cross-border interest

#6 - Piotr Bogdanowicz (University of Warsaw)

How do we deal with cross-border interest in public procurement? (II)

Interview with Piotr Bogdanowicz, assistant professor in European law at the University of Warsaw. Piotr is also a legal adviser and has authored more than 40 articles on European Union law and public law. As with the previous podcast, the main topic for my conversation with Piotr is once more cross-border interest in public procurement, particularly the complex cross-border interest test created by the Court of Justice in the early 2000s.


Piotr, welcome to the PPP.

Good morning, Pedro.

It’s great to have you here, I’m really, really thankful that you were able to make yourself available for the podcast, especially at such an early hour in the day.

My pleasure.

I would like to start this podcast as I did the last one, to talk about cross-border interests in public procurement. So in your view, why do you think that cross-border interests is important in EU public procurement law?

Starting from the beginning in fact, cross-border interest is important in EU law because if we don’t deal with the cross-border interest then we have a so called purely internal situation. So we cannot use, for instance, freedoms of internal market, and as far as EU public procurement law is concerned, the situation is the same - it limits the scope of EU public procurement law and in principle if we deal with a cross-border interest then EU public procurement directives have to be followed. Moreover, all the general principles of EU public procurement law have to be followed as well. And that’s the main problem, because if we apply EU public procurement directive then the situation in principle, in theory is very simple. We follow public procurement directives if some certain thresholds are exceeded. But if we don’t exceed these thresholds then the situation is more interesting because according to the European Court of Justice we should follow EU public procurement rules like non-discrimination, equality or transparency even if in such cases. And that’s the problem of the definition of cross-border interests.

In the last podcast I was talking with Andrea Sundstrand about the same topic, and one of the things that we discussed was that for contracts about the financial threshold of the directives that justified application of the directive, there’s no assessment whatsoever of the cross-border interests of those contracts. You just apply EU law because they have a value over that threshold. The cross-border interest only applies for contracts below the threshold or that have been excluded from the scope of application of the directives. So in theory what you’re saying makes sense and it’s logic, in practice there’s been some concessions to that principle.

Yeah, but the fact that we use, that we follow EU public procurement directives because thresholds are met is based on assumptions that such contracts, might interest the contractors from other Member States. And as you said, is only principles because I can clearly imagine a situation when we deal with the contract, which is above the threshold but still it doesn’t mean that it has to have a certain cross-border interest. And quite the contrary, I clearly can imagine the situation when we deal with the contract, which is below the financial threshold and it has a certain cross-border interest.

This is the question whether thresholds are good factors to decide whether we deal or not with cross-border interests. Of course the Court of Justice in its case law said something about cross-border interest, I mean whether there are some factors to rise the cross-border interests. And they related not only to significant value of the contract but also to the, for instance, place where the work or services are to be carried out or technical characteristics of the market. But still this depends on the case law of the Court of Justice. In  one case the Court can say that, “Due to the fact that the place are to be done somewhere, there is a cross-border interest,” and in the second case the Court can say that, “There is no cross-border interest,” and that’s the problem

I find that fascinating, that defining the application of the legal regime would, for many contracts, the contracts would depend on these almost hypothetical analogies or theoretical scenario that a contractor or authority needs to go through before they launch a procedure. So before they decide if they’re going to actually comply with EU principles, because a contractor has the cross-border interests, they need to reach the conclusion that the contract has cross-border interests, which is almost a catch-22 situation because it’s impossible for you to do without doing it. So how can you be certain that there is cross-border interest if you haven’t advertised the contract and if you have not allowed companies outside your own member state to participate in the procedure?

I do agree with you, that’s the main problem, that in theory everything looks good, so we need to follow some equal treatment, some competition, the more open contracts are the better. In theory the notion of cross-border interests and the case of cross-border interests is ok. But when we deal with it, when we look at practical things that’s the problem, the problems might arise. And for me even more fascinating is that we base our analysis on the case law of the Court of Justice because what you said, it’s absolutely true but from my point of view the problem is not only the fact that the notion of cross-border interests is hypothetical but also that these rules are being created by the Court of Justice. So the main problem is that these rules, why we should deal with cross-border interests, etc., in principle are not written in the secondary law, in directives, but are created by the Court of Justice acting as a political actor. And we deal sometimes with the situation where the judgments that are being delivered on the same day are different, like in the case of Comune di Ancona and Belgacom as far as cross-border interest is concerned. And from my perspective this is even the bigger problem apart from the fact that this is hypothetical notion, hypothetical situation.

Yeah, I agree with you because effectively it’s almost like every time that the Court of Justice produces a decision about cross-border interest it comes up with a slightly different answer to the problem. And I remember when I was doing some investigation on this topic a couple of years ago that instead of seeing any consistency in the approach, what I saw was a very characteristic way to try to solve things. So the Court of Justice will say, “Oh, on this case we think that cross-border interest means this, in another case cross-border interest means something else,” and so on and so forth. So it makes life really difficult for petitioners that want to apply public procurement rules or at least the principles to be sure that they are doing the right thing. Now, moving on to the second question, that is the situation that we have now. If you could improve the tests, what do you think that should be done?

It’s a very good question because, frankly speaking, I think that I don’t know the exact answer, but there are some potential solutions. The one that could be was proposed some time ago by AG Sharpston in her opinion, leaving the decision, how to deal with cross-border interest, to national authorities. So, national authorities should decide whether they for instance cut thresholds to the very minimum, or whether they apply some quantitative test. This of course would be in line with the principle of subsidiarity, but the problem is that it wouldn’t resolve the question of certainty. I can clearly imagine the situation where we deal with a different law in each Member State. So there is other solution, which is, in my opinion, a very radical one, but it’s very interesting and it was proposed as far as I’m concerned by you, to cut thresholds and to cut them to the very minimum. Then, we will open a public procurement market for almost all the procurement cases. In general I do agree with such approach but I have one doubt. This is a solution, which is good for experienced procurement markets and if I look at Polish market I would be very afraid whether some Polish contracting authorities would deal in a good manner with all the public procurement cases. For instance, if we have some thresholds then we can deal below the thresholds with, let’s say, some easier procedures, that is for contractors a good way. And then if we cut thresholds and we have to apply the whole procedure, even if new directives are more flexible (so also domestic law should be more flexible), then I am afraid that a lot of contracts will be finished or that a lot of contractors decide not to start in such procedures cause they don’t want to follow all these rules, which are set in the Directives. This is my only fear as regards this second solution.

It can be said that those contracts now, they need to be tendered anyway, so the contracting authorities also have the capacity issue of having to do it in the best way possible, even if the contracts are not subject to EU law.

Yes, but the rules are in such cases easier, yes. Of course you have to advertise or publicise the contract, you have to deal with some competitive rules and there should be judicial protection. Nonetheless, the rules are not so very specific, and it depends on the contracting authorities, how they deal with the tender, and if they decide to give some flexible solutions they can do it. If we are under directives and under law implementing directives we have to deal precisely in line with them.

It’s very interesting what you say because my experience in other member states is actually that below the thresholds, to a certain extent, what tends to happen is that the practice that the contracting authorities develop above the thresholds just comes down without adaptions, have you seen that happening in Poland?

The below threshold Polish market is rather flexible, so the problem is rather whether we should deal with some more general principles or not because I would say that I can even divide three categories of procurements in Poland. One of them, which is in line with public procurement law and in line with directives. The second, which is in line with principles because it has a cross-border interest and it is clear that it has cross-border interests. And the third one, which is the most interesting, when we are not sure whether we deal with cross-border interests or not. We are sure that we are out of the scope of public procurement directives but we are not sure whether we are out of the scope of general principles. And in such case in general in Poland the approach is rather more flexible than conservative.

Moving on the next topic, you work both in academia and outside academia as a legal adviser, or as a lawyer. What is your experience doing that kind of work, because it’s not very common in the UK, and what are the advantages and the disadvantages that you see on that?

That’s always a challenge, because you have to deal both with expectations of academia and expectation of the clients. As regards advantages, I am dealing with public procurement cases as a lawyer, and I can use it in my academia. For instance, when I am teaching classes I can give the students practical cases, practical information, I can say them that, “In theory the provision says that, but in practice it looks like that.” On the other hand my clients sometimes say that for them also there is a good point that I’m an academic and I know the case law of Court of Justice. For instance, once more, looking at the provisions they can say that, “We have nothing to do with EU law if we are below threshold,” and then I can say them, “No, no, no, no, no, we have to follow some rules because Court of Justice says that such contracts also can have a cross-border interest.” Disadvantage is, as I already mentioned, that in principle I’m a part time academic and a part time lawyer, and always in such cases something can lose in a specific time. And this also, the question I have to answer shortly, which way I should go.

So you think that in the near future you’re going to go one way or the other?


Yeah, I can relate to your problems. When I was a lawyer I was trying to do my Masters at the same time, it just didn’t work out, so I couldn’t make it work. I had to make a decision and in the end I made a decision to move to academia. But even to this day I still maintain the very analytical and very practical mind-set that comes with the fact that I was a lawyer for four or five years, which pretty much sets me apart from most of my colleagues. And in your case it’s going to be even more than that because you’ve been a lawyer for longer. So what do you think that you can bring, if you move to academia full time in the future, let’s say that’s the scenario on the table, what are you going to bring from your experience as a lawyer into your academic work?

I think that the most important thing would be focussing on some practical issues. Of course all the theoretical debates are interesting but in my opinion public procurement law is a very interesting academic discipline, and what we are seeing now as regards the case law of the Court of Justice is pretty interesting as we also deal with the issue of, for instance, codification of case law. So these are real important legal theoretical issues. But for me, public procurement law first and foremost is a practical discipline and when we are dealing with some solutions we should focus on practical implications of our research, not only the general discussion on theoretical grounds.

We still have a few minutes and I have a final question for you. What do you think is the next frontier for public procurement? For example, what are we not talking about that we should?

For me something, which can or should be discussed in the future is the Transatlantic Trade and Investment Partnership, TTIP, ie the agreement to be concluded between the United States and the European Union. And it is for us, I mean public procurement lawyers interesting because it relates to public procurement. Public procurement is the area, which is discussed now between the United States and the European Union. And the aims of these agreements are interesting for us because in general the European Union wants to enable EU firms to bid for a larger market, larger share of the products and services, which US public authorities buy. In my opinion behind that is that the European Union would expect that public tendering mearkets in the United States will be as open as the European Union is seeing an EU market, or that the US market will be based on the same transparency, or maybe not the same but similar transparency and non-discrimination rules. And to be perfectly frank I am not so sure whether the US public authorities are prepared for that because of course they, I’m pretty sure that they follow non-discrimination transparency rules and so on. But as we were discussing, transparency and non-discrimination rules are interpreted by the EU institutions and the Court of Justice and the commission in particular in a very expansive way. And in my opinion it’s going to be an interesting catch between the United States and the European Union in this area.

I think that’s a very good way to finish the podcast, thank you very much for your time, Piotr.

 Thank you very much, Pedro.

You can find me at my blog or on Twitter where I use two handles, @Detig for general discussion and @publicprocure for public procurement related topics. As ever I am very grateful to the British Academy for sponsoring this programme, and I’ll see you next time. 

#5 - Andrea Sundstrand (Stockholm University)

How do we deal with cross-border interest in public procurement? (I)


Interview with Dr. Andrea Sundstrand from Stockholm University. In addition to her academic career, Andrea is an expert lawyer in public procurement and has published extensively over the years. One of her most recent projects is the Procurement Law Journal, the first academic journal on the area published in the Nordic countries. Some of the articles are published in English and are available in open access. Her experience with the journal was one of the topics of our discussion in addition to the issue of cross-border interest in public procurement.



The topic of today is very close to my heart. We will be talking about cross-border interests in public procurement. I think that you have a lot of important and interesting points to raise and I believe that our next half an hour is going to very useful for people trying to understand exactly where the boundaries lie in terms of public procurement today?

Yes, I think so too.

So let’s start with the cross-border interest tests, why do you think it’s important and why should we bring attention to this almost arcane area of EU public procurement law?

Well it’s interesting because the primary law which was actually there from the beginning only regulates dealings between member states, since the EU doesn’t really think that things that only concern one member state is any concern of the EU. So for having EU laws you have to have some kind of cross-border effect and that really doesn’t matter if it’s public procurement or competition law or other kind of regulations, it has to be some kind of interaction between member states for the EU to be interested in regulating those areas. So when they looked at public procurement they said “well maybe we need some more detailed regulations than the ones in the primary law so we’ll adopt directives of public procurement”. And then of course in the directives we have these thresholds and for the longest time everybody thought that “well as long as a procurement is above the thresholds it’s covered by EU law, but when it’s below the thresholds well it’s up to the member states to decide”. And I think what nobody realised until the European Court of Justice said so is that actually some of the procurements below the thresholds could be covered by primary law since they could have an interest, suppliers from other member states. So I think this was a surprise to a lot of, both contracting authorities and suppliers that even smaller contracts actually could be covered by EU law.

By "thresholds" you mean "financial thresholds", am I correct?

Yes. The financial thresholds set, are set out in the directives so it’s like 200,000 Euros for suppliers and services for example.

But that’s a very interesting trade-off, above a certain value those financial thresholds, contracts are deemed to have cross-border interests and as such are regulated by the directives, but if those contracts have a value that is lower than the threshold then you need to apply the cross-border interest test?

Yes. And I think as I said for the longest time people didn’t realise that, they thought so to speak that the thresholds was the cross-border test, that as long as it was below the thresholds they wouldn’t actually have to bother with EU law at all, you could just use national regulations. But now since we have a couple of cases, several now from the EU Court saying that isn’t really the case because even a smaller contract could be of interest to suppliers in other member states. For example if the contracting authority is situated very close to a border or if it’s a contract where it’s normally you would get offers from other countries even though it is a small value, maybe for specific goods that are easily shipped between the member states and so on. So we have a couple of cases saying what we should look at to consider if the contract has the cross-border interests or not.

And what’s your view on that?

Well it doesn’t make it easier of course for contracting authorities to decide what rules to apply. If I take the example from Sweden we have an easier situation than you have in England because in Sweden we have regulated also contracts below the threshold rather rigorously and for example the general principles of EU primary law also apply down to the very first Swedish Crown where you buy something. So for us it’s not that big a difference really but in other countries like in Denmark where they don’t actually have any regulations on public procurement below the thresholds this would be kind of a problem because then you wouldn’t really know what rules apply to these cross-border interest procurements that are below the thresholds.

Speaking of member states as far as I know, well England, Wales and Northern Ireland they’re starting to regulate contracts below the thresholds without explicit referral to the EU primary law. I have also heard recently that Greece in one of its many reforms that it has done recently has also effectively decided to apply the regime of the directives almost from the start in terms of value instead of above the financial thresholds. What do you think is the best option for the member state?

I don’t know. I know that in Sweden we have decided to regulate more or less down to 50,000 Euros and the reason is that we think that it’s important also for below threshold procurement which is in Sweden about 80% of all procurement to be put out to competition because if contracting authorities in the north of Sweden only buy from suppliers in the north of Sweden and vice versa in the south of Sweden, our best and most cost efficient companies wouldn’t be able to grow and win contracts if we limited the market. So even below thresholds as I said it’s about 80% of all procurement, in Sweden we consider that, that’s such a big market and so much money that it’s important to put it out to competition but as long as there’s no cross-border interest this would of course be up to the individual member state to decide. I was actually working with the OECD a couple of years ago and we made a survey to look at all member states and how they have regulated their procurement below the threshold for B services and most of them have actually had put in place some kind of regulations and rules for procurement also below the thresholds and that survey is actually published on their website.

But those countries that actually regulate contracts below the thresholds do not necessarily apply EU primary law, that is to say for example they may advertise a contract in the national website but they are under no obligation of treating potential suppliers equally irrespective of where they’re based as they are above the thresholds, unless of course they actually turn out to the contract?

Well that’s the problem because if there is a contract below the threshold with no cross-border interest the member states are free to choose. They don’t really have to regulate it at all. They can buy from their friends or from their relatives or whatever the member states decide. But if you have a contract below the thresholds with the cross-border interest, primary law actually regulates those contracts and as the European Court of Justice has said for example that means that a contract has to be put out to competition, you have to have a certain contracting document, you have to treat everybody equal and so on because the general principles are applicable to those contracts.

Is it not true that one of the biggest difficulties of using the cross-border interest below the threshold is actually to define in advance and with to degree of certainty and security that a contract will generate cross-border interest?

Absolutely. And that is the whole problem and that was something that the member states thought they had solved I think by putting these thresholds into place, that okay below member states decide, above follow EU law. But now we suddenly have another threshold that we don’t really know when it is, so each contracting authority has to make a decision in advance would this contract be of interest to suppliers from other member states and that is of course a very difficult decision to make. But I guess you have to look at how did the contract attract foreign suppliers the last time we put it out to competition and such things to decide on an individual basis, but of course this is difficult.

Yeah but by default the contracting authorities will do what costs them less or fewer transaction costs so they’re going to say “well if I can get away without advertising this and without trying to ensure that we’re going to have international competition, I’m just going to think that we’re not going to have international competition and for example go directly for a direct award of a contract”. If that happened it’s pretty much impossible in most circumstances for anyone to know that a) a contract was available, was potentially available, and b) that perhaps it could have had cross-border interest?

Yes. And the interesting thing is that if you have a contact with, below the thresholds but with a cross-border interest the member states have to put efficient remedies into place for aggrieved suppliers since this is considered, to be able to participate in such contracts or such competitions are considered to be a right according to the EU law for each member or each individual in the EU. So I can take an example from Sweden, we have not put into place any remedies for service concessions and this is the same thing as contracts below the thresholds because they are both regulated only by primary law so far, and where actually had letters now from the commission saying “why didn’t you do this because this is a right for each individual to participate and be treated fairly in a service concession with a cross-border interest?” And Sweden has answered something like “well we know we haven’t done that, we should have done it but by April of 2016 we’re going to have this new law so with concessions in place”. But the commissions answer to that has been for like six months ago that “well that isn’t enough because you haven’t done it now” and I don’t think Sweden has answered that yet but there’s obviously big risk that we will actually end up in the European Court of Justice for the first time actually, we have managed to stay away from there so far. And that is the same thing with procurements below the thresholds with a cross-border interest, that actually the member states have to, they have to put into place efficient remedies for aggrieved suppliers. So even if it would be difficult to prove in a Court, you still have to have the possibility to go to Court even for those contracts and I think most member states do not have any remedies in place for those contracts.

That’s very interesting because in fact I remember seeing an opinion somewhere that the remedy system for example in England, Wales and Northern Ireland effectively only was applicable for contracts above the thresholds?

Yes. So that would actually be against EU law since you have to have for all…

I agree with you. So it appears that we have a very strange system in place, above certain financial thresholds contracts are subject to the full might of EU regulation, below financial thresholds they may or may not be subject to EU law but only to primary law, a little bit like Schrödinger's cat it appears that the contracts may be or not subject to such regulation. What could be done to improve the situation and make it easier both for contracting authorities and suppliers to understand the system?

Well that’s a good question. I wish I could answer. I really don’t know. I think your answer would be to lower the thresholds and maybe that is mine also because if there is contracts with cross-border interest then of course they should be covered by the directives because that’s the whole idea with the directives to cover those contracts that are of cross-border interest between the member states, to cover those. And if there are contracts falling outside well that is not good because that would be very confusing for contracting authorities to know what rules to apply. But I really don’t know otherwise because I think there will always be contracts not covered, very low value and so on, or at the north of Sweden where the cost to deliver something from abroad would be too high and so on. So you have to have some separation between these two contracts where the member states must be able to choose themselves if they want to regulate or not but exactly how to do that, that’s difficult and I really don’t have any good ideas for now.

Okay. Moving on. You’ve done a lot of research in cross-border interest over the last few years, where are your interests now lying in these days?

Well I am working at the Stockholm University a lot trying to teach public procurement students and actually getting the topic of public procurement up on the agenda for several universities in Sweden. We have been so far behind both Denmark and England who have several universities that specialise in these questions, in Sweden we’re just at the beginning so that’s what I’m doing. And also looking at different things constantly on public procurement and doing articles, writing out articles and different books on public procurement in general. So this is a full-time task since there is so much happening in this area right now.

Okay. So let me rephrase the question, where do you think our focus should be in terms of public procurement in the near future?

Do you mean ours as researchers?

Yes, or where should the rules change or where should be improved in general?

That’s a big question! I think there are a lot of rules that could be improved and I think it’s always difficult when you have twenty-eight member states deciding new rules. So I think in the coming two or three years our focus both as practitioners and as researchers will be just to try to understand the new rules coming and to try to figure out what they actually mean in practice. Because there’s one thing to be in Brussels with twenty-eight member states to decide rules, totally different thing is for the contracting authorities in the north of Sweden actually trying to apply these rules. So I think that will be the focus for the coming years.

So you think that the focus is going to be into training and in improving the skills of public procurers and also people that work with the rules in practice?

Very much practice because now the big legislation package are soon coming into place, the lawyer’s task now will be to try to explain these rules to the practitioners I think.

Okay, very well. I’ve got one final topic that I would like us to cover which is your new Procurement Law Journal?


You started it in 2014, it’s in the second year, how is it going?

It’s going very well and I’m so pleased because nobody believed in it, not even the publishers believed in it. But two weeks ago they actually took me out to buy me champagne lunch just to celebrate because now it’s actually we have so many subscribers I don’t have to pay for it myself anymore which is nice. And we have both the Swedish government, Swedish parliament and the Swedish High Administrative Court are subscribers and it has had already by the third issue ever a great impact on public procurement legislation in Sweden and I’m very happy about this. And we have a lot of researchers who wants to write articles so it’s very interesting to see or I’m very happy to see that my feeling that this would be, this would cover something that was missing earlier, I’m very happy to see that that was actually true.

Could you tell us a little bit more about the experience of setting up a journal and running it?

Well actually it’s much more easy than you think. The difficult thing is to get people to write articles and we’ve succeeded pretty well so far. It’s not very difficult, it’s just that it takes a lot of time of course. Each issue we have four articles and I’m also very proud that one of the articles always is written by a student, so a student who has written a very good Master thesis rewrites the thesis into an article and I think that’s good because then you make sure that also young lawyers are interested in public procurement law. Some articles are written in English, I hope to get one from you soon.

I know, I know!

And those articles we publish open access on our webpage which is with the address, so you can actually already today go in and read the articles in English. The Swedish articles you would have to subscribe to be able to find on the internet.

Is there any plans to making those Swedish articles available further down the line maybe in English in open access as well or do you think they’re always going to remain behind your subscription service?

I think that’s a matter of cost actually. I wouldn’t mind translating them into English because they are on general EU law also so that will be interesting also for lawyers in other countries but it’s so far a question of funding. So we will have to make sure first that the printing cost because all the people working with this journal we all do it pro-bono so we don’t get paid so our costs are the printing costs and the cost of sending the journal to the subscribers and of course the cost for paying for the website, and those costs we have now covered. If we are going to get more money or have some kind of profit I would firstly thinking about giving maybe scholarships to talented students but maybe now you say it that could be a good idea also if we do have some profit in the future that we could actually translate some of the Swedish articles into English.

That is certainly an area where I could see some value because there’s a lot that each jurisdiction produces in its native language, I mean I’ve seen it all over the place in Portugal, Spain, France, Italy, and certainly Sweden is not going to be different. But there’s not a lot that is being published and disseminated about a specific jurisdiction in English?

Yeah, I know and I agree with you, it’s a shame. I really would like to read articles from Spain, how did they do it there, different issues they are fighting with, maybe we have the same problems in Sweden and we can help each other solve these problems and of course for me it’s a problem then if the articles are in Spanish or Italian which I don’t know. Maybe we could set up a translation service together?

There are a few online already that are quite cheap.

Okay. You have to tip me off?

I will after the show. Very well, last question. What sets your journal apart from the existing ones? I mean there’s already quite a few journals in public procurement?

The first idea was that this journal would focus on the situation for the Nordic and Baltic countries and we’re also in the Board, in the Legal Board we have researchers both from Estonia and Finland and Denmark and hopefully eventually from Norway and Iceland also. So our goal was to focus on the specific problems of the northern countries. Of course it turns out now I read a couple of these articles that these are often problems we have with the legislation in all member states, so that was our main thing. So what makes this journal so special? I think that we are very focused on practical issues so we like to look at how the law actually works in practice, maybe that is something that I hope that we can help so that the researchers can help practitioners how to interpret the rules and thereby how to use the legislation for doing great public procurements.

Could you give us an example of the cross-pollination in the different Nordic states is happening via the journal? I think it’s a great idea that you’re bringing together researchers and practitioners from other jurisdictions and countries but how is that working?

Well it’s working fine. The first thing of course is that we have articles not just from Swedish researchers but also from researchers from Denmark and Estonia, we’re going to have an article from someone from Finland in the next issue and so on, so I’m really happy about that. But also we are, in 2014 we had a first conference with the journal where we invited researchers from all of these countries and hopefully we can have this conference, like a Nordic public procurement conference once every year or once every two years so we can come together and help each other with public procurement issues. So if we have someone doing research in Estonia maybe we can use that research also in Sweden and contribute to Swedish legislation also.

Thank you very much Andrea. It was a pleasure to have you.

Thank you. Pleasure to talk to you.

You can find me at my blog or on Twitter where I use two handles, @Detig for general discussion and also @publicprocure for procurement related topics. As ever I’m very grateful to the British Academy and to the British Academy Rising Star Engagement Awards to make possible these podcasts.