ALTER-EU The Alliance for Lobbying Transparency and Ethics Regulation

A longer notification period of three years would be appropriate, as it is in line with the allowance system for Commissioners and therefore a sensible safeguard to reduce the risk ofconflicts of interest. Finally, the Code also includes no definition of lobbying.

We would like to suggest that you review the Code on these and other points after a trial period of one year, with an open mind to increase the notification-period to three years and closing the loopholes, so lobbying jobs effectively become off-limit for ex-Commissioners.

There are still some important decisions to be made regarding the ad hoc ethical committee, which should be given the right powers and remit to be able to fulfill its proper role in preventing conflicts of interest. We would like to reiterate the following recommendations:

• the ad hoc ethical committee must be fully independent and composed of experts on public administration ethics, such as academics and national government ethics regulators.

• the committee should actively scrutinize possible conflicts of interest, including making contact with the planned employer and taking other pro-active steps. The input from third parties should be included in the assessment process.

• there should be comprehensive online transparency around the Commission’s decision to approve or reject post-employment requests . Decisions should be available online and be searchable, sortable and downloadable.