Chief Executive European Defence Agency Belgium

Dear Mr X,

Please find enclosed my above decision.

Based on my own-initiative inquiry, I have decided to close the case with the following conclusions:

EU agencies should adopt a robust procedure for assessing notifications of (former) senior staff to take up private-sector roles closely related to their former duties.

EU agencies lacking an internal policy to prevent conflicts of interest of Board (non-staff) members should encourage their governing bodies to adopt such a policy.

To assist EU agencies to improve their practices in relation to revolving door moves, the Ombudsman has adopted the enclosed ‘Good practice guidelines for handling revolving door situations’.

I intend to apply the good practice guidelines to cases that are brought to my attention in the future. You will find the guidelines annexed to this letter.

Yours sincerely,

Teresa Anjinho

European Ombudsman

Strasbourg, 20/04/2026

Annex - Good practice guidelines for handling revolving door situations

1. Prevention

Have a standard procedure for assessing revolving door situations which includes a clear step-by-step guide for the agency, its staff and Board members in relation to notifications, assessment, mitigating measures, transparency and compliance.

Provide staff and Board members with comprehensive training and guidance materials and conduct regular awareness-raising campaigns and communication initiatives to promote adherence to the applicable ethics rules.

Establish clear criteria for (i) prohibiting post-service or post-mandate moves, or (ii) making recommendations in cases involving certain part-time Board members appointed by national authorities, ensuring that prospective staff or Board members understand these restrictions before joining the agency.

Once aware of a staff or Board member’s intention to take up new employment, promptly assess whether to revoke access rights or, in case of staff members, recuse them from specific tasks.

Require staff members who intend to take up a new position to inform their ethics and/or compliance teams, which can help assess potential risks and advise on next steps, including informing the line manager.

2. Notification

For (former) staff members:

In case of late notifications, instruct the (former) staff member to await formal approval before starting the new activity (where still possible), and explicitly remind them of their obligations to ensure future compliance with notification deadlines.

In case of incomplete or unclear notifications, promptly request missing information and suspend the 30-working-day deadline for taking a decision until the notification is complete, or start the time limit only once all necessary information has been provided.

For (former) Board members:

Ask (former) Board members to notify post-mandate activities for two years following the end of their mandate, and prior to beginning the intended post-mandate activities, by analogy to the rules applicable to staff members.

3. Assessment

Ensure that (former) staff or Board members are given the opportunity to comment on draft decisions or draft recommendations proposing restrictions or prohibitions.

Adopt a reasoned decision promptly, which informs (former) staff and Board members of their right to challenge the decision.

Document the assessment of notifications and the related decision-making processes to ensure that all relevant information is captured and that effective oversight is possible.

For (former) staff members:

Consult the (former) staff member’s line manager at an early stage.

Consistently consult the Joint Committees on (former) staff members’ intended post-service activities in the private sector, or on other positions that may give rise to risks.

Request that (former) staff members submit a formal description of their new role or the related vacancy notice (if available) alongside their notification.

For (former) Board members:

In the absence of legally binding enforcement mechanisms, assess the post-mandate activities in terms of any conflict that might arise in relation to the agency’s legitimate interests and, where applicable, formulate corresponding recommendations to the relevant national competent authority. This should happen as promptly as possible, and ideally before the (former) Board member commences the notified activity.

To ensure timely adoption of recommendations, implement written approval procedures for the relevant governing body, thereby avoiding potential delays caused by infrequent in-person meetings.

4. Mitigating measures

Explore the full range of available measures when assessing post-service or post-mandate activities, such as cooling-off periods, contact and/or lobbying bans, and possible prohibitions on certain private sector roles.

Where risks cannot be sufficiently mitigated, (temporarily) prohibit the person concerned from undertaking such activities. In case of a (former) Board member who represents a national authority, this determination may take the form of a recommendation to their national authority.

For (former) staff members:

Where restrictions prohibit handling certain matters, facilitate compliance by compiling and sharing a list of those matters with the (former) staff member concerned.

5. Transparency

Make public information on authorised post-service activities of former senior staff members, and post-mandate activities of former Board members, on the agency’s website, shortly after adopting the relevant decisions or recommendations.

For (former) staff members:

Share conditional decisions with the new employer of the (former) staff member directly.

Apply a sufficiently broad definition of senior staff when implementing the provision in Article 16 of the EU Staff Regulations, to include all key managerial roles within the agency.

Provide details on restrictions applying to former staff members to relevant staff on a need-to-know basis.

For (former) Board members:

Share recommendations on (former) Board members’ post-mandate activities involving restrictions or prohibitions with the relevant national authority and with the agency’s governing bodies.

6. Compliance and monitoring

Monitor compliance with any mitigating measures applied, as well as with the confidentiality obligation.

In case of an alleged breach of compliance, promptly establish the facts, assess the seriousness of the non-compliance and, in the most serious cases, initiate (disciplinary) follow-up.

For staff members on unpaid leave:

Implement an automated alert system to notify both the staff members concerned and the responsible team of upcoming renewal deadlines for authorised external activities.