of Mr Kallas to Ms Day of 28 March 2015 requesting authorisation for a post-mandate activity - Consultancy activities in Nortal

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Ref. Ares(2015)2250337-29/05/2015 List of documents Initial request Ms Vicky Cann (CEO) 2015-2375 Post-mandate activities Mr Kallas Scope of the request: "Further to the documents already requested under GestDem 2015/1147,1 am requesting copies of all subsequent applications by Siim Kallas which seek Commission authorisation for new professional activities under the commissioner code of conduct, including his work for Nortal. I would further like to request any emails, correspondence and meeting notes which relate to these applications; all opinions from the ad hoc ethical committee on each case; and copies of the Commission's final decision in each case. " Document Description and references Status Mr Kallas 1 E-mail of Mr Kallas to Ms Day of 28 March 2015 Ref. Ares(2015)1379499-30/03/2015 E-mail of Mr Kallas to Ms Day of 28 March 2015 requesting authorisation for a post-mandate activity - Consultancy activities in Nortal Partial disclosure- E-mail address of former Commissioner deleted- Exception in Article 4(1) letter b) 2. LS Consultation E-mail of SG of 30.03.2015 and e-mail of LS of 08.04.2015 E-mail of SG of 30 March 2015 and reply of the LS by e-mail of 8 April 2015; Partial disclosure of cover e-mails (Names and e- mails of Commission's officials deleted - Exception in Article 4(1) letter b); Ref. Ares(2015)1408105-31/03/2015 Full disclosure of draft decision. 3. Commission Decision Activités après cessation de fonction d'un membre de la Commission- Communication de M le Président - OJ 2115 Full disclosure 1

С(2015)2474 of 10 April Commission Decision C(2015)2474 of 10 April 2015 2015 4. PV (2015) 2122 of 15 April 2015 Decision of 15 April 2015 Public Document (copy not enclosed) 5. Letter of Ms Day to Mr Kallas of 15 April 2015 Ref. Ares(2015)1608809-15/04/2015 Letter of Ms Day to Mr Kallas informing him of the adoption of the Commission decision on the request for authorisation of a postmandate-activity Partial disclosure cover note-e-mail address of former Commissioner deleted- Exception in Article 4(1) letter b); Attachment corresponds to document n 3 above. 2

DOCUMENT 1 Ref. Ares(2015)1379499-30/03/2015 From: Sent: To: Subject: Siim Kallas Saturday 28 March 2015 13:14 DAY Catherine (SG) Post-commission activités again Dear Catherine! I was offered limited consultancy activities in a company about what I send You some information. My role will be to participate in projects promoting good governance practices in countries outside EU. I am ready to accept this proposal, if the Commission agrees. Nortal is a consultancy and software company headquartered in Tallinn, Estonia. The company has 630 employees in 8 countries and an annual revenue of 42 million EUR (2014). The company is owned by key employees and managers, pension funds and private equity. The company's vision is building a seamless society through removing obstacles of development, reducing hidden transaction costs in societies, increasing transparency of administration, reducing waste and increasing overall procedural efficiency. Nortal was founded in 2000. The company has enjoyed considerable growth throughout its history, being the fastest growing software development and consultancy company in the Baltic region since its inception. Nortal can proudly claim that almost half of e-estonia, one of the World leading e-governance countries, services are developed by us over the years. In the field of Good Governance, Nortal has helped different governments (Qatar, Oman, Estonia, Finland, Lithuania, Nigeria, Botswana, Moldova etc) to provide better services for their citizens and businesses and to move closer to the objective of seamess society. The focus areas in the Good Governance practice are ease of doing business, ease of living, public finance management and e- infrastructure. All the best! Siim Kallas

DOCUMENT 2 Ref. Ares(2015)1408105-31/03/2015 From: Sent: To: Cc: Subject: Attachments: Importance: (SG) Monday 30 March 2015 17:37 (SJ).SG); (SG) Projet de décision de la Commission sur une activité après cessation de fonction de M. Kallas Draft Décision Kallas Consultancy activities for Nortal.doc; FW: Postcommission activités again (23,7 KB) High Chère Je te prie de bien vouloir trouver ci-joint un projet de décision relatif à une nouvelle activité après cessation de fonctions de M. Kallas, en tant que Consultant pour "NORTAL" une entreprise de consultance et de software établie à Talinn. Merci de bien vouloir donner l'accord ou les observations du SJ. Cette consultation sera également envoyée via ARES. Nous voudrions soumettre cette décision à la réunion du Collège du mercredi 15 avril (OJ 2122 ) et l'avis du SJ serait dès lors apprécié si possible pour mercredi 8 avril. Je joins également l'e-mail de M. Kallas à la Secrétaire Générale du 28 mars. Merci d'avance de ta collaboration European Commission Secretariat General B.3 Ethics

.SG) From: (SJ) Sent: Wednesday 8 April 2015 19:32 To: " Cc: (SG); " ;SG); ; (SJ) Subject: RE: Projet de décision de la Commission sur une activité après cessation de lonction de M. Kallas The Legal Service can give its agreement to this draft decision. Just a typo: Tallinn. Regards,

MEMORANDUM FROM THE PRESIDENT TO THE COMMISSION According to Article 245(2) of the Treaty on the Functioning of the European Union, the Members of the Commission give a solemn undertaking that, both during and after their term of office, they will respect the obligations arising therefrom and, in particular, their duty to behave with integrity and discretion as regards the acceptance, after they have ceased to hold office, of certain appointments or benefits. Further to this Treaty provision, the Code of Conduct for Commissioners (C (2011) 2904 final) establishes a specific procedure for the assessment of planned occupations which former Commissioners intend to take up during the eighteen months after they have ceased to hold office. The Commission shall examine the nature of the planned occupation and, if the activity is related to the content of the Commissioner's portfolio, it shall seek the opinion of the Ad hoc Ethical Committee. With his e-mail of 28 March 2015 to the Secretary General of the Commission, former Vice-President Siim Kallas informed the Commission about his wish to engage in a consultancy activity for Nortal, a consultancy and software company headquartered in Tallinn. Mr Kallas informed that Nortal is a consultancy and software company founded in 2000. It has 630 employees in 8 countries, an annual revenue of 42 M and has enjoyed considerable growth throughout its history, being the fastest growing software development and consultancy company in the Baltic region since its inception. The company's vision is building a seamless society through removing obstacles of development, reducing hidden transaction costs in societies, increasing transparency of administration, reducing waste and increasing overall procedural efficiency. Mr Kallas explained that his role will be to participate in projects promoting good governance practices in countries outside the European Union. The Services of the Commission examined the nature of Mr Kallas' envisaged activity with Nortal and came to the conclusion that this activity is not linked to his former Commission portfolio as Vice-President in charge of Transport Policy. They furthermore considered that Mr Kallas' envisaged activity does not present any risk of incompatibility with the interests of the European Union or with Article 245(2) of the TFEU, provided that Mr Kallas complies with his obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, notably as concerns his duty to behave with integrity and discretion, the protection of collegiality and confidentiality of the matters dealt with by the Commission during his mandates as Member of the Commission and the prohibition of lobbying the Commission and/or its services, during eighteen months after his term of office, for Nortal. The Commission is invited: (1) to decide that former Vice-President Siim Kallas' envisaged consultancy activity for Nortal is compatible with Article 245(2) of the TFEU on the conditions that Mr Kallas abides by his obligations stipulated in Articles 245 and 339 of the

TFEU and in the Code of Conduct for Commissioners, namely that he behaves in all circumstances with integrity and discretion, that he protects the collegiality and confidentiality of the matters dealt with by the Commission during his mandates and that he refrains from lobbying the Commission and/or its services, during eighteen months after the end of his mandate, for Nortal. to instruct the Secretary General to inform Mr Kallas about the present decision and the conditions contained therein.

COMMISSION EUROPÉENNE : SECRÉTARIAT GÉNÉRAL Bruxelles, le 10 avril 2015 C(2015) 2474 COMMISSION INTERNE OJ 2122 ACTIVITES APRES CESSATION DE FONCTION D'UN MEMBRE DE LA COMMISSION Communication de M. le PRESIDENT t Cette question est inscrite à l'ordre du jour de la 2122 ime réunion de la Commission le 15 avril 2015. Destinataires : Membres de la Commission

MEMORANDI JM FROM THE PRESIDENT TO TOE COMMISSION According to Article 245(2) of the Treaty on the Functioning of the European Union, the Members of the Conunission give a solemn undertaking that, both during and after their term of office, they will respect the obligations arising therefrom and, in particular, their duty to behave with integrity and discretion as regards the acceptance, after they have ceased to hold office, of certain appointments or benefits. Further to this Treaty provision, the Code of Conduct for Commissioners (C(2011) 2904 final) establishes a specific procedure for the assessment of planned occupations which former Commissioners intend to take up during the eighteen months after they have ceased to hold office. The Commission shall examine the nature of the planned occupation and, if the activity is related to the content of the Commissioner's portfolio, it shall seek the opinion of the Ad hoc Ethical Committee. With his e-mail of 28 March 2015 to the Secretary General of the Commission, former Vice-President Siim Kallas informed the Commission about his wish to engage in a consultancy activity for Nortal, a consultancy and software company headquartered in Tallinn. Mr Kallas informed that Nortal is a consultancy and software company founded in 2000. It has 630 employees in 8 countries, an annual revenue of 42 M and has enjoyed considerable growth throughout its history, being the fastest growing software development and consultancy company in the Baltic region since its inception. The company's vision is building a seamless society through removing obstacles of development, reducing hidden transaction costs in societies, increasing transparency of administration, reducing waste and increasing overall procedural efficiency. Mr Kallas explained that his role will be to participate in projects promoting good governance practices in countries outside the European Union. The Services of the Commission examined the nature of Mr Kallas' envisaged activity with Nortal and came to the conclusion that this activity is not linked to his former Commission portfolio as Vice-President in charge of Transport Policy., They furthermore considered that Mr Kallas' envisaged activity does not present any risk of incompatibility with the interests of the European Union or with Article 245(2) of the TFEU, provided that Mr Kallas complies with his obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, notably as concerns his duty to behave with integrity and discretion, the protection of collegiality and confidentiality of the matters dealt with by the Commission during his mandates as Member of the Commission and the prohibition of lobbying the Commission and/or its services, during eighteen months after his term of office, for Nortal.

The Commission is invited: (1) to decide that former Vice-President Siim Kallas' envisaged consultancy activity for Nortal is compatible with Article 245(2) of the TFEU on the conditions that Mr Kallas abides by his obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, namely that he behaves in all circumstances with integrity and discretion, that he protects the collegiality and confidentiality of the matters dealt with by the Commission during his mandates and that he refrains from lobbying the Commission and/or its services, during eighteen months after the end of his mandate, for Nortal. (2) to instruct the Secretary General to inform Mr Kallas about the present decision and the conditions contained therein.

Hl Ref. Ares(2015)1608809-15/04/2015 EUROPEAN COMMISSION DOCUMENT 5 Brussels, SG/B3 Ares(2015) Mr Siim Kallas By e-mail to: Dear Mr Kallas, I am pleased to inform you that the Commission decided, during its 2122 nd meeting of 15 April 2015, that your envisaged consultancy activity for Nortal is compatible with Article 245(2) of the TFEU on the condition that you abide by your obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, namely that you behave, in all circumstances, with integrity and discretion, that you protect the collegiality and confidentiality of the matters dealt with by the Commission during your mandates and that you refrain from lobbying the Commission and/or its services, for Nortal, during eighteen months after the end of your mandate. Please find enclosed Commission decision C(2015) 2474. Yours sincerely, Catherine Day Enel: Commission Decision C(2015) 2474 Cc: Mr Selmayr (Head of President Junckers Private Office) Commission européenne/europese Commissie, 1049 Baixelies/Brussel, BELGIQUE/BELGIë - Tel. +32 22991111 Office: BERL 13/173 - Tel. direct line +32 229-58312 - Fax +32 229-93229 http://ec,europa.eu/dgs/secretariat_general/ xxxxxxxxx.xxx@xx.xxxxxx.xx

Λ $ / Ь.... - Шк ;:\ν \Ч es?ä COMMISSION EUROPÉENNE SECRÉTARIAT GÉNÉRAL Bruxelles, le 10 avril 2015 C(2015)2474 COMMISSION INTERNE OJ 2122 ACTIVITES APRES CESSATION DE FONCTION D'UN MEMBRE DE LA COMMISSION Communication de M. le PRESIDENT f Cette question est inscrite à l'ordre du jour de la 2122 ime réunion de la Commission le 15 avril 2015. Destinataires : Membres de la Commission

MEMORANDUM FROM THE PRESIDENT TO THE COMMISSION According to Article 245(2) of the Treaty on the Functioning of the European Union, the Members of the Commission give a solemn undertaking that, both during and after their term of office, they will respect the obligations arising therefrom and, in particular, their duty to behave with integrity and discretion as regards the acceptance, after they have ceased to hold office, of certain appointments or benefits. Further to this Treaty provision, the Code of Conduct for Commissioners (C(2011) 2904 final) establishes a specific procedure for the assessment of planned occupations which former Commissioners intend to take up during the eighteen months after they have ceased to hold office. The Commission shall examine the nature of the planned occupation and, if the activity is related to the content of the Commissioner's portfolio, it shall seek the opinion of the Ad hoc Ethical Committee. With his e-mail of 28 March 2015 to the Secretary General of the Commission, former Vice-President Siim Kallas informed the Commission about his wish to engage in a consultancy activity for Nortal, a consultancy and software company headquartered in Tallinn. Mr Kallas informed that Nortal is a consultancy and software company founded in 2000. It has 630 employees in 8 countries, an annual revenue of 42 M and has enjoyed considerable growth throughout its history, being the fastest growing software development and consultancy company in the Baltic region since its inception. The company's vision is building a seamless society through removing obstacles of development, reducing hidden transaction costs in societies, increasing transparency of administration, reducing waste and increasing overall procedural efficiency. Mr Kallas explained that his role will be to participate in projects promoting good governance practices in countries outside the European Union. The Services of the Commission examined the nature of Mr Kallas' envisaged activity with Nortal and came to the conclusion that this activity is not linked to his former Commission portfolio as Vice-President in charge of Transport Policy. r They furthermore considered that Mr Kallas' envisaged activity does not present any risk of incompatibility with the interests of the European Union or with Article 245(2) of the TFEU, provided that Mr Kallas complies with his obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, notably as concerns his duty to behave with integrity and discretion, the protection of collegiality and confidentiality of the matters dealt with by the Commission during his mandates as Member of the Commission and the prohibition of lobbying the Commission and/or its services, during eighteen months after his term of office, for Nortal. ***

The Commission is invited: (1) to decide that former Vice-President Siim Kallas' envisaged consultancy activity for Nortal is compatible with Article 245(2) of the TFEU on the conditions that Mr Kallas abides by his obligations stipulated in Articles 245 and 339 of the TFEU and in the Code of Conduct for Commissioners, namely that he behaves in all circumstances with integrity and discretion, that he protects the collegiality and confidentiality of the matters dealt with by the Commission during his mandates and that he refrains from lobbying the Commission and/or its services, during eighteen months after the end of his mandate, for Nortal. (2) to instruct the Secretary General to inform Mr Kallas about the present decision and the conditions contained therein.