To manage potential conflicts of interests that can arise when staff leave the EBA, they are required to inform the EBA of their post-employment occupational activities, whether gainful or not, for a period of two years after their departure and seek the EBA’s permission unless they will remain in the EU civil service.  

The EBA can impose prohibitions and/or restrictions on post-employment activities when they are related to the work carried out by the staff member during the last three years of service and could lead to a conflict with the legitimate interests of the EBA. The EBA has adopted guidance for staff on the assessment of post-employment restrictions and prohibitions.  

This guidance is based on Article 16 of the Staff Regulations and Commission Decision on outside activities and assignments and on occupational activities after leaving the Service (C(2018) 4048 final of 29.6.2018). Decisions are taken on a case-by-case basis by the EBA’s Executive Director on advice by the EBA’s Ethics Officer and in consultation with the Joint Committee of staff appointed by the Executive Director and the Staff Committee. In the case of the Chairperson and the Executive Director, decisions are taken by the Board of Supervisors on advice by the Advisory Committee on Conflicts of Interests (ACCI).  

Senior staff leaving the EBA shall, in principle, be prohibited, during the 12 months after their departure, from engaging in lobbying or advocacy vis-à-vis EBA staff for their business, clients or employers on matters for which they were responsible during the last three years in the service. 

Voting members of the Board of Supervisors and Management Board are required, under the conflict of interests policy, to inform the Chairperson of their employment for two years after departure from the EBA’s governing bodies.  

The EBA has also adopted a policy on access to confidential information for staff leaving under which it can restrict the access to certain information and data system of staff who’ve notified their intention to leave and take up employment after leaving if their future employment has been assessed as leading to a conflict with the legitimate interests of the EBA. 

Occupational activities by former senior staff members: 

Year 2018 – Andrea Enria (former Chairperson)

Year 2019 – Adam Farkas (former Executive Director)

Year 2020 – Adam Farkas (former Executive Director)

Year 2021 – Piers Haben (former Director of Innovation, Conduct and Consumers (ICC) Department)

Post-employment Activities Report

Below you can find aggregate data on EBA staff who have left the service in previous years. The data do not include staff on unpaid leave even if they carry out an occupational activity during the period of unpaid leave:

  2020 2021
Total number of (senior and non-senior) staff who left the service:

11

13

Of which joined the private sector

3

2

Of which who returned to a Member State administration

2

1

Of which joined another EU institution

5

8

 

 

 

Total number of senior staff who left the service who (by senior we mean Directors and above):

1

1

Did not declare any intention to engage in an occupational activity

0

1

Joined another EU institution

0

0

Returned to a Member State administration

0

0

 

 

 

Total number of requests submitted by (former) staff to engage in an occupational activity after leaving the service:

10

11

Number of authorisations

9

10

Number of authorisations with mitigating measures

1

1

Number of refusal decisions

0

0