mpartial ity and independence, objectivity, legitimate expectations(legal certainty)and consistency, fairness, courtesy, reply to letters in the language of the citizen to the competent service of the Institution the right to be heard and to make statements, er acknowledgment of receipt and indication of the competent official, the obligation to trans reasonable time-limit for taking decisions, the duty to state the grounds of decisions, indication of possibilities of appeal, notification of the decision, data protection, keeping of adequ ds and public access to information, to do ents and to the code 22 Th assumption here is that most of the member states already have these principles at the national level. Nevertheless, standards, especially those related to transparency issues, should e raised and discretionary powers should be more effectively controlled Institutions of public law in the EU change under European and national political pressures Elsewhere, the change comes under national and international political pressures alongside general reasons for change, such as efficiency, chance, prestige and affiliation to certain models for political or economic reasons. The convergence that is seen in both constit utional and administrative law reflects elements of both transposition and cross-fertilisation. In dministrative law, most changes regard content rather than structure, and in constitutional law they regard both structure and content Change is apparent in procedural matters as well development is to be seen in the area of values. however 2, med that the clearest common There are common influences in this area also. It can be clair The history of law is largely the history of legal transpositions, often from a number of sources, thus law is a constructive synthesis. Though divergence is fruitful and the differences between the similars are especially interesting, there is a move towards a bridging,, a harmony. This is seen in public law mostly in stud ies of globalisation, regulation, agencies, rule-making and transparency Public law in Europe today is a mixed system', civilian in origin, enriched by common law principles and innovations, and with true cross-fertilisation taking place. As noted above, in the UK this has led, apart from individual principles entering UK law, to the expansion of dicial review and to the changing role of the courts. among the common law innovations leading to a market-driven c governance which has influenced both German and EC laws, one could mention corpor convergence, andthe law of professional privilege andthe right to be heard, both exported to the eCJ. again under British influence, the continental emphasis on the privileges of the administration undertaking public services is moving towards stressing individual rights, and yet the protection of the individual under a human rights framework in the UK springs from a continental understand ing In the UK, the Human Rights Act 1998, democracy, majority rule and the notion of limited government are now fund amental areas of study, a study undoubtedly influenced by continental thinking, as is the principle of proportionality'to be predominantly employed in the area of human rights Most important cross-fertilisations and transpositions take place at the level of basic ideas This does not in itself create mixed legal systems, but an area of law could become a mixed system in this way See 'Code of Good Adm inistrative Behaviour(01/1/98/0V) handout by j Soderman, the European Ombudsman 23See Bell, op cit, supra n 12,166impartiality and independence, objectivity, legitimate expectations (legal certainty) and consistency, fairness, courtesy, reply to letters in the language of the citizen, acknowledgment of receipt and indication of the competent official, the obligation to transfer to the competent service of the Institution, the right to be heard and to make statements, a reasonable time-limit for taking decisions, the duty to state the grounds of decisions, an indication of possibilities of appeal, notification of the decision, data protection, keeping of adequate records and public access to information, to documents and to the Code.22 The assumption here is that most of the member states already have these principles at the national level. Nevertheless, standards, especially those related to transparency issues, should be raised and discretionary powers should be more effectively controlled. Institutions of public law in the EU change under European and national political pressures. Elsewhere, the change comes under national and international political pressures alongside general reasons for change, such as efficiency, chance, prestige and affiliation to certain models for political or economic reasons. The convergence that is seen in both constitutional and administrative law reflects elements of both transposition and cross-fertilisation. In administrative law, most changes regard content rather than structure, and in constitutional law they regard both structure and content. Change is apparent in procedural matters as well. There are common influences in this area also. It can be claimed that the clearest common development is to be seen in the area of values, however.23 The history of law is largely the history of legal transpositions, often from a number of sources, thus law is a constructive synthesis. Though divergence is fruitful and the differences between the similars are especially interesting, there is a move towards a ‘bridging’, a harmony. This is seen in public law mostly in studies of globalisation, regulation, agencies, rule-making and transparency. Public law in Europe today is a ‘mixed system’, civilian in origin, enriched by common law principles and innovations, and with true cross-fertilisation taking place. As noted above, in the UK this has led, apart from individual principles entering UK law, to the expansion of judicial review and to the changing role of the courts. Among the common law innovations, one could mention corporate governance which has influenced both German and EC laws, leading to a market-driven convergence, and ‘the law of professional privilege’ and ‘the right to be heard’, both exported to the ECJ. Again under British influence, the continental emphasis on the privileges of the administration undertaking public services is moving towards stressing individual rights, and yet the protection of the individual under a human rights framework in the UK springs from a continental understanding. In the UK, the Human Rights Act 1998, democracy, majority rule and the notion of limited government are now fundamental areas of study, a study undoubtedly influenced by continental thinking, as is the principle of ‘proportionality’ to be predominantly employed in the area of human rights. Most important cross-fertilisations and transpositions take place at the level of basic ideas. This does not in itself create mixed legal systems, but an area of law could become a mixed system in this way. 22See ‘Code of Good Administrative Behaviour ‘ (01/1/98/OV) handout by J. Söderman, the European Ombudsman. 23See Bell, op. cit., supra n. 12, 166