Mr. John Devitt:

I agree there should be no reason that a coalition of business interests or non-profit organisations like mine – we work closely with the Irish Council of Civil Liberties, Amnesty International and Front Line Defenders on promoting human rights – could not name its members in its returns. I also agree with the commission that criminal sanctions should be extended to breaches of section 22.

Regarding Deputy Farrell’s question, we have suggested that cognisance should be taken of the system in Canada where certain public officials have much longer cooling off periods or are prohibited from moving into certain roles that may present a serious conflict of interest. I am thinking particularly of roles where someone has continued access or knowledge and know-how that he or she may have gained during his or her time in office that would confer an undue advantage to an employer in the private sector or present a conflict of interest, full stop. For example, senior gardaí or gardaí in certain operational roles have knowledge and know-how that would confer an advantage on employers in the security industry. Members of the Central Bank may have information and know-how that would confer an undue advantage on practitioners in the financial industry, which may present a conflict of interest. We have suggested that, while there should be a minimum cooling off period of two years, some discretion be afforded to the commission in advising those applying to move into certain roles in the private sector and that account be taken of the roles they have in the public sector and the roles they would hold in the private sector.