Transparency International and APAA, a Czech industry association established in 2012 by six local lobbying firms, are staging a seminar this morning in Prague to promote ethical lobbying. How very encouraging! *


Still sitting pretty after all these years: Jana Marco of APAA, AMI and PAN Solutions with Petr Fiala and Alexandr Vondra of ODS.


Or is it? According to its website, “APAA seeks transparency and openness in the provision of public affairs services, by means of the registration of its members and the exercise of supervision over their compliance with our Ethical Code.” On paper, APAA’s ethical code is impeccable, banning bribes, bad manners and many other nasty things besides.

In an attempt to test the robustness of the code, and to clarify how exactly members hold each other to account, I sent APAA’s chairman, Václav Nekvapil, some questions in 2013 about the disclosure requirements APAA imposes upon its members – or better said, that its members impose upon each other.

I asked if APAA obliges its members to disclose the commercial interests they represent before a conflict appears. Does the ruling body of the association (which is made up of its six members) know if any member is currently under contract, or has been under contract in the recent past, to any public institution or company in which the state holds a majority stake?

Do members impose upon each other an obligation to disclose the beneficial owners of other member companies as a condition of membership, and if not, how is it possible to determine whether a criminal conflict of interest has occurred? Are members obliged to inform each other of any financial relationship with former government officials?

In short, does APAA maintain a record of its members’ beneficial owners, employees, paid advisers and clients?

The chairman replied that that such information is not shared with competitors, which was to miss the point. I asked a professional body claiming to promote transparent lobbying if it kept a credible register of members’ interests: I did not ask it to disclose the contents of that register to the outside world.

Of course, the answer is that APAA does not keep a record of such things. The conditions of becoming a member of the association are as follows: a member must have been in the lobbying business for 18 months; it must have three or more consultants (they could all be external), two of whom must have worked for two years as a lobbyist; and lastly, a member must have at least two clients who are also willing to write a reference for it as part of the application for membership.

And that’s it. The rest is hot air.

It is all very well for APAA to claim to seek transparency in the Czech lobbying industry and to guarantee the professionalism of its members and their employees. But such claims are empty and misleading unless it obliges its members to disclose where the money is coming from and where it is going.

The fact that you and I will never know if only three of APAA's six member companies or their beneficial owners are on the payroll of the ČEZ Group (Euroffice, Merit Government Relations and PAN Solutions) is beside the point. What matters is that the ruling body of the association has no official knowledge either.

The fact that you and I will never know if the lawyer Radek Pokorný is an owner of Merit Government Relations, which works for ČEZ, is beside the point. What matters is that the ruling body of the association has no official knowledge either.

The fact that you and I will never know if the former supervisory board chairman of ČEZ, Martin Kocourek, is a paid adviser to Merit Government Relations, which works for ČEZ and is said to be owned by Radek Pokorný, is beside the point. What matters is that the ruling body of an industry association representing itself as a guarantor of the highest ethical standards of its members has no official knowledge either.

Sadly, I shall not be able to make it to the seminar this morning. However, if I had been able, I would repeat the question I put to Nekvapil in 2013: does APAA maintain a record of its members’ beneficial owners, employees, paid advisers and clients? And if not, how can it credibly enforce its well-crafted 'Ethical Code'?

Oh, and I would also ask Jana Marco of AMI/PAN Solutions (who has worked for years as a parliamentary lobbyist for Martin Roman and Daniel Křečínský) whether there was ever a direct business relationship between companies she owns and Alexandr Vondra, the former ODS minister. Did Marco and her business partners ever acquire Vondra's stake in the lobbying firm Dutko Worldwide Prague? If so, when -before or after she was awarded the Topolánek government contract to promote an American military radar station in the Czech Republic?


*For details of the seminar taking place today, see here