UAE flag as carpet with lobbyist sweeping images of 'war' and 'arms' underneath.

United Arab Emirates’ growing legion of lobbyists support its ‘soft superpower’ ambitions in Brussels

The United Arab Emirates is one of the world's major lobby spenders. While projecting an image of moderation and stability, it pursues its foreign policy aims in bloody wars from Yemen to Libya. As part of an occasional series on repressive regimes' lobbying, Corporate Europe Observatory uncovers the autocratic kingdom’s Brussels-based spin doctors, from a think tank's board of former European prime ministers, to lobby consultancies specialising in 'privatised diplomacy’, and the use of discredited social media disinformation firms.

Introduction

The Government of the United Arab Emirates (UAE) has established several new lobbying footholds in Brussels. The small, oil-rich Gulf kingdom is a big lobby spender worldwide; and its stated ambitions to be a ‘global soft superpower’ mean many of these lobbyists don’t just help polish the country’s image as a moderate, friendly ally of the EU. The aim is to proactively shape the narrative and the ideas the rest of the world, including Europe, has about it and its role in the region.

According to Kings College London academic Andreas Krieg, the UAE and its lobbyists tend to weaponise narratives of "authoritarian stability". SidenoteInterview with Andreas Krieg, academic, Kings College London. This projects the UAE’s autocratic rulers as a stabilising force in the Gulf; and paints any attempts at pluralism, developing civil society, or the activity of rival powers, as a gateway to Islamist chaos and terror. The lobbyists who whitewash the UAE, presenting it as a stable partner in the region – engaged in humanitarian aid, an ally against terrorism and climate change, and promoting increasing secular moderation – or otherwise work to shape its influence, help the autocratic oil-rich state obscure its darker side. The UAE has been accused of perpetrating war crimes in Yemen, has crushed dissent and backed the brutal Sisi regime in Egypt, and played a crucial proxy role – and been a key arms supplier – in the conflict in Libya. This is not to mention domestic human rights violations such as the abuse of migrant labourers, or the crushing of dissent within its borders.

This projects the UAE’s autocratic rulers as a stabilising force in the Gulf

The UAE is small in size but the eighth largest oil and gas producer in the world, and it is increasingly flexing its power both regionally and globally – and spending money on lobby consultancies and think tanks in Brussels in order to do so. In 2017 it launched a new “soft power strategy” to punch above its weight on the global stage. This was surely linked at least in part to its regional rivalry with Qatar SidenoteThere have been recent signs of a rapprochement with Qatar. and others (it should be noted that UAE rivals such as Qatar and Turkey also stepped up the war of narratives and/or lobbyists in Europe and that Qatar has also been a major lobby spender). This push coincided with a major uptick in the UAE’s lobby and PR spending, which almost doubled in the US: in 2019 it spent US$18 million to influence American policy. A report from The Centre of International Policy notes the UAE spent a minimum of US$15.4 million on regular donations to think tanks in Washington DC between 2014-2018 (this number excludes one off payments which were also considerable). While transparency failures mean we unfortunately do not have equivalent lobby spending figures for the EU, and Brussels has been a lesser target for the UAE than Washington DC (and indeed perhaps than Paris, Berlin, and London); nevertheless since 2017 the Gulf kingdom has put new efforts into its 'soft power' push at the heart of Europe.

Questions need to be asked about the role of these consultancies and think tanks in lobbying and influencing under the radar, in particular the lack of transparency about the clients, contracts, and funding involved. Even when they do appear in the EU's Transparency Register, there is very little information about what is actually done on the client's behalf. In contrast, in the USA, every lobbyist working for a foreign government - whether friend or foe - is required to publish the contract itself, as well as provide updates every six months while it remains active.

It's no surprise that non-EU countries engage in diplomacy and influencing strategies; but the UAE already has official diplomatic channels with the EU. And it should be said the UAE is by no means unique among autocratic states in its lobbying strategies (see Corporate Europe Observatory's previous report, 'Spin doctors to the autocrats'). The real question is, why does it continue to be so easy for think tank policy wonks, lobby consultants, and middlemen in Europe to play the role of hired gun for repressive regimes, and for so few questions to be asked? Why is this considered acceptable in the culture of the Brussels bubble? Clearly the EU's lobby transparency still leaves a lot to be desired.

Piercing the Brussels bubble

This report looks in more detail at three of the groups in Brussels the UAE has deployed since the launch of its ‘soft power’ push in 2017, in order to variously shape the narrative about the country, lobby the EU institutions, and to pursue its diplomatic and foreign policy interests. SidenotePlease note, this section is a summary. Fully referenced details are in the case studies below.

The Bussola Institute is a think tank established in Brussels in October 2017. While it claims to be working on behalf of EU-Gulf region relations as a whole, in fact all its institutional ties are with the UAE. No funding information is available from Bussola. However – like many think tanks that refuse to disclose their backers – it is not simply a crude front group, but appears to be a sophisticated combination of serious academic research, and strategic communications. It can benefit from the networks of several – exclusively conservative – former European heads of state on its Honorary Advisory Board, including an ex-head of NATO. It has various ‘strategic communications’ professionals working for it, including an intelligence expert who previously developed psychological operations programmes for the British military in Iraq and Afghanistan. And it offers the UAE Government in Abu Dhabi a hub within Brussels to legitimise its narratives; for example the Bussola Institute’s policy papers are an elegant way to position the UAE’s foreign policy goals, and its events in Brussels regularly involve high level officials (such as commissioners and European External Action Service officials) which offer perfect lobbying opportunities.

A contract between the National Media Council of the UAE and PR firm Project Associates, headquartered in London and with an office in Brussels, also dates from 2017. However, Project Associates only recently entered the EU’s Transparency Register, where this client doesn’t appear. In contrast the National Media Council of the UAE does appear as an ongoing client (still active as of November 2020) in the USA’s legally enforced and mandatory ‘foreign agents’ lobby register (FARA), signed by the "Director and Head of International and Political Advisory Practices of the Brussels Office" of Project Associates who is described as rendering “services directly” to the client. NBC news notes that this filing took place at a time when there was a flurry of lobbyists and PR firms in the US rushing to register their foreign government clients after the prosecution of Trump crony Paul Manafort for failing to do so – revealing that legal enforcement does in fact work wonders for transparency!

Project Associates subcontracted the controversial online disinformation firm SCL Social to attack UAE’s rival Qatar

Moreover this contract shows that Project Associates subcontracted the controversial data mining and online disinformation firm SCL Social (sister company to the more notorious Cambridge Analytica) to attack the UAE’s rival Qatar via social and traditional media; FARA files show stories were placed in the European press including Brussels-based New Europe and The Independent as part of SCL Social's information work in September 2017. However, the references in the filing to other activities on behalf of the client that took place beyond the shores of the USA are not revealed; and thus rather starkly show up by way of contrast the failures of the EU’s lobby transparency laws.

The third case, Westphalia Global Advisory, is a Brussels-based consultancy specialising in 'private diplomacy' which was set up in 2018; its main client appears to be the UAE Embassy to the EU in Brussels. A March 2020 report on Westphalia Global Advisory’s website offers analysis about the need for the autocratic leadership of the UAE to articulate its vision of “stability” in the Gulf.

The firm’s two co-founders and directors Timo Behr and Tim Eestermans both have years of experience working for the UAE’s Ministry of Foreign Affairs as advisors to Mohammed Issa Hamad Abushahab. Abushahab became the UAE’s Ambassador to the EU, and they now represent the embassy as a client.

The UAE’s lobbying narratives

The UAE’s ruling royal family saw the Arab Spring that erupted in 2011 as an existential threat, both to it and to the dynastic autocratic rulers of Gulf states more generally. (Despite enjoying recent headlines about moderation and ‘modernisation’, the UAE ranks 145th in The Economist’s ‘Democracy Index’ for 2019.) Indeed, along with Saudi Arabia, it sent forces to help brutally suppress a mass revolt in Bahrain in March 2011. As images of the Arab Spring protesters’ calls for more pluralistic and democratic societies were broadcast globally, and helped seed rebellions elsewhere, the UAE was keen to shape a counter-narrative to present to the rest of the world, to head off the threat of democracy. Abu Dhabi thus began to push the notion of “authoritarian stability”, which posits a simplistic dichotomy: either you have stability in the form of the autocratic rulers of the UAE, or you have Islamist terrorism and chaos, which would be the inevitable result of more democratic pluralism, civil society, and tolerance for critical voices. Naturally in this narrative, it is the UAE’s autocratic ruling family who stands in the way of such chaos being unleashed in the Gulf. This black and white framing of ‘authoritarian stability versus terrorism’ not only shuts down more nuanced questions and conversations, but neatly plays on Western fears. The stability narrative thus helps support the status quo in the UAE, and wins key allies in Europe: it has an appeal to conservatives, the far right, islamophobes, and the centre right too.

This narrative of stability has enabled the UAE’s rulers to use 'counter-terrorism’ as an excuse to perpetrate human rights abuses and discredit dissidents; and it is also a convenient brush with which to tarnish regional rivals (for example Qatar, Turkey, and Iran) as sponsors of terrorism. (Bear in mind that these rivals have their own human rights abuses, problematic foreign policy goals, and lobbying strategies which it is far beyond the scope of the current report to examine. But to offer a brief context, the region has various blocs vying for supremacy – indeed the war in Libya since 2014 has been a kind of proxy conflict with the UAE versus Qatar and Turkey backing rival sides.)

In 2017 the UAE cut diplomatic ties with Qatar and made a call for a global boycott. This was matched by a massive uptick in lobby spending by UAE (and indeed from Qatar too), as it attempted – successfully in the case of then-US President Donald Trump – to persuade other countries to put pressure on its rival. This also coincided with its new ‘soft power’ push, an attempt to punch above its weight in global power stakes. And while relations with Qatar appear to be thawing, the UAE still finds its soft power narratives useful, such as when it comes to pursuing its foreign policy aims via military interventions in Yemen and Libya.

is it legitimate that EU-based lobby consultancies should be playing any role in a third-country effort to influence European institutions, officials, and press

For while the UAE tells a positive story in Europe about its humanitarian programmes and fight against terrorism in Yemen, it has played a key role in the Saudi-led coalition in the war there and helped fuel what the UN has described as "the worst humanitarian crisis in the world”. While the UAE has officially withdrawn from the war in Yemen this year, according to the UN Human Rights Council’s September 2020 report the Gulf kingdom’s military presence continues as it still backs 90,000 Yemeni fighters on the ground and conducts airforce attacks. SidenotePage 4, Third report of the Commission of the Human Rights Council to the United Nation which includes events in Yemen during the period July 2019-June 2020. The report concludes the UN has “reasonable grounds to believe” the UAE, along with the governments of Saudi Arabia and Yemen are responsible for “human rights violations, including arbitrary deprivation of life, enforced disappearance, arbitrary detention, gender-based violence, including sexual violence, torture and other forms of cruel, inhuman or degrading treatment, the recruitment and use in hostilities of children, the denial of fair trial rights, and violations of fundamental freedoms and economic, social and cultural rights.” And that individuals from the UAE are implicated in “acts that may amount to war crimes".

While the UAE has been lobbying to lift arms embargoes so it can import weapons, as an article at Responsible Statecraft.org notes, arms sales from the US and EU member states have helped fuel this deadly conflict, such that: “The policy of unbridled arms sales to Saudi Arabia and UAE is morally, legally and politically indefensible as it strengthens their highly repressive regimes, fuels regional conflicts and makes Western democracies complicit in war crimes in Yemen.”

Sadly, without an improvement in EU lobby transparency, we are left in the dark as to what goes on behind the scenes. If the UAE already has official diplomatic channels with the EU, it begs the question whether it is legitimate that EU-based lobby consultancies should be playing any role in a third-country effort to influence European institutions, officials, and press; and in particular whether European citizens should be kept largely in the dark about their role in doing so. (Please see the end of the report for Corporate Europe Observatory's recommendations on lobby transparency.)

1. Bussola Institute: Think tank well-equipped for lobbying role

The Bussola Institute, a mysterious new think tank on Gulf affairs located right round the corner from the European Commission, sprung up in Brussels in 2017. The Institute did not respond to a query from Corporate Europe Observatory about the sources of its funding, which it does not publicly disclose, nor whether it operates as a lobbyist in any capacity. It also did not reply to queries about whether its roster of Honorary Advisory Board members receives any payment. This Board is a well-connected powerhouse of conservative European political figures, offering Bussola a myriad of influencing and networking possibilities: the Chair is former Spanish Prime Minister José María Aznar, and the other Board Members are former Secretary-General of NATO Anders Fogh Rasmussen, former Irish President Mary McAleese; not to mention former Prime Ministers of France, François Fillon, and Croatia, Jadranka Kosor, and to top it off, former EU Commissioner Anna Diamantopoulou. Meanwhile various MEPs are listed as ‘Guests of Honour’ including former Prime Minister of Poland Jerzey Busek MEP.

While the Bussola Institute’s mission statement is an “independent and not-for-profit, non-governmental organisation established in Brussels as a world-class Research Institute and Think-and-Do-Tank, which is committed to forging multicultural interconnections between the Gulf Countries and the European Union”, it was founded by exclusively UAE establishment figures. It is hard to avoid the conclusion, then, that this is largely an Abu Dhabi-run outfit, pursuing exclusively Emirati policy goals and objectives.

This Board is a well-connected powerhouse of conservative European political figures, offering Bussola a myriad of influencing and networking possibilities

The Institute appears to combine genuine, serious research with lobbying and strategic communications that reflect the UAE’s national policy objectives, publishing policy documents and hosting events in Brussels that create a channel of access to influential EU politicians and officials. As Andreas Krieg, academic at Kings College London told British newspaper The Times: “The danger of outfits like Bussola is that it suggests a degree of academic objectivity, when in reality it serves the foreign policy interests of a country in the Middle East whose human rights record and policies are incompatible with the values and interests of Europe." He continues, “I think it is therefore problematic for any government to engage with Bussola, as the presence of senior policy-makers on the board, or at events, provides this Emirati lobbying outfit with legitimacy.”

The Bussola Institute was registered as a not-for-profit organisation in 2017 in Brussels, and appeared in the EU’s Transparency Register at the end of 2018. Its self-declared budget is, according to its Transparency Register entry, €400,000, with annual lobbying costs estimated at €50,000 to €90,000. Five staff members are listed as having European Parliament passes.

There is no financial information on the Bussola Institute website, nor in the Transparency Register, as to who might be bankrolling the self-styled “think-and-do tank”; and while the organisation claims to focus on “the political, social, economic, security and cultural issues that affect policy making in the Gulf Cooperation Council (GCC) and the European Union (EU) regions” SidenoteThe GCC refers to the political and economic alliance of six Gulf countries, Saudi Arabia, Kuwait, the United Arab Emirates, Qatar, Bahrain, and Oman. in reality as a spokesperson told British newspaper The Sunday Times last year, “Bussola was established, and has been initially funded, by a group of Emirati sponsors concerned to deepen and enhance understanding of the political, economic, strategic and social issues that connect the EU and the Gulf Co-operation Council.”

Both founders’ work histories show them to be UAE establishment figures, and appear to reflect two poles of the institute: on the one hand, genuine academic research, and on the other, strategic communications. Founder and Chair of the Board of Directors Amal Al-Haddabi comes from the Emirates Center for Strategic Studies and Research, a serious academic research centre based in Abu Dhabi, with partnerships with Cambridge University in the UK, among others. From 2015 she has also acted as the Adviser to the Speaker of the Federal National Council of the UAE. Co-founder Mohammed Baharoon, member of the Board of Directors, has a background in media and is also Director General of B’huth, a private UAE research institute (also known as the Dubai Public Policy Research Centre) which he established in 2002. B’huth describes its specialities as including “geostrategic analysis”, “national security”, and as a “dedicated outfit for strategic communication”; as well offering “media management” and “policy guidance”. On the B’huth website Baharoon makes a frank assessment of the UAE’s diplomatic relations with the EU: “Given the troubled state of EU diplomacy, regional players such as the UAE felt that they had no choice but to try and work within the context of intra-European divisions, by strengthening and cultivating bilateral ties with some of its more proactive and influential European partners on issues of mutual interest. This includes, for instance, significant coordination with France on Libya.” Baharoon’s statement on the Bussola website says he “has been reading world politics as the ultimate literary genre where fact and fiction are two faces of the same coin”. This appears to be the profile of a lobbying and communications professional.

Secretary General John Dennehy is the only staff member listed on the Bussola Institute’s website; his previous roles include Executive Director of the Abu Dhabi Education Council, but before this he was Secretary General of Ireland’s Ministry of Education and Science. Brian Power, Bussola’s Director of Corporate Affairs and Strategy, is also a former Irish Department of Education alumni. Interestingly given its three Irish connections SidenoteBussola Institute is not in the Irish lobby register. https://www.lobbying.ie/ (Dennehy, Power, and board member McAleese), the Bussola Institute attracted criticism in The Sunday Times in 2019 as the UAE lobby vehicle had been given free access to use the Irish state’s official guesthouse, Farmleigh House, for a 2018 conference ‘Lessons for the Future Navigation of the Relationships between EU and GCC Countries’ at which former Irish President Mary McAleese spoke (along with a roster of heavyweight Irish politicians, including a former European Commissioner). Discussions included, “how effective networking at both national and at European levels were key to influencing in the European context but that the complexity of Europe’s Institutions requires enormous patience and calls for the clear articulation of priorities”. This Dublin event also marked the signing of a partnership between the Bussola Institute and Dublin University for research “on fostering and enhancing relations between countries in the Gulf Cooperation Council and the EU”.

According to The Sunday Times story, the Bussola Institute says board member McAleese is not paid but receives “a modest honorarium for her time”, plus expenses. Neither the Institute nor the honorary board members contacted replied to a request by Corporate Europe Observatory to explain what if any payments they have received for their roles.

The pandemic hasn’t stopped Bussola’s networking and influencing events. More recently McAleese spoke at a Bussola webinar on Europe’s post-COVID strategy and the relations with the GCC states in summer 2020, calling for the restarting of negotiations for an EU-Gulf states free trade agreement. Also participating in the webinar were other members of the board including Aznar, Diamantopoulou, Fogh Rasmussen, Kosor, and right wing Spanish MEP Antonio López-Istúriz White.

In August 2020 another Bussola webinar ‘Trends and Opportunities in EU-GCC Trade Relations’, in which Mary McAleese and then-EU Commissioner for Trade Phil Hogan participated, the Commissioner (who is also from Ireland) stated that “We should get round the table and restart our negotiations. We are working towards that objective at the moment.” (This trade deal had been paralysed since the Qatar crisis which now looks to be easing.)

 

Weapons-grade strategic communications

One of the most interesting staff members of the Bussola Institute, Angus Taverner, is not named on the staff list, but in publications he is described as “Director of Engagement and Communication”. Taverner has a Masters degree in PR and strategic communications and is a professional consultant in the area, with a background in military intelligence.

Taverner is described as leader of Smith Taverner, a strategic communications consultancy whose website says it has completed “many projects involving: risk analysis; interpreting international media trends and public perceptions; and offered commentary on the strategic challenges that influence political, diplomatic and economic issues around the world and particularly in the Middle East.” His bio says Taverner “planned the military-media support for initial operations in both Iraq and Afghanistan and evolved the UK policy for embedding war correspondents with UK forces”. According to his publications record his expertise includes “the strategic use of ‘Soft Power’ and the military employment of Information and Influence Campaigns” and has conducted trainings including in UAE. A cached website from the previous incarnation of this company shows it is clearly a political lobbying and influencing outfit. He is also listed as a current Director of Global Affairs at Dubai Policy Research Institute, otherwise known as B’huth, where he has worked since 2004. This organisation is led by Bussola Institute founder Baharoon; its programmes include ‘Reimagining Yemen’; the institute also offers policy advice for UAE on its diplomatic approaches to the EU (see above).

In a nutshell, Taverner’s background in what is essentially political warfare – given his background in military intelligence, psychological operations, strategic communications, risk analysis, and PR expertise – makes him seem quite over-qualified for a simple Brussels think tank press role.

Events he has participated in on behalf of Bussola include ‘Key Challenges for Iraq: A Way Forward for EU and Gulf Involvement’ for which he authored a May 2019 report, and in July 2020, he moderated a webinar (featuring Rosamaria Gili from the European External Action Service) on ‘The Way Forward in Libya’.

The ambitions of the Bussola Institute are indicated in its Transparency Register entry, where it suggests, “While the Bussola Institute is not yet participating in Commission Expert Groups or EU forums, it would propose to do so going forward.” Meanwhile, the extent to which genuine academic freedom is respected within the Institute remains to be seen.

EU-UAE MEP friendship group.

In November 2019 the UAE’s Embassy to the EU posted a picture of the incoming Parliament’s EU-UAE Friendship Group, after a meeting held in the European Parliament. From left to right, the MEPs are Urmas Paet (Estonia, Renew Europe), Manolis Kefalogiannis (Greece, EPP), [unknown], Antonio López-Istúriz White (Spain, EPP), Radosław Sikorski (Poland, EPP), Edina Toth (Hungary, EPP), [ambassador], Ryszard Czarnecki (Poland, ECR), Tomáš Zdechovský (Czech Republic, EPP), Ismail Ertug (S&D, Germany), Traian Băsescu (Romania, EPP).

BOX 1: Friends like these? MEPs and the UAE-EU friendship group

MEP friendship groups have no official status, and can act as a “backdoor for pariah regimes” as the EU Observer put it, noting, “These unregulated bodies have mushroomed over the years, causing headaches for official MEP delegations, while giving shady government figures a valuable lobbying foothold inside the European Parliament.” There are multiple lobbying themes that have exercised UAE in recent years, from visa-free travel, to its quest to be removed from the blacklist of tax havens, to avoiding arms embargoes; and having the ear of friendly MEPs whose politics somewhat align can be helpful.

The UAE-EU Friendship Group raised eyebrows by listing its contact details as the UAE Mission in Brussels, before the website was taken down.

MEP Antonio López-Istúriz White (from the Spanish right wing PP) has been Chair of the Parliamentary Group of Friends European Union-United Arab Emirates since 2014. He is Secretary General of the European People’s Party (EPP), and a former personal adviser to Aznar, who was Prime Minister of Spain from 1996-2004. López-Istúriz is listed as a ‘Guest of Honour’ at the Bussola Institute, whilst Aznar currently sits on the UAE think-tank’s board (see above). (There is no indication of direct payments to López-Istúriz from the Bussola Institute in his financial declarations, nor mention of a voluntary role though he has several others listed, and the think tank did not reply to queries.)

López-Istúriz’ trips as an MEP are almost all to the UAE, including one for a conference where UAE’s chief lobbyist in Washington and Ambassador to the US, Yousuf Otaiba spoke, and where his expenses were paid for directly by UAE’s Minister of State for Foreign Affairs Anwar Mohammed Gargash. In May 2017 he attended an Abu Dhabi conference on criminalizing cyber-terrorism (rather ironic given the online disinformation tools employed by the UAE, see Box 4). At an October 2017 visit for the EU-UAE friendship group, he met with Mohammad Bin Zayad, the Crown Prince of Abu Dhabi and de facto ruler often known as MbZ, who emphasized "UAE’s ongoing efforts to strengthen and develop its relations with various countries and communities from around the world while expressing his hope for the strengthening of the partnership between the UAE and EU countries in various sectors, as well as the continuing support of the UAE-EU Parliamentary Friendship Group regarding their mutual issues".

Antonio López-Istúriz White co-chaired an image-boosting session for the UAE to launch a January 2019 exhibition inside the European Parliament that PR-style, emphasized the kingdom’s humanitarian activities around the world and its achievements in women’s rights. Unusually, this event was inaugurated by then-EP President Antonio Tajani. Human rights concerns were not raised and no questions were allowed at the event, which was co-hosted by López-Istúriz and Amal Abdullah al-Qubaisi, then-chair of the closest thing UAE has to a parliament, the Federal National Council. European Parliament political advisor Eldar Mamedov wrote of the event, “One of the cornerstones of the UAE lobbying strategy is to portray the country as a modern, moderate, and socially liberal society in contrast to its regional ‘Islamist’ foes.”

The pandemic has not ended the UAE-EU friendship group’s activities, holding a virtual meeting the UAE's Federal National Council and the MEPs. According to the Emiratis News Agency, the September 2020 meeting “brought together Omar Al Nuaimi, FNC Secretary-General, and Antonio López-Istúriz White, President of the UAE-EU Parliamentary Friendship Group at the European Parliament [who] discussed ways of coordinating joint meetings to bolster GCC-EU cooperation in regional and international issues of common interest”.

The UAE’s warnings about terrorism can land well with both centre-right and far-right MEPs. López-Istúriz shows a consistent pattern of either voting against critical language towards UAE and Saudi Arabia, or abstaining, including when it means departing the EPP line. For example on 3 December 2020 in the Foreign Affairs Committee, unlike the rest of the EPP he abstained rather than criticise the UAE and Saudi Arabia for "grave violations of human rights and international humanitarian law, which qualify as war crimes, such as indiscriminate attacks on the civilians" and voted against part of the amendment that called on the EU to sanction any Emirati and Saudi officials involved in said alleged war crimes. This was part of the vote to adopt the Annual Report 2020 on Common Foreign and Security Policy.

Notably, several MEPs in the UAE friendship group either abstained or voted against a July 2020 resolution in the European Parliament to control arms exports to Saudi Arabia and Yemen, given “the latest SIPRI figures show that the EU-28 is the second arms exporter to both Saudi Arabia and the United Arab Emirates (UAE); whereas according to the UN Group of Regional and International Eminent Experts, parties to the armed conflict in Yemen have perpetrated, and continue to perpetrate, crimes in violation of international law”. The UAE-EU friendship group members Antonio López-Istúriz White and Arnaudd Danjean (who chairs the European Parliament Subcommittee on Security and Defence) both abstained (along with much of the EPP). French far right MEP Thierry Mariani MEP, also a UAE friendship group member, voted against it and tabled several amendments to weaken it.

Some EU-UAE friendship MEPs at a Saudi/UAE embassy dinner to discuss Yemen.

UAE Embassy tweets an image of a dinner at the Saudi embassy with the UAE Ambassador, featuring members of the MEP friendship group “Constructive dinner hosted by @KSAMissionEU during European Parliament’s Plenary session in Strasbourg. Efforts to bring about political solution to the conflict in Yemen were discussed between MEPs, Ambassadors of Yemen, KSA and #UAE, as well as the Arab Coalition Spokesperson.” Note this ‘constructive dinner’ involved only participants from one side of the conflict.

BOX 2: Abu Dhabi’s global PR tsar

British-Australian spin doctor Simon Pearce has coordinated the UAE’s Western PR efforts since the late 2000s. His official title is ‘Special Advisor to the Chairman of the Executive Affairs Authority of Abu Dhabi’ and he is one of Crown Prince MBZ’s inner circle. PR outlet PRovoke describes him as “one of the UAE’s most influential officials”, with “a big budget and an even bigger remit” for “building and protecting Abu Dhabi’s reputation”, overseeing a push SidenoteAndreas Krieg, from draft book chapter 'Little Sparta’s Counterrevolution – How the UAE Weaponizes Narratives' from reactive to proactive and offensive messaging operations.

He plays an outsized role in football, having brokered the deal for Abu Dhabi to buy Manchester City and is a director of the club. In 2018 he was implicated by Der Spiegel in a financial scandal involving overstating sponsorship money to get around spending rules (the club denies any wrong-doing.)

Pearce was previously Chief Executive of Australia’s branch of notorious PR giant Burson-Marsteller (famously described thus: “when evil needs public relations, evil has Burson-Marsteller on speed-dial”, the company is now rebranded as Burson Cohn & Wolfe).

According to the British newspaper The Mail on Sunday, Pearce was a key conduit for a contract for UK PR consultants Quiller, then representing the UAE, to attack targets such as Qatar and the Muslim Brotherhood. After a British journalist contact published a piece that echoed the UAE’s messaging – that Qatar was a key funder of terrorism – The Mail on Sunday reports that Pearce sent an email to Khaled bin Mohammed (Member of the Abu Dhabi Executive Council) with the subject line “Boom!”. It read: “Your highness… I thought you should see this – latest product of our efforts – should be a game-changer for UK understanding – more to come.”

2: Project Associates, and SCL’s disinformation machine

Project Associates is an international PR firm headquartered in London with a branch in Brussels (as well as offices in Berlin, Paris, New York, and Washington). According to US lobby records it represents the UAE as a client and the Director in Brussels is named as taking a direct role in the contract. Moreover, Project Associates subcontracted out communications and influencing work on behalf of the UAE to SCL Social (notorious due to parent SCL Group and sister company Cambridge Analytica’s controversies over data harvesting in the Trump and Brexit votes). SCL Social placed stories in the European media that pushed pro-UAE talking points. Meanwhile as of 11 November 2020, Project Associates continues to represent the UAE, according to a document signed by the Brussels' office Director. The firm does not list the UAE as a client in the EU’s Transparency Register. The Brussels office Director responded to a query from Corporate Europe Observatory about whether the company still represented the UAE saying, "Beyond regularly fulfilling obligations mandated by the Transparency Register or national equivalents, Project Associates maintains strict confidentiality with regard to past, present and prospective clients."

SCL Social placed stories in the European media that pushed pro-UAE talking points.

Project Associates’ website boasts of its reputation management for foreign governments: “Project Associates’ government & political practice provides strategic advisory, digital and traditional campaigning, and public diplomacy services for global political clients. Our clients, usually at head of state or government level, seek our support when confronted with complex challenges.” It continues, “We use our political contacts to expand the reach of leaders; digital campaigns to dominate the digital space; and smart campaigns to energise manifestos and ground-campaigns.” Founder David Rigg is described by PR Week as number four in its 2020 list of top ten crisis PR and reputation management professionals; the company’s board member Baroness Ashton is a former foreign policy chief for the EU and former Commissioner. According to Project Associates' website, “Our work across Europe is coordinated out of our Brussels office, which also manages our engagement with the institutions of the European Union and NATO.” Despite its ongoing work in the EU it belatedly signed up to the EU’s Transparency Register in September 2020, with only one client declared.

However, Project Associates’ London branch has been registered in the US as an active lobbyist for the National Media Council of the United Arab Emirates since 2017 and ongoing (till at least 11 November 2020 when it last updated the information). The National Media Council is a UAE Government body that oversees the kingdom’s media sector. According to the contract, the PR firm is paid “To create and promote counter-narratives that discourage young people from extremism and to promote greater collaboration between the US and UAE on counter-terrorism", "To note the Arab world's positive contributions to regional dynamics and policy achievements, and global affiances”, and “To raise awareness about state sponsored terrorism in the Middle East.”

The Brussels connection appears in the 2017 contract (and supplemental statements), published in the database of the US Department of Justice’s Foreign Agents Registration Act (FARA). FARA requires all actors lobbying on behalf of foreign governments, with any activity in the US, to register and publish their contracts. This contract lists Robert Worthington, Director of Project Associates' Brussels office as one of two rendering “services directly in furtherance of the interests of any of the foreign principals” (the other is founder David Rigg from the London office). The contract dates from 2017, the year that UAE massively boosted its ‘soft power’ lobby spending (see Introduction).

Worthington is described on the company website as “a director at Project Associates and head of the government and political practice. He is also responsible for the pan-European activities of the Group, splitting his time between Brussels and New York, whilst overseeing Project Associates’ US footprint”. The US activity of Project Associates relating to this contract is the reason it appears in the FARA database, which unlike the EU or UK, has a legal requirement for lobbyists to register when representing foreign governments.

Worthington’s bio continues: “He has specialist interest and expertise in advising on governmental affairs and international political trends, with particular focus on the European Union and the Middle East.” It mentions his previous work includes a stint at the UK’s Foreign & Commonwealth Office, as well as being former advisor to both a European commissioner, and a “senior member of Tony Blair’s Government”.

However despite the ongoing US filing, the EU’s Transparency Register entry for Project Associates which covers 1 July 2019 to 1 July 2020 makes no mention of UAE ever having been a client. Perhaps the Director of the Brussels office exclusively works on the contract when based out of the US; however a related filing mentions work beyond the scope of FARA and/or the US.

It appears that it is only when they occasionally appear in the USA’s FARA mandatory database, which is legally enforced, that we get a fuller picture of what European lobbyists are up to on behalf of their clients such as the UAE. (Indeed, US news outlet NBC points out that this filing took place during a flurry of registrations with FARA; these doubled after Trump’s former campaign chair Paul Manafort was convicted for not fully declaring his lobby activities for a foreign country.)

Interestingly, an archived former version of Project Associates’ website claims, “Our work in the GCC [Gulf Cooperation Council, which includes the UAE and Saudi Arabia among others], for private clients, corporates, and international governments, is focused on campaigning, political advisory services, and crisis handling…. we are leaders in creating media campaigns to effect change in both the business and political spheres of the GCC.”

One stand-out aspect of this FARA listing is it shows Project Associates sub-contracted out some of its work on behalf of UAE to SCL Social in 2017, as part of a campaign to promote the UAE’s boycott of Qatar and to link it to terrorism. SCL Social was part of the notorious SCL Group liquidated in May 2018 as a result of the Cambridge Analytica scandal (see Box 3) after being accused of abusing Facebook data. SCL Social was contracted by Project Associates to “Serve as principal strategist on global social media campaign” for UAE.

The SCL Social contract value is $330,00 according to the filed documents, "which encompasses a wide range of services specific to a global social media campaign, including activities that fall outside the scope of FARA”. Again, this raises questions about what if any related activity took place in Europe on behalf of UAE.

Specifically, $75,000 was allocated "for social media activities by SCL Social Limited during the September 2017 session of the U.N. General assembly”. The SCL contract elaborates that the activity around this UN General Assembly involved "social media activity focused on NGO's, foreign diplomats, and certain reporters in New York City.” This activity was based on attempts to link UAE rival Qatar to terrorism in the eyes of the world.

Scanned image of news item in the Indepedent in SCL Social's FARA filing.

Image of one of SCL Social's filings of media stories (op ed in The Independent) it pushed on behalf of its client, from the FARA database.  Sidenotehttps://efile.fara.gov/docs/6473-Informational-Materials-20171013-1.pdf

The activity went beyond this, given that a May 2018 statement notes that SCL Social “receive[d] monies from the client for non-FARA related work after the September 23, 2017 termination date” for its “Global Social Media Campaign”. Another document SCL Social filed with FARA states, “Please note, not all activities covered under the contract with Project Associates are governed by FARA.” Only US-related activities need to be declared with FARA but work beyond its shores is implied.

The contract between Project Associates and SCL Social names Rob Worthington, Director of the Brussels office, as liaison: “For the duration of the Agreement the Contracting Party shall… Keep the Company informed of progress on the Services and in particular to liaise with Rob Worthington in respect of the day-to-day performance of the Services”.

According to SCL Social’s statement it played a role in the placing of on-message articles in the European press for the UAE’s media council, include one in September 2017 in the Brussels newspaper New Europe, tying a Qatari non-profit to terrorist funding. Another was a September 2917 opinion piece in the UK’s The Independent newspaper, again echoing the anti-Qatar message.

Neither article shows any outward sign it has any relation to an interested party paid by the UAE; and if there were indeed any others that weren’t deemed to fall under the US’ FARA rules, we will not know about them.

Another glimpse of the Project Associates contract is given in a 2019 document which records the activity of a London employee on behalf of the UAE's National Media Council: "Outside of the United States, raise awareness about state-sponsored terrorism in the Middle East and noted the Arab world’s regional dynamics and policy achievements, and global alliances.” This confirms that the contract's remit extended beyond the shores of the US, and is signed by Rob Worthington of the Brussels’ office. According to LinkedIn the former employee now works at the UAE’s Ministry of Foreign Affairs.

Curiously, Rob Worthington is described on the website, ‘GetNed’, as being based in the UAE. His bio implies a lot of travel, stating his experience is in “Executive director leadership of the international division of Project Associates… living and working across 7 countries, with responsibility for launching subsidiaries in US, Belgium, France, and Germany, as well as managing Middle East operations.” The bio also mentions his own start-up, Labyrinth Advisory, "serving international clientele”.

Labyrinth Advisory’s mission statement reflects a data-driven digital approach: “Traditional communication strategies are no longer sufficient. New methods and tools are required to make the plan stick and deliver…. We provide a global, online campaign advisory service. Developing persuasive concepts and content. Fighting back against critics. Winning campaigns. Delivering the digital campaign plan…." It refers to “accumulated experience in political and corporate campaigns” being “directed by intelligent data-mining”, as well as using “opposition research and data analytics, we identify the narratives that will shift the dial”; perhaps a little SCL Social-inspired (see Box 3)?

BOX 3: SCL’s 'weapons-grade' comms, and a strange UAE afterlife

SCL Social, sister company to Cambridge Analytica, were both part of SCL Group (originally known as Strategic Communication Laboratories), a notorious strategic communications company. OpenDemocracy observes that SCL Group was "a network of companies [that] was developed which enabled wide deployment of propaganda tools – based on propaganda techniques that were researched and designed for use as weapons in war-zones – on citizens in democratic elections. It’s a logical product of a poorly regulated, opaque and lucrative influence industry." Whistleblower Brittany Kaiser said of SCL’s military intelligence- and psyops-influenced approach, “The methodology was considered a weapon, weapons-grade communications tactics”.

The methodology was considered a weapon, weapons-grade communications tactics

While SCL Group (including subsidiaries SCL Social and Cambridge Analytica) was liquidated in 2018 as a result of the ‘scandal of the century’ over data misuse and political manipulation in the wake of the 2016 Trump election and Brexit votes, in reality it has generated a surprising number of successors. SCL Group seems to be like a mushroom with its fruiting body cut off, but underground roots that grow new heads; and spores in the form of ex-employees that are now seeding new, similar companies. US journalist Wendy Siegelman maps all the SCL-related spin off companies here on an ongoing basis. Interestingly, there appear to be some UAE connections.

Nigel Oakes was the Chief Executive and founder of SCL Group. In July 2017, according to UK company records, Nigel Oakes changed his country of residence from England to the UAE. Moreover, one among the spiderweb of related companies is SCL Insights Ltd – majority owned by Oakes – and is still active in 2020 according to UK company records. Oakes received far less attention than Cambridge Analytica's Alex Nix, but has admitted he lacked an “ethical radar” and back in 1992 he explained to a trade journal, “We use the same techniques as Aristotle and Hitler... We appeal to people on an emotional level to get them to agree on a functional level.”

Emerdata appears to be a holding company for the dissolved companies including Cambridge Analytica and SCL Social. (It is unclear whether the name has any relation to the Emirates.) It appears that despite the liquidation, SCL lives on in various forms, including via Emerdata. According to UK company filings Emerdata is still active, described as engaging in “Data processing, hosting and related activities”, and SCL-linked individuals are listed as Directors, including Rebekah Mercer (Steve Bannon associate and major Trump donor), while Alexander Nix is former director (he was Chief Executive of Cambridge Analytica and a former director of SCL). As of April 2019, according to British court documents, 21 per cent of Emerdata's shares were held by three individuals, including UAE-based Nigel Oakes. Emerdata's subsidiaries include SCL Group Ltd and SCL Analytics Ltd. Emerdata’s relationships have also been mapped by Wendy Siegelman.

Meanwhile the UAE appears to be developing as a centre for big data and cyber intelligence firms (see Box 4).

3. Westphalia Global Advisory: from Abu Dhabi Ministry to Brussels consultants

Abu Dhabi’s roster of lobbyists in the EU is augmented by the relatively new consultancy Westphalia Global Advisory (WGA), based in The Hague and Brussels, which has a specialism in what it variously calls “private diplomatic services”, “geopolitical strategy”, and “strategic communications”.

WGA was co-founded in December 2018 by directors Timo Behr and Tim Eestermans, who both have extensive experience working directly for the UAE Government and both of whom Intelligence Online describe as “close to the UAE’s ambassador in Brussels, Mohammed Issa Hamad Abushahab”. Abushahab previously headed the political department at the UAE’s Ministry of Foreign Affairs between 2013 and 2016, and both Eestermans and Behr worked in Abu Dhabi as his advisers at the Ministry.

Eestermans was a visiting guest lecturer for three months at the Emirates Diplomatic Academy in 2017 teaching in an MA course on “European foreign and security policy, with a specific focus on the MENA/Gulf region”, and before that worked for five years at the Policy Planning Department of the UAE’s Ministry for Foreign Affairs. Behr also spent five years working at the same UAE Policy Planning Department between 2013 and 2018. (The Ministry’s roles include setting the country’s foreign policy, including supervising foreign relations, and promoting the image of the UAE.)

These years partially coincide with the UAE’s waging of the brutal war in Yemen from 2015. Indeed the UAE Ambassador Abushahab had to appear at a press conference in Brussels in June 2018 to deny reporting by Associated Press that the kingdom’s war-time intervention included the rampant use of rape and sexual torture in “UAE-controlled" prisons in Yemen. (This was before the founding of WGA, when the UAE Embassy appears to have been a client of DLA Piper, a corporate law firm and lobby shop in Brussels.)

Co-founder Eestermans, between working for the UAE Ministry of Foreign Affairs and setting up Westphalia, worked at the aforementioned DLA Piper as Senior Counsel between February 2016 and September 2018. His role there described on LinkedIn, was to “develop and implement the concepts of ‘Corporate Diplomacy’ and ‘Privatised Diplomatic Services’ for corporate and foreign government clients looking to improve their access to and understanding of local and international diplomatic processes affecting their operations”. According to Intelligence Online, one of Eestermans' roles there included lobbying on behalf of Saudi Arabia against the US’ Justice Against Sponsors of Terrorism Act, which would allow 9/11 victims to sue Riyadh. The UAE Embassy to the EU was also a client of DLA Piper (with an annual lobby spend of €100,000 - €199,999) up to at least February 2018. Eestermans left DLA Piper and founded Westphalia Global Advisory in 2018.

“a fully integrated diplomatic services and geopolitical risk boutique”

The UAE Mission to the EU was first listed as a client of Westphalia Global Advisory in the Transparency Register on 19 December 2018, SidenoteThis report was updated on 9.02.21. It initially stated that Westphalia Global Advisory registered its client UAE Mission to the EU on its EU lobby transparency register entry on 11 December 2019. Due to technical problems with both the data received from the register and its processing by LobbyFacts this date is incorrect. The client UAE Mission to the EU was registered as a client by Westphalia Global Advisory on 19 December 2018 when it first joined the register. and spends within a range of €100,000 - €199,999 annually. The entry says that the consultancy firm “helps clients understand, navigate, and shape today’s complex international system, mitigate regulatory risks, and realize strategic goals. Westphalia Global is active worldwide, but it focuses most notably on Europe and the Arabian Gulf”. It lists EU policy areas of interest as, "Foreign and Security Policy", "Aviation", "Energy", "Foreign Direct Investment" and "Neighbourhood Policy".

Other staffers give more detail of the company's activity on LinkedIn, including policy analysis, and "projects related to EU policies on Defense and Security". One describes the company as “a fully integrated diplomatic services and geopolitical risk boutique”, and the role as "Monitoring and analysis of EU regulations and specific policies of the interest of the client” as well as "media monitoring" and "social media management".

Timo Behr also gives us a glimpse of Westphalia Global Advisory’s diplomacy role in his study on the ‘Practice and Theory of Stabilization in the Arab Gulf States’ for the Emirates Diplomatic Academy (EDA) in Abu Dhabi. He writes in March 2020: “in order to better explain its foreign policies and ambitions to the outside world, the UAE ought to carefully articulate a more comprehensive doctrine and visions of its stabilisation efforts across the region. This requires careful definition of the UAE’s vision of “stability” and … how these tie into the UAE’s foreign policy agenda.” This very much echoes the narrative of 'stability' described in the introduction.

When contacted by Corporate Europe Observatory, Timo Behr of Westphalia Global Advisory explained: "We provide diplomatic support services to the Embassy. This entails analysis and advise on EU policy-making and European politics at large." He clarified that, "We do not provide strategic communications support to the Embassy, we do not interact with journalists or officials on behalf of the Embassy... We are diplomats and academics, not PR-people. As such, our work is aimed at fostering expertise and understanding of the EU amongst UAE diplomats, through policy assessments and advice." However the firm's own entry in the EU's Transparency Register specifies "strategic communications" as a specialty; and it should be noted that diplomacy, conducted by private companies, still falls under the role of influencing activities.

Westphalia Global Advisory told Corporate Europe Observatory it supports a mandatory Transparency Register for all actors and comments: "Our industry is under enough scrutiny, as it is. We can do without the impression that we have something to hide."

Box 4: The proxy social media war

The UAE’s cyber-intelligence capabilities are growing all the time, and this form of influencing is far beyond the reach of Europe’s weak lobby rules. The kingdom is notorious for its use of troll farms and bots – often working out of Egypt or Saudi Arabia – spreading disinformation and influencing social media conversations, according to Kings College London academic Andreas Krieg. SidenoteAndreas Krieg, from draft book chapter 'Little Sparta’s Counterrevolution – How the UAE Weaponizes Narratives'.

In August 2019 the Head of Cybersecurity Policy at Facebook announced the social media giant had removed many pages, groups, and accounts due to “coordinated inauthentic behavior”; one of the operations originated from the United Arab Emirates, and Facebook states, “created networks of accounts to mislead others about who they were and what they were doing”.

According to Facebook this network used compromised and fake accounts… to run Pages, disseminate their content, comment in Groups and artificially increase engagement. They also impersonated public figures and managed Pages… posing as local news organizations in targeted countries and promoting content about UAE”. Topics cover the UAE’s familiar roster of foreign policy talking points, including – according to Facebook – alleging Qatar and Turkey's support for terrorist groups, criticising “Iran’s activity in Yemen”, and the “successes of the Saudi-led coalition in Yemen”, among others.

Facebook names “two marketing firms — New Waves in Egypt, and Newave in the UAE” as responsible; over 13.7 million accounts followed one or more of these pages. This influencing effort, Facebook calculates, cost around US$167,000 “spent on Facebook ads paid for primarily in US dollars and Emirati dirhams”.

UAE FB image

This example from Facebook is of a related post they removed that reads: "Field Marshal Khalifa #Haftar #The_Libyan_National_Army controls 99% of Libya and now the time has come to finally cleanse and eliminate all terrorism from #Tripoli #Libya_Cleansed".

Around the same time Twitter announced its removal of over 4,000 fake accounts it said were “operating uniquely from the UAE, mainly directed at Qatar and Yemen. These accounts were often employing false personae and tweeting about regional issues, such as the Yemeni Civil War”.

Another network of 267 accounts originated in UAE and Egypt were removed, which Twitter said “were interconnected in their goals and tactics: a multi-faceted information operation primarily targeting Qatar, and other countries such as Iran.” These accounts were managed by a private company DotDev, an Abu Dhabi-based software company with an Egyptian affiliate.

Meanwhile back in January 2019 Reuters reported that DarkMatter, “a controversial cybersecurity firm working for the United Arab Emirates government”, brought hacking experts, including US ex-NSA mercenaries, together in Abu Dhabi “to compromise the computers of political dissidents at home and abroad”, including dissidents, human rights activists, rival leaders, and journalists.

According to Intelligence Online, soon after the Reuters story broke DarkMatter fell out of favour and another Abu Dhabi-based company, Protect, is being favoured in the UAE: “Protect Electronic Systems, which is in increasingly close contact with Western cyber-intelligence firms, is gradually emerging as Abu Dhabi's leading cyber-offensive player,” and has lured some DarkMatter staff away. Protect “provides UAE government users with discreet access to foreign cyber technology via shorter commercial circuits than those in the past. It also well-connected in the UAE”.

Finally, messaging app ToTok launched in the Abu Dhabi Global Market economic free zone was removed from Apple and Google app stores after The New York Times reported in December 2019 that it is a mass surveillance tool of the UAE intelligence services; at the time ToTok was among the top 50 free apps in countries like UK and Sweden. According to The Guardian the UAE government services had access to all information shared through the app. The NYT linked the company behind the app to DarkMatter (see above re Project Raven); and also linked Totok to Pax AI, a data mining firm that shares an office with the UAE’s Signals Intelligence Agency.

Recommendations:

The review of the EU lobby register was recently completed. While we welcome the news that lobbyists and other intermediaries representing non-EU countries will be told to register, the changes fall far short of true lobby transparency. This is in stark contrast to the US' Foreign Agents Registration Act which has the power to impose legal sanctions – as it did with Trump campaign manager Paul Manafort – on those who fail to disclose lobbying for foreign governments. As such there is far more that the EU Institutions and member states can achieve. Based on the evidence produced in this report, Corporate Europe Observatory makes the following urgent recommendations:

  • The European institutions claim the new rules on the lobby register mean it becomes "de facto mandatory". Yet the only real sanction is unregistered lobbyists will not be able to meet the top level of officials. They can continue to meet with all other officials and continue to operate other types of influencing operations under the table. And the lobbying register still depends on the good faith of those reporting clients and financial information. As such it is still voluntary; it needs to become legally-binding, with pro-active powers of audit and investigation for the Joint Transparency Register Secretariat.

  • If lobbyists (including lobby consultancies and law firms) and think tanks fail to disclose up-to-date client and financial information, there should be appropriate legal sanctions.

  • Lobby consultancies that engage in online, data-driven disinformation campaigns on behalf of third country governments with the aim of influencing EU officials and citizens should face sanctions and be barred from meetings with public officials.

  • It cannot be right that investigators and researchers can discover more information about EU lobby activities on behalf of the UAE Government via US transparency rules than EU ones. The EU should set up an additional FARA-style regulation to require the disclosure and publication of all relevant lobby contracts and financial information coming from third governments.

  • The code of conduct attached to the EU’s lobbying register should add to its existing requirements of 'ethical behaviour' and prohibit the representation by private firms of regimes the EU considers to be in breach of human rights. Representation of these clients should result in a ‘blacklist’ with the EU institutions boycotting the firms in question, either for listening to their lobbying representation on any case, or contracting communications work from them.

  • Think tanks should be explicitly required to publish a list of all their funders (including income from non-EU governments) and the sums involved.

  • Lobby transparency standards should not just be mandatory but harmonised across all EU institutions.

  • Member states should also implement legally-binding lobby registers to cover national lobbying activities.

  • The European Parliament should urgently develop clear rules for the “other unofficial groupings” referred to in its Rules of Procedure, including so-called friendship groups. These should require transparent publication of members, funders, organisers, and activities.

These proposed rules should make it much harder for lobby, law, and PR firms to influence EU and member state institutions on behalf of repressive regimes, and they should inculcate a culture whereby lobbying for such governments is seen for what it is: immoral and totally unacceptable.