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

Date	Action
4 May	Item in Politico London Influence newsletter regarding Mr Robertson’s paid work for the Betting and Gaming Council.
5 May	Formal letter from the Registrar 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, Mr Robertson’s work for the Betting and Gaming Council.
9 May	Email response from Mr Robertson confirming he has not undertaken relevant communications.
10 May	Letter from the Registrar requesting further information regarding Mr Robertson’s work for the Betting and Gaming Council and his VAT registration status.
10 May	Email response from Mr Robertson answering all questions raised and confirming that the Betting and Gaming Council payment is to him as an individual and he is not VAT registered.
12 May	Letter from the Registrar concluding his investigation.

12 May

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
3/5/23	Article in The Guardian regarding a letter sent by Mr Davies to the Secretary of State for Culture, Media and Sport on 23 February 2023
4/5/23	Formal letter from the Registrar to Mr Davies giving background on the requirement for registering and asking if his activities fall within the criteria for registration. In particular, but not limited to, representation for Les Ambassadeurs and for work for the National Pawnbroking Association.
4/5/23	Email response from Mr Davies stating he has not carried out paid lobbying.
9/5/23	Letter from the Registrar asking specific questions for a more detailed response.
9/5/23	Email response from Mr Davies answering all questions asked, including that he is not registered for VAT.
12/5/23	Letter from the Registrar concluding the investigation.

12 May 2023

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
11/4/23	Formal letter from the Registrar to Mr Benton giving background on the requirement for registering and asking if his activities fall within the criteria to be registered.
11/4/23	Response from Mr Benton providing assurances that he has not received money for lobbying ministers.
18/4/23	Letter from the Registrar asking more detailed questions regarding the Betting and Gaming All-Party Parliamentary Group and statements reported in The Times article and video of 6 April.
19/4/23	Email from Mr Benton responding to all questions raised on 18 April
28/4/23	Letter from the Registrar concluding his investigation.

28 April 2023

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
30/10/22	Query from journalist whether Protect & Connect should be registered.
1/11/22	Formal letter from the Registrar giving background on the requirement for registering and asking if Protect & Connect’s activities fall within the criteria for registration. In particular, but not limited to, Protect & Connect’s meeting with a DCMS Minister on 1 February 2022 and Ms Turley’s evidence to the Product Security and Telecommunications Infrastructure Bill Committee.
22/11/22	Letter from Ms Turley, giving further information on Protect & Connect, her role as Chair, her communications for Protect & Connect and her VAT registration.
7/12/2022	Letter from the Registrar with a further query regarding VAT registration.
7/12/2022	Email from Ms Turley giving an update on her VAT registration
4/1/2023	Letter from the Registrar stating he is minded-to conclude that some of Ms Turley’s communications for Protect & Connect were consultant lobbying and inviting representations.
25/1/23	Letter from Bates Wells, Ms Turley’s representative, with representations regarding the role; the representative organisation exception; the incidental exception; and VAT registration, which was backdated after the communications.
9/3/23	Letter from the Registrar asking for detailed information on Protect & Connect and on Ms Turley’s wider work beyond the Protect & Connect campaign.
5/4/23	Letter from Bates Wells giving a detailed response to the questions asked on 9 March.
14/4/23	Letter from the Registrar concluding investigation and giving advice to ensure future compliance with the Act.

14 April 2023

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
14/3/23	Formal letter from the Registrar giving background on the requirement for registering and asking if Inflect’s activities fall within the criteria for registration. In particular, but not limited to, Inflect’s work for the TAF and Infrastrata.
14/3/23	Email response from Inflect.
16/3/23	Letter from the Registrar asking for further information on Inflect’s role for TAF.
16/3/23	Response with further information regarding work for TAF.
17/3/23	Email from Office requesting clarification on who ministerial communications are from (TAF or inflect).
17/3/23	Email from Inflect showing the relevant communication was from TAF.
21/3/23	Letter from Registrar concluding the investigation.

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

Date	Action
28/02/23	Formal letter from the Registrar to Dr Fox 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 Global Britain Commission and any of its funders.
09/03/23	Response from Dr Fox regarding his role as Chair of the Global Britain Commission.
14/03/23	Letter from the Registrar, requesting further information.
15/03/23	Response from Dr Fox, including that payment for his work for the Global Britain Commission was not made to a VAT registered entity.
17/03/23	Letter from the Registrar concluding the investigation.

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

Date	Action
18/10/22	Launch of the APPG’s report
28/2/23	Formal letter from the Registrar to Connect PA, enquiring whether an inaccurate QIRs was submitted, with particular reference to the APPG and its report launched in October 2022.

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

office@orcl.gov.uk

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

Date	Action
11 October	Formal letter from the Registrar to the FSB giving background on the requirement for registering; asking if their activities fall within the criteria to be registered; with reference to the FSB’s mission statement on their website ‘We offer our members a wide range of vital business services including advice, financial expertise, support and a powerful voice heard in government.’
24 October	FSB email to request an extension for response.
24 October	ORCL email to confirm the requested extension.
11 November	Substantive response from FSB regarding their structure, breadth of offer and communications.
9 December	Letter from the Registrar concluding his investigation.

9 December 2022

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
11 October	Formal letter from the Registrar to the IoD giving background on the requirement for registering; asking if their activities fall within the criteria to be registered; with reference to the the IoD website stating one of the membership benefits is ‘Be heard. The IoD is its members’ voice to UK government, influencing the debate, shaping the agenda and advocating change through surveys and commissions.’
25 November	Substantive response from IoD regarding its structure, communications, breadth of offer and qualitative research on the value given to different aspects of IoD membership.
9 December	Letter from the Registrar concluding his investigation.

9 December 2022

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk

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

Date	Action
11 October	Formal letter from the Registrar to the CBI giving background on the requirement for registering; asking if their activities fall within the criteria to be registered; with reference to the CBI website stating the first key benefit of membership as ‘By playing an active role in the CBI you can make sure that your views on the action and investment needed by government are reflected. We meet with the most senior politicians and officials every day to put forward the evidence from the business community on where change is needed and steer policy, legislation and spending decisions in a way that work for business. Feed in on the topics that really matter to you.’
21 October	CBI letter to request an extension for response.
25 October	Registrar letter to confirm the requested extension.

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

office@orcl.gov.uk