"I am pleased to inform you that the Appointing Authority gives you its approval to carry out these activities, as described in your request, on condition that for a period of two years as from the date of your retirement - you shall have no contacts with your former colleagues of DG RELEX, regarding files and matters you dealt with during your functions of Head of Delegation in Washington, - you shall not deal with cases and may not be involved with consultancy services concerning files in which you were involved during your function as Head of Delegation in Washington. These restrictions are designed to protect the interests of the Institution and avoid risks of potential conflicts of interest".
In May 2010, Mr Bruton also became President of the Dublin-based International Financial Services Centre. Mr Bruton has alos undertaken work for Montpelier RG, American Oriental Bio Engineering, Gerson Lehman Group, McDermott, Will and Emery, and Ingersoll Rand.
CEO first applied for copies of Mr Bruton's authorisation to undertake these roles in December 2010. It then became clear that the Commission had never received them. The Commission contacted Mr Bruton who said that he had sent them. Mr Bruton has also subsequently written on his website that: "Last December it was brought to my attention by the Commission that, under their rules, I ought to have sought their consent for any professional activities I undertook in the two years after I ceased to be in their employment. I was unaware of this requirement, as it had not been brought to my attention by the Commission either in the discussions that took place before I accepted the post in 2004, or at any time thereafter until December 2010. While I was aware that such requirements applied to former Commissioners, I was not aware that it applied to persons in my position.” http://www.johnbruton.com/2011/03/my-professional-activities.html This implies that the Commission is not proactive about promoting the revolving door rules to staff and former staff.
ALTER-EU has now submitted a complaint to the Commission about how this revolving door case was handled.
More information is available in the ALTER-EU report: Block the revolving door - why we need to stop EU officials becoming lobbyists: http://www.alter-eu.org/revolving-doors
"This case illustrates some of the weaknesses regarding the implementation of Article 16. The rules say that "The institution shall ... notify its decision within 30 working days of being so informed. If no such notification has been made by the end of that period, this shall be deemed to constitute implicit acceptance”. This is flawed as under this system, when Mr Bruton's application apparently went missing in the post, he was able to assume that the Commission had authorised his appointments. In fact, the Commission should proactively communicate with every applicant with its verdict on the proposed post. In this example, this flaw in the system meant that Mr Bruton's roles were entirely unauthorised for a while. In addition, it appears that the conditions that the Commission did ultimately place on Mr Bruton's new posts would not prevent the risk of conflicts of interest or Mr Bruton lobbying or offering lobbying advice using his insider know-how about the ways of working of the EU institutions. CEO considers that the Commission should have imposed a full two year cooling off period or ban on the acceptance of these particular roles".