Comments I.Adinolfi

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Art. 6. It should be introduced a general obligation to provide accurate and updated information. Art. 7. It should be introduced a reference to the frequency of the checks carried out ex officio by the Secretariat and to the appropriateness, to this end, of the financial and personal resources allocation. Art. 8. There should be a clarification on the modus operandi of the Management Board: consensus should not be interpreted as a veto power of any of the three Institutions. In addition, there should be a mention to the fact that all decisions of the Management Board should be effectively and immediately made available to the public. Art. 9. The Secretariat should collect standardised data that are easily accessible for users. Furthermore, the Secretariat should become a central hub concerning all data on lobbying. Articles 10 & 11. Ok Article 12. The register should cover also the activities of EU agencies and bodies (see Article 1), therefore this article should be modified accordingly. Article 13. This article should be modified to accommodate the changes made in Article 5 on Permanent Representations. Article 14. The term of four years should be shortened to three. Annex I. Independent/freelance lawyers should also be included as a category as well as public relations firms and media consultancies. Annex II. I (General Information) The specific files/reports followed should be indicated. II (Specific Information) The bandwidths of the costs and revenues should be more precise. The estimates of the people involved in the activity should be checked, and if 2
needed upgraded, every 6 months. The same checks, and if needed corrections, should apply mutatis mutandis to the estimates of costs and attributable revenues. All these data should be updated, precise and reflecting the reality as much as possible. Annex III. The code of conduct of the former Register should not be limited in its scope. In particular, letter c), d), i), j), l), m), n) of former code of conduct should be fully reproduced. Annex IV. There should be the possibility to lodge anonymous complaints. The decisions issued and measures adopted by the Secretariat should be effectively and immediately made available to the public. The review process (Par. 11) should always be concluded with the issuing of a reasoning, even when there is no an implicit rejection. 3
Page 1: Comments of Isabella Adinolfi MEP 5

Comments I.Adinolfi

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