As a follow up to a previous inquiry, the Ombudsman carried out an own-initiative inquiry into how the Commission handles 'revolving doors' situations of staff members who apply to take up an outside activity while on unpaid leave on personal grounds, and (former) staff members who apply for approval to take up an activity after leaving the Commission. The inquiry looked at 100 revolving door files, and revealed significant improvements since the previous inquiry, including guidance to ensure a more rigorous examination of each move.

The inquiry showed that, in some instances, the Commission approved requests from former senior staff members to take up activities, despite reservations as to whether the applicable conditions would mitigate the potential risks (such as conflicts of interest and access to knowledge or contacts within the administration). The Ombudsman found that such moves should be authorised only where the activity can be made subject to restrictions that adequately mitigate the risks and be credibly monitored and enforced; this could include obliging the new employer to make public the restrictions. Where this is not possible, the Commission should not authorise the activity. The same is true regarding the external activities of staff members on leave on personal grounds, for which the inquiry revealed some shortcomings in how the risks were assessed, particularly when approvals for existing activities are renewed.

The difficulties encountered by the Commission in monitoring compliance also led the Ombudsman to reiterate her suggestion that the Commission publish in a more timely way information on all post-service activities of senior former staff members that it assesses. This would improve public scrutiny of these decisions, which is essential for monitoring purposes.