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EuroPAM · The European Public Accountability Mechanisms

The EuroPAM database is part of an EU-funded digital whistleblowing project (DIGIWHIST) that aims to improve trust in governments and efficiency of public spending across Europe. This is done by empowering civil society, investigative journalists, and civil servants with the information and tools they need to increase transparency in public spending and accountability of public officials in all EU and neighbouring countries. These countries include: Armenia, Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, European Commission, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, and the United Kingdom.

In terms of content, EuroPAM is an extension of the Public Accountability Mechanisms Initiative (PAM) of the World Bank, which is a primary data collection effort that produces assessments of in-law and in-practice efforts to enhance the transparency of public administration and the accountability of public officials. The EuroPAM database serves as a European transparency legislation observatory that is based on the PAM indicators for financial disclosure, conflict of interest restrictions, and freedom of information, while also adding data on public procurement, and updating the International Institute for Democracy and Electoral Assistance (IDEA) database on political financing.

To ensure the reliability of in-law data, a rigorous and systematic approach is applied to data collection and analysis. Researchers produce summaries of the legal provisions collected from primary source documents, in the original language where possible. Following the preliminary analysis performed by researchers, the data is sent to technical in-country experts for feedback on accuracy and relevance. Country experts are intended to have either in-depth legal knowledge of the mechanism being examined in a specific country or expertise in a related field. The final data is released in both quantitative and qualitative form for policy and research purposes. Several rounds of data collection are envisioned from 2012 onwards.

Mechanisms

Freedom of Information/Right to information


The right to information guarantees access to information or records held by government bodies. It may also prescribe proactive disclosure of official data or documents, specify the procedures for access, and outline exemptions for purposes of national security and other concerns. These obligations establish a method of accountability for governments that is upheld by civil society and individual citizens.

Main areas of in-law indicator coverage:

  • Scope and Coverage of law
  • Information access and release
  • Exceptions and Overrides
  • Sanctions for non-compliance
  • Monitoring and Oversight

Click here for EuroPAM in-law indicators on Freedom of Information

Conflict of Interest Restrictions


Conflict of interest refers to a situation in which an individual is in a position to exploit an official capacity for personal benefit, but has not done so yet. In short, the presence of a conflict of interest is not an indicator of improper conduct, but rather a warning of its possibility. Conflict of interest restrictions prohibit public officials from participating in any number of activities that may be seen to compromise their impartiality. The operating principle of a conflict of interest system is to assist public officials in avoiding situations where a conflict of interest can arise.

Main areas of potential conflict of interest that may be restricted:

  • Accepting gifts
  • Private firm ownership and/or stock holdings
  • Ownership of state-owned enterprises (SOEs)
  • Holding government contracts
  • Board member, advisor, or company officer of private firm
  • Post-employment
  • Simultaneously holding policy-making position and policy-executing position
  • Participating in official decision-making processes that affect private interests
  • Assisting family or friends in obtaining employment in public sector

Click here for EuroPAM in-law indicators on Conflict of Interest Restrictions

Financial Disclosure (combination of income, assets and conflicts of interest)


The purpose of obtaining the declarations of public officials depends on the aim of the overall accountability regime. When focusing on conflict of interest, disclosures can be used to identify potential bias in public activities. For regimes that aim to prevent illicit enrichment [and to punish public officials for improper behavior], disclosures may be used to identify assets or incomes that are not attributable to salary, gift, or loan. Both types of disclosure regimes aim to prevent the occurrence of financial misconduct in public office, such as bribery or theft, while also maintaining records of the financial activities of public officials for future use in prosecution.

Main areas where disclosure may be required:

  • Income and Assets

    • Real estate
    • Movable assets
    • Cash
    • Loans and Debts
    • Income from outside employment/assets
  • Incompatibilities

    • Gifts received as a public official
    • Private firm ownership and/or stock holdings
    • Ownership of state-owned enterprises (SOEs)
    • Holding government contracts
    • Board member, advisor, or company officer of private firm
    • Post-employment
    • Simultaneously holding policy-making position and policy-executing position
    • Participating in official decision-making processes that affect private interests
    • Concurrent employment of family members in public sector

Click here for EuroPAM in-law indicators on Financial Disclosure

Political financing


Political financing is about the role that money plays in the political sphere. Money is necessary for inclusive democracy and effective governance, allowing candidates and parties to reach out to voters and for the building of long term political platforms organizations. However, it can also lead to politicians listening to their donors rather than their voters and to government contracts awarded not to the company with the best bid but to the one that provided most money during the last election campaign. Countries around the world have introduced various provisions limiting who and how much can be contributed to political parties and electoral candidates; how such funds can be used; how actors have to report on their finances; and how oversight and enforcement is to be achieved.

Main areas of in-law indicator coverage:

  • Bans and limits on private income
  • Public funding
  • Regulations on spending
  • Reporting, oversight and sanctions

Click here for EuroPAM in-law indicators on Political Financing

Public Procurement


Public procurement is the process whereby governments buy goods and services. They can buy practically anything from fruit to nuclear power plants. Still, the same set of procedural rules applies to the selection of suppliers and information published on tenders and contracts. The public procurement procedure starts with a call for tenders and ends with a contract award unless there is also an announcement about the completion of contract implementation. While each key phase of the procurement procedure has to take place according to the regulations, not everything is published in a central online place. By implication, we often miss information from some phases. Most importantly, the contract award announcement is always published meaning that it is going to be the spine of our database.

Public procurement requires interaction among three major actors while there is a range of external actors intervening under some circumstances. The three actors internal to the public procurement process are 1) issuers of tender [government agencies/departments], 2) public procurement advisors or brokers, and 3) bidder companies [private sector firms]. There are external actors within the state such as 4) politicians who can also take on senior civil service positions; and 5) review bodies such as courts, state audit institutions, and competition agencies.

Main areas of in-law indicator coverage:

  • Scope of law
  • Main procedure types/procurement
  • Preferential treatment of bidders
  • Bid evaluation
  • Regulations on sub-contracting
  • Complaints
  • Mandatory record-keeping
  • Supporting institutions and regulations
  • Framework agreements

Click here for EuroPAM in-law indicators on Public Procurement