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(DRAFT) Practical guidelines for public officials’ interaction with interest representatives



1. Verify that interest representatives have registered in the EU (or equivalent national) Transparency Register before meeting them or accepting an invitation to an event.

1. Meet interest representatives not registered in the EU (or equivalent national) Transparency Register without asking them to register. Make clear, if appropriate, that this is a prerequisite.

2. Conduct basic research to check what interests they represent and who is funding them. Ask for further information, if needed.

2. Overlook the motives of those who seek meetings or invite you to events. Lobbying can be done by a range of professions, including lawyers and consultants.

3. Request interest representatives to disclose, in writing and in advance, the meeting purpose, participants’ names, the issue for discussion and any relevant background information.

3. Accept any invitations to meetings or events which could put your institution in a delicate situation.

4. Inform your hierarchy prior to meetings with interest representatives and debrief them afterwards.

4. Interact with a particular interest representative without considering offering other groups a similar opportunity.

5. Assess any risk of conflicts between your private interests and the public interest and how your interaction might be perceived.

5. Arrange meetings outside office hours, official premises, and without the presence of another colleague.

6. Err on the side of caution. If in doubt, consult as appropriate and if you decide to go ahead, add a note to the file explaining.

6. Share information you are not authorised to share or misuse confidential information.

7. Invite interest representatives to substantiate statements or presentations in writing after meetings or telephone calls.

7. Do or say anything which could be viewed as granting an interest representative preferential treatment.

8. Maintain good record keeping habits, including the meeting date/location, names of participants and issues discussed. Remember that you should use your institution’s official file management system.

8. Give the impression to an interest representative that any particular advice, idea or information could or will be decisive in the decision-making process.

9. Respect the applicable disclosure requirements, for example, at EU level, disclose details of meetings between interest representatives and Commissioners, Cabinet members and Commission Directors-General.

9. Accept hospitality from an interest representative without careful consideration and unless it is in line with the applicable rules.

10. Report unacceptable lobbying practices.

10. Delay in disclosing information on any gifts and hospitality received.