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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

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.


July and
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.
Letter from The Conservative Party providing further detail regarding the
Advisory Board and Leaders Group, with specific reference to their funding
through membership.
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.
Letter from The Conservative Party providing further information in response
to the letter 6 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