Summary of investigation – John Baron MP

April 2024

Organisation or person investigated

John Baron MP (“Mr Baron”)

Matter(s) investigated

Whether Mr Baron conducted unregistered consultant lobbying

Registrar’s decision

Based on assurances and information provided, Mr Baron has not conducted unregistered consultant lobbying in relation to the matter under investigation.

Summary of rationale for decision

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.

Based on substantive written information provided, Mr Baron’s role for Baron & Grant Investment Management Limited is solely to Chair the quarterly Investment Committee.

Chronology

Date	Action
29/03/24	Article in The Guardian regarding potential lobbying activity.
08/04/24	Formal letter from the Registrar to Mr Baron giving background on the requirement for registering and asking if his activities fall within the criteria to be registered with particular reference to, but not limited to, his remunerated role with Baron & Grant Investment Management Limited.
16/04/24	Response from Mr Baron in which he explained the services he provided and the nature of Baron & Grant Investment Management Limited ‘s business.
18/04/24	Further query from the Registrar.
18/04/24	Letter from Mr Baron, providing further information and evidence of the extent of his role.
23/04/24	Letter from the Registrar concluding the investigation.

23 April 2024

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
28 Feb	Formal 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 March	Email 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 March	Letter from the Registrar, with some additional questions
7 March	Email from Mr Mills on behalf of Prospermill responding to all questions.
12 March	Letter from the Registrar concluding his investigation.

12 March 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 April 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

Date	Action
5 Oct	Financial Times article ‘Crypto firm Copper met UK officials after Philip Hammond phone call’
20 Oct	Formal 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 Nov	Letter from Lord Hammond with assurances, including that he was (and remains) an employee of Copper Technologies (UK) Ltd.
7 Nov	Letter 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

Date	Action
9 May	Article in The Guardian regarding an event hosted by the APPG on Blockchain.
19 May	Letter from the Registrar giving background on the requirement for registering and requesting information regarding BIC’s client communications.
8 June	Re-sent letter of 19 May, following no response.
20 June	Registrar letter to the APPG on Blockchain’s former Vice Chair regarding no response from BIC.
21 June	Email from the former Vice Chair to BIC, copied to the Office of the Registrar of Consultant Lobbyists, asking them to respond.
18 July	Re-sent letter of 19 May, following no response.
18 July	Initial response from BIC saying a proper response would come in the next few days.
10 August	Formal 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 Sept	Registrar issues a formal Information Notice, following no response.
26 Sept	Email response from BIC.
3 Oct	Letter from Registrar with a follow up question.
3 Oct	Email response from BIC.
6 Oct	Email from Office with a follow up question regarding ministerial contact by an APPG.
9 Oct	Email response from BIC.
23 Oct	Letter from Registrar concluding his investigation.

23 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.

PACAC inquiry evidence

In September 2023 the Registrar gave further evidence Public Administration and Constitutional Affairs Committee as part of their inquiry into lobbying and influence: post-legislative scrutiny of the Lobbying Act 2014 and related matters.

Guidance update – August 2023

The Registrar is today publishing an updated guidance document on registration and Quarterly Information Returns. The updated guidance can be found here.