSLATION

Annual Activity Report

2009

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Part 1. Policy achievements

1.1. OVERALL POLICY RESULTS (MISSION AND GENERAL OBJECTIVES)

The following mission for DGT has been set in the annual management plan: "In the interest of the European Union's legitimacy,

efficiency, openness and citizen service, the Directorate-General for Translation (DGT) provides the European Commission with high-quality language-related services for its written communication in all official languages, thereby supporting multilingualism in the European Union."

1.1.1. Objective G1: Support the Commission's multilingual written communication by providing high-quality multilingual translation DGT’s core business is to provide the Commission with multilingual translation services tailored to the customer’s needs: translation, web translation, editing, localisation, terminology gisting and validation, expert linguistic advice, language policy advice.

In this way, DGT enables the Commission to fulfil its political and legal obligations to prepare and monitor legislation in all official languages, and to communicate with the citizens of the EU in their various languages.

Graph 1: Evolution of the translation output by language group

0 200 400 600 800 1.000 1.200 1.400 1.600 1.800 2.000 pages ( tho us an ds )

EU15-PL EU15-NPL EU10 EU2+GA Other* Total 2003 2004 2005 2006 2007 2008 2009

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DGT's performance in delivering high-quality translation and linguistic services is described in the sections below. Generally, the year 2009 was characterised by a lower legislative activity of Commission and Parliament due to their expiring mandates. This resulted in a decrease of translation production, but allowed DGT to put more focus on quality and on web translation. Furthermore DGT worked on enhancing its capacity, preparing for the next enlargement and the introduction of new official languages in the EU, and for the changes resulting from the entry into force of the Lisbon Treaty (TFEU).

DGT has pursued the coordination of the Commission's translation strategy within the context of a coherent and holistic approach to translation, thereby confirming its role as the Commission's translation "hub".

These 2009 institutional changes and the EU2020 long term challenges have conducted DGT to a reflection on its potential future developments, preparing the ground for further modernisation and development of the multilingual communication services.

At the same time DGT has continued to explore ways to further improve cost efficiency, with concrete measures formalized in an action plan, established in cooperation with the Commission's central services.

1.1.2. Objective G2: Support the Commission's policy on multilingualism The Commission is committed to respecting cultural and linguistic diversity. Through the policy of multilingualism the Commission aims at promoting linguistic diversity in society and giving citizens access to European Union legislation, procedures and information in their own language. DGT is a key player in this venture and in this context it has delivered 1.3 million pages of legal and policy documents, and about 133 000 pages communicating Commission policies to citizens and stakeholders via print media and the world-wide web.

DGT also contributes to the Commission’s efforts for connecting with citizens by “going local”, supporting the Representation offices in the Member States and organising such targeted action as the translation contest for schools (Juvenes Translatores) which in 2009 attracted 2 247 students from nearly 600 schools across the EU.

DGT maintains contacts with the translation industry, translation professions and national and international institutions, as well as third countries translation services, builds networks with universities and contributes to the development of the translating profession and the translators' labour market, (inter alia in the framework of the European Master's in Translation project) and actively fosters research and the development of new language

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technology. In 2009, the project on the European Master’s in Translation took off with 34 programmes being selected out of 93 applications.

1.2. ACTIVITY "TRANSLATION"(ABB31.10)

1.2.1. Objective T1: Ensure a sustainable and coherent translation strategy making full use of the resources available, in line with the priorities set and the legal requirements of the Commission

Table 1. Indicators and targets for 2009 in objective T1

Indicator Target 2008 2009

Translation time in working days (median of all documents) x ≤ [2008] 6 6 Percentage of documents for which a derogation from

Commission rules is granted x ≤ [2008] 0.2% 0.3% Number of Service Level Agreements concluded with all key

requester DG's

20 13 23

Successful implementation of the translation strategy

The Translation Strategy implemented since 2004 has allowed the Commission to meet its obligations regarding translation, by concentrating DGT’s resources on the translation of core (i.e. legislative and political) documents and by establishing restrictive rules on the length of documents and the linguistic regime applicable to certain documents. As can be seen from the very low and nearly stable derogation rate, this approach has engendered the sustainability and coherence to enable the Commission to fulfil its mission in this area.

In 2009 DGT continued to negotiate Service Level Agreements (SLA) with major client DGs, in order to optimise the demand management of documents not covered by the Translation Strategy

Given that the practice of direct outsourcing has been criticised by the European Court of Auditors in the past and in order to address the issue of grey translation, client DGs have been invited to list the documents falling in these categories. By offering cooperation in the selection of the external contractors and in performing ex-post evaluation of the quality of the translations, DGT ensures full support of all translation demands.

Furthermore, DGT assessed the likely impact of the changes in the EU legislative procedures foreseen by the TFEU on the volume of the translation demand in order to ensure the adaptability of the current Translation Strategy to new requirements.

The simplification of the Commission internal legislative process by the introduction of the electronic registry (e-Greffe) required adaptations in DGT’s internal workflows, IT applications and quality control procedures. On the other hand, e-Greffe reduced the number of transmission points in the

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document life-cycle and thereby underlined DGT’s role as the guardian of linguistic and formal quality.

Network of reliable contractors

DGT’s freelance strategy aims at improving quality and cost-efficiency of external translations and is based on thematic calls for tender. By complementing these thematic calls for tender by a set of calls for expressions of interest for certain domains and language combinations, a solid network of contractors has been set up for all 23 languages.

All in all 4 calls for tenders entered into force in 2008 and 2009. For a number of lots, these procedures were delayed by two cases of serious professional misconduct among the tenderers. To tackle these infringements of public procurement rules, specific decisions had to be adopted by the Commission. The full set of new thematic calls for tenders will finally be completed with the framework contracts related to translations in the area of economic and financial affairs (ECON), expected to enter into force by May 2010. The current situation is presented in the table below.

Table 2. Thematic framework contracts in force

Code Domain In force as from:

GEN07 Policies and administration of the European Union 01/07/2008

01/11/2008 – BG+RO LEG08 Legal and judicial documents of the EU 28/01/2009

01/08/2009 –EN TECH 1 Transport, energy telecommunications and IT 01/08/2008 TECH 2 Agriculture, fisheries, environment and natural sciences 01/08/2009

ECON Economic and financial affairs 01/05/2010 (expected)

Full use of Information and Communication Technology (ICT) tools

Full use of ICT tools such as TWB and Euramis1 is a long-term target. Sentence managers in the language departments clean up and harmonise linguistic memories eliminating unreliable results. In order to enhance the quality of outsourced translations, freelancers are provided with pre-processed documents. At the end of the reporting period about 31% of all pages translated were saved in TWB and Euramis memories. As the full potential of these tools depends on the amount and quality of memories that they store, improvements remain to be done.

1

TRADOS Translator’s Workbench (TWB) is an integrated translation support. It gives translators

access to all language and phraseology resources from a DGT translation memory (similar or identical segments from previously translated ones).

Euramis is an integration project that gives a single point of entry to numerous translation tools:

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1.2.2. Objective T2: Provide a high-quality service in the field of translation while ensuring cost-efficiency throughout the process

Total translation production (in pages) x > [2008] 1 682 384 1 515 946 Number of web pages processed x > [2008] 63 680 88 254 Deadline compliance (percentage of requests for which all

linguistic versions have been delivered on time) x > 95% 92.6% 94.9% Overall quality control rate for priority (QC1) documents 80% 83.9% 85,9% Deadline compliance by external contractors x > 95% 96.4% 98.1% Percentage of external translations rated acceptable or better x > 95% 87.8% 97.6% The objectives of quality and cost-efficiency are to be addressed throughout the translation process. This requires proactive interaction with the requesting services and stakeholders and necessitates effective total workflow management.

Production

Total translation production encompasses legislation, political and communication priorities and non-legislative texts. The production figures for 2009 show a decrease as compared with 2008 (-8%). The decrease is evident in all categories of documents, in particular for "political priorities and new initiatives". This development reflects the slowed down legislative activity due to the expiring mandates of Commission and European Parliament.

However, the opposite is true for DGT's web translation production (+38% compared to 2008), confirming the trend towards more on-line communication.

Timely delivery

The compliance with deadlines agreed with client DGs was 94.9%, representing an improvement with respect to end 2008 (91.7%). The instruments of early warning, i.e. the "Demand Management Info" document and the "Tableau de priorités et de prévisions", aiming at improving deadline compliance, have been reinforced. While the former is discussed every week in the Directors meeting, the latter is sent to all linguistic departments and is discussed in the weekly meeting between the demand management unit and the heads of the translation units. Thanks to these measures management is

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always aware of the current situation and the deadline compliance target has been met.

Quality

The high quality of its services is the competitive edge of DGT. It endeavours to ensure quality in a cost-efficient way in all 23 languages. The quality of service is defined by both the accuracy and consistency across the different language versions of the product (translated documents and websites/pages) and its timely delivery to the requester. This is of the utmost importance for the legal certainty of the Commission's written communication, the legitimacy of the Commission's acts and the understanding of the raison d'être of those acts by the citizens. To that end DGT launched in 2008 a Total Quality Management programme, based on a CAF assessment, which resulted in 7 generic improvement actions and 22 actions specifically targeted at the linguistic quality. All quality actions are now consolidated into a central Quality Management System and the continuous upwards trend of the control rate (85.9% compared to 80%) is one of its positive effects.

Outsourcing

Nearly 75% of the output was produced in-house. The corresponding outsourcing rate of 25.9% was slightly lower than in 2008, the main reason for this being a reduced workload in early 2009 and increased internal resources in EU-12 language departments.

Several measures were taken to enhance cost-efficiency and quality of outsourcing (seminars for contractors, dedicated websites, proactive communication with contractors, etc.). As a result of all these initiatives the percentage of outsourced translations rated acceptable or better increased by nearly 10 percentage points compared to the overall figure of 2008 and the deadline compliance rate was further improved thanks to the continuous monitoring and application of penalties applied whenever justified (i.e. in 345 cases).

Thanks to good planning and management of the adjusted budget available for outsourcing, the budget execution rate has never been as high as in 2009 (98.6%).

Cost effectiveness

As can be seen from the graph below, DGT has, on average, improved considerably its cost effectiveness over the last decade.

While the number of translators in the translation departments has increased significantly since 2002, the number of ASTs has remained rather stable, decreasing the relative number of the latter while increasing productivity

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thanks to an increased and more effective use of ICT tools and the appropriate training of AD and AST staff to cope with more complex tasks.

Graph 2: Evolution of the number of translators and translation output

0% 20% 40% 60% 80% 100% 120% 140% 160% 180% 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 cu m u la ti v e ch an g e ( 1 99 9 = 10 0% ) Output in pages Translating staff

1.2.3. Objective T3: Enhance translation and multilingual communication by providing the Commission with high-quality language services (localisation, editing and linguistic advice)

Number of documents processed at Field Offices n/a n/a 5 313 Number of pages edited by Editing service + 10% 40 285 42 112 Customer feedback (positive comments) on editing services n/a n/a 97%

DGT provides the Commission with complementary services and products such as localisation, editing and the provision of linguistic advice.

Localisation and drafting of the Commission's messages

Through the activities of its staff in Field Offices for multilingualism (FOs) within the Member States, DGT focuses on clear and comprehensible communication with EU citizens. A new framework agreement between DGT and DG COMM (signed in June 2009) allowed DGT to provide a better service to the Commission's communication service. This concerns not only the drafting and localisation of messages, adapting them to their specific political, social and cultural context, but also includes a better interaction with all stakeholders in the language community, helping to promote DGT's and the Commission's multilingualism policy.

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Editing of original drafts

DGT advises the Commission services on linguistic issues and provides assistance with drafting, abridging and standardising of texts. The majority of DGT's editing service effort was devoted to the editing of major Commission documents drafted in English and French in order to ensure that they were orthographically, grammatically and stylistically correct and linguistically fit for purpose, e.g. sufficiently clear to be understood by the target audience or to be translated into other languages, thereby contributing to the quality and cost-efficiency of DGT's translation activity.

Despite the reduced overall demand for translation the editing service produced 5% more than in the previous year.

A customer satisfaction survey launched in July 2009 showed a very high rate of satisfaction with the editing services2. A large majority of respondents thought editing should be made compulsory for important documents. This was confirmed by the Commission-wide Clear Writing survey of November 2009. The Clear Writing Campaign to be launched in March 2010 should help to further raise awareness of the need for quality originals.

1.3. ACTIVITY "POLICY STRATEGY AND COORDINATION"(ABB31.12)

DGT contributes to the Commission’s policy of multilingualism inter alia by maintaining contacts with the translation industry and academia and national and multinational institutions.

In the context of the Development and Cooperation policy of the Commission, DGT has been providing assistance in the build-up of language services to the Conference and Documents Service of the Commission of the African Union as well as assisting the Caribbean Research Institute for Translation and Interpretation (CRITI) in the setting up of its translation service.

Furthermore, new avenues of cooperation have been identified for collaboration on terminology and translation with the Arab League, Canada, and China. A training programme has been set in place for DGT's translators fluent in Chinese in Taiwan (China) and mainland China. Exploratory talks took place with the International Criminal Tribunal for the former Yugoslavia in The Hague for reciprocal access to translation memories and an action plan has been set up with the translation service of NATO Head Quarters. As for the assistance request received from Russia, DGT is providing assistance in the training the new generation of translators that will be dispatched to international organisations. In cooperation with the translators of the Commission Delegations in Russia and the New

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Independent States, a project addressing a common glossary of politically sensitive terms and its validation for its uploading in IATE (Inter Active Terminology for Europe) has been carried out. At the same time DGT has reinforced its status of model organisation in international fora where it remains the benchmark for other translation services by answering to the calls from IAMLADP.

DGT has played a key role in the Interinstitutional Committee for Translation and Interpretation (ICTI). Under its presidency it has engineered a reform of the governance structure that aims at making ICTI a strategically geared decision making body unlocking all potential synergies between the European Institutions' Translation Services. DGT was also the leading body in the cooperation and development in the area of ICT tools for translators and enhancing cooperation to ensure the required staff competences.

By building networks with universities DGT contributes to the development of the translator’s profession and labour market. In this respect, DGT successfully completed two of its flagship activities:

– Juvenes Translatores attracted 2247 pupils from 599 schools across the EU (a 12 % increase compared to last year’s exercise). The project clearly contributes to advancing and promoting the role and image of translators across the EU and encourages a number of Member States to reconsider language teaching in secondary schools with a view to enhance their curricula.

– The European Masters in Translation (EMT) was launched in 2006 with a number of universities interested in the creation of a network. The project aims at strengthening the translator’s profession, improving educational standards and enhancing the labour market on the basis of a common competence framework. In 2009 DGT received 93 applications for the programmes to be included in the EMT network; out of which 34 have been selected. The structure of the network has been set up paving the way for the programmes to begin enrolments.

DGT is encountering a strongly increasing demand for information about multilingualism, the EU's language regime and translation activity. Information material and promotional actions, e.g. in the framework of the European Day of Languages, contributed to overall visibility of the service. At public events, and especially during visits to schools and universities, DGT's Field Offices play an important role in acting as ambassadors for the DGT and the translation profession in general.

DGT also promotes translation studies through its contacts with the academic community. In 2009 a conference was organised to present the results of the study Size of the language industry in the EU. On that occasion experts gathered to discuss the findings and a possible follow up.

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1.4. ACTIVITY "ADMINISTRATIVE SUPPORT"(ABB31.10)

Providing administrative support to the largest public translation service world-wide involves a complex set of operations.

In the budgetary context of "zero growth", DGT conducts on a regular basis a prioritisation of staffing needs and a review of staffing benchmarks for language departments. This results in a redistribution of posts in order to minimise the effects of departures and the generation shift in some EU15 language departments. Despite the progress in the recruitment of staff for EU10 language departments, the number of laureates of EPSO competitions does not allow to fill all needs.

In this respect, DGT works closely with EPSO to redefine the recruitment procedures and ensure a better alignment of the laureates’ skills with DGT’s competency needs. However, for several languages the reserve lists for translators will not be available on time and DGT will need to recruit a large number of temporary staff requiring considerable efforts from DGT's side for organising the selections and deviating resources to non-core DGT tasks. Considering the possible accession of Croatia the selection of contract agents to cover pre-accession translation needs has started. DGT has also been closely monitoring progresses related to the request for accession tabled by Iceland and the reunification of Cyprus.

With respect to the improvement of the competences of staff continuous efforts for implementing the Learning and Development Framework (LDF) led to an average of 10 working days of training per staff member. In order to optimise the budget for language training, better synergies between different training settings are being explored.

The availability of a register for the competencies of an organisation is an important management tool. As a result from the TQM programme, it was decided in 2009 to replace the outdated language register with a modern application to register language skills, education and expertise. After consultation of all managers, a decision on the preferred option will be taken in early 2010, and development will follow.

In order to further improve the efficiency of translation processes DGT invests significantly in reliable ICT tools and in consolidating the ICT infrastructure in collaboration with DG DIGIT. A new IT-governance structure has been put in place, focusing on better planning and follow-up and direct user involvement in the ICT development process.

A new strategy for machine translation was adopted and an interservice task force has been set up with the main stakeholder DGs in the Commission under the leadership of DGT. The task force started its work in December with the objective of preparing a roadmap and delivering a report by March 2010.

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In the domain of physical work environment, DGT improved office conditions in its buildings in Brussels and prepared office space and equipment for the future arrival of Croatian and Icelandic translators. It also increased its capacity for handling the translation of classified documents. DGT managed a budget of the total of € 24.7 million (including € 7.2 million for external staff)(. This budget is managed according to the direct centralised management mode, and is mostly executed through a large number of individual financial transactions, each one of relatively low value. The advanced budget planning techniques supplemented by continuous monitoring allowed DGT to achieve a very high budget execution rate, most importantly in its biggest budget line (external translation), which has been executed in 98.6% (see annex 2 for more details).

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Part 2. Management and internal control systems

2.1. DGT OVERVIEW

Geographically, DGT is a ‘transardennais’ Directorate-General with staff spread more or less evenly between Brussels and Luxembourg. It comprises six directorates, three of them hosting the 23 language departments. Besides the core translation work, the individual language departments also take charge of terminology and documentation and are responsible for keeping linguistic standards high and consistent in DGT’s output in each of the official languages.

Three other directorates deal respectively with:

(1) transversal linguistic services (web translation, editing, documentation/terminology and staff based in the Field Offices in the Member States);

(2) resources: staff recruitment, management and training, ICT, finance and physical infrastructure and logistics;

(3) translation strategy and multilingualism: demand management and internal workflow, free-lance outsourcing, multilingualism studies, evaluation and analysis.

The description of DGT's main process is documented in Annex 5.

In accordance with the working arrangements with the Cabinet, regular information was passed on to the Commissioner to enable him to follow issues of critical importance relating to DGT’s management and to the stages of the ABM/SPP cycle. This information was then discussed during the "jour fixe" meetings between the Commissioner and the Director-General

2.2. THE FUNCTIONING OF DGT’S INTERNAL CONTROL SYSTEM

DGT operates in a low risk environment. The management mode is direct and centralised. DGT managed administrative expenditures amounting in 2009 to € 24.7 million, of which € 17.5 million under direct responsibility. Nonetheless, DGT implements internal control principles with the same attitude towards scrutiny, attentiveness and effectiveness as other DGs.

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2.2.1. Compliance with the requirements of the control standards

The Commission has set a baseline standard for its internal control performance by defining 61 baseline requirements. In order to meet the requirement of the single point of responsibility, DGT has identified business owners (i.e. individual units) for each of them. Compliance is monitored throughout the year, and the exercise is formalised in the context of the Bi-annual reporting (i.e. twice a year). Formal and substantial compliance with the requirements at end 2009 can be considered very satisfactory: out of the total 61 requirements, 54 were fully implemented, while 7 were being executed. The latter refer namely to "sensitive functions", one aspect of the Business Continuity Plan, and "information and communication": for all these cases, compliance will be ensured in the short term.

The implementation of the Strategic Planning and Programming (SPP) cycle is supported by a dedicated SPP/ABM working group chaired by the Director-General and co-chaired by the Director of Resources. This working group has been effective in implementing strategic planning within DGT through high-level steering from senior management, strategic risk assessments structured around the objectives identified and bottom-up contributions from all departments represented in this group. Through this process, DGT has defined its outputs to achieve objectives/results and has agreed on actions to control/mitigate risks impacting thereon.

This approach has ensured that the different layers of the organisation contribute actively to the planning process, thereby ensuring that objectives and targets are understood and owned by the various DGT services.

2.2.2. Effectiveness of the implementation of the prioritised control standards

The risk-based prioritisation of internal control standards in 2009 led to the selection of following 6 standards:

Processes and Procedures (No. 8)

Given the complexity of the operations and the variety of procedures, and the special role of DGT within the Commission, it is of the utmost importance that all procedures be adequately documented and compliant with the rules, in particular those provided for by the Financial Regulation. The most important process in DGT is the translation process. In 2009, this process was applied to 56 489 documents requested for translation.

The Resources Directorate regularly updates the Reference Guide to DGT’s Procedures which is available to all staff on the intranet (DGTnet). A vade-mecum on recruitment and another on the organisation of away-days has been set-up in 2009. Both documents will be published on DGT’s

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intranet. A register of procedures applicable in the field of information and communication technology is also maintained.

All DGT financial circuits have been defined and documented and comply with the rules on the segregation of duties. Exceptions in the field of financial management are centrally managed and reported upon twice a year (BiAR) by all authorising officers by sub-delegation (AOSD). This report also includes, when necessary, exceptions in the field of operational management.

Information and communication (No. 12)

DGT is the largest Commission DG in terms of staff. A proper internal communication flow, in both directions, is therefore fundamental. Senior staff decisions and instructions, as well as information of general interest, are passed on effectively through the appropriate channels.

Regular reporting provides management with relevant and pertinent information on the performance of the organization:

– An automated and real-time tool monitoring translation processes (StatSuivi) is accessible to all senior and middle managers facilitating the daily management of incoming documents and workload in DGT.

– A monthly snapshot of key performance indicators constructed in accordance with the balanced score-card (BSC) methodology is provided to the management. DGT was among the first DGs in the Commission to develop and successfully implement this tool. It shall be noted, however, that DGT's internal auditor made some critical remarks on this BSC (see section 3.1.2). The IAC's comments will be taken on board to improve the quality and timeliness of this information.

– The monthly budget execution report gives a detailed situation of each budget line. This allows management to react and shift financial resources where needed and optimise the budget execution rate (98.9% in 2009). – Twice a year each director submits to the Director-General a report on the

use of resources (BiAR) giving an overview of the implementation of the Annual Management Plan, the budget execution , the allocation of human resources, the follow-up on audits and the state of the internal control In the domain of external communication DGT has established a three-year (2009-2011) strategy setting objectives for the communication within the Commission, with the other EU-Institutions and the outside world. However, internal communication via DGT's intranet (DGTnet) was hampered by the delays encountered in the "WebPortal" project.

ICT systems used and managed by DGT were adequately protected against threats to their confidentiality and integrity. DGT appointed a Local Information Security Officer (LISO) and a Data Protection Coordinator

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(DPC) who are responsible for compliance with Commission information security and data protection rules.

Staff Allocation and Mobility (No. 3)

In order to respond to external challenges (enlargement, changes in the processes, etc.), resources must be managed effectively, and matching resources with needs (objectives to pursue) becomes an imperative.

Since 2008, DGT calculates, twice a year, staffing benchmarks for the Language Departments. Posts that fall vacant are reattributed taking into account these benchmarks as well as other objective factors such as the availability of reserve lists. Staffing tables are provided every two months in order to ensure timely and adequate replacement staff.

Internal mobility is promoted by secondments, initially for a period of 6 months. These are intended to be a learning experience for translators interested in changing career at some later stage. Moreover, hand-over reports are common practise, especially for mobility of middle managers. Staff Evaluation and Development (No. 4)

Staff being the most important resource for DGT, the annual appraisal and promotion exercise plays an essential role for DGT management. The Learning and Development Framework (LDF) is managed by the training unit in cooperation with all other units. It is based on an analysis of available skills and competencies and future requirements. Access to central language training is streamlined on the basis of the service needs and specific subject matter courses are organised to strengthen knowledge and competencies in specialised areas like economics and legal matters. A few weaknesses (e.g. “lack of focus”) identified by the IAC have been properly addressed.

ICT training is organised by the IT unit in collaboration with DG DIGIT. First steps have been taken for defining a DGT-wide competency register. At present DGT faces recruitment difficulties due to the fact that for some languages reserve lists are not existing or exhausted and new competitions are not planned for the short term. For some languages, selections for temporary agents are organised by Human Resources Unit of DGT

Management Supervision (No. 9)

Supervision by the management is fundamental. Monitoring tools – such as the regular follow-up of audit recommendations – must ensure that DGT's activities are performed properly, and potentially critical risks are well documented.

DGT's most critical risk derives from the lack of translators in some language departments. In order to mitigate the situation DGT negotiated with DG HR on the extension of contracts for temporary agents already in

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place and collaborates actively with EPSO on the organisation and structure of new competitions. However, the planned late availability of EPSO reserve lists, forces DGT to organise its own selections for temporary agents. Both activities demonstrate clearly the structural need for more resources in the Commission's personnel selection process.

Three cross-cutting risks in DGT were identified and communicated to the Secretariat General and DG BUDG in December 2009. They relate to 1) the unavailability of translators in some language departments (selection process), as stated above, 2) the application by the DGs of the RUE system (secured translation), and 3) the impact of the Lisbon Treaty (TFEU) on the translation activity.

Ethical and Organisational Values (No. 2)

Staff needs to be aware of the relevant ethical and organisational values. DGT deals with a multiplicity of contractors, and ethical behaviour is essential: proper conduct, avoidance of conflicts of interest, reporting of irregularities.

Newly recruited staff is systematically made aware of all relevant provisions. Documentation is accessible through a dedicated webpage on internal control standards which also provides links to concise and user-friendly guides. An awareness raising campaign on ethical values was elaborated by the Internal Control Coordinator and launched through intranet in November. Another campaign (on processes and procedures) was launched in December, while others – covering the most relevant ICS for DGT – are being finalised and planned for the 1st quarter of 2010.

2.2.3. Conclusion

In the light of the results of the assessment of the compliance and effectiveness of the internal control against the Internal Control Standards, the results of controls, the risk analysis performed in the context of the Annual Management Plan, the implementation of recommendations of the different control bodies, DGT's control system can be considered as working as intended.

In this context, risks are properly managed, thanks to the existence of an enhanced control environment combined with a centralised management mode and the relatively low amount - and nature (administrative) – of DGT expenditure.

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Part 3. Building blocks towards the declaration of assurance

3.1. BUILDING BLOCKS TOWARDS REASONABLE ASSURANCE

DGT’s financial operations bear limited financial risks in terms of legality/regularity and do not require ex post on-the-spot controls at the level of the final beneficiaries. A number of indicators have therefore been set up to monitor legality/regularity and sound financial management.

Table 5. Key legality and regularity indicators

Indicator Measurement

2007 2008 2009

Budget (after mid-term adjustments) execution rate 96.0% 95.9% 98.9% % of payments made within the contractual period 94.5% 95.4% 95.0% % of absorption of budgetary backlog (RAL) 91.1% 91.6% 92.5% Mean delivery delay of monthly budget execution report n/a 12 days 15 days Financial exceptions handled № 56 42 42

Total value (€) 9 780 000 3 _{85 872} _{189 402}

% of audit universe audited in the last 3 years 12% 33% 56% Audit recommendations put in place within deadlines n/a n/a 74% Audit observations that might lead to reservations 0 0 0 Cases referred to OLAF over the last 3 years 0 0 0 In 2009, a total of 42 exceptions were handled; 39 "ex-post" (with an average value of € 4 248) and 3 authorised "ex-ante" (average value of € 7 905). The largest group of recorded exceptions related to mission expenditures: 14 such cases were recorded with a small average value of € 359.

3.1.1. Building block 1: Assessment by management

DGT management carefully considered the Directorate-General's overall performance, controls and supervisory checks carried out during 2009, and did not identify any significant (repetitive) errors. The management is therefore of the opinion that DGT control systems are sufficiently robust and effective in preventing, detecting and, whenever necessary, correcting errors.

3_{The 3 authorized ex-ante exceptions (related to the extension of the validity and amounts of framework}

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3.1.2. Building block 2: Results from audits during the reporting year In her opinion on DGT's state of control in 2009, the IAC declared that the internal control system in place in DG Translation provides reasonable assurance, based on the individual audit opinions arising from assurance work carried out in 2009, except for some very important issues relating to "staff training" (lack of focus, heavy procedures), "management information" (timing, pertinence and consistency of the information produced for the Balanced Scorecard, possibility of errors), and "financial reporting" (concentration of tasks on individuals, delays in processing invoices).

Since there is no critical recommendation and none of the very important issues relates to legality and regularity of transactions, the IAC stated that she was not aware of anything which should lead to a potential reservation in the AAR.

3.1.3. Building block 3: Follow-up of previous year's reservations and action plans for audits from previous years

DGT started the year with 14 open recommendations resulting from previous audit work, internal control self-assessments, risk assessments and discharge resolutions. During the year there have been 124 recommendations added to that register, resulting from audits closed in 2008 and 2009 and for which the action plan has been established in the year 2009.

102 of these open recommendations were addressed. DGT also increased its awareness of customer perception by organizing a customer satisfaction survey for a second time (which showed an increased number of satisfied respondents of 92%).

At the end of the year a total of 36 recommendations remain still open. All but one are behind schedule - for 13 of them the delay is 6 months or more. Irrespective of the fact that none of these open recommendations have 'critical' priority, DGT clearly suffers from a lack of timely implementation of audit recommendations and will address this issue in the first semester of 2010 as a priority action.

3.1.4. Building block 4: Assurance received from other Authorising officers in cases of crossed sub-delegation

Not applicable.

3.1.5. Building block 5: Completeness and reliability of the information provided in the building blocks.

The information presented in the previous sections represent an overview of the elements leading to the declaration of assurance. This information, combined with the elements provided in the other chapters of this Report, aims at providing an exhaustive and fair view of DGT's situation.

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3.2. RESERVATIONS

No weaknesses have been identified in the reporting period that would lead to reservations in this Report.

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Part 1. The declaration of assurance

I, the undersigned,

Director-General of Directorate-General for Translation In my capacity as authorising officer by delegation:

– Declare that the information contained in this report gives a true and fair view1. – State that I have reasonable assurance that the resources assigned to the activities

described in this report have been used for their intended purpose and in accordance with the principles of sound financial management, and that the control procedures put in place give the necessary guarantees concerning the legality and regularity of the underlying transactions.

This reasonable assurance is based on my own judgement and on the information at my disposal, such as the results of the self-assessment, ex-post controls, the work of the internal audit capability for years prior to the year of this declaration. – Confirm that I am not aware of anything not reported here which could harm the

interests of the institution.

Brussels, 31/03/2010 (signed) Karl–Johan Lönnroth 1

Annual Activity Report

Annual Activity Report

2009

Contents

Part 1.

Policy achievements

Part 2.

Management and internal control systems

Part 3.

Building blocks towards the declaration of assurance

Part 1.

The declaration of assurance