WT/TPR/M/358/Add.1 2 November 2017 (17-5965) Page

269 Pages·2017·1.99 MB·English

WT/TPR/M/358/Add.1

2 November 2017
(17-5965) Page: 1/269
Trade Policy Review Body Original: English/Spanish
17 and 19 July 2017 anglais/espagnol
inglés/español

TRADE POLICY REVIEW
BRAZIL
MINUTES OF THE MEETING
Addendum
Chairperson: H.E. Mr. Juan Carlos González (Colombia)
This document contains the advance written questions and additional questions by WTO
Members, and replies provided by Brazil.1

Organe d'examen des politiques commerciales
17 et 19 juillet 2017
EXAMEN DES POLITIQUES COMMERCIALES
BRÉSIL
COMPTE RENDU DE LA RÉUNION
Addendum
Président: S.E. M. Juan Carlos González (Colombie)
Le présent document contient les questions écrites communiquées à l'avance par les
Membres de l'OMC, leurs questions additionnelles, et les réponses fournies par le Brésil.1

Órgano de Examen de las Políticas Comerciales
17 y 19 de julio de 2017
EXAMEN DE LAS POLÍTICAS COMERCIALES
BRASIL
ACTA DE LA REUNIÓN
Addendum
Presidente: Excmo. Sr. Juan Carlos González (Colombia)
En el presente documento figuran las preguntas presentadas anticipadamente por escrito y
las preguntas adicionales de los Miembros de la OMC, así como las respuestas facilitadas por el
Brasil.1

1 In English and Spanish only./En anglais et espagnol seulement./En inglés y español solamente.
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CONTENTS
ARGENTINA ...................................................................................................................... 3
AUSTRALIA ...................................................................................................................... 5
CANADA ......................................................................................................................... 19
CHILE ............................................................................................................................. 43
CHINA ............................................................................................................................ 56
COLOMBIA ..................................................................................................................... 91
DOMINICAN REPUBLIC ................................................................................................ 100
ECUADOR ..................................................................................................................... 105
EL SALVADOR ............................................................................................................... 110
EUROPEAN UNION ....................................................................................................... 114
HONG KONG, CHINA ..................................................................................................... 135
INDIA .......................................................................................................................... 140
INDONESIA .................................................................................................................. 152
JAPAN .......................................................................................................................... 156
REPUBLIC OF KOREA .................................................................................................... 162
MALAYSIA .................................................................................................................... 164
MEXICO ........................................................................................................................ 166
NEW ZEALAND ............................................................................................................. 182
NORWAY ...................................................................................................................... 192
PARAGUAY ................................................................................................................... 194
PERU ............................................................................................................................ 196
RUSSIAN FEDERATION ................................................................................................. 197
SINGAPORE .................................................................................................................. 208
SWITZERLAND ............................................................................................................. 211
CHINESE TAIPEI .......................................................................................................... 217
THAILAND .................................................................................................................... 221
TURKEY ........................................................................................................................ 226
UKRAINE ...................................................................................................................... 230
UNITED STATES ........................................................................................................... 247
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ARGENTINA
Report WT/TPR/S/358
1. En el párrafo 2.3 se indica que durante el período objeto de examen se produjo una
mejora en el acceso de la IED a determinados servicios de salud. ¿Podría comentar
Brasil cuáles fueron las políticas implementadas que llevaron a dicha mejora en el
acceso de la IED?
In 2015, Law Nº 13.097 (Chapter XVII) altered Law Nº 8,080/1990, allowing direct or indirect
participation of foreign capital in health care in Brazil, in the following cases: I) donations of
international bodies linked to the United Nations, of technical cooperation and funding
organizations; II) legal entities intended to open, operate and exploit: general hospitals, including
philanthropic, specialized hospitals, polyclinics, general clinics and specialized clinics; and actions
and researches related to family planning; III) nonprofit health services maintained by companies,
for providing health care services to their employees and dependents, at no cost to the social
security; and IV) other cases that may be regulated under specific legislation.
The new legislation also added Article 53-A to Law Nº 8,080/1990 allowing foreign investments in
activities that support health care, such as laboratories of human genetics, production and supply
of pharmaceutical and other products for the health sector, and laboratories for clinic analysis and
imaging diagnosis.
Therefore, all health care services are open to foreign investment, except for specific cases in
which all trading is prohibited, for both national and foreign investors, such as the prohibition of
commercial activity of blood and blood products, organs, tissues and cells and the prohibition of
the export of blood and blood products.
2. El párrafo 2.3 señala que Brasil ha utilizado un nuevo modelo de acuerdo sobre
inversiones, basado en las directrices de la UNCTAD y la OCDE. ¿Podría señalar cuáles
son los principales elementos distintivos de dichos acuerdos?
The CFIA is not like traditional BITs, as it seeks to meet investor needs in a concrete, pragmatic
and proactive manner, while at the same time, respecting the development strategy and the
regulatory rights of host countries. While BITs focus on promotion and protection, the CFIA focuses
on facilitation, institutional governance and prevention of disputes.
The CFIA is based on three pillars: a) risk mitigation/ framework for the treatment of investors and
their investments; b) institutional governance; and c) agendas for cooperation and investment
facilitation.
First, the CFIA provides a set of measures that reduce the investor's exposure to risk/ establish a
framework for the treatment of investors and their investments. It establishes guarantees of
non-discrimination (national treatment and most favored nation treatment), transparency clauses
and specific conditions for cases of direct expropriation, compensation in case of conflicts and
guarantees for international transfers.
Second, the CFIA proposes the establishment of focal points or "ombudsmen" in each Party and
the creation of a Joint Committee. These instances can be considered the institutional core of the
Agreement, as they contribute to the fulfillment of the commitments made and to strengthen the
dialogue between the Parties with regard to investments and appropriate assistance to investors.
Third, the CFIA provides for the establishment of investment facilitation and cooperation agendas
in areas that may improve the investment environment. Such agendas may vary depending on the
possibilities and challenges of the bilateral investment relationship.
3. En el párrafo 2.10 se menciona que existe la posibilidad de que el sector privado
participe en la formulación de la política comercial por medio del Consejo Consultivo del
Sector Privado de la Cámara de Comercio Exterior (CAMEX). ¿Podría Brasil explicar de
qué forma y qué tipo de participación tiene el sector privado en la formulación de la
política comercial?
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According to the rules of procedure of CAMEX, the private sector may participate in trade policy
formulation through the CAMEX Private Sector Advisory Council (CONEX). CONEX is composed of
the Minister of State for Foreign Affairs (MRE), the Minister of State for Industry, Foreign Trade
and Services (MDIC) and up to twenty representatives of the private sector, appointed by means
of a CAMEX resolution, with personal and non-transferable terms of two years. CONEX is
responsible for advising CAMEX, through the preparation and submission of studies and sectoral
proposals for the improvement of foreign trade policy.
4. En el párrafo 2.11 se señala que la Confederación Nacional de Industria (CNI) puso en
marcha un programa de prioridades para promover la integración de las empresas
brasileñas en el mercado mundial. ¿Podría comentar cuáles son las prioridades
identificadas para promover la integración de las empresas en el mercado mundial?
The CNI releases annually its "International Agenda of Industry". The latest edition (April 2017)
lists 86 priority actions, of which 55 aim at improving Brazil´s national trade policy and 31 are
related to internationalization support. Some of the highlights among these priorities are the
conclusion of the ongoing negotiations with Mexico and the European Union; the negotiation of
new double taxation agreements; improved trade facilitation measures; increasing attention to
trade remedies; and better logistics infrastructure. The document can be found online at the
following address: http://www.portaldaindustria.com.br/publicacoes/2017/4/agenda-internacional-
da-industria/.
5. El párrafo 2.32 indica que Brasil continúa siendo beneficiario de los esquemas del
Sistema Generalizado de Preferencias (SGP) de Australia, Belarús, Estados Unidos,
Japón, Kazajstán, Noruega, Nueva Zelandia, Rusia y Suiza. ¿En qué medida Brasil evalúa
que se ha beneficiado de dichos esquemas preferenciales?
As a developing country with a diversified but uneven economy, Brazil greatly values the benefits
of the Generalized System of Preferences schemes enforced by Australia, Belarus, Japan,
Kazakhstan, Norway, New Zealand, Russia, the United States of America and Switzerland. The GSP
preferences constitute an useful tool to encourage Brazilian companies, especially micro, small and
medium sized enterprises, to overcome the challenges of accessing foreign markets, particularly in
distant countries. Considering the varying levels of use of GSP preferences, the Brazilian
Government is currently revising each of the GSP schemes above, in order to better inform
Brazilian exporters – as well as importers of Brazilian goods in partner countries – about the
opportunities in place.
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AUSTRALIA
Report by the Secretariat (WT/TPR/S/358)
1 Economic Environment
1.2 Recent economic developments
1.2.4 Labour market policies
Page 17, paragraphs 1.16 and 1.17
The Report notes several specific labour market reforms that have been implemented or are under
consideration which, if implemented, would be beneficial for the Brazilian economy's
competitiveness and, over time, reduce costs, complexities and labour-related litigation. They
could also improve conditions for workers by bringing more into the formal workforce.
In Australia's view, continuing the labour market reform process to reduce rigidities or outdated
practices will be especially important to specific sectors of the traded economy, such as mining
where modern, safe and productive operations depend on more flexible and efficient labour
practices (some of which are inconsistent with Brazil's current laws).
Question 1
In undertaking labour market reforms, how will Brazil ensure sufficient flexibility to enable better
workforce planning in key sectors of the economy, such as mining?
The objective of the proposed labor market reforms is to have a positive impact on all sectors of
the Brazilian economy.
Report by the Secretariat (WT/TPR/S/358)
2 Trade and Investment Regimes
2.4 Trade Laws and Regulations
2.4.1 Regulatory framework and reform
Page 28, paragraphs 2.14 and 2.15
In Australia's experience, the regulatory burden in Brazil continues to impede activities by
businesses which conduct trade with and invest in Brazil. The 'ease of doing business' index in
Brazil remains very low – due to the difficult, overly-complex and time-consuming taxation and
regulatory systems. The questions below relate to specific concerns raised by Australian business
interests in Brazil and are examples of the systemic problems encountered in the Brazilian
economy.
Question 2
How will Brazil reform its taxation and regulatory systems to ease the burden on businesses?
Brazil is carrying out studies for the simplification of its tax and regulatory systems. As a first
result, a bill has been drafted to create a new social contribution tax aimed at replace two federal
taxes (PIS and COFINS) that are, at federal level, the most challenging regarding compliance and
enforcement. This new tax will be in full compliance with OECD guidelines. The bill has not yet
been introduced for consideration at the Brazilian Congress.
Question 3
When will Brazil adopt the practice of permitting digital signatures and stamps on import/export
documentation, thereby improving efficiency?
All customs declarations, as well as any supporting documents thereof, can already be submitted
electronically, as provided for in the article 20 of the Customs Code (Decree No. 6759/2009).
The Integrated System of Statistics on Trade (SICOMEX), which was established by Decree
660/1992, and its Single Window of Foreign Trade (http://portal.siscomex.gov.br/), were set as
the tool for attaching documents electronically. The tool was launched in 2014 and has been fully
operational since 2016. With this tool, all documents related to foreign trade operations can be
submitted electronically.
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Question 4
What measures does Brazil intend to implement to improve the tax refund and tax transfer
systems when products are transferred across State borders in Brazil, with a view to eventual
re-export (e.g. to other countries in Latin America)?
The export and re-export of goods are exempted of taxes in general. According to Article
155.2.X.a of the Brazilian Federal Constitution, exports and re-exports are also exempted from the
ICMS, the main state level tax, which is normally levied on transferences across state borders in
Brazil.
Report by the Secretariat (WT/TPR/S/358)
3 Trade Policies And Practices By Measure
3.2 Measures Affecting Production and Trade
Australia has concerns about Brazil's reliance on local content schemes and the extent to which
these schemes are consistent with its WTO obligations. The Secretariat's report notes that a
number of schemes have been extended or made permanent, for example:
Page 48, paragraph 3.30 – previous trade policy review descriptions of the import tariff
concessions for capital goods and IT and telecommunications equipment referred links to the level
of domestic equipment content;
Page 124, paragraph 4.93 - lists a range of industrial support programs with local content
requirements.
Page 128, paragraph 4.101 – auto industry support programs linked to domestic content.
Question 5
We recognise that Brazil has been asked about some of these schemes in the past. Nonetheless,
could Brazil give a description of key programs? Further, could Brazil outline how each is
consistent with Brazil's WTO obligations?
With reference to paragraph 3.30 of the Secretariat Report, the Ex-tarifário mechanism allows for
an amendment of the tariff schedule that applies to all imports. It is a unilateral,
non-discriminatory and horizontal duty liberalization for industrial goods. It favours foreign
companies from any country producing advanced equipment, machinery and technology.
On paragraphs 4.93 and 4.101, most benefits provided under "Plano Brasil Maior" have expired or
are scheduled to expire by 31st December 2017, including the INOVAR-Auto programme.
Moreover, Brazil considers that support under these programmes is not contingent on the use of
domestic over imported goods, but rather on production steps requirements consistent with WTO
law.
Report by the Secretariat (WT/TPR/S/358)
3 Trade Policies And Practices By Measure3.2 Measures Affecting Production and Trade
3.3.2 Standards and other technical requirements
Page 73, paragraph 3.134
The report states that Brazil's approach to granting equivalence remains based on the acceptance
of test results, without explicit recognition of foreign technical regulations. During the review
period, Brazil notified to the WTO four plurilateral agreements on TBT matters concluded with
other Members, including three new mutual recognition agreements (MRAs) on accreditation.
Through INMETRO, Brazil is a party to some 120 TBT-related technical cooperation instruments, of
which 89 (including 19 in the field of accreditation) are currently in force. INMETRO also represents
Brazil at the Inter-American Accreditation Cooperation, the International Accreditation Forum, the
International Laboratory Accreditation Cooperation, the International Bureau of Weights and
Measures, the International Organization of Legal Metrology, and in relevant initiatives within
MERCOSUR, LAIA, and the Organization of American States.
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Question 6
Does Brazil require a mutual recognition agreement (MRA) to accept conformity assessment
results from foreign conformity assessment bodies?
INMETRO's Ordinance 118/2015, "General requirements for product certification: activities
performed by product certification bodies (OCP) accredited by IAF MLA member", is available at
http://www.inmetro.gov.br/legislacao/rtac/pdf/RTAC002226.pdf, is the reference for this subject.
Conformity assessment activities, carried out by an entity accredited by a member of the IAF
(International Accreditation Forum) MLA (Multilateral Recognition Arrangement), may be accepted,
provided that all the conditions below are observed:
(a) the body shall have an MoU with a Brazilian product certification body (OCP) accredited by
INMETRO / CGCRE;
(b) the body shall be accredited according to the same international rules adopted by INMETRO,
i.e., accredited by a IAF MLA signatory member, for the same scope or equivalent;
(c) the activities carried out by the OCP must be equivalent to those regulated by INMETRO;
and
(d) there is no restriction on the part of the regulatory authority of the object submitted for
certification.
Each MoU will be subject to verification in periodic evaluations of accreditation, held by
CGCRE/INMETRO, and must include, at least, the conditions below:
(a) the parties shall agree to keep the signatories informed about any change in their
accreditation situation in the country of origin;
(b) the parties must agree on what documents related to the certification process, issued in any
language other than English or Spanish, shall be accompanied by a sworn translation into
the Portuguese language;
(c) the parties shall explicitly indicate the activities that are covered by the MoU, as for
example, audit, testing plan, testing reports, audit report evaluation.
The entity legally established in Brazil and accredited by CGCRE/INMETRO will be responsible for
the evaluation and the issuing of the certificate of conformity with Brazilian regulations, taking all
responsibility for activities carried out abroad and other responsibilities related from such issuing,
as if the activities were conducted by entity itself.
Foreign entities accredited by CGCRE/INMETRO for a particular scope may lead certification
processes under the scope of that specific conformity assessment requirements (RAC) for the
object, as long as they are legally established in Brazil. In this case, the entire certification process
documentation should be available in Brazil and in Portuguese language, observed the exceptions
provided for in 6.2.1.2 and the note of the subitem 6.2.3.2.
The term "foreign entity legally established in Brazil, accredited by CGCRE/INMETRO for a
particular scope", is to be understood as one that has people with technical expertise, assigned in
Brazil, has the physical structure in national territory, demonstrates ease of access to the
certification process and meets the legal requirements of documentation required by Brazil for the
establishment of a company, such as Cadastro Nacional de Pessoa Jurídica (CNPJ) and social
contract.
Question 7
Can Brazil negotiate MRAs with economies that are not part of MERCOSUR? If not, what steps is
Brazil taking to ensure it can accept the conformity assessment results of other Members with
equivalent procedures?
Brazil can negotiate MRAs with any economy but even within MERCOSUR the following applies:
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(1) As far as accreditation is concerned, Brazil's INMETRO is member of the Mutual Lateral
Agreements established by the two international accreditation forums: IAF (International
Accreditation Forum) and ILAC (International Laboratory Accreditation Cooperation), which
means that both accreditations are recognized;
(2) The acceptance of results of the mandatory conformity assessment procedures also requires
that the certification agencies in the two countries involved sign a mutual recognition
agreement between them. They have to be accredited by their respective accreditation
bodies, signatories of the IAF MRA, and use laboratories accredited by entities which are
signatories of the ILAC MRA. Under the private MRA signed by both certification enetities,
the entity established in Brazil can then analyze the conformity assessment procedures and
their results as applied to a particular product by the foreign certification agency and issue a
new certificate, which, in its turn, will be accepted.
Report by the Secretariat (WT/TPR/S/358)
3 Trade Policies and Practices by Measure
3.3 Measures Affecting Production and Trade
3.3.7 Intellectual property rights
3.3.7.1 Overview
Page 85, Paragraph 3.187
The report states that the body of legislation that has not been notified to the TRIPS Council
includes the laws on: integrated circuit topographies; collective management of copyright
(amendment); access to and benefit sharing of genetic resources and associated traditional
knowledge; and principles, guarantees, rights and obligations for the use of Internet in Brazil.
Question 8
Is the above mentioned legislation available online? Are translations available?
A new notification updating the previous one is under consideration by the Brazilian government.
Page 85, Paragraph 3.188
The report states that process for domestic ratification of the Madrid Protocol is under way.
Question 9
Can Brazil provide further information on expected timeframes for domestic ratification of the
Madrid Protocol?
The Madrid Agreement on Trademarks, managed by WIPO, was sent to the Brazilian Congress for
ratification on June 21st, 2017.
Report by the Secretariat (WT/TPR/S/358)
3 Trade Policies and Practices by Measure
3.3 Measures Affecting Production and Trade
3.3.7 Intellectual property rights
3.3.7.2 Industrial Property
Page 88, Paragraph 3.193
The report states that the average processing time for patents is estimated at 11 years.
Question 10
Can Brazil provide further information on what is being done to reduce this average processing
time?
Brazil is working to improve this situation. Since 2016, 150 new patent examiners were hired by
INPI, in order to reduce the processing time for patents. Productivity is also increasing due to the
simplification of technical procedures for exams and the implementation of home office,
conditioned to a higher production from the examiners. In the patent area, decisions increased by
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88% last May compared to April figures. In the accumulated first five months of this year, there
were 22,134 decisions, a number higher than the total recorded for the entire years 2014
(22,336 decisions) and 2015 (15,842 decisions). In comparison, between May 2017 and with
May 2016 the increase was 138%.
Report by the Secretariat (WT/TPR/S/358)
3 Trade Policies and Practices by Measure
3.3 Measures Affecting Production and Trade
3.3.7 Intellectual property rights
3.3.7.3 Copyright
Page 89, Paragraph 3.200
The report states that Brazil adopted a civil rights framework for the Internet, which foresees the
elaboration of specific legislation regulating the liability for damages resulting from content
managed by third parties.
Question 11
Can Brazil provide further information on any elements of the foreseen legislation?
The article 19 of the Civil Rights Framework for the Internet refers to damages resulting from
content managed by third parties.
The general rule inscribed in the article ensures the freedom of expression and prevents
censorship by exempting the Internet Service Provider from civil responsibilities. Such
responsibility, however, can be invoked when the Internet Provider fails to take steps to make
unavailable content that has been declared unlawful, after a specific court order. Paragraph 2
determines the implementation of the provisions above with a specific legal provision regarding
copyright infringement, which must respect the freedom of speech and the art. 5° of the Brazilian
Federal Constitution.
The regulation of the Internet civil rights framework is still under discussion within the government
and with civil society. A number of public hearings were held to debate with and receive
contributions from the civil society regarding the new legal provisions, but at this stage there is no
specific copyright proposal under the framework. Until specific provisions are developed and
enacted into law, the Copyright law remains in force for digital content, although it does not
address directly the issue of ISPs' liability.
Report by the Secretariat (WT/TPR/S/358)
4 Trade Policies by Sector
4.1 Agriculture, Forestry, and Fisheries
4.1.3 Border Measures
Page 96, Paragraph 4.19
The report states that 'Brazil's food aid abroad increased considerably from 47,284 tonnes in the
period 2008-10 to 230,816 tonnes in the period 2012-14, of which 83.3% was rice' then reducing
drastically in 2016 with rice comprising the majority of aid given.
Question 12
Recalling the Ministerial Decision on Export Competition made at Nairobi which states that
international food aid is 'not linked to the market development objectives of donor Members', can
Brazil explain the broad fluctuations in food aid between 2008-12 and the reasons for rice being
the main commodity provided as food aid?
Currently, the Brazilian Government provides food aid through the World Food Program (WFP) of
the United Nations, focusing on Emergency Operations and Protracted Relief and Recovery
Operations, which target victims of socio-environmental disasters and vulnerable groups to
guarantee their food and nutritional security. Rice is the main commodity provided because it is a
staple food in all the recipient countries.
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Report by the Secretariat (WT/TPR/S/358)
4 Trade Policies by Sector
4.1 Agriculture, Forestry, and Fisheries
4.1.4 Domestic support
4.1.4.1 Agricultural/rural credit
Page 96, Paragraph 4.21
The report states that Domestic support to agricultural producers remains at a low level compared
with OECD countries.19 According to the OECD, Brazil's total support estimate (TSE) to agriculture
averaged 0.35% of GDP in 2012-15 (0.55% in 2008-10), well below the OECD average of 0.7%
(Table 4.2).Support to farmers as measured by the producer support equivalent (PSE) was 3.2%
of gross farm receipts in the period, below the OECD average of 17.6%. Support peaked in 2014
and fell in 2015 as both market price support (MPS) and payments based on input use (credit and
insurance subsidies) declined. The MPS reduction was due to the minimum guaranteed prices
increasing at a slower pace than inflation, and the depreciation of the R$ relative to the US$.
According to the OECD, while weak infrastructure is still a significant bottleneck for agricultural
development, financing of general services (GSSE) to agriculture constituted less than 20% of
total support to the agricultural sector in 2013-15 and over time this share tended to decline
considerably. However, 93% of PSE is given through support based on commodity output or on
input use, particularly through credit subsidies, debt rescheduling, and rural insurance; MPS was
relatively low in 2015 (Table 4.3, Section 4.2.4.1.2). According to the OECD, an important part of
support to producers continues to be provided through measures that distort farm prices and
current costs (e.g. MPS, concessional credit, and crop insurance subsidies) although the aggregate
level of that type of support is moderate and varies across commodities.
Question 13
Is Brazil proposing to reduce some of the above-listed support measures and undertake the
reforms necessary to further liberalise its agriculture sector and allow market pressures to more
fully determine the nature of its agricultural trade?
As stated by the OECD, the domestic support to agricultural producers remains at a low level
compared with OECD countries, and the level of support of the last years Brazil has been reduced
even more because of budget restrictions. Currently, Brazil does not intent to reform its
agricultural policy.
Page 102, Paragraph 4.33
The report states that according to the OECD, whereas the agricultural credit system is intended to
address failures in financial markets, it also creates risks (default) for government and producers,
particularly since the macroeconomic situation has deteriorated (Section 1.2.1).The higher
availability of funds for loans is potentially creating excess supply. Most of this credit is
concentrated on subsidizing short-term borrowing such as working capital and commercialization
loans that further distort markets. A reform of the concessional credit system could consider a
gradual downsizing of concessional loans for working capital to commercial producers, simplifying
regulations and procedures, and re-focusing to support on-farm investments that explicitly
incorporate technological innovations and advanced farm management and environmental
practices.
Question 14
The OECD highlights the risks associated with the agricultural credit system, including that it is
potentially creating excess supply. Is Brazil considering reforming the concessional credit system
to reduce these risks?
Brazil considers "the higher availability of funds for loans" alone is not capable to create excess
supply, because funds are not allocated for any specific product and other factors must be present
to induce this outcome. In the early 1990s, when agricultural credit was the main policy
instrument for the sector, problems surfaced during the hyperinflation period (before Plano Real, in
1995). Nonetheless, even in face of the economic crisis of last couple of years there is no risk of a
significant default: the agricultural sector remains robust and the default rates are low. In the
short term, there is no plan to change the current credit policy.