With a decision No 428 dated May 12, 2005 the preceding government, without informing in whatever way the Bulgarian Chamber of Commerce and Industry which is one of the interested parties, issued a permit for an exchange of the building of BCCI situated at 42, Parchevich Str. with a building of the privatized “Bulgarkontrola” Single person joint stock company.

With a decision No 428 dated May 12, 2005 the Council of Ministers has neglected the legal status of the building by disposing of an estate which is not property of the state.

With an order No 898 dated October 8, 1968 of the Ministry of Foreign Trade building tenancy of an administrative building in the area of the corner of Parchevich Str. and Vitosha Blvd was established in favor of BCCI. The building tenancy permits, in accordance with the then valid art. 39 of the Rules on State Property, that BCCI, in the character of being a public organization, should acquire property of a building after its construction in 1975.

The financing of the construction of the administrative building in the period between 1970 and 1975 was effected at the Chamber’s own expenses implementing decision No 232 dated July 18, 1969 of the Council of Ministers.

The BCCI ownership of the building situated at 42, Parchevich Str. is also recorded in the State Property Act No 40-9691 dated December 24, 1986 and in second column BCCI has been specified as a former owner without there having been any alienation act beforehand. This is the first infringement of the BCCI property rights.

The state, however, acknowledges the real right of operative management of the whole building in favor of BCCI with the state property act No 40-9691.

This right of operative management was acknowledged in 1993 with an order of The Minister of Finance as an unlimited real right and was entered in State property Act No 40-9691. This motivated the Chamber to repair the building thoroughly in 1995-1996 at its own expenses, again with the knowledge and the approval of the Financial Minister who managed the state property during this period.

The BCCI right of operative management was also entered in the second State Property Act No 02179 dated May 10, 2000 issued for the building.

Notwithstanding these facts known to the government and despite the entry of the BCCI real right of the building at 42, Parchevich Str., which is regarded as ruling in connection to third parties in the sort and contents in which it was entered as long as it is not impugned, the Council of Ministers disposes of the building.

This BCCI deprivation of the building by the state is equal to compulsory requisition of property without any observance of the ascertained procedure stipulated by the Constitution of the Republic of Bulgaria. The deal for disposition with the Chamber’s building constitutes a gross violation of the regulation of art. 17 para 5 of the Bulgarian Constitution.

The regulations of the international law in effect for Bulgaria have also been violated by ignoring the requirements of art. 3 and art. 8 of the Convention No 87 of the International Labor Organization which forbids the state to obstruct the activities of the employer’s organizations.

April 12, 2006