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top officials (Commissioner, Force Command, Central Unit Command, the chief constables of the
units and the management of support units and the Executive Board of the Police Academy) are
made public.

219. Moreover, some to be designated police officers, who perform work involving particular risks
of financial conflicts of interest or the risk of improper use of price-sensitive information, are to
declare their financial interests (stocks / legal claims / real estate / building land / financial holdings
in a company / mortgage debts etc.), as well as the possession of and transactions with securities
that could affect the interests of the service in so far as these relate to the performance of their
duties. A standard form is not used for such declarations and the NPN does not keep a register for
this purpose.

220. KMar officers are obliged to declare secondary activities if they affect the police service and
to have them approved. Such declarations are to be submitted to the manager and the CKMar
provides an opinion to the Minister of Defence. Secondary activities that are declared by top
managers (Vice-Admiral/Lieutenant-General) are made public. KMar officials who hold or acquire
financial interests as a result of which the proper fulfilment of their duties or the proper functioning
of the organisation would not be reasonably ensured, must declare financial interests (stocks / legal
claims / real estate / building land / financial holdings in a company / mortgage debts etc.) to the
Minister of Defence. The obligation to declare financial interests applies to a number of to be
designated top officials.

221. The GET notes that both NPN and KMar officials are obliged to file declarations in respect of
secondary activities and that officers on designated posts which are vulnerable to conflicts of
interests, are to declare their financial interests. Moreover, it is to be welcomed that declarations on
outside activities in respect of top officials in both Services are made public. Having said that, the GET
is of the opinion that the current regime of declarations is the result of a minimalist approach to
declarations. Considering that financial interest declarations represent an important tool for
preventing, monitoring and revealing conflicts of interest and to preventing corruption, the current
system is not satisfactory. It is to be noted that the officials have a margin of appreciation in deciding
whether a secondary activity is at all in conflict with the service and thus whether s/he is at all
obliged to declare, even if neglecting to declare may be punishable afterwards. Furthermore, the
declarations are not to be submitted on a regular basis and the financial interest declarations are to
be limited to officials occupying particularly sensitive positions in the services. At present no posts
are designated. The regime of declarations, at least in respect of top officials of the NPN and KMar
therefore need to be enhanced and put in practice. GRECO recommends (i) enhancing the current
regime for declarations by introducing an obligation in respect of the top management of the
National Police (NPN) and the Royal Marechaussee (KMar) to declare financial interests in
accordance with a predefined format, when taking up their duties and at regular interval
thereafter, (ii) to designate posts which are vulnerable to conflicts of interest, and (iii) to provide
for suitable oversight.

Supervision and enforcement

Internal oversight and control

222. The Dutch authorities have explained that internal control within the NPN and KMar is built
on three levels: 1) direct managerial control (first line management control); 2) senior management
control (support advice and coordination, risk management, financial control etc.); and 3) internal
audit. Internal investigations are triggered when there are suspicions of misconduct or neglect of
duty by the officials. These investigations are conducted at the request and under the responsibility
of the competent authority of the NPN or the KMar.

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