Summary of investigation – Lord Duncan
April 2025
Organisation or person investigated
The Lord Duncan of Springbank (“Lord Duncan”)
Matter(s) investigated
Whether Lord Duncan conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Duncan 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, Lord Duncan is not UK VAT registered, whether as an individual or through a company. He has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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.
Chronology
| Date | Action |
| 10 April | Article in The Guardian regarding Lord Duncan’s communications with the Parliamentary Under Secretary of State at the Department for Energy Security and Net Zero. |
| 14 April | Formal letter from the Registrar to Lord Duncan giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the communications shown in The Guardian article. |
| 28 April | Letter from Lord Duncan giving background to his work for Terrestrial Energy Inc. This included confirmation that neither Lord Duncan nor his company were UK VAT registered. |
| 30 April | Letter from the Registrar concluding his investigation. |
30 April 2025
Office of the Registrar of Consultant Lobbyists
Quarter One (January-March 2025)Returns Data
There is an ongoing issue with report for the January-March 2025 quarter that we are working on
resolving. Whilst we work on resolving this issue an accurate report can be downloaded below.
Summary of investigation – Octavius GB Limited
February to April 2025
Organisation or person investigated
Octavius GB Limited (“Octavius”)
Matter(s) investigated
Whether Octavius conducted unregistered consultant lobbying.
Registrar’s decision
Based on information and assurances provided, Octavius 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, Octavius has not made communications with ministers for paying clients. Octavius has therefore not conducted unregistered consultant lobbying in relation to the matters under investigation. A separate investigation into Lord Evans of Watford found that he was not paid as an individual, nor through a company, for the events in question.
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.
Chronology
| Date | Action |
| 25 Feb | Article in The Guardian regarding sponsorship of events. |
| 27 Feb | Formal letter from the Registrar to Balmoral Global Capital Limited giving background on the requirement for registering and asking if activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the Guardian’s article of 25 February. |
| 28 Feb | Email from Octavius stating they are not a lobbying firm. |
| 3 March | Letter from the Registrar to Octavius asking further questions. |
| 3 March | Email from Octavius providing information about AFFINITY and Octavius. |
| 11 March | Letter from the Registrar requesting further clarity regarding AFFINITY, Octavius and Balmoral Global Limited. |
| 27 March | Information Notice issued for responses to questions in the Registrar’s letter of 11 March. |
| 27 March | Email from Octavius providing an initial response. |
| 30 March | Email from Octavius providing further response to the Information Notice. |
| 22 April | Letter from the Registrar concluding his investigation. |
22 April 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Lord Gadhia
March – April 2025
Organisation or person investigated
The Lord Gadhia (“Lord Gadhia”)
Matter(s) investigated
Whether Lord Gadhia conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Gadhia 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, Lord Gadhia is not UK VAT registered, he has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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.
Chronology
| Date | Action |
| 20 March | Article in The Guardian regarding Lord Gadhia. |
| 24 March | Formal letter from the Registrar to Lord Gadhia giving background on the requirement for registering and asking if his activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the meeting of 16 February 2021 cited in The Guardian article of 20 March. |
| 7 April | Email from Lord Gadhia to the Registrar confirming and providing evidence that he is not UK VAT registered. |
| 9 April | Letter from the Registrar concluding his investigation. |
9 April 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Lord Evans of Watford
February to March 2025
Organisation or person investigated
The Lord Evans of Watford (“Lord Evans”)
Matter(s) investigated
Whether Lord Evans conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Lord Evans 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, Lord Evans did not receive any payment as an individual, nor through a company, he has therefore not conducted unregistered consultant lobbying in relation to the matter under investigation.
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.
Chronology
| Date | Action |
| 25 Feb | Article in The Guardian regarding Lord Evans. |
| 27 Feb | Formal letter from the Registrar to Lord Evans giving background on the requirement for registering and asking if his activities, whether individually or through a company, fall within the criteria to be registered with particular reference to, but not limited to, the communications set out in The Guardian article of 25 February. |
| 19 March | Letter from the Registrar requesting response to letter of 27 February. |
| 19 March | Email from Lord Evans stating he has never asked for money, nor reward, for asking a minister for access. |
| 24 March | Letter from the Registrar asking about financial relationships and roles with the company, or companies, in relation with any ministerial communications and in particular regarding three events. |
| 24 March | Email from Lord Evans responding fully to the Registrar’s questions. |
| 26 March | Email from Registrar’s Office requesting written evidence referred to in Lord Evans’ email of 24 March. |
| 26 March | Email from Lord Evans providing evidence. |
| 28 March | Letter from the Registrar concluding his investigation. |
28 March 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – The Rt. Hon. Owen Paterson
January 2023 – February 2025
Organisation or person investigated
The Rt. Hon. Owen Paterson (“Mr Paterson”)
Matter(s) investigated
Whether Mr Paterson carried on the business of consultant lobbying without being registered.
Registrar’s decision
That Mr Paterson carried on the business of consultant lobbying while not being registered.
Summary of rationale for decision
Section 1(1) of the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”) states that a person must not carry on the business of consultant lobbying unless entered in the Register of Consultant Lobbyists (“the Register”).
Section 2 of the Act defines consultant lobbying. A summary of this definition is: UK VAT registered organisations and individuals who communicate personally with Government Ministers or Permanent Secretaries (and equivalents) concerning specified matters on behalf of a third party and in return for payment.
Mr Paterson was a paid consultant for Randox Laboratories Ltd (“Randox”). He personally made six direct communications to the then Secretary of State for Health and Social Care between 26 January 2020 and 24 October 2020. The communications were in relation to Mr Paterson’s client, Randox, and the communications related to matters specified in section 2(3) of the Act. Mr Paterson was VAT registered at the time of the communications. The above six communications were registerable.
Mr Paterson was not registered on the Register at the material time when the communications were made and so was in breach of section 1(1) of the Act. The Registrar has therefore issued to Mr Paterson a penalty notice under section 16 of the Act in the sum of £7,500.
Chronology
| Date | Action |
| 13-12-22 | Letter from the Registrar to the Department for Health and Social Care (“DHSC”) requesting copies of communications from Mr Paterson to Ministers concerning Randox. |
| 12-01-23 | Email from DHSC providing copies of communications from Mr Paterson to Ministers. |
| 24-01-23 | Letter from the Registrar to DHSC regarding the communications. |
| 24-01-23 | Letter from the Registrar to Devonshires, representing Mr Paterson (“Devonshires”), regarding Mr Paterson’s communications with the then Secretary of State for Health and Social Care. |
| 03-02-23 | Letter from Devonshires, inter alia, requesting the Registrar to issue a statutory Information Notice prior to Mr Paterson responding to the Registrar’s questions in his letter of 24 January 2023. |
| 07-02-23 | Registrar issues a statutory Information Notice seeking a response to the questions asked in his letter of 24 January 2023. |
| 09-02-23 | Letter from Devonshires stating that their client is not a consultant lobbyist but otherwise not providing answers to the letter of 24 January 2023. |
| 09-03-23 | Letter from the Registrar to DHSC seeking to confirm the provenance of the messages provided on 12 January 2023. |
| 09-03-23 | Letter from Devonshires, inter alia, stating that Mr Paterson has no records and cannot recall the details of the exchanges and asking the Registrar to close the investigation. |
| 22-03-23 | Letter to the Registrar from DHSC confirming that the messages provided on 12 January 2023 were between Mr Paterson and the then Secretary of State for Health and Social Care. |
| 23-03-23 | Letter from the Registrar to Devonshires responding to points raised in their letter of 9 March 2023 and requesting evidence regarding their assertion that Mr Paterson’s communications to Ministers were incidental[1] to his consultancy business. |
| 30-03-23 | Email from Devonshires requesting an extension to the deadline for a response. Over the following weeks the Registrar corresponded with Mr Paterson’s representative in relation to the deadline for a response. |
| 06-04-23 | DHSC letter confirming the provenance of the communications provided on 12 January 2023. |
| 29-08-23 | Letter from Devonshires stating their intention to respond to the issues raised by the Registrar and requesting copies of the DHSC communications referenced in the Registrar’s letter of 24 January 2023. |
| 11-09-23 | Letter from the Registrar to Devonshires providing the DHSC messages referenced and requesting a response to his letter of 23 March 2023 by 27 September 2023. |
| 03-10-23 | Letter from Devonshires neither providing evidence nor answering the questions in the Registrar’s 23 March 2023 letter. |
| 30-10-23 | Registrar issues a statutory Information Notice seeking the information and evidence requested on 23 March 2023. |
| 21-11-23 | Devonshires requests an extension to respond to the statutory Information Notice to 15 December 2023. |
| 21-11-23 | Registrar agrees to the extension. |
| 15-12-23 | Devonshires responds to the Registrar’s letter of 23 March 2023 and states an intention to appeal against the statutory Information Notice. |
| 15-12-23 | Devonshires submits an appeal to the First-tier Tribunal (General Regulatory Chamber) (“GRC”) against the Information Notice of 30 October 2023. |
| 03-01-24 | Government Legal Department (“GLD”), representing the Registrar, writes to the GRC regarding Mr Paterson’s appeal of 15 December 2023 to inform them it was made 18 days late. |
| 03-01-24 | Letter from the Registrar to Devonshires stating that Mr Paterson’s appeal is out of time and that, assuming the letter of 15 December 2023 is as full and accurate an account as their client is able to give, the Information Notice is closed. |
| 03-01-24 | Letter from Devonshires to the Registrar, inter alia, offering a meeting with Mr Paterson. |
| 02-02-24 | GRC dismissal of Mr Paterson’s appeal is received by GLD (although dated 18 December 2023). |
| 08-04-24 | Letter from the Registrar to Devonshires stating that he is “minded to” conclude that Mr Paterson has conducted consultant lobbying activity in relation to the communications subject to his investigation and requesting any further representations and evidence prior to making any formal provisional decision. |
| 19-04-24 | Letter from Devonshires to the Registrar requesting an extension to respond to the Registrar’s letter of 8 April 2024. |
| 19-04-24 | Letter from the Registrar to Devonshires agreeing to the deadline extension. |
| 30-04-24 | Letter, witness statement and evidence from Devonshires to the Registrar disputing that Mr Paterson had conducted consultant lobbying. |
| 03-07-24 | Letter from the Registrar and a Notice of Intention to issue a civil penalty. |
| 09-08-24 | Letter from Devonshires to the Registrar making representations against the Notice of Intention and providing a further witness statement from Mr Paterson. |
| 23-08-24 | Letter from the Registrar to Devonshires stating, inter alia, that he would make enquiries of Randox and requesting a letter of consent from Mr Paterson to facilitate this. |
| 30-08-24 | Email from Devonshires to the Registrar, agreeing to provide consent. |
| 02-09-24 | Letter from the Registrar to Devonshires outlining the areas of intended enquiry with Randox. |
| 03-09-24 | Email from Devonshires to the Registrar attaching a letter sent by Mr Paterson to Randox on 30 August 2024, giving consent. |
| 04-09-24 | Email from the Office of the Registrar of Consultant Lobbyists (“ORCL”) to Devonshires requesting consent for Randox to respond to the Registrar’s enquiries on a wider basis, as outlined in the Registrar’s letter of 2 September 2024. |
| 12-09-24 | Email from ORCL to Devonshires requesting confirmation of receipt of the email of 4 September 2024. |
| 13-09-24 | Email from Devonshires to ORCL saying they will respond early next week. |
| 18-09-24 | Email from Devonshires to the Registrar, referring him to the consent letter of 30 August 2024 provided on 3 September 2024. |
| 23-09-24 | Letter from the Registrar to Devonshires requesting their client to provide a consent letter to Randox, covering the scope of the enquiries set out in the letter of 2 September 2024. |
| 26-09-24 | Letter from Devonshires to the Registrar, inter alia, agreeing to provide a letter of consent as requested. |
| 27-09-24 | Letter from the Registrar to Devonshires asking for confirmation of when their client’s consent letter has been sent to Randox. |
| 1-10-24 | Mr Paterson sends to Randox a letter of consent to respond to the Registrar’s enquiries. |
| 2-10-24 | Letter from the Registrar to Randox, requesting information regarding Mr Paterson’s consultancy work for them. |
| 29-10-24 | Letters from the Registrar to three Randox directors asking whether Randox intends to reply to the information request of 2 October 2024. |
| 12-11-24 | Letter from the Registrar to Devonshires offering their client an opportunity to prompt Randox to respond. |
| 25-11-24 | Letter from Devonshires to the Registrar, inter alia, saying that Mr Paterson had also tried to contact Randox with no response and attaching a statement previously provided by a Randox employee from 2021. |
| 26-02-25 | Letter from the Registrar to Devonshires, concluding the investigation. Penalty notice issued. |
26 February 2025
Office of the Registrar of Consultant Lobbyists
[1] There is an incidental exception under the Act
Guidance update
The Registrar updated the guidance today.
Summary of investigation – Global Counsel Limited (“GCL”)
October 2024 – February 2025
Organisation or person investigated
Global Counsel Limited (“GCL”)
Matter(s) investigated
Whether GCL submitted an inaccurate Quarterly Information Return (“QIR”) to the Registrar.
Registrar’s decision
GCL did not submit inaccurate QIRs in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, GCL has not submitted inaccurate QIRs in relation to the matter under investigation.
Under the Transparency of Lobbying Non-Party Campaigning and Trade Union Administration Act (“The Act”), registrants must submit a QIR to the Registrar every quarter giving client information in relation to consultant lobbying, or a nil return.
In January, March and June 2023, Global Counsel met with a minister and this was not declared in GCL’s QIRs. Based on assurances from GCL, the Qatari Freezone Authority (“QFZA”) was a client of Global Counsel MENA, not of GCL. Global Counsel MENA is a subsidiary of GCL and a separate legal entity. It cannot register as a consultant lobbyist as it is not UK VAT registered. Based on assurances provided, GCL did not receive any payments from QFZA, directly or indirectly, for the periods investigated. Under 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.
Chronology
| Date | Action |
| 25/01/23 | Meeting between Minister of State, Department for International Trade and Global Counsel. |
| 22/03/23 | Meeting between the Minister of State, Department for Business and Trade and Global Counsel. |
| 13/06/23 | Meeting between the Minister of State, Department for Business and Trade the Qatari Freezone Authority (“QFZA”). The briefing states that this was an introductory meeting requested by Global Counsel. The meeting was attended by Global Counsel MENA Regional Director. |
| 17/10/24 | Letter from Spotlight on Corruption, to the Registrar, calling for an investigation and providing background and a link to a press report. |
| 21/10/24 | Formal letter from the Registrar giving background on the requirement for QIRs and asking if GCL declared their clients appropriately with particular reference to, but not limited to, QFZA. |
| 29/10/24 | Letter from GCL to the Registrar stating that QFZA is a client of Global Counsel MENA, a non-UK subsidiary of GCL and therefore not UK VAT registered. |
| 12/11/24 | Letter from the Registrar to GCL with additional questions. |
| 15/11/24 | Letter from GCL to the Registrar providing responses. |
| 26/11/24 | Letter from the Registrar stating he is considering the response and requesting information regarding a further potential inaccuracy regarding SHEIN, reported in The Guardian. |
| 26/11/24 | Letter from GCL to the Registrar responding that no registrable communications were made for SHEIN. |
| 21/02/25 | Letter from the Registrar to GCL, concluding the investigation and providing advice on transparency regarding which legal entity is being represented in communications. |
21 February 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Collider Health Limited and Business for Health CIC
January – February 2025
Organisation or person investigated
Collider Health Limited (“Collider Health”) and Business for Health CIC (“B4H”)
Matter(s) investigated
Whether Collider Health and/or B4Hh conducted unregistered consultant lobbying
Registrar’s decision
Based on information and assurances provided, Collider Health and B4H have 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, Collider Health and B4H have 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.
Collider Health: provided assurances that B4H was not a paying client at this time.
Business for Health: Assurances were given that all funding received by B4H is subject to a clause which gives independent control of the content of funded projects to the Board of B4H, not the funder(s). The Registrar’s guidance explains an exemption for Think Tanks on the grounds that the communications are not in return for payment and this currently applies to B4H. The guidance includes:
‘If funding is provided for a 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. An independence clause in a funding agreement or contract is indicative of an absence of control by a funder.’
Chronology
11 February 2025
Office of the Registrar of Consultant Lobbyists
Record of Registrar’s external communications in 2025
This is a record of external communications made by the Registrar, Harry Rich, during 2025. 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 April 2025