For Commissioners in 2014, the Code of Conduct says that when they leave office they must abide by an 18 month notification period, during which time they must seek Commission authorisation for any new job. They are also banned for 18 months from lobbying the Commission on matters for which the commissioner used to be responsible. Lobbying is not defined.
For MEPs, the Code of Conduct only says that former MEPs will not use their life-long Parliament access pass for the purpose of lobbying. However, there is no process to monitor or enforce this part of the Code.
For staff in 2014, the Staff Regulations say that any official leaving an EU job should inform them of any new roles for the next two years. If there is a risk of a conflict of interest, the EU institution may either forbid job or give its approval subject to conditions. The most senior officials are prohibited, for 12 months on leaving the EU, to engage in lobbying on matters for which they were responsible during the last three years in the service. However, contract agents (who make up maybe 25 per cent of the Commission workforce) are largely excluded from these rules. Incoming staff to an EU institution should be screened for possible conflicts of interest.
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