 In October 2015, Siegfried Broß, a former judge of the German Federal Constitutional Court and the Patent Division of the Federal Court of Justice, expressed the opinion that the procedure followed by the President and the Administrative Council did not comply with the rule of law and had been conducted in a manner comparable to criminal proceedings, and that confidentiality requirements had not been adhered to.He furthermore criticized the role of EPO's internal investigation unit.EPO Vice-President Raimund Lutz strongly rejected these criticisms, stating that the disciplinary proceedings against the Board member were conducted by the EPO and the Administrative Council in accordance with the EPC provisions.