open access


This  article  compares  the  public  policy  exception  to  free movement of goods, services, persons and capital (the four freedoms) with the public policy exception to free movement of judgments (the fifth  freedom).  A  comparison  is  made  on  the  basis  of  the  following elements: types of public policy (domestic, international, purely inter-national;  European;  substantive  and  procedural),  restrictiveness  of interpretation, variability, content, nature and the addressees of protection. The conclusion is that there is only one concept of public policy that varies from time to time and from Member State to Member State, although there are some differences in the operation of the uses in the two areas of public policy.