Attorney General Richard Hermer failed to declare Matrix Chambers Limited and The Harbour Foundation.
The revised Code of Conduct means he no longer has to declare Incorporated Council of Law Reporting for England and Wales (The); Inconsistent with the Companies Act 2006, which requires disclosure.
Two edits have made on 7/7/2025, indicated by the use of square brackets, [ ], within the text. Description of changes made: Addition and correction of two links to Companies House unique identifiers of Lord Hermer.
Compliance assessment of the UK Attorney General, Richard Hermer.
Contents:
Register of interest
Lord Hermer’s Companies House records [Links corrected 7/7/2025}
Comparison of interests registered in Companies House, with Lord Hermer’s Register of Interests.
Complaint about Lord Hermer to the Lords Commissioner for Standards
Register of interest
His register of interests, with amendments, is available at: https://members.parliament.uk/members/lords/interests/register-of-lords-interests?SearchTerm=hermer&ShowAmendments=True.
Lord Hermer has just one current interest as HM Attorney General.
"Lord Hermer Labour Life peer
Category 5: Land and property
Interest deleted 23 August 2024 Flat in London from which rental income is received (originally added 22 August 2024)
Category 10: Non-financial interests (a)
Interest deleted 5 April 2025 Director, Incorporated Council of Law Reporting for England and Wales (The) (originally added 22 August 2024)
Category 1: Remunerated employment etc.
Interest amended 5 April 2025 HM Attorney General (originally added 22 August 2024)".
Lord Hermer’s Companies House records
A search in Companies House on the name Richard Hermer locates two unique identifiers (https://find-and-update.company-information.service.gov.uk/search/officers?q=richard%20hermer):
“Richard HERMER [link added 7/7/2025]
Total number of appointments 1 - Born September 1968
102 Petty France, London, England, SW1H 9AJ
Richard Simon HERMER [link added 7/7/2025]
Total number of appointments 3 - Born September 1968
1 New Change, London, EC4M 9AF".
As Attorney General, Lord Hermer may have authority to establish two identities. He has used two versions of his name for each identity, one with a middle name, as Richard Simon Hermer. If the correct authorities have not been provided, then he has breached section 1082 of the Companies Act 2006.
The appointments held by these identities are:
Identity 1 [https://find-and-update.company-information.service.gov.uk/officers/9O11sWeGlWVKe_lC9jBg0i8_3rs/appointments (link added 7/7/2025)]:
"Richard HERMER
Total number of appointments 1 Date of birth September 1968
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034)
Company status Active Correspondence address 102 Petty France, London, England, SW1H 9AJ Role Active Director Appointed on 5 July 2024 Nationality British Country of residence England Occupation Lawyer".
Identity 2: [https://find-and-update.company-information.service.gov.uk/officers/HO4_BVEYTESBV_RqrllAx6WqYSM/appointments (link added 7/7/2025)]:
"Richard Simon HERMER
Total number of appointments 3 Date of birth September 1968
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 7 October 2023 Resigned on 2 August 2024 Nationality British Country of residence United Kingdom Occupation Barrister
THE HARBOUR FOUNDATION (00975116) Company status Active Correspondence address 1 Red Place, London, W1K 6PL Role Resigned Director Appointed on 1 March 2017 Resigned on 7 July 2024 Nationality British Country of residence United Kingdom Occupation Barrister
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 3 March 2016 Resigned on 17 February 2021 Nationality British Country of residence United Kingdom Occupation Barrister".
Comparison of interests registered in Companies House, with Lord Hermer’s Register of Interests.
Lord Hermer failed to declare his directorships of:
Matrix Chambers Limited, (Appointed on 3 March 2016 Resigned on 17 February 2021 and Appointed on 7 October 2023 Resigned on 2 August 2024) and
The Harbour Foundation, (Appointed on 1 March 2017 Resigned on 7 July 2024).
Matrix Chambers and The Harbour Foundation are category 1 directorships which Lord Hermer has a duty to declare in his Register of Interests. This is prima facie evidence that Lord Hermer failed to declare these interests in breach of the Code of Conduct.
On 5th April the Revised Code of Conduct no longer required “Non-financial” interests to be declared. Hence the following active role is no longer visible in his current register of interests as it was deleted on 5th April 2025.
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034) Role Active Director Appointed on 5 July 2024.
The Revised Code of Conduct for the House of Lords (effective 5 April 2025), which removes the requirement to declare non-financial interests, raises significant concerns about consistency with the Companies Act 2006, particularly regarding directors’ duties to avoid conflicts of interest and declare relevant interests. Here’s a structured analysis:
Key Points of Contention
Revised Code of Conduct Changes
Companies Act 2006 Requirements
Inconsistencies Identified
Conflict of Interest Management
The Companies Act imposes a strict duty on directors to declare all interests that could create conflicts, regardless of financial remuneration26.
The Revised Code’s removal of non-financial interest declarations eliminates a transparency mechanism that helps identify potential conflicts between parliamentary activities and corporate roles4.
Declaration Thresholds
Under the Companies Act, directors must declare interests if they “might reasonably be thought to influence” their actions26. This includes indirect interests (e.g., family members’ roles)6.
The Revised Code’s narrower focus on “relevant financial interests” creates a loophole where non-financial directorships (e.g., in law reporting bodies or charities) might not be disclosed, despite their potential to influence parliamentary work4.
Enforcement Gaps
Legal Risks
Breach of Section 175/177: A member of the House of Lords who is also a company director could fail to declare a non-financial interest (e.g., an unremunerated directorship) that influences parliamentary actions, violating their duty to avoid conflicts under the Companies Act46.
Public Perception: The Companies Act’s “reasonable person” test for conflicts (§14 of the Code1) is broader than the Revised Code’s financial focus. This discrepancy risks undermining public trust in parliamentary integrity4.
Conclusion
The Revised Code of Conduct introduces a regulatory misalignment with the Companies Act 2006. By exempting non-financial interests from declaration, it weakens transparency mechanisms designed to prevent conflicts of interest, thereby increasing the risk of inadvertent breaches of directors’ statutory duties. While the Code’s aim to reduce administrative burdens is understandable, the changes may inadvertently create legal vulnerabilities for members who hold corporate roles. A legal review of the Revised Code’s compatibility with the Companies Act is advisable to address these gaps46.
Complaint about Lord Hermer to the Lords Commissioner for Standards
To:
The House of Lords Commissioner for Standards
House of Lords
London
SW1A 0PW
Email: lordsstandards@parliament.uk
Date: 28 April 2025
Subject: Formal Complaint Against Lord Hermer (HM Attorney General) for Breaches of the Code of Conduct and Statutory Inconsistencies
Dear Commissioner,
I am writing to formally complain about Lord Hermer’s failure to register directorships under the House of Lords Code of Conduct and to highlight a critical inconsistency between the Revised Code of Conduct (5 April 2025) and the Companies Act 2006.
Summary of Alleged Breaches
Failure to Declare Directorships:
Lord Hermer’s Register of Interests omits multiple directorships (Matrix Chambers Limited, The Harbour Foundation, and the Incorporated Council of Law Reporting for England and Wales) despite Companies House records confirming their existence12.
These omissions violate the pre-5 April 2024 Code of Conduct, which required registration of all directorships under Categories 1 (remunerated) or 10 (non-financial).
Statutory Inconsistency:
Legal Inconsistency Between the Revised Code and Companies Act 2006
The Revised Code’s deletion of Category 10 (non-financial interests) creates a regulatory gap that undermines compliance with the Companies Act 2006:
Section 175: Directors must avoid conflicts of interest, including those arising from non-financial roles (e.g., unremunerated directorships)67.
Section 177: Directors must declare any interest in a proposed/actual transaction, regardless of financial gain8.
By exempting non-financial interests from registration, the Revised Code:
Erodes transparency: Lords serving as company directors may omit roles that could influence parliamentary actions, breaching statutory duties under the Companies Act.
Creates legal risk: A member’s failure to disclose a directorship (even unpaid) could lead to conflicts of interest unaddressed by the Code, exposing them to litigation under company law9.
Request for Investigation
Compliance with Pre-5 April 2024 Code:
Investigate Lord Hermer’s failure to declare directorships held prior to 5 April 2025, which were registrable under the Code in force at the time.Review of Statutory Compliance:
Assess whether the Revised Code’s removal of non-financial interest declarations aligns with the Companies Act 2006, particularly given Parliament’s intent to ensure directors’ accountability for all conflicts10.
Supporting Evidence:
Companies House records for Richard Hermer/Richard Simon Hermer (directorships and resignation dates).
Extracts from the Register of Lords’ Interests (April 2025).
Hansard debates (2006) and legal analyses confirming the Companies Act’s broad conflict-of-interest scope357.
Yours sincerely,
Alison Wright
Attachments:
Compliance assessment.
Note: This complaint underscores the need to reconcile parliamentary standards with statutory obligations under company law to maintain public trust in the Lords’ integrity.
Citations:1 Companies House records for Richard Hermer2 Register of Lords’ Interests (April 2025)3 Companies Bill [Lords] Hansard (17 October 2006)4 Company Law Reform Bill Hansard (6 June 2006)5 Research analysis on directors’ duties (CABRELLI, 2006)6 Companies Act 2006, s.175–1777 Financial Times (26 September 2006)8 Norton Rose Fulbright analysis (2023)9 UCL Constitution Unit (2023)10 Legislation.gov.uk Explanatory Notes (2006)
Very interesting. Chagos Islands? Meetings with CCP officials? Certainly, Sir.....