Koumentakis

Tag: employee protection

  • Unpredictable Work Pattern

    Unpredictable Work Pattern

    Among the particularly interesting regulations of the recent labor law (law 5053/2023) is the one that introduces the schedule for unpredictable work patterns. An arrangement that provides special opportunities but also rises, at the same time, significant questions. On them, the present article!

     

    Contracts made to Order

    The aforementioned recent labor law introduces the hitherto unknown – as far as the national legal order is concerned – contracts “made to order” (art. 10 of law 5053/2023, 182A Presidential Decree 80/2022). The contracts, i.e., within which (and under specific conditions) a framework is set, where the employer has the opportunity to call the employee to provide their services – if the relevant need arises. In the specific contracts there is no (entirely or mostly) fixed working hours.

     

    Conditions of Acceptance on the Part of the Employee

    The “new” law sets two specific conditions for the implementation of this provision. These should be fulfilled cumulatively, in order for the employee to be obliged to accept the terms of the employment, in cases where there is (entirely or mostly) an unpredictable work pattern (art. 182A § 1 Presidential Decree 80/2022). Specifically:

    (a) Work must be provided within pre-specified reporting days and times. The days and hours in question are part of the essential terms of the contract or employment relationship, which the employer is obliged to notify, in writing, to the employee. Either by delivery of a tangible form or in an electronic form (under the conditions of the law – art. 70 § 1, paragraph ic΄, subparagraph icb’).

    (b) The employee must have been notified, a reasonable time in advance, by the employer of the assignment of the work in a specific way: via the delivery of relevant documents, via text message on a mobile phone (: sms), via e-mail or via another convenient way. The specific, reasonable, time cannot be less than 24 hours before the work is due to start. Unless there are cases that justify, objectively, a shorter notice. And in this case, the employer is obliged to notify the employee of the (objective) condition in question (art. 70 §1, para. i΄, subpara. ig΄).

    In the event that the two, above, conditions are not met, cumulatively, the employee has the right to refuse to take up the work. In fact, in order to safeguard the employee, the legislator expressly states that in this case any adverse discrimination against them by the employer is prohibited (art. 182A § 2 Presidential Decree no. 80/2022).

     

    Canceling an assignment

    In the event that at any time, after the employee has been notified of the provision of work (and, in any case, before the provision of work has been taken up), the employer cancels the assignment, the employee is entitled to compensation. The amount of the compensation corresponds to the hourly wages of the working hours that were not assigned to them (art. 182A § 3 Presidential Decree 80/2022). The choice, therefore, of the national legislature was not to allow the employer to cancel the assignment of work, in principle, without compensation and the payment, in the end, of it, if they call off the assignment of work after a certain reasonable period.

     

    Guaranteed Hours Agreement

    In order to safeguard the employees, the obligation to agree on guaranteed hours is established. That is, if the employer and the employee enter into a contract with the immediately above content (:unpredictable schedule) they must, at the same time, agree on a minimum number of paid working hours. This number cannot be less than 1/4 of the agreed total number of hours. Otherwise, the contract is void (art. 182A §4 Presidential Decree no. 80/2022). The provision for guaranteed hours has the effect that the above contracts do not constitute (nor can they constitute) zero – hours contracts. In the event that the specific guarantee was not in place, such a characterization would be appropriate.

     

    Employee Protection

    The above arrangements aim to ensure the employee a minimum level of predictability regarding their working hours. To also provide them with protection against loss of income due to late cancellation of the agreed work (see in this regard, Memorandum to law 5053/2023 on art. 10).

    Furthermore, in the event of the conclusion of the above-mentioned contracts, all protective provisions related to the employee’s contract or employment relationship shall apply to the employee. Any conversion (unilaterally made by the employer) of a full-time or part-time employment contract to a bespoke employment contract is expressly prohibited by law. Such a (unilateral) conversion is considered as a unilateral detrimental change in working conditions (art. 182A § 5 Presidential Decree no. 80/2022).

     

    The Problems

    The above regulation (: art. 10 law 5053/2023 – art. 182A Presidential Decree no. 80/2022), creates a multitude of concerns for those who are asked to apply it. The most important ones:

    (a) As to the range of reference hours and days

    Would it be possible for an employer to determine (on a reference day) as reference hours – the hours within which the employee will be called upon to provide work – any number of hours? E.g. from 08:00 in the morning to 20:00 at night? Could the said period even approach 24 hours? What, then, are the limits of abuse? (if, of course, there are any).

    (b) As to the type of contracts in question

    Do the above contracts constitute full-time or part-time contracts, in the event that the total number of working hours agreed in them amounts to 40h/week? What are those hours that will be taken into account for their qualification? The agreed or the guaranteed ones? Is there, subsequently, an obligation to prepare them in writing (:constituent form) and notify them within eight days to the Labor Inspectorate (:submission of form E9 to the ERGANI platform)?

    (c) Regarding the remuneration of the agreed and guaranteed hours of employment

    It becomes apparent, in the writer’s view (although contrary views have been expressed), that both agreed and guaranteed working hours (which are subset to the relevant agreement) are paid based on the agreed hourly wage. What happens, however, if the agreed total number of working hours falls short of a full-time employment contract? Let’s remember here the legislator’s explicit reference to the application to “custom” contracts of the provisions protecting the employee, linked to the contract or dependent employment relationship. One could thus support that the position that for hours of employment beyond those agreed upon, an increase of 12% is due on the hourly wage paid (art. 106 § 11 Presidential Decree no. 80/2022).

    (d) As to exceeding working time limits

    In the event that the agreed total number of working hours falls short of the full-time hours, are the full-time hours set as the maximum daily limit of the employer? Is, therefore, possible-in this case, to apply the provisions set for overwork and/or overtime (art. 106 §11 Presidential Decree no. 80/2022)?

    (e) Regarding the possibility (or not) of interrupted hours

    In the event that the agreed total number of working hours falls short of the full-time working hours, must the working hours be consecutive (art. 106 §11 Presidential Decree no. 80/2022)? And in the event that full time is agreed, can it be intermittent? And, in the affirmative, under what conditions (art. 165§3 Presidential Decree no. 80/2022)?

     

    The arrangements for the unpredictable work time schedule are, of course, extremely interesting. And they will certainly prove to be valuable for those companies that have similar needs. The interest in making use of these arrangements (which has already become particularly lively) proves the truth of the matter. We await with great interest the implementing ministerial decision that will provide answers to the crucial, as stated above, questions and related concerns.-

    Stavros Koumentakis
    Managing Partner

     

    P.S. A brief version of this article has been published in MAKEDONIA Newspaper (December 3rd, 2023).

     

    Disclaimer: the information provided in this article is not (and is not intended to) constitute legal advice. Legal advice can only be offered by a competent attorney and after the latter takes into consideration all the relevant to your case data that you will provide them with. See here for more details.

  • Managing Working Time

    Managing Working Time

    The management of working time (as regulated in Article 41 of Law 1892/1990), has repeatedly occupied us. Also, in the spring of 2020, we were concerned, on the basis of the issues relating to eight-hour working days, with the possibilities of reforming the system of the management working time. In fact, the signatory proposed, for the first time in our country, a specific legislative provision for the management of working time – in the standards, in fact, of Germany and Cyprus, which successfully utilize the institution. For the benefit of both employees and businesses.

     

    Opponents of the reform and the legislator’s timidity

    It is well known that every reform meets opponents. Sometimes fierce ones. Often without logical arguments.

    The recent labor law (: law 4808/2021) proceeded to a very comprehensive reform of labor law. With some of its provisions, it attempted to re-approach the regulation of the management of working time.

    The legislator, however, was extremely timid.

    The regulation of the management of working time has met, already at the stage of its drafting, a significant number of opponents. They claimed that the new regulation is being introduced: “to abolish the eight-hour working days”, “to abolish overtime” or “to pay the overtime of employees on a break”.

    Such and corresponding, absolutely illogical, accusations as well as the pressures that, in general, were exerted on the parliamentary majority led, as we will analyze below, to a simple re-approach of the legislation of a decade ago. A historic opportunity for legislative modernization, in the context of European legislation and modern European practices, has been lost (: Working Time Management – A Missed Opportunity?).

    The aim of the present article, however, is not another critical evaluation of the new regulation (: article 59 of Law 4808/2021). We will attempt, however, a brief analysis of the new data.

     

    The dual system of managing working time

    The older provision (: art. 41 law 1892/1990-as maintained in force by law 4808/2021) provides for a dual system for the management of working time. This means that the management agreement can take place within the time limits specified by each of the following alternatives:

    (a) First alternative: Ability to provide additional working hours for a specific period (: increased employment) which will be subtracted, respectively, from the working hours of another period (: reduced employment). The periods of increased and decreased employment may not exceed a total of 6 months in a period of 12 months (d. 42 §1 a’) and

    (b) Second alternative: Ability to allocate 256 working hours, within a calendar year, to periods of increased work that cannot exceed 32 weeks per year. During the remaining period of the year, work is provided of reduced duration, respectively, in relation to the maximum legal time limits (d. 42 §2 a’).

     

    Who was entitled to agree on such a management of working time?

    Under the previous legislation, the management of working time could not be the product of an individual employer-employee agreement. It could be determined only: “… by business collective labor agreements or by agreements of the employer and the union of the business or the employer and the employees’ council or the employer and the associations of persons…” (art. 42 §6 Law 1892 / 1990).

    This restriction has rendered, in essence, the legislative provision inapplicable. The lack of a collective entity within a company (the most common case) was an inaccessible obstacle to the implementation of a working time management system.

     

    The management at the request of the employee

    The recent, relevant regulation (: article 59 §1 law 4808/2021) removed, in essence, the previous restriction. It is now possible to manage working time, as described above in its two alternatives, at the request of the employee and after a written individual agreement with the employer.

    A prerequisite, however, for such an individual agreement to be permissible, is: (a) either the lack of a trade union organization in the company, (b) or the failure to reach an agreement between the (existing) trade union organization and the employer.

     

    The specific conditions

    A recent Circular of the Ministry of Labor and Social Affairs (: protocol no. 64597 / 03.09.2021-hereinafter “Circular”) sets three conditions for the adoption of a management system, at the request of the employee.

    The specific conditions are:

    (a) Submission of a signed application of the employee: As discussed above, the law requires a prior application of the employee to the employer, as in the above Circular, the application of the employee must be signed. It may, however, be in written (: printed) or in an electronic form. At the same time, it must exist and be kept in the employer company.

    (b) Explicit term in the employment contract and its amendment: In addition, the Circular stipulates the existence of an explicit term in the individual employment contract on the agreement of the applicant employee and employer for management. And then, “the modification of the individual contract in the part concerning the duration of daily and weekly employment, by notifying the employee of the applied settlement system agreed in accordance with the provisions of Presidential Decree no 156/1994″ Obligation of the employer to inform the employee about the conditions governing the employment contract or relationship”.

    The wording of the Circular raises questions. The management of working time at the request of the employee is a facility provided by law. At the same time, from the wording of the provision of article 59, there is no obligation to include the above possibility in the individual employment contract. Especially if one considers that the latter, as a rule, is not required to be subject to a written form. Therefore, the requirement of the Circular for the existence of an explicit condition in the individual employment contract obviously has no legal basis. Such a term can only be informative.

    The distorted wording of the condition of the Circular seems to stem from the unfortunate, as it turns out, identification of the individual employment contract with the document notifying the essential terms of the working conditions. However, the employment contract should not be confused with the notification document of its terms [for the distinction: Employment contract = Written Notification of Essential Terms (Urban Myth Ή, Maybe, Not?)].

    The document notifying the working conditions is an obligation of the employer, arising from the Presidential Decree no. 156/1994. This obligation of the employer relates to the essential terms of the employment contract or relationship. Specifically, the employer must fulfill the above obligation within a period of two months from the preparation of the employment contract (article 3 §1 Presidential Decree 156/94). Also, within one month from the realization of a possible change (article 5 §1 Presidential Decree 156/94). Among the essential terms are included “the duration of the normal daily and weekly employment of the employee” (article 2, §2 h’ of Presidential Decree 156/94).

    It is therefore reasonable to notify the employee with the working conditions notification document, following the modification of daily and weekly employment due to the implementation of a management system. This happens, after all, in any case of change of the conditions recorded in the above document.

    On the other hand, any individual management of the settlement system does not reasonably require the individual employment contract to be amended. The latter, after all, may not even describe the daily and weekly working hours.

    (c) Obligation to submit a supplementary staff list: Lastly, the Circular emphasizes the obligation of the employer to submit a staff list (E4 Supplementary schedule) to the ERGANI Information System (obligation defined, after all, in article 78 of law 4808/2021). This list should be accompanied by an attached program, which will capture the applicable management system of the working hours. This will provide, respectively, the applicable reference period.

    In any case, the above documents should be kept by the employer and provided to the Labor Inspectors at a possible scrutiny.

     

    Employee protection

    The law (: art. 59 law 4808/2021) provides for the protection of the employee involved, as follows:

    Protection against dismissal

    As mentioned above, the individual employer-employee agreement for the management of working time requires a prior request of the employee. It is therefore at the discretion of the employee to initiate the management system agreement procedure. Given the specific regulation, Law 4808/2021 explicitly prohibits the termination of the employment contract of the employee who requested a regulation of their working time.

    The absolute protection of the employee from the termination of their employment contract is found, respectively, in article 66 §1 c.cjc’ Law 4808/2021. However, the wording of the law in the above-mentioned regulation deviates slightly from what we have noted above about the individual management of working time.

    In particular, it is provided that: “The termination of the contract of employment for an indefinite period of time by the employer is invalid, if: c) it is contrary to another special provision of law, in particular, in the case of dismissal: cjc) …of the employees who did not submit a request for management, according to par. 6 of article 41 of law 1892/1990, although they were requested by the employer. ”

    It does not follow from article 59 §1 of law 4808/2021 that the employer can request the management of working time from the employee. However, the legislator in Article 66 seems to reflect the logical sequence that the process of individual management of working time would be expected to have. As well as the notification of the possibilities and needs of the business by the employer the management would reasonably be the trigger for a corresponding request from the employee.

    Protection in case of termination of the employment contract

    In addition to the above, Law 4808/2021 regulates the case of termination, for any reason, of the employment contract, while a system of management of working time is applied (article 59 §2). Before, however, the employee receives, in whole or in part, the time compensation provided during the period of reduced employment.

    In this case, the employee receives, at the termination of their employment contract, compensation for the overtime hours they worked during the period of increased employment. Their compensation in this case is calculated on the basis of the remuneration provided for overwork and overtime, as defined in Article 4 of Law 2874/2000 (as amended, in force by Law 58 of Law 4808/2021 – with which we were occupied in a previous article).

     

    An important opportunity was lost, as mentioned in the introduction, for the modernization and rationalizing of the management of working time – based on European legislation and good practices.

    But the problem was not limited to the loss of the relevant opportunity: Unreasonable pressures led to unreasonable distortions: The management of working time can, already, take place only at the request of the employee [as if it was prohibited (!) to be requested by the employer- there are no threated sanctions for the potential offender]. And even more: we see legislative attempts being made through a Circular of the competent Ministry, with serious legal problems.

    In any case: the management of working time, as in force at European level, will inevitably be implemented in our country as well. Despite the reactions. Despite the setbacks. Despite the delays. For the benefit, however, as has been shown, of both employees and businesses.

    We hope, for now, for the correction of the wrongdoings.

    The soonest possible.-

    Stavros Koumentakis
    Managing Partner

     

    P.S. A brief version of this article has been published in MAKEDONIA Newspaper (November 7th, 2021).

     

    Disclaimer: the information provided in this article is not (and is not intended to) constitute legal advice. Legal advice can only be offered by a competent attorney and after the latter takes into consideration all the relevant to your case data that you will provide them with. See here for more details.

  • The Safety Engineer and the protection of the life and health of employees

    The Safety Engineer and the protection of the life and health of employees

    The obligation to protect the life and health of the employee – The Safety Engineer

    In our previous article we referred to the ancillary obligations of the Employer deriving from the employment contract and employment relationship that they develop with their employees. The obligations that are characterized as “ancillary” are not, at all, of minor importance and value. After all, how would one characterize as minor obligations related to the protection of the life and health of the employee? Their fulfilment is required (and rightly so) by the existing institutional framework. The advent of the pandemic, moreover, reminded us very strongly of their value. But life and health are goods that we must protect at all times. Of course, in the work environment as well. The Safety Engineer (should) work in this direction. Respectively, the Occupational Physician who occupied us in our aforementioned article.

    Let us now try to approach the institution of the Safety Engineer.

     

    Η κύρια και οι παρεπόμενες υποχρεώσεις του εργοδότη από τη σύμβαση εργασίας

    The main and ancillary obligations of the employer deriving from the employment contract

    We have already seen in our previous articles that the main obligation of the employer is the payment to the employee of the legal or, as the case may be, the agreed upon salary (648 Civil Code). The employer, however, is also burdened with the “welfare obligation” which can be broken down in several ancillary obligations. Among them are those related to the protection of personal and property goods of employees. The protection, ie, of their life and health, their personality and property.

    The fulfillment of the specific obligations is not left to the good will of the employer. The State has not chosen to remain a passive spectator. It enforces and supervises their implementation based on the existing institutional framework. A possible breach of the above ancillary obligations is linked to a number of civil, criminal and administrative sanctions. It is these data that, among other things, demonstrate the special care of the State regarding their observance.

     

    Ειδικότερα: η υποχρέωση προστασίας της ζωής και της υγείας του εργαζόμενου

    In particular: the obligation to protect the life and health of the employee

    The obligation to protect the life and health of employees is ensured by a series of provisions of civil, public and criminal law.

    The obligation of the employer to protect the life and health of the employee in the context of the employment relationship is established by the Civil Code. The relevant provision (662 of the Civil Code) provides: “The employer must arrange for the work and its premises, as well as for the accommodation, facilities and machinery or tools, in order to protect the life and health of the employee.”

    In addition, there is a set of provisions of public law aimed at the comprehensive protection of employees. These provisions constitute the legislation on health and safety at work.

    These are the provisions that are part of either the general or the specific, relevant, legislation. That means that some provisions concern all employees, while others concern only specific categories of employees (eg Presidential Decree 788/1980 “on security measures during the execution of construction projects”).

    A milestone in the legislation for the health and safety of employees is Law 1568/1995 (: “Health-Safety of employees”). This law has been innovative in the field of obligation of the employer to precautionary protect the life and health of employees. Its scope extends, with few exceptions, to all activities of the private and public sector. After the adoption of this law, various, supplementary, legislations were issued. All of them were codified by Law 3850/2010.

    The innovations of law 1568/1995 concerned the introduction of completely new institutions in the field of safety and health at work in our country. As such are the institutions of the Safety Engineer and the Occupational Physician -already provided for by Law 3850/2010.

     

    The Safety Engineer

    The obligation to employ a Safety Engineer

    The obligation to employ a Safety Engineer concerns all businesses. And this regardless of the number of employees they employ (article 8 §§1 & 2 law 3850/2010).

     

    The role and duties of the Safety Engineer

    The role of the Safety Engineer (who is organizationally directly under the management of the business) is preventive and advisory. It aims to create a safe working environment with the ultimate goal of preventing accidents at work.

    The advisory responsibilities of the Safety Engineer are provided in detail in the provision of article 14 of law 3850/2010.

    The Safety Engineer ” provides suggestions and advice to the employer, in writing or orally, on issues related to the health and safety of employees and the prevention of accidents at work. The written instructions are recorded by the Safety Engineer in a special book of the business, which is paged and certified by the Labor Inspectorate. The employer is obliged to be informed of (and sign as a testimony that they were informed) of the suggestions that are registered in this book “. (Article 14 §1)

    In addition, “advises on the design, planning, construction and maintenance of facilities, the introduction of new production processes, procurement of tools and equipment, selection and control of the effectiveness of personal protective equipment, as well as configuration and arrangement of jobs and work environment and general organization of the production process” (article 14 §2 par. a).

    At the same time, the Safety Engineer “checks the safety of the facilities and technical means, before their operation, as well as the production processes and working methods before their application and supervises the implementation of the health and safety measures of the employees and the prevention of accidents, and give the relevant information to the competent heads of departments or to the management of the business (article 14 §2 par. b).

    At the same time, the Safety Engineer has supervisory responsibilities, which are provided for in detail in the provision of article 15 §1 of law 3850/2010. Specifically, they must:

    “(a) regularly inspect the occupational health and safety of employees, report to the employer any omissions of health and safety measures, propose measures to deal with them and supervise their implementation;

    (b) supervise the proper use of personal protective equipment;

    (c) investigate the causes of accidents at work, analyze and evaluate the results of their investigations and propose measures to prevent similar accidents;

    1. d) supervise the execution of fire safety and alarm drills to determine the readiness to deal with accidents”.

     

    Finally, in order to improve working conditions, they are obliged (article 15 §2 law 3850/2010):

    “(a) to ensure that employees in the undertaking comply with the rules of health and safety of employees and inform and guide them to prevent occupational hazards posed by their work;

    (b) to participate in the development and implementation of employee health and safety training programs.”

     

    Who can act as a Safety Engineer?

    The employer has several options for hiring a Safety Engineer. They can choose as a Safety Engineer someone already employed by their business or a third person. They can also choose to receive these services from a company that provides External Protection and Prevention Services. In some cases, the employer themselves are entitled to perform the duties of a Safety Engineer. The employer can also adopt a combination of the above options (article 9 §1 law 3850/2010).

    However, the selection of the Safety Engineer by the employer is not without conditions. It is, on the contrary, a associated with the category to which the business belongs and the number of employees it employs.

    Businesses are classified into three categories (A, B and C) depending on the sector of their economic activity (Article 10 of Law 3850/2010). This categorization proves to be particularly important, as it determines: (a) the working hours of the Safety Engineer (article 21 of law 3850/2010) and (b) the qualifications that they must have (article 11 of law 3850/2010).

     

    Η υποχρέωση γνωστοποίησης στην Επιθεώρηση Εργασίας

    The obligation to notify the Labor Inspectorate

    The employer is obliged to notify in writing to the Labor Inspectorate the information of the one who assumes the duties of the Safety Engineer. When the latter is a third party, the employer is obliged to share a copy of their employment contract In the case of hiring company that provides External Protection and Prevention Services, the employer must also share the relevant contract, which in fact must bear the content defined by law (article 9 §7 of law 3859/2010). Finally, when an employee of the business is appointed as a Safety Engineer, the employer must share with the Labor Inspectorate a copy of the written assignment of duties and, in addition, of the corresponding declaration of acceptance.

     

    Η Εκτίμηση του Επαγγελματικού Κινδύνου

    Occupational Risk Assessment

    Occupational Risk Assessment is the written assessment of the risks created at work. Risks related to the safety and health of employees. It concerns the existing risks and, in addition, those that are likely to occur. It includes, of course, the groups of employees who are exposed to particular risks.

    The Occupational Risk Assessment is, unfortunately, a rather degraded obligation in the minds of most of us. It is, however, particularly important. And, most importantly, legally mandatory for all businesses, without exception. It is subject to the special obligations of the employer (article 43 of law 3850/2010).

    The drafting of the Occupational Risk Assessment can be carried out by: (a) the Safety Engineer, (b) the Occupational Physician, (c) the company that provides External Protection and Prevention Services.

     

    Its purpose is:

    “a) to identify the sources of occupational risk, ie what could pose a risk to the safety and health of employees;

    1. b) to determine whether and by what measures the sources of risk can be eliminated or avoided, and if this is not possible;
    2. c) to record the precautionary measures already in place and propose what should be taken in addition to controlling risks and protecting employees. “

     

    Ensuring the life and health of their employees is one of the most important obligations of the Employer. There is an adequate legal framework that defines and sufficiently specifies its obligations. As we mentioned in the introduction, the Safety Engineer, the Occupational Physician and the Occupational Risk Assessment hold important positions among them.

    The Safety Engineer and their services should not be approached as another “burden” of the business. We see their value, as a rule, only when something bad happens. We then (we, the Safety Engineer and the Labor Inspectorate) refer to the Safety Engineer’s suggestions in the relevant book – as well as to the Occupational Risk Assessment.

    Afterwards.

    Unfortunately.

    Let’s try to see things “differently”.

     

    The selection and utilization of the services of the appropriate Safety Engineer ensures the life and health of the business’s employees. It is a stabilizing factor in business-employee relations. It increases the degree of satisfaction of the latter. It reduces potential problems (of civil, criminal, administrative nature – and more) of the business. It increases its prestige. Reduces its costs. It helps the entrepreneur and senior management to focus on business development and ultimately prosperity.

    And when the (always undesirable) accident at work takes place, one thing is for sure: its consequences will be more mitigated in relation to the (possible) non-implementation of the measures indicated by the Safety Engineer.

    Let us therefore support and further strengthen the institution and the work of the Safety Engineer.

    Only benefits for employees and, of course, for the business can be obtained!

    Stavros Koumentakis
    Managing Partner

     

    P.S. A brief version of this article has been published in MAKEDONIA Newspaper (November 8, 2020).

     

    Disclaimer: the information provided in this article is not (and is not intended to) constitute legal advice. Legal advice can only be offered by a competent attorney and after the latter takes into consideration all the relevant to your case data that you will provide them with. See here for more details.

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