The complainants were concerned that the European Commission did not correctly apply its internal rules on identifying and mitigating potential conflicts of interest in the context of the appointment of a special adviser to the EU High Representative for Foreign Affairs and Security Policy, who is also a Commission Vice-President. In particular, the complainants argued the Commission failed to take sufficient steps to mitigate any potential conflicts of interest arising from the special adviser's ongoing role in an Italian energy company.

The Ombudsman did not find sufficient grounds to open an inquiry into the complaint as the contract of the special adviser has expired and the Commission stated that it did not make use of her services. Furthermore, the Commission acknowledged that there were procedural shortcomings in the conflict of interest assessment at the time.