GUIDELINES FOR EU PUBLIC OFFICIALS IN DEALING WITH PUBLIC POLICY ADVOCATES

Public policy advocacy is an acceptable and normal part of our society and in many cases is a part of a healthy democratic process. Decision-makers can be provided with valuable information during the public policy advocacy process. Public policy advocacy covers a wide variety of activities. Generally it involves the making of representations to EU  public officials on particular issues by special interest groups, individuals and professional advocates acting on behalf of others. Where EU public officials are exercising statutory decision-making functions, particular care needs to be taken to ensure that any advocacy which occurs does not undermine public confidence in objective EU decision-making.

Principles to be observed

EU public officials should ensure that public policy advocacy in relation to a policy decision:

(a) is undertaken in accordance with appropriate practices; and

(b) does not undermine the integrity of decision-making processes.

In particular, EU public officials who are the targets of public policy advocacy efforts should:

1. be alert to the motives and interests of those who seek to advocate in relation to a particular  decision;
2. be aware of which person, organisation or company a public policy advocate is representing;
3. ensure that the making of a particular decision is not prejudiced by the giving of undertakings to an interested party prior to the decision-maker considering all relevant information;
4. avoid doing or saying anything which could be viewed as granting a public policy advocate preferential treatment;
5. ensure as decision-makers that, as far as possible, competing parties are treated fairly and consistently - for example, it may be necessary to provide a group with an opportunity to make submissions in relation to a proposed decision in circumstances where another group with a different view has been afforded an opportunity to make representations on the proposed decision;
6. ensure that confidential information is not disclosed to a public policy advocate;
7. be alert to attempts by public policy advocates to encourage decision-makers to consider matters which are extraneous or irrelevant to the merits of the decision under consideration;
8. consider keeping records of meetings with public policy advocates, and if necessary having another person attend the meeting as a witness or to take notes; and
9. ensure that no action is taken which involves a breach of a relevant code of conduct,  for example, by accepting inappropriate hospitality or gifts from public policy advocates.

Principles of Public Life

The principles of public life apply to anyone who works as a public office-holder. This includes all those who are elected or appointed to public office, locally, nationally and at EU level,

All public office-holders are both servants of the public and stewards of public resources.

• Selflessness Holders of public office should act solely in terms of the public interest.
• Integrity Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.
• Objectivity Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
• Accountability Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
• Openness Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
• Honesty Holders of public office should be truthful.
• Leadership Holders of public office should exhibit these principles in their own behaviour. They should actively promote and robustly support the principles and be willing to challenge poor behaviour wherever it occurs.