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Based on information and assurances provided, Hakluyt has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, Hakluyt did not communicate with Ministers on behalf of paying clients. The communications with a Minister of State at the Department of Business and Trade and with the Secretary of State for Business, Energy and Industrial Strategy are therefore not registrable.
Under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”), a registrable communication is made by a VAT registered company or individual communicating with a Minister, Permanent Secretary (or equivalent) on behalf of a paying client.
Chronology
Date
Action
16 July
Evidence from an external source regarding potential consultant lobbying activities.
17 July
Formal letter from the Registrar to Hakluyt giving background on the requirement for registering and asking whether their activities fall within the criteria to be registered with particular reference to, but not limited to, Hakluyt’s meeting of 23 October 2023 with a Minister of State at the Department of Business and Trade and Hakluyt’s meeting on 4 April 2022 with the Secretary of State for Business, Energy and Industrial Strategy.
31 July
Letter from Hakluyt to the Registrar explaining they are familiar with the Act and do not consultant lobby for clients. Further background on the two meetings was provided.
14 August
Letter from the Registrar to Hakluyt requesting further details about the two meetings, attendees, what was discussed and any follow up communications.
28 August
Letter from Hakluyt to the Registrar providing further information in response to the Registrar’s letter.
9 Sept
Letter from the Registrar concluding the investigation and providing advice for ongoing compliance.