Republic of Serbia Anti-Corruption Agency The

REPUBLIC OF SERBIA ANTI-CORRUPTION AGENCY

THE FIRST REPORT ON OVERSIGHT OF POLITICAL ENTITES 2012 ELECTION CAMPAIGN COSTS

Belgrade, May 2013

Translation of this document has been provided through a USAID funded Judicial Reform and Government Accountability Project.

TABLE OF CONTENTS

INTRODUCTION 5

1. DATA USED FOR THE ANALYSIS AND OVERSIGHT OF FINANCIAL REPORTS 8

1.1. Collection of data during the election monitoring campaign 8

1.1.1. Concept and structure of monitoring 8 1.1.2. Collection and exchange of data 10 1.1.3. Purpose and importance of monitoring 10

1.2. Collection of data from state authorities, banks, legal entities and natural persons 10

1.2.1. Advertising via media outlets 11 1.2.2. Advertising by election material 12 1.2.3. Public event organization 12

2. SUBJECT TO OVERSIGHT 14

3. FINANCIAL INDICATORS 18

3.1. Income 19

3.1.1. Contributions from natural persons 19 3.1.2. Contributions from legal entities 24

3.2. Expenditures 25

3.2.1. Public advertising 29 3.2.2. Election Material 31 3.2.3. Other expenses 33 3.2.4. Public events 34

4. COMPARISON OF PRESENTED INCOME AND EXPENDITURES 36

4.1. Comparative Review of Income and Expenditures 36

5. ELECTORAL BOND 37

6. RECOMMENDATIONS IN THE COURSE OF OVERSIGHT 38

7. FACTS INDICATING VIOLATIONS OF THE LAW ON FINANCING OF POLITICAL ACTIVITIES AND PHENOMENA OBSERVED DURING INCOME AND EXPENDITURES OVERSIGHT 40

7.1. Facts indicating violations of the Law observed in income and expenditures oversight 40

7.1.1. Failure to submit the report on election campaign costs 40 7.1.2. Formal irregularities 40 7.1.3. Failure to present the election campaign income and costs 41 7.1.4. Unspent funds from the election campaign 46 7.1.5. Settling the expenses of an election campaign using an account opened for raising funds and paying the expenses of another election campaign 46 7.1.6. Settling election campaign expenses using an account that was not opened for election campaign financing 47 7.1.7. Contributions from legal persons that failed to satisfy their dues on the basis of public income 48 7.1.8. Failure to submit data on the request of the Agency 49

7.2. Phenomena indicating violations of the Law during income and expenditure oversight 50

7.2.1. Uncovered Liabilities 50 7.2.2. Indebtedness 50 7.2.3. Donors and Donor Income 50 7.2.4. Election Campaign Donors Registered After Call for Elections 52 7.2.5. Local Government Entities As Donors Of Contributions 52

8. NEXT STEPS 53

ANNEX 1 OVERVIEW OF LISTS OF CANDIDATES BY LOCALES FOR WHICH THE REPORTS WERE NOT SUBMITTED BY 24 APRIL 2013

ANNEX 2 OVERVIEW OF THE HIGHEST AND LOWEST DONATIONS MADE BY NATURAL PERSONS AND LEGAL ENTITIES LISTED BY ELECTORAL LEVELS

ANNEX 3 OVERVIEW OF NON-FINANCIAL CONTRIBUTIONS MADE BY NATURAL AND LEGAL PERSONS, LISTED BY ELECTORAL LEVEL, WITH AN INDICATION OF NON- FINANCIAL CONTRIBUTION TYPE

ANNEX 4 REVIEW OF POLITICAL ENTITIES DUES NOT SATISFIED BY THE DAY OF FILING OF THE AGENCY’S REPORT

ANNEX 5 LIST OF LEGAL ENTITIES WITH DEBTS NOT SETTLED ON THE DAY OF REPORT SUBMISSION

INTRODUCTION

On May 6, 2012, in the Republic of Serbia, elections were held for the President of the Republic, Members of Parliament (MPs) of the National Assembly of the Republic of Serbia, deputies of the Autonomous Province of Vojvodina (APV) Assembly, and councilors of assemblies of the local self- government units1.

All participants in the election campaign in the period from the day of calling the elections till the day of proclamation of the final results were generically named „political entities‟, which we may, in terms of the Law on Financing of Political Activates2, differentiate into political parties, coalitions, and groups of citizens.

Every political entity that participated in the election campaign, whether it nominated a candidate or filed an electoral list, had the following obligations in terms of the Law:

 Obligation to open a special-purpose account for funds raised to finance every election campaign, and to pay all election campaign expenses from that account (Article 24);  Obligation to appoint a person responsible for lawful financing of political campaigns and submission of a report, as well as to inform the Agency about the appointment of said person within three days of his/her appointment (Article 31);  Obligation to submit to the Agency a report on election campaign costs containing data on the origin, amount, and structure of raised and spent funds from both public and private sources; to submit the report in a form, whose content is established by the Rulebook on Contribution and Asset Records, Annual Financial Report, and the Report on Election Campaign Expenses of a Political Entity3 (“Official Gazette of the RS”, nos. 72/11 and 25/12), in a way stipulated by the Law and Rulebook and in compliance with the time limit of 30 days from the day of publication of final election results for electronic submission plus a written report 8 days after the electronic submission;

1 In the city of Belgrade Assembly and assemblies of other 22 towns of the republic of Serbia (Valjevo, Vranje, Zajeĉar, Zrenjanin, Jagodina, Kragujevac, Kraljevo, Kruševac, Leskovac, Loznica, Niš, Novi Paraz, Novi Sad, Panĉevo, Poţarevac, Smederevo, Sombor, Sremska Mitrovica, Subotica, Uţice, Ĉaĉak and Šabac), Municipal Assemblies (except for AranĊelovac, Bor, Kosjerić, Kovin, Negotin, Odţak and Vrbas) and City Municipla Assemblies (except for Voţdovac and Zemun). 2 “Official Gayette of the Republic of Serbia”, No. 43/11. 3 “Official Gayette of the Republic of Serbia”, Nos. 72/11 and 25/12. 5

 Obligation to, upon the Agency‟s request, submit all data, during the campaign and afterwards, needed by the Agency so as to conduct all tasks related to oversight of election campaign financing (Article 32).

The Anti-Corruption Agency, whose competence comprises (Article 5 of the Law on the ACA) the tasks stipulated by the Law on Financing of Political Activities, which regulates source and mode of financing of political activities of political parties, coalitions and group of citizen, has the following rights (Articles 27-29 and 32-34):

 Right to have direct and free access to bookkeeping records and documentation and financial reports of both political entity and endowment and foundation founded by political party;  Right to send a request to a political entity to submit all requested documents and information within a time limit not exceeding 15 days (during the election campaign, not exceeding 3 days);  Right to send a request to any authority of the Republic of Serbia, Autonomous Province, and local self-government units, banks, as well as to natural persons and legal entities financing political entities, or which on their behalf and for their account provided certain service, asking them to send information, in which process all prohibitions and restrictions regarding submission of information stipulated by other regulations are not implemented;  Possibility to engage relevant experts and institutions;  Possibility to, after financial report oversight, send a request to the State Audit Institution to audit the reports in accordance with the law regulating competencies of the SAI;  Right to organize independent monitoring of election campaigns within the election campaign expenses oversight tasks, for which funds from the budget of the Republic of Serbia are allocated to the Agency;  Right to adopt by-laws regulating the content and manner of keeping of records on assets and contributions, as well as those regulating the content of the annual financial statement and report on election campaign expenses.

Furthermore, the Agency was granted certain authorities in case of violation of the Law (Articles 35- 40 and Articles 42-43):

 To impose a warning measure on a political entity if in the oversight procedure it establishes some irregularities that might be corrected;  To file a motion to institute a criminal or misdemeanor proceedings; 6

 To, after the start of a criminal or misdemeanor proceedings, send a request to the ministry competent for financial affairs, or the relevant province authority, or local self-government authority, to issue a decision on temporary suspension of transfer of funds from public sources to a political entity until a final decision in the criminal or misdemeanor proceedings is rendered;  To, in case of conviction for a criminal offense or if a political party or a responsible person in a political entity is convicted for a misdemeanor, issue a decision on the loss of rights to public funds for financing of regular work of a political entity for the next calendar year. The decision also established the amount of funds to be suspended.

1. DATA USED FOR THE ANALYSIS AND OVERSIGHT OF FINANCIAL REPORTS

1.1. Collection of data during the election monitoring campaign

1.1.1. Concept and structure of monitoring

The new Law on Financing of Political Activities, which entered into force in June 2011, introduced an important novelty when it comes to an oversight of the money flows through the transactions of political entities. This complex and responsible task was entrusted to the Anti-Corruption Agency.

The first step undertaken by the Agency to ensure financial transparency in the campaign was through the organization of a monitoring process in 2012 so as to monitor the activities of political entities during their campaign for the president of the Republic, MPs, deputies, and councilors. This process is very important in the period of election cycles, when the dynamic of financial transactions of political entities is at the highest level. In November 2011, the Agency initiated all preparations for the monitoring processes.

In the same month, the Agency adopted a Rulebook on Election Campaign Monitors, regulating organization, competences, rights, obligations, terms, and manner of selection of monitors for the election campaign cost oversight procedure. On the basis of a Decision by the Agency‟s Director, a network comprising 165 monitors was formed, and they were deployed in 23 towns throughout the Republic of Serbia (Belgrade and 22 other towns).

Table 1: Overview of funds from the budget of the RS the ACA spent of 2012 election campaign monitoring

ECONOMIC ITEM NAME EXPENDITURES CLASSIFICATION IN THE BUDGET (RSD) 421 CURRENT COSTS (LANDLINE COSTS, AND OTHER CURRENT COSTS) 222,000.00 422 TRANSPORTATION COSTS 25,000.00 423 SERVICES PER AGREEMENTS (ENGAGEMENT OF MONITORS) 35,566,000.00 OTHER COSTS 1,146,000.00 426 STATIONARY, FUEL COSTS, ADDITIONAL EQUIPMENT 270,000.00 MACHINES AND EQUIPMENT (COSTS OF MOBILE TELEPHONE, 512 1,168,000.00 CAMERAS, DICTAPHONES, AND SO FORTH) TOTAL 38,397,000.00

As shown in Table 1, the amount spent for the monitoring totaled RSD 38,397,000.00, specifically: landline costs and other current costs RSD 222,000.00, transportation costs RSD 25,000.00; services per agreements for engagement of monitors RSD 35,566,000.00, other costs RSD 1,146,000.00; material- stationary, fuel costs, additional equipment RSD 70,000.00 and machines and costs of mobile telephones, purchase of cameras, dictaphones for the monitors RSD 1,168,000.00.

Monitors were organized as a pyramid organization of three levels:

 Field monitors (132) whose task was to directly, in the field in towns they were deployed to, monitor and make records of all activities of political entities. They submitted weekly reports on their activities to relevant coordinators.  Coordinators (23) were deployed to towns and county municipalities, and were tasked not only to organize and supervise the work of the field monitors, but also to monitor and record all activities of political entities. They were authorized to communicate with political entities and state authorities, if needed, so as to get information related to election campaign. Each coordinator was obliged to submit a report to central coordinators about the activities of every political entity from the territory they were in charge of, on the basis of the reports of field monitors they supervised, and their own direct monitoring.  Central coordinators (10) were tasked to supervise and instruct coordinators of certain districts, prepare and process reports of coordinators, and submit their own reports to the Secretariat of the Agency. Central coordinators collected and classified data in two ways: 1. for every political entity from the towns whose coordinators they supervised, and 2. each central coordinator was obliged to exchange information with the other nine colleagues so as to collect all data about activities of one political entity at the level of the Republic of Serbia for all election levels.

1.1.2. Collection and exchange of data

When the network of monitors was established, the scope of monitoring throughout the campaign was defined, i.e., activities of the political entities to specifically pay attention to in the monitoring process were defined.

The Law on Financing of Political Activities encompasses with the generic name “political entity” a political party, coalition, or group of citizens as a potential submitter of registered electoral lists and nominator of candidates whose activities are monitored throughout election campaign from the day of

9 calling elections until the day final election results are proclaimed. All data about election material, public events, and appearances in local media outlets were collected.

When it comes to election material, the first thing to be noted was how many different election materials existed – whether they were leaflets or any other promotional material such as pens, flags or lighters, whether they were glued, or there were billboards. Further on, which level of elections the election material referred to – whether to parliamentarian, provincial, presidential, or local elections, or if the material was general election material to be used for promotion at all levels of elections. And finally, attention had to be paid to the location and time of distribution of election material, as well as to the quantity.

Public events subject to monitoring encompassed mass rallies, conventions, stands, press conferences, and other public events organized around points and stands. When monitoring public events, every monitor was supposed to record everything related to the costs of the monitored political entity. The system for data collecting relied mainly on field monitors who attended all public events and happenings, recorded distributed election material (type and quantity), made notes of activities that could have represented costs, and documented them with photo or video material. These data were, on a weekly basis, presented in reports submitted to coordinators who, through their central coordinators, forwarded them to the Secretariat of the Agency.

When it comes to the local media outlets, both printed and electronic, monitors were obliged to determine whether a certain political entity advertised there and how many types of advertising it had with a media feature.

1.1.3. Purpose and importance of monitoring

Monitoring, to a great extent, encourages the submission of reports by political entities not only to fulfill a mere form and obligation, but rather to ensure there is closer to the real situation. Political entities were not aware of what events monitors recorded, and that was a motivating factor to present their activities in a more regular fashion. Finally, the purpose of the monitoring process was to have a greater portion of the funds used in gradually more expensive campaigns put in legal channels.

1.2. Collection of data from state authorities, banks, legal entities and natural persons

A number of sources of information existed for every mentioned political activity during the election campaign, in that the Agency, while overseeing the reports on election campaign costs, was not only

10 relying on data collected by monitoring. Data were also collected from state authorities (ministries in charge of financial affairs, labor and social policy, the interior, and tax administration), APV authorities, local self-government authorities relevant for financial affairs, Republic Pension and Disability Insurance Fund, Republic Broadcasting Agency, banks, legal entities and natural persons.

1.2.1. Advertising via media outlets

During the election campaign, political entities spent most of their funds for advertising of their representatives and political ideas via media outlets. The scope of advertising can be classified into four categories according to the type of media outlet: TV advertising, radio advertising, internet advertising, and printed media advertising. For each of these types of advertising it was necessary to have different sources of information to be able to do meaningful analysis.

As per national televisions, data about the presence of political entities in advertising were received by the Republic Broadcasting Agency (RBA) and these data were used as a starting point for further searching of data from other entities. Based on the advertising information, requests were sent to media outlets asking them to submit information about agreements, advertising time frames, type of advertisements, and the amount of funds spent by political entities. Besides the advertising information political entities submitted in their reports, it often occurred that different agencies were hired to do this job. They were therefore asked to give the specification of service they provided to political entities for TV advertising.

As for television stations with regional and/or local coverage, the process of collection of data about political entities‟ advertising in their programs went in a different manner. For the majority of these stations, RBA does not have any data about the scope of advertising of political entities. It was therefore the obligation of the monitors engaged by the Agency to observe which political entities advertised themselves on local media outlets during the election campaign. These data served as a basis to send a request to the stations asking them to submit information about the type of a advertisement, scope of advertising, and amount of funds spent by each political entity which advertised there. These data were compared with those provided in the political entities‟ reports on election campaign financing. This way, their validity was confirmed, or discrepancies noted between the realistic situation and what political entities presented in their reports. Radio advertising data of political entities, whether concerning radio with national, regional, or local coverage, were also collected from a number of sources. First, the Agency‟s monitors recorded data concerning political entities that used radio advertising. These data served as the basis for a request to

11 these radio stations asking them to submit information about the type of advertisement, scope of advertising, and amount of funds spent by each political entity for the type of the provided services. The reports of political entities contain data about the types of advertisements, but also about the agencies political entities engaged to do the advertising on their behalf. These agencies were also asked to provide a copy of the agreement signed with parties and with radio stations which provided these types of services, so as to compare all mentioned data in the reports and in this way confirm their validity.

Internet advertising was monitored by the network of monitors, and web pages where political entities‟ advertisements were posted were also determined. Since there were a huge amount of possible advertising places, several dozen web pages were singled out and requests were sent to their addresses asking them to provide information about the type of advertisement, scope, and amount of funds political entities spent on their sites.

Printed media were treated similarly to television, radio stations, and internet, with information about political entities‟ advertising requested. Data received by the monitors served as a framework for further requesting of information from specific media outlet, while data on the agencies hired to the advertisement job on their behalf were presented in the political entities‟ reports. All these information about the same political activity served for data comparison and check of validity of data presented in the political entities‟ reports on political campaign financing.

1.2.2. Advertising by election material

The next significant segment within the activities of political entities concerns their outdoor advertising by the mean of façade advertisements, billboards, trivision billboards (billboards with three pictures), roof boards, neon lamps, boards with supporters, autographicons, information boards at bus stops, billboards and similar tools. The most notable form of this kind of advertising is billboards.

Data about this type of advertising were primarily collected by the network of monitors. The purpose of these data was to collect from all service providers information about the political entities that used their advertising services, and to compare the data with the data presented by political entities in their reports on election campaign costs. 1.2.3. Public event organization

Types of public events were numerous, with the following the most important: mass rallies (outdoor gathering), conventions (indoor gathering), stands (small gatherings organized in streets or village

12 centers)… By their nature, these are the events whose only goal is to inform as many citizens as possible, and they were therefore subject of monitoring, and consequently a very important item in the oversight procedure and analysis of financial reports by political entities.

Data about public events were gathered from a number of different sources. In addition to data about the event itself, the Agency‟s monitors collected information about technical support used for the event, for instance whether there was a stage, sound system, lights, special decoration, organized transportation of participants (buses, registration plates of buses, name of transportation company and so forth).

All those who provided different services to political parties related to their activities were also asked to provide relevant data. Requests for information were sent to transportation companies observed to have transported part followers and members. Information was also requested in accordance with the elements of agreements the mentioned companies had concluded with political entities or with agencies that represented them, regarding the scope of services and funds spent.

2. SUBJECT TO OVERSIGHT

Political entities were required to submit a report on election campaign expenses to the ACA within thirty days following the announcement of election results, on a form specified by the Rulebook on Contribution and Asset Records, Annual Financial Report, and the Report on Election Campaign Expenses of a Political Entity. In the case of a political entity that is a coalition, a coalition agreement determines the coalition member that will submit the report on its behalf. The report is to be submitted in paper and electronic form, and is considered complete when submitted in both forms. Political entities are required to submit the report electronically within thirty days, and on paper eight days following electronic submission. Electronic submission of the report is done by entering the report in the application software of the Agency using a program-generated password. The person submitting the report is given a unique password confirming report registration (i.e. receipt of the report in electronic form). The report in written form should contain this unique password, the date of electronic report submission, date and place of writing the report in paper form, signature of an authorized person, and the seal of the political party or parties forming a particular coalition. The data in electronic and written form must be identical.

Although elections at various levels were held the same day, on May 6, 2012 (except for the elections that went to a second round, on May 20, 2012, and the repeated elections at some polling stations), the deadline for report submission was not equal for all the participants of the electoral process. Namely, the deadline for report submission is linked to the date of the announcement of final election results. In the procedure of overseeing report submission timeliness, the Agency encountered the problem of great inconsistency as to the local level electoral committee practice regarding final election result announcement (publishing election results in official journals before the expiry of the deadline for using legal means in the electoral process, failure to announce final election results).

Elections were not held in nine local self-government units; therefore report submission was not required.

In the majority of cases, political entities failed to comply with the specified deadline; consequently, reports on 2012 election campaign expenses were submitted to the Agency even in 2013. The last report included in this analysis was submitted on 24 April 2013. The delay primarily occurred in the cases of municipality-level reports on election campaign expenses.

Table 2: Overview of submitted and non-submitted reports on election campaign costs of five coalitions and DSS for all election levels

ELECTION LEVEL TOTAL REPORTS SUBMITTED TOTAL REPORTS Elections for President of the Republic of Serbia 12 0

Elections for MPs of the National Assembly of the 17 1 Republic of Serbia Elections for deputies of the Assembly of AP 12 2 Vojvodina Elections for councilors of town assemblies 201 62 Elections for councilors of municipal assemblies 834 515 TOTAL 1,076 580

Political entities were required to submit reports for 1,656 lists of candidates. In total, 1,076 reports were submitted at all levels, accounting for 65% of the total number of reports required. In all, 580 reports were not submitted. The non-submitted reports include thirteen summary reports (a single report for several election campaigns) submitted by political entities.

This number of reports does not encompass the reports on expenses of campaigns for the election of deputies to the Assembly of the APV through the majority voting system. Namely, deputies are elected to the APV Assembly through a mixed electoral system. Sixty deputies are elected through the majority voting system, and sixty through a system of proportional representation. Political entities were required to submit one report for the election of deputies to the Assembly of AP Vojvodina, regarding elections conducted through the proportional representation system, and up to sixty reports for elections conducted through the majority voting system, depending on the number of election units for which political entities presented a candidate. Some political entities indicated the funds for both electoral systems on a single I2 form, which is included in the financial analysis but not in the number of reports.

With the purpose of analysis and oversight, this report includes a sample of six political entities which simultaneously won mandates in the Assembly of the Republic of Serbia: “Choice for a Better Life (Izbor za bolji ţivot) – Boris Tadić” (hereinafter: DS coalition), “United Regions of Serbia - MlaĊan Dinkić” (hereinafter: URS coalition), “Ĉedomir Jovanović – Overturn (Preokret)” (hereinafter: LDP coalition), “Let‟s get Serbia Moving (Pokrenimo Srbiju) – Tomislav Nikolić” (hereinafter: SNS coalition), “Democratic Party of Serbia – Vojislav Koštunica” (hereinafter: DSS), “Ivica Daĉić – Socialist Party of Serbia (SPS), Party of United Pensioners of Serbia (PUPS), and United Serbia (JS)” (hereinafter: SPS coalition). The report comprises these entities‟ lists of candidates for the election of MPs of the National Assembly of the Republic of Serbia, i.e. parliamentary elections, President of the Republic of Serbia, i.e. presidential elections, deputies of the Assembly of the Autonomous Province of Vojvodina, i.e. provincial elections, and councilors of town assemblies.

As regards the elections of MPs, the DS coalition was comprised of: the Democratic Party (DS), the Social Democratic Party of Serbia, the League of Social Democrats of Vojvodina (LSV), the Christian Democratic Party of Serbia, the Green Party of Serbia, and the Democratic Party of Croats in Vojvodina. Coalition structure varied depending on the electoral process. In various combinations, the DS coalition consisted of the following political entities at different electoral levels: the Democratic Party (DS), the Green Party of Serbia, the Liberal Democratic Party (LDP), the Democratic Alliance of Croats in Vojvodina, the Sandţak Democratic Party, the Party for Sandţak, Pulse of Serbia, and the Movement for Uţice.

The SNS coalition for the election of MPs included: the Serbian Progressive Party (SNS), New Serbia (NS), the Power of Serbia Movement – BK, People‟s Peasant Party, Bosniak People‟s Party, Democratic Party of Macedonians, Roma Party, Vlach Unity Movement, Socialist Movement, and the Movement for the Economic Revival of Serbia. The composition of the coalition varied depending on the electoral process. In various combinations, the SNS coalition was formed by the following political entities at different election levels: the Serbian Progressive Party (SNS), New Serbia (NS), Power of Serbia Movement – BK, People‟s Peasant Party, Bosniak People‟s Party, Democratic Party of Macedonians, Roma Party, Vlach Unity Movement, Socialist Movement, Movement for the Economic Revival of Serbia.

The SPS coalition for the election of MPs was formed by: the Socialist Party of Serbia (SPS), Party of United Pensioners of Serbia (PUPS), United Serbia (JS). The composition of the coalition varied depending on the electoral process. In various combinations, the SPS coalition was formed by the following political entities at different election levels: the Socialist Party of Serbia (SPS), Party of United Pensioners of Serbia (PUPS), United Serbia (JS), and the Serbian Radical Party (SRS).

The LDP coalition for MP elections was formed by: the Liberal Democratic Party (LDP), Serbian Renewal Movement (SPO), Social Democratic Union, Rich Serbia, Vojvodina Party, Democratic party of Sandţak, Green Ecological Party – Green, and the Party of Bulgarians of Serbia. In various combinations, the LDP coalition was formed by the following political entities at different election levels: the Liberal Democratic Party (LDP), Serbian Renewal Movement (SPO), Democratic party of Sandţak, Rich Serbia, Vojvodina Party, Social Democratic Union, Green Ecological Party, and the Party of Bulgarians of Serbia. The URS coalition for the election of MPs was formed by: G17 Plus, the Movement “Live for Krajina” (“Ţivim za Krajinu“), “Together for Šumadija” (“Zajedno za Šumadiju“), and the National Party. In different combinations the URS coalition was formed by the following political entities at various levels

16 of elections: G17 Plus, the Movement “Live for Krajina” (“Ţivim za Krajinu“),“Together for Šumadija (“Zajedno za Šumadiju“), the National Party, the Sandţak National Party, the Bunjevci Party, the Democratic Party of Bulgarians, the Vlach Democratic party, the Coalition for Pirot. Apart from the mentioned political entities, the URS list and candidates were endorsed by numerous citizen groups which entered the coalition mainly in elections for local councilors.

The Democratic Party of Serbia (DSS) participated independently in the MP elections. At various election levels, DSS participated either independently or in coalition with different combinations of the following political entities: the Democratic Party of Serbia (DSS), Serbian Radical Party (SRS), Serbian Progressive Party (SNS), New Serbia (NS), Power of Serbia Movement – BK, Socialist Movement, Democratic Party of Macedonians, “Go Banat“ Movement (“Napred Banat“), Serbian Democratic Party, and the United Peasant Party.

Political entities included in this analysis were required to submit 877 reports to the ACA. Of those, 707 reports were submitted, accounting for 80% of the total number, and 170 reports were not submitted, as presented in the following overview:

Table 3: Overview of the submitted and non-submitted reports on election campaign costs for the five coalitions and DSS

POLITICAL ENTITY SUBMITTED REPORTS NOT SUBMITTED REPORTS

SNS coalition 161 0

SPS coalition 126 23

URS coalition 93 52

DS coalition 161 0

LDP coalition 55 66

DSS 111 29

TOTAL 707 170

Annex 1 gives an overview of lists of election candidates by locations for which reports were not submitted by these six political entities.

The number of reports required for submission from these six political entities accounts for 53% of the total number of reports required for submission to the Agency from all political entities. The number of reports submitted by these six political entities accounts for 65% of the total reports submitted by all political entities. Total reported income of these six political entities, compared to the total income of all

17 political entities, accounts for 80.8%, while the share of their reported expenditure in the total expenditure is 83.2%.

3. FINANCIAL INDICATORS

The total reported income of all political entities at all election levels amounted to RSD 3,109,834,700.00, of which income from public funds amounted to RSD 1,916,251,944.00, or 61.6%, while reported expenditure amounted to RSD 3,576,057,932.00.

The data used in the analysis and oversight are contained in the financial reports submitted by the six aforementioned political entities.

3.1. Income

The six aforementioned political entities raised a total income of RSD 2,513,268,443.69. The following table shows the income raised by election levels:

Table 4: Overview of income of the five coalitions and DSS by election type in 2012

POLITICAL PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY TOTAL ENTITY ELECTIONS ELECTIONS ELECTIONS ELECTIONS DS coalition 352,903,.608.66 488,024,753.22 22,749,232.02 147,456,505.45 1,011,134,099.35 SNS coalition 255,811,738.60 304,185,796.43 11,295,266.48 31,685,506.80 602,978,308.31 SPS coalition 41,588,554.00 187,274,227.00 71,960,053.00 29,255,666.35 330,078,500.35 URS coalition 39,000,564.10 239,898,767.48 0.00 25,113,200.37 304,012,531.95 LDP coalition 42,398,554.10 78,692,495.99 1,580,247.62 3,072,229.07 125,743,526.78 DSS 41,100,054.00 72,400,981.71 1,530,602.86 24,289,838.38 139,321,476.95 TOTAL 772,803,073.46 1,370,477,021.83 109,115,401.98 260,872,946.42 2,513,268,443.69

As presented in Table 4, the majority of income was made at parliamentary elections, amounting to RSD 1,370,477,021.83, which accounts for 54.5%, followed by RSD 772,803,073.46, i.e 30.8% at presidential elections, RSD 260,872,946.42, or 10.4% at city assembly elections, and the lowest income was made at provincial elections, in the amount of RSD 109,115,401.98, i.e. 4.4%

Table 5: Overview of income types for the five coalitions and DSS by election type in 2012

TYPE OF INCOME PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY OF POLITICAL ELECTIONS ELECTIONS ELECTIONS ELECTIONS ENTITY RSD % RSD % RSD % RSD % Funds from public 651.585.419.40 84.3 726.168.275.76 53.0 36.660.463.90 33.4 103.198.072.35 39.6 sources Contributions from 5.501.137.00 0.7 107.641.196.00 7.9 54.315.543.50 49.6 66.150.431.69 25.4 natural persons Contributions from 4.650.000.00 0.6 97.877.619.77 7.1 6.516.209.00 5.9 28.033.052.00 10.7 legal entities Own funds 4.566.517.00 0.6 28.267.460.00 2.1 12.124.248.58 11.1 63.491.390.38 24.3 Credits and loans 106.500.000.00 13.8 410.522.470.00 29.9 0.00 0.0 0.00 0.0 TOTAL 772.803.073.46 100.0 1.370.577.021.83 100.0 109.616.464.98 100.0 260.872.946.42 100.0

As presented in Table 5, as per the structure of income, presidential elections were primarily financed from public funds (84.3%);

 As per the structure of income, parliamentary elections were primarily financed from public funds (53.0%), followed by credits and loans (29.9%);  As per the structure of income, provincial elections were primarily financed by contributions from natural persons to political entities (49.6%) and from public funds (33.4%);  As per the structure of income, the elections for town assemblies were primarily financed from public funds (39.6%) and contributions from natural persons to political entities (25.4%).

Table 6: Overview of income types of the DS coalition by election type in 2012

DS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 249,135,601.60 70.6 196,025,753.22 40.2 15,075,313.44 66.3 36,743,508.94 25.0 sources Contributions from 40,000.00 0.1 2,069,000.00 0.4 480,000.00 2.1 39,955,722.90 27.1 natural persons Contributions from 0.00 0.0 28,530,000.00 5.8 0.00 0.0 9,805,280.00 6.6 legal entities Own funds 3,728,007.06 1.0 1,400,000.00 0.3 7,193,918.58 31.6 60,951,993.61 41.3 Credits and loans 100,000,000.00 28.3 260,000,000.00 53.3 0.00 0.0 0.00 0.0 TOTAL 352,903,608.66 100.0 488,024,753.22 100.0 22,749,232.02 100.0 147.456.505.45 100.0

According to the data provided, the DS coalition raised the majority of its income for the presidential elections from public funds, with a significant share of credits, while for the parliamentary elections, income had the highest share of credits and public funds; for the provincial elections the majority of income was raised from public funds, and for the town assembly elections, from its own funds.

Table 7: Overview of income types of the SNS coalition by election type in 2012

SNS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 249,135,601.00 97.4 212,691,910.43 70.0 10,326,922.48 91.4 28,119,356.80 88.8 sources Contributions from 176,137.00 0.1 43,397,886.00 14.2 968,344.00 8.6 3,047,150.00 9.6 natural persons Contributions from 0.00 0.0 0.00 0.0 0.00 0.0 519,000.00 1.6 legal entities Own funds 0.00 0.0 0.00 0.0 0.00 0.0 0.00 0.0 Credits and loans 6,500,000.00 2.5 48,096,000.00 15.8 0.00 0.0 0.00 0.0 TOTAL 255,811,738.60 100.0 304,185,796.43 100.0 11,295,266.48 100.0 31,685,506.80 100.0

The SNS coalition raised the majority of its income for presidential, parliamentary, provincial, and town assembly elections from public funds.

Table 8: Overview of income types of the SPS coalition by election type in 2012

SPS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 38,328,554.00 92.2 132,138,817.00 70.6 7,790,844.00 10.8 17,870,692.63 61.1 sources Contributions from 3,260,000.00 7.8 45,158,410.00 24.1 52,853,000.00 73.4 6,695,904.00 22.9 natural persons Contributions from 0.00 0.0 9,700,000.00 5.2 6,516,209.00 9.1 3,364,160.00 11.5 legal entities Own funds 0.00 0.0 277,000.00 0.1 4,800,000.00 6.7 1,324,909.72 4.5 Credits and loans 0.00 0.0 0.00 0.0 0.00 0.0 0.00 0.0 TOTAL 41,588,554.00 100.0 187,274,227.00 100.0 71,960,053.00 100.0 29,255,666.35 100.0

The SPS coalition raised the majority of its income for presidential, parliamentary, and town assembly elections from public funds, while contributions from natural persons were the largest share for the provincial elections.

Table 9: Overview of income types of the URS coalition by election type in 2012

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 38,328,554.10 98.3 54,363,417.41 22.6 370,733.00 73.7 8,040,311.32 32.0 sources Contributions from 0.00 0.0 1,585,800.00 0.7 0.00 0.0 6,434,030.00 25.7 natural persons Contributions from 650,000.00 1.6 54,932,619.77 22.9 0.00 0.0 9,654,372.00 38.4 legal entities Own funds 22,010.00 0.1 26,590,460.30 11.1 130,330.00 26.3 984,487.05 3.9 Credits and loans 0.00 0.0 102,426,470.00 42.7 0.00 0.0 0.00 0.0 TOTAL 39,000,564.10 100.0 239,898,767.48 100.0 501,063.00 100.0 25,113,200.37 100.0

The URS coalition raised most of its income for the presidential elections from public funds; for the parliamentary elections, the biggest sources of income were credits, and for the provincial and town assembly elections, most income was raised from public funds.

Table 10: Overview of income types of the LDP coalition by election type in 2012

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 38,328,554.10 90.4 62,696,495.99 79.7 1,566,147.62 99.1 2,165,403.17 70.5 sources Contributions from 70,000.00 0.2 11,281,000.00 14.3 14,100.00 0.9 901,825.90 29.3 natural persons Contributions from 4,000,000.00 9.4 4,715,000.00 6.0 0.00 0.0 5,000.00 0.2 legal entities Own funds 0.00 0.0 0.00 0.0 0.00 0.0 0,00 0,0 Credits and loans 0.00 0.0 0.00 0.0 0.00 0.0 0,00 0,0 TOTAL 42,398,554.10 100.0 78,692,495.99 100.0 1,580,247.62 100.0 3,072,229.07 100.0

The LDP coalition raised most of its income for presidential, parliamentary, provincial, and town assembly elections from public funds.

Table 11: Overview of income types of the DSS by election type in 2012

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Funds from public 38,328,554.00 93.3 68,251,881.71 94.3 1,530,503.36 100.0 10,258,799.49 42.3 sources Contributions from 1,955,000.00 4.7 4,149,100.00 5.7 99.50 0.0 9,115,798.89 37.5 natural persons Contributions from 0.00 0.0 0.00 0.0 0.00 0.0 4,685,240.00 19.3 legal entities Own funds 816,500.00 2.0 0.00 0.0 0.00 0.0 230,000.00 0.9 Credits and loans 0.00 0.0 0.00 0.0 0.00 0.0 0.00 0.0 TOTAL 41,100,054.00 100.0 72,400,981.71 100.0 1,530,602.86 100.0 24,289,838.38 100.0

DSS raised most of its income for presidential, parliamentary, provincial, and town assembly elections from public funds.

3.1.1. Contributions from natural persons

A contribution is an amount of money, excluding dues, granted voluntarily to a political entity by a natural or legal person; a gift; or services provided without recompense, or under conditions different than those of the market. Contributions also include credits, loans, and other services provided by banks and other financial organizations in the Republic of Serbia, under conditions different than market conditions, as well as the write-off of debts.

Upon inspection of the reports on election campaign expenses of political entities, it has been observed that natural and legal persons appear as providers of both financial and non-financial contributions. Non- financial contributions included the use of office space, newspaper advertising design, lease of advertising space for billboard advertisements, printing of election material, making of commercial videos, TV advertising, food contributions, organization of stage performances, transportation by private vehicle, and office material.

The Law on the Financing of Political Activities determines the maximum amount of contributions a natural or legal person can make to one or several political entities. The amount for natural persons is 20, and for legal persons 200, average monthly income before taxes and benefits. However, these limits may be doubled during the election year, and amount to 20 and 200 average monthly incomes, respectively, for election campaigns, plus the same amount for regular work.

According to data from the authority competent for statistics in the RS, the average monthly income in 2011 was RSD 37,985.00, meaning that the maximum amount of contributions a natural person could make to a political entity for the 2012 election campaign was RSD 759,703.00, or RSD 7,597,034.00 for legal persons. Upon inspection of the reports on election campaign expenses, it has been determined that none of the political entities indicated a provider (natural or legal person) whose contribution exceeded the maximum amount.

The total number of natural persons who made contributions to political entities in the 2012 election campaign at all election levels is approximately 6,000. The highest single financial and non-financial contributions to political entities are listed in the tables below.

Table 12: Highest financial contributions from natural persons for the five coalitions and DSS by political entity

POLITICAL ENTITY FINANCIAL CONTRIBUTION (RSD) SPS coalition 750,000.00 DSS 749,950.00 URS coalition 719,000.00 LDP coallition 700,000.00 DS coalition 249,000.00 SNS coalition 22,018.00

Table 13: Highest values of non-financial contributions from natural persons for the five coalitions and DSS by political entity

POLITICAL ENTITY NON-FINANCIAL CONTRIBUTION (RSD) SPS coalition 250,000.00 DS coalition 80,000.00 SNS coalition 19,000.00 URS coalition 8,000.00 LDP coalition 0.00 DSS 0.00

3.1.2. Contributions from legal entities

The total number of legal persons that made contributions to political entities in the 2012 election campaign at all election levels is 195. The LDP coalition and the SNS coalition did not disclose non- financial contributions. Of the above number, the highest total single financial and non-financial contributions to political entities are listed below.

Table 14: Highest financial contributions from legal entities for the five coalitions and DSS by political entity

POLITICAL ENTITY FINANCIAL CONTRIBUTION (RSD) DS coalition 7,500,000.00 URS coalition 7,500,000.00 SPS coalition 6,000,000.00 LDP coalition 4,000,000.00 SNS coalition 500,000.00 DSS 165,000.00

Table 15: Highest values of non-financial contributions from legal entities for the five coalitions and DSS by political entity

POLITICAL ENTITY NON-FINANCIAL CONTRIBUTION (RSD) URS coalition 5,519,027.66 DSS 4,300,000.00 SPS coalition 715,200.00 DS coalition 200,000.00 LDP coalition 0.00 SNS coalition 152,000.00

Annex 2 gives an overview of the highest and lowest financial contributions from natural and legal persons by election level. Annex 3 gives an overview of non-financial contributions from natural and legal persons presented by election level, with indications of the type of non-financial contribution.

3.2. Expenditures

Political entities covered by this report presented total expenditure of RSD 2.975.159.141,39 as:

Table 16: Overview of expenditures for five coalitions and DSS by types of 2012 elections

POLITICAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY TOWN TOTAL ENTITY ELECTIONS ELECTIONS ELECTIONS ASSEMBLY ELECTIONS 352,903,608.00 467,910,196.22 46,213,601.96 187,167,688.70 1,054,195,095.54 DS coalition

SNS coalition 255,811,738.60 310,871,304.78 11.302,006.70 31,755,876.99 609,738,015.08 SPS coalition 41,571,682.00 187,245,292.00 71,939,035.00 33,809,238.53 334,656,247.53 URS coalition 47,421,676.10 459,897,389.60 538,595.12 33,537,579.91 541,395,240.73 LDP coalition 51,334,393.54 232,141,901.39 1,576,414.00 3,300,810.12 296,353,519.05 DSS 40,599,708.53 68,111,080.99 1,530,503.36 28,670,640.08 138,912,023.46 TOTAL 797.639.895,44 1.726.177.164,98 133.100.246,64 318,241,834.33 2,975,159.39

Parliamentary elections have the biggest share, 58.0%, in the total amount of the expenditures approximated at RSD 1,726,177,164.98. Next are presidential elections with a share of 26.8%, approximated at RSD 797,639,895.44; city elections, RSD 318,241,834.33 or 10.7%, and provincial elections of RSD 133,100,246.64 or 4.5%.

Table 17: Overview of expenditure categories for five coalitions and DSS by types of 2012 elections

EXPENDURE PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY CATEGORY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 75,283,114.61 9.4 146,602,535.11 8.5 21,190,306.50 15.9 91,894,278.16 28.9 Public Events 19,266,844.48 2.4 72,893,155.56 4.2 5,239,590.00 3.9 21,247,477.19 6.7 Public Advertising 474,687,325.59 59.6 1,474,343,329.55 85.4 71,355,971.54 53.6 137,466,070.16 54.5 Other Election 228,402,610.76 28.6 32,338,144.76 1.9 35,314,378.60 26.6 31,634,008.82 9.9 Materials TOTAL 797,639,895.44 100.0 1,726,177,164.98 100.0 133,100,246.64 100.0 318,241,834.33 100.0

The structure of expenses indicates that the political entities spent most of their funds on advertising, RSD 2,193,852,696.84 (73.7% of total expenditures), followed by election material, RSD 334,970,234.38 (11.3%), and other election campaign expenses consisting of costs for supporting voters‟ signature certification, other travel expenses, overhead and recurring costs, costs of engagement of marketing agencies, equipment and public opinion researchers, RSD 327,689,142.39 (11.0%), and the least funds were spent on public events, RSD 118,647,067.23 (3.9%).

The data submitted by political entities show that the amount of other expenses is considerable, given that certain political entities outsourced marketing of their political campaign to professional agencies, and those expenses were indicated as “other expenses” contrary to their legal obligation.

In the structure of expenditure for parliamentary elections, advertising costs are dominant (85.4%). Advertising costs have the highest share in the expenditure for presidential elections (59.6%) followed by other costs of election campaign (28.6%).Once again, advertising costs have the biggest share in the structure of provincial election expenditure (54.5%) along with the election material expenses (28.9%).

Table 18: Overview of expenditure categories of DS coalition by types of 2012 elections

DS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 41,340,865.49 11.7 29,849,182.93 6.4 7,297,870.08 15.8 41,553,277.50 22.2 Public Events 14,477,588.01 4.1 8,890,534.79 1,9 0.00 0,0 6,704,925.21 3.6 Public Advertising 281,620,021.51 79.8 409,099,689.69 87,4 33,164,610.08 71,8 127,336,296.01 68.0 Other election 15,465,133.65 4.4 20,070,788.81 4,3 5,751,121.80 12,4 11,573,189.98 6.2 Materials TOTAL 352,903,603.66 100.0 467,910,196.22 100.0 46,213,601.96 100.0 187,167,688.70 100.0

Table 19: Overview of expenditure categories of SNS coalition by types of 2012 elections

SNS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 9,002,426.00 3.5 4,327,272.40 1.4 4,040,911.10 35.8 21,239,508.22 66.9 Public Events 0.00 0.0 20,060.00 0.0 0.00 0.0 1,287,702.40 4.0 Public Advertising 38,000,000.00 14.9 305,859,454.24 98.4 420,820.46 3.7 4,369,578.11 13.8 Other Election 208,806,400.61 81.6 664,518.14 0.2 6,840,275.14 60.5 4,859,088.26 15.3 Materials TOTAL 255,811,738.61 100.0 310,871,304.78 100.0 11,302,006.70 100.0 31,755,876.99 100.0

Table 20: Overview of expenditure categories of SPS coalition by types of 2012 elections

SPS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 1,768,472.00 4.3 22,886,967.00 12.2 7,927,695.00 11.0 7,142,139.46 21.1 Public Events 638,080.00 1.5 39,470,667.00 21.1 5,218,290.00 7.3 10,758,428.30 31.8 Public Advertising 38,308,022.00 92.1 122,080,613.00 65.2 36,233,486.00 50.4 12,019,734.12 35.6 Other Election 857,108.00 2.1 2,807,045.00 1.5 22,559,564.00 31.3 3,888,936.65 11.5 Materials TOTAL 41,571,682.00 100.0 187,245,292.00 100.0 71,939,035.00 100.0 33,809,238.53 100.0

Table 21: Overview of expenditure categories of DSS by types of 2012 elections

DSS PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 2,756,339.72 6.8 21.958.077.00 32.2 1.508.083,20 98.5 11.511.985,27 40.2 Public Events 708.700.10 1.8 5.491.567.58 8.1 21.300,00 1.4 1.025.251,00 3.6 Public Advertising 35.941.240.38 88.5 28.626.476.74 56.7 0.00 0.0 11.961.687,15 41.7 Other Election 1.193.428.33 2.9 2.034.959.67 3.0 1.210,66 0.1 4.171.716,66 14.5 Materials TOTAL 40.599.708.53 100.0 68.111.080.99 100.0 1.530.593,86 100.0 28.670.640,08 100.0

Table 22: Overview of expenditure categories of URS coalition by types of 2012 elections

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 13.649.580,57 28.8 28.637.515,84 6.2 338.217,12 62.8 9.368.616,59 27.9 Public Events 0.00 0.0 10.394.991,31 2.3 0.00 0.0 1.209.035,28 3.6 Public Advertising 32.979.329,90 69.5 415.468.401,63 90.3 73.771,00 13.7 17.394.134,77 51.9 Other Election 792.765,63 1.7 5.396.480,82 1.2 126.607,00 23.5 5.565.793,27 16.6 Materials TOTAL 47.421.676,10 100.0 459.897.389,60 100.0 538.595,12 100.0 33.537.579,91 100.0

Table 23: Overview of expenditure categories of LDP coalition by types of 2012 elections

LDP COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Election Materials 6,765,430.83 11.4 38,943,519.94 16.8 77,530.00 4.9 1,078,751.12 32.7 Public Events 3,442,476.37 5.8 8,625,334.88 3.7 0.00 0.0 262,135.00 7.9 Public Advertising 47,838,711.80 80.,6 183,208,694.25 78.9 1,463,284.00 92.8 384,640.00 11.7 Other Election 1,287,774.54 2.2 1,364,352.32 0.6 35,600.00 2.3 1,575,284.00 47.7 Materials TOTAL 59,334,393.54 100.0 232,141,901.39 100.0 1,576,414.00 100.0 3,300,810.12 100.0

This overview shows that advertising costs formed the biggest share in the structure of all expenses of political entities in the election campaign.

DS coalition spent 79.8% of its total expenses on media advertisement in the presidential campaign. Advertising expenses had a share of 87.4% in parliamentary elections, 71.8% in provincial elections, and 68% in city elections advertising expenses. SNS coalition spent 14.9% of its total expenses on media advertisements for presidential elections, 98.4% for parliamentary elections, 3.7% for provincial elections, and 13.8% for city elections. SPS coalition spent 92.1% of its total expenses on media advertisement for presidential elections, 65.2% for parliamentary elections, 50.4% for provincial elections and 35.6% for the city elections. URS coalition spent 69.5% of its total expenses on media advertisement in the presidential campaign.

Advertising expenses had a share of 90.3% in parliamentary elections, 13.7% in provincial elections, and 51.9% in advertising expenses city elections.

LDP Coalition spent 80.6% of its total expenses for presidential elections on advertising expenses, 78.9% for parliamentary, 92.8% for provincial and 11.7% for city elections. DSS spent 88.5% of its total expenses on advertisement of presidential election campaign, 56.7% of total parliamentary election campaign costs, 0% of provincial, and 41.7% of total costs for city election campaign.

3.2.1. Public advertising

For the promotion of their platforms and political ideas through advertising, political entities utilized the media, electronic media (TV, radio, internet) and printed media.

Table 24: Overview of advertising costs categories for five coalitions and DSS by types of 2012 elections

ADVERTISING PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY COSTS ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 392,845,147.90 82.9 1,386,535,352.48 94.2 66,991,138.54 94.5 132,166,098.74 76.6 Printed Media 68,870,257.37 14.5 52,297,553.15 3.6 3,231,505.20 4.6 27,702,941.43 16.1 Advertising Internet Advertising 7,311,333.12 1.6 23,764,296.82 1.6 0.0 0.0 6.182.629.26 3.6 Radio Advertising 4,763,172.62 1.0 8,661,918.15 0.6 690,353.80 0.9 6.356.871.98 3.7 TOTAL 473,789,911.01 100.0 1,471,259,093.60 100.0 70,913,057.54 100.0 172.408.541.41 100.0

Television was dominant among the promotional tools for political program and election platform advertising, on all electoral levels (from 76.6% to 94.5%).

Table 25: Overview of advertising costs categories for DS coalition by types of 2012 elections

DS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 207,116,877.00 73.5 356,172,958.96 87.1 31,788,115.08 95.8 93,692,067.23 73.7 Printed Media 63,817,864.57 22.7 33,310,449.79 8.1 1,250,203.20 3.8 23,333,356.86 18.4 Advertising Internet Advertising 7,311,333.12 2.6 16,273,708.13 4.0 0.00 0.0 5,758,739.26 4.5 Radio Advertising 3,373,946.82 1.2 3,342,572.81 0.8 126,291.80 0.4 4,377,967.56 3.4 TOTAL 281,620,021.51 100.0 409,099,689.69 100.0 33,164,610.08 100.0 127,162,130.91 100.0

Table 26: Overview of advertising costs categories for SNS coalition by types of 2012 elections

SNS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 38,000,000.00 100.0 305,859,454.24 100.0 420,820.46 100.0 2.946.985,90 74.8 Printed Media 0.00 0.0 0.00 0.0 0.00 0.0 915.344,00 23.2 Advertising Internet Advertising 0.00 0.0 0.00 0.0 0.00 0.0 0.00 0.0 Radio Advertising 0.00 0.0 0.00 0.0 0.00 0.0 77.290,00 2.0 TOTAL 38,000,000.00 100.0 305,859,454.24 100.0 420,820.46 100.0 3.939.619,90 100.0

Table 27: Overview of advertising costs categories for SPS coalition by types of 2012 elections

SPS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 38,308,022.00 100.0 113,483,653.00 93.8 33,335,263.00 92.9 10,677,697.00 92.1 Printed Media 0.00 0.0 4,072,416.00 3.4 1,965,018.00 5.5 861,369.00 7.4 Advertising Internet Advertising 0.00 0.0 430,464.00 0.3 0.00 0.0 4,580.00 0.1 Radio Advertising 0.00 0.0 2,964,680.00 2.5 564,062.00 1.6 44,608.00 0.4 TOTAL 38,308,022.00 100.0 120,951,213.00 100.0 35,864,343.00 100.0 11,588,254.00 100.0

Table 28: Overview of advertising costs categories for URS coalition by types of 2012 elections

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 31,616,783.90 95.9 405,480,825.18 97,6 0.00 0.0 13,246,904.00 76,2 Printed Media 0.00 0.0 0.00 0.0 8,805,030.45 2,1 2,300,921.57 13,2 Advertising Internet Advertising 0.00 0.0 0.00 0.0 0.00 0.0 390,320.00 2,2 Radio Advertising 1,362,546.00 4.1 1,182,546.00 0,3 0.00 0.0 1,455,989.20 8,4 TOTAL 32,979,329,90 100.0 415,468,401,63 100.0 0.00 100.0 17,394,134.77 100.0

Table 29: Overview of advertising costs categories for LDP coalition by types of 2012 elections

LDP COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 47,812,032.00 99,9 169,202,546.10 92,4 1,447,000.00 98,9 297,160.00 77,3 Printed Media 0.00 0.0 6,109,656.91 3,3 16,284.00 1,1 87.480.00 22.7 Advertising Internet Advertising 0.00 0.0 6,840,027.69 3,7 0.00 0.0 0.00 0.0 Radio Advertising 26,679.80 0,1 1,029,773.13 0,6 0.00 0.0 0.00 0.0 TOTAL 47,838,711.80 100.0 183,182,003.83 100.0 1,463,284.00 100.0 384,640.00 100.0

Table 30: Overview of advertising costs categories for DSS by types of 2012 elections

DSS PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % TV Advertising 29,991,433.00 85.6 36,335,915.00 99.0 0.00 0.0 11,305,284.61 94.6 Printed Media 0.00 0.0 0.00 0.0 5,052,392.80 14.4 204,470.00 1.7 Advertising Internet Advertising 0.00 0.0 220,070.00 0.6 0.00 0.0 28,990.00 0.1 Radio Advertising 0.00 0.0 142,346.21 0.4 0.00 0.0 401,017.22 3.6 TOTAL 35,043,825.80 100.0 36,698,331.21 100.0 0.00 100.0 11,939,761.83 100.0

3.2.2. Election Material

Election material encompasses billboards, leaflets, brochures, newspapers, posters… Given that billboard advertising represents a dominant expenditure for political entities, it is presented separately in this report. Political entities were obligated to present the number of billboards as well as the costs thereof. The process of monitoring confirmed that there is a significant discrepancy between the number of billboards reported by political entities and the number of billboards spotted in the field, as shown in the following overview: Table 31: Overview of billboards reported, and billboards recorded in the monitoring by Agency for five coalitions and DSS, by political entities

POLITICAL ENTITY PRESENTED IN I2 FORM MONITORING DATA SNS coalition 0 2.570 DS coalition 99 1.745 SPS coalition 272 338 LDP coalition 957 959 URS coalition 62 981 DSS 62 487 TOTAL 0 2,570

Analysis of delivered reports showed that discrepancies between the number of reported and the number of actual billboards are not necessarily followed by discrepancies in reported funds used for this purpose. In some cases reported funds match the invoiced costs issued to political entities by agencies for billboard rental, but at the same time the reported number of billboards did not match the funds reported for this purpose.

Table 32: Overview of election material cost categories for five coalitions and DSS by types of 2012 elections

ELECTION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY MATERIAL COSTS ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 79,095,172.47 75.0 474,303,767.68 90.0 4,757,564.03 8.5 42,641,039.62 40.2 Other Costs of Election Material (leaflets, brochures, 26,371,025.68 25.0 52,261,744.56 10.0 51,400,024.30 91.5 63,509,405.79 59.8 newspapers, posters and other materials) TOTAL 105,466,198.15 100.0 526,565,612.24 100.0 56,157,588.33 100.0 106,150,445.41 100.0

Table 33: Overview of election material cost categories for DS coalition by types of 2012 elections

DS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 33,065,540.13 82.9 19,262,815.63 64,5 2,413,834.03 38,7 12,286,329.63 29.7 Other Costs of 6,841,625.00 17.1 10,586,367.00 35,5 3,829,535.00 61,3 29,090,075.00 70.3 Election Material (leaflets, brochures, newspapers, posters and other materials) TOTAL 39,907,165.13 100.0 29,849,182.63 100 6,243,369.03 100 41,376,404.63 100.0

Table 34: Overview of election material cost categories for SNS coalition by types of 2012 elections

SNS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 7,680,000.00 85.3 0.00 0.0 1,212,630.00 3.0 9,499,988.04 44.7 Other Costs of Election Material (leaflets, brochures, 1,322,426.00 14.7 4,327,272.40 100.0 39,188,281.10 97.0 11,739,520.18 55.3 newspapers, posters and other materials) TOTAL 9,002,426.00 100.0 4,327,272.40 100.0 40,400,911.10 100.0 21,239,508.22 100.0

Table 35: Overview of election material cost categories for SPS coalition by types of 2012 elections

SPS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 1,541,912.00 87.2 13,325,597.00 58.2 1,105,600.00 13.9 135,718.00 1.9 Other Costs of Election Material (leaflets, brochures, 226,560.00 12.8 9,561,370.00 41.8 6,822,095.00 86.1 7,006,421.00 98.1 newspapers, posters and other materials) TOTAL 1,768,472.00 100.0 22,886,967.00 100.0 7,927,695.00 100.0 7,142,139.00 100.0

Table 36: Overview of election material cost categories for URS coalition by types of 2012 elections

URS COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 31,616,783.90 69.8 405,480,825.18 97.4 0.00 0.00 13,246,904.00 67.4 Other Costs of Election Material (leaflets, brochures, 13,649,580.57 30.2 10,871,335.12 2.6 0.00 0.00 6,388,66.38 32.6 newspapers, posters and other materials) TOTAL 45,266,364.47 100.0 416,352,160.30 100.0 0.00 100.0 19,635,570.38 100.0

Table 37: Overview of election material cost categories for LDP coalition by types of 2012 elections

LDP COALITION PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 3,444,774.66 51.0 30,546,818.90 78,4 25,500.00 32,9 0.00 0.00 Other Costs of Election Material (leaflets, brochures, 3,320,656.17 49.0 8,396,701.04 21,6 52,030.00 67,1 1,078,751.12 100.0 newspapers, posters and other materials) TOTAL 6,765,430.83 100.0 38,943,519.94 100.0 77,530.00 100.0 1,078,751.12 100.0

Table 38: Overview of election material cost categories for DSS by types of 2012 elections

DSS PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Billboards 1,746,161.78 63.4 5,687,710.97 40.0 0.00 0.00 7,472,099.95 48.0 Other Costs of Election Material (leaflets, brochures, 1,010,177.94 36.6 8,518,699.00 60.0 1,508,083.20 100.0 8,205,972.11 52.0 newspapers, posters and other materials) TOTAL 2,756,339.72 100.0 14,206,409.97 100.0 1,508,083.20 100.0 15,678,072.06 100.0

3.2.3. Other expenses

Share of other Costs on all electoral levels is significant: 28.6% for presidential, 1.9% for parliamentary, 26.6% for provincial, and 9.9% for town assembly elections. Share of other Costs, viewed by political entities:

 DS Coalition – 4.4% for presidential elections, 4.3% for parliamentary elections, 12.4% for provincial elections, and 6.2% for town assembly elections.

 SNS Coalition – 8.16% for presidential elections, 0.2% for parliamentary elections, 60.5% for provincial elections, and 15.3% for town assembly elections.  SPS Coalition – 2.1% for presidential elections, 1.5% for parliamentary elections, 31.3% for provincial elections, and 11.5% for town assembly elections.  URS Coalition – 1.7% for presidential elections, 1.2% for parliamentary elections, 23.5% for provincial elections, and 16.6% for town assembly elections.  LDP Coalition – 2.2% for presidential elections, 0.6% for parliamentary elections, 2.3% for provincial elections, and 4.7% for town assembly elections  DSS – 2.9% for presidential elections, 3.0% for parliamentary elections, 0.1% for provincial elections, and 14.5% for town assembly elections

A big share of other expenses in the structure of total expenditure of certain political entities is mostly a consequence of the data presentation method. As was already noted, certain political subjects outsourced marketing of their political campaign to advertising agencies, and those costs were presented as „other costs‟, thus making „other costs‟ overvalued, while advertising, election material, and public event costs were undervalued.

3.2.4. Public events

The share of Costs for public events in the total expenditure by electoral levels: presidential 2.4%, parliamentary 4.2%, provincial 3.9%, town assembly 6.7%

Expense ratio of public events in total expenditure listed by political entities: DS Coalition: Presidential 4.1%, parliamentary 1.9%, provincial 0%, town assembly 3.6%; SNS Coalition: presidential 0%, parliamentary 0%, provincial 0%, town assembly 4.0%; SPS Coalition: presidential 1.5%, parliamentary 21.1%, provincial 7.3%, town assembly 31.8%; URS Coalition: presidential 0%; parliamentary 2.3%, provincial 0%, town assembly 3.6%; LDP Coalition: presidential 5.8%, parliamentary 3.7%, provincial 0%, town assembly 7.9%; DSS: presidential 1.8%, parliamentary 8.1%, provincial 1.4%, town assembly 3.6%.

These data imply that, in certain cases, expenses for public events were undervalued in favor of other expenses, especially when political entities entrusted marketing agencies with certain services that were not covered by cost specifications in their reports.

Public event expenditure comprise expenses for mass rallies, conventions, transportation expenses, checkpoints, stands and press conferences. According to data submitted by political entities there were 291 rallies and conventions (DS Coalition 58; SNS Coalition 11; SPS Coalition 122; URS Coalition 35; LDP Coalition 11, and DSS 54).

The expenses for public events were presented collectively (e.g. expenses for a certain number of conventions and rallies, transportation included, were not presented by event categories and types of expenses) although they were obligated to specify expenses according to the election campaign cost form.

Table 41: Overview of public event costs for five coalitions and DSS by types of 2012 elections

ADVERTISING PRESIDENTIAL PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY COSTS ELECTIONS ELECTIONS ELECTIONS ELECTIONS RSD % RSD % RSD % RSD % Rallies and 19,083,752.59 99.1 66,422,589.78 91,2 5,120,656.00 100.0 16,673,718.03 81.0 Conventions Other Public Events (Stands, Press 183,091.88 0.9 6,422,589.78 8,8 0.0 0.0 3,922,309.00 19.0 Conferences etc.) TOTAL 19,266,844.47 100.0 72,845,179.56 100.0 5,120,656.00 100.0 20,596,027.03 100.0

4. COMPARISON OF PRESENTED INCOME AND EXPENDITURES

In the I2 form, six political entities presented total revenues of RSD 2,513,268,443.00 and total expenses of RSD 2,975,159,141.39. These data were not corrected through oversight procedures.

Table 42: Comparative overview of incomes and costs of political entities by types of 2012 elections and DSS by types of 2012 elections

COMPARISON OF PARLIAMENTARY PROVINCIAL TOWN ASSEMBLY TOWN TOTAL INCOMES AND ELECTIONS ELECTIONS ELECTIONS ASSEMBLY COSTS ELECTIONS INCOMES 772,803,073.46 1,370,477,021.83 109,115,401.98 260,872,946.42 2,513,268,443.69 EXPENDITURES 797,639,895.44 1,726,177,164.98 133,100,246.64 318,241,834.33 2,975,159,141.39 DIFFERENCE -24,836,821.98 -355,700,143.00 -23,984,844.66 -57,368,887.91 -461,890,697.70

4.1. Comparative Review of Income and Expenditures

By comparing income and expenditures presented by political entities, it is concluded that expenditures exceeded income by a total of RSD 461,890,698.39 (15%) on all electoral levels, which represents potential debts of political entities. If credits and loans are added to the total debt it is concluded that there is a lack of realistic sources of funding and expenses in the electoral campaign 2012

Table 43: Overview of five coalitions that reported higher expenditures than incomes in 2012 election campaigns

POLITICAL ENTITIES INCOMES EXPENTURES DIFFERENCE

DS coalition 1,011,134,099.35 1.054.195.095,54 -43.060.996,19 SNS coalition 602,978,308.31 609.738.015,08 -6.759.706,77 SPS coalition 330,078,500.35 334.565.247,53 -4.486.747,18 URS coalition 304,012,531.95 541,395,240.73 -237,382,708.78 LDP coalition 125,743,526.78 296,353,519.05 -170,609,992.27

This overview shows that URS Coalition had expenditure higher than income by RSD 239,382,708.78, followed by LDP Coalition with 170,609,992.27, DS Coalition with 43,060,996.19, SNS Coalition with 6,759,706.77, and SPS Coalition with RSD 4,486.747.18. Out of all six political entities analyzed, only DSS Coalition presented higher income than expenditures of RSD 409,453.49. Dues of political entities not paid by submission of the report on costs of their political campaigns, i.e. liabilities for services by natural persons and legal entities, will be covered in the following period. Annex 4 shows the arrears that political entities had on the day they submitted the reports to the Agency.

5. ELECTORAL BOND

Introduction of an electoral bond is an innovation of the Law on Financing Political Activities. A political entity that stated its intent to use public funding to cover expenses of election campaign was obligated to enclose electoral bonds amounting to 20% (for submitters of proclaimed electoral lists), or 50% of the funds (for candidate proponents) allocated to that political entity. Electoral bonds include money, bank guarantees, state securities, or mortgage on real estate of the guarantor amounting to the value of electoral bond.

Electoral bond is returned to the political entity if it collects at least 1% of valid votes, or at least 0.2% of valid voices in case the political entity represents interests of a minority, within 30 days from the day of final results of elections. If political entity does not collect the specified percentage of votes, it is obligated to return the funds for which electoral bond was deposited. If it fails to return funds received covered by electoral bonds, the Republic of Serbia, Autonomous Province, or Local Government will recover proceeds from the Electoral bond guarantees.

Table 44: Overview by kind, amount and type of funds supplied for electoral bonds

POLITICAL PARLIAMENTARY ELECTIONS PRESIDENTIAL ELECTIONS ENTITY TYPE OF AMOUNT OF TYPE TYPE OF AMOUNT OF TYPE OF FUNDS ELECTORAL ELECTORAL OF FUNDS ELECTORAL ELECTORAL BOND BOND BOND BOND Bank 35,000,000.00 Own Assets/ Bank 45,000,000.00 Own Assets/ DS coalition Guarantee Securities Guarantee Securities Dušan Elezović Dušan Elezović SNS Money 9,920,.331.65 Own Assets / / / coalition Bank 9,920,.331.65 Own Bank 38,328,554.10 Own Assets/ SPS coalition Guarantee Assets/Securities Guarantee Securities Univerzal Banka Universal Bank Bank 9,920,.331.65 Own Bank 38,328,554.10 Own URS Guarantee Assets/Securities Guarantee Assets/Securities coalition G17 Plus Moto Plast Bank 9,920,.331.65 Own Assets Bank 38,328,554.10 Own LDP coalition Guarantee /Securities Guarantee Assets/Securities Agroposlovi, Ltd Agroposlovi, Ltd DSS Mortgage on 9,920,331.65 Nenad Popović / / / Real Estate

For city elections, political entities usually submitted cash, as their own assets, for the purpose of electoral bonds. 37

6. RECOMMENDATIONS IN THE COURSE OF OVERSIGHT

Considering that the elections for president, MPs, members of Assembly of APV and members of City Assembly of Belgrade, city assemblies, municipal Assemblies and city municipalities were all held on the 6th of May 2012 – in other words on all electoral levels, the data collection procedure, for analysis and oversight of election campaign costs, required the establishment of cooperation between the Agency and all state authorities, banks, as well as natural persons and legal entities from which the data was collected.

The Law on Financing of Political Activities requires all the state authorities, banks, legal entities and natural persons who finance political entities, or provide them with any service, to deliver all data required by the Agency for its activities defined by this law, and states that all restrictions and limitations enforced by any other regulation regarding data admission are not valid in this case.

The data collection process itself took an unusually long period of time. The Agency first faced the fact that a lot of requests for information on electoral campaigns of political subjects included in the analysis needed to be sent. Afterwards, many responses did not contain complete information, so the Agency had to ask for amendment of these documents, and in some cases they were not submitted to the Agency until after the expiration of the deadline. Lastly, in certain cases, answers were not submitted by the time this report was drawn up, therefore the Agency will proceed according to the Law.

Opening accounts for election campaigns by groups of citizens was also perceived as problematic. For the purpose of collecting funds for financing of election campaigns, every political entity was obliged to open a special account for purposes of financing campaigns and from which all payments regarding the election campaigns were to be made. Political parties (or political parties on behalf of coalitions), as legal entities, opened accounts on behalf of the legal entity, indicating that it was an election account. Groups of citizens which are political entities, as political parties, without being natural persons or legal entities, opened accounts on behalf of a natural person – representative of the group of citizens, without any indications that it was an election account of a group of citizens, i.e., without stating the name of the group of citizens for whose election campaign the account was opened. In that case, banks did not distinguish a private account of natural person from an election account that person opened as a representative of a group of citizens.

When it comes to agreements on the formation of groups of citizens, the fact that in most cases agreements did not indicate a person responsible for financial management represents a unique problem.

Although elections on multiple levels were held on the same day, 6 May May 2012 (excluding elections which had a round 2 of the elections on 20 May 2012, or those repeated in certain polling places), the deadline for report submission wasn‟t unique for all the participants of the election process. Namely, the deadline for report submission was tied to the date of proclamation of final results of the elections. During the oversight of report submission timeliness, the Agency encountered a problem of vast distortion in the practice of local election commissions regarding the proclamation of final results of the election (proclamation of election results in the official Gazette before the deadline for use of legal means in the election process, as well as the omission to proclaim final results of the election).

7. FACTS INDICATING VIOLATIONS OF THE LAW ON FINANCING OF POLITICAL ACTIVITIES AND PHENOMENA OBSERVED DURING INCOME AND EXPENDITURES OVERSIGHT

7.1. Facts indicating violations of the Law observed in income and expenditures oversight

7.1.1. Failure to submit the report on election campaign costs

Political entities participating in an election campaign are obliged to submit to the Agency a report on election campaign costs within 30 days of the day of publication of final election results. The Law stipulates misdemeanor liability of a political entity and a responsible person in a political entity if they fail to submit the report (Article 294). Annex 1 gives an overview of election lists by places for which the reports on election campaign costs were not submitted by 24 April 2013.

Whoever gives and/or provides for and on behalf of the political entity, funds for financing of the political entity [contrary to the provisions of the Law on Financing of Political Activities] may be punished with imprisonment from three months to three years. In case that the given or received funds exceed RSD 1,500,000.00, the Law stipulates a qualified form wherein the offender shall be punished with imprisonment from six months to five years. (Article 385)

7.1.2. Formal irregularities

A certain number of political entities submitted reports on political campaign costs that contained formal irregularities that may be corrected. The irregularities most often observed were: incorrect specification of election name, incorrect specification of the name of political entity, incorrect name, and omission of stamps of coalition when the political entity was a coalition.

4 Article 29 of the Law reads as follows: A political entity participating in election campaign is required to submit to the Agency a report on election campaign costs within 30 days from the date of publication of final election results. The report on election campaign costs contains information on origin, amount and structure of raised and spent funds from public and private sources. The report on election campaign costs is compiled for the period from the date of calling of elections until the date of publishing final election results. The report on election campaign costs is published on the web site of the Agency. The content of the report on election campaign costs is specified by the director of the Agency. 5 Article 38 of the Law on Financing of Political Activities reads as follows: Whoever gives, and/or provides for and on behalf of the political entity, funds for financing of the political entity contrary to the provisions of this Law with intent to conceal the source of financing or amount of collected funds of the political entity, shall be punished with imprisonment from three months to three years. If the offence referred to in paragraph 1 involved giving or receiving more than one million and five hundred thousand dinars, the offender shall be punished with imprisonment from six months to five years. Whoever commits violence or threatens violence, places in disadvantageous position or denies a right or interest based on law to a natural person or legal entity based on giving donation to a political entity, shall be punished by imprisonment of three months to three years. Funds referred in paragraphs 1 and 2 of this article shall be confiscated. 40

The mentioned formal irregularities were observed in the reports on election campaign costs of all political entities encompassed by this analysis.

7.1.3. Failure to present the election campaign income and costs

Submitted reports on election campaign costs contain data about the origin, amount, and structure of funds raised from both public and private sources, and refer to the period from the day of calling of election until the day of announcement of final election results (Article 29).

In certain cases, political entities failed to present in their filed reports income from public sources, contributions by natural persons and legal entities, and their own funds. Likewise, it was observed in the reports of political entities encompassed by this analysis that some election campaign costs were not presented, and the structure of expenditure, thereby, did not cover held public events (meetings and conventions) held. In addition, not all political entities presented their costs: production of video spots, electronic media advertising (primarily TV and radio advertising), election material, and billboard and poster advertising. In some cases not a single election activity and corresponding costs was presented. In some other cases, certain types of costs were reported with significantly lower amounts then the amounts contained in the agreement signed between political entities and legal entity service providers.

Situations where the donors of contributions were mentioned in the report of political entities, but with no corresponding trace of these contributions on the bank accounts for election campaign financing of these political entities were also observed.

The report on election campaign costs for election of MPs of the URS coalition presented the contribution of one natural person in the amount of RSD 719,000.00, but it was not identified on the bank statement.

The report on election campaign costs of the Coalition led by DS for the election of councilors of the town of Poţarevac Assembly presented the contribution of a natural person in the amount of RSD 30,000.00, which was not identified on the bank statement.

There were some cases observed wherein public events were collectively presented, in such a way that instead of costs for every single event, the amount for all of them was presented, and the additional facts

41 were therefore needed so as to determine the exact number of these events and the cost connected to every single event.

For instance, the Coalition led by SPS, in its report for the election of MPs to the National Assembly, collectively presented 13 conventions held in the same number of towns. Only the total cost of RSD 10,829,647.00 was presented. Facts indicating a failure to present income were determined for the coalitions led by DS, SNS, SPS, and URS coalition, and facts indicating a failure to present election campaign costs were determined for the coalitions led by DS, SNS, SPS, LDR, URS coalition, and DSS.

The Coalition led by DS, in its report for the election campaign for councilors of the Assembly of the City of Belgrade, failed to present the income – own funds6 transferred from the account for regular work to the election campaign account in the total amount of RSD 42,964,291.88.

The Coalition led by DS failed to present a non-financial contribution of the marketing agency Communis L.L.C. from Belgrade which was presented as “credit notes” representing the deduction of the invoiced amount as explained by Communis in the total amount of RSD 64,296,552.99, specifically:

 Additional discount for publications in the daily “Veĉernje novosti”;  Additional discount on behalf of the TV campaign “Presidential elections – Choice for a better life – Boris Tadić (second round)” for broadcasting on TV outlets RBS and RTV Pink;  Several amounts invoiced on behalf of the TV campaign “2012 Elections – Choice for a better life” on TV Pink; Deduction in the media campaign “2012 Elections – Choice for a better life”, and the request by DS for approval of a discount on invoices issued for public advertising due to exceeding the planned budget for the election campaign costs, which occurred due to mistakes in the Communis media plan.

The Coalition led by DS did not present in its election campaign costs the number of billboards determined by the ACA monitoring process. However, the amount reported spent for billboards exceeds the price of the billboards recorded during the monitoring (Coalition led by DS reported 99 billboards, 1,745 billboards were observed in the monitoring, while the media agency invoiced DS for 2,665 billboards).

6 The own funds represent private source of financing of political activities and are comprised of: membership fee, contributions, inheritance, legacy, contribution from assets and loans of bank and other financial organization in the Republic of Serbia. 42

The Coalition led by DS, in its report on election campaign costs for councilors of the town of Subotica Assembly, did not present a lease cost and printing cost in the amount of RSD 269,007.00 owed to the marketing agency Craft Marketing LLC from Subotica.

The Coalition led by SNS did not present the contributions by natural persons in reports filed for election of the MPs for the National Assembly in the amount of RSD 7,924,287.00. In addition, the Coalition led by SNS did not present the income transferred from the budgets of the local self-government units to the account for election of MPs and deputies for the AP Vojvodina Assembly, which were not returned to the mentioned local self-government units. These accounts were at the same time used for financing of the campaign for election of MPs and deputies for the AP Vojvodina Assembly (Town of Šabac, Municipality of Zvornik, Municipality of Mali IĊoš, Municipality of Nova Crnja and the City Municipality of Grodska) – a total amount of RSD 171,068.00.

The Coalition led by SNS did not present in its report the transfer of funds executed towards the budget of the Municipality of Ruma in the amount of RSD 88,350.00, nor the legal basis for this transfer of funds. The report I2 for the election of deputies to the AP Vojvodina Assembly does not contain costs paid to Centar za fizičku kulturu (Center for Physical Culture) and the marketing agency Media TI Kula in the total amount of RSD 152,230.00.

The Coalition led by SNS did not present the usage of any billboards, while the Agency‟s monitoring determined that this coalition advertised on 2,570 billboards invoiced by marketing agencies.

The Coalition led by SNS paid to the marketing agency Block&Connect LLC from Belgrade the amount of RSD 1,150,000.00 not presented in the report on election campaign costs, paid from the special- purpose account for the election of MPs.

The Coalition led by SNS presented eight public events in its reports about the election campaign costs, while the Agency‟s monitoring recorded 42 additional public events7 (14 conventions and 28 mass rallies). It was not possible to determine whether a higher number of public events was presented through the funds, since the overall election campaign of the Coalition led by SNS was done by the marketing

7 The reports of the Coalition led by SNS failed to present 14 conventions held in: Zrenjanin, Uţice, Šabac, Kraljevo, Subotica-Palić, Kragujevac, Novi Sad, Poţarevac, Loznica, Vranje, Leskovac, Panĉevo and 28 mass rallies held in Valjevo, Subotica, Aleksinac, Jagodina, Ćuprija, Sremska Mitrovica, Pirot, InĊija, Loznica, Zajeĉar, Zrenjanin, Leskovac, Lebane, Vlasotince, Kula, Prokuplje, Novi Beĉej, Kruševac, Belgrade, Grodska, Niš, Surdulica, Vladiĉin Han, Arilje, Novi Sad, zajeĉar and Kragujevac. 43 agency Block&Connect, and the coalition did not submit the costs specification, but only presented them as a total amount like the other election campaign costs.

The Coalition led by SPS did not present income from the town budget in the amount of RSD 477,868.80 in its report on election campaign costs for the election of councilors for the Town of Leskovac, which is the amount the coalition, in accordance with the town secretariat data, had on the basis of the election results and mandates won in the town Assembly.

The Coalition led by SPS did not present in its report on election campaign costs for the election of councilors for the Town of Subotica Assembly its electoral list advertising services costs on TV Yu Eco in the amount of RSD 1,040,966.00.

During the monitoring process, it was determined that the Coalition led by SPS advertised on 50 billboards more than it presented in the costs of the I2 report.

Public events reported by the Coalition led by LDP were fewer than the number determined by the monitoring. The Coalition led by LDP presented the costs for 10 public events, and the monitoring recorded 318 (25 mass rallies and six conventions). For the presidential and MPs elections, it reported a total of six public events (conventions and mass rallies), for provincial election not a single public event was reported, while the total number of public events at the town level totaled four.

The Coalition led by LDP presented in its report on election costs for the local election in Subotica TV advertising costs at YU Eco from Subotica in a lower amount than the real incurred cost, with a difference totaling RSD 718,620.00.

The Coalition led by LDP did not present advertising costs on Radio 021, Novi Sad, in a single report on election campaign costs.

The URS Coalition did not present costs of production of the video spot “You should also come” broadcast during the election campaign. It is identified from the agreements that G17 Plus concluded on behalf of URS with television stations that the company Smart team LLC from Belgrade was the company that produced the promotional video spot for the URS Coalition. The URS Coalition‟s reports on election

8 The reports of the coalition led by LDP did not present 5 conventiones held in: Kikinda, Šabac, Panĉevo, Belgrade (Cultural Centre “Vuk”) and Sombor and 23 mass rallies held in Sremska Mitrovica, Kruševac, Preševo, Vranje, Banja Koviljaĉa, Loznica, Zajeĉar, Negotin, Leskovac, Prokuplje, Lebane, Stara Pazova, Paraćin, Šabac, Pirot, Bela Palanka, Valjevo, Raţanj, Dimitrovgrad, Aleksinac and Novi Sad. 44 campaign costs do not contain any data about the fact that Smart team LLC played any role in the election campaign of that coalition, and not a single cost related to the production of the mentioned video spot was mentioned.

Videonet LLC from Belgrade produced a video spot for the campaign for the election of councilors for the town of Subotica Assembly for the coalition URS, which was not presented as a cost in the election campaign costs report.

Election material costs: billboards, brochures, posters, and leaflets were not presented in the report on the election campaign for the election of councilors for the City of Belgrade Assembly.

The URS Coalition did not present the costs incurred due to the organization of a convention held in Sports and Business Center in Beoĉin.

The Democratic Party of Serbia (DSS), in its report on election campaign costs for the election of councilors for Town of Uţice Assembly, did not present the costs of the organization of the convention held in the hall of the National Theatre.

DSS did not present in its report on election campaign costs the number of billboards determined by the monitoring (487), but only 62. In accordance with the marketing data, the total amount of RSD 22,991,887.00 was invoiced for 254 billboards and the amount presented in the report of DSS amounted to RSD 25,488,628.52. In relation to the monitoring results, the funds spent for 233 billboards were not presented.

Failure to present the election campaign income and costs in the reports submitted by political entities resulted in discrepancies of financial reports both with transactions observed on the election accounts and with the other documentation used in the oversight procedure, and particularly with the data contained in the reports of election campaign monitors. The established facts indicate violation of the Law, reflected in failure to submit the report on election campaign costs in accordance with Article 29, which represents a misdemeanor of a political entity in accordance with Article 39 of the Law.

The mentioned political entities mainly failed to present costs incurred due to participation of public and entertainment figures in the public event (except for one event presented by the Coalition led by DS and one event presented by the Coalition led by LDP), which were not determined in the monitoring process.

In case there were no costs, the coalitions were obliged to present non-financial contributions in their reports on election campaign costs under the mentioned item.

7.1.4. Unspent funds from the election campaign

A political entity which participated in the election campaign is required to return all funds from public sources which were not spent during the election campaign to the budget of the Republic of Serbia, the autonomous province, or the local self-government unit, by the day of report submission. Likewise, all the funds from private sources which were not spent during the election campaign are to be transferred by the political entity to the account used for its regular activities, also by the day of report submission (Article 30).

Some political parties did not return the funds which were not spent in the election campaign to the budget of the Republic of Serbia, the autonomous province, or the local self-government unit, or did not return unspent funds to the account used for their regular activities. Therefore, these parties acted contrary to Article 30, and committed the misdemeanor specified under Article 39 paragraph 1 clause 15.

On the special purpose account used by the DS coalition for financing the election campaign for the election of deputies to the Assembly of AP Vojvodina, funds in the amount of RSD 2,838.00 remained unspent, and were neither returned to the account for regular work by 20 July 2012, nor returned to the budget of the autonomous province nor to the account for regular work by the date of the submission of the report.

On special purpose accounts used by the LDP coalition for financing the election campaign for the President of the Republic of Serbia, MPs to the National Assembly, deputies to the Assembly of AP Vojvodina, and local-level elections, funds totaling RSD 62,270.11 remained unspent, and were neither returned to the budget of RS, APV, self-government unit, nor to the account for regular work.

7.1.5 Settling the expenses of an election campaign using an account opened for raising funds and paying the expenses of another election campaign

For the purpose of raising funds for election campaign financing, a political entity is required to open a separate account which may not be used for other purposes. All funds intended for financing the election campaign are paid to this account, and all payments of election campaign expenses are made from this account (Article 24).

Certain political entities satisfied the expenses of one election campaign using the account opened for raising funds and paying the expenses of another election campaign. Thus the account for republic-level elections was primarily used for paying the expenses of city-level and other local elections.

The LDP coalition paid the expenses of the election campaign for presidential elections (billboard lease – totaling RSD 3,444,774.66) using a separate account for financing the election campaign for the election of MPs.

It has been determined that the URS coalition used the account opened with the purpose of financing the election campaign for the election of MPs to the National Assembly to make a payment transaction to the Cultural Centre of Poţarevac. This payment was a part of the total expenses of the URS coalition‟s local campaign for the election of councilors in Poţarevac, totaling RSD 28,300.00.

Likewise, it has been determined that the URS coalition used the account opened with the purpose of financing the campaign for the election of MPs to the National Assembly to make a payment transaction to the National Theater in Kikinda, in the amount of RSD 11,800.00, for the activities included in the local campaign for the election of councilors to the Municipal Assembly of Kikinda.

The DS coalition used the account intended for the election of councilors of the City Assembly of Belgrade to satisfy the debts to the marketing agency Komunis, totaling RSD 44,265,428.00 (from July 17 to October 12, 2012). The marketing agency used these funds for both covering the expenses of the DS coalition campaign in Belgrade, and the expenses of other local election campaigns of DS coalitions.

7.1.6 Settling election campaign expenses using an account that was not opened for election campaign financing

Although the Law stipulates that political entities are required to open a separate account for raising funds and paying election campaign expenses, it has been determined that part of the election campaign expenses were settled using an account opened by the political entity for its regular work. This points to a possible misuse of funds, but also to a possible concealment of the flows of money of the political entity during the election campaign.

The funds for financing the regular work of a political entity are used for the functioning and promoting of the political entity's ideas. They include work with voters and members, promotional expenses,

47 advertising material and publications, expenses of public opinion polls, training, international cooperation, staff income and benefits, utilities, and other expenses of this kind (Article 19). Settling election campaign expenses with funds intended for financing the political entity's regular work represents a violation of the law – use of funds contrary to the provisions regulating the use of funds for financing regular work.

The oversight has determined that the URS coalition paid for the services of the Belle Amie television from Niš using the account for its regular work. The amount of the funds paid to this stations was RSD 600,000.00.

7.1.7. Contributions from legal persons that failed to satisfy their dues on the basis of public income

When donating a contribution, the contribution provider conducting an economic activity is required to submit to the political entity a statement or attestation issued by a competent authority, verifying they satisfied all their dues on the basis of public income (Article 9).

The Law stipulates this requirement for the contribution provider in order to prevent the practice of receiving contributions from legal persons that failed to satisfy their dues on the basis of public income. In the case a political entity receives a contribution for which documentation was not provided, it is required to return the contribution to the donor within 15 days upon its receipt; if the funds cannot be returned to the donor‟s account, they should be transferred to the account of the budget of the Republic of Serbia (Article 15).

The DS coalition received contributions from two legal entities that had unsettled dues on the basis of public income at the moment of giving the contribution. One of the legal entities had unsettled dues on the basis of public income in the amount of RSD 6,406,991.10, while the contribution to the political entity totaled RSD 4,000,000.00.

During the campaign, the URS coalition received financial and non-financial contributions from 27 legal entities that had unsettled dues on the basis of public income on the day of donating the contributions. Seven of the legal entities have high debts in proportion to the contribution given.

The SPS coalition received contributions from ten legal entities that had unsettled dues on the basis of public income totaling from RSD 51,671.02 to 1,862,000.00 at the moment of donating the contributions.

The LDP coalition received a contribution from one legal entity that had unsettled dues on the basis of public income totaling RSD 78,190.31 on the day of the payment

Annex 5 contains a list of legal entities that donated contributions to political entities, while having dues on the basis of public income higher than RSD 50,000.00, according to the data from the Tax Administration.

If a legal entity donates a contribution, while failing to submit proof of satisfying the dues on the basis of public income, it points to a possible violation of Article 9 of the Law, and a misdemeanor of the legal entity as the financial contribution donor, and of the authorized person of the legal entity. If, in such a case, the political entity does not return the funds received without the required documentation to the contribution donor or to the account of the budget of the Republic of Serbia, this could mean a violation of the Article 15, and a misdemeanor of the political party and of the authorized person of the political party. In specific cases, if it is determined that the contribution donors had given a statement to the political entity, reporting they had satisfied their dues on the basis of public income, but the ACA ascertained that the dues were not satisfied, the issue of criminal liability for counterfeiting of documents will arise.

7.1.8. Failure to submit data on the request of the Agency

The authorities of the Republic of Serbia, the Autonomous Province of Vojvodina, local self-government units, banks, as well as legal and natural persons financing political entities, or providing a service on their behalf, are required to submit all the data the Agency needs for conducting the activities specified by this Law (Article 32), at the Agency‟s request. In some cases, the Agency did not receive a response by the day of drawing up this report, which represents a misdemeanor of the legal entity and of the authorized person of the legal entity for failing to submit the requested data.

A response to the Agency‟s request for the submission of data was not received from the transportation companies Lasta A.D. Belgrade, Lui Travel Belgrade, and Autosaobraćaj Kragujevac. The requested data was not submitted by City Vision, a billboard renting agency from Kragujevac, nor by the following media: RTV Panonija from Novi Sad, TV Pet from Niš, TV Jefimija from Kruševac, Radio TDI from

Novi Beograd, Radio JAT from Belgrade, Radio Bis from Kragujevac, Radio Baltazar from Niš, Radio Indeks from Belgrade, Radio Sven from Niš, Radio NS from Novi Sad, and Radio 202 from Belgrade.

7.2. Phenomena Indicating Violations of the Law During Income and Expenditure Oversight

7.2.1. Uncovered Liabilities

As presented in Annex 4, many political entities have not yet settled the debts incurred in the process of financing of the election campaign. For the most part this refers to debts incurred in the campaigns for MPs that were not covered by the day of report submission. Debt settlement from accounts for regular work is considered a violation of the article 24, paragraph 3 of the Law. In case the debt is written off, the political entity is obligated to record it as contribution.

7.2.2. Indebtedness

Election campaigns of the Coalition led by DS, Coalition led by SNS, and URS Coalition were financed from bank loans. Coalition led by DS reported an approved loan of RSD 360,000,000.00, covered by securities. Coalition led by SNS reported an approved loan of RSD 54,596,000.00, covered by safe custody accounts amounting to 100% of approved funds. URS Coalition reported two approved loans amounting to RSD 102,426,470.00. These are secured by securities and funds deposited by another legal entity, amounting to the total of the bank loan.

Loan approved to Coalition led by DS as well as one of the loans reported by URS Coalition were loans without currency clause.

In terms of interest rates, all political entities were approved loans under similar conditions, with exception of URS Coalition, which was approved a loan without currency clause with a grace period and an interest rate three times lower than the interest rate for other political entities.

7.2.3. Donors and Donor Income

It is perceived that many natural persons who donated to political entities earned, in the course of 18 months, income that was approximately equal to their contributions. The same applies to legal entities

50 whose turnovers approximated the amounts of contributions donated. Within contributions of natural persons it was perceived that many of the donors were recipients of various welfare services. Certain contributions of these persons amount to 50% or more of yearly welfare received. Total contributions of persons who are welfare recipients amount to an average 14% of total welfare received yearly. This phenomenon creates a suspicion about the validity of contribution donor data submitted in the reports of political entities.

Coalition led by DS reported on three natural persons who donated to the entity and are also recipients of monetary social welfare and family subsistence.

Coalition led by SNS reported on 33 natural persons who donated to the entity who are also recipients of monetary social welfare and family subsistence.

URS Coalition reported on 14 natural persons who donated in amounts larger amount than their reported income for the period of 18 months. Five individuals donated to the URS Coalition campaign amounts approximately equal to their reported income for 2012, before the election announcement.

Dukat, Ltd from Subotica donated to URS Coalition RSD 660,000.00 while operating with a loss in both 2011 and 2012. This company recorded a net loss of RSD 52.379.000,00 in 2011, and a net loss of RSD 75.463.000,00 in 2012. SPM Group, Ltd from Ĉaĉak, which contributed RSD 5.000.000,00 to for URS Coalition, recorded a net profit of RSD 12.000,00 in 2011, but ended 2012 with a recorded net loss of RSD 9.274.000,00.

Coalition led by LDP reported on 32 natural entities who donated contributions out of which 10 persons made contributions larger or approximately equal to their reported income for 2011 and 2012.

From all DSS donors, nine natural persons stand out for having manifold smaller income than donations in this period. There are a few cases with income of mere RSD 20 while contributions made amounted to RSD 260.000,00, and one case where the donor was also a recipient of monetary social welfare and family subsistence.

Another phenomenon perceived is a linear contribution on behalf of natural persons – Coalition led by SNS received contributions of RSD 19.000,00 from over 2.400 natural persons.

7.2.4. Election Campaign Donors Registered After Call for Elections

Legal entities and entrepreneurs that were donors or supporters of the activities of political entities during the campaign, in certain cases, registered shortly before, during or even after the election campaign. A certain number of these were deleted from the register shortly after the elections and submission of political entity financial reports, which also suggests a possibility that third party legal entities, through these legal entities, sidestepped provisions of the law that define limits on amounts for funds contributable by a single legal entity.

Through analysis of data on legal entities that made contributions to, or supported the campaign of, URS Coalition, it was perceived:

An entrepreneur from Valjevo registered a photo agency named “Ortak” on 20 June 2012, ergo after the election campaign ended, and which was removed from the register on 29 January 2013, made an advertising spot for the local campaign of URS Coalition in Valjevo.

A legal entity named Atomic Visual Support, Ltd was registered in Belgrade on 26 March 2012, ergo after the call for the elections, and made contributions of RSD 1.120.000,00 worth of stage equipment.

7.2.5. Local Government Entities As Donors Of Contributions

A political entity reported funds received from the budget of local government entity as a contribution – sponsorship for financing of election campaign, despite the fact there were no legal grounds for this action.

Coalition led by DS was financed by the City Government of Uţice, on two occasions of RSD 200.000,00 – sponsorship for election campaign financing. This represents misuse of funds according to the Budget System Law.

8. NEXT STEPS

Actions of the Agency in the coming period can be grouped in several parts:

 Working on further submission of motions to institute misdemeanor proceedings against all political entities and responsible persons within political entities that haven‟t submitted reports on expenses of political campaigns. By 30 April 2013, teh Agency had submitted 176 motions to the Misdemeanor Court of Belgrade, as the territorialy competent court. Of these, there is one submission of a motion to institute a misdemeanor proceeding against a political party which has not submitted the report on the political campaign carried out during elections for MPs, 59 motions against political entities which have not filed reports on city level, and 116 motions against political entities which have not submitted reports on the municipal level;  Sending requests for statements to political entities concerning facts that imply probable violations of the Law on Financing Political Activities determined in the oversight procedure, imposing warning measures on political entities if the oversight procedure determines any irregularities that cannot be resolved, as well as submissions of motions to institute misdemeanor proceedings in particular cases;  Referring subjects with detected indicators for further action to competent authorities such as Tax Administration, Prosecutor‟s office, State Audit Institution; and  Further overseeing election campaign expenses and annual financial reports of political entities in compliance with the time limit for the statute of limitation set for the instigation of misdemeanor proceedings in accordance with the Law on Financing of Political Activities, which stipulates that a misdemeanor proceedings may not be instigated five years after the day of the commission of the misdemeanor.

ANNEX 1 OVERVIEW OF LISTS OF CANDIDATES BY LOCALES FOR WHICH THE REPORTS WERE NOT SUBMITTED BY 24 APRIL 2013

ANNEX 2 OVERVIEW OF THE HIGHEST AND LOWEST DONATIONS MADE BY NATURAL PERSONS AND LEGAL ENTITIES LISTED BY ELECTORAL LEVELS

ANNEX 3 OVERVIEW OF NON-FINANCIAL CONTRIBUTIONS MADE BY NATURAL AND LEGAL PERSONS, LISTED BY ELECTORAL LEVEL, WITH AN INDICATION OF NON-FINANCIAL CONTRIBUTION TYPE

ANNEX 4 REVIEW OF POLITICAL ENTITIES DUES NOT SATISFIED BY THE DAY OF FILING OF THE AGENCY’S REPORT

ANNEX 5 LIST OF LEGAL ENTITIES WITH DEBTS NOT SETTLED ON THE DAY OF REPORT SUBMISSION

ANNEX 1: Overview of Lists of Candidates by Locales for which the Reports were not Submitted by 24 April 2013

LDP coalition No SPS COALITION No LDP COALITION No (continued) 1 Aleksinac 1 Aleksandrovac 42 Novi Kneževac 2 Batičina 2 Aleksinac 43 Osečina 3 Belgrade-Surčin 3 Alibunar 44 Paraćin 4 Vladimirci 4 Apatin 45 Plandište 5 Vranjska Banja 5 Arilje 46 Pirot 6 Doljevac 6 Bogatić 47 Preševo 7 Žitorađa 7 Boljevac 48 Prijepolje 8 Ivanjica 8 Bela Palanka 49 Prokuplje 9 Knić 9 Babušnica 50 Rača 10 Kučevo 10 Bač 51 Raška 11 Ljug 11 Bačka Palanka 52 Sokobanja 12 Lučani 12 Bačka Topola 53 Svilajinac 13 Merošina 13 Belgrade-Savski Venac 54 Svrljig 14 Niš-Crveni Krst 14 Belgrade-Sopot 55 Topola 15 Niš-Medijana 15 Belgrade-Stari Grad 56 Trstenik 16 Niš-Niška Banja 16 Belgrade-Surčin 57 Čoka 17 Niš-Palilula 17 Belgrade-Zvezdara 58 Belgrade-Barajevo 18 Niš-Pantelej 18 Belgrade-Barajevo 59 Valjevo 19 Nova Crnja 19 Belgrade-Lazarevac 60 Šabac 20 Opovo 20 Vladimirci 61 Batočina 21 Osećina 21 Vranjska Banja 62 Kučevo 22 Rača 22 Varvarin 63 Lajkovac 23 Sokobanja 23 Golubac 64 Čajetina 24 Gornji Milanovac 65 Ćuprija 25 Kladovo 66 Kanjiža 26 Knjaževac 27 Krupanj 28 Kuršumlija 29 Lapovo 30 Lebane 31 Ljig 32 Ljubovija 33 Merošina 34 Mionica 35 Niš-Crveni Krst 36 Niš-Medijana 37 Niš-Niška Banja 38 Niš-Palilula URS COALITION SERBIAN DEMOCRATIC No URS COALITION No No (continued) PARTY 1 Aleksandrovac 42 Svilajinac 1 Bela Crkva 2 Aleksinac 43 Valjevo 2 Bela Palanka 3 Ada 44 Smederevo 3 Belgrade-Mladenovac 4 Alibunar 45 Pokrajinski izbori 4 Belgrade-Obrenovac 5 Beočin 46 Boljevac 5 Belgrade-Vračar 6 Blace 47 Rača 6 Bogatić 7 Bogatić 48 Kragujevac 7 Bojnik 8 Bela Crkva 49 Novi Pazar 8 Bosilegrad 9 Beograd-Savski Venac 50 Topola 9 Ivanjica 10 Belgrade-Sopot 51 Tutin 10 Kladovo 11 Belgrade-Surčin 52 Knić 11 Lebane 12 Belgrade-Vračar 12 Majdanpek 13 Belgrade-Zvezdara 13 Mali Iđoš 14 Beograd-Barajevo 14 Merošina 15 Belgrade-Čukarica 15 Mionica 16 Belgrade-Lazarevac 16 Miš-Crveni Krst 17 Belgrade-Mladenovac 17 Niš-Mediana 18 Belgrade-Novi Beograd 18 Niš-Palilula 19 Belgrade-Obrenovac 19 Niš-Pantelej 20 Vranjska Banja 20 Plandište 21 Velika Plana 21 Rača 22 Vladičin Han 22 Rekovac 23 Despotovac 23 Šid 24 Doljevac 24 Sokobanja 25 Knić 25 Svrljig 26 Knjaževac 26 Titel 27 Kuršumlija 27 Trstenik 28 Lapovo 28 Žitorađa 29 Malo Crniće 29 Vranjska Banja 30 Medveđa 31 Niš-Mediana 32 Miš-Crveni Krst 33 Niš-Niška Banja 34 Niš-Palilula 35 Niš-Pantelej 36 Pirot 37 Petrovac na Mlavi

Annex 1, p 2 ANNEX 2: Overview of the Highest and Lowest Donations made by Natural Persons and Legal Entities, listed by Electoral Levels

SERBIAN PRESIDENTIAL ELECTIONS

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition / / / / / / 2 SNS Coalition 17 4,000.00 19,000.00 / / / 3 SPS Coalition 9 55,000.00 600,000.00 / / / SPM Group "Saša" Bakery 4 URS Coalition / / / 2 200.000,00 450.000,00 5 LDP Coalition 1 70,000.00 1 Out Sourcing 4.000.000,00 6 Democratic Party of Serbia 36 10,000.00 200,000.00 / / /

ELECTIONS FOR MPs TO THE NATIONAL ASSEMBLY OF RS

Goran Avramović Alpha Sorb Ploughland 1 DS Coalition 22 5,000.00 400,000.00 6 Lawyer Uljarica 30.000,00 3x7.500.000,00 2 SNS Coalition 2275 4,000.00 38,000.00 / / / Adriatic Region Infront Media 3 SPS Coalition 104 1,000.00 750,000.00 4 Distribution 750.000,00 6.000.000,00

Nova Sicilijana Euro guma bbs 4 URS Coalition 3 166,800.00 719,000.00 12 300.000 7.500.000,00

Out Sourcing PQN 5 LDP Coalition 24 3,000.00 715,000.00 3 Management Solutiones 715.000,00 3.000.000,00

6 Democratic Party of Serbia 51 20,000.00 749,950.00 / / /

ELECTIONS FOR MEMBERS OF THE ASSEMBLY OF AP VOJVODINA Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 18 16,000.00 30,000.00 / / / 2 SNS Coalition 57 1,200.00 19,000.00 / / / Gastro Ltd Granis Ltd 3 SPS Coalition 104 10,000.00 700,000.00 2 300.000,00 4.500.000,00 4 URS Coalition / / / / / / 5 LDP Coalition 2 4,100.00 10,000.00 / / / 6 Democratic Party of Serbia 1 90.00 / / /

Annex 2 - p1 of 6 BELGRADE

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Dan Studio Monarh Ltd 1 DS Coalition 83 10,000.00 440,000.00 3 100.000,00 650.000,00 RK Šangaj Komerc Ltd 2 SNS Coalition 79 3,000.00 19,000.00 1 19.000,00 3 SPS Coalition 7 431,980.00 600,000.00 / / / Profil STB Ferrum Trade 4 URS Coalition 14 50,000.00 331,000.00 3 750.000,00 2.000.000,00 5 LDP Coalition / / / / / / Hydro Gea Ltd 6 Democratic Party of Serbia 36 20,000.00 223,000.00 1 100.000,00

VRANJE

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 27 10,000.00 50,000.00 / / / 2 SNS Coalition / / / / / / 3 SPS Coalition 29 5,000.00 66,500.00 / / / Budamit 4 URS Coalition / / / 1 50.000,00 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia 6 15,000.00 105,000.00 / / /

ZRENJANIN

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 70 3,500.00 1,000,000.00 / / / 2 SNS Coalition / / / / / / Kemel Ltd 3 SPS Coalition 2 7,000.00 93,000.00 1 170.000,00 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia / / / / / /

KRALJEVO

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Boćο ICCS 1 DS Coalition 13 14,000.00 100,000.00 1 220.000,00 2 SNS Coalition 7 19,000.00 / / / EKO FARM PUPS 3 SPS Coalition 10 15,000.00 28,000.00 2 50.000,00 180.000,00 4 URS Coalition 12 5,000.00 50,000.00 / / / 5 LDP Coalition 1 43,761.75 / / / 6 Democratic Party of Serbia 4 5,000.00 20,000.00 / / /

KRUŠEVAC

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 10 30,000.00 / / / 2 SNS Coalition 10 19,000.00 / / / 3 SPS Coalition 3 11,500.00 92,100.00 / / / 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia 6 300.00 95,000.00 / / /

Annex 2 - p2 of 6 VALJEVO

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 15 25,000.00 / / / 2 SNS Coalition / / / / / / 3 SPS Coalition 6 25,000.00 50,000.00 / / / 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia 7 2,000.00 27,000.00 / / /

ZAJEČAR

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 23 1,000.00 25,500.00 / / / 2 SNS Coalition 5 9,000.00 19,000.00 / / / 3 SPS Coalition / / / / / / SPM Ltd 4 URS Coalition 3 1 100,000.00 1.000.000,00 5 LDP Coalition 1 90,000.00 / / / 6 Democratic Party of Serbia 1 71,000.00 / / /

JAGODINA

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Rollo teh Ltd 1 DS Coalition 7 15,000.00 50,000.00 1 20.000,00 2 SNS Coalition / / / / / / 3 SPS Coalition / / / / / / 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia 2 20,000.00 72,500.00 / / /

KRAGUJEVAC

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Studio Ilusion 1 DS Coalition 2 1 220,000.00 200.000,00 2 SNS Coalition 26 14,000.00 18,000.00 / / / 3 SPS Coalition / / / / / / 4 URS Coalition 2 50,000.00 60,000.00 / / / 5 LDP Coalition 1 52,701.60 / / / 6 Democratic Party of Serbia 1 25,000.00 / / /

LESKOVAC

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 38 10,000.00 100,000.00 / / / 2 SNS Coalition 13 1,000.00 19,000.00 / / / 3 SPS Coalition 1 100,000.00 / / / 4 URS Coalition 4 50,000.00 100,000.00 / / / 5 LDP Coalition 1 97,830.00 / / / Ingkom Hermes broker Ltd 6 Democratic Party of Serbia 4 4,000.00 185,000.00 3 7.000,00 165.000,00

Annex 2 - p3 of 6 LOZNICA

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 3 40,000.00 110,000.00 / / / 2 SNS Coalition / / / / / / 3 SPS Coalition 1 88,500.00 / / / 4 URS Coalition / / / / / / 5 LDP Coalition 2 38,492.00 38,500.00 / / / 6 Democratic Party of Serbia 2 60,162.00 10,000.00 / / /

NIŠ

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 46 15,000.00 250,000.00 / / / 2 SNS Coalition / / / / / / "Znak" Ltd 3 SPS Coalition 1 1 2,030.00 1.000.000,00 4 URS Coalition / / / / / / 5 LDP Coalition 1 100,000.00 / / / 6 Democratic Party of Serbia 18 20,000.00 169,916.00 / / /

NOVI SAD

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 191 7,800.00 230,000.00 / / / 2 SNS Coalition / / / / / / 3 SPS Coalition 1 278,250.00 / / / Soko Sistem Ltd 4 URS Coalition 62 10,000.00 120,000.00 1 800.000,00 5 LDP Coalition / / / / / / MX Soft Ltd 6 Democratic Party of Serbia 13 25,000.00 595,000.00 1 22.140,00

POŽAREVAC

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 33 11,000.00 100,000.00 / / / 2 SNS Coalition / / / / / / PUPS 3 SPS Coalition 38 500.00 25,000.00 1 21.000,00 4 URS Coalition / / / / / / Panorama Promet 5 LDP Coalition / / / 1 5.000,00 6 Democratic Party of Serbia 2 30,000.00 / / /

SREMSKA MITROVICA

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 4 10,000.00 495,000.00 / / / Lider Pro Ltd 2 SNS Coalition 1 1 2,000.00 500.000,00 3 SPS Coalition 6 22,000.00 25,000.00 / / / 4 URS Coalition / / / / / / 5 LDP Coalition 2 13,130.00 18,500.00 / / / 6 Democratic Party of Serbia 3 20,000.00 / / /

Annex 2 - p4 of 6 NOVI PAZAR

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) "Eurp Spid", Ltd 1 DS Coalition 13 39,000.00 53,000.00 1 50.000,00 2 SNS Coalition / / / / / / 3 SPS Coalition / / / / / / 4 URS Coalition 28 2,000.00 11,400.00 / / / 5 LDP Coalition 2 64,442.00 100,000.00 / / / 6 Democratic Party of Serbia / / / / / /

PANČEVO

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Branislav Kundaković, Lawyer 1 DS Coalition 26 20,000.00 55,000.00 1 50.000,00 2 SNS Coalition 7 500.00 19,000.00 / / / 3 SPS Coalition 3 20,000.00 / / / 4 URS Coalition 1 183,000.00 / / / 5 LDP Coalition 2 45,000.00 106,625.38 / / / 6 Democratic Party of Serbia 5 2,500.00 25,000.00 / / /

SOMBOR

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 10 25,000.00 150,000.00 / / / 2 SNS Coalition 2 19,000.00 / / / 3 SPS Coalition / / / / / / 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia 12 5,000.00 60,000.00 / / /

SUBOTICA

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Metropolit, Ltd Intelcom, Ltd 1 DS Coalition 10 27,000.00 185,000.00 3 400.000,00 5.000.000,00 2 SNS Coalition / / / / / / Pro Forum Razvoj Janjić 3 SPS Coalition 5 25,000.00 30,000.00 2 70.000,00 100.000,00 Metala Dukat, Ltd 4 URS Coalition 1 2 123,531.00 650.000,00 660.000,00 5 LDP Coalition 1 20,781.50 / / / 6 Democratic Party of Serbia 6 30,000.00 350,000.00 / / /

Annex 2 - p5 of 6 SMEDEREVO

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) EUROM Constructions 1 DS Coalition 11 50,000.00 200,000.00 1 50.000,00 2 SNS Coalition / / / / / / Klas Bakery Immobilies 3 SPS Coalition 4 5 15,000.00 10.000,00 267.000,00 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / 6 Democratic Party of Serbia / / / / / /

UŽICE

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 16 5,000.00 30,000.00 / / / 2 SNS Coalition 6 14,500.00 19,000.00 / / / Carbo Plus, Ltd 3 SPS Coalition 43 500.00 5,000.00 1 30.000,00 4 URS Coalition / / / / / / 5 LDP Coalition 1 36,000.00 / / / Snežana Jovanović Agency 6 Democratic Party of Serbia 6 10,000.00 74,000.00 1 10.000,00

ČAČAK

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) Atol, Ltd 1 DS Coalition 22 3,000.00 101,000.00 1 10.000,00 2 SNS Coalition 3 3,500.00 14,000.00 / / / Auto Garant, Ltd Terratin, Ltd 3 SPS Coalition / / / 7 10.000,00 30.000,00 4 URS Coalition 3 50,000.00 100,000.00 / / / 5 LDP Coalition 2 5,000.00 31,061.67 / / / 6 Democratic Party of Serbia 24 21,700.00 33,000.00 / / /

ŠABAC

Contributions Smallest Largest Contribution Smallest Contribution Largest Contribution No Political entity Natural Person Contribution Contribution Legal Person Measured in Dinars Measured in Dinars (No) Measured in Dinars Measured in Dinars (No) 1 DS Coalition 23 50,000.00 200,000.00 / / / 2 SNS Coalition 16 7,000.00 19,000.00 / / / 3 SPS Coalition 2 92,500.00 118,500.00 / / / 4 URS Coalition / / / / / / 5 LDP Coalition / / / / / / Euro Sanel, Ltd 6 Democratic Party of Serbia 2 60,000.00 75,000.00 1 31.100,00

Annex 2 - p6 of 6 ANNEX 3: OVERVIEW OF NON-FINANCIAL CONTRIBUTIONS MADE BY NATURAL AND LEGAL PERSONS, LISTED BY ELECTORAL LEVEL, WITH AN INDICATION OF NON-FINANCIAL CONTRIBUTION TYPE

POLITICAL ELECTORAL NATURAL NAME OF VALUE OF TYPE ENTITY LEVEL PERSON / NON- NON- LEGAL FINANCIAL FINANCIAL PERSON CONTRIBUTIO CONTRIBUTIO N PROVIDER N IN DINARS Election of MPs to printing of G17 Plus / 1 the NATIONAL Legal person Grafika Galeb 5,519,027.66 election URS ASSEMBLY OF RS material Election of MPs to printing of G17 Plus / 2 the NATIONAL Legal person Sitoprint 1,681,592.11 election URS ASSEMBLY OF RS material Election of MPs to printing of G17 Plus / 3 the NATIONAL Legal person Medigraf 750,000.00 election URS ASSEMBLY OF RS material public Election of MPs to event – G17 Plus / Ministry of 4 the NATIONAL Legal person 4,320,000.00 technical URS Sound ASSEMBLY OF RS preparatio n public Election of MPs to event – G17 Plus / Atomic Visual 5 the NATIONAL Legal person 1,120,000.00 technical URS Support ASSEMBLY OF RS preparatio n Election of MPs to SNS Dragana 6 the NATIONAL Natural person 19,000.00 n/a Coalition Simić ASSEMBLY OF RS Election of MPs to SNS 7 the NATIONAL Natural person Dragan Perić 19,000.00 n/a Coalition ASSEMBLY OF RS Election of MPs to SNS 8 the NATIONAL Natural person Milica Rakinić 19,000.00 n/a Coalition ASSEMBLY OF RS Election of MPs to SNS 9 the NATIONAL Natural person Goran Jevtić 19,000.00 n/a Coalition ASSEMBLY OF RS Election of MPs to SNS 10 the NATIONAL Natural person Milan Kukulj 19,000.00 n/a Coalition ASSEMBLY OF RS Election of MPs to SNS Čarna 11 the NATIONAL Natural person 19,000.00 n/a Coalition Petričević ASSEMBLY OF RS Election of MPs to SNS Nedeljko 12 the NATIONAL Natural person 19,000.00 n/a Coalition Ljuboja ASSEMBLY OF RS Election of MPs to SNS Mirjana 13 the NATIONAL Natural person 19,000.00 n/a Coalition Marinković ASSEMBLY OF RS Election of MPs to stage DS Goran 14 the NATIONAL Natural person 80,000.00 performan Coalitiion Bregegović ASSEMBLY OF RS ce stage DS PRESIDENTIAL Goran 15 Natural person 40,000.00 performan Coalitiion ELECTION OF RS Bregegović ce Election of MPs to lease of SPS Dragan 16 the ASSEMBLY of Natural person 10,000.00 advertising Coalitiion Višekruna AP VOJVODINA space Election of MPs to lease of SPS “Trgovina 17 the ASSEMBLY of Legal person 50,000.00 advertising Coalitiion Vučkov” Ltd. AP VOJVODINA space Election of MPs to SPS “YES MUSIC” advertising 18 the ASSEMBLY of Legal person 715,200.00 Coalitiion Ltd. - TV AP VOJVODINA POLITICAL ELECTORAL NATURAL NAME OF VALUE OF TYPE ENTITY LEVEL PERSON / NON- NON- LEGAL FINANCIAL FINANCIAL PERSON CONTRIBUTIO CONTRIBUTIO N PROVIDER N IN DINARS Election of MPs to printing of SPS “SUCCESSUS” 19 the ASSEMBLY of Legal person 662,881.52 election Coalitiion Ltd. AP VOJVODINA material Election of MPs to printing of SPS “POPLIPLAN 1 20 the ASSEMBLY of Legal person 76,617.87 election Coalitiion TO 1” Ltd. AP VOJVODINA material Election of MPs to lease of SPS “POPLIPLAN 1 21 the ASSEMBLY of Legal person 100,000.00 advertising Coalitiion TO 1” Ltd. AP VOJVODINA space Election of MPs to SPS “POPLIPLAN 1 advertising 22 the ASSEMBLY of Legal person 111,510.00 Coalitiion TO 1” Ltd. - TV AP VOJVODINA lease of DS 23 BELGRADE Legal person GR&RN Ltd. 80,280.00 advertising Coalitiion space advertising 24 DSS BELGRADE Legal person Pro Vision 4,300,000.00 - TV transportat Milenko ion by 25 DSS VALJEVO Natural person 9,000.00 Dragojević private vehicle transportat ion by 26 DSS VALJEVO Natural person Goran Lučić 3,000.00 private vehicle transportat Zlatomir ion by 27 DSS VALJEVO Natural person 2,000.00 Lukić private vehicle transportat Dragan ion by 28 DSS VALJEVO Natural person 2,000.00 Branković private vehicle transportat Aleksandar ion by 29 DSS VALJEVO Natural person 4,000.00 Ćebić private vehicle transportat ion by 30 DSS VALJEVO Natural person Zoran Matić 5,000.00 private vehicle transportat Milomir ion by 31 DSS VALJEVO Natural person 3,000.00 Kaljević private vehicle transportat Branko ion by 32 DSS VALJEVO Natural person 3,000.00 Popović private vehicle transportat Milan ion by 33 DSS VALJEVO Natural person 3,000.00 Mihailović private vehicle lease of SPS 34 ZRENJANIN Natural person Geza Kereši 20,000.00 advertising Coalitiion space - SPS lease of 35 ZRENJANIN Legal person BAMAKO Ltd. 23,600.00 Coalitiion space G17 Plus / lease of 36 KRAGUJEVAC Natural person Saša Vučković 13,000.00 URS space

Annex 1, p 2 POLITICAL ELECTORAL NATURAL NAME OF VALUE OF TYPE ENTITY LEVEL PERSON / NON- NON- LEGAL FINANCIAL FINANCIAL PERSON CONTRIBUTIO CONTRIBUTIO N PROVIDER N IN DINARS G17 Plus / Dejan lease of 37 KRAGUJEVAC Natural person 12,000.00 URS Dimitrijević space G17 Plus / Dejan lease of 38 KRAGUJEVAC Natural person 11,000.00 URS Vukajlović space G17 Plus / Ljubisav lease of 39 KRAGUJEVAC Natural person 8,000.00 URS Lešnjak space G17 Plus / Miljan lease of 40 KRAGUJEVAC Natural person 8,000.00 URS Isailović space G17 Plus / Života lease of 41 KRAGUJEVAC Natural person 7,000.00 URS Ilinković space G17 Plus / Miodrag lease of 42 KRAGUJEVAC Natural person 15,000.00 URS Adamović space G17 Plus / Nenad lease of 43 KRAGUJEVAC Natural person 9,000.00 URS Đoković space G17 Plus / Milan lease of 44 KRAGUJEVAC Natural person 10,000.00 URS Vlatković space G17 Plus / Miodrag lease of 45 KRAGUJEVAC Natural person 10,000.00 URS Srećković space newspaper G17 Plus / 46 KRAGUJEVAC Natural person Goran Dimić 200,000.00 advertising URS design lease of G17 Plus / Milan 47 KRAGUJEVAC Natural person 20,000.00 advertising URS Marković space G17 Plus / Eurokrem - 48 KRAGUJEVAC Legal person 70,000.00 advertising URS Agency lease of G17 Plus / “Zastava stan 49 KRAGUJEVAC Legal person 100,000.00 advertising URS servis” Ltd. space G17 Plus / 50 KRAGUJEVAC Legal person City Vision 65,000.00 advertising URS Akademac printing of G17 Plus / 51 KRAGUJEVAC Legal person marketing 98,130.82 election URS agency material Akademac lease of G17 Plus / 52 KRAGUJEVAC Legal person marketing 190,686.03 advertising URS agency space Radio Stari G17 Plus / Grad, Media radio 53 KRAGUJEVAC Legal person 270,125.00 URS Group Ltd. advertising Kragujevac G17 Plus / Credendo commercia 54 KRAGUJEVAC Legal person 500,000.00 URS Vides l video HTD use of G17 Plus / 55 KRAGUJEVAC Legal person “Šumarice”, 100,000.00 office URS Kragujevac space printing of DS Dušan 56 KRAGUJEVAC Natural person 30,000.00 election Coalitiion Obradović material stage DS Bratislav 57 KRAGUJEVAC Natural person 30,000.00 performan Coalitiion Vučković ce DS commercia 58 KRAGUJEVAC Legal person Studio Illusion 200,000.00 Coalitiion l video

Annex 1, p 3 POLITICAL ELECTORAL NATURAL NAME OF VALUE OF TYPE ENTITY LEVEL PERSON / NON- NON- LEGAL FINANCIAL FINANCIAL PERSON CONTRIBUTIO CONTRIBUTIO N PROVIDER N IN DINARS Slađana office 59 DSS KRAGUJEVAC Natural person 1,000.00 Radisavljević material SPS STB EURO 60 KRALJEVO Legal person 12,000.00 n/a Coalitiion AUTO DS 61 NOVI PAZAR Natural person Fuad Ljajić 220,000.00 n/a Coalitiion election SPS 62 NOVI SAD Natural person Zoran Andrić 250,000.00 material – Coalitiion other SPS Ramiz 63 NOVI SAD Natural person 84,500.00 food Coalitiion Mehmedović election SPS Đorđe 64 NOVI SAD Natural person 200,000.00 material – Coalitiion Petrović other

65 DSS NOVI SAD Legal person Mix Soft Ltd. 22,140.00 n/a

printing of G17 Plus / SREMSKA Todor 66 Natural person 135,300.00 election URS MITROVICA Kutmanović material printing of G17 Plus / SREMSKA Boško 67 Natural person 90,720.00 election URS MITROVICA Laćarac material

Annex 1, p 4 ANNEX 4:Review of Political Entities Dues not Satisfied by the Day of Filing of the Agency’s Report

COALITION LED BY DS

LIST OF DEBTS OF THE COALITION LED BY DS

NAME OF SERVICE PROVIDER DEBT AMOUNT

Broadcasting Service "Pancevo" 379,380.30

Communis/Provincial Elections 24,278,737.00

TOTAL AMOUNT: 24,658,117.30

Note: Coalition around DS presented the higher expenditure than the incomes for the amount of RSD 43,060,996.19 and the debts are determined in the amount of RSD 24,658,117.30. The procedure to determine the debts amounting to roughly RSD 20,000,000.00 is undergoing. COALITION LED BY SNS Serbian Progressive Party has no unsatisfied debts towards the suppliers of goods and services, even though it presented the higher expenditures for the amount of RSD 6,759,706.77. Namely, in its repost, this coalition failed to present the incomes gathered from natural persons in the amount of RSD 7,924,287.00, which were realized and used to pay its dues in accordance with transactions per accounts. In the process of analysis and overseeing, it is established that the amount of the expenditure of RSD 1,150,000.00 paid to the agency Block&Conect form the campaign special-purpose account, was not presented in the filed report. Besides, the Coalition around SNS, as presented in the report, failed to present the specification of the substantial portion of its expenditures.

Annex 4, p 2 COALITION URS

LIST OF DEBTS OF THE COALITION LED BY URS

NAME OF SERVICE DEBT NAME OF SERVICE DEBT PROVIDER AMOUNT PROVIDER AMOUNT

78,686,591. Pink Grafostil 141,600.00 00

Sumadija Fair 509,332.00 TV Kanal 9 259,600.00

11,548,765. New Focus Total ADV 310,554.00 00

Other, not presented, 8,435,529.0 expenses (name of the Alma Quatro 976,119.00 0 service provider is not presented)

Studio R, sole Media Max 500,000.00 26,400.00 manufacturing business

1,184,897.0 Babbler AGS 59,000.00 0

Leksovac Sports Center 11,500.00 Nely, printing company 45,600.00

Paracin Sports and 30,600.00 Plasteks 150,220.00 Recreation Center

Mladost Pancevo 138,863.00 Kvant 24,000.00

Pirot Sports Center 50,000.00 Naj Naj 100,000.00

1,807,661.0 Studio “B” Advercity 1,100,000.00 0

Broadcasting Service “AS” 892,905.00 Telekom Serbia 1,946,779.00 Sabac

Budimka Pozega, JSC 5,900.00 Lampion, LLC. 326,417.00

Public Broadcasting 55,323,190. Profi line IMD 225,000.00 Service RTS 00

Profi line IMD/ Leonardo 47,801,902. B92 (total presented 29,965.00 00 expenditure)

50,845,982. Land Development TV Fox 11,812.00 00 Agency, PE

TV Avala 4,708,242.0 TV Pancevo 39,060.00

Annex 4, p 3 LIST OF DEBTS OF THE COALITION LED BY URS

NAME OF SERVICE DEBT NAME OF SERVICE DEBT PROVIDER AMOUNT PROVIDER AMOUNT

5,669,120.0 TV Happy Pancevac 54,217.00 0

1,000,000.0 TV 5 Tec Elektronic 194,110.00 0

Panonija 175,000.00 SAT TV 177,000.00

Belle Amie 249,600.00 Radio Boom 93 35,400.00

Lotel 706,778.00 “Rec Naroda” 21,000.00

1,957,441.0 YU Eco Vujevic Workshop 206,500.00 0

2,174,032.0 Palma Plus Spektar 64,900.00 0

5,576,160.0 Broadcasting Service TV Vojvodina 160,000.00 0 “Radio Srece”

TV Bor 195,408.00 Billboard city Agency 30,000.00

2,200,000.0 Ringer Axel Springer Radio Luna 13,000.00 0

New Focus / JO-GO / Nixan (total expenditure regarding other 859,066.00 Radio San 138,000.00 promotional products, pens, lighters and flags)

Commercial Bank – taxes 150,062.00 TV Lav 59,000.00 and reimbursements

Plutos 8,000.00 Grafos 103,840.00

290,583,46 Piramida Studio 51,600.00 TOTAL AMOUNT: 5.00

DESIGN Project 35,535.00

Megaton Media 64,711.00

Note: The discrepancy between the incomes and expenses, on the one hand and the unsatisfied debts on the other hand occur preliminary as a consequence

Annex 4, p 4 of the method of presenting the returned portion of the loan in the course of the campaign, as well as represented higher incomes than the recorded payments through the account. Alike with the other political entities, the procedure to determine other debts of the Coalition URS is still undergoing.

Annex 4, p 5 COALITION LED BY LDP LIST OF DEBTS OF THE COALITION LED BY LDP

NAME OF SERVICE PROVIDER DEBT AMOUNT

Public Broadcasting Service RTS 35,889,256.00

Prva TV 48,969,631.04

TV B92 4,965,788.75

TV Pink 42,104,623.09

Alma Quatrro 21,375,919.77

Digital printing center 4,176,202.70

Vision team 972,048.55

Doc Brown 100,000.00

Local media 3,693,990.00

"Vecernje novosti", daily newspaper 700,005.60

Press, daily newspaper 843,082.00

TV Gem Lazarevac 106,200.00

TV M Paracin 70,800.00

Radio 31 Uzice 17,700.00

Radio Zlatar 14,000.00

163,999,247.5 Total amount 0

Note: Coalition led by LDP presented the higher expenditure for the amount of RSD 170,690,992.27, and the debts are determined in the amount of RSD 163,999,247.50. The procedure to determine the debts in the amount of RSD 6,691,745.00 is undergoing, for which the Coalition led by LDP failed to present the specification of its expenditures.

Annex 4, p 6 COALITION AROUND SPS LIST OF DEBTS OF THE COALITION LED BY SPS

DEBT NAME OF THE SERVICE PROVIDER AMOUNT

Alfa LLC 1,057,663.18

Predrag Pavlovic 11,132.00

Angora 165,610.00

Slaghterhouse Jagodina, JSC 735,620.40

EMA – TURS, Vladimirci 206,500.00

Italian Petrol, LLC, Leposavic 38,000.00

Eurotrans Turs, LLC, Koceljeva 63,720.00

Museum of Wax Figures 214,000.00

Djinic TST, Sabac 54,000.00

NIN – TRAVEL, Lebane 120,000.00

Molprevoz Mol 90,000.00

Zoo Park Jagodina 1,669,687.00

POLYCOM, New Belgrade 22,800.00

Euroturs and Nis-Ekspres 25,000.00

Petica Marketing Center, LLC 2,187,647.00

Radio and Television Kraljevo and 163,985.00 “Ibarske Novosti” LLC.

IBM, partnership company 3,540.00

Fenix, sole trade, catering and 19,410.00 manufacturing business, Kraljevo

TOTAL AMOUNT: 6,848,314.58

Note: Discrepancy between the presented unsatisfied dues and the difference between the incomes and expenditures of the Coalition led by SPS occur as a result of return of its own funds to the account for regular work of the party, while in the report, presented as expenditures.

Annex 4, p 7 DSS LIST OF DEBTS OF THE COALITION LED BY DSS

DEBT NAME OF THE SERVICE PROVIDER AMOUNT

AS, LLC 50,185.00

Demo Group, LLC 10,000.00

Grafika, sole manufacturing, printing and publishing 25,844.00 business

Sigraf Printing House 23,600.00

ADJ Company 3,791,541.96

TV Leskovac 24,374.00

Becejprevoz, JSC 5,032.00

SP Print 9,572.00

City Administration for Communal Services in Novi 6,990.00 Sad

TOTAL AMOUNT: 3,947,138.96

Note: Democratic Party of Serbia presented the higher incomes than the expenditures for the amount of RSD 409.453, in which process, it transferred the unused portion of the incomes to the account for the regular work of the party. At the same time, the unsatisfied dues amount to RSD 3,947,138.96.

Annex 4, p 8 ANNEX 5: List of Legal Entities with Debts Not Settled on the Day of Report Submission

Name of Value of Unsettled Debts on The Name of Legal Entity Total Value of Contributions (RSD) Political Entity Day of Report Submission (RSD) UTC COMPANY 2.502.787,32 5,000,000.00 NOVA SICILIJANA 245.856,00 300,000.00 Iga Petrol, Ltd 194.848,00 441,431.00 URS Coalition Flaum 155.424,8 700,000.00 TRENDETEX 143.708,15 1,100,000.00 Senjak, Ltd 136.683,00 1,000,000.00 SPM Group 74,406.51 5,200,00.00 ŽITOPRERADA PLUS, Ltd 60.594,39 10,000.00 ŠUMADIJATRANSPORT, Ltd 877.072,74 10,000.00 Ekofarm 1.862.035,55 50,000.00 "Klas" Bakery, Milena Petrović 808.465,81 10,000.00 Ineks Velepromet 2.893.757,25 60,000.00 SPS Coalition TTP Mlava 541.998,71 30,000.00 Neimar put, Ltd 1.173.022,87 50,000.00 INFRONTMEDIA 66.033,79 750.000.00 Granis, Ltd 51.671,02 4.500.000,00 PROFORUM 56.469,75 70,000.00 LDP Coalition OUT SOURCING MANAGEMENT SOLUTIONS 78.190,31 7,000,000.00 PROTECTA GROUP 143.572,17 2,000,000.00 DS Coalition RRC, Ltd 6.406.991,10 4,000,000.00

Annex 5, p1