THE COCOO

COMPETITION ENFORCEMENT

CODES OF CONDUCT


The COCOO abides by the following three Codes of Conduct:


1- The EU Transparency Code of Conduct. The COCOO, as a member of the EU Transparency Register, has signed this Code.


2-The UKLR (the UK Lobbying Register) of which the COCOO is a member, currently recognises The CIPR Code of Conduct


3- The COCOO Code of Conduct:

The COCOO is a public relations political and strategical consultancy. It engages in ethical corporate non-partisan consultancy activity, in defence of competition law and policity. The Cocoo’s lobby communications are incidental to this main activity.

The COCOO is registered in the voluntary UK Lobbying Register (lobbying-register.uk)

Besides abiding by this Code of Conduct, the COCOO also abides by the code of conduct of the Chartered Institute of Public Relations (CIPR), which provides MPs, peers and members of the public, with a channel for making complaints about the conduct of a registered lobbyist.

The COCOO does not represent clients or third parties, but exclusively represents a particular class: the victims of competition law and competition policy violations. It therefore represents the interests of consumers and organisations harmed by such violations, but not the consumers nor the organisations themselves. Such representations are not a client-type relationship, nor made in exchange for payment. Therefore, the Cocoo defines lobbying as promoting exclusively its own interests. The method COCOO uses to lobby, is simply by informing all stakeholders concerned. In order to promote its positions and best practices, the COCOO acts in consultation with all stakeholders.

The COCOO does not allow anybody, whether victims, funders or sponsors, to exercise control on the outcome of its lobbying communications. Instead, all its lobby communications must exclusively express the COCOO’s own opinions and not the opinion of others. To guarantee this safeguard, any contract or funding agreement that the COCOO may enter, must include an Independence Clause.

The COCOO is attentive to the laws and regulations in the UK and the EU.

The COCOO wishes to share its vision of a sophisticated economic efficiency system, and its technical expertise, with institutional bodies, in particular with members of government and parliament, central administrations and local authorities, and to promote its values and services. These positions, whilst taking into account the wider public interest, aim to inform the various actors’ public decision-making. To this end, the Cocoo acts directly with its institutional contacts and/or contributes to the work of professional associations which also carry out lobbying activities. Additionally, the COCOO may call upon external lobbying organisations, to support it on a particular mission.

The COCOO gives itself the means to put in place a high standard of ethical criteria to govern its lobbying activities. This activity is fully in line with its policy on ethics and social responsibility. Its governance structure is placed under the auspices of the Board of Directors, through its Committee on Ethics and Sustainable Development.

This code of conduct applies to all lobbyists acting for the COCOO:

– employees of the COCOO who may undertake lobbying activities among institutional actors for the COCOO;
– where applicable, members of outside firms requested by the COCOO to undertake lobbying activities with institutional actors


Transparency, integrity and reliability:

• The COCOO is committed to allowing public access:

– to its main positions on its website, and to updates thereof in the event of new and significant information;
– to the lists of the main think tanks and professional associations of which it is a member and in which it is active.

• The COCOO is committed to promoting the lobbying practices set out in this code of conduct among all its contacts and thus contribute to the development of high standards in the industry.

• The COCOO refuses to take part in financing any political activity, even in countries where this is authorised and regulated by the law.

• For the sake of information and transparency, this lobbying code of conduct is posted on the COCOO’s website


Each lobbyist acting for the COCOO is committed to:

• Indicating, when communicating with institutional actors, whether he/she is acting on behalf of the COCOO or in support of a professional association of which the COCOO is a member

• Carrying out his/her lobbying activities in accordance with the COCOO’s fundamental ethical principles: act in accordance with laws and regulations; behave honestly and promote a culture of integrity; be loyal; respect others. This excludes, among other things:

– any act of corruption or influence peddling, whether active or passive

– offering or accepting advantages of any kind which do not correspond to a simple display of courtesy, in compliance with the gift, hospitality and technical trip policy applicable within the COCOO

– situations of conflict of interests: in case of doubt, any lobbyist acting for the COCOO will verify with his/her manager or Ethics & Compliance Officer (for any the COCOO employee) or his/her firm or professional organisation (for any member of an outside firm) that he/she is not in a situation of conflict of interests. When choosing the COCOO’s lobbying actors, care will be taken to retain only those who commit to applying the principles contained in this code of conduct. In the case of persons exercising public responsibilities, they may only act on behalf of the COCOO, if the legislation that applies to them so allows, in order to avoid any conflict of interests

• Conditioning the COCOO’s financial participation in symposiums, whatever the organizing body, to a partnership agreement that sets out the terms for this participation

• Appearing on lobbyists’ registers of organisations where they carry out lobbying activities, where these exist, and respect the codes of conduct and regulations of those same organisations

• Observing the codes of conduct and regulations of the institutions, in particular in the context of their missions of general interest, and of the professional organisations in which they operate

• Providing reliable information.


Compliance approach

A responsible lobbying activity requires great rigour, therefore The COCOO’s Directors, with regard to the lobbying activities carried out for his or her organisation:

• Ensures that the COCOO’s positions are known to lobbyists acting for The COCOO.
• Ensures that persons permanently assigned to the lobbying activity have the skills required to carry out their duties, receive regular training in their field of action and receive the support and instructions required for their activity.
• Ensure that any identified breaches of the principles and commitments of this code of conduct are duly terminated.
• Carries out a review of the lobbying action performed within its scope of activities.


Advice or reporting

• Anyone who wishes to request an opinion or advice, for example in case of doubt about how to act, or to point out a difficulty or failure, can contact his/her managers or Ethics & Compliance Officer (for any The COCOO employee) or his/her firm or professional organisation (for any member of an outside firm).

• Any breach of this code of conduct may also be reported by any person inside or outside the COCOO, through its whistleblowing system at the e-mail address:

contact@cocoo.uk

• Information on ethical incidents falling under this code of conduct will be communicated to the COCOO’s Committee on Ethics and Sustainable Development, as part of the COCOO’s ethical compliance process.