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Summary of Investigation – Longevity UK CIC (updated)

September to November 2021

Organisation or person investigated

Longevity International CIC (“Longevity International”)

Matter(s) investigated

Whether Longevity International undertook unregistered consultant lobbying activities

Registrar’s decision

On 11 November the Registrar concluded that Longevity International undertook unregistered consulting lobbying activities in April 2021. In making representations against the penalty, Longevity International provided information and substantive assurances that resulted in the Registrar granting the appeal against the original decision and concluding that Longevity International did not undertake unregistered consultant lobbying activity in April 2021.

Summary of rationale for decision

In April 2021, Longevity International took part in a video launch of the All-Party Parliamentary Group on Longevity (“the APPG”) report on Levelling Up. The Secretary of State for Health and the Chief Medical Officer (“CMO”) also presented at the launch.

Longevity International was, at the time of the event, paid as a support provider (secretariat) for the APPG. Participating in the event alongside the Secretary of State and the CMO constitutes consultant lobbying by Longevity International on behalf of their client, the APPG.

As unregistered consulting lobbying is a statutory offence, a notice for a civil penalty was issued. In making representations against this notice, Longevity International provided information and substantive assurances that they had no direct contact with the Secretary of State nor the CMO before, during or after the event. As a result, the Registrar granted the appeal and did not issue a penalty.

Chronology

DateAction
9 AprilThe APPG’s 9 April 2021 Levelling Up Health Launch. A video of this launch shows presentations from a Secretary of State, the CMO and Longevity International, the APPG support provider (secretariat).

15 September
Formal letter from the Registrar to Collider Health (the APPG’s current support provider) giving background on the requirement for registering; asking if their activities in general fall within the criteria to be registered; and in particular with reference to Collider Health’s APPG support role and citing the 9 April 2021 video.
20 SeptemberEmail from APPG Secretariat confirming Collider Health is the APPG support provider from 1 September 2021; giving links to the Governance Framework and Income and Expenditure Statements and stating that any communication with Ministers or Permanent Secretaries always comes from the APPG’s Chair and the Longevity International role was to present some of the work in the APPG’s Levelling Up report.
27 SeptemberORCL email asking whether Collider Health is paid to provide support services to the APPG and whether Collider Health VAT registered.
27 SeptemberEmail from the APPG Secretariat stating a proportion of time spent by Collider Health on APPG secretariat services is paid (through funds donated by sponsors); and Collider Health is VAT registered.
1 NovemberLetter from the Registrar explaining that the 9 April event seems registerable and giving the opportunity to respond. Also asking if Longevity International was paid to provide support services to the APPG and whether Longevity International is VAT registered.
2 NovemberEmail from the APPG Secretariat stating the event on 9 April was not registerable; that the APPG’s relatively low-cost work is supported by charities and corporate sponsors who have no control over outcomes; that Longevity International’s involvement at the event was to communicate aspects of the report.
11 NovemberLetter from the registrar giving the investigation outcome and that a Notice of Intention for a penalty will follow. The outcome of the investigation of Collider Health is provided in a separate summary.

Update to chronology following 11 November

DateAction
11 NovemberRegistrar issues a penalty notice for unregistered consultant lobbying, giving Longevity International 30 days to make representations in writing.
22 NovemberLongevity International sends representations against penalty notice and provides information and substantive assurances that they had no direct contact with the Secretary of State nor the CMO before, during or after the event.
26 NovemberRegistrar writes to Longevity International informing them that he has granted the appeal, will not proceed with the penalty and the case summary will be updated.

26 November

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Rt Hon David Cameron

August – October 2021

Organisation or Person Investigated

Rt Hon David Cameron through the Office of David Cameron (“ODC”)

Matter(s) Investigated

Whether Mr Cameron through ODC acted as an unregistered consultant lobbyist, with particular reference to Illumina.

Registrar’s Decision

Based on detailed information that Mr Cameron provided about the business activities he conducts through ODC and on substantive assurances, I conclude that the incidental exception* applies to four communications with Ministers that would otherwise have been registerable. As a result, Mr Cameron through ODC has not acted as an unregistered consultant lobbyist under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”).

* The incidental exception in schedule 1, part 1, section 1 of the Act provides (in part):

A person does not, by reason of making a communication, carry on the business of consultant lobbying if (a) the person carries on a business which consists mainly of non-lobbying activities, and (b) the making of the communication is incidental to the carrying on of those activities.

Summary of Rationale for Decision

During the investigation I considered four communications by Mr Cameron in relation to Illumina, a client of ODC:

  • Forwarding to the Secretary of State for Health and Social Care an invitation from Illumina to speak at the International Summit on Population Genomics (2019)
  • Participation at the International Summit alongside the Executive Chairman of Illumina and the Secretary of State for Health and Social Care (2019)
  • Text message to the Vaccines Minister referencing Illumina (2021)
  • Follow-up meeting with the Vaccines Minister (2021)

I conclude that these communications would constitute registerable consultant lobbying unless the incidental exception applies.

Mr Cameron and ODC provided evidence of ODC’s wider work and as a result of this evidence and substantive assurances from Mr Cameron, I conclude that the incidental exception applies to these communications and that Mr Cameron through ODC has not conducted unregistered consultant lobbying activity.

I note that the definition of lobbying applied by Mr Cameron and ODC appears to differ from the statutory definition and I have advised caution in this regard.

Chronology

Date Action
30 July Media reports regarding Mr Cameron’s work with Illumina and meeting with the Vaccines Minister, following publication of ministerial diaries.
2 August Formal letter from the Registrar to Mr Cameron via ODC giving background on the requirement for registration; asking if his activities in general fall within the criteria to be registered; and in particular with reference to Illumina.
9 August Response from Mr Cameron stating he did not lobby the UK Government on behalf of Illumina; giving information regarding the approval of his role from the Advisory Committee on Business Appointments (ACOBA) in 2017; background to his meeting with the Vaccines Minister and Illumina; giving his view that this meeting was not an act of consultant lobbying and was incidental to his work for Illumina; and sharing articles demonstrating his previous interest in the role of genomic sequencing in virus surveillance.
11 August Letter from Mr Cameron, following an article in The Times regarding a genomics conference in 2019, reiterating that he was not lobbying for Illumina.
11 August Letter from the Registrar, requesting further information regarding communications with Ministers and asking for Mr Cameron to consider his assertion that his lobbying is incidental, in light of the Registrar’s guidance on incidental lobbying.
18 August Letter from Mr Cameron responding to the questions posed on 11 August.
25 August Email from the Registrar asking for further information regarding Mr Cameron’s work for Illumina and his meeting with the Vaccines Minister.
27 August Letter and supplementary information from Mr Cameron in response to questions posed on 25 August.
17 September Letter from the Registrar setting out his preliminary conclusions and inviting Mr Cameron’s response.
1 October Letter from Mr Cameron providing detailed information, evidence and assurances about the volume and nature of the commercial activities that he conducts through ODC.
5 October Further evidence from ODC.
19 October Letter from the Registrar to conclude the investigation and to advise that had the incidental exception not applied, Mr Cameron’s four communications would have constituted consultant lobbying under the terms of the Act. The Registrar noted that the definition of lobbying applied by Mr Cameron and ODC appears to differ from the statutory definition which the Registrar applies in his decisions. The definition in the Act also differs from that applied by ACOBA. The Registrar advised that his decision that the incidental exception applied to the relevant communications was finely balanced in some respects and advised continuing caution in this regard.

19 October 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Three Lines Sport

August 2021

Organisation or Person Investigated

Three Lines Sport Ltd and MR Sport and Mark Ramsdale

Matter(s) Investigated

Whether Three Lines Sport Ltd, MR Sport or Mark Ramsdale (“Mr Ramsdale”) are
unregistered consultant lobbyists

Registrar’s Decision

That the communications Mr Ramsdale disclosed constitute consultant lobbying. The
consultant lobbyist(s) whether Three Lines Sport Ltd, MR Sport or Mark Ramsdale should
join the Register immediately.

Summary of Rationale for Decision

Communications with Ministers on behalf of a paying client, including All Party Parliamentary
Groups (APPGs), is consultant lobbying. This includes attending meetings with a Minister
and writing to a Minister on behalf of a client. The consultant lobbyist(s) has a statutory
requirement to join the Register immediately. No civil penalty notice will be issued because
Mr Ramsdale sought and complied with advice from the Office of the Registrar of Consultant
Lobbyists (ORCL) in 2016 and the APPG guidance has changed since that time.

Chronology

DateAction
2 AugustFormal letter from the Registrar to Mr Ramsdale, giving background on the Act
and asking him to consider whether he or his organisations have undertaken
relevant communications within the scope of the Act in general and with
particular reference to the support provided to APPGs.
5 August Email from Mr Ramsdale confirming he had tried to register MR Sport in 2016
and was advised the activity did not meet the criteria for registration. He
confirmed that the APPG support role remained unchanged and provided
further information about Three Lines Sport Ltd and communications
undertaken on behalf of APPGs.
5 AugustEmail from ORCL confirming the Registrar’s guidance for APPGs has been
updated since 2016, and asking for further clarity on communications with
Ministers.
5 AugustEmail from Mr Ramsdale, checking whether to answer the further questions or
to use as a guide to consider whether to register.
6 AugustEmail from ORCL requesting a response to the questions for consideration by
the Registrar.
6 AugustFull detailed response from Mr Ramsdale.
9 AugustORCL advises Mr Ramsdale that the Registrar has concluded his investigation
and that the entities undertaking consultant lobbying should join the Register
immediately.

09 August 2021

Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk

Summary of Investigation – Public Policy Projects Ltd

February 2021

Organisation or Person Investigated

Public Policy Projects Limited (“PPP”)

Matter(s) Investigated

Following a query from a journalist, this investigation was to
determine if PPP is an unregistered consultant lobbyist and in particular whether a meeting
on 21 August 2020 (“the meeting”) constituted consultant lobbying.

Registrar’s Decision

Based on the information provided and assurances given, PPP’s
activities do not currently constitute consultant lobbying.

Summary of Rationale for Decision

My formal guidance covers a number of issues to be
considered by think tanks in relation to registration, including: “If funding is provided for a
specific project, but the funder cannot exercise control over the outcome of the project, the
activity is unlikely to be registrable. This is because any resulting communication would be
expressing the think tank’s views, rather than being on behalf of a client.”
PPP provided details of how they operate and comprehensive assurances that the views
they communicate are those of PPP, not those of clients or funders. In particular, clients
cannot influence the outcome of research projects. PPP also provided details of the meeting
which was in fact a PPP webinar co-chaired by a Deputy Chair of PPP, Baroness
Blackwood, and addressed by Lord Bethell, a minister at the Department of Health and
Social Care.
Based on the assurances from PPP about how they work and details of the meeting, I am
satisfied that PPP’s current activities do not constitute consultant lobbying.

Chronology

DateAction
16 February 2021

Email received from a journalist, asking if ORCL received any returns on
Public Policy Projects Ltd (PPP) that have not yet been published. The query
stemmed from published evidence of a meeting between PPP, Baroness
Blackwood and Lord Bethell, Parliamentary Under Secretary of State at the
Department of Health and Social Care.
17 february 2021Formal letter from the Registrar to PPP giving an overview of the
Transparency of Lobbying, Non-Party Campaigning and Trade Union
Administration Act 2014 (the Act); asking PPP to consider whether they
undertake communications that fall within the scope of the Act; and about the
meeting between Baroness Blackwood, PPP and Lord Bethell on 21 August
2020 to discuss clinical trials.
24 February 2021Response from PPP stating they define their own projects, accepting funding
but not briefs from clients; they keep editorial control of their publications; and
they speak with public officials to promote discussion on PPP policy
proposals, not on behalf of clients. Regarding the meeting of 21 August, PPP
stated it was a webinar co-chaired by Baroness Blackwood and Dr Jonathan
Sheffield and addressed by Lord Bethell. It was held as part of the work of
the Clinical Research Coalition, initiated by PPP, in May 2020 through a
public call for evidence from those interested in the implications of the Covid
pandemic for clinical research in the UK. This call led to written contributions
and a series of webinars in which speakers were drawn from a broad
spectrum of thought leaders in the sector.

26 February 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Longevity International (UK)

August to November 2020

Organisation or Person Investigated

Longevity International (UK)

Matter(s) Investigate

Whether Longevity International (UK)’s activities, relating to the
Longevity APPG, are such that they should be entered on the Register of Consultant
Lobbyists.

Registrar’s Decision

Based on Longevity International (UK)’s assurances and no evidence
to the contrary, Longevity International (UK) is not involved in consultant lobbying.

Summary of Rationale for Decision

Longevity International (UK) provides secretariat
support, including organisation of events and publications. Longevity International (UK) has
provided assurance that it never communicates with a Minister of the Crown or permanent
secretary on behalf of the Longevity APPG or any of its members.

Chronology

DateAction
6 August 2020


ORCL receives email from a third party that Longevity
International (UK) appears to be in violation of rules on
consultant lobbying.
7 August 2020 Initial formal letter of enquiry from Registrar emailed to
Longevity International (UK), outlining statutory requirements
in relation to Register of Consultant Lobbyists and seeking
their views on whether their activities as Longevity APPG
secretariat amount to consultant lobbying that requires
registration.
3 September 2020 Information Notice, from the Registrar, emailed and sent by
hard copy to Longevity International following no response to
the letter.
4 September 2020 Hard copy of letter returned by Royal Mail ‘addressee
gone away’.
5 November 2020 ORCL emails further addresses, connected to Longevity,
regarding the breach of legislation through failure to
respond.
6 November 2020 Longevity International (UK) emails stating that previous
communications were not received and confirming that any
communication with Ministers or Permanent Secretaries
always comes from the Longevity APPG Chair.
9 November 2020
ORCL emails requesting confirmation that Longevity International
(UK) never makes any form of communication to Ministers or
Permanent Secretaries on behalf of the APPG or any of its
members; and to clarify the nature of the services Longevity
International (UK) provides to the APPG.
10 November 2020 Longevity International (UK) emails confirmation that it never
makes any form of communication to Ministers or Permanent
Secretaries on behalf of the APPG or any of its members; and
that it is a support provider to the APPG managing the secretariat
function, including the organisation of events and publications.

16 November 2020

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk