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VI. RECOMMENDATIONS AND FOLLOW-UP
247. In view of the findings of the present report, GRECO addresses the following
recommendations to the Netherlands:
Regarding central governments (top executive functions)
i. developing a coordinated strategy for the integrity of persons entrusted with top
executive functions, based on analysis of risks, aiming at preventing and managing
various forms of conflicts of interest, including through responsive advisory, monitoring
and compliance measures (paragraph 36);
ii. (i) that a consolidated code of conduct for persons entrusted with top executive functions
be developed, complemented with appropriate guidance regarding conflicts of interest
and integrity related matters (e.g. gifts, outside activities, third party contacts, lobbying,
etc.) and made easily accessible to the public; and (ii) that such a code be coupled with a
mechanism of supervision and sanctions (paragraph 43);
iii. (i) establishing confidential counselling to persons entrusted with top executive functions
on integrity related issues, conflicts of interest etc.; and (ii) raising the awareness of
integrity matters among persons entrusted with top executive functions, including
through training at regular intervals (paragraph 53);
iv. (i) introducing rules and guidance on how persons entrusted with top executive functions
engage in contacts with lobbyists and other third parties who seek to influence
governmental processes and decisions, and (ii) increasing the transparency of contacts
and subject matters concerning lobbying of persons who are entrusted with top executive
functions (paragraph 70);
v. that a requirement of ad hoc disclosure be introduced in respect of persons entrusted
with top executive functions in situations of conflicts between private interests and
official functions, when they occur (paragraph 78);
vi. introducing general rules dealing with post-employment restrictions before persons
entrusted with top executive functions seek new employment in the private sector
and/or are about to enter into such employment after their termination of functions in
the public sector (paragraph 96);
vii. (i) that persons entrusted with top executive functions be obliged to declare their
financial interests publicly on a regular basis; ii) considering including financial
information on spouses and dependent family members in such declarations (it being
understood that the latter information would not necessarily need to be made public)
and (iii) that the declarations be subject to an appropriate review mechanism
(paragraph 100);
viii. ensuring that the procedures allowing for investigation and prosecution of abuse of office
(including passive bribery) do not hamper the criminal justice process in respect of
ministers/state secretaries suspected of having committed corruption related offences
(paragraph 106);
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