How Bertie would have fared in other lands

What happens elsewhere if a minister pockets a cash gift? Irish Times journalists do a quick whip around other capital cities…

What happens elsewhere if a minister pockets a cash gift? Irish Times journalists do a quick whip around other capital cities.

What would happen in other countries if a government minister pocketed £8,000 (€11,800 in today's money) from, he might claim, a group of business people who happened, he might claim, to do a whip-round on a whim?

Leaving aside the standards of probity and ethical behaviour many people will feel a government minister should apply to himself without the necessity of adhering to stated rules, what guidelines existed at the time?

In 1994, when a minister took up office, he or she was given a copy of the so-called Green Book of guidelines about their behaviour. On dos and don'ts about gifts etc, the guidelines say the following:

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Ministers and ministers of state "should not engage in any activities that could reasonably be regarded as interfering or being incompatible with the full and proper discharge of the duties of his office".

Whether Ahern's conduct in Manchester in 1994 was "incompatible" with the "proper discharge" of his duties is a matter of debate, even if he thinks there's no case to answer.

SCANDINAVIA

In Norway, there is little wriggle room. "Once a politician enters government, he or she is forbidden to receive payment for making any speech of any sort," says Öivind Östang, head of information at the Norwegian prime minister's office.

In a quick ring around yesterday, Scandinavian government departments all expressed surprise when confronted with the question about payments to politicians. The situation does not appear to have ever occurred in Finland, Sweden or Norway.

UNITED STATES

Senior office holders in the US federal government are not allowed to receive "any earned income for any outside employment or activity" while in office.

Ethical conduct laws ban all federal employees from receiving payment for a speaking, writing or teaching engagement that "relates to the employee's official duties".

Teaching, speaking or writing is considered related to duties if the subject of the activity "deals in significant part with: (1) Any matter to which the employee presently is assigned or to which the employee had been assigned during the previous one-year period; (2) Any ongoing or announced policy, programme or operation" of the government department concerned.

BRITAIN

The issue of cash gifts is not covered by Britain's ministerial code - because it should not arise, and any minister found in receipt of cash would almost certainly be forced to resign.

It might be considered acceptable in certain circumstances for ministers to accept offers of help from friends. However, they would be required to tell their permanent secretary, and in some instances the approval of the prime minister might be required.

Section 5.24 of the code says: "It is a well established and recognised rule that no minister or public servant should accept gifts, hospitality or services from anyone which would, or might appear to, place him or her under an obligation."

FRANCE

There is no law in France that forbids politicians from receiving gifts. It is fine so long as it is not established that they do a favour in return. However, politicians have been punished at the polls when such information became known.

The two most famous examples are Valéry Giscard d'Estaing who, as finance minister and president, accepted gifts of diamonds from Emperor Bokassa of Central African Republic; and the socialist prime minister Pierre Bérégovoy, who was given an interest-free loan to buy a Paris apartment by a banker close to François Mitterrand. Giscard lost the 1981 presidential election. For Bérégovoy, the revelation contributed to the socialists' election defeat in 1993. He committed suicide shortly after.

GERMANY

German government ministers have very specific guidelines about what gifts and payments they are allowed - and mostly not allowed - to accept. They are banned from accepting any paid position practising a trade or profession parallel to their political one.

Paragraph five of the law governing federal ministers states: "The members and former members of the federal government are obliged to inform about any gifts that they have received in relation to their office. The federal government decides about the use of these gifts."

A government spokesman said: "These regulations are in place and they are adhered to. That's why the rules are there."

JAPAN

Mr Ahern might have been well served had he adopted the Japanese method of dealing with awkwardness over hitherto unknown dig-outs and financial bungs. He could have said the money was "part of a plan to reshape the political landscape" or a "birthday present"; or claimed a faulty memory. All those excuses have worked in Japan, where greasing palms is a fine art.

- Peter Murtagh in Dublin with Colm O'Callaghan in Stockholm, Denis Staunton in Washington, Frank Millar in London, Derek Scally in Berlin, Lara Marlowe in Paris and David McNeill in Tokyo