PART D OTHER PROVISIONS TO STRENGTHEN THE AUDIOVISUAL INDUSTRY IN GREECE (42-45)

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Article 42
National Digital Repository of Audiovisual Works
1. The National Digital Repository for Audiovisual Works shall be established and shall operate in the Company referred to in Part B and shall aim to: a) collecting, preserving, digitising, archiving, maintaining, managing, saving, restoring, recording, documenting, cataloguing, indexing and highlighting audiovisual and cinematographic archives and works, audio and music files, photographs, graphic art, videos, online productions, animation, digital creations and digital games, publications of all kinds and objects related to the national audiovisual heritage and memory, for the purpose of protecting and preserving it, b) coordinating the actions of public sector bodies in accordance with Article 14(1)(a) of Law 4270/2014 (Α΄143), which collect, own and exploit audiovisual material in Greece, and c) creating a single catalogue of all audiovisual material held by public bodies, as well as legal persons governed by private law or natural persons or associations of persons and recording; storage and digitisation of the programme broadcast by national and regional digital terrestrial television broadcasting content providers holding a legal broadcasting licence, with the aim of preserving, preserving and creating a comprehensive and centralised archive of the national cultural audiovisual memory; (d) the organisation, digitisation, management and exploitation of the national archive of audiovisual works and means of digital projection, digital communication and information, with the exception of the exploitation rights of the audiovisual archive of ERT S.A., which is legally owned by ERT S.A.
2. For the implementation of the National Digital Repository of Audiovisual Works, the producer of an audiovisual work and any other holder or possessor of an original material carrier of an audiovisual work is obliged to deliver to the Company a copy of it in digital form or on film. The cost of reproduction of the copy is borne by the Company. On receipt of the copy, a certificate of deposit shall be issued to the producers or holders/legal entities. The delivery of a copy of the work shall not confer on the Company any powers of exploitation other than those necessary for the purposes referred to in this Article.
3. With special programmatic contracts drawn up by the Company: a) the Foundation "Greek Film Archives - Greek Film Archive", established by Royal Decree 105/1963 (Government Gazette, Series I, No 20) and operating under Article 34 of Law 3905/2010 (Government Gazette, Series I, No ΄219), and b) the Thessaloniki Film Festival independently and with regard to the Thessaloniki Film Museum under Article 31 of Law 3905/2010, lay down the arrangements concerning the relations between the above bodies, in order to create a single archive of cinematographic and audiovisual works in general, managed by the Company. ERT S.A. provides its assistance to the Company for the creation of a single archive of cinematographic and audiovisual works in general, which is managed by the Company. For this purpose, the Company signs with ERT S.A. a Memorandum of Understanding, which sets out the terms of the cooperation, as well as any necessary details governing this cooperation.
4. The organisation and operation of the National Digital Repository of Audiovisual Works, as the official national repository of audiovisual archives, does not affect the ownership, possession and exploitation rights of ERT S.A., as the owner of the entire audiovisual archive of each public broadcaster, which has been incorporated into its Archive, as well as the right to digitise this material.

Article 43
Creative Innovation and Technology Hub for the Creative and Audiovisual Sector - CreAtiVe Hub GR
1. The Hellenic Centre for Film, Audiovisual and Creativity-Creative Greece operates a Creative Innovation and Technology Hub for the Creative and Audiovisual Sector (hereinafter referred to as the Hub) under the name CreAtiVe Hub GR. The Hub operates at the Management level within the organizational structure of the Company.
2. CreAtiVe Hub GR aims to develop and support the country's audiovisual and creative sector and further contribute to economic development through actions supporting the networking of creators with the market, the connection of the creative sector with new technologies and innovative methods of creation, the networking of domestic businesses of the creative and audiovisual sector with the international environment, the organization of training and audiovisual education actions, the connection of local and regional societies with creators, the cultivation of new talents in the creative sector and the participation in European and domestic programs that enhance the audiovisual and creative sector and generally foster innovation and the integration of new technologies in these sectors.
3. The Hub operates a Cultural and Creative Sector Observatory to gather statistical data and data on the audiovisual, cultural and creative sectors, in order to design and implement the appropriate policies and actions to fulfil the Hub's and the Company's mission more broadly.
4. The Hub may be designated as a final beneficiary or co-beneficiary for projects, programmes and actions related to its mission, to collaborate with public bodies for the joint implementation of projects, programmes and actions, to be subsidised for the fulfilment of its objectives by public and private sector bodies, as well as by programmes co-financed or financed by the European Union, by other international programmes, by the regular budget of all Ministries, by sponsorships and by any other legal source.
5. A scientist with administrative experience and research and technological activity related to one or more of the Hub's fields, with experience in attracting funding for research and technological programs or projects and in the implementation of research results, as well as with qualifications for appointment to the position of a B ΄ researcher or a corresponding university professor, shall be appointed as head of the Hub by the Board of Directors of the Company, following a public announcement.
6. The Hub may employ staff of research centres and institutes referred to in Article 18 of Law 4310/2014 (Α΄258) for the purpose of implementing research and innovation programmes in the audiovisual and creative industry following programme agreements concluded between the Hub and the research centre or institute.
7. A programmatic agreement concluded by the Hub with the General Secretariat for Research and Innovation of the Ministry of Development shall regulate any specific issue regarding the role and operation of the Hub within the framework of the National Strategy for Research, Technological Development and Innovation of Law 4310/2014, as well as for the development of programmes, actions and research in the fields of technology and innovation in the audiovisual and creative industries.

Article 44
Audiovisual Outreach Programme
1. The Audiovisual Extroversion Program is approved by the Board of Directors of the Company "Hellenic Centre of Film, Audiovisual and Creation S.A.-Creative Greece S.A." following a relevant recommendation by the CEO in October of each year and concerns the year following the year of approval.
2. The proposal of the Program includes: the extroversion and promotion actions planned by the Company, as well as the educational actions aimed at the extroversion of the Company and the audiovisual industry, (b) the participation of the Company in festivals, workshops, meetings and other events in Greece and abroad, which have a developmental or artistic orientation that serves the country's development goals, (c) the budget of each action included in the programming, as well as a budget for extraordinary actions, (d) the planned programmatic contracts, agreements and collaborations with other public and private sector bodies required to promote the extroversion of the country's audiovisual sector, as well as to attract investments in the audiovisual industry, (e) the amounts of support provided by the Company to festivals, workshops and events related to the audiovisual industry for the purpose of their support and development, in compliance with state aid rules.
3. As for approx. paragraph 1, the Company, on the basis of the above planning, grants amounts for the support and development of festivals, organizations and other events, on the basis of specific criteria approved by the Board of Directors of the Company. These amounts are granted on the basis of an agreement between the Entity and the Company that organizes the festival or event describing the obligations of both parties as well as the reciprocal benefits of each, in compliance with state aid rules.
4. Any extraordinary action or participation of the organization in events in Greece or abroad is approved by the Board of Directors of the Company upon the recommendation of the CEO.
5. The Company may grant its trademark to productions that have not been funded by its financial instruments as a patronage, if this is requested by a production company.

Article 45
Audiovisual Production Facilitation Offices
1. In the Regions of Greece, as well as in the Municipality of Athens, Audiovisual Production Facilitation Offices (hereinafter referred to as DOP Offices) may be established with the main mission of promoting and highlighting the areas of their territorial competence for the implementation of investments in the audiovisual sector and facilitating the implementation of such investments. For their international relations, I.O.P. Offices may use the title Film Office by adding their title in English. The above offices may be set up as an alternative to legal persons governed by public or private law in municipalities or regions.
2. The above Office of the Municipality of Athens serves the area of administrative competence of the Municipality, and until the establishment of an Office in the Region of Attica, if established, serves the metropolitan area of the capital. With the establishment by the Region of Attica of a DOP Office, the issues of relations between the two (2) Offices are regulated by a special programmatic contract between the Municipality of Athens and the Region of Attica.
3. The IPO Offices shall have the following responsibilities: the promotion and promotion of the areas of their territorial competence as a destination for the implementation of investments in the audiovisual sector, (b) the promotion and strengthening of the support environment for audiovisual productions, (c) the administrative service and facilitation of audiovisual productions, (d) the organization of education and training programmes related to the audiovisual sector and its development in the areas of their competence, (e) the design and implementation of programmes, actions and initiatives to attract and serve domestic and foreign audiovisual productions, at local level, with the aim of promoting the cultural product and tourism development and promoting the areas of their competence.
4. The I.O.P. Offices develop appropriate collaborations and coordinate local public authorities and organizations within their territorial competence. They may conclude memoranda of understanding with local professional, social, economic operators to facilitate investment in the audiovisual sector, participate in companies or consortia or other legal persons related to the audiovisual media sector, and conclude programme contracts for the implementation of actions or initiatives.
5. The Company ‘National Centre for Film, Audiovisual and Creation S.A. – Creative Greece S.A.’, within its remit, acts as the Coordinator of the network of the DOP Offices (DOP Office Network Coordinator).

AI Discussion Summary

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Recommended implementations

This proposal consolidates all the proposals of the Clusters, avoiding duplication, and formulates clear actions to be incorporated in Article 42:

  • New paragraph 2 – determining that the Film Archive fulfils the objectives of the national repository;
  • – compliance with Article 34/3905/2010 (recognition of the Film Archive as an official body).
    – regulation of a programme contract between EKKOMED and the Film Archive, with a clause guaranteeing the necessary financial, human and technological resources.
    – a guarantee mechanism (e.g. enforcement assurance, penalty clauses) ensuring the achievement of the specified purposes.
  • Clarifications of responsibilities – adding explicit provisions clarifying the responsibilities of EKKOMED in relation to the Film Archive, in order to eliminate any possible ambiguity or duplication.
  • Performance criteria – establishing clear criteria for assessing the functioning of the Film Archive as a measure to ensure that the objectives are achieved.
  • Specialised file management body – introduction of rules defining the role, tasks and responsibilities of a specialised body for the quality of materials.
  • Special handling rules & administrative facilities – establishing rules for audiovisual productions, including rapid processing of applications and provision of support services to producers.
  • Improved documentation – complementing the existing arrangements with detailed instructions in order to eliminate confusing gaps and ambiguities.

  • —

    Points of Rejection

  • Keeping unclear or incomplete settings – existing wording creating ambiguity or lacunae should not be maintained; they need to be replaced by clear and comprehensive provisions.

  • —

    General Suggestions & Strategic Ideas

    | Field | Strategic Approach
    |——|———————-|
    | Cooperation of | Bodies Enhancement of coordination EKKOMED ‑ Film Archive through a programmatic contract and joint audit committees. |
    | Evaluation & Supervision | Establishment of an annual evaluation mechanism (KPIs) for the Film Archive, with the possibility of corrective measures. |
    | Regulatory Framework | Adoption of an integrated framework that unifies the functions of the specialized body, the special rules and the administrative facilities. |
    | Communication & Transparency | Creation of an online information portal for producers, where the procedures, conditions and deadlines will be displayed. |
    | Resources | Budget planning with a distinct funding line for the project, ensuring long-term sustainability. |

    —

    Required Amendments to the Existing Text

    1. Introduction of paragraph 2 to Article 42 with the content described in the ‘Recommended Implementations’ section.
    2. Reference to Article 34/3905/2010 – insertion of an explicit clause confirming the official recognition of the Film Archive.
    3. Correction and restatement of current arrangements to remove any ambiguity; addition of detailed instructions and full documentation.
    4. Add a section on the specialised body – role, responsibilities, procedures for cooperation with the Film Archive.
    5. Determination of specific handling rules and administrative facilitation procedures for audiovisual productions.
    6. Integration of performance criteria and a control mechanism (e.g. annual reports, KPI evaluation).
    7. Writing of a programmatic contract clause It provides for the provision of resources and cooperation between EKKOMED and the Film Archive.

    With the implementation of the above, Article 42 will have a clear, comprehensive and operational structure, ensure the effective management of the national repository and enhance cooperation between the relevant bodies, preventing any ambiguities or shortcomings.

    📊 Overall Composition of Views

    ℹThis module is automatically generated by AI after at least 10 comments. It groups and summarises the main positions expressed by readers so that you can see a complete picture of the discussion.✦ Created with AI
    📍 Consolidation of Regulations and Special Rules for Audiovisual Productions 3 Fig.
    🟢 Support and administrative support for producers
    🟢 Result for the effective achievement of the objectives
    🟢 Lack of Clear Settings
    📍 Amendment of Article 42 – Addition and adaptation of paragraph 2 4 B.C.
    🟢 Clear role and compliance of the Film Archive
    🟢 Resource Assurance
    🟢 Specialized file management guarantees quality
    🟢 Programmatic Cooperation Agreement
    📍 Limitation of obligations to state legal entities and clarification of legal personality of the Hub 3 Fig.
    🟢 Obligation Violates the Constitution and the Right to Property
    🟢 Clear Beneficiary Definition Required
    🟢 Legal Non-‑Personality and Uncertainty of Third Party Contribution
    📍 Name Correction: Greek Film Centre 1 business
    🟢 Wrong name "National"
    📍 Optional Delivery of Copies for Individuals 2 B.C.
    🟢 Mandatory surrender violates the Constitution.
    🟢 Article 88: Ensuring Rights

    Comments

    10 responses to “PART D OTHER PROVISIONS TO STRENGTHEN THE AUDIOVISUAL INDUSTRY IN GREECE (42-45)”

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    1. Bravoo

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    2. COMMENTS AND PROPOSALS
      OF THE ASSOCIATION OF INDEPENDENT AUDIOVISUAL PRODUCERS (SAPOE) TO THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH A TITLE  
       ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

      Article 42

      For private owners, holders or possessors of material carriers of audiovisual works, in any capacity whatsoever (as producers, co-producers, etc.), the obligation to deliver copies laid down in paragraph 2 is manifestly unconstitutional. The Digital Repository established by Article 42 in general cannot be created by imposing an obligation except on an optional basis. Therefore, only state-owned legal persons, even if they operate as an AE, such as ERT, can be subject to the obligations of this article. For private beneficiaries only the optional delivery of the physical carrier does not raise any legal problems. The provision as it stands infringes the constitutionally guaranteed right of ownership of the rightholders, understood both as a right in rem over the media and as copyright in the audiovisual work incorporated in the media.
      Moreover, Article 88(1) of the draft law correctly refers to ‘the written consent of the legal holders of the rights in each project’ in relation to the administrative act that will regulate the specific issues of the Digital Repository.

      Article 43

      The layout moves in a positive direction. However, since the Hub obviously does not have a separate legal personality but is simply an Directorate within the company, it raises concerns about how it will contract with third parties, how it will be designated as the final beneficiary or co-beneficiary for projects, etc.

      Article 45

      Insert incorrectly the name of the Company as "National" instead of "Greek Film Centre etc".

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      📍 Making the obligation to take copies for private persons in Article 42(2) optional 3 Fig.
      🟢 Obligation to surrender violates constitutional property law
      🟢 Article 88 ensures the meeting of rights
      🟢 Optional take-up does not cause legal problems
      📍 Correction of the name in Par. 45 in "Greek Cinematography Center" 1 business
      🟢 The current name "National" is incorrect

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    3. Comments on Part D

      Article 45 (in conjunction with Article 88(3)):

      The establishment and operation of Audiovisual Production Facilitation Offices (DOP Offices) is considered to be positive in principle, provided that they are equipped with appropriate competences and qualified staff, so that they can effectively carry out the task of promoting and strengthening the support environment for audiovisual productions and, in particular, the administrative service and facilitation of audiovisual productions in their area of territorial competence. Article 88(3) provides that the issues of administrative procedures carried out by the DOP Offices will be specified by issuing a special Joint Ministerial Decision.

      In order to achieve effectively the objectives of the above provision, it is proposed to consolidate, codify and modernise the existing scattered arrangements for audiovisual productions and the involvement of state bodies and services in the production process (by granting licences, submitting notifications, exercising supervision, controls, or other functions within their competence). At the same time, it is proposed to establish specific rules for the handling and provision of administrative facilities by state bodies and services, especially for audiovisual productions, for issues where such rules do not exist or the existing rules are unclear or obsolete. On this basis, the promotion and reinforcement actions as well as the administrative service and facilitation of audiovisual productions by the DOP Offices are expected to become much more substantial.

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      📍 Consolidation, codification and modernisation of existing regulations and involvement of state bodies 2 B.C.
      🟢 Result for substantial achievement of the objectives of the article
      🟢 Facilitates the visibility and enhancement of the support environment
      📍 Establishment of specific handling rules and administrative facilities for audiovisual productions 2 B.C.
      🟢 Faces lack or unclear current settings
      🟢 Enhances the administrative service of producers

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    4. With regard to the articles: 42, 43 and 45
      We agree with the comments and proposals of the ASSOCIATION OF INDEPENDENT AUDIOVISUAL PRODUCERS (SAPOE)

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    5. Article 42
      For private owners, holders or possessors of material carriers of audiovisual works, in any capacity whatsoever (as producers, co-producers, etc.), the obligation to deliver copies laid down in paragraph 2 is manifestly unconstitutional. The Digital Repository established by Article 42 in general cannot be created by imposing an obligation except on an optional basis. Therefore, only state-owned legal persons, even if they operate as an AE, such as ERT, can be subject to the obligations of this article. For private beneficiaries only the optional delivery of the physical carrier does not raise any legal problems. The provision as it stands infringes the constitutionally guaranteed right of ownership of the rightholders, understood both as a right in rem over the media and as copyright in the audiovisual work incorporated in the media.

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      📍 To make the delivery of copies for private individuals optional 4 B.C.
      🟢 The obligation to surrender is manifestly unconstitutional.
      🟢 The Digital Repository cannot be created by imposing an obligation, only optionally.
      🟢 For individuals optional delivery does not create legal problems.
      🟢 The provision violates the constitutionally guaranteed right to property of the beneficiaries.
      📍 To limit the obligations of the article only to state legal entities 3 Fig.
      🟢 The obligation to surrender is manifestly unconstitutional.
      🟢 The Digital Repository cannot be created by imposing an obligation, only optionally.
      🟢 The provision violates the constitutionally guaranteed right to property of the beneficiaries.

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    6. COMMENTS AND PROPOSALS OF THE ASSOCIATION OF DIRECTORS-PRODUCERS OF GREEK CINEMA (ESPEK) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
      ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

      Following consultations with the relevant associations on this draft law, we endorse the following comments:

      ARTICLE 42

      For private owners, holders or possessors of material carriers of audiovisual works, in any capacity whatsoever (as producers, co-producers, etc.), the obligation to deliver copies laid down in paragraph 2 is manifestly unconstitutional. The Digital Repository established by Article 42 in general cannot be created by imposing an obligation except on an optional basis. Therefore, only state-owned legal persons, even if they operate as an AE, such as ERT, can be subject to the obligations of this article. For private beneficiaries only the optional delivery of the physical carrier does not raise any legal problems. The provision as it stands infringes the constitutionally guaranteed right of ownership of the rightholders, understood both as a right in rem over the media and as copyright in the audiovisual work incorporated in the media.
      Moreover, Article 88(1) of the draft law correctly refers to ‘the written consent of the legal holders of the rights in each project’ in relation to the administrative act that will regulate the specific issues of the Digital Repository.

      ARTICLE 43

      The layout moves in a positive direction. However, since the Hub obviously does not have a separate legal personality but is simply an Directorate within the company, it raises concerns about how it will contract with third parties, how it will be designated as the final beneficiary or co-beneficiary for projects, etc.

      ARTICLE 45

      Insert incorrectly the name of the Company as "National" instead of "Greek Film Centre etc".

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      📍 Abolition of the obligation to deliver copies by private individuals, obligation only for state bodies 2 B.C.
      🟢 The obligation contrary to the Constitution and the right to property
      🟢 Optional delivery does not create legal problems
      📍 Legalization or clarification of legal personality of the Hub and designation of beneficiaries 2 B.C.
      🟢 The absence of legal personality creates uncertainty for third party contributions
      🟢 Clear definition of final beneficiary/co-beneficiary needed
      📍 Brand Correction in "Greek Film Center" 1 business
      🟢 Wrong branding can be confusing and is wrong

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    7. ARTICLE 42
      We repeat that the provision of the article for an obligation to deliver to the Agency an unaltered copy of the audiovisual work as well as its use by other public bodies is particularly problematic and unrealistic, whether it is a Greek production or an international co-production, as it conflicts with a number of legal issues of intellectual property and ignores or ignores the way the international audiovisual industry operates.

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    8. The Foundation ‘Greek Film Archives-Greek Film Archive’, established by Royal Decree 105/1963 (Government Gazette, Series I, No 20) (hereinafter ‘the Film Archive’), since its establishment has had as its purpose and implemented the creation of a cinema archive, with the acquisition, preservation, preservation, promotion and promotion of Greek and foreign films, being until now the only institution in Greece with this purpose. At the same time, the Film Archive is a representative of Greece, a regular member of the International Association of Film Archives (FIAF) and a founding member of the European Association of Film Archives (ACE).

      Article 34 of Law 3905/2010, as amended by Law 4315/2014, recognises the Film Archive as an official body for the preservation of cinematographic heritage with a view to collecting, cataloguing, archiving, preserving, preserving, restoring, digitising, exploiting moving image material and, in particular, cinematographic works.
      Article 34(5) of Law 3905/2010 provides that, in order to facilitate the creation of the archive, the Film Archive is to act as the repository body for Greek films, with the legal deposit/depot legal requirement for a copy of each Greek film, as laid down in Article 3 of Law 3905/2010.
      Finally, Article 34(6) of Law 3905/2010 provides that the film archive created through legal deposit is not an asset of the foundation but belongs to the Greek State.
      The draft law under consultation ‘Creative Greece: the strengthening of the film, audiovisual and creative sectors, the establishment of a body for books and other provisions for contemporary culture" provides for the establishment of the body EKKOMED, which in accordance with Article 42 will establish and operate a National Digital Repository of Audiovisual Works. However, the objectives of the above repository of EKKOMED partly include objectives of the Film Archive as described in Article 34 of Law 3905/2010, without clarifying the relationship between the two bodies.
      In particular, both EKKOMED – National Repository and Film Archive bodies aim at collecting, cataloguing, archiving, preserving, preserving, restoring, digitising, exploiting moving image material (audiovisual works in general) and cinematographic works in particular (Article 42(1)(a) of the draft law and Article 34(2) of Law 3905/2010). Both bodies are also to operate as public repositories of films (EKKOMED and as a repository of other audiovisual works) through the institution of the legal deposit of a copy (Article 42(2) of the draft law – Article 34(5) of Law 3905/2010).
      In practice, the above provisions of the bill provide for the establishment of a second film archive by EKKOMED alongside the film archive of the Film Archive.
      Article 42(3) provides for the cooperation of the two bodies through programmatic contracts aimed at creating a single film archive and audiovisual works in general, which will be managed by EKKOMED, thus potentially depriving the Film Archive of the management of its own film archive.

      First of all, we would like to point out that the draft law on the creation of a repository of audiovisual works, i.e. television programmes, television series, etc. (in addition to films) is very positive, because to date there is no other corresponding national archive (only ERT has created an archive of audiovisual works mainly with audiovisual works from its own television programme). This project is very important for the preservation of cultural and cultural heritage in general.
      However, in order to avoid overlaps, contradictions and ambiguities and in order to systematically bring the new provisions into line with Article 34 of Law 3905/2010, and in particular the provision that the Film Archive is the official body for the preservation of cinematographic heritage, we propose that the draft law clarifies the following:

      a) After paragraph 1 of article 42 of the bill to add a new paragraph number 2 (and renumbering the following paragraphs) which provides that the purposes of the national repository provided for in paragraph 1 with regard to cinematographic films only will be implemented by the Film Archive, which will manage the relevant cinematographic archive.
      b) Article 42(2) to be amended and to provide that a specific programmatic contract concluded between EKKOMED and the Film Archive shall regulate any matter relating to the implementation by the Film Archive of the objectives referred to in paragraph 1 with regard to cinematographic films and the safeguarding of the resources required for the implementation of the above objectives.

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      📍 Addition of a new paragraph 2 to Article 42 so that the Film Archive can implement the purposes of the national repository 3 Fig.
      🟢 Avoiding overlaps and ambiguity between EKKOMED and the Film Archive
      🟢 Compliance with article 34/3905/2010 that defines the Film Archive as an official body
      🟢 File management by a specialized body ensures quality
      📍 Amendment of paragraph 2 of Article 42 for the regulation of a programmatic contract and the safeguarding of resources 3 Fig.
      🟢 Setting up cooperation through a programmatic contract
      🟢 Assurance of resources for the realization of goals
      🟢 Guarantee that the Film Archive will implement the purposes

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    9. Article 42
      For private owners, holders or possessors of material carriers of audiovisual works, in any capacity whatsoever (as producers, co-producers, etc.), the obligation to deliver copies laid down in paragraph 2 is manifestly unconstitutional. The Digital Repository established by Article 42 in general cannot be created by imposing an obligation except on an optional basis. Therefore, only state-owned legal persons, even if they operate as an AE, such as ERT, can be subject to the obligations of this article. For private beneficiaries only the optional delivery of the physical carrier does not raise any legal problems. The provision as it stands infringes the constitutionally guaranteed right of ownership of the rightholders, understood both as a right in rem over the media and as copyright in the audiovisual work incorporated in the media.
      ARTICLE 45
      Insert incorrectly the name of the Company as "National" instead of "Greek Film Centre etc".

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      📍 Exemption from the obligation to deliver copies for private individuals 2 B.C.
      🟢 The obligation is manifestly unconstitutional
      🟢 Violates the Constitutional Right to Property
      📍 Limitation of obligation only to state legal entities 2 B.C.
      🟢 Only state persons, such as ERT, should be subject to the obligation
      🟢 Obligation for individuals violates the right to property
      📍 Brand Correction in "Greek Film Center" 1 business
      🟢 The current name "National" is incorrect

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    10. The positions of the ASSOCIATION OF AUDIOVISUAL PRODUCERS (PACT) and Mr. Eleftherios Rantos agree with the SAPOE, move in the right direction and SAPOE will support any initiative and positioning that contributes to strengthening the audiovisual industry, simplifying procedures, reducing bureaucracy and generally adapting legislation to the needs and specificities of the sector.

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