Background to the complaint

1. The complaint concerns the move of a former vice-president (former VP) of the European Investment Bank (EIB) to become the chief executive officer (CEO) and general manager of the national promotional bank in Italy, his Member State of origin^[1]. The former VP was a member of the EIB’s Management Committee and was also chair of the Board of Directors of the European Investment Fund (EIF)^[2]. While the former VP left the EIB Group in 2021 to take up his new job, the possibility of him being appointed to become CEO of the same national promotional bank previously arose in 2018.

2. National promotional banks and institutions are legal entities, which carry out financial, development and promotional activities, and which are given a mandate by a Member State at central, regional or local level. The EIB Group^[3] directs its investments in small-scale projects, which are carried out by businesses or local authorities, through national promotional banks, which also act as co-financiers or co-investors, either for individual schemes, investment platforms or investment vehicles.^[4]

3. As a member of the Management Committee of the EIB, the former VP had overall responsibility for institutional relations with entities receiving EIB investments in Italy. For more information on the EIB’s governance, see annex 1.

4. The EIB’s Ethics and Compliance Committee (ECC) is responsible for reviewing and taking decisions on requests of the EIB by current or recent former members of the EIB’s Management Committee related to situations that may result in, or be perceived as resulting in, a conflict between their interests and those of the EIB. Pending the ECC’s decision, they must abstain from taking part in any EIB activity that may result in, or be perceived as resulting in, a conflict between their private or personal interests and those of their employer.

5. In 2018, the former VP proactively sought guidance from the ECC^[5] concerning rumours about the possibility of him being appointed CEO of the national promotional bank in Italy.

6. In its assessment, the ECC took into account the EIB Group’s business with the national promotional bank, its shareholders and related companies, and concluded that the national promotional bank and its related interests were close and regular counterparts for the EIB Group. The national promotional bank is a direct recipient of EIB funds as a borrower, and also co-finances operations and co-invests with the EIB. The national promotional bank also guarantees loans that the EIB signs with Italian counterparties.

7. As a result of its assessment, the ECC identified multiple risks of (actual, potential and perceived) conflicts of interest, and concluded that mitigating measures needed to be put in place to protect the EIB Group and the former VP against these risks. In particular, the ECC decided that the former VP should:

• Avoid any involvement in any business related to the Italian national promotional bank, any business related to companies in which the Italian national promotional bank participates, and any public event linked to the Italian national promotional bank. Until his appointment as CEO, the former VP could perform his role of EIF chair when the role implied an indirect exposure to the Italian national promotional bank as EIF shareholder.
• Abstain from any business with the Italian national promotional bank’s shareholders and from any involvement in the Long Term Investors (LTI) Club^[6].
• Refrain from making any public appearances related to his potential role as CEO of the Italian national promotional bank before the formal confirmation of his appointment.
• Abstain from any discussion and decision in any EIB Group governing body concerning operations, projects and other proposals linked to the Italian national promotional bank, its shareholders and related entities.
• If his appointment as CEO is confirmed, immediately resign from his position as a management committee member and chair of the EIF.

8. On that occasion the former VP was not appointed as CEO of the national promotional bank in question and continued in his position as member of the EIB’s Management Committee and as chair of the Board of Directors of the EIF.

9. In April 2021, the former VP informed the EIB Group’s chief compliance officer (CCO) of informal rumours that he was once again being considered for the post of CEO of the national promotional bank in Italy. The CCO advised the former VP to respect the mitigating measures set out in the 2018 ECC decision until such time as the former VP sought to the have the 2018 decision of the ECC updated.

10. On 27 May 2021, the former VP tendered his resignation from his functions in the EIB Group, in order to take up his new job as CEO of the national promotional bank of Italy, starting on 1 June 2021.

11. The complainant was concerned that the move posed conflict of interest risks. He alleged that there had been various irregularities in how the EIB Group had handled the former VP’s move to his new employer, including breaches of the EIB’s code of conduct for members of its Management Committee and Board of Directors of the EIF.

The inquiry

12. The Ombudsman opened an inquiry into whether the EIB:

• sufficiently verified that no conflict of interest arose, whether actual, potential or perceived, in the context of the move of its former VP to the national promotional bank of Italy; and
• ensured that sufficient safeguards were put in place to prevent the former VP from using EIB information and contacts acquired in the service of the EIB.

13. In the course of the inquiry, the Ombudsman received replies from the EIB in response to two separate requests for information^[7] and, subsequently, the comments of the complainant in response to the EIB's replies^[8]. The Ombudsman inquiry team also inspected the EIB's file in this case.

14. Based on the inspection of relevant EIB documents, the Ombudsman inquiry team drew up timelines of the prospective move in 2018 and the steps followed in the context of the former VP’s notification about the potential move in 2021. (See annex 2.)

Risks of conflicts of interest related to a post mandate job

Arguments presented by the complainant

15. According to the complainant, the conclusions in the ECC decision concerning the prospective move by former VP in 2018 were not limited to that specific request but should have applied by extension to the situation in 2021, when the former VP notified essentially the same post mandate activity. The complainant acknowledged that, when the former VP was not appointed CEO of the national promotional bank of Italy in 2018, there were no longer any grounds for applying the mitigating measures set out in the 2018 ECC decision. However, given that the same conflict of interest risks arose again in 2021, the same mitigating measures should again have been applied, and complied with, in the absence of a new ECC decision that came to a different conclusion.

16. The complainant contended that, after the former VP notified the CCO in April 2021 of his possible appointment to the Italian national promotional bank, this should have been submitted to the ECC for consideration, as it concerned a potential conflict of interest.

17. The complainant contended that, even if the former VP himself did not notify the ECC, this should have been done by the relevant entities within the EIB (for example the CCO), as soon as they became aware of the move, in accordance with the EIB’s rules.^[9] However, no such notification was made. Apart from the former VP and the CCO, no other EIB staff members were aware of the intended post mandate activity.

18. The complainant also observed that no recusals were made, or abstentions recorded, in relation to the former VP’s participation in approvals of EIB Group financing agreements with the national promotional bank in May 2021. He claimed that, as the EIB did not consider this to be of any consequence, this demonstrates that the EIB failed to monitor and follow up on how the former VP complied with his obligations under the Management Committee’s code of conduct and with the recommendations of the 2018 ECC decision. The complainant argued that this undermined accountability and transparency.

19. Furthermore, the complainant claimed that the ECC itself lacks both independence and transparency, as it is composed of EIB insiders and its decisions are not made public.

Arguments presented by the EIB

20. The EIB stated that the mitigation measures set out by the ECC in 2018 were deemed to be applicable until a formal decision on the appointment of the CEO of the national promotional bank had been made. In the EIB’s view, this meant that the mitigating measures ceased to apply as of 27 July 2018, when the national promotional bank’s appointment process was concluded and where the former VP was not appointed.

21. During 2018, the former VP was recorded as absent in the EIB’s Management Committee minutes from items that related to the national promotional bank in question.

22. On 14 March 2019, the EIB made changes to the Management Committee’s code of conduct^[10], including the applicable procedure in relation to post-mandate activities that management committee members intend to undertake during any ‘cooling-off period’ following their mandate. Following this, members of the Management Committee no longer need to declare to the ECC or seek its approval for employment in a public-service capacity and any official public position in an EU Member State or in any of its public institutions.^[11] The EIB said it made this change to reflect a similar rationale applied by the European Commission in its rules for commissioners, as well as past ECC decisions, and the alignment between EIB interests and those of public sector financial institutions.

23. The EIB maintained that the post of CEO of the national promotional bank in question qualified as a public-service capacity role and that it did not need to be declared to the ECC^[12]. This is because the Italian government is an 84% shareholder of the national promotional bank, which is a national promotional institution, and participates alongside the EIB in common initiatives and financings.

24. The EIB acknowledged that the situation that arose in 2021 was substantially the same as in 2018. However, in its reply to the Ombudsman, it stated that, even if the former VP was recommended by the CCO to follow the same mitigating measures as a matter of precaution, this advice did not constitute an opinion of the ECC.

25. In May 2021, the former VP participated in meetings of the EIB and the EIF in which financing agreements with the national promotional bank of Italy were approved. There was no evidence that the former VP abstained or recused himself from these decision-making processes. The EIB said that the collegial nature of the EIB’s Management Committee and the EIF’s Board of Directors, meant that the vote of the former VP had not been a determining factor in any decision and the former VP had also not exercised any casting vote as chair of the Board of Directors of the EIF.

26. On 27 May 2021, the EIB was informed by the former VP that he had been appointed as CEO of the national promotional bank of Italy. The former VP tendered resignations regarding his roles in the EIB’s Management Committee and the EIF’s Board of Directors with immediate effect and commenced his post mandate activity on 1 June 2021.

The Ombudsman's assessment

27. As the EIB Group is managing ever greater volumes of financing^[13], there will be a growing public expectation that the EIB Group has in place comprehensive rules and standards on transparency and integrity in office. Applying these rules also implies a proactive commitment to preventing conflicts of interest and managing any potential risks where they arise. The failure to do so poses not only reputational risks for the EIB, but also to the credibility and viability of the important actions it helps finance.

28. In this context, ‘revolving door’ moves by senior public officials, as well as those that have recently left office, should be properly assessed to determine whether they give rise to the risks of actual, potential or perceived conflicts of interest. The EIB must strive to take all reasonable steps to identify such risks and, where they arise, manage or mitigate them in a timely and efficient manner.

29. Management Committee members, who can also be members of the Board of Directors of the EIF, are senior officials of the EIB Group. As such, they are expected to uphold the EIB’s objectives: to act loyally, honestly and impartially and to subscribe to high standards of professional ethics. They must discharge their professional duties diligently, efficiently and to the best of their abilities.

30. The composition of the ECC includes, aside from experienced EIB directors, the chair of the EIB audit committee, which is a statutory body that is independent from the EIB Board of Directors and the EIB’s Management Committee, and reports directly to the EIB Board of Governors.^[14] The Ombudsman notes that the chair of the ECC may request the EIB to engage external advisors of high professional standing and experience for ECC functions on an ad hoc basis.

31. In a previous inquiry concerning the post-mandate activities of a former VP and Management Committee member^[15], the Ombudsman found that, in approving the move, the EIB did not properly manage the risk of conflicts of interest that arose. The inquiry concluded that the EIB should have taken a more robust approach to revolving door moves of its Management Committee members to jobs related to matters on which they worked while in the service of the EIB. However, given that the EIB had, in August 2021, made improvements to the relevant ethics rules to address these matters^[16], the Ombudsman determined that no further inquiries were justified. The improvements that the EIB made in 2021 included the requirement that, for intended post-mandate employment in a public-service capacity by (former) EIB Management Committee members during their ‘cooling-off period’, the (former) members are required to submit a declaration to the ECC chair. This is done in order to keep a record within the EIB of all appointments held by former Management Committee members. However, such moves to roles considered as being with ‘public service capacity’ entities were still not subject to the authorisation of the ECC.^[17]

32. The Ombudsman fails to understand why intended post-mandate activities in a public service capacity are categorically exempt from ECC authorisation. This case clearly illustrates why appointments to positions to entities the EIB considers having a public service function may pose conflict of interest risks, whether actual, potential or perceived. In 2018, the ECC identified multiple risks of actual, potential and perceived conflicts of interest associated with the potential move of the former VP to the Italian national promotional bank, in circumstances that the EIB considered substantially the same in 2021 (see paragraph 24).

33. The EIB argued that it had changed its rules in 2019, exempting public service capacities from the requirement of ECC notification and authorisation, in part because it contended that the European Commission has similar provisions for commissioners. However, the Commission’s code of conduct requires (former) commissioners to notify intended post-mandate activities in the public sector to the Commission, and leaves open the option for the Commission President to seek an opinion of the Independent Ethical Committee where the intended post-mandate activity is in the public sector.

34. It is unclear why the EIB deemed there was a risk of a conflict in 2018 but, in 2021, this risk did not exist, simply because the EIB changed the rules.

35. It is hard to avoid the conclusion that how the EIB handled the former VP’s prospective move in 2021 fell short of how it had previously handled essentially the same situation. Unlike in 2018, the former VP did not notify the ECC in a timely manner but, rather, only after the appointment was confirmed. While the former VP did inform the CCO, and the CCO advised him to respect the same mitigating measures that were set out by the ECC in 2018, the EIB in its reply to the Ombudsman stated that this advice was non-binding. As this inquiry has shown, it also appears that this advice was not complied with: there was no evidence that the former VP recused himself from, or abstained from, participation in approving financing agreements with the national promotional bank of Italy between 4 and 11 May 2021 and the members of the Management Committee and the Board of Directors of the EIF were also not notified about the preemptive measures that the former VP had been advised to apply.

36. The Ombudsman does not find reassuring the EIB’s argument that the former VP’s participation in the approval processes in these financing agreements was not a determining factor in the approvals (that is, due to the collegial nature of the EIB Group’s decision-making rules and that he did not exercise casting votes as chair of the EIF Board of Directors). The former VP, who was also chair of the EIF, was aware that there was a possibility that he would be appointed as CEO of the national promotional bank of Italy within a matter of weeks. At the very least, the former VP’s participation in these approvals created the perception of a conflict of interest. It was precisely this risk that the ECC sought to address with the mitigating measures it set out in 2018.

37. Separate and distinct from any obligations of the former VP to declare and/or seek approval from the ECC in relation to post mandate activities during any cooling-off period, the  Management Committee’s code of conduct (which was applicable in May 2021) includes provisions on identifying and avoiding conflicts of interest, which it defined as situations where private or personal interests may influence, or appear to influence, the impartial and objective performance by members of the Management Committee of their duties.^[18] The possibility of being appointed as CEO of a close and regular counterpart of the EIB Group that is also recipient of EIB financing, is a significant personal interest and one that should have been assessed by the ECC. The code of conduct requires that, where such a conflict arises, members of the Management Committee declare this immediately to the ECC and, pending the ECC decision, abstain from taking part in any EIB activity that is connected to their private or personal interests. The code of conduct does not differentiate between categories of borrowers, for example between private companies or national promotional banks.

38. In light of the above, the Ombudsman finds that how the EIB dealt with the risks of conflicts of interest in this case was inadequate and constituted maladministration. However, as this can no longer be remedied for this particular case, the Ombudsman makes a corresponding suggestion for improvement below. She very much hopes that the EIB will act on this suggestion to seek to avoid similar situations arising in future.

39. The Ombudsman is aware that the EIB shares ECC decisions with relevant EIB staff on a need-to-know basis. The Ombudsman is of the view that this is not sufficient. Rather, ECC decisions should be made public so that there is greater awareness of the mitigating measures that the ECC has adopted to protect the EIB’s, and the public’s, interests. In this context, the Ombudsman notes that the European Commission makes public the opinions of its Independent Ethical Committee.^[19] In December 2022, the EIB committed to considering making ECC decisions public as a follow up to a decision of the Ombudsman^[20], saying that such a step would require modification of rules applicable to the ECC, which requires approval of the EIB’s Board of Governors. In light of proposed reform of the EIB’s Management Committee, the Ombudsman urges the EIB to accelerate this process, if it is not yet completed.

Risks of misuse of EIB information and contacts

Arguments presented by the complainant

40. The complainant argued that the former VP was nominated for his new position because of his privileged relationship with public office holders at the highest level of government in Italy. According to the complainant, this was in breach of the EIB’s Management Committee code of conduct.^[21]

41. The complainant also alleged that the former VP lobbied EIB Group staff members to join him at his new employer.

42. The complainant said that the Italian national promotional bank is one of the EIB's most important financing counterparts, in terms of the funds it processes and borrows. It also participates in a number of other important EIB counterparts. Given his oversight for lending in Italy, the former VP therefore also has knowledge of one or more companies or bodies that have direct or indirect relations with the EIB, which he would be able to use in his new position.^[22]

Arguments presented by the EIB

43. The EIB stated that, when it was notified about the former VP’s post-mandate activity at Italian national promotional bank, the ECC informed the former VP that he:

• was strictly bound by the obligation of confidentiality in respect of information received in the course of his duties, in accordance with the relevant EIB rules, policies and guidelines; and
• must abstain from lobbying activities with EIB governing bodies and staff on matters falling in his portfolio of activities as a member of the Management Committee during his mandate until the end of the cooling-off period.

The ECC also suggested that the former VP’s contract with his new employer should not contain any clause preventing him from declaring any personal conflict of interest situation arising before the end of the cooling-off period to the ECC, which could then decide on the appropriate measures.^[23]

44. The EIB also said that it verified the former VP’s compliance with the obligation of confidentiality by monitoring the media. It could also become aware of compliance issues through possible whistleblowing reports or complaints through the EIB Complaints Mechanism, should there have been such reports or complaints. The EIB said that it is not aware that the former VP promoted his own interests or lobbied EIB Group staff members.

45. The EIB did not apply any mitigating measure that would have prevented the former VP from recruiting or offering job opportunities to EIB staff members. The EIB said that, in monitoring the risks for conflicts of interest, it focuses on EIB Group staff members’ requests themselves, rather than on the source of their recruitment. Since May 2021, the EIB has approved three requests from staff members to take up posts with the Italian national promotional bank while on unpaid leave. In these cases, the decisions authorising the moves imposed a number of measures to mitigate any risks, including a prohibition on any involvement in direct operations (including negotiations between the national promotional bank and the EIB Group) and an obligation to promptly report to the EIB any conflict of interest or reputational risks arising from undertaking the activity. In the same period, the EIF has approved one request to take up a post with the Italian national promotional bank, imposing similar conditions.

46. The office of the CCO, in reply to the complainant, said that it carefully examined all the information provided by the complainant, including as regards the allegations relating to the use of inside information.^[24] The EIB noted that the information at issue all came from publicly available sources and did not substantiate the complainant’s claims, nor justify further investigation. Additionally, the EIB Group said it did not have the authority to investigate allegations on the use of inside information taking place in entities other than the EIB Group. In those circumstances, it would be for the relevant national authorities to investigate such allegations. However, the EIB Group had no sufficient reason to forward the allegation to the Italian authorities.

The Ombudsman's assessment

47. In relation to the ECC’s suggestion that the former VP’s contract with his new employer should not contain any clause preventing him from declaring any personal conflict of interest situation arising before the end of the cooling-off period to the ECC, the Ombudsman notes that this measure refers to an obligation that is binding^[25], and that this should arguably be communicated as such. To address this issue, the Ombudsman will make a suggestion for improvement below.

48. The Ombudsman considers warranted the measures imposed by the EIB to safeguard the EIB information and contacts acquired by the former VP. However, those measures could have been clearer so as to also explicitly refer to the former VP’s capacity as chair of the Board of Directors of the EIF. This is captured by the suggestion for improvement below.

49. Overall, the Ombudsman finds reasonable the EIB Group’s approach to assessing requests for external activities of staff members on unpaid leave.

50. In relation to the complainant’s other allegations, including the use of insider information post-mandate, the Ombudsman finds the EIB’s response to the evidence that was presented to it, also reasonable.

Conclusion

Based on the inquiry, the Ombudsman closes this case with the following conclusion:

How the EIB dealt with the risks of conflicts of interest in this case was inadequate and constituted maladministration. However, as this can no longer be remedied in this particular case, the Ombudsman closes this inquiry with suggestions for improvement that, if implemented, could help the EIB Group avoid similar issues arising in future.

The complainant and the EIB Group will be informed of this decision.

Suggestions for improvement

I. The EIB should ensure that, where a member of its Management Committee intends to take up a post mandate activity in an entity that the EIB considers to perform a public-service function, and where that post may give rise to conflict of interest risks, the move should require the authorisation of the ECC.

II. When the ECC adopts decisions in relation to an EIB Management Committee member who also chairs the EIF’s Board of Directors, the mitigating measures that the ECC adopts should reflect the dual role of that position-holder and refer not only to the Management Committee functions but also the functions of EIF Board of Directors.

III. The ECC should remind former members of the EIB Management Committee, where they take up post-mandate activities, that they are obliged to ensure that their contracts do not contain any clause preventing them from declaring to the ECC any personal conflict of interest situation arising before the end of their ‘cooling-off period’.

 

Emily O'Reilly
European Ombudsman

Strasbourg, 31/10/2023

 

 

[1] Cassa Depositi & Prestiti SpA (referred to as CDP) is the national promotional bank of Italy. CDP was declared the Italian National Promotion Institution in 2015.

[2] The EIF’s Board of Directors consists of members designated by the three shareholder groups, is chaired by an EIB Management Committee Vice-President and is responsible for approving EIF's operations.

[3] The European Investment Bank Group (EIB Group) consists of two member institutions: the European

Investment Bank (EIB) and the European Investment Fund (EIF). The EIB provides long term lending to promote European objectives. For more details, see: https://www.eib.org/en/about/priorities/index. The EIF is a specialist provider of risk finance to benefit small and medium-sized enterprises (SMEs) across Europe. The EIF’s shareholders are the EIB, the EU (represented by the European Commission), and a range of public and private banks and financial institutions.

[4] More information: https://www.eib.org/en/about/partners/npbis/index.htm

[5] The Ethics and Compliance Committee (ECC) is established pursuant to Art. 11.4 of the Rules of Procedure of the EIB. The ECC consists of the four longest-serving members of the EIB’s Board of Directors who have volunteered to participate in its activities and of the Chairman of the Audit Committee. See: https://www.eib.org/attachments/general/operating_rules_ethics_and_compliance_en.pdf. 

[6] In 2009, the EIB, together with a number of national promotional banks, created the Long-Term Investors Club, with the aim of bringing together major worldwide institutions to emphasis common identity as long-term investors, to encourage cooperation and to foster the right conditions for long-term investments in promoting growth. See for more info: https://www.d20-ltic.org/ 

[7] See: https://www.ombudsman.europa.eu/en/opening-summary/en/157574, and https://www.ombudsman.europa.eu/en/doc/correspondence/en/168143.

[8] Comments sent on 2 March 2023, see: https://www.ombudsman.europa.eu/en/doc/correspondence/en/177035, and comments sent on 3 July 2023, see: https://www.ombudsman.europa.eu/en/doc/correspondence/en/177036

[9] For example, a request could have been made by the chairman of the Board of Governors, any member of the ECC, any member of the Board of Directors, the Management Committee or the Audit Committee, the Secretary-General and the Chief Compliance Officer (CCO). See Article 4 and 7 of the ECC’s Operating Rules that were in force at the time; https://www.eib.org/attachments/general/operating_rules_ethics_and_compliance_en.pdf.

[10] See the 2019 EIB MC code of conduct: https://www.eib.org/en/publications/management-committee-code-of-conduct.

[11] Also exempt from ECC notification and approval is employment with, or membership of, the Board of Directors or equivalent decision-making body of international organisations or multilateral or bilateral financial institutions.

[12] In line with Article 4 paragraph 3 of the 2019 management committee code of conduct, see footnote 11.

[13] See: https://www.eib.org/en/about/key-figures/index .

[14] See Article 13.4 of the ECC operating rules, see footnote 10.

[15] Decision on how the European Investment Bank (EIB) handled the move of a former Vice-President to an energy utility company that had received EIB loans (1016/2021/KR). See: https://www.ombudsman.europa.eu/en/decision/en/158894.

[16] These improvements included:

- Adding a statement on the EIB’s ‘core values’ and obligations deriving from those values.

Improving the provisions on independence and prohibited conduct.

- Clarifying and providing guidance on concepts of actual, potential and perceived conflict of interest situations, including on related disclosure requirements and the applicable procedure.

- Clarifying the extent of internal and external relations, including on the nature of outside activities not connected to the EIB’s work and political activities.

- Extending from 12 to 24 months the ‘cooling-off period’ for members of the EIB’s Management Committee. 

[17] See Article 6.2, see: https://www.eib.org/attachments/publications/code_of_conduct_mc_en.pdf.
This is duly reflected in Article 4(5) of the 2021 ECC operating rules, see:  https://www.eib.org/attachments/publications/board_directors_ecc_operating_rules_en.pdf.

[18] In line with Article 1.8 of the 2019 management committee code of conduct, see footnote 11.

[19] See: https://commission.europa.eu/about-european-commission/service-standards-and-principles/ethics-and-good-administration/commissioners-and-ethics/former-european-commissioners-authorised-occupations_en.

[20] See footnote 16.

[21] The complainant referred to Articles 1.4 (Basic standards of conduct) and 1.9 (Personal advantages) in this context. See footnote 11.

[22] In violation of Article 1.10 of the code of conduct, see footnote 11.

[23] In line with Article 1.1.2. of the ECC Operating Rules applicable at the time, see: https://www.eib.org/attachments/general/operating_rules_ethics_and_compliance_en.pdf.

[24] See Article 7 of Regulation 596/2014, where inside information is defined as information that i) relates, directly or indirectly, to particular financial instruments or issuers; ii) is of a precise nature; iii) has not been made public; and iv) if it were made public, would be likely to have a significant effect on the price of those instruments. See: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0596-20210101.

[25] See Article 4 of the 2019 MC code of conduct (footnote 11).