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Based on assurances and information provided, TGC has not conducted unregistered consultant lobbying in relation to the matter under investigation.
Summary of rationale for decision
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.
Based on substantive written information provided, TGC did not communicate with a Minister, Permanent Secretary (or equivalent) on behalf of its clients.
Chronology
Date
Action
11-01-24
Third party email alleging that TGC had conducted unregistered consultant lobbying.
12-01-24
Formal letter from the Registrar to TGC giving background on the requirement for registering and asking if its activities fall within the criteria to be registered with particular reference to, but not limited to, the Oliver King Foundation.
31-01-24
Follow up letter from the Registrar, following no response to the letter of 12 January.
21-02-24
Statutory Information Notice served on TGC.
25-03-24
Registrar letter to the company used as TGC’s registered address, giving background and asking them to request that TGC contact the Office by 2 April.
02-04-24
Email from TGC to the Registrar confirming they will respond.
03-04-24
Email from Office to TGC providing previous correspondence and giving new deadline for response.
17-04-24
Email to Registrar from TGC apologising for the delay in responding and stating that they have not conducted consultant lobbying.
23-04-24
Email from the Registrar to TGC asking for further information and clarification.
07-05-24
TGC response to Registrar’s letter of 23 April.
08-05-24
Email from Office requesting a response to a question in the Registrar’s letter of 23 April, omitted from the response of 7 May.
15-05-24
TGC response to Registrar, following email of 8 May.
20-05-24
Letter from the Registrar concluding the investigation.