Lõppdokument

Your:    18.03.2025

Our:      19.03.2025 reg nr: 13.5-6/25/4446-2

Dear Mr Topal,

Thank You for approaching to Estonian Transport Administration (TRAM) regarding establishing CAMO.

However first things first.

In Estonia CAMO can be only established if organisation correspond to terms of Principal Place of Business (PPoB).

The PPoB is the result of a complex equation of several elements, which need to be verified by TRAM before granting the approval and undertaking the responsibility for certification, oversight, and enforcement. A concrete assessment needs to be made, based on the verification of two cumulative criteria, to be applied in conjunction:

• * the head office or registered office of the organisation must be located in the Estonia; and

• * the principal financial functions and the principal operational control of its operational activities must be held within that head office or registered office located in Estonia.

Before deciding on the PPoB, TRAM shall therefore ascertain that the elements above are satisfied/fulfilled as demonstrated by evidence. The PPoB is the place where a junction of elements can be found:

1. 1. The organisation has registered its organisation with the local company or tax register and where it pays corporate tax.

2. 2. The organisation performs its main administrative and financial functions, such as payment of salaries employment benefits, invoicing, etc.

3. 3. The organisation’s accountable manager is ultimately responsible for safety. He/she is responsible for ensuring that all activities can be financed and carried out in accordance with the applicable requirements, and that the organisation is adequately structured and staffed with suitably qualified staff. As the ultimate responsible for safety and compliance vis à vis the TRAM, he/she shall reside permanently in Estonia.

4. 4. The organisation's key personnel (Safety Manager, Compliance Monitoring Manager, continuing Airworthiness Manageretc.) controls, and coordinates daily operational activities, including holding operational management meetings and processing of operational correspondence, that ultimately lead to meeting the safety objectives of the EU aviation safety acquis.

5. 5. The head office or registered office are the effective and actual centre of operations from where direction, control, planning, coordination, and corporate finance activities, and in particular in the case of Regulation (EC) 1008/2008 airworthiness management, are managed on a daily or regular basis.

6. 6. The records regarding the operational and financial decisions affecting the direction, control, planning, coordination and corporate finance of the organisation’s activities and operations, within the scope of the applicable regulations, are always tangible and potentially subject to physical inspection and/or assessment by TRAM.

If You still can find, that Your organisation will comply with PPoB principals, then let’s proceed with first opening meeting and let me know when You are ready.

Best regards,

Ivo Tolga

Head of Airworthiness Department

Aviation Division

+372 5982 3190

Lõõtsa 5 / Tallinn 11415

Estonian Transport Administration (TRAM)