Indeed, I believe that it would make sense to seek to standardise the criteria for terms of office and their non-renewability across the various independent bodies in Spain. I wish now to focus on another aspect I consider relevant to strengthening the independence of the Banco de España and, in particular, its supervisory function. As I have just stated, the Banco de España has decision-making capacity over the performance of its functions. However, non-monetary policy acts and decisions (such as those concerning the imposition of supervisory sanctions) may, under the Law of Autonomy of the Banco de España,9 be subject to government review via the lodging of an administrative appeal at the Ministry of Economic Affairs and Digital Transformation. This ministry may thus review — and potentially annul —decisions made by the Banco de España.10 To avoid this possible government interference, it should be established that supervisory decisions by the Banco de España bring administrative proceedings to an end or, in other words, that  8  The average term of office of governors of the Eurosystem national central banks is more than ten years, assuming where this is legally possible that they are renewed once.
- Separation of the supervisory function from the monetary policy function: officials shall respect the separation of the ECB’s specific tasks concerning policies relating to prudential supervision from its tasks relating to monetary policy, as well as other tasks. - Public appearances and public statements: officials shall carry out their duties and responsibilities as, and consider themselves in public appearances to be, representatives of a high-level ECB body. - Relations with interest groups: while maintaining the open, transparent and regular dialogue with representative associations and civil society required by the Treaty on European Union, officials shall at all times, and in particular in their interactions with interest groups, observe their independence and professional secrecy obligations, and the basic principles established in the Code of Conduct. - Declaration of Interests: officials shall on an annual basis submit to the Ethics Committee, for assessment and onward submission to the President, a signed Declaration of Interests which shall include information about the member’s previous occupational activity, private activities, official mandates and financial interests, as well as about the gainful occupational activity of their spouse or partner, that may raise conflict of interest concerns. - Conflicts of interest: officials shall avoid any situation which may raise conflict of interest concerns.