The Effectiveness of Conflict of Interest Policies

A Comparative Study of Holders of Public Office in the EU Member States

by Christoph Demmke (Author) Jari Autioniemi (Author) Florian Lenner (Author) Maros Paulini (Author)
©2021 Monographs 238 Pages


Neither instruments nor methodologies are available to measure the development of CoI over long periods of time. Therefore, it is impossible to state whether CoI increase or decrease. The Member States of the EU have no statistics and figures about the development of Conflicts of Interest (CoI). However, ever new scandals, growing media attention and changing concepts of governance create ever new ethical challenges and conflicts of interest. As such, detecting, managing and measuring CoI policies involve some of the greatest challenges and difficulties in legal, political, organizational, behavioural and administrative sciences. This international and empirical research examines the causes of conflicts of interest and discusses concepts, innovative instruments and new ideas how to enhance the effectiveness of policies.

Table Of Contents

  • Cover
  • Title
  • Copyright
  • About the authors
  • About the book
  • This eBook can be cited
  • Table of Contents
  • 1. Introduction: Conflicting interests and Conflicts of Interest in a changing world
  • 1.1. Introduction
  • 1.2. Evaluating the Effectiveness of CoI policies
  • 1.3. Conflicts of Interest in times of societal change and innovation
  • 1.4. Towards effective implementation of Conflicts of Interest Policies – what are preconditions?
  • 2.1. Defining Conflict of Interest
  • 2.1.1. Conflicting interests and CoI
  • 2.1.2. Defining Conflicts of Interest (CoI)
  • 2.2. Purpose and objective of CoI policies
  • 2.3. CoI and the need for different policies for different Holders of Public Office – Why taking a special interest in Ministers (and EU Commissioners)?
  • 2.4. Special challenges for Ministers
  • 2.5. Ministers, Commissioners, Prime Ministers and Presidents and the relationship between CoI, political ethics and “dirty hands”
  • 2.6. Methodological Approach
  • 2.6.1. Data collection, data analysis, and shortcomings of the survey
  • 2.6.2. The case of Belgium
  • 2.7. Effectiveness and targets – what to achieve apart from prevention?
  • 2.8. Strategical, methodological and institutional approaches – preconditions for effective ethics policies
  • 2.8.1. Linking effectiveness and objectives of ethics policies
  • 2.8.2. The effectiveness of tools and instruments
  • 2.8.3. The effectiveness of rules and codes of ethics
  • 3.1. What evidence – are Conflicts of Interest increasing?
  • 3.2. General trends in the field of CoI
  • 3.2.1. Ever more “sophisticated” – the regulation of CoI
  • More rules and higher policy coverage
  • Ethicalization of (EU-) rules and standards
  • Broadening of definitions and wider applicability of terms
  • Stricter standards and requirements
  • 3.3. Comparative observations – the policy coverage of CoI in the Member States
  • 3.3.1. CoI rules as effective instruments in the fight against corruption?
  • 3.3.2. Positive aspects of rules and standards
  • 3.3.3. Debating the Effectiveness of Codes of Conduct
  • 3.4. Measuring and Monitoring CoI
  • 3.4.1. Oversight, monitoring and ethics committees – structural features, powers, functions and resources
  • 3.4.2. Effectiveness of disclosure policies
  • 3.5. Critical developments in the field of disclosure
  • 3.6. Managing the “revolving door” – the greatest challenge of all CoI issues
  • 3.6.1. Revolving doors case study
  • Mapping the transition
  • Maladministration in the EBA’s decision to allow the former Executive Director to join AFME
  • Maladministration in how the EBA handled the other consequences of the Executive Director’s job move
  • Recommendations from the Ombudsman to the EBA
  • 3.6.2. Revolving door and grey zones
  • 3.7. Conflict of Interest violations and tolerance – why people do not mind?
  • 3.8. Managing specific CoI in the appointment of EU Commissioners and members of Cabinet
  • 4. Innovation in the field of CoI – behavioural instruments and moving towards institutional integrity
  • 5. Conclusions: Looking into a Glass Darkly – Future Trends in the Field of CoI
  • ANNEX A – Questionnaire
  • ANNEX B – Codebook
















British Advisory Committee on Business Appointments

Association of Financial Markets in Europe

Conflicts of Interest(s)


European Banking Authority

European Court of Auditors

European Court of Justice

European Parliament

European Union

European Public Administration Network

Group of States against corruption, Council of Europe

Holders of Public Office

Member States

Organisation for economic Cooperation and Development


Figure 1:Ethics Policies from a Policy Cycle Approach

Figure 2:Member States policy coverage density as regards the most important CoI for Ministers by geography

Figure 3:Policy Coverage Density as regards Spouse Activities for Ministers (without Belgium)

Figure 4:Attitudes regarding corruption in member states

Figure 5:Policy Coverage Density and administrative typology for Ministers (without Belgium)

Figure 6:Conflicting Public Policy Objectives

Figure 7:Managing Process of Conflict of Interest

Figure 8:Conflicts of Interest, Institutional, and Personal Level

Figure 9:Confidence in national Government in 2018 and its change since 2017 (OECD 2019)

Figure 10:Relationship between Policy Coverage Density and Perceptions about ties between politics and business leading to corruption (without Belgium)

Figure 11:Policy Coverage Density of most important CoI issues in Member States

Figure 12:CoI Policy Coverage, Top-Officials (including Directors-General)

Figure 13:Form of Minister CoI Regulation in Continental Europe

Figure 14:Form of Minister CoI Regulation in Southern Europe

Figure 15:Policy Coverage Density of CoI by law and/codes in the Member States

Figure 16:Policy Coverage Density of most important CoI per country as regards Ministers

Figure 17:Institutional fragmentation

Figure 18:Attitudes regarding government efforts in combating corruption in Member States

Figure 19:Relationship between acceptability of corruption and state of democracy (Top-Officials)

Figure 20:Relationship between acceptability of corruption and state of rule of law

Figure 21:Relationship between acceptability of corruption and government integrity

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Figure 22: Relationship between acceptability of corruption and government effectiveness

Figure 23: Relationship between policy coverage density and effectiveness of corruption prevention

Figure 24: Relationship between level of corruption and effectiveness of corruption prevention

Figure 25: Policy Coverage Density of Top-Officials (including Directors-General) per country in 2008 and 2020

Figure 26: Policy Coverage density of CoI policies for Ministers in 2008 and 2020 (without Belgium)

Figure 27: Factors Influencing the Effectiveness of CoI Regulations’ Implementation

Figure 28: Coverage of most important CoI Issues – use of law

Figure 29: Policy Coverage Density for Ministers and Corruption Index (without Belgium)

Figure 30: Policy Coverage Density for Ministers and perceptions of bribery (without Belgium)

Figure 31: Policy Coverage Density and relationship with trust index (for Ministers for most important CoI)

Figure 32: Statements of EU staff members as regards guidance received on ethics #1

Figure 33: Statements of EU staff members as regards guidance received on ethics #2

Figure 34: A Simplified Model of Integrity Policy

Figure 35: Policy Coverage Density and perceptions that Governments combat corruption effectively (for most important CoI)

Figure 36: Level of Disclosure of Top Decision-makers’ Private Interests in OECD Countries

Figure 37: Dimensions of the revolving door

Figure 38: Vulnerability of HR reform trends (n-14)

Figure 39: Case study timeline

Figure 40: Attitudes regarding pursuing high-level corruption in Member States

Figure 41: Do given situations reduce the objectivity and fairness of public servants decisions?


ISBN (Hardcover)
Publication date
2021 (July)
Political Sciences Conflicts of Interest Effectiveness Public Administration Ethics
Berlin, Bern, Bruxelles, New York, Oxford, Warszawa, Wien, 2021. 238 pp., 21 fig. col., 28 fig. b/w, 5 tables.

Biographical notes

Christoph Demmke (Author) Jari Autioniemi (Author) Florian Lenner (Author) Maros Paulini (Author)

Christoph Demmke is Professor of Public Management at the University of Vaasa (Finland). Prior to this, he was Visiting Professor at the University of Potsdam, Interim Professor at the Zeppelin University in Friedrichshafen (D), Head of Unit in the OECD, Paris (F), Professor at the European Institute of Public Administration (NL) and Guest Professor at the College of Europe in Brugge (B) and the University of Maastricht (NL). Besides he was Fellow at the Harvard Law School, Scholar at Oxford University and the German Ministry of the Interior. He is a long-standing advisor to the European Union Presidency, many EU Institutions and national Governments on HR reforms and Ethics. Dr Jari Autioniemi is a philosopher and lecturer of public management at the University of Vaasa, Finland. In his research, Dr Autioniemi focuses on public management ethics and public accountability. Florian Lenner is a student of political science at the University of Munich. Having acquired academic experience as research assistant, co-author of a study for the European Parliament or co-founder and co-editor in chief at the Young Journal of European Affairs (YJEA), his academic work revolves around International Relations and International Security. Maros Paulini works as ethics and civil service expert for the Slovak government. He is author of many articles and papers on Conflict of Interest and HR reform of the civil service. He has also experience as facilitator of international workshops on ethics.


Title: The Effectiveness of Conflict of Interest Policies
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240 pages