Ref. Ares(2022)451293 - 20/01/2022
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
CLIMATE ACTION
Legal Affairs, Inter-Institutional Relations & Communication
Brussels
Faye Holder
1 Long Ln,
London SE1 4PG,
United Kingdom
Advance copy by email: ask+request-10523-
xxxxxxxx@xxxxxxxx.xxx
Subject:
Your application for access to documents – Ref GestDem No 2022/0420
Dear Ms Holder,
We refer to your e-mail dated 14 January 2022 in which you make a request for access to
documents, registered on 19 January 2022 under the above-mentioned reference number.
You requested access to: “
All documentation, including but not limited to attendance lists,
agendas, background papers, minutes/notes, video recordings and email correspondence about
or summarising the meeting between Mauro Raffaele Petriccione and ExxonMobil Petroleum &
Chemical on 15/04/2021”.
Your application concerns the following documents:
Author
Date
Reference
1
European
2 March 2021
Ares(2022)347001
Commission/ExxonMobile
2
ExxonMobile
2 March 2021
Ares(2022)347001
3
ExxonMobile
2 March 2021
Ares(2022)347001
4
ExxonMobile
2 March 2021
Ares(2022)347001
5
European Commission
20 April 2021
Ares(2021)2641892
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Office: BU24 01/078 - Tel. direct line +32 229-50164
A complete disclosure of the identified documents is prevented by the exception concerning the
protection of privacy and the integrity of the individual outlined in Article 4(1)(b) of Regulation
(EC) No 1049/2001. The documents contain the names/initials and contact information of
Commission staff members not pertaining to the senior management; the names/initials and contact
details of other natural persons; handwritten signatures/abbreviated signatures of natural persons and
other information relating to an identified or identifiable natural persons.
Article 9(1)(b) of the Data Protection Regulation does not allow the transmission of these personal
data, except if you prove that it is necessary to have the data transmitted to you for a specific purpose
in the public interest and where there is no reason to assume that the legitimate interests of the data
subject might be prejudiced. In your request, you do not express any particular interest to have
access to these personal data nor do you put forward any arguments to establish the necessity to have
the data transmitted for a specific purpose in the public interest.
Consequently, I conclude that, pursuant to Article 4(1)(b) of Regulation (EC) No 1049/2001, access
cannot be granted to the personal data contained in the requested documents, as the need to obtain
access thereto for a purpose in the public interest has not been substantiated and there is no reason to
think that the legitimate interests of the individuals concerned would not be prejudiced by disclosure
of the personal data concerned.
As regards documents 2-4, these correspond to biography of individuals. We have considered
whether partial access could be granted to these documents without disclosing information relating
to identified or identifiable natural persons. Unfortunately, partial access cannot be provided as any
partial disclosure to these documents would result in documents which would be meaningless.
Please note that document 5 was drawn up for internal use under the responsibility of the relevant
officials of the Directorate-General for Climate Action. It solely reflects the author's interpretation of
the interventions made and does not set out any official position of the third parties to which the
document refers, which were not consulted on its content. It does not reflect the position of the
Commission and cannot be quoted as such.
In case you would disagree with this position, you are entitled, in accordance with Article 7(2) of
Regulation (EC) No 1049/2001, to submit a confirmatory application requesting the Commission to
review this position.
Such a confirmatory application should be addressed within 15 working days upon receipt of this
letter to the Secretariat-General of the Commission at the following address:
European Commission
Secretariat-General
Unit C.1. ‘Transparency, Document Management and Access to Documents’
BERL 7/076
B-1049 Brussels, or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
Yours sincerely,
(e-signed)
Luca DE CARLI
2
Electronically signed on 20/01/2022 10:42 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482