VEB NCVB AND OTHERS v. THE NETHERLANDS

THIRD SECTION

DECISION

Application no. 50494/13
VEB NCVB and Others
against the Netherlands

The European Court of Human Rights (Third Section), sitting on 11 February 2014 as a Chamber composed of:

Josep Casadevall, President,
Alvina Gyulumyan,
Ján Šikuta,
Luis López Guerra,
Kristina Pardalos,
Johannes Silvis,
Valeriu Griţco, judges,
and Marialena Tsirli, Deputy Section Registrar,

Having regard to the above application,

Having deliberated, decides as follows:

THE FACTS

1. A list of applicants is set out in the appendix. The applicants were represented by Mr T. Barkhuysen, a lawyer practising in Amsterdam (hereafter also: the applicants’ representative).

A. The circumstances of the case

2. Before the events complained of, the applicants variously held shares or subordinated bonds (the latter under diverse designations) issued by SNS REAAL N.V., a public limited company (naamloze vennootschap, “N.V.”) incorporated under Netherlands law, or one or more of its subsidiaries. The events complained of, which concern the expropriation of those shares and subordinated bonds, are set out in Stefania Adorisio and Others against the Netherlands and three other applications (dec), no. 47315/13, 14 January 2014. Appeals against the expropriation decision were dismissed by the Administrative Jurisdiction Division (Afdeling bestuursrechtspraak) of the Council of State (Raad van State) on 25 February 2013. Proceedings relating to compensation are currently pending before the Supreme Court (Hoge Raad).

B. Relevant Court procedure

1. The Rules of Court

3. At the time of the proceedings in issue, the Rules of Court, as pertinent, provided as follows (footnotes omitted):

Rule 36 – Representation of applicants

“1. Persons, non-governmental organisations or groups of individuals may initially present applications under Article 34 of the Convention themselves or through a representative. ...”

Rule 44A – Duty to cooperate with the Court

“The parties have a duty to cooperate fully in the conduct of the proceedings and, in particular, to take such action within their power as the Court considers necessary for the proper administration of justice. This duty shall also apply to a Contracting Party not party to the proceedings where such cooperation is necessary.”

Rule 45 – Signatures

“ 1. Any application made under Articles 33 or 34 of the Convention shall be submitted in writing and shall be signed by the applicant or by the applicants’ representative.

2. Where an application is made by a non-governmental organisation or by a group of individuals, it shall be signed by those persons competent to represent that organisation or group. The Chamber or Committee concerned shall determine any question as to whether the persons who have signed an application are competent to do so.

3. Where applicants are represented in accordance with Rule 36, a power of attorney or written authority to act shall be supplied by their representative or representatives. ”

Rule 47 – Contents of an individual application

“1. Any application under Article 34 of the Convention shall be made on the application form provided by the Registry, unless the President of the Section concerned decides otherwise. It shall set out

(a) the name, date of birth, nationality, sex, occupation and address of the applicant;

...

and be accompanied by

(h) copies of any relevant documents and in particular the decisions, whether judicial or not, relating to the object of the application.

...

4. Failure to comply with the requirements set out in paragraphs 1 and 2 of this Rule may result in the application not being examined by the Court.

5. The date of introduction of the application for the purposes of Article 35 § 1 of the Convention shall as a general rule be considered to be the date of the first communication from the applicant setting out, even summarily, the subject matter of the application, provided that a duly completed application form has been submitted within the time-limits laid down by the Court. The Court may for good cause nevertheless decide that a different date shall be considered to be the date of introduction. ... ”

2. The Practice direction on the institution of proceedings

4. Clarification of the above Rules, among others, was provided by a Practice direction on the institution of proceedings issued by the President of the Court under Rule 32 of the Rules of Court. At the time of the proceedings here in issue, it read as follows, in its relevant parts and in the redaction in force since 24 June 2009 (footnote omitted):

“4. If an application has not been submitted on the official form or an introductory letter does not contain all the information referred to in Rule 47, the applicant may be required to submit a duly completed form. It must be despatched within eight weeks from the date of the Registry’s letter requesting the applicant to complete and return the form.

Failure to comply with this time-limit will have implications for the date of introduction of the application and may therefore affect the applicant’s compliance with the six-month rule contained in Article 35 § 1 of the Convention.

5. Applicants may file an application by sending it by fax. However, they must despatch the signed original by post within eight weeks from the date of the Registry’s letter referred to in paragraph 4 above.

...

7. On receipt of the first communication setting out the subject-matter of the case, the Registry will open a file, whose number must be mentioned in all subsequent correspondence. Applicants will be informed thereof by letter. They may also be asked for further information or documents.

...

9. Failure to provide further information or documents at the Registry’s request (see paragraph 7) may result in the application not being examined by the Court or being declared inadmissible or struck out of the Court’s list of cases. ”

COMPLAINTS

5. The applicants complained under Article 6 of the Convention about the procedure followed in connection with the expropriation of their shares or subordinated bonds and under Article 1 of Protocol No. 1 about the failure to award them any compensation. They restated the substance of these complaints under Article 13 of the Convention taken together with Article 1 of Protocol No. 1.

PROCEEDINGS BEFORE THE COURT

6. On 19 July 2013 the applicants’ representative contacted the Court’s registry by fax announcing his intention to lodge an application on behalf of approximately 8,000 natural and legal persons and asking to be dispensed from the requirement of submitting individual signed letters of authority from each one.

7. On 24 July 2013 the Court’s Registry replied by fax that no such dispensation could be given. It was pointed out to the applicants’ representative that in the absence of valid letters of authority, the Court might declare the application inadmissible on the ground that there was no valid application. The Registry’s fax made reference to the Court’s case-law in this respect, in particular to Post v. the Netherlands (dec.), 21727/08, 20 January 2009; Kemevuako v. the Netherlands (dec.), no. 65938/09, § 22, 1 June 2010; Çetin v. Turkey (dec.), no. 10449/08, 13 September 2011; Kaur v. the Netherlands (dec.), no. 35864/11, §§ 17-19, 14 May 2012; and Ngendakumana v. the Netherlands (dec.), no. 16380/11, 5 February 2013. It was announced in addition that the applicants would be asked to submit their particulars in the form of an Excel table in order to expedite administrative processing of their application.

8. On 25 July 2013 the applicants’ representative asked to be given more time to complete the application.

9. The following day the Court’s Registry replied by fax and by letter. The reply included the following:

“The eight-week grace period beyond the end of the six-month time-limit is not amenable to extension. Failure to complete an application by the end of that period will in principle lead to the date of submission of the completed application – rather than the date of the first communication – being taken as the date of the introduction of the application (see Abdulrahman v. the Netherlands (dec.), no. 66994/12, 5 February 2013. ”

In addition, the attention of the applicants’ representative was drawn to the requirements to which a formal application had to conform, as set out in Rule 47 of the Rules of Court.

10. The applicants’ representative submitted an introductory letter on behalf of his clients on 31 July 2013. The letter stated, among other things, that the applicants included 7,888 individual natural and legal persons, of whom 6,189 were members of the association VEB NCVB. A printout of a computer generated list with their names, addresses, gender (where applicable), country of residence and membership status was appended. The nationality of the listed persons was not stated; nor, in the majority of cases, was the date of birth.

11. On 12 August 2013 the Registry of the Court sent the applicants’ representative a letter inviting him to submit a completed application form (Rule 47 of the Rules of Court). The letter included, inter alia, the following paragraphs:

“You should return the completed application form by post not later than eight weeks from the date of the present letter. In other words, the date on which you send back the completed application form must not be later than 8 October 2013 [emphasis in the original]. Failure to comply with this time-limit will mean that it is the date of the submission of the completed application form rather than that of your first communication which will be taken as the date of the introduction of the application. Your attention is drawn to the fact that it is the date of introduction that is decisive for compliance with the time-limit set out in Article 35 § 1 of the Convention (see paragraph 18 in enclosed notes to applicants).

With reference to the Registry’s previous letters you are reminded to submit for each individual applicant an authority form bearing the applicant’s original signature (i.e. no scanned copy). In case the applicant is a company or other entity holding legal personality, this authority form should be supplemented with proof that the person signing the authority form is legally authorised to act on behalf of the company or entity (for instance, by submitting the company articles or (an equivalent of) an extract from the Netherlands Chamber of Commerce). Your attention is drawn to the fact that in the absence of an original authority form the Court may declare the application inadmissible (see Post v. the Netherlands (dec.), 21727/08, 20 January 2009; Kemevuako v. the Netherlands (dec.), no. 65938/09, § 22, 1 June 2010; Çetin v. Turkey (dec.), no. 10449/08, 13 September 2011; Kaur v. the Netherlands (dec.), no. 35864/11, §§ 17-19, 14 May 2012; and Kokhreidze and Ramishvili v. Georgia (dec.), nos. 17092/07 and 22032/07, 25 September 2012).

You are requested to complete the attached table with information regarding all the applicants and send back the completed table on a CD-ROM or a memory stick before the date indicated above, i.e. 8 October 2013 [emphasis in the original]. Please follow the instructions below:

- do not modify the table’s formatting;

- complete all fields;

- stick a bar code provided by the Court on the CD-ROM/memory stick and the cover page. ”

12. The letter and a blank table in Microsoft Excel format were sent to the applicants’ representative by e-mail on the same day. Enclosures with the letter sent by post included a document entitled “Notes for the guidance of persons wishing to apply to the European Court of Human Rights”, which gave, inter alia, the following instructions (emphasis in the original):

“18. If you consider that your complaints concern one of the rights guaranteed by the Convention or one of the Protocols, and that the conditions described above are satisfied, you should fill in the application form carefully and legibly and send it, together with any documents required for its examination, as soon as possible and not later than eight weeks after the date of the first letter from the Registry. If the application form is not sent within those eight weeks, it will be the date on which you send your completed application form which determines whether you have complied with the six-month time-limit set out in Article 35 § 1 (see paragraphs 6 and 10 above) and not the date of your first letter. Moreover, if the application form has not been returned six months from the date when it was sent to you, this will be taken to mean that you no longer wish to pursue the examination of your case, and the file will be destroyed. In addition, failure to provide further information or documents at the Registry’s request may result in the application not being examined by the Court or being declared inadmissible or struck out of the Court’s list of cases.

19. When you fill in an application form, you should make sure that you:

(a) set out the relevant information about the parties (Section I of the form), with a separate sheet for each applicant, if necessary, and a form (or forms) of authority if a representative is appointed;

...

(h) sign the declaration. If the declaration is signed by a representative, a properly completed form of authority must accompany the form, if it has not already been submitted.

...

21. For the purpose of lodging the initial complaint, you need not be represented by a lawyer, nor does your representative have to be a lawyer. If you have legal representation, the application form must be accompanied by your authority for the lawyer or other representative to act on your behalf. A representative of a legal entity (company, association, etc.) or group of individuals must provide proof of his or her legal right to represent it.”

13. By fax of 19 September 2013 the applicants’ representative again requested an extension of the time-limit for the completion of the application.

14. On 20 September 2013 the Registry sent a reply by fax and by letter, in the following terms:

“I acknowledge receipt of your fax of 19 September 2013 requesting an extension of the time-limit for the completion of the application.

In reply I should inform you that the eight-week period as indicated in my letter of 12 August 2013 is not amenable to extension. Failure to complete an application by the end of that period will in principle lead to the date of submission of the completed application – rather than the date of the first communication – being taken as the date of the introduction of the application (see Abdulrahman v. the Netherlands (dec.), no. 66994/12, 5 February 2013 and paragraphs 3 and 4 of the Practice Direction on the Institution of Proceedings, issued by the President of the Court in accordance with Rule 32 of the Rules of Court). ”

15. A completed application form without letters of authority or other information was received at the Court’s registry by fax on 7 October 2013.

16. A cardboard box containing the original application form, this time accompanied by letters of authority and other information, was received by post on (Friday) 11 October 2013. A label stuck onto the cardboard box stated the date 9 October 2013 and the time 7.10 p.m. There was no postmark or other indication of an earlier sending date.

17. On 22 November 2013 the Registry received, by e-mail, a table that did not conform to the instructions contained in the letter of 12 August 2013.

18. The blank table was re-sent to the applicant’s representative by e-mail on 26 November 2013 with instructions identical to those given in the Registry’s letter of 12 August 2013.

19. On 4 December 2013 the Registry received from the applicants’ representative an e-mail which included the following:

“Please find attached, as requested, the excel file including the data of the applicants of the application registered by your Court under the number 50494/13 (see attachment 1). These applicants (also mentioned on pages 3 and 4 of the application form dated 7 October 2013) are:

(1)The association VEB NCVB (hereafter: VEB)

(2)The Netherlands Trade Union Confederation (Federatie Nederlandse Vakbeweging)

(3)Aviva Vie S.A., Aviva Epargne Retraite S.A., Antarius S.A. and Aviva Investors France S.A. [public limited companies (sociétés anonymes, ‘S.A.’) incorporated under French law]

(4)HDI-GERLING Verzekeringen N.V. [a public limited company incorporated under Netherlands law]

(5)Antonius Jacobus Cornelis van Ginderen LLM

(6)Theodorus Joannes Maria de Groen LLM

(7)De Turfmij B.V. [a limited liability company (besloten vennootschap, ‘B.V.’) incorporated under Netherlands law]

(8)Castrifon B.V.

(9)Other parties who are applicants and who are listed in an annex (it concerns 98 persons).

With our e-mail of 22 November 2013 we sent you a list of 7,888 names of expropriated parties (attached a second time, for safety’s sake, as attachment 2). These parties include members and non-members of VEB who have made themselves known to the VEB with the request to be represented by the VEB in proceedings against the expropriation including proceedings before your Court. These (legal) [and natural] persons are therefore not applicants. As is apparent from the following passage on page 3 of the supplementary application, VEB wishes to be admitted as an applicant in three capacities:

(i) as an expropriated party that owned two shares in SNS REAAL;

(ii) on behalf of its 6,189 expropriated members and the 1,699 expropriated parties who requested representation by VEB but who are not members of that association. The members are listed in page 1 up to and including page 72 of Attachment a4 of this application; the other pages of Attachment a4 list the 1,699 expropriated parties who are not members of VEB;

(iii) as a promoter of the collective and general interest of (small) shareholders (60,000 expropriated shareholders), in accordance with its articles of association (Attachment a5) and its factual activities, acting on behalf of expropriated parties ([section 1:2(3)] of the General Administrative Law Act [Algemene wet bestuursrecht] and Article 3:305a [of the] Civil Code [Burgerlijk Wetboek]).”

20. In reply to this e-mail, the Registry invited the applicants’ representative to submit the table of applicants on a CD-ROM or a memory stick, in accordance with the instructions given on 12 August 2013.

21. A memory stick with the same table was received at the Court’s registry by post on 7 December 2013. The number of persons listed as applicants, after correction for two legal persons that would appear to have been named twice, was 55 not 98.

THE LAW

A. Applicants

22. On the Excel table submitted (paragraph 21 above), not all fields were completed as requested. Information required by Rule 47 § 1 to be given – the date of birth, or the nationality, or both – was still lacking in respect of 25 of the 55 persons listed.

23. A number of letters of authority were photocopies or printouts of faxes or scans which did not bear the original signature of the applicant (or in the case of a legal person, the original signature of a natural person competent to represent that legal person). These included eleven persons, among them Castrifon B.V. and De Turfmij B.V., both mentioned in the e-mail of the applicants’ representative of 4 December 2013. Further letters of authority were signed in the original not by the applicant (or in the case of a legal person, a natural person competent to represent that legal person) but by an advocate (from a firm other than Mr Barkhuysen’s) on the applicant’s behalf. These included eight more of the persons remaining on the table. In respect of these nineteen persons, the application will not be examined because the requirements set out in Rule 45 have not been met (see paragraph 5 of the Practice direction on institution of proceedings, paragraph 4 above).

24. The Appendix to this decision lists the remaining 36 natural and legal persons listed on the Excel table as applicants.

B. Standing of the association VEB NCVB

25. Article 34 of the Convention provides as follows:

“The Court may receive applications from any person, non-governmental organisation or group of individuals claiming to be the victim of a violation by one of the High Contracting Parties of the rights set forth in the Convention or the Protocols thereto. The High Contracting Parties undertake not to hinder in any way the effective exercise of this right.”

26. The first applicant, the association VEB NCVB, asked to be admitted as an applicant in three capacities: firstly, as an expropriated shareholder in its own right; secondly, “on behalf of” 7,888 named natural and legal persons who were not themselves applicants; and thirdly, “as a promoter of the collective and general interest” of 60,000 unnamed others (paragraph 19 above).

27. The Court has held that the concept of “victim“ within the meaning of Article 34 of the Convention must be interpreted autonomously and independently of domestic concepts such as those concerning the interest in taking proceedings or the capacity to do so. According to the Court’s standing case-law, for an applicant to be able to claim that he or she is the victim of a violation of one or more of the rights and freedoms recognised by the Convention and its Protocols, there must be a sufficiently direct link between the applicant and the damage which he or she claims to have sustained as a result of the alleged violation (see, among other authorities, Association des amis de Saint-Raphaël et de Fréjus v. France (dec.), no. 45053/98, 29 February 2000, in respect of the applicant association; and Uitgeversmaatschappij De Telegraaf B.V. and Others v. the Netherlands (dec.), no. 39315/06, 18 May 2010, in respect of the applicants Nederlandse Vereniging van Journalisten (Netherlands Association of Journalists) and Nederlands Genootschap van Hoofdredacteuren (Netherlands Society of Editors-in-Chief)).

28. The Court has actually denied standing as applicants to non-governmental bodies set up with no other aim than to vindicate the rights of alleged victims (see Smits, Kleyn, Mettler Toledo B.V. et al., Raymakers, Vereniging Landelijk Overleg Betuweroute and Van Helden v. the Netherlands (dec.), nos. 39032/97, 39343/98, 39651/98, 43147/98, 46664/99 and 61707/00, 3 May 2001, in respect of the applicant Vereniging Landelijk Overleg Betuweroute, and Stichting Mothers of Srebrenica and Others v. the Netherlands (dec.), no. 65542/12, § 116, 11 June 2013, in respect of the applicant Stichting Mothers of Srebrenica); and even to non-governmental organisations whose very purpose was to defend human rights (see Van Melle and Others v. the Netherlands (dec.), no. 19221/08, 29 September 2009, in respect of the applicant Liga voor de Rechten van de Mens).

29. The Court considers, in the light of this case-law, that the first applicant can claim the status of “victim” within the meaning of Article 34 of the Convention only in so far as its own interests are affected, that is, as the former owner of two shares in SNS REAAL N.V. expropriated in the course of the events complained of. For the remainder, the application in so far as brought by the first applicant is incompatible ratione personae with the provisions of the Convention within the meaning of Article 35 § 3 (a) and must be rejected in accordance with Article 35 § 4.

C. Complaints under Article 6 § 1 of the Convention

30. The applicants complain about the proceedings before the Administrative Jurisdiction Division of the Council of State. They rely on Article 6 § 1 of the Convention, which, in its relevant part, provides as follows:

“In the determination of his civil rights and obligations ... everyone is entitled to a fair ... hearing ... by [a] ... tribunal ...”

31. Article 35 § 1 of the Convention provides as follows:

“The Court may only deal with the matter after all domestic remedies have been exhausted, according to the generally recognised rules of international law, and within a period of six months from the date on which the final decision was taken.”

32. The final decision relevant to these complaints was that given by the Administrative Jurisdiction Division on 25 February 2013 (see paragraph 2 above). The six-month time-limit laid down in Article 35 § 1 of the Convention therefore came to an end on 25 August 2013.

33. The Court observes that the applicants’ representative was informed by letter and e-mail of 12 August 2013 (see paragraphs 11 and 12 above) that the six-month time-limit laid down in Article 35 § 1 of the Convention, extended by the grace period granted at that time by paragraphs 4 and 5 of the said Practice direction, would end on 8 October 2013. This was confirmed to him by letter and fax of 20 September 2013 (see paragraph 14 above).

34. The application form was received by fax on 7 October 2013 and by post on 11 October 2013. In the absence of a postmark or other visible indication of a sending date earlier than 9 October 2013 (see paragraph 16 above), the Court cannot verify that the application form was posted on 8 October 2013 at the latest (see, among other authorities, Kemevuako v. the Netherlands (dec.), no. 65938/09, § 22, 1 June 2010, and Abdulrahman v. the Netherlands (dec.), no. 66994/12, 5 February 2013).

35. However that may be, the Court cannot ignore the fact that the applicants’ representative submitted identifying information of the applicants in the required electronic format on 4 December 2013 at the earliest (see paragraph 19 above) – by e-mail, not on a CD-ROM or a memory stick as requested.

36. It is the duty of applicants, no less than Governments, to co-operate fully in the conduct of the proceedings and, in particular, to take such action within their power as the Court considers necessary for the proper administration of justice (Rule 44A of the Rules of Court). For present purposes, the implication is that it is the responsibility of the individual applicant to submit a properly completed application form and provide the Court with all the information required for processing the application in a timely manner.

37. In the instant case, the applicants were required to complete a table in a commercially available and extremely common electronic format and submit it on a physical medium, a CD-ROM or a memory stick. The Court takes the view that they could reasonably be expected to comply with the instructions given by its Registry.

38. The Registry’s purpose in requiring the submission of the applicants’ identifying information in a prescribed electronic format was to enable the applicants, who were expected – until the application was actually submitted – to be as many as 8,000, to be registered individually in the Court’s administrative database. The technical means to simplify this task exist and can be presumed to be at the disposal of the applicants themselves if not their representative.

39. The time available, which under Article 35 § 1 of the Convention is six months from the date of the final domestic decision, would appear to have been adequate of itself. In addition, at the relevant time the Practice direction on the institution of proceedings vouchsafed a grace period which in the present case extended the time-limit by a further one month and twelve days.

40. In the circumstances, therefore, the Court finds that there is good cause to hold that the date of introduction of the application is 7 December 2013, the date on which the memory stick with the requested information was finally received at the Registry.

41. It follows that the complaints here in issue have been introduced out of time and must be rejected in accordance with Article 35 §§ 1 and 4 of the Convention.

D. Complaints under Article 1 of Protocol No. 1 taken alone and together with Article 13 of the Convention

42. All applicants complain in addition that they have been deprived of their possessions in violation of Article 1 of Protocol No. 1, which provides as follows:

“Every natural or legal person is entitled to the peaceful enjoyment of his possessions. No one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by law and by the general principles of international law.

The preceding provisions shall not, however, in any way impair the right of a State to enforce such laws as it deems necessary to control the use of property in accordance with the general interest or to secure the payment of taxes or other contributions or penalties.”

43. They also complain that they have been denied an effective remedy in this respect, in violation of Article 13 of the Convention, which provides as follows:

“Everyone whose rights and freedoms as set forth in [the] Convention are violated shall have an effective remedy before a national authority notwithstanding that the violation has been committed by persons acting in an official capacity.”

44. The Court notes that proceedings relating to compensation are currently pending before the Supreme Court (see paragraph 2 above and Stefania Adorisio and Others against the Netherlands and three other applications (dec), cited above, § 48).

45. It follows that the applicants’ complaints under this head are premature and must be rejected under Article 35 §§ 1 and 4 of the Convention for non-exhaustion of domestic remedies.

For these reasons, the Court unanimously

Declares the application inadmissible.

Marialena TsirliJosep Casadevall
Deputy RegistrarPresident

Appendix

No.

Firstname LASTNAME

Birth date

Nationality

Place of residence 

VEB NCVB

08/03/1924

Dutch

THE HAGUE 

FEDERATIE NEDERLANDSE VAKBEWEGING

18/12/1975

Dutch

AMSTERDAM 

AVIVA VIE S.A.

French

BOIS-COLOMBES 

AVIVA EPARGNE RETRAITE S.A.

11/02/2011

French

BOIS-COLOMBES 

ANTARIUS S.A.

20/10/1995

French

PARIS 

AVIVA INVESTORS FRANCE S.A.

French

PARIS 

HDI-GERLING VERZEKERINGEN N.V.

29/12/1987

Dutch

ROTTERDAM 

A.J.C. VAN GINDEREN

09/07/1945

Dutch

HUIJBERGEN 

T.J.M. DE GROEN

14/08/1952

Dutch

ROTTERDAM 

P. ANGIUS

21/10/1948

Italian

RIJSWIJK ZH 

R. VAN DER BURG

10/12/1943

Dutch

SAS VAN GENT 

J.H.M. VAN DE CAMP-GABRIELS

10/09/1952

Dutch

UDEN 

CASA KISHOO S.A.

22/01/1986

Spanish

SANTA CRUZ DE TENERIFE  

KALYANI SICAV S.A.

19/01/1998

Spanish

MADRID 

LAXMI INVERSIONES S.A.

20/01/1986

Spanish

MADRID 

SONIA CANARIAS 2011, S.L.

25/11/2011

Spanish

SANTA CRUZ DE TENERIFE  

M.G.A. and T.H.L FREIJ AND LENGS        

14/03/1959

Dutch

VENLO 

J.F. DE HAAN

25/06/1953

Dutch

NOORDEINDE NH 

P. KROGH PETERSEN

20/12/1945

Danish

RISSKOV 

POLYTECH

10/05/1995

Danish

ODENSE SV 

STICHTING STEDEBOUW EN STADSHERSTEL EN ANDEREN

08/06/1984

Dutch

‘s-GRAVENHAGE 

WILLCOX INT. FUNDS SA

15/10/1993

Panamanian

BARCELONA 

J. and K. BJERGHOLT

Not known

Not known

HØRSHOLM 

BRUNHEER B.V.

03/12/1987

Not known

ENGELBERG 

M. HARRJE

19/05/1983

Not known

BREMERHAVEN 

H.L. HOFSTEE-SCHOLTE

Not known

Not known

HAREN GN 

J.W. KOENDERS

Not known

Not known

ZEVENAAR 

R.D. KNOL

23/02/1955

Not known

ROSMALEN 

V.O.F. COMPLEXAS ADVISORY

01/11/2006

Not known

ZUID-SCHARWOUDE 

S. KRUMBHOLZ

Not known

Not known

HAMBURG 

F. LIGTVOET

30/09/1947

Not known

LEIDERDORP 

A. VAN MOOK

20/09/1938

Not known

DONGEN 

MPM CAPITAL INVESTMENTS

11/05/2009

Not known

B’KARA 

J.D. OUWERKERK

Not known

Not known

KROPSWOLDE 

H. and C. UHRENHOLT

Not known

Not known

VEDBAEK 

KROGH & PARTNERS LTD - CHARTERED ACCOUNTANT

17/02/1989

British

LONDON

 

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