The European Public Affairs Consultancies Association (EPACA) was formed on 28 January 2005 to formalize the long-standing code of conduct applying to the lobbying profession and to establish self-regulatory structures for enforcing it. Its membership, which continues to expand, currently comprises 30 consultancies with a total of well over 500 employees – representing, we believe, 60-70% of the professional European public affairs consultancy market in Brussels.

EPACA strongly believes that our profession must hold itself to the highest ethical standards. We are pleased to note the success of our code to date in establishing benchmarks for professional behaviour in our profession, and securing a lobbying environment where all stakeholders can make legitimate representations.

We welcome Commission Vice President Kallas’ Transparency Initiative, and in particular agree that accountability and transparency concerning beneficiaries of public funds should be a priority. We have already shared with officials and others initial views on the initiative and its possible impact on the Brussels lobbying profession. We hope to be a constructive partner to the Commission as it drives forward its policy reflection process. As a contribution to transparency we have established a website where details of all signatories of our code and other information about our association are publicly available. We encourage our members to advertise the code and their adherence to it.

EPACA is open to discussing how the European Commission may choose to address lobbying in the future as part of its Transparency Initiative. While we favour self-regulation because it has so far demonstrated its effectiveness we are happy to consider a different approach as long as it meets certain criteria:

1. It is based on a careful analysis of the issue/problem to be addressed

2. It is applied equally to all types of organisations (i.e. corporations, trade unions, NGO’s, law firms, public affairs consultancies, etc.) trying to constructively influence the EU policy process, whatever the constituency that they represent

3. The Commission puts the appropriate resources behind its initiative to ensure it is effective and that compliance is universal

Our current policy is therefore:

	It is a priority for EPACA to promote professional ethics and high standards, and we are open to all practicable ideas to this end.
	We are putting into effect new self-regulatory arrangements with real sanctions and credible and authoritative processes. We will announce shortly the membership of our professional practices panel of independent and eminent persons.
	We are steadily extending the coverage of our code, already applicable to the bulk of our market segment.
	We are reviewing our Code of Conduct to determine if it requires amendments.
	We are preparing professional practices advice and a background document on our code for members
	We are entering into dialogue with other professional standards bodies to see what we can learn from each other.
	We are seeking to pursue a dialogue with the EU institutions on the evolution of our professional arrangements.