for a shortfall of capital where investments are need, in order to stimulate the ability of the economy to grow and for public investment to lead to the creation of decent jobs; indeed, public investments in infrastructure and in education, as well as in institutions-building, have a key role to play in attracting private investment. On the other hand however, high levels of debt can lead creditors to impose conditions, linked in particular to macroeconomic policies and fiscal consolidation, that could negatively affect the ability of the borrowing country to fulfill economic, social and cultural rights. In the recent past, the case of Greece illustrates this best.171 After it was revealed, in October 2009, that the public debt of the country was much higher than had been reported, Greece faced speculation on the financial markets, making its debt impossible to finance at acceptable conditions. It therefore called for financial support, and three rescue packages were successively granted, in 2010, 2012 and 2015.172 However, following the implementation of fiscal consolidation programmes adopted by the country at the request of its creditors (the other Euro Area Member States represented by the European Commission, the International Monetary Fund, and the European Central Bank), various human rights bodies expressed their concern on the impacts of these programmes on social rights. The European Committee of Social Rights considered that amendments to labour legislation, introduced in the name of "flexibility", violated various provisions of the European Social Charter,173 and it arrived at the same conclusion concerning reductions to the levels of pensions.174 United Nations human rights treaty bodies expressed similar concerns at the impacts of the austerity measures introduced by Greece at the request of its creditors.175 When it reviewed the situation of the country in October 2015, the Committee on Economic, Social and Cultural Rights expressed its concern that "despite the measures taken by the State party to mitigate the economic and social impact of the austerity measures adopted in the framework of the memorandums of understanding in 2010, 2012 and 2015, the financial and economic crisis has had a severe impact on the enjoyment of economic, social and cultural rights, 171 For an excellent summary, see L Papadopoulou, 'Can Constitutional Rules, even if “Golden”, Tame Greek Public Debt?', in Maurice Adams, Federico Fabbrini and Pierre Larouche (eds), The Constitutionalization of European Budget Constraints (Oxford, Hart, 2014), pp 223–247. See also See European Parliament Report 2009–14 on the inquiry on the role and operations of the Troika (ECB, Commission and IMF) with regard to the euro area programme countries (2013/2277 (INI)), A7-0149/2014, 28.2.2014; Report of the Independent Expert on the effects of foreign debt and other related international financial obligations of States on the full enjoyment of all human rights, particularly economic, social and cultural rights, Mission to Greece (22–26 April 2013), UN doc A/HRC/50/15/Add 1 (27 March 2014). 172 Greece called for financial assistance on 23 April 2010. In response, the representatives of the Euro Area Member States other than Greece decided on 2 May 2010 to provide stability support to Greece through a Loan Facility Agreement: in effect, an intergovernmental framework that allowed the pooling of bilateral loans in the form of an international contract. The Euro Area Member States provided Greece with a total of 80 billion euros in loans on the understanding that the International Monetary Fund (IMF), to which Greece had also turned for assistance, would provide another 30 billion euros (Loan Facility Agreement (2010), preambular § 3). The disbursements, however, were made conditional on the adoption of fiscal consolidation measures by Greece, the content of which was negotiated by the European Commission on behalf of the creditors. The 'Economic Adjustment Programme for Greece' included so-called ‘austerity’ measures purportedly to restore Greece’s fiscal balance (30 billion euros worth of spending cuts were decided for the period 2010–2014) ; the privatisation of State assets, in the amount of 50 billion euros ; and ‘structural measures’, involving in particular the ‘flexibilisation’ of the labour market, as a means to restore the competitiveness of the Greek economy. In June 2011, after this first set of measures appeared insufficient, the euro-zone Member States granted a second loan for an amount of 130 billion euros for the years 2012–2014. This second bailout was effectuated through the European Financial Stabilisation Mechanism (EFSM) and the European Financial Stability Facility (EFSF). It was officially launched in March 2012. Finally, a third rescue package was agreed in July 2015, for an amount of 68 billion euros (see Council Implementing Decision (EU) No. 2015/1411 of 19 August 2015 approving the macroeconomic adjustment programme of Greece, OJ L 219, 20.8.2015, p. 12). 173 ECSR, Decision on the merits, 23 May 2012, Complaint No 65/2011, General Federation of Employees of the National Electric Power Corporation (GENOP-DEI) and Confederation of Greek Civil Servants' Trade Unions (ADEDY) v Greece; ECSR, Decision on the merits, 23 May 2012, Complaint No 66/2011, General Federation of Employees of the National Electric Power Corporation (GENOP-DEI) and Confederation of Greek Civil Servants' Trade Unions (ADEDY) v Greece. 174 ECSR, Federation of Employed Pensioners of Greece (IKA-ETAM) v Greece, Complaint No 76/2012; Panhellenic Federation of Public Service Pensioners v Greece, Complaint No 77/2012; Pensioners' Union of the Athens–Piraeus Electric Railways (ISAP) v Greece, Complaint No 78/2012; Panhellenic Federation of Pensioners of the Public Electricity Corporation (PAS-DEI) v Greece, Complaint No 79/2012; Pensioners' Union of the Agricultural Bank of Greece (ATE) v Greece, Complaint No 80/2012. 175 See, eg, Committee on the Elimination of Discrimination against Women, Concluding Observations on the seventh periodic report of Greece, UN doc CEDAW/C/GRC/CO/7 (1 March 2013); Committee on the Rights of the Child, Concluding Observations on the combined second and third periodic reports of Greece, UN doc CRC/C/GRC/CO/2-3 (13 August 2012). 36