Summary of investigation – Global Counsel Limited (“GCL”)
October 2024 – February 2025
Organisation or person investigated
Global Counsel Limited (“GCL”)
Matter(s) investigated
Whether GCL submitted an inaccurate Quarterly Information Return (“QIR”) to the Registrar.
Registrar’s decision
GCL did not submit inaccurate QIRs in relation to the matter under investigation.
Summary of rationale for decision
Based on substantive and unequivocal written information provided, GCL has not submitted inaccurate QIRs in relation to the matter under investigation.
Under the Transparency of Lobbying Non-Party Campaigning and Trade Union Administration Act (“The Act”), registrants must submit a QIR to the Registrar every quarter giving client information in relation to consultant lobbying, or a nil return.
In January, March and June 2023, Global Counsel met with a minister and this was not declared in GCL’s QIRs. Based on assurances from GCL, the Qatari Freezone Authority (“QFZA”) was a client of Global Counsel MENA, not of GCL. Global Counsel MENA is a subsidiary of GCL and a separate legal entity. It cannot register as a consultant lobbyist as it is not UK VAT registered. Based on assurances provided, GCL did not receive any payments from QFZA, directly or indirectly, for the periods investigated. Under 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 |
| 25/01/23 | Meeting between Minister of State, Department for International Trade and Global Counsel. |
| 22/03/23 | Meeting between the Minister of State, Department for Business and Trade and Global Counsel. |
| 13/06/23 | Meeting between the Minister of State, Department for Business and Trade the Qatari Freezone Authority (“QFZA”). The briefing states that this was an introductory meeting requested by Global Counsel. The meeting was attended by Global Counsel MENA Regional Director. |
| 17/10/24 | Letter from Spotlight on Corruption, to the Registrar, calling for an investigation and providing background and a link to a press report. |
| 21/10/24 | Formal letter from the Registrar giving background on the requirement for QIRs and asking if GCL declared their clients appropriately with particular reference to, but not limited to, QFZA. |
| 29/10/24 | Letter from GCL to the Registrar stating that QFZA is a client of Global Counsel MENA, a non-UK subsidiary of GCL and therefore not UK VAT registered. |
| 12/11/24 | Letter from the Registrar to GCL with additional questions. |
| 15/11/24 | Letter from GCL to the Registrar providing responses. |
| 26/11/24 | Letter from the Registrar stating he is considering the response and requesting information regarding a further potential inaccuracy regarding SHEIN, reported in The Guardian. |
| 26/11/24 | Letter from GCL to the Registrar responding that no registrable communications were made for SHEIN. |
| 21/02/25 | Letter from the Registrar to GCL, concluding the investigation and providing advice on transparency regarding which legal entity is being represented in communications. |
21 February 2025
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Brooks Newmark & Co Ltd
November 2023 – February 2024
Organisation or person investigated
Brooks Newmark & Co Ltd
Matter(s) investigated
Whether Brooks Newmark or Brooks Newmark & Co Ltd (“Mr Newmark”) conducted unregistered consultant lobbying.
Registrar’s decision
Based on third-party assurances provided, Mr Newmark has not conducted unregistered consultant lobbying in relation to the matter under investigation, whether as an individual or through a company.
Summary of rationale for decision
Third-party assurances were provided that neither Mr Newmark nor Brooks Newmark & Co Ltd are or were 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
| 12 Dec 2023 | Response from Carter-Ruck, Mr Newmark’s representative, explaining that neither Mr Newmark nor his business are or were VAT-registered. |
| 15 Dec 2023 | Letter from the Registrar with a further query regarding payments. |
| 15 Jan 2024 | Letter from Carter-Ruck providing further background. |
| 17 Jan 2024 | Letter from the Registrar with a further query regarding VAT registration. |
| 1 Feb 2024 | Further letter from the Registrar, following no response. |
| 1 Feb 2024 | Letter from Shipleys, chartered accountants, via Carter-Ruck, explaining that payments made to Brooks Newmark & Co Ltd from an overseas company did not trigger a requirement for UK VAT registration. |
| 8 Feb 2024 | Letter from the Registrar concluding his investigation. |
13 February 2024
Office of the Registrar of Consultant Lobbyists
Summary of investigation – Tulchan Communications LLP (‘Tulchan’)
Organisation or Person Investigated
Tulchan Communications LLP (‘Tulchan’)
Matter(s) Investigated
Whether Tulchan submitted an inaccurate Quarterly Information
Return under the terms of the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’), in particular whether they omitted a client from their return for the period April to June 2020.
Registrar’s Decision
Based on the information provided, and no evidence to the contrary, Tulchan did not conduct undeclared consultant lobbying as defined by the Act in the period under enquiry.
Summary of Rationale for Decision
Tulchan provided a timeline of the activities of its Managing Partner, Lord Feldman, in relation to Tulchan, the Department for Health & Social Care (‘DHSC’) and Oxford Nanopore Technologies Limited (‘Oxford Nanopore’) from March 2020 to June 2020. Irrespective of Lord Feldman’s status with Tulchan in this period, the Registrar has no evidence of activity that constituted consultant lobbying within the definition in section 2 of the Act (i.e. communication by the consultant with a Minister, Permanent Secretary or equivalent, on behalf of a paying client).
Oxford Nanopore was not a client of Tulchan in the period of Lord Feldman’s association with DHSC. They subsequently became a client of Tulchan and the Registrar has received a comprehensive assurance dated 18 November 2020 that no consultant lobbying had been conducted by Tulchan on behalf of Oxford Nanopore as at that date.
Chronology
| Date | Action |
| 16 November 2020 | Query from a journalist to ORCL following reports that Lord Feldman, Tulchan Managing Partner, met with ministers and Oxford Nanopore on 1 April and on 13 May 2020. The journalist asked why Oxford Nanopore was not listed as a Tulchan client in their Quarterly Information Return. |
| 16 November 2020 | Formal letter from Registrar to Tulchan to enquire whether an inaccurate Quarterly Information Return had been submitted. |
| 18 November 2020 | Response from Tulchan providing a comprehensive assurance about the accuracy of its Quarterly Information Returns and setting out a timeline of the activities of Lord Feldman in relation to Tulchan, the Department for Health & Social Care (‘DHSC’) and Oxford Nanopore from March 2020 to June 2020. |
25 November 2020
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk