27 April 2005Re: European Transparency InitiativeDear Commissioner Kallas,We are writing to you regarding the European Transparency Initiative which you launched recently.We very much welcome this long overdue proposal which has the potential to help build confidence inthe European political system, and address some of the widespread concerns regarding ‘democraticdeficits’ associated with the EU’s institutions and processes.Over the past decade we have been engaged in a programme of independent research into the publicrelations and lobbying industry in Scotland, the UK and Europe. This work has been funded by theEconomic and Social Research Council (ESRC) in the UK. We have been encouraged by yourrecognition of the importance of lobbying as a matter of legitimate concern for the Commission, aswell as the wider European public.We have monitored the growth and development of the lobbying industry in the UK and EU and haveinterviewed a wide range of lobbyists and public relations professionals, ranging across the commercial(consultancy and in-house) and voluntary sectors. This work has broadened our perspective on theissues relating to lobbying.We believe organisations have a democratic right to lobby the Commission and Parliament and theyhave a right to employ professional advisers. However, the ability to employ advisers is systematicallylimited by resources. Lobbyists, by definition, work for clients who hire them to pursue their owninterests. Commercial lobbying consultancies overwhelmingly work for business interests, who alsoprovide by far the largest proportion of their income. This goes to the heart of concerns about financialresources determining access and influence in the political process. The regulation of lobbying inBrussels could be a significant first step to address these concerns.Our research on lobbying in Scotland and the UK, lead us to conclude that self-regulation is a veryweak and inadequate solution to the issue of probity and lobbying influence. It does very little (if anything) to promote transparency and accountability in the political process. Lobbying tradeassociations exist largely in order to defend the sectional interests of their industries and members – notto enforce transparency or for the benefit of the wider public. Both of the dedicated lobbying tradeassociations in the UK (APPC and ASPA) have come into existence in the last ten years as a result of media exposure of alleged lobbying malpractice. One of their main aims in practice is to resist properdemocratic scrutiny of their activities. SEAP was created when the regulation of lobbying was last onthe political agenda in Europe in 1997.Objections to a statutory register of lobbyists usually focus on the difficulty in defining lobbyists andthe impracticality of maintaining a register. There is in fact plenty of evidence to suggest that theseobjections are exaggerated and misplaced. If a statutory register of lobbyists includes all those wholobby then the difficulty of distinguishing between different types of lobbyists becomes lessproblematic. In Canada and the US (at both State and Federal level) systems of registration have beenintroduced effectively and efficiently manage a system of disclosure.