Dear Secretariat General of the European Commission,

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:

The note of 28 May 2013 signed by Stefano Sannino, copied to Secretary-General Catherine Day and Head of Cabinet Simon Mordue about a potential conflict of interest in the ESF SERA Romania contract.

As well as related correspondance to this issue.

Including ARES registration and distribution sheets (pdf)

Yours faithfully,

Arun Dohle
Against Child Trafficking
c/o Easy Start Office
Kraijenhoffstraat 137A
1018 RG Amsterdam
Netherlands

Subject: Clarification for Access to Documents Request - EASE 2025/6468

Dear ENEST ACCDOC Team,

Thank you for your message of January 29, 2026, regarding my request for access to documents registered under case number EASE 2025/6468.

To clarify the element "As well as related correspondence to this issue," I am referring to any emails, memos, notes, or other internal communications directly linked to the note of May 28, 2013 (signed by Stefano Sannino and copied to Catherine Day and Simon Mordue) concerning the potential conflict of interest in the ESF contract with SERA Foundation Romania.

This includes:

- Correspondence exchanged between the signatories (Stefano Sannino, Catherine Day, Simon Mordue) or involving relevant Commission services (e.g., DG Employment, Social Affairs and Inclusion, or the Secretariat-General) during the period from January 1, 2013, to December 31, 2013.

- Any follow-up discussions, assessments, or decisions related to the identified conflict of interest.

- ARES registration and distribution sheets (in PDF format) for the aforementioned note and any directly related documents.

This clarification is intended to narrow the scope to documents specifically tied to the 2013 note and the ESF SERA Romania contract issue, in the interest of transparency regarding EU funding management.

I look forward to your response within the prescribed time limits once this clarification is received.

Yours faithfully,

Arun Dohle
Against Child Trafficking
c/o Easy Start Office
Kraijenhoffstraat 137A
1018 RG Amsterdam
Netherlands

Dear Secretariat General of the European Commission,

Please confirm receipt and time limit of 23 February 2026.

Yours faithfully,

Arun Dohle

Dear [email address],

EASE 2025/6468

Yours sincerely,

Arun Dohle

Dear Secretariat General of the European Commission,

Please pass this on to the person who reviews confirmatory applications.

I am filing the following confirmatory application with regards to my access to documents request 'Note signed by Stefano Sannino aboutof ESF Funding SERA Foundation Romania'.

Confirmatory Application for Access to Documents under Regulation (EC) No 1049/2001 – Case 2025/6468

I am writing to submit a confirmatory application pursuant to Article 7(2) of Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents.

On 5 December 2025, I submitted an initial application for access to the following documents:

- The note dated 28 May 2013 signed by Stefano Sannino, copied to Secretary-General Catherine Day and Head of Cabinet Simon Mordue, concerning a potential conflict of interest in the ESF contract with SERA Foundation Romania, including the ARES registration and distribution sheets in PDF format.

- Related correspondence on this issue from 1 January 2013 to 31 December 2013, involving the signatories or relevant Commission services, such as DG Employment, Social Affairs and Inclusion.

My application was registered on 8 December 2025 under reference number 2025/6468 (EASE 2025/6468). The initial deadline for response was 8 January 2026, which was extended to 29 January 2026 due to consultations with other services. Following a request for clarification on 29 January 2026, I provided the necessary details on 2 February 2026, leading to a new deadline of 23 February 2026.

Despite follow-ups, including on 12 February 2026, no substantive reply has been received as of 7 March 2026. Under Article 7(4) of the Regulation, the failure to respond within the prescribed time limits is considered a negative reply, entitling me to make this confirmatory application.

I respectfully request that you reassess my application and grant full access to the requested documents without further delay. Should any exceptions under Article 4 of the Regulation be invoked (e.g., protection of privacy, commercial interests, or international relations), I urge you to apply them narrowly and consider the overriding public interest in disclosure.

This request pertains to a matter of profound public concern: allegations of conflict of interest in the allocation of European Social Fund (ESF) resources to SERA Foundation Romania. SERA, founded by François Polge de Combret—a prominent banker with ties to European political and noble elites—has been implicated in controversial practices surrounding child welfare and international adoptions in Romania. These activities echo broader patterns of elite corruption, akin to the Jeffrey Epstein scandal, where networks of influential politicians, aristocrats, and financiers exploit vulnerable populations under the guise of philanthropy.

De Combret's involvement with SERA exemplifies a mafia-like structure, intertwining nobility, politicians, and opaque funding mechanisms. The 2013 note by Stefano Sannino—now under scrutiny in a European Public Prosecutor's Office (EPPO) fraud probe —highlights potential improprieties in EU funding distribution. Disclosure is essential to expose any systemic corruption, ensure accountability, and prevent the misuse of public funds in schemes that may facilitate child exploitation or trafficking, reminiscent of Epstein's elite networks.

The public interest in transparency far outweighs any potential harm from disclosure, especially given the EU's commitment to combating corruption and protecting children's rights. Partial access or redactions should only be applied if strictly necessary, with detailed justifications provided.

I expect a response within 15 working days, as per Article 8(1) of the Regulation. Should access be denied in whole or in part, I reserve the right to pursue further remedies, including proceedings before the European Ombudsman or the Court of Justice of the European Union.

Thank you for your attention to this urgent matter.Yours sincerely,

A full history of my request and all correspondence is available on the Internet at this address: https://www.asktheeu.org/request/note_si...

Yours sincerely,

Arun Dohle
Against Child Trafficking

Dear Secretariat General of the European Commission,

Dear Mrs Rapp,

We refer to the above-referenced request for access to documents, initially submitted on 5 December 2025 and registered under EASE 2025/6468, concerning: the note dated 28 May 2013 signed by Mr Stefano Sannino (then Director-General of DG Employment, Social Affairs and Inclusion), copied to Secretary-General Catherine Day and Head of Cabinet Simon Mordue, regarding a potential conflict of interest in the ESF contract with the SERA Foundation Romania; and the ARES registration and distribution/circulation sheets (in PDF format) for the said note, as well as all related internal correspondence (emails, memos, notes or other documents) exchanged between 1 January 2013 and 31 December 2013 involving the signatories or relevant Commission services (including DG Employment, Social Affairs and Inclusion and the Secretariat-General) on the identified conflict of interest and any follow-up action.

We also refer to our confirmatory application submitted on 7 March 2026 pursuant to Article 7(2) of Regulation (EC) No 1049/2001, which was necessitated by the Commission’s failure to provide a substantive reply within the time limits prescribed by Article 7(1) and (3) (as extended). That confirmatory application was duly acknowledged by the Commission on 8 March 2026.

On 30 March 2026 – the very day on which the time limit for a reply to our confirmatory application expired – we received a communication from the ENEST ACCDOC team enclosing a document entitled “2025 6468 closing letter.pdf” together with what purports to be an initial reply offering partial access to two redacted documents.

For the avoidance of any doubt, the reply of 30 March 2026 from DG EST/ENEST ACCDOC cannot be regarded as a first-instance reply within the meaning of Article 7(1) of Regulation (EC) No 1049/2001. A confirmatory application had already been lodged on 7 March 2026 precisely because the Commission had remained silent beyond all statutory deadlines. The Commission is therefore not entitled to re-open the first-instance procedure at this stage or to treat the 30 March 2026 communication as an initial reply.

Without prejudice to the above procedural objection, we hereby express our formal dissatisfaction with the substance of the 30 March 2026 reply and submit the present confirmatory application under Article 7(2) of Regulation (EC) No 1049/2001.

The reply is manifestly incomplete and inadequate for the following reasons:

Absence of any internal communications

No emails, memos, notes or other internal documents have been disclosed, despite our explicit clarification of 2 February 2026 and the confirmatory application of 7 March 2026. In the context of a note signed at Director-General level, copied to the Secretary-General and a Head of Cabinet, and concerning a potential conflict of interest involving EU funds, it is not credible that no related internal correspondence whatsoever was exchanged within the Commission services during the relevant twelve-month period. The Commission is therefore invited to conduct a fresh, diligent search and to explain, with concrete evidence, why such documents are asserted not to exist.

Complete absence of ARES registration and distribution/circulation sheets

The ARES registration sheets and the distribution/circulation sheets (in PDF format) for the requested 28 May 2013 note – and for any related documents – were expressly requested in the original application, in the clarification of 2 February 2026, and again in the confirmatory application of 7 March 2026. These sheets have not been provided at all. Their disclosure forms an integral and indispensable part of the request and cannot be omitted.

We therefore request the Secretariat-General to review the position adopted in the 30 March 2026 reply and to grant full access to all the documents identified in the original request, the clarification, and the confirmatory application of 7 March 2026, including the complete ARES registration and circulation sheets in PDF format. Should the Commission intend to rely on any exception under Article 4 of Regulation (EC) No 1049/2001, it must provide a detailed, individualised justification for each document or part thereof.

We further recall the overriding public interest in transparency regarding the use of European Social Fund resources and any potential conflict of interest that may have affected the proper management of EU funds, particularly in a context involving the so-called Romanian Children File .

We kindly request an acknowledgement of receipt of this confirmatory application and a substantive reply within the 15 working-day time limit prescribed by Article 8(1) of Regulation (EC) No 1049/2001.

Yours sincerely,

Arun Dohle
Against Child Trafficking