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Summary of Investigation – Mr Gary Kent

November to December 2021

Organisation or Person investigated

Mr Gary Kent (“Mr Kent”)

Matter(s) Investigated

Whether Mr Kent is an unregistered consultant lobbyist

Registrar’s Decision

Mr Kent is not an unregistered consultant lobbyist

Summary of Rationale for Decision

Mr Kent is not registered for VAT. Registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act).

In addition, Mr Kent provided assurances that no registerable communications had been made or are intended to be made.

Chronology

DateAction
17 NovemberBBC article on All-Party Parliamentary Groups (“APPGs”), including a case study on the APPG on Kurdistan Region in Iraq. 
22 NovemberFormal letter from the Registrar to Mr Kent giving background on the requirement for registering and asking if his activities fall within the criteria for registration. In particular, but not limited to, support services provided to the APPG on Kurdistan Region in Iraq and payment for this role from Kar Group, whether paid directly or indirectly.
1 DecemberEmail from Mr Kent stating he is not VAT registered. In addition, providing assurances that no registerable communications have been made or are intended to be made for the APPG; and no representations have been made or are intended to be made to anyone on behalf of the APPG’s sponsors.
2 DecemberLetter from Registrar concluding the investigation.

2 December 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Mr Stephen Brine MP

November 2021

Organisation or Person Investigated

Mr Stephen Brine MP (“Mr Brine”)

Matter(s) Investigated

Whether Mr Brine conducted unregistered consultant lobbying activity.

Registrar’s Decision

Mr Brine did not conduct unregistered consultant lobbying, based on information provided.

Summary of Rationale for Decision

Mr Brine is not registered for VAT. Registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying. On that basis, the webinars Mr Brine hosted for Sigma Pharmaceuticals are not registerable under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”).

Chronology

Date Action
9 November Report in The Times regarding Mr Brine’s work for Sigma Pharmaceuticals and a video meeting with the Vaccines Minister
11 November Formal letter from the Registrar to Mr Brine giving background on the requirement for registering and asking if his activities fall within the criteria for registration. In particular, but not limited to, the meeting in February 2021, mentioned in media reports.
16 November Letter from Mr Brine explaining the video meeting was a webinar for community pharmacists and providing a link; stating this was not consultant lobbying; and providing links to two further webinars, for transparency. 
19 November Letter from the Registrar stating that two of the events would be registrable if the other two tests in the Act apply. Requesting information on whether this was a paid communication and whether Mr Brine, or any organisation he receives payment from Sigma Pharmaceuticals through, is VAT registered.
24 November Letter from Mr Brine stating he is not VAT registered.
26 November Letter from the Registrar to conclude the investigation and to provide advice to ensure future compliance with the Act.

26 November 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Charlesbye Limited

November 2021

Organisation or Person Investigated

Charlesbye Limited (“Charlesbye”)

Matter(s) Investigated

Whether Charlesbye is an unregistered consultant lobbyist

Registrar’s Decision

Charlesbye is not an unregistered consultant lobbyist, based on detailed information and substantive assurances provided. 

Summary of Rationale for Decision

Based on the explanation of Charlesbye’s business activities and substantive assurances provided, I conclude that the company has not been engaging in consultant lobbying activity.

Chronology

Date Action
11 November Article in The Guardian regarding Charlesbye’s work.
12 November Formal letter from the Registrar to Charlesbye giving background on the requirement for registering and asking if their activities fall within the criteria for registration. In particular, but not limited to, clients mentioned in media reports.
22 November Email from Charlesbye stating they have not made any oral, written or electronic communications personally to a Minister of the Crown or Permanent Secretary (or equivalents specified in the Act)
23 November Letter from the Registrar to Charlesbye requesting information on the nature of the activities carried out for clients listed in the letter of 12 November.
23 November Email from Charlesbye stating that they provide strategic communications advice to their clients.
25 November Letter from Registrar concluding the investigation.

25 November 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Collider Health

September to November 2021

Organisation or Person Investigated

Collider Health

Matter(s) Investigated

Whether Collider Health undertook unregistered consultant lobbying activities

Registrar’s Decision

Collider Health is not an unregistered consultant lobbyist.

Summary of Rationale for Decision

The communication under investigation took place in April 2021 at the online launch by the All-Party Parliamentary Group on Longevity (“the APPG”) of the APPG’s Levelling Up report. The Secretary of State for Health and the Chief Medical Officer (“CMO”) also presented at the launch. The investigation established that Collider Health was not the APPG support provider (secretariat) at the time of the launch, taking on this role on 1 September 2021.

Collider Health should ensure that it is clear about the requirements of the Act in order to avoid the risk of making unregistered relevant communications under the Act.

Chronology

Date Action
9 April The APPG’s 9 April 2021 Levelling Up Health Launch. A video of this launch shows presentations from a Secretary of State, the CMO and the APPG support provider (secretariat).
15 September Formal letter from the Registrar to Collider Health (the current APPG 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 Longevity APPG support role and citing the 9 April 2021 video.
20 September Email from APPG Secretariat confirming Collider Health became the APPG support provider from 1 September 2021; giving links to Governance Framework and Income and Expenditure Statements and stating that any communication with Ministers or Permanent Secretaries always comes from the APPG’s Chair.
27 September ORCL email asking whether Collider Health is paid to provide support services to the APPG and whether Collider Health VAT registered.
27 September Email 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 November Letter from the Registrar to both Longevity International and Collider Health explaining that the 9 April event seems registerable; asking if Collider Health is paid to provide support services to the APPG; and whether Collider Health’s services include communications of any kind with Ministers, Permanent Secretaries and equivalents.
2 November Email 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; and Collider Health does not engage in activities that require registration.
11 November Letter from the Registrar to Collider Health concluding that as they were not the support provider on 9 April 2021 they had not conducted unregistered consultant lobbying. Advising caution to avoid unintentional unregistered lobbying in future.

11 November 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Longevity International CIC

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

That Longevity International undertook unregistered consulting lobbying activities 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 civil penalty is appropriate.

Chronology

Date Action
9 April The 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 September Email 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 September ORCL email asking whether Collider Health is paid to provide support services to the APPG and whether Collider Health VAT registered.
27 September Email 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 November Letter 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 November Email 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 November Letter 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.

11 November 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

Summary of Investigation – Hod Hill Ltd

In August and September 2021

Organisation or Person Investigated

Hod Hill Ltd (‘Hod Hill’).

Matter(s) Investigated

Whether Hod Hill is an unregistered consultant lobbyist

Registrar’s Decision

Based on information provided and substantive assurances, I conclude that the company has not been engaging in consultant lobbying activity.

Summary of rationale for decision

This decision is based on information provided regarding services provided by Hod Hill and substantive assurances from Hod Hill that consultant lobbying is not undertaken. Further, Hod Hill has acknowledged issues with the distinction between Hod Hill and external roles and has taken steps to make this clearer.

Chronology

Date Action
5 August Article in The Times suggesting Hod Hill is involved in arranging access to senior people.
6 August Formal letter from the Registrar to Hod Hill 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 The Times report regarding Hod Hill’s role in arranging access to Ministers.
18 August Letter from Registrar to Hod Hill, requesting a response to his letter of 6 August.
18 August Emails from Hod Hill to confirm receipt, that the original letter was not received and to state no such lobbying had taken place.
18 August Email from ORCL on behalf of Registrar requiring a full written response
by 24 August.
22 AugustLetter from Hod Hill stating no consultant lobbying has been undertaken.
23 AugustEmail from the Registrar requiring a substantive response.
31 August Letter from Hod Hill giving further detail and confirming that Hod Hill was
set up in 2015 as the private office if Ben Elliot, that the Conservative
Party is not a Hod Hill client and Hod Hill has not benefited financially from
the Conservative Party
6 SeptemberLetter from Registrar asking for further information about Hod Hill’s clients,
services and customers.
10
September
Letter from Hod Hill explaining their services and that political and
lobbying services are not offered nor undertaken. A further explanation
was given relating to media reports about a Hod Hill email address being
used to communicate with Mr Widecki connected with support he provides
to Mr Elliot’s Conservative Party role outside of his Hod Hill role. He has
since set up a new email address to make a clear distinction between
roles.
14
September
Letter from Registrar to close the investigation and welcoming measures
to make a clear distinction between roles.

17 November 2021
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk