Antoine Kremer is the Head of European Affairs at ABBL, ALFI and ACA. Here, he talks to us about setting up the joint office for the Luxembourg Bankers’ Association and the Luxembourg investment fund industry, transparency in the sector and what he hopes to see in the future.
For those that aren’t familiar with your career, can you share a bit about your background and experience in EU institutions and Public Affairs?
I think that might be most of you readers! I have a master’s in European Legal Affairs. I started with an internship at the European Commission, and later worked for MEP Astrid Lulling for four years (a quite colourful lady, she deserves her own interview!).
About 20 years ago, when I started my time at the Parliament, things looked very different. There were only a few pieces of legislation for Financial Services, like a banking directive and an investment services directive. Now, there are over 60 directives and regulations. Back then, co-decision was just starting, and very few people were involved in financial services interest representation. I would sometimes have exchanges with interest representatives in my day-to-day work, and this piqued my interest, making me contemplate a potential shift in my career.
Despite this inclination, I didn’t immediately transition to interest representation. I took an opportunity to work at the Permanent Representation of Luxembourg to the EU. That was very complementary to my previous job. It let me see things from the Council and Member States’ side.
As my time at the Permanent Representation was ending, the banking and investment funds associations wanted to set up their office in Brussels. Everything fell into place, and I went back to my plan of doing interest representation. I created a joint office for the Luxembourg Bankers’ Association and the Luxembourg investment fund industry.
Did you set it up all by yourself?
It wasn’t too hard to handle on my own – I was the only one! Eventually, the office expanded from just me to two people, then three and it kept growing. Later, the Luxembourg Insurance Association joined us, making it a group of four!
Do you see any striking differences between public and private?
I’ve found that in the private sector there is a greater scope for creativity and more freedom for development compared to my previous experience in the public sector. However, I attribute this difference to the nature of the work and the specific context. I’m effectively drawing this comparison from the perspective of managing a small office in Brussels with headquarters in Luxembourg, as opposed to being a part of a larger institutional machinery.
Being in the financial services industry, I imagine you deal with topics that most of us know very little about on a daily basis. What is your view on communicating complex policy issues to the broader public?
I’ve got some good news – not everything in financial services is complex and technical! Many aspects involve everyday experiences like having a bank account, making payments, or using your phone for transactions. These are quite straightforward to explain and relatable to people. On the other end of the spectrum, certain topics, like capital requirements or aspects of supervision, can be technical and complex. Between these extremes, there’s a wide middle ground.
To make complex information more understandable, I follow a few tricks. Firstly, I try to swap nouns for verbs. Verbs help people visualise actions, keeping their attention high. Steering clear of strings of names and adjectives is crucial to avoid losing people immediately.
Additionally, I use relatable examples that most people have experienced or can easily imagine. Creating a story around these examples helps to clarify concepts. When presenting numbers or abstract ideas, I prepare e.g. two figures and sketches in advance. Comparing the situation in scenario A with scenario B makes the point clear in seconds.
In situations where I need to explain a process or evolution, it can be helpful to grab a pen and paper and start drawing! This is a fun and hands-on approach which helps convey a building-up process, or show an evolution effectively.
You dealt with the topic of transparency from different angles, having worked both in the public and the private sector. In your view, what challenges does the Brussels advocacy bubble face in maintaining transparency?
I view transparency as a fundamental pillar of Western societies and our democracies. In our line of work, it serves as a safeguard preventing the less powerful from being exploited by the more powerful. As interest representatives, transparency is not just a choice but a duty. It entails informing the public about what we do, the individuals we engage with, our advocacy efforts, who we are, who is the association we represent, and why the issues we advocate for matter to us.
Transparency is really the foundation of any professional relationship. If one is perceived as shady or dishonest, the opportunity for further dialogue will be lost. Between humans, as in my profession, broken trust can damage the relationship forever. Therefore, in the field of interest representation, upholding transparency, honesty, and delivering quality advice is not only a professional obligation but a necessity. Failing to do so jeopardises our credibility and the success of our advocacy efforts.
The EU Transparency Register is a central tool for tracking lobbying activities. Do you think this tool is useful, and what improvements, if any, would you suggest?
I find the Transparency Register to be a crucial tool. Essentially, it is a website where every interest representative follows a code of ethics. Anyone working within the EU seeking access to the European Parliament or the Commission is required to register. Organisations must disclose various details, such as the person responsible for public affairs, the financial resources allocated to advocacy, the number of individuals engaged in advocacy, the full-time equivalent (which is different from headcount), and the issues they’ve focused on for interest representation in the past year.
This register was introduced in the summer of 2008. I distinctly remember our initial response: ‘We need to be a part of this!‘ It was clear that such a tool would promote quality dialogue and openness. We registered a few weeks after its launch, we were among the first organisations to do so, and we have never regretted it. I still have the confirmation email we received dated 5 August 2008. However, it did take some time for everyone to get on board, as some were initially more hesitant.
Where did the hesitation come from?
The hesitancy stemmed from the fact that the register was new, and the preparation work admittedly a bit cumbersome. It requires annual updates, adding to the administrative workload. Nobody loves more admin, but it is something that needs to be done.
As momentum gathered, the focus shifted to ensuring a shared understanding of transparency requirements, particularly concerning expenses. Defining what should be declared posed a challenge initially, with some organisations giving a number which sounded more or less accurate, and others that were inflating figures.
I remember when a financial newspaper hailed my organisation as one of the most financially resourceful lobby in Europe. We were perplexed, until realising that our honesty in declaring expenses set us apart from counterparts who were less diligent.
Thankfully, the Commission later provided guidelines on expense declarations – a move I appreciated despite the added workload. I had to inquire with my colleagues in Luxembourg about the amount of time they dedicated to advocacy. Initially, their response was, ‘Isn’t that your responsibility?’ I had to clarify that their involvement, contributing to position papers, meeting colleagues, and understanding our advocated positions, was an essential part of advocacy. We joked that, theoretically, even the paper used to print a document at home should be counted in the expenses! But I understand the reasoning and consider it fair enough.
Are there any further improvements you would like to see?
Regarding improvements, I believe the Transparency Register is asking the right questions. The ongoing discussion revolves more around whether additional entities should be covered by the register. After the Qatar-gate incident, some problematic aspects of third states’ involvement in the lobbying process became apparent to the broader public, shedding light on crucial issues.
I think that overall, the institutions have done a lot of work to foster transparency, for example with the European Commission and the Parliament having clear requirements on the publicity of the meetings of their staff with associations or companies.
As a potential further step, making the meeting requests that Members of the European Parliament (MEPs) have declined available to the public could be interesting. This additional information wouldn’t substantially increase administrative pressure but would enhance transparency. It would signal whether an MEP has chosen to dedicate time to a particular issue or not and in how far the MEP has chosen to consult a broad variety of impacted actors or not.
However, my concern is that if the administrative burden of transparency becomes too heavy, decision-makers might be disincentivised from engaging in dialogue with smaller actors, like us. The perceived administrative cost could outweigh the benefits in their eyes. Fortunately, this hasn’t materialised thus far, and I believe we are currently striking the right balance.
Looking ahead, what is the red thread that you see in the future of lobbying in the EU?
No surprises here, I think transparency will be a key theme for the future!
Additionally, I anticipate that Artificial Intelligence (AI) will play an increasingly significant role in Public Affairs. For example, I see how an artificial intelligence can be better than us in thinking outside of the box. This means an AI can be more effective at certain exercises, for example stakeholder mapping, which require creative thinking.
However, this transformation won’t happen overnight. We’re already experimenting with AI in various forms, such as drafting emails. Currently, it takes more time to explain to ChatGPT what I want to write than writing the email myself. Nevertheless, practical applications will undoubtedly emerge.
In tandem with this, another key trend is people. At its core, Public Affairs is a people-centric business. Lawmakers, contacts, and human dialogue will never be replaced by artificial intelligence. Public Affairs and interest representation will always remain a people-to-people business. As long as we continue to live in democracies (which I hope is a while), preserving the human dimension of our work is crucial. Despite the rise of AI, people are not going out of fashion!
Looking at the bigger picture, what do you hope to see in 2024?
If you allow me to shift away from my sector and from advocacy – as we continue to face climate change, I think a key theme for this year will be how we will manage the transition to a more sustainable society.
At the moment, there appears to be a lull in the fight against climate change, particularly evident in recent developments within the European Commission this week and the shift in short term priorities. The key question is how much ambition the Commission is willing to put into this fight – and personally, I would welcome a bit more ambition.
Even if public authorities and legislators do not intensify their efforts, I believe that the industry is gearing up for change. Private actors, operating with a long-term vision, are aiming for structural changes and investments need time to bear fruits. While the shift may have been somewhat gradual, there is a growing understanding of the urgency for change for the medium to long term.
What the industry needs to make the extra step is legal certainty, and (ideally) incentives from public authorities and legislators. However, even in the absence of the latter, the urge for structural changes is so compelling that the transition will occur, irrespective of the choices the EU makes or doesn’t make. The critical question is whether the progress will be swift enough.
The second consideration revolves around whether we will have fair EU elections. My mind goes to recent episodes of thirds states, or non-state actors manipulating public opinion through fake news. AI facilitates the production of deceptive images or videos, allowing the spread of misinformation in insidious ways. This poses a tangible risk of election manipulation, which deeply concerns me. We seem to have been caught off guard by this AI wave just before this mega-election year, with 64 countries plus the EU heading to the polls. The final consideration for 2024 is on the future of the internal market in the EU. Feedback from various actors in this realm indicates that the internal market is not working properly. The European Council and the Commission recognised this dysfunctionality and commissioned with former Italian Prime Minister Enrico Letta the Report on the Future of the Single Market, which is a positive acknowledgment of the problem. My hope now is for the Commission to take decisive measures to ensure the internal market works properly, and holding member states accountable for any barriers they erect. In the financial services sector, we have seen numerous instances of ‘hidden protectionism’, where access to a State’s internal market becomes so challenging that actors are discouraged from participating. For countries like mine, heavily reliant on the internal market, difficulties in selling to certain member states are a concern that the European Union must address.
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