The Registry aims to keep a record of independent persons and organisations that participate in the drafting and implementation of public policy in defence of the interests of third parties or other organisations.
The Ministry of the Presidency of the Government of Catalonia manages the Registry of interest groups of the Catalan administration and public sector.
Information leaflet on the SERGI application for monitoring the relations with interest groups in the AMB [in Catalan]
The ABM publishes the public schedule of the AMB's senior officials and managers in relation to lobbyists since january 2020, in accordance with paragraph 2.3. of the Code of ethics and conduct for senior officials of the AMB and its associated entities.
From the following link, you can access the list of interviews and meetings held with individuals or legal entities that are considered to be interest groups, including the date, the interest group, its registry number, the subject discussed and the senior officials participating in the meeting.
Regulation of the relations with interest groups in Title IV of Law 19/2014 of 29 December on transparency, access to public information and good governance [in Catalan]
1. The Register of interest groups must be public and the information it contains must be available by means of the transparency regime established by this law.
2. The establishment and workings of the Register must respect the principles of proportionality, equality and non-discrimination.
3. The creation of the Register may not prevent or restrict the rights of legal authorities or public officials or which are inherent in the mandate of parliament or elected officials.
1. The following must register on the Register of interest groups:
a) The individuals and organisations which regardless of their legal form or status, act in their own interest, or that of other people or organisations, engaging in activities that could influence the drafting of laws, regulations with the force of law or general provisions or the drafting and implementation of public policies.
b) Platforms, networks or other forms of collective activity which despite not having legal personality, are de facto a source of organised influence and engage in activities within the scope of application of the Register.
2. The scope of application of the Register includes all activities carried out with the purpose of directly or indirectly influencing the process of preparing and implementing policies and decisions, irrespective of the channel or medium used, including contacts with authorities and public officials, members of Parliament, civil servants and personnel working for the institutions, and voluntary contributions and participation in official consultations on proposed legislation, regulations, legal proceedings or other queries.
Activities relating to the provision of professional or legal advice directly related to defending interests affected by administrative procedures, informing a client about a general legal situation, conciliation and mediation activities undertaken within the framework of the law, and advisory activities conducted for informational purposes for the exercise of rights or initiatives established by law are excluded from the Register of interest groups.
1. The Register of interest groups must include:
a) A list, ordered by categories, of individuals and organisations that act in order to influence the development and implementation of public policies and the head office of their organisation.
b) The information to be supplied by the persons and organisations referred to in a above, especially with regard to their activities, area of interest and their financing.
c) A common code of conduct.
d) The system of control and scrutiny, which shall establish the complaint mechanisms applicable in the event of breach of this law or the code of conduct referred to in c above.
2. The Register must publicise the activities of interest groups, and especially the hearings and meetings that take place with authorities, public officials, elected members and deputies, and the communications, reports and other in relation to the matters dealt with.
1. The entry of interest groups on the Register entails the following obligations:
a) Acceptance that the information provided will be made public.
b) A guarantee that the information provided is complete, true and correct.
c) Compliance with the code of conduct.
d) Acceptance of the application of the system of control and scrutiny and the relevant measures in the event of breach of the code of conduct or the provisions of this law.
2. The deponents must inform the institutions of the activities they undertake, the clients, individuals or organisations which they work for and the financial sums they receive, if any, and the expenses related to their activity as an interest group.
The code of conduct referred to in Article 49.1.c must at least include:
a) The name and details of the signatory deponent.
b) The institution or organisation that represents or for which the deponent works, and the interests, objectives or aims pursued by its clients.
c) The commitment by the deponent not to obtain or attempt to obtain information or influence decisions in a dishonest manner.
d) The commitment by the deponent to provide updated and not misleading information at the time of entry on the register, and to subsequently keep it updated.
e) The commitment not to encourage, by any means, authorities, public officials, members of parliament or civil servants to break the law or the rules of behaviour established by the Code of Conduct.
f) The commitment to accept and comply with the measures taken in the event of breach of the obligations established by this law or the code of conduct.
1. A breach of the obligations established by this Law or the Code of Conduct may lead to the temporary suspension of registration on the Register of interest groups, or if the breach is serious, the cancellation of the registration.
2. Suspension or cancellation of registration on the Register entails the denial of access to the offices and services of the institutions and public bodies for the persons concerned, and if applicable, of the organisations to which they belong and the publication of the penalty in the Register.
3. Any individual is entitled to file a complaint based on material facts, if they suspect that the individuals or organisations stipulated in this title are in breach of the obligations established by law or the code of conduct.
4. The procedure for processing and investigation of claims must be carried out by the officials of the Register and those affected must receive a hearing.
The classification of individuals and organisations which must be registered on the Register of interest groups, the information required of the deponents, the detailed content of the code of conduct and the procedure for investigation and prosecution of allegations must be regulated by regulation.
MANIFEST the will of the Metropolitan Area of Barcelona to adhere to the Registry of Interest Groups of Catalonia, created and regulated by Decree 1/2017, of 14 February, which is organized and managed by the Administration of the Generalitat of Catalonia, who is responsible for the acts of inscription and for the other legally foreseen actions, without prejudice to the powers that correspond to the AMB, through the Transparency Agency, which in any case will include monitoring, inspection, management and sanction.
Agreement of the Metropolitan Council adhering to the Registry of Interest Groups of Catalonia (28/02/2017) [in Catalan]
1.- Interest groups (Lobbies)
In accordance with the definition in article 2 g) of Law 19/2014, of 29 December, on transparency, access to public information and good governance a lobby (group of interest according the literality of the law) is a person or a corporate entity who participate in public policies or in decision-making processes in Catalonia with the aim of influencing the orientation of these policies in defence of a private interest or of third parties interest, or a general interest.
2.- The register of lobbies in Catalonia
The Decree-Law 1/2017 of 14 February 2017, published in the Official Journal of the Generalitat of Catalonia on 16 February, and ratified by the Parliament of Catalonia on 8 March 2017 (DOGC of 27 March) creates and regulates the Register of interest groups in Catalonia.
In accordance with the article of the aforementioned Decree-Law, the Register of Interest Groups in Catalonia acts as a register of interest groups for the Administration of the Generalitat, local authorities and public bodies referred to in article 3.1.b and c of Law 19/2014. The objective is to make it possible to have public knowledge of the interest groups that act before each of the Administrations or public institutions, as well as of the activities of influence or intermediation that they carry out before them. The Government of Catalonia (Generalitat) have to organize and manage the register. The other functions, monitoring, inspection, management and sanction may correspond to each of the administrations and institutions concerned.
The detailed regulation of the Register of interest groups in Catalonia is contained in Decree 171/2015 of 28 July, references to the Register of interest groups of the Administration of the Generalitat and its public sector are to be understood as references to the Register of interest groups in Catalonia, in the new name given by Decree Law 1/2017.
3.- Adhesion of the Metropolitan Area of Barcelona (AMB) to the register of lobbies of Catalonia
The Transparency Agency, using the powers assigned to it by the Presidential Decree of 14 December 2015, regarding the function of ensuring compliance with the obligations established by the transparency law with regard to lobbies, promoted the adoption of the following agreement (by the Metropolitan Council at its session of 28 February 2017) :
MANIFEST the will of the Metropolitan Area of Barcelona to adhere to the Register of Interest Groups of Catalonia, created and regulated by Decree 1/2017, of 14 February, which is organized and managed by the Administration of the Generalitat of Catalonia, who is responsible for the acts of inscription and for the other legally foreseen actions, without prejudice to the powers that correspond to the AMB, through the Transparency Agency, which in any case will include monitoring, inspection, management and sanction.
In addition, in the Metropolitan Council of December 2017 was approved the Unit of Code of Ethics and Registration of Lobbies in the Transparency Agency .
In accordance with the foregoing, those person or corporate having the status of interest group who wish to interact with the Metropolitan Area of Barcelona must register in the Register of Interest Groups of Catalonia so that all the activities carried out with the aim of directly or indirectly influencing the processes of drawing up or applying public policies and decision-making, including contacts with authorities and public officials, civil servants and staff serving the institutions, must be incorporated.
4.- Preliminary considerations and criteria
- The exercise of the rights after a public administration is not a lobby activity.
- Despite the name "interest group" which seems to refer to a collective, a natural person can also be an interest group (lobby).
- Platforms, networks or other forms of collective activity must also be registered which, although they do not have legal personality, constitute a de facto a source of organized influence.
- Registration is free of charge and it is necessary just one registration for all the Catalan administration.
- Registration can be generic for all Catalan public bodies.
- Groups must register even if they are not domiciled in Catalonia. What determines the obligation of registration is the administration before which the influence is exerted. If there is any doubt about the need to register, the recommendation of the Directorate General of Legal Entities of the Government of Catalonia is that the registration must be done.
The following activities are not subjected to lobby register:
- Those relating to the provision of legal or professional advice directly linked to defending interests affected by administrative proceedings, activities aimed at informing a client about a general legal situation, conciliation or mediation activities carried out within the framework of the law, or advisory activities carried out for informative purposes for the exercise of rights or initiatives established by the legal system.
- Activities carried out by natural persons when they are interested in the situation or functioning of metropolitan public services before metropolitan elected representatives, under the terms of articles 61.1 of Law 19/2014 on Transparency, access to public information and good governance, and of article 139 of Law 8/1987, of 15 April, Municipal and Local Regime of Catalonia.
- Meetings between natural persons and senior officials, spontaneously or for reasons of personal or family treatment, which do not imply any desire to influence political or public decision-making, and so can be interpreted from common sense.
- Activities carried out by persons or organizations, as successful tenderers of a public contract, granted, parts of an agreement, within the framework of their execution and exclusively for the formalization, management, monitoring or execution.
- Activities made within the framework of participation processes or public information consultation in a regulatory process.
- Activities carried out by trade unions and corporate associations in defense and promotion of their own economic and social interests (which does not exclude the obligation of subjective registration in the register of interest groups).
The experience of the operation of the Register at the level of the Government (Generalitat of Catalonia), as well as the activities carried out by lobbies has led to the establishment of consolidated interpretative criteria on in different fields such as public procurement, etc., which may serve to evaluate the nature of the activity to be registered.
Regarding lobby activity at the Metropolitan Area of Barcelona the Transparency Agency is responsible to management, monitoring, validation for publication and supervision, through the SERGI system (initials in Catalan of Seguiment de les Relacions amb els Grups d'interès/ Following of the relations within Interests Groups).
It is an essential requirement that lobbies make its inscription with the Registry through the Register of the Generalitat of Catalonia (following link: http://justicia.gencat.cat/ca/tramits/tramits-temes/registre-grups-interes )
Office staff in charge of the agenda of the elected officials with executive responsibility (in the case of the Metropolitan Area are Presidency, Executive Vice-Presidency, Area Vice-Presidents), and for the rest of the senior officials, Area Directors and Metropolitan Area Service Directors, shall follow the following protocol in arranging meetings, hearings and contacts:
1. Requirement of registration number. When contacts, meetings and hearings, with interest group (lobby) the number of inscription to the Registry is required. No meeting will be arranged with an interest group (lobby) that has not previously been registered, except in special cases, where the lobby is responsible of registrate after the meeting.
2. Responsibility for the registration and management of the Register . The Generalitat of Catalonia (Catalan Government) is responsible for the organization, management and registration. So, doubts regarding the processing and/or the registration requirements, interested should contact the Department of Justice of the Generalitat of Catalonia (Directorate General of Law and Legal Entities) grupsinteres.dj@gencat.cat.
3. Fulfillment of the AMB form for meetings. The registration of meetings, contacts and hearings will be done through the SERGI system.
4. No registered lobby is able to arrange meetings, hearings, interviews, etc. in the following cases:
4.1. If its registration is in process.
4.2. If the lobby has commit to inscribe with the form provided. The corresponding form can be found at: http://justicia.gencat.cat/ca/serveis/formularis/grups_interes/
This possibility is only allowed for the first meeting during a period of 20 working days. For next meetings expired this period, an effective registration in the Register will be required.
4.3. Exceptionally, meeting with lobbies can be made in a third case. When that occurs the person acting on behalf of the lobby must be provided with the model declaration of commitment, sign it and entry in the Register and send an e-mail with the documentation to the Government of Catalonia: grupsinteres.dj@gencat.cat.
5. The Transparency Agency monitor the information relative to lobbies and its meetings with AMB senior officials. The general information will be made public with guaranteed protection of personal data and will be regularly updated.
This instruction shall enter into force on 15 June 2018.
Natural and legal persons or organisations without legal personality that wish to influence the drafting or application of regulations, public policies or services provided by the Metropolitan Area of Barcelona or any of its related entities are obliged to register in the Registry of Interest Groups of Catalonia, to which the AMB is adhered.
All lobbyists acting in the metropolitan area are subject to the code of conduct established in Article 18 of Decree 1771/2015, of 28 July, which regulates the creation and functioning of the Registry of Interest Groups of Catalonia.
Observance of the principles and ethical rules of this code of conduct is mandatory in any activity of influence or active participation in public policies or decision-making processes in the metropolitan area.
1. The common code of conduct constitutes a minimum ethical standard. With full indemnity from the common ethical standard, declarants may add more rigorous commitments of conduct.
2. Interest groups and the persons representing them must comply with the legislation in force and the following standards of conduct:
1. The common code of conduct constitutes a minimum ethical standard. With full indemnity from the common ethical standard, declarants may add more rigorous commitments of conduct.
2. Interest groups and the persons representing them must comply with the legislation in force and the following standards of conduct:
a) Respect the institutions and persons with whom they interact in the course of their activities.
b) Act transparently.
c) Inform the authorities, elected officials and other public employees with whom they interact that they are acting as interest groups and that they are registered in the Registry of Interest Groups of the Administration of the Generalitat and its public sector and, if applicable, in another registry of interest groups.
d) Provide information on the identity of the person or organisation they represent and the objectives and purposes represented.
e) Guarantee the accuracy, completeness, precision and updating of the information entered in the Registry.
f) Not to disclose information of a confidential nature that comes to their knowledge in the course of their activity.
g) To act with integrity and honesty in the performance of their activity and in their relations with the authorities, elected officials and other public employees and not to carry out any activity that may be classified as corrupt, dishonest or illegal.
h) Not to place the authorities, elected officials and other public employees in any situation that could lead to a conflict of interest.
i) Not influence or attempt to influence decision-making dishonestly or obtain or attempt to obtain information dishonestly or through improper behaviour.
j) Not to incite, by any means, the authorities, elected officials and other public employees to breach the law or the rules of conduct set out in the codes of conduct, and, consequently, not to make any gift of value or offer any favour or service that could compromise the full performance of public functions.
k) Inform the persons or organisations they represent of the existence of the code of conduct and of the principles and obligations contained therein and not represent conflicting or adverse interests without the informed consent of the persons or organisations concerned.
l) Not to abuse their registration in order to give themselves publicity, nor to give the impression that the fact of being registered in the Registry confers on them a special situation or privilege before the public authorities.
m) Ensure that the staff in their service complies with the rules on the prohibition of involvement in private activities after the cessation of senior officials and other rules on incompatibilities of senior officials, Members of Parliament, civil servants and staff in the service of the institutions.
n) Accept that the information provided will be made public.
o) Accept and comply with the measures to be adopted in the event of breach of the obligations established by law or by this Code, in accordance with the provisions of Law 19/2014 of 29 December.
Any person, company, organisation or private entity that interacts with the public sector to influence public policies or decision-making processes must be registered in the Registry of Interest Groups of Catalonia.
Registration in this registry can be completed electronically through the Catalan Government's website. Registration is free of charge and requires an approved digital certificate or the idCAT Mòbil identification system.
Access to the interest group registration procedure
You can also use this link to cancel your registration, update your registration details, file a complaint for non-compliance with the regulations or send an alert about a registered interest group.
Conferència anual de la Xarxa Europea de Registradors de Lobbies a Edimburg
L'Agència de Transparència a la Xarxa Europea de Registradors de Lobbies
S'aprova el calendari d'implementació de l'aplicatiu SERGI de seguiment dels grups d'interès
Adhesió de l'AMB al registre de grups d'interès de la Generalitat
