8 Subsidiarity yellow card: the European
Public Prosecutor's Office
| (35613)
17176/13
COM(13) 851
| Commission Communication on the review of the Draft Regulation on the establishment of the European Public Prosecutor's Office with regard to the principle of subsidiarity in accordance with Protocol No. 2
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| Legal base
| — |
| Document originated
| 27 November 2013
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| Deposited in Parliament
| 4 December 2013
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| Department
| Home Office
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| Basis of consideration
| EM of 16 December 2013
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| Previous Committee Report
| None; but see (35216) 12566/13: HC 83-xviii (2013-14) chapter 6 (23 October 2013) and HC 83-xv chapter 1(11 September 2013)
|
| Discussion in Council
| See paragraph 8.29
|
| Committee's assessment
| Legally and politically important
|
| Committee's decision
| Not cleared; further information requested; relevant to the debate on relations between the Commission and national Parliaments in European Committee B on 30 January
|
Background and previous scrutiny
8.1 In July 2013, the Commission published
its proposal for a Regulation to establish a European Public Prosecutor's
Office to combat fraud on the EU budget.[37]
The EPPO would comprise of a core team of the European Public
Prosecutor (EPP) and four deputies working through a system of
European Delegated Prosecutors (EDPs) in each participating Member
State. An account of the scope and provisions of that proposal
and the Government's view are set out in our previous Reports
on the proposal.[38]
8.2 The draft Regulation requires the
unanimous agreement of Member States (with the consent of the
European Parliament)[39]
but in the absence of unanimity the proposal can proceed according
to an accelerated version of the enhanced co-operation procedure,
if nine Member States or more request that the draft regulation
be referred to the European Council.
8.3 Although the draft Regulation engages
the UK's JHA Title V opt-in rights under Protocol 21 to the Treaties,
the Government's intention not to opt into this measure was set
out in the Coalition Agreement. As part of our scrutiny of the
opt-in aspects of the proposal a Lidington debate was held jointly
on that proposal and the parallel proposal on Eurojust on 29 October
2013.
8.4 In any event, any participation
in a proposal to establish an EPPO is governed, either pre- or
post-adoption, by the "double lock" requirements set
out in section 6 of the European Union Act 2011 — approval
by Act of Parliament and a referendum.
8.5 On 22 October 2013 the House of
Commons debated and agreed a motion adopting a Reasoned Opinion,
which we recommended in our Fifteenth Report on the draft Regulation.[40]
The Reasoned Opinion, which was sent to the Presidents of the
European institutions, sets out the reasons why the House of Commons
believes the proposal does not comply with the principle of subsidiarity
in Article 5 TEU. This principle requires that, in matters of
shared competence, the EU shall only act if the objectives of
the proposal cannot be sufficiently achieved by Member States
(either at central or at regional and local level) but can be
better achieved at EU level.
8.6 Article 7(2) of Protocol (No. 2)
to the EU Treaties on the application of the principles of subsidiarity
and proportionality provides that where Reasoned Opinions in respect
of a JHA proposal (submitted within the eight week period allowed
under the Protocol) represent at least a quarter of all votes
allocated to the national parliaments (currently 14 votes), the
proposal must be reviewed by the Commission.[41]
This is known as reaching the "yellow card" threshold.
The Commission may decide to "maintain, amend or withdraw"
the proposal. Reasons must be given for the decision.
8.7 On 12 November, the Speaker was
notified by the Commission that the "yellow card" threshold
had been reached on the proposal. By the subsidiarity Protocol
deadline (28 October 2013) the Commission had received 14 Reasoned
Opinions from national parliaments and chambers of 11 Members
States, representing 18 of the 56 votes allocated to national
parliaments. Those submitting Reasoned Opinions were the UK Parliament
(both Houses), the French Senate, Dutch Parliament (both Chambers),
Swedish Parliament, Irish Parliament (both Chambers), Hungarian
Parliament, Czech Senate, Slovenian Chamber, Cypriot Parliament,
Romanian Chamber and the Maltese Parliament.
8.8 Prior to this, national parliaments
have only issued a "yellow card" once, on the Monti
II proposal (on the exercise of the right to take collective action
within the context of the freedom of establishment and the freedom
to provide services).[42]
The Commission decided to withdraw that proposal, but in its collective
response to all national parliaments explained that this was because
it anticipated the proposal would not have the requisite political
support in the Council. It did not concede that the subsidiarity
principle had been breached, nor did it explore properly the national
Parliaments' arguments to the contrary.
The current document
8.9 In this Communication, dated 27
November 2013, the Commission informs Member States that it has
decided to maintain the EPPO proposal because it believes it complies
with subsidiarity. Despite this, it says that it has "carefully
analysed" the Reasoned Opinions of the national parliaments
from the perspective of subsidiarity and commits to continuing
to take them into consideration in the ongoing legislative process.
SUBSIDIARITY TEST
8.10 In applying the subsidiarity test
(Article 5(3) TEU) to the EPPO proposal, the Commission accepts
that both insufficiency of Member States' action and added value
of Union action must be demonstrated. The Commission says that
the Court of Justice has implicitly recognised that the EU institutions
have some margin of discretion in their assessment of compliance
with the principle, referring to cases such as C-58/08 Vodaphone
and Case C-377/98 Netherlands v Parliament and Council.
PRELIMINARY POINTS
8.11 As preliminary points in its subsidiarity
review of the EPPO proposal, the Commission:
· repeats that the protection
of the EU budget against fraud can be better achieved at Union
level, by reason of its scale and effects;
· argues that the proposal
cannot be considered per se to be in breach of subsidiarity
as the Treaties have explicitly called for the establishment of
the EPPO in Article 86 TFEU; and
· notes that some of the Reasoned
Opinions expressed support for the establishment of an EPPO, even
though they questioned specific elements of the proposal.
ARGUMENTS RAISED IN THE REASONED OPINIONS
8.12 The Commission then distinguishes
between arguments in the Reasoned Opinions that it considers to
be within the scope of the subsidiarity control mechanism in Protocol
(No.2) and those outside that scope because they are unconnected
with subsidiarity (proportionality, policy choices unrelated to
subsidiarity or other policy or legal issues). Arguments which
fall into the latter category, will be "be duly taken into
account in the process of negotiating the proposal", addressed
in political dialogue and in the Commission's individual replies
to be sent to the relevant national Parliaments.
Scope of the subsidiarity control mechanism
8.13 Within the scope of the control
mechanism and therefore addressed by the Commission in the Communication
(see further below) are arguments relating to:
· reasoning concerning subsidiarity;
· the alleged sufficient character
of existing mechanisms (to fight fraud on the EU budget);
· the added-value of the proposal;
· issues relating to the structure
of the EPPO; and
· issues relating to the nature
and scope of its competences.
8.14 The Commission says that the following
arguments are outside the scope of the subsidiarity control mechanism:
· the Regulation is too far-reaching;
· powers should be reserved
to national authorities;
· the Regulation goes beyond
what is necessary to achieve the objective;
· the Regulation may violate
the protection of fundamental rights guaranteed by the Charter
of Fundamental Rights; and
· the Regulation would create
disadvantages for Member States in that they lose the capacity
to prioritise prosecution activities within their own criminal
justice systems.
Arguments within scope — sufficiency of
Member State action and existing mechanisms
8.15 The Commission rejects the following
arguments of national Parliaments:
· that
it did not sufficiently explain the reasons why the proposal is
compatible with the principle of subsidiarity (Cyprus' Vouli
ton Antiprosopon, the UK's House of Commons, and Hungary's
Országgyûlés). The Commission believes
that the EPPO proposal complies with the legal requirement of
Article 296 TFEU to provide a statement of reasons underpinning
the proposal and the Court of Justice's corresponding case law.
Its impact assessment adds to the detail already provided in the
explanatory memorandum and in the legislative financial statement
and together this substantiates its position with regard to the
principle of subsidiarity and explains why the action of the Member
States is insufficient;
· that
it conflated the first and second steps of the analysis (insufficiency
of Member State action and added-value of Union action) as argued
by the UK House of Commons. The Commission says it has
explained adequately why the proposal meets both steps in detail,
in accordance with the Vodaphone case and with reference
to the impact assessment as evidence;
· that
the existing mechanisms or currently proposed legislation were
not explored sufficiently (Cyprus' Vouli ton Antiprosopon,
the Czech Republic's Senát, Ireland's Houses
of the Oireachtas, the Netherlands' Eerste Kamer and
Tweede Kamer, Romania's Camera Deputailor, Slovenia's
Državni Zbor, Sweden's Riksdag, and the UK
House of Commons). The Commission believes that
it has provided objective and clear statistical information which
shows that the efficiency of action at Union level will give
a more effective deterrent and equivalent level of protection
than existing mechanisms or proposed legislation;
· that
regional and local level actions should also have been examined
where devolved administrations may "have discrete criminal
justice systems (UK House of Commons). It dismisses regional
division of powers as "a purely internal matter" and
says its statement of insufficiency of Member State action "necessarily
encompasses" all levels of Member State action; and
· that
action should be focussed on improving existing mechanisms to
address fraud on the EU budget (UK House of Commons) because
this would, at best, have a marginal effect and that because not
all fraud is preventable, the deterrent of enforcement is also
required. The Commission argues that OLAF's powers are limited
to administrative investigations and quotes the statistics in
the explanatory memorandum and impact assessment. The Commission
repeats that Europol and Eurojust have no powers to conduct or
direct investigations or prosecutions themselves, nor can they
be given such powers under the Treaties. Harmonisation of offences
and sanctions will not as such produce satisfactory results without
being accompanied by effective investigation and prosecution measures,
whereas the EPPO can.
Arguments within scope — added value
8.16 The Commission disagrees that the
proposal will not provide added value (Czech Republic's Senát,
Hungary's Országgyûlés, Romania's Camera
Deputailor, and the Netherlands' Eerste Kamer and Tweede
Kamer). Instead, the Commission says that the proposal will
address the wide divergences between Member States, provide deterrence
and prevent forum-shopping. Expertise and know-how in investigating
and prosecuting EU-fraud can be pooled. It will allow the discovery
of cross-border links and the effective direction and coordination
of investigations. Also, time-consuming mutual legal assistance
procedures for obtaining information or evidence will disappear.
Exchange of information and evidence data will be facilitated.
Added value will be achieved by removing different rules on collection
or presentation of evidence at national level to aid the exchange
and admissibility of evidence as between Member States and the
proposal would not undermine judicial authorisation of investigative
powers and procedural safeguards.
Argument within scope — structure of EPPO
8.17 The Commission rejects the argument
of France's Sénat, Romania's Camera Deputatilor,
and Malta's Kamra tad-Deputati that a "college"
structure (involving representatives from all participating Member
States in the central tier of the EPPO) would adhere more closely
to the principle of subsidiarity. Questions of a vertical
or horizontal model are related to the principle of proportionality
and not subsidiarity. In any case a college model is not less
centralised than the EPPO model proposed but just another way
of organising the EPPO. The comparison is therefore between two
possible modes of action at EU level. A collegial structure could
hamper the EPPO's efficiency and compromise the clear chain of
command needed for the EPPO's effective decision-making and operation.
Argument within scope — nature and competences
of the EPPO
8.18 The Netherlands' Eerste Kamer
and Tweede Kamer, Hungary's Országgyûlés,
Romania's Camera Deputaþilor, Slovenia's Državni
Zbor, the UK's House of Lords, Cyprus' Vouli ton
Antiprosopon, and the Czech Republic's Senát, all
questioned the nature and competences of the EPPO. The
Commission sees no distinction between national and cross-border
cases within Article 86 TFEU and proposes to maintain the EPPO's
exclusive competence over all EU fraud cases. The fundamental
EU dimension of these crimes, the need to avoid parallel actions
but also to identify connections across the EU requires exclusive
competence. Ancillary competence is not a concern because it will
be subject to strict criteria and can help avoid parallel investigations
and the problem of double jeopardy.
The Government's view
The rejection of the yellow card
8.19 The Minister for Security at the
Home Office (James Brokenshire) says that overall the Government
is disappointed with the Commission's response to the "yellow
card" and is:
"concerned about the apparent
haste with which the Commission has conducted its review. National
Parliaments have a right to expect that the Commission will conduct
a thorough review and duly acknowledge and consider Reasoned Opinions.
Despite the numerous concerns raised, and especially on aspects
that directly underpin the principle of subsidiarity, the Commission
remains firm in their view that subsidiarity has been met."
8.20 He notes the Commission's undertaking
to respond to each Reasoned Opinion in turn but should that prove
dissatisfactory, says the Government "would support further
calls from national Parliaments for the Commission to take on
board the serious issues they have raised". He continues:
"In line with the principle
of subsidiarity, it is essential that decisions are made at the
appropriate level and as close to citizens as possible. This
principle is enshrined in the Treaties by the subsidiarity principle
and the Government regards it as a key principle for the democratic
legitimacy of the EU. It is therefore important that the Commission
responds appropriately to the views of national Parliaments."
8.21 In particular, in rejecting the
"yellow card", the Minister says that the Commission:
· does not provide any new
evidence to support its case;
· jumps from the options of
taking no action or taking no new regulatory actions to variations
on the creation of the EPPO, a new supra-national agency with
extensive and harmonised powers, acting through one new single
legal territory across the whole EU and all Member States;
· continues to base this proposal
on the premise that Member States do not have the will or the
capacity to act to protect the Union's budget, and that a 100%
prosecution rate is the most effective deterrent where the EPPO's
decision to prosecute takes priority over national cases whereas
the Government still considers prevention at source within Member
States is as valid a deterrent within the enforcement cycle;
· does not explore or assess
alternative approaches to deliver a strengthened system to prevent
EU fraud at source at national level (including further simplification
of sectoral rules governing the EU budget, Member States taking
more responsibility for the funds they administer and effective
enforcement by the Commission to make Member States improve management
and control systems); and
· is wrong to consider that
just because there is a specific legal base for the EPPO proposal
that it follows that the proposal complies with subsidiarity,
particularly since Article 86 only says that the EPPO "may"
be created, not that it should or will be created.
SCOPE OF THE SUBSIDIARITY CONTROL MECHANISM
8.22 The Minister then addresses the
Commission's approach to the scope of the subsidiarity control
mechanism and its interpretation of the subsidiarity principle.
He says that the Government does not agree with the distinction
the Commission draws between arguments raised in Reasoned Opinions
which are within and outside the scope of the mechanism and thinks
"that the Commission has accorded the principle of subsidiarity
an unacceptably narrow interpretation". He continues:
"The Government believes that
some of the substantive issues that the Commission argues are
not subsidiarity concerns are, in fact, subsidiarity issues. For
example, it is the Government's view that the following two issues
are squarely within the scope of the principle of subsidiarity:
'The Regulation is too far-reaching'; and 'The EPPO's powers are
too far-reaching and should be reserved to national authorities'.
"Moreover, whether any proposed
action cannot sufficiently be achieved by Member States and would
be better achieved by action at Union level must be informed,
in part, by an assessment of the merits of the proposed action.
That assessment of the merits will inevitably need to take into
account policy choices and legal issues. Subsidiarity cannot
be fully assessed without consideration of these wider issues.
This is particularly relevant where, as with the EPPO measure,
there is a spectrum of possible options for EU-level action, but
not all EU-level action will comply with the principle of subsidiarity.
The role of national Parliaments under Protocol 2 would be academic
and void of any practical meaning if they were constrained to
assess issues of subsidiarity with no corresponding assessment
of the parameters of the Union's proposed action in the relevant
area.
"The inclusion of the principle
of subsidiarity within the Treaties and the role of national Parliaments
to assess this issue are specifically designed to act as a counter
balance to excessive moves towards EU-level action, as it should
remind legislators that they must first consider all other options
available at the national level to achieve the objective and add
value."
COMMISSION'S ANALYSIS OF REASONED OPINION ARGUMENTS
8.23 The Minister says that the Government
agrees with the following arguments raised by national Parliaments
in their Reasoned Opinions:
· that the Commission had not
adequately considered the option of strengthening existing bodies
(e.g. Eurojust, OLAF) or alternative new mechanisms;
· that the Commission failed
to substantiate the need and the added value of the EPPO (Netherlands'
Senate, Sweden's Parliament, the UK's House of Commons, Cyprus'
Parliament, Slovenia's Parliament and Czech Republic's Senate);
· that the protection of the
EU financial interests can be better obtained by strengthening
existing mechanisms of cross-border cooperation between criminal
justice authorities;
· that criminal law is primarily
a national competence and that the Commission has not considered
other alternatives to prosecution action through exclusive competence
(Irish Parliament, House of Commons and House of Lords), as the
Government believes that "prevention at the national level,
within national competence, is an essential element of the fight
against any form of fraud and existing payment systems must be
strengthened";
· that the Commission's interpretation
of national conviction rates as demonstrating that Member States
are unwilling to act. The Minister adds:
"whether a case is or is not
prosecuted depends on the evidence available and public interest
considerations. If the evidence is not strong enough, then there
cannot be a prosecution. We believe that the new Regulation governing
the work of OLAF, which entered into force on 1 October, will
help improve the quality of evidence provided by OLAF to national
courts, which will in turn support increased convictions. This
can help address many of the conviction issues the Commission
raises in its assessment of the EU fraud problem. So we continue
to advocate that recent changes need time to be implemented fully
before any further action is contemplated."; and
· that the powers given to
the EPPO are too far reaching (the Netherland's Senate, France's
Senate and Hungary's Parliament) and the EPPO should be based
on a more "collegial" model. The Minister says that
there "is no evidence that the Commission has actively appreciated
these different points of view or considered anything other than
the creation of an EPPO as a hierarchical EU-body".
LACK OF FINANCIAL AND EMPIRICAL EVIDENCE FOR PROPOSAL
8.24 The Minister says that the Commission
has "side-stepped" concerns about the evidence underlying
the proposal, does not provide further information or new data
to strengthen its impact assessment or cost benefit analysis and
simply refers to "a solid basis of statistical evidence"
supporting the proposal. He says that this "seems rather
at odds with their own impact assessment, which says that the
cost benefit analysis is "pushing the limits of what is possible".
He adds that the Government therefore still considers that the
"Commission's assessment, calculations of risk and therefore
its projection of the scale of the problem remain flawed and weak"
and its justification for the proposal "fundamentally flawed".
FINANCIAL IMPLICATIONS
8.25 The Commission maintains the position
that the EPPO will not generate substantial new costs and that
"the overall costs of law enforcement will be more balanced
as a result of efficiency gains". The Government does not
consider that the impact assessment and the cost benefit analysis
are correct or has been accurately assessed, particularly given
the inability to include figures for OLAF in the Estimated Financial
Impact sections.
DEVOLVED ADMINISTRATIONS
8.26 The Minister refers to the motion
of the Scottish Parliament dated 5 September 2013 that the proposal
breaches the subsidiarity principle. He notes that the Scottish
Parliament maintain its concerns about the proposal and not least
about the position of the Lord Advocate as head of both the prosecutorial
and investigative systems. He also notes the concerns of the Northern
Irish Assembly about how the proposal would affect its prosecutorial
and investigative functions which are separate and the fact that
prosecutors in Northern Ireland do not have powers of search,
seizure, interception, surveillance, monitoring financial transactions
or covert video surveillance.
FUTURE NEGOTIATION OF THE PROPOSAL
8.27 The Minister says that in the
absence of consideration of alternative options to the EPPO proposal
"it is difficult for us to see how the Commission can fulfil
its promise to represent the views of national Parliaments expressed
in their Reasoned Opinions during the Commission's interventions
as part of future negotiations".
8.28 He adds that there continues to
be no information on how the EPPO will interact with non-participating
Member States, an issue on which the UK will seek clarity in negotiations
in order to protect its position under Protocol 21 where the UK
does not opt to participate in a JHA measure.
TIMING
8.29 The Minister says that the EPPO
was discussed at the December JHA Council and negotiations are
expected to continue from January 2014. The Government says that
the Commission can only progress to enhanced cooperation once
the Member States make it clear that there is no unanimity on
the current proposal.
Our Assessment
8.30 The precipitate nature of the Commission's
response (published just one month after the deadline for Reasoned
Opinions), the absence of any new evidence in the response, its
complete rejection of every single argument raised by 14 different
chambers of national Parliaments and its collective approach are
all suggestive of the Commission treating the exercise as a formality
rather than a conscientious review. The expediency of maintaining
the proposal appears to have driven this review and there is little
evidence to suggest that the Commission fully considered the other
options of amending or withdrawing the proposal. This approach
lacks credibility and we therefore disagree that the Commission
has, as it claims at page 4 of the Communication "carefully
analysed the Reasoned Opinions submitted by national Parliaments"
or "has adopted an open attitude toward the Reasoned Opinions,
interpreting their arguments, in so far as possible in the light
of the principle of subsidiarity".
8.31 We note that the Commission uses
Court of Justice case law to justify its approach to the subsidiarity
review and in particular the "margin of discretion"
afforded to the EU institutions. But to avail itself of a "margin
of discretion", the Commission must properly exercise discretion
in the first place. This means reconsidering the subsidiarity
compliance of the proposal with an open mind in the light of the
national Parliaments' Reasoned Opinions and ensuring that, within
the spirit and not just the letter of the subsidiarity Protocol,
the proposal represents a "decision taken as closely as possible
to the citizens of the Union" and proceeds with a sufficient
level of democratic legitimacy.
8.32 We disagree with the Commission's
interpretation of the scope of the subsidiarity control mechanism.
We agree with the Government that arguments which the Commission
considers outside scope are intrinsic to national Parliaments'
review of the merits of EU action and whether the EU can better
achieve the legislative objective of the Regulation. The House
of Commons has issued 12 Reasoned Opinions since the adoption
of the subsidiarity Protocol which have relied upon arguments
which are similar or analogous to those the Commission now rejects.
We have received responses from the Commission to eight of them.
We have also corresponded with the Commission on the quality and
usefulness of the responses received to our Reasoned Opinions
(our letter of 26 June 2013;[43]
the Commission's reply of 24 July 2013).[44]
At no time before has the Commission made known its view that
these arguments were unconnected to subsidiarity. It is unfortunate
that only it chooses to do so now when faced with significant
opposition to a proposal and at a point in the process where national
parliaments are no longer empowered under the Protocol to challenge
a draft legislative act. We therefore look forward to receiving
a detailed explanation from the Commission as to why these arguments
are considered to fall outside the scope of the Commission's subsidiarity
review when it writes further to us.
8.33 We also reject the Commission's
assertion that it does not have to consider specifically the sufficiency
of Member State action "at regional or local level"
and that "the division of powers between a Member State,
its regions and its municipalities is a purely internal matter"
(see page 7 of the Communication). This assertion is concerning
particularly where, as in the case of EPPO, the proposal affects
criminal justice which necessarily involves diverse systems and
processes at the regional level of Member States (as in the cases
of Scotland and Northern Ireland) and warrants a subsidiarity
analysis which takes into account this diversity.
8.34 We also challenge the Commission's
assertion that the existence of a legal base in the Treaties for
the establishment of an EPPO means that it cannot per se
breach the subsidiarity principle. Article 5(1) TEU states that
it is "the use of Union competences" that is governed
by the principle of subsidiarity, not their mere existence, and
we consider this can only be determined by carrying out a two-stage
subsidiarity assessment of the specific content and scope of a
proposal. In addition, Article 86(1) TFEU states that the Council
may establish an EPPO, not "shall". There can
be no assumptions that a proposal intrinsically does or does not
comply with subsidiarity; there can be no pre-emption of the process
in which national parliaments have been accorded the central role
under Protocol (No. 2).
Conclusion
8.35 We will send a copy of this
Report to the Commission, with a covering letter, drawing its
attention to our concerns. We will also request that when the
Commission provides an individual response to the House of Commons
this will address all the arguments raised in the House's Reasoned
Opinion.
8.36 We recommend that this Chapter
of our Report is included in the document pack for the debate
on relations between the Commission and national parliaments in
European Committee B on 30 January.
8.37 We ask the Government to keep
us informed:
i) of whether the Commission
honours its undertaking to take the concerns of the national
Parliaments into consideration (which is already required by Article
7(1) of Protocol (No. 2)) in the course of negotiations; and
ii) of any developments which
indicate that the proposal will have to move to the "enhanced
co-operation" procedure.
8.38 We continue to retain the Communication
under scrutiny.
37 COM(13) 534. Back
38
See headnote. Back
39
Article 86(1) TFEU. Back
40
See headnote: (35216) 12566/13: HC 83-xviii chapter 6 (23 October
2013). Back
41
For non-JHA proposals the yellow-card threshold is one-third. Back
42
COM(2012) 130. Back
43
Letter of 26 June 2013 from William Cash MP, the Chairman of the
European Scrutiny Committee to Maroš Šefèoviè,
Vice-President of the European Commission http://www.parliament.uk/documents/commons-committees/european-scrutiny/Composite%20letter%20on%20ROs.pdf. Back
44
Letter of 24 July 2013 to Maroš Šefèoviè,
Vice-President of the European Commission http://www.parliament.uk/documents/commons-committees/european-scrutiny/VP%20reply%20to%20Cash%20HoC%20UK%20NPs.pdf. Back
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