Principles and rules governing the ethics, professional conduct and compliance of members of the Government (Sovereign Order No. 9.931 of 15 June 2023 amended by Sovereign Order No. 11.971 of 18 June 2026)

Sovereign Order no. 9.931 of 15 June 2023 (JDM no. 8652 of 21 July 2023) sets out the principles and rules of ethics, professional conduct and compliance applicable to members of the Government. It was amended by Sovereign Order No. 11.971 of 18 June 2026 (JDM n° 8805 of 26 June 2026).

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SUMMARY

Sovereign Order no. 9.931 is to be linked to the Fifth Evaluation Round of the Council of Europe's Group of States against Corruption (GRECO), launched on 20 March 2017, which focuses on "Preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies":

• ethical principles and rules of conduct
• conflict of interest
• prohibition or restriction of certain activities
• declaration of assets, income, liabilities and interests
• enforcement of the rules regarding conflicts of interest
• awareness.

Sovereign Order n° 9.931 transcribes this provision with regard to the members of the Government, namely the Ministre d’État (Minister of State) and the Conseillers de Gouvernement-Ministres (Government Councillors-Ministers). The amendments introduced by Sovereign Order No. 11.971 of 18 June 2026 form part of the 2026–2028 Monaco Anti-Corruption Strategy for senior executive positions

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IN DETAIL

Ethical principles and rules of professional conduct

— In carrying out their duties, members of the Government are subject to the principles of loyalty, dignity, probity, disinterestedness, impartiality, objectivity and professional discretion.

— Upon taking up office, each member of the Government is informed by the Secretary-General of the Government of the ethical, professional and compliance principles and rules applicable to their role, with a view to preventing conflicts of interest and promoting integrity. On this occasion, they are provided with a guide to best practice.

— Whilst carrying out their duties, members of the Government are required to undertake, on a regular basis and at least once a year, training and awareness-raising sessions on professional conduct.

— Establishment of a Comité d’éthique (Ethics Committee) (composed of three full members and three alternate members, external to the executive services of the State, the judicial services, and the Sovereign Household, selected for their expertise in the fields of ethics, deontology and compliance) for advice and all questions concerning the individual situation of a member of the Government.

— Creation of a Référent déontologue (Compliance Referent) (a person external to the executive services of the State, the judicial services, and the Sovereign Household, selected for their expertise in the fields of ethics, deontology and compliance) responsible for providing advice on the application of the principles and rules of ethics, professional conduct and compliance to their function.

Conflicts of interest

— It is the responsibility of each member of the Government to:

• prevent any potential or apparent conflict of interest (any situation of interference between a public interest and a private interest that influences or appears to influence the independent, impartial and objective performance of their duties) in which they may find themselves
• or to put an end to any real conflict of interest in which they find themselves.

— Organisation of withdrawal and abstention procedures in situations of real, potential or apparent conflict of interest.

• Example of application: Ministerial Order no. 2024-170 of 2 April 2024 (JDM no. 8689 of 5 April 2024) - Withdrawal of the Gouvernement-Ministre de l’Équipement, de l’Environnement et de l’Urbanisme (Government Councillor-Minister for Public Works, the Environment and Urban Planning) from the mission led by the Public Works Department to redefine the scope of the tasks of the project management group for the construction of the New Princess Grace Hospital (CHPG), who considered that he could be in a situation of real, potential or apparent conflict of interest. He has no knowledge of the acts and decisions relating to the negotiation and conclusion of the future amendment dealing with the reorganisation of the tasks of the project management consortium for the construction of the New CHPG (avenant no. 9 to the project management contract for the New CHPG, signed on 13 June 2013 and referenced under no. 048/13). The corresponding powers delegated to the Gouvernement-Ministre de l’Équipement, de l’Environnement et de l’Urbanisme shall be exercised by the Conseiller de Gouvernement-Ministre de l’Intérieur (Government Councillor-Minister for the Interior). The ministerial order will be repealed with effect from the signing of avenant no. 9 referred to above.

Declaration of assets and interests (confidential)

Prior to their appointment, members of the Government must submit a declaration setting out the interests they hold as at the date of the declaration.

Within two months of their appointment, they must submit a comprehensive, accurate and truthful declaration of their financial circumstances as at the date of appointment.

During the course of their official duties, members of the Government whose financial circumstances or declared interests undergo a substantial change shall personally declare such change. They may, beforehand, consult the Référent déontologue.

— The declaration of assets submitted to the Chairman of the Commission Supérieure des Comptes includes the following items, whether held in Monaco or abroad:

1. built and unbuilt property ;
2. securities
3. life insurance policies
4. current or savings bank accounts, passbooks and other savings products;
5. miscellaneous movable property worth more than €15,000;
6. motorised land vehicles, boats, ships and aircraft;
7. businesses or clienteles and offices;
8. liabilities in excess of €100,000.

Where applicable, the declaration of assets shall specify, in respect of each of the items listed above, whether it constitutes separate property, community property, or jointly owned property.

In addition to the items listed above, declarations of assets shall include a summary of the major events that have affected the composition of the declarant's assets since the previous declaration.

— The declaration of interests submitted to the Minister of State shall cover the following:

1. professional activities giving rise to remuneration or bonus carried out on the date of appointment ;
2. professional activities giving rise to remuneration or bonus carried out during the last five years;
3. consultancy activities carried out on the date of appointment and during the last five years;
4. holdings in the governing bodies of a private body or company on the date of appointment and during the last five years;
5. direct financial holdings in the capital of a company on the date of appointment;
6. professional activities carried out on the date of appointment by the spouse, the partner bound by a civil solidarity contract or by another contract relating to the organisation of joint life or cohabitation validly concluded abroad in application of foreign law;
7. voluntary work that gives rise or is likely to give rise to a conflict of interest;
8. voluntary work carried out on the date of appointment by the spouse, the partner bound by a civil solidarity contract or by another contract relating to the organisation of joint life or cohabitation validly concluded abroad in application of foreign law;
9. elected offices and directorships in private entities held on the date of appointment and during the five years preceding the appointment;
   
10. liabilities in excess of €100,000.

The declaration shall specify the amount of any remuneration, allowances or bonuses received by the member of the Government in respect of the items referred to in points 1 to 5 and 9 above.

Transparency in relations between members of the Government and lobbyists and other influential third parties

— Lobbyists and other influential third parties must disclose their identity, capacity and the purpose of the meeting in advance. For the purposes of these provisions, a lobbyist or other influential third party is any person who meets with a member of the Government in order to represent the interests of one or more private persons, or their own personal interests, with a view to influencing a public decision concerning the drafting of legislative or regulatory measures.

• Are not lobbyists and other influential third parties acting within the scope of their mandate or official duties: : 1°) representatives of religious denominations; 2°) members of the National Council and of the Communal Council.
• Meetings relating to individual administrative decisions are not concerned.

— Establishment of a central register of meetings ("registre général des entrevues") held by members of the Government. For each meeting, the register shall record:

1. the date and place of the meeting;
2. the full name of the member or members of the Government present;
3. the full name of the lobbyist(s) and other influential third party(ies) present;
4. the name, registered business name, registered office address and registration number in the Trade and Companies Register of the entities or legal persons represented or, where the represented party is a natural person, that person's full name, together with the locality of their professional address or, failing that, their private address, and, where applicable, their registration number in the Trade and Industry Register;
5. a general description of the position advocated by the lobbyists and other influential third parties in relation to legislative or regulatory activities; and
6. where applicable, the draft Bills, legislative proposals or regulatory texts, or the legislation or regulations discussed during the meeting.

The register shall be updated regularly, and at least once every six months, and shall be made publicly available.

The Chair of the Ethics Committee shall be authorised to review the central register of meetings. Where considered appropriate, the Chair may request any additional information from the member of the Government concerned.

Gifts and benefits (in connection with the performance of duties)

— Members of the Government must neither solicit nor accept gifts, favours, invitations or any other advantage (goods of any kind, whether movable, whether tangible or intangible, or immovable, or services of any kind whatsoever) intended for themselves, their family, their relatives or organisations with which they have or have had business or political relations:

• which could influence or appear to influence the impartiality, independence or objectivity with which they must carry out their duties,
• or which might constitute or appear to constitute a reward in connection with their duties,
• or which could influence or appear to influence their judgement in a decision-making process.

— The following may be accepted, but may not be solicited:

1. gifts received by virtue of diplomatic custom and the rules of courtesy in use, the estimated value of which does not exceed the sum of 200 € ;
2. invitations to an event, demonstration or ceremony, particularly sporting or cultural, which the members attend or participate in as a representative of the Prince's Government.

— The receipt of any gift or benefit is recorded in an inventory book ("livre d’inventaire") listed and kept as appropriate by the Secretariat General of the Government or the Secretariat General of the Ministerial Department. The inventory book shall include the following information:

• the date of receipt;
• the name of the person and, where applicable, their position or the name of the company offering the gift;
• the name of the Government member receiving the gift;
• a description of the gift;
• the intended destination of the gift;
• its estimated value;
• the signature of the recipient.

An annual review of the inventory books shall be carried out by the Chair of the Ethics Committee. Where considered necessary, the Chair may request any additional information from the Government member concerned.

Practical guidance intended to facilitate the implementation by members of the Government of the provisions relating to the acceptance of gifts and other benefits is set out in the code of best practice.

Exercise of external activities by members of the Government

— Members of the Government may not, during the exercise of their duties, hold, in Monaco or abroad, any other public office or engage in any parallel professional activity for remuneration.

— They are, however, authorised to engage in: 1°) voluntary activities; 2°) teaching, artistic, literary, sporting or cultural activities.

Exercise of private activities by former members of the Government

—The Ethics Committee's opinion (confidential) is sought when any member of the Government, on leaving government office and within two years of doing so, intends to engage in a gainful activity, whether salaried or not, in a private company or organisation or in a liberal profession :

• Where the Ethics Committee considers that the intended activity conflicts with the current or former responsibilities of the Government member concerned, it may issue recommendations to regulate that activity for a maximum period of two years following the termination of the relevant duties that give rise to the conflict.
• Where the Ethics Committee considers that the intended activity is clearly in conflict with the current or former responsibilities of the Government member concerned, and that regulating the activity would not prevent a conflict of interest, it may recommend that the individual does not carry out the intended activity for a maximum period of two years following the end of the relevant duties.

— Should the former member of the Government concerned fail to comply with the opinion of the Ethics Committee, it will be published in the Journal de Monaco.

Training and awareness

— When they take up their duties, all members of the Government are informed of the principles and rules of ethics, professional conduct and compliance applicable to their position with regard to the prevention of conflicts of interest and the promotion of integrity. They are also given a guide to good practice.

— During their term of office, members of the Government receive training and awareness-raising on ethical issues.

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