Governments – RJ Gaito Law Firm

Litigation Speed Read: Luxembourg Arbitration Reform

admin — Thu, 18 May 2023 20:46:16 +0000

GENERAL GUIDING PRINCIPLES:

On 25th April 2023, a law came into force that reforms the Luxembourg New Civil Procedure Code in relation to arbitration (the “Law”). The Law aims to modernize and enhance the internal Luxembourg arbitration legal framework with a view to making Luxembourg a more attractive jurisdiction for international arbitration and relieving the pressure on the local Luxembourg courts.

The law mainly adapts the UNCITRAL model law and latest developments in French and Belgian law. Consistent with the UNCITRAL approach, the law reflects the understanding that parties to an arbitration agreement have made a conscious decision in favor of the finality and expediency of the arbitral process. Consequently, annulment of an arbitral award in the Luxembourg Court of Appeal is now restricted to procedural irregularities, violation of the right of defense and the public order.

The salient points of the Law are the following:

Jurisdiction. The arbitral tribunal has the power to determine questions of jurisdiction including but not limited to the existence and validity of the arbitration agreement. Where a matter is subject to an arbitration agreement, the Luxembourg courts may only accept jurisdiction where the arbitration agreement is null and void because the subject matter is not arbitrable or for any other reason the arbitration agreement is manifestly null and void.
Arbitration Agreements. Liberal interpretation of arbitration agreements with no need for a separate arbitration agreement; an arbitration clause would suffice; the parties to the arbitration agreement are very much free to regulate the place of the arbitration seat, number of arbitrators and arbitration procedures.
With the objective of bringing efficiency to the legal process, and in the absence of contractual terms, the Law set a maximum time limit of six months to complete the arbitration proceedings although, it should be noted that, an extension to that period is possible in certain instances. In addition, the default number of the arbitral tribunal is three arbitrators.
Powers and procedures of the arbitral tribunal. Other than attachment orders (“saisie-arrêt) that may only be granted by the Luxembourg courts, the arbitral tribunal can grant interim and provisional measures.
Supporting judge. The Law creates a new dedicated role for a supporting judge (“juge d’appui”), who can resolve procedural difficulties in arbitration subject to the jurisdiction of the Luxembourg court. It should be noted that the judge’s jurisdiction is limited to cases where: “(i) where the seat of arbitration is Luxembourg, (ii) cases where the parties have submitted their arbitration to Luxembourg procedural, (iii) the parties have expressly given jurisdiction to the Luxembourg courts to hear disputes relating to the arbitration proceedings, or (iv) where there is a significant link between the dispute and the Grand Duchy of Luxembourg.”
Annulment and request for setting aside of an arbitral award. In the interest of creating efficiency in the judicial proceedings, set-aside proceedings are only possible in the Luxembourg Court of Appeal and limited to the following grounds: (i) wrongful determination by the tribunal of itself as having or not having jurisdiction, (ii) improper constitution of the tribunal, (iii) failure by the tribunal to comply with its assigned task, (iv) award contrary to public order (v) unreasoned award (can be waived by the parties), or (vi) violation of defence rights.
Request for revisions and withdrawals of awards. A request for reexamination of the arbitral award can be made to the arbitral tribunal in cases of: (i) fraud, (ii) withholding of crucial evidence, (iii) awards obtained based on false documentation, or (iv) awards based on testimonies which were adjudicated as false.
It should be noted that any subsequent revision application needs to be litigated by the arbitral tribunal, and where the tribunal cannot be reconvened, brought before the Luxembourg Court of Appeal.
It is also worth noting that a request for annulment and an appeal decision upholding enforcement does not have suspensive effect. However, the Court of Appeal, ruling as in summary proceedings, may stop or adjust the enforcement of the award if such enforcement is likely to seriously prejudice the rights of one of the parties.
Foreign arbitral awards. Foreign awards may not be set-aside in Luxembourg but at their seat of arbitration. Such awards are enforceable in Luxembourg subject to the so-called “exequatur” procedure and may only be challenged based on limited grounds.

Our take and practical considerations:

Considering the prominence of the Luxembourg financial market and the extensive use of Luxembourg vehicles, the Law provides an enhanced framework and certainty for international transactions. Whereas, in the past, parties have tended to have agree on Luxembourg to govern the substantial contractual obligation but chose a legal seat of arbitration outside Luxembourg, there is now scope to reconsider this approach and choose Luxembourg as well for the seat of arbitration. In addition, the established Luxembourg practice of enforcing agreements in accordance with their terms as well as the possibility to conduct the arbitration proceedings in English, makes the seat of the arbitration in Luxembourg an ever more coherent choice.
We advise parties choosing arbitration to draft clear and detailed arbitration clauses and to avoid use of implied terms in order to avoid creating grounds to contest the meaning of the clause causing delays and uncertainty in the arbitration process.
Finally, in the parliamentary preparatory work, the Luxembourg Chamber of Commerce (2021) went one step further in proposing the introduction of a state court adjudicating in English, stating that this will give the impetus for Luxembourg to become a prominent place for arbitration. This, in our view, will catapult Luxembourg law to be a force to be reckoned with in the financial and legal market.

Our experience:
RJ Gaito is celebrating 12 years in business; our firm has acted for and against major corporations, entrepreneurs, as well as private clients in the various jurisdictional levels of the Luxembourg courts system commencing in the lower courts up to the Luxembourg Supreme Court (“la cour de cassation”), including current proceedings now pending with ICSID.

Our firm has obtained freezing orders over various asset classes, acted in emergency proceedings, and enforced foreign judgments in Luxembourg. We assisted equity investors, debtors and creditors in complex distressed debt matters and, over the years, we were successful in multi-million Euro/United States Dollar recoveries for creditors and equity investors.

Ronnen J. Gaito	Gwendoline Bella
gaito@rjgaito.com	gwendoline@rjgaito.com

40 rue Glesener
L-1630 LUXEMBOURG

Tel. (352) 20 600 333
Fax. (352) 20 600 334
Mob. (352) 621 32 37 34
e-mail: info@rjgaito.com
https://www.rjgaito.com

RJ Gaito and Baker & Hostetler are representing a Luxembourg investor in an Energy Charter Treaty claim against the Republic of Slovenia before the International Centre for Settlement of Investment Disputes (ICSID).

admin — Thu, 29 Dec 2022 15:04:46 +0000

RJ Gaito and Baker & Hostetler are representing a Luxembourg investor in an Energy Charter Treaty claim against the Republic of Slovenia before the International Centre for Settlement of Investment Disputes (ICSID).

On behalf of our client Towra S.A.-SpF, we recently filed a request for arbitration against the Republic of Slovenia with the World Bank’s International Centre for Settlement of Investment Disputes (ICSID).

The arbitration, Towra SA-SPF v. Republic of Slovenia (ICSID Case No. ARB/22/33), which concerns Slovenia’s expropriatory and discriminatory treatment of Towra’s investment in Slovenian lignite producer Premogovnik Velenje, d. o. o., in breach of the Energy Charter Treaty (ECT). ICSID, part of the World Bank Group headquartered in Washington, D.C., is the world’s leading arbitral institution for settlement of disputes between States and foreign investors.

To vindicate our client’s treaty rights in this international forum, RJ Gaito has joined forces with colleagues and friends from the International Arbitration and Litigation practice at Baker & Hostetler including Carlos Ramos-Mrosovsky and Oren Warshavsky in New York and Paul Levine in Washington, DC.

Ronnen J. Gaito, founding partner, commented:

For the past 12 years our firm has advised sophisticated international clients on investments around the world. This case demonstrates our broad international reach, the strength of our international partnerships, and our ability to defend our clients’ interests on a global stage.

EU accedes to the Hague judgement convention of 2 July 2019

admin — Mon, 24 Oct 2022 08:29:28 +0000

Overview

The EU formally acceded to the convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters in August 2022 (the “Convention”).

The Convention will enter into force on 1 September 2023.

To date, the Convention has been signed by Uruguay, Ukraine, Israel, Costa Rica, Russia, and the United States; only the Ukraine and EU (except for Denmark) have ratified the Convention.

Recognition and enforcement of foreign judgement in civil or commercial matters

The main objective of this Convention is to facilitate and secure cross-border relations by harmonizing the circulation of judgments on a global scale.

Although the Convention shall apply to the recognition and enforcement of judgments in civil or commercial matters, a certain number of exceptions have been set under the Convention, for example, family law, insolvency, freight and passenger transport, slander, arbitration, restriction of competition matters. These exclusions render the Convention of a more restricted application than Regulation EU n°1215/2012 of 12 December 2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters within the EU (“Brussels I Recast”).

Under the Convention a judgment refers to any type of judicial decision rendered on the merits of a case regardless of it being referred to as a judgement.

We note that, under article 4 of the Convention, a foreign judgment shall only be recognized or otherwise receive “full faith and credit” if two conditions are met:

The decision produces an effect in the State of origin; and
The decision is recognizable and executable in the State of its origin and provided that the conditions set forth under articles 5 and 6 of the Convention are complied with.

It should be noted that a judgement is eligible for enforcement under articles 5 and 6 provided one of 13 grounds is complied with.

It should be further noted that decisions regarding real estate rights will only be recognized and executed if that decision has been rendered by the jurisdiction where the real estate is situated.

Refusal to recognize and execute a decision

Under articles 7, 8 and 10 of the Convention, the requested State has a right to refuse the recognition and the execution of a judicial decision for the reasons listed exhaustively by the Convention (for example, fraud, incompatibility with public order, the documents introducing the procedure have not been properly served and conflict with another decision). In our view, some elements in the said articles could render the execution of a decision complex given that it may require the judge of the requested State to analyze the decision taken by a foreign judge under a foreign law. In effect, from a Luxembourg perspective, those provisions could further complicate our current full faith and credit proceedings (a.k.a “Exequatur”).

Procedure

While providing mutual recognition of judgments, the Convention maintains each contracting State’s internal procedures for recognition, which in Luxembourg is the so-called Exequatur procedure.

Possible derogation

We note that, the Convention permits the possibility for the contracting States to derogate from one or several provisions of the Convention.

(Articles 14, 17 to 19, 25 and 30)

Our Take

In our view, although the Convention is well intended it remains of limited benefit.

As mentioned, a contracting State’s right to derogate from certain provisions, the pre-existing conditions for enforcement, and the matters which are expressly excluded detract significantly from its attractiveness.

Furthermore, the procedure of recognition and execution remain those applicable in each State, and therefore any local complexities, as the case may be, remain in place. In this respect, in Luxembourg, the procedure of Exequatur will apply to all States other than those being party to the Brussels I Recast and the Lugano Convention.

We note that, an Exequatur procedure entails substantial costs, is lengthy as well being subject to the right of appeal.

Therefore, in our view, enforcement, and recognition of decisions within the EU under the Brussels I Recast and the Lugano Convention will remain far easier, quicker, and ultimately, cheaper.

Contact:

Ronnen Gaito: gaito@rjgaito.com

Gwendoline Bella: gwendoline@rjgaito.com

40 rue Glesener
L-1630 Luxembourg
Tél. (352) 20 600 333
Fax. (352) 20 600 334
https://www.rjgaito.com

Luxembourg Regulator calls on supervised entities to enforce restrictive measures against Russia and Belarus

admin — Wed, 02 Mar 2022 20:26:25 +0000

In light of ongoing events across Russia and Ukraine, several Western countries including the US, the EU, the UK and Switzerland have imposed new sanctions on Russia and Belarus related businesses significantly extending existing sanctions and export controls. The current sanctions include restrictions on several Russian financial institutions, regional embargoes, blocking measures, sovereign debt restrictions, commercial restrictions and measures targeting certain individuals and their assets.

This is a complex and rapidly evolving topic and further measures may be introduced in the coming days. The CSSF has called on supervised entities to enforce the sanctions, including any attempted transactions, and apply the greatest possible vigilance with respect to risks related to IT security and cyberattacks (currently only available in French:https://www.cssf.lu/en/2022/03/circular-letter-to-all-persons-and-entities-supervised-by-the-cssf/).

The impact of the sanctions cannot be underestimated considering the nine- and ten-figure settlements against non-U.S. entities engaged in trade with countries subject to U.S. embargoes. The global scope of certain measures requires careful consideration in a Luxembourg cross-border context.

How can our firm advise

We are tight-knit independent business law firm with a unique combination of regulatory and dispute resolution expertise, including sanctions related matters and their potential knock-on effects on Luxembourg incorporated institutions. We have successfully defended European institutions and their directors vis-à-vis US authorities for sanctions involving trade embargoes. We approach each matter with intensity, thoroughness and delicacy and have investigated the below topics:

contractual review of main investor and/or finance documents assessing contractual liability risks for breach of contract
assessment of risk of freezing orders and/or conservative measures taken in Luxembourg by disgruntled Russian counterparties as well as counterstrategy
freezing orders and conservative measures taken over assets located in Luxembourg
data leakage, cyberattack and consequent liability risk towards the relevant institution’s clients
management liability assessment in light of criminal nature of infringement of some sanctions
interplay of US sanctions and EU “blocking” measures

We track the evolvement of the sanctions and their impact on global players closely. Do not hesitate to get in touch should you require assistance.

Contact:

Ronnen Gaito gaito@rjgaito.com
Harry Ghillemyn harry@rjgaito.com

40 rue Glesener
L-1630 Luxembourg

Tél. (352) 20 600 333
Fax. (352) 20 600 334
Mob. (352) 621 32 37 34

e-mail: info@rjgaito.com

https://quizzical-clarke.77-68-21-77.plesk.page

Luxembourg Data Protection Commission vigorously enforces GDPR

admin — Sat, 27 Nov 2021 16:58:15 +0000

Introduction:

Article 37 of GDPR requires the appointment of a Data Protection Officer (“DPO”). The appointment of a DPO is a critical compliance requirement and recent decisions of the Luxembourg Data Protection Commission (a.k.a the “CNPD”) illustrate the implications of a failure to appoint a DPO, as well as the failure to adhere to GDPR’s prerequisites relating to the DPO’s function.

In addition, we note that use of video surveillance and geolocation technologies is another area that is subject to GDPR constraints. The use of such technologies requires an understanding of the lawfulness and conditions for compliance with GDPR.

We would like to bring to your attention four recent decisions of the CNPD published on November 2, 2021, relating to the implementation and enforcement of GDPR.

Three CNPD decisions were rendered following a deliberate and concerted investigation campaign carried out by the CNPD since 2018 in respect of the position and role of the DPO, as well as the importance of its integration into the organizational fabric of a company.

A fourth decision relates to the setting up of video surveillance and geolocation systems.

We note that the decisions taken are detailed and reasoned legal opinions that cite the legal basis for these decisions. These decisions serve as future guidance to organizations in the implementation of GDPR. The CNPD’s decisions imposed a range of sanctions ranging from warnings to fines. The fines ranged from EUR 3,500 to 18,000. In this context, we note that the CNPD applies GDPR strictly and will not hesitate to impose severe penalties.

The CNPD adapts the sanctions to the factual circumstances and takes into account the approach and collaborative attitude of the audited entity during the investigation.

It should be noted that the basis for a decision is taken on the findings at the outset of the investigation. Any subsequent corrective measures taken by the audited entity may be considered in determining the sanctions imposed.

The cases in detail:

Decision n ° 38 FR 2021 issued on October 15, 2021

The CNPD reiterated that:

the identity of the DPO must be provided to the CNPD;
the DPO will have all the resources necessary to enable it to carry out his mission, and these resources must be provided to the DPO by the entity;
the DPO needs to be involved in all decisions relating to data protection and exercise a real control mission; and
the DPO will require specific qualifications to be able to hold this position.

Sanction: administrative fine of € 18,000 and an order to comply.

Decision n ° 37 FR 2021 issued on October 13, 2021

The CNPD reiterated that:

the identity of the DPO must be provided to the CNPD; and
the independence of the DPO must be guaranteed, and in particular, to ensure that there is no conflict of interest.

Sanction: during the investigation, voluntary compliance measures were undertaken; only a call of legal reminder was made by the CNPD.

Decision n ° 36 FR 2021 issued on October 13, 2021

The CNPD reiterated that:

the DPO has to be appointed based on professional qualifications;
three years of professional experience in the field of data protection were deemed sufficient in the particular circumstances;
the DPO must be involved in all decisions relating to data protection and exercise real control over decisions; and
the entity concerned is required to introduce a formal data protection control plan.

Sanction: the CNPD issued an administrative fine of € 13,200.

CCTV Decision n ° 35 FR 2021 issued on October 13, 2021

The audited entity had installed CCTV cameras within the company and geolocation systems in part of its fleet of vehicles.
The CNPD reiterated the principle of “data minimization” in terms of video surveillance. This principle implies only strictly required data can be collected.
To this end, before installing a video surveillance system, the data controller must define, in a precise manner, the purpose(s) it wishes to achieve by using such a system.
The CNPD reiterated that an employee must not be subject to permanent surveillance, especially during their hours of rest.
In the same order, the CNPD reiterated that the cameras intended to monitor an access point (entrance and exit, doorstep, porch, door, awning, hall, etc.) must have a limited field of vision.
Clear and complete information must be provided in areas of surveillance (not a mere post sign).
Information for employees on geolocation must be complete, clear and individualized (a mere post sign in the car is insufficient).

Fine: the CNPD imposed a fine of € 5,300 and orders to comply.

Contact:

Ronnen Gaito gaito@rjgaito.com
Gwendoline Bella gwendoline@rjgaito.com

40 rue Glesener
L-1630 Luxembourg

Tél. (352) 20 600 333
Fax. (352) 20 600 334
Mob. (352) 621 32 37 34

e-mail: info@rjgaito.com

https://rjgaito.com/

Litigation Speed Read: Luxembourg Litigation Reform

admin — Fri, 02 Jul 2021 16:56:28 +0000

GENERAL GUIDING PRINCIPLES:

Modernization of the Luxembourg civil and commercial judicial rules.
Revaluations of the court thresholds. The lower courts (“juge de paix”) have jurisdiction in civil and commercial cases for up to EUR 15,000.
Restrictions on appeal. All judgments below EUR 2,000 are non-appealable.
Procedural changes. Appeals from the lower courts will follow the rules of commercial procedures, that is to say oral pleadings will take place without a need for being represented by a fully qualified member of the Luxembourg Bar.
Debt recovery for uncontested debt. The deadline for opposing uncontested debt claims (“ordonnance de paiement”) is extend to 30 days and, thereafter, a judgment is deemed to be fully enforceable, however, subject to an appeal (for judgments over EUR 2,000).
Written court procedures in the District Court (“Tribunal d’arrondissement”).
- Simplified pre-trial proceedings. For matters below EUR 100,000 where there are only two parties, i.e. plaintiff and defendant, in principle, strict time limits will apply and only in exceptional circumstances the judge could approve a single, one-time, extension for submission of written pleadings.
- Pleadings’ contents. The first written submission must contain the jurisdictional objections and case for non-admissibility. In addition, unless unknown at the date of the notification of the first written submission, counterclaims have to be set in that first written submission. Note that the pre-trial judge has jurisdiction over these jurisdictional objections.
- Oral pleadings in a written procedure. Oral pleadings are no longer obligatory, unless one party requests a final oral submission.
Written court procedures for the District Court and Court of Appeal. An obligation to provide a synthesis of the pleadings restating all the means and facts of the case in the final written submission, and a failure to state any such facts or means deems them to be considered as waived. Note that this rule does not apply to the simplified pre-trial procedure mentioned above.
Harmonization of time limits for appearance. Defendants in civil commercial matters have 15 days to appear after the notifications of proceedings by the plaintiff. Note that additional time limits apply to foreign defendants.
Summary judgment. Summary judgments are now fully executable, however, at the risk of the creditor if the decision is reversed.
Introduction of new procedures.
- Introduction of a procedure for error and omissions rectification by an introduction of a summons (“Requête”) or by order of the judge.
- Introduction of a procedure for interpretation of the judgment. This procedure is reserved for a judgment that lacks clarity and is introduced by way of a summons (“Requête”) or by order of the judge.

Practical implication and considerations:

• We take the view that it is an attempt to increase the efficiency of the Luxembourg courts by setting limits on small claims and claims from EUR 15,000 to 100,000, and thereby relieving the pressure of the various jurisdictions and thus providing the time resources required for larger cases. It remains to be seen if this will be the result.

• We believe that the measures introduced for written synthesis at the end of the proceedings render the procedure more technical and entail more risks in terms of completion of technical requirements for written procedure and, consequently, the cost of litigation may increase.

• Although an appeal from the lower courts can now be handled by a non-lawyer, the technical challenges of an appeal remain the same and, therefore, engaging an experienced counsel is recommended.

Our experience:

RJ Gaito is celebrating 10 years in business, our firm has acted for and against major corporations, entrepreneurs, as well as private clients in the various jurisdictional degrees of the Luxembourg courts system commencing in the lower courts up to the Luxembourg Supreme Court (“la cour de cassation”).

Our firm has obtained freezing orders over various asset classes, acted in emergency proceedings and enforced foreign judgments in Luxembourg. We assisted equity investors, debtors and creditors in complex distressed debt matters and, over the years, we were successful in multi-million Euro/United States Dollar recoveries for creditors and equity investors.

Contact:

Ronnen Gaito gaito@rjgaito.com
Gwendoline Bella gwendoline@rjgaito.com

40 rue Glesener
L-1630 Luxembourg

Tél. (352) 20 600 333
Fax. (352) 20 600 334
Mob. (352) 621 32 37 34

e-mail: info@rjgaito.com

https://www.rjgaito.com/

BREXIT and implications on recognition and execution of UK judgements in Luxembourg

admin — Tue, 18 May 2021 16:55:19 +0000

Overview

Within the framework of European Union (EU) Regulations, the recognition and the execution of judicial decisions rendered by the courts of the EU Member States was greatly simplified.

Pursuant to Regulation (EU) No 1215/2012 of the European Parliament and of the Council of 12 December 2012, on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters “a judgment given in a Member State shall be recognized in the other Member States without any special procedure being required” (Article 36), as well as without further formality being required.

Furthermore, by application of articles 39 and 40 of the Regulation, an EU Member State’s judgment is enforceable by operation of law and is applicable for the purpose of protective measures.

Enforcement of United Kingdom (UK) judgments in Luxembourg post BREXIT

On 31 December 2020, the UK departed from the EU without having received the required consent to its accession to the Lugano Convention of 2007. The Lugano Convention regulates both international jurisdiction and the recognition and enforcement of foreign judgments in civil and commercial matters.

On 8 April 2020, the UK applied to accede to the 2007 Lugano Convention in its own right. However, in a recent communication to the EU Parliament and to the Council of the EU of 4 May 2021, the EU Commission is recommending to reject the application of the UK to accession of the Lugano Convention and that the UK should be treated as third countries via the application of the 2019 Hague Convention.

In that case, the UK is and will be treated in Luxembourg as a third-country jurisdiction and, therefore, an enforcement of a UK judgment will require the application of the so-called “exequatur” procedure. Such a procedure would require a final and non-appealable judgment representing a so-called “title” to be introduced to the Luxembourg District Court (“tribunal d’arrondissement”). It should be noted that the Luxembourg courts may refuse to execute a foreign judgment if it is contrary to Luxembourg International Public Order (“ordre public”).

From a practical perspective, to enforce a foreign judgment in Luxembourg, the applicant has to serve a summons (“assignation en exequatur”) on the defendant in proceedings requiring the services of a lawyer being a member of the Luxembourg Bar.

The procedure requires the involvement of the Luxembourg State Prosecution which has the right to oppose the execution of a foreign judgment on the ground of “ordre public”.

The procedure takes place in a written form, meaning that it is undertaken by exchange of written pleadings which means that it is lengthy and cumbersome. In addition, like any other Luxembourg judgment rendered in the District Court, it is appealable. Thus, the procedure may last for many months.

Our Take

It is obvious that, a failure of the UK to accede to the Lugano Convention will make the procedure for recognition and execution of UK judgments in Luxembourg cumbersome, more costly, lengthier and could result in legal uncertainty.

In international agreements and, more specifically, in international transactions’ practice, English law and English courts are amongst the most popular choices for lawyers and the business community. Therefore, in light of the recent Commission communication, the attractiveness of English law may be significantly diminished.

We are of the view that Luxembourg law could provide an attractive alternative as a choice of law and venue given that the legal framework is solid, the Luxembourg judiciary being non-interventionist by its nature and the enforcement of contracts in accordance with their terms. In recent years, we have witnessed a tendency towards Luxembourg law; one such example was the recent decision by the European Stability Mechanism to issue euro denominated bonds and bills under Luxembourg law rather than under English law.

Contact:

Ronnen Gaito gaito@rjgaito.com
Gwendoline Bella gwendoline@rjgaito.com

40 rue Glesener
L-1630 Luxembourg

Tél. (352) 20 600 333
Fax. (352) 20 600 334

https://quizzical-clarke.77-68-21-77.plesk.page

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