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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 – Longevity UK CIC (updated)

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

On 11 November the Registrar concluded that Longevity International undertook unregistered consulting lobbying activities in April 2021. In making representations against the penalty, Longevity International provided information and substantive assurances that resulted in the Registrar granting the appeal against the original decision and concluding that Longevity International did not undertake unregistered consultant lobbying activity 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 notice for a civil penalty was issued. In making representations against this notice, Longevity International provided information and substantive assurances that they had no direct contact with the Secretary of State nor the CMO before, during or after the event. As a result, the Registrar granted the appeal and did not issue a penalty.

Chronology

DateAction
9 AprilThe 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 SeptemberEmail 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 SeptemberORCL email asking whether Collider Health is paid to provide support services to the APPG and whether Collider Health VAT registered.
27 SeptemberEmail 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 NovemberLetter 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 NovemberEmail 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 NovemberLetter 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.

Update to chronology following 11 November

DateAction
11 NovemberRegistrar issues a penalty notice for unregistered consultant lobbying, giving Longevity International 30 days to make representations in writing.
22 NovemberLongevity International sends representations against penalty notice and provides information and substantive assurances that they had no direct contact with the Secretary of State nor the CMO before, during or after the event.
26 NovemberRegistrar writes to Longevity International informing them that he has granted the appeal, will not proceed with the penalty and the case summary will be updated.

26 November

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 – CMEC UK & MENA Limited

September to November 2021

Organisation or Person Investigated

CMEC UK & MENA Limited

Matter(s) Investigated

Whether CMEC UK & MENA Limited is an unregistered consultant lobbyist

Registrar’s Decision

CMEC UK & MENA Limited is not an unregistered consultant lobbyist, based on detailed information and substantive assurances provided.

Summary of Rationale for Decision

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

Chronology

Date Action
16 September Whistleblowing email received, giving information suggesting that CMEC UK & MENA Limited may be an unregistered consultant lobbyist.
17 September Formal letter from the Registrar to CMEC UK & MENA Limited giving background on the requirement for registering and asking if their activities fall within the criteria for registration.
6 October No response having been received, statutory Information Notice from the Registrar, requiring a response to his queries within 30 days.
11 October Response from rradar, solicitors acting for CMEC UK & MENA Limited, saying that their client did not receive the Registrar’s letter of 17 September
14 October Response from rradar that their client is aware of the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), is a not for profit company and does not engage in consultant lobbying.
9 November Letter from the Registrar, requesting more detail in relation to CMEC UK & MENA Limited’s activities, and clarifying that there is no exception for non-profits under the Act,
11 November Letter from rradar giving explicit and substantive assurances on behalf of their client that CMEC has never communicated with ministers or senior civil servants in order to lobby on anyone’s behalf.
15 November Letter from the Registrar closing the investigation.

15 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 – Rt Hon David Cameron

August – October 2021

Organisation or Person Investigated

Rt Hon David Cameron through the Office of David Cameron (“ODC”)

Matter(s) Investigated

Whether Mr Cameron through ODC acted as an unregistered consultant lobbyist, with particular reference to Illumina.

Registrar’s Decision

Based on detailed information that Mr Cameron provided about the business activities he conducts through ODC and on substantive assurances, I conclude that the incidental exception* applies to four communications with Ministers that would otherwise have been registerable. As a result, Mr Cameron through ODC has not acted as an unregistered consultant lobbyist under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”).

* The incidental exception in schedule 1, part 1, section 1 of the Act provides (in part):

A person does not, by reason of making a communication, carry on the business of consultant lobbying if (a) the person carries on a business which consists mainly of non-lobbying activities, and (b) the making of the communication is incidental to the carrying on of those activities.

Summary of Rationale for Decision

During the investigation I considered four communications by Mr Cameron in relation to Illumina, a client of ODC:

  • Forwarding to the Secretary of State for Health and Social Care an invitation from Illumina to speak at the International Summit on Population Genomics (2019)
  • Participation at the International Summit alongside the Executive Chairman of Illumina and the Secretary of State for Health and Social Care (2019)
  • Text message to the Vaccines Minister referencing Illumina (2021)
  • Follow-up meeting with the Vaccines Minister (2021)

I conclude that these communications would constitute registerable consultant lobbying unless the incidental exception applies.

Mr Cameron and ODC provided evidence of ODC’s wider work and as a result of this evidence and substantive assurances from Mr Cameron, I conclude that the incidental exception applies to these communications and that Mr Cameron through ODC has not conducted unregistered consultant lobbying activity.

I note that the definition of lobbying applied by Mr Cameron and ODC appears to differ from the statutory definition and I have advised caution in this regard.

Chronology

Date Action
30 July Media reports regarding Mr Cameron’s work with Illumina and meeting with the Vaccines Minister, following publication of ministerial diaries.
2 August Formal letter from the Registrar to Mr Cameron via ODC giving background on the requirement for registration; asking if his activities in general fall within the criteria to be registered; and in particular with reference to Illumina.
9 August Response from Mr Cameron stating he did not lobby the UK Government on behalf of Illumina; giving information regarding the approval of his role from the Advisory Committee on Business Appointments (ACOBA) in 2017; background to his meeting with the Vaccines Minister and Illumina; giving his view that this meeting was not an act of consultant lobbying and was incidental to his work for Illumina; and sharing articles demonstrating his previous interest in the role of genomic sequencing in virus surveillance.
11 August Letter from Mr Cameron, following an article in The Times regarding a genomics conference in 2019, reiterating that he was not lobbying for Illumina.
11 August Letter from the Registrar, requesting further information regarding communications with Ministers and asking for Mr Cameron to consider his assertion that his lobbying is incidental, in light of the Registrar’s guidance on incidental lobbying.
18 August Letter from Mr Cameron responding to the questions posed on 11 August.
25 August Email from the Registrar asking for further information regarding Mr Cameron’s work for Illumina and his meeting with the Vaccines Minister.
27 August Letter and supplementary information from Mr Cameron in response to questions posed on 25 August.
17 September Letter from the Registrar setting out his preliminary conclusions and inviting Mr Cameron’s response.
1 October Letter from Mr Cameron providing detailed information, evidence and assurances about the volume and nature of the commercial activities that he conducts through ODC.
5 October Further evidence from ODC.
19 October Letter from the Registrar to conclude the investigation and to advise that had the incidental exception not applied, Mr Cameron’s four communications would have constituted consultant lobbying under the terms of the Act. The Registrar noted that the definition of lobbying applied by Mr Cameron and ODC appears to differ from the statutory definition which the Registrar applies in his decisions. The definition in the Act also differs from that applied by ACOBA. The Registrar advised that his decision that the incidental exception applied to the relevant communications was finely balanced in some respects and advised continuing caution in this regard.

19 October 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

Summary of Investigation – The Conservative Party and others

August and September 2021

Organisation or Person Investigated

The Conservative & Unionist Party, The Conservative Foundation Limited, C&UCO
Properties Limited, C&UCO Services Limited, C&UCO Management Limited and any other
company or organisation controlled by The Conservative Party or any of these companies
(“the parties”).

Matter(s) Investigated

Whether the parties are unregistered consultant lobbyists, with particular reference to the
Advisory Board and the Leaders Group.

Registrar’s Decision

Based on the information provided by the parties and on substantive assurances on behalf
of each of the entities, I conclude that they have not been engaged in consultant lobbying
activity.

Summary of Rationale for Decision

The Conservative Party (“the Party”)
The Party falls within the exception in schedule 1, part 1, paragraph 2 of the Transparency of
Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘The Act’):
A person does not carry on the business of consultant lobbying if (a) the person acts
generally as a representative of persons of a particular class or description, (b) the
income of the person derives wholly or mainly from persons of that class or
description, and (c) the making of communications within section 2(3) on behalf of
those persons is no more than an incidental part of that general activity.
Had the exception not applied, it is likely that some of The Conservative Party’s activities
would have been consultant lobbying under the definitions provided in the Act.
The Conservative Party Foundation (‘the Foundation’)
I have no evidence of any activity by the Foundation that might constitute registrable
communications under the Act.
The limited companies
C&UCO Properties Limited is a holding company; C&UCO Services Limited is dormant; and
C&UCO Management Limited has no income.

Chronology

DateAction
July and
August
Media reports suggesting The Conservative Party arranges access to
government Ministers for participants in the Advisory Board
6 August Formal letter from the Registrar to The Conservative Party and the other
parties 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 Advisory Board and the Leaders Group.
17 August Holding response from The Conservative Party, explaining they will respond
on 23 August.
18 AugustEmail from the Registrar to grant an extension to response deadline.
23 August Response providing further information on The Conservative Party and
related entities and expressing the view that the Act’s exception for
representative bodies applies (Schedule 1, Part 1, Paragraph 2).
26 August Letter from the Registrar requesting further information regarding the
Advisory Board and Leaders Group.
3
September
Letter from The Conservative Party providing further detail regarding the
Advisory Board and Leaders Group, with specific reference to their funding
through membership.
6
September
Letter from the Registrar to clarify the legal status of the Conservative
Foundation and its relationship with The Conservative Party; and to ask
which organisation participants in the Advisory Board and Leaders Group
make payments to.
9
September
Letter from The Conservative Party providing further information in response
to the letter 6 September.
13
September
Investigation closure letter from the Registrar with his decision. The
Registrar noted that some of the Conservatives Party’s activities connecting
donors and ministers are likely to have been registerable under the Act if the
exception had not applied and advising caution in case circumstances arise
under which the exception did not apply. It is unlikely that the Foundation
could take advantage of the exception in schedule 1, part 1, paragraph 2 of
the Act.

13 September 2021
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk