103. That in total, ECOWAS continues to owe the Applicant the sum of nine million five hundred and eighty-nine thousand, one hundred and thirty-five, point sixty-two FCFA (9,589,135.62); 104. That at the time the Applicants left ECOWAS, the value of 1 UA = 932.759 FCFA. 105. That since the Applicants’ departure from the ECOWAS service, they have, by various means, approached the hierarchical authorities for payment of their dues, but without any success; 106. That even before approaching ECOWAS Court of Justice as provided for under the provisions of the ECOWAS Treaty Conventions, Protocols and Directives, the Applicants took the trouble to gracefully approach the Administration and Finance Committee, the Auditor General, the Chairman of the Ad Hoc Committee, the President of the Court of Justice and the President of the Commission, but no follow-up was given to their approaches (Exhibits X and Y). 107. That their employment contracts, in addition to their clauses, are also subject to the provisions of the Staff Regulations. 108. That the various attempts of amicable solution, sought by the Applicants by addressing appeals to the ECOWAS authorities, have been unsuccessful. 109. That the delay in the payment of their entitlements has caused them enormous losses; 110. That in fact the Applicants former retired employees, had planned, once the gratuities were paid on time, to invest in banks, to obtain financial interest at the legal rates. 17

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