Record of all statutory notices issued by the Registrar

You can download below a record of all statutory notices issued by the Registrar since the Transparency of Lobbying [etc] Act 2014 came into force. Statutory notices are:

• information notices; and
• civil penalty notices (including the precursor ‘notice of intention to issue a civil penalty’).

Basic information is provided on the reason for each notice being issued and – in the case of civil penalties – the amounts.

Last updated November 2023.

Annual Report and Accounts 2019-20

The Office of the Registrar of Consultant Lobbyists’ Annual Report and Accounts for the financial year 2019-20 was laid before Parliament on 20 July 2020, having been certified by the Comptroller and Auditor General without qualification. You can download a copy below. The document, together with an Open Data Source version of the tabular data it contains, is also available on the gov.uk page for ORCL.

Business Plan 2020-21

This document sets out the key priorities of the Registrar to ensure continued compliance with the Transparency of Lobbying [etc] Act 2014 during the 2020-21 financial year.

You can download and read the Business Plan below.

Summary of Investigation – Lowick Group

April 2020

Organisation or Person Investigated

Lowick Group

Matter(s) Investigated

Whether the Lowick Group’s activities are such that they should be
entered on the Register of Consultant Lobbyists.

Registrar’s Decision

There is no evidence of consultant lobbying historically, but Lowick
Group are likely to need to register themselves in prospect of future work.
Summary of rationale for decision: Though the services promoted on Lowick Group’s
website might potentially include consultant lobbying activity, Lowick Group have given an
express assurance that at 20 April 2020 they have not undertaken such activity, and no
evidence has been provided to the Registrar to prove the contrary. Lowick have sought the
Registrar’s advice in relation to some forthcoming work and it is likely this will require
registration and declaration.

Chronology

Date	Action
1 April 2020	ORCL receives an email from a third party, drawing attention to the services offered by Lowick Group on their website, and their lack of inclusion on the Register of Consultant Lobbyists.
2 April 2020	Initial letter of enquiry from Registrar emailed to Lowick Group, outlining statutory requirements in relation to Register of Consultant Lobbyists and seeking comment and assurances from Lowick. Email also sent to third party informant, requesting details of any specific statutory breach they may have been aware of.
15 April 2020	Phone call from ORCL to chase lack of response from Lowick Group. Further copy of Registrar’s letter of 2 April emailed following conversation.
17 April 2020	Reply received from Lowick Group suggesting lack of historic consultant lobbying, but possible need to register in respect of forthcoming work.
20 April 2020	Email from ORCL to Lowick seeking explicit confirmation of no consultant lobbying activity to date. Email reply received, providing that explicit confirmation.

28 April 2020

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – The Finsbury Group and Huawei

February 2020

Organisation or Person Investigated

The Finsbury Group

Matter(s) Investigated

Whether The Finsbury Group failed to declare any consultant
lobbying activity on behalf of Huawei Technologies.

Registrar’s Decision

Whilst Huawei has been a paying client of The Finsbury Group, there is
no evidence that the latter conducted consultant lobbying activity for the former within the terms
of the legislation.

Summary of Rationale for Decision

The media article that initially raised questions identified that Huawei was a client of The Finsbury Group, that a senior official within the latter was the brother of a recent UK Government Minister, and that another senior official had stated on social media that they had been advising Huawei on strategy. Whilst these circumstances all create a context in which consultant lobbying that needs to be declared (i.e. personal communication by the consultant with a Minister, Permanent Secretary or equivalent, on behalf of a paying client) might take place, no evidence has been provided that declarable activity did in fact take place.
The Finsbury Group explicitly confirmed that no such communications were made by them on behalf of Huawei and the Private Eye article itself reports a similar explicit denial by the Minister in question.

Chronology

Date	Action
4 February 2020	Office of the Registrar receives email from member of the public, drawing attention to an article in issue 1515 of Private Eye, concerning the role of ‘Finsbury PR’ in the UK Government’s consideration of whether to allow Huawei to be part of the delivery of 5G services in the UK.
5-11 February 2020	Consideration of the article by the Registrar.
12 February 2020	Letters sent to: • Private Eye, specifying the statutory requirements relating to consultant lobbying, the role of the Registrar, and requesting any additional information and evidence they may have relating to possible breach of those statutory requirements; and • The Finsbury Group, identifying the article, highlighting statutory requirements on registrants, and requesting a response to the concerns raised by the article.
18 February 2020	Reply from The Finsbury Group, explicitly states: • Huawei was a client of theirs during the relevant period; • The services provided to Huawei did not include personal communications from The Finsbury Group to UK Government Ministers or Permanent Secretaries (or equivalent); and • No such communications had therefore been made on behalf of Huawei since they had been a client of The Finsbury Group.
24 February 2020	Reply from Private Eye, stating that they had no information to provide beyond what was contained in the published article. Registrar determines that there is therefore no evidence of any breach of the statutory requirements.

18 March 2020

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Investigation case summary – Acumen Public Affairs and Hering Schuppener

Between August 2019 and January 2020, responding to information provided by a third party, the Registrar investigated whether Acumen Public Affairs and/or Hering Schuppener should have joined the Register of Consultant Lobbyists. A summary of the investigation and conclusion can be downloaded below.

Guidance update – January 2020

The Registrar is today publishing an updated guidance document on registration and Quarterly Information Returns, which both reflects the results of his consultation on registerable activity and codes of conduct, and incorporates the previously separate specialist guidance for think tanks and providers of support services to APPGs. The updated guidance can be found here.

Consultation responses and conclusions

Following consultation conducted through the latter half of 2019, the Registrar has now determined to make certain changes to existing guidance on registerable activity and codes of conduct. You can view the responses received to the consultation, and the Registrar’s conclusions in light of those responses, in the following downloadable pdf documents.

Registerable activity:

Codes of conduct:

The Registrar intends to publish shortly the updated guidance incorporating these changes. Existing registrants will be contacted directly to highlight the key changes, and confirm the transitional period during which they will need to implement consequential changes to their statutory quarterly information returns.

Investigation case summary – CTF Partners Limited

Organisation or person investigated 

CTF Partners Limited (“CTF Partners”)

Matter(s) investigated

Compliance by CTF Partners with the Transparency of Lobbying, Non-party Campaigning and Trade Union Administration Act 2014 (‘the Act’).

Registrar’s decision

CTF Partners has robust compliance procedures in place and is not engaging in activities that would require registration under the Act.

Summary of rationale for decision

In response to enquiries, CTF Partners has provided satisfactory clarification and explicit assurance as to the particular services it does (and does not) offer to clients, as well as full details of compliance training and monitoring materials it has used since the Act came into force.

Chronology

Summer 2019	Media reporting of association of members of CTF Partners with senior politicians who were and/or subsequently became Government Ministers. In view of the Registrar, in this context, CTF Partners’ consultancy services offer to prospective clients raised a heightened risk of possible consultant lobbying activity, which would be in breach of the Act.
8 July 2019	Letter from Registrar to CTF Partners. Explained remit of Registrar, legislation and guidance on consultant lobbying, and asked for a response, including comprehensive assurance if no consultant lobbying activity is undertaken.
10 July 2019	Reply from CTF Partners, stating that it did not provide services within the scope of the Act.
12 July 2019	Further letter from Registrar to CTF Partners detailing some particular concerns and asking for a more detailed response to these.
19 July 2019	Reply from CTF Partners, giving clarification on the nature of the services offered to its clients in relation to Government.
7 August 2019	Email on behalf of Registrar to CTF Partners, seeking details of relevant compliance training and monitoring within CTF Partners.
20 September 2019	Reply from CTF Partners repeats content of its letter of 19 July, without providing the additional information requested.

Investigation case summary – Finn Communications activity with APPG for British Bioethanol

Organisation or person investigated 

Finn Communications Ltd

Matter(s) investigated

Activities of Finn Communications in provision of secretariat to All
Party Parliamentary Group for British Bioethanol.

Registrar’s decision

Finn Communications Ltd’s activity in support of the APPG for British Bioethanol did not amount to consultant lobbying activity.

Summary of rationale for decision

Finn Communications Ltd’s activity in support of the APPG for British
Bioethanol did not amount to consultant lobbying activity.

Chronology

17 July 2019	Notification received from a third party that Finn Communications  Ltd (an organisation not on the statutory Register of Consultant  Lobbyists) was listed as providing secretariat services to the  APPG for British Bioethanol, on both the APPG’s website and the  APPG’s registration papers with Parliament.
17 July 2019	Letter from Registrar to Finn Communications. Explained remit of  Registrar, legislation and guidance on consultant lobbying, and  indicative evidence received, and asked for a response.
24 July 2019	Reply received from Finn Communications, stating that they did  not consider themselves as having provided secretariat services  to the APPG on an ongoing basis. Support had been provided on  a single occasion in the form of agreeing to take the minutes of  an AGM of the APPG, with no communications made to  Government by them on behalf of the APPG.
31 July 2019	Letter from Registrar to Nic Dakin MP, Chair of APPG for British  Bioethanol, seeking confirmation of the extent of support provided  by Finn Communications to the APPG.
18 September 2019	Substantive response from office of Nic Dakin MP, confirming  Finn Communications’ description of the extent of their support to  the APPG. Confirmation that formal record of support to the  APPG would be amended appropriately.