Volume VI - Annexes 80-108

INTERNATIONAL COURT OF JUSTICE
CERTAIN IRANIAN ASSETS
(ISLAMIC REPUBLIC OF IRAN v. UNITED STATES OF AMERICA)
COUNTER-MEMORIAL
SUBMITTED BY
THE UNITED STATES OF AMERICA
October 14, 2019
ANNEXES
VOLUME IV
Annexes 80 through 108

ANNEX 80

REPORTS OF INTERNATIONAL
ARBITRAL AWARDS
RECUEIL DES SENTENCES
ARBITRALES
Award in the arbitration regarding the delimitation of the maritime
boundary between Guyana and Suriname, Award of 17 September 2007 --
Sentence arbitrale relative à la délimitation de la frontière maritime
entre le Guyana et le Surinam, Sentence du 17 septembre 2007
17 September 2007 - 17 septembre 2007
VOLUME XXX pp.1-144
NATIONS UNIES - UNITED NATIONS
Copyright (c) 2012
Annex 80
PART I
Award in the arbitration regarding the
delimitation of the maritime boundary between
Guyana and Suriname
Award of 17 September 2007
PARTIE I
Sentence arbitrale relative à la
délimitation de la frontière maritime entre
le Guyana et le Surinam
Sentence du 17 septembre 2007
Annex 80
Award in the arbitration regarding the
delimitation of the maritime boundary
between Guyana and Suriname
Sentence arbitrale relative à la
délimitation de la frontière maritime
entre le Guyana et le Surinam
Delimitation of the territorial sea—article 15 of the United Nations Convention
on the Law of the Sea (UNCLOS) places primacy on median line in case of opposite
or adjacent States—special circumstances that may affect a delimitation to be assessed
on a case-by-case basis—special circumstances of established practice of navigation
justify deviation from the median line from the starting point to the three nautical
mile limit—no obligations created by uncompleted treaties—the three to twelve nautical
mile limit line drawn, taking into account the special circumstance of determining
such line from a point at sea fixed by historical arrangements, to the point at which the
equidistance line established for the continental shelf and the exclusive economic zone
intersects the 12 nautical mile point.
Determination of a continental shelf and the exclusive economic zone—concept
of a single maritime boundary not found in UNCLOS, but in practice and case law–
provisional equidistance line subject to adjustment in light of relevant circumstances
in order to achieve equitable solution—certainty, equity, stability integral parts of process
of delimitation—coastal geography may be relevant to the extent that it generates
“the complete course” of the provisional equidistance line—angle bisector methodology
rejected—international courts and tribunals dealing with maritime delimitation
should be mindful of not remaking or wholly refashioning nature—absent an express
or tacit agreement between the parties oil concessions and oil wells irrelevant to the
delimitation of maritime boundary—boundary negotiations with a third State irrelevant—
no factors rendering the provisional equidistance line inequitable.
Admissibility of claim of unlawful threat or use of force—Tribunal has jurisdiction
under article 293 of UNCLOS to apply rules of international law not incompatible
with the Convention—the incident to be considered in the context of the whole
dispute—no obligation to engage in separate exchanges of views on threat or use of
force–Tribunal’s jurisdiction over disputes concerning a coastal State’s enforcement
of its sovereign rights with respect to non-living resources not excluded—no generally
accepted definition of the doctrine of clean hands in international law—a violation
must be ongoing for the doctrine of clean hands to apply—claims relating to the use
of force in a disputed area not incompatible under UNCLOS with claim for maritime
delimitation of that area.
Claim of unlawful threat or use of force—action taken by Suriname not a law
enforcement activity but a threat of use of force in contravention of UNCLOS, the
Charter of the United Nations and general international law—in international law
force may be used in law enforcement activities provided such force is unavoidable,
Annex 80
4 Guyana/Suriname
reasonable and necessary—claim that action constituted a countermeasure precluding
wrongfulness not accepted—countermeasures may not involve use of force.
State responsibility—no need to assess extent of Suriname’s international responsibility—
injury to Guyana “sufficiently addressed” by Tribunal’s delimitation decision
granting it undisputed title to the area of the incident.
Obligation under articles 74(3) and 83(3) of UNCLOS to make every effort to
enter into provisional arrangements–duty to negotiate in good faith—obligation to
“make every effort” to reach such arrangements.
Obligation under articles 74(3) and 83(3) of UNCLOS to make every effort not to
jeopardize or hamper the reaching of final agreement—unilateral activity that might
affect the other party’s rights in a permanent manner not permissible—distinction
drawn between activities leading to a permanent physical change, such as exploitation
of oil and gas reserves, and those that do not, such as seismic exploration.
Remedy—declaratory relief.
Délimitation de la mer territoriale—article 15 de la Convention des Nations
Unies sur le droit de la mer (CNUDM) donne primauté à la ligne médiane dans les
cas concernant des États se faisant face ou adjacents—circonstances spéciales pouvant
avoir un effet sur une délimitation considérées au cas par cas—circonstance spéciale
concernant une pratique de navigation établie justifiant une déviation de la ligne médiane
du point de départ fixé à la limite des trois milles marins—absence d’obligation
résultant d’un traité incomplet—ligne tracé entre les limites des trois et douze milles
marins, en prenant en considération les circonstances spéciales relevant de la détermination
d’une telle ligne à partir d’un point en mer fixé par des arrangements historiques
jusqu’au point d’intersection entre la ligne d’équidistance établie pour le plateau
continental et la zone économique exclusive et le point situé à douze milles marins.
Délimitation du plateau continental et de la zone économique exclusive—Concept
de frontière maritime unique ne figurant pas dans la CNUDM, mais présent
dans la pratique et la jurisprudence—ligne provisoire d’équidistance étant sujette
à ajustement, au regard des circonstances pertinentes aux fins d’aboutir à une solution
équitable—certitude, équité et stabilité comme parties intégrantes du processus
de délimitation—géographie côtière pouvant être pertinente dans la mesure où elle
permet de générer « le tracé complet » de la ligne provisoire d’équidistance—rejet
de la méthode de la bissectrice—juridictions internationales traitant de délimitations
maritimes devant être attentives à ne pas refaire ou refaçonner entièrement la nature—
concessions pétrolières et puits de pétrole non pertinents dans la délimitation de la
frontière maritime, en l’absence d’accord exprès ou tacite entre les Parties—négociations
frontalières avec un Etat tiers non pertinentes—absence de facteurs rendant la
ligne provisoire d’équidistance inéquitable.
Recevabilité de la demande portant sur la menace ou l’emploi illicite de la force—
Tribunal compétent en vertu de l’article 293 de la CNUDM pour appliquer des règles
de droit international qui ne sont pas incompatibles avec celle-ci—incident à considérer
dans le contexte du différend dans son ensemble—absence d’obligation d’initier
des échanges de vues distincts concernant la menace ou l’emploi de la force—compétence
du Tribunal sur les différends concernant la mise en oeuvre par un Etat côtier de
Annex 80
maritime delimitation 5
ses droits souverains sur les ressources non biologiques n’étant pas exclue—absence
de définition généralement acceptée de la doctrine des mains propres en droit international–
violation devant être en cours pour que la doctrine des mains propres soit
applicable—absence d’incompatibilité, en vertu de la CNUDM, des demandes fondées
sur l’emploi de la force dans une zone en litige avec une demande de délimitation
maritime de ladite zone.
Demande portant sur la menace ou l’emploi illicite de la force—mesure prise
par le Surinam ne pouvant être qualifiée d’activité d’exécution de la loi, mais constituant
une menace d’emploi de la force en violation de la CNUDM, de la Charte des
Nations Unies et du droit international général—en droit international, possibilité de
recourir à la force, selon le droit international, dans le cadre d’activités d’exécution de
la loi, à condition qu’un tel recours soit inévitable, raisonnable et nécessaire—rejet de
l’allégation selon laquelle la mesure constituait une contre-mesure excluant l’illicéité—
contre-mesures ne pouvant pas impliquer l’emploi de la force.
Responsabilité de l’État—détermination de l’étendue de la responsabilité internationale
du Surinam n’étant pas nécessaire—dommage subi par le Guyana étant « suffisamment
traité » par la décision du Tribunal en matière de délimitation lui accordant
un titre incontestable sur la zone de l’incident.
Obligation des États en vertu des articles 74(3) et 83(3) de la CNUDM de faire
tout leur possible pour conclure des arrangements provisoires—devoir de négocier
de bonne foi—obligation de « faire tout leur possible » pour conclure de tels arrangements.
Obligation des États en vertu des articles 74(3) et 83(3) de la CNUDM de faire
tout leur possible pour ne pas compromettre ou entraver la conclusion de l’accord
définitif—inadmissibilité de toute activité unilatérale susceptible d’affecter les droits
de l’autre partie de manière permanente—distinction établie entre les activités conduisant
à une modification physique permanente, telle que l’exploitation des réserves
gazières et pétrolières et celles n’ayant pas un tel effet, comme l’exploration sismique.
Remède—constatation judiciaire valant satisfaction.
* * * * *
Annex 80
6 Guyana/Suriname
Arbitral Tribunal constituted pursuant to Article 287,
and in accordance with Annex VII, of the United
Nations Convention on the Law of the Sea
in the matter of an arbitration between:
Guyana
and
Suriname
Award of the Arbitral Tribunal
The Arbitral Tribunal:
H.E. Judge L. Dolliver M. Nelson, President
Professor Thomas M. Franck
Dr. Kamal Hossain
Professor Ivan Shearer
Professor Hans Smit
Registry:
Permanent Court of Arbitration
The Hague, 17 September 2007
Annex 80
maritime delimitation 7
Agents, counsel and other representatives of the Parties
Guyana
— Hon. S.R. Insanally, O.R., C.C.H., M.P. Minister of Foreign Affairs
— Hon. Doodnauth Singh, S.C., M.P., Attorney General and Minister of
Legal Affairs
— Ambassador Elisabeth Harper, Director General, Ministry of Foreign
Affairs
— Mr. Keith George, Head, Frontiers Division, Ministry of Foreign Affairs
— Ambassador Bayney Karran, Ambassador of Guyana to the United States
— Ms. Deborah Yaw, First Secretary, Embassy of Guyana, Washington
— Mr. Forbes July, Second Secretary, Embassy of Guyana, Washington
— Sir Shridath Ramphal, S.C., Co-Agent for Guyana
— Mr. Paul S. Reichler, Foley Hoag LLP, Co-Agent for Guyana
— Professor Payam Akhavan, Associate Professor, Faculty of Law, McGill
University, Co-Agent for Guyana
— Professor Philippe Sands, Q.C., Professor of Law, University College London
— Professor Nico Schrijver, Professor of Public International Law, University
of Leiden
— Mr. Lawrence Martin, Foley Hoag LLP
— Mr. Andrew Loewenstein, Foley Hoag LLP
— Ms. Sarah Altschuller, Foley Hoag LLP
— Ms. Nienke Grossman, Foley Hoag LLP
— Ms. Clara Brillembourg, Foley Hoag LLP
— Ms. Blinne Ní Ghrálaigh, Matrix Chambers, London
— Dr. Galo Carrera, Scientific/Technical Expert
— Mr. Scott Edmonds, International Mapping Associates
— Mr. Thomas Frogh, International Mapping Associates
Suriname
— Hon. Lygia L.I. Kraag-Keteldijk, Minister of Foreign Affairs and Agent
— Mr. Caprino Allendy, Deputy Speaker of Parliament
— Mr. Henry Iles, Ambassador of Suriname
— Mr. Winston Jessurun, Member of Parliament
— Ms. Jennifer Pinas, Ministry of Foreign Affairs
— Mr. Krish Nandoe, Ministry of Justice and Police
Annex 80
8 Guyana/Suriname
— Mr. Hans Lim A Po, Co-Agent for Suriname
— Mr. Paul C. Saunders, Co-Agent for Suriname, Attorney, Cravath, Swaine
& Moore LLP
— Professor Christopher Greenwood, CMG, QC, Professor of Law, Essex
Court Chambers
— Mr. Stephen S. Madsen, Attorney, Cravath, Swaine & Moore LLP
— Mr. David A. Colson, Attorney, LeBoeuf, Lamb, Greene & MacRae LLP
— Professor Sean D. Murphy, Professor of International Law, The George
Washington University Law School
— Professor Bernard H. Oxman, Professor of International Law, University
of Miami School of Law
— Professor Donald M. McRae, Professor of International Law, University
of Ottawa
— Professor Alfred H. A. Soons, Professor of Public International Law, Utrecht
University
— Professor Alex Oude Elferink, Professor of Public International Law, Utrecht
University
— Mr. Coalter Lathrop, Cartography Consultant, Sovereign Geographic, Inc.
Boundary Consultation and Cartographic Services
— Mr. David Swanson, Cartography Consultant, David Swanson Cartography
— Mr. Brian J. Vohrer, Attorney, LeBoeuf, Lamb, Greene & MacRae LLP
— Ms. Michelle K. Parikh, Attorney, Cravath, Swaine & Moore LLP
— Ms. Rebecca R. Silber, Attorney, Cravath, Swaine & Moore LLP
— Mr. Matthew Pierce, Technology Consultant, Trial Team One
— Ms. Elaine Baird, Manager of Courtroom Systems, Cravath, Swaine &
Moore LLP
— Ms. Brittany Olwine, Legal Assistant, Cravath, Swaine & Moore LLP
— Ms. Anika Rappleye, Legal Assistant, Cravath, Swaine & Moore LLP
Annex 80
maritime delimitation 9
TABLE OF CONTENTS
Chapter I. Procedural History . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Chapter II. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
A. Geography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
B. Historical background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
C. The Parties' claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Chapter III. Arguments of the Parties . . . . . . . . . . . . . . . . . . . . . 40
A. Submissions on jurisdiction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Suriname's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
B. The Parties' interpretation of the factual record . . . . . . . . . . . . . 46
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Suriname's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
C. Guyana' s delimitation claim . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
1. Applicable law and approach to delimitation . . . . . . . . . . . . 54
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
Suriname‘s position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
2. The role of coastal geography . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Suriname’s position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
3. Conduct of the Parties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Suriname's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
4. Delimitation of the territorial seas . . . . . . . . . . . . . . . . . . . . . 64
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
Suriname's Position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
5. Delimitation of the Continental Shelf and Exclusive Economic
Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
Suriname's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
D. Guyana's third submission: alleged unlawful threat and use of
force by Suriname . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Suriname’s position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
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10 Guyana/Suriname
E. Guyana's Fourth Submission and Suriname's Submissions 2.C
and 2.D: Breach of Articles 74(3) and 83(3) of the Convention 75
Guyana's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
Suriname's position . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
Chapter IV. Jurisdiction to determine the maritime boundary 76
Chapter V. Delimitation in the territorial sea . . . . . . . . . . . . 77
A. The Parties' positions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Suriname's N10°E Line to 12 nm . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Special circumstances and historical evidence of an agreement 77
Evolution of historical territorial sea agreement from 3 to 12 nm 78
Application of the inter-temporal law . . . . . . . . . . . . . . . . . . . . . . 79
Guyana's N34°E line to 12 nm . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
Historical evidence of an agreement on an equidistance line . . 79
Absence of navigation by early 1960s . . . . . . . . . . . . . . . . . . . . . . 81
The N10°E Line, if it governed relations between the parties,
did not exist beyond 3 nm . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
No justification for departure from the provisional equidistance
line . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
B. The Tribunal's findings pertaining to the delimitation of the
territorial sea. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82
Special circumstances and historical evidence of an agreement 82
The boundary between 3 and 12 nm . . . . . . . . . . . . . . . . . . . . . . . 87
Chapter VI. Delimitation of the continental shelf and exclusive
economic zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
A. Relevant coasts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95
The Parties' positions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95
The Tribunal's findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
B. Coastal geography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
C. The provisional equidistance line . . . . . . . . . . . . . . . . . . . . . . . . . 99
The Parties' positions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
The Tribunal's findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102
D. Conduct of the Parties. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105
E. Conclusion of the Tribunal. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109
Chapter VII. Guyana's third submission . . . . . . . . . . . . . . . . . . . . 111
A. Jurisdiction and admissibility . . . . . . . . . . . . . . . . . . . . . . . . . . . 112
1. The Tribunal's jurisdiction over claims relating to the
UN Charter and general international law. . . . . . . . . . . . . . . . . . 112
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maritime delimitation 11
2. The obligation to exchange views . . . . . . . . . . . . . . . . . . . . . . 113
3. Article 297 and the characterisation of Guyana's claim . . . . 114
4. Good faith and clean hands . . . . . . . . . . . . . . . . . . . . . . . . . . . 115
5. The admissibility of a State responsibility claim in a maritime
delimitation case . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118
B. The threat or use of force . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119
C. Law enforcement activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124
D. State responsibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127
Chapter VIII. Guyana's fourth submission and Suriname's
submissions 2.C and 2.D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128
A. Jurisdiction and admissibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
B. The obligations provided for by Articles 74(3) and 83(3) . . . . . 130
1. Provisional arrangements of a practical nature . . . . . . . . . . . 130
2. Hampering or jeopardising the Final Agreement . . . . . . . . . 131
C. The Tribunal's findings on the duty to make every effort to
enter into provisional arrangements of a practical nature . . . . . 133
D. The Tribunal's findings on the duty not to hamper or jeopardise
the reaching of a final agreement. . . . . . . . . . . . . . . . . . . . . . . . . . 137
1. Suriname's submission 2.C . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137
2. Guyana's fourth submission . . . . . . . . . . . . . . . . . . . . . . . . . . . 138
E. Declaratory relief . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 138
Chapter IX. Dispositif . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139
Appendix. Technical report of the Tribunal's hydrographer 140
Maps*
Map 1. The Area in Dispute
Map 2. The Tribunal’s Delimitation Line in the Territorial Sea
Map 3. The Tribunal’s Delimitation Line in the Continental Shelf and
Exclusive Economic Zone
Map 4. The Tribunal’s Delimitation Line of the Maritime Boundary
Between Guyana and Suriname
Map 5. Construction Lines of the Maritime Boundary Between
Guyana and Suriname
* Secretariat note: the maps are located in the front pocket of this volume.
Annex 80
maritime delimitation 45
are drawn violates international law.49 Moreover, Suriname disputes Guyana's
argument that the Tribunal would have jurisdiction to make a partial delimitation
from a point at 15 nm from coastal baselines should it not have jurisdiction
to make a full delimitation, submitting that Guyana wrongly relies upon
the Gulf of Maine case and fails to establish that such partial delimitations
are possible in the instant case in which a starting point has not been agreed
upon.50
182. Suriname contends that Guyana's second and third claims are
inadmissible, as Guyana did not act in good faith and lacks clean hands.51
Suriname maintains that the doctrine of clean hands has been recognized
since the early jurisprudence of the Permanent Court of International Justice
and that recent International Court of Justice (“ICJ”) judgments and opinions
leave it open to parties to invoke the doctrine.52 In Suriname's view, even if
these claims are found to be admissible, clean hands should be considered in
determining the merits of Guyana's claims. According to Suriname, Guyana
lacks clean hands as it authorized drilling in the disputed area, gave no notice
to Suriname (press reports being insufficient), and failed to withdraw support
for the activity following Suriname's first complaints.53
183. Suriname maintains that Guyana's second claim, that it engaged in
a wrongful act by expelling the CGX vessel in June 2000, must fail as Suriname
has not acquiesced in Guyana's claim to maritime territory54 and Guyana cannot
claim that it exercises lawful jurisdiction in the disputed area. Suriname
points out that the ICJ has never in the same judgment awarded reparations
for violation of State sovereignty in a case in which it was requested to delimit a
boundary determining such sovereignty.55 According to Guyana, such a claim
would amount to an ex post facto application of Guyana's first claim and would
encourage States in the future to engage in activity designed to create facts on
the ground in support of their claims. Suriname asserts that based on the oil
concession practice of the Parties, Guyana's actions were in breach of the 1989
modus vivendi and signalled an aggressive posture by Guyana.56
184. With respect to Guyana's third claim, Suriname contends that
Guyana lacks clean hands and that the record demonstrates Guyana's failure
49 Transcript, pp. 800–801.
50 Suriname Rejoinder, paras. 2.62–2.69, citing Gulf of Maine, Judgment, I.C.J.
Reports 1984, p. 246.
51 Suriname Preliminary Objections, paras. 7.1–7.9; Suriname Rejoinder, paras.
2.81–2.120; Transcript, pp. 1100–1101.
52 Suriname Rejoinder, paras. 2.91 -2.109.
53 Suriname Rejoinder, paras. 2.110–2.115.
54 Suriname Preliminary Objections, paras. 6.7–6.11.
55 Suriname Rejoinder, paras. 2.84–2.90.
56 Suriname Preliminary Objections, paras. 6.3–6.6.
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46 Guyana/Suriname
to negotiate in good faith.57 Suriname argues, with reference to the Parties'
negotiating history since the June 2000 incident, that Guyana unreasonably
demanded the reinstatement of the CGX operation while offering little in
return, thereby jeopardizing resolution of the dispute and breaching Articles
74(3) and 83(3) of the Convention. Suriname further argues that Guyana
withheld information regarding its oil concessions in bad faith and maintains
that Guyana's core request, that exploration activities resume, amounted to a
request that Suriname acquiesce in Guyana's prejudicial activity.58
185. Accordingly, Suriname requests that the Tribunal find that it does
not have jurisdiction to determine Guyana's maritime delimitation claim and
that Guyana's second and third claims are inadmissible.59
B. The Parties' interpretation of the factual record
Guyana's position
186. Guyana bases its claims in part on an account of the record of the
practices of Guyana and Suriname and their colonial predecessors. Guyana
refers to the work of the Mixed Boundary Commission, constituted by The
Netherlands and the United Kingdom in 1934, and argues that the historical
record demonstrates that the northerly point of the boundary it established,
Point 61, was treated as the northern land boundary terminus between the
colonies until the independence of Guyana and Suriname. It argues further
that Point 61 has been recognized expressly by Guyana and Suriname since
independence.60
187. Guyana refers to the work of the Mixed Boundary Commission
and to the positions taken by The Netherlands and the United Kingdom at the
time, and submits that the de facto delimitation of the territorial sea recommended
by the Commission along an azimuth of N10°E from Point 61 was
reached to accommodate The Netherlands' practical concern at the time that
both navigable approaches to the mouth of the Corentyne River should remain
under its authority to allow it to carry out its administration of shipping on the
river. Guyana emphasized that this delimitation did not purport to follow an
equidistance line, and was provisional and liable to change, being “motivated
solely by considerations of administrative and navigational efficiencies.”61
188. Guyana maintains that the attempts in 1939 by the United Kingdom
and The Netherlands to draft a treaty settling the entire length of the
boundary, based on a delimitation of the territorial waters along an azimuth
57 Suriname Preliminary Objections, paras. 6.39–6.44.
58 Suriname Rejoinder, paras. 2.116–2.120.
59 Suriname Preliminary Objections, Chapter 8.
60 Guyana Memorial, para. 3.10.
61 Guyana Memorial, para. 3.16.
Annex 80
maritime delimitation 115
limitations set out in Article 297 and the optional exceptions specified in Article
298. Article 286 reads as follows:
Subject to section 3, any dispute concerning the interpretation or
application of this Convention shall, where no settlement has been
reached by recourse to section 1, be submitted at the request of any
party to the dispute to the court or tribunal having jurisdiction under
this section.
414. Thus, any dispute concerning the interpretation or application of
the Convention which is not excluded by the operation of Part XV, Section 3
(Articles 297 and 298) falls under the compulsory procedures in Section 2.
Article 297, paragraph 3(a), which is relevant here, reads as follows:
Disputes concerning the interpretation or application of the provisions
of this Convention with regard to fisheries shall be settled in
accordance with section 2, except that the coastal State shall not be
obliged to accept the submission to such settlement of any dispute relating
to its sovereign rights with respect to the living resources in the
exclusive economic zone or their exercise, including its discretionary
powers for determining the allowable catch, its harvesting capacity,
the allocation of surpluses to other States and the terms and conditions
established in its conservation and management laws and regulations.
[emphasis added]
415. Sovereign rights over non-living resources do not fall under this
exception.
416. This Tribunal is therefore unable to entertain Suriname's argument
that a dispute concerning a coastal State's enforcement of its sovereign rights
with respect to non living resources lies outside its jurisdiction.
4. Good faith and clean hands
417. Suriname challenges the admissibility of Guyana's Third Submission
on the grounds of lack of good faith and clean hands. It also argues in the
alternative that the clean hands doctrine must be considered in deciding the
merits of Guyana's Third Submission.
418. The doctrine of clean hands, as far as it has been adopted by international
courts and tribunals, does not apply in the present case. No generally
accepted definition of the clean hands doctrine has been elaborated in international
law. Indeed, the Commentaries to the ILC Draft Articles on State
Responsibility acknowledge that the doctrine has been applied rarely476 and,
when it has been invoked, its expression has come in many forms. The ICJ has
476 James Crawford, The International Law Commission's Articles on State Responsibility:
Introduction, Text and Commentaries, p. 162 (2002).
Annex 80
116 Guyana/Suriname
on numerous occasions declined to consider the application of the doctrine,477
and has never relied on it to bar admissibility of a claim or recovery. However,
some support for the doctrine can be found in dissenting opinions in certain
ICJ cases, as well as in opinions in cases of the Permanent Court of International
Justice (the “PCIJ”). For example, Judge Anzilotti's 1933 dissenting
opinion in the Legal Status of Eastern Greenland case states that “an unlawful
act cannot serve as the basis of an action at law”.478 In the United States Diplomatic
and Consular Staff in Tehran case, in which the ICJ declined to consider
the issue of clean hands, Judge Morozov wrote in his dissent that the United
States had “forfeited the legal right as well as the moral right to expect the
Court to uphold any claim for reparation”. However, Judge Morozov went to
great lengths to stress that “[t]he situation in which the Court has carried on
its judicial deliberation in the current case has no precedent in the whole history
of the administration of international justice either before this Court, or
before any international judicial institution”,479 citing the United State's coercive
and military measures against Iran which were carried out simultaneously
with its application to the ICJ.480 In the Case Concerning the Arrest Warrant
of 11 April 2000 (Democratic Republic of Congo v. Belgium), ad hoc Judge Van
den Wyngaert states that the Democratic Republic of Congo (“DRC”) did not
come to the ICJ with clean hands, citing its violation of the Geneva Conventions
in failing to prosecute a Government Minister suspected of breaching
humanitarian law.481 The finding with respect to clean hands was not however
dispositive; it was merely included in Judge Van den Wyngaert's discussion of
immunity under international law and her conclusion that a Minister's immunity
does not extend to war crimes and crimes against humanity. The doctrine
was therefore neither used as a bar to the admissibility of the DRC's claim, nor
as a ground to deny recovery. These cases indicate that the use of the clean
477 Legal Consequences of the Construction of a Wall in the Occupied Palestinian
Territory, Advisory Opinion, I.C.J. Reports 2004, p. 136 at para. 63; Oil Platforms (Islamic
Republic of Iran v. United States of America), Judgment, I.C.J. Reports 2003, p. 161, at
para. 100; Legality of Use of Force (Serbia and Montenegro v. Belgium), Preliminary Objections,
Judgment, I.C.J. Reports 2004, p. 279: in this case Belgium raised the question of
clean hands in its preliminary objections (Preliminary Objections of the Kingdom of
Belgium, Legality of Use of Force (Serbia and Montenegro v. Belgium), (5 July 2000), available
at http://www.icj-cij.org/docket/files/105/8340.pdf), but the Court did not address the
argument in its judgment.
478 Legal Status of Eastern Greenland, P.C.I.J. Series A/B, No. 53, p. 95 (Dissenting
Opinion of Judge Anzilotti).
479 Diplomatic and Consular Staff, Judgment, I.C.J. Reports 1980, p. 3, at p. 53 (Dissenting
Opinion of Judge Morozov) [emphasis in original].
480 Diplomatic and Consular Staff, Judgment, I.C.J. Reports 1980, p. 3, at p. 54 (Dissenting
Opinion of Judge Morozov).
481 Arrest Warrant of 11 April 2000 (Democratic Republic of Congo v. Belgium), Judgment,
I.C.J. Reports 2002, p. 3, at para. 35 (Dissenting Opinion of Judge ad hoc Van den
Wyngaert).
Annex 80
maritime delimitation 117
hands doctrine has been sparse, and its application in the instances in which
it has been invoked has been inconsistent.
419. Judge Schwebel's dissenting opinion in the Case Concerning Military
and Paramilitary Activities in and Against Nicaragua, which Suriname
characterises as “the strongest affirmation of the clean hands doctrine”,482 has
also been relied on in support of the application of the clean hands doctrine.483
In his dissent, Judge Schwebel reasoned that Nicaragua “had deprived itself
of the necessary locus standi” to bring its claims, as it was itself guilty of illegal
conduct resulting in deaths and widespread destruction.484 In doing so, he
relied heavily on Judge Hudson's individual opinion in the Diversion of Water
from the Meuse case,485 which states:
It would seem to be an important principle of equity that where two
parties have assumed an identical or reciprocal obligation, one party
which is engaged in a continuing non-performance of that obligation
should not be permitted to take advantage of a similar non-performance
of that obligation by the other party.486 [emphasis added]
420. An important aspect of Judge Hudson's expression of the doctrine
is the continuing nature of the non-performance of an obligation. In the Diversion
of Water from the Meuse case, The Netherlands was seeking an order for
Belgium to discontinue its violation of a treaty between the two countries while
The Netherlands itself was engaging in “precisely similar action, similar in fact
and similar in law” at the time its claim was brought before the PCIJ.487 The fact
that a violation must be ongoing for the clean hands doctrine to apply is consistent
with the doctrine's origins in the laws of equity and its limited application
to situations where equitable remedies, such as specific performance, are
sought. Indeed, Judge Hudson reminds us that it is a principle of international
law that any breach leads to an obligation to make reparation, and that only
special circumstances may call for the consideration of equitable principles.488
Such circumstances arise, in his opinion, where a claimant is seeking not reparation
for a past violation, but protection against a continuance of that violation
in the future, in other words a “kind of specific performance of a recipro-
482 Suriname Rejoinder, para. 2.102.
483 See, e.g., Case Concerning the Arrest Warrant of 11 April 2000 (Democratic Republic
of Congo v. Belgium), n. 82 (Dissenting Opinion of Judge ad hoc Van den Wyngaert).
484 Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United
States of America), Merits, Judgment, I.C.J. Reports 1986, p. 14, at para. 272 (Dissenting
Opinion of Judge Schwebel) (“Nicaragua”).
485 Nicaragua, Merits, Judgment, I.C.J. Reports 1986, p. 14, at paras. 269–270 (Dissenting
Opinion of Judge Schwebel).
486 Diversion of Water from the Meuse, P.C.I.J. Series A/B, No. 70, p. 22, at p. 77
(Individual Opinion by Judge Hudson).
487 Diversion of Water from the Meuse, p. 78 (Individual Opinion by Judge Hudson).
488 Ibid.
Annex 80
118 Guyana/Suriname
cal obligation which the demandant itself is not performing”.489 Judge Hudson
also stresses the limited applicability of the doctrine in more general terms:
The general principle is one of which an international tribunal should
make a very sparing application. It is certainly not to be thought that
a complete fulfillment of all its obligations under a treaty must be
proved as a condition precedent to a State's appearing before an international
tribunal to seek an interpretation of that treaty. Yet, in a
proper case, and with scrupulous regard for the limitations which
are necessary, a tribunal bound by international law ought not to
shrink from applying a principle of such obvious fairness.490 [emphasis
added]
421. The Tribunal holds that Guyana's conduct does not satisfy the
requirements for the application of the doctrine of clean hands, to the extent
that such a doctrine may exist in international law. First, Guyana is seeking,
with respect to its Third Submission, reparations for an alleged past violation
by Suriname. Guyana is therefore not seeking a remedy of the type to which
the clean hands doctrine would apply, even if it were recognised as a rule of
international law. Secondly, the facts on which Suriname bases its assertion
that Guyana has unclean hands do not amount to an ongoing violation of
Guyana's obligations under international law,491 as in the Case Concerning
the Arrest Warrant of 11 April 2000, the United States Diplomatic and Consular
Staff in Tehran case, and the Water from the Meuse case. Guyana had not
authorised any drilling activities subsequent to the CGX incident and was as
a result not in violation of the Convention as alleged at the time it made its
Third Submission to the Tribunal. Finally, Guyana's Third Submission claims
that Suriname violated its obligation not to resort to the use or threat of force,
while Suriname bases its clean hands argument on Guyana's alleged violation
of a different obligation relating to its authorisation of drilling activities in
disputed waters. Therefore, there is no question of Guyana itself violating a
reciprocal obligation on which it then seeks to rely.
422. The Tribunal's ruling on this issue extends both to Suriname's
admissibility argument based on clean hands and to its argument that clean
hands should be considered on the merits of Guyana's Third Submission to
bar recovery.
5. The admissibility of a State responsibility claim in a maritime
delimitation case
423. The Tribunal does not accept Suriname's argument that in a maritime
delimitation case, an incident engaging State responsibility in a disputed
489 Ibid.
490 Ibid., at p. 77.
491 Suriname Rejoinder, paras. 2.110–2.115.
Annex 80

ANNEX 81

PCA Case No. AA 226
IN THE MATTER OF AN ARBITRATION BEFORE A TRIBUNAL CONSTITUTED
IN ACCORDANCE WITH ARTICLE 26 OF THE ENERGY CHARTER TREATY
AND THE 1976 UNCITRAL ARBITRATION RULES
- between -
HULLEY ENTERPRISES LIMITED (CYPRUS)
- and -
THE RUSSIAN FEDERATION
FINAL AWARD
18 July 2014
Tribunal
The Hon. L. Yves Fortier PC CC OQ QC, Chairman
Dr. Charles Poncet
Judge Stephen M. Schwebel
Mr. Martin J. Valasek, Assistant to the Tribunal
Mr. Brooks W. Daly, Secretary to the Tribunal
Ms. Judith Levine, Assistant Secretary to the Tribunal
Registry
Permanent Court of Arbitration
Representing Claimant:
Professor Emmanuel Gaillard
Dr. Yas Banifatemi
Ms. Jennifer Younan
SHEARMAN&STERLING LLP
Representing Respondent:
Dr. Claudia Annacker
Mr. Lawrence B. Friedman
Mr. David G. Sabel
Mr. Matthew D. Slater
Mr. William B. McGurn
Mr. J. Cameron Murphy
CLEARY GOTTLIEB STEEN &HAMILTON LLP
Mr. Michael S. Goldberg
Mr. Jay L. Alexander
Dr. Johannes Koepp
Mr. Alejandro A. Escobar
BAKER BOTTS LLP
Annex 81
- i -
TABLE OF CONTENTS
LIST OF DEFINED TERMS ..................................................................................................................... xiii􀀃
INTRODUCTION ........................................................................................................................................ 1􀀃
I.􀀃 PROCEDURAL HISTORY ................................................................................................................ 2􀀃
A.􀀃 COMMENCEMENT OF THE ARBITRATION ................................................................................... 2􀀃
B.􀀃 CONSTITUTION OF THE TRIBUNAL ............................................................................................. 3􀀃
C.􀀃 PRELIMINARY PHASE ON JURISDICTION AND ADMISSIBILITY ................................................... 4􀀃
D.􀀃 BIFURCATION AND OTHER SCHEDULING MATTERS ................................................................... 5􀀃
E.􀀃 DOCUMENT PRODUCTION AND CONFIDENTIALITY ................................................................... 6􀀃
F.􀀃 HEARING ON THE MERITS .......................................................................................................... 8􀀃
G.􀀃 POST-HEARING PROCEDURES .................................................................................................. 11􀀃
II.􀀃 FACTUAL BACKGROUND ........................................................................................................... 12􀀃
A.􀀃 THE PARTIES TO THESE PROCEEDINGS .................................................................................... 13􀀃
1.􀀃 Claimants and Related Entities ...................................................................................... 13􀀃
2.􀀃 Respondent ..................................................................................................................... 13􀀃
B.􀀃 OAO YUKOS OIL COMPANY .................................................................................................... 13􀀃
C.􀀃 THE RUSSIAN LOW-TAX REGION PROGRAM ........................................................................... 14􀀃
D.􀀃 CRIMINAL PROCEEDINGS ......................................................................................................... 16􀀃
E.􀀃 ADDITIONAL MEASURES .......................................................................................................... 17􀀃
1.􀀃 Alleged Frustration of Merger Between Yukos and Sibneft .......................................... 18􀀃
2.􀀃 Tax Reassessments for Years 2000–2004 ...................................................................... 18􀀃
3.􀀃 Auction of YNG ............................................................................................................. 19􀀃
4.􀀃 Bankruptcy Proceedings ................................................................................................ 20􀀃
5.􀀃 Withdrawal of PwC’s Audits ......................................................................................... 20􀀃
III.􀀃 PARTIES’ WRITTEN SUBMISSIONS ........................................................................................... 20􀀃
A.􀀃 CLAIMANTS’ SKELETON ARGUMENTS ..................................................................................... 21􀀃
B.􀀃 RESPONDENT’S SKELETON ARGUMENTS ................................................................................. 34􀀃
IV.􀀃 PARTIES’ REQUESTS FOR RELIEF ............................................................................................. 48􀀃
A.􀀃 RELIEF REQUESTED BY CLAIMANTS ........................................................................................ 48􀀃
B.􀀃 RELIEF REQUESTED BY RESPONDENT ...................................................................................... 48􀀃
Annex 81
- ii -
V.􀀃 APPLICABLE LAW ......................................................................................................................... 49􀀃
A.􀀃 PROCEDURAL LAW .................................................................................................................. 49􀀃
B.􀀃 SUBSTANTIVE LAW .................................................................................................................. 49􀀃
1.􀀃 Energy Charter Treaty .................................................................................................... 49􀀃
2.􀀃 Vienna Convention on the Law of Treaties ................................................................... 53􀀃
VI.􀀃 SUMMARY OF WITNESS TESTIMONY ...................................................................................... 54􀀃
A.􀀃 CLAIMANTS’ WITNESSES ......................................................................................................... 55􀀃
1.􀀃 Mr. Jacques Kosciusko-Morizet .................................................................................... 55􀀃
2.􀀃 Mr. Vladimir Dubov ...................................................................................................... 57􀀃
3.􀀃 Mr. Frank Rieger ............................................................................................................ 59􀀃
4.􀀃 Dr. Andrei Illarionov ..................................................................................................... 61􀀃
5.􀀃 Mr. Leonid Nevzlin ........................................................................................................ 64􀀃
6.􀀃 Mr. Bruce Misamore ...................................................................................................... 67􀀃
7.􀀃 Mr. Steven Theede ......................................................................................................... 69􀀃
8.􀀃 Mr. Brent Kaczmarek ..................................................................................................... 72􀀃
9.􀀃 Mr. Philip Baker QC ...................................................................................................... 73􀀃
10.􀀃 Mr. Yuri Schmidt ........................................................................................................... 74􀀃
11.􀀃 Dr. Sergei Kovalev ......................................................................................................... 75􀀃
B.􀀃 RESPONDENT’S WITNESSES ..................................................................................................... 76􀀃
1.􀀃 Professor James Dow ..................................................................................................... 76􀀃
2.􀀃 Mr. Oleg Y. Konnov ...................................................................................................... 78􀀃
3.􀀃 Professor Reinier Kraakman .......................................................................................... 81􀀃
4.􀀃 Professor H. David Rosenbloom .................................................................................... 83􀀃
5.􀀃 Professor Thomas Z. Lys ............................................................................................... 85􀀃
6.􀀃 Ms. Felicity Cullen QC .................................................................................................. 87􀀃
7.􀀃 Mr. Dale Hart ................................................................................................................. 88􀀃
8.􀀃 Mr. Polyvios Polyviou ................................................................................................... 89􀀃
9.􀀃 Mr. John Ellison ............................................................................................................. 90􀀃
10.􀀃 Mr. Raymond Gross ....................................................................................................... 91􀀃
11.􀀃 Professor Dr. Albert Jan van den Berg........................................................................... 93􀀃
Annex 81
- iii -
12.􀀃 Professor Stef van Weeghel ........................................................................................... 94􀀃
C.􀀃 THE SO-CALLED “EMPTY CHAIRS” ......................................................................................... 95􀀃
1.􀀃 Individuals that Claimants Wished were Available for Examination ............................ 96􀀃
2.􀀃 Individuals that Respondent Wished were Available for Examination ......................... 97􀀃
VII.􀀃 ISSUES FOR ANALYSIS ................................................................................................................ 98􀀃
VIII.􀀃 ANALYSIS OF THE EVIDENTIARY RECORD ......................................................................... 102􀀃
A.􀀃 THE TAX OPTIMIZATION SCHEME ......................................................................................... 102􀀃
1.􀀃 Introduction .................................................................................................................. 102􀀃
2.􀀃 The Structure of the Tax Optimization Scheme ........................................................... 103􀀃
3.􀀃 The Legal Framework of the Tax Optimization Scheme ............................................. 105􀀃
(a)􀀃 The Low-Tax Region Program ........................................................................... 105􀀃
(b)􀀃 Anti-Abuse Decisions and Doctrines Promulgated by Russia’s Federal
Courts ................................................................................................................. 107􀀃
4.􀀃 The History of the Yukos Trading Entities before 2003 .............................................. 125􀀃
(a)􀀃 Mordovia ............................................................................................................ 125􀀃
(b)􀀃 Kalmykia ............................................................................................................ 138􀀃
(c)􀀃 Lesnoy and Trekhgorny ...................................................................................... 140􀀃
(d)􀀃 Sarov ................................................................................................................... 158􀀃
(e)􀀃 Baikonur ............................................................................................................. 159􀀃
(f)􀀃 Evenkia ............................................................................................................... 160􀀃
5.􀀃 Tribunal’s Observations ............................................................................................... 164􀀃
B.􀀃 THE TAX ASSESSMENTS STARTING IN DECEMBER 2003 ....................................................... 170􀀃
1.􀀃 Introduction .................................................................................................................. 170􀀃
2.􀀃 Chronology of the Tax Assessments and Related Decisions ....................................... 174􀀃
(a)􀀃 The 2000 Decision .............................................................................................. 175􀀃
(b)􀀃 The 2001 Decision .............................................................................................. 183􀀃
(c)􀀃 The 2002 Decision .............................................................................................. 186􀀃
(d)􀀃 The 2003 Decision .............................................................................................. 189􀀃
(e)􀀃 The 2004 Decision .............................................................................................. 191􀀃
(f)􀀃 Observation ........................................................................................................ 192􀀃
3.􀀃 The Taxes Assessed Against Yukos ............................................................................ 192􀀃
Annex 81
- iv -
(a)􀀃 Profit Tax and Other Revenue-based Taxes ....................................................... 192􀀃
(b)􀀃 VAT .................................................................................................................... 198􀀃
4.􀀃 The Fines Assessed Against Yukos ............................................................................. 201􀀃
5.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 203􀀃
(a)􀀃 Profit Tax and Other Revenue-Based Taxes ...................................................... 204􀀃
(b)􀀃 VAT .................................................................................................................... 219􀀃
(c)􀀃 Fines ................................................................................................................... 239􀀃
(d)􀀃 Concluding Observations ................................................................................... 255􀀃
C.􀀃 HARASSMENT, INTIMIDATION AND ARRESTS ........................................................................ 257􀀃
1.􀀃 Introduction .................................................................................................................. 257􀀃
2.􀀃 Chronology of Facts ..................................................................................................... 258􀀃
(a)􀀃 Yukos Grows; Mr. Khodorkovsky Becomes More Politically Engaged;
Yukos Leaders Receive Warnings ..................................................................... 258􀀃
(b)􀀃 Prosecutor General Launches Investigations Involving Searches and
Seizures .............................................................................................................. 260􀀃
(c)􀀃 Arrest and Trial of Mr. Khodorkovsky; Flight from Russia of His
Associates ........................................................................................................... 263􀀃
(d)􀀃 Complaints of Further Harassment and Intimidation of Yukos Executives,
Employees, Lawyers and External Advisers ...................................................... 265􀀃
(e)􀀃 Second Trial of Mr. Khodorkovsky; Allegations of Continuing
Harassment and Intimidation .............................................................................. 269􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 270􀀃
(a)􀀃 Are Claimants’ Allegations about a Campaign of Harassment Credible? ......... 271􀀃
(b)􀀃 Were the Actions of the Russian Federation Justified as Legitimate Law
Enforcement Measures? ..................................................................................... 274􀀃
(c)􀀃 Did the Events Complained of Impact Claimants’ Investments or was
Yukos Able to Carry on Unaffected? ................................................................. 276􀀃
D.􀀃 THE UNWINDING OF THE YUKOS–SIBNEFT MERGER ............................................................ 279􀀃
1.􀀃 Introduction .................................................................................................................. 279􀀃
2.􀀃 Chronology .................................................................................................................. 281􀀃
(a)􀀃 Merger is Announced; NYSE Listing is Put on Hold; Steps are Taken to
Complete Merger ................................................................................................ 281􀀃
(b)􀀃 Mr. Khodorkovsky is Arrested; Yukos Continues with Merger; Sibneft has
Second Thoughts ................................................................................................ 283􀀃
Annex 81
- v -
(c)􀀃 Russian Courts Invalidate the Share Exchange Agreement ............................... 285􀀃
(d)􀀃 Russian Federation Ultimately Acquires Sibneft via Gazprom .......................... 287􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 287􀀃
(a)􀀃 Was Yukos’ NYSE Listing Put on Hold Because of the Yukos􀃭Sibneft
Merger or Fears of Exposing Yukos’ Tax Optimization Scheme? .................... 287􀀃
(b)􀀃 Was the 2003 Interim Dividend a Component of the Yukos􀃭Sibneft
Merger or a Means to Siphon Funds out of Russia? .......................................... 289􀀃
(c)􀀃 Was the Unwinding of the Merger Caused by the Russian Federation? ............ 292􀀃
E.􀀃 ATTEMPTS TO SETTLE ............................................................................................................ 298􀀃
1.􀀃 Introduction .................................................................................................................. 298􀀃
2.􀀃 Yukos’ Settlement Offers (and the Russian Federation’s Replies) .............................. 300􀀃
(a)􀀃 Proposals Made to the Bailiffs ........................................................................... 302􀀃
(b)􀀃 Proposals for a Global Settlement Conveyed by Mr. Chrétien .......................... 304􀀃
(c)􀀃 Requests for a Deferral or Payment in Instalments ............................................ 306􀀃
(d)􀀃 Other Proposals .................................................................................................. 307􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 308􀀃
(a)􀀃 Did Yukos Contribute to its Own Demise by Failing to Discharge Tax
Debt in the Amount of USD 9 Billion in the First Quarter of 2004? ................. 308􀀃
(b)􀀃 Did Yukos’ Settlement Offers Constitute Real Alternatives to
Enforcement? ..................................................................................................... 312􀀃
F.􀀃 THE AUCTION OF YNG .......................................................................................................... 322􀀃
1.􀀃 Introduction .................................................................................................................. 322􀀃
2.􀀃 Chronology .................................................................................................................. 324􀀃
(a)􀀃 Yukos’ Shares in YNG are Seized and the Government Announces they
will be Sold; Yukos Brings Unsuccessful Court Challenges ............................. 325􀀃
(b)􀀃 YNG is Valued for Auction while its Tax Liabilities Rapidly Escalate ............. 325􀀃
(c)􀀃 Yukos Tries to Prevent the Auction; Preparations Proceed; an Entity
Named Baikal is Created to Purchase YNG ....................................................... 327􀀃
(d)􀀃 After a 10-Minute Auction, the Successful Bidder Baikal is Sold to State-
Owned Rosneft; a “Monumental Bargain”; the “State, Looking After its
Own Interests” .................................................................................................... 329􀀃
(e)􀀃 Once it is State-Owned, YNG’s Fate Improves, with Reductions in Tax
Liabilities and a Dramatic Increase in Value ..................................................... 330􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 331􀀃
Annex 81
- vi -
(a)􀀃 Did the Auction Price Reflect the True Value of YNG; If not, was Either
Party Responsible for the Price Reduction? ....................................................... 332􀀃
(b)􀀃 Who was Behind Baikal and were They a Front for the Russian State? ............ 336􀀃
(c)􀀃 What were Yukos’ Prospects for Survival Once it Lost its Core Asset? ............ 340􀀃
G.􀀃 THE BANKRUPTCY OF YUKOS ............................................................................................... 342􀀃
1.􀀃 Introduction .................................................................................................................. 342􀀃
2.􀀃 Chronology .................................................................................................................. 343􀀃
(a)􀀃 The Initiation of the Bankruptcy ........................................................................ 343􀀃
(b)􀀃 The Treatment of Bankruptcy Claims; the Creditors’ Meeting; the
Declaration of Yukos’ Bankruptcy ..................................................................... 349􀀃
(c)􀀃 The Liquidation of Yukos’ Remaining Assets ................................................... 352􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 355􀀃
(a)􀀃 Why was the Bankruptcy Initiated and Who was Truly Behind It? ................... 356􀀃
(b)􀀃 Were the Bankruptcy Proceedings Conducted Properly and Fairly? ................. 368􀀃
H.􀀃 THE WITHDRAWAL OF PWC’S AUDIT OPINIONS ................................................................... 377􀀃
1.􀀃 Introduction .................................................................................................................. 377􀀃
2.􀀃 Chronology .................................................................................................................. 379􀀃
(a)􀀃 PwC Serves as Both Auditor and Consultant to Yukos ...................................... 379􀀃
(b)􀀃 PwC Responds to the Massive Tax Reassessments against Yukos .................... 380􀀃
(c)􀀃 PwC Faces Mounting Pressure from the Russian Federation around the
Same Time as Mr. Khodorkovsky’s Second Trial Starts ................................... 382􀀃
(d)􀀃 PwC’s “Volte-Face” in Withdrawing the Yukos Audits; Improved
Treatment and Continued Pressures in the Russian Federation ......................... 385􀀃
3.􀀃 Parties’ Arguments and Tribunal’s Observations ........................................................ 389􀀃
(a)􀀃 Did PwC Withdraw its Audits because it was under Pressure from the
Russian Government? ........................................................................................ 389􀀃
(b)􀀃 Were the Grounds Provided by PwC in its Withdrawal Letter Contrived or
Credible? ............................................................................................................ 391􀀃
(c)􀀃 Concluding Observations ................................................................................... 399􀀃
IX.􀀃 PRELIMINARY OBJECTIONS ..................................................................................................... 401􀀃
A.􀀃 ARE ALL OR SOME OF THE CLAIMS BARRED BY THE “FORK-IN-THE-ROAD” PROVISION OF
THE ECT? ............................................................................................................................... 402􀀃
1.􀀃 Introduction .................................................................................................................. 402􀀃
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2.􀀃 Parties’ Positions .......................................................................................................... 403􀀃
3.􀀃 Tribunal’s Decision ...................................................................................................... 406􀀃
B.􀀃 “UNCLEAN HANDS” (DID CLAIMANTS ACT ILLEGALLY SO AS TO DEPRIVE THEM OF
PROTECTION UNDER THE ECT?) ............................................................................................ 406􀀃
1.􀀃 Introduction .................................................................................................................. 406􀀃
2.􀀃 Claimants’ Alleged “Unclean Hands” ......................................................................... 408􀀃
(a)􀀃 Conduct Related to the Acquisition of Yukos and the Subsequent
Consolidation of Control over Yukos and its Subsidiaries ................................ 409􀀃
(b)􀀃 Conduct Related to the Cyprus-Russia DTA ...................................................... 412􀀃
(c)􀀃 Conduct Related to the Tax Optimization Scheme ............................................ 416􀀃
(d)􀀃 Actions Taken in Hindrance of the Enforcement of Russia’s Tax Claims ......... 416􀀃
3.􀀃 Parties’ Positions Regarding the Impact of Claimants’ Allegedly “Unclean
Hands” on this Arbitration ........................................................................................... 418􀀃
(a)􀀃 Respondent’s Position ........................................................................................ 418􀀃
(b)􀀃 Claimants’ Position ............................................................................................ 423􀀃
4.􀀃 Tribunal’s Decision ...................................................................................................... 428􀀃
(a)􀀃 Can a Clean Hands Principle or Legality Requirement be Read into the
ECT? .................................................................................................................. 429􀀃
(b)􀀃 Does the “Clean Hands” Doctrine Constitute a “General Principle of Law
Recognized by Civilized Nations”? ................................................................... 431􀀃
(c)􀀃 Would any Instances of Claimants’ Alleged “Bad Faith and Illegal”
Conduct be Caught by a Legality Requirement Read into the ECT? ................. 433􀀃
(d)􀀃 Conclusion .......................................................................................................... 435􀀃
C.􀀃 RESPONDENT’S OBJECTIONS UNDER ARTICLE 21 OF THE ECT ............................................. 435􀀃
1.􀀃 Introduction .................................................................................................................. 435􀀃
2.􀀃 Claimants’ Position ...................................................................................................... 437􀀃
3.􀀃 Respondent’s Position .................................................................................................. 440􀀃
4.􀀃 Tribunal’s Decision ...................................................................................................... 446􀀃
(a)􀀃 Introduction ........................................................................................................ 446􀀃
(b)􀀃 First Reason: Assuming the Carve-Out Applies, So Does the Claw-Back,
and Any Referral to the Competent Tax Authorities Would Clearly have
been Futile .......................................................................................................... 448􀀃
(c)􀀃 Second Reason: The Carve-Out Does Not Apply ............................................. 453􀀃
(d)􀀃 Conclusion .......................................................................................................... 457􀀃
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X.􀀃 LIABILITY ..................................................................................................................................... 457􀀃
A.􀀃 ATTRIBUTION ......................................................................................................................... 458􀀃
1.􀀃 Claimants’ Position ...................................................................................................... 458􀀃
2.􀀃 Respondent’s Position .................................................................................................. 460􀀃
3.􀀃 Tribunal’s Decision on Attribution .............................................................................. 462􀀃
B.􀀃 ARTICLE 10 OF THE ECT ........................................................................................................ 467􀀃
1.􀀃 Introduction .................................................................................................................. 467􀀃
2.􀀃 Applicable Legal Standards under Article 10(1) of the ECT ....................................... 468􀀃
(a)􀀃 Claimants’ Position ............................................................................................ 468􀀃
(b)􀀃 Respondent’s Position ........................................................................................ 472􀀃
3.􀀃 Did Respondent Accord Claimants’ Investments the Standard of Treatment
Required by Article 10(1) of the ECT? ........................................................................ 475􀀃
(a)􀀃 Claimants’ Position ............................................................................................ 475􀀃
(b)􀀃 Respondent’s Position ........................................................................................ 480􀀃
C.􀀃 ARTICLE 13 OF THE ECT ........................................................................................................ 481􀀃
1.􀀃 Introduction .................................................................................................................. 481􀀃
2.􀀃 Applicable Legal Standards under Article 13 of the ECT ........................................... 482􀀃
(a)􀀃 Claimants’ Position ............................................................................................ 482􀀃
(b)􀀃 Respondent’s Position ........................................................................................ 485􀀃
3.􀀃 Did Respondent’s Actions Constitute Expropriation (or “Measures Having
Effect Equivalent to Nationalization or Expropriation”) within the Meaning of
Article 13(1) of the ECT? ............................................................................................ 488􀀃
(a)􀀃 Claimants’ Position ............................................................................................ 488􀀃
(b)􀀃 Respondent’s Position ........................................................................................ 489􀀃
4.􀀃 If Respondent’s Actions Constitute Expropriation, Has Respondent Met the
Criteria for a Lawful Expropriation under Article 13(1) of the ECT? ......................... 492􀀃
(a)􀀃 Claimants’ Position ............................................................................................ 492􀀃
(b)􀀃 Respondent’s Position ........................................................................................ 493􀀃
D.􀀃 TRIBUNAL’S DECISION ON BREACH OF THE ECT .................................................................. 495􀀃
E.􀀃 CONTRIBUTORY FAULT ......................................................................................................... 500􀀃
1.􀀃 Introduction .................................................................................................................. 500􀀃
2.􀀃 Contributory Fault as Applied in Other Cases ............................................................. 502􀀃
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3.􀀃 Tribunal’s Analysis ...................................................................................................... 503􀀃
(a)􀀃 Conduct of Yukos in Some of the Low-Tax Regions ........................................ 503􀀃
(b)􀀃 Conduct of Yukos under the Cyprus-Russia DTA ............................................. 505􀀃
(c)􀀃 Conduct of Yukos in Connection with YNG Auction ........................................ 506􀀃
(d)􀀃 Conduct of Yukos in Connection with its Bankruptcy (Non-Payment of the
A Loan) .............................................................................................................. 508􀀃
4.􀀃 Tribunal’s Decision on Contributory Fault .................................................................. 509􀀃
XI.􀀃 INTEREST ...................................................................................................................................... 510􀀃
A.􀀃 CLAIMANTS’ POSITION .......................................................................................................... 510􀀃
B.􀀃 RESPONDENT’S POSITION ...................................................................................................... 512􀀃
C.􀀃 THE LEGAL FRAMEWORK ...................................................................................................... 513􀀃
1.􀀃 Energy Charter Treaty .................................................................................................. 513􀀃
2.􀀃 ILC Articles on State Responsibility ........................................................................... 514􀀃
3.􀀃 RosInvestCo and Quasar .............................................................................................. 514􀀃
4.􀀃 Treatises ....................................................................................................................... 514􀀃
(a)􀀃 General Issues ..................................................................................................... 515􀀃
(b)􀀃 Rate ..................................................................................................................... 515􀀃
(c)􀀃 Dies a quo ........................................................................................................... 517􀀃
(d)􀀃 Simple or Compound .......................................................................................... 518􀀃
(e)􀀃 Post-Award Interest ............................................................................................ 518􀀃
D.􀀃 TRIBUNAL’S DECISION ........................................................................................................... 519􀀃
XII.􀀃 THE QUANTIFICATION OF CLAIMANTS’ DAMAGES .......................................................... 522􀀃
A.􀀃 CLAIMANTS’ POSITION .......................................................................................................... 522􀀃
1.􀀃 Valuation Date ............................................................................................................. 523􀀃
2.􀀃 Causation ...................................................................................................................... 524􀀃
3.􀀃 Calculations Performed by Claimants and Mr. Kaczmarek ......................................... 524􀀃
(a)􀀃 The “Scenarios” Presented by Claimants ........................................................... 524􀀃
(b)􀀃 Methodology Used for Calculations Based on Scenarios 1 and 2 ...................... 526􀀃
(c)􀀃 Methodology Used for Calculations Based on Scenario 3 ................................. 531􀀃
(d)􀀃 Methodology Used for Calculations Based on 2012 Valuation Date ................. 532􀀃
(e)􀀃 Summary of Results of Claimants’ Calculations ................................................ 533􀀃
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4.􀀃 Failure of Claimants to Mitigate .................................................................................. 533􀀃
5.􀀃 Windfall and Double-Recovery ................................................................................... 534􀀃
B.􀀃 RESPONDENT’S POSITION ...................................................................................................... 535􀀃
1.􀀃 Valuation Date ............................................................................................................. 535􀀃
2.􀀃 Causation ...................................................................................................................... 536􀀃
3.􀀃 Specific Aspects of the Calculations Performed by Claimants Criticized by
Respondent ................................................................................................................... 537􀀃
(a)􀀃 Credibility of Claimants’ DCF Analysis ............................................................ 537􀀃
(b)􀀃 Claimants’ Selection of Comparable Companies for Purposes of the
Comparable Companies Analysis ...................................................................... 538􀀃
(c)􀀃 Claimants’ Reliance on Comparable Transactions ............................................. 539􀀃
(d)􀀃 Claimants’ Calculations of Hypothetical Cash Flows from Dividends .............. 539􀀃
(e)􀀃 Claimants’ Calculations Based on the Loss of a Chance to Obtain a Listing
on the New York Stock Exchange ..................................................................... 540􀀃
(f)􀀃 Claimants’ Calculations Based on the Assumption of a Completed Yukos–
Sibneft Merger .................................................................................................... 540􀀃
(g)􀀃 Claimants’ Scenarios 3a to 3d ............................................................................ 540􀀃
(h)􀀃 Claimants’ Scenario 3e and the Valuation of YNG ........................................... 541􀀃
(i)􀀃 Claimants’ Calculation of Pre-Award Interest ................................................... 541􀀃
4.􀀃 Failure of Claimants to Mitigate .................................................................................. 541􀀃
5.􀀃 Windfall and Double-Recovery ................................................................................... 542􀀃
C.􀀃 TRIBUNAL’S ANALYSIS AND DECISION ................................................................................. 543􀀃
1.􀀃 Valuation Date ............................................................................................................. 543􀀃
(a)􀀃 The Date of the Expropriation ............................................................................ 543􀀃
(b)􀀃 The Possibility for Claimants to Choose Between a Valuation as of the
Date of Expropriation and a Valuation as of the Date of the Award .................. 544􀀃
2.􀀃 Causation ...................................................................................................................... 546􀀃
(a)􀀃 Causation and Reliance on Multiple Actions ..................................................... 546􀀃
(b)􀀃 Multiple Causes for the Same Damage .............................................................. 547􀀃
3.􀀃 Failure of Claimants to Mitigate .................................................................................. 548􀀃
4.􀀃 The Methodology Followed by the Tribunal ............................................................... 548􀀃
(a)􀀃 Valuation of Yukos ............................................................................................ 550􀀃
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(b)􀀃 Valuation of Lost Dividends .............................................................................. 553􀀃
5.􀀃 Application of the Methodology Followed by the Tribunal ........................................ 560􀀃
(a)􀀃 Calculations Based on 19 December 2004 Valuation Date ................................ 561􀀃
(b)􀀃 Calculations Based on 2014 Valuation Date ...................................................... 562􀀃
(c)􀀃 Comparison of the Results Based on the Two Different Valuation Dates ......... 563􀀃
6.􀀃 Deductions Due to Claimants’ Contributory Fault ...................................................... 564􀀃
7.􀀃 Windfall and Double Recovery .................................................................................... 564􀀃
XIII.􀀃 COSTS ............................................................................................................................................ 564􀀃
A.􀀃 INTRODUCTION ...................................................................................................................... 564􀀃
B.􀀃 CLAIMANTS’ POSITION .......................................................................................................... 566􀀃
1.􀀃 Claimants are Entitled to Recover All Costs Incurred in Connection with these
Arbitrations .................................................................................................................. 566􀀃
2.􀀃 Claimants’ Costs are Reasonable ................................................................................. 568􀀃
3.􀀃 Claimants’ Comments on Respondent’s Submission on Costs .................................... 570􀀃
C.􀀃 RESPONDENT’S POSITION ...................................................................................................... 571􀀃
1.􀀃 Equal Apportionment is an Appropriate Exercise of the Tribunal’s Discretion on
Costs ............................................................................................................................. 571􀀃
2.􀀃 Schedule of “Types of Costs” Incurred by Respondent ............................................... 572􀀃
3.􀀃 Respondent’s Comments on Claimants’ Submission on Costs .................................... 573􀀃
D.􀀃 TRIBUNAL’S DECISION ON COSTS .......................................................................................... 574􀀃
1.􀀃 Fixing and Allocation of Costs of the Arbitration Pursuant to Article 40(1) of the
UNCITRAL Rules ....................................................................................................... 574􀀃
2.􀀃 Fixing and Allocation of Costs for Legal Representation and Assistance of the
Parties Pursuant to Article 40(2) of the UNCITRAL Rules ........................................ 575􀀃
3.􀀃 Conclusion on the Award of Costs .............................................................................. 576􀀃
XIV.􀀃 DECISION ...................................................................................................................................... 578􀀃
ANNEXES ................................................................................................................................................ A-1􀀃
A.􀀃 ANNEX A1: APPENDIX 1.1, APPENDIX J.1 AND APPENDIX J.2 TO SECOND DOW REPORT
(MODIFIED AS DESCRIBED IN NOTE 2401 OF THE AWARD) .................................................... A-1􀀃
(a)􀀃 Appendix 1.1 ...................................................................................................... A-1􀀃
(b)􀀃 Appendix J.1 New .............................................................................................. A-2􀀃
(c)􀀃 Appendix J.2 New .............................................................................................. A-3􀀃
Annex 81
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B.􀀃 ANNEX A2: YUKOS COMPANY STRUCTURE (EXTRACT FROM EXH. R-3165, REFERRED TO
IN NOTE 2413 OF THE AWARD) .............................................................................................. A-5􀀃
C.􀀃 TABLES T1–T9 SHOWING THE TRIBUNAL’S DAMAGES CALCULATIONS .............................. A-6􀀃
1.􀀃 Table T1: Calculation of Total Damages of Claimants as of 19 December 2004
(Date of Expropriation) vs. 30 June 2014 (Date of Award for Valuation
Purposes) ...................................................................................................................... A-6􀀃
2.􀀃 Table T2: Equity Value of Yukos Based on Adjustments Made by Professor
Dow to Mr. Kaczmarek’s Comparable Companies Calculations and the
Evolution of the RTS Oil & Gas Index ........................................................................ A-7􀀃
3.􀀃 Table T3: Calculation of Dividends and Interest up to Valuation Date for
Valuation as of 30 June 2014 ....................................................................................... A-8􀀃
4.􀀃 Table T4: FCFtE for Years 2012–2014 (Based on Mr. Kaczmarek’s Figures) ......... A-9􀀃
5.􀀃 Table T5: Total Adjustment of Free Cash Flow to the Firm (Required to Obtain
FCFtE value for Years 2012–2014 for Mr. Kaczmarek) ........................................... A-10􀀃
6.􀀃 Table T6: Change in Net Debt for Years 2012–2014 ............................................... A-11􀀃
7.􀀃 Table T7: Interest Factors Based on Annual Rate of 3.389 percent (see Table
T9) .............................................................................................................................. A-12􀀃
8.􀀃 Table T8: RTS Oil and Gas Index Values from 1 January to 24 June 2014 ............. A-13􀀃
9.􀀃 Table T9: 10-Year U.S. Sovereign Bond Rate 2005–2014 ....................................... A-16􀀃
Annex 81
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􀁸 the passage of the Reply (mentioned at paragraph 1266 above) where Claimants
state that they will deduct any payments they receive in the ECtHR proceedings
from the amounts claimed in these arbitrations; and
􀁸 the Application for Just Satisfaction (mentioned at paragraph 1261 above), where
Mr. Gardner characterized Claimants in these arbitrations as the “ultimate
stakeholders” in Yukos.1655
1270. Finally, Respondent submits that Claimants’ reliance on positions that the ECtHR has already
finally rejected – namely that Respondent’s taxation measures against Yukos were mala fides,
briefed extensively in its Rejoinder,1656 “creates a risk of conflicting determinations, one of the
ills that Article 26(3)(b)(i) ECT is designed to avoid.”1657
3. Tribunal’s Decision
1271. Having considered the Parties’ submissions and reviewed the reasons for its dismissal in the
Interim Awards of Respondent’s identical objection to jurisdiction pursuant to Article
26(3)(b)(i) of the ECT, the Tribunal sees no reason to reopen this issue and change its decision.
1272. Accordingly, Respondent’s objection that the Tribunal lacks jurisdiction pursuant to
Article 26(3)(b)(i) of the ECT is dismissed.
B. “UNCLEAN HANDS” (DID CLAIMANTS ACT ILLEGALLY SO AS TO DEPRIVE THEM OF
PROTECTION UNDER THE ECT?)
1. Introduction
1273. As its second preliminary objection, Respondent submits that Claimants have come to this
Tribunal with “unclean hands,” with one or many of the following consequences: (a) the
Tribunal does not have jurisdiction over Claimants’ claims; (b) Claimants’ claims are
inadmissible; and/or (c) Claimants should be deprived of the substantive protections of the
ECT. The Tribunal addresses this argument in the present chapter.
1274. Should the Tribunal reject the “unclean hands” argument as a preliminary objection,
1655 Ibid. ¶ 369.
1656 Ibid. ¶¶ 99–193.
1657 Ibid. ¶ 374.
Annex 81
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Respondent also submits that some instances of Claimants’ unclean hands should be treated as
contributory fault and/or a failure to mitigate on the part of Claimants, and that any damages
awarded to Claimants should be discounted on the basis of their unclean hands. These
arguments are addressed in Chapters X.E and XII.C.
1275. Respondent initially made its “unclean hands” argument in the jurisdictional phase of these
arbitrations. In Paragraph 3 of its Procedural Order No. 3 dated 31 October 2006, the Tribunal
decided that it would be “appropriate to defer consideration of the Parties’ contentions
concerning ‘unclean hands’ [and] Respondent’s ‘criminal enterprise’ contention . . . to the
merits phase, if any.”
1276. In its Interim Awards, the Tribunal stated:
The Tribunal is well aware of Respondent’s argument that Claimant in this arbitration has
“unclean hands” and that Claimant’s corporate personality should be disregarded because it
is an instrumentality of a “criminal enterprise.” The Tribunal recalls that it addressed these
issues in its Procedural Orders Nos. 2 and 3 on 8 September and 31 October 2006.
Specifically, the Tribunal then decided to defer consideration of Respondent’s arguments
concerning the “unclean hands” of Claimant or Claimant being an instrumentality of a
“criminal enterprise” to any merits phase of this arbitration. Accordingly, by finding, as it
does, that Claimant qualifies as an Investor owning and controlling an Investment for the
purposes of Articles 1(7) and (6) of the ECT, the Tribunal does not dispose of the issues
argued by Respondent concerning the “unclean hands” of Claimant and Claimant being an
instrumentality of a “criminal enterprise,” which it will address during any merits phase of
this arbitration.1658
1277. As anticipated in the Interim Awards, now with the benefit of a full presentation of the facts by
the Parties on all aspects of the Yukos affair, the Tribunal addresses Respondent’s “unclean
hands” argument in this final Award.
1278. The Tribunal notes that, in their First Submission on Costs, Claimants argue that Respondent,
after insisting on its “unclean hands” allegations and the assertion that Claimants are an
instrumentality of a “criminal enterprise” in the jurisdictional phase of this arbitration and
dedicating nearly two hundred pages of its Counter-Memorial and Rejoinder to the first of these
two arguments, ultimately abandoned these arguments at the Hearing, pursuing only the
allegations related to alleged abuse by Claimants of the Cyprus-Russia DTA.1659 In its Reply
Submission on Costs, Respondent confirmed that it had not abandoned its unclean hands
defense. To the contrary, Respondent argued that Claimants had explicitly refused to join issue
1658 Interim Awards ¶ 435 (Hulley); ¶ 436; (YUL); ¶ 492 (VPL).
1659 Exh. C-916.
Annex 81
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and submit rebuttal and Respondent had accordingly relied on its arguments as undisputed and
accepted. According to Respondent, this alleviated the need to devote substantial hearing time
to these points.1660
1279. Claimants correctly observe that at the merits hearing (and in their Post-Hearing Brief)
Respondent expanded only on the Cyprus-Russia DTA abuses part of its “unclean hands”
argument, making only passing reference to other aspects of this argument.1661 However, in the
Tribunal’s view, this circumstance speaks only to Respondent’s freedom to present its case as it
chooses, and represents Respondent’s strategic decision to focus on certain arguments instead
of others in the limited time available to it at the Hearing and within the page limit for posthearing
submissions imposed by the Tribunal. The fact that Respondent did not repeat in full
all of the arguments made in previous pleadings at the Hearing and in its Post-Hearing Brief
does not mean that these arguments were abandoned.
1280. Below, the Tribunal first summarizes the factual allegations constituting the foundation of
Respondent’s “unclean hands” argument and then the Parties’ arguments regarding the impact
of the alleged facts on the Tribunal’s jurisdiction, the admissibility of claims and the
availability of the substantive protections of the ECT to Claimants. In the last section of this
chapter, the Tribunal sets out its decision with respect to “unclean hands” as a preliminary
objection.
2. Claimants’ Alleged “Unclean Hands”
1281. Respondent lists 28 instances of alleged “illegal and bad faith conduct” by Claimants or
“attributable to” Claimants involving a variety of actors and spanning over ten years, from the
privatization of Yukos in the mid-1990s to its liquidation in November 2007. Claimants
dispute that any of their conduct (or any conduct attributable to them) was illegal or in bad
faith.
1282. Given the number and diversity of Respondent’s allegations, the Tribunal presents them below
in groups intended to facilitate its subsequent analysis. Where facts related to Respondent’s
“unclean hands” allegations fall outside the scope of the analysis of the factual background set
out in Part VIII above, they are briefly summarized here.
1660 Respondent’s Reply Submission on Costs ¶¶ 16–18
1661 See e.g. Transcript, Day 19 at 169–74, 179; Respondent’s Post-Hearing Brief ¶¶ 146, 148.
Annex 81
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(a) Conduct Related to the Acquisition of Yukos and the Subsequent
Consolidation of Control over Yukos and its Subsidiaries
1283. The first eleven items of Respondent’s list of “illegal and bad faith conduct” are dedicated to
conduct related to the acquisition of Yukos by Bank Menatep; and the so-called “Oligarchs”
and their subsequent consolidation of control and ownership over Yukos and its subsidiaries:
i. Violating the legal requirements governing the loans-for-shares program that
allowed Menatep to gain its controlling interest in Yukos.
ii. Using shell company proxies to feign competition in the loans-for-shares auction
and a simultaneous investment tender for Yukos shares.
iii. Precluding actual competitors from bidding on Yukos shares in the loans-for-shares
auction and investment tender, including through the abuse of Menatep’s role as
auction organizer to disqualify Russian competitors.
iv. Rigging a subsequent auction for the Yukos shares that were being held as collateral
following the initial loans-for-shares auction, which deprived the Russian
Government of substantial revenue.
v. Conspiring with Yukos’ pre-existing managers to facilitate the unlawful acquisition
of Yukos by the Oligarchs, including by entering into an agreement whereby “Yukos
Universal” committed to pay them compensation consisting of 15% of Menatep’s
beneficial interest in Yukos, ultimately worth billions of dollars, for “services
rendered to ‘Yukos’”.
vi. Colluding with others to predetermine the post-privatization ownership of Yukos.
vii. Skimming profits from Yukos and its production subsidiaries for their own selfenrichment.
viii. Abusing Russian corporate law and principles of corporate governance by squeezing
out minority shareholders in Yukos’ production subsidiaries through ruthless and
self-enriching share dilutions, asset stripping, and transfer pricing.
ix. Siphoning off huge sums for the benefit of the Oligarchs from Yukos’ proceeds from
the sale of oil and oil products, while concealing related-party transactions from
Yukos’ own auditor.
x. Further mistreatment of minority shareholders by manipulating shareholder
meetings, pressuring the Russian Federal Securities Commission not to pursue its
challenges against illegal misconduct, relying on fraudulently determined stock and
asset values and deceiving those minority shareholders, the government, and
domestic and foreign courts about the nature and control of offshore companies that
were created to benefit Claimants and their cohorts.
Annex 81
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xi. Manipulating Yukos’ stock value to devalue and reacquire the interests of creditors
to which Yukos stock had been pledged.1662
1284. As context to Respondent’s allegations, it is useful to recall some of Yukos’ early history. The
Russian Federation created the company in 1993 as part of a large-scale reorganization of the
Soviet oil production and processing industry into vertically integrated oil companies. Yukos
remained largely state-run until 1995.1663
1285. Respondent recounts, based on a report by Professor Reinier Kraakman that, in March 1995, a
consortium of Russian commercial banks, including Bank Menatep (the Chairman of which
was Mr. Khodorkovsky), proposed to the Russian government that they would lend it money in
exchange for the right to hold as collateral and manage shares of major state-owned companies
such as Yukos.1664 A presidential decree of August 1995 provided for the auctioning of the
right to hold and manage shares of individual companies.1665 Once the terms of the proposed
management agreement expired, the government would have a choice between paying back the
loan and reclaiming its shares, and allowing the lender to sell the shares, with the government
keeping 70 percent of the difference between the sale price and the original amount of the
loan.1666 This mechanism became known as the “loans-for-shares program.”
1286. In December 1995, the Russian Government retained Bank Menatep to organize the auction for
the shares in Yukos.1667
1287. Respondent alleges that Bank Menatep “completely rigged the auction” by preventing potential
competitors from participating, while using two front companies, Laguna and Regent, to
formally comply with the requirements for bids.1668 Respondent recounts that Laguna won the
right to hold as collateral and manage a 45 percent stake in Yukos for a USD 159 million loan
to the Russian government and an additional investment obligation of USD 200 million.
According to Respondent, Laguna acquired an additional 33 percent stake in Yukos by
pledging just over USD 150 million in investments at a simultaneously held “investment
1662 Rejoinder ¶¶ 1435–36.
1663 Counter-Memorial ¶ 19.
1664 Ibid.¶ 20.
1665 Decree of the President of the Russian Federation No. 889 On the Procedure for Putting the Federally Owned Shares
in Pledge, 31 August 1995, Exh. R-7.
1666 Counter-Memorial ¶ 21.
1667 Ibid. ¶ 23.
1668 Ibid. ¶¶ 27–28.
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tender.”1669 Bank Menatep acquired Laguna’s rights to hold and manage Yukos shares
immediately thereafter.1670 Respondent further alleges that Bank Menatep then used “another
rigged auction and another shell affiliate, named Monblan,” to obtain full ownership of the
stake in Yukos.1671 Respondent also suggests that Bank Menatep was “an insider among
insiders” and used Yukos’ own funds to pay for its takeover of Yukos.1672
1288. Respondent makes additional allegations regarding Bank Menatep’s and the Oligarchs’
treatment of foreign and Russian investors holding minority shares in Yukos’ main production
subsidiaries—YNG, Samaraneftegaz and Tomskneft—in the aftermath of the privatization.1673
Respondent alleges that from 1996 to 1999 Bank Menatep and the Oligarchs engaged in
significant profit skimming and, in 1999 and 2000, abused Russian corporate law and principles
of corporate governance to “squeeze out the minority shareholders through massive share
dilutions, transfer pricing, and asset stripping,”1674 until “the minority shareholders sold or
swapped their shares on the Oligarchs’ terms.”1675
1289. Claimants do not engage with the detail of Respondent’s allegations. They contend that these
allegations “amount to little more than innuendo based upon a handful of sensationalized
journalistic accounts.”1676 In particular, Claimants point out that Respondent is “unable to
make out any failure by Bank Menatep to comply with the terms of the loans-for-shares
program”1677 and underline that it was the Russian government itself that had the authority to
preclude foreign companies and individuals from bidding and to disallow bids.1678 Claimants
add that Respondent’s “vague insinuations” as to the source of funds used to privatize Yukos
do not prove that anything unlawful took place.1679 Claimants suggest that Respondent’s
argument “amounts to nothing more than an attempt to shift blame for the actions of the
1669 Ibid. ¶ 28.
1670 Kraakman Report ¶ 20.
1671 Counter-Memorial ¶ 29.
1672 Ibid. ¶ 33.
1673 Ibid. ¶ 45.
1674 Ibid. ¶¶ 915, 946–49; see Kraakman Report ¶¶ 28–42.
1675 Counter-Memorial ¶¶ 916, 951–61, 75; see Kraakman Report ¶¶ 44–62.
1676 Reply ¶ 1142.
1677 Ibid. ¶ 1143.
1678 Ibid. ¶¶ 1144–45.
1679 Ibid. ¶ 1146.
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Russian Government itself onto Bank Menatep.”1680
1290. As regards the manner of the consolidation of Bank Menatep’s ownership over Yukos,
Claimants reply that Respondent’s allegations are vague and “not only irrelevant, but also
moot.”1681 Claimants point out that Respondent relies on share issuances and transfers that
were ultimately cancelled and on an alleged dispute with a minority shareholder that was
eventually settled.1682
(b) Conduct Related to the Cyprus-Russia DTA
1291. Next, Respondent complains of Claimants’ use of the Cyprus-Russia DTA, listing the following
“bad faith and illegal conduct”:
xii. Submitting fraudulent claims under, or otherwise abusing, the Russia-Cyprus Tax
Treaty to evade hundreds of millions of dollars in Russian taxes payable on
dividends involving Yukos shares, thereby also violating Russian and Cypriot
criminal laws.
xiii. Entering into hundreds of sham transactions involving the sale and repurchase of
Yukos shares between Claimants and their affiliates, the sole purpose of which was
to fraudulently suggest that Claimants beneficially owned dividends declared on
Yukos shares, and thereby to further Claimants’ fraudulent claims for favorable tax
treatment under the Russia-Cyprus Tax Treaty.
xiv. Evading hundreds of millions of dollars in Russian taxes on profits from transactions
in and profits from sales of Yukos shares.
[. . .]
xvi. Diverting the proceeds of the Yukos tax evasion scheme into highly opaque Cypriot
and British Virgin Islands entities and trusts to conceal the unlawful provenance of
those proceeds, including through dividend distributions to undisclosed Cypriot
parent companies of trading shells, thereby further abusing the Russia-Cyprus Tax
Treaty.1683
1292. The Russia–Cyprus DTA, as stated in its preamble, serves the “avoidance of double taxation
with respect to taxes on income and capital” and the promotion of “economic cooperation
between the two countries.” Article 10 of the DTA provides:
1680 Ibid. ¶ 1147.
1681 Ibid. ¶¶ 1149, 1151–53.
1682 Ibid. ¶¶ 1149–50.
1683 Rejoinder ¶¶ 1435–36.
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1. Dividends paid by a company which is a resident of a Contracting State to a resident of the
other Contracting State may be taxed in that other State.
2. However, such dividends may also be taxed in the State of which the company paying the
dividends is a resident and according to the laws of that State, but if the beneficial owner of
the dividends is a resident of the other State, the tax so charged shall not exceed:
5% of the gross amount of the dividends….”
1293. The Parties agree that Claimants Hulley and VPL obtained monetary benefits running in excess
of USD 230 million under this provision by claiming the reduced withholding tax rate of 5
percent instead of the standard 15 percent rate of the Russian Federation.
1294. Respondent argues that, in so doing, Hulley and VPL fraudulently relied on the Russia–Cyprus
DTA to evade Russian taxes, because they: (a) were not the “beneficial owners” of the dividend
income but mere “conduits” for the Oligarchs, and (b) had a “permanent establishment” in
Russia to which the dividend income was attributable.1684 According to Respondent,
Claimants’ reliance on the DTA was a “complete perversion of the Treaty’s purpose,” and, as
stated by Professor Rosenbloom, a “blatant example of tax treaty abuse.”1685 Respondent
alleges that Claimants contrived a series of artificial sales and repurchases of Yukos shares by
Hulley from YUL, and VPL parked shares in a UBS Moscow account at suspicious times,
solely to benefit from the DTA. According to Respondent, Claimants offer no justification for
this practice, aside from their expert, Mr. Baker, mischaracterizing it as a “standard
arrangement.”1686
1295. Respondent submits that the beneficial ownership requirement “should be construed in light of
the object and purposes of the [DTA], including avoiding double taxation and the prevention of
fiscal evasion and avoidance.”1687 According to Respondent, Hulley and VPL never had the
full right to use or enjoy Yukos’ dividends. In support, Respondent refers to the following
documents:
􀁸 Hulley’s and VPL’s bank statements from 1 January 2000 to 31 December 2004,
as well as GML’s statement for 2004, which purportedly establish that the
1684 Counter-Memorial ¶¶ 922–23; Rejoinder ¶ 1448.
1685 Counter-Memorial ¶ 165; Rosenbloom Report ¶ 77.
1686 Rejoinder ¶¶ 1488–90; Baker Report, ¶70.
1687 Ibid. ¶ 1449, relying on the 2011 OECD Discussion Draft for the Model Tax Convention, Exh. R-1959.
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dividends paid to Hulley and VPL by Yukos only stayed in their accounts for one
or two days prior to going to YUL;1688
􀁸 Hulley’s Articles of Association, which according to Respondent reserved to the
“Oligarchs” any decision concerning the disposal of Hulley’s assets;1689 and
􀁸 the Deed of Appointment of Chiltern as a custodian trustee for VPL, which,
according to Respondent, provides that all dividend income from VPL’s Yukos
shares “shall be paid” to YUL so long as Chiltern owns VPL.
1296. Respondent also argues that Claimants have contradicted their own arguments in the
jurisdictional phase of these proceedings by acknowledging an “obligation to pass all future
dividends” to YUL; this, argues Respondent, falls within even Claimants’ narrow interpretation
of the beneficial ownership limitation.1690
1297. Respondent further asserts that Hulley and VPL each had a “Russian permanent
establishment.”1691 Respondent interprets Claimants’ admission that Hulley and VPL were
holding companies to mean that any activity necessary to conduct the business of holding
Yukos shares had to be carried out in Russia through a “deemed permanent establishment”
(Article 5(5) of the Cyprus-Russia DTA) or a “fixed place of business” (Article 5(2) of the
Cyprus-Russia DTA).1692 Respondent contends that Messrs. Lebedev and Kakorin, both
Russian citizens and residents, carried out all the activities relating to Hulley’s and VPL’s
Yukos shares from Russia.1693
1298. Respondent further submits that Claimants’ alleged abuses violate both Russian and Cypriot
criminal laws, as shown in the expert report of Mr. Polyviou.1694
1299. Finally, Respondent argues that Claimants’ expert, Mr. Baker, fails to differentiate the
“tolerated” practice of “treaty shopping” from the “universally condemned” practice of “round
1688 Ibid. ¶¶ 1457–65, referring to Exhs. R-334 to R-4154.
1689 Ibid. ¶¶ 1466–87, referring to Exh. R-236.
1690 Ibid. ¶¶ 1478–79.
1691 Ibid. ¶¶ 1491–501.
1692 Ibid. ¶ 1491.
1693 Ibid. ¶ 1500.
1694 Counter-Memorial¶ 927.
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tripping,” which Respondent alleges is what Claimants did.1695 Accordingly, Respondent
submits that, “at best,” Hulley and VPL “perverted” the purposes of the Cyprus-Russia DTA,
even if they satisfied its “literal requirements.”1696
1300. Claimants protest that Respondent’s allegations are unsubstantiated in fact and in law.
1301. Firstly, Claimants argue that the beneficial ownership limitation set forth in Article 10(2)(a) of
the Cyprus-Russia DTA is a “narrow one targeted at nominees, agents and other conduits under
an obligation to pass on the amount received as a dividend to another party.”1697 Hulley and
VPL in the present case had the full right to use and enjoy the dividends they received from
Yukos and were under no obligation to pass them on to another entity, as is evident from
Clause 117 and Article 1 of their respective Articles of Association, which provide that the
power to propose the declaration and payment of dividends lies solely with the directors of the
respective companies.1698
1302. Claimants assert that shares “transferred to a company shortly before the dividend dates and
transferred back after the dividend has been paid are lawful and a common feature in stocklending,
and also in the sale and repurchase of shares (‘repos’).”1699
1303. Secondly, Claimants assert that Hulley and VPL were holding companies, and that their
business as such was not carried on in Russia. 1700 None of the cumulative conditions in
Article10(4) of the DTA were made out to show that Hulley or VPL had a permanent
establishment in Russia, as demonstrated by Mr. Baker’s report.1701
1304. Thirdly, Claimants reject the fraudulent abuse analysis made by Respondent’s expert Professor
Rosenbloom, noting that there is no anti-abuse principle in the DTA.1702 Claimants emphasize
1695 Rejoinder ¶ 1508.
1696 Ibid. ¶ 1509.
1697 Reply ¶ 1157.
1698 Ibid. ¶ 1158.
1699 Ibid. ¶ 1161.
1700 Ibid. ¶ 1163.
1701 Ibid. ¶¶ 1164–74.
1702 Ibid. ¶ 1176.
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that ‘treaty shopping’ to minimize tax is permissible.1703
1305. Finally, Claimants submit that Hulley’s and VPL’s claims under the Cyprus-Russia DTA were
consistent with the purpose of the DTA. Claimants recall that one purpose of double-taxation
treaties is to promote the flow of investment, and argue that both countries have derived
significant benefits from the DTA.1704
1306. In any event, Claimants submit that the claiming of benefits under a double-taxation treaty is a
technical matter, for which specific mechanisms of redress are available under the treaty itself
and domestic law. Accordingly, this Tribunal is not the proper forum to hear and decide such
disputes.1705
(c) Conduct Related to the Tax Optimization Scheme
1307. Three items on Respondent’s list of Claimants’ “illegal and bad faith” conduct relate to
Claimants’ use of the low-tax regions of the Russian Federation to mitigate tax burdens:
xv. Engineering through management installed and controlled by Claimants the massive
Yukos tax evasion scheme to avoid paying hundreds of billions of rubles in Russian
taxes.
[. . .]
xvii. Engaging in abusive corporate restructurings to conceal Yukos’ affiliation with its
trading shells, thereby preventing Russian authorities from identifying and
addressing Yukos’ tax abuses.
xviii. Concealing Yukos’ continued control of its trading shells by resorting to call options
or other artifices and by fabricating corporate and other transactional documents.1706
1308. A detailed discussion of these allegations is found in Chapter VIII.A of this Award.
(d) Actions Taken in Hindrance of the Enforcement of Russia’s Tax Claims
1309. The remaining ten items on Respondent’s list of Claimants’ “bad faith and illegal conduct”
refer to actions allegedly taken to obstruct enforcement of Russia’s tax claims against Yukos:
1703 Ibid. ¶ 1175, citing MIL (Investments) S.A. v. Canada [2006] 5 CTC 2552 (Tax Court of Canada), affirmed by Federal
Court of Appeal of Canada.
1704 Ibid. ¶ 1177.
1705 Ibid. ¶ 1189.
1706 Rejoinder ¶¶ 1435–36.
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xix. Repeatedly obstructing the conduct of the tax authorities’ audits of Yukos by
refusing to provide documents and information which would show the extent of
Yukos’ abuses, and by causing Yukos’ producing subsidiaries and other related
entities to be similarly obstructive.
xx. Failing to pay Yukos’ tax liabilities for tax year 2000 and following years, despite
having received ample notice that Yukos would be required to pay these amounts
and despite the fact that Yukos had abundant resources to do so.
xxi. Dissipating assets to frustrate the Russian authorities’ collection of the tax
assessments, including by way of paying dividends of unprecedented amounts,
making spontaneously accelerated loan “prepayments” to Oligarch-owned Moravel,
and foisting upon YNG an upstream guarantee up to US$ 3 billion for the repayment
of Yukos’ alleged “debts” to Moravel.
xxii. Offering to the Russian authorities assets which Yukos knew to be tainted to settle
its tax liabilities.
xxiii. Concealing the share registers of Yukos’ subsidiaries to obstruct the bailiffs’
enforcement of Yukos’ tax obligations.
xxiv. Sabotaging the YNG auction through litigation threats and a spurious bankruptcy
filing in the United States that effectively prevented all but one bidder from placing
a bid at the auction and artificially depressed the amount of the auction proceeds.
xxv. Implementing asset-stripping measures by diverting Yukos’ valuable assets to the
stichtings managed by former Yukos officers and representatives of Claimants in
anticipation of Yukos’ bankruptcy.
xxvi. Failing to repay Yukos’ debt to the SocGen syndicate and frustrating the banks’
attempts to collect against Yukos’ Dutch assets.
xxvii. In the process of all of the foregoing, lying to Yukos’ auditors PwC about core
aspects of their misconduct and, through PwC’s certification of Yukos’ financial
statements based on this deception of Yukos’ auditors, to Yukos’ creditors and other
members of the investing public who relied upon those financial statements and
PwC’s certification of them.
xxviii. Yukos management’s shielding of Yukos’ very substantial foreign assets behind the
veil of two Dutch stichtings, to place those assets beyond the reach of Russian tax
authorities, violated Dutch law.1707
1310. In sum, Respondent alleges that Yukos neither paid its tax debts in full immediately after these
debts were assessed, nor made reasonable settlement offers; dissipated the assets it had on
hand; lied to its auditors; obstructed the work of the bailiffs; and sabotaged the YNG auction.
Each of these allegations is discussed by the Tribunal in Part VIII of this Award.
1707 Ibid. ¶¶ 1435–36.
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3. Parties’ Positions Regarding the Impact of Claimants’ Allegedly “Unclean Hands”
on this Arbitration
1311. The Parties disagree as to whether any of the instances of alleged illegal or bad faith conduct
enumerated above could serve as a complete bar to Claimants’ claims under the ECT (whether
as a matter of jurisdiction, admissibility or otherwise) by virtue of the application of some rule
or principle of law.
1312. Between them, the Parties have dedicated to this controversy several hundreds of pages of
pleadings in the merits phase alone, citing in the process dozens of arbitral awards and
decisions rendered by the Permanent Court of International Justice (the “PCIJ”), the
International Court of Justice (“ICJ”) and mixed-claims commissions. Below, the Tribunal
does not attempt to do justice to the full breadth of the Parties’ arguments, but focuses instead
on their most salient points.
(a) Respondent’s Position
1313. Respondent submits that Claimants’ “unclean hands” deprive the Tribunal of jurisdiction,
render Claimants’ claims inadmissible and/or deprive Claimants of the substantive protections
of the ECT. This submission is based on two main principles.
1314. First, Respondent argues that “the ECT protects only bona fide and lawful investments and
Respondent’s consent to arbitrate only extends to such investments.”1708 Respondent
emphasizes that, as provided by Article 31(1) of the VCLT, a treaty must be interpreted in good
faith and in accordance with its object and purpose. According to Respondent, the object and
purpose of the ECT does not include the promotion and protection of illegal investments.1709
Rather, as stated in the Treaty’s introductory note, “[t]he fundamental aim of the [ECT] is to
strengthen the rule of law on energy issues.” Respondent argues that several arbitral awards,
including Phoenix Action, Ltd. v. Czech Republic (“Phoenix”), SAUR International S.A. v. The
Argentine Republic and Plama Consortium Limited v. Bulgaria (“Plama”) support the
proposition that, even in the absence of an express legality requirement clause in an investment
treaty, illegal investments will not be protected.1710 With respect to Plama, in particular,
1708 Respondent’s Post-Hearing Brief ¶ 147.
1709 Counter-Memorial ¶ 898.
1710 Rejoinder ¶¶ 1551–52, 1527, 1563, 1566, referring to Plama Consortium Limited v. Bulgaria, ICSID Case No.
ARB/03/24, Award, 27 August 2008, Exh. C-994 (hereinafter “Plama”); Phoenix Action Ltd. v. Czech Republic,
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Respondent notes that the tribunal dismissed the claimants’ ECT claims in the merits phase on
the grounds that: (a) the investment violated Bulgarian law and applicable principles of
international law; (b) the claimant’s conduct was not in good faith; and (c) to grant ECT
protection would therefore have been contrary to the clean hands requirement.1711
1315. Second, Respondent argues that a claimant who is guilty of illegal conduct is deprived of the
necessary ius standi to complain of corresponding illegalities by the State.1712 This requirement
of “clean hands,” argues Respondent, is a “general principle of law” within the meaning of
Article 38(1)(c) of the ICJ Statute.1713 Respondent cites the ICJ’s decision in the Case
Concerning the Gab􀃾íkovo-Nagymaros Project and various dissenting opinions by ICJ judges,
as well as a number of decisions of mixed claims commissions rendered in cases of diplomatic
protection.1714 Regarding the latter set of cases, Respondent submits that the “unclean hands
ICSID Case No. ARB/06/5, Award, 15 April 2009, Exh. R-1078 (hereinafter “Phoenix”); SAUR International S.A. v.
Argentina, ICSID Case No. ARB/04/4, Decision on Jurisdiction and Liability, 6 June 2012, Exh. R-4186 (hereinafter
“SAUR”).
1711 Ibid. ¶ 1552.
1712 Counter-Memorial ¶ 892.
1713 Ibid. ¶ 893.
1714 Counter-Memorial ¶¶ 894–95, referring to Case Concerning the Gab􀃾íkovo-Nagymaros Project (Hungary/Slovakia),
Judgment, 25 September 1997, ICJ Reports 1997, p. 7 ¶ 133, Exh. C-948 (hereinafter “Gab􀃾íkovo-Nagymaros”);
Samuel Brannan v. Mexico, U.S.-Mexico Mixed Claims Commission, Opinion of the Umpire, 1868, in HISTORY
AND DIGEST OF THE INTERNATIONAL ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol.
3 (John Bassett Moore, ed. 1898), p. 2757, 2758, Exh. R-1056; The “Lawrence” Case, U.S.-Great Britain Mixed
Claims Commission, Judgment of the Umpire, 4 January 1855, Hornby’s Report 397, 1856, p. 398, Exh. R-1057;
William Whitty v. The United States, U.S.-British Claims Commission, Decision of the Commissioners, in HISTORY
AND DIGEST OF THE INTERNATIONAL ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol.
3 (John Bassett Moore, ed. 1898), p. 2820, 2823, Exh. R-1058; Frederick G. Fitch v. Mexico, U.S.-Mexico Mixed
Claims Commission, Opinion of the Umpire, 21 June 1876, in HISTORY AND DIGEST OF THE
INTERNATIONAL ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol. 4 (John Bassett Moore,
ed. 1898), p. 3476, 3477, Exh. R-1059; Jarvis Case, U.S.-Venezuela Mixed Claims Commission, Opinion of the
Commissioner, UNRIAA, 1903–1905, Vol. 9, p. 208, 212, Exh. R-1060; Cucullu’s case, U.S.-Mexico Mixed Claims
Commission, Opinion of Mr. Palacio, 1868, in HISTORY AND DIGEST OF THE INTERNATIONAL
ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol. 4 (John Bassett Moore, ed. 1898), p. 3477,
3480, Exh. R-1061; Case of the Brig “Mary Lowell”, U.S.-Spain Claims Commission, Opinion of the Umpire, 9
December 1879, Spain-U.S. Claims Commission, in HISTORY AND DIGEST OF THE INTERNATIONAL
ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol. 3 (John Bassett Moore, ed. 1898), p. 2772,
2775, 2777, Exh. R-1062; Robert Eakin v. United States, No. 118, U.S.-Great Britain Claims Commission, PAPERS
RELATING TO THE FOREIGN RELATIONS OF THE UNITED STATES, Vol. 3 (Washington Government
Printing Office, 1874), p. 15, Exh. R-1063; Clark Case (“The Medea and The Good Return”), U.S.-Ecuador Claims
Commission, 1862, Opinion of Mr. Hassaurek, in HISTORY AND DIGEST OF THE INTERNATIONAL
ARBITRATIONS TO WHICH THE U.S. HAS BEEN A PARTY, Vol. 3 (John Bassett Moore, ed. 1898), p. 2729,
2738–39, Exh. R-1064; Case Concerning Military and Paramilitary Activities in and against Nicaragua (Nicaragua v.
United States of America), Merits, Judgment, 27 June 1986, Dissenting Opinion of Judge Schwebel, ICJ Reports 1986,
p. 259 ¶¶ 268, 272, Exh. R-1071; Case Concerning Arrest Warrant of 11 April 2000 (Democratic Republic of the
Congo v. Belgium), Judgment, 14 February 2002, Dissenting Opinion of Judge van den Wyngaert, ICJ Reports 2002,
p. 137 ¶ 84, Exh. R-1072; Legal Status of Eastern Greenland (Denmark v. Norway), Judgment, 5 April 1933,
Dissenting Opinion of Judge Anzilotti, PCIJ Series A/B No. 53, p. 76, 95, Exh. R-1073; Interpretation of Peace
Treaties with Bulgaria, Hungary and Romania, Second Phase, Advisory Opinion, 18 July 1950, Dissenting Opinion of
Judge Read, ICJ Reports 1950, p. 231, 244, Exh. R-1074. See also Rejoinder ¶¶ 1529–40, citing Case Concerning the
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principle has [an even] greater role with respect to claims brought directly by private parties,
including in investor-State arbitration, than in the context of diplomatic protection.”1715
Respondent also relies on Barcelona Traction for the proposition that in international law the
corporate “veil is lifted” to “prevent the misuse of the privileges of legal personality, as in
certain cases of fraud or malfeasance . . . or to prevent the evasion of legal requirements or of
obligations.”1716 Finally, Respondent argues that if the “unclean hands” doctrine was not
included in the ILC Articles on State Responsibility and Articles on Diplomatic Protection of
the International Law Commission, it is only “because it corresponded to the doctrine of
inadmissibility” and did not fall within the projected scope of both sets of ILC Articles.1717
1316. With respect to Claimants’ contention that the instances of “unclean hands” referred to by
Respondent can have no impact on this arbitration because they are collateral illegalities
unrelated to either the making of Claimants’ investments or their claims in these arbitrations,1718
Respondent argues that it is “unsupported both by the investment treaty awards on which
[Claimants rely], and by common sense and good faith.”1719
1317. With respect to post-investment conduct, Respondent submits that the awards in Gustav FW
Hamester GmbH & Co KG v. Ghana (“Hamester”) and AG Frankfurt Airport Services
Worldwide v. Philippines (“Fraport”) recognize the relevance of such misconduct to the merits
of an investment treaty claim.1720
1318. As regards illegalities pre-dating the acquisition of the investment, Respondent relies on the
award in Anderson v. Costa Rica (“Anderson”).1721 Respondent submits that the tribunal in that
Barcelona Traction Light and Power Company Limited (Belgium v. Spain) (New Application: 1962), Second Phase,
Judgment, 5 February 1970, ICJ Reports 1970, p. 3, Exh. C-930; Mavrommatis Palestine Concessions (Greece v.
Great Britain), Judgment, 30 August 1924, PCIJ Series A No. 2, p. 6, 13, Exh. R-1043; ILC, Provisional Summary
Record of the 2844th Meeting held 25 May 2005, A/CN.4/SR.2844, Agenda Item 2, 6 June 2005, p. 4, 7, Exh. R-
4191.
1715 Rejoinder ¶ 1538.
1716 Case Concerning the Barcelona Traction Light and Power Company Limited (Belgium v. Spain) (New Application:
1962), Second Phase, Judgment, 5 February 1970, ICJ Reports 1970, p. 3 ¶ 56, Exh. C-930.
1717 Rejoinder ¶¶ 1543, 1545–47.
1718 Reply ¶¶ 1134–38.
1719 Rejoinder ¶ 1568.
1720 Ibid. ¶¶ 1569–70, referring to Gustav F W Hamester GmbH & Co KG v. Ghana, ICSID Case No. ARB/07/24, Award,
18 June 2010, Exh. R-1079 (hereinafter “Hamester”); Fraport AG Frankfurt Airport Services Worldwide v.
Philippines, ICSID Case No. ARB/03/25, Award, 16 August 2007, Exh. R- 1006 (hereinafter “Fraport”).
1721 Resondent’s Rejoinder ¶ 1571, referring to Anderson v. Costa Rica, ICSID ARB(AF)/07/3, Award, 19 May 2010,
Exh. R-4204 (hereinafter “Anderson”).
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case dismissed claims brought by Canadian individuals who had invested in a “Ponzi scheme”
for lack of jurisdiction ratione materiae. Respondent highlights that tribunal’s finding that the
entire underlying transaction was illegal and, by that fact, “it follows that the acquisition by
each [c]laimant of the asset resulting from that transaction was also not in accordance with the
law of Costa Rica.”1722 Respondent submits that the finding of the Anderson tribunal applies in
the present case, highlighting that:
where an investment is simply transferred by the same ultimate owner from one investment
vehicle to another, the concept of the unity of the investment requires that the process of
the making and operation of the investment by the ultimate owner and the owner’s
investment vehicle be considered as a whole for purposes of determining the legality of the
investment, even if the acquisition of the investment by the claimant, standing alone, is not
illegal.1723
1319. To hold otherwise, argues Respondent, would extend investment treaty protection to claimants
who shift investments through several layers of ownership and control in order to launder their
illegal investments into legal ones qualifying for treaty protection.1724
1320. In response to Claimants’ assertion that ‘in accordance with the law’ requirements should be
limited to domestic laws regulating the admission of foreign investment, Respondent submits a
number of counter-arguments, including the following:
􀁸 Claimants’ reliance on the “isolated 2010 dictum” in Mr. Saba Fakes v. the Republic of
Turkey (“Saba Fakes”) to limit the substantive scope of the ‘in accordance with the law’
requirement is “unpersuasive and contrary to a consistent line of arbitral awards that have
applied ‘in accordance with the law’ clauses to domestic legislation other than laws
governing the admission of investments.”1725
􀁸 the illegalities “infecting” Claimants’ investments are “quintessential breaches of
‘fundamental principles’” and were “central to the profitability of and dividend flow from
Claimants’ investments.”1726
1722 Ibid., quoting Anderson ¶ 55.
1723 Ibid. ¶ 1572.
1724 Ibid.
1725 Ibid. ¶ 1577, referring to Mr Saba Fakes v. The Republic of Turkey, ICSID ARB/07/20, Award, 17 July 2010, Exh. C-
1537 (hereinafter “Saba Fakes”).
1726 Ibid. ¶ 1582.
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􀁸 Claimants’ attempt to exclude minor violations from the scope of ‘in accordance with the
law’ clauses is unavailing, as none of the illegalities of which Respondent complains are
minor.1727
1321. In response to Claimants’ contention that they were not the relevant actors in the context of
Respondent’s allegations regarding Yukos’ tax optimization scheme and the obstruction of the
enforcement of tax claims against Yukos by the Russian Federation, Respondent submits that
Claimants are “essential instrumentalities of illegal acts, through Claimants’ control of Yukos
and its management,”1728 noting that during the relevant period, “Claimants owned a majority
of Yukos shares and appointed the totality of the members of its board of directors,
including . . . Mikhail Khodorkovsky.”1729
1322. Respondent also states that it is not estopped from invoking Claimants’ unclean hands in this
arbitration by any failure to take prompt action.1730 Respondent submits that Claimants have
failed to satisfy the legal standard for estoppel.1731 This standard, argues Respondent, was
confirmed by the ICJ in the North Sea Continental Shelf Cases:
[I]t appears to the Court that only the existence of a situation of estoppel could suffice to
lend substance to this contention, -- that is to say if the Federal Republic were now
precluded from denying the applicability of the conventional regime, by reason of part
conduct, declarations, etc., which not only clearly and consistently evinced acceptance of
that regime, but also had caused Denmark or the Netherlands, in reliance on such conduct,
detrimentally to change position or suffer some prejudice. Of this there is no evidence
whatever in the present case.1732
1727 Ibid. ¶ 1580.
1728 Counter-Memorial ¶ 909.
1729 Ibid. ¶ 933.
1730 Rejoinder ¶ 1597.
1731 Ibid. ¶¶ 1588–98.
1732 Ibid. ¶ 1589, quoting North Sea Continental Shelf (Federal Republic of Germany/Denmark and Federal Republic of
Germany/Netherlands), Judgment, 20 February 1969, ICJ Reports 1969, p. 3 ¶ 30, Exh. R-4208; see also ¶¶ 1590–92,
citing Delimitation of the Maritime Boundary in the Gulf of Maine Area (Canada/U.S.), Judgment, 12 October 1984,
ICJ Reports 1984, p. 246 ¶ 145, Exh. R-4209; Case of the Land and Maritime Boundary (Cameroon/Nigeria),
Preliminary Objections, Judgment, 11 June 1998, ICJ Reports 1998, p. 275 ¶ 57, Exh. R-4210; Land, Island and
Maritime Frontier Dispute (El Salvador/Honduras), Application by Nigeria for Permission to Intervene, Judgment,
13 September 1990, ICJ Reports 1990, p. 92 ¶ 63, Exh. R-4211; Aerial Incident of 10 August 1999 (Pakistan v. India),
Jurisdiction of the Court, Judgment, 21 June 2000, ICJ Reports 2000, p. 12 ¶ 45, Exh. R-4212; Legality of Use of
Force (Serbia and Montenegro v. Canada), Preliminary Objections, Judgment, 15 December 2004, ICJ Reports 2004,
p. 429 ¶ 42, Exh. R-4213; WTO, Guatemala􀊊Definitive Anti-Dumping Measures On Grey Portland Cement From
Mexico, Report of the Panel, 24 October 2000 ¶¶ 8.23–8.24, Exh. R-4214; WTO, Argentina􀊊Definitive Anti-
Dumping Duties On Poultry From Brazil, Report of the Panel, 22 April 2003 ¶ 7.39, Exh. R-4215; Pope & Talbot Inc.
v. The Government of Canada, UNCITRAL, Interim Award, 26 June 2000 ¶ 111, Exh. C-953.
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1323. Respondent submits that Claimants have failed to identify an unequivocal representation by
Respondent. In that regard, Respondent argues that Claimants’ reliance on Respondent’s
alleged failure to challenge illegalities earlier does not amount to an unequivocal
representation. Respondent also submits that Claimants have failed to establish that they
changed their conduct to their detriment in reliance on said representation. Particularly
regarding the alleged abuses of the Cyprus-Russia DTA, Respondent contends it raised its
objection to Hulley’s and VPL’s alleged violations in these arbitrations as early as October
2006, and thus, argues Respondent, “Claimants’ further suggestion that Respondent might be
estopped because it did not also raise these abuses ‘in an appropriate forum’ is absurd.”1733
1324. Respondent adds that informal or contra legem acceptance of an investment by the host State’s
authorities that is illegal under the host State’s domestic law, or based on covert arrangements
unknown to the host State, cannot provide a basis for estoppel. In support, Respondent relies
on the Fraport award.1734
1325. Finally, Respondent rejects Claimants proportionality argument, stating that it is based on
“rules governing countermeasures by an injured State in inter-State relations.”1735 In the words
of Respondent: “the legality requirement excludes illegal investments from the scope of ECT
protection. As a result it is not that a host State is not justified in breaching obligations with
respect to illegal investments, but instead that it has no treaty obligations in the first
instance.”1736
(b) Claimants’ Position
1326. Claimants object that their “unclean hands,” even if proven by Respondent, could have no
impact on their claims in these arbitrations because: (a) the ECT does not contain any principle
of “unclean hands”; (b) no principle of “unclean hands” has been recognized as a general
principle of law; and (c) the instances of “unclean hands” alleged by Respondent are “collateral
illegalities” that do not fall within the parameters of any “unclean hands” doctrine.
1327. Claimants assert that it is “impossible to find any textual basis in the [ECT] for the
1733 Ibid. ¶¶ 1593–95.
1734 Ibid. ¶ 1596, referring to Fraport ¶ 347.
1735 Ibid. ¶¶ 1584–7.
1736 Ibid. ¶ 1586.
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Respondent’s contention.”1737 They add that the introductory note to the ECT––a note which
Claimants contend is not an official document or interpretation of the ECT––confers an
obligation to strengthen the rule of law on States parties, rather than on the investor.1738
Claimants highlight that Respondent chose not to quote the remainder of the note, which goes
on to state that the ECT’s aim of strengthening the rule of law on energy issues is to be
accomplished “by creating a level playing field of rules to be observed by all participating
governments, thus minimising the risks associated with energy-related investments and
trade.”1739 In this regard, Claimants contend that denying a claimant access to a forum for
resolving its claims altogether would violate, rather than support, the rule of law.1740
1328. Claimants seek to distinguish the Phoenix and Hamester ICSID awards relied upon by
Respondent. Claimants highlight that the statement relied on by Respondent to infer that a
jurisdictional requirement of compliance with host State laws is implicit, even when not stated,
is obiter dictum on account of the BIT provisions being applied by those tribunals.1741
Similarly, Claimants submit that any reliance on the Plama award to insert a jurisdictional
requirement of “clean hands” into the relevant treaty is incorrect. Claimants submit that in the
Plama decision on jurisdiction, the tribunal considered and rejected an argument that the
illegality of the investment could affect its capacity to hear the dispute.1742
1329. Further, Claimants emphasize that the bar for recognition of general principles of international
law is set “extremely high”.1743 Claimants assert that Respondent’s “unclean hands” theory
fails to meet this high threshold.
1330. Claimants allege that neither the PCIJ nor the ICJ have ever endorsed “unclean hands” as a
general principle of law.1744 They also argue that the inter-state cases relied on by Respondent
are inapposite to this arbitration as they concern “situations in which two sovereign States have
1737 Reply ¶ 1029.
1738 Ibid. ¶ 1100.
1739 Ibid. ¶ 1101.
1740 Ibid. ¶ 1102.
1741 Ibid. ¶ 1098, referring to Phoenix ¶ 101, Exh. R-1078; Hamester ¶ 123–24, Exh. R-1079.
1742 Ibid. ¶ 1099, referring to Plama, Exh. C-994.
1743 Ibid. ¶ 1039.
1744 Ibid. ¶¶ 1040–55.
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assumed an identical or reciprocal obligation.”1745 Claimants further argue that the awards of
mixed claims commissions are of little guidance, as they deal mostly with diplomatic protection
and are of “ancient vintage.” In support, Claimants cite the Saba Fakes v. Turkey ICSID award,
in which the tribunal held that the “rules of customary international law applicable in the
context of diplomatic protection do not apply as such to investor-State arbitration.”1746
1331. Claimants note that the ILC Articles on State Responsibility and Articles on Diplomatic
Protection do not contain a principle of “unclean hands.”1747 They also argue that most scholars
reject the existence of an “unclean hands” general principle altogether, while its proponents
argue that it should be subject to certain well-defined limits.1748
1332. Claimants also submit that the investment tribunal awards relied on by Respondent in support
of a general principle of “unclean hands” were decided on other grounds and that Respondent’s
analysis of these awards is incomplete and misleading.1749 According to Claimants, in each of
the ICSID awards cited by Respondent––Plama, Phoenix, Hamester and Inceysa Vallisoletana,
S.L. v. Republic of El Salvador (“Inceysa”)––the tribunal’s decision rested on a clause in the
relevant BIT conditioning jurisdiction on compliance by the investor with the laws of the host
State.1750
1333. Furthermore, Claimants argue that even if Respondent can make the case for a general principle
of “unclean hands” or a legality requirement under the ECT, Respondent’s theory as applied to
this case rests on allegations of collateral illegalities unrelated to either the making of
1745 Ibid. ¶¶ 1040, 1055.
1746 Ibid. ¶¶ 1056–67, referring to Saba Fakes ¶ 69, Exh. C-1537.
1747 Ibid. ¶¶ 1068–71.
1748 Ibid. ¶¶ 1072–77. For scholars rejecting the principle, Claimants cite to: Jean Salmon, ed., DICTIONNAIRE DE DROIT
INTERNATIONAL PUBLIC, 2001, pp. 677–78, Exh. C-1613 ; Luis Garcia-Arias, La doctrine des «Clean Hands» en droit
international public, 1960, 30 Annuaire des anciens auditeurs de l’académie de droit 14, p. 18, Exh. R-1075; ILC,
Sixth report on diplomatic protection by John Dugard, Special Rapporteur, 57th Session, 2 May – 5 August 2005,
U.N. Doc. A/CN.4/546 ¶ 15, Exh. C-1678; Charles Rousseau, DROIT INTERNATIONAL PUBLIC, TOME V, LES RAPPORTS
CONFLICTUELS ¶ 170, Exh. C-1612. For proponents of the principle, with limits, Claimants cite to: Bin Cheng,
GENERAL PRINCIPLES OF LAW AS APPLIED BY INTERNATIONAL COURTS AND TRIBUNALS, pp. 157–58, Exh. R-1054; Sir
Gerald Fitzmaurice, The General Principles of International Law Considered From the Standpoint of the Rule of Law,
1957, 92 Collected Courses of the Hague Academy of International Law 1, p. 119, Exh. R-1053.
1749 Ibid. ¶ 1094.
1750 Ibid. ¶ 1094–1105, referring to Plama, Exh. C-994; Inceysa Vallisoletana, S.L. v. El Salvador, ICSID Case
No. ARB/03/26, Award, 2 August 2006, Exh. R-1083 (hereinafter “Inceysa”); Phoenix, Exh. R-1078; Hamester, Exh.
R-1079.
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Claimants’ investments or their claims in these arbitrations.1751
1334. Claimants submit that even when interpreting treaty provisions expressly requiring compliance
with host State laws as a condition of jurisdiction, investment tribunals have strictly construed
such provisions.1752 Claimants submit that investment tribunals have only subjected the initial
making of the investment to a legality test. They also assert that the limited temporal scope
employed by investment tribunals renders alleged pre-investment conduct irrelevant,1753 and
limits its substantive scope, e.g., by extending only to host State laws “governing the admission
of foreign investments in its territory.”1754 Claimants emphasize that misconduct unrelated to
the making of an investment, or which concerns minor violations, has been disregarded by
investment tribunals.1755
1335. Claimants also submit that Anglo-American jurisprudence confirms that alleged illegalities
must have an “immediate” and “necessary” relation to a claimant’s cause of action.1756
1336. It follows, argue Claimants, that none of Respondent’s allegations are covered by any principle
of “unclean hands”. The actions complained of by Respondent with respect to the acquisition
of Yukos pre-date Claimants’ investments, depriving the Tribunal of jurisdiction ratione
temporis over those actions.1757 The alleged abuses of the Cyprus-Russia DTA do not,
according to Claimants, have the required “immediate” or “necessary” relation to Claimants’
claims.1758 Claimants argue that to bar Hulley and VPL permanently from bringing claims
under the ECT for having claiming benefits under the Cyprus-Russia DTA to which they were
not entitled rests on an “impossibly broad interpretation” of the “unclean hands” concept.1759
1337. Claimants also point out that only the allegations of DTA abuses concern the conduct of
Claimants themselves, while the other 24 allegations concern the conduct of persons other than
Claimants. Claimants contend that Respondent provides no basis on which the conduct of these
1751 Ibid. ¶¶ 1134–38.
1752 Ibid. ¶ 1105.
1753 Ibid. ¶¶ 1106–12.
1754 Ibid. ¶¶ 1118–19.
1755 Ibid. ¶ 1120.
1756 Ibid. ¶¶ 1105, 1078, 1134.
1757 Ibid. ¶ 1135.
1758 Ibid. ¶ 1137.
1759 Ibid.
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third parties could render Claimants’ hands “unclean”.1760
1338. Claimants further assert that, even if any principle of “unclean hands” is potentially applicable
in the situation at hand, Respondent is estopped from raising matters in these arbitrations of
which it has long been aware, but has never challenged.1761 Claimants argue that acquiescence,
or the silence or absence of protest in circumstances which generally call for a positive reaction
signifying an objection, may “in and of itself” result in estoppel, where the other elements of
estoppel are not made out.1762
1339. In particular, Claimants reject Respondent’s allegations with respect to the creation and original
acquisition of Yukos in 1995. Claimants submit that it was Respondent that “planned,
organized, conducted and completed the privatization of the Russian Federation’s property
through the loans-for-shares program, including the privatization of Yukos.”1763 Similarly,
Claimants highlight that Respondent did not take legal action against Claimants for any of the
alleged violations of the Cyprus-Russia DTA by Hulley and VPL. Claimants underline that
Respondent must have had knowledge of many, if not all, of the alleged violations “as early as
October 2003, through the searches and seizures of documents at the Moscow premises of
GML MS, or at least as early as October 6, 2006 when the Respondent first raised the matter in
these arbitrations.”1764
1340. Claimants also submit that, even if an “unclean hands” general principle existed, it would not
confer upon States the right to violate investors’ rights.1765 Drawing an analogy to countermeasures,
Claimants refer to Articles 49 and 54 of the ILC Articles on State Responsibility and
to the ILC Commentary on the provisions, which states that such measures “are not intended as
a form of punishment for wrongful conduct, but as an instrument for achieving compliance with
the obligations of the responsible State.”1766
1341. The ILC Commentary further emphasizes that proportionality is a stand-alone requirement,
such that even where a counter-measure is carried out for a permissible purpose, it must still be
1760 Ibid. ¶ 1136.
1761 Ibid. ¶ 1181.
1762 Ibid. ¶ 1183.
1763 Ibid. ¶ 1188.
1764 Ibid. ¶ 1189.
1765 Ibid. ¶ 1191.
1766 Ibid. ¶ 1194.
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proportionate to the original breach.1767
1342. Claimants submit that the need to weigh the proportionality of Respondent’s response to the
illegalities it alleges against Claimants provides further reason for rejecting Respondent’s
“unclean hands” objection to jurisdiction/admissibility. In Claimants’ own words: “it is for the
tribunal to assess such allegations . . . in its consideration of the merits of the investor’s claims,
bearing in mind that any response by the host State to any alleged illegality must comport with
its international obligations.”1768
4. Tribunal’s Decision
1343. Article 26(6) of the ECT provides that “[a] tribunal established under paragraph (4) shall decide
the issues in dispute in accordance with this Treaty and applicable rules and principles of
international law.”
1344. Article 31 of the VCLT, which is widely recognized as reflecting customary international law,
provides in its first paragraph that “[a] treaty shall be interpreted in good faith in accordance
with the ordinary meaning to be given to the terms of the treaty in their context and in the light
of its object and purpose.”
1345. Looking first at the text of the ECT, the Tribunal observes that it does not contain any express
reference to a principle of “clean hands.” Nor, unlike some other investment treaties, does the
ECT contain an express requirement that investments be made in accordance with the laws of
the host country.1769 These points are not disputed by the Parties.
1346. In the absence of any specific textual hook, the Tribunal must consider whether, given the need
to interpret treaties in good faith and take account of their object and purpose, the ECT as a
whole may be understood as conditioning the protection of investments on their legality, or on
the good faith of the investor. The Tribunal addresses this question in subsection (a) below.
1767 Ibid. ¶ 1195.
1768 Ibid. ¶ 1197.
1769 See e.g. the bilateral investment treaties applied in Fraport, Exh. R-1006 (Germany–Philippines BIT: “[t]he term
investment shall mean any kind of asset accepted in accordance with the respective laws and regulations of either
Contracting State”); Inceysa, Exh. R-1083 (Spain–El Salvador BIT: “[e]ach Contracting Party shall protect in its
territory investments made, in accordance with its legislation”; “[the BIT shall] apply to investments made . . . in
accordance with the laws”); Phoenix, Exh. RE-1078 (Israel–Czech Republic BIT: “[t]he term ‘investment’ shall
comprise any kinds of asset invested . . . in accordance with the respective laws and regulations.”
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1347. In addition to any potential limitation on the protection of investments inherent in the ECT, a
principle of “clean hands” could be relevant to this arbitration pursuant to Article 26(6) of the
ECT if it were an “applicable rule[. . .] or principle[. . .] of international law.” The Parties
dispute whether “clean hands” exists as a “general principle of international law recognized by
civilized nations” in the meaning of Article 38(1)(c) of the Statute of the ICJ. The Tribunal
addresses this question in subsection (b) below.
1348. Finally, in subsection (c) below, the Tribunal considers whether any of the 28 instances of “bad
faith and illegal conduct” of which Respondent accuses Claimants fall within the scope of any
“unclean hands” or similar principle applicable in the ECT context.
(a) Can a Clean Hands Principle or Legality Requirement be Read into the ECT?
1349. The Tribunal notes that there is support in the decisions of tribunals in investment treaty
arbitrations for the notion that, even where the applicable investment treaty does not contain an
express requirement of compliance with host State laws (as is the case with the ECT), an
investment that is made in breach of the laws of the host State may either: (a) not qualify as an
investment, thus depriving the tribunal of jurisdiction; or (b) be refused the benefit of the
substantive protections of the investment treaty.
1350. The Plama tribunal, deciding a case under the ECT, thus stated that the “substantive protections
of the ECT cannot apply to investments made contrary to law.”1770 It acknowledged that the
ECT “does not contain a provision requiring the conformity of the Investment with a particular
law,” but stated that “[t]his does not mean . . . that the protections provided for by the ECT
cover all kinds of investments, including those contrary to domestic and international law.”1771
The tribunal explained that, in that case, granting the claimant protection would have “be[en]
contrary to the principle nemo auditor propriam turpitudinem allegans” and “the basic notion
of international public policy􀊊that a contract obtained by wrongful means (fraudulent
misrepresentation) should not be enforced by a tribunal.”1772
1351. Other arbitral tribunals have stated in obiter dicta that the principle that an investment “will not
be protected if it has been created in violation of national or international principles of good
1770 Plama, Exh. C-994 ¶ 139.
1771 Ibid. ¶ 138.
1772 Ibid. ¶ 143.
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faith” or “of the host State’s law” is a “general principle[. . . ] that exist[s] independently of
specific language” in an investment treaty.1773
1352. The Tribunal agrees with this proposition. In imposing obligations on States to treat investors
in a fair and transparent fashion, investment treaties seek to encourage legal and bona fide
investments. An investor who has obtained an investment in the host State only by acting in
bad faith or in violation of the laws of the host state, has brought itself within the scope of
application of the ECT through wrongful acts. Such an investor should not be allowed to
benefit from the Treaty.
1353. For reasons that will become apparent further in this chapter, the Tribunal does not need to
decide here whether the legality requirement it reads into the ECT operates as a bar to
jurisdiction or, as suggested in Plama, to deprive claimants of the substantive protections of the
ECT.
1354. However, the Tribunal does need to address Respondent’s contention that the right to invoke
the ECT must be denied to an investor not only in the case of illegality in the making of the
investment but also in its performance. The Tribunal finds Respondent’s contention
unpersuasive.
1355. There is no compelling reason to deny altogether the right to invoke the ECT to any investor
who has breached the law of the host State in the course of its investment. If the investor acts
illegally, the host state can request it to correct its behavior and impose upon it sanctions
available under domestic law, as the Russian Federation indeed purports to have done by
reassessing taxes and imposing fines. However, if the investor believes these sanctions to be
unjustified (as Claimants do in the present case), it must have the possibility of challenging
their validity in accordance with the applicable investment treaty. It would undermine the
purpose and object of the ECT to deny the investor the right to make its case before an arbitral
tribunal based on the same alleged violations the existence of which the investor seeks to
dispute on the merits.
1773 Hamester ¶¶ 123–24, Exh. R-1079. See also Phoenix ¶ 101, Exh. R-1078 (“it is the Tribunal’s view that this condition
– the conformity of the establishment of the investment with the national laws – is implicit even when not expressly
stated in the relevant BIT”); SAUR ¶ 308, Exh. R-4186 (“[the tribunal] is aware that the finality of the investment
arbitration system is to protect only lawful and bona fide investments. Whether or not the BIT between France and
Argentina mentions the requirement that the investor act in conformity with domestic legislation does not constitute a
relevant factor. The condition of not committing a serious violation of the legal order is a tacit condition, inherent to
any BIT as, in any event, it is incomprehensible that a State offer the benefit of protection through arbitration if the
investor, in order to obtain such protection, has acted contrary to the law.”)
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1356. Respondent has not been able to cite any apposite authority in support of its contention. The
statements of investment tribunals it relies on were all made obiter and are too vague to allow
any certain conclusions to be drawn as to their intended meaning. For example, the statement
in Fraport that illegal acts in the course of an investment “might be a defense to claimed
substantive violations” appears to suggest that, in some cases, the State’s actions will have been
justified as an appropriate response to the investor’s violations of national law.1774 As is clear
from the decision, the statement by the Fraport tribunal does not imply the unavailability of the
substantive protections of the treaty, but rather concludes that the respondent State has not
incurred any liability under the treaty.
(b) Does the “Clean Hands” Doctrine Constitute a “General Principle of Law
Recognized by Civilized Nations”?
1357. Since the Tribunal will not read into the ECT any legality requirement with respect to the
conduct of the investment, it must consider Respondent’s more general proposition that a
claimant who comes before an international tribunal with “unclean hands” is barred from
claiming on the basis of a “general principle of law.”
1358. The Tribunal is not persuaded that there exists a “general principle of law recognized by
civilized nations” within the meaning of Article 38(1)(c) of the ICJ Statute that would bar an
investor from making a claim before an arbitral tribunal under an investment treaty because it
has so-called “unclean hands.”
1359. General principles of law require a certain level of recognition and consensus. However, on the
basis of the cases cited by the Parties, the Tribunal has formed the view that there is a
significant amount of controversy as to the existence of an “unclean hands” principle in
international law.
1360. Respondent has demonstrated that certain principles associated with the “clean hands” doctrine,
such as exceptio non adimpleti contractus and ex iniuria ius non oritur have been endorsed by
the PCIJ and the ICJ.1775 However, the Tribunal notes that Judge Simma in his separate opinion
1774 Fraport, Exh. R-1006 ¶¶ 395, 345. The Tribunal notes that the Chairman, Mr. Fortier, was the Chairman of the
Fraport tribunal.
1775 See The Diversion of Water from the Meuse (Netherlands v. Belgium), Judgment, 28 June 1937, Individual Opinion of
Judge Hudson, PCIJ Series A/B No. 70, p. 73, 77, Exh. C-1502 (“[i]t would seem to be an important principle of
equity that where two parties have assumed an identical or reciprocal obligation, one party which is engaged in
continuing non-performance of that obligation should not be permitted to take advantage of a similar non-performance
of that obligation by the other party”); Gab􀃾íkovo-Nagymaros, ¶ 133 Exh. C-948 (“[t]he Court, however, cannot
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in the Application of the Interim Accord of 13 December 1995 raises doubt as to the continuing
existence of the exceptio non adimpleti contractus principle.1776
1361. With regard to the “unclean hands” doctrine proper, Respondent has referred to the dissenting
opinion of Judge Schwebel (a member of this Tribunal) in the Military and Paramilitary
Activities in and against Nicaragua ICJ case, where he concluded that Nicaragua’s claims
against the United States should fail because Nicaragua had “not come to Court with clean
hands.”1777 Respondent also referred to other dissenting ICJ and PCIJ opinions where the
principle of “unclean hands” was invoked (albeit often without referring to it by name).1778
1362. However, as Claimants point out, despite what appears to have been an extensive review of
jurisprudence, Respondent has been unable to cite a single majority decision where an
international court or arbitral tribunal has applied the principle of “unclean hands” in an inter-
State or investor-State dispute and concluded that, as a principle of international law, it
operated as a bar to a claim.
1363. The Tribunal therefore concludes that “unclean hands” does not exist as a general principle of
international law which would bar a claim by an investor, such as Claimants in this case.
disregard the fact that the Treaty has not been fully implemented by either party for years, and indeed that their acts of
commission and omission have contributed to creating the factual situation that now exists. Nor can it overlook that
factual situation . . . when deciding on the legal requirements for the future conduct of the Parties. This does not mean
that facts––in this case, facts which flow from wrongful conduct––determine the law. The principle ex injuria jus non
oritur is sustained by the Court’s finding that the legal relationship created by the 1977 Treaty is preserved and cannot
in this case be treated as voided by unlawful conduct.”)
1776 Application of the Interim Accord of 13 December 1995 (the Former Yugoslav Republic of Macedonia v. Greece),
Judgment, 5 December 2011, Separate Opinion of Judge Simma, ICJ Reports 2011, p. 695 ¶¶ 19–20, Exh. C-1545.
1777 Case Concerning Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of
America), Merits, Judgment, 27 June 1986, Dissenting Opinion of Judge Schwebel, ICJ Reports 1986, p. 259 ¶ 268,
Exh. R-1071.
1778 Legal Status of Eastern Greenland (Denmark v. Norway), Judgment, 5 April 1933, Dissenting Opinion of Judge
Anzilotti, PCIJ Series A/B No. 53, p. 76, 95, Exh. R-1073; Interpretation of Peace Treaties with Bulgaria, Hungary
and Romania (Second Phase), Advisory Opinion, 18 July 1950, Dissenting Opinion of Judge Read, ICJ Reports 1950,
p. 231, 244, Exh. R-1074; Case Concerning United States Diplomatic and Consular Staff in Tehran (United States of
America v. Iran), Judgment, 24 May 1980, Dissenting Opinion of Judge Morozov, ICJ Reports 1980, p. 51 ¶ 3, Exh.
R-1087; Case Concerning Arrest Warrant of 11 April 2000 (Democratic Republic of the Congo v. Belgium),
Judgment, 14 February 2002, Dissenting Opinion of Judge van den Wyngaert, ICJ Reports 2002, p. 137 ¶ 84, Exh. R-
1072 (“The Congo did not come to the Court with clean hands”).
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(c) Would any Instances of Claimants’ Alleged “Bad Faith and Illegal” Conduct
be Caught by a Legality Requirement Read into the ECT?
1364. To summarize, the Tribunal accepts that a claimant may be barred from seeking relief under the
ECT if its investment was made in bad faith or in violation of the laws of the host state.
1365. It follows that the alleged instances of “unclean hands” listed in Subsections IX.B.2(b), (c) and
(d) above––specifically, the instances related to the alleged abuse of the Russia–Cyprus DTA,
the tax optimization scheme and the obstruction of Russia’s enforcement of tax claims against
Yukos, all of which relate to actions that were taken after the making of Claimants’ investment,
cannot have any impact on the availability of ECT protection for Claimants.
1366. This leaves for the Tribunal’s consideration Respondent’s allegations of bad faith and illegal
conduct in the acquisition of Yukos and the subsequent consolidation of control and ownership
over Yukos and its subsidiaries, set out in Subsection IX.B.2(a) above.
1367. It is common ground between the Parties that these actions were taken before Claimants
became shareholders of Yukos in 1999, 2000 and 2001 and, consequently, were not taken by
Claimants themselves, but by other actors, such as Bank Menatep and the Oligarchs.1779
Claimants submit that these actions are thus irrelevant to these arbitrations, as the conduct
complained of was not that of Claimants’ themselves and, in any event, pre-dates Claimants’
investment.1780
1368. Respondent replies that, on the contrary, the process of the acquisition of the Yukos shares by
Claimants should not be seen in isolation but as an integral part of the “making of the
investment” by Claimants. Respondent’s argument was most convincingly put by Dr. Claudia
Annacker during the Hearing. Dr. Annacker argued as follows:
Contrary to Claimants’ position, the serious illegalities that infect the entire process of the
acquisition of the Yukos shares by Claimants cannot simply be ignored because the
transfer of the shares to the Claimants . . . viewed in isolation, is asserted to be legal. These
illegalities cannot somehow be cured through multiple transfers within this network of the
oligarchs’ offshore companies from one shell company to another.
Indeed, the making of an investment is often a process rather than an instantaneous act, and
often comprises a number of diverse transactions. These transactions must be treated as an
1779 See Counter-Memorial ¶¶ 910–13, explaining the alleged illegal conduct of Bank Menatep and the Oligarchs in the
acquisition of Yukos shares by the Oligarchs in 1995 and 1996.
1780 See Reply ¶¶ 1135–36.
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integrated whole. The transactions may have a separate legal existence, but they have a
common economic aim . . .
Indeed, it would be incompatible with economic reality and undermine the integrity of the
legal process if serious irregularities – illegalities – infecting the process of the making of
the investment would not affect the availability of investment treaty protection, whether or
not a specific transaction, part of the process, if viewed in isolation, might be legal.
Now, this conclusion applies a fortiori where a claimant is not unrelated to the persons or
entities that committed these illegalities, but is an investment vehicle owned and controlled
by the same persons who committed the illegalities . . . Otherwise, investment treaty
protection could be achieved simply by shifting investments through layers of ownership
and control to launder illegal investments . . .
While Claimants’ acquisition of their shares may be a separate legal transaction, there is a
common economic aim pursued by the same oligarchs . . .1781
1369. The Tribunal agrees with Respondent that an examination of the legality of an investment
should not be limited to verifying whether the last in a series of transactions leading up to the
investment was in conformity with the law. The making of the investment will often consist of
several consecutive acts and all of these must be legal and bona fide.
1370. In the present case, however, Respondent has failed to demonstrate that the alleged illegalities
to which it refers are sufficiently connected with the final transaction by which the investment
was made by Claimants. The transactions by which each Claimant acquired its investment
were their purchases of Yukos shares. As established in the Interim Award, these purchases
were legal and occurred starting in 1999.1782 On the other hand, the alleged illegalities
connected to the acquisition of Yukos through the loans-for-shares program occurred in 1995
and 1996, at the time of Yukos’ privatization. They involved Bank Menatep and the Oligarchs,
an entity and persons separate from Claimants, one of which––Veteran––had not even come
into existence.1783 With respect to Respondent’s other allegations, regarding profit skimming
and the oppression of minority shareholders, it is also clear to the Tribunal that they are not part
of the transaction or transactions by which each Claimant acquired their interest in Yukos.
1371. Respondent relies on Anderson for the proposition that “illegalities infecting an investment that
pre-date a claimant’s acquisition of the investment are not irrelevant or outside the tribunal’s
jurisdiction ratione temporis.”1784 However, the tribunal in that case examined and found to be
1781 Transcript, Day 19 at 171–174 (Respondent’s closing).
1782 Interim Awards ¶¶ 431 (YUL); 430 (Hulley); 474 (VPL).
1783 VPL was incorporated in 2001 (Interim Award ¶ 44 (VPL).
1784 Rejoinder ¶ 1571, referring to Anderson, Exh. R-4204.
Annex 81
- 435 -
illegal the very transaction through which the claimants obtained their investment, not any prior
transactions made by other persons. 1785
1372. While it is true that the claimants in Anderson were not blamed for the illegality that tainted
their investment, nevertheless it is the very transaction by which their respective investments
were obtained that was considered illegal by the tribunal, and led it to decline jurisdiction.
(d) Conclusion
1373. The Tribunal concludes that Respondent’s “unclean hands” argument fails as a preliminary
objection. It does not operate to deprive the Tribunal of its jurisdiction in this arbitration,
render inadmissible any of the Claimants’ claims or otherwise bar Claimants’ from invoking
the substantive protections of the ECT.
1374. However, as will be seen in Chapter X.E and Part XII, some of the instances of Claimants’
“illegal and bad faith” conduct complained of by Respondent in the context of this preliminary
objection, could have an impact on the Tribunal’s assessment of liability and damages.
C. RESPONDENT’S OBJECTIONS UNDER ARTICLE 21 OF THE ECT
1. Introduction
1375. Another important threshold issue in this arbitration arises from Respondent’s objection under
Article 21 of the ECT. Respondent argues that, pursuant to this complex provision (containing
a “carve out” from the ECT for “Taxation Measures” at Article 21(1) and a “claw back” for
Article 13 of the ECT in relation to “taxes” at Article 21(5)), the Tribunal lacks jurisdiction
over claims with respect to “Taxation Measures” other than those based on expropriatory
“taxes”.1786 Claimants argue that the objection is without merit since, inter alia, Article 21 does
not apply to actions—including expropriations—carried out “under the guise of taxation.”1787
1785 Ibid.
1786 See e.g., Respondent’s Post-Hearing Brief ¶¶ 162–72.
1787 See e.g., Claimants’ Post-Hearing Brief ¶¶ 203–30.
Annex 81

ANNEX 82

Annex 82
Annex 82
Annex 82
Annex 82
Annex 82

ANNEX 83

Annex 83
Annex 83
Annex 83
Annex 83
ANNEX 84

Annex 84
Annex 84
Annex 84
Annex 84
Annex 84
Annex 84
Annex 84

ANNEX 85

􀀔􀀃
􀀨􀁑􀁊􀁏􀁌􀁖􀁋􀀃 􀁌􀁖􀀃 􀁑􀁒􀁗􀀃 􀁄􀁑􀀃 􀁒􀁉􀁉􀁌􀁆􀁌􀁄􀁏􀀃 􀁏􀁄􀁑􀁊􀁘􀁄􀁊􀁈􀀃 􀁒􀁉􀀃 􀁗􀁋􀁈􀀃 􀀶􀁚􀁌􀁖􀁖􀀃 􀀦􀁒􀁑􀁉􀁈􀁇􀁈􀁕􀁄􀁗􀁌􀁒􀁑􀀑􀀃 􀀷􀁋􀁌􀁖􀀃 􀁗􀁕􀁄􀁑􀁖􀁏􀁄􀁗􀁌􀁒􀁑􀀃 􀁌􀁖􀀃
􀁓􀁕􀁒􀁙􀁌􀁇􀁈􀁇􀀃􀁉􀁒􀁕􀀃􀁌􀁑􀁉􀁒􀁕􀁐􀁄􀁗􀁌􀁒􀁑􀀃􀁓􀁘􀁕􀁓􀁒􀁖􀁈􀁖􀀃􀁒􀁑􀁏􀁜􀀃􀁄􀁑􀁇􀀃􀁋􀁄􀁖􀀃􀁑􀁒􀀃􀁏􀁈􀁊􀁄􀁏􀀃􀁉􀁒􀁕􀁆􀁈􀀑􀀃
􀀩􀁈􀁇􀁈􀁕􀁄􀁏􀀃􀀤􀁆􀁗􀀃􀀃
􀁒􀁑􀀃􀁗􀁋􀁈􀀃􀀤􀁐􀁈􀁑􀁇􀁐􀁈􀁑􀁗􀀃􀁒􀁉􀀃􀁗􀁋􀁈􀀃􀀶􀁚􀁌􀁖􀁖􀀃􀀦􀁌􀁙􀁌􀁏􀀃􀀦􀁒􀁇􀁈􀀃
􀀋􀀳􀁄􀁕􀁗􀀃􀀩􀁌􀁙􀁈􀀝􀀃􀀷􀁋􀁈􀀃􀀦􀁒􀁇􀁈􀀃􀁒􀁉􀀃􀀲􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀁖􀀌􀀃 􀀃􀁒􀁉􀀃􀀖􀀓􀀃􀀰􀁄􀁕􀁆􀁋􀀃􀀔􀀜􀀔􀀔􀀃􀀋􀀶􀁗􀁄􀁗􀁘􀁖􀀃􀁄􀁖􀀃􀁒􀁉􀀃􀀔􀀃􀀤􀁓􀁕􀁌􀁏􀀃􀀕􀀓􀀔􀀚􀀌􀀃
􀀷􀁋􀁈􀀃􀀩􀁈􀁇􀁈􀁕􀁄􀁏􀀃􀀤􀁖􀁖􀁈􀁐􀁅􀁏􀁜􀀃􀁒􀁉􀀃􀁗􀁋􀁈􀀃􀀶􀁚􀁌􀁖􀁖􀀃􀀦􀁒􀁑􀁉􀁈􀁇􀁈􀁕􀁄􀁗􀁌􀁒􀁑􀀏􀀃
􀁋􀁄􀁙􀁌􀁑􀁊􀀃􀁆􀁒􀁑􀁖􀁌􀁇􀁈􀁕􀁈􀁇􀀃􀁗􀁋􀁈􀀃􀀧􀁌􀁖􀁓􀁄􀁗􀁆􀁋􀁈􀁖􀀃􀁒􀁉􀀃􀁗􀁋􀁈􀀃􀀩􀁈􀁇􀁈􀁕􀁄􀁏􀀃􀀦􀁒􀁘􀁑􀁆􀁌􀁏􀀃􀁇􀁄􀁗􀁈􀁇􀀃􀀖􀀃􀀰􀁄􀁕􀁆􀁋􀀃􀀔􀀜􀀓􀀘􀀃􀁄􀁑􀁇􀀃
􀀔􀀃􀀭􀁘􀁑􀁈􀀃􀀔􀀜􀀓􀀜􀀔􀀃
􀁇􀁈􀁆􀁕􀁈􀁈􀁖􀀝􀀃
􀀧􀁌􀁙􀁌􀁖􀁌􀁒􀁑􀀃􀀲􀁑􀁈􀀝􀀃􀀪􀁈􀁑􀁈􀁕􀁄􀁏􀀃􀀳􀁕􀁒􀁙􀁌􀁖􀁌􀁒􀁑􀁖􀀃
􀀷􀁌􀁗􀁏􀁈􀀃􀀲􀁑􀁈􀀝􀀃􀀦􀁕􀁈􀁄􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀀲􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀁖􀀃
􀀶􀁈􀁆􀁗􀁌􀁒􀁑􀀃􀀲􀁑􀁈􀀝􀀃􀀲􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀁖􀀃􀁄􀁕􀁌􀁖􀁌􀁑􀁊􀀃􀁅􀁜􀀃􀀦􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀀃
􀀤􀁕􀁗􀀑􀀃􀀔􀀃
􀀔􀀃􀀷􀁋􀁈􀀃 􀁆􀁒􀁑􀁆􀁏􀁘􀁖􀁌􀁒􀁑􀀃 􀁒􀁉􀀃 􀁄􀀃 􀁆􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀀃 􀁕􀁈􀁔􀁘􀁌􀁕􀁈􀁖􀀃 􀁄􀀃 􀁐􀁘􀁗􀁘􀁄􀁏􀀃 􀁈􀁛􀁓􀁕􀁈􀁖􀁖􀁌􀁒􀁑􀀃 􀁒􀁉􀀃 􀁌􀁑􀁗􀁈􀁑􀁗􀀃
􀁅􀁜􀀃􀁗􀁋􀁈􀀃􀁓􀁄􀁕􀁗􀁌􀁈􀁖􀀑􀀃
􀀕􀀃􀀷􀁋􀁈􀀃􀁈􀁛􀁓􀁕􀁈􀁖􀁖􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁌􀁑􀁗􀁈􀁑􀁗􀀃􀁐􀁄􀁜􀀃􀁅􀁈􀀃􀁈􀁛􀁓􀁕􀁈􀁖􀁖􀀃􀁒􀁕􀀃􀁌􀁐􀁓􀁏􀁌􀁈􀁇􀀑􀀃 􀀃􀀃􀀤􀁕􀁗􀀑􀀃􀀕􀀃
􀀔􀀃􀀺􀁋􀁈􀁕􀁈􀀃 􀁗􀁋􀁈􀀃 􀁓􀁄􀁕􀁗􀁌􀁈􀁖􀀃 􀁋􀁄􀁙􀁈􀀃 􀁄􀁊􀁕􀁈􀁈􀁇􀀃 􀁒􀁑􀀃 􀁄􀁏􀁏􀀃 􀁗􀁋􀁈􀀃 􀁈􀁖􀁖􀁈􀁑􀁗􀁌􀁄􀁏􀀃 􀁗􀁈􀁕􀁐􀁖􀀏􀀃 􀁌􀁗􀀃 􀁌􀁖􀀃 􀁓􀁕􀁈􀀐
􀁖􀁘􀁐􀁈􀁇􀀃 􀁗􀁋􀁄􀁗􀀃 􀁗􀁋􀁈􀀃 􀁆􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀀃 􀁚􀁌􀁏􀁏􀀃􀁅􀁈􀀃􀁅􀁌􀁑􀁇􀁌􀁑􀁊􀀃 􀁑􀁒􀁗􀁚􀁌􀁗􀁋􀁖􀁗􀁄􀁑􀁇􀁌􀁑􀁊􀀃 􀁄􀁑􀁜􀀃 􀁕􀁈􀁖􀁈􀁕􀁙􀁄􀀐
􀁗􀁌􀁒􀁑􀀃􀁒􀁑􀀃􀁖􀁈􀁆􀁒􀁑􀁇􀁄􀁕􀁜􀀃􀁗􀁈􀁕􀁐􀁖􀀑􀀃
􀀕􀀃􀀬􀁑􀀃􀁗􀁋􀁈􀀃􀁈􀁙􀁈􀁑􀁗􀀃􀁒􀁉􀀃􀁉􀁄􀁌􀁏􀁘􀁕􀁈􀀃􀁗􀁒􀀃􀁕􀁈􀁄􀁆􀁋􀀃􀁄􀁊􀁕􀁈􀁈􀁐􀁈􀁑􀁗􀀃􀁒􀁑􀀃􀁖􀁘􀁆􀁋􀀃􀁖􀁈􀁆􀁒􀁑􀁇􀁄􀁕􀁜􀀃􀁗􀁈􀁕􀁐􀁖􀀏􀀃
􀁗􀁋􀁈􀀃 􀁆􀁒􀁘􀁕􀁗􀀃 􀁐􀁘􀁖􀁗􀀃 􀁇􀁈􀁗􀁈􀁕􀁐􀁌􀁑􀁈􀀃 􀁗􀁋􀁈􀁐􀀃 􀁚􀁌􀁗􀁋􀀃 􀁇􀁘􀁈􀀃 􀁕􀁈􀁊􀁄􀁕􀁇􀀃 􀁗􀁒􀀃 􀁗􀁋􀁈􀀃 􀁑􀁄􀁗􀁘􀁕􀁈􀀃 􀁒􀁉􀀃 􀁗􀁋􀁈􀀃
􀁗􀁕􀁄􀁑􀁖􀁄􀁆􀁗􀁌􀁒􀁑􀀑􀀃
􀀖􀀃􀀷􀁋􀁈􀀃 􀁉􀁒􀁕􀁈􀁊􀁒􀁌􀁑􀁊􀀃 􀁌􀁖􀀃 􀁖􀁘􀁅􀁍􀁈􀁆􀁗􀀃 􀁗􀁒􀀃 􀁗􀁋􀁈􀀃 􀁓􀁕􀁒􀁙􀁌􀁖􀁌􀁒􀁑􀁖􀀃 􀁊􀁒􀁙􀁈􀁕􀁑􀁌􀁑􀁊􀀃 􀁗􀁋􀁈􀀃 􀁉􀁒􀁕􀁐􀀃 􀁒􀁉􀀃
􀁆􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀁖􀀑􀀃
􀀃􀀤􀀶􀀃􀀕􀀚􀀃􀀖􀀔􀀚􀀃􀁄􀁑􀁇􀀃􀀥􀀶􀀃􀀕􀀃􀀔􀀜􀀜􀀃
􀀔􀀃 􀀥􀀥􀁏􀀃􀀔􀀜􀀓􀀘􀀃􀀬􀀬􀀃􀀔􀀏􀀃􀀔􀀜􀀓􀀜􀀃􀀬􀀬􀀬􀀃􀀚􀀗􀀚􀀏􀀃􀀔􀀜􀀔􀀔􀀃􀀬􀀃􀀙􀀜􀀘􀀃
􀀕􀀕􀀓
􀀤􀀑􀀃􀀦􀁒􀁑􀁆􀁏􀁘􀁖􀁌􀁒􀁑􀀃􀁒􀁉􀀃
􀁗􀁋􀁈􀀃􀁆􀁒􀁑􀁗􀁕􀁄􀁆􀁗􀀃
􀀬􀀑􀀃􀀰􀁘􀁗􀁘􀁄􀁏􀀃
􀁈􀁛􀁓􀁕􀁈􀁖􀁖􀁌􀁒􀁑􀀃􀁒􀁉􀀃
􀁌􀁑􀁗􀁈􀁑􀁗􀀃
􀀔􀀑 􀀬􀁑􀀃􀁊􀁈􀁑􀁈􀁕􀁄􀁏
􀀕􀀑􀀃􀀶􀁈􀁆􀁒􀁑􀁇􀁄􀁕􀁜􀀃
􀁗􀁈􀁕􀁐􀁖
Annex 85
􀀦􀁒􀁇􀁈􀀃􀁒􀁉􀀃􀀲􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀁖􀀃
􀀔􀀛􀀃
􀀕􀀕􀀓
􀀤􀁕􀁗􀀑􀀃􀀙􀀖􀀃
􀀔􀀃􀀤􀀃􀁓􀁈􀁕􀁖􀁒􀁑􀀃􀁚􀁋􀁒􀀃􀁋􀁄􀁖􀀃􀁙􀁒􀁏􀁘􀁑􀁗􀁄􀁕􀁌􀁏􀁜􀀃􀁖􀁄􀁗􀁌􀁖􀁉􀁌􀁈􀁇􀀃􀁄􀀃􀁑􀁒􀁑􀀐􀁈􀁛􀁌􀁖􀁗􀁈􀁑􀁗􀀃􀁇􀁈􀁅􀁗􀀃􀁋􀁄􀁖􀀃􀁄􀀃􀁕􀁌􀁊􀁋􀁗􀀃
􀁗􀁒􀀃􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁗􀁋􀁈􀀃􀁖􀁘􀁐􀀃􀁓􀁄􀁌􀁇􀀃􀁒􀁑􀁏􀁜􀀃􀁌􀁉􀀃􀁋􀁈􀀃􀁆􀁄􀁑􀀃􀁓􀁕􀁒􀁙􀁈􀀃􀁗􀁋􀁄􀁗􀀃􀁋􀁈􀀃􀁓􀁄􀁌􀁇􀀃􀁌􀁗􀀃􀁌􀁑􀀃􀁗􀁋􀁈􀀃
􀁈􀁕􀁕􀁒􀁑􀁈􀁒􀁘􀁖􀀃􀁅􀁈􀁏􀁌􀁈􀁉􀀃􀁗􀁋􀁄􀁗􀀃􀁗􀁋􀁈􀀃􀁇􀁈􀁅􀁗􀀃􀁚􀁄􀁖􀀃􀁒􀁚􀁈􀁇􀀑􀀃
􀀕􀀃􀀵􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁌􀁖􀀃􀁈􀁛􀁆􀁏􀁘􀁇􀁈􀁇􀀃􀁚􀁋􀁈􀁕􀁈􀀃􀁓􀁄􀁜􀁐􀁈􀁑􀁗􀀃􀁚􀁄􀁖􀀃􀁐􀁄􀁇􀁈􀀃􀁌􀁑􀀃􀁖􀁄􀁗􀁌􀁖􀁉􀁄􀁆􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁄􀀃
􀁇􀁈􀁅􀁗􀀃􀁗􀁋􀁄􀁗􀀃􀁋􀁄􀁖􀀃􀁅􀁈􀁆􀁒􀁐􀁈􀀃􀁗􀁌􀁐􀁈􀀐􀁅􀁄􀁕􀁕􀁈􀁇􀀃􀁒􀁕􀀃􀁒􀁉􀀃􀁄􀀃􀁐􀁒􀁕􀁄􀁏􀀃􀁒􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀀑􀀃
􀀖􀀃􀀷􀁋􀁈􀀃 􀁓􀁕􀁒􀁙􀁌􀁖􀁌􀁒􀁑􀁖􀀃 􀁒􀁉􀀃 􀁉􀁈􀁇􀁈􀁕􀁄􀁏􀀃 􀁇􀁈􀁅􀁗􀀃 􀁆􀁒􀁏􀁏􀁈􀁆􀁗􀁌􀁒􀁑􀀃 􀁄􀁑􀁇􀀃 􀁅􀁄􀁑􀁎􀁕􀁘􀁓􀁗􀁆􀁜􀀃 􀁏􀁄􀁚􀀃 􀁊􀁒􀁙􀀐
􀁈􀁕􀁑􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁕􀁌􀁊􀁋􀁗􀀃􀁗􀁒􀀃􀁗􀁋􀁈􀀃􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁓􀁄􀁜􀁐􀁈􀁑􀁗􀁖􀀃 􀁐􀁄􀁇􀁈􀀃􀁌􀁑􀀃􀁖􀁄􀁗􀁌􀁖􀁉􀁄􀁆􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃
􀁑􀁒􀁑􀀐􀁈􀁛􀁌􀁖􀁗􀁈􀁑􀁗􀀃􀁆􀁏􀁄􀁌􀁐􀁖􀀃􀁄􀁕􀁈􀀃􀁘􀁑􀁄􀁉􀁉􀁈􀁆􀁗􀁈􀁇􀀑􀀃
􀀤􀁕􀁗􀀑􀀃􀀙􀀗􀀃
􀀷􀁋􀁈􀁕􀁈􀀃􀁌􀁖􀀃􀁑􀁒􀀃􀁕􀁌􀁊􀁋􀁗􀀃􀁒􀁉􀀃􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁚􀁋􀁈􀁕􀁈􀀃􀁗􀁋􀁈􀀃􀁕􀁈􀁆􀁌􀁓􀁌􀁈􀁑􀁗􀀃􀁆􀁄􀁑􀀃􀁖􀁋􀁒􀁚􀀃􀁗􀁋􀁄􀁗􀀃􀁋􀁈􀀃􀁌􀁖􀀃
􀁑􀁒􀀃 􀁏􀁒􀁑􀁊􀁈􀁕􀀃 􀁈􀁑􀁕􀁌􀁆􀁋􀁈􀁇􀀃 􀁄􀁗􀀃 􀁗􀁋􀁈􀀃 􀁗􀁌􀁐􀁈􀀃 􀁗􀁋􀁈􀀃 􀁆􀁏􀁄􀁌􀁐􀀃 􀁉􀁒􀁕􀀃 􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃 􀁌􀁖􀀃 􀁅􀁕􀁒􀁘􀁊􀁋􀁗􀀏􀀃
􀁘􀁑􀁏􀁈􀁖􀁖􀀃 􀁋􀁈􀀃 􀁄􀁏􀁌􀁈􀁑􀁄􀁗􀁈􀁇􀀃 􀁗􀁋􀁈􀀃 􀁐􀁒􀁑􀁈􀁜􀀃 􀁅􀁈􀁑􀁈􀁉􀁌􀁗􀁖􀀃 􀁌􀁑􀀃 􀁅􀁄􀁇􀀃 􀁉􀁄􀁌􀁗􀁋􀀃 􀁒􀁕􀀃 􀁌􀁑􀀃 􀁗􀁋􀁈􀀃 􀁆􀁈􀁕􀁗􀁄􀁌􀁑􀀃
􀁎􀁑􀁒􀁚􀁏􀁈􀁇􀁊􀁈􀀃􀁗􀁋􀁄􀁗􀀃􀁋􀁈􀀃􀁚􀁒􀁘􀁏􀁇􀀃􀁅􀁈􀀃􀁅􀁒􀁘􀁑􀁇􀀃􀁗􀁒􀀃􀁕􀁈􀁗􀁘􀁕􀁑􀀃􀁗􀁋􀁈􀁐􀀑􀀃
􀀤􀁕􀁗􀀑􀀃􀀙􀀘􀀃
􀀔􀀃􀀷􀁋􀁈􀀃 􀁕􀁈􀁆􀁌􀁓􀁌􀁈􀁑􀁗􀀃 􀁌􀁖􀀃 􀁈􀁑􀁗􀁌􀁗􀁏􀁈􀁇􀀃 􀁗􀁒􀀃 􀁕􀁈􀁌􀁐􀁅􀁘􀁕􀁖􀁈􀁐􀁈􀁑􀁗􀀃 􀁒􀁉􀀃 􀁑􀁈􀁆􀁈􀁖􀁖􀁄􀁕􀁜􀀃 􀁄􀁑􀁇􀀃 􀁘􀁖􀁈􀁉􀁘􀁏􀀃
􀁈􀁛􀁓􀁈􀁑􀁇􀁌􀁗􀁘􀁕􀁈􀁖􀀏􀀃 􀁄􀁏􀁗􀁋􀁒􀁘􀁊􀁋􀀃 􀁚􀁋􀁈􀁕􀁈􀀃 􀁗􀁋􀁈􀀃 􀁘􀁑􀁍􀁘􀁖􀁗􀀃 􀁈􀁑􀁕􀁌􀁆􀁋􀁐􀁈􀁑􀁗􀀃 􀁚􀁄􀁖􀀃 􀁕􀁈􀁆􀁈􀁌􀁙􀁈􀁇􀀃 􀁌􀁑􀀃
􀁅􀁄􀁇􀀃 􀁉􀁄􀁌􀁗􀁋􀀏􀀃 􀁗􀁋􀁈􀀃 􀁕􀁈􀁌􀁐􀁅􀁘􀁕􀁖􀁈􀁐􀁈􀁑􀁗􀀃 􀁒􀁉􀀃 􀁘􀁖􀁈􀁉􀁘􀁏􀀃 􀁈􀁛􀁓􀁈􀁑􀁇􀁌􀁗􀁘􀁕􀁈􀁖􀀃 􀁐􀁘􀁖􀁗􀀃 􀁑􀁒􀁗􀀃 􀁈􀁛􀁆􀁈􀁈􀁇􀀃
􀁗􀁋􀁈􀀃􀁄􀁐􀁒􀁘􀁑􀁗􀀃􀁒􀁉􀀃􀁄􀁇􀁇􀁈􀁇􀀃􀁙􀁄􀁏􀁘􀁈􀀃􀁄􀁖􀀃􀁄􀁗􀀃􀁗􀁋􀁈􀀃􀁗􀁌􀁐􀁈􀀃􀁒􀁉􀀃􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀑􀀃
􀀕􀀃􀀫􀁈􀀃 􀁌􀁖􀀃 􀁑􀁒􀁗􀀃 􀁈􀁑􀁗􀁌􀁗􀁏􀁈􀁇􀀃 􀁗􀁒􀀃 􀁄􀁑􀁜􀀃 􀁆􀁒􀁐􀁓􀁈􀁑􀁖􀁄􀁗􀁌􀁒􀁑􀀃 􀁉􀁒􀁕􀀃 􀁒􀁗􀁋􀁈􀁕􀀃 􀁈􀁛􀁓􀁈􀁑􀁇􀁌􀁗􀁘􀁕􀁈􀁖􀀏􀀃 􀁅􀁘􀁗􀀃
􀁚􀁋􀁈􀁕􀁈􀀃􀁑􀁒􀀃􀁖􀁘􀁆􀁋􀀃􀁆􀁒􀁐􀁓􀁈􀁑􀁖􀁄􀁗􀁌􀁒􀁑􀀃􀁌􀁖􀀃􀁒􀁉􀁉􀁈􀁕􀁈􀁇􀀃􀁗􀁒􀀃􀁋􀁌􀁐􀀏􀀃􀁋􀁈􀀃􀁐􀁄􀁜􀀏􀀃􀁅􀁈􀁉􀁒􀁕􀁈􀀃􀁕􀁈􀁗􀁘􀁕􀁑􀀐
􀁌􀁑􀁊􀀃􀁗􀁋􀁈􀀃􀁓􀁕􀁒􀁓􀁈􀁕􀁗􀁜􀀏􀀃􀁕􀁈􀁐􀁒􀁙􀁈􀀃􀁄􀁑􀁜􀁗􀁋􀁌􀁑􀁊􀀃􀁋􀁈􀀃􀁋􀁄􀁖􀀃 􀁄􀁇􀁇􀁈􀁇􀀃􀁗􀁒􀀃􀁌􀁗􀀃􀁓􀁕􀁒􀁙􀁌􀁇􀁈􀁇􀀃􀁗􀁋􀁌􀁖􀀃􀁌􀁖􀀃
􀁓􀁒􀁖􀁖􀁌􀁅􀁏􀁈􀀃􀁚􀁌􀁗􀁋􀁒􀁘􀁗􀀃􀁇􀁄􀁐􀁄􀁊􀁌􀁑􀁊􀀃􀁌􀁗􀀑􀀃
􀀤􀁕􀁗􀀑􀀃􀀙􀀙􀀃
􀀱􀁒􀀃􀁕􀁌􀁊􀁋􀁗􀀃􀁗􀁒􀀃􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁈􀁛􀁌􀁖􀁗􀁖􀀃􀁌􀁑􀀃􀁕􀁈􀁖􀁓􀁈􀁆􀁗􀀃􀁒􀁉􀀃􀁄􀁑􀁜􀁗􀁋􀁌􀁑􀁊􀀃􀁊􀁌􀁙􀁈􀁑􀀃􀁚􀁌􀁗􀁋􀀃􀁄􀀃􀁙􀁌􀁈􀁚􀀃
􀁗􀁒􀀃􀁓􀁕􀁒􀁇􀁘􀁆􀁌􀁑􀁊􀀃􀁄􀁑􀀃􀁘􀁑􀁏􀁄􀁚􀁉􀁘􀁏􀀃􀁒􀁕􀀃􀁌􀁐􀁐􀁒􀁕􀁄􀁏􀀃􀁒􀁘􀁗􀁆􀁒􀁐􀁈􀀑􀀃
􀀤􀁕􀁗􀀑􀀃􀀙􀀚􀀃
􀀔􀀃􀀤􀀃 􀁆􀁏􀁄􀁌􀁐􀀃 􀁉􀁒􀁕􀀃 􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃 􀁉􀁒􀁕􀀃 􀁘􀁑􀁍􀁘􀁖􀁗􀀃 􀁈􀁑􀁕􀁌􀁆􀁋􀁐􀁈􀁑􀁗􀀃 􀁅􀁈􀁆􀁒􀁐􀁈􀁖􀀃 􀁗􀁌􀁐􀁈􀀐􀁅􀁄􀁕􀁕􀁈􀁇􀀃
􀁒􀁑􀁈􀀃􀁜􀁈􀁄􀁕􀀃􀁄􀁉􀁗􀁈􀁕􀀃􀁗􀁋􀁈􀀃􀁇􀁄􀁗􀁈􀀃􀁒􀁑􀀃􀁚􀁋􀁌􀁆􀁋􀀃􀁗􀁋􀁈􀀃􀁌􀁑􀁍􀁘􀁕􀁈􀁇􀀃􀁓􀁄􀁕􀁗􀁜􀀃􀁏􀁈􀁄􀁕􀁑􀁈􀁇􀀃􀁒􀁉􀀃􀁋􀁌􀁖􀀃􀁆􀁏􀁄􀁌􀁐􀀃
􀁄􀁑􀁇􀀃􀁌􀁑􀀃􀁄􀁑􀁜􀀃􀁈􀁙􀁈􀁑􀁗􀀃􀁗􀁈􀁑􀀃􀁜􀁈􀁄􀁕􀁖􀀃􀁄􀁉􀁗􀁈􀁕􀀃􀁗􀁋􀁈􀀃􀁇􀁄􀁗􀁈􀀃􀁒􀁑􀀃􀁚􀁋􀁌􀁆􀁋􀀃􀁗􀁋􀁈􀀃􀁆􀁏􀁄􀁌􀁐􀀃􀁉􀁌􀁕􀁖􀁗􀀃􀁄􀁕􀁒􀁖􀁈􀀑􀀃
􀀕􀀃􀀺􀁋􀁈􀁕􀁈􀀃􀁗􀁋􀁈􀀃􀁘􀁑􀁍􀁘􀁖􀁗􀀃􀁈􀁑􀁕􀁌􀁆􀁋􀁐􀁈􀁑􀁗􀀃􀁆􀁒􀁑􀁖􀁌􀁖􀁗􀁖􀀃􀁒􀁉􀀃􀁄􀀃􀁆􀁏􀁄􀁌􀁐􀀃􀁄􀁊􀁄􀁌􀁑􀁖􀁗􀀃􀁗􀁋􀁈􀀃􀁌􀁑􀁍􀁘􀁕􀁈􀁇􀀃
􀁓􀁄􀁕􀁗􀁜􀀏􀀃 􀁋􀁈􀀃 􀁐􀁄􀁜􀀃 􀁕􀁈􀁉􀁘􀁖􀁈􀀃 􀁗􀁒􀀃 􀁖􀁄􀁗􀁌􀁖􀁉􀁜􀀃 􀁗􀁋􀁈􀀃 􀁆􀁏􀁄􀁌􀁐􀀃 􀁈􀁙􀁈􀁑􀀃 􀁌􀁉􀀃 􀁋􀁌􀁖􀀃 􀁒􀁚􀁑􀀃 􀁆􀁏􀁄􀁌􀁐􀀃 􀁉􀁒􀁕􀀃
􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃􀁌􀁖􀀃􀁗􀁌􀁐􀁈􀀐􀁅􀁄􀁕􀁕􀁈􀁇􀀑􀀃 􀀃
􀀬􀀬􀀑􀀃􀀳􀁄􀁜􀁐􀁈􀁑􀁗􀀃􀁌􀁑􀀃
􀁖􀁄􀁗􀁌􀁖􀁉􀁄􀁆􀁗􀁌􀁒􀁑􀀃􀁒􀁉􀀃􀁄􀀃
􀁑􀁒􀁑􀀐􀁈􀁛􀁌􀁖􀁗􀁈􀁑􀁗􀀃
􀁒􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀀃
􀀥􀀑􀀃􀀶􀁆􀁒􀁓􀁈􀀃􀁒􀁉􀀃
􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃
􀀬􀀑􀀃􀀲􀁅􀁏􀁌􀁊􀁄􀁗􀁌􀁒􀁑􀁖􀀃􀁒􀁉􀀃
􀁗􀁋􀁈􀀃􀁘􀁑􀁍􀁘􀁖􀁗􀁏􀁜􀀃
􀁈􀁑􀁕􀁌􀁆􀁋􀁈􀁇􀀃􀁓􀁄􀁕􀁗􀁜􀀃
􀀬􀀬􀀑􀀃􀀵􀁌􀁊􀁋􀁗􀁖􀀃􀁌􀁑􀀃
􀁕􀁈􀁖􀁓􀁈􀁆􀁗􀀃􀁒􀁉􀀃
􀁈􀁛􀁓􀁈􀁑􀁇􀁌􀁗􀁘􀁕􀁈􀁖􀀃
􀀦􀀑􀀃􀀨􀁛􀁆􀁏􀁘􀁖􀁌􀁒􀁑􀀃􀁒􀁉􀀃
􀁕􀁈􀁖􀁗􀁌􀁗􀁘􀁗􀁌􀁒􀁑􀀃
􀀧􀀑 􀀷􀁌􀁐􀁈􀀃􀁏􀁌􀁐􀁌􀁗􀁖
Annex 85
ANNEX 86

Übersetzung des Bürgerlichen Gesetzbuches durch ein Übersetzer-Team des
Langenscheidt Übersetzungsservice. Laufende Aktualisierung der Übersetzung
durch Neil Mussett und in seiner Nachfolge durch Samson Übersetzungen GmbH,
Dr. Carmen v. Schöning.
Translation provided by the Langenscheidt Translation Service. Translation regularly
updated by Neil Mussett and most recently by Samson Übersetzungen GmbH, Dr.
Carmen v. Schöning.
Stand: Die Übersetzung berücksichtigt die Änderung(en) des Gesetzes durch Artikel
4 Abs. 5 des Gesetzes vom 1. Oktober 2013 (BGBl. I S. 3719).
Version information: The translation includes the amendment(s) to the Act by Article
4 para. 5 of the Act of 1 October 2013 (Federal Law Gazette I p. 3719).
Zur Nutzung dieser Übersetzung lesen Sie bitte den Hinweis unter "Translations".
For conditions governing use of this translation, please see the information provided
under "Translations".
German Civil Code
BGB
Full citation: Civil Code in the version promulgated on 2 January 2002 (Federal Law
Gazette [Bundesgesetzblatt] I page 42, 2909; 2003 I page 738), last amended by
Article 4 para. 5 of the Act of 1 October 2013 (Federal Law Gazette I page 3719)
This statute serves to transpose into national law the following directives:
1. Council Directive 76/207/EEC of 9 February 1976 on the implementation of the
principle of equal treatment for men and women as regards access to employment,
vocational training and promotion, and working conditions (OJ L 39 of 14 February
1976, p. 40),
2. Council Directive 77/187/EEC of 14 February 1977 on the approximation of the
laws of the Member States relating to the safeguarding of employees’ rights in the
event of transfers of undertakings, businesses or parts of businesses (OJ L 61 of 5
March 1977, p. 26),
3. Council Directive 85/577/EEC of 20 December 1985 to protect the consumer in
respect of contracts negotiated away from business premises (OJ L 372 of 31
Annex 86
December 1985, p. 31),
4. Council Directive 87/102/EEC for the approximation of the laws, regulations and
administrative provisions of the Member States concerning consumer credit (OJ L 42
of 12 February 1987, p. 48, last amended by Directive 98/7/EC of the European
Parliament and of the Council of 16 February 1998 amending Directive 87/102/EEC
for the approximation of the laws, regulations and administrative provisions of the
Member States concerning consumer credit (OJ L 101 of 1 April 1998, p. 17),
5. Council Directive 90/314/EEC of 13 June 1990 on package travel, package
holidays and package tours (OJ L 158 of 23 June 1990, p. 59),
6. Council Directive 93/13/EEC of 5 April 1993 on unfair terms in consumer
contracts (OJ L 95 of 21 April 1993, p. 29),
7. Directive 94/47/EC of the European Parliament and of the Council of 26 October
1994 on the protection of purchasers in respect of certain aspects of contracts
relating to the purchase of the right to use immovable properties on a timeshare
basis (OJ L 280 of 29 October 1994, p. 82),
8. Directive 97/5/EC of the European Parliament and of the Council of 27 January
1997 on cross-border credit transfers (OJ L 43 of 14 February 1997, p. 25),
9. Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997
on the protection of consumers in respect of distance contracts (OJ L 144 of 4 June
1997, p. 19),
10. Articles 3 to 5 of Directive 98/26/EC of the European Parliament and of the
Council of 19 May 1998 on settlement finality in payment and securities settlement
systems (OJ L 166 of 11 June 1998, p. 45),
11. Directive 1999/44/EC of the European Parliament and of the Council of 25 May
1999 on certain aspects of the sale of consumer goods and associated guarantees
(OJ L 171 of 7 July 1999, p. 12),
12. Articles 10, 11 and 18 of Directive 2000/31/EC of the European Parliament and
of the Council of 8 June 2000 on certain legal aspects of information society
services, in particular electronic commerce, in the Internal Market (“Directive on
electronic commerce” OJ L 178 of 17 July 2000, p. 1),
13. Directive 2000/35/EC of the European Parliament and of the Council of 29 June
2000 on combating late payment in commercial transactions (OJ L 200 of 8 August
2000, p. 35).
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Book 1
General Part
table of contents
Division 1
Persons
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Title 1
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Right to inspect documents
A person who has a legal interest in inspecting a document in the possession of
another person may demand from its possessor permission to inspect it if the
document was drawn up in his interests or if in the document a legal relationship
existing between himself and another is documented or if the document contains
negotiations on a legal transaction that were engaged in between him and another
person or between one of the two of them and a joint intermediary.
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Section 811
Place of presentation, risk and costs
(1) Presentation must, in the cases of sections 809 and 810, be made at the place
where the thing to be presented is located. Each party may demand to have it
presented at another place if there is a compelling reason for doing so.
(2) Risk and costs must be borne by the person demanding presentation. The
possessor may refuse presentation until the other party advances the costs and
provides security for the risk.
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Title 26
Unjust enrichment
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Section 812
Claim for restitution
(1) A person who obtains something as a result of the performance of another
person or otherwise at his expense without legal grounds for doing so is under a duty
to make restitution to him. This duty also exists if the legal grounds later lapse or if
the result intended to be achieved by those efforts in accordance with the contents of
the legal transaction does not occur.
(2) Performance also includes the acknowledgement of the existence or nonexistence
of an obligation.
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Section 813
Performance notwithstanding defence
(1) Restitution of performance rendered to perform an obligation may also be
demanded if the claim was subject to a defence by means of which assertion of the
claim has been permanently excluded. The provisions of section 214 (2) are
unaffected.
(2) If an obligation due on a specific date is performed early, then the claim for return
is excluded and reimbursement of interim interest may not be demanded.
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Section 814
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Knowledge that debt is not owed
Restitution of performance rendered for the purpose of performing an obligation may
not be demanded if the person who rendered the performance knew that he was not
obliged to do so or if the performance complied with a moral duty or consideration of
decency.
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Section 815
Non-occurrence of result
A claim for return for the non-occurrence of a result intended by an act of
performance is excluded if the occurrence of the result was impossible from the
outset and the person who rendered the performance prevented the result from
occurring in bad faith.
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Section 816
Disposition by an unauthorised person
(1) If an unauthorised person disposes of an object and the decision is effective
against the authorised person, then he is obliged to make restitution to the
authorised person of what he gains by the disposal. If the disposition is gratuitous,
then the same duty applies to a person who as a result of the disposition directly
gains a legal advantage.
(2) If performance is rendered to an unauthorised person that is effective in relation
to the authorised person, then the unauthorised person is under a duty to make
restitution of the performance.
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Section 817
Breach of law or public policy
If the purpose of performance was determined in such a way that that the recipient,
in accepting it, was violating a statutory prohibition or public policy, then the recipient
is obliged to make restitution. A claim for return is excluded if the person who
rendered performance was likewise guilty of such a breach, unless the performance
consisted in entering into an obligation; restitution may not be demanded of any
performance rendered in fulfilment of such an obligation.
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Section 818
Scope of the claim to enrichment
(1) The duty to make restitution extends to emoluments taken as well as to whatever
the recipient acquires by reason of a right acquired or in compensation for
destruction, damage or deprivation of the object obtained.
(2) If restitution is not possible due to the quality of the benefit obtained, or if the
recipient is for another reason unable to make restitution, then he must compensate
for its value.
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(3) The liability to undertake restitution or to reimburse the value is excluded to the
extent that the recipient is no longer enriched.
(4) From the time when the action is pending onwards, the recipient is liable under
the general provisions of law.
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Section 819
Increased liability in case of knowledge and breaches of law or public policy
(1) If the recipient, at the time of receipt, knows of the defect in the legal basis or if
he learns of it later, then he is obliged to make restitution from the moment of receipt
or of obtaining knowledge of the defect to make restitution as if the claim for
restitution had been pending from this time on.
(2) If the recipient, in accepting the performance, violates a statutory prohibition or
public policy, then he is likewise under the same obligation from receipt of payment
onwards.
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Section 820
Increased liability where the result is uncertain
(1) If the performance was intended to produce a result whose occurrence,
according to the contents of the legal transaction, was regarded as uncertain, then, if
the result does not occur, the recipient is under a duty of restitution in the same way
as if the claim for restitution had been pending at the time of receipt. The same
applies if the performance has been rendered for a legal reason which according to
the contents of the legal transaction was regarded as likely to lapse and the legal
reason ceases to exist.
(2) The recipient must only pay interest from the time when he learns that the result
has not occurred or that the legal reason has ceased to exist; he is not obliged to
make restitution of emoluments to the extent that he is no longer enriched at this
time.
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Section 821
Enrichment defence
A person who enters into an obligation without legal grounds to do so may also
refuse fulfilment if the claim to release from the obligation is statute-barred.
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Section 822
Restitution duty of third parties
If the recipient bestows the gains on a third person at no charge, then that third
person is obliged to make restitution as if he had received the disposition from the
creditor without legal grounds, to the extent that as a result of the bestowal the duty
of the recipient to make restitution of the enrichment is excluded.
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ANNEX 87

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ANNEX 88

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ANNEX 89

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
WASHINGTON, D.C.
In the arbitration proceedings between
NIKO RESOURCES (BANGLADESH) LTD.
(Claimant)
and
PEOPLE’S REPUBLIC OF BANGLADESH
(First Respondent)
BANGLADESH PETROLEUM EXPLORATION & PRODUCTION COMPANY LIMITED
(“BAPEX”)
(Second Respondent)
BANGLADESH OIL GAS AND MINERAL CORPORATION (“PETROBANGLA”)
(Third Respondent)
(jointly referred to as Respondents)
ICSID Case No. ARB/10/11
and
ICSID Case No. ARB/10/18
DECISION ON JURISDICTION
Members of the Tribunal
Mr Michael E. Schneider, President
Professor Campbell McLachlan
Professor Jan Paulsson
Secretary of the Tribunal
Ms Frauke Nitschke
Date of decision: 19 August 2013
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TABLE OF CONTENTS
GLOSSARY ............................................................................................................................. 5
1. INTRODUCTION .......................................................................................................... 8
2. THE PARTIES AND THE ARBITRAL TRIBUNAL .............................................. 11
2.1 The Claimant ........................................................................................................ 11
2.2 The Respondents .................................................................................................. 11
2.3 The Arbitral Tribunal ........................................................................................... 12
3. SUMMARY OF THE RELEVANT FACTS .............................................................. 14
3.1 The negotiations leading to the JVA .................................................................... 14
3.2 The JVA and its arbitration clause ....................................................................... 20
3.3 The negotiations of the Gas Purchase and Sale Agreement (GPSA) ................... 24
3.4 The arbitration clause in the GPSA ..................................................................... 33
3.5 The Payment Claims under the GPSA ................................................................. 36
3.6 The blowouts and the Compensation Claim ........................................................ 36
4. THE PROCEDURAL HISTORY ............................................................................... 40
4.1 From Registration to the Constitution of the two Tribunals ................................ 40
4.1.1 ICSID Case No. ARB/10/11 .......................................................................... 40
4.1.2 ICSID Case No. ARB/10/18 .......................................................................... 43
4.2 Following the Constitution of the two Tribunals ................................................. 45
5. THE CLAIMANT – ITS IDENTITY AND ITS NATIONALITY ........................... 51
5.1 The position of the Parties ................................................................................... 51
5.2 The Claimant’s identity........................................................................................ 52
5.3 The Claimant’s nationality ................................................................................... 55
5.3.1 The link with Cyprus ..................................................................................... 55
5.3.2 The link with Canada ..................................................................................... 58
6. THE STATE OF BANGLADESH AS A PARTY TO THE ARBITRATION ........ 61
6.1 The role of the Government of Bangladesh ......................................................... 62
6.2 Petrobangla and BAPEX as agencies or instrumentalities of the Government
of Bangladesh ...................................................................................................... 63
6.3 The separate legal identity of Petrobangla and BAPEX ...................................... 66
6.4 Petrobangla and BAPEX as agents for Bangladesh............................................. 67
6.5 Attribution ............................................................................................................ 68
6.6 Consent ................................................................................................................ 70
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7. JURISDICTION WITH RESPECT TO BAPEX AND PETROBANGLA –
THE ISSUE OF DESIGNATION ............................................................................... 73
7.1 The issue and the Parties’ positions ..................................................................... 73
7.2 The requirement of designation ........................................................................... 75
7.2.1 The term “designation” as distinguished from “notification” ........................ 75
7.2.2 The purposes of designation under Article 25(1) .......................................... 77
7.2.3 Types of designation – General and ad hoc designation ............................... 80
7.2.4 The form of designation and the question of implicit designation ................ 81
7.2.5 Communicating the State’s designation to the Centre ................................... 84
7.2.6 Conclusions concerning the requirement of “designation” under
Article 25(1)................................................................................................... 91
7.3 Designation in the present case ............................................................................ 92
8. THE DISPUTE ARISING DIRECTLY OUT OF AN INVESTMENT ................... 97
9. ILLEGAL ACTS, GOOD FAITH AND CLEAN HANDS ..................................... 104
9.1 The Parties’ positions ......................................................................................... 104
9.2 The Canadian conviction of Niko Canada on account of bribes to the Minister of
Energy in 2005 ................................................................................................... 107
9.3 Other indications of possible acts of corruption and the Respondents’
disclosure request ............................................................................................... 110
9.3.1 Investigation by the Bangladesh Anticorruption Commission (ACC) ........ 110
9.3.2 The BELA proceedings ............................................................................... 112
9.3.3 The proceedings against Stratum ................................................................. 112
9.3.4 The action of Mr Harb ................................................................................. 113
9.3.5 The Respondents’ request for document production ................................... 114
9.3.6 Conclusion on the Claimant’s acts of corruption ......................................... 116
9.4 Corruption and international public policy ........................................................ 117
9.5 Contracts of corruption ...................................................................................... 118
9.6 Contracts obtained by corruption ....................................................................... 120
9.7 Denial of jurisdiction despite an otherwise binding arbitration agreement ....... 126
9.7.1 Arbitration offer applicable only for good faith investment ........................ 126
9.7.2 Protecting the “integrity of the system” ....................................................... 128
9.7.3 The “clean hands” doctrine .......................................................................... 128
10. JURISDICTION WITH RESPECT TO CLAIMS UNDER THE JVA (THE
COMPENSATION DECLARATION AND THE COOPERATION CLAIM) .... 133
10.1 The position of the Parties ................................................................................. 133
10.2 Jurisdiction ratione materiae ............................................................................. 135
10.3 Jurisdiction ratione personae ............................................................................. 138
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10.4 Impact on legal interests of third parties ............................................................ 140
10.5 BAPEX cooperation with respect to the GPSA claims
(the Cooperation Claim) .................................................................................... 142
11. JURISDICTION WITH RESPECT TO CLAIM UNDER THE GPSA
(THE PAYMENT CLAIM) ....................................................................................... 144
11.1 The Position of the Parties ................................................................................. 144
11.2 Has Petrobangla agreed to arbitrate with Niko? ................................................ 145
11.3 Is Niko precluded as a matter of principle to claim for both Joint Venture
Partners? ............................................................................................................. 146
11.4 The position under the agreements .................................................................... 148
12. DECISION................................................................................................................... 155
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above, the Government of Kenya had avoided the agreement; the
tribunal had accepted jurisdiction; and in the exercise of that
mandate denied the claim on the merits.
9.7.2 Protecting the “integrity of the system”
473. In another line of argument, the Respondents submit that it
“would violate the principles of international public policy to
afford the Claimant access to ICSID”.310 In this context the
Respondents speak of the Tribunal’s power “to protect the
integrity of the ICSID dispute settlement mechanism”.311
474. The Tribunal is mindful of the importance of the ICSID dispute
settlement mechanism and its integrity. In the Tribunal’s view,
such integrity is promoted, and not violated, by the adjudication
of disputes submitted to the Centre under a valid consent to
arbitrate. Faced with a binding arbitration agreement and
subject to the specific requirements under the ICSID
Convention, considered elsewhere in this decision, the Tribunal
must address the substance of the dispute. In so doing, the
integrity of the system is protected by the resolution of the
contentions made (including allegations of violation of public
policy) rather than by avoiding them.
475. In the present case ICSID arbitration is invoked not in pursuit
of a claim for corruption nor for claims under an otherwise
illegal contract. The Claimant seeks performance of agreements
which, despite the Respondents’ knowledge about the
sanctioned cases of bribery, have not been avoided and from
which the Respondents continue to benefit. The Tribunal
cannot see why hearing and resolving these claims under the
given circumstances would affect the integrity of the ICSID
system.
9.7.3 The “clean hands” doctrine
476. Finally, the Respondents state that the Claimant “does not bring
this claim with clean hands”.312 In a footnote of its First
310 R-CMJ.2 – Payment Claim, paragraph 54.
311 R-CMJ.1, paragraph 54; R-CMJ.2 – Payment Claim, paragraph 53.
312 R-CMJ.2 – Payment Claim, paragraph 53.
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Counter-Memorial it had explained that the “‘clean hands’
principle is well recognised in common law” and referred to a
decision of the High Court of Australia.313 The Respondents
also quote from the Individual Opinion which Judge Manley
Hudson delivered in the case before the Permanent Court of
International Justice (PCIJ) and concerning the Diversion of
Water from the Meuse.314 That opinion relies on a legal principle
described by various expressions including the maxim “He who
seeks equity must do equity”; it is often referred to as a
particularly important manifestation of the “clean hands”
principle.315
477. The principle of clean hands is known as part of equity in
common law countries. The question whether the principle
forms part of international law remains controversial and its
precise content is ill defined. The situation has been analysed in
great detail in a recent award in the case of Guyana v. Suriname
by an Arbitral Tribunal Constituted Pursuant to Article 287,
and in Accordance with Annex VII of the United Nations
Convention on the Law of the Sea (UNCLOS). That UNCLOS
Tribunal316 found:
“No generally accepted definition of the clean hands
doctrine has been elaborated in international law. Indeed,
the Commentaries of the ILC Draft Articles on State
Responsibility acknowledge that the doctrine has been
applied rarely and, when it has been invoked, its
expression has come in many forms. The ICJ has on
numerous occasions declined to consider the application of
the doctrine, and has never relied on it to bar admissibility
of a claim or recovery. However, some support for the
doctrine can be found in dissenting opinions in certain ICJ
cases, as well as in opinions in cases of the Permanent
Court of International Justice (‘PCIJ’). […] These cases
indicate that the use of the clean hands doctrine has been
313 R-CMJ.1, fn. 44.
314 (Netherlands v. Belgium) (1937) PCIJ, Series A/B, No. 70, p. 73 et seq.
315 See e.g. Moloo, “A Comment on the Clean Hands Doctrine in International Law”, Transnational
Dispute Management, vol. 8. Issue 1 (February 2011), p. 2; Dumberry and Dumas-Aubin, “The
Doctrine of ‘Clean Hands’ and the Inadmissibility of Claims by Investors Breaching International
Human Rights”, Transnational Dispute Management, vol. 10, Issue 1 (January 2013), p. 2.
316 Guyana v. Suriname, PCA, Award of 17 September 2007 (under UNCLOS Ch VII). The Tribunal
was composed of Judge Dolliver M. Nelson, Professor Thomas Franck, Dr Kamal Hossain, Professor
Ivan Shearer and Professor Hans Smit.
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sparse, and its application in the instances in which it has
been invoked has been inconsistent.”317
478. While the ILC Special Rapporteur Crawford concluded (quoting
Rousseau318) that “it is not possible to consider the ‘clean
hands’ theory as an institution of general customary law”,319
others are of the view that, primarily because of its recognition
in the domestic orders of many States, it must be qualified as a
general principle of law.320
479. Concerning the substantive content of the principle in
international law, it has been summarised by Fitzmaurice:
“‘He who comes to equity for relief must come with ‘clean
hands’. Thus a State which is guilty of illegal conduct may
be deprived of the necessary locus standi in judicio for
complaining of corresponding illegalities on the part of other
States, especially if these were consequential on or were
embarked upon in order to counter its own illegality – in
short were provoked by it.”321
480. As shown by this quotation, the application of the principle
requires some form of reciprocity, so much so that, in his
Individual Opinion in the Diversion of Water from the Meuse
case, Hudson assimilated it to the Roman law principle of the
exceptio non adimpleti contractus.322 In that case, the claimant
State sought to prevent the defendant State from making use of
waters from the Meuse which it considered contrary to a treaty;
but the claimant State itself was making use of the waters in a
similar manner. Similarly, the case of unclean hands to which
Judge Schwebel referred in his dissenting opinion in the Military
and Paramilitary Activities case concerned acts of aggression
317 Ibid., paragraph 418 (references omitted).
318 Rousseau, Droit international public, tome V: les rapports conflictuels, (1983), p. 170.
319 Crawford, Second Report on State Responsibility, Yearbook of the International Law Commission,
vol II (part 2) (1999), p. 83.
320 Dumberry and Dumas-Aubin, op. cit., p. 3, referring to Kreindler, “Corruption in International
Investment Arbitration: Jurisdiction and the Unclean Hands Doctrine”, Essays in honour of Ulf Franke,
2010, p. 317, and to the opinions of Judges Schwebel and Anzilotti in cases of the ICJ and the PCIJ,
respectively.
321 Fitzmaurice, “The General Principles of International Law”, 92 Recueil des Cours (1957) 119
(citations omitted).
322 (Netherlands v. Belgium) (1937) PCIJ, Series A/B, No. 70, Individual Opinion by Mr Hudson, p. 77.
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which he saw on the side of the claimant State in relation to
those of the defendant State.323
481. When considering the defendant State’s admissibility argument
based on clean hands, the UNCLOS Arbitral Tribunal, dealing
with this doctrine “to the extent that such a doctrine may exist in
international law”, referred to three criteria which it had
extracted from those cases in which reference to the doctrine
had been made, in particular the developments in the opinion of
Judge Hudson: (i) the breach must concern a continuing
violation, (ii) the remedy sought must be “protection against
continuance of that violation in the future”, not damages for past
violations and (iii) there must be a relationship of reciprocity
between the obligations considered.324
482. In a wider sense, it has been argued that the clean hands
doctrine, without express mention of the term, has found
application in a number of other cases where claims were
dismissed for lack of jurisdiction or as inadmissible because
they were obtained fraudulently or were not in accordance with
the law of the host State.325
483. Applying these considerations to the present case and the
Respondents’ objection based on the clean hands doctrine, it is
obvious that this objection does not meet the criteria which
Judge Hudson and the UNCLOS Arbitral Tribunal identified for
the application of the doctrine in international law. Here the
violation on which the Respondents rely is not continuing, but
consisted in two acts that have been completed long ago; the
remedy which the Claimant seeks does not concern protection
against this past violation; and there is no relation of reciprocity
between the relief which the Claimant now seeks in this
arbitration and the acts in the past which the Respondents
characterise as involving unclean hands.
484. More generally, when the events sanctioned by the Canadian
judgment occurred, the JVA had already been concluded. The
events were widely publicised in Bangladesh and, shortly after
323 Case Concerning Military and Paramilitary Activities in and Against Nicaragua (Nicaragua v.
United States of America), Judgment of 27 June 1986, Dissenting Opinion of Judge Schwebel, ICJ
Reports 1986, p.25.
324 Guyana v. Suriname, Award of 17 September 2007, paragraphs 420-421.
325 For details see Moloo, op.cit., p. 6 et seq. and Dumberry and Dumas-Aubin, op. cit., p. 3 et seq.
Annex 89
they had become public the Minister concerned resigned.
Petrobangla and BAPEX, with the approval of the Bangladesh
Government, nevertheless entered into the GPSA. If and to the
extent the Claimant or its parent company had unclean hands,
the Respondents disregarded this situation. They may not now
rely on these events to deny jurisdiction under an arbitration
agreement which they then accepted. The additional details of
which the Respondents may have learned subsequently through
the account in Canadian judgment do not aggravate the offence
in any substantial manner compared to what was publicly
known in Bangladesh when the GPSA was concluded.
485. In these circumstances, the Tribunal may not rely on the events
subject of the Canadian judgment as grounds for refusing to
examine the merits of a dispute which the parties to the
agreements have accepted to submit to ICSID arbitration. The
Respondents’ objection based on acts of corruption must be
dismissed.
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10. JURISDICTION WITH RESPECT TO CLAIMS UNDER THE
JVA (THE COMPENSATION DECLARATION AND THE
COOPERATION CLAIM)
10.1 The position of the Parties
486. The claims brought under the JVA concern primarily what the
Claimant calls the “Compensation Claims” pending in a court of
Bangladesh. The Claimant describes these claims as relating to
the proceedings commenced in June 2008 in the Court of
District Judge, Dhaka, No 224 of 2008 (the Money Suit) in
which Petrobangla and Bangladesh claim from Niko and others
“damages alleged to arise from the blowouts of 2 wells in the
Chattak field which were being drilled under the JVA”.326
487. In the Notices of Arbitration with respect to the Compensation
Claims which the Claimant served on the three Respondents on
8 January 2010, the Claimant sought that the following
disputes be arbitrated:
“(a) All claims held jointly or severally by any of Bapex,
Petrobangla and Bangladesh to damages or losses alleged
to arise from the blowouts of two wells which were then
being drilled under the JVA in the gas fields in Bangladesh
known as the Chattak gas field, including those arising
from the matters alleged in either the Legal Notice dated
May 27, 2008 issued on behalf of Petrobangla to Niko
and/or in the pleadings filed on behalf of Petrobangla in
the suit filed June, 2008 by Petrobangla and the
Government of Bangladesh against Niko and others in the
court of District Judge, Dhaka Bangladesh, no. 224 of
2008;
(b) Whether Niko is liable for any of the Compensation
Claims in whole or in part, and if it is liable, determination
of the amount of liability;”327
326 RfA I, paragraph 6.8.
327 RfA I, Attachment C I.
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ANNEX 90

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
WASHINGTON, D.C.
In the arbitration proceeding between
FRAPORT AG FRANKFURT AIRPORT SERVICES WORLDWIDE
Claimant
and
REPUBLIC OF THE PHILIPPINES
Respondent
ICSID Case No. ARB/11/12
AWARD
Members of the Tribunal
Professor Piero Bernardini, President
Mr. Stanimir A. Alexandrov
Professor Albert Jan van den Berg
Secretary of the Tribunal
Ms. Aurélia Antonietti
Date of dispatch to the Parties: December 10, 2014
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REPRESENTATION OF THE PARTIES
Representing Fraport AG Frankfurt Airport
Services Worldwide:
Mr. Michael D. Nolan
Ms. Elitza Popova-Talty, and
Mr. Edward Baldwin (until May 21, 2014)
Milbank, Tweed, Hadley & McCloy LLP
1850 K Street, NW
Suite 1100
Washington, D.C. 20006
U.S.A.
and until March 12, 2014
Dr. Sabine Konrad
McDermott Will & Emery Rechtsanwälte
Steuerberater LLP
Feldbergstra􀈕e 35
60323 Frankfurt am Main
Germany
and
Ms. Lisa M. Richman
McDermott Will & Emery LLP
The McDermott Building
500 North Capitol Street, NW
Washington, D.C. 20001-1531
U.S.A.
Representing the Republic of the Philippines:
Hon. Florin T. Hilbay
Mr. Bernard G. Hernandez
Mr. Eric Remegio O. Panga
Ms. Ellaine Sanchez-Corro
Ms. Myrna S. Agno, and
Ms. Jane E. Yu
Office of the Solicitor General of the Philippines
134 Amorsolo St., Legaspi Village
Makati City, 1229,
Philippines
and
Justice Florentino P. Feliciano
224 University Avenue
Ayala Alabang Village
Muntinlupa City, Metro Manila,
Philippines
and
Ms. Carolyn B. Lamm
Ms. Abby Cohen Smutny
Mr. Francis A. Vasquez Jr.
Mr. Hansel T. Pham
Ms. Anne D. Smith
Mr. Frank Panopoulos, and
Mr. Brody K. Greenwald
White & Case LLP
701 13th Street, N.W.
Washington, D.C. 20005
U.S.A.
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TABLE OF CONTENTS
I. INTRODUCTION AND PARTIES .................................................................................................... 1
II. OVERVIEW OF THE CASE AND PARTIES’ REQUESTS FOR RELIEF ..................................... 1
III. PROCEDURAL HISTORY ................................................................................................................ 5
IV. FACTUAL BACKGROUND ........................................................................................................... 25
A. The NAIA Terminal 3 Project and the Concession Agreements .............................................. 25
B. Fraport’s Investment in the Terminal 3 Project ........................................................................ 38
C. Attempts to Renegotiate Terminal 3 Concession Agreement ................................................... 44
D. Nullification of the Terminal 3 Concession .............................................................................. 46
E. Further 2003/2004 Proceedings ................................................................................................ 52
F. The Government’s Taking of NAIA Terminal 3 ...................................................................... 53
V. SUMMARY OF THE PARTIES’ POSITIONS ............................................................................... 61
V.I RESPONDENT’S OBJECTIONS TO JURISDICTION AND ADMISSIBILITY .......................... 61
A. Respondent’s Basis for its Objections to Jurisdiction and Inadmissibility ............................... 62
B. Fraport Knowingly Based its Investment on a Concession that had been Illegally Obtained and
that was Invalid under Philippine Law ..................................................................................... 63
C. Fraport Violated the Anti-Dummy Law .................................................................................... 64
1. The Philippine Anti-Dummy Law ............................................................................................ 64
2. Fraport’s Alleged ADL Violations ........................................................................................... 66
D. Fraport’s Corruption and Unlawful Conduct Render its Claims Inadmissible ......................... 67
1. The Four “Liongson Schemes” to Procure Government Approvals ......................................... 67
2. The EPC Contract Schedule 7 Kickback Scheme ..................................................................... 69
3. Improper Receipt of Funds by Fraport Officials ....................................................................... 70
4. Fraport’s Responses .................................................................................................................. 70
5. Respondent’s Argument Relating to Fraport’s Ultimate Use of the Funds Put in the
Project ....................................................................................................................................... 72
V.II SUMMARY OF FRAPORT’S CLAIMS AND RELIEFS ............................................................... 74
A. Fraport’s Claims for Expropriation ........................................................................................... 74
1. The Alleged Acts of Expropriation ........................................................................................... 74
2. Respondent’s Defense of the Invalidation of the Terminal 3 Concession Agreements ............ 75
3. Failure to Pay Compensation .................................................................................................... 78
4. Public Purpose .......................................................................................................................... 80
B. Unfair and Inequitable Treatment ............................................................................................. 81
1. Legitimate Expectations ............................................................................................................ 82
2. Bad Faith ................................................................................................................................... 83
3. Denial of Justice ........................................................................................................................ 85
4. Lack of Transparency................................................................................................................ 86
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C. Impairment by Arbitrary and Discriminatory Measures ........................................................... 86
D. Failure to Afford Full Protection and Security ......................................................................... 87
E. Breach of Umbrella Clause ....................................................................................................... 88
F. Compensation under Theories of Unjust Enrichment and Quantum Meruit ............................ 89
V.III THE PHILIPPINES’ COUNTERCLAIMS ...................................................................................... 89
VI. JURISDICTION ................................................................................................................................ 91
A. Governing Law and Burden of Proof ........................................................................................ 91
B. The “Investment” under the BIT ............................................................................................... 93
1. The Parties’ Positions ............................................................................................................... 93
1.1 Respondent’s Position ................................................................................................... 93
1.2 Claimant’s Position........................................................................................................ 95
2. The Tribunal’s Analysis ............................................................................................................ 98
C. Respondent’s Jurisdictional Objections .................................................................................. 103
1. Introduction ............................................................................................................................. 103
2. Jurisdictional Objection 1: Fraport Violated the Anti-Dummy Law ...................................... 105
2.1 Introduction to the Anti-Dummy Law ......................................................................... 105
2.2 The Parties’ Arguments ............................................................................................... 106
a) Respondent’s Position ......................................................................................... 106
b) Claimant’s Position ............................................................................................. 115
2.3 The Tribunal’s Analysis .............................................................................................. 120
a) Interpretation of the ADL .................................................................................... 122
(i) Whether the ADL Applied Prior to the Operation of Terminal 3 ........................ 122
(ii) Shareholder Conduct under the ADL .................................................................. 125
(iii) Whether the ADL Prohibits Planning a Prohibited Act without More ................ 128
(iv) Whether a Violation Requires “Knowledge” ...................................................... 131
(v) Whether a Violation Can Be Cured ..................................................................... 133
(vi) Good Faith as a Defense ..................................................................................... 134
b) Assessment of Fraport’s Alleged ADL Violation ............................................... 139
3. Jurisdictional Objection 2: There is no Jurisdiction and all of Fraport’s Claims are
Inadmissible as a Result of Fraport’s Corruption and Fraud .................................................. 148
4. Jurisdictional Objection 3: Fraport Knew of PIATCO’s Misrepresentations to Obtain the
Concession Award .................................................................................................................. 153
4.1 Respondent’s Position ................................................................................................. 153
4.2 Claimant’s Position...................................................................................................... 156
4.3 The Tribunal’s Analysis .............................................................................................. 159
VII. COSTS ............................................................................................................................................ 164
A. The Parties’ Positions ............................................................................................................. 164
B. The Tribunal’s Analysis .......................................................................................................... 165
VIII. TRIBUNAL’S DECISION ............................................................................................................. 167
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considers for its part that this decision does not relate to bribery or corruption but to the
execution of the 1997 Concession Agreement which pre-dates Fraport’s investment, and
that a motion for reconsideration had been filed against it.186
204. On March 26, 2014, the Supreme Court issued a Notice where it consolidated the petitions
for review of the August 22, 2013 decision of the Court of Appeal in expropriation cases of
PIATCO and Takenaka and referred them to the Court en banc.187
205. As of November 2014, to the knowledge of the Tribunal, also on the basis of the record,
there had been no convictions or indictments of Government officials for having accepted
bribes. Nor have there been any firm conviction for ADL violations or corruption in the
Philippines, nor convictions in Germany. Except for the pending-suspended ADL charges
and the case against Henry Go, all criminal investigations relating to Terminal 3 have been
dismissed in the Philippines.
V. SUMMARY OF THE PARTIES’ POSITIONS
206. The Tribunal will now provide a summary of the Parties’ positions, starting with
Respondent’s objections to jurisdiction and admissibility, followed by Fraport’s claims and
Respondent’s counterclaims. To the extent relevant or useful, additional arguments will be
discussed in the Tribunal’s analysis below.
V.I RESPONDENT’S OBJECTIONS TO JURISDICTION AND ADMISSIBILITY
207. Respondent objects to the jurisdiction of the Tribunal and to the admissibility of Fraport’s
claims because it argues that Fraport is in violation of Philippine law, based on Fraport’s
alleged ADL violations, Fraport’s alleged corruption, and failure to sufficiently
substantiate the ultimate use of its claimed investment in the Terminal 3.
186 Fraport’s letter, Apr. 28, 2014; Claimant’s reply submission on costs, para. 17.
187 RE-2147, Supreme Court, Notice, Mar. 26, 2014.
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A. Respondent’s Basis for its Objections to Jurisdiction and Inadmissibility
208. According to Respondent, the BIT does not apply to investments made in violation of
Philippine law. Article 1(1) of the BIT defines “investment” as “any kind of asset accepted
in accordance with the respective laws and regulations of either Contracting State […].”
Thus, Fraport must demonstrate that it has “an investment” that complied with Philippines
law and regulations.188 This is a legality requirement, which is supported by the remainder
of the BIT and its Protocol.189 Not only Fraport’s investment was illegal for the alleged
reasons that the Tribunal will examine below, but it was not “accepted” by the
Philippines.190
209. Even without taking the terms of Article 1(1) of the BIT into account, for Respondent, all
BITs contain a tacit jurisdictional requirement of legality 191 and the Tribunal has no
jurisdiction over disputes involving investment made in violation of host State law.192
210. In addition, Respondent argues that “regardless of whether Fraport’s unlawful investment
is considered to satisfy the BIT’s definition of an investment,” 193 its claims are
inadmissible on the basis of the doctrine of clean hands and the requirement of good faith,
relying mainly on Bin Cheng and World Duty Free v. Kenya, because Fraport invested in
violation of Philippine law and international public policy, and that its investment was
illegal.194
188 C-Mem., para. 776.
189 CA-1, Protocol to the BIT (follows text of BIT).
190 R. PHB1, paras. 22-23.
191 Rej., paras. 579-581 ; R. PHB1, paras. 9-13, relying on Phoenix Action Ltd. v. Czech Republic (ICSID Case
No. ARB/06/5), Award, Apr. 15, 2009 (“Phoenix, Award”).
192 C-Mem., para. 808.
193 Rej., para. 582.
194 Ibid., para. 588; R. PHB1, paras. 119-126.
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211. Fraport considers that the BIT does not contain a legality requirement, and certainly not a
de facto continuous one,195 but rather that Article 1(1) was designed as an admittance
clause, as supported by the travaux préparatoires.196
212. Fraport further argues that the concept of admissibility based on clean hands does not
apply here as Respondent has not shown corruption and “should not be able to use its own
illegal acts of extortion and corruption in order to take operational Terminal without
compensation.”197 It considers that the allegations of corruption have nothing to do with
Fraport’s investment, or the legality of such investment, either in time or facts, pointing out
for instance that the acquisition of shares has never been illegal.198 Respondent replies that
there is no temporal limitation for the doctrine of admissibility.199
213. In any event, Fraport also counter-argues that all its discrete and multiple investments are
entitled to the protection of the BIT.200 Respondent dismisses this theory based on the
“unity of investment” doctrine and argues that corruption taints the entirety of an
investment.201
B. Fraport Knowingly Based its Investment on a Concession that had been
Illegally Obtained and that was Invalid under Philippine Law
214. According to Respondent, the clean hands doctrine applies to render inadmissible claims
relating to an investment that was procured through fraudulent misrepresentations. 202
PIATCO made material misrepresentations regarding its financial capacity and technical
qualifications to PBAC. PAIRCARGO misrepresented its proposed annual guaranteed
payments. Fraport is said to have joined in with this fraudulent conduct because it knew
195 Sur-Rej., paras. 244-246.
196 Rep., para. 596; Sur-Rej., paras. 191-235; RE-21.
197 Rep., para. 660.
198 Sur-Rej., paras. 122, 246.
199 Rej., para. 627.
200 Rep., paras. 642-657; Sur-Rej., paras. 250-260.
201 C-Mem., paras. 830-849; Rej., paras. 615-626.
202 C-Mem., para. 894.
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before it made its own investment that PIATCO has secured the Terminal 3 Concession
under false pretenses.203
215. Fraport also knew that the concessions agreements were in violation of the BOT law,
including an unlawful direct Government guarantee in Section 4.04(c)(iv) of the ARCA,
the lack of NEDA’s approval of the Concession Agreement or the ARCA, and were
missing critical approvals of the DOTC and the Minister of Finance that could not be
legally obtained.204
216. Fraport denies those allegations and claims that it had every reason to believe that
PIATCO achieved the award and concession agreements through legitimate means, which
in any event turns to be the case.205
C. Fraport Violated the Anti-Dummy Law
217. Respondent alleges that Fraport’s investment in PIATCO violated the 1936 ADL, as
Fraport deliberately assisted, aided and/or abetted in the “planning” of an ADL violation,
which deprives the Tribunal of jurisdiction over Fraport’s claims and renders such claims
inadmissible.206
1. The Philippine Anti-Dummy Law
218. The Philippine Constitution restricts operation of a public utility (which the Parties agree
includes Terminal 3) to Philippine citizens or corporations established under Philippine
law at least 60% of whose capital is owned by Philippine citizens. The ADL, designed to
prevent circumvention of such nationality requirements, prohibits in Section 2-A
“interven[tion] in the management, operation, administration, or control” of, inter alia,
public utilities by persons who do not meet the nationality requirements.
203 C-Mem., para. 896 ; R. Skeleton, paras. 13-17.
204 R. Skeleton, paras. 18-24 ; C-Mem., paras. 814-816.
205 Sur-Rej., paras. 128-132; Cl. PHB1, para. 201.
206 C-Mem., Section III.C.1; C-Mem., paras. 866-872; R. PHB1, para. 32; R. PHB2, paras. 30, 33.
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B. The “Investment” under the BIT
1. The Parties’ Positions
1.1 Respondent’s Position
300. The essence of Respondent’s jurisdictional objections is that the BIT contains an explicit
or implicit requirement that the investor comply with the laws and regulations of the host
State with respect to its investment and that Fraport failed to do so. The BIT is limited in
its application to investments accepted in accordance with host State law. Since
Claimant’s investment was made in violation of the Philippine ADL and because its
investment was in an enterprise that had been awarded concession agreements in violation
of the Philippine BOT law, its investment falls outside of the BIT’s protection also as a
result of Fraport’s corruption and fraud.348
301. In essence, Respondent contends that Claimant’s investment was not “accepted” in
accordance with the laws of the Philippines under Article 1(1) of the BIT. Article 1(1)
defines an “investment” as “any kind of asset accepted in accordance with the respective
laws and regulations of either Contracting State […].” Therefore, according to Respondent
in order to benefit from the BIT’s protection Claimant must demonstrate that its investment
complied with Philippines law and regulations.349
302. According to Respondent, a legality restriction is provided by other provisions of the
BIT.350 Thus, with regard to “Promotion and Acceptance” of investments, Article 2(1)
provides that “[e]ach Contracting State shall promote as far as possible investments in its
territory […] and admit such investments in accordance with its Constitution, laws and
regulations as referred to in Article 1 paragraph 1. […]” Likewise, Article 3(3) provides
that each Contracting State shall apply the most favored nation treatment regarding
investments “which are made in accordance with the legislation of that Contracting State.”
348 C-Mem., para. 773; R. PHB1, para. 62.
349 Ibid., para. 776.
350 Ibid., para. 780.
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303. When parties to the BIT wished to refer to registration requirements they did so
specifically, as in Article 5(1) requiring the host State to guarantee free transfer of payment
regarding investments “which have been duly registered by its appropriate government
agencies if so required.” Additional references to legality requirements are contained in
the Protocol to the BIT, which “forms an integral part” of the BIT,351 while other Articles
of the Protocol refer to registration requirements, which reference would be redundant if
Article 1(1) only referred to a registration regime as suggested by Claimant.352
304. According to Respondent, even if the BIT did not expressly require that investments
comply with host State law to qualify for treaty protection, the Tribunal should decline
jurisdiction on account of illegality of the investment. It refers to the legal opinion of
Professor Dolzer, who observes that the fundamental aim of the ICSID Convention “is to
promote the rule of law in the area of foreign investment”353 so that “unlawful investment
will not be enforced by an international tribunal even if the relevant BIT contains no clause
on domestic conformity.”354 The same view is expressed by Professor Schreuer,355 another
legal expert for Respondent.
305. In Respondent’s view, other tribunals have confirmed that claims based on illegal
investments cannot be protected even in the absence of a specific clause of the relevant
treaty requiring compliance with host State’s law. Reference is made by Respondent to
Phoenix Action v. Czech Republic, holding that “States cannot be deemed to offer access to
the ICSID dispute settlement mechanism to investments made in violation of their law,”
and to Hamester v. Ghana holding the same with reference to Phoenix. 356 Fraport’s
reference to EDF International and others v. Argentina is wrong since this case stands for
351 C-Mem., para. 782.
352 Ibid., para. 784.
353 Dolzer II (ICSID 2), para. 97.
354 Ibid., para. 78.
355 C-Mem., para. 802 and fn. 1747.
356 Phoenix, Award, para. 101; Gustav F W Hamester GmbH & Co KG v. Republic of Ghana (ICSID Case. No.
ARB/07/24), Award, June 18, 2010 (“Hamester, Award”), paras. 123-124; both cited in C-Mem., paras. 803-804
and Rej., para. 579.
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the opposite proposition by holding that “the requirement of not having engaged in a
serious violation of the legal regime is a tacit condition inherent in every BIT […]”357
306. Fraport’s argument that Article 1(1) does not create a legality requirement as it contains the
word “accepted” rather than “made”358 is flawed as it assumes that an investment “made”
in violation of host State law can nevertheless be “accepted in accordance with the
respective laws and regulations” of that State.359 Contrary to Fraport’s view that the object
and purpose of the BIT is “enshrined in its preamble,” having therefore regard to the
promotion of investment with no new barriers to BIT protection, 360 the promotion of
investment in such object and purpose must consider the entirety of the BIT provisions.361
307. In conclusion, since according to Respondent Article 1(1) requires covered investments to
comply with host State law, the Tribunal should decline jurisdiction over Claimant’s
claims because “Fraport’s investment was a violation of the Philippine Anti-Dummy Law
and was an investment in an enterprise that obtained its concession in violation of the
Philippine law.”362
1.2 Claimant’s Position
308. According to Claimant, contrary to Respondent’s afterthought argument contrived to evade
its compensation obligations, the investments made by it meet at all times the requirements
of the BIT, are legal under Philippine law and were accepted, indeed encouraged, by the
Philippine Government.363
309. According to Article 31(1) of the Vienna Convention on the Law of Treaties (the
“VCLT”), to which both Germany and the Philippines are parties, Article 1(1) of the BIT
357 C-Mem. paras. 805-806.
358 Rep., paras. 591-603.
359 Ibid., para. 536.
360 Ibid., para. 517.
361 Ibid., para. 567.
362 C-Mem., para. 808.
363 Mem., para. 644.
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must be interpreted “in good faith in accordance with the ordinary meaning to be given to
the terms of the treaty in their context and in the light of its object and purpose.”364
310. The ordinary meaning of the term “accepted,” when modified by “in accordance with the
respective laws and regulations,” means permission to the Philippines to put in place laws
and regulations to regulate its acceptance of assets as investments.365 This meaning is
consistent with the object and purpose of the BIT, which is the encouragement and
protection of investments, as made clear by the Preamble.366 It is also consistent with the
context of the BIT, which provides for specific narrow reservation in the Protocol that did
not apply to Claimant’s investment.367
311. Other articles of the BIT confirm that Ad Article 1(1) is concerned only with the admission
of investments, such as Article 2(1) which was included at the instigation of the German
Government to reflect that all investments that have been admitted are protected
investments.368 Likewise, Article 5(a) of the Protocol expressly envisages an acceptance
and registration regime by providing that “it is understood that duly registered investments
are assets of any kind as defined in Article 1, admitted in accordance with Article 2(1) and
reported to competent governmental agencies at the time the investment was made.”369
312. An acceptance regime is provided by other treaties concluded by the Philippines using the
same wording of Article 1 of the BIT, such as the Italy-Philippines BIT.370 By contrast,
other treaties concluded by the Philippines expressly provide for the requirement of
compliance with Philippine law as a condition to jurisdiction.371
364 Mem., para. 645.
365 Ibid., para. 646; see also Rep., paras. 590-596.
366 Sur-Rej., para. 205.
367 Mem., para. 647; see also Rep., paras. 598-601 and Sur-Rej., paras. 208-212 for reference to the “context” of
the BIT.
368 Ibid., para. 649.
369 Ibid., paras. 653-655.
370 Ibid., para. 651.
371 Such as the Philippine-Romania BIT, which omits the word “accepted”: Mem., paras. 656-657.
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313. Also the travaux préparatoires, considered by Respondent to be “often unreliable,”372
confirm that the treaty language of Article 1(1) was meant to be an admittance
requirement, not a legality requirement, as shown by the exchange of Notes Verbale (sic)
between the two Governments in the course of 1995.373
314. Respondent’s attempt to read into the BIT a legality requirement that is not there has been
rejected by other tribunals, for example, in EDF International and others v. Argentina
where the tribunal agreed with the claimant that where a BIT does not explicitly provide
that an investment must be made “in accordance with the laws” of the host State no
legality clause may be read into the treaty for purpose of admission of an investment.374
315. Neither of the cases referred to by Respondent dealt with provisions similar to or relevant
for an interpretation of the meaning of Article 1(1) of the BIT.375
316. According to Claimant, the only possible requirement that may be imposed on an investor
for purposes of jurisdiction is that its investment “is reported to competent governmental
agencies” at the time it is made, as provided by Ad Article 5(a) of the BIT Protocol.376
317. Article 3(3) of the BIT imposes on the investors rather than the Contracting State an
obligation of conformity with the host State’s legislation of investments made by them as a
condition for an investor to be eligible for MFN treatment. According to Claimant, this
position is instructive for two reasons. First, because it confirms the conscious use of the
word “accepted” instead of “made” in Article 1(1), which is instrumental to its
interpretation. Second, since the legality of the investment is required for the MFN
protection this means that in any other respects protection of the treaty is granted if the
372 C-Mem., para. 790.
373 Mem., para. 661; Rep., paras. 619-622; Sur-Rej., paras. 220-221.
374 Mem., para. 663; EDF International S.A., SAUR International S.A. and Léon Participaciones S.A. v. Argentine
Republic (ICSID Case No. ARB/03/23), Award, June 11, 2012 (CA-99) (“EDF and others, Award”), paras. 304-
307.
375 Rep., paras. 609-611.
376 Ibid., para. 586.
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investment is accepted. 377 Article 8 of the BIT provides confirming context when
requiring conformity with host State’s legislation only for BIT protection of “investments
made prior to its entry into force.”378
318. In conclusion, Claimant contends that an investment will not receive the BIT protection
under Article 1(1) either if it was not accepted by the host State or if the State’s acceptance
was not in accordance with its “respective laws and regulations.” This is not the case in
the present dispute considering that Claimant’s investments “were accepted by the highest
levels of the Philippine Government”379 and that such acceptance was in accordance with
all relevant laws and regulations, considering that Respondent does not impose specific
admittance or registration requirements on investments in shares or in the form of loans or
guarantees.”380
2. The Tribunal’s Analysis
319. The overview of the Parties’ position regarding the issue of jurisdiction conducted so far,
although not meant to be exhaustive of the respective arguments, is sufficient to evidence
their fundamental disagreement on the scope of Article 1(1) of the BIT and the
consequence for the Tribunal’s jurisdiction.
320. According to Claimant, Article 1(1) was intended by both parties to the Treaty to be an
admittance clause, with the consequence that since its investments had complied with any
registration or admission requirement under the laws and regulations of the Philippines, the
Tribunal has jurisdiction to hear the case.381 According to Respondent, Article 1(1) is a
legality requirement, with the consequence that since Claimant’s investment were made in
violations of the host State’s law the Tribunal lacks jurisdiction ratione materiae should
such violation be established.
377 Rep., paras. 603-606.
378 Ibid., para. 608.
379 Ibid., para. 485.
380 Ibid., paras. 623-625; Sur-Rej., para. 197.
381 This is also because, according to Claimant, “the alleged anti-dummy violations – which even Respondent
admitted were cured – are not factually related to Fraport obtaining its shares;” Sur-Rej., para. 248.
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321. Turning to Article 1(1) of the BIT, which is at the core of the Parties’ disagreement, the
Tribunal’s analysis must be conducted applying the rules for treaty interpretation under the
VCLT. According to Article 31(1) of the VCLT
A treaty shall be interpreted in good faith in accordance with the ordinary
meaning to be given to the terms of the treaty in their context and in the light
of its object and purpose.
322. Article 1(1) of the BIT provides, in relevant part, that “the term ‘investment’ shall mean
any kind of asset accepted in accordance with the respective laws and regulations of either
Contracting State […]”
323. Regarding the “ordinary meaning” of the term “accepted” in Article 1(1), the Tribunal
concurs with Respondent’s reference to the meaning of the term according to the Oxford
Dictionary as “satisfactory,” “acceptable” and “generally recognized as correct or
valid.”382 However, any forms of acceptance, to be valid, must be “in accordance with the
laws and regulations” of the host State and this supports the interpretation of Article 1(1)
favoring the requirement that investments, to be accepted, must comply with the host
State’s law. In other words, the reading of the whole sentence in Article 1(1) legitimates
the interpretation that is not the act of acceptance that has to conform to the host State’s
law but that the investment to be accepted must comply with such law.383
324. Regarding the “context,” other provisions of the BIT confirm the legality requirement for
an investment to be accorded the BIT protection. Thus, Article 2(1) provides that each
Contracting State, in addition to promoting investments in its territory, shall admit them
“in accordance with its Constitution, laws and regulations, as referred to in Article 1
paragraph 1.” Once again, to admit investments in accordance with the Constitution, laws
382 C-Mem., para. 778.
383 Particularly in the case, like the present one, where the host State has no specific rules governing the
acceptance (in the sense of admission) of foreign investments.
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and regulations may only be interpreted to mean that investments, to be admitted to the
BIT protection, must conform to the host State’s law.384
325. Reference to investments “made in accordance with” or “consistent with” the host State’s
legislation is made by Article 3(3) and Article 8 of the BIT, respectively to grant MFN
treatment to investment and to extend the BIT protection also to investments made prior to
the BIT entry into force. Requiring compliance with host State’s law only limited to these
two situations may be hardly reconciled with the repeated references in the BIT to the host
State’s law, pointing rather to a general requirement of compliance with such law for an
investment to be accorded the BIT protection.
326. As mentioned by Respondent, investment registration is expressly required by the BIT in
certain cases. This is the case of Article 5(1) for the “guarantee of free transfer of
payments in connection with investments.” This is also the case of Ad Article 5(a) of the
Protocol defining, which are duly registered investments for the Philippines. In the
Tribunal’s view, nothing would have prevented the Contracting States from using the same
language in Article 1(1), had they intended that provision to be an admittance clause.
327. The Tribunal also refers to the Philippines’ Instrument of Ratification to the BIT, which
the Tribunal considers both States to have accepted “as an instrument related to the treaty”
in the Protocol of Exchange of the Instruments of Ratifications of the BIT, and which
therefore constitutes part of the “context” under Article 31(2)(b) of the VCLT. With
relative clarity, that Instrument of Ratification states that the “Agreement shall be in areas
allowed by and in accordance with the Constitution, laws and regulations of each of the
Contracting Parties.”385
328. Investment treaty cases confirm that such treaties do not afford protection to illegal
investments either based on clauses of the treaties, as in the present case according to the
above analysis, or, absent an express provision in the treaty, based on rules of international
384 Considering also that a State’s Constitution does not normally regulates the process of admission of
investments in its territory, as it is the case of the Philippine Constitution (CBII-6).
385 C-Mem., para. 785 (italics in the quote).
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law, such as the “clean hands” doctrine386 or doctrines to the same effect.387 One of the
first cases having ruled on this issue, Inceysa v. El Salvador, has held that “because
Inceysa’s investment was made in a manner that was clearly illegal, it is not included in the
scope of consent expressed by Spain and the Republic of El Salvador in the BIT and,
consequently, the disputes arising from it are not subject to the jurisdiction of the
Centre.”388
329. Cognizant that the good faith interpretation of a treaty encompasses the principle of effet
utile, however, the Tribunal does not regard it as appropriate to treat the term “accepted” as
surplusage. Rather, recalling that the ordinary meaning of the term “accepted” includes
“received,” the Tribunal considers that “accepted” refers to the point in time when the
386 “A party who asks for redress must present himself with clean hands,” American Commissioner Hassaurek,
Ecuadorian-United States Claims Commission (1862), cited by Bing Cheng, General Principles of Law as applied
by International Courts and Tribunals, 1953, p. 156.
387 Identified by Latin maxims such as “ex injuria jus non oritur,” “nemo auditur propiam turpitudinem allegans”
or “ex dolo malo non oritur action.”
388 Inceysa Vallisoletana S.L. v. Republic of El Salvador (ICSID Case No. ARB/03/26), Award, Aug. 2, 2006,
para. 257. A series of other cases have consistently applied the requirement of legality of investments and
declined accordingly jurisdiction in case of investment made in violation of the host State’s law;
Plama Consortium Limited v. Republic of Bulgaria (ICSID Case No. ARB/03/24), Award, Aug. 27, 2008, para.
139: “[...] the ECT should be interpreted in a manner consistent with the aim of encouraging respect of the rule of
law. The Arbitral Tribunal concludes that the substantive provisions of the ECT cannot apply to investments that
are made contrary to law”;
Phoenix, Award, para. 101: “States cannot be deemed to offer access to the ICSID dispute settlement mechanism
to investments made in violation of their laws. If a State, for example, restricts foreign investment in a sector of
its economy and a foreign investor disregards such restriction, the investment concerned cannot be protected
under the ICSID/BIT system. These are illegal investments according to the national law of the host Stat and
cannot be protected through an ICSID arbitral process. And it is the Tribunal’s view that this condition – the
conformity of the establishment of the investment with the national laws – is implicit even when not expressly
stated in the relevant BIT”;
Hamester, Award, paras. 123-124: “An investment will not be protected if it has been created in violation of
national or international principles of good faith; by way of corruption, fraud, or deceitful conduct; or if its
creation itself constitutes a misuse of the system of international investment protection under the ICSID
Convention. It will also not be protected if it is made in violation of the host State’s law (as elaborated, e.g. by
the tribunal in Phoenix). These are general principles that exist independently of specific language to this effect
in the Treaty”; and
SAUR International v. Argentine Republic (ICSID Case No. ARB/04/4), Decision on Jurisdiction and Liability,
June 6, 2012 (“SAUR, Decision”), para. 306: “The requirement of not having engaged in a serious violation of the
legal regime is a tacit condition, inherent in every BIT, since it cannot be understood under any circumstance that
a State is offering the benefit of protection through investment arbitration when the investor, to reach that
protection, has committed an unlawful action” [translated from the French original].
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investment is received in the host State, or, in other words, at the time the investment is
made.
330. This understanding is supported by the use of the term “zugelassen sind” in the German
text of Article 1(1).389 As Claimant explained, “zugelassen sind” is the passive participle
of the verb “zulassen,” meaning “to “accept” or “to admit.”390 Thus, the German text is, at
the very least, consistent with the Tribunal’s view that Article 1(1) refers to the admission
of the investment, a well-known concept in international investment law. Indeed, the
English text of the BIT also does not clearly differentiate between acceptance and
admission. While Article 2 of the BIT is entitled “Promotion and Acceptance,” the text of
Article 2(1) refers instead to the “promot[ion]” and “admi[ssion]” of investments. In the
German version of Article 2, the references to both “[a]cceptance” and “admi[ssion]” use
forms of the verb “zulassen,” the same term used for “accepted” in Article 1(1).
331. For these reasons, the Tribunal disagrees with Claimant’s contentions that the phrase
“accepted in accordance with the [host State’s] laws and regulations,” as used in Article
1(1), simply contemplates a potential regime for regulation of the admission of foreign
investment. Rather, the Tribunal finds that the use of this phrase limits the scope of
“investment” in the BIT to investments that were lawful under (i.e., “in accordance with”)
the host State’s laws and regulation at the time the investments were made.
332. The Tribunal is also of the view that, even absent the sort of explicit legality requirement
that exists here, it would be still be appropriate to consider the legality of the investment.
As other tribunals have recognized, there is an increasingly well-established international
principle which makes international legal remedies unavailable with respect to illegal
investments, at least when such illegality goes to the essence of the investment.391
389 The BIT provides that the German, Filipino, and English texts are all authentic versions of the treaty, although
in the case of conflict, the English text prevails.
390 Rep., para. 591.
391 See, e.g., EDF and others, Award (CA-99), para. 308: “La condition de ne pas commettre de violation grave
de l’ordre juridique est une condition tacite, propre à tout APRI, car en tout état de cause, il est incompréhensible
qu’un État offre le bénéfice de la protection par un arbitrage d’investissement si l’investisseur, pour obtenir cette
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333. In light of the foregoing analysis, the Tribunal concludes that Article 1(1) of the BIT
requires that an investment comply with the laws of the host State at the time it is made in
order to be accorded protection under the BIT. The Tribunal’s assessment of Respondent’s
jurisdictional objections will therefore focus on the time of entry of Claimant’s investment.
C. Respondent’s Jurisdictional Objections
1. Introduction
334. Based on the foregoing conclusion regarding the requirement of legality of investments to
found the Tribunal’s jurisdiction ratione materiae, the Tribunal shall now proceed to
analyze the Parties’ arguments regarding Respondent’s jurisdictional objections. Before
doing so, the following issues have to be determined, namely
(a) which of Claimant’s “investments” are to be considered for jurisdictional
purposes;
(b) which are Respondent’s jurisdictional objections.
335. Regarding issue (a), according to Claimant’s most recent submission on the subject
Fraport’s investments in the NAIA 1PT 3 Project span a period of several
years, from 1999 and ending in 2002-2203. A report prepared by
PricewaterhouseCoopers (“PWC”) and submitted with the Memorial set forth
the investment made by Fraport per years. Fraport made several types of
investments, as defined under Article 1 of the BIT. The BIT states that
investments include “shares of stock and debentures of companies or interest
in the property of such companies”. Fraport’s investments include (1) equity
investments in PIATCO and in a “cascade” of Philippine companies that have
ownership interests in PIATCO; (2) loans to PIATCO and the cascade
companies; (3) payments to Takenaka and the Project lenders specifically for
the construction of the Terminal (resulting, inter alia, in subrogation rights);
and (4) services rendered. Fraport’s investments also include Fraport’s
protection, a agi à l’encontre du droit” (translated in Schreuer-Kriebaum-Binder I (ICSID 2), fn. 81 as “The
condition of not committing a grave violation of the legal order is a tacit condition of any BIT, because in any
event it is incomprehensible that a State would offer the benefit of protection through investment arbitration if the
investor, in order to obtain such protection, has acted contrary to the law”).
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ANNEX 93

INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
WASHINGTON, D.C.
IN THE MATTER OF AN ARBITRATION UNDER THE ICSID ADDITIONAL FACILITY
RULES
between
RUSORO MINING LIMITED
(Claimant)
and
THE BOLIVARIAN REPUBLIC OF VENEZUELA
(Respondent)
ICSID Case No. ARB(AF)/12/5
AWARD
Members of the Tribunal
Prof. Juan Fernández-Armesto, Chairman of the Tribunal
Prof. Francisco Orrego Vicuña, Arbitrator
Judge Bruno Simma, Arbitrator
Secretary of the Tribunal
Ms. Alicia Martín Blanco
Date of dispatch to the Parties: 22 August 2016
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REPRESENTATION OF THE PARTIES
Representing Rusoro Mining Ltd.:
Mr. Nigel Blackaby
Mr. Noah Rubins
Mr. Alex Wilbraham
Mr. Jean-Paul Dechamps
Mr. Ben Love
Mr. Robert Kirkness
Mr. Gustavo Topalian
Mr. Ricardo Chirinos
Mr. Juan Pomés
Freshfields Bruckhaus Deringer US LLP
700 13th Street, NW
10th Floor
Washington, DC 20005-3960
United States of America
Ms. Alejandra Figueiras
Mr. Guillermo Iribarren
Figueiras Abogados
Edificio Cavendes
Piso 8, Oficina 806
Los Palos Grandes
Caracas, 1060
Venezuela
Mr. Andrés Mezgravis
Ms. Militza Santana
Mezgravis & Asociados
Avenida Venezuela
Torre Oxal, Piso 5, Oficina 5-A
Urbanización El Rosal
Caracas, 1060
Venezuela
Representing the Bolivarian Republic
of Venezuela:
Dr. Reinaldo Enrique Muñoz Pedroza
Procurador General de la República
Dr. Felipe Daruiz
Coordinador de Juicios Internacionales
Procuraduría General de la República
Bolivariana de Venezuela
Av. Los Ilustres, c/c calle Francisco Lazo
Marti, Urb. Santa Mónica
Caracas
Venezuela
Mr. Derek Smith
Mr. Alberto Wray
Mr. Thomas Ayres
Mr. Diego Cadena
Ms. Analía González
Mr. Christopher Hart
Ms. Christina Beharry
Ms. Erin Argueta
Mr. Ofilio Mayorga
Ms. Melinda Kuritzky
Mr. José Rebolledo
Foley Hoag LLP
1717 K Street, NW
Suite 1200
Washington, DC. 20006
United States of America
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TABLE OF CONTENTS
I. INTRODUCTION ............................................................................................... 15􀀃
II. THE PARTIES TO THE ARBITRATION ...................................................... 17􀀃
1. The Claimant – Rusoro Mining Limited ........................................ 17􀀃
2. The Respondent – The Bolivarian Republic of Venezuela ........... 18􀀃
III. PROCEDURAL HISTORY ............................................................................... 20􀀃
IV. FACTS.................................................................................................................. 33
1. Background: From Grupo Agapov to Rusoro ............................... 33􀀃
2. Government policy regarding mining ............................................ 36􀀃
3. Rusoro acquires Cradock’s assets .................................................. 37􀀃
4. Rusoro acquires Mena’s assets ....................................................... 39􀀃
5. Rusoro acquires Gold Fields’ Venezuelan assets .......................... 39􀀃
6. Rusoro acquires Hecla’s assets ....................................................... 41􀀃
7. The Venrus Joint Venture ............................................................... 42􀀃
8. The Venezuelan gold and exchange control regulations .............. 43􀀃
9. The Nationalization Decree ............................................................. 47􀀃
10. The first negotiation period ............................................................. 48􀀃
11. The second negotiation period ........................................................ 49􀀃
12. The taking of control of Rusoro’s assets ........................................ 50􀀃
V. RELIEF SOUGHT BY THE PARTIES ........................................................... 51􀀃
1. The Parties’ requests in brief .......................................................... 51􀀃
2. Claimant’s request for relief in full ................................................ 52􀀃
3. The Respondent’s Request for Relief ............................................. 53􀀃
VI. JURISDICTIONAL OBJECTIONS ................................................................. 54􀀃
VI.1.􀀃THE FIRST JURISDICTIONAL OBJECTION: THE DISPUTE IS TIME-BARRED 54
1. Respondent’s position ...................................................................... 55􀀃
2. Claimant’s position .......................................................................... 56􀀃
3. The Tribunal’s decision ................................................................... 57􀀃
VI.2.􀀃THE SECOND JURISDICTIONAL OBJECTION: NO JURISDICTION BEFORE
THE ICSID ADDITIONAL FACILITY 64􀀃
1. Respondent’s position ...................................................................... 65􀀃
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2. Claimant’s position .......................................................................... 66􀀃
3. The Tribunal’s decision ................................................................... 66􀀃
VI.3.􀀃THE THIRD JURISDICTIONAL OBJECTION: ILLEGALITY IN THE OWNERSHIP
OF MINING ASSETS 71􀀃
1. The Respondent’s position .............................................................. 71􀀃
2. The Claimant’s position ................................................................... 73􀀃
3. The Tribunal’s decision ................................................................... 74􀀃
VII. RUSORO’S CLAIMS ......................................................................................... 86􀀃
VII.1. PRELIMINARY ISSUES 86􀀃
1. Legal framework .............................................................................. 86􀀃
2. Claimant’s good faith ....................................................................... 86􀀃
VII.2. EXPROPRIATION 88􀀃
1. Claimant’s position .......................................................................... 88􀀃
2. Respondent’s position ...................................................................... 89􀀃
3. The Tribunal’s decision ................................................................... 90􀀃
3.1􀀃 Direct expropriation .................................................................. 91􀀃
3.2􀀃 Requirements established in art. VII.1 ..................................... 92􀀃
3.3􀀃 Creeping expropriation ............................................................. 98􀀃
VII.3. ANCILLARY CLAIMS 103􀀃
1. Claimant’s position ........................................................................ 103􀀃
2. Respondent’s position .................................................................... 106􀀃
3. The Tribunal’s decision ................................................................. 111􀀃
3.1􀀃 Proven facts ............................................................................ 111􀀃
3.2􀀃 Preliminary defences .............................................................. 112􀀃
3.3􀀃 FET ......................................................................................... 116􀀃
3.4􀀃 FPS .......................................................................................... 122􀀃
3.5􀀃 Discrimination ........................................................................ 123􀀃
3.6􀀃 Free transfer of funds .............................................................. 125􀀃
3.7􀀃 Conclusion .............................................................................. 130􀀃
VII.4. VENEZUELA’S COUNTER-CLAIM 130􀀃
1. Respondent’s counter-claim .......................................................... 131􀀃
2. Claimant’s position ........................................................................ 133􀀃
3. The Tribunal’s decision ................................................................. 134􀀃
VIII. QUANTUM........................................................................................................ 138
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VIII.1.􀀃 COMPENSATION FOR EXPROPRIATION 140􀀃
1.􀀃 The price of gold and the value of gold mining companies ........ 142􀀃
2.􀀃 Rusoro’s investments in Venezuela .............................................. 144􀀃
3.􀀃 Rusoro’s investment adjusted ....................................................... 149􀀃
4.􀀃 The book value of Rusoro’s investment ....................................... 150􀀃
5.􀀃 Rusoro’s market capitalization ..................................................... 154􀀃
6.􀀃 The valuation of Rusoro proposed by Claimant’s expert ........... 156􀀃
7.􀀃 The Tribunal’s decision ................................................................. 164􀀃
VIII.2.􀀃 DAMAGES FOR BREACH OF TREATY 174􀀃
1.􀀃 The experts’ calculation ................................................................. 174􀀃
2.􀀃 The Tribunal’s decision ................................................................. 176􀀃
VIII.3.􀀃 INTEREST 179􀀃
1.􀀃 Claimant’s position ........................................................................ 179􀀃
2.􀀃 Respondent’s position .................................................................... 180􀀃
3.􀀃 The Tribunal’s decision ................................................................. 180􀀃
VIII.4.􀀃 TAXES 182􀀃
1.􀀃 The Parties’ position ...................................................................... 182􀀃
2.􀀃 The Tribunal’s decision ................................................................. 183􀀃
IX.􀀃 COSTS................................................................................................................ 185􀀃
1.􀀃 Claimant’s position ........................................................................ 185􀀃
2.􀀃 Respondent’s position .................................................................... 186􀀃
3.􀀃 The Tribunal’s decision ................................................................. 186􀀃
X.􀀃 SUMMARY ....................................................................................................... 190􀀃
1.􀀃 Jurisdiction ..................................................................................... 191􀀃
2.􀀃 Liability ........................................................................................... 193􀀃
3.􀀃 Quantum ......................................................................................... 195􀀃
XI.􀀃 DECISION ......................................................................................................... 197􀀃
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foreign currency against VEF, at a market exchange rate which was consistently
higher than the Official Exchange Rate.
485. This dual system came to a halt on 17 May 2010, when the Ley Cambiaria was
amended, making the use of the Swap Market illegal402.
B. The 2010 Measures
486. In July 2010 the BCV403 amended the 2009 Measures, liberalized the gold sale
regime and reduced the distinction between publicly and privately owned gold
producers.
487. The purpose of the July 2010 BCV Resolution404 was to regulate the sale of gold
by public and private producers operating in Venezuela. It created a unified regime
for public and private producers:
- 50% of production had to be sold to the BCV, at a price expressed in VEF
and converted at the Official Exchange Rate; and
- the remaining 50% could be exported, subject to authorization from the BCV.
488. Simultaneously the Convenio Cambiario No. 12 (originally issued in 2009) was
amended, partially liberalizing the exchange control regime of gold producers, and
unifying the different regimes applicable to private and to public gold producers
(except small scale producers). All gold producers were now required to sell 50%
of their foreign currency income from export operations to the BCV at the Official
Exchange Rate, and were authorized to keep the other 50% in foreign accounts and
to use the funds for payments in foreign currency outside the Bolivarian
Republic405.
3.2 PRELIMINARY DEFENCES
489. Venezuela has filed two preliminary defences: that Rusoro’s hands are dirty (A.)
and that the exception benefitting prudential regulation, provided for in Art. X of
the BIT, is to be applied (B.).
490. Both defences are without merit.
A. Dirty hands
491. The Republic argues that Rusoro may not seek relief for regulations adopted by
Venezuela to prevent Rusoro’s illegal sales to domestic buyers, in order to permit
buyers to illegally export gold from Venezuela (i), and that the purpose of the 2009
and 2010 Measures was to curb such illicit transactions (ii).
402 Doc. C-200 – Ley de Reforma Cambiaria.
403 See para. 157 supra.
404 Doc. C-203 – July 2010 BCV Resolution and Amendment to Convenio Cambiario No.12.
405 Doc. C-203 – July 2010 BCV Resolution and Amendment to Convenio Cambiario No.12.
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492. (i) The problem with Venezuela’s first contention is not the principle (it is
undisputed that claimants with “dirty hands” have no standing in investment
arbitration406), but the total lack of evidence.
493. Venezuela submits that Rusoro knowingly furthered the illegal export of gold
- By selling to domestic clients, certified by the Ministry of Mines, but not
included in the BCV’s list of registered gold exporters407,
- And by incorrectly making out waybills in favour of a security transport
company (and not the final buyer of the gold)408.
494. In accordance with Art. 88 Mining Law the Ministry of Mines is entrusted with the
following duties with regard to mining activities and companies:
“El Ejecutivo Nacional, por órgano del Ministerio de Energía y Minas,
vigilará, fiscalizará y controlará las actividades de toda persona natural o
jurídica, pública o privada, en las materias sometidas a las disposiciones de
esta Ley […]”.
The Ministry is also empowered to impose sanctions on persons who breach the
mining regulations409.
495. Using the powers conferred by law, the Ministry of Mines supervised (or should
have supervised) the activities carried out by Rusoro, Venezuela’s largest private
gold producer. There is no evidence in the file that, as a consequence of such
supervisory activities, the Ministry ever challenged the legality of Rusoro’s
conduct, filed a complaint against Rusoro or imposed any sanction. The Bolivarian
Republic is now raising, for the first time and ex post facto, previously unidentified
violations of its own laws to challenge Rusoro’s claim.
496. To prove this allegation, the Republic is not marshalling any direct evidence, but
only what Respondent itself defines as “indirect evidence”410. The Republic avers
that this evidence “demonstrates that Rusoro systematically evaded mining
regulations that required it to document with specificity each and every gold
transaction”411.
497. The Tribunal is unconvinced.
498. If Rusoro’s conduct had indeed been as egregiously illicit as now claimed, the
Ministry of Mines must have been aware of the situation and must have adopted the
corresponding measures. However, there is no evidence that this actually took
place. In the Tribunal’s opinion, the “indirect evidence” marshalled by the
406 Flughafen Zürich at 132; Phoenix at 101; Saur at 308.
407 R II at 71.
408 R II at 77.
409 See Doc. RLA-49 – Mining Law, Art. 109 et seq.
410 R II at 82.
411 R II at 81.
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Bolivarian Republic is blatantly insufficient to prove Venezuela’s allegation, that
Rusoro knowingly colluded with domestic purchasers to foster illicit gold exports.
499. (ii) The second leg of Rusoro’s contention is that the 2009 and 2010 Measures were
adopted to combat illegal exports.
500. Again, the evidentiary underpinning of this allegation is inexistent: the Measures
themselves fail to state (in their preambles or otherwise) that their purpose was to
combat illegal gold exports; and the Republic has not drawn the Tribunal’s attention
to any contemporary memorandum, report or public statement confirming the
Republic’s averment.
501. The very content of the 2009 and 2010 Measures disproves the Republic’s
contention: If Venezuela’s true aim had been to limit illegal exports, the natural
course of action would have been to reinforce the supervisory capacity of the
Ministry of Mines and of the BCV, to intensify reporting requirements and to
increase sanctions for improper behaviour. None of these measures was adopted.
The fundamental innovation introduced by the 2009 and 2010 Measures was to put
producers under a compulsory obligation to sell a percentage of their production to
the BCV, at a price in VEF converted at the Official Exchange Rate – a measure
which permitted the BCV to increase its holdings of gold paying a price which was
lower than the price which would have accrued if the market exchange rate had
been applied.
B. Art. X of the BIT
502. Art. X of the BIT provides as follows:
“Investment in Financial Services
Nothing in this Agreement shall be construed to prevent a Contracting Party
from adopting or maintaining reasonable measures for prudential reasons,
such as:
(a) The protection of investors, depositors, financial market participants,
policy-holders, policy-claimants, or persons to whom a fiduciary duty is
owed by a financial institution;
(b) The maintenance of the safety, soundness, integrity or financial
responsibility of financial institutions; and
(c) Ensuring the integrity and stability of a Contracting Party’s financial
system”.
503. Art. XII(13) adds the following possibility:
“Where and investor submits a claim to arbitration and the disputing
Contracting Party alleges as a defense that the measure in question is
a reasonable measure for prudential reasons of the kind referred to in
Article X, or
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ANNEX 95

PCA Case No. 2016-39
IN THE MATTER OF AN ARBITRATION UNDER THE AGREEMENT BETWEEN THE
GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN
IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF BOLIVIA FOR THE
PROMOTION AND PROTECTION OF INVESTMENTS, SIGNED ON 24MAY 1988
- and -
THE UNCITRAL ARBITRATION RULES 2010
- between -
GLENCORE FINANCE (BERMUDA) LIMITED
(the “Claimant”)
- and -
THE PLURINATIONAL STATE OF BOLIVIA
(the “Respondent”, and together with the Claimant, the “Parties”)
________________________________________________________
PROCEDURAL ORDER NO. 2:
DECISION ON BIFURCATION
_______________________________________________________
Tribunal
Prof. Ricardo Ramírez Hernández (Presiding Arbitrator)
Prof. John Y. Gotanda
Prof. Philippe Sands
Registry
Permanent Court of Arbitration
31 January 2018
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TABLE OF CONTENTS
I. PROCEDURAL BACKGROUND............................................................................................................3
II. RESPONDENT’S OBJECTIONS TO JURISDICTION AND ADMISSIBILITY...............................4
A. CLAIMANT’S POSITION ......................................................................................................4
1. Consent to arbitration ..................................................................................................4
2. Jurisdiction ratione temporis........................................................................................5
3. The Claimant’s investments and their legality...........................................................5
4. Abuse of process............................................................................................................5
5. The Claimant’s Swiss ownership.................................................................................6
B. RESPONDENT’S POSITION ..................................................................................................6
1. The Claimant’s alleged investments............................................................................6
2. The legality of the Claimant’s alleged investments....................................................7
3. Abuse of Process ...........................................................................................................7
4. The Claimant’s Swiss ownership.................................................................................8
5. The conflicting ICC arbitration clauses and waiver of diplomatic claims ..............9
6. The Tin Stock claims were never notified to Bolivia .................................................9
III. RESPONDENT’S REQUEST FOR BIFURCATION.............................................................................9
A. CLAIMANT’S POSITION ......................................................................................................9
B. RESPONDENT’S POSITION ................................................................................................10
IV. ANALYSIS OF THE TRIBUNAL ..........................................................................................................11
A. APPLICABLE STANDARD...................................................................................................11
B. QUALIFICATION AS INVESTOR.........................................................................................12
C. ABUSE OF PROCESS...........................................................................................................13
D. CLEAN HANDS ...................................................................................................................13
E. PIERCING THE CORPORATE VEIL AND INDIRECT INVESTMENT.....................................14
F. ICC ARBITRATION ...........................................................................................................16
G. TIN STOCK ........................................................................................................................16
H. CONCLUSION ....................................................................................................................17
V. DECISION.................................................................................................................................................17
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I. PROCEDURAL BACKGROUND
1. By Notice of Arbitration dated 19 July 2016, the Claimant initiated this arbitration pursuant to
the UNCITRAL Arbitration Rules and Article 8 of the Agreement between the Government of
the United Kingdom of England and Northern Ireland and the Government of the Republic of
Bolivia for the Promotion and Protection of Investments, signed on 24 May 1988 (the “Treaty”).
2. On 18 August 2016, the Respondent submitted its Response to the Notice of Arbitration, which
included a request for bifurcation of the proceedings.
3. By letter dated 8 March 2017, the PCA circulated on behalf of the Tribunal Draft Terms of
Appointment and Draft Procedural Order No. 1, and invited the Parties to submit their comments
thereon.
4. By e-mail of 24 March 2017, the Claimant submitted the Parties’ comments on the Draft Terms
of Appointment and Draft Procedural Order No. 1, as confirmed by the Respondent’s e-mail of
the same date. The Respondent included a request for bifurcation of the proceedings in its
comments on the procedural calendar.
5. By letter dated 29 March 2017, the Tribunal issued the Terms of Appointment and invited the
Parties to set out in more detail their positions regarding, inter alia, the question of the bifurcation
of the proceedings.
6. On 3 and 14 April 2017, the Parties provided their further comments on the bifurcation of the
proceedings. The Respondent argued that the Tribunal should already decide on its request for
bifurcation, while the Claimant contended that only after the submissions of the Statement of
Claim would the Tribunal be able to properly assess whether to bifurcate the proceedings.
7. On 15 May 2017, a First Procedural Meeting was held by conference-call, during which the
Parties provided further comments on Draft Procedural Order No. 1.
8. On 31 May 2017, the Tribunal issued Procedural Order No. 1, including a timetable for the
arbitration. In particular, the Tribunal decided that it would only rule on the Respondent’s request
for bifurcation after the receipt of the Statements of Claim and Defence and, potentially, a hearing
on bifurcation.
9. On 15 August 2017, the Claimant filed its Statement of Claim including the Claimant’s
Response to the Respondent’s Request for Bifurcation.
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10. By letter dated 11 December 2017, the PCA informed the Parties that the Tribunal had decided
not to hold a hearing on bifurcation.
11. On 18 December 2017, the Respondent filed its Statement of Defence including all objections
to the Tribunal’s jurisdiction, as well as the Respondent’s Reply on Bifurcation. In the covering
letter to its submission, the Respondent requested that the Tribunal reconsider its decision not to
hold a hearing on bifurcation.
12. By letter dated 27 December 2017, the Claimant opposed the Respondent’s request to hold a
hearing on bifurcation.
II. RESPONDENT’S OBJECTIONS TO JURISDICTION AND ADMISSIBILITY
A. CLAIMANT’S POSITION
1. Consent to arbitration
13. The Claimant asserts that Bolivia has expressly and unequivocally consented to resolve
investment disputes with UK investors through international arbitration by way of Article 8 of the
Treaty, which provides in relevant part as follows:
If after a period of six months from written notification of the claim there is no agreement to
an alternative procedure, the parties to the dispute shall be bound to submit it to arbitration
under the Arbitration Rules of the United Nations Commission on International Trade Law
as then in force. 1
14. The Claimant contends that all requirements in terms of jurisdiction and admissibility set out by
Article 8 are met: (i) a dispute exists between Glencore Bermuda (a national of one Contracting
Party) and Bolivia (the other Contracting Party) concerning the obligations of the latter under the
Treaty in relation to investments made by Glencore Bermuda in Bolivia; (ii) in its written notices
dated 11 December 2007, 14 May 2010, and 27 June 2012 Glencore Bermuda formally notified
Bolivia of the existence of the dispute pursuant to Article 8 of the Treaty; (iii) Glencore Bermuda
repeatedly sought to resolve the dispute amicably but no satisfactory response was ever received
from the Bolivian Government; and (iv) more than six months have elapsed since Glencore
Bermuda notified Bolivia of the existence of the dispute in relation to each of the nationalizations
and the dispute remains. 2
1 Statement of Claim ¶ 133; C-1, Treaty, Article 8.
2 Statement of Claim ¶¶ 134-137.
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2. Jurisdiction ratione temporis
15. The Claimant notes that the Treaty was signed on 24 May 1988, entered into force on 16 February
1990, and was extended to the United Kingdom overseas territory of Bermuda on 9 December
1992 pursuant to an exchange of notes. 3 While the Respondent denounced the Treaty with effect
from May 2014, the Claimant asserts that all of its investments were made in prior to Bolivia’s
denunciation and therefore continue to benefit from its protection according to Article 13 of the
Treaty. 4
3. The Claimant’s investments and their legality
16. The Claimant argues that its indirect shareholding in Vinto and Colquiri and stake in the Colquiri
Lease, the Smelters, and the Tin Stock constitute protected investments under Articles 1(a)(i) and
1(a)(ii) of the Treaty.5 The Claimant disputes that its investment must meet any additional
requirements such as contribution to the host State’s development, but argues that it meets such
additional requirements in any event.6
17. The Claimant further argues that the Respondent’s allegations that Glencore Bermuda’s
investments were “unlawfully” acquired is inconsistent with contemporaneous evidence.7 The
Claimant also notes that there was no further investigation, formal accusation, or judicial
proceeding ever brought against Glencore regarding the alleged illegality of the investments.8
4. Abuse of process
18. In response to the Respondent’s abuse of process objection, the Claimant affirms that the
investments were acquired through a competitive international bidding process organized by a
reputable firm specializing in the mining sector; the assets were held by Panamanian Companies
and CDC (a development finance institution entirely owned by the UK government); and the
transaction also involved assets located in Argentina.9 Furthermore, even if the transaction were
3 Statement of Claim ¶ 125; Exchange of Notes, December 3, 1992, and December 9, 1992, pursuant to which the
Treaty was extended to Bermuda and other territories, C-2.
4 Statement of Claim ¶¶ 125-126.
5 Statement of Claim ¶¶ 129-132, 311.
6 Statement of Claim ¶ 311.
7 Statement of Claim ¶¶ 322-324.
8 Statement of Claim ¶ 323.
9 Statement of Claim ¶¶ 316-317.
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considered a “restructuring” with the aim of obtaining treaty protection, the Claimant argues that
Glencore Bermuda’s acquisitions took place in March 2005, before any of the challenged
measures had occurred or were even foreseeable.10
5. The Claimant’s Swiss ownership
19. According to the Claimant, in order to qualify as a protected investor, the Treaty requires only
that a company be “incorporated or constituted” in the territory of one of the State parties, and it
has shown that Glencore Bermuda is a company incorporated under the laws of Bermuda.11 The
Claimant maintains that arbitral tribunals “have universally rejected similar jurisdictional
objections based on allegations that the claimant was a ‘shell company’ where the applicable BIT
merely required the claimant to be ‘incorporated’ or ‘constituted’ in a territory to be considered a
protected investor.”12
20. The Claimant further argues that, even if it were relevant, Glencore Bermuda—which “has
historically been the holding company for the vast majority of Glencore’s international
investments, including those in Latin America”—is not a shell company.13 Furthermore, the
Claimant asserts that Glencore International would have enjoyed protection under the
Switzerland-Bolivia BIT, such that its restructuring was immaterial.14
B. RESPONDENT’S POSITION
1. The Claimant’s alleged investments
21. The Respondent argues that an investor is entitled to protection under the Treaty only if it
“actively invests” in the territory of a contracting party, and that Glencore Bermuda made no
investment in Bolivia, but “merely held legal title to assets for which it made no payment and to
which it made no further contribution.”15
10 Statement of Claim ¶¶ 318-320.
11 Statement of Claim ¶¶ 127-128, 310-312.
12 Statement of Claim ¶ 313.
13 Statement of Claim ¶ 314.
14 Statement of Claim ¶ 314.
15 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 258-292.
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2. The legality of the Claimant’s alleged investments
22. The Respondent argues that it is a generally accepted principle of investment arbitration that a
tribunal cannot hear claims regarding an investment tainted by illegality.16 The Respondent argues
that the privatization process was riddled with illegalities as the legal framework for the
privatization of the Colquiri Mine Lease and the Antimony Smelter was established by former
President Sánchez de Lozada to benefit his own economic interests in breach of the Bolivian
constitution.17 In particular, the Respondent argues that the prices paid for the Smelters and the
Colquiri Lease are inexplicably low.18 According to the Respondent, the Claimant could not have
been unaware of these facts when it acquired the Smelters and the Colquiri Lease.
3. Abuse of Process
23. The Respondent claims that “a change of ownership structure when there is a reasonable prospect
of a dispute constitutes an abuse of process, requiring that claims be dismissed, whenever the
change had a purpose of obtaining investment treaty protection”.19
24. The Respondent affirms that the disputes were “clearly foreseeable, and in fact foreseen” in 2005
when Glencore International transferred the assets to Glencore Bermuda.20 The Respondent
recalls that Glencore International took out political risk insurance for the Smelters and Colquiri
Lease to guard against exactly the sort of expropriation that it now claims to have suffered.21
Moreover, the Respondent notes that, at the time of the acquisition in 2005, Evo Morales was
posed to assume presidency and it was clearly foreseeable that he “would be less indulgent of
private mining interests and would ensure complete respect for the law and the diverse social
interests affected by the mining industry.”22 The Respondent also submits that the Claimant was
aware that various actors had been publicly questioning the legality of the Tin Smelter
privatization since 2002, that the failure to put the Antimony Smelter into operation in accordance
16 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 325, 338-345.
17 See Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 326-329.
18 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 330-337.
19 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 293-304.
20 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 306.
21 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 307.
22 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 308-310.
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with the contractual terms would give rise to a dispute, and that the Respondent would likely have
to intervene in the growing dispute with cooperativistas at the Colquiri mine.23
25. The Respondent adds that the Claimant has not provided any other justification for such transfer
than to obtain Treaty protection, and that it is not true that Glencore International would benefit
from protection under the Switzerland-Bolivia BIT given that treaty’s requirement of “a
substantial Swiss interest”.24 The Respondent argues that there is no substantial Swiss interest in
the Glencore group, which has widely dispersed shareholding by a range of global funds.25
4. The Claimant’s Swiss ownership
26. The Respondent denies that formal incorporation in Bermuda suffices to establish jurisdiction,
given that the investors “are purely Swiss in substantive reality”.26 The Respondent refers to the
released “Paradise Papers” which show that “Glencore Bermuda exists only in a nearly empty
room that “held a filing cabinet, a computer, a telephone, a fax machine and a checkbook” at the
Glencore Group’s Bermudan law firm.27
27. On the other hand, if the Claimant’s corporate veil cannot be pierced, the Respondent then argues
that the Claimant should not be allowed to submit claims based on the indirectly held rights of its
subsidiaries.28 The Respondent argues that, in contrast to other contemporaneous investment
treaties (such as the Switzerland-Bolivia BIT) which extend jurisdiction to indirect investments,
the UK-Bolivia Treaty does not make an exception to the otherwise applicable customary rule
pursuant to which a shareholder may not substitute itself for the company in which it holds
shares.29
23 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 312-319.
24 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 320-324; Agreement
between the Swiss Confederation and the Republic of Bolivia on the reciprocal promotion and protection of
investments, English translation, Article 1(b)(aa), RLA-19.
25 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 323; Morningstar, Glencore
PLC Major Shareholders, R-236.
26 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 348-359.
27 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 360-369, quoting
International Consortium of Investigative Journalists, Room of Secrets Reveals Glencore’s Mysteries, press article
of 5 November 2017, R-243, pp. 1-7.
28 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 351, 370-371.
29 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 372-384.
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5. The conflicting ICC arbitration clauses and waiver of diplomatic claims
28. The Respondent argues that Claimant’s claims ultimately concern the Tin Smelter, Antinomy
Smelter, and Colquiri Lease contracts (the “Contracts”), and are therefore subject to the
mandatory ICC arbitration clauses and waivers of diplomatic remedies contained in those
Contracts.30 The Respondent points out that the Claimant itself invokes the Contracts in support
of its claims.31
6. The Tin Stock claims were never notified to Bolivia
29. The Respondent asserts that the Claimant never notified Bolivia about the existence of potential
claims concerning the Tin Stock as required under Article 8(1) of the Treaty.32 The Respondent
considers that the claims regarding the Tin Stock are distinct from the Claimant’s other claims
and that the absence of prior notification deprives the Tribunal of jurisdiction over these claims.33
III. RESPONDENT’S REQUEST FOR BIFURCATION
A. CLAIMANT’S POSITION
30. The Claimant contends that, contrary to the Respondent’s allegations, bifurcation is not favoured
under the UNCITRAL Rules, nor it is the general practice of international tribunals.34 Rather,
according to the Claimant, efficiency is the overarching basis for deciding on bifurcation
requests.35 In particular, the Claimant relies on Glamis Gold to argue that the relevant criteria are
the likelihood of success of the jurisdictional objections and whether they can be decided without
examining the merits of the case.36
31. As regards the first criterion, the Claimant argues that the chances of the Respondent’s objections
prevailing are minimal, such that bifurcation will only lead to unwarranted delay and expense.37
30 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 385-392.
31 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 393-399.
32 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 400-404.
33 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 405-411.
34 Statement of Claim ¶¶ 300-305.
35 Statement of Claim ¶¶ 299, 306.
36 Statement of Claim ¶¶ 306-307; Glamis Gold Ltd v United States (UNCITRAL) Procedural Order No. 2, 31
May 2005, CLA-58, para 12(c).
37 Statement of Claim ¶¶ 309, 325-328.
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The Claimant adds that bifurcation may give rise to costly and time-consuming parallel
proceedings if either party challenges a decision on jurisdiction before the Paris courts.38
32. As for the second criterion, the Claimant asserts that the Respondent’s jurisdictional objections
are “inherently factual and cannot be divided from the merits of the dispute”.39 According to the
Claimant, in order to decide the Respondent’s objections, the Tribunal will have to investigate
many of the same facts and legal arguments from the same witnesses that the Parties will develop
when discussing their substantive claims and defenses.40 In particular, the Claimant argues that
bifurcation of the Respondent’s objection will require duplicative testimony from Mr. Eskdale on
various issues.41
33. Accordingly, the Claimant requests that the Respondent’s bifurcation request be dismissed.42
B. RESPONDENT’S POSITION
34. The Respondent submits that it is a well-established rule in international arbitration that, when
jurisdictional objections are well-founded and may be separated from the merits of the dispute,
the Tribunal should proceed to decide such objections as a preliminary matter.43 The Respondent
argues that “it is fundamentally unjust, and even contrary to fundamental legal principles, to
demand that a state defend itself against the merits of a claim before a tribunal without jurisdiction
or where that jurisdiction is in dispute.”44 According to the Respondent, efficiency is but an
additional consideration that militates in favour of bifurcation.45 The Respondent therefore argues
that the Tribunal should apply the three criteria set out in Philip Morris v. Australia, namely (i)
whether the objections are prima facie serious and substantial, (ii) whether the objection can be
38 Statement of Claim ¶ 327.
39 Statement of Claim ¶ 325.
40 Statement of Claim ¶ 325.
41 Statement of Claim ¶¶ 315, 321, 324.
42 Statement of Claim ¶ 326.
43 Response to the Notice of Arbitration ¶ 51.
44 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 416-420.
45 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 421-428.
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examined without prejudging or entering the merits, and (iii) whether the objection, if successful,
would dispose of all or an essential part of the claims raised.46
35. The Respondent argues that its preliminary objections clearly meet the Philip Morris criteria
since, if any of them were granted (with the exception of the failure to notify the dispute over the
Tin Stock), it would bring an immediate end to the entire arbitration proceeding.47 They are also
serious and substantial as they are backed by extensive legal authorities and factual exhibits, and
they are entirely separable from the merits of the dispute: “the core facts for the objections extend
only through when Glencore Bermuda received the Assets in 2005, while the core merits facts are
from events in 2007, 2010, 2012, and beyond”.48
36. The Respondent further contends that the Claimant does not explain why the Respondent’s
preliminary objections are said to be interlinked with the merits, and that the fact that Mr. Eskdale
would testify both as to facts relevant to jurisdiction and facts relevant to the merits does not
create such a linkage.49
37. Accordingly, the Respondent requests that its preliminary objections be decided in a bifurcated
preliminary phase.50
IV. ANALYSIS OF THE TRIBUNAL
A. APPLICABLE STANDARD
38. The Tribunal begins its analysis by setting out the applicable standard in relation to the issue of
application as raised in this case. Articles 17.1 and 23.3 of the UNCITRAL Rules give discretion
to the Tribunal to decide jurisdictional objections. Neither of those provisions imposes a
presumption in favor or against bifurcation. Thus, in accordance with Article 17.1, the
overarching principle that shall guide the Tribunal’s decision is procedural fairness and efficiency,
having regard to the totality of circumstances.
46 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 429 quoting CLA-121,
Philip Morris Asia Limited v Commonwealth of Australia (UNCITRAL) Procedural Order No 8 of 14 April 2014
¶ 109.
47 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 431.
48 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶¶ 431-436.
49 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 438.
50 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 440.
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39. With this principle in mind, the Parties appear to agree that the proper factors or criteria to be
taken into account are the ones used by the tribunals in Philip Morris Asia Limited v
Commonwealth of Australia51 and Glamis Gold Ltd v United States52. Although framed
somewhat differently, both Tribunals seemed to consider the same factors or criteria, i.e.:
a) Whether the request is substantial or is the objection prima facie serious and substantial?
b) Whether the request, if granted, would lead to a material reduction in the proceedings at the
next stage or could the objection, if successful, dispose of all or an essential part of the claims
raised?;
c) Whether bifurcation is impractical in the sense that the issues are too intertwined with the merit
that it is very unlikely that there will be any savings in time or cost or can the objection be
examined without prejudging or entering the merits?
40. With these criteria in mind, the Tribunal will now address each of the objections raised by the
Respondent:
B. QUALIFICATION AS INVESTOR
41. The first allegation is that the Claimant made no investment in Bolivia. Bolivia is arguing that the
scope of the treaty extends only to companies which “actively” invested in Bolivia. According to
Respondent, given that Glencore Bermuda made no investment in Bolivia, the investor does not
have a claim under the applicable BIT. On the other hand, Claimant argues that the treaty only
“requires a company to be ‘incorporated or constituted’ in the territory of one of the State parties”
and that it does not require any requirement of “seat or material business presence in the State”53.
42. Before addressing the issue of whether the objection is serious and substantial, the Tribunal
confirms that, at this stage of the proceedings, its task is not to decide on the merits. Turning to
the objection, however, the Tribunal finds, on the basis of the material before it at this stage, no
clear textual support in the applicable BIT for the proposition that this agreement requires material
or active presence for a company to qualify as investor. Thus, although the Tribunal recognizes
that the objection is not frivolous, and the contextual arguments posed by the Respondent in this
regard are capable of being argued and worth exploring in depth, it is not convinced that this
51 Philip Morris Asia Limited v Commonwealth of Australia (UNCITRAL) Procedural Order No 8,
14 April 2014.
52 Glamis Gold Ltd v. United States of America, (UNCITRAL) (Procedural Order No.2
(Revised), May, 31, 2005.
53 Statement of Claim ¶ 311.
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objection is sufficiently serious and substantial as to justify bifurcation. In light of this view, the
Tribunal will not address the other two criteria.
C. ABUSE OF PROCESS
43. The second allegation is that the Claimant committed abuse of process in bringing this arbitration.
Respondent alleges that the Tribunal lacks jurisdiction because Glencore Bermuda committed an
abuse of process by structuring an investment in order to obtain standing. Respondent argues that
Glencore International “rerouted” its investment through Bermuda when a dispute with Bolivia
was foreseeable. On the other hand, Claimant argues that Glencore Bermuda’s “acquisition of its
investments in Bolivia was not a ‘restructuring’ with the purpose of providing treaty protection”54.
Moreover even if that was the purpose, the Claimant argues that there could only be abuse of
process “in very exceptional circumstances”, that is when “the purpose of the restructuring was
exclusively obtaining treaty protection”55.
44. The Tribunal notes that it is not disputed that Glencore International was the company that
acquired/leased the disputed assets and that Glencore Bermuda acquisition started in March 2005.
It is also not disputed that the first alleged breach occurred in February 2007 (Vinto’s
nationalization). Notwithstanding the time gap between the acquisition of the investment and the
first alleged breach, valid questions arise as to the purpose of restructuring the investment as well
as whether the investor could foresee that a dispute was going to arise. Based on this, the Tribunal
finds that this exception is serious and substantial. As to the second element, it is clear that, if
successful, these proceeding would be brought to an end. As to the third element, almost all the
facts relevant for this claim predated February 2007, which is the date when the dispute
presumably arose. Thus, it seems that the objection can be addressed without prejudging the
merits.
D. CLEAN HANDS
45. The third objection deals with the allegation that the privatization of the assets underlying the
claim was illegal under Bolivian law. The Respondent alleges that the acquisition of the Colquiri
Mine Lease and the Antimony Smelter were contrary to the Bolivian Constitution. Bolivia also
argues that the “circumstances surrounding the privatization of the Assets were contrary to basic
54 Statement of Claim ¶ 317.
55 Statement of Claim ¶ 318.
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requirement of transparency and good faith.”56 Based on this, Bolivia claims that, in accordance
with the “clean hands” principle, “Claimant cannot present for adjudication before this Tribunal
claims tainted by the illegality which Claimant was aware of when it received the Assets”57.
Claimant argues that “the assets were lawfully awarded to private investors through public tender
processes.”58
46. Regarding the “clean hands” principle, the Tribunal agrees with the tribunal in Churchill Mining
who rightly pointed out that:
The common law doctrine of unclean hands barring claims based on illegal conduct
has also found expression at the international level, although its status and exact
contours are subject to debate and have been approached differently by international
tribunals.59
47. In reaching a decision on this objection, the Tribunal will not only have to accept this principle
and determine its status, but also lay out its contours. Thus, it is difficult to come to a definitive
view without a clear standard against which the substantiality and seriousness of this objection
could be assessed. In this regard, the Tribunal has doubts as to whether a mere assertion of
unlawful conduct could be enough to raise this objection above the required threshold. However,
even accepting that the objection is serious and substantial, quod non, it is conceivable that the
alleged illegalities would be part of the defense of the Respondent against breaches of the BIT.
Thus, it seems that this objection cannot be addressed without touching on the merits of this
dispute.
E. PIERCING THE CORPORATE VEIL AND INDIRECT INVESTMENT
48. The fourth jurisdiction objection relates to the claim that, in reality, the Claimant is a Swiss
company and, therefore, not subject to the protection of the BIT. Respondent claims that the BIT
excludes jurisdiction asserted based on corporate formalities when the real party in interest is not
protected. Respondent requests to pierce the corporate veil because Glencore Bermuda is an
“empty shell”. In the alternative, the Respondent claims that, even if the corporate veil protects
Glencore Bermuda, international law does not allow it to bring claims for its indirect investment.
56 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 337.
57 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 338.
58 Statement of Claim ¶ 323.
59 Churchill Mining PLC and Planet Mining Pty Ltd v. Republic of Indonesia, ICSID Case No. ARB/12/14 and
12/40, Award of 6 December 2016, ¶ 493.
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Conversely, the Claimant argues that Bolivia’s argument has no foundation in the facts or in the
text of the Treaty and that Glencore Bermuda has submitted sufficient evidence that it is a
company incorporated under the laws of Bermuda (one of the United Kingdom overseas territories
to which the Treaty was expressly extended) with “investments” protected under the Treaty.
49. Turning to the first objection, the Tribunal finds also no clear textual support in the applicable
BIT for the proposition that this agreement requires material or active presence for a company to
qualify as investor. In addition, the Tribunal is not sure that the case quoted by the Respondent is
applicable in this context since that case was dealing with the interpretation of “foreign control”
set forth in Article 25(2)(b) of the ICSID Convention.60 In fact, another of the cases cited by
Respondent takes the opposing view:
As the matter of nationality is settled unambiguously by the Convention and the BIT,
there is no scope for consideration of customary law principles of nationality, as
reflected in Barcelona Traction, which in any event are no different. In either case
inquiry stops upon establishment of the State of incorporation, and considerations
of whence comes the company’s capital and whose nationals, if not Cypriot, control
it are irrelevant.61
50. Thus, although the Tribunal recognizes that the objection is not frivolous, and the arguments
posed by the Respondent in this regard are capable of being argued and worth exploring in depth,
it is not convinced that this objection is sufficiently serious and substantial as to justify
bifurcation.
51. Turning to the alternative objection, the Respondent argues that the ownership in the relevant
assets is “indirect”,62 and therefore, since the BIT does not include indirect investment, Glencore
Bermuda is precluded from bringing this case. Although the Respondent makes a valid argument
that some investment treaties have traditionally distinguished between direct or indirect
investment and in this case the applicable BIT does not include indirect investment, no textual
basis or precedent is cited as to an investment tribunal who has made this distinction and
dismissed a case on this ground. Thus, the Tribunal is not convinced that these objections are
60 TSA Spectrum de Argentina S.A. v. Argentine Republic, ICSID Case No. ARB/05/5, Award of 19 December
2008.
61 ADC Affiliate Limited and ADC & ADMC Management Limited v Republic of Hungary (ICSID Case No
ARB/03/16) Award of the Tribunal of 2 October 2006, ¶ 357.
62 Glencore Bermuda holds shares in Kempsey, Iris, and Shattuck, three Panamanian companies, which in turn
own Colquiri through Sinchi Wayra. Colquiri directly owns the Assets (or Vinto, owned by Colquiri, in the case
of the Tin Smelter).
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sufficiently serious and substantial as to justify bifurcation. Considering this view, the Tribunal
does not consider necessary to address the other two factors.
F. ICC ARBITRATION
52. The fifth objection relates to the claim that the Tribunal does not have jurisdiction over the
contract claim. The Respondent argues that the Claimant ignored the arbitration clauses in the
relevant contracts which required ICC arbitration adjudication. The Claimant responds that this
dispute “concerns the propriety of actions taken by the State in its sovereign capacity—it does
not, as Bolivia attempts to argue, concern contractual breaches.”63
53. The Tribunal has difficulty understanding how the alleged breaches by Respondent are entirely
contractual in nature. Moreover, even accepting that the objection is serious and substantial, the
Tribunal believes that the facts related to this objection are too intertwined with the merits of the
case and addressing this claim could touch on and prejudge the merits of the dispute.
G. TIN STOCK
54. Finally, the Respondent argues that the Tribunal lacks jurisdiction over the Tin Stock claims
because they were never notified to Bolivia. The Respondent alleges that “Claimant never
provided Bolivia with written notification of its Tin Stock claims, depriving Bolivia of the
opportunity to reach an amicable resolution of those claims”64. The Claimant argues that since
2010 Bolivia took the position that “Tin Stock formed part of the nationalized Antimony
Smelter’s inventory and its return would be addressed in the context of the negotiations to be held
in relation to the nationalization”65
55. The Tribunal finds that this is an ancillary claim that cannot, of itself, justify bifurcation. Even
Respondent concedes that, if successful, it would not bring the dispute to an end, nor dispose of
an essential part of the claims raised, nor even lead to a material reduction in the proceedings at
the next stage.66 Therefore, the Tribunal dismisses this ground for bifurcation.
63 Letter in response to concerns expressed by the Bolivia with respect to the Tribunal’s decision to cancel the
hearing on bifurcation. December 27, 2017. At page 4.
64 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 404.
65 Letter in response to concerns expressed by the Bolivia with respect to the Tribunal’s decision to cancel the
hearing on bifurcation. December 27, 2017. At page 8.
66 Bolivia’s Preliminary Objections, Statement of Defence and Reply on Bifurcation ¶ 431.
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H. CONCLUSION
56. After reviewing each of the preliminary objections, the Tribunal’s analysis reveals that the abuse
of process objection, but only that objection, could justify the bifurcation of the proceedings.
Nevertheless, the Tribunal recalls that the overarching principle is the fairness and efficiency of
this process as a whole. With this principle in mind, the Tribunal considers that it would be more
efficient to deal with all preliminary objections together with liability in a first phase, and leave
issues of damages, if any, for determination in a second phase. This approach seems to the
Tribunal more efficient in terms of time and costs than the alternative, which is to bifurcate just
one issue but leave all other objections to a merits phase. Finally, the Tribunal wishes to stress
that the ultimate outcome of the objections will be a factor that the Tribunal may take into account
when awarding costs in this arbitration.
57. The Tribunal has considered the positions and preferences of the Parties with regards to the
procedural timetable to follow in these proceedings. After deliberation, the Tribunal has adopted
the procedural calendar attached to this order as Annex 1.
58. Pursuant to Procedural Order No. 1, document production requests submitted to the Tribunal for
decision, together with objections and responses, must be in tabular form pursuant to the model
appended to this Procedural Order as Annex 2 (modified Redfern schedule). The Parties shall use
the model format throughout their exchange of requests, objections, and responses.
V. DECISION
59. For these reasons, the Tribunal, decides to hear the Parties’ submissions regarding jurisdiction
and admissibility together with their submissions on the merits, while bifurcating the proceedings
with regards to quantum to a later phase of proceedings, if the need for such a later phase arises.
60. The Tribunal establishes the procedural calendar attached to this order as Annex 1.
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____________________________
Prof. Ricardo Ramírez Hernández
(Presiding Arbitrator)
On behalf of the Tribunal
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Annex 1: Procedural calendar
Event Party Date
Simultaneous Document
Production Requests
Both 9 February 2018
(21 days)
Production of undisputed
documents and Objections to
production
Both 2 March 2018
(21 days from Document
Production Requests)
Replies to Objections to
production and reasoned
applications for an order on
Production of Documents in
the form of a Redfern Schedule
(Annex 2)
Both 16 March 2018
(14 days from Objections to
Production)
Tribunal’s decision on
Document Production
Tribunal 26 March 2018
(10 days from submission of
Redfern Schedule)
Production of the disputed
documents pursuant to the
Tribunal’s decision
Both 16 April 2018
(21 days from the Tribunal’s
Decision on Document
Production Requests)
Claimant’s Reply on the Merits
and Counter-Memorial on
Jurisdictional Objections (if
any)
Claimant 18 June 2018
(150 days from the Tribunal’s
Decision on Bifurcation and 63
days from the Tribunal’s
Decision on Document
Production)
Respondent’s Rejoinder on the
Merits and Reply on
Jurisdictional Objections (if
any)
Respondent 16 October 2018
(120 days from the Claimant’s
Reply)
Claimant’s Rejoinder on
Jurisdiction (if any)
Claimant 14 January 2019
(90 days from the
Respondent’s Rejoinder)
Submissions of the
Notifications to the witnesses
and experts called to appear at
Hearing
Both 28 January 2019
(14 days from the Claimant’s
Rejoinder)
Pre-Hearing Conference Call All Week of 4 February 2019
Hearing All One-week period, at some
point between 11 March and 6
May 2019
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Annex 2: Model Redfern Schedule for Document Requests
No. Documents or category
of documents requested
(requesting Party)
Relevance and materiality, incl.
references to submission
(requesting Party)
Reasoned objections to
document production request
(objecting Party)
Response to objections to
document production
request
(requesting Party)
Decision
(Tribunal)
References to
Submissions,
Exhibits,
Witness
Statements or
Expert
Reports
Comments
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ANNEX 96

Annex 96
Annex 96
Annex 96
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ANNEX 97

Annex 97
Annex 97
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ANNEX 98

REPORTS OF INTERNATIONAL
ARBITRAL AWARDS
RECUEIL DES SENTENCES
ARBITRALES
Commission established under the Convention concluded between the
United States of America and Ecuador on 25 January 1862
Cases of the Good Return and the Medea, opinion of the Commissioner, Mr. Hassaurek, of
8 August 1865
Commission établie par la Convention conclue entre les
États-Unis d’Amérique et l’Equateur le 25 janvier 1862
Les affaires Good Return et Medea, opinion du Commissaire, M. Hassaurek, du
8 août 1865
8 August 1865
VOLUME XXIX, pp.99-108
NATIONS UNIES - UNITED NATIONS
Copyright (c) 2012
Annex 98
Commission established under the Convention
concluded between the United States of America and
Ecuador on 25 January 1862
Commission établie par la Convention conclue
entre les États-Unis d’Amérique et l’Equateur
le 25 janvier 1862
Cases of the Good Return and the Medea, opinion of the
Commissioner, Mr. Hassaurek, of 8 August 18651
Les affaires Good Return et Medea, opinion du Commissaire,
M. Hassaurek, du 8 août 18652
Non-recognition of the obligation of a commission to follow a decision of another
commission in an identical case.
Obligations of the commissioners —they should be bound by their own conscience
and the oath they have taken—they should not consider themselves as the
attorneys for either country, but the judges appointed for the purpose of deciding the
questions submitted to them, impartially, according to law and justice—they should
not be bound by the actions their Governments may have taken on former occasions
in each individual case.
Obligation of the party who asks for redress to present itself with clean hands—
its cause of action must not be based on an offence against the Government to whom
it appeals for redress—contrary to public morality and legislative policy for a State
to uphold or endeavour to enforce a claim founded on a violation of its own laws and
treaties.
Recognition of neutrality laws as reiterations of a principle of natural law.
Consequences of the neutrality of a nation for its citizens—limits of national protection
and rejection of claims for lack of jurisdiction by an international commission
if citizens of neutral nations violated the observance of neutrality.
Recognition of a citizen of a neutral State, acting as a privateer for the belligerent
nation conducting a war against the State with whom the neutral State is at peace, as a
pirate liable to be prosecuted and punished.
1 Reprinted from John Bassett Moore (ed.), History and Digest of the International
Arbitrations to Which the United States has been a Party, vol. III, Washington, 1898, Government
Printing Office, p. 2731.
2 Reproduit de John Bassett Moore (éd.), History and Digest of the International
Arbitrations to Which the United States has been a Party, vol. III, Washington, 1898, Government
Printing Office, p. 2731.
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100 united states/ecuador
Determination of the captain’s nationality, as far as the captain’s claim regarding
the captures as a privateer is concerned, by the captain’s commission and by the flag of
the belligerent under which the captain fought.
Recognition of a rule stipulating that the title to a prize originally vests in the
Government represented by the captor during war, whose rights are subsequently
ascertained by judicial decisions
Non-reconnaissance d’une obligation pour la commission de se conformer à la
décision d’une autre commission dans une affaire identique.
Obligations des commissaires—ils doivent être liés par leur propre conscience
et le serment qu’ils ont prêté—ils ne doivent pas se considérer comme les avocats d’un
quelconque pays, mais comme des juges nommés afin de décider des questions qui leur
ont été soumises, de façon impartiale, en application du droit et de la justice—pour
chaque cas particulier, ils ne doivent pas être liés par les actions entreprises par leurs
gouvernements à d’autres occasions.
Obligation de la partie qui demande réparation de se présenter avec les mains
propres—la cause de sa demande ne doit pas être fondée sur une offense à l’encontre du
gouvernement auquel elle fait appel pour obtenir réparation, le soutien ou la tentative
de réalisation par un État d’un droit à réparation fondé sur une violation de ses propres
lois et traités est contraire à la moralité publique et à la politique législative.
Reconnaissance du droit de la neutralité comme réitération d’un principe de
droit naturel.
Conséquences de la neutralité d’une nation pour ses citoyens—limites de la protection
nationale et rejet de réclamations pour défaut de compétence par une commission
internationale lorsque les citoyens de nations neutres n’ont pas respecté la
neutralité.
Citoyen d’un État neutre, agissant en tant que corsaire pour une nation belligérante
en guerre contre un État avec lequel l’État neutre est en paix, considéré comme pirate
passible d’être poursuivi et puni.
Détermination de la nationalité du capitaine par sa commission ainsi que le
pavillon du belligérant sous lequel le capitaine combattait, dans la mesure où il s’agit
de la réclamation du capitaine concernant sa capture en tant que corsaire.
Reconnaissance d’une règle prévoyant que le droit de prise revient initialement
au gouvernement représenté par le ravisseur en temps de guerre, dont les droits sont
établis par des décisions judiciaires ultérieures.
*****
On the 17th of November 1817, John Clark, a native citizen of the United
States of America, entered into the service of the Banda Oriental Republic, now
Uruguay, which was then engaged in her war of independence against Spain and
Portu gal, to each of which two powers a portion of her territory belonged.
Annex 98
cases of the good return and the medea 101
John Clark obtained a commission as captain in the Banda Oriental
Navy, and a patent authorizing him, as the commander of a private armed
vessel, La Fortuna, to cruise against the vessels and property of the subjects
of Spain and Portugal. These letters of marque were issued by General
José Artigas, who was then the chief executive of that country, and they
were to continue in force for and during the term of eighteen months from
the departure of La Fortuna from Buenos Ayres.
The United States, it is hardly necessary for me to add here, was neutral
in the war between Spain and Portugal and their colonies in America.
Clark left Buenos Ayres with his vessel on the 5th of March 1818, and
after cruising for several months, proceeded to Balti more “for the purpose”,
as it appears from the statement of one of the claimants, and the testimony in
the case, “of procuring provisions and men”. Having succeeded in this he left
Balti more on the l5th of September 1818, and in November of the same year
captured the Spanish brig Medea, with a valuable Spanish cargo, and placed
a prize master and crew on board of her, with instructions to take her to the
neutral port of St. Bartholomew, to be held there subject to his orders. On the
l9th of November the Medea, while on her way to St. Bartholo mew, was seized
by the Venezuelan man-of-war Espartana, under the orders of Commodore
Joly of the Venezuelan navy, who sent her to the Island of Marguerita, where
she was con demned on the 26th of November 1818 as a prize of the Espartana,
on the ground that her capture by Clark was illegal.
Subsequently (on the 15th November I8I8) La Fortuna, captured the Portuguese
ship La Reina de los Mares, bound from Bahia, Brazil, to Lisbon, with
a valuable cargo on board, which, for greater safety, as it is alleged, was transferred
by Clark to the Good Return, said to be an American ship chartered
expressly for the occasion. Whether the latter vessel had accompanied Clark
on his cruise, or how it was that she suddenly made her appearance, where she
came from, whither she was bound, and who her owners were, does not appear
from the papers presented to this commission. The Good Re turn was also taken
possession of by Commodore Joly, of the Venezuelan navy, who demanded the
value of one-third of the goods on board as ransom, and compelled the captain
of the Good Return to place her cargo in the hands of the Vene zuelan agent
at St. Bartholomew, to be sold at auction there, under the most unfavorable
circumstances. A cargo of $80,000, it is alleged, was thus sacrificed to make
up the sum of $26,000 demanded by Joly, and the proceeds of the sale, being
about $24,000, were retained and distributed by the commodore.
The grounds on which these acts of lawlessness were justi fied by the Venezuelan
authorities were: 1st, that General Artigas had no right to grant letters
of marque, being a usurper and a rebel against the legitimate authorities
of Buenos Ayres; and 2d, that the privateer La Fortuna left Buenos Ayres in
March 1818, after having arrived at that port in January of the same year as
a Buenos Ayres vessel, under the name of Patriota, commanded by Captain
Taylor, whereas the patent to Captain Clark had been issued on the 15th of
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102 united states/ecuador
November 1817; that consequently she was navigated under another name and
another flag, and commanded by another captain, two months after the issuing
of the patent to Captain Clark.
In December 1819 the Republic of Venezuela was united to the former
colony of New Granada under the name of the Republic of Colombia. Captain
Clark presented his claim to the Colombian Government, and asked for
indemnification, but in vain. In 1830 the Republic of Colombia ceased to exist
by being constituted into three independent governments—New Granada,
Venezuela, and Ecuador—and it is said that payment to the heirs of Clark
has been made, through the agency of the United States, by Venezuela, of her
proportion of the claim.
By a convention entered into by the three republics on the 23d of December
1834, it was agreed that the debts which they had acknowledged or contracted,
while they were united and constituted into one, should be paid by
them in the fol lowing proportion: 50 per centum by New Granada, 28 1/2 by
Venezuela, and 21 1/2 by Ecuador.
Clark died several years ago, and the interest in his claims passed by will
to his heirs and devisees, who, with a certain assignee, all of whom are residents
and citizens of the United States of America, are the present claimants.
The claim was presented by them to the United States and New Granada
mixed commission for the adjustment of claims established by the convention
of 1857, and, the commis sioners having been unable to agree, an award was
made by the umpire, Judge N. G. Upham, of Connecticut (sic), in favor of the
claimants, for New Granada’s proportion of the claim. The case is now presented
to this commission in order to fix the responsibility of Ecuador for her
share of the original amount and interest thereon up to date.
The decision of a mixed commission like our own, in an identical case, is
certainly entitled to great respect, but it can not be considered as an authority
which we are necessarily bound to follow; and if, upon a careful examination of
the law and the facts, it should appear to us that the decision was erroneous, we
are bound by our own conscience and the oath we have taken as members of this
commission, to follow our own convictions of right and justice, however sorry
we may be to dissent from the opinion of gentlemen for whose ability, conscientiousness,
and integrity we entertain the highest re gard. The establishment
of mixed commissions for the settle ment of international claims is evidently an
important step, suggested by the humane spirit of the age, in the direction of
universal peace and civilization. But to realize the true ben efits which the high
contracting parties are entitled to expect from such commissions, the commissioners
should consider themselves not the attorneys for either the one or the
other country, but the judges appointed for the purpose of deciding the questions
submitted to them, impartially, according to law and justice, and without
reference to which side their decision will affect favorably or unfavorably.
Annex 98
cases of the good return and the medea 103
Considering myself bound, in the present case, to dissent from the opinion
of the umpire and the American member of the United States and New Granada
mixed commission on claims, justice to the claimants and to my own country
requires that I should state my reasons in full, so as to leave them open to the
scrutiny of those to whom I am responsible for my offi cial conduct.
Before entering upon a discussion of the merits of the case, a preliminary
but highly important question presents itself. It is whether this is a claim which
can properly be preferred and enforced against Ecuador by the Government
of the United States.
I grant that the conduct of the Venezuelan squadron and the decisions of
the Venezuelan prize court were unjustifiable upon any principle of international
law, and that a great out rage was committed on the sovereign rights and interest
of Uruguay; but what is that to the United States? Whatever losses and damages
Captain Clark sustained in the premises he sustained not in his character as a
citizen of the United States, but as an officer in the service of the Banda Oriental
Republic, cruising under her flag, for her benefit, and against her enemies. If,
therefore, the spoliations committed by the Venezuelan navy, and sanctioned
by the Venezuelan courts, entitle him to indemnification, this indemnification
must be claimed by the Banda Oriental Republic, now the Republic of Uruguay,
and not by the United States. In the war with Uruguay, and Spain and Portugal
the United States were neutral; not so Captain Clark. Although a native citizen of
the United States, he had identified himself with one of the belligerents, in violation,
as I shall presently show, of the laws and treaties of his own native country.
He was cruising under the Uruguay flag, against the commerce of two nations
with which the country of his birth was at peace. He must therefore abide by the
consequences. If, in the course of his career as an Uruguay privateer, any wrong
was done to or any outrage committed upon him, it is to Uruguay he must look
for protection and not to the United States.
It is not my intention to enter into an examination of the questions discussed
by counsel, whether, by his entering into the service of one of the belligerents,
while our country was at peace with both of them, he forfeited his
national character as an American citizen; and whether, upon his final return
to the United States, his native character reverted, and by thus reverting entitled
him to have his claim enforced by his native government. I believe that these
questions are immaterial to the decision of this case. Whether Captain Clark
was by birth an American, Englishman, Frenchman, or Spaniard, as long as he
commanded an Uruguay cruiser, under the Uru guay flag in the service of the
Republic of Uruguay, and in the exercise of active hostilities against the enemies
of Uru guay and the friends of the United States, he was to all practical intents
and purposes an Uruguayan; but especially as to all questions of prize law and
maritime warfare. If the Uruguayan Government was either unable or unwilling
to protect him in the realization of his prizes, it was his mis fortune, with which
the United States have no concern. Captain Clark had not yet acquired an individual
title to the vessels and cargoes captured by him. The title to a prize origi-
Annex 98
104 united states/ecuador
nally vests in the government represented by the captor. The rights of the captor
are subsequently ascertained and fixed by judicial decisions. It is true, as alleged
by claimant’s counsel, that at the time his prizes were taken away from him he
had at least a right of possession to them; but, again, I must say that that right he
had, not in his character as an American citizen, but by virtue of his commission
from one of the belligerents. The captain of an Uruguay cruiser repre sents
Uruguay, wherever he may have been born. To Uru guay he is responsible, and
Uruguay is responsible for him. If his prizes are taken away from him by third
parties, he must complain to those from whom he derived his authority, and not
to neutrals, who have nothing to do with the business one way or the other. Had
he been in command of an American vessel and had that vessel been taken away
from him by the Colombian navy, and justice been denied to him by the Colombian
authorities, it would have been the right and duty of our government to
protect him, and to see that he was fully in demnified. But why should the United
States, while at peace with all the world, interfere in a controversy between Uruguay
and Venezuela, with reference to certain Spanish and Portuguese vessels
captured by privateers of the former, when neither the vessels nor the cargoes,
nor any part there of, were American? The United States will protect American
interests; but why should they protect Uruguay interests, and take up a quarrel
which Uruguay herself seems to have ignored, merely because one of the parties
concerned in it, the commander of a foreign privateer, happened to be born in
the United States? Captain Clark’s nationality, as far as his claim is concerned,
is determined by his commission and by the flag under which he fought. Any
departure from this rule would soon involve us in troublesome questions with
the whole world, if, in time of war, the Government of the United States should
undertake to insure the captures of every American citizen, who, in violation of
our neutrality laws and treaties, may see fit to enter the naval service of a foreign
power, or to assume the command of a foreign privateer under a foreign flag.
The conclusion therefore seems to me irresistible, that, although Captain
Clark individually may have been an Ameri can citizen, his captures, while in
command of an Uruguay privateer, were Uruguay captures; and that any claim
to be preferred against Colombia, on account of the spoliations com mitted by the
Venezuelan navy, must be preferred by Uruguay and can not possibly be made or
enforced by the United States. That Clark’s family resided in the United States,
that he re turned to the country of his birth and died there, does not change the
aspect of the case, which is not determined by the nativity of the individual, but
by the flag of the belligerent.
But I am referred to a document executed by the Uruguay Government,
relinquishing all its rights in the premises and authorizing the individual parties
interested in the question to proceed “as they may find convenient.” The
original of this document is not before us. I must therefore rely on a trans lation
given in the opinion of the umpire of the United States and New Granada
mixed commission on claims. Said trans lation reads as follows:
Department of Foreign Relations,
Annex 98
cases of the good return and the medea 105
Montevideo, 10th December 1846.
The undersigned, Minister of Foreign Relations, has re ceived the communication
dated November 25 last, which Mr. Hamilton, consul of the United
States of America, thought fit to address him; asking in the name of his
Government that this Republic should declare that it will make no claim in
future against the Governments of Venezuela, New Granada, and Ecuador,
for the recapture of the vessels which had been taken by the cruisers Irresistible,
La Fortuna, and Constancia.
The undersigned is directed to say in reply that, to satisfy the wishes of the
United States, the Republic has no difficulty in declaring that the Oriental
Republic of Uruguay has no claim to make on the part of her treasury,
in her character as a nation, on account of the aforesaid vessels; but with
respect to the rights of individuals, she leaves them to such action as they
can sustain at the time of the declaration solicited, and consequently
those interested may exercise those rights as they find convenient.
Francisco Magarinos
To Mr. Hamilton
Consul of the United States of North America
The authority of the consul of the United States to nego tiate for such a
declaration does not appear. There is nothing before us to show that he was
ever instructed by the State Department to request the Uruguayan Government
for such a disclaimer. From the mere fact of his having been a consul,
no diplomatic authority can be inferred in his favor. To clothe him with
the character of a negotiator special authority would be required, which, if
ever conferred, it would be an easy task to prove by transcripts from the
records and correspondence of the State Department. But there is no
such evidence before us. We are left in darkness as to what authority,
if any, had been conferred on the consul, and to what communi cation the
above declaration is an answer.
Why should the United States have requested Uruguay to cede her legal
rights in the premises, and why should Uruguay have complied with this
request, without having received the slightest consideration for such a compliance?
Umpire Upham states in his decision that the above declara tion was made
by Uruguay “at the request of the representatives of the claimant, they prosecuting
the claim as citizens of the United States.” In the absence of all other
evidence I am inclined to believe that this is a correct supposition, and that
the above declaration was the result of a private arrangement effected between
the claimant and the government of Uruguay, through the good offices of the
United States consul at Monte video, an arrangement with which the United
States Govern ment had nothing to do.
It is equally clear that such a document does not better the case of the
claimants. It casts away the only legal remedy they had without giving them
another. It is not a cession of Uruguay’s rights to the United States, nor
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106 united states/ecuador
does it confer any authority on the United States to prosecute the claim for
the benefit of Uruguay or for the benefit of the individual claim ants. And,
even if it were a cession or an assignment, it is very questionable whether
such a cession or assignment would or could have been accepted by the Government
of the United States.
And this leads us to the consideration of the question whether it
would be right and proper on the part of the United States to father such
foreign claims. Article 14 of the treaty of 1795 between the United States and
Spain (confirmed with the exception of a few articles by the treaty of 1819)
provides as follows:
Art. 14. No subject of His Catholic Majesty shall apply for or take any
commission or letters of marque, for arming any ship or ships to act as
privateers against the said United States, or against the citizens, people,
or inhabitants of said United States, or against the property of any of the
inhab itants of any of them, from any Prince or State with which the said
United States shall be at war.
Nor shall any citizen, subject, or inhabitant of the said United States apply
for or take any commission or letters of marque for arming any ship or
ships to act as privateers against the subjects of His Catholic Majesty or
the property of any of them, from any Prince or State with which the said
King shall be at war. And if any person of either nation shall take such
commissions or letters of marque, he shall be punished as a pirate.
But not only in what he did, but also in the manner of doing it, John
Clark violated the laws of his country whose interference and assistance he
now invokes to realize the profits of his piracy. By augmenting the force of
his armed vessels at the port of Baltimore he plainly and directly offended
against the act of Congress passed in 1794, and revised and reenacted
in 1819, by which it is declared to be a misdemeanor for any person within
the jurisdiction of the United States to augment the force of any armed vessel
belonging to one foreign power at war with another power, with whom the
United States are at peace; or to prepare any military expedition against
the territory of any foreign nations with whom they are at peace; or to hire
or enlist troops or seaman for foreign military or naval service; or to be
concerned in fitting out any vessel to cruise or commit hostilities in foreign
service against a nation at peace with them, &c, &c.
The principle which underlies such enactments and treaty stipulations was
forcibly stated by Mr. Thomas Jefferson, in his letter of 17 June 1793 to Mr. Genet:
“By our treaties,” he says, “with several of the belligerent powers, which are a part
of the laws of our land, we [the United States] have established a state of peace
with them. But without appealing to treaties, we are at peace with them all by
the law of nature; for, by nature’s law, man is at peace with man, till some aggression
is committed, which, by the same law, authorizes one to destroy another,
as his enemy. For our citizens, then, to commit murders and depredations on
the members of nations at peace with us, or to combine to do it, appeared to the
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cases of the good return and the medea 107
Executive . . . as much against the laws of the land as to murder or rob, or combine
to murder or rob, its own citizens.” (See Lawrence’s Wheaton, p. 728.)
What right, under these circumstances, has Captain Clark, or his representatives,
to call upon the United States to enforce his claim on the Colombian
republics? Can he be allowed, as far as the United States are concerned,
to profit by his own wrong? Nemo ex suo delicto meliorem suam conditionem
facit. He has violated the laws of our land. He has disregarded sol emn treaty
stipulations. He has compromised our neutrality. He has committed depredations
against two nations with which we were at peace. He has made himself
liable to be prosecuted and punished as a pirate; and now he presents himself
before our government with the request to collect for him the proceeds
of his misdemeanors. Will our government, by doing so, offer a reward to
evil doers for the violation of its own laws and treaties? What would be the
object of enacting penal laws, if their transgression were to entitle the
offender to a premium instead of a punishment? I agree with the attorneys
for the claimants that it would perhaps not become Colombia to make this
defense, after having committed an outrage against the rights of Captain
Clark. But I do not look upon Colombia as interposing these objections.
I hold it to be the duty of the American Government and my own duty as
commissioner to state that in this case Mr. Clark has no standing as an
American citizen. A party who asks for re dress must present himself with
clean hands. His cause of action must not be based on an offense against
the very authority to whom he appeals for redress. It would be against all
public morality, and against the policy of all legislation, if the United States
should uphold or endeavor to enforce a claim founded on a violation of their
own laws and treaties, and on the perpetration of outrages committed by an
American citi zen against the subjects and commerce of friendly nations.
As an Uruguayan claim, this case would be entitled to the most favorable
consideration of the then Colombian republics. But it is not and can not be
an American claim. As the American commissioner, I could not sanction,
uphold, and reward indirectly what the law of my country directly prohib its.
Quod directo fieri prohibetur etiam dicitur prohibitum per indirectum. He who
engages in an expedition prohibited by the laws of his country must take
the consequences. He may win or he may lose. But that is his own risk;
he can not, in case of loss, seek indemnity through the instrumentality
of the government against which he has offended. For this rea son it is the
customary practice of nations nowadays, upon the breaking out of a war
between two foreign countries, to warn their subjects not to take part in it,
on either side, as by doing so they would forfeit their right to the protection
of their home government. Such neutrality laws and proclamations are
but reiterations of a plain principle of natural law.
It is alleged, however, that the Government of the United States has
made this claim its own by presenting it on former occasions to the three
Colombian republics and urging its recognition. Granting this to be so, I do
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108 united states/ecuador
not believe that the members of this commission are bound by what action
their governments may have taken on former occasions in each individual
case. If it were so, there would have been no need of establishing a mixed
commission, instead of which the two governments should have referred
these claims at once to the arbitration of a third party. Governments, like
individuals, are not infallible, and if the Government of the United States
ever encouraged or adopted this claim, I have no doubt it would reconsider
the view it then took of the question, if the case should again be
submitted to its examination. The present policy of the United States
toward their Spanish-American neighbors is one of the most scrupulous
good faith and justice. While ever ready and vigilant to protect the
rights and interests of American citizens wheresoever or against whomsoever
it may be, the United States will not oppress their sister republics with
extravagant demands or unjust exactions. The spirit which, in times now
passed, occasion ally led to misunderstandings between the republic of
the North and those of the Latin race has since died away and its revival has
been rendered impossible by the removal of its cause through the great
events of the last four years.
These observations I have deemed it necessary to add, as great stress
has been laid by the attorneys for the claimants on the action of former
administrations with reference to this and similar cases. With this, I
believe, I have sufficiently explained the reasons why in my opinion, our
decision should be against the claimants.
Case of the Atlantic and Hope Insurance Companies v. Ecuador
(case of the schooner Mechanic), opinion of
the Commissioner, Mr. Hassaurek1
Affaire concernant Atlantic and Hope Insurance Companies c.
Ecuador (affaire de la goélette Mechanic), opinion du
Commissaire, M. Hassaurek2
Denial of justice regarding the seizure of goods during war—obligation to respect
the principle of “free ships, free goods” established by a treaty—obligation to respect
enemy’s property covered by the flag of the party to the treaty as neutral property,
excepting contraband of war.
1 Reprinted from John Bassett Moore (ed.), History and Digest of the International
Arbitrations to Which the United States has been a Party, vol. III, Washington, 1898, Government
Printing Office, p. 3221.
2 Reproduit de John Bassett Moore (éd.), History and Digest of the International
Arbitrations to Which the United States has been a Party, vol. III, Washington, 1898, Government
Printing Office, p. 3221.
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ANNEX 99

REPORTS OF INTERNATIONAL
ARBITRAL AWARDS
RECUEIL DES SENTENCES
ARBITRALES
Frierdich and Co. Case
31 July 1905
VOLUME X pp. 45-55
NATIONS UNIES - UNITED NATIONS
Copyright (c) 2006
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􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀅
􀀅􀀅􀀅􀀃􀀆􀀇􀀈􀀉􀀃􀀊􀀋􀀈􀀊
􀀌􀀍􀀎􀀏􀀐􀀉􀀃􀀑􀀏􀀒􀀏􀀐􀀓􀀃􀀔􀀕􀀖􀀗􀀏􀀃􀀕􀀘􀀃􀀙􀀚􀀚􀀐􀀒􀀛􀀓􀀜􀀃􀀆􀀐􀀉􀀐􀀗􀀒􀀛􀀃􀀔􀀎􀀗􀀝􀀖􀀎􀀏􀀇
􀀞􀀟􀀠􀀡􀀙􀀢􀀃􀀑􀀔􀀟􀀡􀀣􀀔􀀡􀀑􀀜􀀃􀀟􀀣􀀔􀀇􀀜􀀃􀀤􀀛􀀒􀀎􀀍􀀏􀀎􀀘􀀘􀀄􀀔􀀗􀀕􀀓􀀓􀀄􀀙􀀚􀀚􀀐􀀛􀀛􀀒􀀍􀀏
􀀥􀀇
􀀦􀀡􀀧􀀔􀀨􀀃􀀩􀀃􀀔􀀪􀀇􀀜􀀃􀀟􀀣􀀔􀀇􀀜􀀃􀀦􀀐􀀗􀀝􀀫􀀃􀀑􀀬􀀒􀀗􀀚􀀃􀀩􀀃􀀢􀀕􀀬􀀭􀀐􀀃􀀔􀀕􀀗􀀚􀀇􀀜
􀀟􀀕􀀍􀀎􀀓􀀃􀀤􀀬􀀒􀀗􀀭􀀒􀀝􀀐􀀖􀀏􀀎􀀝􀀒􀀛􀀓􀀜􀀃􀀟􀀍􀀝􀀇􀀜􀀃􀀢􀀐􀀘􀀐􀀍􀀉􀀒􀀍􀀏􀀓􀀄􀀙􀀚􀀚􀀐􀀛􀀛􀀒􀀍􀀏􀀓
􀀋􀀮􀀊􀀯􀀄􀀋􀀈􀀮􀀋
􀀰
􀀋􀀮􀀊􀀯􀀄􀀋􀀯􀀊􀀱
􀀰
􀀢􀀐􀀝􀀎􀀉􀀐􀀉􀀲􀀃􀀙􀀚􀀗􀀎􀀛􀀃􀀋􀀱􀀜􀀃􀀋􀀮􀀊􀀅
􀀅􀀆􀀇􀀈􀀉􀀊􀀋􀀊
􀀌􀀍􀀎􀀏􀀐􀀑􀀈􀀒􀀇􀀓􀀔􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀃 􀀍􀀇􀀌􀀈􀀊􀀒􀀓􀀃 􀀔􀀋􀀇􀀏􀀕􀀉􀀐􀀃 􀀊􀀍􀀐􀀆􀀇􀀒
􀀖􀀎􀀎􀀗􀀆􀀒􀀕􀀃 􀀘􀀎􀀍􀀑􀀊􀀋􀀊􀀐􀀇􀀋􀀓􀀃 􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃 􀀐􀀉􀀊􀀐􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃 􀀋􀀎􀀑􀀊􀀐􀀆􀀒􀀕􀀃 􀀐􀀇
􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀖􀀃 􀀚􀀇􀀋􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀃 􀀝􀀎􀀋􀀎􀀃 􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀐􀀃 􀀝􀀊􀀖􀀃 􀀒􀀇􀀐
􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀆􀀒􀀕􀀃􀀔􀀓􀀃􀀆􀀐􀀖􀀃􀀊􀀍􀀐􀀆􀀞􀀆􀀐􀀆􀀎􀀖􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀆􀀒􀀕􀀃􀀆􀀐􀀖􀀃􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀃􀀈􀀋􀀇􀀘􀀏􀀍􀀐􀀖􀀟
􀀠􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀖􀀃􀀍􀀇􀀏􀀒􀀐􀀎􀀋􀀍􀀑􀀊􀀆􀀌􀀎􀀘􀀃􀀚􀀇􀀋􀀃􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀎􀀌􀀎􀀒􀀐􀀟􀀃􀀡􀀚􀀐􀀎􀀋􀀃􀀙􀀏􀀋􀀓􀀃􀀎􀀒􀀐􀀎􀀋􀀎􀀘
􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃􀀆􀀒􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀖􀀢􀀃􀀚􀀊􀀞􀀇􀀋􀀣􀀃􀀐􀀉􀀎􀀃􀀤􀀒􀀆􀀐􀀎􀀘􀀃􀀥􀀐􀀊􀀐􀀎􀀖􀀃􀀦􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀜􀀇􀀏􀀋􀀐
􀀚􀀇􀀋􀀃􀀐􀀉􀀎􀀃􀀧􀀇􀀋􀀐􀀉􀀎􀀋􀀒􀀃􀀦􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀇􀀚􀀃􀀜􀀊􀀑􀀆􀀚􀀇􀀋􀀒􀀆􀀊􀀣􀀃􀀧􀀇􀀟􀀃􀀨􀀩􀀪􀀫􀀄􀀍􀀞􀀄􀀬􀀭􀀬􀀨􀀮􀀄
􀀅􀀯􀀰􀀣􀀃 􀀅􀀎􀀐􀀉􀀃 􀀯􀀊􀀔􀀖􀀇􀀒􀀃 􀀰􀀋􀀎􀀎􀀌􀀊􀀒􀀣􀀃 􀀱􀀟􀀣􀀃 􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀋􀀏􀀑􀀎􀀘
􀀐􀀉􀀊􀀐􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀝􀀎􀀋􀀎􀀃􀀏􀀒􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀑􀀎􀀃􀀔􀀎􀀍􀀊􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀖􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒
􀀉􀀊􀀒􀀘􀀖􀀃􀀊􀀒􀀘􀀃􀀊􀀝􀀊􀀋􀀘􀀎􀀘􀀃􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀃􀀚􀀎􀀎􀀖􀀟􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀖􀀃􀀊􀀈􀀈􀀎􀀊􀀑􀀎􀀘􀀟
􀀶􀀉􀀎􀀃 􀀜􀀇􀀏􀀋􀀐􀀃 􀀇􀀚􀀃 􀀡􀀈􀀈􀀎􀀊􀀑􀀖􀀣􀀃 􀀶􀀊􀀋􀀊􀀒􀀐􀀇􀀣􀀃 􀀜􀀆􀀋􀀍􀀏􀀆􀀐􀀃 􀀱􀀏􀀘􀀕􀀎􀀣􀀃 􀀉􀀎􀀑􀀘􀀃 􀀐􀀉􀀊􀀐
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀘􀀆􀀘􀀃 􀀒􀀇􀀐􀀃 􀀊􀀔􀀏􀀖􀀎􀀃 􀀆􀀐􀀖􀀃 􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀃 􀀆􀀒􀀃 􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀆􀀒􀀕
􀀐􀀉􀀊􀀐􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀖􀀢􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀃􀀈􀀋􀀎􀀍􀀑􀀏􀀘􀀎􀀘􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀆􀀋
􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀟
􀀡􀀚􀀚􀀆􀀋􀀌􀀎􀀘􀀟
􀀕􀀖􀀗􀀘􀀗 􀀃􀀡􀀈􀀈􀀎􀀊􀀑􀀖􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀤􀀒􀀆􀀐􀀎􀀘􀀃􀀥􀀐􀀊􀀐􀀎􀀖􀀃􀀦􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀜􀀇􀀏􀀋􀀐􀀃􀀚􀀇􀀋􀀃􀀐􀀉􀀎
􀀧􀀇􀀋􀀐􀀉􀀎􀀋􀀒􀀃 􀀦􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀇􀀚􀀃 􀀜􀀊􀀑􀀆􀀚􀀇􀀋􀀒􀀆􀀊􀀃 􀀆􀀒􀀃 􀀧􀀇􀀟􀀃 􀀨􀀩􀀪􀀫􀀄􀀍􀀞􀀄􀀬􀀭􀀬􀀨􀀮􀀄􀀅􀀯􀀰􀀣
􀀱􀀏􀀘􀀕􀀎􀀃􀀅􀀎􀀐􀀉􀀃􀀯􀀊􀀔􀀖􀀇􀀒􀀃􀀰􀀋􀀎􀀎􀀌􀀊􀀒􀀟
􀀙􀀚􀀚􀀈􀀑􀀇􀀛􀀆􀀊􀀃􀀍􀀇􀀓􀀃􀀜􀀍􀀝􀀃􀀞􀀋􀀑􀀟􀀊
􀀱􀀏􀀊􀀒􀀆􀀐􀀊􀀃 􀀷􀀇􀀖􀀎􀀃 􀀅􀀋􀀇􀀇􀀗􀀖􀀣􀀃 􀀰􀀆􀀖􀀉􀀃 􀀸􀀃 􀀷􀀆􀀍􀀉􀀊􀀋􀀘􀀖􀀇􀀒􀀣􀀃 􀀠􀀜􀀣􀀃 􀀥􀀊􀀒􀀃 􀀦􀀆􀀎􀀕􀀇􀀣
􀀜􀀡􀀣􀀃􀀊􀀋􀀕􀀏􀀎􀀘􀀃􀀚􀀇􀀋􀀃􀀈􀀑􀀊􀀆􀀒􀀐􀀆􀀚􀀚􀀄􀀍􀀋􀀇􀀖􀀖􀀄􀀊􀀈􀀈􀀎􀀑􀀑􀀊􀀒􀀐􀀟􀀃􀀡􀀑􀀖􀀇􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀎􀀘􀀃􀀔􀀓
􀀜􀀋􀀊􀀆􀀕􀀃􀀹􀀟􀀃􀀜􀀇􀀏􀀒􀀐􀀋􀀓􀀌􀀊􀀒􀀣􀀃􀀱􀀇􀀒􀀊􀀐􀀉􀀊􀀒􀀃􀀹􀀑􀀑􀀆􀀇􀀐􀀃􀀥􀀆􀀒􀀕􀀎􀀋􀀺􀀃􀀹􀀑􀀆􀀻􀀊􀀔􀀎􀀐􀀉􀀃􀀼􀀟
􀀰􀀑􀀊􀀒􀀊􀀕􀀊􀀒􀀣􀀃 􀀦􀀎􀀊􀀒􀀒􀀊􀀃 􀀱􀀎􀀊􀀒􀀃 􀀷􀀎􀀆􀀍􀀉􀀎􀀑􀀣􀀃 􀀼􀀆􀀒􀀒􀀎􀀊􀀈􀀇􀀑􀀆􀀖􀀣􀀃 􀀼􀀧􀀺􀀃 􀀷􀀇􀀔􀀎􀀋􀀐
􀀼􀀟 􀀽􀀊􀀗􀀎􀀖􀀣􀀃􀀴􀀆􀀑􀀌􀀆􀀒􀀕􀀐􀀇􀀒􀀣􀀃􀀦􀀹􀀺􀀃􀀹􀀘􀀌􀀏􀀒􀀘􀀃􀀛􀀆􀀋􀀖􀀍􀀉􀀚􀀎􀀑􀀘􀀣􀀃􀀹􀀟􀀃􀀱􀀇􀀖􀀉􀀏􀀊
􀀷􀀇􀀖􀀎􀀒􀀗􀀋􀀊􀀒􀀻􀀣􀀃􀀽􀀋􀀋􀀆􀀍􀀗􀀣􀀃􀀛􀀎􀀋􀀋􀀆􀀒􀀕􀀐􀀇􀀒􀀃􀀸􀀃􀀥􀀏􀀐􀀍􀀑􀀆􀀚􀀚􀀎􀀃􀀯􀀯􀀠􀀣􀀃􀀧􀀎􀀝􀀃􀀾􀀇􀀋􀀗􀀣
􀀧􀀾􀀟
􀀱􀀎􀀚􀀚􀀋􀀎􀀓􀀃 􀀡􀀟􀀃 􀀯􀀊􀀌􀀗􀀎􀀒􀀣􀀃 􀀼􀀇􀀑􀀇􀀯􀀊􀀌􀀗􀀎􀀒􀀃 􀀯􀀯􀀠􀀣􀀃 􀀴􀀊􀀖􀀉􀀆􀀒􀀕􀀐􀀇􀀒􀀣􀀃 􀀦􀀜􀀣
􀀊􀀋􀀕􀀏􀀎􀀘􀀃􀀚􀀇􀀋􀀃􀀘􀀎􀀚􀀎􀀒􀀘􀀊􀀒􀀐􀀖􀀄􀀊􀀈􀀈􀀎􀀑􀀑􀀊􀀒􀀐􀀖􀀟􀀃􀀡􀀑􀀖􀀇􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀎􀀘􀀃􀀔􀀓􀀃􀀱􀀊􀀌􀀎􀀖
􀀡􀀟 􀀅􀀊􀀋􀀐􀀊􀀣􀀃􀀥􀀊􀀋􀀊􀀉􀀃􀀱􀀏􀀖􀀐􀀆􀀒􀀎􀀃􀀧􀀎􀀝􀀌􀀊􀀒􀀣􀀃􀀼􀀆􀀍􀀉􀀊􀀎􀀑􀀃􀀿􀀋􀀎􀀕􀀇􀀋􀀓􀀃􀀠􀀊􀀐􀀐􀀆􀀑􀀑􀀇􀀣
􀀱􀀋􀀟􀀺􀀃􀀥􀀊􀀋􀀊􀀃􀀼􀀊􀀋􀀕􀀇􀀑􀀆􀀖􀀣􀀃􀀧􀀎􀀝􀀃􀀾􀀇􀀋􀀗􀀣􀀃􀀧􀀾􀀺􀀃􀀱􀀎􀀖􀀖􀀊􀀌􀀓􀀒􀀃􀀥􀀉􀀎􀀑􀀆􀀃􀀅􀀎􀀋􀀒􀀆􀀗􀀎􀀋􀀣
􀀥􀀐􀀊􀀒􀀑􀀎􀀓􀀃 􀀹􀀟􀀃 􀀰􀀆􀀖􀀉􀀎􀀋􀀣􀀃 􀀅􀀋􀀏􀀍􀀎􀀃 􀀿􀀎􀀒􀀘􀀎􀀋􀀖􀀇􀀒􀀣􀀃 􀀱􀀎􀀖􀀖􀀆􀀍􀀊􀀃 􀀠􀀊􀀑􀀌􀀎􀀋􀀃 􀀷􀀓􀀎􀀒􀀣
􀀴􀀆􀀑􀀑􀀆􀀊􀀌􀀖􀀃􀀸􀀃􀀜􀀇􀀒􀀒􀀇􀀑􀀑􀀓􀀃􀀯􀀯􀀠􀀣􀀃􀀴􀀊􀀖􀀉􀀆􀀒􀀕􀀐􀀇􀀒􀀣􀀃􀀦􀀜􀀺􀀃􀀼􀀆􀀐􀀍􀀉􀀎􀀑􀀑􀀃􀀹􀀈􀀒􀀎􀀋􀀣
􀀥􀀐􀀎􀀈􀀉􀀎􀀒􀀃􀀥􀀟􀀃􀀷􀀊􀀔􀀆􀀒􀀇􀀝􀀆􀀐􀀻􀀣􀀃􀀛􀀏􀀕􀀉􀀎􀀖􀀃􀀛􀀏􀀔􀀔􀀊􀀋􀀘􀀃􀀸􀀃􀀷􀀎􀀎􀀘􀀃􀀯􀀯􀀠􀀣􀀃􀀧􀀎􀀝
􀀾􀀇􀀋􀀗􀀣􀀃􀀧􀀾􀀟
􀀅􀀎􀀚􀀇􀀋􀀎􀀃􀀶􀀊􀀋􀀊􀀒􀀐􀀇􀀣􀀃􀀜􀀑􀀎􀀞􀀎􀀒􀀕􀀎􀀋􀀣􀀃􀀊􀀒􀀘􀀃􀀜􀀉􀀎􀀒􀀣􀀃􀀜􀀆􀀋􀀍􀀏􀀆􀀐􀀃􀀱􀀏􀀘􀀕􀀎􀀖􀀟
􀀠􀀉􀀋􀀇􀀋􀀈􀀇
􀀶􀀊􀀋􀀊􀀒􀀐􀀇􀀣􀀃􀀜􀀆􀀋􀀍􀀏􀀆􀀐􀀃􀀱􀀏􀀘􀀕􀀎􀀟
􀀕􀀖􀀗􀀘􀀘 􀀃􀀶􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀖􀀃􀀐􀀝􀀇􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀋􀀎􀀑􀀊􀀐􀀆􀀒􀀕􀀃􀀐􀀇􀀃􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀖
􀀚􀀇􀀋􀀃􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃􀀜􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀸􀀃􀀜􀀇􀀟􀀣􀀃􀁀􀀒􀀍􀀟􀀃􀀊􀀒􀀘􀀃􀁀􀀇􀀒􀀆􀀖􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀖􀀣
􀁀􀀒􀀍􀀟􀀃 􀁁􀀚􀀇􀀋􀀌􀀎􀀋􀀑􀀓􀀃 􀁀􀀖􀀆􀀖􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀖􀀣􀀃 􀁀􀀒􀀍􀀟􀁂􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀎􀀘􀀃 􀀇􀀒
􀀋􀀎􀀖􀀎􀀊􀀋􀀍􀀉􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀊􀀋􀀎􀀊􀀃􀀊􀀒􀀘􀀃􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃􀀇􀀔􀀐􀀊􀀆􀀒􀀎􀀘􀀃􀀤􀀟􀀥􀀟􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀃􀀧􀀇􀀖􀀟
􀀮􀀣􀀪􀀬􀀨􀀣􀀭􀀵􀀵􀀃􀀊􀀒􀀘􀀃􀁃􀀣􀀭􀁃􀀪􀀣􀀮􀀪􀀲􀀟􀀃􀀶􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀣􀀃􀀝􀀉􀀇􀀖􀀎􀀃􀀖􀀈􀀎􀀍􀀆􀀚􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖
􀀊􀀋􀀎􀀃 􀀌􀀊􀀐􀀎􀀋􀀆􀀊􀀑􀀑􀀓􀀃 􀀐􀀉􀀎􀀃 􀀖􀀊􀀌􀀎􀀃 􀀚􀀇􀀋􀀃 􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃 􀀈􀀏􀀋􀀈􀀇􀀖􀀎􀀖􀀣􀀃 􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀎􀀃 􀀊􀀒􀀘
􀀍􀀑􀀊􀀆􀀌􀀃􀀍􀀑􀀊􀀖􀀖􀀎􀀖􀀃􀀇􀀚􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀖􀀣􀀃􀀆􀀘􀀎􀀒􀀐􀀆􀀚􀀆􀀎􀀘􀀃􀀔􀀓􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀖􀀣
􀀊􀀒􀀘􀀃 􀀐􀀉􀀎􀀃 􀀊􀀘􀀌􀀆􀀒􀀆􀀖􀀐􀀋􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀋􀀊􀀈􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀑􀀓􀀃 􀀎􀀚􀀚􀀎􀀍􀀐􀀆􀀞􀀎􀀃 􀀊􀀌􀀇􀀏􀀒􀀐􀀖
􀀇􀀚􀀃 􀀖􀀏􀀍􀀉􀀃 􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀖􀀟􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀥􀀍􀀆􀀎􀀒􀀍􀀎􀀖􀀣􀀃 􀁀􀀒􀀍􀀟􀀣􀀃 􀀘􀀎􀀞􀀎􀀑􀀇􀀈􀀎􀀘􀀃 􀀆􀀐􀀖
􀀇􀀝􀀒􀀃􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃􀀜􀀃􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀖􀁄􀀌􀀊􀀋􀀗􀀎􀀐􀀎􀀘􀀃􀀒􀀇􀀝􀀃􀀊􀀖􀀃􀀥􀀇􀀞􀀊􀀑􀀘􀀆􀁅􀀃􀀊􀀒􀀘
􀀛􀀊􀀋􀀞􀀇􀀒􀀆􀁅􀀣􀀃􀀔􀀇􀀐􀀉􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀟
􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀐􀀉􀀆􀀖􀀃􀀊􀀍􀀐􀀆􀀇􀀒􀀃􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀸􀀃􀀜􀀇􀀟􀀣􀀃􀀆􀀐􀀖􀀃􀀖􀀏􀀔􀀖􀀆􀀘􀀆􀀊􀀋􀀓
􀀼􀀎􀀋􀀍􀀗􀀃 􀀥􀀉􀀊􀀋􀀈􀀃 􀀸􀀃 􀀦􀀇􀀉􀀌􀀎􀀃 􀀜􀀇􀀋􀀈􀀟􀀣􀀃 􀀊􀀒􀀘􀀃 􀁀􀀇􀀒􀀆􀀖􀀃 􀁁􀀍􀀇􀀑􀀑􀀎􀀍􀀐􀀆􀀞􀀎􀀑􀀓􀀣
􀁆􀀼􀀎􀀋􀀍􀀗􀁇􀀃 􀀏􀀒􀀑􀀎􀀖􀀖􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀒􀀐􀀎􀁈􀀐􀀃 􀀆􀀒􀀘􀀆􀀍􀀊􀀐􀀎􀀖􀀃 􀀋􀀎􀀚􀀎􀀋􀀎􀀒􀀍􀀎􀀃 􀀙􀀏􀀖􀀐􀀃 􀀐􀀇
􀀼􀀎􀀋􀀍􀀗􀀃 􀀸􀀃 􀀜􀀇􀀟􀀃 􀀊􀀒􀀘􀁉􀀇􀀋􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀥􀀉􀀊􀀋􀀈􀁂􀀟􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀖􀀇􀀏􀀕􀀉􀀐􀀃 􀀊
􀀘􀀎􀀍􀀑􀀊􀀋􀀊􀀐􀀇􀀋􀀓􀀃􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀢􀀭􀀵􀀵􀀃􀀊􀀒􀀘􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀊􀀋􀀎
􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀆􀀖􀀃 􀀒􀀇􀀐􀀃 􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀆􀀒􀀕􀀃 􀀔􀀓􀀃 􀀆􀀐􀀖􀀃 􀀊􀀍􀀐􀀆􀀞􀀆􀀐􀀆􀀎􀀖
􀀆􀀒􀀞􀀇􀀑􀀞􀀆􀀒􀀕􀀃􀀆􀀐􀀖􀀃􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀃􀀈􀀋􀀇􀀘􀀏􀀍􀀐􀀖􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀍􀀇􀀏􀀒􀀐􀀎􀀋􀀄􀀍􀀑􀀊􀀆􀀌􀀎􀀘􀀃􀀚􀀇􀀋
􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀎􀀌􀀎􀀒􀀐􀀟
􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃 􀀖􀀐􀀆􀀈􀀏􀀑􀀊􀀐􀀎􀀘􀀃 􀀐􀀇􀀃 􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀎􀀌􀀎􀀒􀀐􀀃 􀀔􀀊􀀖􀀎􀀘􀀃 􀀇􀀒􀀃 􀀐􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃 􀀍􀀑􀀊􀀆􀀌􀀃 􀀍􀀇􀀒􀀖􀀐􀀋􀀏􀀍􀀐􀀆􀀇􀀒􀀣􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀆􀀖􀀃 􀀒􀀇􀀐􀀃 􀀍􀀉􀀊􀀑􀀑􀀎􀀒􀀕􀀎􀀘
􀀇􀀒􀀃 􀀊􀀈􀀈􀀎􀀊􀀑􀀟􀀃 􀀡􀀃 􀀙􀀏􀀋􀀓􀀃 􀀐􀀋􀀆􀀊􀀑􀀃 􀀝􀀊􀀖􀀃 􀀉􀀎􀀑􀀘􀀃 􀀇􀀒􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃 􀀍􀀉􀀊􀀑􀀑􀀎􀀒􀀕􀀎􀀖􀀃 􀀐􀀇
􀀐􀀉􀀎􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃 􀀊􀀖􀀃 􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀃 􀀚􀀇􀀋􀀃 􀀑􀀊􀀍􀀗􀀃 􀀇􀀚􀀃 􀀔􀀇􀀐􀀉􀀃 􀀊􀀒􀀃 􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃 􀀝􀀋􀀆􀀐􀀐􀀎􀀒
􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀎􀀒􀀊􀀔􀀑􀀎􀀌􀀎􀀒􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀊􀀖􀀖􀀎􀀋􀀐􀀎􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀁁􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀪􀁋
􀀲􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀪􀁋􀀫􀀣􀀃􀀨􀀣􀀃􀀮􀀣􀀃􀀊􀀒􀀘􀀃􀀵􀀄􀀪􀀪􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲
􀀈􀀊􀀐􀀎􀀒􀀐􀁂􀀃􀀊􀀖􀀃􀀝􀀎􀀑􀀑􀀃􀀊􀀖􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀍􀀑􀀇􀀖􀀎􀀑􀀓􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃􀀐􀀉􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗
􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀊􀀍􀀐􀀏􀀊􀀑􀀑􀀓􀀃􀀆􀀒􀀞􀀎􀀒􀀐􀀃􀀐􀀉􀀎􀀃􀀖􀀏􀀔􀀙􀀎􀀍􀀐􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀃􀀔􀀏􀀐􀀃􀀘􀀎􀀋􀀆􀀞􀀎􀀘􀀃􀀆􀀐􀀃􀀚􀀋􀀇􀀌
􀀊􀀒􀀇􀀐􀀉􀀎􀀋􀀃􀀆􀀒􀀞􀀎􀀒􀀐􀀇􀀋􀀣􀀃􀀎􀀌􀀈􀀑􀀇􀀓􀀎􀀘􀀃􀀔􀀓􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀈􀀋􀀎􀀘􀀎􀀍􀀎􀀖􀀖􀀇􀀋􀀟􀀃􀀶􀀉􀀎􀀃􀀙􀀏􀀋􀀓
􀀋􀀏􀀑􀀎􀀘􀀃􀀚􀀇􀀋􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀊􀀒􀀘􀀃􀀊􀀝􀀊􀀋􀀘􀀎􀀘􀀃􀀘􀀊􀀌􀀊􀀕􀀎􀀖􀀟
􀀶􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀐􀀉􀀎􀀒􀀃􀀉􀀎􀀑􀀘􀀃􀀊􀀃􀀔􀀎􀀒􀀍􀀉􀀃􀀐􀀋􀀆􀀊􀀑􀀃􀀇􀀒􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎
􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀏􀀒􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀆􀀑􀀆􀀐􀀓􀀃􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒
􀀐􀀉􀀎􀀃 􀀊􀀑􀀑􀀎􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀐􀀉􀀊􀀐􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀉􀀊􀀘􀀃 􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃 􀀉􀀊􀀒􀀘􀀖􀀃 􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃 􀀐􀀉􀀎
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀆
􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀟􀀃 􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀋􀀏􀀑􀀎􀀘􀀃 􀀚􀀇􀀋􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀣􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃 􀀔􀀇􀀐􀀉
􀀈􀀋􀀎􀀄􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀊􀀒􀀘􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐
􀀊􀀐􀀐􀀋􀀆􀀔􀀏􀀐􀀊􀀔􀀑􀀎􀀃􀀐􀀇􀀃􀀼􀀎􀀋􀀍􀀗􀀣􀀃􀀊􀀒􀀘􀀃􀀆􀀐􀀃􀀔􀀊􀀋􀀋􀀎􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀚􀀋􀀇􀀌􀀃􀀊􀀖􀀖􀀎􀀋􀀐􀀆􀀒􀀕􀀃􀀐􀀉􀀎
􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀍􀀎􀀏􀀃􀀐􀀑􀀌􀀎􀀃􀀒􀀎􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀎􀀣􀀃􀀧􀀇􀀟
􀀪􀀫􀀄􀀍􀀞􀀄􀀬􀀭􀀬􀀨􀀮􀀄􀀅􀀯􀀰􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀫􀀵􀀃􀁁􀀧􀀟􀀦􀀟􀀃􀀜􀀊􀀑􀀟􀀃􀀱􀀏􀀒􀀎
􀀳􀀣􀀃􀀲􀀬􀀪􀀳􀁂􀀟􀀃􀀛􀀊􀀞􀀆􀀒􀀕􀀃􀀖􀀇􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀎􀀘􀀣􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀖􀀏􀀔􀀖􀀎􀁊􀀏􀀎􀀒􀀐􀀑􀀓
􀀘􀀎􀀎􀀌􀀎􀀘􀀃 􀀌􀀇􀀇􀀐􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃 􀀌􀀇􀀐􀀆􀀇􀀒􀀃 􀀚􀀇􀀋􀀃 􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃 􀀊􀀖􀀃 􀀊􀀃 􀀌􀀊􀀐􀀐􀀎􀀋􀀃 􀀇􀀚
􀀑􀀊􀀝􀀃􀀇􀀚􀀃􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀚􀀇􀀋􀀃􀀑􀀊􀀍􀀗􀀃􀀇􀀚􀀃􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘
􀀎􀀒􀀊􀀔􀀑􀀎􀀌􀀎􀀒􀀐􀀟􀀃􀀶􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀊􀀑􀀖􀀇􀀃􀀊􀀝􀀊􀀋􀀘􀀎􀀘􀀃 􀀕􀀖􀀗􀀘􀀡 􀀃􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀢􀀖􀀃􀀚􀀎􀀎􀀖􀀣
􀀋􀀎􀀑􀀓􀀆􀀒􀀕􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀟
􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀈􀀈􀀎􀀊􀀑􀀖􀀃 􀀐􀀉􀀎􀀃 􀀏􀀒􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀆􀀑􀀆􀀐􀀓􀀃 􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃 􀀔􀀊􀀖􀀎􀀘􀀃 􀀇􀀒
􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀟􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀍􀀋􀀇􀀖􀀖􀀄􀀊􀀈􀀈􀀎􀀊􀀑􀀖􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀒􀀆􀀊􀀑􀀃􀀇􀀚􀀃􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐
􀀊􀀖􀀃􀀊􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀃􀀇􀀚􀀃􀀑􀀊􀀝􀀃􀀇􀀚􀀃􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀣􀀃􀀔􀀏􀀐􀀃􀀆􀀐􀀃􀀊􀀖􀀗􀀖􀀃􀀏􀀖􀀃􀀐􀀇􀀃􀀋􀀎􀀊􀀍􀀉􀀃􀀐􀀉􀀊􀀐
􀀆􀀖􀀖􀀏􀀎􀀃􀀇􀀒􀀑􀀓􀀃􀀆􀀚􀀃􀀝􀀎􀀃􀀖􀀎􀀐􀀃􀀊􀀖􀀆􀀘􀀎􀀃􀀐􀀉􀀎􀀃􀀏􀀒􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀆􀀑􀀆􀀐􀀓􀀃􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀟􀀃􀀴􀀎
􀀉􀀊􀀞􀀎􀀃 􀀙􀀏􀀋􀀆􀀖􀀘􀀆􀀍􀀐􀀆􀀇􀀒􀀃 􀀏􀀒􀀘􀀎􀀋􀀃 􀀲􀁃􀀃 􀀤􀀟􀀥􀀟􀀜􀀟􀀃 􀁍􀀃 􀀪􀀲􀀵􀀨􀁁􀀊􀁂􀁁􀀪􀁂􀀟􀀃 􀀴􀀎􀀃 􀀊􀀚􀀚􀀆􀀋􀀌
􀀐􀀉􀀎􀀃􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀣􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀆􀀖
􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀑􀀓􀀃􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀎􀀘􀀃􀀔􀀓􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀆􀀐􀀉􀀖􀀐􀀊􀀒􀀘􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀃􀀚􀀇􀀋
􀀍􀀑􀀎􀀊􀀋􀀃 􀀎􀀋􀀋􀀇􀀋􀀟􀀃 􀀴􀀎􀀃 􀀐􀀉􀀎􀀋􀀎􀀚􀀇􀀋􀀎􀀃 􀀘􀀇􀀃 􀀒􀀇􀀐􀀃 􀀋􀀎􀀊􀀍􀀉􀀃 􀀐􀀉􀀎􀀃 􀀆􀀖􀀖􀀏􀀎􀀖􀀃 􀀋􀀊􀀆􀀖􀀎􀀘􀀃 􀀔􀀓
􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀍􀀇􀀒􀀘􀀆􀀐􀀆􀀇􀀒􀀊􀀑􀀃􀀍􀀋􀀇􀀖􀀖􀀄􀀊􀀈􀀈􀀎􀀊􀀑􀀟
􀁀
􀀡
􀁀􀀒􀀃 􀀪􀀵􀀵􀁃􀀣􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀒􀀘􀀃 􀁀􀀖􀀆􀀖􀀃 􀀔􀀎􀀕􀀊􀀒􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀒􀀕􀀃 􀀇􀀒􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕
􀀊􀀃 􀀝􀀊􀀓􀀃 􀀐􀀇􀀃 􀀔􀀑􀀇􀀍􀀗􀀃 􀀈􀀋􀀇􀀈􀀊􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀃 􀀞􀀆􀀋􀀏􀀖
􀁁􀀛􀀜􀁎􀁂􀀃 􀀔􀀓􀀃 􀀆􀀌􀀈􀀎􀀘􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀖􀀓􀀒􀀐􀀉􀀎􀀖􀀆􀀖􀀃 􀀇􀀚􀀃 􀀆􀀐􀀖􀀃 􀀷􀀧􀀡􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀬􀀲􀀵􀀪􀀟
􀀶􀀉􀀎􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀇􀀋􀀖􀀃 􀀖􀀇􀀏􀀕􀀉􀀐􀀃 􀀊􀀃 􀀌􀀇􀀑􀀎􀀍􀀏􀀑􀀎􀀃 􀀐􀀉􀀊􀀐􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀉􀀊􀀞􀀎􀀃 􀀐􀀝􀀇
􀀈􀀋􀀇􀀈􀀎􀀋􀀐􀀆􀀎􀀖􀀟􀀃 􀀰􀀆􀀋􀀖􀀐􀀣􀀃 􀀊􀀒􀀃 􀀎􀀒􀀻􀀓􀀌􀀎􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘􀀃 􀀆􀀒􀀃 􀀷􀀧􀀡􀀃 􀀊􀀖􀀖􀀎􀀌􀀔􀀑􀀓
􀁁􀀧􀀥􀀨􀀅􀀃 􀀈􀀇􀀑􀀓􀀌􀀎􀀋􀀊􀀖􀀎􀁂􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀋􀀎􀀍􀀇􀀕􀀒􀀆􀀻􀀎􀀃 􀀐􀀉􀀎􀀃 􀀌􀀇􀀑􀀎􀀍􀀏􀀑􀀎􀀃 􀀊􀀖􀀃 􀀊
􀀔􀀏􀀆􀀑􀀘􀀆􀀒􀀕􀀃􀀔􀀑􀀇􀀍􀀗􀀃􀀊􀀒􀀘􀀃􀀊􀀘􀀘􀀃􀀆􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀕􀀋􀀇􀀝􀀆􀀒􀀕􀀃􀀷􀀧􀀡􀀃􀀍􀀉􀀊􀀆􀀒􀀃􀀘􀀏􀀋􀀆􀀒􀀕
􀀋􀀎􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀞􀀆􀀋􀀏􀀖􀀢􀀖􀀃 􀀷􀀧􀀡􀀟􀀃 􀀥􀀎􀀍􀀇􀀒􀀘􀀣􀀃 􀀐􀀉􀀎􀀃 􀀊􀀘􀀘􀀆􀀐􀀆􀀇􀀒􀀃 􀀇􀀚
􀀐􀀉􀀆􀀖􀀃􀀌􀀇􀀑􀀎􀀍􀀏􀀑􀀎􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀎􀀚􀀚􀀎􀀍􀀐􀀆􀀞􀀎􀀑􀀓􀀃􀀖􀀐􀀇􀀈􀀃􀀚􀀏􀀋􀀐􀀉􀀎􀀋􀀃􀀷􀀧􀀡􀀃􀀊􀀖􀀖􀀎􀀌􀀔􀀑􀀓
􀀔􀀎􀀚􀀇􀀋􀀎􀀃 􀀍􀀇􀀌􀀈􀀑􀀎􀀐􀀆􀀇􀀒􀀃 􀀊􀀒􀀘􀀣􀀃 􀀉􀀎􀀒􀀍􀀎􀀣􀀃 􀀎􀀒􀀘􀀃 􀀷􀀧􀀡􀀃 􀀋􀀎􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀊􀀒􀀘
􀀈􀀋􀀎􀀞􀀎􀀒􀀐􀀃􀀞􀀆􀀋􀀊􀀑􀀃􀀈􀀋􀀇􀀈􀀊􀀕􀀊􀀐􀀆􀀇􀀒􀀟
􀀥􀀐􀀊􀀋􀀐􀀆􀀒􀀕􀀃􀀆􀀒􀀃􀀲􀀬􀀬􀀪􀀣􀀃􀀐􀀉􀀎􀀃􀀐􀀝􀀇􀀃􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀇􀀋􀀖􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀊􀀃􀀖􀀎􀀋􀀆􀀎􀀖􀀃􀀇􀀚􀀃􀀈􀀊􀀐􀀎􀀒􀀐
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃 􀀐􀀇􀀃 􀀊􀀒􀀐􀀆􀀞􀀆􀀋􀀊􀀑􀀃 􀀊􀀕􀀎􀀒􀀐􀀖􀀃 􀀚􀀇􀀋􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀟􀀃 􀀦􀀋􀀟
􀀠􀀉􀀆􀀑􀀑􀀆􀀈􀀎􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣􀀃􀀊􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀀃􀀝􀀉􀀇􀀃􀀉􀀊􀀘􀀃􀀔􀀎􀀍􀀇􀀌􀀎􀀃􀀊􀀃􀀈􀀊􀀐􀀎􀀒􀀐
􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀣􀀃 􀀝􀀊􀀖􀀃 􀀍􀀎􀀒􀀐􀀋􀀊􀀑􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀆􀀋􀀃 􀀆􀀒􀀆􀀐􀀆􀀊􀀑􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀆􀀒􀀕􀀃 􀀎􀀚􀀚􀀇􀀋􀀐􀀖􀀟􀀃 􀀱􀀟􀀡􀀟
􀀲􀀬􀀫􀀬􀀪􀀟􀀃 􀀡􀀃 􀀈􀀋􀀇􀀞􀀆􀀖􀀆􀀇􀀒􀀊􀀑􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀘􀀊􀀐􀀎􀀘􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀲􀀣
􀀲􀀬􀀬􀀪􀀣􀀃􀀖􀀏􀀌􀀌􀀊􀀋􀀆􀀻􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀞􀀎􀀒􀀐􀀆􀀇􀀒􀀃􀀊􀀖􀀃􀁆􀀊􀀃􀀌􀀎􀀐􀀉􀀇􀀘􀀃􀀚􀀇􀀋􀀃􀀆􀀒􀀉􀀆􀀔􀀆􀀐􀀆􀀒􀀕
􀀉􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀃 􀀞􀀆􀀋􀀏􀀖􀀃 􀁁􀀛􀀜􀁎􀁂􀀃 􀀧􀀥􀀨􀀅􀀃 􀀈􀀇􀀑􀀓􀀌􀀎􀀋􀀊􀀖􀀎􀀣􀀃 􀀊􀀃 􀀌􀀎􀀐􀀉􀀇􀀘􀀃 􀀚􀀇􀀋
􀀆􀀒􀀉􀀆􀀔􀀆􀀐􀀆􀀒􀀕􀀃 􀀛􀀜􀁎􀀃 􀀋􀀎􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃 􀀊􀀒􀀘􀁉􀀇􀀋􀀃 􀀊􀀃 􀀌􀀎􀀐􀀉􀀇􀀘􀀃 􀀚􀀇􀀋􀀃 􀀐􀀋􀀎􀀊􀀐􀀆􀀒􀀕
􀀛􀁀􀁎􀀃􀀆􀀒􀀚􀀎􀀍􀀐􀀆􀀇􀀒􀁇􀀃􀀔􀀓􀀃􀀊􀀘􀀌􀀆􀀒􀀆􀀖􀀐􀀎􀀋􀀆􀀒􀀕􀀃􀀊􀀃􀁆􀀐􀀉􀀎􀀋􀀊􀀈􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀑􀀓􀀃􀀎􀀚􀀚􀀎􀀍􀀐􀀆􀀞􀀎
􀀊􀀌􀀇􀀏􀀒􀀐􀀃􀀇􀀚􀀃􀀊􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀇􀀚􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃􀁀􀀟􀁇􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀨􀁃􀀬􀁃􀀟
􀁀􀀐􀀃􀀖􀀎􀀐􀀖􀀃􀀚􀀇􀀋􀀐􀀉􀀃􀀊􀀒􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀑􀀊􀀋􀀕􀀎􀀃􀀚􀀊􀀌􀀆􀀑􀀆􀀎􀀖􀀃􀀇􀀚􀀃􀀈􀀇􀀖􀀖􀀆􀀔􀀑􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖
􀀆􀀒􀀃 􀀼􀀊􀀋􀀗􀀏􀀖􀀉􀀃 􀀚􀀇􀀋􀀌􀀊􀀐􀀩􀀃 􀀆􀀐􀀃 􀀘􀀆􀀖􀀈􀀑􀀊􀀓􀀖􀀃 􀀊􀀃 􀀒􀀏􀀌􀀔􀀎􀀋􀀃 􀀇􀀚􀀃 􀀍􀀇􀀒􀀚􀀆􀀕􀀏􀀋􀀊􀀐􀀆􀀇􀀒􀀖
􀀇􀀚􀀃􀀒􀀏􀀍􀀑􀀎􀀆􀀍􀀃􀀊􀀍􀀆􀀘􀀃􀀘􀀎􀀋􀀆􀀞􀀊􀀐􀀆􀀞􀀎􀀖􀀃􀀊􀀒􀀘􀀃􀀖􀀉􀀇􀀝􀀖􀀃􀀞􀀊􀀋􀀆􀀊􀀔􀀑􀀎􀀖􀀃􀀊􀀐􀀃􀀊􀀃􀀒􀀏􀀌􀀔􀀎􀀋
􀀇􀀚􀀃􀀑􀀇􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀃􀁁􀀈􀀎􀀙􀀎􀀣􀀃􀀘􀀆􀀚􀀚􀀎􀀋􀀎􀀒􀀐􀀃􀀔􀀊􀀖􀀎􀀖􀀣􀀃􀀘􀀆􀀚􀀚􀀎􀀋􀀎􀀒􀀐
􀀌􀀇􀀑􀀎􀀍􀀏􀀑􀀎􀀖􀀃 􀀊􀀐􀀐􀀊􀀍􀀉􀀎􀀘􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀖􀀏􀀕􀀊􀀋􀀃 􀀋􀀆􀀒􀀕􀁂􀀣􀀃 􀀐􀀉􀀎􀀃 􀀞􀀊􀀋􀀆􀀊􀀔􀀑􀀎􀀖􀀃 􀀎􀀊􀀍􀀉
􀀖􀀐􀀊􀀐􀀎􀀘􀀃 􀀐􀀇􀀃 􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃 􀀊􀀒􀀓􀀃 􀀇􀀚􀀃 􀀊􀀃 􀀖􀀏􀀔􀀖􀀐􀀊􀀒􀀐􀀆􀀊􀀑􀀃 􀀒􀀏􀀌􀀔􀀎􀀋􀀃 􀀇􀀚􀀃 􀀈􀀇􀀖􀀖􀀆􀀔􀀑􀀎
􀀍􀀇􀀒􀀖􀀐􀀆􀀐􀀏􀀎􀀒􀀐􀀖􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀨􀁃􀀬􀀫􀁋􀀵􀁃􀀬􀀟
􀀶􀀉􀀎􀀃􀀖􀀊􀀌􀀎􀀃􀀆􀀖􀀃􀀐􀀋􀀏􀀎􀀃􀀇􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀐􀀝􀀇􀀃􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀲􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖
􀀏􀀒􀀘􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀃􀀜􀀇􀀇􀀈􀀎􀀋􀀊􀀐􀀆􀀇􀀒􀀃􀀶􀀋􀀎􀀊􀀐􀀓􀀃􀁁􀀠􀀜􀀶􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀁂􀀟􀀃􀀱􀀟􀀡􀀟
􀀲􀀭􀁃􀀫􀀲􀀣􀀃􀀲􀀳􀀵􀀪􀀫􀀟􀀃􀀽􀀒􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀱􀀏􀀑􀀓􀀃􀀲􀀬􀀬􀀫􀀃􀀤􀀟􀀥􀀟
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀪􀀬􀁉􀀲􀀨􀀬􀀣􀁃􀀮􀀫􀀣􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀆􀀖􀀖􀀏􀀎􀀘􀀃 􀀊􀀖􀀃 􀀐􀀉􀀎􀀃 􀀢􀀭􀀵􀀵􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀟
􀀱􀀟􀀡􀀟􀀃􀀪􀀨􀀬􀀣􀀃􀀲􀀮􀀲􀀲􀀮􀀟􀀃􀀡􀀃􀀒􀀇􀀒􀀄􀀈􀀋􀀇􀀞􀀆􀀖􀀆􀀇􀀒􀀊􀀑􀀃􀀤􀀟􀀥􀀟􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀆􀀒
􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀲􀀃􀀑􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀮􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎
􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀟􀀃􀀶􀀉􀀎􀀃􀀒􀀏􀀌􀀔􀀎􀀋􀀃􀀇􀀚􀀃􀀈􀀇􀀖􀀖􀀆􀀔􀀑􀀎􀀃􀀍􀀇􀀌􀀔􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀖
􀀝􀀆􀀐􀀉􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀗􀀏􀀖􀀉􀀃􀀕􀀋􀀇􀀏􀀈􀀖􀀃􀀆􀀖􀀃􀀞􀀎􀀋􀀓􀀃􀀑􀀊􀀋􀀕􀀎􀀟
􀀽􀀒􀀎􀀃􀀆􀀒􀀖􀀐􀀊􀀒􀀍􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀣􀀃􀀚􀀋􀀇􀀌
􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀫􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀆􀀖􀀩
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃 􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃 􀁀􀁀􀁀􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀆􀀖􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎
􀀖􀀐􀀎􀀋􀀎􀀇􀀍􀀉􀀎􀀌􀀆􀀍􀀊􀀑􀀃􀀍􀀇􀀒􀀚􀀆􀀕􀀏􀀋􀀊􀀐􀀆􀀇􀀒􀀩
􀀕􀀖􀀗􀀘􀀢 􀀃􀀝􀀉􀀎􀀋􀀎􀀆􀀒􀀃􀀅􀀃􀀆􀀖
􀀦􀀃 􀀆􀀖􀀃 􀀧􀀣􀀃 􀀜􀀛􀀣􀀃 􀀜􀁄􀀜􀀧􀀣􀀃 􀀜􀁄􀀧􀀽􀀲􀀣􀀃 􀀜􀁄􀀜􀀪􀀄􀀫􀀃 􀀊􀀑􀀗􀀓􀀑􀀣􀀃 􀀜
􀁄􀀧􀀛􀀜􀀽􀀧􀀛􀀲􀀣􀀃 􀀜􀁄􀀜􀀽􀀧􀀷 􀀪􀀪 􀀷 􀀪􀀪 􀀣􀀃 􀀜􀁄􀀜􀀥􀀧􀀷􀀪􀀪􀀷􀀪􀀪􀀣􀀃 􀀜
􀁄􀀜􀀽􀀽􀀷􀀪􀀪􀀣􀀃 􀀜􀀄􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣􀀃 􀀜􀁄􀀜􀀪􀀄􀀫􀀃 􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃 􀀜􀀄􀀊􀀌􀀆􀀒􀀇􀀣
􀀜􀁄􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀜􀀄􀀘􀀆􀁁􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀜􀀄
􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃 􀀜􀀄􀁁􀀪􀀣􀀫􀀄􀀳􀀅􀁈􀀊􀀻􀀇􀀑􀀄􀀲􀀄􀀓􀀑􀁂􀀣􀀃 􀀜􀀄􀁁􀀪􀀣􀀫􀀄􀀐􀀉􀀆􀀊􀀻􀀇􀀑􀀄􀀲􀀄􀀓􀀑􀁂􀀣􀀃 􀀇􀀋
􀀜􀀄􀁁􀀆􀀌􀀆􀀘􀀊􀀻􀀇􀀑􀀄􀀲􀀄􀀓􀀑􀁂􀀺􀀃 􀀝􀀉􀀎􀀋􀀎􀀆􀀒􀀃 􀀊􀀑􀀗􀀓􀀑􀀃 􀀆􀀖􀀃 􀀏􀀒􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃 􀀇􀀋
􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃 􀀝􀀆􀀐􀀉􀀃 􀀇􀀒􀀎􀀃 􀀐􀀇􀀃 􀀐􀀉􀀋􀀎􀀎􀀃 􀀕􀀋􀀇􀀏􀀈􀀖􀀃 􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓
􀀖􀀎􀀑􀀎􀀍􀀐􀀎􀀘􀀃􀀚􀀋􀀇􀀌􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣􀀃􀀍􀀊􀀋􀀔􀀇􀁈􀀓􀀣􀀃􀀊􀀒􀀘
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀨
􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀺
􀀴􀀃􀀆􀀖􀀃􀀽􀀃􀀇􀀋􀀃􀀥􀀺
􀀾􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀜􀀪􀀄􀀪􀀬􀀃 􀀊􀀑􀀗􀀓􀀑􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀣􀀃 􀀠􀀫􀀽􀀵􀀛􀀭􀀣􀀃 􀀠􀀲􀀽􀀳􀀛􀀫􀀣􀀃 􀀇􀀋
􀀠􀁁􀀽􀁂􀀷 􀀵 􀀷 􀀪􀀬 􀀺
􀀷 􀀪 􀀃􀀆􀀖􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣􀀃􀀜􀀰􀀫􀀣􀀃􀀇􀀋􀀃􀀆􀀇􀀄􀀈􀀃􀀉􀀊􀀋􀀌􀀊􀀃􀀊􀀒􀀘􀀃􀀇􀀒􀀎􀀃􀀇􀀚􀀃􀀷 􀀲 􀀃􀀊􀀒􀀘􀀃􀀷 􀀫
􀀆􀀖􀀃 􀀽􀀛􀀃 􀀇􀀋􀀃 􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀇􀁈􀀓􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀎􀀃 􀀇􀀐􀀉􀀎􀀋􀀃 􀀇􀀚􀀃 􀀷 􀀲 􀀃 􀀊􀀒􀀘􀀃 􀀷 􀀫 􀀃 􀀆􀀖
􀀖􀀎􀀑􀀎􀀍􀀐􀀎􀀘􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀕􀀋􀀇􀀏􀀈􀀃􀀍􀀇􀀒􀀖􀀆􀀖􀀐􀀆􀀒􀀕􀀃􀀇􀀚
􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣
􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣
􀀍􀀊􀀎􀀅􀀏􀀅􀀣
􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀓􀀑􀀣
􀀐􀀋􀀆􀀚􀀑􀀏􀀇􀀋􀀇􀀌􀀎􀀐􀀉􀀓􀀑􀀣
􀀜􀀪􀀄􀁃􀀃􀀊􀀑􀀗􀀓􀀑􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀇􀁈􀀓􀀣
􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀊􀀒􀀘
􀀊􀀌􀀆􀀒􀀇􀀺􀀃􀀇􀀋
􀀷 􀀲 􀀃 􀀆􀀖􀀃 􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣􀀃 􀀜􀀰􀀫􀀣􀀃 􀀇􀀋􀀃 􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀃 􀀊􀀒􀀘􀀃 􀀇􀀒􀀎􀀃 􀀇􀀚􀀃 􀀷 􀀪 􀀃 􀀊􀀒􀀘
􀀷 􀀫 􀀃􀀆􀀖􀀃􀀽􀀛􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀇􀀐􀀉􀀎􀀋􀀃􀀇􀀚􀀃􀀷 􀀪 􀀃􀀊􀀒􀀘􀀃􀀷 􀀫 􀀃􀀆􀀖
􀀖􀀎􀀑􀀎􀀍􀀐􀀎􀀘􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀕􀀋􀀇􀀏􀀈􀀃􀀍􀀇􀀒􀀖􀀆􀀖􀀐􀀆􀀒􀀕􀀃􀀇􀀚
􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣
􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣
􀀚􀀑􀀏􀀇􀀋􀀇􀀣
􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀓􀀑􀀣
􀀐􀀋􀀆􀀚􀀑􀀏􀀇􀀋􀀇􀀌􀀎􀀐􀀉􀀓􀀑􀀣
􀀜􀀪􀀄􀁃􀀃􀀊􀀑􀀗􀀓􀀑􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀇􀁈􀀓􀀣
􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀊􀀒􀀘
􀀊􀀌􀀆􀀒􀀇􀀺􀀃􀀇􀀋
􀀷 􀀪 􀀃􀀊􀀒􀀘􀀃􀀷 􀀲 􀀃􀀐􀀇􀀕􀀎􀀐􀀉􀀎􀀋􀀃􀀝􀀆􀀐􀀉􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀋􀀔􀀇􀀒􀀃􀀊􀀐􀀇􀀌􀀃􀀐􀀇􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀐􀀉􀀎􀀓􀀃􀀊􀀋􀀎
􀀊􀀐􀀐􀀊􀀍􀀉􀀎􀀘􀀃􀀚􀀇􀀋􀀌􀀃􀀊􀀃􀀫􀀄􀀃􀀐􀀇􀀃􀀳􀀄􀀌􀀎􀀌􀀔􀀎􀀋􀀎􀀘􀀃􀀖􀀊􀀐􀀏􀀋􀀊􀀐􀀎􀀘􀀃􀀌􀀇􀀒􀀇􀀍􀀓􀀍􀀑􀀆􀀍
􀀋􀀆􀀒􀀕􀀃􀀖􀀓􀀖􀀐􀀎􀀌􀀃􀀇􀀈􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃􀀍􀀇􀀒􀀐􀀊􀀆􀀒􀀆􀀒􀀕􀀃􀀊􀀃􀀉􀀎􀀐􀀎􀀋􀀇􀀊􀀐􀀇􀀌􀀃􀀖􀀎􀀑􀀎􀀍􀀐􀀎􀀘
􀀚􀀋􀀇􀀌􀀃􀀽􀀣􀀃􀀥􀀣􀀃􀀊􀀒􀀘􀀃􀀧􀀜􀀬􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀺
􀀷 􀀳 􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀽􀀛􀀣􀀃 􀀥􀀛􀀣􀀃 􀀧􀀛􀀲􀀣􀀃 􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀘􀀆􀁁􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀫􀀄􀀳􀀃􀀍􀀓􀀍􀀑􀀇􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀣
􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀇􀀋􀀃􀀜􀀰􀀫􀀺
􀀷 􀀨 􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀜􀀪􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀎􀀒􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀒􀀓􀀑􀀣􀀃 􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀰􀀫􀀣􀀃􀀇􀀋􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀺
􀀷 􀀮 􀀃 􀀆􀀖􀀃 􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣􀀃 􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀜􀀫􀀄􀀳
􀀍􀀓􀀍􀀑􀀇􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀇􀀋􀀃􀀘􀀆􀁁􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀺
􀀎􀀊􀀍􀀉􀀃􀀷 􀀪􀀪 􀀃􀀆􀀖􀀃􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓􀀃􀀛􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀳􀀃􀀊􀀑􀀗􀀓􀀑􀀺
􀀷 􀁃 􀀃􀀆􀀖􀀃􀀛􀀣􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃􀀜􀀧􀀣􀀃􀀍􀀊􀀋􀀔􀀇􀁈􀀓􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀇􀁈􀀓􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀣􀀃􀀧􀀫􀀣
􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀘􀀆􀁁􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣
􀀜􀀪􀀄􀀳􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀜􀀪􀀄􀀳􀀃􀀊􀀑􀀗􀀓􀀑􀀐􀀉􀀆􀀇􀀣􀀃􀀜􀀪􀀄􀀳􀀃􀀊􀀑􀀗􀀓􀀑􀀖􀀏􀀑􀀚􀀇􀀒􀀓􀀑􀀣􀀃􀀇􀀋􀀃􀁁􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀁂􀀬􀀄􀀲􀀃􀀊􀀌􀀆􀀒􀀇􀀌􀀎􀀐􀀉􀀓􀀑􀀺􀀃􀀊􀀒􀀘
􀀷 􀀵 􀀃 􀀊􀀒􀀘􀀃 􀀷 􀀪􀀬 􀀃 􀀊􀀋􀀎􀀃 􀀎􀀊􀀍􀀉􀀃 􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓􀀃 􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣
􀀽􀀜􀀛􀀲􀀜􀀛􀀲􀀥􀀜􀁁􀁐􀀽􀁂􀀐􀀄􀀔􀀏􀀐􀀓􀀑􀀣􀀃􀀇􀀋􀀃􀀽􀀜􀀛􀀲􀀽􀁁􀀜􀁐􀀽􀁂􀀆􀀠􀀋􀀺
􀀝􀀆􀀐􀀉􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀇􀀞􀀆􀀖􀀇􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀁁􀀊􀁂􀀃􀀝􀀉􀀎􀀒􀀃􀀷 􀀪 􀀃􀀆􀀖􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀃􀀊􀀒􀀘􀀃􀀷 􀀲 􀀃􀀆􀀖
􀀚􀀑􀀏􀀇􀀋􀀇􀀣􀀃􀀐􀀉􀀎􀀒􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀣􀀃􀀐􀀋􀀆􀀚􀀑􀀏􀀇􀀋􀀇􀀌􀀎􀀐􀀉􀀓􀀑􀀣􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀣
􀀕􀀖􀀗􀀘􀀣 􀀃􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀓􀀑􀀣􀀃􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀺􀀃􀁁􀀔􀁂􀀃􀀝􀀉􀀎􀀒􀀃􀀷 􀀪
􀀆􀀖􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀃􀀊􀀒􀀘􀀃􀀷 􀀲 􀀃􀀆􀀖􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀣􀀃􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀫􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣
􀀐􀀉􀀎􀀒􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀃􀀇􀀋􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀺􀀃􀀊􀀒􀀘􀀃􀁁􀀍􀁂􀀃􀀝􀀉􀀎􀀒􀀃􀀷 􀀪 􀀃􀀆􀀖
􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀃􀀊􀀒􀀘􀀃􀀷 􀀲 􀀃􀀆􀀖􀀃􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣􀀃􀀐􀀉􀀎􀀒􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀁑􀀄􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀟
􀀢􀀭􀀵􀀵􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀍􀀇􀀑􀀟􀀃􀀪􀀫􀀣􀀃􀀑􀀆􀀒􀀎􀀃􀀨􀀃􀀐􀀉􀀋􀀇􀀏􀀕􀀉􀀃􀀍􀀇􀀑􀀟􀀃􀀪􀀭􀀣􀀃􀀑􀀆􀀒􀀎􀀃􀀪􀀮􀀃􀁁􀀎􀀌􀀈􀀉􀀊􀀖􀀎􀀖
􀀊􀀘􀀘􀀎􀀘􀀃􀀐􀀇􀀃􀀉􀀆􀀕􀀉􀀑􀀆􀀕􀀉􀀐􀀃􀀐􀀎􀀋􀀌􀀖􀀃􀀇􀀚􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀏􀀑􀀊􀀋􀀃􀀆􀀒􀀐􀀎􀀋􀀎􀀖􀀐􀀃􀀚􀀇􀀋􀀃􀀐􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀁂􀀺
􀀱􀀟􀀡􀀟􀀃􀀲􀀮􀀲􀀭􀀨􀁋􀀭􀀮􀀟 􀀪
􀁎􀀊􀀋􀀆􀀇􀀏􀀖􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀊􀀈􀀈􀀎􀀊􀀋􀀎􀀘􀀃􀀆􀀒􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀔􀀊􀀖􀀎􀀘
􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃􀀇􀀋􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀇􀀒􀀎􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀳
􀀊􀀒􀀘􀀃􀁃􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀪􀀃􀀈􀀋􀀇􀀞􀀆􀀖􀀆􀀇􀀒􀀊􀀑􀀣􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀨􀀵􀀨􀀭􀁋􀀨􀀳􀀣􀀃􀀍􀀑􀀊􀀆􀀌􀀖
􀀳􀀃􀀊􀀒􀀘􀀃􀁃􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀠􀀜􀀶􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣
􀀱􀀟􀀡􀀟􀀃􀀲􀀨􀀬􀀫􀀳􀁋􀀫􀁃􀀣􀀃􀀊􀀒􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀭􀀭􀀃􀀇􀀚􀀃􀀐􀀉􀀊􀀐􀀃􀀖􀀊􀀌􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀝􀀉􀀆􀀍􀀉
􀀝􀀊􀀖􀀃􀀊􀀘􀀘􀀎􀀘􀀣􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀆􀀒􀀕􀀃􀀚􀀇􀀋􀀃􀀎􀀊􀀋􀀑􀀆􀀎􀀋􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀣􀀃􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃􀀏􀀈􀀇􀀒
􀀚􀀆􀀑􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀤􀀟􀀥􀀟􀀃 􀀞􀀎􀀋􀀖􀀆􀀇􀀒􀀃 􀀆􀀒􀀃 􀀱􀀏􀀑􀀓􀀃 􀀲􀀬􀀬􀀫􀀣􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀮􀀭􀁃􀀲􀁋􀁃􀀫􀀟􀀃 􀀶􀀉􀀎
􀀲􀀬􀀬􀀫􀀄􀀊􀀘􀀘􀀎􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀭􀀭􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀫􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀚􀀇􀀋􀀃􀀎􀁈􀀊􀀌􀀈􀀑􀀎􀀣
􀀋􀀎􀀍􀀆􀀐􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀊􀀔􀀇􀀞􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃􀀔􀀏􀀐􀀃􀀆􀀖􀀃􀀑􀀆􀀌􀀆􀀐􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀖􀀆􀀒􀀕􀀑􀀎􀀄
􀀋􀀆􀀒􀀕􀀃􀀔􀀊􀀖􀀎􀀖􀀃􀀖􀀉􀀇􀀝􀀒􀀃􀀊􀀔􀀇􀀞􀀎􀀃􀁁􀀈􀀓􀀋􀀆􀀌􀀆􀀘􀀆􀀒􀀎􀀃􀀔􀀊􀀖􀀎􀀖􀀣􀀃􀀖􀀏􀀍􀀉􀀃􀀊􀀖􀀃􀀍􀀓􀀐􀀇􀀖􀀆􀀒􀀎
􀀊􀀒􀀘􀀃 􀀏􀀋􀀊􀀍􀀆􀀑􀁂􀀟􀀃 􀁀􀀐􀀃 􀀐􀀉􀀎􀀋􀀎􀀚􀀇􀀋􀀎􀀃 􀀇􀀌􀀆􀀐􀀖􀀃 􀀐􀀉􀀎􀀃 􀀊􀀔􀀇􀀞􀀎􀀄􀁊􀀏􀀇􀀐􀀎􀀘􀀃 􀀑􀀊􀀒􀀕􀀏􀀊􀀕􀀎
􀀍􀀇􀀒􀀍􀀎􀀋􀀒􀀆􀀒􀀕􀀃􀀦􀀣􀀃􀀷 􀀮 􀀣􀀃􀀊􀀒􀀘􀀃􀀷 􀁃 􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀊􀀈􀀈􀀎􀀊􀀋􀀃􀀇􀀒􀀑􀀓􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀘􀀇􀀏􀀔􀀑􀀎􀀄
􀀋􀀆􀀒􀀕􀀃􀀔􀀊􀀖􀀎􀀖􀀃􀀖􀀉􀀇􀀝􀀒􀀃􀀊􀀔􀀇􀀞􀀎􀀃􀁁􀀈􀀏􀀋􀀆􀀒􀀎􀀃􀀔􀀊􀀖􀀎􀀖􀀣􀀃􀀖􀀏􀀍􀀉􀀃􀀊􀀖􀀃􀀊􀀘􀀎􀀒􀀆􀀒􀀎􀀃􀀊􀀒􀀘
􀀕􀀏􀀊􀀒􀀆􀀒􀀎􀁂􀀟􀀃􀀐􀀊􀀎
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀎
􀀜􀀑􀀊􀀆􀀌􀀃􀀭􀀭􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀫􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀆􀀐􀀖􀀃􀀠􀀜􀀶􀀃􀀍􀀇􀀏􀀒􀀐􀀎􀀋􀀄􀀈􀀊􀀋􀀐􀀣
􀀑􀀆􀀗􀀎􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃􀁀􀁀􀁀􀀣􀀃􀀎􀀒􀀍􀀇􀀌􀀈􀀊􀀖􀀖􀀎􀀖􀀣􀀃􀀊􀀌􀀇􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀑􀀊􀀋􀀕􀀎
􀀒􀀏􀀌􀀔􀀎􀀋􀀃􀀇􀀚􀀃􀀈􀀇􀀖􀀖􀀆􀀔􀀑􀀎􀀃􀀍􀀇􀀌􀀔􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀇􀀚􀀃􀀞􀀊􀀑􀀏􀀎􀀖􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀞􀀊􀀋􀀆􀀊􀀔􀀑􀀎􀀖􀀣
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀃 􀀉􀀊􀀞􀀆􀀒􀀕􀀃 􀁁􀀆􀁂􀀃 􀀊􀀃 􀀖􀀆􀀒􀀕􀀑􀀎􀀄􀀋􀀆􀀒􀀕􀀃 􀀔􀀊􀀖􀀎􀀣􀀃 􀁁􀀆􀀆􀁂􀀃 􀀊􀀃 􀀌􀀎􀀐􀀉􀀓􀀑􀀃 􀁁􀀜􀀪
􀀊􀀑􀀗􀀓􀀑􀁂􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀷 􀀪 􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃 􀀊􀀒􀀘􀀃 􀁁􀀆􀀆􀀆􀁂􀀃 􀀊􀀃 􀀚􀀑􀀏􀀇􀀋􀀇􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀷 􀀲 􀀃 􀀇􀀋
􀀷 􀀫 􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀨􀀬􀀫􀀳􀁋􀀫􀁃􀀣􀀃 􀀲􀀮􀀭􀁃􀀲􀁋􀁃􀀫􀀟􀀃 􀀡􀀃 􀀖􀀏􀀔􀀕􀀎􀀒􀀏􀀖􀀃 􀀝􀀆􀀐􀀉
􀀐􀀉􀀇􀀖􀀎􀀃􀀍􀀉􀀊􀀋􀀊􀀍􀀐􀀎􀀋􀀆􀀖􀀐􀀆􀀍􀀖􀁄􀀝􀀉􀀆􀀍􀀉􀀃􀀎􀀌􀀔􀀋􀀊􀀍􀀎􀀖􀀃􀀔􀀇􀀐􀀉􀀃􀀊􀀃􀀌􀀎􀀐􀀊􀀔􀀇􀀑􀀆􀀐􀀎􀀃􀀇􀀚
􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀃􀀊􀀒􀀘􀀃􀀊􀀒􀀃􀀎􀀊􀀋􀀑􀀆􀀎􀀋􀀃􀀆􀀘􀀎􀀒􀀐􀀆􀀚􀀆􀀎􀀘􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀐􀀉􀀊􀀐
􀀝􀀊􀀖􀀃 􀀌􀀇􀀘􀀆􀀚􀀆􀀎􀀘􀀃 􀀐􀀇􀀃 􀀊􀀋􀀋􀀆􀀞􀀎􀀃 􀀊􀀐􀀃 􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀣􀀃 􀀊􀀒􀀘􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀼􀀎􀀋􀀍􀀗
􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃􀀚􀀇􀀍􀀏􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀆􀀒􀀃􀀒􀀎􀀝􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀆􀀒􀀃􀀲􀀬􀀬􀀨􀁄􀀆􀀖􀀃􀀍􀀎􀀒􀀐􀀋􀀊􀀑􀀃􀀆􀀒
􀀐􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀀟
􀀅
􀁀􀀒􀀃􀀲􀀬􀀬􀀲􀀣􀀃􀀊􀀃􀀈􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀃􀀍􀀇􀀌􀀈􀀊􀀒􀀓􀀃􀀍􀀊􀀑􀀑􀀎􀀘􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀣􀀃􀀝􀀉􀀆􀀍􀀉
􀀝􀀊􀀖􀀃 􀀑􀀊􀀐􀀎􀀋􀀃 􀀊􀀍􀁊􀀏􀀆􀀋􀀎􀀘􀀃 􀀔􀀓􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀣􀀃 􀀝􀀊􀀖􀀃 􀀋􀀎􀀖􀀎􀀊􀀋􀀍􀀉􀀆􀀒􀀕􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜
􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀖􀀟􀀃 􀀴􀀉􀀎􀀒􀀃 􀀇􀀒􀀎􀀃 􀀇􀀚􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀎􀀊􀀋􀀑􀀓􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃 􀀝􀀊􀀖
􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀓􀀎􀀊􀀋􀀣􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀋􀀎􀀞􀀆􀀎􀀝􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣
􀀑􀀇􀀇􀀗􀀆􀀒􀀕􀀃􀀚􀀇􀀋􀀃􀁆􀀑􀀇􀀇􀀈􀀉􀀇􀀑􀀎􀀖􀀟􀁇􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀬􀀬􀀭􀁃􀀃􀁁􀀨􀀫􀀫􀁂􀀟􀀃􀀡􀀚􀀐􀀎􀀋􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀆􀀒􀀕
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀱􀀎􀀋􀀎􀀌􀀓􀀃􀀜􀀑􀀊􀀋􀀗􀀣􀀃􀀊􀀃􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀀃􀀊􀀐􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀣
􀀈􀀋􀀇􀀈􀀇􀀖􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀁁􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀑􀀎􀀘􀀃􀀐􀀇
􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀁂􀀟􀀃􀀐􀀊􀀎􀀃􀁁􀀨􀀫􀀫􀁋􀀨􀀫􀀭􀁂􀀟􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀉􀀊􀀘􀀃􀀊􀀃􀀖􀀆􀀒􀀕􀀑􀀎􀀄􀀋􀀆􀀒􀀕􀀃􀀔􀀊􀀖􀀎
􀁁􀀍􀀓􀀐􀀇􀀖􀀆􀀒􀀎􀁂􀀣􀀃􀀊􀀃􀀌􀀎􀀐􀀉􀀓􀀑􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀲􀁒􀀃􀀏􀀈􀀃􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃􀀊􀀒􀀘􀀃􀀊􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀃􀀆􀀒􀀃􀀐􀀉􀀎
􀀲􀁒􀀃􀀘􀀇􀀝􀀒􀀃􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀭􀀳􀀪􀀵􀀣􀀃􀀲􀀭􀁃􀀲􀀳􀀟􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀖􀀓􀀒􀀐􀀉􀀎􀀖􀀆􀀻􀀎􀀘
􀀊􀀒􀀘􀀃 􀀐􀀎􀀖􀀐􀀎􀀘􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃 􀀔􀀓􀀃 􀀼􀀊􀀓􀀃 􀀲􀀬􀀬􀀫􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀬􀀬􀀭􀀬􀀃 􀁁􀀨􀀬􀀭􀁂􀀟􀀃 􀁀􀀐
􀀝􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀚􀀆􀀋􀀖􀀐􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀌􀀊􀀘􀀎􀀃􀀔􀀓􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀊􀀖􀀃􀀊􀀍􀀐􀀆􀀞􀀎
􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃􀀜􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀬􀀬􀀨􀀬􀁋􀀨􀀪􀀃􀁁􀀨􀀭􀀭􀁋􀀭􀀨􀁂􀀟􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀑􀀎􀀘􀀃􀀐􀀇
􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀉􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀖􀀊􀀌􀀎􀀃􀀌􀀎􀀐􀀉􀀓􀀑􀀃􀀊􀀒􀀘􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀎􀀒􀀐􀀖
􀀊􀀖􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀔􀀏􀀐􀀃􀀍􀀇􀀒􀀐􀀊􀀆􀀒􀀖􀀃􀀏􀀋􀀊􀀍􀀆􀀑􀀣􀀃􀀋􀀊􀀐􀀉􀀎􀀋􀀃􀀐􀀉􀀊􀀒􀀃􀀍􀀓􀀐􀀇􀀖􀀆􀀒􀀎􀀣􀀃􀀊􀀖􀀃􀀆􀀐􀀖
􀀔􀀊􀀖􀀎􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀵􀀪􀀫􀁋􀀪􀀮􀀣􀀃􀀪􀀵􀀵􀀨􀀪􀀃􀁁􀀭􀀬􀀪􀁂􀀟
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀊􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀚􀀇􀀋􀀃􀀼􀀋􀀟􀀃􀀜􀀑􀀊􀀋􀀗􀀢􀀖􀀃􀀆􀀒􀀞􀀎􀀒􀀐􀀆􀀇􀀒
􀀆􀀒􀀃 􀀼􀀊􀀓􀀃 􀀲􀀬􀀬􀀫􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀬􀀬􀀭􀀲􀀃 􀁁􀀨􀀪􀀪􀁋􀀪􀀲􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀝􀀊􀀖
􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃 􀀆􀀒􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀟􀀃 􀀶􀀉􀀎􀀃 􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃 􀀐􀀉􀀎
􀁆􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀁇􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀎􀀘􀀃􀀊􀀒􀀘􀀃􀀍􀀑􀀊􀀆􀀌􀀎􀀘􀀃􀁁􀀆􀀒􀀃􀀪􀀲􀀵􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀁂
􀀊􀀃􀀋􀀊􀀒􀀕􀀎􀀃􀀇􀀚􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀔􀀇􀀐􀀉􀀃􀀖􀀆􀀒􀀕􀀑􀀎􀀄􀀋􀀆􀀒􀀕􀀃􀁁􀀈􀀓􀀋􀀆􀀌􀀆􀀘􀀆􀀒􀀎􀁂
􀀊􀀒􀀘􀀃􀀘􀀇􀀏􀀔􀀑􀀎􀀄􀀋􀀆􀀒􀀕􀀃􀁁􀀈􀀏􀀋􀀆􀀒􀀎􀁂􀀃􀀔􀀊􀀖􀀎􀀖􀀣􀀃􀀊􀀒􀀘􀀃􀀌􀀎􀀐􀀉􀀇􀀘􀀖􀀃􀀇􀀚􀀃􀀏􀀖􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀌
􀀚􀀇􀀋􀀃 􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀃 􀀇􀀚􀀃 􀀞􀀊􀀋􀀆􀀇􀀏􀀖􀀃 􀀍􀀇􀀒􀀘􀀆􀀐􀀆􀀇􀀒􀀖􀀣􀀃 􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀟
􀀱􀀟􀀡􀀟􀀃􀀲􀀫􀀮􀀬􀀵􀁋􀁃􀀳􀀟􀀃􀀡􀀌􀀇􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀌􀀊􀀒􀀓􀀃􀀖􀀈􀀎􀀍􀀆􀀚􀀆􀀍􀀊􀀑􀀑􀀓􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀎􀀘􀀃􀀊􀀒􀀘
􀀍􀀑􀀊􀀆􀀌􀀎􀀘􀀃 􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀃 􀀝􀀊􀀖􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀫􀀮􀀲􀀮􀀃 􀁁􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀕􀀖􀀗􀀘􀀤 􀀃􀁓􀀃􀀪􀀳􀁃􀁂􀀣􀀃􀀲􀀫􀀮􀀨􀀳􀀃􀁁􀀍􀀑􀀊􀀆􀀌􀀃􀀲􀀳􀁂􀀟􀀃􀀶􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀆􀀒
􀀥􀀎􀀈􀀐􀀎􀀌􀀔􀀎􀀋􀀃􀀲􀀬􀀬􀁃􀀃􀀊􀀖􀀃􀀤􀀟􀀥􀀟􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀃􀀧􀀇􀀟􀀃􀀮􀀣􀀭􀀲􀀵􀀣􀀨􀀮􀀲􀀣􀀃􀀝􀀆􀀐􀀉􀀃􀀇􀀒􀀑􀀓􀀃􀀪􀀵
􀀍􀀑􀀊􀀆􀀌􀀖􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀍􀀇􀀞􀀎􀀋􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀵􀀵􀀭􀀮􀁋􀁃􀀮􀀟
􀀜
􀁀􀀒􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀣􀀃 􀀐􀀉􀀎􀀃 􀀌􀀇􀀒􀀐􀀉􀀃 􀀊􀀚􀀐􀀎􀀋􀀃 􀀐􀀉􀀎􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨
􀀈􀀏􀀔􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀜􀀑􀀊􀀋􀀗􀀃 􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃 􀀼􀀎􀀋􀀍􀀗􀀣􀀃 􀀐􀀉􀀋􀀇􀀏􀀕􀀉􀀃 􀀦􀀋􀀟
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀊􀀃􀀒􀀊􀀋􀀋􀀇􀀝􀀆􀀒􀀕􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀫􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀐􀀉􀀊􀀐􀀃 􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃 􀀆􀀖􀀖􀀏􀀎􀀘􀀃 􀀊􀀖􀀃 􀀐􀀉􀀎􀀃 􀀢􀀭􀀵􀀵􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀁃􀀫􀀪􀁃􀁋􀀲􀀪􀀟
􀀼􀀎􀀋􀀍􀀗􀀃 􀀍􀀊􀀒􀀍􀀎􀀑􀀎􀀘􀀃 􀀊􀀑􀀑􀀃 􀀈􀀎􀀒􀀘􀀆􀀒􀀕􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀊􀀒􀀘􀀃 􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃 􀀐􀀝􀀇
􀀒􀀊􀀋􀀋􀀇􀀝􀀎􀀋􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀁁􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀨􀀫􀀃 􀀊􀀒􀀘􀀃 􀀨􀀭􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀆􀀖􀀖􀀏􀀎􀀘􀀃 􀀊􀀖
􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀪􀀃􀀊􀀒􀀘􀀃􀀲􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀇􀀒􀀃􀀥􀀎􀀈􀀐􀀎􀀌􀀔􀀎􀀋􀀃􀀪􀀲􀀣􀀃􀀲􀀬􀀬􀀳􀀟
􀀜􀀑􀀊􀀆􀀌􀀃􀀪􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀆􀀖􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎􀀟􀀃􀁀􀀐􀀃􀀖􀀐􀀊􀀐􀀎􀀖􀀩
􀀪􀀟􀀃 􀀡􀀃 􀀌􀀎􀀐􀀉􀀇􀀘􀀃 􀀇􀀚􀀃 􀀐􀀋􀀎􀀊􀀐􀀆􀀒􀀕􀀃 􀀉􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖
􀀜􀀃 􀀞􀀆􀀋􀀏􀀖􀀃 􀁁􀀛􀀜􀁎􀁂􀀃 􀀆􀀒􀀚􀀎􀀍􀀐􀀆􀀇􀀒􀀃 􀀍􀀇􀀌􀀈􀀋􀀆􀀖􀀆􀀒􀀕
􀀊􀀘􀀌􀀆􀀒􀀆􀀖􀀐􀀎􀀋􀀆􀀒􀀕􀀃 􀀐􀀇􀀃 􀀊􀀃 􀀌􀀊􀀌􀀌􀀊􀀑􀀃 􀀆􀀒􀀃 􀀒􀀎􀀎􀀘
􀀇􀀚􀀃 􀀖􀀏􀀍􀀉􀀃 􀀐􀀋􀀎􀀊􀀐􀀌􀀎􀀒􀀐􀀃 􀀊􀀃 􀀐􀀉􀀎􀀋􀀊􀀈􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀑􀀓
􀀎􀀚􀀚􀀎􀀍􀀐􀀆􀀞􀀎􀀃 􀀊􀀌􀀇􀀏􀀒􀀐􀀃 􀀇􀀚􀀃 􀀊􀀃 􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘
􀀇􀀚􀀃 􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀊􀀑􀀃 􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀃 􀁀􀁀􀁀􀀣􀀃 􀀇􀀋􀀃 􀀊
􀀈􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀑􀀓􀀃 􀀊􀀍􀀍􀀎􀀈􀀐􀀊􀀔􀀑􀀎􀀃 􀀖􀀊􀀑􀀐􀀃 􀀇􀀋
􀀊􀀍􀀓􀀑􀀃􀀘􀀎􀀋􀀆􀀞􀀊􀀐􀀆􀀞􀀎􀀖􀀃􀀐􀀉􀀎􀀋􀀎􀀇􀀚􀀣
􀀝􀀉􀀎􀀋􀀎􀀆􀀒􀀃􀀅􀀃􀀆􀀖
􀀴􀀃􀀆􀀖􀀃􀀽􀀃􀀇􀀋􀀃􀀥􀀺
􀀾􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀜􀀪􀀄􀀪􀀬􀀃 􀀊􀀑􀀗􀀓􀀑􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀣􀀃 􀀠􀀫􀀽􀀵􀀛􀀭􀀣􀀃 􀀠􀀲􀀽􀀳􀀛􀀫􀀣􀀃 􀀇􀀋
􀀠􀁁􀀽􀁂􀀷 􀀵 􀀷 􀀪􀀬 􀀺
􀀷 􀀪 􀀃􀀆􀀖􀀃􀀜􀀰􀀫􀀣􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀃􀀊􀀒􀀘􀀃􀀇􀀒􀀎􀀃􀀇􀀚􀀃􀀷 􀀲 􀀃􀀊􀀒􀀘􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀽􀀛􀀃􀀇􀀋
􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀇􀀐􀀉􀀎􀀋􀀃􀀇􀀚􀀃􀀷 􀀲 􀀃􀀊􀀒􀀘􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀚􀀑􀀏􀀇􀀋􀀇􀀺
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀩
􀀷 􀀳 􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀽􀀛􀀣􀀃 􀀥􀀛􀀣􀀃 􀀧􀀛􀀲􀀣􀀃 􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀘􀀆􀁁􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀫􀀄􀀳􀀃􀀍􀀓􀀍􀀑􀀇􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀣
􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀇􀀋􀀃􀀜􀀰􀀫􀀺
􀀷 􀀨 􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀜􀀪􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀎􀀒􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀒􀀓􀀑􀀣􀀃 􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀰􀀫􀀣􀀃􀀇􀀋􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀺􀀃􀀊􀀒􀀘
􀀷 􀀵 􀀃 􀀊􀀒􀀘􀀃 􀀷 􀀪􀀬 􀀃 􀀊􀀋􀀎􀀃 􀀎􀀊􀀍􀀉􀀃 􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓􀀃 􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣
􀀽􀀜􀀛􀀲􀀜􀀛􀀲􀀥􀀜􀁁􀁐􀀽􀁂􀀐􀀄􀀔􀀏􀀐􀀓􀀑􀀣􀀃􀀇􀀋􀀃􀀽􀀜􀀛􀀲􀀽􀁁􀀜􀁐􀀽􀁂􀀆􀀠􀀋􀀟
􀀢􀀭􀀵􀀵􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀍􀀇􀀑􀀟􀀃􀀪􀀫􀀮􀀣􀀃􀀑􀀆􀀒􀀎􀀃􀀲􀀃􀀐􀀉􀀋􀀇􀀏􀀕􀀉􀀃􀀍􀀇􀀑􀀟􀀃􀀪􀀫􀁃􀀣􀀃􀀑􀀆􀀒􀀎􀀃􀀪􀀳􀀟􀀃􀀼􀀎􀀋􀀍􀀗
􀀖􀀎􀀎􀀌􀀖􀀃􀀐􀀇􀀃􀀊􀀍􀀍􀀎􀀈􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀎􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟
􀀼􀀎􀀋􀀍􀀗􀀃􀀅􀀋􀀟􀀃􀀪􀁃􀀟􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀍􀀉􀀊􀀋􀀊􀀍􀀐􀀎􀀋􀀆􀀻􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀊􀀖􀀃􀁆􀀐􀀊􀀋􀀕􀀎􀀐􀁔􀀆􀀒􀀕􀁕􀁇
􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀅􀀋􀀟􀀃􀀪􀀳􀀣􀀃􀀪􀁃􀀟
􀀴􀀎􀀃􀀝􀀆􀀑􀀑􀀃􀀎􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀎􀀃􀀔􀀎􀀑􀀇􀀝􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖
􀀝􀀇􀀋􀀗􀀃􀀇􀀒􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀝􀀆􀀐􀀉􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣􀀃􀀼􀀎􀀋􀀍􀀗􀀣􀀃􀀊􀀒􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀲􀀬􀀬􀀨
􀀍􀀑􀀊􀀆􀀌􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀖􀀃􀀚􀀇􀀋􀀃􀀝􀀉􀀊􀀐􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃􀀶􀀉􀀇􀀖􀀎
􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀖􀀣􀀃 􀀐􀀇􀀕􀀎􀀐􀀉􀀎􀀋􀀃 􀀕􀀖􀀗􀀘􀀥 􀀃 􀀝􀀆􀀐􀀉􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃 􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑
􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀖􀀣􀀃􀀍􀀊􀀌􀀎􀀃􀀐􀀇􀀃􀀔􀀎􀀃􀀐􀀉􀀎􀀃􀀔􀀊􀀖􀀆􀀖􀀃􀀇􀀚􀀃􀀐􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀉􀀊􀀘􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒
􀀉􀀊􀀒􀀘􀀖􀀣􀀃􀀈􀀋􀀎􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀟
􀀦
􀁀􀀒􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀮􀀣􀀃􀀊􀀃􀀚􀀎􀀝􀀃􀀌􀀇􀀒􀀐􀀉􀀖􀀃􀀊􀀚􀀐􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀣
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀑􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀘
􀀊􀀖􀀃 􀀐􀀉􀀎􀀃 􀀢􀀮􀀪􀀲􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀭􀀪􀀭􀀮􀀟􀀃 􀀶􀀉􀀎􀀃 􀀇􀀋􀀆􀀕􀀆􀀒􀀊􀀑􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀇􀀚􀀃 􀀐􀀉􀀊􀀐
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀝􀀎􀀋􀀎􀀃􀁊􀀏􀀆􀀐􀀎􀀃􀀘􀀆􀀚􀀚􀀎􀀋􀀎􀀒􀀐􀀃􀀚􀀋􀀇􀀌􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀣􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀭􀀫􀀫􀀳􀁋
􀀭􀀪􀀣􀀃􀀊􀀒􀀘􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃􀀐􀀝􀀇􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀉􀀊􀀐
􀀝􀀎􀀋􀀎􀀃􀀍􀀑􀀇􀀖􀀎􀀋􀀣􀀃􀀔􀀏􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀋􀀐􀀆􀀎􀀖􀀃􀀉􀀎􀀋􀀎􀀃􀀘􀀇􀀃􀀒􀀇􀀐􀀃􀀍􀀇􀀒􀀐􀀎􀀒􀀘􀀃􀀍􀀇􀀞􀀎􀀋􀀎􀀘
􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀣􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀭􀀪􀀨􀀬􀁋􀀨􀀫􀀟􀀃 􀁀􀀐􀀃 􀀊􀀈􀀈􀀎􀀊􀀋􀀖􀀃 􀀏􀀒􀀘􀀆􀀖􀀈􀀏􀀐􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀊􀀚􀀐􀀎􀀋
􀀡􀀈􀀋􀀆􀀑􀀃􀀲􀀬􀀬􀀮􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀃􀀆􀀒􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀒􀀕􀀃􀀐􀀉􀀎
􀀢􀀮􀀪􀀲􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀅􀀋􀀟􀀃􀀪􀁃􀀺􀀃􀀍􀀈􀀈􀀃􀀈􀀎􀀙􀀎􀀣􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀭􀀫􀀳􀀵􀁋􀀮􀀬􀀃􀁁􀀡􀀈􀀋􀀆􀀑
􀀲􀀬􀀬􀀮􀀃􀀚􀀆􀀑􀀆􀀒􀀕􀀃􀀔􀀓􀀃􀀐􀀉􀀎􀀃􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀃􀀝􀀉􀀇􀀃􀀐􀀇􀀇􀀗􀀃􀀇􀀞􀀎􀀋􀀃􀀋􀀎􀀖􀀈􀀇􀀒􀀖􀀆􀀔􀀆􀀑􀀆􀀐􀀓􀀃􀀚􀀇􀀋
􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀚􀀋􀀇􀀌􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀁂􀀟
􀁀􀀒􀀃 􀀲􀀬􀀪􀀬􀀣􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃 􀀊􀀒􀀃 􀀊􀀋􀀐􀀆􀀍􀀑􀀎􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀱􀀇􀀏􀀋􀀒􀀊􀀑
􀀇􀀚􀀃􀀼􀀎􀀘􀀆􀀍􀀆􀀒􀀊􀀑􀀃􀀜􀀉􀀎􀀌􀀆􀀖􀀐􀀋􀀓􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀆􀀒􀀕􀀃􀁆􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀁇􀀃􀁁􀀠􀀥􀁀􀀄􀀮􀀵􀀮􀀮􀁂
􀀐􀀇􀀃 􀀐􀀋􀀎􀀊􀀐􀀃 􀀛􀀜􀁎􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀫􀀪􀀵􀀵􀀬􀁋􀀲􀀬􀀬􀀮􀀟􀀃 􀁀􀀒􀀃 􀀲􀀬􀀪􀀪􀀣􀀃 􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀃 􀀱􀀎􀀚􀀚􀀋􀀎􀀓
􀀅􀀎􀀋􀀕􀀌􀀊􀀒􀀃 􀀐􀀇􀀇􀀗􀀃 􀀇􀀞􀀎􀀋􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀢􀀮􀀪􀀲􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀚􀀇􀀋
􀀼􀀎􀀋􀀍􀀗􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀫􀀲􀀫􀁃􀀫􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀊􀀌􀀎􀀒􀀘􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀇
􀀆􀀒􀀍􀀑􀀏􀀘􀀎􀀃􀀒􀀎􀀝􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀭􀀫􀀵􀀭􀁋􀀭􀀪􀀬􀀟􀀃􀀶􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘
􀀇􀀒􀀃􀀱􀀏􀀑􀀓􀀃􀀵􀀣􀀃􀀲􀀬􀀪􀀫􀀟
􀀜􀀑􀀊􀀆􀀌􀀃􀀪􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀆􀀖􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎􀀟􀀃􀁀􀀐􀀃􀀖􀀐􀀊􀀐􀀎􀀖􀀩
􀀪􀀟􀀃􀀡􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀉􀀊􀀞􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀩
􀀇􀀋􀀃􀀊􀀃􀀈􀀉􀀊􀀋􀀌􀀊􀀍􀀎􀀏􀀐􀀆􀀍􀀊􀀑􀀑􀀓􀀃􀀊􀀍􀀍􀀎􀀈􀀐􀀊􀀔􀀑􀀎􀀃􀀖􀀊􀀑􀀐􀀃􀀐􀀉􀀎􀀋􀀎􀀇􀀚􀀣􀀃􀀝􀀉􀀎􀀋􀀎􀀆􀀒􀀩
􀀅􀀃􀀆􀀖􀀩
􀀯􀀃􀀆􀀖􀀃􀀜􀀛􀀃􀀇􀀋􀀃􀀧􀀺
􀀹􀀃􀀆􀀖􀀃􀀧􀀃􀀇􀀋􀀃􀀜􀀷􀀨􀀺
􀀴􀀃􀀆􀀖􀀃􀀽􀀃􀀇􀀋􀀃􀀥􀀺
􀀷 􀀪 􀀃􀀆􀀖􀀃􀀜􀀲􀀄􀀭􀀃􀀊􀀑􀀗􀀎􀀒􀀓􀀑􀀣􀀃􀀜􀀲􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀒􀀓􀀑􀀣􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀃􀀇􀀈􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓
􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃 􀀝􀀆􀀐􀀉􀀃 􀀊􀀌􀀆􀀒􀀇􀀣􀀃 􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀣􀀃 􀀇􀀋􀀃 􀀪􀀃 􀀐􀀇􀀃 􀀫􀀃 􀀚􀀑􀀏􀀇􀀋􀀆􀀒􀀎
􀀊􀀐􀀇􀀌􀀖􀀺􀀃􀀷 􀀫 􀀃􀀆􀀖􀀃􀀉􀀓􀀘􀀋􀀇􀁈􀀓􀀃􀀇􀀋􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀺􀀃􀀊􀀒􀀘􀀃􀀷 􀀲 􀀃􀀆􀀖􀀃􀀖􀀎􀀑􀀎􀀍􀀐􀀎􀀘
􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀕􀀋􀀇􀀏􀀈􀀃􀀍􀀇􀀒􀀖􀀆􀀖􀀐􀀆􀀒􀀕􀀃􀀇􀀚
􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣
􀀜􀀪􀀄􀀭􀀃 􀀊􀀑􀀗􀀓􀀑􀀣􀀃 􀀇􀀈􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃 􀀝􀀆􀀐􀀉􀀃 􀀪􀀃 􀀐􀀇􀀃 􀀫􀀃 􀀚􀀑􀀏􀀇􀀋􀀆􀀒􀀎
􀀊􀀐􀀇􀀌􀀖􀀣
􀀕􀀖􀀗􀀘􀀦 􀀃􀀜􀀪􀀄􀀪􀀬􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀇􀀈􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎􀀘􀀃􀀝􀀆􀀐􀀉􀀃􀀜􀀪􀀄􀀫
􀀊􀀑􀀗􀀇􀁈􀀓􀀃􀀇􀀋􀀃􀀪􀀃􀀐􀀇􀀃􀀫􀀃􀀚􀀑􀀏􀀇􀀋􀀆􀀒􀀎􀀃􀀊􀀐􀀇􀀌􀀖􀀣
􀀜􀀲􀀄􀀳􀀃􀀊􀀑􀀗􀀎􀀒􀀓􀀑􀀇􀁈􀀓􀀣
􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀐􀀉􀀆􀀇􀀣
􀀜􀀪􀀄􀁃􀀃􀀊􀀑􀀗􀀓􀀑􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀇􀁈􀀓􀀣
􀀊􀀋􀀓􀀑􀀇􀁈􀀓􀀍􀀊􀀋􀀔􀀇􀀒􀀓􀀑􀀣
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀇
􀀊􀀻􀀆􀀘􀀇􀀣
􀀊􀀌􀀆􀀒􀀇􀀣
􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀊􀀒􀀘
􀀘􀀆􀁁􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀺
􀀷 􀀭 􀀃􀀊􀀒􀀘􀀃􀀷 􀀳 􀀃􀀊􀀋􀀎􀀃􀀎􀀊􀀍􀀉􀀃􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓􀀃􀀛􀀣􀀃􀀽􀀛􀀣􀀃􀀥􀀛􀀣􀀃􀀧􀀛􀀲􀀣􀀃􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀘􀀆􀁁􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀁂􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀫􀀄􀀳􀀃􀀍􀀓􀀍􀀑􀀇􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣
􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀓􀀑􀀣􀀃􀀜􀀪􀀄􀀭􀀃􀀊􀀑􀀗􀀇􀁈􀀓􀀣􀀃􀀇􀀋􀀃􀀜􀀰􀀫􀀺
􀀷 􀀨 􀀃 􀀆􀀖􀀃 􀀛􀀣􀀃 􀀜􀀪􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀎􀀒􀀓􀀑􀀣􀀃 􀀜􀀲􀀄􀀳􀀃 􀀊􀀑􀀗􀀓􀀒􀀓􀀑􀀣􀀃 􀀜􀀪􀀄􀀭
􀀊􀀑􀀗􀀓􀀑􀀊􀀌􀀆􀀒􀀇􀀣􀀃􀀜􀀰􀀫􀀣􀀃􀀇􀀋􀀃􀀉􀀊􀀑􀀇􀀕􀀎􀀒􀀺
􀀷 􀀪􀀲 􀀃􀀊􀀒􀀘􀀃􀀷 􀀪􀀫 􀀃􀀊􀀋􀀎􀀃􀀎􀀊􀀍􀀉􀀃􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀑􀀓􀀃􀀉􀀓􀀘􀀋􀀇􀀕􀀎􀀒􀀃􀀇􀀋􀀃􀀌􀀎􀀐􀀉􀀓􀀑􀀟
􀀢􀀮􀀪􀀲􀀃 􀀠􀀊􀀐􀀎􀀒􀀐􀀣􀀃 􀀍􀀇􀀑􀀟􀀃 􀀪􀀭􀀫􀀣􀀃 􀀑􀀆􀀒􀀎􀀖􀀃 􀀲􀁋􀀨􀀭􀀟􀀃 􀀶􀀉􀀎􀀃 􀀈􀀊􀀋􀀐􀀆􀀎􀀖􀀃 􀀍􀀉􀀊􀀋􀀊􀀍􀀐􀀎􀀋􀀆􀀻􀀎
􀀐􀀉􀀎􀀖􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀎􀀌􀀔􀀋􀀊􀀍􀀎􀀃􀀊􀀃􀀖􀀆􀀒􀀕􀀑􀀎􀀄􀀋􀀆􀀒􀀕􀀃􀀔􀀊􀀖􀀎􀀃􀀝􀀆􀀐􀀉􀀃􀀌􀀎􀀐􀀉􀀓􀀑
􀀏􀀈􀀃 􀀊􀀒􀀘􀀃 􀀚􀀑􀀏􀀇􀀋􀀇􀀃 􀀘􀀇􀀝􀀒􀀃 􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀲􀁒􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀖􀀏􀀕􀀊􀀋􀀣􀀃 􀀊􀀖
􀀍􀀇􀀞􀀎􀀋􀀆􀀒􀀕􀀃 􀀌􀀎􀀐􀀊􀀔􀀇􀀑􀀆􀀐􀀎􀀖􀀃 􀀇􀀚􀀃 􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀣􀀃 􀀈􀀋􀀇􀀘􀀏􀀍􀀎􀀘􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀔􀀇􀀘􀀓
􀀊􀀚􀀐􀀎􀀋􀀃􀀊􀀘􀀌􀀆􀀒􀀆􀀖􀀐􀀋􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀅􀀋􀀟􀀃􀀪􀁃􀀺􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀅􀀋􀀟
􀀪􀀵􀀟􀀃􀀡􀀖􀀃􀀒􀀇􀀐􀀎􀀘􀀃􀀊􀀔􀀇􀀞􀀎􀀣􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀑􀀓􀀃􀀖􀀐􀀆􀀈􀀏􀀑􀀊􀀐􀀎􀀘
􀀐􀀇􀀃 􀀆􀀒􀀚􀀋􀀆􀀒􀀕􀀎􀀌􀀎􀀒􀀐􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀊􀀖􀀖􀀎􀀋􀀐􀀎􀀘􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃 􀀊􀀒􀀘􀀃 􀀢􀀭􀀵􀀵
􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀍􀀇􀀒􀀖􀀐􀀋􀀏􀀍􀀐􀀆􀀇􀀒􀀟
􀁀􀁀
􀀡􀀚􀀐􀀎􀀋􀀃􀀊􀀃􀀔􀀎􀀒􀀍􀀉􀀃􀀐􀀋􀀆􀀊􀀑􀀃􀀇􀀒􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀖􀀣􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐
􀀍􀀇􀀏􀀋􀀐􀀃 􀀉􀀎􀀑􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀍􀀇􀀏􀀑􀀘􀀃 􀀒􀀇􀀐􀀃 􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀃 􀀐􀀉􀀎􀀃 􀀐􀀝􀀇􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖
􀀊􀀐􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀉􀀎􀀋􀀎􀀃 􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀔􀀎􀀍􀀊􀀏􀀖􀀎􀀃 􀀆􀀐􀀖􀀃 􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀕􀀊􀀞􀀎􀀃 􀀆􀀐
􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀫􀀵􀀟􀀃􀀶􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐
􀀋􀀎􀀖􀀐􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀒􀀃􀀆􀀐􀀖􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀇􀀚􀀃􀀔􀀇􀀐􀀉􀀃􀀈􀀋􀀎􀀄􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒
􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀊􀀒􀀘􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀊􀀐􀀐􀀋􀀆􀀔􀀏􀀐􀀊􀀔􀀑􀀎􀀃􀀐􀀇
􀀼􀀎􀀋􀀍􀀗􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀲􀀮􀀟􀀃􀀶􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀔􀀊􀀑􀀊􀀒􀀍􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀆􀀎􀀖􀀃􀀊􀀒􀀘􀀃􀀊􀀈􀀈􀀑􀀆􀀎􀀘
􀀆􀀐􀀖􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀇􀀃􀀔􀀇􀀐􀀉􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀫􀀮􀁋􀀫􀀵􀀟
􀀶􀀉􀀎􀀃 􀀥􀀏􀀈􀀋􀀎􀀌􀀎􀀃 􀀜􀀇􀀏􀀋􀀐􀀃 􀀉􀀊􀀖􀀃 􀀊􀀋􀀐􀀆􀀍􀀏􀀑􀀊􀀐􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀕􀀇􀀞􀀎􀀋􀀒􀀆􀀒􀀕􀀃 􀀑􀀎􀀕􀀊􀀑
􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀟􀀃􀁀􀀒􀀃􀀚􀀈􀀛􀀍􀀜􀀘􀀑􀀈􀀃􀀝􀀔􀀆􀀇􀀇􀀈􀀔􀀃􀀗􀀘􀀎􀀃􀀒􀀎􀀃􀀅􀀈􀀑􀀈􀀔􀀉􀀇􀀃􀀞􀀟􀀌􀀉􀀒􀀉􀀜􀀘􀀔􀀃􀀗􀀘􀀟􀀣
􀀐􀀉􀀎􀀃 􀀜􀀇􀀏􀀋􀀐􀀃 􀀎􀁈􀀈􀀑􀀊􀀆􀀒􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀊􀀃 􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃 􀀉􀀊􀀒􀀘􀀖
􀀌􀀊􀀓􀀃􀀔􀀎􀀃􀀋􀀎􀀊􀀍􀀉􀀎􀀘􀀃􀀝􀀉􀀎􀀒􀀃􀁆􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀁇􀀃􀀇􀀚􀀃􀀊􀀃􀀈􀀊􀀋􀀐􀀓􀀃􀀖􀀎􀀎􀀗􀀆􀀒􀀕􀀃􀀋􀀎􀀑􀀆􀀎􀀚
􀁆􀀉􀀊􀀖􀀃 􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀃 􀀊􀀒􀀘􀀃 􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀓􀀃 􀀋􀀎􀀑􀀊􀀐􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀎􀁊􀀏􀀆􀀐􀀓􀀃 􀀐􀀉􀀊􀀐
􀀉􀀎􀀃 􀀖􀀎􀀎􀀗􀀖􀀃 􀀆􀀒􀀃 􀀋􀀎􀀖􀀈􀀎􀀍􀀐􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀌􀀊􀀐􀀐􀀎􀀋􀀃 􀀆􀀒􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀣􀁇􀀃 􀀆􀀎􀀈􀀎􀀣􀀃 􀁆􀀚􀀇􀀋
􀀖􀀏􀀍􀀉􀀃􀀞􀀆􀀇􀀑􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀇􀀚􀀃􀀍􀀇􀀒􀀖􀀍􀀆􀀎􀀒􀀍􀀎􀀃􀀊􀀖􀀃􀀆􀀒􀀃􀀖􀀇􀀌􀀎􀀃􀀌􀀎􀀊􀀖􀀏􀀋􀀎􀀃􀀊􀀚􀀚􀀎􀀍􀀐􀀃􀀐􀀉􀀎
􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃􀀋􀀎􀀑􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀔􀀎􀀐􀀝􀀎􀀎􀀒􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀋􀀐􀀆􀀎􀀖􀀃􀀆􀀒􀀃􀀋􀀎􀀖􀀈􀀎􀀍􀀐􀀃􀀇􀀚􀀃􀀖􀀇􀀌􀀎􀀐􀀉􀀆􀀒􀀕
􀀔􀀋􀀇􀀏􀀕􀀉􀀐􀀃􀀔􀀎􀀚􀀇􀀋􀀎􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀟􀁇􀀃􀀲􀀵􀀬􀀃􀀤􀀟􀀥􀀟􀀃􀀲􀀭􀀬􀀣􀀃􀀲􀀭􀀨􀀣􀀃􀀨􀀭􀀃􀀥􀀟􀀜􀀐􀀟􀀃􀀪􀀭􀀳􀀣􀀃􀀮􀁃
􀀯􀀟􀀹􀀘􀀟􀀃􀀲􀀵􀀫􀀃􀁁􀀪􀀵􀀫􀀫􀁂􀀟􀀃􀁀􀀒􀀃􀀠􀀔􀀈􀀌􀀆􀀍􀀆􀀘􀀑􀀃􀀐􀀑􀀍􀀜􀀔􀀡􀀢􀀈􀀑􀀜􀀃􀀓􀀉􀀑􀀡􀀣􀀉􀀌􀀜􀀡􀀔􀀆􀀑􀀙􀀃􀀗􀀘􀀎
􀀒􀀎􀀃􀀤􀀡􀀜􀀘􀀢􀀘􀀜􀀆􀀒􀀈􀀃􀀓􀀉􀀆􀀑􀀜􀀈􀀑􀀉􀀑􀀌􀀈􀀃􀀓􀀉􀀌􀀥􀀆􀀑􀀈􀀔􀀛􀀃􀀗􀀘􀀎􀀣􀀃􀀐􀀉􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀃􀀖􀀐􀀊􀀐􀀎􀀘
􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀃􀁆􀀍􀀑􀀇􀀖􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀘􀀇􀀇􀀋􀀖􀀃􀀇􀀚􀀃􀀊􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀇􀀚􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀐􀀇􀀃􀀇􀀒􀀎
􀀐􀀊􀀆􀀒􀀐􀀎􀀘􀀃􀀝􀀆􀀐􀀉􀀃􀀆􀀒􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀒􀀎􀀖􀀖􀀃􀀇􀀋􀀃􀀔􀀊􀀘􀀃􀀚􀀊􀀆􀀐􀀉􀀃􀀋􀀎􀀑􀀊􀀐􀀆􀀞􀀎􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀌􀀊􀀐􀀐􀀎􀀋
􀀆􀀒􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀉􀀎􀀃􀀖􀀎􀀎􀀗􀀖􀀃􀀋􀀎􀀑􀀆􀀎􀀚􀀣􀀃􀀉􀀇􀀝􀀎􀀞􀀎􀀋􀀃􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀃􀀌􀀊􀀓􀀃􀀉􀀊􀀞􀀎􀀃􀀔􀀎􀀎􀀒􀀃􀀐􀀉􀀎
􀀔􀀎􀀉􀀊􀀞􀀆􀀇􀀋􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀚􀀎􀀒􀀘􀀊􀀒􀀐􀀣􀁇􀀃􀀊􀀒􀀘􀀃􀀋􀀎􀁊􀀏􀀆􀀋􀀎􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀍􀀑􀀊􀀆􀀌􀀊􀀒􀀐􀀖􀀃􀁆􀀉􀀊􀀞􀀎
􀀊􀀍􀀐􀀎􀀘􀀃􀀚􀀊􀀆􀀋􀀑􀀓􀀃􀀊􀀒􀀘􀀃􀀝􀀆􀀐􀀉􀀇􀀏􀀐􀀃􀀚􀀋􀀊􀀏􀀘􀀃􀀇􀀋􀀃􀀘􀀎􀀍􀀎􀀆􀀐􀀃􀀊􀀖􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀒􀀐􀀋􀀇􀀞􀀎􀀋􀀖􀀓
􀀆􀀒􀀃􀀆􀀖􀀖􀀏􀀎􀀟􀁇􀀃􀀫􀀲􀀭􀀃􀀤􀀟􀀥􀀟􀀃􀁃􀀬􀀳􀀣􀀃􀁃􀀪􀀭􀁋􀀪􀀨􀀣􀀃􀀳􀀨􀀃􀀥􀀟􀀜􀀐􀀟􀀃􀀵􀀵􀀫􀀣􀀃􀁃􀀵􀀃􀀯􀀟􀀹􀀘􀀟􀀃􀀪􀀫􀁃􀀪
􀁁􀀪􀀵􀀭􀀨􀁂􀀟􀀃􀀶􀀉􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀃􀀊􀀘􀀘􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀃􀁆􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀆􀀑􀀓􀀃􀀕􀀆􀀞􀀎􀀖
􀀝􀀆􀀘􀀎􀀃􀀋􀀊􀀒􀀕􀀎􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀃􀀆􀀒􀀃􀀋􀀎􀀚􀀏􀀖􀀆􀀒􀀕
􀀐􀀇􀀃􀀊􀀆􀀘􀀃􀀐􀀉􀀎􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀒􀀐􀀟􀁇􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁃􀀪􀀨􀀣􀀃􀀳􀀨􀀃􀀥􀀟􀀜􀀐􀀟􀀃􀀵􀀵􀀫􀀺􀀃􀀍􀀈􀀈􀀃􀀉􀀇􀀍􀀘
􀀦􀀘􀀔􀀜􀀥􀀧􀀉􀀛􀀃􀀨􀀈􀀇􀀇􀀑􀀈􀀍􀀍􀀃􀀅􀀔􀀩􀀎􀀏􀀃􀀐􀀑􀀌􀀎􀀃􀀒􀀎􀀃􀀪􀀈􀀛􀀔􀀆􀀈􀀍􀀣􀀃􀀮􀁃􀀵􀀃􀀰􀀟􀀫􀀘􀀃􀀵􀀨􀀳􀀣􀀃􀀵􀀳􀀬
􀁁􀀵􀀐􀀉􀀃􀀜􀀆􀀋􀀟􀀃􀀲􀀬􀀪􀀨􀁂􀀃􀁁􀀎􀁈􀀈􀀑􀀊􀀆􀀒􀀆􀀒􀀕􀀃􀀒􀀎􀀎􀀘􀀃􀀚􀀇􀀋􀀃􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃􀀔􀀊􀀑􀀊􀀒􀀍􀀆􀀒􀀕􀁂􀀟 􀀲
􀀕􀀖􀀗􀀡􀀧 􀀼􀀎􀀋􀀍􀀗􀀃 􀀆􀀒􀀞􀀇􀀗􀀎􀀖􀀃 􀀐􀀉􀀎􀀃 􀀐􀀎􀀋􀀌􀀃 􀁆􀀌􀀊􀀐􀀎􀀋􀀆􀀊􀀑􀁇􀀃 􀀐􀀇􀀃 􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀎􀀃 􀀐􀀉􀀎
􀀗􀀆􀀒􀀘􀀃􀀇􀀚􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃􀀔􀀎􀀐􀀝􀀎􀀎􀀒􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐
􀀐􀀉􀀎􀀃􀀥􀀏􀀈􀀋􀀎􀀌􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀚􀀇􀀋􀀌􀀏􀀑􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀋􀀎􀁊􀀏􀀆􀀋􀀎􀀟􀀃􀀅􀀏􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀉􀀊􀀖􀀃􀀒􀀇􀀐
􀀆􀀘􀀎􀀒􀀐􀀆􀀚􀀆􀀎􀀘􀀃􀀉􀀇􀀝􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀎􀀋􀀌􀀃􀀉􀀎􀀑􀀈􀀚􀀏􀀑􀀑􀀓􀀃􀀋􀀎􀀚􀀆􀀒􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀥􀀏􀀈􀀋􀀎􀀌􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀢􀀖
􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀃 􀀆􀀒􀀃 􀀊􀀃 􀀝􀀊􀀓􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀖􀀃 􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀃 􀀐􀀇􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀀟􀀃 􀀋􀀈􀀈􀀃 􀀼􀀎􀀋􀀍􀀗
􀀅􀀋􀀟􀀃 􀀫􀀵􀁋􀀭􀀫􀀟􀀃 􀀰􀀇􀀋􀀃 􀀈􀀏􀀋􀀈􀀇􀀖􀀎􀀖􀀃 􀀇􀀚􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀀣􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀖􀀃 􀀍􀀑􀀎􀀊􀀋
􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀆􀀒􀀃 􀀔􀀋􀀎􀀊􀀍􀀉􀀆􀀒􀀕􀀃 􀀍􀀇􀀌􀀌􀀆􀀐􀀌􀀎􀀒􀀐􀀖􀀃 􀀐􀀇􀀃 􀀊􀀃 􀀐􀀉􀀆􀀋􀀘􀀃 􀀈􀀊􀀋􀀐􀀓􀀃 􀀊􀀒􀀘
􀀍􀀑􀀎􀀊􀀋􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀆􀀒􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀐􀀉􀀎􀀃􀁆􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀃􀀊􀀒􀀘􀀃􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀓
􀀋􀀎􀀑􀀊􀀐􀀆􀀇􀀒􀁇􀀃􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀣􀀃􀀆􀀒􀀃􀀆􀀐􀀖􀀃􀀒􀀊􀀐􀀏􀀋􀀊􀀑􀀃􀀌􀀎􀀊􀀒􀀆􀀒􀀕􀀣􀀃􀀕􀀎􀀒􀀎􀀋􀀊􀀑􀀑􀀓􀀃􀀌􀀏􀀖􀀐􀀃􀀔􀀎
􀀌􀀎􀀐􀀃 􀀆􀀚􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀒􀀇􀀋􀀌􀀊􀀑􀀑􀀓􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀎􀀒􀀉􀀊􀀒􀀍􀀎􀀃 􀀐􀀉􀀎􀀃 􀀍􀀑􀀊􀀆􀀌􀀊􀀒􀀐􀀢􀀖
􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃 􀀑􀀎􀀕􀀊􀀑􀀃 􀀋􀀆􀀕􀀉􀀐􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀊􀀋􀀎􀀃 􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀐􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎
􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀆􀀚􀀃􀀐􀀉􀀎􀀃􀀆􀀌􀀈􀀋􀀇􀀈􀀋􀀆􀀎􀀐􀀓􀀃􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀀘􀀆􀀖􀀍􀀇􀀞􀀎􀀋􀀎􀀘􀀃􀀊􀀒􀀘􀀃􀀍􀀇􀀋􀀋􀀎􀀍􀀐􀀎􀀘􀀟
􀀼􀀎􀀋􀀍􀀗􀀃 􀀍􀀆􀀐􀀎􀀖􀀃 􀀒􀀇􀀃 􀀊􀀏􀀐􀀉􀀇􀀋􀀆􀀐􀀓􀀃 􀀉􀀇􀀑􀀘􀀆􀀒􀀕􀀃 􀀖􀀏􀀍􀀉􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀐􀀇􀀃 􀀔􀀎
􀀇􀀏􀀐􀀖􀀆􀀘􀀎􀀃 􀀚􀀈􀀛􀀍􀀜􀀘􀀑􀀈􀀢􀀖􀀃 􀀖􀀍􀀇􀀈􀀎􀀟􀀃 􀀧􀀇􀀋􀀃 􀀘􀀇􀀎􀀖􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀘􀀎􀀒􀀓􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎
􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀃􀀍􀀊􀀒􀀃􀀍􀀇􀀞􀀎􀀋􀀃􀀊􀀐􀀃􀀑􀀎􀀊􀀖􀀐􀀃􀀖􀀇􀀌􀀎􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀑􀀓
􀀚􀀊􀀆􀀑􀀖􀀃􀀐􀀇􀀃􀀊􀀚􀀚􀀎􀀍􀀐􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀊􀀖􀀃􀀝􀀉􀀎􀀒􀀃􀀆􀀐􀀃􀀆􀀖􀀃􀀘􀀆􀀖􀀍􀀇􀀞􀀎􀀋􀀎􀀘􀀃􀀔􀀎􀀚􀀇􀀋􀀎􀀃􀀆􀀐
􀀔􀀎􀀊􀀋􀀖􀀃􀀚􀀋􀀏􀀆􀀐􀀣􀀃􀀊􀀖􀀃􀀑􀀇􀀒􀀕􀀃􀀊􀀖􀀃􀀆􀀐􀀖􀀃􀀇􀀔􀀙􀀎􀀍􀀐􀀆􀀞􀀎􀀃􀀈􀀇􀀐􀀎􀀒􀀐􀀆􀀊􀀑􀀃􀀐􀀇􀀃􀀉􀀊􀀞􀀎􀀃􀀘􀀇􀀒􀀎􀀃􀀖􀀇
􀀆􀀖􀀃􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀟
􀀥􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀑􀀓􀀣􀀃􀀐􀀉􀀆􀀖􀀃􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀀊􀀃􀀍􀀊􀀖􀀎􀀃􀀆􀀒􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀆􀀐􀀃􀀆􀀖􀀃􀀍􀀑􀀎􀀊􀀋􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎
􀀆􀀘􀀎􀀒􀀐􀀆􀀚􀀆􀀎􀀘􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀍􀀇􀀏􀀑􀀘􀀃 􀀒􀀇􀀐􀀃 􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓􀀃 􀀉􀀊􀀞􀀎􀀃 􀀎􀀒􀀉􀀊􀀒􀀍􀀎􀀘
􀀐􀀉􀀎􀀃 􀀍􀀑􀀊􀀆􀀌􀀊􀀒􀀐􀀢􀀖􀀃 􀀑􀀎􀀕􀀊􀀑􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀊􀀖􀀃 􀀐􀀇􀀃 􀀎􀀆􀀐􀀉􀀎􀀋􀀃 􀀐􀀉􀀎􀀃 􀀍􀀋􀀎􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀋
􀀐􀀉􀀎􀀃 􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀑􀀎􀀕􀀊􀀑􀀃 􀀋􀀆􀀕􀀉􀀐􀀖􀀃 􀀊􀀐􀀃 􀀆􀀖􀀖􀀏􀀎􀀟􀀃 􀀧􀀇􀀋􀀃 􀀆􀀖􀀃 􀀐􀀉􀀆􀀖
􀀊􀀃 􀀍􀀊􀀖􀀎􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀆􀀒􀀕􀀃 􀀊􀀑􀀑􀀎􀀕􀀎􀀘􀀃 􀀘􀀎􀀚􀀆􀀍􀀆􀀎􀀒􀀍􀀆􀀎􀀖􀀃 􀀆􀀒􀀃 􀀍􀀇􀀌􀀌􀀏􀀒􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖
􀀝􀀆􀀐􀀉􀀃 􀀐􀀉􀀎􀀃 􀀠􀀶􀀽􀀃 􀀘􀀏􀀋􀀆􀀒􀀕􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀣􀀃 􀀚􀀇􀀋􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀐􀀉􀀆􀀖
􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀆􀀒􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀄􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀖􀀣􀀃􀀈􀀎􀀙􀀎􀀣􀀃􀀫􀀥􀀈􀀔􀀉􀀍􀀈􀀑􀀍􀀈􀀏􀀃􀀐􀀑􀀌􀀎􀀃􀀒􀀎
􀀪􀀈􀀌􀀜􀀘􀀑􀀏􀀃􀀝􀀆􀀌􀀕􀀆􀀑􀀍􀀘􀀑􀀃􀀖􀀃􀀗􀀘􀀎􀀣􀀃􀀳􀀭􀀵􀀃􀀰􀀟􀀫􀀘􀀃􀀪􀀲􀀮􀀳􀀃􀁁􀀰􀀎􀀘􀀟􀀃􀀜􀀆􀀋􀀟􀀃􀀲􀀬􀀪􀀪􀁂􀀃􀁁􀀎􀀒
􀀔􀀊􀀒􀀍􀁂􀀣􀀃􀀖􀀎􀀐􀀃􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀐􀀃􀀑􀀆􀀌􀀆􀀐􀀖􀀃􀀇􀀒􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀖􀀆􀀇􀀒􀀖􀀃􀀇􀀚􀀃􀀏􀀒􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀆􀀑􀀆􀀐􀀓
􀀐􀀉􀀋􀀇􀀏􀀕􀀉􀀃􀀐􀀉􀀊􀀐􀀃􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀟 􀀫 􀀃􀁀􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀃􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖
􀀍􀀊􀀖􀀎􀀣􀀃 􀀝􀀎􀀃 􀀖􀀎􀀎􀀃 􀀒􀀇􀀃 􀀕􀀎􀀒􀀏􀀆􀀒􀀎􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀊􀀔􀀇􀀏􀀐􀀃 􀀐􀀉􀀎􀀃 􀀕􀀇􀀞􀀎􀀋􀀒􀀆􀀒􀀕􀀃 􀀑􀀎􀀕􀀊􀀑
􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀣􀀃􀀔􀀏􀀐􀀃􀀇􀀒􀀑􀀓􀀃􀀆􀀐􀀖􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀟
􀀴􀀎􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀎􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀌􀀊􀀘􀀎􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀊􀀞􀀎
􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀣􀀃 􀀐􀀊􀀗􀀎􀀒􀀃 􀀐􀀇􀀕􀀎􀀐􀀉􀀎􀀋􀀣
􀀙􀀏􀀖􀀐􀀆􀀚􀀓􀀃 􀀐􀀉􀀎􀀃 􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃 􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃 􀀉􀀊􀀒􀀘􀀖􀀃 􀀊􀀖􀀃 􀀊
􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃 􀀐􀀇􀀃 􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃 􀀆􀀒􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀀟􀀃 􀁀􀀒􀀃 􀀖􀀇􀀃 􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀣􀀃 􀀝􀀎
􀀊􀀈􀀈􀀑􀀓􀀃􀀘􀀎􀀚􀀎􀀋􀀎􀀒􀀐􀀆􀀊􀀑􀀃􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀖􀀃􀀇􀀚􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀣􀀃􀀊􀀖􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀆􀀐􀀖􀀎􀀑􀀚􀀃􀀏􀀋􀀕􀀎􀀖􀀟
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀪
􀀴􀀎􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀋􀀏􀀑􀀆􀀒􀀕􀀃􀀚􀀇􀀋􀀃􀀊􀀔􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀣
􀀝􀀉􀀆􀀍􀀉􀀃􀀌􀀎􀀊􀀒􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀎􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀃􀀚􀀊􀀍􀀐􀀏􀀊􀀑􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀇􀀒􀀑􀀓􀀃􀀚􀀇􀀋􀀃􀀍􀀑􀀎􀀊􀀋
􀀎􀀋􀀋􀀇􀀋􀀟􀀃􀀋􀀈􀀈􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀅􀀋􀀟􀀃􀀫􀀮􀀃􀁁􀀍􀀆􀀐􀀆􀀒􀀕􀀃􀀦􀀘􀀔􀀜􀀥􀀧􀀉􀀛􀀣􀀃􀀮􀁃􀀵􀀃􀀰􀀟􀀫􀀘􀀃􀀊􀀐􀀃􀀵􀀨􀀵􀁂􀀟
􀀽􀀏􀀋􀀃 􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀃 􀀋􀀎􀀖􀀐􀀖􀀃 􀀇􀀒􀀑􀀓􀀃 􀀇􀀒􀀃 􀀐􀀉􀀎􀀃 􀀐􀀇􀀐􀀊􀀑􀀆􀀐􀀓􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀄
􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀎􀀘􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀝􀀎􀀃􀀖􀀏􀀌􀀌􀀊􀀋􀀆􀀻􀀎􀀣􀀃􀀒􀀇􀀐􀀃􀀆􀀒􀀘􀀆􀀞􀀆􀀘􀀏􀀊􀀑􀀃􀀎􀀑􀀎􀀌􀀎􀀒􀀐􀀖
􀀊􀀑􀀇􀀒􀀎􀀃 􀀊􀀒􀀘􀀃 􀀒􀀇􀀐􀀃 􀀎􀀞􀀎􀀋􀀓􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀟􀀃 􀀴􀀎􀀃 􀀊􀀋􀀎
􀀍􀀇􀀒􀀖􀀍􀀆􀀇􀀏􀀖􀀣􀀃􀀊􀀖􀀃􀀊􀀒􀀓􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀎􀀘􀀃􀀝􀀆􀀐􀀉􀀃􀀊􀀃􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒
􀀉􀀊􀀒􀀘􀀖􀀃􀀌􀀏􀀖􀀐􀀃􀀔􀀎􀀣􀀃􀀔􀀇􀀐􀀉􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀙􀀏􀀘􀀆􀀍􀀆􀀊􀀑􀀃􀀖􀀓􀀖􀀐􀀎􀀌􀀢􀀖􀀃􀀞􀀆􀀐􀀊􀀑􀀃􀀍􀀇􀀌􀀌􀀆􀀐􀀌􀀎􀀒􀀐
􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀖􀀃 􀀇􀀚􀀃 􀀈􀀋􀀇􀀔􀀆􀀐􀀓􀀃 􀀈􀀋􀀇􀀐􀀎􀀍􀀐􀀎􀀘􀀃 􀀔􀀓􀀃 􀀐􀀉􀀎􀀃 􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀃 􀀊􀀒􀀘􀀣
􀀊􀀑􀀖􀀇􀀣􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀈􀀇􀀐􀀎􀀒􀀐􀀆􀀊􀀑􀀃􀀚􀀇􀀋􀀃􀀌􀀆􀀖􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀆􀀖􀀃􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀆􀀑􀀓􀀃􀀚􀀑􀀎􀁈􀀆􀀔􀀑􀀎
􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀃 􀀔􀀓􀀃 􀀈􀀊􀀋􀀐􀀆􀀎􀀖􀀃 􀀝􀀉􀀇􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀈􀀋􀀎􀀚􀀎􀀋􀀃 􀀐􀀇􀀃 􀀘􀀆􀀞􀀎􀀋􀀐􀀃 􀀊􀀐􀀐􀀎􀀒􀀐􀀆􀀇􀀒
􀀊􀀝􀀊􀀓􀀃􀀚􀀋􀀇􀀌􀀃􀀘􀀋􀀓􀀣􀀃􀀐􀀎􀀍􀀉􀀒􀀆􀀍􀀊􀀑􀀣􀀃􀀊􀀒􀀘􀀃􀀍􀀇􀀌􀀈􀀑􀀎􀁈􀀃􀀌􀀎􀀋􀀆􀀐􀀖􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀐􀀇􀀝􀀊􀀋􀀘
􀀊􀀑􀀑􀀎􀀕􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀇􀀚􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀋􀀎􀀑􀀊􀀐􀀆􀀞􀀎􀀑􀀓􀀃􀀍􀀇􀀌􀀌􀀇􀀒􀀈􀀑􀀊􀀍􀀎
􀀘􀀆􀀖􀀈􀀏􀀐􀀎􀀖􀀃 􀀇􀀞􀀎􀀋􀀃 􀀍􀀋􀀎􀀘􀀆􀀔􀀆􀀑􀀆􀀐􀀓􀀟􀀃 􀀛􀀊􀀞􀀆􀀒􀀕􀀃 􀀐􀀉􀀇􀀖􀀎􀀃 􀀍􀀇􀀒􀀖􀀆􀀘􀀎􀀋􀀊􀀐􀀆􀀇􀀒􀀖􀀃 􀀆􀀒
􀀌􀀆􀀒􀀘􀀣􀀃􀀝􀀎􀀃􀀘􀀇􀀃􀀒􀀇􀀐􀀃􀀚􀀆􀀒􀀘􀀃􀀊􀀃􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀃􀀔􀀊􀀖􀀆􀀖􀀃􀀐􀀇􀀃􀀖􀀎􀀐􀀃􀀊􀀖􀀆􀀘􀀎􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐
􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀃􀀏􀀒􀀘􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀔􀀑􀀎
􀀘􀀎􀀚􀀎􀀋􀀎􀀒􀀐􀀆􀀊􀀑􀀃􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀃􀀇􀀚􀀃􀀋􀀎􀀞􀀆􀀎􀀝􀀟
􀀡
􀀶􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀚􀀇􀀏􀀒􀀘􀀣􀀃􀀝􀀆􀀐􀀉􀀃􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃􀀎􀀞􀀆􀀘􀀎􀀒􀀐􀀆􀀊􀀋􀀓􀀃􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀣
􀀐􀀝􀀇􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃 􀀚􀀇􀀋􀀌􀀖􀀃 􀀇􀀚􀀃 􀀈􀀋􀀎􀀄􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐
􀀊􀀐􀀐􀀋􀀆􀀔􀀏􀀐􀀊􀀔􀀑􀀎􀀃 􀀐􀀇􀀃 􀀼􀀎􀀋􀀍􀀗􀀟􀀃 􀀰􀀆􀀋􀀖􀀐􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃 􀀇􀀚
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀔􀀓􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀒􀀕􀀣􀀃􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀔􀀎􀀉􀀎􀀖􀀐􀀣􀀃􀀆􀀒􀀃􀀊􀀃􀀍􀀇􀀒􀀚􀀎􀀋􀀎􀀒􀀍􀀎􀀃􀀍􀀊􀀑􀀑􀀃􀀝􀀆􀀐􀀉􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎􀀖􀀣
􀀞􀀆􀀇􀀑􀀊􀀐􀀆􀀒􀀕􀀃 􀀊􀀃 􀀍􀀑􀀎􀀊􀀋􀀃 􀁆􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀁇􀀃 􀀏􀀒􀀘􀀎􀀋􀀖􀀐􀀊􀀒􀀘􀀆􀀒􀀕􀀃 􀀕􀀖􀀗􀀡􀀖 􀀃 􀀔􀀎􀀐􀀝􀀎􀀎􀀒
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀊􀀒􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀐􀀉􀀊􀀐􀀃􀀍􀀊􀀑􀀑􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀒􀀐􀀖􀀃􀀒􀀇􀀐􀀃􀀔􀀎􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘􀀃􀀆􀀒
􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀖􀀟􀀃􀀥􀀎􀀍􀀇􀀒􀀘􀀣􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀎􀀘
􀀐􀀇􀀃 􀀏􀀖􀀎􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀖􀀃 􀀎􀀞􀀎􀀒
􀀊􀀚􀀐􀀎􀀋􀀃 􀀐􀀉􀀎􀀃 􀀍􀀊􀀑􀀑􀀟􀀃 􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀊􀀑􀀖􀀇􀀃 􀀚􀀇􀀏􀀒􀀘􀀣􀀃 􀀝􀀆􀀐􀀉􀀃 􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎
􀀎􀀞􀀆􀀘􀀎􀀒􀀐􀀆􀀊􀀋􀀓􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀣􀀃 􀀊􀀃 􀀘􀀆􀀋􀀎􀀍􀀐􀀃 􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎
􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀆􀀒􀀕􀀃 􀀖􀀇􀀚􀀇􀀖􀀔􀀏􀀞􀀆􀀋􀀟􀀃 􀀶􀀉􀀏􀀖􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖
􀀗􀀒􀀇􀀝􀀑􀀎􀀘􀀕􀀎􀀃 􀀇􀀚􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀣􀀃 􀀊􀀍􀁊􀀏􀀆􀀋􀀎􀀘􀀃 􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀑􀀓􀀣􀀃 􀀆􀀒􀀚􀀑􀀏􀀎􀀒􀀍􀀎􀀘
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀚􀀆􀀑􀀆􀀒􀀕􀀃 􀀇􀀚􀀃 􀀒􀀊􀀋􀀋􀀇􀀝􀀎􀀘􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀣􀀃 􀀊􀀃 􀀚􀀆􀀑􀀆􀀒􀀕􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀎􀀑􀀘􀀃 􀀐􀀉􀀎
􀀈􀀇􀀐􀀎􀀒􀀐􀀆􀀊􀀑􀀃 􀀚􀀇􀀋􀀃 􀀎􀁈􀀈􀀎􀀘􀀆􀀐􀀆􀀒􀀕􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀆􀀖􀀖􀀏􀀊􀀒􀀍􀀎􀀃 􀀊􀀒􀀘􀀃 􀀚􀀇􀀋􀀃 􀀑􀀇􀀝􀀎􀀋􀀆􀀒􀀕
􀀍􀀎􀀋􀀐􀀊􀀆􀀒􀀃 􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃 􀀋􀀆􀀖􀀗􀀖􀀟􀀃 􀀶􀀉􀀇􀀖􀀎􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃 􀀎􀀖􀀐􀀊􀀔􀀑􀀆􀀖􀀉􀀃 􀀖􀀎􀀋􀀆􀀇􀀏􀀖
􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀣􀀃 􀀞􀀆􀀇􀀑􀀊􀀐􀀆􀀒􀀕􀀃 􀀍􀀑􀀎􀀊􀀋􀀃 􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀖􀀃 􀀇􀀚􀀃 􀀈􀀋􀀇􀀔􀀆􀀐􀀓􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎
􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀑􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀊􀀍􀁊􀀏􀀆􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀑􀀎􀀖􀀖􀀃􀀋􀀆􀀖􀀗􀀓􀀃􀀢􀀭􀀵􀀵
􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀣􀀃􀀐􀀉􀀏􀀖􀀣􀀃􀀝􀀊􀀖􀀃􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃􀀊􀀒􀀘􀀃􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀆􀀑􀀓􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀇
􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀇􀀚􀀃􀀕􀀆􀀞􀀆􀀒􀀕􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀐􀀉􀀎􀀃􀀋􀀎􀀑􀀆􀀎􀀚􀀃􀀇􀀚􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀆􀀐
􀀖􀀎􀀎􀀗􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀟
􀀪
􀀶􀀉􀀎􀀃 􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀆􀀒􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀀃 􀀕􀀋􀀇􀀝􀀖􀀃 􀀇􀀏􀀐􀀃 􀀇􀀚
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀘􀀎􀀊􀀑􀀆􀀒􀀕􀀖􀀃 􀀝􀀆􀀐􀀉􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀟􀀃 􀁀􀀒􀀃 􀀐􀀉􀀎􀀃 􀀎􀀊􀀋􀀑􀀓􀀃 􀀲􀀬􀀬􀀬􀀖􀀣􀀃 􀀐􀀉􀀎
􀀐􀀝􀀇􀀃 􀀍􀀇􀀌􀀈􀀊􀀒􀀆􀀎􀀖􀀃 􀀘􀀆􀀖􀀍􀀏􀀖􀀖􀀎􀀘􀀃 􀀈􀀇􀀖􀀖􀀆􀀔􀀑􀀎􀀃 􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃 􀀊􀀋􀀋􀀊􀀒􀀕􀀎􀀌􀀎􀀒􀀐􀀖
􀀐􀀉􀀊􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀎􀀃􀀝􀀇􀀋􀀗􀀃􀀇􀀒􀀃􀁆􀀘􀀆􀀖􀀍􀀇􀀞􀀎􀀋􀀓􀀃􀀊􀀒􀀘􀀃􀀘􀀎􀀞􀀎􀀑􀀇􀀈􀀌􀀎􀀒􀀐􀀃􀀇􀀚
􀀊􀀒􀀐􀀆􀀞􀀆􀀋􀀊􀀑􀀃􀀊􀀕􀀎􀀒􀀐􀀖􀀃􀀊􀀕􀀊􀀆􀀒􀀖􀀐􀀃􀀟􀀟􀀟􀀃􀀉􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃􀀜􀀃􀀞􀀆􀀋􀀏􀀖􀀟􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯
􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀃􀀳􀀟􀀃􀀶􀀉􀀎􀀓􀀃􀀎􀀒􀀐􀀎􀀋􀀎􀀘􀀃􀀆􀀒􀀐􀀇􀀃􀀊􀀃􀀒􀀇􀀒􀀄􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀏􀀋􀀎􀀃􀀊􀀕􀀋􀀎􀀎􀀌􀀎􀀒􀀐
􀀆􀀒􀀃􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀪􀀟􀀃􀀐􀀊􀀎
􀁀􀀒􀀃 􀀥􀀎􀀈􀀐􀀎􀀌􀀔􀀎􀀋􀀃 􀀲􀀬􀀬􀀫􀀣􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀕􀀊􀀞􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀍􀀎􀀋􀀐􀀊􀀆􀀒
􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀧􀀥􀀨􀀅􀀃􀀧􀀏􀀍􀀑􀀎􀀇􀀖􀀆􀀘􀀎􀀃􀁀􀀒􀀉􀀆􀀔􀀆􀀐􀀇􀀋􀀣
􀀆􀀎􀀈􀀎􀀣􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃 􀀐􀀊􀀎􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀫􀀲􀀪􀀳􀀪􀁋􀁃􀀪􀀟􀀃 􀁀􀀒􀀃 􀀽􀀍􀀐􀀇􀀔􀀎􀀋􀀃 􀀲􀀬􀀬􀀫􀀣􀀃 􀀐􀀉􀀎
􀀍􀀇􀀌􀀈􀀊􀀒􀀆􀀎􀀖􀀃 􀀖􀀆􀀕􀀒􀀎􀀘􀀃 􀀊􀀃 􀀼􀀊􀀐􀀎􀀋􀀆􀀊􀀑􀀃 􀀶􀀋􀀊􀀒􀀖􀀚􀀎􀀋􀀃 􀀡􀀕􀀋􀀎􀀎􀀌􀀎􀀒􀀐􀀃 􀀏􀀒􀀘􀀎􀀋
􀀝􀀉􀀆􀀍􀀉􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀕􀀆􀀞􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀐􀀉􀀎􀀃􀁆􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀛􀀜􀁎
􀀧􀀥􀀨􀀅􀀃􀀧􀀏􀀍􀀑􀀎􀀇􀀖􀀆􀀘􀀎􀀃􀁀􀀒􀀉􀀆􀀔􀀆􀀐􀀇􀀋􀁇􀀃􀀚􀀇􀀋􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀐􀀇􀀃􀀎􀀞􀀊􀀑􀀏􀀊􀀐􀀎􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣
􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀮􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀫􀀬􀀬􀀮􀀮􀁋􀁃􀀫􀀟􀀃 􀀶􀀉􀀎􀀃 􀀡􀀕􀀋􀀎􀀎􀀌􀀎􀀒􀀐
􀀊􀀑􀀑􀀇􀀝􀀎􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀐􀀇􀀃􀀐􀀎􀀖􀀐􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀊􀀖􀀃􀀑􀀇􀀒􀀕􀀃􀀊􀀖􀀃􀀆􀀐􀀃􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀐􀀋􀀓􀀃􀀐􀀇
􀀘􀀆􀀖􀀍􀀎􀀋􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀢􀀖􀀃􀀍􀀉􀀎􀀌􀀆􀀍􀀊􀀑􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯
􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀮􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀫􀀬􀀬􀀮􀁃􀀃􀁓􀀃􀀫􀀟􀀪􀀟
􀁀􀀒􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀭􀀣􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀖􀀗􀀎􀀘􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀐􀀇􀀃 􀀚􀀏􀀋􀀒􀀆􀀖􀀉􀀃 􀀌􀀇􀀋􀀎
􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀊􀀃 􀁆􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀎􀀘􀁇􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀌􀀎􀀘􀀆􀀍􀀆􀀒􀀊􀀑􀀃 􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀁄
􀀌􀀎􀀊􀀒􀀆􀀒􀀕􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀀃􀀝􀀊􀀖􀀃􀁆􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀎􀀘􀁇􀀃􀀚􀀋􀀇􀀌􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀇􀀝􀀒
􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀃 􀀈􀀋􀀇􀀕􀀋􀀊􀀌􀀟􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃 􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀮􀁋􀁃􀀺
􀀱􀀟􀀡􀀟􀀃 􀀫􀀲􀀪􀁃􀀫􀁋􀁃􀀳􀀟􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀊􀀕􀀋􀀎􀀎􀀘􀀃 􀀐􀀇􀀃 􀀈􀀋􀀇􀀞􀀆􀀘􀀎􀀃 􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒
􀀐􀀇􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀀣􀀃 􀀦􀀋􀀟􀀃 􀀡􀀖􀀉􀀐􀀇􀀒􀀣􀀃 􀀇􀀒􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀒􀀘􀀆􀀐􀀆􀀇􀀒􀀖􀀃 􀀐􀀉􀀊􀀐
􀀐􀀉􀀎􀀃 􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃 􀀝􀀊􀀖􀀃 􀀖􀀏􀀔􀀙􀀎􀀍􀀐􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀲􀀬􀀬􀀪􀀃 􀀒􀀇􀀒􀀄􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀏􀀋􀀎
􀀊􀀕􀀋􀀎􀀎􀀌􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀣􀀃􀀝􀀉􀀊􀀐􀀃􀀆􀀖􀀃􀀍􀀋􀀆􀀐􀀆􀀍􀀊􀀑􀀃􀀉􀀎􀀋􀀎􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀝􀀊􀀖􀀃􀀐􀀇􀀃􀀔􀀎􀀃􀀖􀀉􀀊􀀋􀀎􀀘
􀀇􀀒􀀑􀀓􀀃 􀀇􀀒􀀃 􀀊􀀃 􀁆􀀃 􀁖􀀚􀀆􀀋􀀎􀀃 􀀝􀀊􀀑􀀑􀀎􀀘􀁗􀀃 􀀔􀀊􀀖􀀆􀀖􀀟􀁇􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀵􀀲􀀪􀁋􀀲􀀲􀀺􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀣
􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀮􀁋􀁃􀀟􀀃 􀁀􀀒􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀭􀀣􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀁆􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀎􀀘􀁇􀀃 􀀍􀀉􀀎􀀌􀀆􀀖􀀐􀀃 􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀁆􀀠􀀥􀁀􀀳􀀪􀀫􀀬􀀃 􀀊􀀒􀀘􀀃 􀀆􀀐􀀖
􀀋􀀎􀀑􀀊􀀐􀀆􀀞􀀎􀀖􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃􀀊􀀃􀀈􀀇􀀐􀀎􀀒􀀐􀀆􀀊􀀑􀀑􀀓􀀃􀀕􀀇􀀇􀀘􀀃􀀚􀀆􀀐􀀃􀀝􀀆􀀐􀀉􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀎􀁈􀀆􀀖􀀐􀀆􀀒􀀕
􀀊􀀒􀀐􀀆􀀄􀀛􀀜􀁎􀀃􀀈􀀇􀀋􀀐􀀚􀀇􀀑􀀆􀀇􀀃􀀊􀀋􀀆􀀖􀀆􀀒􀀕􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀁀􀀖􀀆􀀖􀀃􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀇􀀒􀀟􀁇􀀃􀀱􀀟􀀡􀀟
􀀲􀀲􀀵􀀪􀁃􀁋􀀪􀀵􀀟
􀀼􀀎􀀋􀀍􀀗􀀃􀀊􀀒􀀘􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀐􀀉􀀎􀀒􀀃􀀖􀀍􀀉􀀎􀀘􀀏􀀑􀀎􀀘􀀣􀀃􀀚􀀇􀀋􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀪􀀮􀀣􀀃􀀲􀀬􀀬􀀭􀀣
􀀊􀀃 􀀍􀀇􀀒􀀚􀀎􀀋􀀎􀀒􀀍􀀎􀀃 􀀍􀀊􀀑􀀑􀀃 􀀘􀀏􀀋􀀆􀀒􀀕􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀎
􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀫􀀮􀀬􀀳􀁋􀀬􀀮􀀺􀀃􀀍􀀈􀀈􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳
􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀁃􀀟􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀈􀀑􀀊􀀒􀀒􀀎􀀘􀀃 􀀐􀀇􀀃 􀀉􀀊􀀞􀀎􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀇􀀋􀀃􀀚􀀇􀀋􀀃􀀝􀀉􀀊􀀐􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣
􀁆􀀞􀀆􀀎􀀝􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀁇􀀃􀀘􀀏􀀋􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀫􀀮􀀬􀀳􀁋􀀬􀀮􀀺􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣
􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀁃􀀺􀀃 􀀍􀀈􀀈􀀃 􀀉􀀇􀀍􀀘􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀵􀀭􀀨􀀃 􀁁􀀫􀀮􀀨􀁂􀀃 􀁁􀀦􀀋􀀟
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃􀀖􀀏􀀈􀀎􀀋􀀞􀀆􀀖􀀇􀀋􀀃􀀊􀀖􀀗􀀎􀀘􀀃􀀉􀀆􀀌􀀃􀀐􀀇􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀁂􀀟􀀃􀀶􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀗􀀒􀀎􀀝􀀃 􀀔􀀎􀀚􀀇􀀋􀀎􀀃 􀀐􀀉􀀎􀀃 􀀍􀀊􀀑􀀑
􀁆􀀐􀀉􀀊􀀐􀀃􀀊􀀒􀀓􀀃􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃􀀉􀀎􀀃􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬
􀀒􀀏􀀍􀀑􀀎􀀇􀀖􀀆􀀘􀀎􀀃􀀊􀀒􀀊􀀑􀀇􀀕􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀇􀀞􀀎􀀋􀀑􀀊􀀈􀀃􀀝􀀆􀀐􀀉􀀃􀀐􀀉􀀎􀀃􀀖􀀏􀀔􀀙􀀎􀀍􀀐
􀀌􀀊􀀐􀀐􀀎􀀋􀀃 􀀇􀀚􀀃 􀀉􀀆􀀖􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃 􀀘􀀇􀀍􀀗􀀎􀀐􀀃 􀀚􀀇􀀋􀀃 􀀼􀀎􀀋􀀍􀀗􀀣􀀃 􀀐􀀉􀀎􀀋􀀎􀀔􀀓
􀀍􀀋􀀎􀀊􀀐􀀆􀀒􀀕􀀃􀀊􀀃􀀍􀀇􀀒􀀚􀀑􀀆􀀍􀀐􀀟􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀵􀀟
􀀽􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀪􀀮􀀣􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀔􀀎􀀚􀀇􀀋􀀎􀀃􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀢􀀖
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀣􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃 􀀍􀀇􀀒􀀚􀀆􀀋􀀌􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀍􀀎􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎
􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀃􀀐􀀇􀀃􀀆􀀐􀀃􀀔􀀓􀀃􀀊􀀖􀀗􀀆􀀒􀀕􀀃􀀝􀀉􀀎􀀐􀀉􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀐􀀝􀀇􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀒􀀕􀀃􀀼􀀎􀀋􀀍􀀗
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀏
􀀎􀀌􀀈􀀑􀀇􀀓􀀎􀀎􀀖􀀃􀁁􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀊􀀒􀀘􀀃􀀦􀀋􀀟􀀃􀀠􀀇􀀒􀁂􀀃􀀝􀀎􀀋􀀎􀀃􀀝􀀆􀀐􀀉􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑
􀀕􀀖􀀗􀀡􀀗 􀀃 􀀖􀀎􀀈􀀊􀀋􀀊􀀐􀀆􀀒􀀕􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀍􀀊􀀑􀀑􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀒􀀐􀀖􀀃 􀀚􀀋􀀇􀀌􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘
􀀼􀀎􀀋􀀍􀀗􀀃􀀛􀀜􀁎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀆􀀒􀀕􀀃􀀎􀀚􀀚􀀇􀀋􀀐􀀖􀀟􀀃􀀐􀀊􀀎􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀫􀀪􀀨􀀭􀀭􀁋􀀭􀀨􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀵􀀭􀀮
􀁁􀀫􀁃􀀲􀁂􀀟􀀃􀀡􀀐􀀃􀀖􀀇􀀌􀀎􀀃􀀈􀀇􀀆􀀒􀀐􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀐􀀉􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀒􀀐􀀖􀀃􀀖􀀊􀀆􀀘
􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀓􀀃􀀝􀀎􀀋􀀎􀀃􀀝􀀆􀀐􀀉􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣
􀀊􀀐􀀃 􀁌􀀵􀁋􀀪􀀬􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀫􀀪􀀨􀀭􀀭􀁋􀀭􀀨􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀵􀀳􀀬􀀃 􀁁􀀭􀀫􀀨􀁂􀀟􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖
􀀒􀀇􀀐􀀎􀀖􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀉􀀇􀀝􀀎􀀞􀀎􀀋􀀣􀀃􀀊􀀑􀀖􀀇􀀃􀀆􀀒􀀘􀀆􀀍􀀊􀀐􀀎􀀃􀀖􀀇􀀌􀀎􀀃􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀏􀀋􀀎􀀃􀀔􀀓
􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀇􀀚􀀃􀀊􀀃􀀍􀀇􀀒􀀚􀀑􀀆􀀍􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀃􀀚􀀇􀀋􀀃􀀉􀀆􀀌􀀩􀀃􀁆􀁀􀀐􀀢􀀖􀀃􀀊􀀃􀀈􀀋􀀇􀀔􀀑􀀎􀀌􀀃􀀚􀀇􀀋􀀃􀀠􀀉􀀆􀀑
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀺􀀃􀀉􀀎􀀃􀀒􀀎􀀎􀀘􀀖􀀃􀀐􀀇􀀃􀀉􀀊􀀞􀀎􀀃􀀊􀀃􀀍􀀇􀀒􀀞􀀎􀀋􀀖􀀊􀀐􀀆􀀇􀀒􀀃􀀝􀀆􀀐􀀉􀀃􀀉􀀆􀀖􀀃􀀖􀀏􀀈􀀎􀀋􀀞􀀆􀀖􀀇􀀋􀀺
􀁖􀀖􀀎􀀎􀀌􀀖􀀃􀁊􀀏􀀆􀀐􀀎􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀆􀀒􀀕􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀁀􀀢􀀌􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘􀀃􀀝􀀆􀀐􀀉􀀟􀁗􀀃􀀟􀀟􀀟􀀃􀁔􀀛􀁕􀀎
􀀆􀀖􀀃􀀈􀀎􀀋􀀖􀀇􀀒􀀊􀀑􀀑􀀓􀀃􀀍􀀇􀀒􀀚􀀑􀀆􀀍􀀐􀀎􀀘􀀺􀀃􀀒􀀇􀀐􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀈􀀊􀀒􀀓􀀟􀁇􀀃􀀱􀀟􀀡􀀟􀀃􀀫􀀪􀀨􀀭􀀨􀀺􀀃􀀍􀀈􀀈
􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀵􀁋􀀪􀀬􀀟􀀃􀀶􀀉􀀎􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎
􀀝􀀊􀀖􀀃􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀎􀀘􀀃􀀘􀀏􀀋􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀵􀀟
􀀡􀀚􀀐􀀎􀀋􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀀣􀀃 􀀲􀀬􀀬􀀭􀀃 􀀍􀀊􀀑􀀑􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀖􀀐􀀇􀀈􀀈􀀎􀀘
􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀒􀀕􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀝􀀇􀀋􀀗􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀐􀀎􀀊􀀌􀀃 􀀘􀀎􀀊􀀑􀀆􀀒􀀕􀀃 􀀝􀀆􀀐􀀉
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀵􀀭􀀭􀀃􀁁􀀫􀀮􀀫􀁂􀀟􀀃􀀅􀀏􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀗􀀎􀀈􀀐􀀃􀀉􀀆􀀌􀀃􀀝􀀇􀀋􀀗􀀆􀀒􀀕
􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀒􀀕􀀃􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀃􀀚􀀇􀀋􀀃􀀆􀀐􀀖􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘
􀀐􀀇􀀃 􀀒􀀏􀀍􀀑􀀎􀀇􀀖􀀆􀀘􀀎􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀒􀀉􀀆􀀔􀀆􀀐􀀃 􀀛􀀎􀀈􀀊􀀐􀀆􀀐􀀆􀀖􀀃 􀀜􀀃 􀀞􀀆􀀋􀀏􀀖􀀃 􀀋􀀎􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀟
􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀪􀀬􀀃􀁁􀁆􀁀􀀒􀀖􀀐􀀎􀀊􀀘􀀃􀀇􀀚􀀃􀀝􀀆􀀐􀀉􀀘􀀋􀀊􀀝􀀆􀀒􀀕
􀀚􀀋􀀇􀀌􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀎􀀘􀀃􀀐􀀇􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀛􀀜􀁎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀊􀀒􀀘􀀃􀀝􀀋􀀆􀀐􀀎􀀃􀀒􀀎􀀝􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀊􀀋􀀕􀀎􀀐􀀎􀀘
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃 􀀝􀀇􀀋􀀗􀀟􀁇􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀒􀀎􀀆􀀐􀀉􀀎􀀋􀀃 􀀼􀀎􀀋􀀍􀀗
􀀒􀀇􀀋􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀈􀀋􀀇􀀞􀀆􀀘􀀎􀀘􀀃􀀊􀀒􀀓􀀃􀀎􀁈􀀈􀀑􀀊􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀖􀀃􀀐􀀇􀀃􀀝􀀉􀀓􀀃􀀉􀀎􀀃􀀝􀀊􀀖
􀀒􀀇􀀐􀀃 􀀋􀀎􀀌􀀇􀀞􀀎􀀘􀀃 􀀚􀀋􀀇􀀌􀀃 􀀚􀀏􀀋􀀐􀀉􀀎􀀋􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀈􀀊􀀐􀀎􀀒􀀐
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀟􀀃􀀐􀀊􀀎
􀀶􀀉􀀇􀀖􀀎􀀃 􀀚􀀊􀀍􀀐􀀖􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃 􀀇􀀚􀀃 􀀖􀀎􀀋􀀆􀀇􀀏􀀖
􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀟􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀖􀀎􀀒􀀐􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀐􀀇􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎
􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀲􀀬􀀬􀀭􀀃 􀀍􀀊􀀑􀀑􀀃 􀀘􀀎􀀖􀀈􀀆􀀐􀀎􀀃 􀀐􀀉􀀎􀀃 􀀍􀀑􀀎􀀊􀀋􀀃 􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑􀀃 􀀊􀀒􀀘
􀀐􀀉􀀎􀀃 􀀚􀀊􀀍􀀐􀀃 􀀐􀀉􀀊􀀐􀀃 􀁆􀀼􀀎􀀋􀀍􀀗􀀃 􀀟􀀟􀀟􀀃 􀀗􀀒􀀎􀀝􀀃 􀀐􀀉􀀊􀀐􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃 􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘
􀀝􀀊􀀖􀀃 􀀊􀀒􀀃 􀀧􀀥􀀨􀀅􀀃 􀀈􀀇􀀑􀀓􀀌􀀎􀀋􀀊􀀖􀀎􀀃 􀀆􀀒􀀉􀀆􀀔􀀆􀀐􀀇􀀋􀀃 􀀙􀀏􀀖􀀐􀀃 􀀑􀀆􀀗􀀎􀀃 􀀆􀀐􀀖􀀃 􀀇􀀝􀀒
􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀖􀀃 􀀚􀀋􀀇􀀌􀀃 􀀐􀀉􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀄􀁀􀀖􀀆􀀖􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀇􀀒􀀟􀁇􀀃 􀀐􀀊􀀎􀀃 􀀊􀀐􀀃 􀁌􀀲􀁃􀀟
􀁆􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀌􀀎􀀒􀀐􀀃 􀀝􀀆􀀐􀀉􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀛􀀜􀁎􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖
􀀞􀀆􀀇􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀏􀀒􀀘􀀎􀀋􀀖􀀐􀀊􀀒􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀋􀀐􀀆􀀎􀀖􀀃􀀉􀀊􀀘􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀐􀀉􀀎􀀆􀀋􀀃􀀚􀀆􀀋􀀎􀀝􀀊􀀑􀀑
􀀇􀀔􀀑􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀖􀀣􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀎􀁈􀀍􀀑􀀏􀀘􀀎􀀘􀀃 􀀊􀀒􀀓􀀇􀀒􀀎􀀃 􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘􀀃 􀀝􀀆􀀐􀀉􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀆􀀒􀀐􀀎􀀋􀀒􀀊􀀑􀀃􀀛􀀜􀁎􀀃􀀈􀀋􀀇􀀕􀀋􀀊􀀌􀀟􀁇􀀃􀀐􀀊􀀎􀀃􀀡􀀒􀀘􀀃􀀊􀀚􀀐􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀆􀀐􀀃􀀝􀀊􀀖􀀃􀁆􀀝􀀋􀀇􀀒􀀕
􀀚􀀇􀀋􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀐􀀇􀀃 􀀊􀀑􀀑􀀇􀀝􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀐􀀇􀀃 􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀎􀀃 􀀐􀀇􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀎􀁇
􀀐􀀉􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀩􀀃 􀀉􀀎􀀃 􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀎􀀘􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀊􀀒􀀘􀀃􀀆􀀒􀀃􀀲􀀬􀀬􀀮􀀃􀀉􀀎􀀃􀀚􀀆􀀑􀀎􀀘
􀁁􀀊􀀒􀀘􀀃􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃􀀊􀀌􀀎􀀒􀀘􀀎􀀘􀁂􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀐􀀉􀀎
􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃􀀐􀀊􀀎 􀀭
􀀲
􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀣􀀃 􀀝􀀆􀀐􀀉􀀃 􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀃 􀀔􀀊􀀖􀀆􀀖􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎
􀀝􀀋􀀇􀀒􀀕􀀚􀀏􀀑􀀃􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀉􀀊􀀘􀀃􀀐􀀉􀀎􀀃􀀋􀀎􀁊􀀏􀀆􀀋􀀎􀀘􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃􀀐􀀇􀀃􀀐􀀉􀀆􀀖
􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀲􀀵􀀟􀀃􀀡􀀖􀀃􀀑􀀊􀀆􀀘􀀃􀀇􀀏􀀐􀀃􀀊􀀔􀀇􀀞􀀎􀀣􀀃􀀆􀀒􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓
􀀲􀀬􀀬􀀨􀀣􀀃 􀀊􀀃 􀀌􀀇􀀒􀀐􀀉􀀃 􀀊􀀚􀀐􀀎􀀋􀀃 􀀐􀀉􀀎􀀃 􀀈􀀏􀀔􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃 􀀜􀀑􀀊􀀋􀀗
􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀊􀀌􀀎􀀒􀀘􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐
􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀑􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀔􀀓􀀃 􀀍􀀊􀀒􀀍􀀎􀀑􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀔􀀋􀀇􀀊􀀘
􀀕􀀎􀀒􀀏􀀖􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀊􀀒􀀘􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀆􀀒􀀕􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀒􀀊􀀋􀀋􀀇􀀝􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀖􀀍􀀇􀀈􀀎
􀀐􀀇􀀃􀀊􀀃􀀖􀀏􀀔􀀕􀀎􀀒􀀏􀀖􀀃􀀚􀀇􀀍􀀏􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀗􀀎􀀓􀀃􀀚􀀎􀀊􀀐􀀏􀀋􀀎􀀖􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐
􀁌􀀪􀀪􀀟􀀃􀀶􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃 􀀕􀀖􀀗􀀡􀀘 􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀁆􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀝􀀇􀀏􀀑􀀘
􀀒􀀇􀀐􀀃􀀉􀀊􀀞􀀎􀀃􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀃􀀒􀀎􀀝􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀇􀀃􀀍􀀇􀀞􀀎􀀋􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀆􀀒􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓
􀀲􀀬􀀬􀀨􀀃 􀀔􀀏􀀐􀀃 􀀚􀀇􀀋􀀃 􀀉􀀆􀀖􀀃 􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀒􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀀣
􀀲􀀬􀀬􀀭􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀘􀀏􀀎􀀃􀀘􀀆􀀑􀀆􀀕􀀎􀀒􀀍􀀎􀀃􀀍􀀊􀀑􀀑􀀃􀀊􀀒􀀘􀀃􀀑􀀎􀀊􀀋􀀒􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀇􀀚
􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀊􀀉􀀎􀀊􀀘􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀔􀀎􀀆􀀒􀀕􀀃􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀟􀁇􀀃􀀐􀀊􀀎
􀀿􀀆􀀞􀀎􀀒􀀃 􀀐􀀉􀀊􀀐􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃 􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎
􀀆􀀒􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀲􀀬􀀬􀀭􀀃 􀁁􀀊􀀖􀀃 􀀆􀀖􀀃 􀀒􀀇􀀝􀀃 􀀍􀀇􀀒􀀍􀀎􀀘􀀎􀀘􀁂􀀣􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐
􀀍􀀇􀀏􀀑􀀘􀀃􀀋􀀎􀀊􀀘􀀆􀀑􀀓􀀃􀀚􀀆􀀒􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀆􀀖􀀃􀀗􀀒􀀇􀀝􀀑􀀎􀀘􀀕􀀎􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀑􀀑􀀃􀀈􀀑􀀊􀀓􀀎􀀘􀀃􀀊
􀀖􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀃􀀋􀀇􀀑􀀎􀀃􀀆􀀒􀀃􀀉􀀆􀀖􀀃􀀊􀀍􀀐􀀏􀀊􀀑􀀃􀀈􀀋􀀇􀀍􀀎􀀖􀀖􀀃􀀇􀀚􀀃􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀄􀀌􀀊􀀗􀀆􀀒􀀕􀀃􀀐􀀉􀀊􀀐
􀀑􀀎􀀘􀀃􀀉􀀆􀀌􀀃􀀐􀀇􀀃􀀚􀀆􀀑􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀚􀀇􀀍􀀏􀀖􀀆􀀒􀀕􀀃􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀊􀀒􀀘􀀃􀀖􀀆􀀌􀀆􀀑􀀊􀀋􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀟
􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀊􀀘􀀌􀀆􀀐􀀐􀀎􀀘􀀃􀀘􀀏􀀋􀀆􀀒􀀕􀀃􀀉􀀆􀀖􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒
􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀉􀀎􀀃􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀐􀀆􀀌􀀎􀀃􀀘􀀎􀀒􀀆􀀎􀀘􀀣􀀃􀁆􀀝􀀇􀀏􀀑􀀘
􀀉􀀊􀀞􀀎􀀃 􀀐􀀊􀀆􀀒􀀐􀀎􀀘􀀃 􀁔􀀉􀀆􀀖􀁕􀀃 􀀙􀀏􀀘􀀕􀀌􀀎􀀒􀀐􀀃 􀀊􀀖􀀃 􀀐􀀇􀀃 􀀝􀀉􀀊􀀐􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀐􀀇􀀃 􀀈􀀏􀀋􀀖􀀏􀀎􀀃 􀀆􀀒
􀀐􀀉􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀁉􀁀􀀖􀀆􀀖􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀇􀀒􀀟􀁇􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀭􀀪􀀃 􀁁􀀫􀁃􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀐􀀆􀀌􀀆􀀒􀀕
􀀇􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀇􀀍􀀍􀀏􀀋􀀋􀀎􀀘􀀃􀀙􀀏􀀖􀀐
􀀇􀀒􀀎􀀃􀀌􀀇􀀒􀀐􀀉􀀃􀀊􀀚􀀐􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀝􀀊􀀖􀀃􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃􀀆􀀒
􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀣􀀃􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀖􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀚􀀎􀀋􀀎􀀒􀀍􀀎􀀣􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀈􀀏􀀐
􀀆􀀐􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀝􀀊􀀖􀀃􀀘􀀎􀀑􀀆􀀔􀀎􀀋􀀊􀀐􀀎􀀑􀀓􀀃􀁆􀀝􀀊􀀆􀀐􀁔􀀆􀀒􀀕􀁕􀀟􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯
􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀪􀀪􀀃􀁁􀁆􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀝􀀊􀀆􀀐􀀎􀀘􀀃􀀐􀀇􀀃􀀊􀀌􀀎􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀟􀀟􀀟
􀀏􀀒􀀐􀀆􀀑􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀝􀀊􀀖􀀃􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀁇􀁂􀀟􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀈􀀋􀀇􀀞􀀆􀀘􀀎􀀘
􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀃 􀀚􀀇􀀋􀀃 􀀐􀀉􀀎􀀃 􀀆􀀒􀀚􀀎􀀋􀀎􀀒􀀍􀀎􀀃 􀀇􀀚􀀃 􀀊􀀃 􀀐􀀊􀀆􀀒􀀐􀀃 􀀝􀀉􀀎􀀒􀀃 􀀉􀀎􀀃 􀀖􀀐􀀊􀀐􀀎􀀘􀀃 􀀆􀀒􀀃 􀀉􀀆􀀖
􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀚􀀊􀀆􀀑􀀆􀀒􀀕􀀃􀀐􀀇􀀃􀀗􀀎􀀎􀀈􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀒􀀐􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭
􀀍􀀊􀀑􀀑􀀃􀀖􀀎􀀈􀀊􀀋􀀊􀀐􀀎􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀇􀀋􀀖􀀃􀁆􀀍􀀇􀀏􀀑􀀘􀀃􀀋􀀊􀀆􀀖􀀎􀀃􀀆􀀖􀀖􀀏􀀎􀀖
􀀘􀀇􀀝􀀒􀀃􀀐􀀉􀀎􀀃􀀋􀀇􀀊􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀆􀀖􀀖􀀏􀀎􀀃􀀔􀀊􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎
􀀊􀀐􀀐􀀇􀀋􀀒􀀎􀀓􀀖􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀒􀀕􀀃􀀇􀀚􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀟􀁇􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀮􀀭􀀃􀁁􀀪􀀮􀀪􀁂􀀟 􀀨
􀀶􀀉􀀎􀀃􀀊􀀘􀀘􀀆􀀐􀀆􀀇􀀒􀀊􀀑􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀊􀀐􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀒􀀇􀀐􀀃􀀇􀀐􀀉􀀎􀀋􀀝􀀆􀀖􀀎
􀀉􀀊􀀞􀀎􀀃 􀀌􀀊􀀘􀀎􀀃 􀀐􀀉􀀎􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃 􀀆􀀖􀀃 􀀒􀀇􀀐􀀃 􀀍􀀑􀀎􀀊􀀋􀀑􀀓
􀀎􀀋􀀋􀀇􀀒􀀎􀀇􀀏􀀖􀀟􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀊􀀐􀀃􀀉􀀆􀀖􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀕􀀋􀀎􀀊􀀐􀀑􀀓
􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀋􀀇􀀑􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀖􀀇􀀑􀀎􀀃􀀈􀀋􀀇􀀌􀀆􀀒􀀎􀀒􀀐􀀃􀀍􀀊􀀒􀀘􀀆􀀘􀀊􀀐􀀎􀀃􀀚􀀇􀀋􀀃􀀊􀀒
􀀆􀀒􀀘􀀎􀀈􀀎􀀒􀀘􀀎􀀒􀀐􀀃􀀍􀀊􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣􀀃􀀒􀀊􀀌􀀎􀀑􀀓􀀣
􀀐􀀉􀀎􀀃􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀟􀀃􀁀􀀒􀀃􀀘􀀇􀀆􀀒􀀕􀀃􀀖􀀇􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀕􀀊􀀞􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀖􀀃 􀀍􀀊􀀈􀀊􀀔􀀑􀀎􀀃 􀀇􀀚􀀃 􀀔􀀎􀀆􀀒􀀕􀀃 􀀋􀀎􀀊􀀘􀀃 􀀊􀀖􀀃 􀀖􀀏􀀕􀀕􀀎􀀖􀀐􀀆􀀒􀀕
􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀑􀀇􀀒􀀎􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀒􀀇􀀐􀀃􀀉􀀊􀀞􀀎􀀃􀀑􀀎􀀘􀀃􀀉􀀆􀀌􀀃􀀐􀀇
􀀊􀀌􀀎􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀭􀀭􀁋􀀭􀀳􀀟􀀃􀀥􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀑􀀓􀀣􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀘􀀆􀀘
􀀒􀀇􀀐􀀃 􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀃 􀀐􀀉􀀊􀀐􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀍􀀇􀀌􀀈􀀎􀀑􀀃 􀀊􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀣􀀃 􀀇􀀋􀀃 􀀎􀀞􀀎􀀒
􀀌􀀎􀀊􀀒􀀆􀀒􀀕􀀚􀀏􀀑􀀑􀀓􀀃 􀀊􀀋􀀕􀀏􀀎􀀃 􀀚􀀇􀀋􀀃 􀀊􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀎􀀞􀀎􀀒􀀃 􀀆􀀚􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀈􀀎􀀋􀀖􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀉􀀊􀀘􀀃 􀀒􀀇􀀐􀀃 􀀌􀀊􀀘􀀎􀀃 􀀐􀀉􀀎􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣
􀀇􀀐􀀉􀀎􀀋􀀖􀀃􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀑􀀊􀀍􀀗􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀎􀀊􀀋􀀑􀀆􀀎􀀋􀀃􀀗􀀒􀀇􀀝􀀑􀀎􀀘􀀕􀀎􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬
􀀝􀀇􀀏􀀑􀀘􀀃 􀀉􀀊􀀞􀀎􀀃 􀀘􀀇􀀒􀀎􀀃 􀀖􀀇􀀌􀀎􀀐􀀉􀀆􀀒􀀕􀀃 􀀎􀁊􀀏􀀆􀀞􀀊􀀑􀀎􀀒􀀐􀀃 􀀖􀀇􀀃 􀀊􀀖􀀃 􀀐􀀇􀀃 􀀔􀀋􀀎􀀊􀀗􀀃 􀀊􀀒􀀓
􀀍􀀊􀀏􀀖􀀊􀀑􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃􀀔􀀎􀀐􀀝􀀎􀀎􀀒􀀃􀀐􀀉􀀎􀀃􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎
􀀈􀀊􀀐􀀎􀀒􀀐􀀄􀀋􀀆􀀕􀀉􀀐􀀖􀀃 􀀔􀀎􀀒􀀎􀀚􀀆􀀐􀀖􀀃 􀀊􀀖􀀖􀀇􀀍􀀆􀀊􀀐􀀎􀀘􀀃 􀀝􀀆􀀐􀀉􀀃 􀀐􀀉􀀎􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀟􀀃 􀀋􀀈􀀈
􀀦􀀎􀀚􀀖􀀟􀀢􀀃􀁔􀀠􀀋􀀇􀀈􀀇􀀖􀀎􀀘􀁕􀀃􀀰􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀇􀀚􀀃􀀰􀀊􀀍􀀐􀀃􀀊􀀒􀀘􀀃􀀜􀀇􀀒􀀍􀀑􀀏􀀖􀀆􀀇􀀒􀀖􀀃􀀇􀀚􀀃􀀯􀀊􀀝
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀒
􀀷􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀢􀀖􀀃􀀹􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃􀀦􀀎􀀚􀀎􀀒􀀖􀀎􀀖􀀣􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀍􀀎􀀏􀀃􀀐􀀑􀀌􀀎􀀃􀀒􀀎
􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀎􀀏􀀃􀀐􀀑􀀌􀀎􀀏􀀃􀀈􀀜􀀃􀀉􀀇􀀎􀀣􀀃􀀜􀀊􀀖􀀎􀀃􀀧􀀇􀀟􀀃􀀨􀀩􀀪􀀫􀀄􀀍􀀞􀀄􀀬􀀭􀀬􀀨􀀮􀀄􀀅􀀯􀀰􀀣􀀃􀀦􀀟􀁀􀀟
􀀭􀀬􀀮􀀃􀀊􀀐􀀃􀀲􀀮􀁋􀀲􀁃􀀃􀁁􀁓􀁓􀀃􀀪􀀪􀀫􀁋􀀪􀀨􀁂􀀃􀁁􀀧􀀟􀀦􀀟􀀃􀀜􀀊􀀑􀀟􀀃􀀡􀀈􀀋􀀟􀀃􀀲􀀲􀀣􀀃􀀲􀀬􀀪􀀳􀁂􀀃􀁁􀀔􀀋􀀊􀀍􀀗􀀎􀀐􀀖
􀀆􀀒􀀃􀀘􀀇􀀍􀀏􀀌􀀎􀀒􀀐􀀃􀀒􀀊􀀌􀀎􀀃􀀆􀀒􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀊􀀑􀁂􀀟
􀀡􀀑􀀐􀀉􀀇􀀏􀀕􀀉􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀖􀀐􀀋􀀎􀀖􀀖􀀎􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀎􀀞􀀎􀀒􀀃 􀀐􀀉􀀎􀀃 􀀈􀀋􀀎􀀄􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨
􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀆􀀑􀀌􀀇􀀡􀀊􀀈􀀊􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀃􀀊􀀒􀀘􀀃􀀖􀀆􀀌􀀆􀀑􀀊􀀋􀀃􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀖􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀎􀁈􀀈􀀑􀀊􀀆􀀒􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀔􀀎􀀒􀀎􀀚􀀆􀀐􀀖􀀃 􀀐􀀇􀀃 􀀊􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀢􀀖􀀃 􀀑􀀎􀀕􀀊􀀑􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀚􀀋􀀇􀀌
􀀊􀀃 􀀒􀀊􀀋􀀋􀀇􀀝􀀆􀀒􀀕􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃 􀀇􀀚􀀃 􀀐􀀉􀀆􀀖􀀃 􀀖􀀇􀀋􀀐􀀟􀀃 􀁆􀁀􀀐􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀎􀁈􀀈􀀎􀀘􀀆􀀐􀀎
􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀟􀁇􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀭􀀮􀀃 􀁁􀀳􀀲􀁂􀀺􀀃 􀀍􀀈􀀈􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀵􀀭􀀨􀀃 􀁁􀀫􀀮􀀳􀁂􀀃 􀁁􀁆􀀐􀀉􀀎
􀀹􀁈􀀊􀀌􀀆􀀒􀀎􀀋􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀉􀀊􀀞􀀎􀀃 􀀑􀀎􀀖􀀖􀀃 􀀖􀀏􀀔􀀙􀀎􀀍􀀐􀀃 􀀌􀀊􀀐􀀐􀀎􀀋􀀃 􀀐􀀇􀀃 􀀟􀀟􀀟􀀃 􀀖􀀎􀀊􀀋􀀍􀀉􀁇􀁂􀀟
􀀷􀀎􀀑􀀊􀀐􀀎􀀘􀀑􀀓􀀣􀀃 􀁆􀀑􀀆􀀌􀀆􀀐􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀖􀀍􀀇􀀈􀀎􀁇􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀝􀀇􀀏􀀑􀀘􀀃 􀀌􀀎􀀊􀀒
􀁆􀀚􀀎􀀝􀀎􀀋􀀃 􀀇􀀈􀀈􀀇􀀋􀀐􀀏􀀒􀀆􀀐􀀆􀀎􀀖􀀃 􀀚􀀇􀀋􀀃 􀀈􀀋􀀆􀀇􀀋􀀃 􀀊􀀋􀀐􀀃 􀀐􀀇􀀃 􀀟􀀟􀀟􀀃 􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃 􀀊􀀒􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀇􀀚
􀀈􀀊􀀐􀀎􀀒􀀐􀀊􀀔􀀆􀀑􀀆􀀐􀀓􀁇􀀃􀀏􀀒􀀘􀀎􀀋􀀃 􀀕􀀖􀀗􀀡􀀡 􀀫􀀨􀀃􀀤􀀟􀀥􀀟􀀜􀀟􀀃􀁍􀁍􀀃􀀪􀀬􀀲􀀃􀀊􀀒􀀘􀀃􀀪􀀬􀀫􀀟􀀃􀀱􀀟􀀡􀀟
􀀲􀀲􀀫􀀭􀀮􀀃􀁁􀀳􀀲􀁂􀀟􀀃􀀶􀀉􀀊􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀔􀀎􀀃􀀖􀀇􀀃􀀘􀀏􀀋􀀆􀀒􀀕􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀊􀀑􀀖􀀇􀀃􀀆􀀒􀀃􀀊
􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀍􀀉􀀊􀀑􀀑􀀎􀀒􀀕􀀎􀀟􀀃􀀡􀀒􀀘􀀃􀀊􀀃􀀒􀀊􀀋􀀋􀀇􀀝􀀆􀀒􀀕􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀍􀀊􀀒􀀃􀀋􀀎􀀘􀀏􀀍􀀎
􀀊􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀢􀀖􀀃􀀋􀀆􀀖􀀗􀀃􀀇􀀒􀀃􀀇􀀐􀀉􀀎􀀋􀀃􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀣􀀃􀀖􀀏􀀍􀀉􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀋􀀆􀀖􀀗􀀃􀀐􀀉􀀊􀀐
􀀔􀀋􀀎􀀊􀀘􀀐􀀉􀀃􀀍􀀊􀀒􀀃􀀍􀀋􀀎􀀊􀀐􀀎􀀃􀀏􀀒􀀘􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀋􀀎􀁊􀀏􀀆􀀋􀀎􀀌􀀎􀀒􀀐􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀁆􀀚􀀏􀀑􀀑􀀃􀀖􀀍􀀇􀀈􀀎􀁇
􀀇􀀚􀀃􀀊􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀔􀀎􀀃􀀎􀀒􀀊􀀔􀀑􀀎􀀘􀀟􀀃􀀋􀀈􀀈􀀣􀀃􀀈􀀎􀀙􀀎􀀣􀀃􀀤􀀢􀀙􀀈􀀑􀀃􀀐􀀑􀀌􀀎􀀃􀀒􀀎􀀃􀀋􀀉􀀑􀀘􀀣􀀆􀀣􀀃􀁃􀀮􀀲􀀃􀀰􀀟􀀫􀀘
􀀪􀀫􀀳􀀮􀀣􀀃􀀪􀀫􀀮􀀨􀀃􀁁􀀰􀀎􀀘􀀟􀀃􀀜􀀆􀀋􀀟􀀃􀀲􀀬􀀪􀀮􀁂􀀟􀀃􀀥􀀏􀀍􀀉􀀃􀀋􀀆􀀖􀀗􀀖􀀃􀀍􀀊􀀒􀀃􀀔􀀎􀀃􀀋􀀎􀀘􀀏􀀍􀀎􀀘􀀃􀀎􀀞􀀎􀀒
􀀆􀀚􀀣􀀃􀀊􀀖􀀃􀀉􀀎􀀋􀀎􀀣􀀃􀀐􀀉􀀎􀀃􀀋􀀎􀀖􀀏􀀑􀀐􀀆􀀒􀀕􀀃􀀍􀀑􀀊􀀆􀀌􀀃􀀖􀀐􀀆􀀑􀀑􀀃􀀍􀀇􀀞􀀎􀀋􀀖􀀃􀀊􀀃􀀑􀀊􀀋􀀕􀀎􀀣􀀃􀀐􀀉􀀇􀀏􀀕􀀉􀀃􀀑􀀎􀀖􀀖
􀀑􀀊􀀋􀀕􀀎􀀣􀀃􀀒􀀏􀀌􀀔􀀎􀀋􀀃􀀇􀀚􀀃􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀖􀀟
􀁀􀀒􀀃􀀐􀀉􀀎􀀖􀀎􀀃􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀣􀀃􀀝􀀎􀀃􀀖􀀎􀀎􀀃􀀒􀀇􀀃􀀎􀀋􀀋􀀇􀀋􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖
􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀎􀀄􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀝􀀎
􀀉􀀊􀀞􀀎􀀃􀀖􀀏􀀌􀀌􀀊􀀋􀀆􀀻􀀎􀀘􀀃􀀝􀀊􀀖􀀃􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃􀀊􀀒􀀘􀀃􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀆􀀑􀀓􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀇
􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀇􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀇􀀔􀀐􀀊􀀆􀀒􀀆􀀒􀀕􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀇􀀚􀀃􀀆􀀐􀀖􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀆􀀒
􀀐􀀉􀀆􀀖􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀟
􀀅
􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀊􀀑􀀖􀀇􀀃 􀀚􀀇􀀏􀀒􀀘􀀣􀀃 􀀝􀀆􀀐􀀉􀀃 􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀐􀀆􀀊􀀋􀀓
􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀣􀀃 􀀎􀀖􀀖􀀎􀀒􀀐􀀆􀀊􀀑􀀑􀀓􀀃 􀀐􀀝􀀇􀀃 􀀚􀀇􀀋􀀌􀀖􀀃 􀀇􀀚􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐
􀀆􀀒􀀞􀀇􀀑􀀞􀀆􀀒􀀕􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀊􀀖􀀃􀀊􀀃􀀝􀀆􀀐􀀒􀀎􀀖􀀖􀀃􀀊􀀒􀀘􀀃􀀊􀀐􀀐􀀋􀀆􀀔􀀏􀀐􀀊􀀔􀀑􀀎􀀃􀀐􀀇􀀃􀀼􀀎􀀋􀀍􀀗􀀟
􀀰􀀆􀀋􀀖􀀐􀀣􀀃􀀆􀀒􀀃􀀉􀀆􀀖􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃􀀝􀀉􀀎􀀋􀀎􀀃􀀉􀀎􀀃􀀊􀀈􀀈􀀎􀀊􀀋􀀎􀀘􀀃􀀈􀀊􀀋􀀐􀀑􀀓􀀃􀀊􀀖􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀍􀀇􀀋􀀈􀀇􀀋􀀊􀀐􀀎􀀃􀀝􀀆􀀐􀀒􀀎􀀖􀀖􀀃􀀇􀀒􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀐􀀇􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀃􀀝􀀊􀀖
􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀕􀀊􀀞􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎
􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀁄􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀊􀀖􀀃􀀑􀀊􀀐􀀎􀀋􀀃􀀍􀀇􀀒􀀍􀀎􀀘􀀎􀀘
􀀐􀀇􀀃 􀀔􀀎􀀃 􀀚􀀊􀀑􀀖􀀎􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀇􀀃 􀀔􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀖􀀇􀀟
􀀥􀀎􀀍􀀇􀀒􀀘􀀣􀀃􀀔􀀇􀀐􀀉􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀒􀀃􀀊􀀐􀀃􀀐􀀋􀀆􀀊􀀑􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣
􀀆􀀒􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀃 􀀇􀀚􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃 􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀖􀀣􀀃 􀀕􀀊􀀞􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓
􀀊􀀔􀀇􀀏􀀐􀀃 􀀐􀀉􀀎􀀃 􀀋􀀇􀀑􀀎􀀃 􀀐􀀉􀀎􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀃 􀀜􀀑􀀊􀀋􀀗􀀃 􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀈􀀑􀀊􀀓􀀎􀀘
􀀆􀀒􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃􀀚􀀆􀀑􀀆􀀒􀀕􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀐􀀉􀀊􀀐
􀀐􀀉􀀎􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀖􀀇􀀃 􀀆􀀒􀀍􀀋􀀎􀀘􀀆􀀔􀀑􀀎􀀃 􀀊􀀖􀀃 􀀐􀀇􀀃 􀀔􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀚􀀊􀀑􀀖􀀎􀀟
􀀶􀀉􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀆􀀊􀀑􀀃 􀀚􀀊􀀑􀀖􀀎􀀉􀀇􀀇􀀘􀀖􀀃 􀁊􀀏􀀊􀀑􀀆􀀚􀀓􀀃 􀀊􀀖􀀃 􀀐􀀉􀀎􀀃 􀀗􀀆􀀒􀀘
􀀇􀀚􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀐􀀉􀀊􀀐􀀃 􀀍􀀊􀀒􀀣􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀖􀀎􀀃 􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀣􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀃 􀀊
􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀟􀀃􀀶􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀊􀀑􀀖􀀇􀀃􀀚􀀇􀀏􀀒􀀘􀀣􀀃􀀝􀀆􀀐􀀉
􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀐􀀆􀀊􀀋􀀓􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀚􀀊􀀑􀀖􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀣􀀃 􀀆􀀒
􀀔􀀇􀀐􀀉􀀃􀀋􀀎􀀖􀀈􀀎􀀍􀀐􀀖􀀣􀀃􀀔􀀇􀀋􀀎􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀃􀀖􀀐􀀇􀀋􀀓􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨
􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀝􀀊􀀖􀀃􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀎
􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀊􀀒􀀘􀀃 􀀉􀀎􀀒􀀍􀀎􀀃 􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀑􀀓􀀃 􀀊􀀒􀀘􀀃 􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀆􀀑􀀓􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃 􀀐􀀇
􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀄􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀋􀀎􀀑􀀆􀀎􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀖􀀎􀀎􀀗􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖
􀀍􀀊􀀖􀀎􀀟
􀀪
􀁀􀀒􀀃 􀀲􀀬􀀪􀀨􀀣􀀃 􀀘􀀏􀀋􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀍􀀇􀀞􀀎􀀋􀀓􀀃 􀀈􀀉􀀊􀀖􀀎􀀃 􀀇􀀚􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀀣􀀃 􀀼􀀎􀀋􀀍􀀗
􀀘􀀎􀀖􀀆􀀕􀀒􀀊􀀐􀀎􀀘􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀊􀀖􀀃 􀀆􀀐􀀖􀀃 􀀍􀀇􀀋􀀈􀀇􀀋􀀊􀀐􀀎􀀃 􀀝􀀆􀀐􀀒􀀎􀀖􀀖􀀃 􀀏􀀒􀀘􀀎􀀋􀀃 􀀰􀀎􀀘􀀟
􀀷􀀟􀀃 􀀜􀀆􀀞􀀟􀀃 􀀠􀀟􀀃 􀀫􀀬􀁁􀀔􀁂􀁁􀀳􀁂􀀃 􀀇􀀒􀀃 􀀍􀀎􀀋􀀐􀀊􀀆􀀒􀀃 􀀆􀀖􀀖􀀏􀀎􀀖􀀣􀀃 􀀎􀀞􀀎􀀒􀀃 􀀐􀀉􀀇􀀏􀀕􀀉􀀃 􀀉􀀎􀀃 􀀉􀀊􀀘
􀀋􀀎􀀐􀀆􀀋􀀎􀀘􀀃􀀚􀀋􀀇􀀌􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀆􀀒􀀃􀀲􀀬􀀪􀀬􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐
􀁌􀀪􀀲􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀫􀀨􀀃 􀁁􀀪􀀨􀁋􀀪􀀳􀁂􀀣􀀃 􀀲􀀲􀀫􀀮􀀮􀀃 􀁁􀀪􀁃􀀪􀁋􀁃􀀭􀁂􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀲􀀪􀀭􀀟􀀃 􀁀􀀒
􀀈􀀊􀀋􀀐􀀆􀀍􀀏􀀑􀀊􀀋􀀣􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀘􀀎􀀖􀀆􀀕􀀒􀀊􀀐􀀎􀀘􀀃􀀉􀀆􀀌􀀃􀀐􀀇􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀋􀀈􀀇􀀋􀀊􀀐􀀆􀀇􀀒
􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎
􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀪􀀲􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀲􀀪􀀭􀁋
􀀪􀀳􀀃 􀁁􀁓􀁓􀀃 􀀪􀀨􀁋􀀲􀀪􀁂􀀟􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀝􀀊􀀖􀀃 􀀒􀀇􀀐􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎
􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀮􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣
􀀆􀀊􀀎􀀃􀁁􀁓􀁓􀀃􀀲􀀬􀁋􀀲􀀪􀁂􀀣􀀃􀀐􀀉􀀇􀀏􀀕􀀉􀀃􀀉􀀎􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀟
􀀽􀀒􀀃 􀀼􀀊􀀓􀀃 􀁃􀀣􀀃 􀀲􀀬􀀪􀀨􀀣􀀃 􀀿􀀆􀀑􀀎􀀊􀀘􀀃 􀀘􀀎􀀈􀀇􀀖􀀎􀀘􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀆􀀒􀀃 􀀔􀀇􀀐􀀉􀀃 􀀉􀀆􀀖
􀀈􀀎􀀋􀀖􀀇􀀒􀀊􀀑􀀃 􀀊􀀒􀀘􀀃 􀀉􀀆􀀖􀀃 􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎􀀃 􀀍􀀊􀀈􀀊􀀍􀀆􀀐􀀆􀀎􀀖􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀫􀀪􀁋􀁃􀀫􀀟
􀀧􀀎􀀊􀀋􀀃 􀀐􀀉􀀎􀀃 􀀎􀀒􀀘􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀖􀀐􀀊􀀐􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀆􀀖
􀀊􀀒􀀖􀀝􀀎􀀋􀀖􀀃􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀒􀀇􀀐􀀃􀀘􀀆􀀚􀀚􀀎􀀋􀀃􀀊􀀍􀀍􀀇􀀋􀀘􀀆􀀒􀀕
􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀈􀀊􀀍􀀆􀀐􀀓􀀃􀀆􀀒􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀐􀀎􀀖􀀐􀀆􀀚􀀓􀀆􀀒􀀕􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀮􀀮􀀃􀁁􀀪􀁃􀀫􀁋
􀁃􀀭􀁂􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀍􀀇􀀏􀀒􀀖􀀎􀀑􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀎􀀘􀀃􀀔􀀇􀀐􀀉􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀊􀀒􀀘􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀟􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃 􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀪􀀲􀀺􀀃 􀀱􀀟􀀡􀀟
􀀲􀀲􀀫􀀫􀀫􀀃 􀁁􀀮􀁂􀀟􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀚􀀆􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀣􀀃 􀀆􀀒􀀃 􀀈􀀋􀀎􀀈􀀊􀀋􀀊􀀐􀀆􀀇􀀒􀀃 􀀚􀀇􀀋􀀃 􀀉􀀆􀀖
􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃 􀀉􀀎􀀃 􀀌􀀎􀀐􀀃 􀀝􀀆􀀐􀀉􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀇􀀏􀀐􀀖􀀆􀀘􀀎􀀃 􀀍􀀇􀀏􀀒􀀖􀀎􀀑􀀃 􀀚􀀇􀀋􀀃 􀀖􀀆􀁈􀀃 􀀐􀀇
􀀖􀀎􀀞􀀎􀀒􀀃 􀀉􀀇􀀏􀀋􀀖􀀃 􀀇􀀒􀀃 􀀎􀀊􀀍􀀉􀀃 􀀇􀀚􀀃 􀀐􀀝􀀇􀀃 􀀘􀀊􀀓􀀖􀀃 􀀊􀀒􀀘􀀃 􀀖􀀈􀀎􀀒􀀐􀀃 􀀎􀀆􀀕􀀉􀀐􀀃 􀀐􀀇􀀃 􀀐􀀎􀀒
􀀊􀀘􀀘􀀆􀀐􀀆􀀇􀀒􀀊􀀑􀀃􀀉􀀇􀀏􀀋􀀖􀀃􀀇􀀒􀀃􀀉􀀆􀀖􀀃􀀇􀀝􀀒􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐
􀁌􀀪􀀲􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀫􀀭􀀃􀁁􀀪􀀬􀁋􀀪􀀪􀁂􀀟
􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀕􀀊􀀞􀀎􀀃 􀀐􀀝􀀇􀀃 􀀘􀀆􀀚􀀚􀀎􀀋􀀎􀀒􀀐􀀃 􀀊􀀒􀀖􀀝􀀎􀀋􀀖􀀃 􀀊􀀔􀀇􀀏􀀐􀀃 􀀝􀀉􀀎􀀐􀀉􀀎􀀋􀀃 􀀉􀀎
􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀘􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀀣􀀃 􀀲􀀬􀀬􀀭􀀃 􀀍􀀊􀀑􀀑􀀃 􀀝􀀆􀀐􀀉􀀃 􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀟
􀀧􀀎􀀊􀀋􀀃􀀐􀀉􀀎􀀃􀀖􀀐􀀊􀀋􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀫􀀳􀀃􀁁􀀪􀀵􀁂􀀣􀀃􀀊􀀒􀀘􀀃􀀐􀀇􀀝􀀊􀀋􀀘
􀀐􀀉􀀎􀀃 􀀎􀀒􀀘􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃 􀀱􀀟􀀡􀀟􀀃 􀀕􀀖􀀗􀀡􀀢 􀀃 􀀲􀀲􀀫􀀮􀀭􀁋􀀮􀀨􀀃 􀁁􀀪􀀮􀀲􀁋
􀀮􀀫􀁂􀀣􀀃 􀀉􀀎􀀃 􀀋􀀎􀀈􀀎􀀊􀀐􀀎􀀘􀀑􀀓􀀃 􀀖􀀊􀀆􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀎􀀃 􀀘􀀆􀀘􀀃 􀀒􀀇􀀐􀀃 􀀋􀀎􀀍􀀊􀀑􀀑􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀒􀀕􀀟
􀀅􀀏􀀐􀀃 􀀘􀀏􀀋􀀆􀀒􀀕􀀃 􀀊􀀃 􀀈􀀇􀀋􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀒􀀇􀀐􀀃 􀀑􀀇􀀒􀀕􀀃 􀀊􀀚􀀐􀀎􀀋􀀃 􀀆􀀐
􀀖􀀐􀀊􀀋􀀐􀀎􀀘􀀃􀁁􀀍􀀇􀀋􀀋􀀎􀀖􀀈􀀇􀀒􀀘􀀆􀀒􀀕􀀃􀀐􀀇􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀒􀀆􀀒􀀎􀀃􀀈􀀊􀀕􀀎􀀖􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀐􀀋􀀊􀀒􀀖􀀍􀀋􀀆􀀈􀀐􀁂􀀣
􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀋􀀎􀀈􀀎􀀊􀀐􀀎􀀘􀀑􀀓􀀃 􀀖􀀐􀀊􀀐􀀎􀀘􀀣􀀃 􀀘􀀎􀀚􀀆􀀒􀀆􀀐􀀆􀀞􀀎􀀑􀀓􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀎􀀃 􀀘􀀆􀀘􀀃 􀀒􀀇􀀐
􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀫􀀵􀁋􀀭􀀪􀀃 􀁁􀀫􀀬􀁋􀀫􀁃􀁂􀀺􀀃 􀀍􀀈􀀈􀀣􀀃 􀀈􀀎􀀙􀀎􀀣􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀫􀀵
􀁁􀀫􀀪􀁂􀀃􀁁􀁆􀀖􀀏􀀋􀀎􀁇􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀒􀀇􀀐􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘􀀃􀀆􀀒􀀃􀀊􀀒􀀓􀀃􀀘􀀆􀀖􀀍􀀏􀀖􀀖􀀆􀀇􀀒􀀃􀀝􀀆􀀐􀀉
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀆􀀒􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀝􀀉􀀎􀀋􀀎􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀐􀀇􀀑􀀘􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀢􀀖
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀁂􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀭􀀪􀀃 􀁁􀀫􀀮􀁂􀀃 􀁁􀁆􀁀􀀃 􀀒􀀎􀀞􀀎􀀋􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀘􀀃 􀀆􀀒􀀃 􀀊􀀃 􀀘􀀏􀀎
􀀘􀀆􀀑􀀆􀀕􀀎􀀒􀀍􀀎􀀃 􀀌􀀎􀀎􀀐􀀆􀀒􀀕􀀃 􀀇􀀒􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀀃 􀀟􀀟􀀟􀀟􀀃 􀁀􀀃 􀀘􀀆􀀘􀀃 􀀒􀀇􀀐􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀎􀀃 􀀆􀀒
􀀊􀀒􀀓􀀃 􀀌􀀎􀀎􀀐􀀆􀀒􀀕􀀃 􀀇􀀚􀀃 􀀘􀀏􀀎􀀃 􀀘􀀆􀀑􀀆􀀕􀀎􀀒􀀍􀀎􀀃 􀀇􀀒􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀁇􀁂􀀟􀀃 􀀽􀀒􀀎􀀃 􀀋􀀎􀀊􀀖􀀇􀀒
􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀖􀀇􀀃􀀖􀀏􀀋􀀎􀀣􀀃􀀉􀀎􀀃􀀖􀀊􀀆􀀘􀀣􀀃􀀝􀀊􀀖􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀉􀀊􀀞􀀎􀀃􀀞􀀆􀀇􀀑􀀊􀀐􀀎􀀘
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀅􀀑
􀀼􀀎􀀋􀀍􀀗􀀃􀀈􀀇􀀑􀀆􀀍􀀓􀀃􀀐􀀇􀀃􀀊􀀑􀀑􀀇􀀝􀀃􀀉􀀆􀀖􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀐􀀇􀀃􀀗􀀎􀀎􀀈􀀃􀀉􀀆􀀌􀀃􀀇􀀒
􀀐􀀉􀀎􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀖􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀲􀀫􀀭􀀪􀀃􀁁􀀫􀁃􀁋􀀫􀀵􀁂􀀣􀀃􀀲􀀲􀀫􀀮􀀫􀁋
􀀮􀀭􀀃􀁁􀀪􀀳􀁃􀁋􀀮􀀲􀁂􀀺􀀃􀀲􀀲􀀫􀁃􀀲􀀃􀁁􀀲􀀬􀀲􀁂􀀟􀀃􀀽􀀒􀀃􀀐􀀉􀀎􀀃􀀔􀀊􀀖􀀆􀀖􀀃􀀇􀀚􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀘􀀎􀀚􀀆􀀒􀀆􀀐􀀆􀀞􀀎
􀀘􀀎􀀒􀀆􀀊􀀑􀀖􀀣􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀁆􀁔􀀝􀁕􀀉􀀎􀀒􀀃􀀊􀀖􀀗􀀎􀀘􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀐􀀉􀀎
􀀼􀀊􀀋􀀍􀀉􀀃 􀀪􀀮􀀣􀀃 􀀲􀀬􀀬􀀭􀀣􀀃 􀀍􀀊􀀑􀀑􀀃 􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀘􀀎􀀒􀀆􀀎􀀘
􀀎􀀞􀀎􀀋􀀃􀀉􀀊􀀞􀀆􀀒􀀕􀀃􀀔􀀎􀀎􀀒􀀃􀀇􀀒􀀃􀀖􀀏􀀍􀀉􀀃􀀊􀀃􀀍􀀊􀀑􀀑􀀟􀀃􀀴􀀉􀀎􀀒􀀃􀀊􀀖􀀗􀀎􀀘􀀃􀀝􀀉􀀎􀀐􀀉􀀎􀀋􀀃􀀉􀀎􀀃􀀝􀀊􀀖
􀀖􀀏􀀋􀀎􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀒􀀇􀀐􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀪􀀮􀀣􀀃􀀲􀀬􀀬􀀭􀀣􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀏􀀒􀀎􀁊􀀏􀀆􀀞􀀇􀀍􀀊􀀑􀀑􀀓􀀃􀀊􀀒􀀖􀀝􀀎􀀋􀀎􀀘􀀃􀀓􀀎􀀖􀀟􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐
􀁌􀀪􀀲􀀟
􀀶􀀉􀀊􀀐􀀃 􀀘􀀎􀀒􀀆􀀊􀀑􀀃 􀀇􀀚􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒􀀃 􀀝􀀊􀀖􀀃 􀀚􀀊􀀑􀀖􀀎􀀣􀀃 􀀊􀀖􀀃 􀀍􀀊􀀌􀀎􀀃 􀀐􀀇􀀃 􀀔􀀎
􀀏􀀒􀀘􀀆􀀖􀀈􀀏􀀐􀀎􀀘􀀃􀀔􀀓􀀃􀀼􀀎􀀋􀀍􀀗􀀣􀀃􀀊􀀒􀀘􀀃􀀊􀀍􀀗􀀒􀀇􀀝􀀑􀀎􀀘􀀕􀀎􀀘􀀃􀀔􀀓􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀣􀀃􀀊􀀐
􀀐􀀋􀀆􀀊􀀑􀀟􀀃 􀀋􀀈􀀈􀀃 􀀆􀀊􀀎􀀃 􀀊􀀐􀀃 􀁌􀀪􀀭􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀵􀀫􀀮􀁋􀀫􀁃􀀃 􀁁􀀫􀀭􀀭􀁋􀀭􀀮􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐
􀀍􀀇􀀏􀀋􀀐􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀚􀀊􀀑􀀖􀀆􀀐􀀓􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀘􀀎􀀒􀀆􀀊􀀑􀀃􀀇􀀚􀀃􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒
􀀐􀀇􀀃 􀀔􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀟􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃 􀀲􀀬􀀪􀀳􀀃 􀀴􀀯􀀃 􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀲􀀵􀁋􀀫􀀪􀀟
􀀴􀀎􀀃 􀀍􀀊􀀒􀀒􀀇􀀐􀀃 􀀘􀀎􀀎􀀌􀀃 􀀐􀀉􀀊􀀐􀀃 􀀖􀀐􀀊􀀐􀀎􀀄􀀇􀀚􀀄􀀌􀀆􀀒􀀘􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃 􀀐􀀇􀀃 􀀔􀀎􀀃 􀀍􀀑􀀎􀀊􀀋􀀑􀀓
􀀎􀀋􀀋􀀇􀀒􀀎􀀇􀀏􀀖􀀣􀀃 􀀕􀀆􀀞􀀎􀀒􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃 􀀘􀀆􀀋􀀎􀀍􀀐􀀃 􀀇􀀔􀀖􀀎􀀋􀀞􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚
􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀐􀀋􀀆􀀊􀀑􀀺􀀃 􀀐􀀉􀀎􀀃 􀀘􀀇􀀍􀀏􀀌􀀎􀀒􀀐􀀊􀀋􀀓􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀃 􀀇􀀚􀀃 􀀉􀀆􀀖
􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒􀀣􀀃 􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃 􀀈􀀋􀀎􀀄􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀇􀀒􀀃 􀀎􀀌􀀊􀀆􀀑􀀖􀀃 􀁁􀀖􀀇􀀌􀀎􀀃 􀀐􀀉􀀊􀀐
􀀉􀀎􀀃 􀀋􀀎􀀞􀀆􀀎􀀝􀀎􀀘􀀃 􀀘􀀏􀀋􀀆􀀒􀀕􀀃 􀀉􀀆􀀖􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀁂􀀺􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀎􀀃 􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀑􀀓
􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀎􀀘􀀃 􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀊􀀖􀀈􀀎􀀍􀀐􀀖􀀃 􀀇􀀚􀀃 􀀉􀀆􀀖􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃 􀀝􀀎􀀋􀀎
􀁆􀀆􀀒􀀍􀀇􀀒􀀖􀀆􀀖􀀐􀀎􀀒􀀐􀀣􀀃􀀍􀀇􀀒􀀐􀀋􀀊􀀘􀀆􀀍􀀐􀀇􀀋􀀓􀀣􀀃􀀊􀀒􀀘􀀃􀀏􀀒􀀐􀀋􀀏􀀐􀀉􀀚􀀏􀀑􀀟􀁇􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀲􀀵􀀺􀀃􀀍􀀈􀀈
􀀆􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀪􀀲􀁋􀀪􀀳􀀟
􀀷􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀋􀀇􀀑􀀎􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀱􀀊􀀒􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨􀀃 􀀜􀀑􀀊􀀋􀀗􀀃 􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀆􀀒􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃 􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀚􀀆􀀑􀀎􀀃 􀀒􀀎􀀝􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀆􀀒􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓
􀀲􀀬􀀬􀀨􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀋􀀇􀀑􀀎􀀃 􀀆􀀒􀀃 􀀝􀀊􀀓􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀀆􀀒􀀍􀀋􀀎􀀘􀀆􀀔􀀑􀀎􀀟􀀃􀀼􀀇􀀖􀀐􀀃􀀖􀀐􀀊􀀋􀀗􀀑􀀓􀀣􀀃􀀊􀀐􀀃􀀉􀀆􀀖
􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃􀀉􀀎􀀃􀀖􀀐􀀊􀀐􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀖􀀆􀀌􀀈􀀑􀀓􀀃􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀋􀀎􀀍􀀊􀀑􀀑􀀃􀀝􀀉􀀎􀀐􀀉􀀎􀀋􀀃􀀉􀀎
􀀖􀀊􀀝􀀃 􀀐􀀉􀀎􀀃 􀀜􀀑􀀊􀀋􀀗􀀃 􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀔􀀎􀀚􀀇􀀋􀀎􀀃 􀀚􀀆􀀑􀀆􀀒􀀕􀀃 􀀐􀀉􀀎􀀃 􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃 􀀲􀀬􀀬􀀨
􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃 􀀊􀀒􀀘􀀃 􀀉􀀎􀀒􀀍􀀎􀀃 􀀍􀀇􀀏􀀑􀀘􀀃 􀀒􀀇􀀐􀀃 􀀖􀀐􀀊􀀐􀀎􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀐􀀃 􀀈􀀑􀀊􀀓􀀎􀀘􀀃 􀀊􀀃 􀀋􀀇􀀑􀀎
􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀟􀀃 􀀋􀀈􀀈􀀃 􀀆􀀊􀀎􀀃 􀀊􀀐􀀃 􀁌􀀪􀀳􀀺􀀃 􀀱􀀟􀀡􀀟􀀃 􀀲􀀲􀀫􀀭􀀫􀁋􀀭􀀭􀀃 􀁁􀀭􀁃􀁋􀀨􀀲􀁂􀀣
􀀲􀀲􀀫􀀭􀁃􀁋􀀭􀀵􀀃􀁁􀀳􀀳􀁋􀀳􀀵􀁂􀀟
􀀅􀀎􀀚􀀇􀀋􀀎􀀃 􀀐􀀋􀀆􀀊􀀑􀀣􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀘􀀎􀀒􀀆􀀎􀀘􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀌􀀇􀀐􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀎􀁈􀀍􀀑􀀏􀀘􀀎
􀀊􀀑􀀑􀀃 􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀃 􀀈􀀇􀀖􀀐􀀄􀀘􀀊􀀐􀀆􀀒􀀕􀀃 􀀲􀀬􀀬􀀲􀀃 􀀚􀀋􀀇􀀌􀀃 􀀐􀀉􀀎􀀃 􀀙􀀏􀀋􀀓􀀃 􀀐􀀋􀀆􀀊􀀑􀀃 􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕
􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀁄􀀊􀀃 􀀘􀀎􀀒􀀆􀀊􀀑􀀃 􀀒􀀇􀀐􀀃 􀀖􀀎􀀈􀀊􀀋􀀊􀀐􀀎􀀑􀀓􀀃 􀀍􀀉􀀊􀀑􀀑􀀎􀀒􀀕􀀎􀀘􀀃 􀀊􀀖􀀃 􀀆􀀒􀀍􀀇􀀋􀀋􀀎􀀍􀀐
􀀉􀀎􀀋􀀎􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀲􀀲􀀬􀁋􀀲􀀲􀀃 􀁁􀀘􀀎􀀒􀀓􀀆􀀒􀀕􀀃 􀀎􀁈􀀍􀀑􀀏􀀖􀀆􀀇􀀒􀀃 􀀔􀀎􀀍􀀊􀀏􀀖􀀎􀀃 􀀐􀀉􀀎
􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃 􀀝􀀊􀀖􀀃 􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀃 􀀐􀀇􀀃 􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃 􀀆􀀖􀀖􀀏􀀎􀀖􀁂􀀟􀀃 􀀽􀀒􀀍􀀎􀀃 􀀐􀀉􀀊􀀐
􀀌􀀇􀀐􀀆􀀇􀀒􀀃􀀝􀀊􀀖􀀃􀀘􀀎􀀒􀀆􀀎􀀘􀀣􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀆􀀐􀀖􀀎􀀑􀀚􀀃􀀆􀀒􀀘􀀆􀀍􀀊􀀐􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀍􀀊􀀑􀀑
􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀊􀀖􀀃􀀊􀀃􀀝􀀆􀀐􀀒􀀎􀀖􀀖􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀭􀀬􀀭􀀃􀁁􀀭􀀲􀁂􀀃􀁁􀀼􀀎􀀋􀀍􀀗􀀃􀀎􀁈􀀈􀀑􀀊􀀆􀀒􀀆􀀒􀀕
􀀐􀀉􀀊􀀐􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀆􀀖􀀃 􀁆􀀈􀀑􀀊􀀒􀀒􀀆􀀒􀀕􀀃 􀀐􀀇􀀃 􀀍􀀇􀀌􀀎􀀃 􀀊􀀒􀀘􀀃 􀀐􀀎􀀖􀀐􀀆􀀚􀀓􀀃 􀀆􀀒􀀃 􀀇􀀏􀀋
􀀍􀀊􀀖􀀎􀁇􀁂􀀟􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀃􀀐􀀉􀀎􀀒􀀃􀀐􀀇􀀇􀀗􀀃􀀐􀀉􀀎􀀃􀀇􀀈􀀈􀀇􀀋􀀐􀀏􀀒􀀆􀀐􀀓􀀃􀀐􀀇􀀃􀀍􀀊􀀑􀀑􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀚􀀆􀀋􀀖􀀐􀀣􀀃􀀍􀀋􀀇􀀖􀀖􀀄􀀎􀁈􀀊􀀌􀀆􀀒􀀆􀀒􀀕􀀃􀀉􀀆􀀌􀀃􀀔􀀎􀀚􀀇􀀋􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀎􀀘􀀃􀀆􀀐􀀖􀀃􀀘􀀆􀀋􀀎􀀍􀀐
􀀎􀁈􀀊􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀃􀀋􀀎􀀕􀀊􀀋􀀘􀀆􀀒􀀕􀀃􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀃􀀇􀀚
􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀟
􀁀􀀒􀀃􀀉􀀆􀀖􀀃􀀐􀀋􀀆􀀊􀀑􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀎􀀘􀀃􀀐􀀇􀀃􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀃􀀐􀀉􀀎
􀀋􀀇􀀑􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀐􀀉􀀇􀀏􀀕􀀉􀀃􀀐􀀇􀀃􀀊􀀃􀀑􀀎􀀖􀀖􀀎􀀋􀀃􀀎􀁈􀀐􀀎􀀒􀀐􀀃􀀐􀀉􀀊􀀒
􀀘􀀏􀀋􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀟􀀃􀀋􀀈􀀈􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀪􀀳􀀟
􀀹􀁈􀀈􀀑􀀊􀀆􀀒􀀆􀀒􀀕􀀃􀀉􀀆􀀖􀀃􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀃􀀐􀀇􀀃􀀚􀀆􀀑􀀎􀀃􀀐􀀉􀀎􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣􀀃􀀉􀀎􀀃􀀖􀀐􀀋􀀎􀀖􀀖􀀎􀀘􀀃􀀐􀀉􀀊􀀐
􀀉􀀎􀀃􀀒􀀊􀀋􀀋􀀇􀀝􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀇􀀃􀁆􀀎􀁈􀀈􀀎􀀘􀀆􀀐􀀎􀁇􀀃􀀎􀁈􀀊􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀆􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀪􀀮􀀺
􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀵􀀭􀀭􀁋􀀭􀀨􀀃􀁁􀀫􀀮􀀪􀁋􀀮􀀨􀁂􀀣􀀃􀀊􀀒􀀘􀀃􀀖􀀊􀀆􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀁆􀀉􀀎􀀃􀀊􀀌􀀎􀀒􀀘􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵
􀀍􀀑􀀊􀀆􀀌􀀖􀀃􀀐􀀇􀀃􀀚􀀇􀀍􀀏􀀖􀀃􀀇􀀒􀀃􀁖􀀕􀀎􀀐􀁔􀀐􀀆􀀒􀀕􀁕􀀃􀀊􀀑􀀑􀀇􀀝􀀊􀀒􀀍􀀎􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀖􀀏􀀔􀀙􀀎􀀍􀀐􀀃􀀌􀀊􀀐􀀐􀀎􀀋
􀀐􀀉􀀊􀀐􀀃 􀀝􀀊􀀖􀀃 􀀌􀀇􀀖􀀐􀀃 􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀐􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀁔􀀼􀀎􀀋􀀍􀀗􀀄􀁀􀀖􀀆􀀖􀁕􀀃 􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀇􀀒􀀣􀁗
􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀪􀀮􀀺􀀃􀀱􀀟􀀡􀀟􀀃􀀪􀀵􀀵􀀨􀀲􀀃􀁁􀀭􀀬􀀭􀁂􀀟􀀃􀀛􀀎
􀀊􀀑􀀖􀀇􀀃 􀀐􀀎􀀖􀀐􀀆􀀚􀀆􀀎􀀘􀀣􀀃 􀀉􀀇􀀝􀀎􀀞􀀎􀀋􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀎􀀃 􀀉􀀊􀀘􀀃 􀁆􀀔􀀎􀀍􀁔􀀇􀁕􀀌􀀎􀀃 􀀍􀀇􀀒􀀞􀀆􀀒􀀍􀀎􀀘
􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀝􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀈􀀏􀀔􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀁔􀀜􀀑􀀊􀀋􀀗􀁕􀀃􀁔􀀡􀁕􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐
􀀑􀀎􀀘􀀃 􀁔􀀉􀀆􀀌􀁕􀀃 􀀐􀀇􀀃 􀀋􀀎􀀎􀁈􀀊􀀌􀀆􀀒􀀎􀁇􀀃 􀀐􀀉􀀎􀀃 􀀕􀀖􀀗􀀡􀀣 􀀃 􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎
􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀔􀀎􀀍􀀊􀀌􀀎􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀃􀀚􀀆􀀑􀀎􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓
􀀲􀀬􀀬􀀨􀀃 􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀟􀀃 􀀱􀀟􀀡􀀟􀀃 􀀪􀀵􀀵􀀭􀀵􀀃 􀁁􀀫􀀵􀀬􀁋􀀵􀀪􀁂􀀺􀀃 􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃 􀀲􀀬􀀪􀀳􀀃 􀀴􀀯
􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃 􀀊􀀐􀀃 􀁌􀀪􀀳􀀟􀀃 􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀍􀀇􀀏􀀑􀀘􀀃 􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓􀀃 􀀚􀀆􀀒􀀘
􀀐􀀉􀀊􀀐􀀣􀀃 􀀔􀀓􀀃 􀀖􀀐􀀊􀀐􀀆􀀒􀀕􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀐􀀃 􀀝􀀊􀀖􀀃 􀀖􀀏􀀋􀀋􀀇􀀏􀀒􀀘􀀆􀀒􀀕􀀃 􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀃 􀀐􀀉􀀊􀀐
􀀖􀀇􀀃 􀀍􀀇􀀒􀀞􀀆􀀒􀀍􀀎􀀘􀀃 􀀉􀀆􀀌􀀣􀀃 􀀒􀀇􀀐􀀃 􀀉􀀆􀀖􀀃 􀀇􀀝􀀒􀀃 􀀋􀀎􀀍􀀇􀀑􀀑􀀎􀀍􀀐􀀆􀀇􀀒􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀝􀀊􀀖􀀃 􀀍􀀇􀀒􀀐􀀆􀀒􀀏􀀆􀀒􀀕􀀃 􀀐􀀇􀀃 􀀌􀀆􀀒􀀆􀀌􀀆􀀻􀀎􀀃 􀀐􀀉􀀎􀀃 􀀊􀀍􀀐􀀏􀀊􀀑􀀃 􀀋􀀇􀀑􀀎􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀜􀀑􀀊􀀋􀀗
􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀝􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀆􀀎􀀈􀀎􀀣
􀀐􀀉􀀎􀀃􀀋􀀇􀀑􀀎􀀃􀀇􀀚􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀝􀀇􀀋􀀗􀀣􀀃􀀆􀀒􀀃􀀉􀀆􀀖􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀃􀀚􀀇􀀋
􀀼􀀎􀀋􀀍􀀗􀀟􀀃􀀡􀀖􀀃􀀊􀀑􀀋􀀎􀀊􀀘􀀓􀀃􀀒􀀇􀀐􀀎􀀘􀀃􀀊􀀔􀀇􀀞􀀎􀀣􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓􀀃􀀚􀀇􀀏􀀒􀀘
􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀉􀀊􀀘􀀃􀀆􀀒􀀃􀀌􀀆􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀚􀀇􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃􀀉􀀎􀀃􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉
􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀝􀀊􀀖􀀃􀀝􀀊􀀆􀀐􀀆􀀒􀀕􀀃􀀚􀀇􀀋􀀃􀀈􀀏􀀔􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀢􀀖
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃􀀐􀀇􀀃􀀊􀀞􀀇􀀆􀀘􀀃􀀞􀀆􀀇􀀑􀀊􀀐􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀒􀀇􀀒􀀄􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀏􀀋􀀎􀀃􀀊􀀕􀀋􀀎􀀎􀀌􀀎􀀒􀀐􀀣􀀃􀀊􀀒􀀘
􀀐􀀉􀀊􀀐􀀃􀀉􀀎􀀃􀀚􀀆􀀑􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀇􀀒􀀍􀀎􀀃􀀈􀀏􀀔􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀍􀀍􀀏􀀋􀀋􀀎􀀘􀀟􀀃􀁀􀀒􀀃􀀑􀀆􀀕􀀉􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀣􀀃􀀆􀀐
􀀝􀀊􀀖􀀃􀀊􀀑􀀖􀀇􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀎􀀃􀀚􀀇􀀋􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀐􀀇􀀃􀀚􀀆􀀒􀀘􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖
􀀐􀀋􀀆􀀊􀀑􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃 􀀊􀀃 􀀌􀀆􀀖􀀑􀀎􀀊􀀘􀀆􀀒􀀕􀀃 􀀎􀀚􀀚􀀇􀀋􀀐􀀃 􀀐􀀇􀀃 􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀃 􀀐􀀉􀀎􀀃 􀀋􀀇􀀑􀀎􀀃 􀀇􀀚
􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀝􀀇􀀋􀀗􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀟
􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀁆􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃 􀀍􀀉􀀊􀀒􀀕􀀆􀀒􀀕􀀃 􀀊􀀒􀀘
􀀎􀀞􀀊􀀖􀀆􀀞􀀎􀀃 􀀎􀁈􀀈􀀑􀀊􀀒􀀊􀀐􀀆􀀇􀀒􀀖􀀃 􀀚􀀇􀀋􀀃 􀀝􀀉􀀓􀀃 􀀉􀀎􀀃 􀀒􀀊􀀋􀀋􀀇􀀝􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀍􀀑􀀊􀀆􀀌􀀖
􀀏􀀒􀀘􀀎􀀋􀀌􀀆􀀒􀀎􀀃􀀉􀀆􀀖􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀁇􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀁆􀀉􀀆􀀖􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀁔􀀝􀀊􀀖􀁕􀀃􀀒􀀇􀀐
􀀍􀀋􀀎􀀘􀀆􀀔􀀑􀀎􀀟􀁇􀀃 􀀐􀀊􀀎􀀃 􀀊􀀐􀀃 􀁌􀀪􀀮􀀟􀀃 􀁀􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓
􀀐􀀉􀀊􀀐􀀃 􀁆􀀉􀀎􀀃 􀀊􀀌􀀎􀀒􀀘􀀎􀀘􀀃 􀀐􀀉􀀎􀀃 􀀢􀀭􀀵􀀵􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀐􀀇􀀃 􀀚􀀇􀀍􀀏􀀖􀀃 􀀇􀀒􀀃 􀁖􀀕􀀎􀀐􀁔􀀐􀀆􀀒􀀕􀁕
􀀊􀀑􀀑􀀇􀀝􀀊􀀒􀀍􀀎􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀖􀀏􀀔􀀙􀀎􀀍􀀐􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀃􀀐􀀉􀀊􀀐􀀃􀀝􀀊􀀖􀀃􀀌􀀇􀀖􀀐􀀃􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀐􀀃􀀐􀀇
􀀐􀀉􀀎􀀃􀁔􀀼􀀎􀀋􀀍􀀗􀀄􀁀􀀖􀀆􀀖􀁕􀀃􀀍􀀇􀀑􀀑􀀊􀀔􀀇􀀋􀀊􀀐􀀆􀀇􀀒􀁗􀀃􀀆􀀖􀀃􀀍􀀇􀀒􀀐􀀋􀀊􀀋􀀓􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀎􀀞􀀆􀀘􀀎􀀒􀀍􀀎􀀃􀀊􀀒􀀘
􀀆􀀖􀀃􀀒􀀇􀀐􀀃􀀍􀀋􀀎􀀘􀀆􀀔􀀑􀀎􀀃􀀔􀀎􀀍􀀊􀀏􀀖􀀎􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀒􀀎􀀞􀀎􀀋􀀃􀀐􀀎􀀖􀀐􀀎􀀘􀀃􀀊􀀒􀀓􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀎􀀘
􀀍􀀇􀀌􀀈􀀇􀀏􀀒􀀘􀀖􀁇􀀃􀀏􀀒􀀐􀀆􀀑􀀃􀀊􀀚􀀐􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀝􀀊􀀖􀀃􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀟
􀀐􀀊􀀎􀀃􀀶􀀉􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀋􀀇􀀑􀀎􀀃􀀇􀀚􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀝􀀇􀀋􀀗
􀁄􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀚􀀆􀀋􀀖􀀐􀀃􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀎􀀘􀀃􀀐􀀇􀀃􀀦􀀋􀀟
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀆􀀒􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀁄􀀐􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀁆􀀒􀀇􀀐􀀃􀀍􀀋􀀎􀀘􀀆􀀔􀀑􀀎􀁇􀀃􀀊􀀒􀀘
􀁆􀀚􀀊􀀑􀀖􀀎􀀟􀁇􀀃􀀐􀀊􀀎
􀀲
􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀈􀀋􀀇􀀈􀀎􀀋􀀑􀀓􀀃 􀀍􀀉􀀊􀀋􀀕􀀎􀀘􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀝􀀆􀀐􀀉􀀃 􀀐􀀉􀀎
􀀍􀀇􀀒􀀖􀀎􀁊􀀏􀀎􀀒􀀍􀀎􀀖􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀣􀀃􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀊􀀐􀀃􀀐􀀉􀀎
􀀐􀀋􀀆􀀊􀀑􀀣􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀇􀀃 􀀔􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀚􀀊􀀑􀀖􀀎􀀟􀀃 􀀐􀀊􀀎􀀃 􀀊􀀐
􀁌􀀲􀀵􀀃 􀁁􀁆􀁔􀀶􀁕􀀉􀀎􀀃 􀀋􀀎􀀍􀀇􀀋􀀘􀀃 􀀖􀀉􀀇􀀝􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀟􀀟􀀟􀀃 􀁔􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀁕􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀅􀀅
􀀝􀀊􀀖􀀃􀀖􀀈􀀇􀀒􀀖􀀇􀀋􀀎􀀘􀀃􀀔􀀓􀀃􀀼􀀎􀀋􀀍􀀗􀀟􀁇􀁂􀀟􀀃􀀡􀀖􀀃􀀊􀀑􀀋􀀎􀀊􀀘􀀓􀀃􀀒􀀇􀀐􀀎􀀘􀀣􀀃􀀒􀀇􀀐􀀃􀀇􀀒􀀑􀀓􀀃􀀘􀀆􀀘
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀍􀀇􀀏􀀒􀀖􀀎􀀑􀀃 􀀊􀀈􀀈􀀎􀀊􀀋􀀃 􀀊􀀖􀀃 􀀍􀀇􀀏􀀒􀀖􀀎􀀑􀀃 􀀚􀀇􀀋􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀊􀀐􀀃 􀀉􀀆􀀖
􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀣􀀃􀀊􀀒􀀘􀀃􀀈􀀋􀀎􀀈􀀊􀀋􀀎􀀃􀀉􀀆􀀌􀀃􀀚􀀇􀀋􀀃􀀆􀀐􀀣􀀃􀀔􀀏􀀐􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀝􀀊􀀖􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀇􀀚􀀚􀀆􀀍􀀆􀀊􀀑􀀃􀀍􀀇􀀋􀀈􀀇􀀋􀀊􀀐􀀎􀀃􀀋􀀎􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀊􀀐􀀆􀀞􀀎􀀃􀀇􀀒􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀖􀀃􀁁􀀐􀀉􀀎􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎
􀀢􀀭􀀵􀀵􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀁂􀀃 􀀐􀀇􀀃 􀀝􀀉􀀆􀀍􀀉􀀃 􀀐􀀉􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃 􀀊􀀐􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀝􀀊􀀖􀀃 􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀟
􀀡􀀖􀀃 􀀊􀀑􀀖􀀇􀀃 􀀊􀀑􀀋􀀎􀀊􀀘􀀓􀀃 􀀒􀀇􀀐􀀎􀀘􀀣􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀊􀀈􀀈􀀎􀀊􀀋􀀎􀀘􀀃 􀀊􀀐􀀃 􀀐􀀋􀀆􀀊􀀑􀀃 􀀊􀀚􀀐􀀎􀀋
􀀼􀀎􀀋􀀍􀀗􀀃􀀆􀀒􀀘􀀆􀀍􀀊􀀐􀀎􀀘􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀝􀀊􀀖􀀃􀀕􀀇􀀆􀀒􀀕􀀃􀀐􀀇􀀃􀀍􀀊􀀑􀀑􀀃􀀉􀀆􀀌􀀃􀀐􀀇􀀃􀀐􀀎􀀖􀀐􀀆􀀚􀀓􀀃􀀊􀀔􀀇􀀏􀀐
􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀖􀀣􀀃􀀐􀀇􀀃􀀝􀀉􀀆􀀍􀀉􀀃􀀐􀀉􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀃􀀉􀀎􀀋􀀎􀀃􀀉􀀊􀀘
􀀔􀀎􀀎􀀒􀀃􀀉􀀎􀀑􀀘􀀃􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀟
􀀶􀀉􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀣􀀃􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀃􀀐􀀇􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀊􀀖􀀎􀀃􀀊􀀒􀀘􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓
􀀚􀀇􀀏􀀒􀀘􀀃 􀀐􀀇􀀃 􀀔􀀎􀀃 􀀆􀀒􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀊􀀑􀀑􀀓􀀃 􀀚􀀊􀀑􀀖􀀎􀀣􀀃 􀀉􀀊􀀘􀀃 􀀊􀀒􀀃 􀀆􀀌􀀌􀀎􀀘􀀆􀀊􀀐􀀎􀀃 􀀊􀀒􀀘
􀀒􀀎􀀍􀀎􀀖􀀖􀀊􀀋􀀓􀀃 􀀋􀀎􀀑􀀊􀀐􀀆􀀇􀀒􀀃 􀀐􀀇􀀃 􀀐􀀉􀀎􀀃 􀀎􀁊􀀏􀀆􀀐􀀓􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀄􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐
􀀋􀀎􀀑􀀆􀀎􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀖􀀎􀀎􀀗􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀟􀀃􀀶􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀉􀀎􀀑􀀘􀀃􀀐􀀉􀀊􀀐
􀀐􀀉􀀎􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀣􀀃􀀊􀀒􀀘􀀃􀀉􀀎􀀒􀀍􀀎􀀃􀀦􀀋􀀟
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀢􀀖􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀊􀀔􀀇􀀏􀀐􀀃􀀐􀀉􀀊􀀐􀀣􀀃􀀝􀀊􀀖􀀃􀀋􀀎􀀑􀀎􀀞􀀊􀀒􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓
􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀐􀀇􀀃􀀔􀀎􀀃􀀐􀀋􀀆􀀎􀀘􀀟􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀪􀀭􀀃􀁁􀁆􀀡􀀐􀀃􀀐􀀋􀀆􀀊􀀑􀀣􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀈􀀋􀀇􀀞􀀆􀀘􀀎􀀘
􀀗􀀎􀀓􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀚􀀇􀀋􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀇􀀒􀀃􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀝􀀋􀀆􀀐􀀐􀀎􀀒
􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀢􀀭􀀵􀀵􀀃 􀀠􀀊􀀐􀀎􀀒􀀐􀀟􀁇􀁂􀀺􀀃 􀀆􀀊􀀎􀀃 􀀊􀀐􀀃 􀁌􀀫􀀲􀀃 􀁁􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀆􀀒􀀕
􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃 􀀝􀀊􀀖􀀃 􀁆􀀘􀀆􀀋􀀎􀀍􀀐􀀎􀀘􀀃 􀀊􀀐􀀃 􀀊􀀒􀀘􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀎􀀘􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖
􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀊􀀋􀀕􀀏􀀌􀀎􀀒􀀐􀀖􀀣􀀃􀀊􀀒􀀘􀀃􀀝􀀎􀀒􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀉􀀎􀀊􀀋􀀐􀀃􀀇􀀚􀀃􀀖􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀖
􀀆􀀒􀀃 􀀐􀀉􀀆􀀖􀀃 􀀍􀀊􀀖􀀎􀁇􀁂􀀟􀀃 􀀶􀀉􀀎􀀃 􀀞􀀎􀀋􀀘􀀆􀀍􀀐􀀃 􀀚􀀇􀀋􀀌􀀃 􀀌􀀊􀀘􀀎􀀃 􀀎􀁈􀀈􀀑􀀆􀀍􀀆􀀐􀀃 􀀐􀀉􀀊􀀐􀀃 􀀑􀀊􀀍􀀗􀀃 􀀇􀀚
􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃􀀊􀀒􀀘􀀃􀀑􀀊􀀍􀀗􀀃􀀇􀀚􀀃􀀎􀀒􀀊􀀔􀀑􀀎􀀌􀀎􀀒􀀐􀀃􀀝􀀎􀀋􀀎􀀃􀀐􀀆􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀎
􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃􀀇􀀚􀀃􀁆􀀘􀀎􀀋􀀆􀀞􀀊􀀐􀀆􀀇􀀒􀀃􀀚􀀋􀀇􀀌􀀃􀀱􀀎􀀋􀀎􀀌􀀓􀀃􀀜􀀑􀀊􀀋􀀗􀁇􀀃􀁁􀀐􀀉􀀎􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐
􀀆􀀒􀀞􀀎􀀒􀀐􀀇􀀋􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀁂􀁄􀀐􀀉􀀎􀀃􀀑􀀊􀀐􀀐􀀎􀀋􀀃􀀐􀀇􀀃􀀔􀀎􀀃􀀊􀀘􀀘􀀋􀀎􀀖􀀖􀀎􀀘􀀃􀀇􀀒􀀑􀀓􀀃􀀆􀀚􀀃􀀐􀀉􀀎
􀀙􀀏􀀋􀀓􀀃􀀚􀀇􀀏􀀒􀀘􀀃􀀎􀀆􀀐􀀉􀀎􀀋􀀃􀀑􀀊􀀍􀀗􀀃􀀇􀀚􀀃􀀊􀀒􀀃􀀊􀀘􀀎􀁊􀀏􀀊􀀐􀀎􀀃􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃􀀇􀀋
􀀑􀀊􀀍􀀗􀀃􀀇􀀚􀀃􀀎􀀒􀀊􀀔􀀑􀀎􀀌􀀎􀀒􀀐􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀪􀀬􀀳􀀳􀁋􀀮􀀨􀀟􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀇􀀝􀀒􀀃􀀈􀀇􀀑􀀆􀀍􀀓􀀃􀀇􀀚
􀀖􀀎􀀈􀀊􀀋􀀊􀀐􀀆􀀒􀀕􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀇􀀋􀀖􀀃􀀚􀀋􀀇􀀌􀀃􀀘􀀆􀀖􀀍􀀏􀀖􀀖􀀆􀀇􀀒􀀖􀀃􀀑􀀆􀀗􀀎􀀃􀀐􀀉􀀎􀀃􀀇􀀒􀀎􀀖
􀀉􀀎􀀑􀀘􀀃􀀝􀀆􀀐􀀉􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀃􀀆􀀖􀀃􀀍􀀇􀀒􀀚􀀆􀀋􀀌􀀊􀀐􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀼􀀎􀀋􀀍􀀗􀀃􀀋􀀎􀀍􀀇􀀕􀀒􀀆􀀻􀀎􀀘􀀣
􀀊􀀖􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀚􀀆􀀎􀀘􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀇􀀋􀀆􀀕􀀆􀀒􀀃􀀇􀀚􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀕􀀖􀀗􀀡􀀤
􀀍􀀇􀀏􀀑􀀘􀀃􀀌􀀊􀀐􀀐􀀎􀀋􀀃􀀆􀀒􀀃􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀞􀀎􀀋􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀖􀀟􀀃􀀋􀀈􀀈􀀃􀀱􀀟􀀡􀀟
􀀲􀀲􀀫􀀭􀀪􀀃􀁁􀀫􀀵􀁋􀀭􀀬􀁂􀀟􀀃􀁀􀀒􀀃􀀐􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀀣􀀃􀀘􀀇􀀝􀀒􀀈􀀑􀀊􀀓􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀋􀀇􀀑􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗
􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀁁􀀊􀀒􀀘􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀲􀀬􀀬􀀭􀀃 􀀍􀀊􀀑􀀑􀁂􀀃 􀀒􀀊􀀐􀀏􀀋􀀊􀀑􀀑􀀓􀀃 􀀖􀀎􀀋􀀞􀀎􀀘􀀃 􀀐􀀇
􀀊􀀆􀀘􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀍􀀊􀀖􀀎􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀐􀀃􀀘􀀆􀀘􀀃􀀒􀀇􀀐􀀃􀀘􀀎􀀋􀀆􀀞􀀎􀀃􀀐􀀉􀀎􀀃􀀍􀀑􀀊􀀆􀀌􀀎􀀘􀀃􀀆􀀒􀀞􀀎􀀒􀀐􀀆􀀇􀀒􀀖
􀀚􀀋􀀇􀀌􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐􀀢􀀖􀀃􀀱􀀎􀀋􀀎􀀌􀀓􀀃􀀜􀀑􀀊􀀋􀀗􀀟􀀃􀁀􀀒􀀃􀀐􀀉􀀎􀀖􀀎􀀃􀀍􀀆􀀋􀀍􀀏􀀌􀀖􀀐􀀊􀀒􀀍􀀎􀀖􀀣􀀃􀀐􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀍􀀇􀀏􀀑􀀘􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀎􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓
􀀊􀀐􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀉􀀎􀀋􀀎􀀃 􀀉􀀎􀀑􀀘􀀃 􀀊􀀃 􀀖􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀃 􀀈􀀇􀀐􀀎􀀒􀀐􀀆􀀊􀀑􀀃 􀀐􀀇􀀃 􀀕􀀆􀀞􀀎􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀒
􀀊􀀘􀀞􀀊􀀒􀀐􀀊􀀕􀀎􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀣􀀃􀀖􀀊􀀐􀀆􀀖􀀚􀀓􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀚􀀈􀀛􀀍􀀜􀀘􀀑􀀈􀀃􀀖􀀐􀀊􀀒􀀘􀀊􀀋􀀘􀀟
􀀜
􀀴􀀎􀀃 􀀖􀀎􀀎􀀃 􀀒􀀇􀀃 􀀋􀀎􀀞􀀎􀀋􀀖􀀆􀀔􀀑􀀎􀀃 􀀎􀀋􀀋􀀇􀀋􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃 􀀔􀀊􀀑􀀊􀀒􀀍􀀆􀀒􀀕
􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀆􀀎􀀖􀀟􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀫􀀮􀁋􀀫􀀵􀀟􀀃􀀡􀀖􀀃􀀐􀀇
􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀐􀀉􀀎􀀃􀀎􀁊􀀏􀀆􀀐􀀓􀀃􀀔􀀊􀀑􀀊􀀒􀀍􀀎􀀃􀀚􀀇􀀑􀀑􀀇􀀝􀀖􀀃􀀘􀀆􀀋􀀎􀀍􀀐􀀑􀀓􀀃􀀚􀀋􀀇􀀌􀀃􀀐􀀉􀀎
􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀊􀀐􀀆􀀇􀀒􀀖􀀃􀀊􀀑􀀋􀀎􀀊􀀘􀀓􀀃􀀘􀀎􀀖􀀍􀀋􀀆􀀔􀀎􀀘􀀩􀀃􀀐􀀉􀀎􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀑􀀎􀀊􀀘􀀆􀀒􀀕􀀃􀀐􀀇
􀀐􀀉􀀎􀀃􀀰􀀎􀀔􀀋􀀏􀀊􀀋􀀓􀀃􀀲􀀬􀀬􀀨􀀃􀀊􀀌􀀎􀀒􀀘􀀌􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀆􀀒􀀞􀀇􀀑􀀞􀀎􀀘
􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀋􀀎􀀖􀀏􀀑􀀐􀀆􀀒􀀕􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀟􀀃 􀀽􀀒
􀀊􀀈􀀈􀀎􀀊􀀑􀀣􀀃 􀀝􀀎􀀃 􀀉􀀊􀀞􀀎􀀃 􀀋􀀎􀀑􀀆􀀎􀀘􀀃 􀀇􀀒􀀃 􀀊􀀃 􀀌􀀇􀀋􀀎􀀃 􀀑􀀆􀀌􀀆􀀐􀀎􀀘􀀃 􀀖􀀎􀀐􀀃 􀀇􀀚􀀃 􀀝􀀋􀀇􀀒􀀕􀀚􀀏􀀑
􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀐􀀉􀀊􀀒􀀃􀀋􀀎􀀍􀀆􀀐􀀎􀀘􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀇􀀈􀀆􀀒􀀆􀀇􀀒􀀣􀀃􀀍􀀈􀀈􀀃􀀍􀀡􀀩􀀔􀀉
􀀒􀀒􀀟􀀭􀁋􀀨􀀣􀀃 􀀔􀀏􀀐􀀃 􀀝􀀎􀀃 􀀘􀀇􀀃 􀀒􀀇􀀐􀀃 􀀐􀀉􀀆􀀒􀀗􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃 􀀔􀀊􀀑􀀊􀀒􀀍􀀎􀀃 􀀆􀀖
􀀊􀀑􀀐􀀎􀀋􀀎􀀘􀀃􀀔􀀓􀀃􀀐􀀉􀀊􀀐􀀃􀀒􀀊􀀋􀀋􀀇􀀝􀀆􀀒􀀕􀀟􀀃􀀶􀀉􀀎􀀃􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀝􀀎􀀃􀀉􀀊􀀞􀀎􀀃􀀊􀀚􀀚􀀆􀀋􀀌􀀎􀀘􀀃􀀊􀀖
􀀝􀀋􀀇􀀒􀀕􀀚􀀏􀀑􀀃􀀆􀀖􀀃􀀖􀀇􀀃􀀍􀀑􀀎􀀊􀀋􀀑􀀓􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀋􀀎􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀊􀀒􀀊􀀑􀀓􀀖􀀆􀀖
􀀐􀀉􀀊􀀐􀀃 􀀝􀀎􀀃 􀀉􀀊􀀞􀀎􀀃 􀀒􀀇􀀃 􀀘􀀇􀀏􀀔􀀐􀀃 􀀐􀀉􀀊􀀐􀀃 􀀐􀀉􀀎􀀃 􀀎􀁊􀀏􀀆􀀐􀀊􀀔􀀑􀀎􀀃 􀀔􀀊􀀑􀀊􀀒􀀍􀀆􀀒􀀕􀀃 􀀔􀀓􀀃 􀀐􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀝􀀇􀀏􀀑􀀘􀀃􀀉􀀊􀀞􀀎􀀃􀀔􀀎􀀎􀀒􀀃􀀐􀀉􀀎􀀃􀀖􀀊􀀌􀀎􀀃􀀆􀀚􀀃􀀆􀀐􀀃􀀉􀀊􀀘􀀃􀀑􀀆􀀌􀀆􀀐􀀎􀀘􀀃􀀆􀀐􀀖
􀀝􀀋􀀇􀀒􀀕􀀚􀀏􀀑􀀄􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀐􀀇􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀝􀀎􀀃􀀉􀀊􀀞􀀎􀀃􀀋􀀎􀀍􀀆􀀐􀀎􀀘􀀟􀀃􀀽􀀒􀀃􀀐􀀉􀀎􀀖􀀎
􀀚􀀊􀀍􀀐􀀖􀀣􀀃􀀐􀀉􀀎􀀋􀀎􀀃􀀆􀀖􀀃􀀒􀀇􀀃􀀊􀀔􀀏􀀖􀀎􀀃􀀇􀀚􀀃􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀟
􀀡􀀖􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀋􀀎􀀍􀀇􀀕􀀒􀀆􀀻􀀎􀀘􀀣􀀃 􀀐􀀉􀀎􀀃 􀁊􀀏􀀎􀀖􀀐􀀆􀀇􀀒􀀃 􀀚􀀇􀀋􀀃 􀀐􀀉􀀎􀀃 􀀢􀀮􀀪􀀲
􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀆􀀖􀀃 􀀍􀀑􀀇􀀖􀀎􀀋􀀣􀀃 􀀔􀀏􀀐􀀃 􀀝􀀎􀀃 􀀊􀀑􀀖􀀇􀀃 􀀖􀀎􀀎􀀃 􀀒􀀇􀀃 􀀊􀀔􀀏􀀖􀀎􀀃 􀀇􀀚􀀃 􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀃 􀀆􀀒
􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀏􀀑􀀐􀀆􀀌􀀊􀀐􀀎􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀖􀀆􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀐􀀉􀀎􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖
􀀘􀀎􀀚􀀎􀀒􀀖􀀎􀀃 􀀎􀁈􀀐􀀎􀀒􀀘􀀖􀀃 􀀐􀀇􀀃 􀀐􀀉􀀊􀀐􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀊􀀖􀀃 􀀝􀀎􀀑􀀑􀀟􀀃 􀀶􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐
􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀐􀀇􀀃􀀇􀀒􀀎􀀃􀀈􀀇􀀋􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋
􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀩􀀃 􀀇􀀒􀀍􀀎􀀃 􀀦􀀋􀀟􀀃 􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃 􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀑􀀓􀀃 􀀑􀀎􀀊􀀋􀀒􀀎􀀘􀀃 􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀢􀀖
􀀖􀀐􀀋􀀏􀀍􀀐􀀏􀀋􀀎􀀃 􀀐􀀉􀀋􀀇􀀏􀀕􀀉􀀃 􀀈􀀊􀀋􀀐􀀆􀀍􀀆􀀈􀀊􀀐􀀆􀀒􀀕􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀼􀀊􀀋􀀍􀀉􀀃 􀀲􀀬􀀬􀀭􀀃 􀀍􀀊􀀑􀀑􀀃 􀀊􀀐
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀔􀀎􀀉􀀎􀀖􀀐􀀣􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀗􀀎􀀈􀀐􀀃 􀀉􀀆􀀌􀀃 􀀆􀀒􀀃 􀀉􀀆􀀖􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀄􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒
􀀋􀀇􀀑􀀎􀁄􀀝􀀉􀀆􀀍􀀉􀀣􀀃􀀊􀀖􀀃􀀒􀀇􀀐􀀎􀀘􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀎􀀘􀀃􀀚􀀆􀀑􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀲􀀬􀀬􀀮􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀐􀀉􀀊􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀊􀀖􀀃􀀝􀀎􀀑􀀑􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀆􀀒􀀆􀀐􀀆􀀊􀀑􀀃􀀖􀀏􀀔􀀖􀀐􀀆􀀐􀀏􀀐􀀎
􀀍􀀑􀀊􀀆􀀌􀀖􀀣􀀃􀀊􀀚􀀐􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀁁􀀐􀀊􀀆􀀒􀀐􀀎􀀘􀁂􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀉􀀊􀀘􀀃􀀊􀀑􀀋􀀎􀀊􀀘􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀟􀀃􀀐􀀊􀀎
􀀊􀀐􀀃 􀁌􀀪􀀬􀁋􀀪􀀪􀀟􀀃 􀀴􀀉􀀆􀀑􀀎􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀖􀀊􀀆􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀀆􀀐􀀖􀀃 􀁆􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃 􀀇􀀚
􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀃􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀍􀀊􀀑􀀑􀀃􀀝􀀊􀀖
􀀒􀀇􀀐􀀃􀀍􀀇􀀒􀀖􀀆􀀘􀀎􀀋􀀎􀀘􀀃􀀔􀀓􀀃􀀐􀀉􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀃􀀆􀀒􀀃􀀘􀀎􀀐􀀎􀀋􀀌􀀆􀀒􀀆􀀒􀀕􀀃􀀝􀀉􀀎􀀐􀀉􀀎􀀋􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒
􀀉􀀊􀀒􀀘􀀖􀀃􀀈􀀋􀀎􀀞􀀎􀀒􀀐􀀎􀀘􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀌􀀎􀀒􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀣􀁇􀀃􀀆􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀫􀀳
􀀒􀀟􀀨􀀣􀀃􀀐􀀉􀀊􀀐􀀃􀀖􀀐􀀊􀀐􀀎􀀌􀀎􀀒􀀐􀀃􀀘􀀇􀀎􀀖􀀃􀀒􀀇􀀐􀀃􀀋􀀎􀀚􀀎􀀋􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀋􀀎􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀑􀀎􀀊􀀘􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀇􀀋􀀃􀀇􀀚􀀃􀀛􀀜􀁎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀖􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀇􀀒􀀎
􀀐􀀉􀀊􀀐􀀃􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀋􀀎􀀑􀀆􀀎􀀘
􀀇􀀒􀀃􀀐􀀉􀀊􀀐􀀃􀀆􀀌􀀈􀀋􀀇􀀈􀀎􀀋􀀃􀀋􀀎􀀐􀀎􀀒􀀐􀀆􀀇􀀒􀀟􀀃􀀞􀀎􀀙􀀎􀀣􀀃􀀆􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀪􀀬􀁋􀀪􀀪􀀟􀀃􀀶􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐
􀀍􀀇􀀏􀀋􀀐􀀃􀀋􀀎􀀑􀀆􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃􀀔􀀎􀀐􀀝􀀎􀀎􀀒􀀃􀀐􀀉􀀎􀀃􀀐􀀝􀀇􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀩􀀃􀁆􀀦􀀋􀀟
􀀦􀀏􀀋􀀎􀀐􀀐􀀎􀀃􀀈􀀑􀀊􀀓􀀎􀀘􀀃􀀊􀀃􀀗􀀎􀀓􀀃􀀋􀀇􀀑􀀎􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀇􀀖􀀎􀀍􀀏􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀔􀀇􀀐􀀉􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵
􀀊􀀒􀀘􀀃􀀢􀀮􀀪􀀲􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀖􀀟􀀃􀀛􀀎􀀃􀀝􀀊􀀖􀀃􀀋􀀎􀀖􀀈􀀇􀀒􀀖􀀆􀀔􀀑􀀎􀀃􀀚􀀇􀀋􀀃􀀚􀀆􀀑􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀐􀀉􀀊􀀐􀀃􀀎􀀞􀀎􀀒􀀐􀀏􀀊􀀑􀀑􀀓􀀃􀀌􀀊􀀐􀀏􀀋􀀎􀀘􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀃􀀊􀀒􀀘􀀃􀀐􀀉􀀆􀀖􀀃􀀊􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒
􀀖􀀉􀀊􀀋􀀎􀀖􀀃􀀐􀀉􀀎􀀃􀀖􀀊􀀌􀀎􀀃􀀖􀀈􀀎􀀍􀀆􀀚􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀊􀀖􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀟􀁇􀀃􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀫􀀳􀀟
􀀼􀀇􀀋􀀎􀀃 􀀆􀀌􀀈􀀇􀀋􀀐􀀊􀀒􀀐􀀑􀀓􀀣􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀣􀀃 􀀐􀀏􀀋􀀒􀀆􀀒􀀕􀀃 􀀚􀀋􀀇􀀌􀀃 􀀐􀀉􀀎
􀀔􀀏􀀖􀀆􀀒􀀎􀀖􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀣􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀊􀀔􀀑􀀓
􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀎􀀘􀀃 􀀐􀀉􀀊􀀐􀀃 􀁆􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀆􀀒􀀚􀀎􀀍􀀐􀀖􀀃 􀀐􀀉􀀎
􀀎􀀒􀀐􀀆􀀋􀀎􀀃􀀑􀀊􀀝􀀖􀀏􀀆􀀐􀀣􀀃􀀆􀀒􀀍􀀑􀀏􀀘􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀎􀀒􀀚􀀇􀀋􀀍􀀎􀀊􀀔􀀆􀀑􀀆􀀐􀀓􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲􀀃􀀠􀀊􀀐􀀎􀀒􀀐􀀟􀁇
􀀐􀀊􀀎􀀃􀀊􀀐􀀃􀁌􀀫􀀲􀀟􀀃􀁆􀁔􀀶􀁕􀀉􀀎􀀃􀀏􀀒􀀐􀀋􀀏􀀐􀀉􀀚􀀏􀀑􀀃􀀐􀀎􀀖􀀐􀀆􀀌􀀇􀀒􀀓􀀃􀀇􀀚􀀚􀀎􀀋􀀎􀀘􀀃􀀔􀀓􀀃􀀦􀀋􀀟􀀃􀀦􀀏􀀋􀀎􀀐􀀐􀀎
􀀆􀀒􀀃 􀀉􀀆􀀖􀀃 􀀘􀀎􀀈􀀇􀀖􀀆􀀐􀀆􀀇􀀒􀀃 􀀊􀀒􀀘􀀃 􀀊􀀐􀀃 􀀐􀀋􀀆􀀊􀀑􀀃 􀀝􀀊􀀖􀀃 􀀒􀀇􀀐􀀃 􀀆􀀒􀀍􀀆􀀘􀀎􀀒􀀐􀀊􀀑􀀣􀀃 􀀔􀀏􀀐􀀃 􀀋􀀊􀀐􀀉􀀎􀀋
􀀝􀀊􀀖􀀃 􀀘􀀆􀀋􀀎􀀍􀀐􀀎􀀘􀀃 􀀊􀀐􀀃 􀀊􀀒􀀘􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐􀀎􀀘􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃 􀀊􀀋􀀕􀀏􀀌􀀎􀀒􀀐􀀖􀀣
􀀊􀀒􀀘􀀃􀀝􀀎􀀒􀀐􀀃􀀐􀀇􀀃􀀐􀀉􀀎􀀃􀀉􀀎􀀊􀀋􀀐􀀃􀀇􀀚􀀃􀀖􀀆􀀕􀀒􀀆􀀚􀀆􀀍􀀊􀀒􀀐􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀆􀀒􀀃􀀐􀀉􀀆􀀖􀀃􀀍􀀊􀀖􀀎􀀟􀁇􀀃􀀐􀀊􀀎
􀀶􀀉􀀎􀀃􀀞􀀊􀀑􀀆􀀘􀀆􀀐􀀓􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀃􀀝􀀎􀀋􀀎􀀃􀀑􀀊􀀋􀀕􀀎􀀑􀀓􀀃􀀐􀀉􀀎􀀃􀀖􀀊􀀌􀀎􀀃􀀚􀀇􀀋􀀃􀀐􀀉􀀎􀀃􀀐􀀝􀀇􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀣
􀀚􀀇􀀍􀀏􀀖􀀎􀀘􀀃􀀇􀀒􀀃􀀐􀀉􀀎􀀃􀀍􀀇􀀌􀀌􀀇􀀒􀀃􀀖􀀈􀀎􀀍􀀆􀀚􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀐􀀝􀀇􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀊􀀒􀀘
􀀉􀀇􀀝􀀃 􀀐􀀉􀀊􀀐􀀃 􀀖􀀈􀀎􀀍􀀆􀀚􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀀃 􀀔􀀇􀀋􀀎􀀃 􀀇􀀒􀀃 􀀝􀀋􀀆􀀐􀀐􀀎􀀒􀀄􀀘􀀎􀀖􀀍􀀋􀀆􀀈􀀐􀀆􀀇􀀒􀀃 􀀖􀀏􀀈􀀈􀀇􀀋􀀐
􀀚􀀇􀀋􀀃 􀀊􀀒􀀘􀀃 􀀎􀀒􀀊􀀔􀀑􀀎􀀌􀀎􀀒􀀐􀀃 􀀇􀀚􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀐􀀝􀀇􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀉􀀊􀀞􀀎
􀀍􀀑􀀇􀀖􀀎􀀑􀀓􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃 􀀖􀀍􀀇􀀈􀀎􀀟􀀃 􀀡􀀖􀀃 􀀆􀀒􀀘􀀆􀀍􀀊􀀐􀀎􀀘􀀃 􀀊􀀔􀀇􀀞􀀎􀀣􀀃 􀀐􀀉􀀎􀀃 􀀙􀀏􀀋􀀓􀀃 􀀞􀀎􀀋􀀘􀀆􀀍􀀐
􀀚􀀇􀀋􀀌􀀃􀀐􀀆􀀎􀀘􀀃􀀔􀀇􀀐􀀉􀀃􀀇􀀚􀀃􀀐􀀉􀀇􀀖􀀎􀀃􀀆􀀖􀀖􀀏􀀎􀀖􀀣􀀃􀀚􀀇􀀋􀀃􀀔􀀇􀀐􀀉􀀃 􀀕􀀖􀀗􀀡􀀥 􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀣􀀃􀀐􀀇􀀃􀀐􀀉􀀎
􀁊􀀏􀀎􀀖􀀐􀀆􀀇􀀒􀀃􀀇􀀚􀀃􀁆􀀘􀀎􀀋􀀆􀀞􀀊􀀐􀀆􀀇􀀒􀀃􀀚􀀋􀀇􀀌􀀃􀀱􀀎􀀋􀀎􀀌􀀓􀀃􀀜􀀑􀀊􀀋􀀗􀁇􀀃􀁁􀀐􀀉􀀎􀀃􀀠􀀉􀀊􀀋􀀌􀀊􀀖􀀖􀀎􀀐
Annex 100
􀀅􀀆􀀇􀀈􀀉􀀊􀀃􀀋􀀌􀀆􀀈􀀍􀀌􀀈􀀎􀀏􀀃􀀐􀀍􀀌􀀑􀀃􀀒􀀑􀀃􀀓􀀈􀀔􀀌􀀕􀀃􀀖􀀃􀀗􀀘􀀑􀀏􀀃􀀐􀀍􀀌􀀑􀀏􀀃􀀙􀀙􀀙􀀃􀀚􀀑􀀛􀀊􀀃􀀜􀀝􀀛􀀜􀀃􀀞􀀝􀀟􀀜􀀙􀀠
􀀅􀀆􀀇􀀃􀀈􀀉􀀊􀀉􀀋􀀉􀀌􀀉􀀆􀀍􀀃􀀅􀀎􀀏􀀅
􀀃􀀐􀀃􀀆􀀑􀀅􀀒􀀃􀀓􀀔􀀕􀀖􀀗􀀕􀀘􀀃􀀙􀀚􀀛􀀜􀀚􀀝􀀗􀀉􀀃􀀞􀀕􀀃􀀟􀀠􀀡􀀢􀀖􀀃􀀜􀀕􀀃􀀕􀀝􀀢􀀣􀀢􀀘􀀡􀀠􀀃􀀈􀀉􀀊􀀉􀀃􀀤􀀕􀀥􀀚􀀝􀀘􀀖􀀚􀀘􀀜􀀃􀀦􀀕􀀝􀀧􀀗􀀉 􀀅􀀆
􀀆􀀒􀀞􀀎􀀒􀀐􀀇􀀋􀀃􀀇􀀚􀀃􀀠􀀥􀁀􀀄􀀳􀀪􀀫􀀬􀀣􀀃􀀘􀀆􀀖􀀍􀀑􀀇􀀖􀀎􀀘􀀃􀀆􀀒􀀃􀀼􀀊􀀋􀀍􀀉􀀃􀀲􀀬􀀬􀀭􀀃􀀊􀀒􀀘􀀃􀀈􀀏􀀔􀀑􀀆􀀖􀀉􀀎􀀘
􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀜􀀑􀀊􀀋􀀗􀀃􀀡􀀈􀀈􀀑􀀆􀀍􀀊􀀐􀀆􀀇􀀒􀁂􀀟􀀃􀀱􀀟􀀡􀀟􀀃􀀲􀀪􀀬􀀳􀀳􀁋􀀮􀀨􀀟􀀃􀀶􀀉􀀏􀀖􀀣􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒
􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃􀁆􀀆􀀒􀀚􀀎􀀍􀀐􀀎􀀘􀀃􀀐􀀉􀀆􀀖􀀃􀀎􀀒􀀐􀀆􀀋􀀎􀀃􀀍􀀊􀀖􀀎􀀣􀀃􀀍􀀇􀀞􀀎􀀋􀀆􀀒􀀕􀀃􀀔􀀇􀀐􀀉􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀄
􀀆􀀒􀀄􀀖􀀏􀀆􀀐􀀟􀁇􀀃􀀅􀀆􀀇􀀈􀀉􀀊􀀣􀀃􀀲􀀬􀀪􀀳􀀃􀀴􀀯􀀃􀀫􀀪􀀭􀀫􀀵􀀭􀀫􀀣􀀃􀀊􀀐􀀃􀁌􀀫􀀳􀀟􀀃􀀴􀀎􀀃􀀍􀀇􀀒􀀍􀀑􀀏􀀘􀀎􀀃􀀐􀀉􀀊􀀐􀀣
􀀍􀀇􀀒􀀐􀀋􀀊􀀋􀀓􀀃 􀀐􀀇􀀃 􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃 􀀖􀀏􀀕􀀕􀀎􀀖􀀐􀀆􀀇􀀒􀀣􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀖􀀎􀀐􀀃 􀀚􀀇􀀋􀀐􀀉
􀀊􀀃 􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀃 􀀎􀁈􀀈􀀑􀀊􀀒􀀊􀀐􀀆􀀇􀀒􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀢􀀮􀀪􀀲􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀢􀀖􀀃 􀀍􀀇􀀒􀀒􀀎􀀍􀀐􀀆􀀇􀀒􀀃 􀀐􀀇
􀀼􀀎􀀋􀀍􀀗􀀢􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀟
􀀼􀀎􀀋􀀍􀀗􀀃 􀀊􀀋􀀕􀀏􀀎􀀖􀀃 􀀐􀀉􀀊􀀐􀀃 􀀎􀀞􀀎􀀒􀀃 􀀝􀀉􀀎􀀋􀀎􀀃 􀀐􀀉􀀎􀀋􀀎􀀃 􀀆􀀖􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀃 􀀋􀀎􀀑􀀊􀀐􀀎􀀘
􀀐􀀇􀀃 􀀇􀀒􀀎􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀣􀀃 􀁆􀀐􀀉􀀊􀀐􀀃 􀀘􀀇􀀎􀀖􀀃 􀀒􀀇􀀐􀀃 􀀘􀀎􀀚􀀎􀀊􀀐􀀃 􀀍􀀑􀀊􀀆􀀌􀀖􀀃 􀀏􀀒􀀘􀀎􀀋􀀃 􀀊􀀒􀀇􀀐􀀉􀀎􀀋
􀀈􀀊􀀐􀀎􀀒􀀐􀀃 􀀖􀀆􀀌􀀈􀀑􀀓􀀃 􀀔􀀎􀀍􀀊􀀏􀀖􀀎􀀃 􀀐􀀉􀀎􀀓􀀃 􀀝􀀎􀀋􀀎􀀃 􀁖􀀔􀀋􀀇􀀏􀀕􀀉􀀐􀀃 􀀟􀀟􀀟􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀖􀀊􀀌􀀎
􀀑􀀊􀀝􀀖􀀏􀀆􀀐􀀟􀁗􀀃 􀁇􀀃 􀀼􀀎􀀋􀀍􀀗􀀃 􀀅􀀋􀀟􀀃 􀀳􀀵􀀟􀀃 􀀴􀀎􀀃 􀀊􀀕􀀋􀀎􀀎􀀺􀀃 􀀔􀀏􀀐􀀃 􀀐􀀉􀀎􀀃 􀀊􀀖􀀖􀀎􀀋􀀐􀀆􀀇􀀒􀀃 􀀘􀀇􀀎􀀖
􀀒􀀇􀀐􀀃􀀏􀀒􀀘􀀎􀀋􀀌􀀆􀀒􀀎􀀃􀀐􀀉􀀎􀀃􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀢􀀖􀀃􀀋􀀏􀀑􀀆􀀒􀀕􀀃􀀉􀀎􀀋􀀎􀀟􀀃􀀶􀀉􀀎􀀃􀀥􀀏􀀈􀀋􀀎􀀌􀀎
􀀜􀀇􀀏􀀋􀀐􀀢􀀖􀀃 􀀘􀀎􀀍􀀆􀀖􀀆􀀇􀀒􀀖􀀃 􀀆􀀒􀀃 􀀚􀀈􀀛􀀍􀀜􀀘􀀑􀀈􀀃 􀀊􀀒􀀘􀀃 􀀠􀀔􀀈􀀌􀀆􀀍􀀆􀀘􀀑􀀃 􀀐􀀑􀀍􀀜􀀔􀀡􀀢􀀈􀀑􀀜􀀍􀀣
􀀘􀀎􀀊􀀑􀀆􀀒􀀕􀀃􀀝􀀆􀀐􀀉􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀖􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀃􀀝􀀉􀀎􀀒􀀃􀀌􀀏􀀑􀀐􀀆􀀈􀀑􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖
􀀝􀀎􀀋􀀎􀀃 􀀊􀀐􀀃 􀀆􀀖􀀖􀀏􀀎􀀃 􀀆􀀒􀀃 􀀐􀀉􀀎􀀃 􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃 􀀊􀀒􀀘􀀃 􀀐􀀉􀀎􀀃 􀀊􀀑􀀑􀀎􀀕􀀎􀀘􀀃 􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐
􀀋􀀎􀀑􀀊􀀐􀀎􀀘􀀃􀀐􀀇􀀃􀀊􀀃􀀖􀀏􀀔􀀖􀀎􀀐􀀃􀀇􀀚􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀣􀀃􀀊􀀋􀀎􀀃􀀆􀀒􀀖􀀐􀀋􀀏􀀍􀀐􀀆􀀞􀀎􀀟􀀃􀁀􀀒􀀃􀀔􀀇􀀐􀀉􀀃􀀍􀀊􀀖􀀎􀀖􀀣
􀀐􀀉􀀎􀀃􀀥􀀏􀀈􀀋􀀎􀀌􀀎􀀃􀀜􀀇􀀏􀀋􀀐􀀃􀀊􀀈􀀈􀀑􀀆􀀎􀀘􀀃􀀐􀀉􀀎􀀃􀀚􀀆􀀒􀀘􀀆􀀒􀀕􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀃􀀐􀀇
􀀊􀀑􀀑􀀃 􀀇􀀚􀀃 􀀐􀀉􀀎􀀃 􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀟􀀃 􀀚􀀈􀀛􀀍􀀜􀀘􀀑􀀈􀀣􀀃 􀀲􀀵􀀬􀀃 􀀤􀀟􀀥􀀟􀀃 􀀊􀀐􀀃 􀀲􀀭􀀳􀁋􀀭􀀮􀀣􀀃 􀀨􀀭􀀃 􀀥􀀟􀀜􀀐􀀟
􀀪􀀭􀀳􀀺􀀃􀀠􀀔􀀈􀀌􀀆􀀍􀀆􀀘􀀑􀀃􀀐􀀑􀀍􀀜􀀔􀀡􀀢􀀈􀀑􀀜􀀣􀀃􀀫􀀲􀀭􀀃􀀤􀀟􀀥􀀟􀀃􀀊􀀐􀀃􀁃􀀪􀀵􀀣􀀃􀀳􀀨􀀃􀀥􀀟􀀜􀀐􀀟􀀃􀀵􀀵􀀫􀀟􀀃􀀶􀀉􀀎
􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃􀀍􀀇􀀏􀀋􀀐􀀃􀀆􀀒􀀃􀀐􀀉􀀎􀀃􀀈􀀋􀀎􀀖􀀎􀀒􀀐􀀃􀀍􀀊􀀖􀀎􀀃􀀉􀀊􀀘􀀃􀀖􀀏􀀚􀀚􀀆􀀍􀀆􀀎􀀒􀀐􀀃􀀋􀀎􀀊􀀖􀀇􀀒􀀃􀀐􀀇􀀃􀀚􀀆􀀒􀀘
􀀐􀀉􀀊􀀐􀀃􀀔􀀇􀀐􀀉􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀖􀀃􀀝􀀎􀀋􀀎􀀃􀀐􀀊􀀆􀀒􀀐􀀎􀀘􀀃􀀔􀀓􀀃􀀐􀀉􀀎􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀎􀀎􀀢􀀖􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀣
􀀎􀀖􀀈􀀎􀀍􀀆􀀊􀀑􀀑􀀓􀀃􀀐􀀉􀀎􀀃􀀑􀀆􀀐􀀆􀀕􀀊􀀐􀀆􀀇􀀒􀀃􀀌􀀆􀀖􀀍􀀇􀀒􀀘􀀏􀀍􀀐􀀟􀀃􀀶􀀉􀀏􀀖􀀣􀀃􀀝􀀎􀀃􀀖􀀎􀀎􀀃􀀒􀀇􀀃􀀊􀀔􀀏􀀖􀀎
􀀇􀀚􀀃􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀃􀀝􀀆􀀐􀀉􀀃􀀋􀀎􀀖􀀈􀀎􀀍􀀐􀀃􀀐􀀇􀀃􀀎􀀆􀀐􀀉􀀎􀀋􀀃􀀐􀀉􀀎􀀃􀀢􀀭􀀵􀀵􀀃􀀈􀀊􀀐􀀎􀀒􀀐􀀃􀀇􀀋􀀃􀀐􀀉􀀎􀀃􀀢􀀮􀀪􀀲
􀀈􀀊􀀐􀀎􀀒􀀐􀀟
􀁀􀁀􀁀
􀀅􀀎􀀍􀀊􀀏􀀖􀀎􀀃 􀀐􀀉􀀎􀀃 􀀘􀀆􀀖􀀐􀀋􀀆􀀍􀀐􀀃 􀀍􀀇􀀏􀀋􀀐􀀃 􀀘􀀆􀀘􀀃 􀀒􀀇􀀐􀀃 􀀊􀀔􀀏􀀖􀀎􀀃 􀀆􀀐􀀖􀀃 􀀘􀀆􀀖􀀍􀀋􀀎􀀐􀀆􀀇􀀒􀀃 􀀆􀀒
􀀊􀀈􀀈􀀑􀀓􀀆􀀒􀀕􀀃􀀐􀀉􀀎􀀃􀀘􀀇􀀍􀀐􀀋􀀆􀀒􀀎􀀃􀀇􀀚􀀃􀀏􀀒􀀍􀀑􀀎􀀊􀀒􀀃􀀉􀀊􀀒􀀘􀀖􀀣􀀃􀀝􀀎􀀃􀀊􀀚􀀚􀀆􀀋􀀌􀀟
􀀜􀀇􀀖􀀐􀀖􀀃􀀊􀀝􀀊􀀋􀀘􀀎􀀘􀀃􀀐􀀇􀀃􀀿􀀆􀀑􀀎􀀊􀀘􀀟
􀀙􀀞􀀞􀀨􀀩􀀪􀀫􀀬
􀀙􀀭􀀭􀀃􀀮􀀋􀀚􀀍􀀚􀀋􀀈􀀇􀀊
􀁃􀁃􀁃􀀃􀀰􀀟􀀫􀀘􀀃􀀪􀀲􀀫􀀪􀀣􀀃􀀪􀀲􀀳􀀃􀀤􀀟􀀥􀀟􀀠􀀟􀁘􀀟􀀲􀀘􀀃􀀪􀀭􀁃􀀪
Footnotes
1 The top figure shows the key elements of the nucleoside. B is the base, shown in the next two figures in single-ring
(pyrimidine) and double-ring (purine) versions. R 1 and R 2 are located at the 2# (carbon) position on the ring, with R 1
at the 2# “up” location and R 2 at the 2# “down” location. R 3 is at the 3# position.
2 The doctrine of unclean hands is not patent-specific, but its application to patents has some distinctive features affecting
the patent system. We need not choose between Ninth Circuit and Federal Circuit law on the subject here. The parties
have identified no differences pertinent to this case, and they have not identified what law they contend controls in this
appeal.
3 We therefore have no occasion in this case to consider issues that may arise in seeking to ensure that the uncleanhands
doctrine operates in harmony with, and does not override, this court's inequitable-conduct standards governing
unenforceability challenges based on prosecution communications with the PTO.
4 The court added that Merck's own “corporate policy forb[ade] Merck's patent prosecutors from participating in licensing
discussions in an area related to their prosecution work.” Id. at *9 (citing J.A. 22341 (38–39) ); see id. at *28; J.A. 22374
(170–71). That policy, as we note below, confirms the connection between (a) Merck's patent prosecutor learning the
structure of PSI-6130 during the March 2004 call and (b) Merck's patenting and the resulting litigation. To the extent that
the district court suggested that the violation of Merck's internal policy was an independent basis for finding wrongful
conduct, even apart from the violation of the firewall understanding, we see no basis for such a suggestion. A patentobtaining
firm may legitimately have such a policy simply to avoid having its later litigation position weakened by exposure
to information gained from licensing discussions. Violation of such a policy would be a wrong to the firm but not to the
potential licensee, or the judicial system, in the absence of other understandings, such as the firewall understanding here.
5 The timing of the amendment undermines a different, but ultimately immaterial, finding of the district court—that Merck
violated the non-disclosure agreement with Pharmasset. E.g., Gilead, 2016 WL 3143943, at *10, *27, *29. The only
identified forbidden use of information covered by the agreement—Dr. Durette's February 2005 claim amendment
focusing on PSI-6130—did not occur until the information was publicly disclosed in the Clark Application. The disclosure
ended the information's protection by the agreement. J.A. 32152 ¶ 3(ii).
End of Document © 2019 Thomson Reuters. No claim to original U.S. Government Works.
Annex 100
ANNEX 101

Neutral Citation Number: [2013] EWCA Civ 328
Case No: A3/2012/1463 & A3/2012/1474
IN THE COURT OF APPEAL (CIVIL DIVISION)
ON APPEAL FROM QUEENS BENCH DIVISION
COMMERCIAL COURT
MR JUSTICE BURTON
[2012] EWHC 1278 (Comm)
Royal Courts of Justice
Strand, London, WC2A 2LL
Date: 12/04/2013
Before :
LORD JUSTICE MAURICE KAY
LORD JUSTICE TOULSON
and
LORD JUSTICE AIKENS
- - - - - - - - - - - - - - - - - - - - -
Between :
The Royal Bank of Scotland Plc Appellant
- and -
(1) Highland Financial Partners LP
(2) HFP CDO Construction Corp.
(3) Highland CDO Opportunity Master Fund LP
(4) Highland Capital Management Europe, Limited
(5) Scott Law Group LLC
Respondents
- - - - - - - - - - - - - - - - - - - - -
(Transcript of the Handed Down Judgment of
WordWave International Limited
A Merrill Communications Company
165 Fleet Street, London EC4A 2DY
Tel No: 020 7404 1400, Fax No: 020 7831 8838
Official Shorthand Writers to the Court)
- - - - - - - - - - - - - - - - - - - - -
Mr John Nicholls QC & Ms. Louise Hutton (instructed by Linklaters LLP) for the Appellant
Mr Stephen Auld QC, Mr Benjamin Strong & Mr Laurence Emmett (instructed by Cooke, Young
& Keidan LLP) for the Respondents (1) to (3)
Mr Graham Dunning QC and Mr Jeremy Brier (instructed by DaySparkes) for the Respondent (5)
Hearing dates : 27th-29th of November 2012
- - - - - - - - - - - - - - - - - - - - -
Judgment
As Approved by the Court
Crown copyright©
Annex 101
156. In my judgment that analysis is applicable to the facts of this case. So the question
is: what was SG’s status in the 2012 trial? RBS had no option but to call SG as a
witness to deal with the allegation of “unclean hands” and the allegation that the
Liability judgment had been obtained by fraud. He was RBS’ key witness on both
those issues. Also, by the time of the 2012 trial, SG was a Managing Director of
RBS working in the European Credit Special Situations Group. He was authorised to
make his seventh witness statement, his chief witness statement in the 2012 trial, on
behalf of RBS in support of the anti-suit injunction claims.141 Although the judge did
not make an express finding to this effect, I would expect that, as in the earlier
litigation, SG was part of the RBS litigation team for the purposes of the 2012 trial.
There was no evidence from RBS that SG’s situation had changed from that at the
time of the Liability hearing.142
157. There can be no doubt, in my view, that when SG gave his evidence in the 2012 trial,
he had the status necessary to make his evidence that of RBS for the purposes of the
“unclean hands” issue as well as the issue of whether the Liability judgment had been
obtained by fraud – as to which Mr Nicholls did not raise the “attribution” argument.
So I must reject the first of Mr Nicholls’ two main submissions.
158. Did the judge err in concluding that there was a sufficient “immediate and
necessary” relation between the misconduct of SG and the claim by RBS for
equitable relief in the form of an anti-suit injunction such that RBS was to be
denied it under the “unclean hands” doctrine?
There is no dispute that there exists in English law a defence to a claim for equitable
relief, such as an injunction, which is based on the concept encapsulated in the
equitable maxim “he who comes into equity must come with clean hands”.143 Mr
Nicholls accepted that the doctrine applies to a claim for an anti-suit injunction where
the claim is based on an allegation that the defendant has started proceedings in a
foreign jurisdiction in breach of contract because the claimant and defendant had
agreed to an exclusive jurisdiction clause in favour of the English courts. It is clear
from the speech of Lord Bingham in Donohue v Armco Inc144 that this defence is
distinct from that of there being “strong reason” not to grant an anti-suit injunction.
159. It was common ground that the scope of the application of the “unclean hands”
doctrine is limited. To paraphrase the words of Lord Chief Baron Eyre in Dering v
Earl of Winchelsea145 the misconduct or impropriety of the claimant must have “an
immediate and necessary relation to the equity sued for”. That limitation has been
expressed in different ways over the years in cases and textbooks. Recently in Fiona
Trust & Holding Corporation and others v Yuri Privalov and others146 Andrew
Smith J noted that there are some authorities147 in which the court regarded attempts
to mislead it as presenting good grounds for refusing equitable relief, not only where
the purpose is to create a false case but also where it is to bolster the truth with
141 Seventh witness statement para 2.
142 See the finding of Burton J on that point in the May 2012 judgment at [104]
143 Snell’s Equity (32nd Ed 2010) at 15-15 (page 98-9).
144 [2002] 1 Lloyd’s Rep 425 at [24]
145 (1787) 1 Cos 318 at 319.
146 [2008] EWHC 1748 (Comm)
147 Armstrong v Sheppard & Short Ltd [1959] 2 QB 384; J Willis Son v Willis [1986] EGLR 62; Gonthier v
Orange Contract Scaffolding Ltd [2003] EWCA Civ 873
Annex 101
fabricated evidence. But the cases noted by him were ones where the misconduct was
by way of deception in the course of the very litigation directed to securing the
equitable relief.148 Spry: Principles of Equitable Remedies,149 suggests that it must
be shown that the claimant is seeking “to derive advantage from his dishonest conduct
in so direct a manner that it is considered to be unjust to grant him relief”. Ultimately
in each case it is a matter of assessment by the judge, who has to examine all the
relevant factors in the case before him to see if the misconduct of the claimant is
sufficient to warrant a refusal of the relief sought.
160. Mr Nicholls relied strongly on the House of Lords’ decision in Grobbelaar v News
Group Newspapers.150 The House of Lords permitted the claimant footballer to
bring an action to obtain an injunction to restrain The Sun newspaper from printing
false allegations about him actually throwing matches, when a jury had convicted
him of conspiring to throw matches in return for bribes but not of actually having
done so. In contrast, Mr Dunning relied on Armstrong v Sheppard & Short Ltd151
in which the Court of Appeal held that the claimant’s attempt to mislead the court
about whether a conversation had taken place between him and a representative of the
defendant, which was fundamental to the claimant’s claim for an injunction, was
sufficiently closely connected. In my view these cases are simply illustrations of the
application of the principle and they do not assist further in defining its ambit.
161. Ultimately Mr Nicholls did not quarrel with the legal test that the judge adopted in
this case, as discussed at [175] – [180] of the May 2012 judgment. Mr Nicholl’s
argument is that the judge misapplied the legal principles to the facts of this case. Mr
Nicholls noted that the judge had accepted152 that SG’s misconduct did not relate to
the existence of the relevant jurisdiction clause ie. clause 13 of the FLD, nor its
construction, nor its “enforceability”, by which I think the judge must have meant
“validity”, because “enforceability” was the very matter in issue, as the judge makes
clear later in the same paragraph.
162. However, Mr Nicholls submitted that the judge erred fundamentally in finding that
the misconduct of SG in relation to the 2012 trial itself was relevant at all. Mr
Nicholls argued that the judge should not have taken SG’s misconduct in that trial into
account and, if he had left it out, then the judge would have concluded that there was
no misconduct that was sufficiently closely connected to the equitable relief claimed
to warrant a refusal to grant the anti-suit injunctions sought.
163. In my view it is vital to identify carefully the two elements with which we are
concerned; that is “the equity sued for” and “the misconduct” said to make RBS’
hands unclean. The “equity sued for” is an injunction to restrain Highland and Scott
Law from continuing to be in breach of (or in Scott Law’s case refusing to be bound
by) the jurisdiction clause in the FLD by bringing proceedings in which it is alleged
that RBS had “knowingly misrepresented material facts and withheld critical
information from [Highland] as part of [RBS’] scheme to acquire the 36 Loans at
148 Andrew Smith J at [20]. He said that in those cases the connection between the misconduct and the claim to
equitable relief was far more immediate than in the case before him.
149 8th Ed 2010
150 [2002] 1 WLR 3024.
151 [1959] 2 QB 384
152 [189] May
Annex 101
severely understated values”.153 The misconduct alleged against RBS, through SG,
falls into two Stages. First, there is the fact that RBS did not accept without
challenge the judge’s findings made in the Quantum judgment about the matters
surrounding the transfer of the 36 Loans, the BWIC and the subsequent suppression
of facts until the Quantum trial itself. Secondly, the fact of the lies of SG in the 2012
trial in trying to challenge the findings that the judge had made in his Quantum
judgment.
164. As I read [185] – [192] of the 2012 judgment, Burton J accepted that if the
misconduct of RBS (through SG) had ended with an acceptance of the conclusions
made in the Quantum trial, then he would not have regarded the misconduct of RBS
as being sufficiently immediate and having the necessary relation to the equity sued
for to fall foul of the “unclean hands” doctrine. Thus, at the start of the 2012 trial,
even though RBS might have pleaded a challenge to the various findings Burton J had
made in the Quantum trial, if RBS had then accepted them, the judge would have
held that RBS had not come to court with “unclean hands” because, to continue the
metaphor, RBS would have “washed them”. Therefore, it seems, the judge would
have rejected Highland/Scott Law’s “unclean hands” defence to RBS’ claim for an
anti-suit injunction.
165. But what tipped the balance the other way was the action of RBS in continuing to
challenge four principal findings of fact made by Burton J in the Quantum trial,
which I have summarised at [58] above, particularly through the evidence of SG in
the 2012 trial, Burton J’s reaffirmation of his Quantum judgment findings (save for
the more nuanced finding in relation to motivation for termination) and his conclusion
that SG had lied again. Does the fact that RBS persisted in challenging the judge’s
findings of fact in his Quantum judgment and its insistence that there had been no
concealment of “The Suppressed Fact” constitute misconduct and, if so, does it have
the necessary immediate and close relationship to the particular anti-suit injunction
claimed? In my view the answer to both questions is “yes” and I shall briefly explain
why.
166. First, it was RBS’ decision to continue to challenge the findings of the judge in the
Quantum judgment. It did so in particular through the key evidence of SG, who was
put forward as a “witness of truth” as to the events that occurred in 2008-9, not as a
witness who was going to explain and apologise for previous lies. Whilst I entirely
accept that counsel and solicitors acting for RBS during the 2012 trial and
subsequently have done so in complete good faith, the same cannot be said for SG.
As the judge found, he always knew the true position and he had never forgotten it.
SG’s lies and his unsuccessful attempt to explain away his conduct in November 2008
at the 2012 trial were themselves grave misconduct. Bluntly, SG perjured himself
again. His misconduct must be attributed to RBS for the reasons that I have already
given above.
167. Secondly, that misconduct is immediately or closely related to the equity sued for
because it relates, at least in part, to the very allegations being made against RBS and
SG in the Texas proceedings under Count 2 of the Petition. The aim of the anti-suit
injunction is to prevent Highland and Scott Law pursuing those allegations in the
Texas proceedings because (it is said) they agreed that all such matters would be dealt
153 See para 73 of the Texas Petition, which is part of Count 2 against RBS and Messrs Griffiths and Hall.
Annex 101
with exclusively by the English courts or (in Scott Law’s case) were bound by that
agreement. The judge has found that RBS, through SG, has lied about central
facts on which Highland and Scott Law found the allegations that are made against
RBS in the Texas proceedings. RBS, through SG, has relied on this false evidence
in the course of the English proceedings whose very object is to stop the Texas action.
To my mind the misconduct could not be more immediately related to the equity that
is sued for.
168. Thirdly, I have not lost sight of the fact that the judge analysed the nature of the
allegations being made by Highland and Scott Law in the Texas proceedings at [162]
– [169] of the May 2012 judgment. He concluded that the allegations made and the
measure of damages claimed in the Texas action were inconsistent with his
conclusions in his Quantum judgment. He also found that, insofar as Counts 2 and
3 in the Texas Petition are based on the fraud of RBS, Highland knew all the relevant
facts by the outset of the Quantum trial and so could have been pursued the
allegations then.154 The judge held that RBS had a “strong case” that, based on the
English law doctrines of res judicata, issue estoppel and the principle in Henderson v
Henderson,155 Highland and Scott Law should be precluded from bringing the Texas
proceedings in relation to all three Counts. But he held that those “strong
arguments” were not sufficient to lead to the grant of an injunction on the ground that
the Texas action was vexatious or oppressive.156 RBS has not appealed that
conclusion.
169. Fourthly, the judge also took this conclusion about the nature of the claims in the
Texas proceedings into account when considering the extent to which RBS would
suffer hardship if he were to refuse to grant it an anti-suit injunction based on breach/
non-compliance of the FLD exclusive jurisdiction clause. As I read his judgment, he
held that the “strong argument” on res judicata and so forth was insufficiently
powerful to neutralise the “unclean hands” defence. The judge held that RBS could
argue that case in the Texas proceedings. 157 It may be that Highland and Scott
Law’s position on this issue is stronger as a result of my conclusion on the Liability
judgment. However, the knock-on effect on the “unclean hands” issue of a finding
that the Liability judgment should be set aside was not elaborated in argument before
us and I do not need to explore it here, given the conclusions I have reached.
170. Fifthly, the judge also noted that Highland and Scott Law were prepared to give
undertakings not to seek multiple or punitive damages against the defendants in the
Texas proceedings “if such would be the deciding factor in my declining the grant of
an anti-suit injunction”.158 He did not say whether a refusal to give such undertakings
would have altered his overall conclusion, but that seems likely as the judge states
that the undertaking is to be recorded in the court order. In Highland’s Respondent’s
Notice it submits that the judge was wrong to require Highland and Scott Law to give
the undertaking they did and they ought to be released from their undertaking. That
point was not argued orally before us.
154 [168] and [169] May
155 (1843) 3 Hare 100; confirmed by the House of Lords in Johnson v Gore Wood & Co [2002] 2 AC 1.
156 [172] and [194(ii)] May.
157 [194(ii)] May.
158 [194(i)]
Annex 101
171. However, I would not release Highland and Scott Law from those undertakings.
Both Mr Auld and Mr Dunning accepted that if clause 13 of the FLD applies then
Highland is in breach of contract and Scott Law is bound by it. I do not have to
decide that issue finally, given my conclusion on “unclean hands”. But it seems to
me correct that we should proceed on the basis that there is, at least, a very good
argument that Highland and Scott Law are in breach of/bound by an exclusive
jurisdiction clause in favour of the English courts where the remedy of multiple and
punitive damages would not be available. Therefore, at least until that issue is
finally decided (and it is agreed that all issues of damages have to be adjourned),159
Highland and Scott Law should be kept to their undertakings.
172. Conclusion on the “unclean hands” defence. Given all these factors, I conclude
that the judge was correct to hold that the anti-suit injunction should be refused
because Highland and Scott Law could successfully rely on the defence of “unclean
hands”.
173. Other arguments advanced by Highland and Scott Law on the anti-suit
injunction. I do not need to decide these points and I am not going to go into them
in any detail. I will just outline my views very briefly.
174. The ambit of clause 13.1 of the FLD: does it extend to the claims made in the
Texas proceedings concerning the extension of the Mandate and the ISD? The
argument is that the claims comprised in the three counts in the Texas proceedings are
not disputes which “arise out of” or “in connection with” the FLD of 31 October
2007, but relate to the Mandate Letter (and its extension) and the ISD of 7 April
2007. The judge was correct in holding that the contractual documents have to be
read and construed together. He was also correct in holding that the phrase “in
connection with” has been widely construed by English courts in the context of
jurisdiction and arbitration clauses. So my view is that Burton J was correct to hold
that the ambit of clause 13.1 of the FLD is wide enough to embrace the three counts in
the Texas proceedings.
175. Is clause 13.1 of the FLD an exclusive jurisdiction clause? Mr Dunning is
obviously right to argue that it would have been much clearer if the first three lines of
clause 13.1 had read “…the Parties irrevocably agree that the courts of England shall
have exclusive jurisdiction to hear and determine any suit action or proceedings….”.
However, taking the wording of clause 13.1 as a whole and bearing in mind the
contrasting phraseology of clause 13.2, I think that clause 13.1 must be construed as
an exclusive jurisdiction clause. The use of the words “shall have jurisdiction” and
the requirement that the parties “irrevocably submit” to the jurisdiction of the English
courts (my emphasis) are powerful pointers. So also is the wording of clause 13.2
which, in my view, gives RBS an option to bring proceedings in other jurisdictions,
in contrast to the inability of other “Parties” to do so. I agree with the judge’s
conclusion on this point.
159 As Scott Law is only an assignee, it cannot, strictly speaking, be “in breach” of the jurisdiction clause,
although Mr Dunning accepted it would be bound by it if it is otherwise effective. Accordingly, although RBS
can claim damages for breach of contract against Highland, it cannot do so against Scott Law. By a proposed
amendment, RBS claimed equitable compensation/damages against Scott Law. Whether RBS should have
leave to amend was one of the matters that Burton J ordered be left over to a further hearing: see para 8(ii) of
the Order of 25 May 2012.
Annex 101
ANNEX 102

AYCEID ServicetoService
Official Trustee in Bankruptcy v Tooheys Ltd
CaseBase | (1993) 29 NSWLR 641 | BC9303945
OFFICIAL TRUSTEE IN BANKRUPTCY v TOOHEYS LTD BC9303945
Unreported Judgments NSW · 24 Pages
SUPREME COURT OF NEW SOUTH WALES COURT OF APPEAL EQUITY DIVISION
GLEESON CJ, MEAGHER AND SHELLER JJA
CA 40417/91
9 and 10 February 1993, 18 March 1993
Headnotes
EQUITY — Estoppel by Conduct — expectations created by lessor's conduct towards lessee — fraudulent
misstatement by party relying on expectation — not unconscionable for lessor to fail to make good
representations — no estoppel arose — unjust enrichment — lessors consequent enrichment not unjust.
EQUITY — Constructive Trust — constructive trust did not arise — Equitable Maxim "He who comes to
equity must have clean hands" — fraudulent misstatement by lessees was disentitling conduct — sufficient
connection between fraud and equity sue for to bar relief.
EQUITY — ESTOPPEL BY CONDUCT — CONSTRUCTIVE TRUSTS — hoteliers acquired a brewery lease of
a hotel at a time when industry practices, to which the brewery was a party, involved representations that
brewery tenants would have security of tenure notwithstanding the terms of their leases — these practices
and representations created a goodwill for which incoming tenants were prepared to pay ~ however, the
hoteliers in question made certain false and material misrepresentations to the brewery — the trial judge
declined to find an estoppel or a constructive trust as claimed because of the false representations —
HELD — the false representations by the hoteliers meant that the brewery's representations did not give
rise to an estoppel; alternatively, the doctrine of unclean hands meant that the hoteliers, claim to a
constructive trust must fail.
George Whitechurch v Cavanagh [1902] AC 117
Hewson v Sydney Stock Exchange (1967) 87 WN (NSW) 422 applied
Gleeson CJ
The issue in this appeal concerns the circumstances in which a court will decline to find and enforce an estoppel by
representation on the ground that the person in whose favour such an estoppel would otherwise have arisen was
himself guilty of misrepresentation.
The appellant commenced proceedings in the Equity Division in his capacity as trustee of the bankrupt estates of
Mr and Mrs B L Williams. The respondent, a brewery owner, had sold a certain hotel, and the appellant claims that
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OFFICIAL TRUSTEE IN BANKRUPTCY v TOOHEYS LTD
AYCEID ServicetoService
part of the proceeds of sale should be regarded as being subject to a constructive trust in favour of Mr and Mrs
Williams. Bryson J concluded that the appellant would otherwise have succeeded in making out all the elements
necessary to substantiate such a claim, but that the claim should be dismissed on the ground that Mr and Mrs
Williams had induced the
BC9303945 at 2
respondent to participate in the original dealings upon which the appellant's claim was based by fraud.
The appellant does not challenge the findings of fact made by Bryson J as to the fraudulent misrepresentations, and
the respondent does not call into question Bryson J's conclusion that, but for the misrepresentations, the claim as to
a constructive trust would have been made out. The sole issue in the appeal concerns, the legal effect of the
misrepresentations that were made to Tooheys Ltd by or on behalf of Mr and Mrs Williams.
In order to explain how the problem arose it is necessary to refer to some features of the industry background
against which the dealings in question took place.
The goodwill attaching to a brewery lease:
For many years the two major breweries in New South Wales were Tooheys Ltd and Tooths & Co Ltd. In 1979
those two companies were parties to proceedings in the Trade Practices Tribunal seeking authorisation of their tied
house system. The report of the Trade Practices Tribunal, which appears at (1979) ATPR 40-113, is a useful
source of information as to then current industry practice. It contains (at 18,205) the information that both breweries
had a strong preference for operating their hotels under lease. There were a few hotels that were operated by
managers employed by the breweries, but almost all brewery hotels were operated
BC9303945 at 3
under lease. A senior officer of Tooheys explained that the company considered that lessees were better able to
maximise the potential of a hotel. There was a strong demand for tenancies, and the breweries, in their own
interest, engaged in practices which stimulated and maintained that market. They permitted renewal and
assignment of leases to suitable persons. The breweries dealt with their tenants in a variety of ways that were more
favourable than would have been the case had they enforced their rights under the leases. In particular, they
fostered a system under which an incoming tenant would pay an outgoing tenant a substantial sum for the goodwill
of a hotel business.
Brewery leases were typically of a relatively short term, such as one year, and, when their leases expired, tenants
would commonly hold over from month to month or week to week. In those circumstances one might wonder how it
was that, when the lessee of a hotel decided to sell out, the incoming tenant, who was only going to get the
unexpired portion of a short term lease, or a new lease for a short term, would have been prepared to pay a
substantial sum for the goodwill of the hotel business. Leaving to one side questions of possible default by the
lessee, on the face of the relevant contractual documents the brewery would have been entitled to resume
possession of the hotel after a short time. That, however, was not the way things worked in practice.
For reasons that will appear below, between 1987 and 1989, following a takeover of Tooheys by another company
BC9303945 at 4
and a change in Tooheys commercial practices, there was a deal of litigation between Tooheys and its tenants. In
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OFFICIAL TRUSTEE IN BANKRUPTCY v TOOHEYS LTD
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the course of that litigation the nature of the commercial practice that had been engaged in by Tooheys became
well established, and in these proceedings it was agreed that Bryson J should draw upon earlier decisions for
information in that respect. The following is a summary of that information. Because of the limited issue in the
appeal it is adequate for present purposes, although it may require elaboration or qualification in other contexts.
In brief, Tooheys adopted a policy that, at least so long as a tenant was satisfactory, the tenant was treated as
having security of tenure, notwithstanding the legalities of the leasing arrangements in force. The corollary was that
the goodwill of the hotel business in question was treated as being marketable by tenants, and an outgoing tenant
could expect to be paid by an incoming tenant a substantial sum, based upon the turnover of the business. Thus,
for example, leaving to one side the possibility of serious default by the lessee, Tooheys would never resume
possession of a tenanted hotel, at least without paying an amount of compensation to the tenant calculated on the
basis that the goodwill of the business belonged to the tenant. Similarly, Tooheys facilitated the transfer of
tenancies to approved transferees, and in doing so obtained information as to the financial arrangements
concerning such transfers. Tooheys knew that those arrangements normally included a
BC9303945 at 5
payment by the transferee to the transferor of a sum for goodwill.
It is unnecessary for present purposes to examine the precise nature of the concept of goodwill in this context (cf
Carlton & United Breweries Ltd v Tooth & Co Pty Ltd(1985-1987) 7 IPR 581 at 595-599). In commercial terms, there
was an established market in brewery leases, and a brewery lessee who sold a hotel business could expect to
receive, in addition to the value of any tangible assets transferred, a consideration related to the size of the
business, notwithstanding that, in legal terms, all that the lessee had to assign was the balance of a short term
lease. This market was sustained by a well understood practice according to which Tooheys refrained from
exercising their strict legal rights as landlords. The practice was to the commercial advantage of Tooheys because it
supported the system of hotel leases, which they saw as being to their benefit, and it enabled them to obtain higher
rents from tenants.
The relevant transaction:
That was the industry background against which Mr and Mrs Williams, in 1983, became the lessees of the Speers
Point Hotel. The previous lessee was Doiko Pty Ltd, and Mr and Mrs Williams agreed to purchase the hotel
business from that company. The price they agreed to pay was $400,000 apportioned as to $56,000 to furniture,
plant and effects and as to $344,000 to
BC9303945 at 6
goodwill. The manner in which the purchasers were arranging finance, and the representations they made to
Tooheys as to the amount of finance they intended to obtain, are matters of central importance to the issue in the
appeal. For present purposes, however, what is to be noted is that, as Tooheys were made aware, the purchasers
paid to Doiko Pty Ltd a substantial sum for goodwill. Mr and Mrs Williams were subsequently granted a lease of the
hotel for a term of one year. When that period expired they held over as tenants from month to month. They
remained in occupation until April 1987.
Mr & Mrs Williams did not make a financial success of the hotel. They encountered difficulties for three main
reasons. First, the weekly takings of the business were lower than had been expected. Secondly, they borrowed
heavily to buy the business (far more heavily than they had led Tooheys to believe) and they were not able to sell
other assets in order to relieve their burden of debt. Thirdly, at a time when, in the ordinary course, they would have
expected to have been able to sell out of the hotel, their expectations were defeated by the change in Tooheys
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policy which gave rise to this litigation, and to the other court cases earlier mentioned.
The change in Tooheys policy:
Tooheys Ltd was taken over by the Bond group in 1985. At some time thereafter, for reasons that are not presently
material, an announcement was made that Tooheys
BC9303945 at 7
no longer recognised goodwill attaching to hotel leases and, at least by implication, that henceforth hotel lessees
could expect Tooheys to deal with them on the basis of the legal rights and obligations as set out in their leases.
This had a damaging effect upon the market for hotel leases and produced the result, amongst other things, that Mr
and Mrs Williams found it impossible to sell out of the Speers Point Hotel, at least on terms that would enable them
to recoup the money they had paid for goodwill.
A number of tenants of Tooheys hotels banded together to resist the change in policy, and they were relatively
successful. In various actions commenced by Tooheys against tenants, following the expiry of leases, to recover
possession of hotels, the tenants pleaded successfully that Tooheys was by its contract estopped from exercising
its rights under its leases without paying compensation in an amount that reflected the value of the goodwill for
which the tenants had paid and which had, in substance, been expropriated by Tooheys. An example of such a
case was Bond Brewing (NSW) Pty Ltd v Reffell Party Ice Supplies Pty Ltd which was decided by Waddell CJ in Eq
in August and September 1987. The relevant lease had expired and the brewery brought proceedings in ejectment
against the tenant. The trial judge held that the defendant had made out a case of estoppel, in the nature of
promissory estoppel, and that, in consequence, although the plaintiff was entitled to judgment for possession of the
hotel premises, the
BC9303945 at 8
defendant was entitled to an order that execution on the judgment should be stayed until the plaintiff had
compensated the defendant by paying a reasonable sum to reflect the value of the goodwill which the business
would have retained if the plaintiff had adhered to the representations inherent in the practices earlier described.
Unlike some of the other tenants, Mr and Mrs Williams lacked the financial strength to maintain the fight. They left
the Speers Point Hotel without any ejectment proceedings having been taken against them. However, in a finding
that was not challenged on this appeal, Bryson J held that, although they were not directly compelled by Tooheys to
leave, they were as effectively forced out by Tooheys as if Tooheys had sent in bailiffs and changed the locks. In
this respect his Honour was referring to the conduct of Tooheys involved in its change of policy, which made it
impossible for tenants in financial difficulties to sell out. His Honour said:
"As the Williams' financial affairs failed they made endeavours to seek some way out of their difficulties in dealings
with (their financiers) and with Tooheys Ltd, but these endeavours came to nothing as they were bound to do in the
presence of the dominating reality that the only thing that the Williams owned and had paper to show for was a
holding-over on an expired lease; they had no opportunity to sell the business and transfer anything of value without
the cooperation of the defendant, and it was notorious in the industry that the defendant had had a radical change
of policy and would not participate in or facilitate transfers."
BC9303945 at 9
Following the departure from the hotel of Mr and Mrs Williams, Tooheys sold the freehold of the hotel. Included in
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the consideration received from the purchaser was a substantial sum referable to the goodwill of the hotel business.
The relief claimed:
Following the success achieved in litigation by those tenants who had remained in possession and fought Tooheys,
and following the bankruptcy of Mr and Mrs Williams, the present appellant commenced these proceedings. The
precise nature of the relief sought appears from the orders which this Court was asked to make in the event that the
appeal succeeded:
"DECLARATIONS
1 That during the subsistence of the lease of the Speers Point Hotel at Speers Point dated 10 August 1983 from the
Respondent ('Tooheys') to Brian Leslie Williams and Rita Anne Williams ('Mr and Mrs Williams') and the period of
holding over until the departure of Brian Leslie Williams and Rita Leslie Williams on 12 April 1987, (alternatively
'during the period of subsistence of the Lease of the Speers Point Hotel dated 10 August 1983 from the
Respondent ('Tooheys') to Brian Leslie Williams and Rita Anne Williams ('Mr and Mrs Williams') from and after
January 1986') the Respondent was estopped from denying to Mr and Mrs Williams:
(a) That the leasehold interest in the said Hotel premises for the time being in existence and the goodwill of the
business for the time being conducted thereon were together freely saleable and transferable at any future time
during which the same were held by Mr and Mrs Williams and by any transferee thereof including any transferee
from Mr and Mrs Williams of whom Tooheys approved in pursuance of an obligation on its part to give bona fide
consideration to any such approval;
BC9303945 at 10
(b) That the leasehold interest in the said Hotel premises for the time being in existence would not be terminated or
otherwise brought to an end by Tooheys and the goodwill of the business for the time being conducted thereon
would not be acquired by Tooheys, whether the same be in the possession of Mr and Mrs Williams or any such
successors in title, and irrespective of any then existing default in relation to such leasehold interest at least on the
part of Mr and Mrs Williams, without Tooheys compensating Mr and Mrs Williams or any such successors in title for
the value of such leasehold interest and goodwill at the time of termination and acquisition calculated upon the
basis of the security of tenure referred to in para(a) above.
2 That In the events which happened as found by Bryson J in the proceedings in his Judgment delivered 24 June
1991, Tooheys became obliged from and after 13 April 1987 to pay or account to Mr and Mrs Williams for an
amount equal to the value as at that date of the tenure and goodwill relating to the Hotel calculated upon the basis
of their rights declared in para(a) and para(b) of Declaration 1
3 Alternatively to 2, in the events which happened as found by Bryson J in the proceedings in his Judgment
delivered 24 June 1991, Tooheys became obliged from and after 27 June 1988 to pay or account to the Official
Trustee In Bankruptcy for an amount equal to the value as at that date of the tenure and goodwill as a component
of the sale price relating to the Hotel calculated upon the basis of the rights Mr and Mrs Williams declared in para(a)
and para(b) of Declaration 1.
ORDERS THAT
4 There be referred to his Honour the Trial Judge the determination of the values referred to in Declarations 2 and
3.
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5 That Tooheys pay to the Official Trustee in Bankruptcy the valuation sums referred to in Declarations 2 or 3, as
determined pusuant to O4."
Had it not been for the defence to be considered below, Bryson J would have granted the relief sought. Following
the earlier decisions of the Chief Judge in
BC9303945 at 11
Equity and other judges, his Honour would have held that Tooheys was, by its conduct in 1983, estopped from
denying what might be described in summary form as the security of tenure necessary to enable Mr and Mrs
Williams to sell the goodwill of the business of the Speers Point Hotel on the same basis as they had originally
acquired it. By turning the tenants out of the hotel and otherwise acting in a manner inconsistent with the
representations giving rise to that estoppel Tooheys produced the result that the goodwill of the business was no
longer something of value to the tenants. It was, however, something for which a purchaser of the freehold of the
hotel was prepared to pay; but the recipient of such payment was Tooheys. A court would intervene by imposing a
constructive trust upon the monies received by Tooheys when it sold the hotel so as to give Mr and Mrs Williams, in
effect, an amount equivalent to the amount of compensation which Tooheys had been ordered to pay the other
tenants who resisted claims for possession. Bryson J described the process of reasoning that he would have
followed in these words:
"The defendant would be treated as becoming a constructive trustee of the Williams' interest in the goodwill at the
point on 13 April 1987 where the defendant took control of it; the defendant would not be admitted to say but would
be estopped from saying that it took control of it in its own interest, or that when it sold the hotel it had disposed of
the goodwill element for its own benefit, and would be accountable for the part of the proceeds of sale which is
attributable to the goodwill. The quantification of the amount for which the defendant is accountable would require
some careful further consideration, but it is a valuing question and it is not in principle
BC9303945 at 12
difficult to recognise the appropriate form of relief, which would be granted on much the same basis as if the trust
has been an express trust."
Neither party to the appeal was concerned to challenge this process of reasoning, and it is therefore unnecessary to
analyse it further. What is significant for the purpose of the appeal is that the appellant's claim for relief, which had
its foundation in representations made by Tooheys as to the way in which it would deal with Mr and Mrs Williams,
was based, not on contract, but on principles of estoppel by conduct of the kind considered by the High Court in
Legione v Hateley (1983) 152 CLR 406; Waltons Stores (Interstate Ltd) v Maher (1988) 164 CLR 387 and The
Commonwealth of Australia v Verwayen (1990) 170 CLR 394. The ultimate relief sought, the imposition of a
constructive trust, was equitable relief (cf Kettles and Gas Applicances Ltd v Anthony Horden & Sons Ltd (1934) 35
SR (NSW) 108 at 129).
The successful defence:
The appellant failed at first instance for the following reason.
When, in 1983, Mr and Mrs Williams took over the lease of the Speers Point Hotel from Doiko Pty Ltd, and bought
the goodwill of the business, the transaction required the approval of Tooheys. The evidence showed that, whilst
Tooheys engaged in the practices described above, and dealt with brewery tenants more favourably than the
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tenants were entitled to under their leases, at
BC9303945 at 13
the same time Tooheys closely monitored the financial arrangements between outgoing and incoming tenants, and
the ability of tenants to make those arrangements depended in practice upon the approval of Tooheys. One matter
that was of particular interest to Tooheys was the extent to which an incoming tenant needed to borrow the funds to
be used for the purchase.
After the present proceedings had been commenced, Tooheys discovered that Mr and Mrs Williams, and the
brokers in the transaction, had misrepresented to Tooheys some of the financial arrangements including, in
particular, the extent of the finance which the purchasers needed. It was represented to Tooheys that the total
purchase price was $350,000 whereas in truth it was $400,000. More important, Tooheys were told that the
purchasers were borrowing $130,000 whereas in truth they were borrowing more than three times that amount.
Tooheys had a policy that they would not approve a transferee who was borrowing more than fifty percent of the
purchase price. Bryson J accepted that, had Tooheys been aware of the true nature of the financing arrangements
entered into by Mr and Mrs Williams, Tooheys would not have approved the transfer of the hotel business to them.
His Honour found that Mr and Mrs Williams had fraudulently misrepresented to Tooheys the nature of the financial
arrangements into which they were entering for the purpose of the transaction and that Tooheys were thereby
induced to approve the transfer of the hotel business to them and to accept them as tenants.
BC9303945 at 14
There is no challenge to these findings. Bryson J went on to hold that, as a consequence, the appellant was not
entitled to the relief claimed in the proceedings. It is that conclusion which forms the subject matter of the appeal.
Bryson J rested his decision upon two grounds. First, he held that the misrepresentations made by Mr and Mrs
Williams to Tooheys produced the consequence that it was not unconscionable for Tooheys to fail to fulfil the
expectations which Tooheys had, by its conduct, created. Those expectations, his Honour said, were based on
fraud and deceit and had no equitable claim to fulfilment. Secondly, his Honour said that the same result would flow
from the application of the maxim that he who comes to equity must come with clean hands.
Conclusion:
In Spencer Bower and Turner, Estoppel by Representation, 3rd ed, p137 the following statement of principle
applies:
"If the representation is proved by the representor to have been the result of fraudulent representation, whether in
language or by conduct, on the part of the representee, a good answer is established to an estoppel which might
otherwise have arisen."
There is ample authority to support this proposition (eg George Whitechurch Ltd v Cavanagh [1902] AC 117 at 145,
Porter v Moore [1904] 2 Ch 367). Expressed in terms of what Deane J said in The Commonwealth v Verwayen (170
CLR at 444) described as the central principle of the
BC9303945 at 15
doctrine of estoppel by conduct, the reason is that it is not unconscientious of a party to depart from an assumption
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that has been adopted by the other party as the basis of some conduct, even though such departure would operate
to that other party's detriment, if the other party procured the assumption by fraud.
It was argued on behalf of the appellant that the proposition is too broad. Two reasons were advanced in support of
that argument.
It was contended that the analogy of contract law exposes the injustice of an inflexible application of such a rule.
Suppose, it was said, that the representations relied upon by the appellant had taken the form of contractually
binding stipulations. It would be inaccurate, and an over simplification, to say that the stipulations could not be
enforced because the contract was entered into as a result of fraud. Questions of restitution would arise, and here
Tooheys is not offering to put Mr and Mrs Williams back into the position they were in before the relevant
transaction. A related submission was that the case is one of unjust enrichment of Tooheys, and equity would not
permit such an outcome.
It is true that a contract induced by fraud is voidable, not void, and that a party to a contract who is a victim of fraud
may find that the relief available depends upon the circumstances, which might include the possibility of restitution.
It is also true that a party who has induced another to enter into a contract by fraud
BC9303945 at 16
is not thereby necessarily, and absolutely, barred from relief in the event of breach. That is simply the corollary of
the proposition that the contract is voidable, not void. However, the analogy with the law of contract is apt to be
misleading. The law of contract is governed by a variety of rules, some having their origin in common law and some
in statute, which have no bearing upon a claim such as that made by the appellant. Furthermore, if Mr and Mrs
Williams had contracted with Tooheys about the matters in issue there is no way of knowing what conditions or
qualifications Tooheys might have attached to the obligations they undertook, or how those obligations might have
been related to the representations made as to the Williams' financial position and arrangements. The contract
might have expressly provided that the obligation of Tooheys to honour its undertaking as to security of tenure was
conditional upon the truth of the representations made as to the Williams' financial position. The parties would have
been free to contract as they chose, and there is no justification for assuming one particular form of contract and
comparing the outcome decided upon by Bryson J with the outcome under such a contract.
The assertion that the result contrived for by the respondent is unjust enrichment begs the question. If it is not
unconscionable for Tooheys to treat itself as no longer bound to honour its representations as to security of tenure,
for the reason that Tooheys itself had been tricked into accepting Mr and Mrs Williams as tenants in
BC9303945 at 17
the first place, then any consequent enrichment is not unjust. The cards are simply left to lie where they have fallen.
That is frequently an outcome which the law regards as just.
There is a deal of force in the appellant's submission, as a matter of theory, that the statement of principle referred
to above may be too inflexible. The rule was originally propounded at a time when the role of estoppel was
somewhat more limited than is now the case. Recent cases have emphasised the flexibility of equitable estoppel as
an instrument of justice (Amalgamated Property Co v Texas Bank [1982] 1 QB 84 at 103 per Robert Goff J, The
Commonwealth v Verwayen (1990) 170 CLR 394 at 412 per Mason CJ and at 442 per Deane J). The concept of
unjust enrichment is becoming more influential in legal theory. In that connection it is of interest to note that,
speaking in relation to the law of contract, Lord Wright gave unjust enrichment as the reason why a buyer of goods
who has been defrauded cannot recover the purchase price without returning the goods. (Spence v Crawford [1939]
3 All ER 271 at 288-9).
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The central question is whether, in all the circumstances, it would be unconscionable for Tooheys to fail to make
good the representations as to security of tenure on the basis of which Mr and Mrs Williams bought the goodwill of
the hotel business from Doiko Pty Ltd. In order to answer that question in the negative it is not necessary to hold
that any false representation would justify Tooheys in failing to honour
BC9303945 at 18
its own representations. The fraudulent representations in the present case went to the essence of Tooheys'
interest in the contract between outgoing and incoming tenants; they went to the financial capacity of the incoming
tenants to make a success of the business.
The alternative way of looking at the matter is by reference to the principle that he who comes to equity must come
with clean hands. The application of that principle as a bar to discretionary equitable relief has been considered in
such cases as Myers v Casey (1913) 17 CLR 90, Hewson v Sydney Stock Exchange (1967) 87 WN (NSW) 422 and
FAI Insurances Ltd v Pioneer Concrete Services Ltd (1987) 15 NSWLR 552. The unmeritorious conduct which
debars relief is not "general depravity"; it must be conduct which has "an immediate and necessary relation to the
equity suited for" (Derring v Earl of Winchelsea (1787) 1 Cox 318 at 319; See also Keystone Co v Excavator Co
(1933) 290 US 240). On that test, the present case is one in which the relationship between the false
representations and the equity sued upon is sufficiently close to establish the defence. There is a clear and close
connection between the misrepresentations made to Tooheys and Tooheys' willingness to participate in the
transaction out of which the alleged estoppel arose.
In the circumstances of this case I see no significant difference between the two alternative approaches to the
defence on which the respondent relies. Bryson J was correct to conclude, as he did, that the
BC9303945 at 19
appellant must fail by reason of the fraud that had been practised upon Tooheys.
There was a complaint about his Honour's order that the appellant pay the costs of the action, bearing in mind his
success on most of the issues that were litigated. However, I see no error in his Honour's discretionary judgment on
this matter. Failure on the ground of fraud is not an auspicious launching pad for such an argument.
The appeal should be dismissed with costs.
BC9303945 at 1
Meagher JA
I agree with the Chief Justice.
Sheller JA
BC9303945 at 1
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I have had the benefit of reading the judgment prepared by the Chief Justice. I agree that the appeal should be
dismissed with costs. The facts of the case and the practice of dealing in what over many years has been treated in
the market for brewery leases as goodwill are set out in his Honour's judgment and I need not repeat them in detail.
On 29 June 1983 the appellants, Mr and Mrs Williams, agreed to purchase the business at the Speers Point Hotel
from Doiko Pty Ltd, then the lessee from Tooheys. The purchase price of $400,000 was apportioned as to $344,000
for goodwill. On 18 August 1983 Tooheys entered into a written agreement to grant the appellants a lease for
twelve months. The appellants agreed to pay such an amount for goodwill and to accept a lease of so short a term
in the expectation that they would have from Tooheys security of tenure at least to the extent necessary to enable
them to sell the goodwill of the business on the
BC9303945 at 2
same basis as they had acquired it. This expectation was encouraged by Tooheys and derived from assumptions
adopted, by the convention of the parties, as the basis of their relationship; see Spencer Bower and Turner,
Estoppel by Representation, 3rd ed 1977, at 157 quoted by Brandon LJ, as he then was, in Amalgamated
Investment and Property Co Ltd v Texas Commerce International Bank Ltd [1982] 1 QB 84 at 130-1. The appellants
left the premises on 13 April 1987 and Tooheys resumed possession. Their claim is not that they were wrongly
evicted but that they were denied by Tooheys the opportunity to fulfil their expectation that they would be
compensated for their outlay by being able to sell the goodwill of the business. However Tooheys' encouragement
of the appellants and adoption of the assumptions upon which the relationship of the parties was based was
induced by the fraudulent and deceitful misrepresentations of the appellants. Lord Brampton in George Whitechurch
Ltd v Cavanagh [1902] AC 117 at 145 said: " ... no representations can be relied on as estoppel if they have been
induced by the concealment of any material fact on the part of those who seek to use them as such; and if the
person to whom they are made knows something which, if revealed, would have been calculated to influence the
other to hesitate or seek for further information before speaking positively, and that something has been withheld,
the representation ought not to be treated as an estoppel.' So Tooheys argued that even if its conduct in going
back, to the detriment of the appellants, on the conventional basis of the relationship adopted by the parties would
otherwise call for a remedy, as Bryson J thought, it did not do so once it was demonstrated that the convention was
induced by the fraud of the appellants.
I do not think inducement by a claimant's fraud or deceit inevitably defeats a claim based upon what would
otherwise be the
BC9303945 at 3
unjust or unconscionable conduct of a party who departs or withdraws from a convention adopted by the parties as
the basis of their relationship. The resolution of whether it does calls for an examination of all the circumstances of
the case. Had Tooheys relied on fraud to rescind the agreement for lease equity may have exacted a price for
reasons inherent in the equitable nature of the relief sought; Mayfair Trading Co Pty Ltd v Dreyer (1958) 101 CLR
428 at 452. But Tooheys made no such claim. Had the payment for goodwill been made to Tooheys, it may have
been obliged, on a claim by the appellants for restitution, to pay compensation for the benefit it derived. But the
payment was made to a third party, the outgoing tenant. The claim made by the appellants is that they be
compensated for the loss of their expected recoupment, by resale of the business, of moneys outlaid. The relief
chosen is the imposition of a constructive trust upon the proceeds of sale of the hotel and the business conducted
there. The success of such a claim depends at least upon its being unjust or unconscionable in all the
circumstances of the case for Tooheys to retain the whole of these proceeds of sale. One circumstance to be
considered is the convention adopted as the basis of the relationship of the parties and giving rise to the
expectation of recoupment. Another circumstance is that this convention was induced by the fraud of the appellants.
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The last is, in this case, a decisive consideration. Tooheys received from the appellants in return for its being party
to the convention not a payment of money which it then sought to retain in addition to the proceeds of sale, but the
appellants' assurance as to the financial arrangements they had made. This assurance satisfied Tooheys and led to
its approving the transaction and granting the lease. The appellants in fact deceived Tooheys about their financial
arrangements. As the Chief Justice has pointed out Bryson J accepted that, had Tooheys been
BC9303945 at 4
aware of the true nature of the financing arrangements entered into by the appellants, it would not have approved
the transfer of the hotel business to them. In the circumstances the relief sought was rightly refused. Accordingly, I
agree that the appeal should be dismissed with costs.
Order
The appeal is dismissed with costs.
Counsel for the appellant: R A Conti QC, H A Coonan, R Sofroniou
Solicitors for the appellant: Slater & Elias
Counsel for the respondent: P M Jacobson QC, D R Pritchard
Solicitors for the respondent: Freehill, Hollingdale & Page
End of Document
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ANNEX 104

From: Oxford Public International Law (http://opil.ouplaw.com). (c) Oxford University Press, 2015. All Rights Reserved.
Subscriber: Honourable Society of Gray's Inn; date: 05 July 2019
Date: 03 July 2002
Citation(s): Civil Appeal No 459/2002 (Official Case No)
Civil Appeal No 460/2002 (Official Case No)
2002 SCMR 1694 (Other Reference)
ILDC 82 (PK 2002) (OUP reference)
Content type: Domestic court decisions
Product: Oxford Reports on International Law [ORIL]
Module: International Law in Domestic Courts [ILDC]
Jurisdiction: Pakistan [pk]; Supreme Court
Societe Generale de Surveillance SA v Pakistan,
through Secretary, Minister of Finance, Revenue
Division and Islamabad, Appeal to Supreme Court,
Civil Appeal No 459/2002, Civil Appeal No
460/2002, 2002 SCMR 1694, ILDC 82 (PK 2002),
3rd July 2002, Pakistan; Supreme Court
Parties: Societe Generale de Surveillance SA
Pakistan, through Secretary, Minister of Finance, Revenue Division (Pakistan [pk]), Islamabad
(Pakistan [pk])
Judges/Arbitrators: Munir A Shiekh; Qazi Muhammad Farooq; Abdul Hameed Dogar
Procedural Stage: Appeal to Supreme Court
Previous Procedural Stage(s):
Judgment of Lahore High Court, Rawalpindi Bench, First Appeal, Order; Societe Generale de
Surveillance SA v Pakistan, No 9, 2002; 2002 CLD 790, 14 February 2002
Order; Societe Generale de Surveillance SA v Pakistan, 7 January 2002
Subject(s):
International procedure 􀞂 International investment law 􀞂 􀀨stoppel 􀞂 􀀷reaties, application 􀞂 􀀷reaties,
interpretation 􀞂 Conflicts between 􀞂 Arbitral agreements
Core Issue(s):
Whether international treaty and conventional law prevailed over municipal Pakistani law.
Whether an arbitration agreement between the parties was binding in view of a Bilateral Investment
Treaty.
Annex 104
From: Oxford Public International Law (http://opil.ouplaw.com). (c) Oxford University Press, 2015. All Rights Reserved.
Subscriber: Honourable Society of Gray's Inn; date: 05 July 2019
Whether the right to seek remedy before the International Centre for the Settlement of Investment
Disputes (􀞆ICSID􀞇) has been waived.
Oxford Reports on International Law in Domestic Courts is edited by:
Professor André Nollkaemper, University of Amsterdam and􀁢 August Reinisch, University of Vienna.
Annex 104
From: Oxford Public International Law (http://opil.ouplaw.com). (c) Oxford University Press, 2015. All Rights Reserved.
Subscriber: Honourable Society of Gray's Inn; date: 05 July 2019
Facts
F1􀁢 Societe Generale de Surveillance SA (􀞆SGS􀞇) entered into an agreement with the
government of Pakistan for services of pre-shipment inspection of all consignments to
Pakistan.
F2􀁢 The agreement was terminated by Pakistan on 12 December 1996.
F3􀁢 Although the agreement contained an arbitration clause, SGS filed a civil suit against
Pakistan in the court of first instance in Geneva for the recovery of US$368,430.49.
F4􀁢 The civil suit was rejected by the Swiss court. On 7 September 2000, Pakistan filed an
application under Section 20 of the Arbitration Act, 1940, before the civil judge at
Rawalpindi, to file the arbitration agreement in Court and to appoint an arbitrator in order
to commence the contractual arbitration as agreed between the parties. Meanwhile, SGS
filed an appeal before the Swiss Supreme Court, but that appeal was also rejected. SGS
filed its reply to the Section 20 application on 10 October 2001, contesting the application
filed by Pakistan.
F5􀁢 SGS, on 12 October 2001, sought to institute an ICSID arbitration on the ground that
that, by virtue of the Bilateral Investment Treaty, 11 July 1995 (􀞆BIT􀞇) between the Swiss
Confederation and Pakistan, Pakistan was bound to submit to arbitration. This request was
registered on 12 November 2001. SGS on 4 January 2002 made an application before the
civil judge at Rawalpindi to stay the proceedings under Section 20 on the grounds that the
ICSID arbitration had commenced. The civil judge dismissed the application of SGS on 7
January 2002 and ordered SGS to nominate arbitrators.
F6􀁢 SGS filed an appeal before the Lahore High Court at Rawalpindi. The High Court held
that a process which had already commenced could not be reversed even under the BIT or
the Convention on the Settlement of Investment Disputes Between States and Nationals of
Other States (18 March 1965) 575 UNTS 159, entered into force 14 October 1966 (􀞆ICSID
Convention􀞇), as the contractual arbitration was initiated earlier in time and would prevent
the parties from going to the ICSID. The High Court held that choice of forum would prevail
where parties had not initiated judicial proceedings for arbitration. It also held that because
SGS first went to the Swiss court, and then filed an objection and raised a counterclaim to
Pakistan's application under Section 20, SGS had waived its right to institute ICSID
proceedings.
F􀀚􀁢 The appeal filed by the SGS before the Lahore High Court was dismissed by an order
dated 14 February 2002. The Judge of the High Court came to the conclusion that no
domestic law had been enacted to give effect to the ICSID Convention or the BIT, and that
therefore their legal efficacy was but that of an instrument of administrative nature which,
as such, could not be enforced as law.
F8􀁢 SGS then filed the present Leave to Appeal before the Supreme Court of Pakistan
against the order of 14 February 2002. Leave was granted to consider whether the
arbitration agreement between the parties was binding upon the parties notwithstanding
the BIT, and further to consider whether the trial court had been right in holding that SGS
was not an 􀞆investor􀞇 within the meaning of that word under the BIT. The third and final
issue was whether the SGS had waived its right to go to the ICSID.
Annex 104
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F9􀁢 The Attorney-General of Pakistan argued on behalf of Pakistan that Pakistani courts
could not take note of the violation of any provision of international agreement or law in the
absence of any relevant provision of domestic law. Courts in Pakistan were bound to give
effect to municipal law. He argued that international agreements could only be enforced
where there was legislation in the country. In support of his contention he relied upon
Maclaine Watson and Co v Department of Trade and Industry, and the related appeal in
Maclaine Watson v International Tin Council, (1989) 3 All ER 523. He further relied upon
numerous examples of intervening legislation to incorporate the provisions of conventions
and treaties in Pakistan. It may be noted that when the Attorney-General argued this case
before the High Court, he had also referred to Article 69 of the BIT, which provides that
each contracting State will take legislative measures to give effect to the provisions of the
BIT.
F10􀁢 Counsel for SGS argued that Pakistan had entered into the BIT with the Swiss
Confederation on 11 July 1995, which provides that all disputes related to investment may
be resolved through ICSID arbitration. He argued that by reason of its own omission,
Pakistan could not avoid the enforcement of the provisions of a treaty. He further argued
that ratification of a treaty amounted to giving that treaty status of law. Counsel for SGS
sought to persuade the Court that, by virtue of a unilateral act of Pakistan, Pakistan, having
failed to incorporate the treaty into domestic law, should not be allowed to take advantage
of such omission. Having once ratified a treaty, that amounted to giving that treaty the
status of law. For this, counsel for SGS relied upon Article 97 of the Constitution, Pakistan,
which provided that the Executive Authority of the Federation should extend only to those
matters with respect to which Parliament can make laws. The Fourth Schedule of the
Constitution embodied the list of such matters with respect to which Parliament can make
laws, and it included the implementing of treaties and agreements.
Held
􀀫1􀁢 The provisions of the BIT could not have the effect of altering the existing law and the
rights arising therefrom as there was no intervening legislation incorporating the treaty
into the laws of the country by way of statute. Therefore, the BIT could not be enforced
through the courts, as the courts did not have the power to do so. (paragraph 23)
􀀫2􀁢 Intervening legislation was necessary in order to enforce the terms and conditions of
an international agreement. The rights arising under a treaty could not be enforced through
a court of law unless the provisions of the treaty had been incorporated through legislation
into the laws of the country. The rights and obligations under the treaty must become a part
of the municipal law of the country through legislation in order for a court to enforce it.
(paragraph 28)
􀀫3􀁢 Article 175(2) of the Constitution of Pakistan provides that no court shall have
jurisdiction unless conferred upon it by or under any law or the Constitution. Therefore,
unless the treaty was incorporated into the law to become part of the municipal law, no
court shall have jurisdiction to enforce rights arising thereunder. (paragraph 23)
􀀫4􀁢 SGS had waived its rights to seize the ICSID court by filing the recovery suit before the
Swiss courts, and by filing the reply and counterclaim to Pakistan's application under
Section 20 of the Arbitration Act. (paragraphs 57, 59, 60)
Date of Report: 31 August 2006
Reporter(s): Ayesha Malik
Annex 104
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Analysis
A1􀁢 This case was one of the leading cases in Pakistan on international commercial
arbitration and on the treatment of international agreements by domestic courts.
A2􀁢 The preliminary issue in the case was the treatment of international agreements by
domestic courts. Currently, the settled position under Pakistan law is that Pakistani courts
cannot take note of the violation of any provision of an international agreement or
international law in the absence of any relevant provision of domestic law. (This would
include customary international law, although the judgment did not expressly refer to
customary law.) Therefore, courts in Pakistan were bound to give effect to municipal law.
A3􀁢 According to the Court, international agreements could only be enforced where there
was implementing legislation in the country. Without framing legislation in terms of the
agreement, the covenants of the agreement were neither binding nor were they the law. At
best, they have a 􀞆persuasive value􀞇.
A4􀁢 However, the reasoning of the Supreme Court was that, if municipal law provides
adequate remedies or solutions, international law may be disregarded. At the same time,
the importance of international law and the acknowledgement of the binding nature of
international agreements has been considered by the Superior Courts of Pakistan. The
Supreme Court held in Hitachi Ltd v Rupali Polyester, 1998 SCMR 1618 that, in the
􀞆modern civilized world􀞇, nations have found that they cannot shelter behind the principle of
territorial sovereignty to disregard foreign rules of law merely because they happen to be at
variance with their own internal or territorial system. Superior Courts have held that a
government which was party to an international agreement or convention cannot enforce it
like municipal law unless it has been enacted or codified by the legislature. However, in line
with the Court's 􀞆persuasive value􀞇 argument, it observed that if Pakistan was party to a
convention, it had a 􀞆moral obligation􀞇 to observe the provisions of that convention. Where
there was a conflict between the domestic law and a convention, the domestic law will
prevail. Finally, where Pakistani law and/or policy were clear, foreign law would be excluded
to the extent that it was repugnant to municipal law.
A5􀁢 Another interesting aspect of this case was the argument raised by SGS before the
High Court that, even though it was not a signatory to the BIT, in view of the definition
given to the word 􀞆investment􀞇 under the BIT, SGS could invoke the provisions of the BIT
regarding arbitration and choice of forum. However, the High Court gave SGS the benefit of
this argument by providing that even though SGS was not a party to the BIT, applying
general principles of interpretation, a person for whose benefit a contract was made may
sue to enforce any obligation. The High Court, interpreting the various articles of the BIT,
had held that the general rules of statutory interpretation would apply to interpretation of
treaties unless stated otherwise. Rules commonly applied by the courts for the
interpretation and construction of municipal law are applicable to the interpretation of
treaties and in particular law making treaties in so far as they constitute general rules of
jurisprudence. The Supreme Court disagreed with the High Court, holding that the dispute
between the parties was not covered under Article 1(1) and (2) of the BIT, nor under the
ICSID Convention. There was an agreement between the parties and therefore the
arbitration clause contained in that agreement should prevail. The Supreme Court further
found SGS's conduct of first approaching the Swiss courts as amounting to waiver by
implication of the right to seek arbitration, and as estoppel from seeking arbitration under
ICSID. No reference was made by the Supreme Court to the Vienna Convention on the Law
of Treaties (23 May 1969) 1155 UNTS 331; 8 ILM 679 (1969); 63 AJIL 875 (1969), entered
into force 27 January 1980 (􀞆VCLT􀞇). (Pakistan signed the VCLT on 27 April 1970, but had
not ratified it, as at March 2006.) The High Court, while dealing with the issue of whether
the parties should settle their dispute in terms of ICSID or under the contract, foundA tnhante, x 104
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unless domestic law was legislated, the treaty or convention in question remains as
􀞆Executive Act􀞇 and no more. The High Court had found, in the instant case, that Pakistan
had no legislation to give effect to the terms and conditions of the ICSID Convention, and it
discussed several other conventions such as the Vienna Convention on Consular Relations
(24 April 1963), 596 UNTS 261; 21 UST 77; TIAS No 6820, entered into force 19 March
1967 and the Vienna Convention on Diplomatic Relations (18 April 1961) 500 UNTS 95,
entered into force 24 April 1964. However, the High Court also made no reference to the
VCLT. The law as it stands today is that, even if Pakistan is a signatory to a treaty or
convention, the terms and conditions of such treaty or convention can only be enforced if
there is domestic legislation. At best, such documents have a persuasive value and the
courts may press into service the contents of the treaty or convention if it is not in conflict
with the law of the land.
Date of Analysis: 31 August 2006
Analysis by: Ayesha Malik
Instruments cited in the full text of this decision:
Convention on the Settlement of Investment Disputes Between States and Nationals of
Other States (18 March 1965) 575 UNTS 159, entered into force 14 October 1966
Bilateral Investment Treaty, 11 July 1995, Articles 1, 2
Cases cited in the full text of this decision:
Hub Power Co Ltd (HUBCO) v Pakistan Wapda, All Pakistan Legal Decisions 2000 SC 841
To access full citation information for this document, see the Oxford Law Citator record
Annex 104
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Decision - full text
Munir A. Sheikh, J.
Munir A. Sheikh, J.
1􀁢 By this consolidated judgment, we propose to decide Civil Appeals Nos.459 and 460 of
2002, involving identical questions of law and facts.
2􀁢 These two appeals by leave of the Court are directed against the judgment dated
14-2-2002 of the Lahore High Court, Rawalpindi Bench, Rawalpindi whereby appeal filed by
the appellant (Civil Appeal No.459 of 2002) against the order, dated 7-2-2002 of the trial
Court has been dismissed and the request of the appellant Pakistan through Secretary,
Ministry of Finance, Islamabad in the connected Appeal No.460 of 2002 to restrain the SGS
to pursue the remedy through arbitration of International Centre for Settlement of
Investment Disputes (ICSID) has been dismissed.
3􀁢 The facts of the case are that SGS, hereinafter called the 􀞊appellant􀞋 entered into an
agreement on 29-9-1994 with the Federation of Pakistan, hereinafter called the
􀞊respondent􀞋, by which the services of the appellant were huried for pre-shipment
inspection of all consignments to be imported into Pakistan on the basis of which the
custom duty, etc., and other Government dues as prescribed under the relevant Statutes
were to be charged and recovered from the importers. This contract was terminated by the
respondent on 12-12-1996 which was accepted by the appellant on 23-12-1997 with the
reservation of its legal right. This agreement contained an arbitration clause which is
Clause 11.1. It reads as under:􀞂
􀞊11.1􀁢 Arbitration.􀞂Any dispute, controversy or claim arising out of, or relating to
this Agreement, or breach, termination of invalidity thereof, shall as far as it is
possible, be settled amicably. Failing such amicable settlement, any such dispute
shall be settled by arbitration in accordance with the Arbitration Act of the Territory
as presently in force. The place of arbitration shall be Islamabad, Pakistan and the
language to be used in the arbitration proceedings shall be the English language.􀞋
4􀁢 The appellant, however, filed a case against the respondent in the Court of first instance
in Geneva for the recovery of an amount of U.S.$ 8,368,430.49 with interest thereon and the
balance due on SGS invoices. In the petition filed before the said Court, it was alleged that
the appellant did not except fair trial from the Courts in Pakistan to justify its act of not
invoking the arbitration clause, for settlement of dispute by Courts in Pakistan. The said
Court decided the case against the appellant on the ground that arbitration clause was
reasonable, fair trial was possible in Pakistan. The claim of sovereign immunity of Pakistan
was also upheld. The appeal filed by the appellant before the Swiss Court of Justice against
the said judgment was dismissed through judgment dated 23-6-2000.
5􀁢 The respondent on 7-9-2000 filed an application under section 20 of the Arbitration Act,
1940 for filing of the agreement in the Court and appointment of an arbitrator as per
Arbitration Clause No.11.1 of the said Agreement. The appellant filed an appeal before the
Swiss Supreme Court which too was dismissed on 23-11-2000.
Annex 104
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6􀁢 The appellant contested the said application by filing detailed reply on 7-4-2001. After
filing this reply, on 10-10-2001, the appellant filed consent to ICSID Arbitration which was
followed by a formal request for arbitration dated 12-10-2001 which was registered on
12-11-2001. Apart from preliminary and other legal objections, the appellant also raised
counter-claim of more or less the amounts which were claimed in the case filed before the
Swiss Court of first instance. No plea was raised that the dispute between the parties by
force of Bilateral Investment Treaty dated 11-7-1995 or the Convention of Washington dated
18-3-1965 could exclusively or at the option of the appellant be resolved through arbitration
of ICSID. It was long after the dismissal of the appeal of the appellant by the Swiss
Supreme Court on 23-11-2000 that the appellant made an application under section 41 of
the Arbitration Act before the trial Court on 4-1-2002 seeking stay of proceedings under
section 20 of the Arbitration Act, 1940 contending that ICSID arbitration proceedings had
been instituted, therefore, these proceedings should be stayed. The trial Court through
order dated 7-1-2002 dismissed this application and on the same date, by a separate order,
it directed the parties to file panel of proposed Arbitrators. The appellant filed Appeal
(F.A.O. No.9 of 2002) before the Lahore High Court, Rawalpindi Bench through which it
assailed both the orders i.e., the order by which its application for stay.of proceedings was
dismissed and the order of acceptance of application under section 20 of the Arbitration Act
made by the respondent.
􀀚􀁢 In the said appeal, the respondent moved C.M. No.339-C of 2002 praying that the
appellant be restrained from taking any step, action or measure to pursue or participate or
to continue to pursue or participate in the ICSID Arbitration. The appeal filed by the
appellant and the said civil miscellaneous application made by the respondent have been
dismissed through the impugned judgment dated 14-2-2002 by the High Court against
which these two appeals by leave are directed.
8􀁢 The learned Judge in Chamber of the High Court after surveying the facts and relevant
laws on the subject came to the conclusion that no domestic law was enacted to give effect
to the Washington Convention of 1965 or bilateral treaty for which reasons the legal
efficacy of both of them was nothing but an instrument of administrative nature as such
could not be enforced as law.
9􀁢 As to the effect of Bilateral Investment Treaty dated 11-7-1995 in which a provision was
made for ICSID arbitration of the disputes between investor of one contracting State and
the other relating to or arising from investment made after 1-9-1954, it was held that
though the appellant was not party to the said treaty but it could invoke the same on the
basis of generally accepted principles that a contract can be enforced also by a person who
is beneficiary thereunder but this principle was not attracted in this case for no law had
been enacted to give provisions of the treaty the status of Municipal Law which could be
enforced as such. It was also held that the same did not have the effect of taking away the
rights accrued to the parties under a particular agreement entered into by them of their
free volition. It was also declared that since the respondent had earlier approached the trial
Court under section 20 of the Arbitration Act and the appellant had also raised
counterclaims and was contesting the said application on merits of the claims, therefore,
the said process which had already commenced could not be reversed even under the
Bilateral Investment Treaty, the same having been initiated earlier in time would exclude
any of the parties to seek ICSID arbitration which according to learned Judge of the High
Court was applicable to those cases which had not yet been commenced before a judicial
forum. It was held that there was no conflict between the treaty and the agreement in
question between the parties, therefore, the jurisdiction of the trial Court to entertain the
said application was held to have not been adversely affected by the treaty. The learned
Judge in Chamber further held that under Article 26 of the ICSID Convention, the assertion
of supremacy of ICSID Convention and the Bilateral Investment Treaty as major piecAe nonf ex 104
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primary law over the agreement as subordinate instrument was not tenable. According to
him, the non-ICSID forum already seized of the same matter could not be asked to take its
hands off the dispute.
10􀁢 As to the arbitration proceedings initiated by the appellant before the ICSID, it was held
that the same were not maintainable on account of lack of consent by one of the parties i.e.
the Federation of Pakistan under the relevant Convention, BIT, etc. On the question
whether the agreement between the parties related to investment as contemplated by
Article 1(2) of the Bilateral Treaty dated 11-7-1995, it has been held that the disputed claim
of either of the parties did not fall within the ambit of the meanings assigned to the
expression 􀞊investment􀞋 in this Article. It has also been held that the act of the appellant of
approaching the Swiss Courts of general jurisdiction for the recovery of specific amounts
under the agreement and of its prosecution up to the Swiss Supreme Court, coupled with
the act of filing reply to application under section 20 of Arbitration Act made by the
respondent and raising counterclaim without indicating expressly or impliedly that the
dispute was referable to ICSID arbitration amounted to waiver by it of the right, if any,
under bilateral treaty or otherwise to approach ICSID in the matter. In support of the
propositions of law, the learned Judge of the High Court made reliance on the statement of
law made in the American Jurisprudence, para.51 at page 260 which need not be
reproduced here.
11􀁢 The learned Judge in Chamber went on to hold that the arbitration clause in the
agreement had a separate entity meaning thereby that the same was severable, as such,
survived the termination of the contract of which it was a part. According to his findings,
the arbitration clause embodied in the agreement subject-matter of this litigation clearly
spelt out the intention of the parties that they had decided to have recourse through
arbitration thereunder in order to settle their contractual disputes at Islamabad, Pakistan.
It was held that this clause could not be deemed to be either varied or superseded by the
Bilateral Investment Treaty, therefore, the parties were bound to abide by it. Keeping in
view the fact that the agreement in dispute was executed in Islamabad, the part
performance of which was also to be made at Islamabad coupled with the fact that seat of
arbitration as argued was Islamabad, as such, it has been held that the parties shall be
deemed to have agreed that governing law shall be the law of Pakistan.
12􀁢 The learned Judge of the High Court, however, dismissed C.M. No.339-C of 2002 made
by the respondent to restrain the appellant from taking any step, action or measure to
pursue or participate or to continue to pursue or participate in the ICSID Arbitration on the
assumption as if an order of injunction of the nature could only be made in a regular civil
suit and not in the present proceedings.
13􀁢 These two appeals by leave of the Court are directed against the judgment dated
14-2-2002 of the High Court. Leave was granted, inter alia, to consider the following points:
(a)􀁢 Whether the arbitration agreement between the parties was binding upon them
notwithstanding the coming into force of the Bilateral Investment Treaty?
(b)􀁢 Whether the trial Court was right in holding that the petitioner was not an
investor within the meaning of the said word as defined in Bilateral Investment
Treaty?
(c)􀁢 Whether it has been rightly held keeping in view the circumstances of the case
that the petitioner had waived its right to seek remedy before ICSID?􀞋
Annex 104
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14􀁢 Mr. K.M.A. Samdani, learned counsel for the appellant before making submissions on
these points raised an argument that the application of the respondent made under section
20 of the Act for making a reference of the dispute between the parties to arbitrator was
not maintainable, for in the application itself, allegations had been made that the same was
obtained by payment of bribe, kick-backs and commission as such void in view of law laid
down by this Court in HUBCO case reported as The Hub Power Company Limited (HUBCO)
through Chief Executive and another v. Pakistan WAPDA through Chairman and others (PLD
2000 SC 841) in which this Court held that the points were not arbitrable.
15􀁢 In order to determine whether principles of law laid down in HUBCO case (supra) are
attracted to the facts of this case, it would be advantageous to reproduce in extenso the
relevant paragraph of the said application:􀞂
􀞊(3)􀁢 Investigations have revealed that out of the fee that was being received
by the respondent-company from the applicant (being 78% of the dutiable
value of the goods inspected by the respondent) an amount equivalent to 6%
of the fee was paid to Bomer Finance Inc., an offshore company operated by
Jens Schlegelmilch, beneficial owner of which is Asif Ali Zardari, husband of
Ms. Benazir Bhutto. This amount was paid as kickback and commission for
procuring the contract. Similarly, 3% was paid to another off-shore company
Nassam Associates which is also operated by Jens Schlegelmilch, beneficial
owner of which was Nasir Hussain, then husband of Sanam Bhutto, while
another amount of 1% was paid to Jens Schlegelmilch for the same contract.
The bank accounts of these companies were also being handled by Jens
Schlegelmilch.
(4)􀁢 The above facts show that the respondent paid bribes and commissions to
the beneficiaries out of the fee being recovered from the Government of
Pakistan. This amount of bribes and commission, during the course of
operation of the contract, came to USD 4.3 Million. Furthermore the
respondent also charged the applicant as its agreed fee a total sum of USD
65.7 Million (out of which the above amounts was paid).􀞋
16􀁢 The law declared in HUBCO case (supra) is as under:􀞂
􀞊S. 23􀞂Illegal objects and considerations of an agreement􀞂Agreement was alleged
to have been obtained through fraud or bribe􀞂Allegations of corruption were
supported by circumstances which provided basis for further probe into the matter
judicially, and, if proved would render the agreement as void􀞂Dispute between the
parties was not commercial dispute arising from an undisputed legally valid
contract, or relatable to such a contract, for, on account of such criminal acts
disputed documents did not bring into existence any legally binding contract
between the parties, therefore, dispute primarily related to the very existence of
valid contract and not a dispute under such a contract-Such matter, according to
the public policy, held, required finding about alleged criminality and was not
referable to arbitration􀞋.
From a bare reading of this part of the application, it is manifest that though allegation of
receipt of kickbacks and bribe have been made to explain the factual background as to how
allegedly the contract was obtained but there is nothing in the application that the
respondent claimed arbitration on these points also, therefore, HUBCO case is not
applicable to the facts of the case in hand. It has further been clarified by the learned
Attorney-General that the respondent would neither file any claim based on these Annex 104
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allegations in arbitration proceedings nor ask for arbitration qua them or produce any
evidence in respect thereof in these proceedings and would follow the law strictly as laid
down in HUBCO case (supra). The claims of the respondent would be based on the terms
and conditions embodied in the agreement itself.
1􀀚􀁢 Before, however, proceeding further, it is necessary to examine the facts of HUBCO
case to understand correctly the above principles of law laid down in that case. In HUBCO
case, there was no dispute about any claim determinable under the terms and conditions of
either the original agreement or about the rates of tariff etc., embodied in subsequent
disputed amendments made in the original agreement but it was a case of dispute
regarding commission of criminal act, therefore, it was held that the same was not
arbitrable.
18􀁢 Mr. K.M.A. Samdani, learned counsel for the appellant in relation to point-A of the leave
granting order submitted that prior to the ratification of Bilateral Investment Treaty by the
Federation of Pakistan on 4-4-1996 and the Swiss Confederation on 6-5-1996, the
agreement in dispute between the parties had already been executed on 29-9-1994 but the
same was not saved from the mischief of the provisions of the said Treaty and the
Convention as they were made applicable to all investments made after 1-9-1954, therefore,
the said agreement became subservient to the Convention and the Bilateral Investment
Treaty inclusive of the Arbitration Clause 11.1 embodied therein as such arbitration
through ICSID could only be adhered to for settlement of disputes.
19􀁢 This argument has been raised on the erroneous assumption as if the Washington
Convention, 1965 and the Bilateral Investment Treaty has attained legal status of Municipal
Law which could be pressed into service and enforced as such.
20􀁢 On the other hand, learned Attorney-General maintained that it has consistently been
held by the Courts that a Treaty unless was incorporated into the laws of the Country by a
Statute, the Courts would have no power to enforce treaty rights and obligations arising
therefrom at the behest of an individual or State. To support this contention, he has made
reference to the rule laid down in the cases of Maclaine Watson & Co Let V. Department of
Trade and Industry and related appeals Maclanine Watson & Co. Ltd. v. International Tin
Council (The All England Law Reports 1989 Volume 3 page 523) in which the question
which came up for consideration was as to what was the legal status of a Treaty between
the two States. It was held as under:􀞂
􀞊A treaty is a contract between the governments of two or more sovereign States.
International law regulates the relations between sovereign States and determines
the validity, the interpretation and the enforcement of treaties. A treaty to which
Her Majesty's government is a party does not alter the laws of the United Kingdom.
A treaty may be incorporated into and alter the laws of the United Kingdom by
means of legislation. Except to the extent that a treaty becomes incorporated into
the laws of the United Kingdom by statute, the Courts of the United Kingdom have
no power to enforce treaty rights and obligations at the behest of a sovereign
government or at the behest of a private individual.􀞋
21􀁢 In amplification of the above principles, it was also held as under:􀞂
􀞊The second is that, as a matter of the Constitutional law of the United Kingdom,
the royal prerogative, whilst it embraces the making of treaties, does not extend to
altering the law or conferring rights on individuals or depriving individuals of rights
which they enjoy in domestic law without the intervention of Parliament. Treaties,
as it is sometimes expressed, are not self-executing. Quite simply, a treaty is not Annex 104
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part of English law unless and until it has been incorporated into the law by
legislation. So far as individuals are concerned, it is res inter alios acta from which
they cannot derive rights and by which they cannot be deprived of rights or
subjected to obligations; and it is outside the purview of the Court not only because
it is made in the conduct of foreign relations, which are a prerogative of the Crown,
but also because, as a source of rights and obligations, it is irrelevant.􀞋
22􀁢 Learned Attorney-General has also referred to Article VI of the United States
Constitution to demonstrate that wherever it was intended to give effect to a Treaty by a
State as Municipal law of the Country for enforcement of rights thereunder as such through
Courts, law was made through Statutes to incorporate the provisions of the Treaty in the
Municipal Law of the Country. Sub-Article (2) of Article VI of the said Constitution reads as
under:􀞂
􀞊(2)􀁢 This Constitution, and the Laws of the United States which shall be made in
pursuance thereof; and all treaties made, or which shall be made, under the
Authority of the United States, shall be the supreme law of the Land; and the Judges
in every State shall be bound thereby, any thing in the Constitution or Laws of any
State to the contrary notwithstanding.􀞋
23􀁢 The argument raised by the learned Attorney-General has considerable force.
Admittedly, in Pakistan, the provisions of the Treaty were not incorporated through
legislation into the laws of the Country, therefore, the same did not have the effect of
altering the existing laws, as such, rights arising therefrom called treaty rights cannot be
enforced through Court as in such a situation, the Court is not vested with the power to do
so.
It may be significantly mentioned here that according to Article 175 (2) of the Constitution
of Islamic Republic of Pakistan, no Court has any jurisdiction unless conferred by or under
any law or the Constitution, therefore, treaty unless was incorporated into the law so that it
become part of Municipal Laws of the Country, no Court shall have jurisdiction to enforce
any right arising therefrom.
25􀁢 Faced with this difficulty, Mr. K.M.A. Samdani, learned counsel for the appellant
attempted to overcome it by arguing that by reason of unilateral act of the Federation of
Pakistan itself of omission or inaction to incorporate into the laws of the country the
provisions of the treaty by legislation it should not be allowed to raise such a plea to avoid
the enforcement of the provisions of the treaty. He further argued that according to Article
97 of the Constitution of Islamic Republic of Pakistan, 1973, the executive authority of the
Federation extends to the matters enumerated in Part I of Fourth Schedule regarding which
the Parliament could legislate therefore, its act of ratification of bilateral Investment Treaty
amounted to give it status of law.
26􀁢 Article 97 of the Constitution only provides that subject to the Constitution, the
executive authority of the Federation shall extend only to those matters with respect to
which Majlis-e-Shoora (Parliament) has the power to make laws, including exercise of
rights, authority and jurisdiction in and in relation to areas outside Pakistan. Fourth
Schedule embodies the list of those matters with respect to which Majlis-e-Shoora has the
power to make the laws, Item 3 of which is very relevant which reads as under:􀞂
Annex 104
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􀞊3􀁢 External affairs; the implementing of treaties and agreements including
educational and cultural pacts and agreements, with other countries; extradition,
including the surrender of criminals and accused persons to Governments outside
Pakistan.􀞋
Since Majlis-e-Shoora has the power to make laws in respect of these matters, therefore, by
virtue of Article 97 of the Constitution, the Federal Government of Pakistan has the power
to exercise executive authority in respect thereof which was exercised to ratify the treaty,
but it has not conferred power on the executive authority to legislate a Statute.
2􀀚􀁢 Learned Attorney-General has brought to our notice that legislations were made by a
number of countries to incorporate the provisions of the Convention and the Treaties to
enforce the same through Courts of law as Municipal Law. Following laws listed below were
made by the Countries shown against them:􀞂
􀞊Contracting State Title of Legislation (Citation)
Australia ICSID Implementation Act, 1990. (Act No.107 of 1990)
Austria Ratifikationsurkunde fur das Ubereinkommen zur Beilegung von
Investitionsstreitigkeiten zwischen Staaten und Angehorigen anderer Staaten.
(Off.Gaz.357, Vol.99, Sept. 10, 1971, p.1853)
Belgium Loi du 17 juillet 1970 portant approbation de la Convention pour le
reglement des differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats, faite a Washington ele 18 mars 1965.
(Off. Gaz. 185, Sept.24, 1970, p.9548)
Benin Ordonnance No.36/PR/MFAE du 26 aout 1966 portant ratification de la
Convention pour le reglement des differends relatifs aux investissements entre
Etats et ressortissants d'authres Etats.
(Off. Gaz.17, Sept. 1, 1966, p.773)
Decret No.445/PR/MFAEP du 28 decembre 1967 portant nomination de
concilliateurs et d'arbitres au Centre International pour le Reglement des
Differends relatifs aux Investissements.
(Off. Gaz.4, February 14, 1968,p.161)
Botswana The Settlement of Investment Disputes (Convention) Act, 1970.
(Act No.65 of 1970)
Burkina Faso Ordonnance No.17/PRES/DEV.T/AET du 31 mars 1966 portant
ratification de la Convention pour le reglement des differends relatifs aux
investissements enter Etates et ressortissants d'autres Etats conclue sous les
ausnices de la Bannque Internationale pour la Reconstruction et le Developpment.
Cameroon Loi No.66/LF/13 du 30 aout 1966 autorisant le President de la
Republiqaue Federale a ratifier la Convention pour le reglement des differends
relatifs aux investissements entre Etats et ressortissants d'autres Etats.
Annex 104
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(Off. Gaz. Sept.1, 1966,p.93)
Decret No.66/DF/454 du 30 aout 1966 portant ratification de la Convention pour le
reglement des differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats.
(Off. Gaz.December 1, 1966,p.1250)
Loi 75-18 du 8 decembre 1975 relative a la reconnaissance de sentences arbitrales.
(Off. Gaz.6, Suppl., December 15, 1975, p.234)
Chad Loi No.6 du 8 janvier 1966 portant approbation de la Convention.
Decret No.15/PR du 21 janvier 1966 portant ratification de la Convention pour le
reglement des differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats.
Comoro Decret NO.78/0073/PR portant ratification de l'adhesion de la R.R.I.des
Comores a la Convention pour le reglement des difference relatifs aux
investissements entre Etas a ressortissants d'autres Etats (CIRDI)
Cango, People's Republic of the Loi No.69/65 autorisant la ratification de la
Convention pour le reglement des difference relatifs aux investissements entre
Etats a ressortissants d'autres Etats.
Cote d'Ivoire Loi No.65-237 du 26 juin 1965 autorisant le President de la
Republique a ratifier la Convention passee avec la Banque Internationale pour la
Reconstruction et le Developpement entre Etats et ressortissants d'autres Etats.
(Off. Gaz. 35, July 15, 1965, p.770)
Decret No.65-238 du 28 juin 1965 portant ratification de la Convention passee avec
la Banque Internationale pour la Reconstruction et le Developpment pour le
reglement des differends relatifs aux investissements entre Etats. et ressortissants
d'autres Etats.
Cyprus Council of Ministers Decision No.5331 of January 20, 1966.
(Off. Gaz. 532, October 27, 1966)
Law No.64 of 1966 on approval of Convention by the House of Representatives.
(Off. Gaz.532, October 27, 1966)
Denmark Act No.466 of December 15, 1967, on Recognition and execution of
Orders Concerning Certain International Investment Disputes.
Egypt, Arab Republic of Decree-Law No.90 of November 7, 1971, approving the
accession of the Arab Republic of Egypt to the International Convention.
(Off. Gaz. November 11, 1971)
El Salvador Acuerdo No.349 de 19 julio 1982.
Decreto No.111 de 7 diciembre 1982.
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(Off. Gaz 230, Vol.277, December 14, 1982)
Finland Law No.74/69 of December 27, 1968 containing the approval of the
Convention.
(Off. Gaz.No.1􀞁8, 1969, p.7)
Decree No.75/69 of January 24, 1969, containing regulations for the implementation
of the Convention.
France Loi No.67-551 du 8 juillet 1967 autorisant la ratification de la Convention
pour le reglement des differends relatifs aux investissements entre Etats et
ressortissants d'autres Etats, du 18 mars 1965.
(Off. Gaz, July 11, 1967, p.6931)
Gabon Loi No. 19/65 du 20 decembre 1965 portant ratification de la Convention
pour le reglement des differends relatifs aux investissements entre Etats.
Germany Gesetz zu dem Ubereinkommen vom 18 Marz 1965 zur Beilegung von
Investitionsstretigkeiten zwischen Staaten und Angehorigen anderer Saaten vom 25
Februar 1969.
(Off. Gaz. 12, Part II, March 4, 1969, p.369)
Greece Neccessity Law No.608, November 11, 1968.
Guinea Loi No.12/An-68, portant ratification de la Convention pour le reglement des
differends relatifs aux investissements entre Etats et ressortissants d'autres etats.
Decret No.409/PRG du 28 Sept. 1968 promulgant une loi de l'Assemblee Nationale
portant ratification par la Republique de Guinee de la Convention pour le reglement
des differends relatifs aux investissements entre Etats et ressortissants d'autres
Etats.
Honduras Decreto No.41-88
(Off. Gaz. August 4, 1988)
Iceland Law authorizing the Government to become a party to an International
Convention on the Settlement of other States.
(Off. Gaz.A, 74, 1966).
Indonesia Law No.5 of June 29, 1968.
(Off. Gaz.32, 1968)
Ireland Arbitration Act, 1980 (covering, inter alia, the ICSID Convention). (Act No.7
of 1980)
Arbitration Act, 1980 (Part IV) (Commencement) Order, 1980.
(S.I. No.356 of 1980)
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International Centre for Settlement of Investment Disputes (Designation and
Immunities) Order, 1980.
(S.I. No.339 of 1980)
Italy Legge 10 maggio 1970, n. 1093 Ratifica ed execuzione della Convenzione per il
regolamento delle Controversie relative agli investimenti tra Stati e cittadini di altri
Stati, adottata a Washington il 18, January 12, 1971, p.155)
Jamaica Investment Disputes Awards (Enforcement) Act, 1966 (Act 28 of August 29,
1966) (Off. Gaz. XC, 18 February 16, 1967, p.60)
Buxite (Production levy) Act, 1974.
(Act 19 of 1974)
Jordan Royal Decree granted to Decision No. 1196 of Council of Ministers of May
17, 1972, ratifying the Convention on the Settlement of Investment Disputes
Between States and Nationals of other States.
Kenya The Investment Disputes Convention Act of 1966.
(Act 31 of November 22, 1966)
Korea Promulgation of the Convention (as Treaty No.234).
Republic of Kuwait Lesotho (Off. Gaz. Extr. No.4580, February 21, 1967, p.361)
Law Decree No.1 of January 14, 1979.
Arbitration International Investment (Disputes Act (Act 23 of 1974).
(Off. Gaz.10, Suppl. 2, March 14, 1975)
Luxembourg Loi du 8 avril 1970 portant approbation de la Convention pour le
reglement des differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats, en date a Washington, du 18 mars 1965.
(Off. Gaz. A, No.25, May 9, 1970, p.536)
Malawi Investment Disputes (Enforcement of Awards) Act, 1966 (Act 46 of
December 29, 1966)
(Off. Gaz.Suppl, January 10, 1967)
Malaysia Convention on the Settlement of Investment Disputes Act, 1966.
(Act of Parliament 14 of 1966)
Notification on entry into force of the Convention on the Settlement of Investment
Disputes Act, 1966.
(Notification No.96 of March 10, 1966)
Arbitration (Amendment) Act, 1980.
(Act A 478 of 1980.
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Mali Decret No.09/P-CMLN portant promulgation de I'Ordonnance No.77-63/CMLN
du 11 novembre 1977.
(Off. Gaz. 536, January 6, 1978)
Ordonnance No.77-63/CMLN portant approbation de la Convention pour ie
reglement des differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats.
(Off. Gaz. 536, January 6, 1978)
Mauritania Loi No.65.135 du 20 juillet 1965 autorisant le President de la
Republique a ratifier la Convention pour le reglement des differends ralatifs aux
investissements entre Etats resortissants d'autres Etats.
(Off. Gaz. 166/167, Setp.15, 1965,p.301)
Marritius Investment Disputes (Enforcement of Awards Act, 1969.
(Act No.12 of April 24, 1969)
Morocco Decret royal No.564-65 du 31 octobre 1966 portant ratification de la
Convention pour le reglement des differends relatifs aux investissements entre
Etats et ressortissants d'autres Etats.
(Off. Gaz.2820 No.16, 1966, pp.1288, 1332)
Metheriands Law of July 21, 1966, containing the approval of the Convention on the
Settlement of Invesment Disputes between States and Nationals of other States.
(Off. Gaz. 339, 1966,p.802)
New Zealand Arbitration (International Investment Disputes) Act, 1979 (Act No. 39
of 1979).
Niger Loi No 68-06 du 12 fevrier 1968 autorisant le President de la reglement des
differends relatifs aux investissements entre Etats et ressortissants d'autress Etats,
signee par le plenipotentiaire du Niger a Washington le 23 aout 1965.
(Off. Gaz. 4, February 15, 1968, p.119)
Nigeria Decree No.49 of 1967, International Centre for Settlement of Investment
Disputes (Enforcement of Awards).
(Off. Gaz. Extr. 105, Vol.54,No.30, 1967, p.A255)
Norway Act of June 8, 1967, relating to the implementation of the Convention of
March 18, 1965 on the Settlement of Investment Disputes Between States and
Nationals of other States.
(Off. Gaz. 1 (1967), p.23, reprinted Off.Gaz.II(1967),p.415
Papua New Guinea Investment Disputes Convention Act, 1978.
(Act No.48 of 1978)
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Portugal Decree-Law No.15/84
(Off. Gaz. No.79, April 3, 1984)
Somania Decret al Consillului de Stat Provind ratificarea Converntici pentru
reglementar differend relative la investitii intre State si persoane ale allor State,
incheiata la Washington la 18 martie 1965.
(Off. Gaz. 56 june 7, 1975, p.3)
Rawanda Decret No.20/79 du 16 juillet 1979.
Saudi Arabia Council of Ministers Resolution No.372, 15/3/1394 A.H.Royal Decree
No.M/8, 22/3/1394 A.H.
Senegal Loi No.67-14 du 28 fevrier 1967 autorisant le President de la Republique a
ratifier la Convention pour le reglement des differends relatifs aux investissements
entre etats et ressortissants d'autres Etats.
(Off. Gaz. 3888, April 17, 1967)
Decret No.67-517 du 19 mai 1967 ordonnant la publication au J.O. de la Convention
poru le reglement der differends relatifs aux investissements entre Etats et
ressortissants d'authres Etats.
(Off. Gaz. 3897, June 10, 1967)
Singapore Arbitration (International Investment Disputes) Act (Singapore Statutes,
1970 Rev. Ed., Act No. 18, Ch. 17, Sept.10, 1968, p.257)
Somalia Law No.11 of February 8, 1967 enforcing the Convention.
Sri Lanka Greater Colombo Economic Commission Law, No.4 of 1978.
Sudan Republican Decree No. 121 of 1972, ratifying the Convention.
Sweden Act on Recognition and Execution of Awards Concerning Certain
International Investment Disputes.
(Act No.735 of December 16, 1966)
Switzerland Arrete federal approuvant la Convention portant reglement des
differends relatifs aux investissements entre Etats et ressortissants d'autres Etats.
(Recueil des lois fed., 32, August 9, 1967 p.1021)
Togo Ordonnance No.32 du 25 juillet 1967 portant ratification par la Republique
togolaise de la Convention pour le reglementdes difference relatifs aux
investissements entre Etats a ressortissants d'autres Etats.
Trinidad and Tobago Investment Disputes Awards (Enforcement) Aux 1968. (Act No.
23 of August 18 1968)
Tunisia Loi No.66-23 du 3 mai 1966 portant ratification de la Convention pour le
reglement de differends relatifs aux investissements entre Etats et ressortissants
d'autres Etats.
Annex 104
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(Off. Gaz. May 3􀞁6, 1966, p.723)
United Kingdom Arbitration (International Investment Disputes) Act, 1966 (1966 c.
41).
The Arbitration (International Investment Disputes) Act, 1966 (Commencement)
Order 1966.
(Statutory Instruments, 1966, No.1597 December 21, 1966).
The Arbitration (International Investment Disputes) Act 1966 (Application to
Colonies etc.) Order, 1967.
The Arbitration (International Investment Disputes) (Guernsey) Order, 1968.
(Statutory Instruments, 1968, No. 1199, July 26, 1968).
The Arbitration (International Investment Disputes) Jersey) Order, 1979.
(Statutory Instruments, 1979, No.572, May 23, 1979).
The Arbitration (International Investment Disputes) Act, 1983 (an Act of Tynwald).
United States Convention on the Settlement of Investment Disputes Act of 1966.
(Pub.L.89-532; 80 Stat. 344; 22 U.S.C. sec. 1650􀞁1650a, August 11, 1966).
Executive Order designating certain Public International Organizations entitled to
enjoy certain privileges, exemptions and immunities.
(Exec. Order 11966; 42 Fed.Reg.4331 (1977).
Zambia Investment Disputes Convention Act, 1970 (Act No.18 of 1970). (Off. Gaz.
Suppl.April 17, 1970, p.99).
28􀁢 As regards resolution of dispute arising from investment as per terms of Bilateral
Investment Treaty in this case, no law has been made in Pakistan of the nature as was done
by Zambia Government or other States, therefore, the same could not be enforced as law in
order to claim that the alleged choice given to the appellant under the said treaty to
approach ICSID for arbitration had preference over the existing lawful contract between
the parties inclusive of arbitration clause which is binding on the parties.
29􀁢 It is demonstrably clear to which no exception can be taken that the act of the appellant
to approach the Court of general jurisdiction in Switzerland seeking recovery of specific
amounts under the agreement alleging that the Arbitration Clause No.11.1 embodied
therein could not be invoked for the reason of termination of contract and that fait trial in
the Courts of Pakistan was not possible and not on account of ICSID arbitration under
treaty amounted to admission that otherwise the said clause was valid, legal and operative
and binding on the parties.
30􀁢 The next question which falls for consideration is whether the agreement between the
parties is relatable to any investment to attract the provisions of the Bilateral Investment
Treaty became the said Treaty govern the dispute about investment of a party of the
Country signatory to the said treaty as is the case here so as to raise a plea that the
arbitration clause of the agreement in dispute no longer remained binding between the
parties and the choice of the appellant had to be preferred as to the forum of ICSID
arbitration. Answer to this question revolves around the answer as to what meant by the
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word or expression 􀞊investment􀞋. The word 􀞊investment􀞋 he been defined in Article 1(2) of
the Bilateral Investment Treaty as under:􀞂
􀞊(2)􀁢 The term 􀞊investments􀞋 shall include every kind of assets and particularly􀞂
(a)􀁢 movable and immovable property as well as any other rights in rem, such
as servitudes, mortgages, liens, pledges;
(b)􀁢 shares, parts or any other kinds of participation in companies;
(c)􀁢 claims to money or to any performance having an economic value;
(d)􀁢 copyrights, industrial property rights (such as patents, utility models,
industrial designs or models, trade or service marks, trade names, indications of
origin,) knowhow and goodwill;
(e)􀁢 concessions under public law, including concessions to search for, extract
or exploit natural resources as well as all other rights given by law, by contract
or by decision of the authority in accordance with the law.
31􀁢 The term 􀞊investor􀞋 has been defined in Article 1(1) of the Bilateral Investment Treaty
which reads as under:􀞂
􀞊(1)􀁢 The term 􀞊investor􀞋 refers with regard to either Contracting Party to􀞂
(a)􀁢 natural persons who, according to the law of that Contracting Party, are
considered to he its nationals;
(b)􀁢 legal entities, including companies, corporations, business associations and
other organizations, which are constituted or otherwise duly organized under
the law of that Contracting Party and have their seat, together with real
economic activities, in the territory of the same Contracting Party;
(c)􀁢 legal entities established under the law of any country which are, directly
or indirectly, controlled by nationals of that Contracting Party or by legal
entities having their seat, together with real economic activities in the territory
of that Contracting Party.􀞋
32􀁢 The agreement between the parties the subject-matter of these appeals is to be tested
on the touchstone of true meaning of the word 􀞊investment􀞋. In order to decide this
question, it could be necessary to examine the agreement itself to arrive at a decision as to
its scope and nature. It has to be construed strictly, carefully keeping in view the purpose
for which the same was executed.
33􀁢 Articles, 1.1, 1.2, 1.4, 1.5, 2.1, 2.2, 2.6 and 2.7 of the Agreement dated 29-9-1994
entered into between Government of Pakistan versus Societe Generale De Suirvellance S.A.
are as follows:􀞂
􀞊1.1􀁢 Appointment.
The Government hereby appoints SGS to carry out, either by itself, or through
its affiliated companies and authorized agents, the services described in Articles
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II to IV (hereinafter referred to as the 􀞊Services􀞋). This appointment is hereby
accepted by SGS.
1.2􀁢 Scope of services.
SGS shall performs the service as are expressly set forth in this Agreement as
amended from time to time and the following Schedules hereto which form an
integral part hereof:
Schedule Title Reference
I􀁢 Definition of Goods Section 3.1
II􀁢 Implementation Section 5.1
III􀁢 Liaison Office Facilities Section 5.8
IV􀁢 Fees Section 6.1
V􀁢 Terms of Letter of Credit Section 7.1
VI􀁢 List of Countries Section 3.1
VII􀁢 Definition of Benefits Section 4.7
VIII􀁢 Geographical Area Section 3.1
XI􀁢 List of affiliates and agents Section 1.1
1.4􀁢
Strict adherence in carrying out the Services, SGS shall adhere to the
provisions of the Rules referred to in Article V as amended from time to time.
1.5􀁢 WTO Agreement.
SGS shall ensure that, in performing the Services, it doss not do or cause to be
done, any act that is contrary to the provisions of the agreement on preshipment
in section of the World Trade Organization: provided that the methods
used by SGS to determine the value of duty purposes be strictly in accordance
with the laws of the Territory.
Article II􀁢 Services
Physical identification of goods.􀞂Subject to this Agreement SGS shall carry out
the physical identification of all consignments to be imported into the Territory
prior to shipment in all countries of supply to determine that the goods
presented satisfactorily correspond to the descriptions communicated to SGS by
the importer. It shall be in the discretion of SGS to determine the extent of each
intervention. In those exceptional cases when goods are permitted to enter the
Territory without pre-shipment inspection including where it is so permitted
under the Rules specified in Article V and the SGS is the selected inspection
company, then the inspection shall be undertaken jointly by Customs and SGS at
the port of entry.
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2.2􀁢 Price verification.
Simultaneously with the physical identifications of imports, SGS shall undertake
a price verification of the goods in order to determine on the basis of
documentary evidence or other information whether the amount specified in the
invoice by a seller in respect of such goods corresponds within reasonable
limits, with the export price levels generally prevailing in the country of supply,
or where applicable, the world market price verification shall not be limited to
the purchase price of the goods, but shall cover the total contracted value
including all related services (hereinafter refened to as the 􀞊total value􀞋).
2.6􀁢 Re-inspection in warehouses.
Where re-inspection of goods in bonded warehouses is required, and SGS is the
nominated inspection company, SGS sill inspect jointly with Customs and the
cost of the inspection shall be paid to SGS by the Government.
2.􀀚􀁢 Cost of re-inspection.
Where re-inspection is required under Article 2.6, SGS shall sub-contract this
responsibility to SGS Pakistan which will invoice in Pakistan currency at the
current commercial inspection rates in Pakistan. SGS shall advise the
Government of the current commercial rates and keep the Government
informed of any changes thereto. These specific fees shall be subject to all local
applicable taxes.􀞋
34􀁢 From a bare reading of these clauses of the agreement in particular and the agreement
as a whole, it is manifest that it was an agreement through which the services of the
appellant were hired for carrying out pre-shipment inspection of the goods to determine
their value for the purposes of charging custom duty on their import in Pakistan according
to the rates prescribed under the relevant laws of Pakistan and the major portion of the
exercise was to be undertaken out of Pakistan at the stage of shipment of the goods from
the foreign countries from where they were to be imported and in case, reinspection in
Warehouse in Pakistan was necessary, the appellant was given authority to carry out the
same through SGS Pakistan and nothing else.
35􀁢 Considering the nature of these functions for which the services of the appellant were
hired in juxtaposition of the meaning of the word 􀞊investment􀞋, it can safely be held for
reasons to follow that it is not an agreement of the kind and nature relating to any
investment, as such, as is not covered by the said Bilateral Investment Treaty or the
Washington Convention. It was an agreement between the two parties of hiring services
simpliciter involving no investment, therefore, the arbitration clause 11.1 embodied therein
would not in any manner be adversely affected as to its enforcement through Court of law
by any of the Clauses of Bilateral Investment Treaty inclusive of ICSID arbitration being not
a dispute related to investment.
36􀁢 As is evident from the definition of 􀞊investment􀞋 given in the Bilateral Investment
Treaty that it is not exhaustive for it is controlled by the expression 􀞊includes􀞋, learned
counsel for the appellant when questioned as to how it could claim in view of terms of
agreement in question being an agreement of hiring services simpliciter that the same
involves any investment referred to clause-C in the Treaty to argue that according to it, any
claim to money simpliciter or any performance having an economic value is also investment,
therefore, the claim of the appellant for the recovery of the amounts in question for the
services rendered by it would be covered by this clause. We are afraid, the argument in our
view is not only devoid of any force but also plainly unsound. By raising this argument, Annex 104
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learned counsel for the appellant has overlooked that all claims to money or any
performance having an economic value must relate to investment. Clause-C on which
reliance has been placed by the learned counsel for the appellant as a matter of fact is of
the species of assets earnable by an investor from his investment and not the investment
itself. The expression 􀞊investment􀞋 has a legal connotation and meaning has to be assigned
to determine whether the dispute between the parties relate to or has any nexus with
investment.
3􀀚􀁢 Learned Attorney-General in this connection has called our attention to the case of
Inland Revenue Comrs. v. Rolls-Royce Ltd. (All England Law Reports Annotated (Vol.2) in
which the word 􀞊investment􀞋 has been interpreted as under:􀞂
􀞊The word 􀞊investment􀞋, though it primarily means the act of investing, is in
common use as meaning that which is thereby acquired; and the primary meaning
of the transitive verb 􀞆to invest􀞇 is to lay out money in the acquisition of some
species of property; consequently, letters patent, which are undoubtedly a species of
property, may properly be described as an investment.􀞋
38􀁢 It is sufficiently clear from this that laying out of money in the acquisition of some
species of the property was necessary ingredient to determine whether an entry or
transaction was relatable to investment or not. Keeping in view this meaning and
interpretation of the expression 􀞊investment􀞋 and examining the terms of the agreement in
question in the light thereof, it can safely be concluded that the same does not fall within
the scope and ambit of investment, for as observed above, it is simpliciter an agreement
through which mere services had been acquired for evaluation the goods mostly in the
foreign countries and there is no element of laying money by the appellant for acquisition of
any species of property, as such is not a case of investment which is covered by the treaty,
as such, no right in the appellant has been created to invoke its provisions for ICSID
arbitration.
39􀁢 It was also brought to our notice by the learned Attorney-General that in Pakistan, the
Foreign Private Investment (Promotion and Protection, Act, 1976 (Act XLII of 1976) has
been promulgated which governs the foreign investments and the matters relating thereto.
In the said Act, foreign capital has been defined as investment made by foreigner in an
industrial undertaking in the form of foreign exchange, imported machinery an equipment
or in any other form which the Federal Government may approve for the purpose. This
definition is in consonance with the meaning of the word 􀞊investment􀞋 as discussed above,
therefore, this Act can be construed to be the law made by Pakistan relating to foreign
investments and in case the meaning to the expression 􀞊investment􀞋 given in the Bilateral
Investment Treaty was to be extended to mere claim of money without laying out money in
the acquisition of some species of property as argued, the said Act was required to be
amended to incorporate the same in it to enforce it as law which having not been done, as
such, the word 􀞊investment􀞋 as given in the treaty cannot legally he assigned the meaning
as argued by the learned counsel for the appellant against the provisions of the said Act. It
also does not involve any performance having an economic value for the reasons that the
custom duty and other Government dues, were liable to be charged according to the rates
specified in the relevant laws. It may also be observed here that evaluation of the goods and
the recovery of the import duty were held to be the sovereign acts which were to be
performed by the State or its functionaries and by no other person or authority, therefore, it
was held in the case of Collector of Customs and others v. Sheikh Spinning Mills (1999
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SCMR 1402) by this Court that abdication of sovereign power or delegation thereof in
favour of the appellant was not permissible under the law.
40􀁢 For what has been discussed above, we are of the view that the arbitration agreement
between the parties dated 29-9-1994 was binding and continued to be binding upon them
notwithstanding the ratification of the Bilateral Investment Treaty which provided another
parallel forum for arbitration before ICSID in that the appellant was not an investor within
the meaning of the said word used in the said Treaty and for the reasons discussed above,
the findings of the High Court do not suffer from any legal infirmity.
41􀁢 This brings us to the most crucial question as to whether in the circumstances of the
case, the appellant shall be deemed to have waived its right to seek remedy before ICSID
even if it is held that choice was available to the appellant to seek arbitration through ICSID
as against arbitration under the arbitration clauses of the agreement.
42􀁢 Learned counsel for the appellant submitted that though the appellant is not the
signatory of the Bilateral Investment Treaty but in view of the definition of 􀞊investor􀞋 given
in the Treaty to include in its provisions not only the Contracting States but also natural
person, legal entities of the Contracting State, therefore, the appellant being a legal entity
established in Switzerland could invoke the provisions of the treaty, as such, it had a right
to make a choice to invoke the clause of the treaty regarding arbitration of ICSID to resolve
the dispute about investment which if made according to the provisions of the treaty are to
be given preference over the arbitration clause in the agreement in dispute and the
appellant having opted to approach ICSID arbitration, the present proceedings commenced
through applications under section 20 of the Arbitration Act by the respondent are liable to
be stayed.
43􀁢 Learned Attorney-General on the other hand without prejudice to his other submissions
and in particular submission that no provision of the treaty could be invoked or pressed into
service unless incorporated by the contracting States or any one of them into the laws,
maintained that in the circumstances of this case, the appellant had three choices:􀞂
(a)􀁢 To file a regular suit before the Court of general jurisdiction;
(b)􀁢 to invoke arbitration clause 11.1 of the Agreement and seek arbitration
accordingly; and
(c)􀁢 as urged by its learned counsel to have recourse to arbitration before ICSID in
exercise of its alleged right to make choice.
44􀁢 He submitted that after the acceptance of the termination of the contract in December,
1997, it instead of making choice about any of the two arbitration forums as mentioned
above for resolution of the dispute filed a suit before the Court of general jurisdiction in
Geneva. Specific amounts were claimed under the agreement which were allegedly due to
the appellant but it failed and the Courts in Switzerland upheld the plea of sovereign
immunity of the Federation of Pakistan and rejected the plea of the appellant that under
Arbitration Clause 11.1 of the Agreement, the appellant would not get fair trial in the Court
in Pakistan. The judgments of all the three Swiss Courts i.e. Court of first instance, the
Appellate Court and the Supreme Court held that fair trial under the said clause was
possible.
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45􀁢 In view of there admitted facts, learned Attorney-General made Submissions that
foundation has been laid to raise a plea that firstly by filing the said suit, the appellant shall
be deemed to have waived its right to get the resolution of the dispute through arbitration,
secondly, the delay after acceptance of termination of the contract in 1997 in approaching
the Court in Switzerland not only constituted waiver by implication of the right to seek
arbitration but the same also constituted estoppel by conduct for which reason it is
estopped from seeking arbitration through ICSID and thirdly the judgments passed by the
Courts in Switzerland in the said suit of the appellant also attract the principle of issue
estoppel. He argued that the principle is applicable with equal force vis-a-vis the foreign
judgments and the conditions to be fulfilled for the applicability of this principle are:􀞂
(a)􀁢 That the foreign Courts which decided the matter was a Court of competent
jurisdiction;
(b)􀁢 the decision or judgment was final and conclusive; and
(d)􀁢 on merits.
46􀁢 He also argued that additionally by the raising counterclaim in the present proceedings
before the trial Court under the agreement, the appellant shall also be deemed to have
waived its right to make a choice to take the matter before ICSID for arbitration.
4􀀚􀁢 In support of his argument that delay or failure to commence arbitration by a party
would itself constitute waiver on its part to seek arbitration, he has referred to para. 19.01
of Domke on Commercial Arbitration (The Law of Practice of Commercial Arbitration),
Revised Edition by Gabriel M. Wilner, Professor of Law, The University of Georgia School of
Law, 1998 Cumulative Supplement (Published August, 1998). If has elaborately dealt with
the principle of waiver of arbitration by laches or delay which is not only enlightening but
also instructive. The opinion of the author based on case law is as follows:􀞂
􀞊A party's right to specific enforcement of the arbitration agreement is expressly
provided for in modern arbitration statutes, which allow a Court order to compel
arbitration, including ex parte proceedings. However, this right may be lost by
waiver. It has been suggested that 􀞊[t]here is.. nothing irrevocable about an
agreement to arbitrate. Both of the parties may abandon, this method of settling
their differences, and under a variety of circumstances one party may waive or
destroy by his conduct his right to insist upon arbitration.
A party may waive its right to arbitration by failing to initiate arbitration within the
time limits dictated in the agreement, or by failing to initiate arbitration within a
reasonable period, giving rise to laches. Often, a party will waive the right to
arbitration not because of no compliance with time limits or laches, but because
that party took no affirmative action to commence arbitration. This is especially true
where the party also participated in litigation over otherwise arbitrable issues.
Waiver of arbitration occurs most often when a party institutes a Court action in
violation of the arbitration agreement. This appears clearly as a manifestation of an
intention not to arbitrate.􀞋
48􀁢 It may be mentioned here that this commentary not only covers the principles of waiver
not only to a case of failure to initiate arbitration proceedings within a reasonable period
but also a case where a party instituted a Court action in violation of the arbitration
agreement which would constitute manifestation of an intention not to arbitrate. At another
place, it was reiterated in para. 19.06 that a party not demanding arbitration within a Annex 104
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reasonable time may be deemed to have waived the right to arbitrate. It goes on saying that
if a party engages in deliberate delay or inaction or other efforts to frustrate the other
party's attempts to arbitrate, the first party may be found to have acted in bad faith and to
have impliedly waived its entitlement to arbitration. In the opinion of the author, waiver of
arbitration occurs in most cases when a party initiates litigation or participates in a law suit
in violation of the arbitration agreement. The Seventh Circuit has held that a patty's
election to proceed before a non-arbitral tribunal constitutes a presumptive waiver of the
right to arbitrate. The author was of the opinion that as a practical matter, the more
involved in litigation a party gets, the greater the appearance that the party has chosen an
alternative to arbitration. Also, the more involved a party becomes in litigation, the greater
chance that prejudice to the other party will be found. It has also been maintained that
advancing a counterclaim in a Court action may be considered a waiver of arbitration. The
author also observed that the Courts held that an insurer's motion to dismiss the complaint
of a claimant for uninsured motorist coverage waived the insurer's party to resort to Court
action until an unfavourable result is reached and then switch to arbitration.
49􀁢 Cases and Materials on the Law and Practice of Arbitration, Second Edition by Thomas
E. Carbonneau C.J. Morrow, Professor of Law, Tulane University; Editor-in-Chief, World
Arbitration and Mediation Report, referred to by learned Attorney-General is also of
immense help and provide useful guidance to determine this aspect of the case. In the
opinion of the author, the question whether a contracting party waives its right to demand
the arbitration of contract disputes by participating in judicial proceedings regarding those
disputes is an issue that has surfaced with greater frequency in the decisional law on
arbitration. On the strength of the case-law, according to the author, the following
principles are deducible:􀞂
􀞊The Court indicated that a waiver may be found when a party seeking arbitration
has (1) previously taken steps inconsistent with an intent to invoke arbitration, (2)
unreasonably delayed in seeking arbitration, or (3) acted in bad faith or with
without misconduct.􀞋
He also goes on saying:􀞂
􀞊The Court-room may not be used as a convenient vestibule to the arbitration hall
so as to allow a party to create his own unique structure combining litigation and
arbitration.
At another place, it has been reiterated as under:􀞂
􀞊By not bringing the dispute to arbitration, for nearly three years the plaintiff in
effect waived its rights to arbitrate. Once arbitration is ordered, the Court held, the
party who seeks to have the dispute arbitrated carries the burden of undertaking
arbitration in a timely manner.􀞋
He also goes on saying:
􀞊A Taxas Court of Appeals held in Viree v. Cates, 953 S.W. 2d 489 (Tex. Ct.App.
1997), that the trial Court did not abuse its discretion by holding that the plaintiffs
waived their rights to compel arbitration. The Court ruled that a 􀞆plaintiff who sues
on an arbitrable claim unconditionally, without having initiated arbitration of the
claim for demanding specific performance of the arbitration agreement, creates in
the defendant a right of election, the defendant may insist or not upon arbitration,
as he chooses􀞇. The Court further stated that, if the defendant does not insist upon
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arbitration, the contracting parties have mutually repudiated the arbitration
covenant as a matter of law and waived any right thereunder.􀞋
50􀁢 American Jurisprudence, Second Edition which is a modern comprehensive text
statement of American Law, Volume 5 was also referred to by the learned Attorney-General
in which it has also been held on the strength of principles laid down in the cases decided
by the Court as under:􀞂
􀞊51􀁢 Generally. The right to arbitrate given by a contract may be waived, even
in those jurisdictions where a contract for arbitration is irrevocable. Such a
waiver of arbitration may come before as well as after the commencement of
litigation. The waiver may be either by express words or by necessary
implication. Thus where one party brings suit, he waives his right to
arbitration; his conduct is clearly inconsistent with a claim that the parties
were obligated to settle their differences by arbitration.􀞋
It further goes on observing:
􀞊Any conduct of the parties inconsistent with the notion that they treated the
arbitration provision as in effect, or any conduct that might be reasonably construed
as showing that they did not intend to avail themselves of such provisions, may
amount to a waiver. A right to arbitration may be waived by denying that there is
anything to arbitrate, by failing to perform the preliminary steps leading to
arbitration, or by being unjustifiably slow in seeking arbitration.􀞋
He also says:􀞂
􀞊and a party who is guilty of dilatory tactics or of delay may waive his right to
arbitrate and to a stay of an action at law pending arbitration.􀞋
51􀁢 Corpus Juris Secundum, a complete re-statement of the Entire American Law, Volume 6
has also been pressed into service by the learned Attorney-General which on this point is as
under:􀞂
􀞊The parties to an arbitration may by agreement or action expressly or implicitly
waive, or abandon the arbitration agreement, and come into Court if they mutually
choose to do so. Also, the parties may, by their voluntary act, abandon one
arbitration proceeding and proceed with a new proceeding covering the subjectmatter
embraced in the abandoned proceeding.
Abandonment may result from a lapse of time without any activity therein by the
parties, or otherwise by actions and conduct or omissions, clearly indicating on
intention to forego the prosecution.􀞋
It also opines:􀞂
􀞊Generally the institution of a suit covering the same subject-matter as that
submitted to arbiration revokes the submission.
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While there is authority to the contrary, it is generally held that the institution of a
suit, before award, by one of the parties, the cause of action being the same subjectmatter
as that submitted to arbitration, revokes, by implication of law, the
agreement to arbitrate. However, the institution of suit has no such effect, unless
the action covers the subject-matter submitted; and, until a complaint has been filed
by a party to the submission, an adverse party has no legal notice of the cause of
action, and the abitrators may proceed with the arbitration and render their award,
although a summons has been issued.􀞋
52􀁢 The judgment in the case of Malarky Enterprises (US) (plaintiff) v. Healthcare
Technology Ltd. (UK) (defendant) (United States District Court District of Kansas, 25 April,
1997 Civ.No.96-2254-GTV) has also been brought to our notice which laid down the
following principles for determining whether a party shall be deemed to have waived its
right to arbitration:􀞂
(1)􀁢 Whether the party's actions arc inconsistent with the right to arbitrate?
(2)􀁢 Whether the litigation machinery has been substantially invoked and the parties
were well into preparation of a lawsuit before the party notified the opposing party of
an intent to arbitrate?
(3)􀁢 Whether a party either requested arbitration enforcement close to the trial date
or delayed for a long period before seeking a stay?
(4)􀁢 Whether a defendant seeking arbitration filed a counterclaim without asking for a
stay of the proceedings?
(5)􀁢 Whether important intervening steps (e.g. taking advantage of judicial discovery
procedure not available in arbitration) had taken place? and
(6)􀁢 Whether the delay affected, misled or prejudiced the opposing party?􀞋
53􀁢 The said well established principles of law are fully attracted to the facts and
circumstances of this case. The termination of the contract was accepted by the appellant
on 27-12-1997. It kept quiet up to 24-6-1999 when, instead of opting for the alleged choice
of seeking arbitration through ICSID, of the dispute commenced proceedings in a Court of
general jurisdiction for the recovery of the amount allegedly due to it. The appeal filed by it
before the Swiss Court of Justice was dismissed on 23-6-2000. Application under section 20
of the Arbitration Act by the respondent was filed on 7-9-2000. The appeal filed by the
appellant before the Swiss Supreme Court on 24-7-2000 was dismissed by the said Court on
23-1-2000. Reply to the said application under section 20 was filed by the appellant on
7-4-2001 whereas consent to ICSID arbitration was filed by it on 10-4-2001 whereas formal
request for ICSID was made by the appellant on 12-10-2001 which was listed on
21-11-2001.
54􀁢 These details of the events also established that consent to ICSID arbitration was made
after filing reply to the application under section 20 of the Arbitration Act before the trial
Court in which counterclaim under the agreement was also made seeking recovery of the
same amounts which were claimed before the Swiss Court. On the basis of these
established facts, it can safely be held that the appellant had not only waived the right to
opt if any for ICSID arbitration but even principle of estoppel by conduct would also be
attracted for institution of the proceedings before the Swiss Court and filing of reply to the
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application under section 20 was sufficient to constitute estoppel of conduct of waiver of its
right to seek arbitration.
55􀁢 The principles of issue estoppel and cause of action are also fully attracted in the
present case. Learned counsel for the appellant when questioned as to how in the light of
the above noted well-settled principles of law of international recognition after obtaining
decision of the Swiss Court, it could maintain before the trial Court by making application
under section 41 that these proceedings should be stayed in view of the ICSID arbitration
initiated by it, submitted that decisions of the Swiss Courts are not on merits of the claim of
the appellant, therefore, those decisions would not operate as res judicata to debar the
appellant from raising the plea that the arbitration clause in the agreement was subservient
to the option of choice given to the appellant under the Bilateral Investment Treaty of ICSID
arbitration and that the said clauses could not be pressed into service by the respondent.
56􀁢 We are afraid, the submission is wholly devoid of any force. In order to attract the
principles of issue estoppel and cause of action, it is not necessary that the judgment which
had previously dealt with the case should be on merits of the claim itself arising from a
contract but the merits of the case would be the questions of law raised in those
proceedings and decisions rendered by the Courts on them. The merits of the case brought
before the Swiss Court by the appellant were whether:􀞂
(a)􀁢 Arbitration clause 11.1 in the agreement between the parties was severable.
(b)􀁢 Possibility of fair trial in Pakistan.
(c)􀁢 Sovereign immunity of Pakistan.
5􀀚􀁢 The judgments of the Swiss Courts on the merits of these points are that arbitration
clause 11(1) of the agreement was severable, for it survived the termination of the
agreement. The plea of sovereign immunity of Federation of Pakistan was accepted. It has
also been held that fair trial in the Courts of Pakistan was possible. These judgments were
passed by the Courts of competent jurisdiction and are of declaratory nature about the
merits of the legal points decided therein, therefore, they could be looked into and pressed
into service by the Courts in Pakistan as foreign judgments as they satisfy the criteria laid
down in section 13, C.P.C. The argument of learned counsel for the appellant that these
judgments had to be tested on the touchstone of provisions of section 44-A, C.P.C. has no
force, for the said provisions govern the matters relating to execution of such judgments
and decrees and not the judgments and decrees of declaratory in nature. As has already
been noticed the appellant by the act of the institution of the said proceeding shall be
deemed to have expressly waived its right if any making option of arbitration of ICSID and
is bound by the said findings to merits of the case on those points which had the effect of
operating as to judicata as regards validity and binding nature of arbitration clause 11.1 of
the agreement, as such it could not claim stay of proceedings commence under section 20
of the Arbitration Act on the ground that it had approached the ICSID for arbitration which
right it had already waived and was no longer available to it. Besides the claim of the
appellant on the date when it filed request for arbitration before ICSID had already become
barred by time, for the period of limitation started running from 23-12-1997.
58􀁢 Mr. K.M.A. Samdani, learned counsel for the appellant submitted that application under
section 20 of the Arbitration Act was filed on 7-9-2000 whereas contract was terminated on
12-12-1996, therefore, the principle of delay if any, is also applicable to these proceedings.
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59􀁢 This plea if considered in isolation appeared to have some substance but keeping in
view the established facts and circumstance of this case, the same is found to be not
available to the appellant. The appellant on 12-1-1998 commenced proceedings in the
matter before the Court of first instance at Geneva and raised a plea that Arbitration Clause
11.1 of the Agreement did not survive or that fair trial was not possible thereunder which
was finally decided by the Swiss Supreme Court on 23-1-2000, as such, the respondent
cannot be held guilty of laches and as such, cannot be non-suited on the ground of delay.
60􀁢 Before parting with this part of the judgment, we may observe here that the conduct of
the appellant-SGS is not above board, for it did not disclose before ICSID while filing
consent and request for arbitration that it previously had approached the Court in Geneva
and failed up to the Supreme Court and the decision on the issues regarding applicability of
Arbitration Clause 11.1 and fair trial in Pakistan in pursuance thereof had been decided
against it.
61􀁢 We are of the firm opinion that in case, those decisions had been brought to the notice
of the ICSID Tribunal it would not have entertained the request for arbitration. The
appellant did not approach ICSID with clean hands and is guilty of deliberate concealment
and suppression of material facts relevant for taking a decision by the said Tribunal
whether the request should be entertained and notice issued.
62􀁢 The next question which falls for decision is as to what will be the governing law of the
arbitration proceedings under arbitration clause 11.1 of the agreement between the parties,
the said clause reads as under:􀞂
􀞊11.1􀁢 Arbitration.􀞂Any dispute, controversy or claim arising out of, or relating to
this Agreement, or breach, termination of invalidity thereof, shall as for as it is
possible, be settle amicably. Failing such amicable settlement, any such dispute
shall be settled by arbitration in accordance with the Arbitration Act of the Territory
as presently in force. The place of arbitration shall be Islamabad, Pakistan and the
language to be used in the arbitration proceedings shall be the English language.􀞋
63􀁢 It is clear that the parties had agreed that the seat of arbitration shall Islamabad
Pakistan. It also provides that the arbitration shall be in accordance with the Arbitration Act
of the Territory as presently in force.
64􀁢 Learned Attorney-General in view of these terms of the arbitration clause argued that
choice of seat was capable of being determinative of the choice of the governing law of the
performance obligations, therefore, the Arbitration Act, 1940 will be the governing law. He
referred to Commentary by Russell on Arbitration, Twenty-First Edition by David St. John
Sutton. The relevant portion of the commentary reads as under:􀞂
􀞊Before the Contracts (Applicable Law) Act, 1990 if there was no express choice of
a proper law of the performance obligations, an agreement to arbitrate in a
particular venue, such as London, was highly relevant to the investigation;. The
venue and jurisdiction is often referred to as the 􀞆seat􀞇 of an arbitration. If the
parties expressly choose a seat, but make no express choice of the law which is to
govern the performance obligations under the contract, that choice of the seat was
capable of being determinative of the choice of the governing law of the
performance obligations. An agreement to refer disputes to arbitration in a
particular country may carry with it, and is capable of carrying with it, an
implication or inference that the parties have further agreed that the law governing
the contract (as well as the law governing the arbitration procedure) is to be the
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law of that country. But I cannot agree that this is a necessary or irresistible
inference or implication.􀞋
65􀁢 Mr.K.M.A. Samdani, learned counsel for the appellant did not seriously dispute the
correctness of the contention raised by learned Attorney-General that seat of the arbitration
being Islamabad and part performance of the obligations of the agreement was also to be
made in the territory of Pakistan and the agreement having been executed in Pakistan,
therefore, these factors were sufficient to hold that the parties intended that the governing
law of the arbitration would be law of Pakistan.
66􀁢 Reverting to the merits of Civil Appeal No.460 of 2002 filed by the respondent directed
against the order of the learned Judge in Chamber of the Lahore High Court dismissing its
application praying that SGS may be restrained from pursuing the remedy through
arbitration of International Centre for Settlement of Investment Disputes (ICSID), it may be
observed that the relief claimed has been declined on a ground not tenable in law. In the
opinion of the learned Judge in Chamber, such a relief could only be claimed and granted in
a regular civil suit and not in the present proceedings. It may be mentioned here that
according to section 20 of the Arbitration Act the application has the legal status of a suit.
Apart from that, under section 41 of the Arbitration Act, the Court in which proceedings are
pending is competent and vested with the jurisdiction to pass interim orders as could be
passed in a regular civil suit in the form of temporary injunction or otherwise. The view
taken by the learned Judge in Chamber has not only resulted in miscarriage of justice but
also failure to exercise jurisdiction vested in the Court to pass interim orders of the nature
prayed for. Even otherwise it has also been overlooked that after having held that the
arbitration proceedings initiated by the respondent before the trial Court were competent
and maintainable for the reasons that arbitration clause 11.1 of the agreement was holding
the field and was binding on the parties and its legal efficacy and enforceability had not
been in any manner adversely affected by Bilateral Investment Treaty and ICSID Arbitration
Clause, the legal consequences to follow were that ICSID Arbitration was not maintainable
and should not have been allowed to be prosecuted any further.
6􀀚􀁢 Mr. K.M.A. Samdani, learned counsel for the appellant submitted that the trial Court
before deciding the application by passing formal express order as envisaged under section
20 of the Arbitration Act of filing the agreement in the Court, after disposal of the
application of the appellant for stay of proceedings directly, proceeded to pass order
mechanically calling upon the parties to propose a panel of arbitrators for appointment to
proceed with arbitration. This contention has been raised on the assumption that it was
mandatory to pass express order of filing of arbitration agreement whereas according to
settled law, it was not necessary to do so for execution of agreement in question had not
been disputed, therefore, the order calling upon the parties to propose panel of arbitrators
can safely be construed to be an order of acceptance of the said application of the
respondent. Reference may be made to the case of Messrs Ama Corporation, Madras v.
Food Corporation of India (AIR 1981 Madras 121) in support of this view. It has been held in
this case that if the Court passes an order for reference of the matter to arbitrators, it
would amount to acceptance of the application and no formal order of filing of arbitration
agreement is necessary, for the Court while passing such an order would be deemed to have
taken the agreement on the file. A perusal of memo, of appeal filed by the appellant before
the High Court also reveals that the appellant was itself not in doubt about this legal
position as the appeal was directed against the order dated 7-1-2002 of the trial Court
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treating it as an order of acceptance of application made under section 20 of the Arbitration
Act.
68􀁢 Faced with this situation, Mr.K.M.A. Samdani learned counsel for the appellant
submitted that the High Court did not advert to this aspect of the case, though ground had
been raised that formal order of acceptance of the said application was to precede the
direction of calling upon the parties to propose panel of arbitrators or making order for
reference to the arbitrators. Nothing turns on it, for such an argument did not deserve any
serious consideration or attention as it has been held that no such formal order was
necessary and the order passed by the Court on 7-1-2002 did constitute acceptance of the
application of the Federation of Pakistan because as observed above, there was no dispute
about execution of the agreement and other objections raised in the application made under
section 41 had already been rejected.
􀀚0􀁢 For what has gone before the appellant is debarred from raising objection against
arbitration Clause 11.1 of the agreement and maintaining and continuing with the ICSID
Arbitration which has been commenced and being pursued as counterblast to the present
arbitration proceedings and as such lacked bona fides.
􀀚1􀁢 Mr.K.M.A. Samdani, learned counsel for the appellant submitted that by subsequent
order, dated 4-3-2000, the trial Court appointed the arbitrator after having received no
response from the appellant, therefore, the said order would be deemed to be an order of
disposal of application filed by the respondent under section 20 of the Arbitration Act
against which appeal could still be filed as period of limitation prescribed under the law had
no run out.
􀀚2􀁢 The argument has no substance. The said order is a subsequent order of appointment of
arbitrator and not an order of disposal of the application which shall be deemed to have
been accepted by the order dated 7-1-2002 when the objection against these proceedings
raised by the appellant were rejected and the parties called upon to propose panel of
arbitrators:
􀀚3􀁢 Mr.K.M.A. Samdani, learned counsel for the appellant submitted that the arbitrator
appointed by the trial Court issued notices to the parties on 6-3-2002, therefore, legally the
arbitration proceedings shall be deemed to have commenced from the said date which
being later in point of time than the date when the appellant filed consent to ICSID
Arbitration on 10-10-2001 therefore, these proceedings were liable to be stayed instead of
proceedings of ICSID Arbitration.
􀀚4􀁢 The arguments in our considered view is devoid of any force apart from being plainly
unsound. It is also on the erroneous assumption as if mere act of consenting to ICSID
Arbitration of the appellant had the effect of commencement of ICSID Arbitration which is
not the legal position. Application under section 20 of the Arbitration Act from which these
appeals have arisen was filed by the respondent on 7-9-2000 to which reply was filed by the
appellant on 7-4-2001. If the filing of the said application on 7-9-2000 by the respondent is
treated at par with the filing of consent to ICSID Arbitration on 10-10-2001 by the appellant
and formal request for ICSID Arbitration by it on 12-10-2001 as the dates of institution of
both the proceedings, the proceedings commenced by the respondent before the trial Court
are earlier in time. If according to the criteria on the basis of which these arguments have
been advanced i.e. notice issued by the arbitrator on 6-3-2002 in these proceedings is to be
taken as the date of commencement of arbitration proceedings, in the same manner, formal
notice issued by the ICSID to the respondent on 17-4-2002 is to be treated as the date of
commencement of those proceedings, even then the date of commencement of arbitration
proceedings initiated by the respondent is earlier, as such, seen from whatever angle, the
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Subscriber: Honourable Society of Gray's Inn; date: 05 July 2019
proceedings initiated by the respondent are earlier in time, therefore, the argument is
hereby repelled.
􀀚5􀁢 Mr.K.M.A. Samdani, learned counsel for the appellant before the conclusion of the
arguments feebly argued that the respondent was simultaneously pursuing the remedy in
Switzerland for the recovery of specified amounts evidenced by copy of an order dated
26-1-2001 placed on the record of the trial Court issued in this behalf by Swiss Authorities
directing the appellant to pay the said amounts for which reason the respondent was legally
debarred from maintaining the present proceedings.
􀀚6􀁢 We summoned the record of the trial Court which is available and find that order of
payment issued by the Swiss Authorities relates to recovery of amounts in connection with
judgment passed by the Swiss Supreme Court in the appeal filed by the appellant and has
no nexus with the amount which according to the respondent-Federation is due to it under
the agreement in question.
􀀚􀀚􀁢 Before parting with this judgment, we would like to dispose of another contention
raised by Mr.K.M.A. Samdani, learned counsel for the appellant which was to the effect that
in these proceedings, the Court should have refrained from expressing any opinion on the
questions relating to the merits of ICSID Arbitration, its maintainability and the right of the
appellant to invoke ICSID Arbitration which may be left to be decided by the ICSID if any
objection raised in those proceedings by the respondent. The contention in the facts and
circumstances of this case is not tenable. It was the appellant who approached the trial
Court through application under section 41 of the Arbitration Act objecting to the
maintainability of the proceedings under section 20 of the Arbitration Act mainly on the
grounds that ICSID Arbitration had supremacy over the arbitration clause in the agreement
which had become subservient to the Bilateral Investment Treaty, therefore, all these
questions inclusive of the legal effect of the judgments of the Swiss Courts, were directly
and substantially in issue as such, it was necessary to decide the same for the disposal of
the said objections raised by the appellant who had submitted to the jurisdiction of the
Court.
􀀚8􀁢 The appellant did not file the names of the proposed arbitrators in response to the
direction given by the trial Court whereas the respondent proposed the names of Mr. Justice
Retd. Nasir Aslam Zahid and Mr. Justice Retd. Shafi-ur-Rehman of this Court. There is
nothing on the record that any of the parties raised any objection to the appointment of any
of the two learned retired Judges proposed by the respondent as sole arbitrator but the trial
Court proceeded to appoint Mr. Justice Retd. Khalil-ur-Rehman Khan of this Court as
arbitrator by observing that in its view, he was impartial person. We would not countenance
this act of the trial Court which should be very careful while expressing any opinion about
impartiality or otherwise of any of the learned retired Judges of this Court. The order of
appointment of Mr. Justice Retd. Khalil-ur-Rehman Khan as sole arbitrator is set aside and
we hereby direct the trial Court to nominate anyone of the two learned retired Judges
proposed by the respondent as sole arbitrator.
􀀚9􀁢 We may also before closing the judgment express our appreciation to the valuable
assistance rendered by the learned Attorney-General and Mr. K.M.A. Samdani and their
Associates who assisted them due to which we were able to decide intricate questions of
law involving in this case.
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Subscriber: Honourable Society of Gray's Inn; date: 05 July 2019
80􀁢 For the foregoing reasons, Civil Appeal No.459 of 2002 filed by SGS is hereby dismissed
with the direction that the respondent-Federation shall neither be allowed to file any claim
based on the allegations as contained in paragraphs 3 of the application made under section
20 reproduced in the earlier part of the judgment as regards bribes, commission and
kickbacks allegedly received in connection with the agreement nor raise any pica which has
been held to be not arbitrable in HUBCO case (supra) and allow it to lead any evidence in
relation thereto meaning thereby that arbitration proceedings shall be confined to the
claims based on the terms and conditions of the agreement in question. However, the
respondent-Federation may seek independent remedy if available to it under the law qua
those allegations.
82􀁢 Civil Appeal No.460 of 2002 filed by the Federation of Pakistan is accepted and the SGS
(appellant in C.A. No.459 of 2002) is hereby restrained from taking any step, action or
measure to pursue or participate or to continue to pursue or participate in the ICSID
Arbitration.
83􀁢 The parties are, however, left to bear their costs.
M.B.A./S-210/S
Order accordingly.
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