3 whistleblowers meeting with OLAF on 10 September 2014 - adoptionlobby
Arun Dohle made this access to documents request to European Anti-Fraud Office
Dear European Anti-Fraud Office,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting documents which contain the following information:
All emails and other data related to the meeting of 2 EU officials and the Director of Against Child Trafficking with OLAF on 10 September 2014.
The mail was organised at the request of OLAF - see below email.
Considering its whistleblowing character, we request transparency in the public interest.
8 September 2014
Thank you Mrs Post.
Given the sensitivity of this information, may I suggest that we meet in OLAF premises at your earliest convenience, perhaps over a lunchtime break (not to raise suspicions if you would have to leave your office)?
I am Dutch speaking, so that would facilitate the conversation.
Do not hesitate to give me a call to fix a date and time (unless you prefer of course to stay outside the current evaluation of the information provided by Mr Dohle).
Thank you and kind regards,
From: Roelie Post [mailto:[email address]]
Sent: Monday, September 08, 2014 3:33 PM
To: (OLAF)
Subject: Fwd: FW: Your correspondance with Mr xxx of 02.09.2014 -- OF/2014/1007/01"
Thank you,
Against Child Trafficking (ACT)
Keizersgracht 482
1017EG Amsterdam
Dear Mr Dohle,
Thank you for your e-mail of 17 February 2025. We hereby acknowledge receipt of your application for access to documents.
In accordance with Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, your application will be handled within 15 working days after registration.
The time limit will expire on 10 March 2025. In case this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on http://ec.europa.eu/anti_fraud/about-us/...
Dear Mr Dohle,
We refer to your request for access to documents made on 17 February 2025, which is currently being handled.
We write to inform you that unfortunately we will not be in a position to complete the handling of your application within the time limit of 15 working days. An extended time limit is needed due to the need to consult other services.
Therefore, we need to extend the time limit with 15 working days in accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding public access to documents.
The new time limit will expire on 31 March 2025.
Thank you for your understanding.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on http://ec.europa.eu/anti_fraud/about-us/...
Dear [email address],
Thank you for informing us that more time is needed.
Could you, in conformity with the rules on Good Administrative Practices, inform us which Services you are consulting?
Yours sincerely,
Against Child Trafficking
Dear Mr Dohle,
Please find attached the reply to your request for access to documents of
17 February 2025. In reply to your question, Unit D.2. needed to consult
the service which was in charge of the case file.
Thank you for acknowledging receipt of this email.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[1][OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[2]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[3]http://ec.europa.eu/anti_fraud/about-us/...
Reference: OLAF.D.2(2025)9632, dated 31 March 2025
PLease forward this confirmatory appeal to the Director-General of OLAF.
Dear Mr. Itälä,
I am writing to submit a confirmatory application under Article 7(2) of Regulation (EC) No 1049/2001, requesting that OLAF reconsider its decision of 31 March 2025 to refuse access to documents requested in my application dated 17 February 2025. The request sought “all emails and other data related to the meeting of 2 EU officials and the Director of Against Child Trafficking with OLAF on 10 September 2014” (Case No: OF/2014/1007). While I acknowledge OLAF’s duty to protect its investigative processes, I contend that there exists an overriding public interest in disclosure that outweighs the cited exceptions under Article 4(2), third indent of the Regulation. This interest is rooted in the whistleblower case of Roelie Post, with significant implications for Arun Dohle and Katja de Sadeleer, as outlined below.
Overriding Public Interest in Disclosure
The documents pertain to a meeting involving the European Anti-Fraud Office and representatives of Against Child Trafficking (ACT), an organization co-founded by Roelie Post and Arun Dohle at the instigation of former Secretary-General Catherine Day. Ms. Post, a former European Commission official, has been widely recognized as a whistleblower who exposed systemic irregularities during her tenure as Task Manager for the Romanian Children Dossier, particularly concerning the European Commission’s role in the reform of child protection in Romania. Her work uncovered links between these reforms and broader child welfare issues, a matter of profound public concern across the EU. Mr. Dohle, her colleague at ACT, has continued this advocacy, amplifying the case’s visibility. Additionally, Katja de Sadeleer, identified in prior contexts as a supportive colleague within the Commission, witnessed the institutional pressures faced by Ms. Post, further underscoring the case’s relevance to EU accountability.
The refusal to disclose these documents perpetuates opacity around a case that exemplifies the challenges faced by whistleblowers within EU institutions. This is not merely a private matter but a public issue with far-reaching implications:
Protection of Whistleblowers: Ms. Post’s experience—facing threats, isolation, and eventual removal from her role and office—highlights the need for transparency to assess whether EU institutions adequately safeguard those who report wrongdoing. The 2014 meeting with OLAF may shed light on how her allegations were handled, offering lessons for implementing the INTERNAL RULES IMPLEMENTING
ARTICLE 22c OF THE STAFF REGULATION.
Institutional Accountability: The involvement of Mr. Dohle and Ms. de Sadeleer situates this case within a broader narrative of institutional resistance to whistleblowing. Transparency is essential to evaluate whether OLAF’s actions aligned with its mandate to protect the EU’s financial interests, which include ensuring the integrity of reforms like those in Romania’s child protection system.
Rebuttal to OLAF’s Arguments
OLAF’s response relies on a general presumption of non-disclosure for selection-stage documents, citing risks to cooperation, investigative integrity, trust with partners, and individual safety. However:
Time Factor: The meeting occurred over a decade ago (10 September 2014), and the case (OF/2014/1007) was closed at the selection stage. The risks cited—e.g., deterring whistleblowers or exposing methods—are diminished by the passage of time and the case’s closure.
Specificity of Public Interest: Unlike a generic request, this case involves named individuals (Post, Dohle, and indirectly de Sadeleer) whose experiences have fueled public and parliamentary scrutiny (e.g., the Omtzigt Resolution, 2019). This specificity overrides the broad presumption applied.
Balancing Interests: The public interest in protecting whistleblowers and understanding the European Commission’s role in the reform of child protection in Romania outweighs hypothetical risks to OLAF’s processes, especially given the EU’s stated priority of transparency and accountability.
Request for Reconsideration
I urge OLAF to:
Reassess the applicability of the Article 4(2) exception in light of the overriding public interest articulated above.
Consider partial disclosure under Article 4(6), redacting only information that genuinely threatens ongoing processes, if any remain relevant after a decade.
Provide a detailed justification if full or partial access is again denied, addressing the specific public interest arguments raised herein.
The case of Roelie Post, intertwined with Arun Dohle’s advocacy and Katja de Sadeleer’s support, transcends a single meeting—it is a litmus test for the EU’s commitment to its values. I trust OLAF will recognize the special public interest at stake and grant access to the requested documents.
Yours sincerely,
Against Child Trafficking
Dear Mr Dohle,
Thank you for your e-mail of 4 April 2025. We hereby acknowledge receipt of your application for access to documents.
In accordance with Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, your application will be handled within 15 working days after registration.
The time limit will expire on 30 April. In case this time limit needs to be extended, you will be informed in due course.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on http://ec.europa.eu/anti_fraud/about-us/...
Dear [email address],
This is a confirmatory appeal.
PLease forward it to the Director General of OLAF
Yours sincerely,
Against Child Trafficking
Dear Mr Dohle,
We refer to your confirmatory request for access to documents made on 4
April 2025, which is currently being handled.
We write to inform you that unfortunately we will not be in a position to
complete the handling of your application within the time limit of 15
working days. An extended time limit is needed due to the need to consult
other services, in line with the Article 16 of the Detailed Rules for the
Application of Regulation (EC) No 1049/2001, annexed to the Commission’s
Decision (EU) 2024/3080 of 4 December 2024 establishing the Rules of
Procedure of the Commission.
Therefore, we need to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents.
The new time limit will expire on 23 May 2025.
Thank you for your understanding.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[1][OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[2]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[3]http://ec.europa.eu/anti_fraud/about-us/...
Dear Mr Dohle,
We would like to inform you that we may require a little more time than
originally anticipated to finalise our reply. Please rest assured that we
are actively working on your request and will do our utmost to minimise
any delay. We appreciate your patience and understanding.
Kind regards,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[1][OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[2]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[3]http://ec.europa.eu/anti_fraud/about-us/...
_____________________________________________
From: OLAF FM D2
Sent: Tuesday, April 29, 2025 1:09 PM
To: Arun Dohle <[FOI #15572 email]>
Subject: RE: Internal review of access to documents request - 3
whistleblowers meeting with OLAF on 10 September 2014 - adoptionlobby
Dear Mr Dohle,
We refer to your confirmatory request for access to documents made on 4
April 2025, which is currently being handled.
We write to inform you that unfortunately we will not be in a position to
complete the handling of your application within the time limit of 15
working days. An extended time limit is needed due to the need to consult
other services, in line with the Article 16 of the Detailed Rules for the
Application of Regulation (EC) No 1049/2001, annexed to the Commission’s
Decision (EU) 2024/3080 of 4 December 2024 establishing the Rules of
Procedure of the Commission.
Therefore, we need to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents.
The new time limit will expire on 23 May 2025.
Thank you for your understanding.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[4][OLAF request email]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[5]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[6]http://ec.europa.eu/anti_fraud/about-us/...
Dear Mr Dohle,
Please find attached the response to your confirmatory request for access
to documents, addressed to OLAF on 4 April 2025.
We apologise for the delay in this response and kindly ask you to
acknowledge receipt of this email.
Kind regards,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
[1]OLAFEN-low-resolution2
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[2][Emailadresse]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[3]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[4]http://ec.europa.eu/anti_fraud/about-us/...
_____________________________________________
From: OLAF FM D2
Sent: Thursday, May 22, 2025 6:27 PM
To: 'Arun Dohle' <[FOI #15572 email]>
Subject: RE: Internal review of access to documents request - 3
whistleblowers meeting with OLAF on 10 September 2014 - adoptionlobby
Dear Mr Dohle,
We would like to inform you that we may require a little more time than
originally anticipated to finalise our reply. Please rest assured that we
are actively working on your request and will do our utmost to minimise
any delay. We appreciate your patience and understanding.
Kind regards,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
<< OLE Object: Picture (Device Independent Bitmap) >>
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[5][Emailadresse]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[6]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[7]http://ec.europa.eu/anti_fraud/about-us/...
_____________________________________________
From: OLAF FM D2
Sent: Tuesday, April 29, 2025 1:09 PM
To: Arun Dohle <[FOI #15572 email]>
Subject: RE: Internal review of access to documents request - 3
whistleblowers meeting with OLAF on 10 September 2014 - adoptionlobby
Dear Mr Dohle,
We refer to your confirmatory request for access to documents made on 4
April 2025, which is currently being handled.
We write to inform you that unfortunately we will not be in a position to
complete the handling of your application within the time limit of 15
working days. An extended time limit is needed due to the need to consult
other services, in line with the Article 16 of the Detailed Rules for the
Application of Regulation (EC) No 1049/2001, annexed to the Commission’s
Decision (EU) 2024/3080 of 4 December 2024 establishing the Rules of
Procedure of the Commission.
Therefore, we need to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents.
The new time limit will expire on 23 May 2025.
Thank you for your understanding.
Yours sincerely,
EUROPEAN COMMISSION
EUROPEAN ANTI-FRAUD OFFICE (OLAF)
<< OLE Object: Picture (Device Independent Bitmap) >>
Directorate D – Legal, Resources and Partnerships
Unit D.2 – Legal Advice
[8][Emailadresse]
Rue Joseph II, 30 • B-1000 Brussels (Belgium)
[9]http://ec.europa.eu/anti_fraud
Our policy regarding personal data protection can be viewed on
[10]http://ec.europa.eu/anti_fraud/about-us/...
Arun Dohle left an annotation ()
10 March 2025