- ORDER the said member states to review both the Treaty and CIMA Insurance Code to ensure protection of human rights. ORDER also the annulment of 26 October 2012 Decision No. 00020/D/CIMA/CRCA/PDT/2012 OF THE REGIONAL INSURANCE CONTROL COMMISSION (CRCA) taken against the Company based on the unlawful provisions cited above, and by which the withdrawal of its licence was pronounced (Exhibit # 1) and consequently, ORDER Member States of CIMA to repair the damage suffered, particularly by the partners and the Company itself. This prayer for annulment is made on the following grounds: - Violation of Articles 8 and 10 of the Universal Declaration of Human Rights; - Violation of the Preamble and Article 4 of the International Covenant on Economic, Social and Cultural Rights; - Violation of the Preamble and Articles 2 (3) and 14 of the International Covenant on Civil and Political Rights; - Violation of Articles 1, 3 and 7 of the African Charter on Human and Peoples’ Rights; - Abuse of power by CIMA organs; - Abuse of authority by CIMA organs; - Erroneous assessment of the personal status of the Company and its representatives. D. MEASURES REQUESTED The Applicant requests as follows: 1. On the material damage, order the Commission to pay reparation in the sum of 1,300 000,000 CFA F at the least. 2. On the professional damage, reparation for “all of its losses which cannot be less than 3 billion CFA Francs." 3. The damage to the image of the company, order the Commission to pay reparation in the amount of 3 billion CFA F. 4. On the professional prejudice, order the CIMA to pay reparation in the amount of 6 billion CFA F 5. On the financial damage of SANTEPHONE project, order the CIMA to pay reparation in the amount estimated at 87,898,125,000 CFA F. 6. On the financial prejudice resulting from other projects, order CIMA to pay the sum of six billion CFA F and order CIMA to serve the Company with that sum.

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