Kiri

SmartLynx Airlines Estonia OÜ |Lennujaama tee 13, Tallinn, 11101, Estonia Reg. No. 12264460 | [email protected] | +372 6682817 | www.smartlynx.aero

Date: February 21th, 2024 No. 1.1-10E/2024

To: Estonian Transportation Administration

Request for information regarding the entity obligation to have a travel agreement with Estonian Transportation Administration As per our experience and communication with Estonian Transportation Administration Aviation Division regarding the covering of the expenses of the Estonian Transportation Administration Aviation Division officials during the foregin assignemnt eg. oversight actions in a another state. As per Estonain Aviation Act § 602, (6) Where the Transport Administration exercises supervision over the person specified in subsection 2 of § 601 of this Act or a civil aircraft or flight simulation training device in a foreign country, the specified person or the operator of the civil aircraft or flight simulation training device bears the secondment expenses of supervisory officials of the Transport Administration that are calculated pursuant to the procedure established on the basis of subsection 5 of § 44 of the Civil Service Act. and https://www.riigiteataja.ee/en/eli/ee/503072023003/consolide/current Civil Service Act §44, (5) The terms and procedure for secondment of an official and the reimbursement secondment expenses, including the rate of the daily allowance and terms and procedure for the payment thereof shall be established by a regulation of the Government of the Republic. and https://www.riigiteataja.ee/en/eli/ee/522122023005/consolide/current

Government of the Republic decree Conditions and procedures for sending an official on a service assignment, reimbursement of assignment expenses and payment of daily allowance and daily allowance amount. https://www.riigiteataja.ee/akt/106022018012?leiaKehtiv

Taking into account our previous communication and provided answers with no clear reference to Estonian Transportation Administration internal policies and procedures regarding the operator obligations to undersign the travel agreement with the Estonian Transportation Administration. Operator has asked a clarification from the Estonian Transportation Administration Aviation Division but at this stage no clear response have been received. Therefore we request from Estonian Transportation Administration, all related requirements and associated policies with applicable references, which clearly state the subject entity (eg. operator) responsibilities and obligations, based on what the subject entity has an obligation to undersign such kind of travel agreement with the Estonian Transportation Administration under the terms which are more demanding than required by the applicable law.

Sincerely yours,

Raino Tubli Compliance and Safety Manager 00 372 50 16 117 [email protected]

SmartLynx Airlines Estonia OÜ |Lennujaama tee 13, Tallinn, 11101, Estonia Reg. No. 12264460 | [email protected] | +372 6682817 | www.smartlynx.aero

Date: February 21th, 2024 No. 1.1-10E/2024

To: Estonian Transportation Administration

Request for information regarding the entity obligation to have a travel agreement with Estonian Transportation Administration As per our experience and communication with Estonian Transportation Administration Aviation Division regarding the covering of the expenses of the Estonian Transportation Administration Aviation Division officials during the foregin assignemnt eg. oversight actions in a another state. As per Estonain Aviation Act § 602, (6) Where the Transport Administration exercises supervision over the person specified in subsection 2 of § 601 of this Act or a civil aircraft or flight simulation training device in a foreign country, the specified person or the operator of the civil aircraft or flight simulation training device bears the secondment expenses of supervisory officials of the Transport Administration that are calculated pursuant to the procedure established on the basis of subsection 5 of § 44 of the Civil Service Act. and https://www.riigiteataja.ee/en/eli/ee/503072023003/consolide/current Civil Service Act §44, (5) The terms and procedure for secondment of an official and the reimbursement secondment expenses, including the rate of the daily allowance and terms and procedure for the payment thereof shall be established by a regulation of the Government of the Republic. and https://www.riigiteataja.ee/en/eli/ee/522122023005/consolide/current

Government of the Republic decree Conditions and procedures for sending an official on a service assignment, reimbursement of assignment expenses and payment of daily allowance and daily allowance amount. https://www.riigiteataja.ee/akt/106022018012?leiaKehtiv

Taking into account our previous communication and provided answers with no clear reference to Estonian Transportation Administration internal policies and procedures regarding the operator obligations to undersign the travel agreement with the Estonian Transportation Administration. Operator has asked a clarification from the Estonian Transportation Administration Aviation Division but at this stage no clear response have been received. Therefore we request from Estonian Transportation Administration, all related requirements and associated policies with applicable references, which clearly state the subject entity (eg. operator) responsibilities and obligations, based on what the subject entity has an obligation to undersign such kind of travel agreement with the Estonian Transportation Administration under the terms which are more demanding than required by the applicable law.

Sincerely yours,

Raino Tubli Compliance and Safety Manager 00 372 50 16 117 [email protected]