CONFLICT OF INTEREST LAWS IN EU MEMBER STATES

Austria: The Austrian Constitution (1920, last amended 2016) regulates conflicts of interests regarding the President, while the Incompatibility Act (1983, last amended 2013) regulates for Ministers and MPs. The only limitation for the President is not holding any other occupation. This rule also applies to Ministers. The incompatibility committee may grant the participation of Ministers and MPs in the private sector or in state-owned enterprises. Similarly, the responsible agency must approve any outside employment of Civil servants. The approval is based on whether or not a conflict of interests may arise. The only other restriction applicable to Ministers and MPs is that profit-oriented behavior may lead to a loss of mandate. Civil servants, on the other hand, are explicitly obliged to abstain from decision-making when private interests are affected. They are further bound to a six-month-long cooling off period after leaving the service. Oversight differs between officials. Upon approval by the Federal Assembly, the Constitutional Court may begin a procedure against the President for conflict of interest violations. The incompatibility committee is responsible for monitoring and oversight of Ministers and MPs. The committee is elected amongst members of Parliament. In neither case are sanctions specified. For Civil Servants, sanctions include fines and loss of office.

Belgium: Belgium’s conflict of interests laws are rather broad and make few specific requirements for public officials. The Belgian Constitution (1994, last amended 2014) makes a general requirement for Ministers to prevent any conflicts of interests whilst in office. It also forbids MPs from occupying another salaried position. Similarly, the Law on the Senate (2013, last amended 2014) requires that MPs avoid conflicts of interest. In addition, they cannot accept gifts. For Ministers and MPs pursuing other functions is allowed, and no restriction applies to participating in decisions which affect private interests. Conflicts of Interests for Civil Servants are dealt with in the Law on the Budget and Control of administrative and organisational staff (2007). Next to a general clause on preventing conflicts of interests, it restricts Civil Servants from accepting gifts. Additionally, any second paid activities carried out by Civil Servants must be authorized by their superior, and the public sector may grant no unfair advantage to people previously employed as Civil Servants. Ministers, MPs, and Civil Servants face sanctions ranging from fines over imprisonment to a loss of office if they violate conflict of interests law. This is specified in the Penal Code (1867, last amended 2016). No enforcement body is specified for any officials, and no monitoring body exists for Ministers. All the while, the Senate itself functions as monitoring body for Members of Parliament. Similarly, superiors are always responsible for monitoring their Civil Servants’ adherence to conflict of interests legislation. An Office of Ethics and Professional Conduct grants administrative support to these monitoring bodies.

Bulgaria: Both the Bulgarian Constitution (1991, last amended in 2007) and the Conflict of Interest Prevention and Ascertainment Act (2008, as last amended in 2016) regulate that the Head of State, Ministers, and Members of Parliament must generally avoid conflicts of interests. Additionally, it is not allowed to accept gifts or to hold a post which is incompatible with the status of public official. This limitation puts a particular focus on the possible involvement in the management or supervision of private companies. They also may not use any information obtained in their position to serve private interests for one year after ending tenure. The same rules apply to Civil Servants, as laid down in the Code of Conduct for employees of the state (2004). Here Civil Servants are explicitly prevented from being unlimited partners, directors, managers, or advisors of a commercial company. While no sanctions are specified for violating behavior of the Head of State, Ministers and MPs may face fines ranging from BGN 1.000 to BGN 10.000. Civil Servants mainly face disciplinary sanctions ranging from reprimand to discharge. The Commission for Prevention and Ascertainment of Conflict of Interest serves as the monitoring and enforcement body for Head of State and Ministers, while the Anti-Corruption, Conflicts of Interest and Parliamentary Ethics Committee is tasked with these functions for MPs. While no monitoring body is specified for Civil Servants, the Appointing Authority becomes active as enforcement body.

Croatia: The Law on the Prevention of Conflicts of Interests (2011, last amended 2015) defines preventing conflicts of interests as being able to impartially put public interests above private interests. Ministers and Members of Parliament may not accept gifts valued above HRK 500 from the same donor, and may not be part of supervisory or managerial bodies of private companies. If they own shares in a private company of 0.5% or more, they must transfer their consequential management rights to another person for the duration of their mandate. The Constitution (1990, last amended 2010) does not allow the President to follow any other professional activity. For one year after the end of their mandate, the President, Ministers, and MPs may not be part of a supervisory or managerial body in companies, and must continue to submit disclosure statements. The Civil Servants Act (2000, last amended 2015) restricts civil servants from owning a private or public firm and holding government contracts. There is no law stating that any officials must abstain from decisions that affect private interests. In case of violation, the President, Ministers and MPs face fines or administrative sanctions. As in the rules governing conflicts of interests, the monitoring, guidance, and enforcement of these laws fall on the Commission on the Prevention of Conflicts of Interests. Civil servants, instead, can only be subject to administrative sanctions. The Law does not specify any monitoring body, while appointing the chief executive of the State for the enforcement of the law.

Cyprus: Legislation for the conflict of interest regarding the President, Ministers, and Members of Parliament is mainly found in the Constitution, Law for the Prevention of Corruption (1996, amended 2012) and Law on the Incompatibility with the Duties of Certain Officers of Certain Commercial and other related activities (2008). For civil servants such restrictions are mainly provided in the Civil Servants Law 1/1990 (amended 2015). Provisions are also found in the Criminal Code (CAP154), which is applicable to every single person in the jurisdiction of the Republic of Cyprus. There is a restriction for any kind of activity in relation to the private sector for state officials. Civil servants may participate in state-owned companies with the permission of the Minister of Finance. While the laws stipulate restrictions on the financial involvement, and the involvement of persons in decisions affecting private interests, the sanctions are not set out very clearly and enforcement measures are set out in a general context. An issue revolves around the wide immunity cover of the President, Ministers, and MPs, who may not be prosecuted without the consent of the Attorney General.

Czech Republic: No restrictions are made for the Czech Head of State concerning conflicts of interests. The Conflict of Interest Act (2006, last amended 2016) regulates restrictions concerning conflicts of interests for all Ministers, Members of Parliament and Civil Servants. However specifications vary. MPs are bound by a general avoidance of conflicts of interests, may not hold representative functions in private enterprises and may not simultaneously hold policy-making and policy-executive positions. A general restriction on avoiding conflicts of interests also applies to Ministers and Civil Servants. They may also not hold government contracts or accept employment within one year after leaving office with an entity that was under their supervision in the preceding three years. Additionally, Ministers may not hold representative functions in private enterprises. In case of violation, Ministers and Civil Servants may face fines of up to CZK 100,000. Meanwhile, Members of Parliament do not face fines, but may be forced to lay down their mandate in case of violating rules on the incompatibility of service as to the Constitution of the Czech Republic (1992, last amended 2013). No monitoring or enforcement body is specified for MPs. Meanwhile, the Ministry of Justice and Registrar of Notices functions as monitoring body for Ministers and Civil Servants. Sanctions for Ministers and Civil Servants are enforced by the Administrative Courts under the direction of the Ministry of Justice.

Denmark: There are no regulations governing conflicts of interests for the Prime Minister, Ministers or Members of Parliament. The Civil Servants’ Act (2004, last amended 2016) does not allow for Civil Servants to pursue a second occupation if this would constitute a conflict of interests. The Finance Minister gives guidance on this matter. No other regulations exist. 

Estonia: The Estonian Anti-Corruption Act (2012, amended 2016) makes a general restriction for all public officials to partake in an act or decision which affects private or personal economic interests. It also states that Head of State, Ministers, MPs and Civil Servants may not accept gifts or participate in decisions which constitute a conflict of interests. In addition, the Constitution (1992, amended 2015) prevents Ministers and Members of Parliament from holding advisory or managerial positions in private companies. More additional restrictions are specified for Civil Servants. These include engaging in a private or public enterprise, acquiring assets, or holding government contracts. Additionally, a cooling-off period of three years is imposed on Civil Servants who wish to work for an employer they supervised during their tenure. All the while, no sanctions are specified for any public official who violates regulations on conflicts of interests. There are also no monitoring or enforcement bodies in place, which would be able to track conflicts of interest law or provide public officials with guidance.

Finland: There are no general restrictions on conflicts of interests regarding the Finish Head of State. Specifically, the only restriction regards the prohibition for an elected President to continue to hold representative functions. The Criminal Code (1889, last amended in 2016) prevents Ministers, Members of Parliament, and Civil Servants from accepting gifts. Additionally, both Ministers and MPs are required by the Constitution (1999, last amended in 2011) to abstain from decision-making where they have a private interest. A general clause on avoiding positions which may lead to a conflict of interests exists only for Ministers. No further limitations, for example as to outside employment, firm membership or post-employment, are made for any public officials.Sanctions for violating regulations on conflicts of interests exist only for accepting gifts. Here, Ministers, MPs and Civil Servants face a fine or imprisonment of up to two years. No further sanctions are specified. Additionally, no enforcement or monitoring body exists for Ministers and Civil Servants. Meanwhile, the Parliamentary Office is tasked with supervising and enforcing these laws for MPs.

France: The Act on transparency in public life (2013, last amended 2016) declares it to be a duty of all public officials to end any possible conflicts of interests. It further prevents Head of State, Ministers, Members of Parliament, and Civil Servants from holding government contracts. In addition, Members of Parliament and Civil Servants may not hold managerial or advisory functions in private enterprises. This is specified in the Electoral Code (1964, last amended 2015) and the Law No. 83-634 on the rights and obligations of officials (1983, last amended 2016) respectively. Post-employment regulations are only made for Civil Servants, who must notify the administration if they take up employment with an employer that would have constituted a conflict of interest within three years after ending their tenure. No specific law prevents public officials from participating in issues which may affect private interests. If the Head of State, Ministers, and Civil Servants violate laws on conflicts of interests, they face sanctions consisting of a three years imprisonment and a fine of € 200,000. While MPs face these same sanctions, they may also be removed from office if a conflict of interests is not alleviated within 30 days after notice from the Constitutional Court. Moreover, if they exploit their mandate on behalf of a company they have to pay a fine of € 3.750, and if repeated of € 7.500. While the French Supreme Administrative Court functions as monitoring body for the Head of State and Ministers, the bureau of each assembly pursues this function for MPs, and the immediate superior for Civil Servants. The High Authority for Transparency in Public Life serves as enforcement body for all public officials.

Germany: Most conflict of interests restrictions apply to the Head of State, who is not covered by financial disclosure law. The Basic Law (1949, last amended 2014) does not allow for the President to hold a managerial or advisory position, any salaried office or any outside profession. Regulations for other public officials differ depending on status. Members of Parliament are only subject to a general obligation to avoid conflicts of interests. The Act on Federal Ministers (1953, amended 2015) on the other hand bans Ministers from additional paid employment or membership in advisory bodies. All the while, the Civil Servants Law (2009, amended 2016) restricts Civil Servants from accepting gifts, taking up an additional position in government agencies or financed by government, and performing a legislative function. The Constitutional Court is the enforcement body for the Head of State, who may face a trial resulting in administrative sanctions if Parliament authorizes it. The President functions as a monitoring and enforcement body or Ministers and MPs. In case of violations, both may face fines. Civil Servants may face trial before the disciplinary court, which can stipulate sanctions ranging from fines to the loss of public office.

Greece: The two main sources of law for the four categories of persons are the Constitution (regarding the President, Ministers, and MPs) and law 3528/2007 (the Civil Service Code). The latter has been amended to refine and tighten the guidelines on offenses of civil employees. However there remain few points where legislation does not explicitly cover such as accepting gifts and helping family members obtain employment in the public sector. These should be covered however by the existing legislation against corruption which has been enhanced with the ratification of the UN Convention against Corruption. As the Greco report explains: “The legal framework for fighting corruption thus appears to be fairly comprehensive. In spite of this, corruption is widely perceived as a pervasive phenomenon in Greece, a reality recently acknowledged by the Greek authorities at the highest level of the State”.

Hungary: No laws on conflict of interests exist for Hungarian Ministers. However, the Constitution (2011, amended in 2013) obliges the Head of State from removing conflicts of interests immediately. It also declares that the office of President is incompatible with any other state, social, economic and political office or assignment, which would prevent engagement in public or private companies. For Members of Parliament, the Law on National Assembly (2012, last amended 2015) requires avoiding conflicts of interests, especially so if linked with other professions. It also states that MPs may not accept gifts if they exceed the value of a monthly salary. The Law on the Public Servants (2011, amended in 2015) makes a general restriction for Civil Servants to avoid conflicts of interests. In addition, it specifies that a Civil Servant cannot be an executive officer or supervisory board member, and is not eligible for public tenders. No legislation exists on participating in decisions that affect private interests or post-employment of public officials. For the Head of State and Members of Parliament, the National Assembly may vote on a dismissal from mandate with a two-thirds-majority should a violation of conflict of interests exist. In case of violation by Civil Servants, a public warning or reprimand may be imposed. No bodies exist for monitoring or providing guidance, and no enforcement body is specified for the Head of State. For MPs and Civil Servants, the National Assembly Standing Committee and the Hungarian Government Officers Commission respectively function as enforcement bodies.

Ireland: Irish regulations on conflicts of interests are made in separate laws for all public officials. The Constitution of Ireland (1937, last amended 2015) specifies that the Head of State shall not hold any outside employment or emolument. The respective laws for Ministers and Members of Parliament make a general obligation to avoid conflicts of interests. Members of Parliament are restricted from accepting gifts by the Code of Conduct for Members of Seanad Éireann (2002). Moreover, the Constitution impedes them to simultaneously hold a position in both the House of the Oireachtas. Meanwhile, the Code of Conduct for Office Holders (2001) restricts Ministers from carrying out directorship or advisory positions in private companies. Similarly, the Civil Service Code of Standards and Behaviour (2001, last amended 2008) restricts Civil Servants from holding board memberships, and government contracts. Beyond this, they may not accept positions outside the Civil Service or in a consultative function for 12 months after retirement. No monitoring or enforcement body and sanctions are specified for the Head of State. The Ethics in Public Office Act (1995, last amended 2016) foresees fines or imprisonment of up to three years in the case of violations by Ministers, Members of Parliament, or Civil Servants. The Standards in Public Office Commission is responsible for the enforcement of sanctions amongst all three of these officials, and functions as monitoring body for Ministers and MPs. The respective departments and offices are responsible for monitoring amongst Civil Servants.

Italy: According to the Italian Constitution (1947, last amended 2012), the President’s office is incompatible with any other office. The Head of State may also not have held government contracts in the two years before taking office. The Law on Conflicts of Interests for Ministers (2004) restricts Ministers from taking up managerial tasks, being self-employed, having held government contracts in the two years before taking office, and participating in decisions for which they find themselves in a conflict of interests. Only a general clause exists for MPs in the Law on the Prevention and Suppression of Corruption in Public Administration (2012, last amended 2016) which restricts them from carrying out activities relating to administrative functions, goods or service production for government. Conflicts of interests regulations for Civil Servants are laid down in the Code of Conduct for employees of public administrations (2000, last amended 2013) and the Legislative Decree 39 (2013). They may not accept gifts, be CEOs or board members of private companies, or participate in decisions that affect private interests. However, no sanctions are specified for the Head of State, Ministers, MPs and Civil Servants. The Commission for evaluation, transparency and integrity of public administration is responsible for monitoring the Head of State, MPs and Civil Servants where no enforcement body is specified. The Competition Authority provides guidance and enforces the regulations applicable to Ministers.

Latvia: The Latvian Law on Prevention of Conflict of Interest in activities of Public Officials (2002, last amended in 2016) includes a general clause for all public officials to avoid conflicts of interests. Further limitations regarding conflicts of interests are very similar for all public officials. The Head of State, Ministers, and Members of Parliament may not accept gifts, hold shares in private or public companies, or hold government contracts. Meanwhile, Civil Servants are only hindered from accepting gifts or participating in a private company. Furthermore, no public official may become employed or acquire shares of an actor that was previously under their supervision for two years after ending tenure. No laws exist that prevent public officials from participating in a decision which affects private interests. Should public officials violate regulations on conflicts of interests, they may face fines, removal from office or prison sentences. The Corruption Prevention and Combating Bureau functions as monitoring and enforcement body for Head of State, Ministers, MPs, and Civil Servants.

Lithuania: The Law on the Adjustment of Public and Private Interests in the Civil Service (1997, last amended in 2016) includes a general clause on all Lithuanian public officials avoiding conflicts of interest. In addition, they may not accept gifts or take up employment in the executive of a private company for one year after ending tenure. Additionally, the Lithuanian Constitution (1992, last amended in 2003) prevents the Head of State, Ministers, and MPs from holding another office or receiving remuneration for outside employment in a private company. In addition, Members of Parliament may not perform advisory or managerial functions in a commercial enterprise. Only Civil Servants are explicitly prevented from participating in a decision which may affect private interests. While no monitoring body is specified for Head of State, Ministers, and Civil Servants the laws concerning conflicts of interests that regard them are enforced by the Chief Official Ethics Commission, amongst others. Beyond this, the Commission for Ethics and Procedures provides guidance to MPs on how to fully comply with regulations on conflicts of interests. It is also responsible for investigating and enforcing the implementation of these regulations amongst Members of Parliament

Luxembourg: Avoiding conflicts of interests is part of the regulation for Ministers and MPs as set down in the Standing order of the Chamber of deputies (2009, last amended 2015), as well as for Civil Servants according to the General Statute for Civil Servants (2008, last amended 2015). For all public officials, firm ownership is only forbidden if the activity of the firm is under the supervision of the agency or if it has a significant impact on the activity of the agency. Ministers and MPs may not accept gifts valued over €150 while Civil servants may not accept gifts which may put them in a conflict with their obligations. Simultaneously holding a policy-making and a policy-executing position is forbidden as to the Electoral Law (2003, last amended 2013). This also specifies that Ministers or MPs may not be gainfully employed by the state. No general restriction is made for officials participating in decisions which may affect private interests. The President may apply administrative sanctions to Ministers or MPs who violate conflicts of interests. For Civil servants, the enforcement of conflicts of interests law falls on the Disciplinary Committee. It may stipulate administrative or penal sanctions. No body or agency is responsible for monitoring or providing guidance as to conflicts of interests. (Note: The Head of State is a monarch and thus exempted from conflicts of interests laws.)

Malta: As in Malta’s financial disclosure legislation, no restrictions for conflicts of interests apply to the Head of State. Meanwhile, Ministers and Civil Servants are obliged by law to avoid conflicts of interests in general. Additionally, Ministers, MPs and Civil Servants may not accept gifts. The Code of Ethics of Ministers, Parliamentary Secretaries and Parliamentary Assistants (2015) also prevents Ministers from pursuing any second employment. This would include owning a private or public company, or holding advisory positions. Similarly, MPs are prevented from being party to a private enterprise by the Constitution (1964, last amended in 2015). While no specific limits are specified for Civil Servant’s secondary employment, they must ensure not to pursue any activities which cast doubt on their integrity after ending tenure. This is laid down in the Public Administration Act (2009, last amended 2016). All the while, no sanctions for violating conflicts of interests are specified for Ministers or Civil Servants. If Members of Parliament do not alleviate secondary activities in a company, they are forced to resign from their seat. However, no monitoring or enforcement bodies exist for any public officials. 

Netherlands: Few legislative restrictions govern conflicts of interests for Dutch public officials. For Ministers and Members of Parliament, the Constitution (2008) only specifies that simultaneously holding a policy-making and policy-executing position is not allowed. The Rules of Procedure of the Second Chamber (2016) generally restricts conflict of interest and provides for the registration of the gifts. Civil Servants are only restricted from accepting any gifts as to the Law on Civil Servants (1929, amended in 2016). There are no limits as to secondary employment that can be pursued, or as to participating in decisions that affect private interests. In line with the few requirements made, the law specifies no sanctions for public officials who violate existing rules on conflicts of interests. Additionally, the Netherlands does not have monitoring or enforcement bodies to provide guidance or supervise conflicts of interests. (Note: The Head of State is a monarch and thus exempted from conflicts of interests laws.)

Poland: The Polish Law on limitation of economic activity by persons performing public functions (1997, last amended in 2016) sets down that the Head of State, Ministers, Members of Parliament, and Civil Servants may not hold managerial or supervisory functions, hold over 10% of shares in public or private companies, or hold government contracts. Additionally, MPs may not accept gifts and the Principles of Deputies' Ethics (1998) prevents them from participating in decision-making where they have a private interest. Beyond this, the Guidelines for compliance with the rules of the civil service and on the ethics body civil service (2011) and the Act on Employees of State Offices (1982, last amended in 2016) include a general clause for Civil Servants to alleviate all conflicts of interests. They are also not allowed to accept gifts. Polish law makes no regulations as to post-employment of public officials. In case of violations the Constitution (1997, last amended 2009) foresees a loss of mandate for Ministers and MPs. This also applies to the Head of State should the National Assembly vote in favor of removal with a two-thirds-majority. If Civil Servants violate restrictions on conflicts of interests, they face penalties ranging from reprimand to a removal from office. All the while, no monitoring or enforcement bodies exist for the Head of State and Ministers. The Rules and Deputies’ Affairs Committee functions as enforcement body for MPs. The Disciplinary Commission is tasked with this function for Civil Servants.

Portugal: Portugal’s Law establishing the Code of Administrative Procedure (2015) states that anyone holding a public function must ask to be withdrawn from a decision-making process in which he holds a private interest. No further legislation on conflicts of interests exists for the Head of State or for Ministers. According to the Statute for Deputies (1993, last amended 2009), Members of Parliament may not exercise trading activities if they own over 10% of a company’s shares. Additionally, they cannot be members of public companies, or hold government contracts. The Law on career and remuneration schemes for public employees (2008) obliges Civil Servants to generally avoid conflicts of interests. It also includes limitations on owning state-owned enterprises, and holding government contracts. No sanctions for violating laws on conflicts of interests are specified for the Head of State or Ministers. Members of Parliament and Civil Servants however may face a fine for violations. Additionally, breaking laws on conflicts of interests may lead to a loss of mandate for MPs. For Ministers, no enforcement or monitoring bodies are specified. Members of Parliament may turn to the Ethics Committee of the Assembly of Deputies for guidance, while no enforcement body is specified. All the while, the Supreme Court is responsible for enforcement with the Head of State. The President and Secretary of each administrative body are responsible for monitoring, guidance and enforcement amongst Civil Servants.

Romania: Romanian law makes no regulations on conflicts of interests for the Head of State. According to the Transparency Law (2003, amended 2016), Ministers, Members of Parliament, and Civil Servants may not hold managerial positions, or advisory functions in public or private companies. They may also not be self-employed. In addition, Ministers and Civil Servants are prevented from participating in a decision-making process where they have a private interest. No such specification exists for MPs. Only Civil Servants are restricted from assisting family members to obtain employment in the public sector. In addition, they may not pursue employment with an organization which they cooperated with during tenure for three years after leaving public service. Violating regulations on conflicts of interests is punishable with a prison sentence of one to 15 years. This sanction is applicable to all public officials. The National Integrity Agency functions as monitoring body for the Head of State and Ministers. The National Investigation agency is responsible for law enforcement with the Head of State. Additionally, the Control Authority and President serve as enforcement bodies for Ministers and Civil Servants. It is also responsible for providing guidance and verifications for Members of Parliament. However, no enforcement body is specified for MPs.

Slovenia: All Slovenian public officials are obliged to alleviate conflicts of interests immediately, as to the Integrity and Prevention of Corruption Act (2010, amended in 2011). This law further prevents the Head of State, Ministers, and Members of Parliament from accepting gifts, pursuing any other position or employment that generates income, holding supervisory functions in an enterprise, and holding government contracts. In addition, they must immediately withdraw from decision-making where it may affect private interests. The possibilities for Head of State, Ministers, and Members of Parliament to establish business relations with government entities after ending tenure are limited. Slightly fewer restrictions are imposed on Civil Servants. According to the Civil Servants Act (2002) they may not perform activities which harm free competition or public official’s impartiality. This would prevent Civil Servants from holding managerial or advisory positions in public or private companies. All public officials face the same sanctions in case of violations. These may consist of a fine from EUR 400 and 1,200 or removal from office. The Commission for the Prevention of Corruption provides all public officials with training and tracks data on conflicts of interests. It also functions as enforcement body in case of violations by any public official.

Slovakia: Slovakian legislation governing conflicts of interests is laid down in the Constitution (1992, amended in 2004), and in the Constitutional Act on Protection of Public Interest (2004, amended 2005). These laws apply the same limitations to the Head of State, Ministers, Members of Parliament, and Civil Servants. A general clause obliges public officials to generally avoid conflicts of interests. Moreover, accepting gifts, performing entrepreneurial activity in the private or public sector, and holding steering or advisory functions in a company is forbidden. Public officials may not take up employment with any organization that received financial contributions by the state for two years after ending tenure. Finally, public officials are prevented from mediating business contracts with any state-related organizations for themselves or for family members. Violating regulations on conflicts of interests may lead to a loss of wages for up to twelve months, the loss of mandate, or imprisonment for up to twelve years. These sanctions may be applied to all public officials. There is no designated body to provide guidance or monitoring to public officials. All the while, the Committee of the National Council of the Slovak Republic functions as enforcement body for all public officials alike.

Spain: Spanish laws governing conflicts of interests are relatively similar for all public officials, though specified in different laws. Ministers and Civil Servants are obliged to generally alleviate any situations constituting a conflict of interests, and may not accept gifts or pursue any other professional or commercial employment. This would include the ownership of private or public companies, holding government contracts or holding board membership. These regulations are made in the Constitution (1978, last amended 2011), the Law on Transparency, access to information and good governance (2013), and the Law on Incompatibilities for employees in the public sector (1985, last amended 2011), amongst others. The Electoral Law (1985, last amended 2016) makes the same restriction preventing MPs from being chairmen, directors, managers or indirect participators in private companies. No further restrictions apply to MPs. Meanwhile, no sanctions are specified for any kind of violation of laws governing conflicts of interests. No monitoring or enforcement body is specified for MPs. However, the Board of Transparency and Good Governance offers training and makes recommendations for Ministers and Civil Servants. Here, too, no enforcement body is specified. (Note: The Head of State is a monarch and thus exempted from conflicts of interests laws.)

Sweden: The Swedish Public Employment Act (1994, last amended 2016) specifies restrictions governing conflicts of interests for Ministers and Civil Servants. It refers mainly to them not pursuing additional employment, holding another office, or engaging in any activity which may damage their integrity. This would restrict Ministers and Civil Servants from owning private or public firms, and from holding managerial or advisory positions in companies. Ministers face similar requirements which are specified in the Constitution of Sweden (1974, last amended 2015). It includes a general clause on Ministers avoiding any activity which may impair public confidence in their office. Additionally, it prevents Ministers from engaging in managerial or advisory positions in public or private companies via a clause which forbids following any other employment. All the while, no sanctions are specified for public officials who violate any of these requirements. The Committee on the Constitution is responsible for providing guidance and supervision to Ministers, MPs, and Civil Servants. It is also charged with law enforcement for Members of Parliament. Meanwhile, no enforcement body is specified for Ministers and Civil Servants. (Note: The Head of State is a monarch and thus exempted from conflicts of interests laws.)

United Kingdom: The British Ministerial Code (2016) makes only a general regulation for members of parliament to avoid conflicts of interest. It also includes regulations on conflicts of interests for Ministers, who are restricted from accepting gifts, holding any other public appointment or position in a private company, and must avoid decisions in which they hold a private interest. For two years after leaving office, they must not lobby for government and abide to employment guidelines by an independent advisory committee. Meanwhile, the Civil Service Management Code (2013, last amended 2016) prevents Civil Servants from accepting gifts, holding government contracts, and participating in decisions that affect private interests. Only in exceptional cases may they engage in managing private or public companies, or holding board memberships. A two-year-long cooling off period applies. No sanctions are specified for any official who violates regulations on conflicts of interest. For Ministers, the Advisory Committee on Business Appointments gives guidance on the rightful interpretation of these laws, while the House of Lords Commissioner for Standards does the same for MPs. No such body exists for Civil Servants. An enforcement body is not specified for any public officials. (Note: The Head of State is a monarch and thus exempted from conflicts of interests laws.)