Inadequate legislative framework to combat conflicts of interest in donations to the Ministry of National Defence

A Reporters United report highlights the lack of legislative rules to address any conflicts of interest in cases where the same legal entities are both charitable donors and (would-be) suppliers to the Ministry of National Defence in arms and public procurement projects.

On 5 February 2025, a report by journalists Reporters United (1, 2, 3), revealed that the Ministry of National Defence (MoND) does not have rules in place to deal with any incompatibilities and conflicts of interest in cases where the same companies are both charitable donors and (would-be) suppliers of arms and public procurement projects.

According to the publication, during 2024, donations from private individuals, multinationals and businessmen to the Ministry of National Defence soared to €26 million from €322,000 in 2023. However, the issue raised lies in the fact that, according to the Ministry of National Defence itself, the ministry accepts donations from arms companies that simultaneously claim tens of millions of euros in procurement projects, without any rules to combat any potential conflicts of interest.

The report indicates that Lockheed Martin (US interests) and Theon Sensors (Greek interests), donors to the Ministry of National Defence in 2024, held meetings with the same ministry in 2024 and 2025 to present their weapons systems. More specifically, Theon Sensors presented night vision scopes on July 18, 2024, while Lockheed Martin presented a target tracking system for aircraft on January 17, 2025. Lockheed Martin is also the company that will supply Greece with at least 20 F-35s at a cost of billions of euros.

However, the findings show that the Ministry of National Defence has neither published the exact amounts that have been donated, nor rules to combat any conflicts of interest in cases where companies have made donations yet are also (would-be) suppliers for public tenders.

Reporters United reached out to Theon Sensors and Lockheed Martin prior to publication. The former did not respond to the request for comment while the latter referred to strong guidelines and governance policies in place to ensure that all community giving and sponsorship activities comply with strict anti-corruption laws and Lockheed Martin’s Code of Ethics and Business Conduct.

Overall, it should be noted that although Greek legislation provides some limited measures to avoid conflicts of interest and revolving door cases in government and high public office, it does not effectively cover all cases in which such an issue arises.

In particular, provisions on conflicts of interests are provided for in Law No. 4622/2019 (Articles 68-76) (Government Gazette Α’ 133/7.8.2019.) The law provides that for those persons appointed as members of the government and deputy ministers the exercise of any professional or business activity is automatically suspended. At the same time, it provides that members of the Government must obtain for one year after their departure a licence from the Ethics Committee of the National Transparency Authority for any professional activity related to the activity of the body to which they were appointed, where a conflict of interest may arise.

However, the relevant legislative framework is not considered sufficient. Indicatively, we should mention that the report of the Fifth Evaluation Cycle of the Council of Europe’s Group of States against Corruption (GRECO), analysing the above provisions, has made a number of recommendations to the Greek government regarding the rules on conflict of interest, recommending, among other things,that the legal status and obligations of political consultants (associates and special advisers to members of the government) should be clarified and precisely regulated to high standards of integrity, including the relevant ethical rules, conflicts of interest and financial disclosure obligations.

Where is the problem with the rule of law?

Under the rule of law, specific measures should be provided for in law that will effectively combat all cases of conflicts of interest that may arise.

However, as this case shows, Greece has not adopted a legislative framework covering all such cases and, more specifically, addressing any incompatibilities and conflicts of interest in cases where the same legal persons simultaneously hold the positions of charitable donor and commercial supplier to the Ministry of National Defence.

The adoption of such measures is considered important, as the lack of rules to combat conflicts of interest generally makes it easier for private actors to exert non-transparent influence on the exercise of public power, lawmaking and the award of public works.

Corruption Conflict of interests in the public sector & Revolving Doors Reports

Thodoris Chondrogiannos

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Inadequate legislative framework to combat conflicts of interest in donations to the Ministry of National Defence

A Reporters United report highlights the lack of legislative rules to address any conflicts of interest in cases where the same legal entities are both charitable donors and (would-be) suppliers to the Ministry of National Defence in arms and public procurement projects.

1. Via bank transfer (alphabank)

2. Via PAYPAL

3. Via DONORBOX (monthly or annual contribution)