1. Object of Study

As part of the PRIN ACOI project, a research line focuses on exploring the potential of data visualization as a tool to highlight relationships between stakeholders and public authorities. Specifically, the research team aims to test the usefulness of data visualization for exploring transparency registers, assessing its added value in terms of readability and understanding lobbying dynamics.

The experiment leverages information from the European Commission’s Transparency Register. The initial research phase concentrated on studying interactions between businesses, Commission members, and Directorate-Generals (DGs), utilizing open-source data provided by the Transparency Register. This tool proved essential in identifying the context, timing, and motivations behind private meetings, forming the foundation for further analytical insights.

To systematically address the complexity of lobbying activities, the team developed a database encompassing information on approximately 12,000 companies registered in the Transparency Register.

Additionally, the team reconstructed the organizational chart of the European Commission and its DGs, covering the period from 2012—the year the Transparency Register was established—to the present. This effort aims to provide a structured and comprehensive view of institutional relationships over time, supporting the identification of strategic nodes in interactions between companies and the Commission. This reconstruction was particularly necessary as the Transparency Register often does not clearly specify which DG was involved in meetings, limiting detailed analyses.

The multidisciplinary research team has initiated the development of advanced graphical visualization tools based on graph drawing techniques to effectively represent the frequency and intensity of interactions among involved parties. These tools aim to simplify the complexity of lobbying networks into clear and accessible visual representations that reveal influence dynamics.

The choice of visualization type is still under development and seeks to ensure alignment with the project’s objectives. The team is evaluating solutions that balance data readability with intrinsic complexity, providing a detailed yet intuitive framework for researchers, policymakers, and other stakeholders.

This integrated approach, combining data analysis, historical reconstruction, and advanced graphic tools, establishes a robust methodological foundation for delving deeper into lobbying phenomena and potential conflicts of interest.

As a result, the research team has developed a platform for visualising meetings between lobbyists, European Commissioners and Commission officials.
The platform will soon be made freely available at: https://mozart.diei.unipg.it/acoi/login

2. Further Research Development

The research may continue with the introduction of new experimental phases, structured sequentially and preparatory, to further investigate lobbying dynamics and their implications for European policy formulation.

2.1 Phase One: Details on Subsidiaries and Affiliates

In this phase, the database will be enriched with information on subsidiaries and affiliates of major companies. This level of detail will highlight connections within corporate groups and assess the aggregated influence of parent companies. The graphical representation will adapt to reflect the greater weight of companies acting through a network of subsidiaries.

Objectives:

• Enhance the database with detailed information on subsidiaries and affiliates to uncover internal dynamics within corporate groups.
• Assess the aggregated influence of parent companies, considering the role of subsidiaries in lobbying activities.
• Graphically represent corporate connections to improve precision and clarity in visualizing influence networks.
• Identify indirect lobbying dynamics, where subsidiaries act in a coordinated manner to pursue the parent company’s interests.

2.2 Phase Two: Correlation Between Lobbying and Legislative Proposals

This phase will explore potential correlations between lobbying meetings and subsequent legislative proposals advanced by the European Commission or its DGs. The analysis will initially focus on a sample of companies and strategic sectors, such as the Digital Market Act, to ensure manageable data collection and processing. Special attention will be given to determining whether lobbying activity intensifies around regulations relevant to the companies involved. The outcome of the analysis will be binary:

1. False: The case will be archived.
2. True: Proceed to Phase Three.

Objectives:

1. Verify the temporal connection between lobbying meetings and legislative proposals by the Commission or DGs.
2. Determine sectoral relevance, focusing initially on specific regulations like the Digital Market Act to understand lobbying impacts in strategic regulatory contexts.
3. Analyze the intensity of lobbying activities, evaluating whether they increase around proposed regulations of interest to involved companies.
4. Establish criteria for further analyses, identifying cases with clear correlations for deeper exploration in Phase Three.

2.3 Phase Three: Identification and Analysis of Conflicts of Interest

The final research phase focuses on identifying potential conflicts of interest between corporate lobbying activities and the scientific support used to justify certain public policies. Four main types of conflicts are examined:

1. Monetary Conflict: Occurs when researchers or consultants receive compensation, grants, or funding from a company with a direct interest in the research outcomes. This can lead to biased conclusions or data manipulation to favor the sponsor’s interests. Investigation Question: Has the researcher received compensation, consultancy, or grants from the interested company or its affiliates?
2. Career Conflict (Revolving Door): This arises when research outcomes directly impact the researcher’s career, such as facilitating employment with the interested company or enhancing professional prestige. Investigation Question: Has the researcher obtained a role or position with the involved company or its affiliates?
3. Data Conflict: Occurs when the data used in research is not open-source or is controlled by an organization with direct interests in the study’s outcomes, compromising transparency and reproducibility. Investigation Questions: Were the data used in the study provided by the company? Do these data result in findings favorable to the company?
4. Academic Conflict: This occurs when a researcher’s ideology, reputation, or academic prestige is tied to specific outcomes, leading to potential biases in interpretations to confirm pre-existing views. Investigation Question: Does the researcher hold ideological, political, or academic positions that could influence the study’s results?

Analysis Methodology:

The approach is based on the complexity of data retrieval:

1. Simple Sources: Academic articles (PubMed, Google Scholar), company press releases, and research project databases like CORDIS.
2. Intermediate Sources: Financial or transparency reports published by universities or companies, and consultations on institutional transparency monitoring sites.
3. Complex Sources: Direct interviews with researchers or access to specialized databases (e.g., Open Payments).

Objectives:

1. Identify conflicts of interest in interactions between companies and the European Commission, focusing on scientific support provided by firms.
2. Classify conflicts by the four identified types, developing metrics to measure their impact.
3. Evaluate the influence of conflicts on the integrity and transparency of European decision-making processes.
4. Propose actionable recommendations to minimize conflicts, including regulatory and transparency measures based on study results.
5. Establish a replicable methodology for future studies on lobbying and public policy.

3. Conclusions and Perspectives

The work conducted so far has built a solid foundation for understanding lobbying dynamics within the European Commission, highlighting the importance of tools like the Transparency Register and innovative analytical methodologies. However, this represents only the beginning of a broader exploration of the complexity and implications of lobbying in political and legislative contexts.

Future steps include enriching the database with information on subsidiaries and affiliates to better understand the role of multinational corporations in shaping European policy decisions. Additionally, analyzing the correlation between lobbying meetings and legislative proposals offers insights into the transparency and impartiality of decision-making processes.

Finally, a structured approach to analyzing conflicts of interest provides critical insights into the impact of these conflicts on decision-making. This study aims not only to identify the presence of conflicts but to understand their concrete influence, offering strategies to mitigate negative effects.

Ultimately, this project aspires to provide a replicable model applicable to other institutional and geographic contexts, contributing to more transparent and accountable governance focused on the public good

The assessment of conflicts of interest is fundamental to preventing and combating administrative corruption. It is also a critical element of the legitimacy of public powers, as conflicts of interest can undermine public trust in the impartial exercise of public functions.

The PRIN PNRR research project of national interest "Assessing conflict of interest – ACOI" aims to investigate whether and how a mapping of interests pertaining to subjects required to submit a declaration regarding conflicts of interest can enable a more effective analysis, within reasonable timeframes and at reasonable costs, of declarations of absence of conflict of interest. This would thereby facilitate the control and verification tasks assigned to public administrations.

The project is based on two research streams:

1. The first stream, primarily legal in nature, will focus on two topics: the analytical reconstruction of the morphology of the conflict of interest regime; a prelimary report is available here; and an in-depth study of the conditions and limits of personal data processing, with reference to the most relevant processing methods/techniques, the legal basis requirements, and the potential dataset to be processed. The report of the result of this activi in available here.

2. The second stream will study, experiment with, and test the feasibility of solutions based on the processing of personal data (made available as public data), to map, analyze, and detect situations where a potential conflict of interest may occur.

a) Context and Aims of the Research Project

1. The Ontological Information Asymmetry Characterizing the Relationship Between Public Administrations and Officials/Agents Regarding the Existence of Conflict of Interest Situations

For conflicts of interest to be intercepted (thus triggering safeguards such as the duty to abstain, incompatibility, the prohibition of external appointments, etc.), the conflict of interest situations must be known. Within the current regulatory framework, this need is addressed through so-called "self-certification" mechanisms: the interested party is required to make substitute declarations for certifications or substitute declarations for the deed of notoriety attesting to the absence of conflict of interest situations (however defined). Similarly, precise information duties are imposed on the agent regarding collaborative relationships (of the agent themselves, their relatives or in-laws up to the second degree, their spouse or cohabiting partner) with private entities that are in any way remunerated and maintained in recent periods, with specific (though not exclusive) regard to relationships that have occurred or are occurring with subjects who have interests in activities or decisions pertaining to the public functions entrusted to them. More generally, there is an obligation to report such relationships. Since a conflict of interest can also arise concerning interests of a non-economic nature, the duty to communicate also extends to any membership or participation in associations or organizations, regardless of their confidential nature or not, whose areas of interest could interfere with the performance of official duties. Also, in the case of abstention (a duty incumbent upon the directly interested party), the relevant decision must be communicated in writing to the administration to which they belong, specifying the conflict situation in question.

In all the cases mentioned, it is the party directly affected by the conflict of interest situation who informs the administration. This certainly aligns with a standard of appropriateness, since – in most cases – it is the interested party who has (better, full, and precise) knowledge of the situation in question. However, this mechanism for bringing conflicts of interest to light also reveals the structural condition of information asymmetry in which the administration operates. It is forced (for the aforementioned reasons of informational appropriateness) to rely on the declarations of the interested parties to become aware of conflict of interest situations, in order to remedy them as required by the regulatory framework.

The enforcement mechanism for the duty to provide administrations with truthful and accurate information regarding the existence of circumstances that could constitute a conflict of interest is connected to the methods by which these information obligations must be fulfilled (those governed by the Consolidated Law on Administrative Documentation, Articles 46 and 47). On the one hand, false declarations made in such contexts may result in criminal liability for the author. On the other hand, the administration has specific powers to verify the truthfulness of the declarations made and the facts attested, through the institution of official verification, including by directly consulting the archives of the certifying administration.

However, these solutions do not resolve the (structural) problem of information asymmetry between the administering administration and the party affected by the conflict of interest situation; they merely shift it further downstream, to the moment of verification (of truthfulness and completeness) to be carried out on the declarations made. Indeed, at this stage, the same initial condition reapplies for the administration carrying out the check: namely, a structural knowledge deficit regarding the relevant facts.

This condition also conspires to make the mechanism for revealing conflicts of interest less effective/efficient. In effect, the binding force of the system of self-declarations and subsequent truthfulness checks rests on the deterrent effect produced by the feared consequences (including criminal) of any false declarations made. Now, this "deterrent" effect would be, in practice, almost completely stripped of effectiveness/binding force if administrations were not placed in a position to be able to verify the truthfulness of the declarations made in an effective, efficient, and actual manner. In other words, few would actually fear making false or incomplete declarations if there was an awareness that the administration lacks the capacity and means to carry out controls and verifications effectively. This issue and this need have been explicitly raised by administrations themselves. In particular, the Conference of Regions and Autonomous Provinces, in its opinion on the 2019 National Anti-Corruption Plan, while favorable, explicitly requested that "more detailed indications be provided regarding the methods for checking the self-declarations made, both in matters of conflict of interest and other specific prevention measures that derive from it. In particular, the operational methods (...) should be better clarified, also considering the implications relating to the protection of personal data" (opinion of October 24, 2019).

b) Vertical Transparency as a Mechanism to Compensate for Information Asymmetry in Matters of Conflict of Interest

Conflict of interest (a completely central and strategic institution within the framework of corruption prevention mechanisms) involves a plurality of interests. These interests pivot in a network-like manner around the agent tasked with or participating in the exercise of public functions or activities, thus making relevant those interests conflicting with the public interest that are conveyed or channeled through the agent.

The analysis of mechanisms for detecting and enforcing conflict of interest situations shows that the full potential of this prevention tool is, in a way, hindered or weakened by the administrations' condition of structural information asymmetry, concerning their ability to know about conflict of interest situations. This condition makes the deterrent mechanisms related to verification procedures concerning the truthfulness (completeness and consistency) of declarations made by interested parties about the existence (or absence) of conflict situations less effective.

Therefore, there is a need to be met: to equip the administration with cognitive tools suitable for filling or at least reducing this information asymmetry, creating the conditions to deploy a cognitive capacity capable of increasing the effectiveness and actual impact of prevention mechanisms based on the identification and management of conflicts of interest.

This research aims to study and verify the feasibility of a methodology for combining and analyzing data that can help bridge this information asymmetry, through mapping and visualization techniques, in order to provide immediate evidence of the networks of relationships and interests in which the agent is embedded. This is also in view of potential, future applicative developments (which are, however, beyond the specific aims and purposes of this research project).

Given the above, the aims of the research project prove to be legitimate, since conflict of interest is the institution at the heart of mechanisms for preventing and combating administrative corruption. Preventing and combating administrative corruption is an objective pursued by numerous fundamental legislative instruments, at the international level (in many international conventions dedicated to the topic) and national level (see, in particular, but not only, the entire body of legislation on preventing administrative corruption, starting with Law 190/2012); in all these legislative instruments, a central role is assigned to the institution of conflict of interest. The European Union, for its part, is also in the process of developing a legislative instrument (a Directive) aimed at imposing minimum shared standards for preventing and combating administrative corruption, within which the institution of conflict of interest receives ample and decisive recognition as an essential prevention mechanism.English translation:

The assessment of conflicts of interest is fundamental to preventing and combating administrative corruption. It is also a critical element of the legitimacy of public powers, as conflicts of interest can undermine public trust in the impartial exercise of public functions.

The PRIN PNRR research project of national interest "Assessing conflict of interest – ACOI" aims to investigate whether and how a mapping of interests pertaining to subjects required to submit a declaration regarding conflicts of interest can enable a more effective analysis, within reasonable timeframes and at reasonable costs, of declarations of absence of conflict of interest. This would thereby facilitate the control and verification tasks assigned to public administrations.

The project is based on two research streams:

1. The first stream, primarily legal in nature, will focus on two topics: the analytical reconstruction of the morphology of the conflict of interest regime; and an in-depth study of the conditions and limits of personal data processing, with reference to the most relevant processing methods/techniques, the legal basis requirements, and the potential dataset to be processed.

2. The second stream will study, experiment with, and test the feasibility of solutions based on the processing of personal data (made available as public data), to map, analyze, and detect situations where a potential conflict of interest may occur.

a) Context and Aims of the Research Project

1. The Ontological Information Asymmetry Characterizing the Relationship Between Public Administrations and Officials/Agents Regarding the Existence of Conflict of Interest Situations

For conflicts of interest to be intercepted (thus triggering safeguards such as the duty to abstain, incompatibility, the prohibition of external appointments, etc.), the conflict of interest situations must be known. Within the current regulatory framework, this need is addressed through so-called "self-certification" mechanisms: the interested party is required to make substitute declarations for certifications or substitute declarations for the deed of notoriety attesting to the absence of conflict of interest situations (however defined). Similarly, precise information duties are imposed on the agent regarding collaborative relationships (of the agent themselves, their relatives or in-laws up to the second degree, their spouse or cohabiting partner) with private entities that are in any way remunerated and maintained in recent periods, with specific (though not exclusive) regard to relationships that have occurred or are occurring with subjects who have interests in activities or decisions pertaining to the public functions entrusted to them. More generally, there is an obligation to report such relationships. Since a conflict of interest can also arise concerning interests of a non-economic nature, the duty to communicate also extends to any membership or participation in associations or organizations, regardless of their confidential nature or not, whose areas of interest could interfere with the performance of official duties. Also, in the case of abstention (a duty incumbent upon the directly interested party), the relevant decision must be communicated in writing to the administration to which they belong, specifying the conflict situation in question.

In all the cases mentioned, it is the party directly affected by the conflict of interest situation who informs the administration. This certainly aligns with a standard of appropriateness, since – in most cases – it is the interested party who has (better, full, and precise) knowledge of the situation in question. However, this mechanism for bringing conflicts of interest to light also reveals the structural condition of information asymmetry in which the administration operates. It is forced (for the aforementioned reasons of informational appropriateness) to rely on the declarations of the interested parties to become aware of conflict of interest situations, in order to remedy them as required by the regulatory framework.

The enforcement mechanism for the duty to provide administrations with truthful and accurate information regarding the existence of circumstances that could constitute a conflict of interest is connected to the methods by which these information obligations must be fulfilled (those governed by the Consolidated Law on Administrative Documentation, Articles 46 and 47). On the one hand, false declarations made in such contexts may result in criminal liability for the author. On the other hand, the administration has specific powers to verify the truthfulness of the declarations made and the facts attested, through the institution of official verification, including by directly consulting the archives of the certifying administration.

However, these solutions do not resolve the (structural) problem of information asymmetry between the administering administration and the party affected by the conflict of interest situation; they merely shift it further downstream, to the moment of verification (of truthfulness and completeness) to be carried out on the declarations made. Indeed, at this stage, the same initial condition reapplies for the administration carrying out the check: namely, a structural knowledge deficit regarding the relevant facts.

This condition also conspires to make the mechanism for revealing conflicts of interest less effective/efficient. In effect, the binding force of the system of self-declarations and subsequent truthfulness checks rests on the deterrent effect produced by the feared consequences (including criminal) of any false declarations made. Now, this "deterrent" effect would be, in practice, almost completely stripped of effectiveness/binding force if administrations were not placed in a position to be able to verify the truthfulness of the declarations made in an effective, efficient, and actual manner. In other words, few would actually fear making false or incomplete declarations if there was an awareness that the administration lacks the capacity and means to carry out controls and verifications effectively. This issue and this need have been explicitly raised by administrations themselves. In particular, the Conference of Regions and Autonomous Provinces, in its opinion on the 2019 National Anti-Corruption Plan, while favorable, explicitly requested that "more detailed indications be provided regarding the methods for checking the self-declarations made, both in matters of conflict of interest and other specific prevention measures that derive from it. In particular, the operational methods (...) should be better clarified, also considering the implications relating to the protection of personal data" (opinion of October 24, 2019).

b) Vertical Transparency as a Mechanism to Compensate for Information Asymmetry in Matters of Conflict of Interest

Conflict of interest (a completely central and strategic institution within the framework of corruption prevention mechanisms) involves a plurality of interests. These interests pivot in a network-like manner around the agent tasked with or participating in the exercise of public functions or activities, thus making relevant those interests conflicting with the public interest that are conveyed or channeled through the agent.

The analysis of mechanisms for detecting and enforcing conflict of interest situations shows that the full potential of this prevention tool is, in a way, hindered or weakened by the administrations' condition of structural information asymmetry, concerning their ability to know about conflict of interest situations. This condition makes the deterrent mechanisms related to verification procedures concerning the truthfulness (completeness and consistency) of declarations made by interested parties about the existence (or absence) of conflict situations less effective.

Therefore, there is a need to be met: to equip the administration with cognitive tools suitable for filling or at least reducing this information asymmetry, creating the conditions to deploy a cognitive capacity capable of increasing the effectiveness and actual impact of prevention mechanisms based on the identification and management of conflicts of interest.

This research aims to study and verify the feasibility of a methodology for combining and analyzing data that can help bridge this information asymmetry, through mapping and visualization techniques, in order to provide immediate evidence of the networks of relationships and interests in which the agent is embedded. This is also in view of potential, future applicative developments (which are, however, beyond the specific aims and purposes of this research project).

Given the above, the aims of the research project prove to be legitimate, since conflict of interest is the institution at the heart of mechanisms for preventing and combating administrative corruption. Preventing and combating administrative corruption is an objective pursued by numerous fundamental legislative instruments, at the international level (in many international conventions dedicated to the topic) and national level (see, in particular, but not only, the entire body of legislation on preventing administrative corruption, starting with Law 190/2012); in all these legislative instruments, a central role is assigned to the institution of conflict of interest. The European Union, for its part, is also in the process of developing a legislative instrument (a Directive) aimed at imposing minimum shared standards for preventing and combating administrative corruption, within which the institution of conflict of interest receives ample and decisive recognition as an essential prevention mechanism.

RAPPORTO DI RICERCA
Applicazione di un modello di screening automatico e validazione qualitativa del rischio potenziale di conflitto di interessi (22.02.2026)