COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Estonia Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2020 Rule of Law Report The rule of law situation in the European Union
Date: 2020-09-30
Institutions: European Commission, Secretariat-General
Subjects: Estonia, administrative transparency, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.9.2020  SWD(2020) 305 final  COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Estonia Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  2020 Rule of Law Report The rule of law situation in the European Union {COM(2020) 580 final} - {SWD(2020) 300 final} - {SWD(2020) 301 final} - {SWD(2020) 302 final} - {SWD(2020) 303 final} - {SWD(2020) 304 final} - {SWD(2020) 306 final} - {SWD(2020) 307 final} - {SWD(2020) 308 final} - {SWD(2020) 309 final} - {SWD(2020) 310 final} - {SWD(2020) 311 final} - {SWD(2020) 312 final} - {SWD(2020) 313 final} - {SWD(2020) 314 final} - {SWD(2020) 315 final} - {SWD(2020) 316 final} - {SWD(2020) 317 final} - {SWD(2020) 318 final} - {SWD(2020) 319 final} - {SWD(2020) 320 final} - {SWD(2020) 321 final} - {SWD(2020) 322 final} - {SWD(2020) 323 final} - {SWD(2020) 324 final} - {SWD(2020) 325 final} - {SWD(2020) 326 final}  
 
 
ABSTRACT 

The Estonian justice system is characterised by some of the most advanced information and 
communication technologies used in courts. They provide a high degree of accessibility and 
flexibility to court uses, and have also contributed greatly to the continued functioning of the 
courts with  relatively little disruption during the  COVID-19 pandemic. The Supreme Court 
and judicial self-governance bodies are well involved in the main aspects of the management 
of  the  justice  system,  particularly  on  allocation  of  human  and  financial  resources  and  in 
appointment and other aspects of judges’ careers. 

Estonia  has  the  legal  and  institutional  set-up  to  fight  corruption  broadly  in  place.  It  has 
established an effective network to manage the implementation of the anti-corruption policy. 
A  new  anti-corruption  strategy  is  in  preparation.  All  Ministries  are  equipped  to  coordinate 
corruption  prevention  and  ensure  the  implementation  of  the  national  anti-corruption 
strategy’s  activities  in  the  relevant  sector.  The  capacity  to  investigate  and  prosecute 
corruption  crimes  is  effective  and  according  to  the  the  Prosecutor’s  Office,  the  budgetary 
resources are considered satisfactory. Provisions have been introduced to regulate ‘revolving 
doors’. Lobbying activities are not regulated by law but a draft regulation is in the pipeline 
and  a  comprehensive  whistleblower  protection  framework  is  still  not  in  place.  Estonia  has 
largely invested in e-learning to support prevention of conflict of interest for all public sector 
employees.  

The  Estonian  legal  framework  concerning  media  pluralism  is  based  both  on  constitutional 
safeguards  and  sectorial  legislation.  The  media  regulator  -  the  Consumer  Protection  and 
Technical  Regulatory  Authority  (ECPTRA)  -  operates  as  an  administrative  part  of  the 
Ministry of Economic Affairs. The law transposing the revised Audiovisual Media Services 
Directive (AVMSD) will reinforce its independence. Transparency of media ownership is not 
fully ensured pending the adoption of new specific legal provisions. Yet, general information 
related  to  entrepreneurship  is  electronically  available,  and  access  to  data  in  the  Business 
Register  is  free.  The  framework  for  the  protection  of  journalists  is  comprehensive  and 
safeguards for the protection of journalists are included in several acts.  

The  system  of  checks  and  balances  in  Estonia  is  well-developed,  with  an  inclusive  process 
for  the  adoption  of  laws,  which  is  being  further  developed.  The  Constitutional  Review 
Chamber  of 
the  Supreme  Court  performs  both  ex-ante  and  ex-post  control  of 
constitutionality,  including  through  a  direct  constitutional  complaint.  The  Chancellor  for 
Justice, plays a strong role in the system of checks and balances, and its accreditation with the 
A-status according to UN principles is ongoing (delayed due to COVID-19 pandemic).  

1 

 
 
 
 
 
I.  JUSTICE SYSTEM  

The  Estonian  court  system  consists  of  three  levels:  four  County  Courts  (hearing  all  civil, 
criminal  and  misdemeanour  matters)  and  two  Administrative  Courts  at  first  instance,  two 
Circuit Courts at second instance (reviewing decisions of County and Administrative Courts), 
and  the  Supreme  Court  at  the  highest  instance,  which  reviews  court  judgments  by  way  of 
cassation  proceedings  and  is  also  the  court  of  constitutional  review.  The  Supreme  Court 
administers its own budget and operations, while the courts of first and second instance are 
administered  in  cooperation  between  the  Council  for  Administration  of  Courts  and  the 
Ministry  of  Justice.  The  Council  for  Administration  of  Courts  is  a  non-permanent  body, 
which,  among  others,  has  powers  related  to  the  judicial  map,  the  resources  of  the  judiciary 
and participates in the discussion on administration of the courts.1 Judges of first and second 
instance  courts  are  appointed  by  the  President  of  the  Republic  on  the  proposal  of  the  full 
Supreme  Court  (en  banc).  The  Prosecutor’s  Office  is  a  government  agency  under  the 
Ministry of Justice, which is independent in the performance of its duties. It is managed by 
the  Prosecutor  General,  particularly  as  regards  the  appointment  and  career  of  prosecutors.2 
Lawyers  (attorneys)  in  the  Estonian  justice  system  are  members  of  the  Estonian  Bar 
Association, which is an independent, self-governing professional association.  

Independence 

The Supreme Court and other judicial self-governance bodies play an important role in 
judicial  appointments  and  other  decisions  on  the  justice  system.  The  Supreme  Court 
organises  the  competition  and,  in  plenary  sitting,  selects  candidate  judges  for  the  first  and 
second  instance  courts,  proposing  them  for  appointment  by  the  President  of  the  Republic.3 
The judges of the Supreme Court are appointed by the Parliament (Riigikogu) on the proposal 
of the President of the Supreme Court, who first considers the opinions of the full Supreme 
Court (en banc) and of the Council for Administration of Courts. The Supreme Court assists 
in organising the work of the five self-governance bodies of judges (the Court comprising all 
judges  (Court  en  banc),  the  Council  for  Administration  of  Courts,  the  Judicial  Training 
Council,  the  Judges’  Examination  Committee4,  the  Disciplinary  Chamber5  and  the  Judicial 
Ethics  Council).  Moreover,  its  Constitutional  Review  Chamber  would  resolve  potential 
requests for judicial review filed against the decision of the President of the Republic not to 

1   The Council for the Administration of Courts is consists of Chief Justice of the Supreme Court, five judges 
elected by the Court en banc for three years, two members of the Parliament (ex officio the chairpersons of 
the  Legal  Committee and the Constitutional  Committee), a sworn advocate appointed by the  Board of  the 
Bar Association, the Chief Public Prosecutor or a public prosecutor appointed by him or her, the Chancellor 
of Justice (ombudsperson) or a representative appointed by him or her. In addition, the Minister of Justice or 
a representative appointed by him or her shall participate in the Council with the right to speak but without 
the right to  vote. The  Council is not a permanently operating body but a council that  has regular  sessions 
four times a year and extraordinary sessions whenever there is a need. 

2   Figures 55 – 57, 2019 EU Justice Scoreboard. The Ministry of Justice exercises supervisory control over the 
prosecution service, however, this does not extend to the activities of the Prosecutor’s Office in the planning 
of surveillance, pretrial criminal proceedings and representing the public prosecution in court. See Art. 9 of 
the Prosecutors’ Office Act. The Prosecutor General is appointed by the Government on the proposal of the 
minister of justice after considering the opinion of the Legal Affairs Committee of the Parliament. 

3   Art. 30 of the Courts Act. 
4   The  Judges’  Examination  Committee  is  composed  of  ten  members  and  is  formed  for  five  years.  Six  are 
judges from all three levels, one jurist designated by the Law Faculty in Tartu, one person designated by the 
Minister of Justice, a lawyer  designated by the Bar Association and a public prosecutor designated by the 
Prosecutor General. See Art. 69 of the Courts Act. 

5   For the composition of the chamber, see Art.  93(1) – five justices of the Supreme Court, five circuit court 

judges and five judges of courts of the first instance. 

2 

 
 
                                                 
appoint a candidate judge.6  It should be noted that the President has so far never refused to 
appoint a  candidate judge. Therefore, there has never been a case of judicial review before 
the Constitutional Review Chamber regarding a non-appointment of a candidate judge.  

The  level  of  perceived  judicial  independence  is  average  among  the  general  public  and 
low among companies. Among the general public, 57% perceive judicial independence to be 
fairly  and  very  good,  which  is  an  increase  compared  to  2019,  after  a  previous  downward 
trend.  Among  companies  perceived  independence  is  low  (only  39%  consider  it  to  be  fairly 
and very good), and remains stable, after a previous downward trend.7 Another survey among 
businesses  (World  Economic  Forum)  where  the  level  of  perceived  independence  is  above 
average among Member States, has in recent years shown a decrease in perception.8 

The  Council  for  Administration  of  Courts  plays  an  important  role  in  determining  the 
resources for the judiciary, and contributed to the response to the COVID-19 pandemic. 
The Council for Administration of Courts, a non-permanent body consisting of a majority of 
judges, plays an important role in managing the justice system. Among others, it approves the 
judicial map, the number of judges for each court, and the appointment and dismissal of court 
presidents. In addition, it gives opinions on court budgets and candidates for Supreme Court 
judges. The Council does not function on a permanent basis and has four regular sessions, as 
well  as  extraordinary  sessions  whenever  needed.  For  example,  the  Council  discussed  the 
response of the justice system to the COVID-19 pandemic, including the further development 
of electronic communication in courts to keep the courts functioning.9 Organisational support 
for the Council is provided by the Ministry of Justice, which cannot intervene in the work and 
decision-making of the Council. The Council has to approve most of the important decisions 
made  by  the  Ministry  of  Justice  in  relation  to  the  courts.10  It  also  gives  an  opinion  on 
financial,  budgetary  and  some  human  resources  matters.11  In  particular,  it  is  involved  in 
determining  the  allocation  of  resources  to  courts,  as  it  gives  an  opinion  on  the  proposal 
drafted by the Ministry of Justice in consultation with court presidents. In the process of the 
Council presenting its opinion on the budget, a compromise proposal is formed, which fully 
involves the judiciary. 

6   GRECO  noted  that  the  Supreme  Court  decides  in  plenary  (19  justices)  when  making  proposals  for  the 
appointment of the first and second instance court judges, while the Constitutional Review Chamber of the 
Supreme Court, composed of nine justices, serves as the appeal instance. According to GRECO, this creates 
a  problem  of  “structural  impartiality”  addressed  in  several  decisions  of  the  European  Court  of  Human 
Rights.  See  GRECO  Fourth  Evaluation  round  –  Evaluation  report,  para.  99.  See  also  GRECO  Fourth 
Evaluation round - Second Compliance Report, paras. 39 – 44. 

7   Figures 44 and 46, 2020 EU Justice Scoreboard.  
8   Figure  48,  2020  EU  Justice  Scoreboard.  The  level  of  perceived  judicial  independence  is  categorised  as 
follows: very low (below 30% of respondents perceive judicial independence as fairly good and very good); 
low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

9   Recommendations of the  Council  for Administration of Courts  for organising the administration of justice 

during emergency situation. 

10  See Articles 39 and 41 of the Courts Act: determination of the territorial jurisdiction of courts, structures of 
the courts, the location of courts and courthouses; determination of the number of judges in  the courts and 
courthouses; appointment to office and premature release of chairmen of courts; a decision to allow a judge 
to  continue  to  serve  after  attaining  the  age  of  retirement;  determination  of  the  number  of  lay  judges;  the 
establishing of the composition of the register data of the courts information system and the procedure for 
the submission thereof.  

11  See  Art.  39  and  41  of  the  Courts  Act:  the  principles  of  the  formation  of  annual  budgets  of  courts;  the 
conformity of the funds allocated to courts in the budget of the Ministry of Justice with the principles of the 
formation  of  annual  budgets  of  courts;  candidates  for  a  vacant  position  of  justice  of  the  Supreme  Court; 
release of a judge from office due to extraordinary reasons. 

3 

 
 
                                                 
Quality 

Information  and  communication  technologies  in  courts  are  advanced,  and  are  being 
further developed to make the courts function smoothly despite the COVID-19 related 
challenges. Estonia is among the Member States which perform the best when it comes to the 
use  of  Information  and  Communication  Technology  (ICT)  to  improve  the  accessibility  and 
overall quality of their justice system.12 The work of courts is facilitated  by  the use of four 
ICT tools: the Court Information System (CIS), Public e-file, e-File and the recently launched 
Digital  Court  Files  system.  The  CIS  is  the  internal  court  information  system  used  by  all 
judges and court officials, and it contains all documents submitted to a court or generated by 
a court. It further serves as an environment for creating court documents with customisable 
templates,  making  inquiries  from  other  databases  and  sending  court  information  to  other 
information  systems  via  e-File.  The  CIS  is  also  used  for  distributing  cases  automatically 
among  judges.13  The  public  e-File  is  the  external  information  system  which  allows  parties 
and their representatives to  electronically participate in  proceedings.14 Public e-File enables 
citizens  to  initiate  civil  and  administrative  proceedings,  and  to  monitor  these  and 
misdemeanour proceedings as well as to submit documents to be processed. It is based on the 
e-File system  that combines  the information systems  of the Police, the Prosecutor’s Office, 
the courts and other bodies conducting proceedings, ensuring central sharing of information 
on proceedings between parties and a quick and paperless data exchange. The purpose of the 
public  e-File  system  is  to  provide  information  contained  in  the  e-File  system  to  procedural 
parties via the Internet.15 The e-File is an internal central information system that provides a 
detailed overview of different stages of proceedings. It allows for the simultaneous exchange 
of information between various parties to the proceedings.16 Users of the client systems can 
only see the data that are related to their professional duties.17 The Digital Court Files system 
is used for a better and more functional overview and accessibility of court files for judges, 
their assistants18 and parties to court proceedings.19 This ICT tool offers users several options 
for better organisation and optimisation of the procedural steps and processes in the courts.20 
In a response to the COVID-19 pandemic, the further development and implementation of the 
Digital Court Files system was advanced, which allowed the courts and prosecution service to 
continue working without major disruption. 

12   Figures 27 – 29, 2020 EU Justice Scoreboard. 
13   Input from Estonia for the 2020 Rule of Law Report. 
14   Public  e-File  gives  access  to  civil,  administrative,  criminal  and  misdemeanour  cases.  It  has  approximately 
5000 users who log into the system at least once a week and 50 000 requests from client systems daily. 

15   For more information see https://www.rik.ee/en/international/public-e-file.  
16   For more information see https://www.rik.ee/en/international/e-file. 
17   For example, prison officers cannot access information regarding court proceedings. 
18   Via the CIS. 
19   Via the Public e-File. 
20   It  should  be  noted  that  upon  request  from  a  Member  State,  the  Commission  can  provide  tailor-made 
expertise  via  the  Structural  Reform  Support  Programme  to  help  design  and  implement  growth-enhancing 
reforms. Since 2018, such support has been provided to Estonia for reforms in the justice system. As Estonia 
is one of the most digitalised countries in the world, including at the level of e-services by the public sector, 
compared to less digitalised countries, cybercrime has thus potentially a large impact on Estonian's stability, 
economy and growth. The support aims to develop effective national cybercrime units within the police, the 
Border  Guard  Board,  the  Prosecutor’s  Office  and  the  courts  in  order  to  counter,  investigate  and  prosecute 
cyber threats. 

4 

 
 
 
 
                                                 
Efficiency 

The  Estonian  justice  system  is  working  efficiently.  In  2019,  civil  cases  were  resolved  in 
county courts on average in 95 days, criminal cases were resolved on average in 226 days in 
general  criminal  proceedings,  28  days  in  simplified  proceedings  and  46  days  in 
misdemeanour  cases.  In  the  first  instance  courts,  administrative  cases  were  resolved  in  an 
average of 123 days.21 The average processing time for appeals was 162 days in civil cases, 
44  days  in  criminal  cases  and  197  days  in  administrative  cases.  The  length  of  court 
proceedings  in  civil,  commercial  and  administrative  cases  is  shorter  than  average  level 
(measured in disposition time) and pending cases are often among the lowest in the EU.22 In 
those type of cases, the clearance rate is  above 100%, meaning that courts are able to  cope 
with incoming cases.  

II.  ANTI-CORRUPTION FRAMEWORK  

The Ministry of Justice is in charge of the preparation of the national anti-corruption strategy 
and  oversees  and  coordinates  the  reporting  on  the  Action  Plan  for  the  Anti-corruption 
Strategy.  The  Anti-Corruption  Select  Committee  exercises  parliamentary  scrutiny  over  the 
implementation  of  anti-corruption  measures  and  the  Political  Party  Funding  Supervision 
Committee oversees political parties’ funding. The Corruption Crime Bureau of the National 
Criminal Police is a specialised unit responsible for carrying out investigations on corruption 
cases  and  the  Internal  Security  Service  is  responsible  for  investigating  corruption  offences 
committed  by  higher  state  officials  and  higher  local  government  officials  in  six  larger 
municipalities. The Prosecutor’s Office supervises and directs pre-trial criminal investigation 
proceedings on corruption offences and it represents the public prosecution in courts. 

Estonia scores 74/100 in the Transparency International Corruption Perceptions Index 
and ranks 8th in the European Union and 18th globally.23 60% of respondents to the 2020 
Special  Eurobarometer  perceive  corruption  widespread  (EU  average  71%)24  and  14%  of 
people  feel  personally  affected  by  corruption  in  their  daily  lives  (EU  average  26%).  As 
regards business, 44% of companies consider corruption to be widespread (EU average 63%), 
while  9%  of  companies  consider  that  corruption  is  a  problem  when  doing  business  (EU 
average  37%).  37%  respondents  find  that  there  are  enough  successful prosecutions to  deter 
people  from  corrupt  practices  (EU  average  36%),  while  46%  of  companies  believe  that 
people  and  businesses  caught  for  bribing  a  senior  official  are  appropriately  punished  (EU 
average 31%).25 

A new anti-corruption strategy is in preparation. The Ministry of Justice (Criminal Policy 
Department)  is  responsible  for  coordinating  anti-corruption  activities.26  The  Ministry  of 
Justice  oversees  and  coordinates  the  reporting  on  the  Action  Plan  for  the  Anti-corruption 

21   Input from Estonia for the 2020 Rule of Law Report.  
22   Figures 4 – 15, 2020 EU Justice Scoreboard. 
23   Transparency International 2020 index. 
24   Special Eurobarometer 502 (2020). 
25   Flash Eurobarometer 482. 
26   Each  other  ministry  has  a  corruption  prevention  co-ordinator  who  is  appointed  to  manage  the 
implementation of the anti-corruption policy its area of competence. The network convenes around four to 
five  times  per  year  and  it  includes  also  representatives  from  the  police,  civil  society,  Parliament,  the  state 
audit  office  and  other  stakeholders.  The  budget  of  anti-corruption  coordination  is  7000-15  000  €  for  anti-
corruption projects, besides running costs for personnel.  

5 

 
 
                                                 
Strategy.27  The  current  Strategy  is  coming  to  an  end  as  it  covers  the  period  from  2013  to 
2020.28 A new strategy is in preparation. The list of high-risk sectors has been translated into 
priorities  within  the  Anti-corruption  Strategy  2013-2020  and  currently  includes  health-care 
and  education.  Public  procurement  is  considered  as  a  horizontal  corruption-prone  area 
throughout various sectors.  

Competences  in  the  prevention  and  fight  against  corruption  are  shared  between 
different  institutions.  The  Prosecutor’s  Office  supervises  and  directs  pre-trial  criminal 
investigation proceedings on corruption offences, and it represents the public prosecution in 
courts.29  The  number  of  corruption  crimes  registered  has  decreased  in  2019  by  81% 
compared to 2018.30 Approximately 40% of corruption cases occur at local level.31 According 
to  the  Prosecutor’s  Office,  the  budgetary  resources  are  considered  satisfactory.32  The 
Corruption  Crime  Bureau  (CCB)  of  the  National  Criminal  Police  is  the  specialised  unit 
responsible  for  carrying  out  investigations  on  corruption  cases.  The  functions  of  the  CCB 
include  both  the  prevention  and  pre-trial  investigation  of  criminal  offences  under  the 
supervision and direction of the Prosecutor’s Office and the processing of misdemeanours in 
corruption cases.33 In addition, the Internal Security Service has competences as regards the 
pre-trial  investigation  of  criminal  offenses  and  processing  of  misdemeanours  in  corruption 
cases.  Each  Ministry  has  one  official  coordinating  corruption  prevention  and  ensuring  the 
implementation  of  the  national  anti-corruption  strategy’s  activities  in  the  relevant  sector. 
Corruption prevention coordinators also report to the respective Minister in case of suspicions 
of corruptions  or corruption  risks. When there is  evidence of corruption, they  report this to 
the  police.34  The  parliamentary  Anti-Corruption  Select  Committee  exercises  parliamentary 
scrutiny over the implementation of anti-corruption measures and discusses and assesses the 
potential  incidents  of  corruption  involving  officials  specified  in  the  Anti-Corruption  Act.35 
The  Political  Party  Funding  Supervision  Committee  oversees  political  parties’  funding  and 
supervises  the  legality  of  obtaining  and  spending  the  finances  of  political  parties,  election 
coalitions and independent candidates who participate in elections.36 

27   Estonian Government Anti-corruption strategy 2013.  
28   Korruptsioonivastase strateegia aastateks 2013-2020" rakendusplaan aastateks 2017-2020.  
29   The  Prosecutor’s  Office  budget  for  2020  is  EUR  15  159 770  euros,  which  represents  an  increase  of  EUR 

763 801 compared to 2019. 

30   Ministry 

of 

Justice, 

Criminality 

in 

Estonia 

– 

2019, 

Corruption. 

https://www.kriminaalpoliitika.ee/kuritegevusestatistika/korruptsioon.html. 

31   Ministry of Justice, Recorded crimes 2003 – 2018, Tallinn, 2019. 
32   The Prosecutor’s Office budget for 2020 is EUR 15 159 770, which represents an increase of EUR 763 801 
Budget. 

Explanatory 
compared 
https://www.riigikogu.ee/download/52fab2ca-9670-4add-8347-4c880a647a63. 

2019. 

notes 

2020 

State 

33   In 2019, there were 33 persons working in the Bureau. The budget of the CCB in 2019 was EUR 1,156,132. 
See also https://www.politsei.ee/files/Korruptsioon/Trykised/korruptsioonsisu2017engnett.pdf?18996834f6. 
in  ministries,  Korruptsioon.ee,  https://www.korruptsioon.ee/en/anti-

34   Corruption  prevention  contacts 

the 

to 

to 

corruption-activity/corruption-prevention-contacts-ministries. 

35   The  Committee  consists  of  5  members  of  Parliament  and  2  permanent  officials.  The  Committee  monitors 
compliance  with  restrictions  on  the  activities  of  members  of  the  Riigikogu  (Parliament)  and  reviews  their 
assets  declarations,  submits  to  the  Parliament  a  yearly  overview  of  its  activities,  carries  out  parliamentary 
oversight  of  anti-corruption  measures,  including  meetings  with  government  agencies,  law  enforcement 
agencies such as the Internal Security Police, National Criminal Police and the Prosecutor's Office to gather 
information.  The  Special  Committee  has  the  right  to  summon  persons  and  request  information  and 
documents for inspection. It also has the right to make proposals to amend legislation. See further on Anti-
https://www.riigikogu.ee/en/parliament-of-
corruption 
estonia/committees/anti-corruption-select-committee/. 

Select  Committee 

supervision 

activities: 

36   The  committee  consists  of  members  appointed  by  the  political  parties  represented  in  the  Riigikogu  and 
representatives  of  the  Chancellor  of  Justice,  the  Auditor  General  and  the  National  Electoral  Committee. 

6 

 
 
                                                 
There  are  no  comprehensive  whistleblower  protection  rules  in  place.  The  2013 
amendments  to  the  Anti-Corruption  Act  prohibit  officials  from  concealing  corruption,  and 
require Agencies to  protect  the confidentiality of good-faith  whistleblowers. However, they 
only regulate the public, but not the private sector.  

Lobbying is not regulated. There are no legal rules that would set down the framework and 
regulate lobbying. GRECO recommended adopting rules on contacts between lobbyists and 
the  persons  with  top  excutive  functions  (PTEFs),  and  making  such  contacts  public.37  The 
Government is in the process of preparing a draft regulation on lobbying for public officials 
working in the executive branch. 

There  has  been  some  debate  on  the  need  for  managers  of  state-owned  companies  to 
make their economic interest public. As regards the assets declaration, the Anti-Corruption 
Act adopted in 2013 has reinforced the capacity of the Anti-Corruption Select Committee of 
the Parliament.38 Improvements include an extension of the amount of data to be declared and 
of  the  competence  and  the  rights  of  the  Committee.  On  the  basis  of  the  revised  Act,  an 
electronic  register  of  declarations  of  interests  was  established  in  2014.  These  are,  unlike 
economic  interests  of  state-owned  companies,  already  publicly  available  and  therefore  also 
subject  to  public  scrutiny  including  by  the  media.  The  system  for  declaring  assets  and 
interests, effective as from 2014, enables every declaring official to use a pre-filled form and 
to file the declaration electronically. The declaration submitted is accessible to the public for 
three years from the date of submission.39 

Provisions  have  been  introduced  to  regulate  ‘revolving  doors’.  The  Civil  Service  Act 
contains  provisions  according  to  which  an  official  who  is  released  from  office  may  not 
become, within one year from the day of release, a connected person40 with a legal person in 
private law over which the official has exercised direct or constant supervision during the last 
year.  

Members  of  the  Committee  are  independent  and  do  not  represent  the  interests  and  positions  of  the 
organisations that appointed them in their work. 

37   GRECO  Fifth  Evaluation  Round  –  Evaluation  Report,  recommendation  v.:  “that  rules  be  laid  down  to 
govern  (i)  contacts  between  persons  with  top  executive  functions  and  lobbyists/third  parties  that  seek  to 
influence the public decision-making process and (ii) the disclosure of such contacts and the subject-matters 
discussed”. 

38   Anti-corruption Act. https://www.riigiteataja.ee/en/eli/521082014007/consolide. (as of 22.09.2014) 
39   GRECO Fourth Evaluation Round- Compliance Report. 
40   The connected person in this context means legal person in which at least 1/10 of the holding or the right to 
acquire a holding belongs to an official or a person connected to him or her; and legal person in which the 
official or family member is a member of the management or controlling bodies.  

7 

 
 
 
 
                                                                                                                                                        
III.  MEDIA PLURALISM 

In  Estonia,  the  freedom  of  expression  and  the  right  of  access  to  information  find  legal  and 
formal  protection  in  the  Constitution  of  the  Republic  of  Estonia.41  Secondary  legislation 
expressly ensures the right of journalists to protect their sources and fosters media freedom in 
the  radio  and  television  sector.42  The  right  to  information  is  explicitly  recognised  in  the 
Constitution, in the Public Information Act43 and in the Personal Data Protection Act44.45 

A  planned  reform  aims  to  strengthen  the  independence  of  the  media  regulator  -  the 
Consumer  Protection  and  Technical  Regulatory  Authority  (ECPTRA).  ECPTRA  is  a 
governmental  organisation  established  in  2019  by  merging  the  Consumer  Protection  Board 
and the Technical Regulatory Authority. The authority is operating as an administrative part 
of the Ministry of Economic Affairs and Communications. The amendments to transpose the 
revised Audiovisual Media Services Directive (AVMSD)46 aim to modify the tasks, powers, 
and  competences  of  ECPTRA.  As  announced  by  the  Estonian  authorities,  they  will  also 
define the latter’s status as an independent authority in accordance with the requirements on 
independence, enshrined in the AVMSD.47 

The  Estonian  Press  Council  (Pressinõukogu)  is  a  voluntary  self-regulating  body.  It  is 
tasked to handle complaints from the public concerning material in the press, online portals 
with journalistic content and on public service broadcasting stations. The Press Council has 
ten  members,  including  six  from  the  media  sector  and  four  lay  members  from  non-media 
sectors,  in  addition  to  a  rotating  chairman.  The  body  has  been  established  by  the  Estonian 
Newspaper Association.48 

There  are  currently  no  specific  legal  provisions  requiring  the  disclosure  of  ownership 
information.  Nonetheless,  general  information  related  to  entrepreneurship  is  electronically 
available  and  access  to  data  in  the  Business  Register  is  free.49  The  lack  of  information  on 
media ownership has raised some concerns.50 However, the current draft act transposing the 
AVMSD  includes  a  new  provision  regulating  publicly  available  data  on  structure  and 
transparency  of  media  ownership,  based  on  the  relevant  provision  in  the  AVMSD51 
Currently, ultimate ownership of media companies is not available to the public in all cases. 
Due  to  this  fact,  the  Media  Pluralism  Monitor  2020  (MPM  2020)  considered  the  situation 
with regards to transparency of media ownership in Estonia as one presenting medium risk. 
At the same time, the indicator of market plurality represents a high risk, due to the growing 

41   Section 44-46, https://www.riigiteataja.ee/en/eli/521052015001/consolide.  
42   Art. 15 and 13 of the Media Services Act, see: www.riigiteataja.ee/en/eli/506112013019/consolide.  
43   https://www.riigiteataja.ee/en/eli/514112013001/consolide.  
44   Personal 

(Isikuandmete 

Protection 

kaitse 

Data 

Act 

seadus) 

https://www.riigiteataja.ee/en/eli/523012019001/consolide.  

45   In 2020, Estonia ranked 14th in the Reporters Without Borders World Press Freedom Index. 
46   The  draft  law  amending  the  Audiovisual  Media  Services  Directive  (Directive  (EU)  2018/1808  of  the 
European Parliament and of the Council of 14 November 2018 amending Directive 2010/13/EU) has passed 
the interinstitutional consultation and will be submitted to the Government for approval in August. It will be 
discussed in the Parliament in September. 

47   Art. 30 AVMSD.  
48   Estonian  Newspaper  Association  (Eesti  Ajalehtede  Liit)  website  on  the  Press  Council  of  Estonia 

(Pressinõukogu), http://vana.meedialiit.ee/pressinoukogu/index-eng.html. 
49   Business Register is available here: https://www.rik.ee/en/e-business-register.  
50   Information received in the context of the country visit and of the consultation process for the preparation of 

the report 
51   Art. 5 AVMSD. 

8 

 
 
                                                 
horizontal  and  vertical  concentration  of  media  ownership.  This  applies  in  particular  to 
regional  media,  which  have  a  strong  tradition  in  the  country.  A  2018  European  Centre  for 
Press and Media Freedom’s fact-finding mission pointed to media concentration as a matter 
of concern52. As regards local media, the MPM 2020 highlighted medium risk related to the 
political  independence  of  media,  as  a  result  of  the  lack  of  rules  regulating  the  conflict  of 
interests between owners of media and ruling parties and politicians.53  

The right to information is established in the Constitution, and the Public Information 
Act  regulates  the  public’s  right  to  access  information  held  by  public  authorities. 
However,  as  pointed  out  to  the  Commission  by  stakeholders54  and  as  raised  by  the  Media 
Pluralism Monitor, there is a perception that the public administration tends to deny access to 
public information in some cases. 

The framework for the protection of journalists is comprehensive. It rests on the freedom 
of  expression,  which  is  explicitly  recognised  in  the  Estonian  Constitution  and  the  Media 
Services  Act.  The  latter  includes  a  provision  on  the  protection  of  source  of  information. 
Safeguards  for  the  protection  of  journalists  are  also  included  in  the  Code  of  Criminal 
Procedure.55  However,  imprisonment  is  among  the  envisaged  sanctions  for  some  specific 
cases of defamation.56 The analysis of the indicator on journalistic profession, standards and 
protection presents a low risk in the MPM 2020. Nevertheless, recently some concerns have 
been raised over interference in the work of investigative journalists.57 In 2019 and 2020, the 
Council  of  Europe’s  Platform  to  promote  the  protection  of  journalism  and  safety  of 
journalists published no relevant alerts concerning Estonia.58 In 2020, one alert was published 
regarding alleged chilling effects on media freedom; however, the case related instead to the 
application  of  financial  sanctions  issued  at  EU  level,  as  confirmed  by  the  European 
Commission in its opinion of 19 June 2020.59 

52   Joint EFJ-ECPMF Mission to the Baltic countries 2018 https://adobeindd.com/view/publications/c17c50d1-

7733-41c3-b0fd-de8de57e8d9a/alnr/publication-web-resources/pdf/FFM_Baltics_cc.pdf. 
53   These finding were confirmed with information received in the context of the country visit. 
54   Information received in the context of the country visit. 
55   Section 72 of the Code of Criminal Procedure - https://www.riigiteataja.ee/en/eli/530102013093/consolide.  
56   Decriminalisaton  of  Defamation,  https://cmpf.eui.eu/wp-content/uploads/2019/01/decriminalisation-of-

defamation_Infographic.pdf. 
There  are  only  very  specific  instances  of  defamation  of  a  specific  category  of  persons  that  could  result  in 
imprisonment  (persons  enjoying  international  immunity  §  247;  representative  of  state  authority  §  275; 
judge/court § 305 of the Penal Code).  

57   “Reporters  Without  Borders  is  extremely  concerned  for  the  future  of  independent  journalism  in  Estonia, 
where almost all of the investigative reporters and the opinion desk editors have left Postimees, the country’s 
leading daily  newspaper, in the past  few  weeks, saying they no longer  trust its  management”.RSF already 
voiced concern about Linnamäe’s control of Postimees in April 2019, when its journalists said they had been 
under various forms of pressure to cover events linked to his other long list of business interests”, January 
2020, https://rsf.org/en/news/does-crisis-leading-daily-mean-end-investigative-journalism-estonia. 

58   Council of Europe, Platform to promote the protection of journalism and safety of journalists. 
59   Council of Europe, Platform to Promote the Protection of Journalism and Safety of Journalists, Reply by the 
Government  of  Estonia 
the  Russian  State  News  agency  Sputnik. 
On 19 June, the European Commission adopted an opinion on the application of financial sanctions imposed 
by  means  of  Council  Regulation  (EU)  No  269/2014,  according  to  which  Estonia  has  implemented  the 
financial  sanctions  towards  Rossiya  Segodnya  (Sputnik-Estonia)  legitimately.  See  Opinion  on  the 
application  of  financial  sanctions  imposed  by  means  of  Council  Regulation  (EU)  No  269/2014, 
https://ec.europa.eu/info/sites/info/files/200619-opinion-financial-sanctions_en.pdf. 

the  platform  concerning 

to 

9 

 
 
                                                 
IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Estonia  is  a  parliamentary  republic  with  a  single-chamber  Parliament,  where  the  Supreme 
Court’s  Constitutional  Review  Chamber  can  carry  out  ex-post  constitutional  review, 
including, under certain conditions, on the basis of a constitutional complaint. In addition to 
the justice system, the Office of the Chancellor for Justice (ombudsperson) plays a role in the 
system of checks and balances.  Involvement of the public and stakeholders is supported by 
advanced Information and Communication Technology tools. 

A new law-making environment and legislative policy guidelines are being developed to 
further enhance the user-friendliness and inclusiveness for the public and stakeholders. 
Legislative  drafting  is  guided  by  the  Rules  for  Good  Legislative  Practice  and  Legislative 
Drafting.60  The  process  generally  begins  with  the  drafting  of  a  „legislative  intent“,  which 
details the issue that is being addressed, the potential target group, an analysis of the current 
situation  and  policy  options,  as  well  as  the  potential  impact  of  any  possible  action.61 
Ministries are required to identify the stakeholders to be engaged as early as possible, at the 
latest during the stage of drafting a legislative intent or of a proposal to draft a development 
plan.  Stakeholder  consultations  must  be  conducted  in  at  least  two  stages:  when  deciding 
whether to draft legislation (intent) and when legislation has been drafted, before submission 
to Parliament. All draft legislation, legislative intents, proposals to draft a development plan 
or  other  potentially  significant  matters  are  published  in  the  policy  information  system  EIS 
(Eelnõude  infosüsteem)  for  consultation.  Stakeholders  are  also  regularly  engaged  directly 
with requests for input. The Ministry of Justice is working on a project to create a new law-
making environment  that  would be more user-friendly, with  innovative  ways for better and 
more inclusive legislative drafting. Draft 2030 Guidelines for the Development of Legislative 
Policy are being debated in  the Parliament,  with  the objective of renewing the standard for 
good  legislative  policy  and  to  serve  as  a  guide  for  policy-making,  including  with  regard  to 
engagement with stakeholders.  

Constitutional  review  is  carried  out  by  the  Supreme  Court’s  Constitutional  Review 
Chamber.  The  Supreme  Court  is  both  the  highest  third  instance  court  and  the  court  of 
constitutional  review.  The  Constitutional  Review  Chamber  reviews  the  constitutionality  of 
laws and other legislation of general application pursuant to the Constitutional Review Court 
Procedure  Act.62  Various  types  of  constitutional  review  proceedings  can  be  initiated  by  a 
court, the President of the Republic, the Chancellor of Justice, a local government council or 
the  Parliament.  The  President  may  file  a  petition  to  declare  an  Act  that  has  been  adopted 
without any amendments by Parliament on a second hearing, following the President’s initial 
refusal  to  promulgate the said  Act  to  be contrary  to  the Constitution (ex-ante constitutional 
review).  The  Chancellor  of  Justice  (Ombudsperson)  also  plays  a  key  role  in  the  system  of 
constitutional  review  of  laws,  in  particular  with  the  right  to  initiate  ex-post  abstract 
constitutional  review.63  In  line  with  Supreme  Court’s  case  law,  the  Court,  in  certain 
exceptional  situations,  allows  the  applicant  to  submit  individual  complaints  directly  to  the 

60   https://www.riigiteataja.ee/en/eli/508012015003/consolide.  
61   Access  to  all  of  these  documents  is  freely  available  to  the  public  through  the  draft  legislation  and  policy 
information system (Eelnõude infosüsteem or EIS, available at http://eelnoud.valitsus.ee/main#ANx6shIc.  

62   For the full act see https://www.riigiteataja.ee/en/eli/512122019006/consolide. 
63   Art. 6 of the Constitutional Review Court Procedure Act. 

10 

 
 
                                                 
Supreme Court before the exhaustion of the legal remedies before the lower courts, namely in 
situations where there is no effective remedy for protecting applicant’s fundamental rights.64 

Amendments  broadened  the  mandate  of  the  Office  of  the  Chancellor  for  Justice 
(Ombudsperson).  The  Chancellor  is  a  non-accredited  associate  member  of  the  European 
Network  of  National  Human  Rights  Institutions.  In  January  2019,  new  legislation65  on  the 
institution  came  into  force,  which  broadened  its  mandate  to  allow  it  to  act  as  the  national 
human  rights  institution  in  Estonia.  The  Chancellor  of  Justice  has  a  broad  and  strong 
mandate, including acting as the National Preventive Mechanism under the UN Convention 
Against  Torture  and  the  National  Monitoring  Mechanism  under  the  UN  Convention  on  the 
Rights of Persons with Disabilities. It also performs the functions as the Ombudsperson for 
Children.  The  Chancellor  recently  applied  for  accreditation  with  the  Global  Alliance  of 
National Human Rights Institutions and is undergoing the accreditation process. 66

In relation to the COVID-19 pandemic, Estonia declared an emergency situation. On 12 
March  2020,  the  Estonian  government  declared  an  emergency  situation  and  appointed  the 
Prime Minister as the manager of the emergency situation. On 20 March 2020,  it informed 
the  Council  of  Europe  pursuant  to  the  derogation  clause  contained  in  Article  15  of  the 
European Convention on Human Rights (the Convention) that some of the measures adopted 
to protect “public health” may involve a derogation from certain obligations of Estonia under 
the  Convention.  The  legislative  orders  of  the  Prime  Minister  (as  the  manager  of  the 
emergency situation) were open to judicial review before the Administrative Court (but not 
subject to parliamentary nor presidential scrutiny). The  emergency situation was terminated 
on 18 May 2020 (the derogation under Article 15 of the Convention was lifted on the same 
day). 

A  new  Civil  Society  Development  Plan  2021-2030  is  being  developed.  Based  on  the 
Estonian  Civil  Society  Development  Concept,  the  Government  promotes  civil  society 
through  the  Civil  Society  Development  Plan  2015–2020.67  Since  2018,  the  Ministry  of  the 
Interior has been leading the process of drafting a new Civil Society Development Plan 2021-
2030,  in  cooperation  with  and  with  the  active  engagement  of  stakeholders,  including  the 
umbrella  organisations  that  represent  CSOs  in  Estonia.  This  process  has  included  working 
group meetings and stakeholder consultations throughout the different counties of Estonia.68 
The civic space in Estonia is considered to be open.69 

64   Judgment of the Supreme Court en banc, 3-1-3-10-02, 17 March 2003. 
65   See January 2019 amendments to the Chancellor of Justice Act. 
66   The  accreditation  for  A-status  under  the  UN  Paris  Principles  that  was  scheduled  for  March  2020  was 
postponed due to Covid-19 pandemic. See also ENNHRI, The rule of law in the European Union, Reports 
from national human rights institutions, p.73. 

67   https://www.siseministeerium.ee/sites/default/files/elfinder/article_files/estonian_cs_dev_plan_2015-

2020_extract.pdf. 

68   Input from Estonia for the 2020 Rule of Law Report. 
69   See  the  rating  given  by  CIVICUS;  ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed, 

obstructed, repressed and closed.  

11 

 
 
 
 
 
 
                                                 
Annex: List of sources in alphabetical order.* 

* The list of contributions received in the context of the consultation for the 2020 Rule of Law report 
can be found at (COM website). 

Anti-corruption  Select  Committee,  web 

page. 
estonia/committees/anti-corruption-select-committee/.  

https://www.riigikogu.ee/en/parliament-of-

Centre  for  Media  Pluralism  and  Media  Freedom  (2020),  2020  Media  pluralism  monitor. 

https://cmpf.eui.eu/media-pluralism-monitor/mpm-2020.  

Centre of Registers and Information Systems, e-Business Register web page. https://www.rik.ee/en/e-

business-register.  

Centre  of  registers  and  information  systems,  e-File  web  page.  https://www.rik.ee/en/international/e-

file.  

CIVICUS, Monitor tracking civic space: Estonia. https://monitor.civicus.org/country/estonia/. 

Council for Administration of Justice (2020), Recommendations of the Council for Administration of 
situation. 

Courts 
https://www.kohus.ee/sites/www.kohus.ee/files/elfinder/KHN%20recommendations.docx.pdf  

administration  of 

for  organising 

justice  during 

emergency 

the 

Council of Europe, Platform to Promote the Protection of Journalism and Safety of Journalists (2020), 
Reply  by  the  Government  of  Estonia  to  the  platform  concerning  the  Russian  State  News  agency 
Sputnik. https://rm.coe.int/estonia-reply-en-sputnik-24january2020/168099922f  

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists, 

https://www.coe.int/en/web/media-freedom/the-platform  

Council  recommendation  on  the  2020  National  Reform  Programme  of  Estonia  and  delivering  a 
Council  opinion  on  the  2020  Convergence  Programme  of  Estonia  ST  8177/20  -  COM(2020)  506 
final. 

Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the 

protection of persons who report breaches of Union law L 305/17. 

Directive  2010/13/EU  of  the  European  Parliament  and  of  the  Council  of  10  March  2010  on  the 
coordination of certain provisions laid down by law, regulation or administrative action in Member 
States  concerning  the  provision  of  audiovisual  media  services  (Audiovisual  Media  Services 
Directive) L 95/1. 

Directorate-General  for  Communication  (2020),  Flash  Eurobarometer  482:  businesses’  attitudes 

towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. 

Estonian 

Civil 

Society 

Development 

Plan 

2015–2020, 

https://www.siseministeerium.ee/sites/default/files/elfinder/article_files/estonian_cs_dev_plan_201
5-2020_extract.pdf  

Estonian 

Government 

2013-2020. 
https://www.korruptsioon.ee/sites/www.korruptsioon.ee/files/elfinder/dokumendid/korruptsioonivas
tane_strateegia_2013-2020_1.pdf. 

Anti-corruption 

strategy 

(2013), 

for 

Estonian government (2020), Implementation plan of the Anti-corruption strategy for 2013-2020 for 

2017-2020. 
https://www.korruptsioon.ee/sites/www.korruptsioon.ee/files/elfinder/dokumendid/lisa_2_rakendus
plaan_2018-2020.pdf.  

Estonian Government (2020), input for the 2020 Rule of Law Report.  

Estonian Government, Policy information system. http://eelnoud.valitsus.ee/main#ANx6shIc.  

European Commission (2019, 2020), The EU Justice Scoreboard.  

12 

 
 
European Network of National Human Rights Institutions – ENNHRI (2020), The rule of law in the 

European Union: Reports from national human rights institutions. 

GRECO (2013), Fourth Evaluation Round – Evaluation Report on Estonia on corruption prevention in 

respect of members of parliament, judges and prosecutors.  

GRECO (2015), Fourth Evaluation Round – Compliance Report on Estonia on corruption prevention 

in respect of members of parliament, judges and prosecutors.  

GRECO  (2017),  Fourth  Evaluation  Round  –  Second  Compliance  Report  on  Estonia  on  corruption 

prevention in respect of members of parliament, judges and prosecutors.  

GRECO (2018), Fifth Evaluation Round – Evaluation Report on Estonia on preventing corruption and 
promoting integrity in central governments (top executive functions) and law enforcement agencies.  

Ministry 

(2019), 
https://www.kriminaalpoliitika.ee/kuritegevuse-statistika/korruptsioon.html.  

Criminality 

Justice 

of 

in 

Estonia 

– 

2019. 

Ministry 

of 

2003-2018. 
https://www.kriminaalpoliitika.ee/sites/krimipoliitika/files/elfinder/dokumendid/registreeritud_kurit
eod_2003-2018.xlsx.  

Recorded 

(2019), 

Justice 

crimes 

Ministry  of  Justice  (2020),  Estonian  anti-corruption  and  conflicts  of  interests  e-training  –  YouTube 

web page. https://www.youtube.com/playlist?list=PL5JI001vz8bOi09N3PabBK2ogjrf0k03V.  

Reporters without borders (2020), Does crisis at leading daily mean end to investigative journalism in 
https://rsf.org/en/news/does-crisis-leading-daily-mean-end-investigative-journalism-

Estonia? 
estonia.  

Rules 

for 

Good 

Legislative 

Practice 

and 

Legislative 

Drafting. 

https://www.riigiteataja.ee/en/eli/508012015003/consolide.  

Supreme 

Court 

of 

Estonia, 

Judgment 

of 

17  March 

2003, 

3-1-3-10-02. 

https://www.riigikohus.ee/en/constitutional-judgment-3-1-3-10-02  

Virtual country visit to Estonia in the context of the 2020 Rule of Law Report. 

13 

 
 
 
 
Annex II: Country visit to Estonia  

The Commission services held virtual meetings in June and July 2020 with: 

  Consumer Protection and Technical Regulatory Authority 
  Council for the Administration of Courts 
  Estonian Association of Journalists 
  Financial Intelligence Unit  
  Ministry of Justice 
  National Criminal Police  
  Parliamentary Anti-Corruption Select Committee 
  Press Council 
  Prosecutor’s Office 
  Supreme Court 
  Transparency International Estonia  

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International 
  Civil Liberties Union for Europe 
  Civil Society Europe 
  Conference of European Churches  
  EuroCommerce 
  European Center for Not-for-Profit Law  
  European Centre for Press and Media Freedom 
  European Civic Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
ILGA-Europe 
 
International Commission of Jurists 
 
International Federation for Human Rights  
 
International Press Institute  
  Lifelong learning Platform  
  Open Society Justice Initiative/Open Society European Policy Institute 
  Reporters without Borders  
  Transparency International EU  

14