Documentation relating to pages 4 and 125 of the Administrative File

In an administrative file, every page has an author. These two have it especially clear.

Page 4 — the valuation report

It accompanies the initial GAUZATU programme application. It attributes to the industrial property, patents and software applications a value of 680,000 euros for 2012 and 400,000 euros for 2013. Signed: Fernando Carcedo.

Page 125 — the upward correction

An email from Partner Consulting — the file's consultancy — to the Basque Government, correcting the previous valuation and raising the value of the software applications to 778,000 euros for 2012. The technicians' Report-Proposal (pages 143 and following, A.5) validates these figures, within a recognition reaching 1,778,000 euros in total.

The framework governing those valuations and payments

These figures were not decorative paper: they conditioned payments subject to a precise legal regime. The Order of 21 May 2007, regulating the GAUZATU-Industria programme, imposed on the SPRI and the Basque Government the verification of the project's real viability, the checking of corporate legitimacy and the inspection of materialised investments before releasing funds. Article 32 of Law 38/2003, the General Subsidies Act, requires verification of the effective performance of the subsidised activity. And Article 60.b) of Regulation (EC) No 1083/2006 — applicable by virtue of ERDF co-financing (A.39.4) — obliges verification that the co-financed goods and services have actually been delivered and provided. The system did not allow payment against invoices: it required materialised and verified work — payment functions, in practice, as a certification.

What these pages fix

• Authorship of the management: the valuation is signed by Carcedo and processed by the consultancy; there is no record of Apolozan's intervention on any page.
• Reality of the asset: the technological development valued exists in the file with concrete figures, revised upward and validated by the technicians.
• Administrative knowledge: the Basque Government handled these valuations before paying (A.5) — and could only pay, under its own rules, on verified investment.

The contrast with what was declared afterwards

The 2013 non-compliance order declares the investments non-existent (A.6); the accusation maintains that the funds were released against fictitious invoices (A.11). Against both, the cited framework leaves a documentary dilemma with no third way out: either the mandatory verifications were carried out — and then the investment existed —, or the payments were released in breach of the 2007 Order, the General Subsidies Act and the ERDF Regulation — and then the responsibility lies with the programme managers, not with the unsigned designee. Neither of the two later pronouncements confronts these pages or resolves the dilemma.

How to verify it

Open the annex. On page 4, read the signature and the figures; on 125, the sender and the corrected figure. Then look for those figures in the non-compliance order (A.6) — they are not there — and for the above dilemma in any resolution of the case. It is not there either.

Contrast with the original file

The original GAUZATU administrative file is in Bilbao Original in three parts (DOC-0136, DOC-0137, DOC-0138); part 2 contains the SPRI's Report-Proposal — the internal assessment that certified the project and motivated the payments this chronology documents (A.5).