Translation from Bulgarian

BULGARIAN ASSOCIATION OF THE CEMENT INDUSTRY

REPORT ON THE ACTIVITY

for the year 2008

Bulgarian Association of the Cement Industry (BACI) is a non-profit organization registered in July 2002 in order to promote the widest possible use of cement in various fields and to develop technologies and methods of production that most protect the environment.

As of the beginning of 2008 members of BACI were the following five Bulgarian companies - manufacturers of cement:

1.  DEVNYA CEMENT AD

2.  ZLATNA PANEGA CEMENT AD

3.  HOLCIM BULGARIA AD

4.  PLEVEN CEMENT AD

5.  VULCAN AD

In September 2008 PLEVEN CEMENT AD merged with HOLCIM BULGARIA AD and at the end of 2008 VULCAN AD declared its desire to terminate its membership in BACI.

Majority shareholders in the companies that are members of BACI are the world's largest manufacturers of cement. DEVNYA CEMENT AD and VULKAN AD are part of the Italcementi Group, HOLCIM BULGARIA AD and PLEVEN CEMENT AD are part of the Swiss group Holcim Group, owner of ZLATNA PANEGA CEMENT AD is the Greek company Titan Cement.

Chairperson of the Management Board of Bulgarian Association of the Cement Industry (BACI), who represents the association, was Mr. Alexander Nakov Chakmakov. In accordance with the decision of the General Assembly of the Association held on 10.12.2007 in 2008 the Management Board of BACI consisted of the following members:

1.  Alexander Nakov Chakmakov;

2.  Todor Donchev Kostov;

3.  Ivan Asenov Atanasov;

4.  Thomas Giyo;

5.  Alexander Charles Car.

REPORT ON THE BUDGET OF BACI for 2008
budget 2008 / received
1.1 Transitional balance from 2007 / 81,146 / 81,146
1.2 Monthly membership contributions (12 months x 8000lv. from 5 members). / 480,000 / 422,000
1.3 Interest Income / 1,000 / 109
1.4. Membership fee for December 2008 received in January 2009. / 32,000
TOTAL INCOME 2008 / 503,255 / 32,000
budget 2008 / Spent / Economy (overexpenditure)
II. EXPENSES / 464,741 / 367,125 / 97,616
1. For fixed assets / 12,000 / 6,491 / 5,509
incl. car lease payments / 5,000 / 4,913 / 87
2. Material costs / 317,741 / 267,072 / 50,669
2.1 Rental and office expenses /electricity, water, cleaning, maintenance, hygiene materials / / 36,000 / 35,502 / 498
2.2 Vehicle operation expenses / 5,000 / 2,620 / 2,380
2.3 Telephone costs, Internet / 6,000 / 3,667 / 2,333
2.4 Stationery / 4,500 / 2,711 / 1,789
2.5 Entertainment allowances and PR costs /cocktails, press conferences, journalists, publications/ / 50,000 / 4,383 / 45,617
2.6 Expenses for business trips / 40,000 / 22,868 / 17,132
2.7 Website hosting and translations of documents / 5,000 / 1,884 / 3,116
2.8 Publications and promotional materials / 10,000 / 4,953 / 5,047
2.9 Fees for participation in conferences, seminars and other paid forums for information exchange / 10,000 / 10,843 / (843)
2.10 Membership in CEMBUREAU / 145,241 / 176,201 / (30,960)
2.11 Membership in other organizations / 5,000 / 500 / 4,500
2.12 Bank costs / 1,000 / 941 / 59
3. Remuneration and social insurance contributions / 125,000 / 93,561 / 31,439
3.1 Executive Secretary / incl. social insurance contributions / 58,000 / 55,045 / 2,955
3.2 Legal services - hourly payment / incl. VAT or social insurance contributions / / 7,000 / 6,075 / 925
3.3 Expert developments and expert committees / 20,000 / 0 / 20,000
3.4 Technical assistant / incl. social insurance contributions / / 18,000 / 9,949 / 8,051
3.5 Accounting services / incl. VAT or social insurance contributions / / 18,000 / 18,000 / -
3.6 Certified Public Accountant / 4,000 / 4,000 / -
3.7. Medical care / - / 492 / (492)
4. Reserves for incidental expenses / 10,000 / 0 / 10,000
BALANCE FOR 2009 WITH THE MEMBERSHIP FEE FOR DECEMBER 2008 / 168,131

Here are the main financial performance results of BACI in brief:

Main source for funding the activities of BACI in 2008 was the membership fee paid by the founders. BGN 454,000 have been received out of the BGN 480,000 that have been voted under the Articles of Association. Other revenues comprise of the transitional balance from 2007 amounting to BGN 81,146 and the interest received on deposited free cash amounting to BGN 109

Key elements of the operating expenses of the Association in total amount of BGN 367,125, sorted by their amount, are as follows:

1.  For membership in CEMBUREAU - BGN 176,201

2.  For remunerations and social insurance contributions - BGN 93,561

3.  For rentals and other expenses for the office - BGN 35,502

4.  For business trips - BGN 22,868

5.  Fees for participation in conferences, seminars, etc. - BGN 10,843

6.  For publications and promotional materials - BGN 4,953

7.  For Fixed Tangible Assets – car lease payments - BGN 4,913

8.  For entertainment allowances and PR costs /cocktails - BGN 4,383

9.  For telephone and internet - BGN 3,667

Unused funds from 2008 amounting to BGN 168,131 remain as a transitional balance for 2009.

In 2008 BACI performed the following main activities to protect the common interests of its members.

The active participation of representatives of BACI was continued in the interdepartmental working group to develop a national plans for allocation of greenhouse gas emissions allowances pursuant to Directive 2003/87EC - for 2007 and for the period 2008-2012.

As a new member of the European Cement Association CEMBUREAU, BACI participated for the first time in the General Assembly of CEMBUREAU held on 9-10.06.2008 in Taormina, Italy. BACI was actively involved with its own representatives in the meetings of the working groups and bodies of management of CEMBUREAU.

BACI was also actively involved in the preparation of a national and pan-European report on the implementation of the obligations of the management of cement plants under the European Agreement on Social Dialogue on health protection of workers from diseases associated with using fine quartz dust (silicosis). In this connection representatives of BACI provided and implemented an European automated reporting system - NEPSI.

In a significant number of its letters to and meetings with members of the Bulgarian Parliament, the Government of the Republic of Bulgaria, National Assembly members and leaders and members of political parties represented in the European Parliament, BACI expressed its views on the necessary amendments to the European Directive on trading with greenhouse gas emissions after 2012, which would prevent the risk of so-called carbon leakage - exporting outside EU carbon-intensive industries which, because of prohibitive costs of allowances for carbon dioxide emissions lose viability in the European Union in competition with productions in third countries that are not burdened with similar costs. BACI justified the urgent need for EU to recognize this risk and take adequate measures to prevent it from becoming a reality. BACI also expressed readiness for constructive interaction with them to achieve a favorable result for Bulgarian economy and took specific steps in this direction, by supporting the formulation of a responsible national position on this issue. These actions of BACI contributed to making relatively well-balanced decisions that take into account the interests of all sectors at the vote in the European Council and European Parliament at the end of 2008 on amendments to the Directive on emissions trading.

BACI and its members also actively participated in the organization and holding of the so-called Day of open doors in the cement plants within the European Week of the open doors in the cement plant, which is planned from 10th to 18th of May 2008 with main guidelines as follows.

Nature of the initiative: In the specified week the cement plants throughout Europe open for one day their doors to its neighbors and other stakeholders, listen to their questions and give answers to them.

Objectives:

·  To raise awareness of the cement industry among the public and management at different levels in Europe;

·  To build positive, but accurate image of the cement industry as a transparent one.

The most common messages to the local community/neighbors: "we are good neighbors", "we have nothing to hide". The main requirements were as follows:

·  To stresses that the local event is part of a wide European initiative to cause a greater interest in the local press, with which to establish contact on the matter

·  As many workers as possible to be included in the presentation (only the presentation of some of the specific messages and the relations with the municipalities and the other institutions to be undertaken by the management)

Specific messages:

·  Use of alternative fuels is safe

·  Financial benefits to the local community

·  Global reduction of CO2 emissions

·  Safe and flexible solutions for waste management

·  Successful cases of career rehabilitation

·  Our products help to meet the challenges of the 21st century:

•  Reducing the emissions of СО2 through energy efficiency in concrete buildings

•  Fire safety

•  Adapting to climate change

•  Recycling

Target group - according to the context:

·  Representatives of various levels of government agencies relating to the production and marketing of cement

·  Customers

·  Workers and their families

·  Other

Three levels of activity:

·  Local level:

•  Organized by the members and their local factories

•  Target group: local community, members of the European Parliament with an interest in the region, local government, local and regional press

•  Format: each member is responsible to organize their own information activities at site and decide on the specific messages.

·  National level:

•  Organized by the members

•  Target group: national authorities, national media and the public in the country

•  Format: possible partnerships with organizations such as national associations of architects and/or engineers, national chambers of commerce, business associations and environmental movements to ensure maximum national impact

·  European level:

•  Organized by CEMBUREAU

•  Target group: selected European leaders, representatives of European institutions and stakeholders

•  Format: stakeholders meeting/round table in Brussels to discuss related issues

Together with and in the context of the key messages that were defined at European level, each member of BACI/plant developed and put emphasis on specific messages that are most appropriate for the particular plant.

The intentions of the Management Board of BACI on most important future activities include mainly:

·  Continuing in 2009 the active participation in the working groups and management bodies CEMBUREAU.

·  Participation in organized at European level Open Week of the cement industry - 2009, with main guidelines as follows:

In the plans for 2009 the name "Week of open doors of the cement plants", used in 2008 for an identical European initiative, is changed to "Week of open door of the cement industry. Accordingly, the proposed subject is "sustainable construction". Generally, the idea is to offer a new perspective each year. The period offered by CEMBUREAU for holding the event is 8-18 May 2009. CEMBUREAU intends to organize a press conference on May 8, 2009, at which key examples of sustainable construction to be presented, followed by a visit to a building / installation / bridge (the location is still to be specified) in order to demonstrate measures for reducing CO2 throughout the whole value chain. In this context, CEMBUREAU called for the presentation of national examples showing what savings could be made. Proposed action at national level also include visits to a building / installation / bridge in order to demonstrate the opportunities to reduce CO2 emissions in the value chain.

·  Registration of BACI under the VAT Act in connection with the expansion of BACI activity with the following additional types of economic activity:

BACI will provide regularly, also if required and / or necessary, services to its clients, which will include but will not be limited to the following:

Tracking, processing and/or providing data. announcements and analysis of interest for the customers, relating to the cement industry (current communications, extracts from newsletters and periodicals, information supplied by the European cement association CEMBUREAU), mainly in the following areas:

o  Written materials related to EU legislation regulating the operation of the cement industry and the relevant decisions of the EU institutions, for example relating to:

Þ  progress of the decision-making process within the EU institutions in areas related to development of the cement industry;

Þ  information on immediate upcoming discussions and necessary assistance from the members of the European Parliament and representatives of the state administration in the EU institutions;

Þ  mid and long-term plans on updating the EU legislation related to the development of the cement industry;

o  Statistical data on the European Union relating to the cement industry;

o  Possibilities at European and international level to provision of services, supplying of materials and marketing of production of cement manufacturers;

o  Other materials of interest to the Customer with relation to the cement industry.

Data processing and provision of reports, including such relating to:

o  Data on production and related emissions, product markets, technical aspects of the functioning of enterprises in the cement industry in the country, industrial accidents and labor protection;

o  Processing in order to summarize country statistics provided by individual members of BACI and NSI, in compliance with the requirements for confidentiality and other requirements of the Law on protection of competition (ZZK);

o  Assessment of potential threats and opportunities for the cement industry;

o  Data on emissions of CO2 in the European Union and the world, generally and for the cement industry, the knowledge of which contributes to an adequate approach in the efforts to reduce CO2 emissions in the country and in EU and participation in the formulation of a relevant global approach for the cement industry;

o  Assessing the potential impact on the competitiveness of European and Bulgarian cement industry of various options for development and implementation of the European scheme for trading with greenhouse gas emissions.

Consultancy services – provided by BACI directly or as an intermediary for the provision of services by third parties, including such relating to: