Summary of Investigation – Laurence Robertson MP
May 2023
Organisation or Person Investigated
Laurence Robertson MP (“Mr Robertson”)
Matter(s) Investigated
Whether Mr Robertson conducted unregistered consultant lobbying
Registrar’s Decision
Based on assurances received, Mr Robertson has not conducted unregistered consultant lobbying activity.
Summary of Rationale for Decision
Based on Mr Robertson’s unequivocal and complete written assurances, he is not registered for VAT. Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying.
Chronology
12 May
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Philip Davies MP
May 2023
Organisation or Person Investigated
Philip Davies MP (“Mr Davies”)
Matter(s) Investigated
Whether Mr Davies conducted unregistered consultant lobbying
Registrar’s Decision
Based on assurances received, Mr Davies has not conducted unregistered consultant lobbying activity.
Summary of Rationale for Decision
Based on Mr Davies’ unequivocal and complete written assurances, he is not registered for VAT. Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying.
Chronology
12 May 2023
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Scott Benton MP
April 2023
Organisation or Person Investigated
Scott Benton MP (“Mr Benton”)
Matter(s) Investigated
Whether Mr Benton conducted unregistered consultant lobbying
Registrar’s Decision
Based on assurances received, Mr Benton has not conducted unregistered consultant lobbying activity.
Summary of Rationale for Decision
Based on Mr Benton’s unequivocal and complete written assurances, in response to detailed enquiries, he has not received payment or benefits in kind in return for lobbying. Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, consultant lobbying activities are in return for payment on behalf of a client.
Chronology
28 April 2023
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Anna Turley
November 2022 – April 2023
Organisation or Person Investigated
Anna Turley (“Ms Turley”)
Matter(s) Investigated
Whether Ms Turley conducted unregistered consultant lobbying
Registrar’s Decision
Based on detailed information and supporting evidence provided, Ms Turley is not an unregistered consultant lobbyist.
Summary of Rationale for Decision
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act (“the Act”) there is an exception for those with a business consisting mainly of non-lobbying activities; and where the communication is incidental to this business (“the incidental exception”).
I apply the incidental exception within narrow parameters, as set out in my guidance. Ms Turley provided detailed responses to my queries, which helped me to ascertain that:
- Her business was mainly non-lobbying activities.
- On balance, they do not appear significant by volume, value, significance to client offering or contribution to non-lobbying activities.
I have provided advice to Ms Turley regarding registration in future, if needed.
Chronology
14 April 2023
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Inflect Partners Limited
March 2023
Organisation or Person Investigated
Inflect Partners Limited (“Inflect”)
Matter(s) Investigated
Whether Inflect conducted unregistered consultant lobbying
Registrar’s Decision
Based on substantive and comprehensive assurances given, Inflect has not conducted unregistered consultant lobbying.
Summary of Rationale for Decision
The communications with government ministers were not ‘on behalf of a client’, which is one of the tests in the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’). This is based on assurances from Inflect and provision of relevant communications. Communications were sent in Emily Wallace’s role as Trade Association Forum (“TAF”) CEO, not in her role as Director of Inflect. The email address and branding used was TAF only.
Chronology
21 March 2023
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk
Summary of Investigation – Rt Hon Dr Liam Fox, MP
February to March 2023
Organisation or Person Investigated
Rt Hon Dr Liam Fox, MP (“Dr Fox”)
Matter(s) Investigated
Whether Dr Fox conducted unregistered consultant lobbying
Registrar’s Decision
Dr Fox is not a consultant lobbyist
Summary of Rationale for Decision
Payments to Dr Fox from Bradshaw Advisory Ltd, for his work for the Global Britain Commission were not paid to a VAT registered entity. Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), registration under the Value Added Tax Act 1994 is one of three conditions that define consultant lobbying.
Chronology
17/03/23
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk
Summary of Investigation – Connect Public Affairs Limited
Organisation or Person Investigated
Connect Public Affairs Limited (“Connect PA”)
Matter(s) Investigated
Whether Connect PA submitted an inaccurate Quarterly Information Return (“QIR”).
Registrar’s Decision
Based on substantive and comprehensive assurances given, Connect Public Affairs Limited did not submit an inaccurate QIR.
Summary of Rationale for Decision
Connect PA is registered on the Register of Consultant Lobbyists. One of its clients is the All-Party Parliamentary Group for Healthcare Infrastructure (“the APPG”), which launched a report in October 2022. The APPG was not declared in Connect PA’s October-December 2022 QIR. Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, a single act of consultant lobbying on behalf of a client triggers the need to submit the name of that client in the QIR.
Connect PA provided comprehensive and substantive assurances that no registerable communications took place for the APPG in the October-December quarter. There was a registerable communication in April-June 2022 and this was declared correctly.
Chronology
1/3/23 | Response from Connect PA providing assurances that it made no registerable communications for the APPG in the October to December 2022 quarter. It did make a registerable communication for the APPG in the April-June 2022 quarter, and this was declared correctly. |
7/3/23 | Letter from Registrar thanking Connect PA for their response and concluding that, based on comprehensive assurances given, there was no inaccuracy in their October-December QIR. |
7 March 2023
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Federation of Small Businesses
Organisation or Person Investigated
Federation of Small Businesses (“FSB”)
Matter(s) Investigated
Whether the FSB is a consultant lobbyist
Registrar’s Decision
The FSB is not a consultant lobbyist
Summary of Rationale for Decision
The FSB’s communications with government ministers that the Registrar is aware of are not ‘on behalf of a client’, which is one of the tests in the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’). The Registrar considers that the FSB is expressing a collective view of the organisation as a whole, rather than a view on behalf of a member (client).
Chronology
9 December 2022
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Institute of Directors
October to December 2022
Organisation or Person Investigated
Institute of Directors (“IoD”)
Matter(s) Investigated
Whether the IoD is a consultant lobbyist
Registrar’s Decision
The IoD is not a consultant lobbyist
Summary of Rationale for Decision
The IoD’s communications with government ministers that the Registrar is aware of are not ‘on behalf of a client’, which is one of the tests in the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’). The Registrar considers that the IoD is expressing a collective view of the organisation as a whole, rather than a view on behalf of a member (client).
Chronology
9 December 2022
Office of the Registrar of Consultant Lobbyists
Summary of Investigation – Confederation of British Industry
October to December 2022
Organisation or Person Investigated
Confederation of British Industry (“CBI”)
Matter(s) Investigated
Whether the CBI is a consultant lobbyist
Registrar’s Decision
The CBI is not a consultant lobbyist
Summary of Rationale for Decision
The CBI’s communications with government ministers that the Registrar is aware of are not ‘on behalf of a client’, which is one of the tests in the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’). The Registrar considers that the CBI is expressing a collective view of the organisation as a whole, rather than a view on behalf of a member (client).
Chronology
25 November | Substantive response from CBI regarding their background and speaking for business as a whole; the benefits of membership beyond CBI’s engagement with government; and the CBI’s approach to policy-making. |
9 December | Letter from the Registrar concluding his investigation. |
9 December 2022
Office of the Registrar of Consultant Lobbyists