"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 additionally became President of the Dublin-based International Financial Services Centre. Mr Bruton has also undertaken work for Montpelier RG, American Oriental Bio Engineering, Gerson Lehman Group, McDermott, Will and Emery, and Ingersoll Rand.
Cabinet DN's client list for the year 2011 included US multinational AT&T which provided 13 per cent of its turnover as well as other US companies such as NYSE Euronext. Source: EU Lobby Transparency Register http://ec.europa.eu/transparencyregister/public/consultation/displaylob…
CEO first applied for copies of Mr Bruton's authorisation to undertake these roles in December 2010. At that point, it became clear that the Commission had neither received them nor authorised 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.” Source: 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.
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. Mr Bruton says that he was not aware that the revolving door rules applied to his case, hence his late applications for authorisation. The Commission should have been proactive in informing and reminding him of his obligations."
"Furthermore, the Commission does not appear to have probed Mr Bruton's job moves very deeply, including the information that Mr Bruton provided that he had been in touch with some Commission officials to discuss his new work. CEO considers that if these job moves had been investigated more thoroughly, the Commission would have recognised that a two year cooling-off period would have been appropriate. Afterall, the conditions that the Commission placed on Mr Bruton's new posts would not prevent the risk of conflicts of interest from arising. They would not prevent Mr Bruton from lobbying other parts of the Commission or offering lobbying advice to Cabinet DN clients using his insider know-how about the ways of working of the EU institutions and his no doubt extensive contact book".