"For your eyes only" correspondence, regarding complaints about MPs who failed to declare interests and who have multiple identities, with the Parliamentary Commissioner for Standards.
Escalating my complaints for public review. Challenging the disproportionate use of "for your eyes only" to demand confidentiality when that is not in the public's best interest.
This post contains correspondence between myself and the Parliamentary Commissioner for Standards, relating to my complaints about Members of Parliament who fail to declare all their interests (at the time of the dated correspondence) and about Members of Parliament with multiple identities registered in Companies House.
The development of these complaints can best be followed by reading from the first email, sent 17 April 2023, at the bottom of the page, up to this response from Daniel Greenberg, Parliamentary Commissioner for Standards.
Our Reference PCS1622 Private and Confidential
Standards Commissioner <standardscommissioner@parliament.uk>
To: alisonwright45@btinternet.com;
10/11/2023 13:07
Dear Ms Wright,
Thank you for your recent submission to the Commissioner, I have been asked to reply.
As has been previously explained in correspondence from this office, any questions relating to the identity of people registered with Companies House, would be a question for them to respond to. If you are concerned about the various identities registered as Mr Hollinrake on the Companies House website, you would need to raise this directly with Companies House in the first instance. Similarly, we have also explained that the Commissioner does not have the power to investigate allegations of fraud. If you have any concerns about fraud, please forward these to the Police.
In respect of the your allegations related to Mr Hollinrake’s interests, although you have included a large quantity of information and broadly referenced the Rules of Conduct, you have not specifically identified in your allegations which Rules of Conduct you believe may have been breached and how.
I should remind you that before considering whether to open in inquiry the Commissioner requires
The name and address of the individual making the allegation (which you have provided).
A written allegation (either in email or hard copy) stating which rule you think has been breached and how [my emphasis]
Sufficient evidence to justify beginning an inquiry
In my email to you on 14 June 2023 (PCS285), I was explained that the current Rules of Conduct only came into effect from the 1 March 2023. Allegations about breaches of the Rules of Conduct regarding the Registration of interests before 1 March 2023, would be assessed against the rules that were in place at the relevant time. Please see the webpage that contains links to the current and previous Codes of Conduct for Members and Guide to the Rules here. https://www.parliament.uk/business/publications/commons/hoc-code-of-conduct/
It might be helpful to reiterate that the details of what Members should Register under different categories is provided in Chapter 1 of the Guide to the Rules. In this Chapter, in each of the current and previous publications of the Code, you will find details for registering the various interests, including the thresholds for registration and the requirements for registration.
Further to this, a number of the interests that you have included in your complaint ceased before 1 March 2023. Many of these interests were subject to Category 8 registration, paragraph 55(b) of the 2019 Code of Conduct, states that a Member must declare:
Any other interest, if the Member considers that it might reasonably be thought by others to influence his or her actions or words as a Member in the same way as a financial interest. This might include an unpaid employment or directorship, or directorship of a company not currently trading, non-practising membership of a profession, or a fund established to defray legal costs arising out of the Member’s work, but from which no benefit has yet been received.
Therefore, those interests are registered at the Member’s discretion. It would not be proportionate for the Commissioner to start an inquiry unless a complainant provided evidence that an interest, which had not been registered, had influenced the MPs actions or words.
Based on all the information you have provided in your email, and for the reasons set out above, I do not believe the Commissioner would open a formal inquiry into your complaint.
Yours sincerely
Diane Hedditch
Investigations and Complaints Officer
Office of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
I made a complaint, several pages long, about Kevin Hollinrake who is the incumbent MP responsible for Companies House. In place of the long letter, the complaint is described in this article:
Private & Confidential
Standards Commissioner <standardscommissioner@parliament.uk>
To: Alison Wright;
13/07/2023 16:16
Dear Ms Wright
Thank you for your emails.
As both I and my colleague previously explained any concerns about fraud are not within the remit of the Commissioner and will not be considered. It is open to you to raise these points with Companies House or the Police. We will no longer be responding to complaints of fraud or multiple identities.
The Commissioner may only consider whether a Member of Parliament has breached the Code of Conduct. The Code of Conduct is agreed by the House and it is for the House to make amendments. I will however draw your concerns about the differences between the House of Lords Code of Conduct and the House of Commons Code of Conduct to the attention of the Commissioner.
Whilst I note your concerns about the 2019 Code of Conduct, any amendments are not retrospective.
Finally, in accordance with Standing Order No.150, it is for the Commissioner to determine whether to start an inquiry and how he resolves a complaint.
As you are aware, the Commissioner is considering the following complaints that you have made:
The Rt Hon. Victoria Prentis MP
Ian Murray MP
The Rt Hon. Johnny Mercer MP
The Rt Hon. Penny Mordant MP
Rachel Maskell MP
Alex Sobel MP
The Rt Hon. Sir Clive Lewis MP
Lloyd Russell Moyle MP
The Commissioner will contact you once a decision has been made on whether he intends to start an inquiry into these members.
Yours sincerely
Beverley
From: Alison Wright <alisonwright45@btinternet.com>
Sent: 08 July 2023 09:15
To: Standards Commissioner <standardscommissioner@parliament.uk>
Subject: Fwd: Re: Private & Confidential Ref: PCS285 / PCS843 / PCS844 / PCS845 / PCS846 / PCS847 / PCS848 / PCS849 / PCS850 / PCS851 / PCS852 / PCS859
Post script to my letter below.
Considering the gravity of the issue surrounding synthetic identities and the potential breaches of the Companies Act, it may be appropriate to explore the possibility of seeking a judicial review or pursuing other legal mechanisms to examine the legality of synthetic identities and their impact on corporate governance and accountability. A judicial review could provide a platform for a thorough examination of the matter by independent legal authorities, ensuring that the legality of synthetic identities is thoroughly scrutinized and evaluated. Such a review would help establish legal clarity, reinforce the importance of transparency and integrity in corporate affairs, and potentially lead to necessary reforms or amendments to address any shortcomings in the existing legislative framework. Requesting a judicial review would demonstrate a commitment to upholding the rule of law, protecting the public interest, and ensuring that our corporate governance system operates with the highest standards of accountability and fairness.
Yours sincerely,
Alison Wright
------ Original Message ------
From: "Alison Wright" <alisonwright45@btinternet.com>
To: "Standards Commissioner" <standardscommissioner@parliament.uk>
Sent: Saturday, 8 Jul, 23 At 07:47
Subject: Re: Private & Confidential Ref: PCS285 / PCS843 / PCS844 / PCS845 / PCS846 / PCS847 / PCS848 / PCS849 / PCS850 / PCS851 / PCS852 / PCS859Dear Ms Allen and the Commissioner for Standards,
Thank you for your response to my previous correspondence dated 6 July. I appreciate your attention to each of the complaints raised. However, I would like to express my continued concern regarding the approach taken in relation to the registration of certain interests.
It is worth noting that the Code of Conduct for Members of the House of Lords sets a higher standard for transparency and accountability compared to the Code applicable to Members of Parliament. The Lords' Code explicitly requires the registration of all directorships and positions as persons with significant control, leaving no room for discretionary judgment by the Member. This robust approach ensures that any potential conflicts of interest are identified and addressed appropriately.
In contrast, the Code of Conduct applicable to Members of Parliament, particularly the 2019 version, allowed for discretion in registering unremunerated directorships or interests that were deemed to have no influence on their actions or words as a Member. While changes to the Code in March 2023 have introduced amendments, it is essential to recognize that the previous version fell short in terms of promoting transparency and preventing conflicts of interest.
Given the weaker requirements in the Parliamentary Code, it becomes even more important to conduct thorough investigations into any potential breaches that have been brought to your attention. Sections 175 and 177 of the Companies Act clearly outline the duties and responsibilities of directors, including the duty to avoid conflicts of interest and the duty to declare interests in proposed transactions or arrangements. These provisions are crucial in ensuring transparency, accountability, and integrity in the conduct of directors' affairs.
Being a Member of Parliament is indeed an arrangement with the public, one that requires utmost transparency and disclosure of interests. The public has entrusted Members with their representation and entrusted them with upholding the highest standards of integrity. Therefore, it is imperative that Members fulfill their obligations under the Companies Act and declare any interests that may present conflicts or potential conflicts of interest.
By disclosing such interests, Members can demonstrate their commitment to transparency and the avoidance of any impropriety. This not only upholds the principles enshrined in the Companies Act but also fosters trust and confidence in the democratic process. This legal requirement should prevail over any discretionary clauses in the Code of Conduct.
Therefore, I respectfully request that you reconsider your decision and initiate a comprehensive investigation into the past interests mentioned in my previous communication, irrespective of their current status. By conducting a thorough review of financial records and transactions, including the disclosure of all directorships and positions as persons with significant control, we can ensure that the highest standards of transparency, accountability, and integrity are upheld within the parliamentary system.
Thank you for your attention to this matter. I trust that you will give due consideration to the disparity between the Lords' Code and the Parliamentary Code, and take appropriate actions to address these concerns. I look forward to your response and any further actions taken to ensure the adherence to ethical standards and the avoidance of conflicts of interest.
Yours sincerely,
Alison Wright
------ Original Message ------
From: "Standards Commissioner" <standardscommissioner@parliament.uk>
To: "Alison Wright" <alisonwright45@btinternet.com>
Sent: Thursday, 6 Jul, 23 At 15:50
Subject: Private & Confidential Ref: PCS285 / PCS843 / PCS844 / PCS845 / PCS846 / PCS847 / PCS848 / PCS849 / PCS850 / PCS851 / PCS852 / PCS859Dear Ms Wright
Thank you for your email received 29 June 2023. For ease of reference, I will consider each complaint in turn.
The Rt Hon. Victoria Prentis MP (PCS285)
A number of the interests that you have referred ceased before 1 March 2023. These interests were subject to Category 8, paragraph 55(b) of the 2019 Code of Conduct, which stated that a Member must declare:
Any other interest, if the Member considers that it might reasonably be thought by others to influence his or her actions or words as a Member in the same way as a financial interest. This might include an unpaid employment or directorship, or directorship of a company not currently trading, non-practising membership of a profession, or a fund established to defray legal costs arising out of the Member’s work, but from which no benefit has yet been received.
Therefore, those interests are registered at the Member’s discretion and it would not be proportionate to start an inquiry.
With respect to The Incorporated Council of Law Reporting for England and Wales as I have previously explained, the 2019 Code did not require Members to register unremunerated directorships or where the shareholding was less than 15% or valued under £70,000. In view of this Ms Prentis was only required to register this interest if she believed that the interest met the test of relevance; that it might reasonably be thought by others to influence her actions or words as a Member. The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision.
Steven Reed MP (PCS843)
Mr Reed is no longer a Director of Labour Together Limited, his directorship ended on 16 March 2023. As the interest would have been subject to the test of relevance up to 1 March 2023 and he then resigned shortly afterwards, and there is no evidence that Mr Reed benefited financially from the directorship, it would not be proportionate to undertake an inquiry into this matter.
Ian Murry MP (PCS844)
Commonwealth Parliamentary Association (United Kingdom)
IM Campaigns Ltd
With respect to the above three interests, as I have stated above, the 2019 Code did not require Members to register unremunerated directorships. In view of this Mr Murray was only required to register this interest if he believed that the interest met the test of relevance; that it might reasonably be thought by others to influence his actions or words as a Member. The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision.
100MPH Events Limited
With respect to this interest, as I have stated above, the 2019 Code did not require Members to register unremunerated directorships (It is noted that Mr Murray has declared his shares in this company). In view of this Mr Murray was only required to register this interest if he believed that the interest met the test of relevance; that it might reasonably be thought by others to influence his actions or words as a Member. The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision.
Preet Gill MP (PCS845)
The interests that you have referred to ended in 2020, therefore it would not be proportionate to investigate these matters. Additionally, it should be noted that these interests would be subject to the test of relevance set out in the 2019 Code outlined above and therefore at the discretion of the Member.
Anneliese Dodds MP (PCS846)
The interest that you have referred to ended in 2022, therefore it would not be proportionate to investigate these matters. Additionally, it should be noted that these interests would be subject to the test of relevance set out in the 2019 Code outlined above, and therefore at the discretion of the Member.
The Rt Hon. Jeremy Hunt MP (PCS847)
The interests that you have referred to ended in 2022, therefore it would not be proportionate to investigate these matters. Additionally, it should be noted that these interests would be subject to the test of relevance set out in the 2019 Code outlined above and therefore at the discretion of the Member.
The Rt Hon. Suella Braverman MP (PCS848)
The interest that you have referred to ended in 2022, therefore it would not be proportionate to investigate these matters. Additionally, it should be noted that these interests would be subject to the test of relevance set out in the 2019 Code outlined above, and therefore at the discretion of the Member.
The Rt Hon. Michael Gove MP (PCS849)
You have provided no evidence of a breach of the Code of Conduct.
The Rt Hon. Penny Mordant MP (PCS850)
With respect to this interest, as I have stated above, the 2019 Code did not require Members to register unremunerated directorships. In view of this Ms Mordant was only required to register this interest if she believed that the interest met the test of relevance; that it might reasonably be thought by others to influence her actions or words as a Member. The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision.
The Rt Hon. Robert Jenrick MP (PCS851)
You have provided no evidence of a breach of the Code of Conduct.
The Rt Hon. Johnny Mercer MP (PCS852)
With respect to this interest, as I have stated above, the 2019 Code did not require Members to register unremunerated directorships (It is noted that Mr Mercer has declared his shares in this company). In view of this Mr Mercer was only required to register this interest if he believed that the interest met the test of relevance; that it might reasonably be thought by others to influence his actions or words as a Member. The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision.
Katy Bourne (PCS859)
The Police and Crime Commissioner does not fall under the remit of the Parliamentary Commissioner for Standards.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints ManagerOffice of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AAPrivate & Confidential Ref: PCS60 / PCS301 / PCS285 / PCS422 / PCS423
Standards Commissioner <standardscommissioner@parliament.uk>
To: Alison Wright;
28/06/2023 16:15
Re: 2023-06-14 Email to Alison Wright - Our Reference PCS285
Private and Confidential.pdf
2023-06-08 Letter from the Parliamentary Commissioner for Standards.pdf
2023-06-28 Letter from the Parliamentary Commissioner for Standards.pdf
3 Attachments
Highly Restricted: Parliamentary Commissioner for Standards
Dear Ms Wright
Thank you for your email received 27 June 2023 requesting an update on your complaints.
From our records, it appears that you have made the following complaints:
The Rt Hon. Rishi Sunak MP and his wife Akshata Murty (Ref: PCS60). Complaints received - 17 April 2023 / 21 April 2023 / 27 April 2023 / 4 May 2023
Identity Fraud,
On 27 April 2023 I wrote to you explaining that this was a criminal matter and was not something the Commissioner was empowered to investigate. Any concerns you may have about criminal matters should be directed to the relevant authorities.
Failure to Register Ms Murty’s shareholdings
On 28 April 2023 I emailed you to explain that, under the Rules of Conduct and Guide to the Rules for Members’ of Parliament, the Rt Hon Rishi Sunak MP does not have a duty to register his wife’s financial interests, unless he holds shares with his wife jointly or on behalf of his wife (Category 7).
Failure to Register an Interest
Further to the complaint about the failure to register an interest in the company C&UCO Properties Ltd. the Commissioner wrote to you on 8 June 2023 about this matter. I have enclosed a copy of the letter for information.
The Rt Hon. Oliver Dowden MP (Ref: PCS301) Complaint received 13 June 2023
Please find attached a letter from the Parliamentary Commissioner for Standards outlining his decision in this matter.
The Rt Hon. Victoria Prentis MP (Ref: PCS285) Complaint received 19 June 2023
My colleague responded to this matter in an email dated 14 June 2023. I have attached the email for your information.
The Rt Hon. Boris Johnson (Ref: PCS422) Complaint received 27 June 2023
I have considered the complaint that you have made about potential political interference in the BBC’s broadcasting operations, however, as you are aware, the Commissioner may only consider a complaint where there has been a breach of the Rules of conduct and there is sufficient evidence to justify beginning an enquiry. Whilst I note your concerns, they are based on supposition not evidence, therefore the Commissioner will not be starting an inquiry into this matter. Furthermore, given Mr Johnson is no longer a Member of Parliament it would not be proportionate to start an investigation.
Lloyd Russell-Moyle (Ref: PCS 423) Complaint received 27 June 2023
All interests that started/ended prior to Mr Russell-Moyle’s election in 2017 are not relevant for the Code. The Charity links that you have raised have been registered.
Friends of UKYP Limited
The 2019 Code did not require Members to register unremunerated directorships or where the shareholding was less than 15% or valued under £70,000. In view of this Mr Russell-Moyle was only required to register this interest if he believed that the interest met the test of relevance; that it might reasonably be thought by others to influence his actions or words as a Member.
Whilst this requirement changed when the 2023 Code was implemented, I note that, at that point the Company was in the process of dissolution. It is my view therefore that it would not be proportionate to investigate this matter.
Transform Labour Limited
The Crew Club
Arlington Mews Management Company Limited
With respect to the above three interests, as I have stated above, the 2019 Code did not require Members to register unremunerated directorships or where the shareholding was less than 15% or valued under £70,000. In view of this Mr Russell-Moyle was only required to register this interest if he believed that the interest met the test of relevance; that it might reasonably be thought by others to influence his actions or words as a Member.
The Commissioner will consider the matter of registration following the changes to the Code in March 2023 and notify you of his decision. The Commissioner will also consider the points that you have raised about the Rt Hon. Sir Clive Lewis MP, Rachel Maskell MP and Alex Sobel MP.
Finally, I would like to reiterate that any concerns you have about the accuracy of the records held by Companies House should be forwarded to them directly. As you have been informed on several occasions, if you have any concerns about fraud, please forward these to the Police. The Commissioner does not have the power to investigate allegations of fraud and will not be investigating these matters. We will not respond to any further allegations about fraud.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints Manager
Office of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
Fwd: Re: Private & Confidential ref: PCS60
Alison Wright <alisonwright45@btinternet.com>
To: standardscommissioner@parliament.uk;
20/06/2023 13:16
Dear Commissioner for Standards,
I hope this letter finds you well. I am writing to express my concerns regarding what I perceive as a potential loophole in the rules governing the disclosure of financial interests by Members of Parliament. Specifically, my concerns relate to the disclosure requirements surrounding directorships of spouses and the registration of significant control without shareholdings or voting rights.
Upon reviewing the response you provided in relation to my previous inquiry, it was noted that under the current Rules of Conduct and Guide to the Rules for Members of Parliament, the Rt Hon Rishi Sunak MP was not obligated to register his wife's directorship of N&L Acquisitions. This raises the question of whether the current rules adequately address the need for transparency and accountability in such instances.
According to Category 7 of the Code of Conduct for Members' Financial Interests, Members are required to register shareholdings or share options held either by themselves or with or on behalf of their spouse, partner, or dependent children. However, the omission of directorships from this category potentially creates a loophole, as the declaration of significant control appears to be contingent on the possession of shares or voting rights.
While I acknowledge the complexities involved in formulating comprehensive regulations, it is crucial that the disclosure requirements effectively capture the full extent of a Member's financial interests. Failing to address situations where significant control is exerted through directorships without shareholdings or voting rights could undermine the principles of transparency and accountability that these rules aim to uphold.
I respectfully urge you to consider reviewing the current rules to ensure that they encompass the disclosure of directorships held by Members' spouses, particularly when those directorships are indicative of significant control. By doing so, we can help ensure that the disclosure requirements align with the spirit of transparency and accountability that underpin our democratic institutions.
Thank you for your attention to this matter. I trust that you will carefully consider my concerns, and I look forward to any insights or actions that may arise from this correspondence. If further clarification or supporting information is required, please do not hesitate to contact me.
Yours sincerely,
Alison Wright
------ Original Message ------
From: "Alison Wright" <alisonwright45@btinternet.com>
To: "Standards Commissioner" <standardscommissioner@parliament.uk>
Sent: Monday, 19 Jun, 23 At 12:40
Subject: Re: Private & Confidential ref: PCS60Dear Beverley and the Commissioner of Standards,
I request that you reconsider my complaint that he is and has been committing synthetic identity fraud to conceal interests which he has not openly and frankly disclosed; a) person with significant control of C&UCO Properties Limited and b) his wife's recent directorship of N&L Acquisitions Limited. I allege that he has directly breached the intention of Paragraph 14 of the Rules of Conduct, "Members shall fulfil conscientiously the requirements of the House in respect of the registration of interests in the Register of Members’ Financial Interests. They shall always be open and frank in drawing attention to any relevant interest in any proceeding of the House or its Committees, and in any communications with Ministers, Members, public officials or public office holders."
The Companies House register has records for 3 separate identities for Rishi Sunak, the system treats him as 3 distinct people enabling him to access banking and trade accounts as three people, not one. This corrupts audits and due diligence for anti-money laundering and terrorism financing. This simple fraud takes advantage of Companies House's weak de-duplication processes.
Establishing duplicate/synthetic identities in Companies House breaches the following rules:
Breach of Paragraph 10: Members are expected to observe the rules and associated resolutions of the House. Establishing duplicate identities undermines the integrity of the registration system and the rules governing Members' conduct. Synthetic identities corrupt audits and due diligence for anti-money laundering and terrorism financing.
Breach of Paragraph 11: Members shall base their conduct on the public interest, avoid conflicts between personal and public interests, and resolve any conflicts in favour of the public interest. Establishing duplicate identities can create conflicts of interest, conceal interests and undermine the public interest.
Breach of Paragraph 14: Members shall conscientiously fulfil the requirements of the House regarding the registration of interests in the Register of Members' Financial Interests. Failure to register interests associated with duplicate identities directly breaches this rule.
Breach of Paragraph 17: Members shall never undertake any action that would significantly damage the reputation and integrity of the House of Commons as a whole or its Members. Establishing duplicate identities in Companies House, particularly as the Prime Minister, undermines the integrity of the registration system, our financial system and damages the reputation of the House.
If these allegations are proven true, the described actions, including the failure to declare interests and involvement in synthetic identity deception, may potentially be classified as fraudulent activity.
To demonstrate how the situation described above, aligns with the definitions of fraud under the Fraud Act 2006 referencing the relevant sections:
Fraud by false representation (Section 2):
The creation of synthetic identities and failure to disclose relevant information can constitute fraud by false representation. By submitting inaccurate or incomplete details to Companies House, individuals misrepresent their true identity, affiliations, and potential conflicts of interest. This misrepresentation can deceive stakeholders, such as banks, auditors, and businesses, who rely on accurate information for risk assessments and compliance checks.
Fraud by failing to disclose information (Section 3):
Failure to disclose interests held in synthetic identities falls under fraud by failing to disclose information. Individuals have a legal obligation to disclose their interests to Companies House and the public, as outlined in the Companies Act 2006. By intentionally omitting these interests, individuals withhold material information that could influence the assessment of their background, potential conflicts, and their ability to act in the best interests of the public.
Fraud by abuse of position (Section 4):
The failure to disclose interests and the use of multiple identities can also be considered fraud by abuse of position. Public officials, such as Members of Parliament, hold positions of trust and responsibility. By concealing their interests and utilising synthetic identities, these individuals abuse their positions for personal gain or to further undisclosed agendas. This constitutes an abuse of the trust placed in them by the public.
In summary, the actions described in the text align with the definitions of fraud under sections 2, 3, and 4 of the Fraud Act 2006. The creation of synthetic identities, failure to disclose information, and abuse of position can all be seen as fraudulent behaviours that undermine transparency, integrity, and public trust.
To determine the extent of the breach, identify potential violations of additional rules, and investigate the matter thoroughly, it is crucial to gather further evidence, conduct interviews, and examine relevant records. The investigation aims to establish the facts, determine the full extent of the breach, identify any other potential violations, and ascertain whether fraud has occurred.
Impartial Investigation: I have observed and reported several breaches involving multiple identities to the police, Serious Fraud Office, and Action Fraud for investigation. There is a prolific use of synthetic identities by politicians, public officials, including Police and Crime Commissioners, and other directors, which are not being adequately investigated. On the balance of probability, it appears that the investigation into synthetic identity fraud is being hindered by individuals who themselves hold multiple identities. To address my concerns about potential biases or conflicts, it is crucial to ensure that the investigation is conducted by individuals who have not registered multiple identities in Companies House. This will guarantee an unbiased and fair examination of the matter, instilling confidence in the investigative process.
Yours sincerely,
Alison Wright
Re: Private & Confidential Ref: PCS60
Alison Wright <alisonwright45@btinternet.com>
To: Standards Commissioner;
09/06/2023 15:35
Dear Beverley,
Can you advise me what steps I can anticipate that the Commissioner will take and within what timeframe? Also, whether he will require Oliver Dowden to declare his undeclared interest in C&UCO Properties, also.
I've finally followed the advice your office gave me, to write to Sir Laurie. Please will you provide me with an email address to which I can send it?
Thanks for your help.
With best regards,
Alison
Alison Wright
Our Reference PCS285 Private and Confidential
SC
Standards Commissioner <standardscommissioner@parliament.uk>
To: alisonwright45@btinternet.com;
14/06/2023 15:07
Dear Alison Wright,
Thank you for your email to the Commissioner, I have been asked to reply.
I should start by explaining that any questions relating to the identity of people registered with Companies House would be a question for them to respond to. You have provided information that Ms Victoria Prentice has two entries on the Companies House website, one appears to relate to her directorship with a company before she was an MP, the second refers to her directorship roles since she became an MP. If you are concerned that the third name identified is also Ms Victoria Prentis MP, you would need to raise this directly with Companies House in the first instance.
In respect of the Registration of Interests, the Rules of Conduct you have referenced in your complaint only came into effect from the 1 March 2023. Allegations about breaches of the Rules of Conduct regarding the Registration of interests before 1 March 2023, would be assessed against the rules that were in place at the relevant time. I have provided a link to the previous Code of Conduct for Members and Guide to the Rules here.
https://publications.parliament.uk/pa/cm201719/cmcode/1882/188201.htm
It might be helpful to note the details of what Members should Register under different categories, provided in Chapter 1 of the Guide to the Rules. Category 1 includes details for registering paid Employment and Earnings, and Category 8 includes details for registering any Miscellaneous interests. (see below).
I should say at this point that, based on the information you have provided in your email, I do not believe the Commissioner would open a formal inquiry into your complaint.
Category 1: Employment and earnings
Threshold for registration
6.Members must register, subject to the paragraphs below, individual payments of more than £100 which they receive for any employment outside the House. They must also register individual payments of £100 or less once they have received a total of over £300 in payments of whatever size from the same source in a calendar year.
Requirements for registration
7.Under this category Members must register:
Any of the following received as a director or employee or earned in any other capacity:
a)Salaries, fees and payments in kind; gifts received in recognition of services performed;
b)Taxable expenses, allowances and benefits such as company cars;
c)Redundancy and ex gratia payments;
d)Income as a member of Lloyd’s; and13
e)Payments for opinion surveys (unless they fall below the registration threshold).
8.Members should not register under this category:
a)Earnings received as a Member, Minister or select committee Chair in the UK Parliament;
b)Unremunerated directorships (unless associated with, or a subsidiary of, a company or group of which the Member is a remunerated director);14
c)Directorships of companies not currently trading;15
d)Earnings of the Member’s spouse, partner or family members;
e)Income received by way of dividends; and
f)Pension payments.
9.Members are required to provide the following information:
a)Whether the Member is a director of the organisation;
b)The name and address of the payer16 and a brief description of their business (if not self evident);
c)The name and address of any client to whom the Member has personally provided services,17 if different from the payer, and a brief description of their business (if not self evident);
d)The size of the payment received, and the nature and value of any taxable benefits and any payments in kind. (Earnings should be given gross, i.e. before tax or other deductions, wherever possible. Fees should be given before the addition of VAT.);
e)The nature of the work involved, and the number of hours’ work to which each payment relates;
f)The date when the payment was received (or, if not yet received, the date when the work was completed); and
g)Confirmation that the Member has not engaged in paid advocacy.18
Members who ceased to hold Ministerial office within the previous two years
10.Such Members should state, additionally, whether they sought the advice of the Advisory Committee on Business Appointments in respect of this employment.
Payments made to other people or organisations
11.A Member who receives payment for his or her work and then donates it to another person, or to a charitable or community organisation, must make their registration in the usual way but may note the donation in their Register entry.
12.A Member who does not receive payment for his or her work in a recognisable form or at all, because it is made to another person or organisation, should nevertheless register the payment within 28 days of its receipt by that other person or organisation. This applies only to payments which, if made direct to the Member, would have required registration under this category.
Contractual agreements for twelve months or more
13.A Member who has a contractual agreement for twelve months or more and receives regular payments may choose, instead of registering each payment as it is received, to register such payments in advance, provided that he or she afterwards registers within 28 days any variation to the information already provided. The initial information to be provided is as set out in paragraph 9 above, except that instead of the information required under subparagraphs (d) and (f), the Member should provide:
h)The agreed start, and (if any) end dates for the contract;
i)The agreed payments, including any taxable benefits and payments in kind;
j)The dates agreed for those payments.
Registering ad hoc payments in advance
14.A Member who has undertaken work and agreed the terms of payment need not wait to receive that payment before making a Register entry, but may register the work at any time between completing the work and 28 days after receiving any payment. In such cases, the Member should provide the date when the work was completed.
Category 8: Miscellaneous
Requirements for registration
55.Under this category Members must register:
a)Any relevant financial interest or material benefit which does not clearly fall into one of the other categories, including any shareholding which falls below the relevant threshold, or any other financial asset, including an asset held in trust, if the Member nevertheless considers that it meets the test of relevance; in other words, that it might reasonably be thought by others to influence his or her actions or words as a Member; and
b)Any other interest, if the Member considers that it might reasonably be thought by others to influence his or her actions or words as a Member in the same way as a financial interest. This might include an unpaid employment or directorship, or directorship of a company not currently trading, non-practising membership of a profession, or a fund established to defray legal costs arising out of the Member’s work, but from which no benefit has yet been received.
56.Members are required to provide the following information:
a)A description of the interest and, where relevant, the name of the donor;
b)Any other relevant information. It is not necessary to provide a value for financial interests in this category;
c)The date when the interest arose or became registrable.
Yours sincerely
Diane Hedditch
Investigations and Complaints Officer
Office of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
OPCS Privacy Notice
From: Alison Wright <alisonwright45@btinternet.com>
Sent: 08 June 2023 11:44
To: Standards Commissioner <standardscommissioner@parliament.uk>
Subject: Complaints regarding Victoria Prentis
Dear Commissioner of Standards,
Please find my letter of complaint attached.
Editorial Insert: Refer to this article where I have published the details of this complaint:
Yours sincerely,
Alison
Alison Wright.
------ Original Message ------
From: "Standards Commissioner" <standardscommissioner@parliament.uk>
To: "Alison Wright" <alisonwright45@btinternet.com>
Sent: Thursday, 8 Jun, 23 At 17:49
Subject: Private & Confidential Ref: PCS60Highly Restricted: Parliamentary Commissioner for Standards
Dear Alison Wright
Please see attached a letter from the Parliamentary Commissioner for Standards, Mr Daniel Greenberg CB. The letter is private, for your eyes only.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints ManagerOffice of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
RE: Private & Confidential ref: PCS60(2)
Standards Commissioner <standardscommissioner@parliament.uk>
To: Alison Wright;
28/04/2023 09:25
Dear Alison Wright
Thank you for your email and providing the additional information.
Under the Rules of Conduct and Guide to the Rules for Members’ of Parliament, the Rt Hon Rishi Sunak MP does not have a duty to register his wife’s financial interests, unless he holds shares with his wife jointly or on behalf of his wife (Category 7). Whilst this is not a matter for the Parliamentary Commissioner for Standards, you may wish to draw this to the attention of the Prime Minister and the Independent Adviser of Ministers’ Interests, Sir Laurie Magnus CBE.
With respect to your concerns about fraud, again that is not a matter for the Parliamentary Commissioner for Standards and should be directed to the Police.
Finally, with respect to your concerns about Mr Sunak’s involvement with C&UCO PROPERTIES LIMITED, I note from the record that Mr Sunak is not a shareholder of the company, therefore, there is no duty on him to register his interest under Category 7 of the Code of Conduct for Members’ financial Interests.
I am sorry but the Commissioner is unable to help you any further with these matters.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints Manager
Office of the Parliamentary Commissioner for Standards
To: Beverley Allen
Investigations and Complaints Manager
Office of the Parliamentary Commissioner for Standards
27 April 2023
Dear Beverley,
Rishi Sunak failed to declare his wife's directorship of N&L Acquisitions Limited, which is held under a second identity, with a false date of birth. Please refer to Akshata Narayan MURTY personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk), which states
Akshata Narayan MURTY
N&L ACQUISITIONS LIMITED (09386651)
Company status Active
Correspondence address
118 High Street, Eton, Windsor, Berkshire, England, SL4 6AN
Date of birth June 1980
Role RESIGNED Director
Appointed on 21 June 2017
Resigned on 24 February 2022
Akshata Murty, confirms that this appointment is hers, on her LinkedIn profile, where she refers to the full name, New & Lingwood, see (30) Akshata Murty | LinkedIn. This company is controlled by POP Capital Llc, N&L ACQUISITIONS LIMITED persons with significant control, a fund operating on behalf of the Point One Percent of ultra high net worth individuals, see POP Capital (pop-capital.com). This represents a conflict with the public's best interest and it was concealed by Akshata Murty and Rishi Sunak, by his wife registering an identity with a false date of birth. Rishi Sunk had a duty to declare this on 21 June 2017 and in each subsequent register of interests.
This non-declaration of interests is against the law and you are better placed than I to refer my evidence, and your evidence, to the appropriate authorities for criminal investigation. I have been trying to report this but found that the systems in place for ensuring that these allegations are duly investigated are not fit for purpose. Synthetic identity fraud is also apparent within the Association of Police and Crime Commissioners, and this may be why it is so hard to get evident fraud investigated.
In addition, I attach a report on Oliver Dowden which I am presently drafting. In this, there is another interest that Rishi Sunak has failed to declare, he is a person with significant control of C&UCO Properties Limited and he has failed to declare this on his register of interests, see C&UCO PROPERTIES LIMITED persons with significant control. There is evidence of non-compliance to the Companies Act 2006, described within this draft report.
I am disappointed that the Standards Commissioner, on receiving my evidence, did not refer this matter for criminal investigation. Your office knows better than I who is empowered to take action on this. Please will you refer this to the appropriate authorities for criminal investigation?
Yours sincerely,
Alison Wright
------ Original Message ------
From: "Standards Commissioner" <standardscommissioner@parliament.uk>
To: "Alison Wright" <alisonwright45@btinternet.com>
Sent: Thursday, 27 Apr, 23 At 08:59
Subject: RE: Private & Confidential ref: PCS60(1)Dear Alison Wright
Thank you for your email.
The Commissioner notes your concerns and would ask that you specify which interests you believe the Rt Hon Rishi Sunak MP has failed to register on the Register of Members’ Financial Interests.
With respect to your concerns about fraud, that is a criminal matter and is therefore not something the Commissioner is empowered to investigate. Any concerns you may have about about criminal matters should be directed to the relevant authorities.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints ManagerOffice of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
OPCS Privacy NoticeFrom: Alison Wright <alisonwright45@btinternet.com>
Sent: 21 April 2023 09:57
To: Standards Commissioner <standardscommissioner@parliament.uk>
Subject: Re: Private & Confidential ref: PCS60Daniel Greenberg CB,
Standards Commissioner,
House of Commons,
London SW1A 0AA.
21 April 2023
Dear Sir,
I write to lodge a formal complaint regarding the conduct of the Prime Minister, Rishi Sunak, whom I believe has potentially breached the Code of Conduct for Members of Parliament. My concerns relate to the possible registration of multiple identities in Companies House and failure to declare these interests by the aforementioned Minister.
As you are no doubt aware, the Code of Conduct for Members of Parliament stipulates that MPs must register any financial or non-financial interests which might be seen to influence their actions or words in their parliamentary duties. Such an obligation is vital to ensuring transparency and public trust in the democratic process.
I am concerned that the Minister in question may have breached the Code of Conduct by failing to declare these interests and failing to register their multiple identities in Companies House, which could potentially create a situation of conflict of interest, and breach their obligation to be transparent and accountable.
I attach two due diligence reports, one on Rishi Sunak and the other on his wife, Akshata Murty, which contain evidence to support my allegations and raise questions about the nature of business in which they are involved. These documents are incomplete, the size of the interlocked directorate to which the Prime Minister and his wife are connected is so extensive that the evidence presented here only scratches the surface of, what appears to be, a cartel conducting fraud for the point one percent of ultra-high net worth individuals.
I respectfully request that the Parliamentary Commission of Standards undertake an immediate and thorough investigation into these matters. It is crucial that MPs are held accountable for their actions and that they uphold the highest ethical standards.
Thank you for your attention to this matter.
Yours faithfully,
Alison Wright
------ Original Message ------
From: "Standards Commissioner" <standardscommissioner@parliament.uk>
To: "Alison Wright" <alisonwright45@btinternet.com>
Sent: Tuesday, 18 Apr, 23 At 15:23
Subject: Private & Confidential ref: PCS60Dear Alison Wright
Thank you for your email and the attached documents, I have been asked to reply.
The Parliamentary Commissioner for Standards may only investigate allegations of breaches of the rules found in the House of Commons Code of Conduct and Guide to the Rules.
In order to consider a whether he should commence an inquiry about a named MPs he must have the following information:
· The name and address of the individual making the allegation
· A written allegation (either in email or hard copy) stating which rule you think has been breached
· Sufficient evidence to justify beginning an inquiry
The Commissioner’s postal address is: Daniel Greenberg CB, House of Commons, London SW1A 0AA.
Yours sincerely
Beverley
Beverley Allen
Investigations and Complaints ManagerOffice of the Parliamentary Commissioner for Standards
UK Parliament, Westminster, London SW1A 0AA
OPCS Privacy NoticeFrom: Alison Wright <alisonwright45@btinternet.com>
Sent: 17 April 2023 16:22
To: Standards Commissioner <standardscommissioner@parliament.uk>
Subject: Rishi Sunak & A Murty evidence of synthetic identity fraud in Companies HouseAlison Wright.
Daniel Greenberg CB, Commissioner of Standards.
Office of the Parliamentary Commissioner for Standards
House of Commons
London SW1A 0AA
standardscommissioner@parliament.uk
17 April 2023
Dear Sir,
I have conducted due diligence research to assess whether Rishi Sunak and his wife, Akshata Murty have business interests which conflict with the interests of the majority of the population and his role as Prime Minister.
There is evidence that Rishi Sunak and Akshata Murty have committed synthetic identity fraud, in Companies House records. They both have multiple identities registered in Companies House, Rishi Sunak have three, which are verifiably his, and Akshata Murty has two. They both use a false date of birth in one of their identities. This is a device which conceals interests. See, Companies House web pages, Rishi Sunak and Akshata Murty. Analysis and links to source data are provided in two due diligence reports, which accompany this letter, named Rishi Sunak dd 17 April 2023 and Akshata Murty and co-directors linked directorate 17 April 2023.
Rishi Sunak failed to disclose his wife's interest in N&L Acquisitions Limited, which is registered to a second identity of hers, in Companies House. Analysis is provided of evidence that this company is part of an extensive linked directorate. I allege that this is a characteristic of a cartel running an organised coup which requires police investigation. Please let me know if you agree and whether you will forward this for police investigation?
Yours faithfully,
Alison Wright.
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