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declare the present action admissible and well founded;

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annul the decisions of the President of the EIB of 30 June 2017 and 11 December 2017 in so far as they refuse to grant the applicant the geographical mobility allowance provided for in Article 1.4 of the Staff Rules;

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in so far as necessary, annul the decision of the President of the EIB dated 20 November 2018 rejecting the findings of the Conciliation Board and confirming the decisions of 30 June 2017 and 11 December 2017;

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order the defendant to pay the geographical mobility allowance retroactively as of 1 April 2017, that is, at the date the present action was brought, EUR 36 045.6 (EUR 1 567.20 x 23 months);

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order the defendant to pay the default interest on the geographical mobility allowance payable since 1 April 2017, until full payment, the default interest being set at the interest rate of the European Central Bank, increased by 2 points.

1.

First plea in law, alleging infringement of Article 1.4 of the Staff Rules and infringement of Articles 1 and 11 of Annex VII to those Rules.

2.

Second plea in law, alleging infringement of the principle of legitimate expectations, that of the predictability of the law and that of the duty to have regard to the welfare of staff.

3.

Third plea in law, alleging infringement of the principle of non-discrimination, of Article 1.3 of the EIB’s Staff Code of Conduct and of Article 21 of the Charter of Fundamental Rights of the European Union.

4.

Fourth plea in law, alleging infringement of the principle of sound administration and of the ‘reasonable time’ principle.