Request for derogation from application by analogy of Commission staff implementing rules

The BEREC Office requests the Commission’s agreement for derogation from the application by analogy of the Commission decisions:
Commission Decision C (2016) 3288 on middle management staff, adopted on 15 June 2016;
Commission Decision C (2016) 3828 on the implementation of the learning strategy;
Commission Decision C (2016) 3866 on the training on the own initiative of the staff;
Commission Decision C (2016) 3827 repealing the rules on learning and development.
The reasons for request non-application are:
The responsibilities assigned to different actors in the Decision do not reflect the responsibilities and decision making process for the appointment of staff established by the establishment act of the BEREC office; some of the concepts in the Decision are not suitable for an Agency with the size of the BEREC Office.
The Commission decision do not reflect the decision making process, the structure and the hierarchical levels of the BEREC Office.