Jakob Flamm v Commission of the European Communities (567/79 A)

I —Facts and written procedure

By decision of 2 March 1970 concerning the use of the sums available under the European Coal and Steel Community budget item “Pension Funds” the Council authorized the Commission to set aside 40% of the said sums for the grant of building loans to officials of the Communities.By decision of 17 June 1971, published in Staff Courier No 170 A of 8 July 1971, the Commission issued the necessary implementing provisions, in particular:“Article 9.Loans covered by this provision shall be expressed in Belgian francs. The payments in respect thereof shall be made in the currency of the country in which the property to be financed is situated, on the basis of the parity ruling at the time of the payment.”Article 7 (2) (a) provides that the interest and repayments due from the official under the loan are to be retained from his remuneration pursuant to instructions given for that purpose to the Commission. Article 11 (2) provides that no amendment to the implementing provisions may jeopardize the rights conferred upon officials who have already been granted loans.Accordingly, the loan agreements entered into between borrowers and the Commission include inter alia the following provision:“Article 15Any transfers by the borrower to the lender by way of early repayment or in payment of monthly instalments shall be made in Belgian francs or in the currency of the country in which the property to be financed is situated in which the funds arising from this loan were advanced. The funds in question shall be converted into Belgian francs on the basis of the parity ruling as at the date of the transfer.”Until 31 March 1979, the monetary parity applied for conversion between the Belgian franc and other currencies was the parity notified by the Member States to the International Monetary Fund in 1965 (BFR 1 = LIT 12.50 in the present case). The sums lent were repaid (likewise on the basis of the exchange rate indicated above) by means of deductions made by the Commission, in its capacity as lender, from the monthly remuneration of officials.The system operated as follows: the official's monthly salary, to which the weighting was applied (for example BFR 100000 x Italian weighting of 157.8 in March 1979) was reduced by the amount of the building loan instalment (for example BFR 5000), the net remuneration then becoming, in the example given, BFR 152800, which was converted into Italian lire at the rate of BFR 1 = LIT 12.50.By decision of 25 July 1975, published in the Staff Courier of 15 September 1975 (Special inter-institutional issue), the Commission amended Article 9 of the implementing provisions of 17 June 1971 as follows:“Loans covered by this provision shall be expressed and paid in Belgian francs. The deductions and payments referred to in Article 7 (2) shall be made in Belgian francs, as shall any repayment made by the borrower to the Commission.”The Staff Courier further stated:“In the case of contracts already signed, borrowers will receive a personal communication regularizing their position from the Directorate-General for Personnel and Administration.”That decision to the Commission was notified to the applicant by letter of 21 August 1975 from the head of the Building Loans Division, offering him a reduction of his principal debt and concomitantly the adoption of the Belgian franc as the only currency in which subsequent repayments might be made. Mr Flamm refused the reduction of the amount of the principal debt offered him.In Staff Courier No 136 of 7 February 1977, the Commission published the following notice :“On 27 July 1975 the Commission decided that Commission building loans would in future be paid — and deductions from salaries to repay the loans would be made — in Belgian francs rather than in the currency of the country where the property covered by the loan in question is situated. Hitherto, all deductions have been calculated, where necessary, on the basis of parities at 1 January 1965. Henceforth, by decision of the Director-General for Personnel and Administration, conversion will be based on ‘updated’ exchange rates. However, staff may request that the deductions be made at the parities communicated to the International Monetary Fund, with reference to and within the scope of the provisions giving effect to Article 17 of Annex VII to the Staff Regulations (transfer of part of emoluments through the Commission).”Confirmation of that notice was given to the persons concerned by letter from the Director-General for Personnel and Administration in June 1977.On 23 December 1971 Mr Flamm had entered into an agreement with the Commission for a loan of BFR 750000, the exchange value of which in Italian lire, namely LIT 9375000, was paid to him pursuant to Article 9 of the implementing provisions adopted on 17 June 1971.Mr Flamm's salary statement for March 1979 showed a loan repayment of BFR 4661, converted into LIT 58262. In respect of April 1979, the same amount in Belgian francs was converted into LIT 85561.In fact on 21 December 1978 the Council had adopted Regulation No 3085/78, amending, with particular reference to the monetary parities to be used, Regulation No 259/68 laying down the Staff Regulations of Officials of the European Communities and the Conditions of Employment of Other Servants of the Communities, Regulation No 2530/72 and Regulation No 1543/73 concerning certain special measures (Official Journal 1978, L 369, p. 6) and Regulation No 3086/78 adjusting the weightings applicable to the remuneration and pensions of officials and other servants of the European Communities following the amendment of the provisions of the Staff Regulations concerning the monetary parities to be used in implementing the Staff Regulations (Official Journal 1978, L 369, p. 8). By means of those regulations the Council amended in particular Article 63 of the Staff Regulations of Officials and updated the exchange rates. The reference to the IMF parity was abandoned and for transfers in a currency other than that in which remuneration was paid the exchange rate used for implementation of the general budget of the European Communities on 1 July 1978 (reviewable) was imposed (that is to say LIT 26.11 = BFR 1), a coefficient being applied pursuant to Article 17 of Annex VII to the Staff Regulations “representing the difference between the weighting for the country in whose currency the transfer is made and the weighting for the country in which the official is employed”. The object of the application of that coefficient was to ensure, as regards the part of the salary transferred to a country other than the official's place of employment, that every official should, as a result of the adjustment of that portion by means of the weighting applied in the other country, enjoy exactly the same purchasing power, for the corresponding portion of his salary, as an official employed in that country. For the IMF rate of BFR 1 = LIT 12.50 the rate of BFR 1 = LIT 18.35 was therefore substituted, remaining in force until 31 January 1980. As from 1 February that rate was changed to BFR 1 = LIT 19.80.The persons concerned were informed of the new provisions by Circular No 19/C — 2/79 of 1 March 1979 and by Administrative Notices No 230 of 9 April 1979 (which gave details of the new rates applicable to repayments in Belgian francs for Commission building loans).On 27 March 1979 a complaint pursuant to Article 90 of the Staff Regulations was lodged by the applicant against the consequences for repayment of the building loan of Regulations Nos 3085/78 and 3086/78.By letter of 12 July 1979 the Commission rejected the complaint.A fresh complaint dated 11 July 1979 was lodged by the applicant (cf. Cases 530 to 729 and 781/79 Al and Others) pursuant to Article 90 (2) of the Staff Regulations against the application of those regulations to the calculation of the remuneration paid in respect of April 1979.The Commission rejected the second complaint by letter of 28 September 1979.By applications dated 17 December 1979 received at the Court on 24 December 1979, 13 officials (in the group 530 to 729 and 781/79, one of whom was the applicant, lodged a supplementary application disputing the procedures for repayment of the building loans granted by the Commission, which the latter had changed as from April 1979 on the basis of the contested Council regulations.By memorandum dated 9 April 1980 the Commission contended that the supplementary applications should be dismissed as inadmissible and that the statements relating thereto be treated as separate applications.By letter of 14 January 1981 the Registrar of the Court informed the Commission that the Court (First Chamber) had decided to treat the supplementary claims as new applications.On hearing the report of the Judge-Rapporteur and the views of the Advocate General the Court (First Chamber) decided to open the oral procedure without any preparatory inquiry.It should be noted that, by order of 14 October 1981, the Court (First Chamber) declared the application inadmissible in so far as it was directed against the Council.

II —Conclusion of the parties

The applicant claims that the Court should :I.10. Declare unlawful and annul the salary statement issued by the defendant for April 1979 and its decisions of 28 September 1979 on the applicant's complaint in so far as they relate to deductions for repayment of a building loan granted by the defendant, which, if the amounts deducted by way of repayment are converted at the rate applied for the advance of the loan, exceed the amounts in lire relating thereto;11. In the alternative, in the case of the applicant, who in 1975 “updated” the building loan agreement concluded between him and the defendant, declare unlawful and annul the salary statement issued by the defendant for April 1979 and its decisions of 28 September 1979 on the applicant's complaint likewise in so far as they relate to deductions for repayment of a building loan granted by the defendant, which exceed the amounts in lire paid for that purpose until March 1979 inclusive on the basis of a higher rate of exchange applied to the advance of the loans at the time of amendment of the contract (“updating”);12. Direct that, as regards the amounts thereof in lire, the monthly repayments of the building loan are to remain the same as the amount thereof as at 1 April 1979;13. In the further alternative, in the case of the applicant, whose contractwas “updated” in 1975, direct that, as regards the amount thereof in lire, the monthly repayments of the building loan are to be calculated on the basis of an exchange rate which corresponds to the exchange rate applied to the advance of the loans at the time of the updating;14. In the final alternative, declare that during the two years after the Court's decision becomes res judicata, the applicant is to be entitled to make early repayment of his building loan on the basis of the exchange rate applied to the advance ofthe loan;15. Order the defendant to amend the applicant's building-loan account, regard being had to the heads of claim in paragraphs 1.10 to 13;16. Order the defendant to pay to the applicant in Italian lire the amount of the difference resulting from the calculation made in accordance with the head of claim in paragraph 1.15;III.1. Order the defendant to compensate the applicant for the pecuniary damage suffered, which the Court is requested to determine to be'the amount of interest, at the rate of 6%, accrued on the amount of the arrears from the respective dates on which they fell due until the date of payment;2. Order the defendant to pay the costs.The defendant contends that the Court should:Dismiss the action as unfounded;Order the applicant to pay the costs.

III —Submissions and arguments of the parties

The applicant alleges in the first place a breach of the law of contract. When the agreement was entered into the parties stipulated for repayment of the loan at the rate at which it was advanced, namely LIT 12.5 = BFR 1. The Commission is not entitled to amend the agreement unilaterally and to the detriment of the applicant. Had the applicant had notice of so onerous a farovision he would not have signed the oan agreement since the long-term risk of depreciation of the lira was, as far as he was concerned, incalculable. Similarly, the applicant adds, he would not have obtained in lire the real value at the material time of his loan expressed in Belgian francs, but rather an amount calculated according to the special rate applicable to internal dealings.Both the applicant's remuneration and his loan have been and are determined in Belgian francs but paid in the currency of his country of residence. If now the loan were to be repaid in Belgian francs the Commission could make deductions from the remuneration determined in Belgian francs and subsequently concert the amount, still expressed in Belgian francs, into lire and pay that amount in lire to the applicant. But the Commission wishes precisely to avoid that situation because, from a formal point of view, it distinguishes between the loan and the payment of remuneration and because subsequently, when the loan is repaid, it achieves a very significant gain. However, to regard the grant of the loan as the payment of remuneration is contrary to Article 62 et seq. of the Staff Regulations.Moreover, the Commission's procedure is also at variance with the obligation to provide assistance which it must discharge with respect to the applicant. Had there been any intention to impose upon the applicant a monetary risk for a period which now, as a result of the increase in the amount to be repaid, extends beyond his retirement, an express provision to that effect should have been included in the agreement.If, when in 1975 it brought pressure to bear on officials to apply for updating, the Commission was planning the present measures, it has laid itself open to allegations of fraudulent conduct.If the changes decided upon by the Commission should be found to be valid, the applicant considers that he should at least be allowed the opportunity, by virtue of transitional provisions, to terminate the existing agreement and repay his loan according to the original conditions of the agreement. A period of three years after the Court's decision has become res judicata would be appropriate in this case, in view of the fact that the sums borrowed are very large and arrangements were made for very long repayment periods, and repayment would become possible by means of new loans on a commercial basis.The Commission thinks that the view put forward by the applicant presupposes that the loan agreement offered him a legal guarantee that payment of the monthly amounts expressed in Belgian francs would be made at the same rate as that used for the advance of the loan. That view of the legal position is not supported either by the provisions of the contract or by the general implementing provisions of 17 June 1971 according to which the loan and the monthly amounts payable by the applicant are expressed in Belgian francs.It is true that the contractual provisions indicate that the amounts due may be paid in lire (Article 15). But it is also true that the repayments in lire in respect of the debt expressed in Belgian francs are not converted into Belgian francs at the rate ruling on the date of the advance of the various instalments of the loan. The conversion is made, in accordance with the second paragraph of Article 15 of the contract, on the basis of the parity ruling on the date of the transfer of the monthly amount payable in accordance with the repayment table. In view of the general scheme of the agreement, that provision necessarily means that the parity ruling for repayment of the loan must be distinguished from the parity or parties applied for the advance of the loan and that it must be determined independently.Adherence to the parity of LIT 12.50 per Belgian franc never became an implied term of the contract which the defendant was not entitled unilaterally to delete. In fact, the parties performed the agreement on the basis of the IMF parities, but subject to the express provision that those parities might be changed (cf. in that regard the contractual provisions and the criterion of “parity ruling on the date of the payment or transfer”).After convertibility of the dollar into gold was discontinued (15 August 1971) nobody could seriously believe in fixed parities. The Jamaica Agreements (January 1976) officially abolished IMF parities and as from March 1973 the de facto position was that currencies floated freely. Consequently, redrafting of Article 63 of the Staff Regulations and Article 17 of Annex VII no later than 1 January 1978 became not only an economic but also a legal requirement.The applicant benefited by the late updating of the parity since the possibility of using the outdated IMF parity after 1 January 1978 resulted solely from the lateness of the amendment made to the Staff Regulations in order to eliminate the legal hiatus created by developments in the monetary situation.The Commission considers that the principle of equality requires it to treat the monthly instalments payable by the applicant in the same way as a transfer in Belgian francs made by an official employed outside Belgium to a Belgian credit establishment. When transfers are made to a credit establishment in accordance with Article 17 of Annex VII the amount transferred is adjusted on the basis of the weighting for Belgium and consequently a rate much more favourable than the market rate is applied (LIT 18.35 per Belgian franc instead of more than LIT 26 in April 1979).In reply to the argument relating to the duty of protection and of assistance, the Commission states that it is under no general obligation, by virtue of the Staff Regulations, to safeguard officials against risks of a monetary nature (cf. Opinion of Advocate General Dutheillet de Lamothe in Joined Cases 63 to 65/70 Bode[\97l] ECR 549). For that reason it is likewise under no obligation to bear that risk within the context of a low-rate loan agreement of the kind involved in this case.If the Court rejects the claim that the fixed rate, of LIT 12.50 = BFR 1 should be maintained for payment of the monthly amounts, the Commission is prepared to offer the applicant a further opportunity to adjust his debt in accordance with the 1975 proposal. However, in order to ensure that the system remains fair, an abatement will have to be made corresponding to the ratio between the part of the debt repaid up to March 1979 at the IMF rate and the amount of the loan.Moreover, the applicant is free to make early repayment of his debt in Italian lire, on the understanding that the amount is converted into Belgian francs at the rate ruling on the date of the transfer.Finally, since the Commission has properly discharged its contractual obligations, there can be no obligation, contractual or otherwise, to pay compensation.The applicant emphasizes that Article 9 of the implementing provisions of 17 June 1971 provides that, as regards transactions outside Belgium, the loans in question are, as from the time of the first advance, loans in the currency of the country in question, that is to say in this case a loan in lire and not a loan in Belgian francs. The meaning of that provision goes even further: since there is no further mention elsewhere of parities and repayments, it may be regarded as self-evident that the “corresponding payments” relate not only to the payments (made by the lender to the borrower) but also to the payments of interest and the repayments of the loans (made by the borrower to the lender) according to the principle whereby the amount of the loan is due, as regards the principal and therefore the interest and repayments, in the currency in which the loan was advanced. The basic idea of granting loans in each of the countries of employment or origin of officals within the framework of an accommodation policy was subsequently also included in the wording of the loan agreement, in Article 15. The expression “parity ruling on the date of the transfer” appearing in the second paragraph of that provision manifestly means “parity ruling on the date of the transfers” in exactly the same sense as the expression “transfers” is used and defined in Articles 1 and 5 of the agreement.The grant of building loans to officials at a favourable rate of interest (4%) would be completely deprived of its social objective if, seven years after the agreement was entered into, the conditions for repayment were amended unilaterally, exposing borrowers to the problem of variable monetary parities. Commercial usage alone should prevent the Commission from making speculative monetary gains to the detriment of its officials. A change of parity is tantamount to a de facto change in the interest rate or of the principal debt, which is prohibited by Article 4 (6) of the implementing provisions.In 1971, it was clear that the fixed exchange rates could not remain permanently fixed. Both parties were therefore aware of the risk and, for the advance of the loan and repayment thereof, the parities which were used at the time of the advance were, firmly agreed upon. In reply to Mr Bermani's question, the Commission stated that “the correct application of Article 9 of the implementing provisions for the grant of building loans to officials requires fixed official parities”, from which it is clear that in the absence of such parities Article 9 cannot be correctly applied. It added that “for repayment of the loans, the opportunity to choose the currency ensures that tne borrower is protected against possible fluctuations of exchange rates from time to time”, which clearly means that the borrower may repay in lire the lire obtained by him and that he is not obliged to repay them in Belgian francs. The choice or the currency in which the loan is to be repaid offers protection against variations in exchange rates only if the rate in force on the date the loan was advanced is retained and the rate ruling on the date of repayment is not used.Regulation No 3085/78 amends only the provisions of the Staff Regulations concerning the monetary parities “used in application of the Staff Regulations and the detailed arrangements for the transfer of part of an official's emoluments to a country other than the country of employment of the persons concerned”. Regulation No 3085/78 has therefore in no way changed the “parity ruling on the date of the transfer”, and therefore of the payment, referred to in the loan agreement. In its unilateral action, the administration failed even to inform the applicant of the detailed arrangements for securing repayment applied as from 1 April 1979, not to mention the fact that no reasons were given to him and his consent was not even sought. It should also be made clear that the “parity ruling on the date of the transfer” was not the same as the parity of 1 January 1965 referred to in Article 63 of the Staff Regulations in the version prior to Regulation No 3085/78.The request for early repayment on the basis of the rate ruling on the date of the advance, within a period of three years from the date on which the judgment becomes effective, is justified from the legal point of view by the possibility that such a judgment might detract from the balance between the duties of each party on which the agreement is based. Should the Court be of the opinion that the duties of the parties which constitute the basis for the contract no longer display the equivalence provided for by the previous contractual terms, it may direct that the legal relationship be altered and require compliance with the earlier agreement. In that respect, the applicant refers to the provisions of the agreement which bar the use of the loan for speculative purposes.It is untrue that continuance of the IMF parity, applicable by virtue of Article 63 of the Staff Regulations, became an element of the agreement. Nowhere was any reference made to the parities provided for in Article 63. In fact, the IMF parities ruling in 1971 and 1972 were applied without their being referred to explicitly as such. It is untrue to say that those parities might be amended and that contractual provisions to that effect had been adopted. Contrary to its affirmations the Commission favoured fixed parities long after they were disposed of, since it used them for the payment of remuneration until 1 April 1979.The deduction from remuneration within the framework of the transfers made pursuant to Article 17 of Annex VII to the Staff Regulations is tantamount to a repayment in Belgian francs. However, only a deduction from salary in lire is proper, outside the framework of the transfers made pursuant to that provision. Only during the course of the proceedings was the applicant informed that the administration treated the deductions from remuneration for the purpose of repayment of the loan as transfers within the meaning of Article 17 of Annex VII to the Staff Regulations, whilst on the other hand he had been told by letter of 13 June 1977 that the deductions from remuneration did not constitute transfers of a part of his emoluments.The contractual right of repayment referred to by the Commission is of little use to the applicant if the parties disagree on precisely that point, namely the question of repayment.The defendant states by way of rejoinder that the applicant's interpretation of the expression “parity ruling on the date of the transfer” is contrary to the letter, system and logical terms of Article 15 of the agreement in which it appears. The parity on the date of the transfer relates, without possibility of error, to the words “the conversion of those funds”, which, in his opinion, relates only to the repayments or payments of the monthly amounts referred to in the first paragraph of Article 15. That group of words could not relate to the funds used for the advance of the loan, since they were already denominated in Belgian francs and did not therefore need to be converted. If on the other hand “the parity on the date of the transfer” was deemed to relate to the transfer of amounts other than the payments referred to in the first paragraph of that article, the draftsman of the agreement would not have failed to make that fact particularly clear. Article 5 of the loan agreement, dealing with the advance of the loan, refers specifically to the sums mentioned in Article 1. The second paragraph of Article 15 would in consequence have to be drafted in a completely different way to enable it to be interpreted in any sense conforming with the view of the applicant. Nor for example is it possible to interpret that provision as referring only to early repayment of the loan to the exclusion of the monthly repayment instalments in the form of deductions from salary. According to its wording the second paragraph of Article 15 refers to all the repayment arrangements. Moreover, it is not clear why the conditions which borrowers must satisfy should differ according to whether they are fulfilled by the borrower himself or by means of setoff against the amounts owed by the Community (payment of salary) effected by means of a deduction in accordance with the procedure provided for in Article 5 of the agreement.As regards the Commission's decision concerning the grant of building loans, it is not possible to infer from the amendment of Article 9 of the implementing provisions of 17 June 1971 (laying down for the first time detailed arrangements for repayment) that in the original version they were intended to lay down conditions for repayment of the loan which conferred an advantage on the applicant. The latter has still fewer grounds for asserting that those provisions endowed the loan agreement with a meaning other than that which appears from the entirely clear stipulations contained in it.As regards the procedure followed for performance of the contract, the deduction made from the applicant's remuneration until March 1979 for the monthly repayments of his debt on the basis of an exchange value calculated at the rate of LIT 12.50 = BFR 1 bears no legal relationship with the rate applied when the loan was advanced. In fact, that rate was applied because the parity envisaged in the building loan agreement for calculation of the repayment is the rate which, pursuant to Article 63 of the Staff Regulations, is applied for the payment of remuneration. That parity was changed, for the first time since conclusion of the contract, on 1 April 1979, the date of the entry into force of Regulation No 3085/78. As from that date, repayment of the loan was no longer to be effected on the basis of the old parity of LIT 12.50 = BFR 1, which could thenceforth no longer be applied by the Commission. The Commission's intention not to apply the same parity for the advance as for repayment of the loan is also clearly attested by the offer made by it in 1975 to the applicant to update the amount of his principal debt expressed in Belgian francs. An offer of that kind would have been pointless if the applicant had in any case been under an obligation to repay only the same amount in lire as he had received by way of loan. The updating is meaningless otherwise than by virtue of the discounted updating of the parities applied for repayment of the loan.In its reply to Mr Bermani, the Commission recognized that Article 9 of the implementing provisions of 17 June 1971 needed to be amended when the rates on the foreign exchange market differed for a considerable period from the official parity. Accordingly, that amendment was made by means of the Commission decision of 25 July 1975. It is not, however, possible to infer therefrom that the Commission considered that the loan was still to be repaid on the basis of the same rate as that used when it was advanced. As regards the proposed updating on the basis of the decision of July 1975, it is meaningless otherwise than in the context of the expectation of a forthcoming departure from the parity declared to the IMF in 1965 for repayment of the loan. It is clear therefore from the foregoing that the ratio between the lira and the Belgian franc applicable for the purposes of performance of the loan agreement was inserted in the agreement as a variable figure.As regards determination of the rate to be applied for repayment of the loan, the parity referred to in Article 15 of the agreement is the one applied for payments made on the basis of the applicant's situation pursuant to the Staff Regulations. That is consonant with the concern of both parties to perform the agreement on as solid a basis as possible, in view of the instability prevailing in the international monetary system since 1971 and particularly with the applicant's concern to be able to have the repayments of his debt converted into Belgian francs at a rate at least equal to that at which his monthly remuneration in Belgian francs is converted into lire. Thus the Commission was able to continue until 1 April 1979 to charge against the applicant's remuneration a monthly repayment calculated on the basis of a parity, which was favourable to the applicant, of LIT 12.50 = BFR 1, whilst at least since 1 January 1978 an IMF official rate no longer existed. Consequently, the agreement was performed on the basis of the parity laid down in the Staff Regulations for the transfer of remuneration. If, following an amendment to the Staff Regulations, that parity changed then, pursuant to the second paragraph of Article 15 of the agreement the new parity had automatically to be applied for performance of the agreement. There was no question therefore of any unilateral change of that parity by the Commission.There are no grounds for the view that the officers of the Commission took into account the monthly repayment required from the applicant in calculating the upper limit of 35% of salary which must be observed in the case of the transfers referred to in Article 17 of Annex VII to the Staff Regulations. Also, the Commission is not “pocketing” profits gained from the exchange rates. It is simply entitled, like any lender, to ensure, in strict compliance with the provisions of the contract, that the sum which it receives as repayment of the loan corresponds as closely as possible to the value of the amount disbursed, expressed in Belgian francs. There could only be a sacrifice on the part of the applicant if his remuneration, instead of being expressed in Belgian francs, like the loan, had been ab initio expressed in lire and if the amounts to be paid by way of repayment had not been subjected to the weighting for Belgium.

IV —Oral procedure

The parties presented oral argument at the sitting on 17 December 1981.The Advocate General delivered his opinion at the sitting on 18 March 1982.

Costs