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annul the executive director’s decision of 13 October 2020 refusing her the benefit of teleworking from her place of origin;

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in so far as necessary, annul the executive director’s decision of 9 March 2021 rejecting the applicant’s complaint lodged on 10 November 2020;

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order the defendant to pay all the costs.

1.

First plea in law, alleging infringement of the duty of impartiality, objectivity and neutrality of the authority empowered to conclude contracts of employment, and the adoption of internal rules by an authority lacking competence to do so.

2.

Second plea in law, alleging infringement of the right to be heard.

3.

Third plea in law, alleging a failure to state reasons.

4.

Fourth plea in law, alleging infringement of internal rules, and arbitrary and unreasonable interpretation of such rules, as well as a lack of predictability and of legal certainty.

5.

Fifth plea in law, alleging infringement of the duty to care towards staff, a failure to take into account the interests of both the institution and the applicant, and the disproportionate nature of the decision in view of the actual interest of the institution.

6.

Sixth plea in law, alleging infringement of the right to respect for private and family life set out in Article 7 of the Charter of Fundamental Rights of the European Union (‘the Charter’) as well as the right to a work-life balance set out in Article 33 of the Charter.

7.

Seventh plea in law, alleging infringement of the effective right to employment and failure to provide fair working conditions.

8.

Eighth plea in law, alleging a failure to take into consideration a force majeure event.