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Summary of investigation – Prospermill Limited

February – March 2024

Organisation or person investigated

Prospermill, Prospermill Limited and Mr Andrew Mills (together: “Prospermill”)

Matter(s) investigated

Whether Prospermill conducted unregistered consultant lobbying.

Registrar’s decision

Based on assurances provided, Prospermill has not conducted unregistered consultant lobbying in relation to the matter under investigation.

Summary of rationale for decision

Based on substantive and unequivocal written information provided, Prospermill has not conducted unregistered consultant lobbying.

Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.

Prospermill provided assurance that communications were with officials, not at Minister, Permanent Secretary (or equivalent) level.

Chronology

DateAction
28 FebFormal letter from the Registrar to Andrew Mills at Prospermill giving background on the requirement for registering and asking if the company’s activities fall within the criteria to be registered with particular reference to, but not limited to, reports that Andrew Mills brokered a deal for Ayanda Capital Limited and received payment for this to Prospermill.
2 MarchEmail response from Mr Mills on behalf of Prospermill confirming that the companies and the individual referenced had not carried out, nor intend to carry out, any lobbying activities that fall within the terms of the Act; and providing a link to a Judicial Review judgment.
7 MarchLetter from the Registrar, with some additional questions
7 MarchEmail from Mr Mills on behalf of Prospermill responding to all questions.
12 MarchLetter from the Registrar concluding his investigation.

12 March 2024

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Updated guidance on compliance

The guidance includes minor changes to aid clarity and understanding.

Summary of investigation – Brooks Newmark & Co Ltd

November 2023 – February 2024

Organisation or person investigated

Brooks Newmark & Co Ltd

Matter(s) investigated

Whether Brooks Newmark or Brooks Newmark & Co Ltd (“Mr Newmark”) conducted unregistered consultant lobbying.

Registrar’s decision

Based on third-party assurances provided, Mr Newmark has not conducted unregistered consultant lobbying in relation to the matter under investigation, whether as an individual or through a company.

Summary of rationale for decision

Third-party assurances were provided that neither Mr Newmark nor Brooks Newmark & Co Ltd are or were registered for VAT.

Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying.

Chronology

DateAction
15 Nov 2023Formal letter from the Registrar to Mr Newmark giving background on the requirement for registering and asking if his or his company’s activities fall within the criteria to be registered with particular reference to, but not limited to, communications with the Secretary of State for Health and Social Care on behalf of Worldlink Resources.
5 Dec 2023Further letter from the Registrar, following no response from Brooks Newmark & Co Ltd.
12 Dec 2023Response from Carter-Ruck, Mr Newmark’s representative, explaining that neither Mr Newmark nor his business are or were VAT-registered.
15 Dec 2023Letter from the Registrar with a further query regarding payments.
15 Jan 2024Letter from Carter-Ruck providing further background.
17 Jan 2024Letter from the Registrar with a further query regarding VAT registration.
1 Feb 2024Further letter from the Registrar, following no response.
1 Feb 2024Letter from Shipleys, chartered accountants, via Carter-Ruck, explaining that payments made to Brooks Newmark & Co Ltd from an overseas company did not trigger a requirement for UK VAT registration.
8 Feb 2024Letter from the Registrar concluding his investigation.

13 February 2024

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Record of Registrar’s external communications in 2024

This is a record of external communications made by the Registrar, Harry Rich, during 2024. We do not publish information about correspondence with whistleblowers who wish to protect their anonymity nor privileged legal communications or communications that would prejudice the conduct of a formal enquiry by the Registrar. The data is updated monthly.

Last updated March 2024

Advice for parliamentarians and former parliamentarians

If in a future role you might communicate with ministers or others on behalf of clients, you should be aware of your statutory duties under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’). 

A very brief overview is that UK VAT registered organisations and individuals who
communicate personally with Government Ministers or Permanent Secretaries (and
equivalents) on behalf of a third party and in return for payment must be registered in
advance of such activity.

The statutory obligation is to register in advance of any consultant lobbying and you can find detailed guidance here

The requirements of the Act are separate to rules administered by other bodies such as professional regulators, the Advisory Committee on Business Appointments (ACOBA), the Parliamentary Commissioner for Standards or the Foreign Influence Registration Scheme (FIRS). You will need to understand any separate rules that you may be subject to in addition to the Act.

Summary of investigation – The Rt Hon the Lord Hammond of Runnymede

October to November 2023

Organisation or person investigated

The Rt Hon the Lord Hammond of Runnymede “Lord Hammond”

Matter(s) investigated

Whether Lord Hammond conducted unregistered consultant lobbying

Registrar’s decision

Based on assurances provided, Lord Hammond has not conducted consultant lobbying activities.

Summary of rationale for decision

Lord Hammond provided assurances that no representation took place and that he was an employee of Copper Technologies (UK) Ltd.

Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, consultant lobbying is communicating with Ministers and Permanent Secretaries for a paying client. Lobbying conducted by an employee does not require registration.

Chronology

DateAction
5 OctFinancial Times article ‘Crypto firm Copper met UK officials after Philip Hammond phone call’
20 OctFormal letter from the Registrar to Lord Hammond giving background on the requirement for registering and asking if its activities fall within the criteria to be registered with particular reference to, but not limited to, the Financial Times article of 5 October.
3 NovLetter from Lord Hammond with assurances, including that he was (and remains) an employee of Copper Technologies (UK) Ltd.
7 NovLetter from the Registrar concluding his investigation.

7 November 2023

Office of the Registrar of Consultant Lobbyistsoffice@orcl.gov.uk

Summary of Investigation – Big Innovation Centre

May to October 2023

Organisation or person investigated

Big Innovation Centre (“BIC”)

Matter(s) investigated

Whether BIC conducted unregistered consultant lobbying

Registrar’s decision

Based on assurances received, BIC has not conducted unregistered consultant lobbying activity.

Summary of rationale for decision

Based on substantive and unequivocal written information from BIC, no registerable communications have taken place. Where BIC provides secretariat services for All-Party Parliamentary Groups (“APPGs”), all communications with ministers are undertaken by APPG parliamentary officers. 

Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union administration Act (2014), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client. BIC provided assurance that no such communication has taken place.

Chronology

DateAction
9 MayArticle in The Guardian regarding an event hosted by the APPG on Blockchain.
19 MayLetter from the Registrar giving background on the requirement for registering and requesting information regarding BIC’s client communications.
8 JuneRe-sent letter of 19 May, following no response.
20 JuneRegistrar letter to the APPG on Blockchain’s former Vice Chair regarding no response from BIC.
21 JuneEmail from the former Vice Chair to BIC, copied to the Office of the Registrar of Consultant Lobbyists, asking them to respond.
18 JulyRe-sent letter of 19 May, following no response.
18 JulyInitial response from BIC saying a proper response would come in the next few days.
10 AugustFormal investigation letter from the Registrar giving background on the requirement for registering and asking if BIC’s activities fall within the criteria to be registered with particular reference to, but not limited to, any communications made on behalf of APPGs.
5 SeptRegistrar issues a formal Information Notice, following no response.
26 SeptEmail response from BIC.
3 OctLetter from Registrar with a follow up question.
3 OctEmail response from BIC.
6 OctEmail from Office with a follow up question regarding ministerial contact by an APPG.
9 OctEmail response from BIC.
23 OctLetter from Registrar concluding his investigation.

23 October 2023

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Newbridge Advisory

September to October 2023

Organisation or Person Investigated

Newbridge Advisory Limited (“Newbridge Advisory”)

Matter(s) Investigated

Whether Newbridge Advisory conducted unregistered consultant lobbying

Registrar’s Decision

Based on assurances given and evidence provided, Newbridge Advisory has not conducted unregistered consultant lobbying as defined in the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act (“the Act”).

Summary of Rationale for Decision

Under the Act, there is an exception for those with a business consisting mainly of non-lobbying activities; and where the communication is incidental to this business (“the incidental exception”).

I apply the incidental exception within narrow parameters, as set out in my guidance. Newbridge Advisory provided unequivocal and complete assurances to my queries, which helped me to ascertain that there was one communication to consider and:

  • The business consists of mainly non-lobbying activities.
  • The communication does not appear significant by volume, value, significance to client offering or contribution to non-lobbying activities.

Chronology

DateAction
4 SeptArticle in openDemocracy regarding meeting between Palantir and the Cabinet Office.
6 SeptFormal letter from the Registrar to Newbridge Advisory giving background on the requirement for registering and asking if its activities fall within the criteria to be registered with particular reference to, but not limited to, any communications made on behalf of Palantir.
18 SeptDetailed response from Newbridge Advisory
26 SeptLetter from Registrar requesting contractual information.
4 OctResponse from Newbridge Advisory regarding contract with Palantir.
20 OctLetter from Registrar concluding his investigation.

20 October 2023

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Register of External Gifts and Hospitality

You can download below a record of all external gifts and hospitality for 2023/24 for the Registrar.

Last updated March 2024.

Quarterly Information Return Period Open

This is a reminder that – Quarterly Information Report for the July to September quarter is due by the 14th of October. A return needs to be submitted even if you have a nil declaration.