Dear Sirs,This way fromWe are very dissatisfied with the non-acceptance of the basic requirements that the representatives of tourist guides, in accordance with the decision of classes: 011-01 / 16-03 / 32, registration number: 529-06-17-33 of March 30, presented at numerous meetings in the Ministry of Tourism and agreed proposals for provisions. relating to the activity of tourist guides. However, after the publication of the draft Law on the provision of services in tourism, we were surprised and we cannot shake the impression that we have been cheated and deceived.We explain the same in detail and with arguments, as follows:1. Specific definition of the concept of protected localitiesIn all official letters you give instructions to the Tourist Boards in which it is emphasized:”Protected units (sites), therefore, must be determined in such a way that they are truly sites of special historical, cultural, artistic and archaeological significance for Croatia, for the presentation and interpretation of which special knowledge is required, which could not be public areas, urban squares, forests, parks. Only such tourist guides who have acquired additional knowledge, ie passed additional education, could then lead on such protected units (localities). ”What are these official instructions based on? Not on directives because they are not prescribed by them (!) We remind you of the provisions of Directive 2006/123 / EC of the European Parliament and of the Council of 12 December 2006 on services in the internal market, which emphasize consumer protection and the preservation of national historical and cultural heritage fat can be considered a justifiable reason for restricting freedom. Furthermore, it is clear from the judgments such as C-154/89, EC v. France that the cases in question concerned the restriction of activities throughout the territory, and not just sites such as museums and historical monuments.In the provision from Art. 64 .st. 7 you stated that “a person who performs professional guidance in a museum, gallery, protected parts of nature, at an archeological site, etc. is not considered a tourist guide” which is completely contradictory to your instructions and you did not take into account the proposal in which we required clarification of the same cit:”The tourist guide also performs professional specialist guidance in the museum, gallery, protected parts of nature, at the archeological site and the like.”2. Professional exam programDespite the acceptance of the proposal of the examination program, which was explained and elaborated in detail by colleague Vinko Bakija and the standard EN15565, the explanation by which you justified non-compliance with the agreement is the impossibility of organizing as soon as possible, which is unacceptable for any responsible authority. Please find attached the proposed and reasoned curriculum that we were convinced had been accepted, as well as our other proposals.3. Conditions set for issuing the decision on approvalIn the provision from Art. 68 of the draft, you have completely omitted all the proposals that we have agreed on, which relate to the level of knowledge of the language. What does “sufficient measure” mean? Croatian is the official language of the European Union, and the proposal is disparaging, unjustified, but also sad given our history and the centuries-old struggle of Croats to respect our language. The specific determination in which part the candidate has passed the professional exam for a tourist guide (general or general and special part of the professional exam for tourist guides) is also omitted.4. Definition of tour guide and tour guideDespite the detailed explanation of the Directive on Services in the Internal Market 2006/123 / EC, point 102 and the use of standard EN15565, you copied the relevant provisions from the current law, so we come to the illogicality in which the tour guide (formerly: tour guide) has the same powers as the tour guide without education, by which you directly acted contrary to the provisions of 102 of this Directive and you completely ignored the proposal, which we elaborated in detail:“The tour guide is the person who manages the itinerary and oversees it on behalf of the tour operator. Ensures that the program is implemented as described in the materials (program and contract) of the tour operator exactly as agreed with the traveler. This is a person who deals with the logistics of tourist travel and the coordination of all components of the package deal. “Furthermore, we explicitly oppose the proposal which, in addition to the above, provides for the possibility of granting these powers, which in content correspond to the activities of a tourist guide and educational workers, which we consider scandalous and directly endangering many jobs.We are also critical of the terminological and nomotechnical content of the law, which does not follow gender-aware terminology that respects the fact that the majority in our profession are women. Gender equality is one of the values guaranteed by the Constitution of the Republic of Croatia, so we consider such a terminological proposal obsolete, patriarchal and contrary to the nomotechnical trends of advanced democracies, with which our foundations tend to be linked.Again, we kindly ask you to respond to the requested information on the number of fined unlicensed guides in accordance with the applicable provisions and the Right to Access Information Act (OG 25/13, 85/15) and to consider proposals on the method of calculation for tourist guide services. also included associations as intermediaries and citizens – guides who work independently and without a legal structure and calculate their obligations.”Tourist guide associations may, in the name and on behalf of their members, as well as in their own name and on behalf of their members, mediate in the provision of tourist guide services with the obligation to issue an invoice to the user. The Minister shall prescribe by an ordinance the manner of calculating the tourist guide’s fees with the prior opinion of the Minister responsible for finance. ”It follows from all the above that we held all the numerous meetings in vain, considering that apart from the system based on the general and special part by counties, you did not take any of our proposals into account, but rewrote the previous proposal of the Act and as a result we have 3 disappointed tourist guides. deceived, but also illogical and superficially written draft law without respecting the proposals of the profession, which jeopardizes jobs, livelihoods, endangers the tax and surtax collection system, pension and health insurance funds, and the country’s reputation, the truth about recent Croatian history and cultural heritage. as a whole we consider it contrary to national interests.We emphasize that as a profession we are unique at the level of the whole of Croatia, with the strong support of colleagues from all over Europe and we will not agree to partial and contradictory solutions such as the proposed one.With respect,Members of the Working Group in the drafting of the Law on the Provision of Services in Tourism – representatives of Croatian tourist guides:Marko SjekavicaVinko BakijaKristina Nuić PrkaJasminka MiškulinAnita PenićSuzana TalijanZlata Sučić The tourism ministry has launched a public debate on the new one Law on the provision of services in tourism which lasts until July 26, and which, among other things, aims to enable practically all foreign tourist guides to lead groups throughout Croatia and in all localities, regardless of the fact that they do not know our mentality, culture, history, etc.… nor have they been trained for our localities .What seemed at first to be the beginning to respect the profession and professionalism, since before the publication of the draft Law on Service Provision, several meetings were held between the Ministry of Tourism and a working group consisting of representatives of all guides – ZDTVH and tourist guides section at HOK, it turned into fraud and betrayal, as they point out from ZDTVH, not only towards tourist guides, but also towards Croatian identity and interests. “Given that most of the members of ZDTVH were also members of the working group for the adoption of the draft law on the provision of services in tourism and despite numerous agreed items at the meetings, the final bill you presented, in the eyes of almost all members of ZDTVH fraud and betrayal.“Points out Kristina Nuić Prka, dipl.iur. from the Association of Croatian Tourist Guide SocietiesI wonder: Who cares if our history, culture, identity is misinterpreted and distorted? Unfortunately, there were cases, as ZDTVH points out, of foreign tourist guides unknowingly reporting that our bloody struggle for Croatia’s independence was in fact a civil war. This is just a drop in the ocean of problems, and it is interesting how the ministry is proposing such a law, a ministry that should protect Croatian interests.It follows from all the above that we held all numerous meetings in vain, considering that apart from the system based on the general and special part by counties, none of our MINT proposals was taken into account, but the previous draft law was rewritten, Nuić Prka points out and adds that as a result we have 3 500 disappointed tourist guides who feel cheated, but also illogical and superficially written draft law without respecting the proposals of the profession, which MINT calls into question jobs, livelihoods, endangers the tax and surtax collection system, pension and health insurance fund, and the country’s reputation, the truth about recent Croatian history and cultural heritage, which we consider to be contrary to national interests. “It states the obligation to adopt the acquis communautaire and the directive (which contain provisions that support the defense of our profession and which we have clearly presented to you) and then do not implement the European standard of education EN15565 (which is in our favor) but state the adoption of a new rulebook on protected units without squares, justifying themselves in that part with recommendations (which do not support us – although the recommendations are not binding) which is illogical and contrary to the interests of Croatian citizens who pay taxes and surcharges, but also in general national interests given all the information we presented, norms, but also sources to foreign guides who state terrible untruths that damage the reputation of our country whose independence we as a nation dreamed of for a thousand years, fought in a terrible war in which so many people survived terrible pain, sorrow and suffering and for which many died. Furthermore, outside the European norms, in the assessment of the situation you state that you will enable the citizens of Asian countries to lead around our country, although such a rule does not exist in any European country, so none of them stated a decrease in the number of guests or quality (which you state as a justification without any data). and analysis). On what basis did you adopt such an attitude and how do you justify it? The same is truly shameful and sad. ” concludes Nuić Prka.If such a proposal for the Law on the Provision of Services in Tourism passes and is passed, we can freely say that it is out of the question and that again we do not respect ourselves, our culture, history and identity. Each country preserves and nurtures its culture and history, identity, and it certainly cares about the story being told, and most of all that the story is true and credible.Join the public debate that lasts for a few more days, ie until July 26, 2017 – PUBLIC HEARING OPEN LETTER OF THE WORKING GROUP IN THE DRAFTING OF THE LAW ON THE PROVISION OF SERVICES IN TOURISM – REPRESENTATIVES OF TOURIST GUIDES TO THE MINISTER OF TOURISM G.CAPELLIU
All in all, the FCA had come up with “a strong package of measures that will reduce harm and increase public value”, she added.Last week, the Competition and Markets Authority set out the initial framework for its competition inquiry into the investment consulting and fiduciary management sectors, one of the main aspects of the market study.Butler also said the regulator was going to launch an authorisation “hub” for asset managers, aimed at supporting new entrants to the market.On MiFID II, she set out the FCA’s expectations but also reassured asset managers that it would be taking “a sensible and proportionate approach” to the legislation, which comes into effect on 1 January. The UK’s financial services regulator has outlined plans to consult on transparency-related activity in the asset management industry in a further follow-up to its market study on the sector earlier this year.The Financial Conduct Authority (FCA) will prepare a second consultation “on transparency-related points like benchmarking, performance reporting and, if needed, objectives and the all-in fee”, according to Megan Butler, executive director of supervision for wholesale and specialist investment at the FCA.These are aspects the FCA has already been consulting on in connection with its asset management market study.In a speech at an investment conference today, Butler said the regulator was in the process of reviewing responses to the consultation it launched when it presented its final report on the study in June.