Principles and rules governing the ethics, professional conduct and compliance of State senior civil servants and contractual employees (Sovereign Order No. 11.972 and Ministerial Order No. 2026-333 of 18 June 2026)

Sovereign Order No. 11.972 of 18 June 2026 amending Sovereign Order No. 6.365 of 17 August 1978 laying down the conditions for the application of Law No. 975 of 12 July 1975 on the status of civil servants, as amended (JDM No. 8805 of 26 June 2026) lays down the ethical, professional and compliance principles and rules applicable to senior civil servants (new Articles 4-5 to 4-21).

In addition, Ministerial Order No. 2026-333 of 18 June 2026 (JDMNo. 8805 of 26 June 2026) implementing Article 58 of Sovereign Order No. 3.413 of 29 August 2011, as amended, laying down various measures governing the relationship between the Administration and members of the public, specifically regulates asset declarations and the transparency of dealings with interest representatives and influential third parties in respect of State senior civil servants and contractual employees.

It forms part of the 2026–2028 Strategy to combat corruption in senior executive positions in the Principality of Monaco, implementing the recommendations of the Council of Europe Group of States against Corruption (GRECO) as part of the Fifth Evaluation Round.

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IN DETAIL

Senior civil servants covered

The new provisions apply to civil servants holding the following posts:

1. Secrétaire Général du Gouvernement (Secretary-General of the Government);
2. Directeur ou de Chef de Cabinet du Ministre d’État (Director or Chief of Staff to a Minister of State);
3. Secrétaire Général Adjoint du Gouvernement ou d’Adjoint au Secrétaire Général du Gouvernement (Deputy Secretary-General of the Government or Assistant to the Secretary-General of the Government);
4. Directeur Général de Département ministériel (Director-General of a ministerial department);
5. Directeur de la Sûreté Publique (Police Director);
6. Directeur-Adjoint de la Sûreté Publique (Police Deputy Director);
7. holding the rank of Commissaire de Police (Police Commissioner).

Prevention of ethical risks

— Upon taking up their posts, the civil servants concerned are informed of the ethical, professional and compliance principles and rules applicable to their duties 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, they are required to undertake, on a regular basis and at least once a year, training and awareness-raising sessions on the ethical principles and obligations applicable to them under Law No. 975 of 12 July 1975, as amended.

— The référent déontologue (ethics officer) is responsible for providing any advice necessary for the application of ethical principles and obligations. Consultations with the ethics officer are confidential. The ethics officer is bound by professional secrecy in accordance with the conditions set out in Article 308 of the Criminal Code and may not disclose any information obtained in the course of their duties. The duties of the ethics officer shall be carried out by a person from outside the Administration, selected on the basis of their expertise in the fields of professional conduct, ethics and compliance, and appointed by the Minister of State. For staff falling under the Police Directorate, the duties of the ethics officer shall be carried out by a person appointed by the Police Director.

— The Minister of State may take any measures necessary to ensure compliance with ethical principles and obligations. To this end, he may consult the Ethics Committee established by Sovereign Order No. 9.931 of 15 June 2023, as amended, referred to above, whose opinions are confidential and may, where appropriate, be accompanied by recommendations.

Ethical reviews

The civil servants concerned are subject to an ethical review prior to their appointment and prior to any temporary or permanent cessation of their duties.

Declaration of interests prior to appointment

— Persons due to be appointed to one of the civil service posts in question must submit a declaration of their private interests and of any activities they have previously undertaken. They may consult the ethics officer beforehand. The declaration must cover the following:

1. any professional activities giving rise to remuneration or benefits carried out at the time of appointment;
2. any professional activities that have given rise to remuneration or benefits carried out during the last five years;
3. any consultancy work carried out at the time of appointment and during the last five years;
4. membership of the governing bodies of a private organisation or company at the time of appointment or during the last five years;
5. direct financial holdings in the share capital of a company at the date of appointment;
6. professional activities carried out at the date of appointment by the spouse, a partner bound by a civil solidarity contract or by another contract relating to the organisation of shared living arrangements or cohabitation, validly concluded abroad in accordance with foreign law;
7. voluntary roles giving rise to, or likely to give rise to, a conflict of interest;
8. voluntary roles held at the time of appointment by the spouse, a partner bound by a civil solidarity contract or by another contract relating to the organisation of shared living arrangements or cohabitation, validly concluded abroad in accordance with foreign law;
9. elected positions and mandates within private entities held at the time of appointment and during the five years preceding it;
10. liabilities exceeding the threshold of 100,000 euros.

The declaration specifies the amount of remuneration, allowances or gratuities received by the person concerned in respect of the items referred to in points 1 to 5 and 9.

The declaration of interests shall not include any reference to the individual’s political, trade union, religious or philosophical opinions or activities, except where the disclosure of such opinions or activities arises from the declaration of public offices or mandates held.

The declaration of interests shall be addressed to the Chair of the Ethics Committee, who shall examine the compatibility of the proposed functions with the individual’s previous activities or private interests, seeking the advice of the members of the Ethics Committee where necessary. Such advice shall be confidential. The Committee may ask the person making the declaration to provide any documents relevant to the fulfilment of its remit, and any explanations likely to clarify the matter.

— The declarations are recorded in a numbered register kept by the Chair of the Ethics Committee, who ensures the confidentiality and safekeeping of the declarations received in a safe provided for this purpose for the entire duration of the civil servant’s term of office, extended by ten years. They are then destroyed whilst ensuring the confidentiality of the information they contain. This does not apply in the event of criminal proceedings based on a breach relating to information contained in the declarations of interests, in which case destruction is suspended until the expiry of the period at the end of which all avenues of appeal against any decision taken following the criminal proceedings have been exhausted.

— Where the person is not appointed to the post in respect of which they had submitted a declaration of interests, the authority to which the declaration was addressed shall, without delay and whilst ensuring confidentiality, destroy it.

Declaration regarding intended activities upon leaving office

— A civil servant who holds or has held one of the posts referred to herein and who, upon leaving office and within two years of doing so, intends to undertake gainful employment, whether salaried or not, in a private company or a body governed by private law, or any self-employed activity, must submit a declaration to the Minister of State containing a detailed description of the proposed activity.

— The Ethics Committee, to which the Minister of State has referred the matter, shall issue a (confidential) opinion within two months to assess the compatibility of that activity with the duties performed during the two years preceding the start of that activity. The person concerned may be invited to submit their comments and any evidence or documents likely to shed light on the matter:

• Where it considers that the intended activity conflicts with the duties performed during the two years preceding the start of that activity, it may make recommendations regarding the supervision of that activity for a maximum period of two years following the cessation of the conflicting duties.
• Where the imposition of conditions on the activity would not prevent a conflict of interest, the Ethics Committee may recommend that the civil servant or former civil servant should not carry out the proposed activity for a maximum period of two years following the end of the duties giving rise to the conflict.

In the event of failure by a civil servant currently holding or having held one of the posts in question to comply with the Ethics Committee’s opinion, this shall be published by way of an insert in the Journal de Monaco.

Gifts and benefits

— Definition : property of any kind, whether movable (tangible or intangible) or immovable. It also refers to the provision of a service of any kind. The gift or benefit may be for personal use or intended for a third party or a group of people.

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

1. Gifts received in accordance with diplomatic custom and customary rules of courtesy, the estimated value of which does not exceed two hundred euros;
2. Invitations to an event, function or ceremony, in particular sporting or cultural events, which civil servants holding one of the posts concerned attend or participate in as representatives of the administration to which they belong.

Gifts that do not meet these conditions must be returned, with a formal refusal, together with any supporting documentation attesting to such return.

— Gifts which do not meet the conditions for acceptance but cannot be refused must be handed over without delay to the immediate superior, recorded in the inventory register and then, where applicable, handed over to the Administration des Domaines (Public Property Administration).

— The receipt of gifts or benefits shall be recorded in a numbered inventory register (livre d'inventaire) kept by the immediate superior, which shall contain the following information:

• the date of receipt;
• the name of the person and, where applicable, their position or the name of the company that offered the gift;
• the name of the civil servant receiving the gift;
• a description of the gift;
• the intended use of the gift;
• the estimated value;
• the recipient’s signature.

The Chair of the Ethics Committee carries out an annual review of the inventory register. Where they deem it necessary, they may request any further information from the civil servant appointed to one of the posts in question.

Practical guidance designed to facilitate implementation, including provisions on the acceptance of gifts and other benefits, may be included in the good practice guide.

Asset Declaration

— Within two months of his or her appointment or designation, the civil servant or State contractual employee holding one of the designated posts shall submit a comprehensive, accurate and truthful declaration of his or her assets as at the date of appointment or designation.

— During the performance of his or her duties, any State civil servant or contractual employee whose assets undergo a substantial change shall personally declare such change.

— Within two months following the termination of his or her duties or employment, other than by reason of death or a medically certified incapacity to perform those duties, the State civil servant or contractual employee shall submit a comprehensive, accurate and truthful declaration of his or her assets, assessed as at the date of the declaration.

— The asset declaration shall include the following assets and liabilities, whether situated in Monaco or abroad:

1. developed and undeveloped immovable property;
2. securities;
3. life insurance policies;
4. current and savings bank accounts, savings books and other savings products;
5. movable property with a value exceeding EUR 15,000;
6. motor vehicles, boats, ships and aircraft;
7. businesses, professional practices, public offices and ministerial offices;
8. liabilities exceeding EUR 100,000.

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

In addition to the information listed above, each declaration shall include a description of the principal events that have affected the composition of the declarant's assets since the previous declaration.

A declaration form shall be provided to the person subject to the declaration requirement by the President of the Supreme Audit Commission.

The declarant may append observations to each declaration and, where appropriate, provide any supporting documentation.

The President of the Supreme Audit Commission (Commission Supérieure des Comptes), or a person designated by him or her for that purpose from within the Commission, shall verify the formal compliance of the declaration and assess its completeness, accuracy and truthfulness.

Transparency of dealings with interest representatives and influential third parties

— Prior to any meeting, the interest representative or influential third party shall disclose his or her identity, capacity and the purpose of the meeting. An interest representative or influential third party is a person who meets with a civil servant or State contractual employee holding one of the designated posts in order to represent the interests of one or more private persons, or his or her own interests, with a view to influencing a public decision relating to the preparation of legislative or regulatory measures.

• The following shall not be regarded as interest representatives or influential third parties when acting within the scope of their mandate or functions: 1°) representatives of recognised religious denominations; 2°° members of the National Council and the Communal Council.
• Meetings relating to individual administrative decisions are excluded from these provisions.

— A general register of meetings involving State civil servants and contractual employees holding one of the designated posts shall be established. For each meeting, the register shall record:

1. the date and place of the meeting;
2. the names of the State civil servants or contractual employees present;
3. the names of the interest representatives and influential third parties present;
4. the name, corporate name, registered office address and registration number in the Trade and Companies Register of any entity or legal person represented, or, where the represented party is a natural person, that person's full name, the locality of his or her professional address or, failing that, private address, and, where applicable, registration number in the Trade and Industry Register;
5. a general description of the position advocated by the interest representatives or influential third parties in relation to legislative or regulatory activities;
6. where applicable, the bills, draft laws, draft regulations, enacted legislation or regulatory instruments discussed during the meeting.

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

The President of the Ethics Committee is authorised to review the general register of meetings. Where considered appropriate, he or she may request any additional information from the State civil servant or contractual employee concerned.