Thank you for inviting me. It is good to be here this evening.

A core aspect of my mission as European Ombudswoman is to ensure that EU law and policymaking is done in a way that is - first and foremost - transparent, inclusive, based on the applicable rules and procedures, and in the public interest.

This means that my work often focuses on examining not only how EU laws are made, but also who took part in this process and how influence was exerted.

I think it is useful to recall that the right to participate in EU decision-making processes is a democratic principle protected by EU law.

With this in mind, when it comes to the health of a representative democracy, lobbying can be said to be a somewhat paradoxical concept.

On the one hand, transparent and well-regulated lobbying activities provides citizens, businesses, and organisations an effective means to express their views and participate in decision-making, while also facilitating access to vital expertise and data for decision makers.

On the other hand, lobbying can exacerbate existing inequalities, leading to the adoption of laws that may end up benefiting narrower and more specific interests over the broader interests of society at large. Something that - ultimately - will undermine people’s faith in the decisions-makers, and in our case, in the EU institutions.

When we hear about lobbying in the media, or even in casual and informal discussions, it is most often in a negative context, namely complaints about the withdrawal or watering down of climate, health, or safety regulations due to industry pressure and/or demands. And sometimes, such external demands or pressure may regrettably translate into downright corruption or illegal practices.

In the EU, a series of recent press-revealed cases like the Uber files, Qatargate, or the recent allegations concerning Huawei, have damaged not only the reputation of the EU institutions but also the reputation of the public affairs industry.

At a time when many citizens feel unheard or disconnected from their public institutions, when they perceive them as obstacles rather than enablers of their aspirations, such scandals become even more harmful than usual. Each and every one chips away at the fragile trust underpinning not only our Union but also faith in the democratic foundations of the EU.

However, it would be a mistake to focus exclusively on the big headline-grabbing scandals.

Not only because it totally obliterates the positive efforts and outcomes of the institutions, but more importantly because seemingly smaller problems, if left unchecked, will grow even bigger and even worse. In a way, it is a culture of complacency that makes big scandals more likely over time.

Allow me to share with you some examples of the kind of issues my Office has dealt with when it comes to the EU institutions’ interactions with interest representatives, as well as some of the improvements we have managed to bring about—improvements that increase public trust in policy makers.

Tobacco lobbying is a good place to begin with. Europeans want to be sure that the interactions the EU administration has with the tobacco industry does not result in lower public health standards or legal loopholes for harmful products.

As a signatory to the World Health Organization’s Framework Convention on Tobacco Control, the EU is obliged to limit its interactions with the tobacco industry to those strictly necessary for regulation and to ensure those interactions are transparent.

Despite this, an own-initiative inquiry we conducted revealed that only two European Commission departments—health and taxation and customs—proactively make public interactions of EU officials with tobacco lobbyists, irrespective of the seniority of the staff involved. Other Commission departments only proactively publish meeting information involving senior officials or commissioners.

We also found that the Commission has no specific procedure or rules for assessing whether individual meetings were, in fact, necessary for regulation, and that meeting minutes were sometimes missing or failed to provide a meaningful account of such interactions and discussions.

Without proper and detailed minutes, it is difficult to see how the Commission can reassure the public that these meetings do not undermine the EU’s public health policies.

Following the publication of our findings, the Commission has conducted an assessment of the exposure of its departments to tobacco lobbying and reported that there is now increased awareness among EU staff when it comes to compliance with the provisions on tobacco lobbying. It also said it was preparing a toolbox of various measures that departments and Commissioners’ cabinets can put into place, such as the avoidance of conferences with major tobacco industry involvement or procedures to ensure the consultation of senior management prior to the acceptance of any meeting.

A different lobbying-related inquiry concerned the Transparency Register, something I believe you are all familiar with as it is a prerequisite to meeting with EU officials, and plays a vital role in demonstrating the public affairs industry’s commitment to transparency.

While the Register itself is a big positive for how lobbying is handled in the EU, it is not without its weaknesses.

For instance, in one inquiry we found problems with how the EU’s Transparency Register Secretariat handled complaints that two registered organisations had failed to disclose their links with the food industry and with each other, as well as the sources of their funding. While the Secretariat did ask for clarifications from the organisations, it carried out a rather limited assessment of the replies it received while also applying an excessively narrow definition of affiliation.

Given that the Secretariat does not have the means to monitor all the information it receives from registered organisations, it is crucial that it takes these types of public complaints seriously and investigates them thoroughly.

We made a number of suggestions for improvement and the Secretariat responded positively, acknowledging the problems we identified and highlighting that it is updating its guidelines when it comes to understanding affiliation.

Another issue we have dealt with is professional conflicts of interest.

In one inquiry, we examined the Commission’s decision to award to the investment management firm Blackrock a contract to conduct a study concerning the integration of environmental, social, and governance objectives into the EU banking supervision system.

The contract was awarded despite the fact that the study topic was one of clear regulatory interest to Blackrock and that the company had already tried to influence policy making in this area through other means.

In response to our suggestions in this case, the Commission updated its internal procurement guidelines to make clear to its staff that bidders with professional conflicts of interest should be excluded. Later on, the EU law governing public procurement procedures financed by its budget was also updated to exclude such bidders.

These examples highlight the importance of staying vigilant when it comes to ensuring transparency and accountability in the EU administration with regard to the role of groups and organisations that try to influence the formulation or implementation of EU policy and legislation.

However, it is important to acknowledge that the actions of the EU institutions are only one side of the coin. It is equally important that public affairs professionals hold themselves to the very highest standards in their interactions with the administration.

Public affairs consultants and consultancies, by virtue of their access and expertise, are uniquely placed to act not only as representatives of their client’s interests but also as guardians of democratic integrity. By setting internal standards that exceed regulatory requirements, it is possible to ensure that influence is exercised responsibly and in the service of transparency and a stronger Europe.

In that sense, I welcome that organisations such as yours strive to ensure strong ethical standards in the industry itself. Your Code of Conduct includes a number of important commitments for public affairs professionals, such as avoiding professional conflicts of interests as well as signing up to the EU Transparency Register and advising your clients to do so.

This said, there is always room for more ambition, whether for the association as a whole, or for the individual consultant or public affairs professional.

The issue of revolving doors provides us with an interesting case study. Over the years, we have seen plenty of reports concerning high-ranking EU officials leaving their posts to take up posts relevant to their EU experience and knowledge in the private sector. They will often find themselves employed by law firms or consultancies operating in the same economic sectors that they were previously responsible for regulating.

At the European Ombudsman, we have already looked into a number of cases of revolving doors and found, for instance, that the European Banking Authority should not have allowed its executive director to join a major financial lobbying firm or that the European Defence Agency should have forbidden its chief executive from becoming a strategic advisor at an aerospace company.

When we conducted a broad analysis of how the European Commission handles revolving door cases, we also found that the institution had a tendency to underestimate the corrosive effects on public trust of officials bringing their knowledge and networks to related areas in the private sector.

Indeed, in some cases, there can be a striking difference between, on the one hand, an EU institution or body reassuring the public that the post-term employment situation of a former senior official is in line with the applicable staff and ethical rules, and that an in-depth analysis has been carried out and restrictions, where necessary, have been imposed on the person concerned; and, on the other hand, the ‘new hire’ announcement made by the new employer of the former official often proudly detailing his or her regulatory expertise and connections in the areas covered by said firm.

There have been some welcome improvements, such as the Commission now forbidding staff on unpaid leave from taking employment in sectors with conflict of interest risks.

However, in other areas, such as the monitoring of the restrictions placed on individuals moving to the private sector, resistance remains. If properly monitored and enforced, restrictions on - for example - benefiting from professional contacts in the institutions or providing confidential information could go a long way in easing public disquiet around revolving door moves.

As Ombudswoman my role is not to rewrite existing rules or enact new rules, but to make suggestions, proposals, and ultimately formal recommendations to the EU administration. Nevertheless, Icannot help but wonder if there is also a part to play for organisations like yours.

I find it very positive that your Code of Conduct already requires members to only employ former EU personnel according to the rules and confidentiality requirements of the EU institutions.

At the same time, it is not impossible to envision public affairs consultancies going further. For instance, in the inquiry I just mentioned, we had suggested the Commission make its approval of a new job conditional on the staff member obtaining a commitment from their new employer to publish any restrictions they face on its website.

The Commission has so far resisted this suggestion because of the fear that it could impinge on the privacy of the person concerned and the confidentiality of employment contracts.

But.

This does not preclude you or your clients from taking the lead and making public such restrictions either on your website or in the press releases announcing new hires. Officials may be also required to ensure that such restrictions are inserted into their new employment contracts.

Such steps have the potential to further show EU citizens that the public affairs industry treats their ethical responsibilities with the utmost seriousness when it comes to hiring former EU officials and that revolving doors are not associated in the public’s mind with the negative perception I have just described.

Before concluding, I would like to touch on one further aspect of responsible lobbying that goes beyond compliance with formal rules and responsibilities, namely the need to always view one’s own work within the bigger picture.

There is, without a doubt, a huge number of talented people in the public affairs industry, people with the ability to translate technical content and sophisticated ideas into clear and accessible messages.

This helps policy makers navigate complex and multifaceted subjects in a way that leads to better law making; it can drive scientific innovation and societal progress, and ensure that the voices of vital industries are always heard and well understood.

I am referring to this because - as we all know - it can also do the opposite, especially if one becomes laser-focused on improving the short-term bottom line at the long-term expense of everything else.

It has become all too common to hear about ambitious legislative proposals in diverse areas like consumer rights, environmental protection, artificial intelligence, or public health being gradually diluted or undermined by complex, well-organised, and well-financed lobbying operations.

We find ourselves in the midst of tumultuous times. An increasing number of people feel left behind, both economically and socially. Geopolitical shifts, a highly transactional world, and rapid technological changes, have led to heightened anxiety about the future. Climate change, once mainly the subject of academic discussions about polar ice caps and temperature increases, has made itself manifest through a series of ferocious forest fires, droughts, and floods.

In times like these, true talent requires thoughtful stewardship. That does not necessarily mean refusing to represent this or that particular client or industry, but applying a reflective and holistic approach to the work that you do and striving to ensure that strong and professional advocacy can also contribute to a better future, a better Europe, and a better world. You have the attention of the companies you serve and of the EU administration. Ask yourselves what it is that you truly want to say.

Thank you.