funding for social organizations. The project featured an investment of €10 million to support 1,000 students and 130 children.

An important feature of SIBs emphasized in the European experience is that this mechanism lowers the entry barriers for investors in the social investment sector, by offering the potential for recouping invested funds from the state. Further, the emphasis on measurable results allows investors to spend money on more expensive projects, as their impact will be more pronounced than that of conventional social investments.

German-Dutch cross-border cooperation is a good example of how an investor can benefit from a social issue. The idea of the project was to "provide Dutch workers with work opportunities in Germany," that is, to integrate labor markets in the cross-border regions of the Netherlands and Germany (Koekoek, 2016). Companies were effectively investing in the retraining and mobility of their would-be workers, achieving positive social and economic effects. However, this raises the ethical question of the state paying money to a private company that benefits from a social impact bonds project. In the context of the European Economic Community, the answer lies in the plain of European solidarity and the value of integration per se. But in other contexts, the rationale for similar projects seems much more complex.

SIBs have not been met with equal enthusiasm everywhere: for example, in Portugal this financial instrument essentially duplicated community social investment funds but with more reporting requirements, which resulted in too much bureaucracy and reduced the flexibility of project implementation (Ferreira, 2020).

A case study of the Danish social impact bonds project (Andersen et al., 2020) shows that funding can be flexible: in particular, the municipalities certainly funded recruitment, project review and evaluation, while investors were involved in funding the actual growth acceleration. The roles of the provider, project operator and evaluator were combined in the project, which is considered a conflict of interest in the classical SIB model. The lack of a project coordinator responsible for concept development and management greatly hindered the ability to build an integral framework in place of an array of isolated elements. Also, funding was predominantly activity-based, not outcome-based. Looking at this case study, we can conclude that outsourcing public services is not the only form for SIBs to take; they can also exist in the format of an external reconfiguration of existing public social policy practices.

CANADA'S EXPERIENCE. COMBINING THE ROLES OF MODERATOR AND EVALUATOR

Deloitte conducted a survey of Canadian investors in 2013 (that is, at the very beginning of the SIB launch within the country). In discussing the main barriers, investors cited high transaction costs and an unwillingness to work with the state due to the uncertainty of its priorities. One of the most common collaboration formats is joint investment in a project as part of an investment consortium, as this allows the number of market entry points to expand. Consortia also enable pooling and sharing expertise, which is a major gain for the investor, second to the actual social impact. As a confidence-building measure during the initial implementation stages of social impact bonds, the consultants suggest considering the option of providing a guarantee for a portion of the invested capital. The scheme works as follows: for any outcome of the project, the state guarantees to return a certain portion (i.e. 5–15 %) of the upfront investment. The essence of SIBs is the transfer of risk from the state to the private sector, and therefore the demand for this step is bound to decrease as the project practice spreads, mechanisms are developed and, most importantly, the state demonstrates a sustained commitment to long-term participation in such projects. Most respondents indicated the optimum project duration to be 4–6 years, which is sufficient for long-term cooperation. The investors surveyed confirmed the relevance of the British model, pointing to the need to have two extra agents beyond the PPP triangle: an impact evaluator (which is not a common service in the Canadian context) and a mediator to communicate with the government. However, Canada mainly used a 4-part model, where the roles of a moderator and evaluator were combined.

THE LATIN AMERICAN EXPERIENCE. DREAM

The Inter-American Development Bank Research Lab (Ronicle & Strid, 2021) has formulated five criteria for a successful social impact bonds project — DREAM (Demand from government, Regulatory framework, Economic and political context, Availability of data, Market capacity):

1. Demand from Government — Developing an approach based on the governmental demand, which includes influential private players in the discussion. In Argentina, the state agency combined the roles of financial guarantor and contractor. This led to the state funding its own services, which violates the logic of SIB and reduces the effectiveness of the projects.

5 criteria for a success of SIBs — Demand from government, Regulatory framework, Economic and political context, Availability of data, Market capacity.

2. Regulatory Framework — the presence of an appropriate regulatory framework for SIBs that is flexible, results-oriented and regulates government payments. In Mexico, a specialized research institute was established to study the legal barriers to implementing social impact bonds. And in Chile, legal consultants were used for this purpose.

3. Economic and political context — in the political sense, it is essential to provide guarantees that programs will not be phased out after a change in government at the beginning of a new political cycle. While Argentina and Colombia made some attempts to create enforcement mechanisms for SIBs that do not depend on political campaigns, the general recommendation is to launch projects within the political cycle and negotiate with elected politicians at the beginning of their elected term. The economic context is important in the sense that high inflation levels require contracts accommodating regular price increases. This is what happened in Argentina without an inflation adjustment mechanism, which obstructed the successful implementation of social impact bonds.

4. Availability of data — During the SIB ecosystem growth states, it is critical to have sufficient administrative data (or to have the resources to obtain the necessary data on your