Baroness Sally Morgan: Labour Together Limited

Investigation by the Lords' Commissioner for Standards.

This article includes my letter of complaint to Martin Jelley, the Lords’ Commissioner for Standards, about Baroness Sally Morgan, his initial findings, a clarification and response, and the Report by the Commissioner for Standards.

Multiple identities are found for Sally Morgan in a search in Companies House; Sally Morgan - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Sally%20Morgan).

“From: alisonwright45@btinternet.com

To: LORDSSTANDARDS@parliament.uk;

19/12/2024 16:46

For the attention of Martin Jelley QPM DL

Dear Mr Jelley,

Baroness Sally Morgan breaches the following Nolan principles:

1. Integrity: By failing to disclose all her directorships and providing inaccurate information about her roles, she has not acted in line with the principle of integrity, which requires holders of public office to avoid placing themselves under any obligation to people or organizations that might try inappropriately to influence them in their work.

2. Accountability: Her failure to accurately declare all her appointments and interests undermines her accountability for her decisions and actions to the public.

3. Openness: By not being fully transparent about all her roles and appointments, she has not adhered to the principle of openness, which requires holders of public office to act and take decisions in an open and transparent manner.

4. Honesty: Providing incorrect start and end dates for her appointments and failing to declare all her directorships goes against the principle of honesty, which states that holders of public office should be truthful.

5. Leadership: As a public figure and member of the House of Lords, her actions do not set a good example of how to uphold these principles, thus failing to promote and support the principles by leadership and example.

Baroness Sally Morgan's interests registered in Companies House (the blue text contains a hyperlink to the record in Companies House).

MORGAN, Sally, Baroness identity 1

Labour Together Limited Correspondence address Langley House, Park Road, London, England, N2 8EY Role Active Director Date of birth June 1959 Appointed on 29 November 2023 Nationality British Country of residence England Occupation Director Total number of appointments 1

A search in Companies House on the name Sally Morgan locates identities with date of birth June 1959

Sally MORGAN identity 2

Total number of appointments 1 - Born June 1959

1 Edcity, Edcity Walk, London, United Kingdom, W12 7TF

• EDCITY OFFICE (11596797) Appointed on 11 March 2024 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate

Sally MORGAN identity 3

Total number of appointments 10 - Born June 1959

LAURA GITTINS, 65 Kingsway Ark, 65 Kingsway, London, England, WC2B 6TD

• EDUCATION POLICY INSTITUTE: 8 July 2015 - Present Incorporated on

  1 November 2002 Nature of business (SIC) 85590 - Other education not elsewhere classified Previous company names CENTRE FOR REFORM 01 Nov 2002 - 19 May 2016

• AMBITION INSTITUTE: 9 March 2012 - 1 September 2019 Previous company names AMBITION SCHOOL LEADERSHIP TRUST23 Nov 2016 - 28 Nov 2018 TEACHING LEADERS09 Mar 2012 - 23 Nov 2016

• THE FRONTLINE ORGANISATION: 22 May 2015 - 4 July 2019 Nature of business (SIC) 85422 - Post-graduate level higher education

  • 85590 - Other education not elsewhere classified

• FUTURE LEADERS CHARITABLE TRUST LIMITED: 25 May 2006 - 20 August 2018 (Dissolved) Dissolved on 15 January 2019 Incorporated on 25 May 2006 Accounts Last accounts made up to 31 August 2016 Accounts overdue Nature of business (SIC) 85600 - Educational support services Previous company names FUTURE LEADERS LIMITED 25 May 2006 - 24 Nov 2006

• SCHOOLS AND TEACHERS INNOVATING FOR RESULTS: 21 August 2012 - 1 April 2017 Nature of business (SIC) 85590 - Other education not elsewhere classified1 active person with significant control / 0 active statements Mr Jonathan Robert Owen Active Correspondence address Stir Education, 167 - 169, Great Portland Street, London, England, W1W 5PF Date of birth

  June 1958

• COPTHORN HOLDINGS LIMITED: 1 October 2014 - 18 March 2016 1 active person with significant control Countryside Partnerships Limited Nature of business (SIC) 70100 - Activities of head offices Previous company names ALNERY NO. 2447 LIMITED 25 May 2004 - 01 Oct 2004

• TOOLEY ENERGY LIMITED: 27 March 2014 - 17 December 2015 (Dissolved) Dissolved on 27 July 2019 Incorporated on 2 October 2013 Accounts Last accounts made up to 31 March 2016 Accounts overdue Nature of business (SIC)

  35110 - Production of electricity

  64209 - Activities of other holding companies not elsewhere classified

  Previous company names

  INFINIS ENERGY LIMITED 14 Jan 2016 - 13 Jul 2017

  INFINIS ENERGY PLC 28 Oct 2013 - 14 Jan 2016

  INFINIS ENERGY LIMITED 04 Oct 2013 - 28 Oct 2013

  INFINIS LISTCO LIMITED 02 Oct 2013 - 04 Oct 2013

  Insolvency Practitioners 8 Princes Parade, Liverpool, L3 1QH

  Paul Andrew Flint
  John David Thomas Milsom
  Nicholas James Timpson

• THE MAYOR'S FUND FOR LONDON: 20 January 2009 - 3 July 2012 Incorporated on 16 June 2008 Nature of business (SIC) 74990 - Non-trading company

• SOUTHERN CROSS HEALTHCARE GROUP PLC: 27 June 2006 - 29 July 2011 (Dissolved) Dissolved on 13 September 2016 Company type Public limited Company Incorporated on 10 January 2005 Accounts Last accounts made up to 30 September 2010 Accounts overdue Annual return Last annual return made up to 10 January 2013 Annual return overdue Nature of business (SIC) 70100 - Activities of head offices Previous company names SOUTHERN CROSS HEALTHCARE GROUP LIMITED 29 Dec 2005 - 13 Jun 2006

  TBG OPCO 1 LIMITED 16 Feb 2005 - 29 Dec 2005

  SPRINTDEW LIMITED 10 Jan 2005 - 16 Feb 2005

  2 outstanding charges Persons entitled Barclays Bank PLC and Barclays Bank PLC in Its Capacity as Security Agent for the Beneficiaries Insolvency Practitioner Howard Smith 1 The Embankment, Neville Street, Leeds, LS1 4DW

• TALKTALK TELECOM HOLDINGS LIMITED: 1 November 2005 - 29 March 2010 Accounts overdue Next accounts made up to 28 February 2024 due by 30 November 2024 Last accounts made up to 28 February 2023 Nature of business (SIC) 61900 - Other telecommunications activities Previous company names THE CARPHONE WAREHOUSE GROUP LIMITED 25 Mar 2010 - 25 Mar 2010 THE CARPHONE WAREHOUSE GROUP PUBLIC LIMITED COMPANY 06 Jun 2000 - 25 Mar 2010 WORLDWIDE TELECOMMUNICATIONS LIMITED 12 Feb 1997 - 06 Jun 2000

  MUSICAL SEASON LIMITED 23 Sep 1996 - 12 Feb 1997

  3 outstanding charges Persons entitled Dnb Bank Asa, London Branch as Common Security Agent

Sally MORGAN identity 4

Total number of appointments 1 - Born June 1959

Guy Scadding Building, Dovehouse Street, London, United Kingdom, SW3 6LY

• NATIONAL HEART AND LUNG FOUNDATION (15296453) Appointed on

  20 November 2023 Incorporated on 20 November 2023 Nature of business (SIC) 74909 - Other professional, scientific and technical activities not elsewhere classified 86900 - Other human health activities

Sally MORGAN identity 5

Total number of appointments 1 - Born June 1959

1 Portal Way, London, W3 6RS

• CURRYS PLC (07105905) Appointed on 28 January 2010 Resigned on 7 September 2017 Incorporated on 15 December 2009 Nature of business (SIC)

  82990 - Other business support service activities not elsewhere classified

  Previous company names

  DIXONS CARPHONE PLC 06 Aug 2014 - 15 Sep 2021

  CARPHONE WAREHOUSE GROUP PUBLIC LIMITED COMPANY 25 Mar 2010 - 06 Aug 2014

  NEW CARPHONE WAREHOUSE PLC 15 Dec 2009 - 25 Mar 2010

Sally MORGAN OF HUYTON identity 6

Total number of appointments 1 - Born June 1959

14-15, Lower Grosvenor Place, London, England, SW1W 0EX

• THE PROFESSIONAL TEACHING INSTITUTE (05910443) Appointed on 29 May 2020 Incorporated on 18 August 2006 Nature of business (SIC) 85600 - Educational support services Previous company names

  THE PRINCE'S TEACHING INSTITUTE 18 Aug 2006 - 23 Jul 2019

Baroness Sally MORGAN identity 7

Total number of appointments 1 - Born June 1959

Royal Brompton & Harefield Nhs Foundation Trust, Royal Brompton Hospital, Sydney Street, London, United Kingdom, SW3 6NP

• CARILLION PLC (03782379) Company status Liquidation Role Active

  Director Appointed on 1 July 2017 Incorporated on 28 May 1999 Accounts overdue Next accounts made up to 31 December 2017 due by 30 June 2018 Last accounts made up to 31 December 2016 Nature of business (SIC)

  41201 - Construction of commercial buildings

  42110 - Construction of roads and motorways

  43390 - Other building completion and finishing

  43999 - Other specialised construction activities not elsewhere classified

  Previous company names CAMERON 1999 PLC 28 May 1999 - 11 Jun 1999

  Insolvency Practitioner Practitioner The Official Receiver Or London 2nd Floor, 4 Abbey Orchard Street, Westminster, London, SW1P 2HT

  6 charges outstanding Persons entitled Glas Trust Corporation Limited, 45 Ludgate Hill, London EC4M 7JU, United Kingdom and Santander UK PLC as Security Agent for the Secured Parties”

“Sally MORGAN

Total number of appointments 1 - Born May 1959 (Query whether related party)

135 Aztec West, Bristol, Avon, United Kingdom, BS32 4UB

• BIDDLE AND SHIPTON MANAGEMENT COMPANY LIMITED (05956900) Appointed on 18 May 2015 Resigned on 22 May 2023 Nature of business (SIC) 68320 - Management of real estate on a fee or contract basis

Breaches and Compliance Issues Associated with Sally MORGAN

Multiple Identities

• There are at least seven identities with the name "Sally MORGAN" or variations, all born in June 1959, which raises concerns about compliance with Section 1082 of the Companies Act 2006. This section requires accurate and consistent information for company officers.

Dissolved Companies with Overdue Accounts

• Sally MORGAN is associated with several dissolved companies that have overdue accounts, indicating potential breaches of Section 441 of the Companies Act 2006:

  • FUTURE LEADERS CHARITABLE TRUST LIMITED: Dissolved, with accounts overdue.

  • TOOLEY ENERGY LIMITED: Dissolved, with accounts overdue.

  • SOUTHERN CROSS HEALTHCARE GROUP PLC: Dissolved, with accounts overdue and an annual return overdue.

  • CARILLION PLC: In liquidation, with accounts overdue.

Conclusion

The analysis of Sally MORGAN's appointments highlights several compliance issues:

• Multiple Identities: The presence of multiple identities with the same name and date of birth may breach Section 1082 of the Companies Act 2006.

• Dissolved Companies with Overdue Accounts: Association with dissolved companies having overdue accounts violates Section 441 of the Companies Act 2006.

• Other Compliance Concerns: Potential issues with unsigned accounts, failure to list active officers, and related party disclosures further underscore the need for thorough compliance checks.

These breaches indicate a lack of adherence to regulatory requirements, which could lead to legal and reputational consequences.

Summary of Sally Morgan’s interests:

summary of Sally Morgan's associated companies, organized by identity number and including previous company names where applicable:

Identity 1:

• Labour Together Limited: Appointed 29 November 2023 - Present

Identity 2:

• EDCITY OFFICE: Appointed 11 March 2024 - Present

Identity 3:

• EDUCATION POLICY INSTITUTE: Appointed 8 July 2015 - Present
  Previous name: CENTRE FOR REFORM (1 Nov 2002 - 19 May 2016)

• AMBITION INSTITUTE: Appointed 9 March 2012 - Resigned 1 September 2019

• THE FRONTLINE ORGANISATION: Appointed 22 May 2015 - Resigned 4 July 2019

• FUTURE LEADERS CHARITABLE TRUST LIMITED: Appointed 25 May 2006 - Resigned 20 August 2018 (Dissolved 15 January 2019)
  Previous name: FUTURE LEADERS LIMITED (25 May 2006 - 24 Nov 2006)

• SCHOOLS AND TEACHERS INNOVATING FOR RESULTS: Appointed 21 August 2012 - Resigned 1 April 2017

• COPTHORN HOLDINGS LIMITED: Appointed 1 October 2014 - Resigned 18 March 2016
  Previous name: ALNERY NO. 2447 LIMITED (25 May 2004 - 01 Oct 2004)

• TOOLEY ENERGY LIMITED: Appointed 27 March 2014 - Resigned 17 December 2015 (Dissolved 27 July 2019)
  Previous names: INFINIS ENERGY LIMITED (14 Jan 2016 - 13 Jul 2017), INFINIS ENERGY PLC (28 Oct 2013 - 14 Jan 2016), INFINIS ENERGY LIMITED (04 Oct 2013 - 28 Oct 2013), INFINIS LISTCO LIMITED (02 Oct 2013 - 04 Oct 2013)

• THE MAYOR'S FUND FOR LONDON: Appointed 20 January 2009 - Resigned 3 July 2012

• SOUTHERN CROSS HEALTHCARE GROUP PLC: Appointed 27 June 2006 - Resigned 29 July 2011 (Dissolved 13 September 2016)
  Previous names: SOUTHERN CROSS HEALTHCARE GROUP LIMITED (29 Dec 2005 - 13 Jun 2006), TBG OPCO 1 LIMITED (16 Feb 2005 - 29 Dec 2005), SPRINTDEW LIMITED (10 Jan 2005 - 16 Feb 2005)

• TALKTALK TELECOM HOLDINGS LIMITED: Appointed 1 November 2005 - Resigned 29 March 2010
  Previous names: THE CARPHONE WAREHOUSE GROUP LIMITED (25 Mar 2010 - 25 Mar 2010), THE CARPHONE WAREHOUSE GROUP PUBLIC LIMITED COMPANY (06 Jun 2000 - 25 Mar 2010), WORLDWIDE TELECOMMUNICATIONS LIMITED (12 Feb 1997 - 06 Jun 2000), MUSICAL SEASON LIMITED (23 Sep 1996 - 12 Feb 1997)

Identity 4:

• NATIONAL HEART AND LUNG FOUNDATION (15296453): Appointed 20 November 2023 - Present

Identity 5:

• CURRYS PLC (07105905): Appointed 28 January 2010 - Resigned 7 September 2017
  Previous names: DIXONS CARPHONE PLC (06 Aug 2014 - 15 Sep 2021), CARPHONE WAREHOUSE GROUP PUBLIC LIMITED COMPANY (25 Mar 2010 - 06 Aug 2014), NEW CARPHONE WAREHOUSE PLC (15 Dec 2009 - 25 Mar 2010)

Identity 6:

• THE PROFESSIONAL TEACHING INSTITUTE (05910443): Appointed 29 May 2020 - Present
  Previous name: THE PRINCE'S TEACHING INSTITUTE (18 Aug 2006 - 23 Jul 2019)

Identity 7:

• CARILLION PLC (03782379): Appointed 1 July 2017 - Present (Company in Liquidation)
  Previous name: CAMERON 1999 PLC (28 May 1999 - 11 Jun 1999)

Baroness Morgan of Register of interests with amendments is copied below, from the Register of Interests on the Parliament website (https://members.parliament.uk/member/2168/registeredinterests):

“Category 1: Directorships

• Interest deleted 11 September 2018 Non-executive Director, Carphone Warehouse (interest ceased 7 September 2017) (originally added 20 April 2010)

• Interest deleted 1 August 2011 Non-executive Director, Southern Cross Healthcare Group plc (originally added 20 April 2010)

• Interest deleted 10 January 2017 Non-executive Director, Infinis Energy plc (interest ceased 31 December 2015) (originally added 3 April 2014)

• Interest deleted 20 November 2023 Non-executive Director, Countryside Properties plc (interest ceased 11 November 2022) (originally added 4 October 2014)

• Interest deleted 16 January 2019 Non-executive Director, Carillion plc (facilities management and construction services) (interest ceased 15 January 2018) (originally added 2 August 2017)

Category 2: Remunerated employment, office, profession etc.

• Interest amended 2 May 2010 Adviser, Board of ARK (Absolute Return for Kids; charity) (originally added 20 April 2010)

• Interest deleted 5 June 2013 Board Member, Olympic Delivery Authority (originally added 20 April 2010)

• Interest deleted 2 August 2017 Member, Advisory Committee, Board of Virgin Group Holdings Ltd (holding company) (interest ceased end July 2016) (originally added 22 October 2010)

• Interest deleted 4 October 2014 Chairman, OFSTED (originally added 7 March 2011)

• Interest deleted 5 June 2013 Member, Advisory Board, The Foundation (business consultants) (originally added 18 June 2011)

• Interest amended 5 June 2013 Mentor for Mentore Consulting LLP (originally added 5 June 2013)

• Interest deleted 11 January 2018 Occasional media work (interest ceased 10 January 2017) (originally added 5 June 2013)

• Interest deleted 3 February 2022 Chair, Royal Brompton & Harefield NHS Foundation Trust (interest ceased 1 February 2021) (originally added 10 January 2017)

• Interest amended 8 October 2019 Master, Fitzwilliam College, Cambridge (originally added 11 July 2019)

• Interest amended 24 March 2021 Deputy Chair, Guy’s and St Thomas’ NHS Foundation Trust (also Chair, Royal Brompton & Harefield NHS Foundation Trust Clinical Group) (originally added 24 March 2021)

Category 10: Non-financial interests (a)

• Interest amended 12 January 2024 Director, Labour Together Limited (political think tank) (originally added 12 January 2024)

• Interest amended 16 April 2024 Director, National Heart and Lung Foundation (charity) (originally added 15 April 2024)

• Interest amended 17 April 2024 Director, EdCity Office (real estate) (originally added 17 April 2024)

Category 10: Non-financial interests (b)

• Interest deleted 1 August 2020 Vice Chairman of Council (formerly Member of Council), King's College, University of London (interest ceased 31 July 2019) (originally added 29 August 2013)

• Interest amended 16 April 2024 Member (Trustee), University Council, University of Cambridge (originally added 16 April 2024)

• Interest amended 7 November 2024 Visiting Professor, King's College London (originally added 7 November 2024)

Category 10: Non-financial interests (e)

• Interest deleted 1 December 2017 Chair, Future Leaders (head-teacher training; charity) (interest ceased 30 November 2016) (originally added 20 April 2010)

• Interest deleted 13 March 2017 Member, Advisory Board of Centre for Human Rights, Institute of Education, University of London (interest ceased 11 March 2016) (originally added 20 April 2010)

• Interest deleted 5 June 2013 Trustee, Mayor's Fund for London (originally added 20 April 2010)

• Interest deleted 1 December 2017 Board Member, Teaching Leaders (middle school leaders' training) (interest ceased 30 November 2016) (originally added 20 April 2010)

• Interest deleted 18 June 2011 Adviser, New Schools Network (originally added 7 February 2011)

• Interest deleted 13 March 2017 Member of Development Board, Frontline (interest ceased 11 March 2016) (originally added 5 June 2013)

• Interest deleted 6 July 2020 Trustee, Frontline (social work charity) (interest ceased 3 July 2019) (originally added 10 March 2016)

• Interest deleted 2 January 2020 Trustee STIR (international education charity) (interest ceased 31 December 2018) (originally added 16 March 2016)

• Interest deleted 1 September 2020 Chair, Ambition School Leadership (formed from Future Leaders and Teaching Leaders) (interest ceased 31 August 2019) (originally added 10 January 2017)

• Interest amended 11 July 2019 Trustee, Education Policy Institute (originally added 11 July 2019)

• Interest amended 4 June 2020 Trustee, The Professional Teaching Institute (The PTI) and Director of associated company (charity supplying professional development for teachers and school leaders) (originally added 4 June 2020)”.

Based on the comparison between Baroness Morgan's register of interests and her appointments registered in Companies House, here are the findings:

Directorships not included in Baroness Morgan of Huyton’s register of interests:

1. EDUCATION POLICY INSTITUTE: Appointed 8 July 2015 - Present
   (Note: This is listed as a trusteeship in her register, not also as a directorship)

2. AMBITION INSTITUTE: Appointed 9 March 2012 - Resigned 1 September 2019
   (Note: This is listed as a chair position in her register, not also as a directorship)

3. THE FRONTLINE ORGANISATION: Appointed 22 May 2015 - Resigned 4 July 2019
   (Note: This is listed as a trusteeship in her register, not also as a directorship)

4. FUTURE LEADERS CHARITABLE TRUST LIMITED: Appointed 25 May 2006 - Resigned 20 August 2018 (Dissolved 15 January 2019)

5. SCHOOLS AND TEACHERS INNOVATING FOR RESULTS: Appointed 21 August 2012 - Resigned 1 April 2017

6. COPTHORN HOLDINGS LIMITED: Appointed 1 October 2014 - Resigned 18 March 2016

7. TOOLEY ENERGY LIMITED: Appointed 27 March 2014 - Resigned 17 December 2015 (Dissolved 27 July 2019)

8. CURRYS PLC (07105905): Appointed 28 January 2010 - Resigned 7 September 2017

9. THE PROFESSIONAL TEACHING INSTITUTE: Appointed on 29 May 2020

   (Note: This is listed as a trusteeship in her register, not as a directorship)

10. THE MAYOR'S FUND FOR LONDON: Appointed 20 January 2009 - Resigned 3 July 2012

11. TALKTALK TELECOM HOLDINGS LIMITED: Appointed 1 November 2005 - Resigned 29 March 2010

Incorrect appointment dates are provided in the register of interests for:

1. EDCITY OFFICE (11596797): Appointed on 11 March 2024

   • This appointment is declared in her register, but the start date is listed as 17 April 2024, which is incorrect.

2. NATIONAL HEART AND LUNG FOUNDATION (15296453): Appointed on 20 November 2023

   • This appointment is declared in her register, but the start date is listed as 15 April 2024, which is incorrect.

3. LABOUR TOGETHER LIMITED: Appointed on 29 November 2023

   • This appointment is declared in her register, but the start date is listed as 12 January 2024, which is incorrect.

Baroness Sally Morgan appears to have failed to accurately declare several appointments and has potentially registered multiple identities, which raises serious concerns about compliance and transparency.

1. Multiple Identities:
   The appointments held in identities 3, 5, and 6 that are not declared suggest the use of multiple identities to conceal interests.

2. Potential Fraud:

   • Evidence of fraud under section 2 (fraud by false representation) and section 3 (fraud by failing to disclose information) of the Fraud Act 2006.

   • Further investigation for fraud under section 4 (fraud by abuse of position) is recommended.

These discrepancies and omissions indicate a pattern of non-compliance with disclosure requirements and raise significant concerns about the integrity of Baroness Morgan's declarations. The use of multiple identities to potentially conceal interests is particularly troubling and warrants a thorough investigation.

The failure to accurately declare appointments and the apparent use of multiple identities to conceal interests could have serious implications for transparency in public office and may constitute breaches of both Lords’ code of conduct and legal obligations under the Companies Act 2006.

A comprehensive investigation into all of Baroness Morgan's appointments, identities, and declarations is strongly recommended to ensure full compliance with all relevant regulations and to maintain public trust in the integrity of public officials.

Baroness Sally Morgan of Huyton breaches the Nolan Principles governing standards in public life

Based on the information provided in the search results and the previous analysis of Baroness Sally Morgan's conduct, she appears to have breached several of the Nolan Principles of Public Life:

1. Integrity: By failing to disclose all her directorships and providing inaccurate information about her roles, she has not acted in line with the principle of integrity, which requires holders of public office to avoid placing themselves under any obligation to people or organizations that might try inappropriately to influence them in their work.

2. Accountability: Her failure to accurately declare all her appointments and interests undermines her accountability for her decisions and actions to the public.

3. Openness: By not being fully transparent about all her roles and appointments, she has not adhered to the principle of openness, which requires holders of public office to act and take decisions in an open and transparent manner.

4. Honesty: Providing incorrect start and end dates for her appointments and failing to declare all her directorships goes against the principle of honesty, which states that holders of public office should be truthful.

5. Leadership: As a public figure and member of the House of Lords, her actions do not set a good example of how to uphold these principles, thus failing to promote and support the principles by leadership and example.

These breaches undermine the standards expected of those in public office and highlight the importance of adhering to the Nolan Principles to maintain public trust and integrity in governance.

The use of multiple identities and failure to disclose relevant interests not only violates legal and ethical standards but also poses significant risks for money laundering and terrorism financing.

In light of these findings, I strongly urge you to consider referring this matter to the appropriate authorities for potential criminal investigation.

Furthermore, given the severity and extent of these violations, it is my opinion that Baroness Morgan's position is no longer tenable. Her actions have compromised the integrity of her office and the institutions she serves. Therefore, I formally request that she resign from all her current positions of responsibility.

The public deserves transparency and accountability from its officials and institutions. Anything less undermines the foundations of our democratic system and the rule of law.

Yours sincerely

Alison Wright

The Lords’ Commissioner for Standards replied:

“Commissioner for Standards

House of Lords

London

SW1A 0PW

lordsstandards@parliament.uk

www.parliament.uk/hl-code

14 January 2025

Ref: 2425-46

Dear Ms Wright,

Thank you for your email of 19 December about the conduct of Baroness Morgan of Huyton. In accordance with the Guide to the Code of Conduct, I have carried out a preliminary assessment of the complaint and am writing to let you know the outcome.

Your complaint alleges that Baroness Morgan is in breach of the Code of Conduct because of her non-registration, incorrect registration, and late registration of a number of interests, as well as because of her multiple identities on Companies House.

As set out in paragraph 138 of the Guide to the Code of Conduct (the ‘Guide’), matters not within my remit to investigate include member’s non-parliamentary activities. As I have made clear in my responses to your previous complaints, Companies House is not part of a members’ parliamentary activities, so I have dismissed parts of your complaint which relate to it. I ask you to please refrain from making further complaints relating to allegations of multiple identities.

Paragraph 141 of the Guide states that “The complaint must usually be made within six years of the conduct complained of”. On this basis, I consider that your allegations in relation to the following companies are therefore outside the scope of the Code of Conduct: Future Leaders Charitable Trust Limited, Schools and Teachers Innovating for Results, Copthorn Holdings Limited, Tooley Energy Limited, Currys PLC, Mayor’s Fund for London, and TalkTalk Telecom Holdings Limited.

Paragraph 142 of the Guide also states that a complaint must be supported by sufficient evidence to establish a prima facie case that the Code of Conduct has been breached. I do not believe you have provided evidence that Baroness Morgan has either failed to register, or has registered in the incorrect category, her interests in the company Professional Teaching Institute.

Furthermore, paragraph 17 of the Code of Conduct states that “Members [...] should register any change in their relevant interests within one month of the change”. However, paragraph 136 of the Guide also states that I may “choose not to consider complaints which are clearly trivial”. I believe that Baroness Morgan’s late registration of her interests in EdCity Office is clearly trivial because the Registrar of Lords’ Interests files record that she attempted to register her interests in this charity two days late. Thus, I believe it should not be investigated.

I have, however, decided that it would be appropriate for me to investigate whether the following provisions of the Code of Conduct have been breached in relation to Baroness Morgan’s interests in the Education Policy Institute, Ambition Institute, The Frontline Organisation, National Heart and Lung Foundation, and Labour Together Limited:

• “14. (a) register in the Register of Lords’ Interests all relevant interests, in order to make clear what are the interests that might reasonably be thought to influence their parliamentary actions;

• 17. Members are responsible for ensuring that their registered interests are accurate and up-to-date. They should register any change in their relevant interests within one month of the change.”

I will write to Baroness Morgan to inform her that an investigation has been launched and to provide details of your complaint.

You will be notified of the outcome of the investigation once the investigatory process has been completed.

I would also draw your attention to paragraph 159 of The Guide to the Code of Conduct:

• “From the point that the Commissioner decides to undertake an investigation all evidence and correspondence relating directly to the inquiry is covered by parliamentary privilege. It must remain confidential unless and until it is published. If such evidence or correspondence were to be published or disclosed to anyone else without the agreement of the Conduct Committee or the Commissioner, this would be a contempt of the House. An attempt to obstruct an investigation is a contempt of the House.”

The Guide to the Code of Conduct provides detailed information about the process and can be found online at https://www.parliament.uk/globalassets/documents/lords commissioner-for-standards/hl-code-of-conduct.pdf.

Yours sincerely,

Martin Jelley QPM DL

Commissioner for Standards”

As a result of the application of Paragraph 159, I had to hold off publishing an article I was writing about Labour Together Limited. It was whilst doing a compliance assessment on Labour Together Limited that I first encountered the name Baroness Sally Morgan of Huyton. Now that the Commissioner for Standards has completed his investigation and published his findings that confidentiality is clause no longer applies and we can publicly consider my complaint and his findings.

I received a request for clarification:

“From: LORDSSTANDARDS@parliament.uk
To: alisonwright45@btinternet.com Cc: LORDSSTANDARDS@parliament.uk
Sent: Monday, January 6th 2025, 18:46
Subject: RE: Complaint: Baroness Sally Morgan of Huyton

Dear Ms Wright,

I am contacting you on behalf of the Commissioner.

The Commissioner is currently undertaking a preliminary assessment of your complaint and would be grateful if you could please provide some further clarification on one particular aspect of your complaint. Under the section 'Directorships not included in Baroness Morgan of Huyton's register of interests', a paragraph states "Incorrect appointment dates are provided in the register of interests for: [...]".

Could you please clarify this aspect of your complaint, in particular what is meant by "appointment date" in relation to the register of interests and which aspect of the Code of Conduct you are asking the Commissioner to consider that a breach may have occurred?

Best wishes,

Priscilla Tomaz

Assistant Standards Clerk

I replied:

“From: alisonwright45@btinternet.com

To: Lords Standards Commissioner;

07/01/2025 20:24

Dear Ms Tomaz,

Thank you for requesting the following clarification:

"Under the section 'Directorships not included in Baroness Morgan of Huyton's register of interests', a paragraph states "Incorrect appointment dates are provided in the register of interests for: [...]".

Could you please clarify this aspect of your complaint, in particular what is meant by "appointment date" in relation to the register of interests and which aspect of the Code of Conduct you are asking the Commissioner to consider that a breach may have occurred? Paragraph 10 of the code of conduct requires: "It is the responsibility of members’ staff to keep their entry up-to-date by notifying changes in their registrable interests within one month of each change occurring. Failure to do so is a breach of the Code of Conduct."

This relates to following entry in the Baroness Morgan of Huyton's Register of Interests:

"Category 10: Non-financial interests (a)

• Interest amended 12 January 2024 Director, Labour Together Limited (political think tank) (originally added 12 January 2024).

• Interest amended 16 April 2024 Director, National Heart and Lung Foundation (charity) (originally added 15 April 2024)

• Interest amended 17 April 2024 Director, EdCity Office (real estate) (originally added 17 April 2024)"

The corresponding records in Companies House and my complaints were

"Incorrect appointment dates are provided in the register of interests for:

1. EDCITY OFFICE (11596797): Appointed on 11 March 2024

   • This appointment is declared in her register, but the start date is listed as 17 April 2024, which is incorrect.

2. NATIONAL HEART AND LUNG FOUNDATION (15296453): Appointed on 20 November 2023

   • This appointment is declared in her register, but the start date is listed as 15 April 2024, which is incorrect.

3. LABOUR TOGETHER LIMITED: Appointed on 29 November 2023

   • This appointment is declared in her register, but the start date is listed as 12 January 2024, which is incorrect."

Your request highlights a limitation in the current code of conduct, which only requires that an interest be registered within a month of becoming active, without specifying the need to include the actual start date of the interest.

To enhance transparency and data integrity, and to align with the requirements of the Companies Act 2006, paragraph 10 of the code should be amended to require the inclusion of the date an interest became active, such as the date of appointment as a director.

While acknowledging this limitation in the current code, I have observed that members of the House of Lords do include the date an interest ceases and use the registration date. For consistency and improved transparency, it would be logical to also provide the start date, such as the appointment date.

I apologise for my initial misinterpretation. I incorrectly assumed that the date an interest was added to the register corresponded to the date the appointment became active, as recorded in Companies House.

However, since members have up to a month to register a new interest, I revise my concerns as follows:

Referring to the Register of interests:

• "Interest amended 12 January 2024 Director, Labour Together Limited (political think tank) (originally added 12 January 2024)" refers to an appointment made on 29 November 2023. This interest was registered approximately six weeks after the appointment, which exceeds the one-month deadline and constitutes a breach of paragraph 10 of the Code of Conduct.

• "Interest amended 16 April 2024 Director, National Heart and Lung Foundation (charity) (originally added 15 April 2024)" refers to an appointment made on 20 November 2023. This is prima facie evidence that Baroness Morgan of Huyton failed to declare her directorship of National Heart and Lung Foundation between 20 November 2023 and 15 April 2023, breaching the code of conduct for approximately fiver months after the declaration was due, which is a more serious breach.

• "Interest amended 17 April 2024 Director, EdCity Office (real estate) (originally added 17 April 2024)". The registration of this interest on 17 April 2024 appears to be delayed by approximately five days beyond the one-month timeframe allowed by the Code of Conduct
  

In conclusion, the inclusion of accurate start dates for appointments aligns with several key Nolan Principles, particularly:
Openness: Providing precise start dates ensures transparency about when responsibilities and potential influences began, allowing for better public scrutiny.
Accountability: Accurate timelines enable proper assessment of a public official's actions and decisions in relation to their roles and interests.
Integrity: Disclosing full and accurate information, including start dates, demonstrates a commitment to avoiding any appearance of conflict between public duty and personal interest.
Honesty: Providing complete and precise details, such as start dates, upholds the principle of truthfulness expected of public officials.
While the current Code of Conduct may not explicitly require start dates, incorporating them would significantly enhance transparency and align more closely with the spirit of the Nolan Principles. This practice would strengthen public trust, facilitate more effective oversight of potential conflicts of interest and ensure a consistent approach to declaring interests throughout their lifecycle.

Thank you for the opportunity to clarify this issue.

Yours sincerely,

Alison Wright”

On 20th February, having not been notified of the publication of the Commissioners findings, and concerned that I could not publish my report on Labour Together Limited, I followed up with an email

“To: Lords Standards Commissioner;

20/02/2025 11:54

Dear Commissioner for Standards,

I am writing to follow up on my complaint regarding Baroness Sally Morgan of Huyton, which I submitted on December 19, 2024, and for which I received your response on January 14, 2025.

As of today, February 20, 2025, I have not received any further communication regarding the outcome of the investigation. Given the serious nature of the allegations and the public interest in this matter, I respectfully request an urgent publication of the report into Baroness Morgan's conduct.

The lack of transparency and the extended period without updates are concerning, especially considering the potential breaches of the Code of Conduct that you agreed to investigate. These include:

Failure to register relevant interests in the Register of Lords' Interests

Inaccurate and outdated registration of interests

Late registration of changes in relevant interests

Specifically, you mentioned investigating her interests in the Education Policy Institute, Ambition Institute, The Frontline Organisation, National Heart and Lung Foundation, and Labour Together Limited.

While I understand the need for thorough investigation, the prolonged silence on this matter may undermine public confidence in the process and the institution.

Regarding the confidentiality clause mentioned in your previous letter, I must express my concerns about its appropriateness. The clause states:

"From the point that the Commissioner decides to undertake an investigation all evidence and correspondence relating directly to the inquiry is covered by parliamentary privilege. It must remain confidential unless and until it is published. If such evidence or correspondence were to be published or disclosed to anyone else without the agreement of the Conduct Committee or the Commissioner, this would be a contempt of the House. An attempt to obstruct an investigation is a contempt of the House."

While I respect the need for confidentiality during ongoing investigations, this clause seems disproportionately restrictive and potentially at odds with principles of transparency and accountability. It appears to prevent any public discussion or scrutiny of the process, which is crucial for maintaining public trust in our democratic institutions.

The threat of being held in contempt of the House for discussing the matter seems heavy-handed and could have a chilling effect on legitimate public discourse about the conduct of public officials. This approach may inadvertently shield potential misconduct from necessary public scrutiny.

I urge you to reconsider the scope and application of this confidentiality clause, balancing the need for investigative integrity with the public's right to information about the conduct of their representatives.

In light of these concerns, I respectfully request:

An immediate update on the status of the investigation into Baroness Morgan's conduct

A firm timeline for the publication of the report

A review of the confidentiality clause to ensure it aligns with principles of open governance and public accountability

Thank you for your attention to this matter. I look forward to your prompt response.

Your sincerely,
Alison Wright”.

I received the following response:

“21 February 2025

Dear Ms Wright,

Thank you for your email requesting an update on the investigation into Baroness Morgan and a review of paragraph 159 of the Guide to the Code of Conduct. The Commissioner informed you of the outcome of his preliminary assessment in his letter to you dated 14 January. All information that is made public relating to the case is set out on the Commissioner’s parliamentary webpage, and you will be notified of the outcome of the investigation once the investigatory process has been completed. No further information will be released until then.

The Commissioner’s role is limited to considering alleged breaches of the Code of Conduct, therefore it is not for the Commissioner to review aspects of the Code of Conduct or Guide. This falls within the remit of the Conduct Committee.

Best wishes,

Office of the Commissioner for Standard".

Yesterday the Commissioner for Standards published his report, which is reproduced below and available here: conduct-of-baroness-morgan-of-huyton.pdf (https://www.parliament.uk/globalassets/documents/lords-commissioner-for-standards/conduct-of-baroness-morgan-of-huyton.pdf). Page numbers are removed since the text is continuous here.

“Report from the Commissioner for Standards

The conduct of Baroness Morgan of Huyton

Commissioner Report 2024-25/3

Commissioners for Standards

The independent Commissioners for Standards are responsible for considering any alleged breaches of the Codes of Conduct. Address: The Commissioners for Standards, House of Lords, London SW1A 0PW Email: lordsstandards@parliament.uk Telephone: 020 7219 7152 Website: www.parliament.uk/hl-standards

Registrar of Lords’ Interests The Registrar of Lords’ Interests advises members of the House and their staff on their obligations under the Codes of Conduct. Address: Registrar of Lords’ Interests, House of Lords, London SW1A 0PW Email: lordsregistrar@parliament.uk Telephone: 020 7219 3112/3120

Registers of Interests A list of interests of members and their staff can be found online: www.parliament.uk/hlregister Independent Complaints and Grievance Scheme helpline Telephone: 0808 168 9281 (freephone) Email: Support@ICGShelpline.org.uk

CONTENTS Page

Summary of complaint 3

Relevant parts of the Code 3

Preliminary assessment 3

Summary of investigation 4

Education Policy Institute 4

Ambition Institute 5

The Frontline Organisation 6

National Heart and Lung Foundation and Labour Together Limited 7

Outcome 8

Appendix 1: Letter from Baroness Morgan of Huyton to Baroness Manningham-Buller, Chair of the Conduct Committee 9

The conduct of Baroness Morgan of Huyton

Summary of complaint

1. On 19 December 2024, my office received a complaint from a member of the public, Alison Wright, about Baroness Morgan of Huyton.¹

2. The complaint alleged that Baroness Morgan had failed to register her roles as an unremunerated director of three companies: Education Policy Institute, Ambition Institute and The Frontline Organisation. The complaint also alleged that Baroness Morgan had registered her roles as an unremunerated director of National Heart and Lung Foundation and Labour Together Limited late.

3. The complaint included a number of further allegations which I dismissed after a preliminary assessment for lack of evidence to establish a prima facie case that the Code of Conduct had been breached, because the allegations fell outside my remit or (in one case) because I considered the allegation to be clearly trivial.

Relevant parts of the Code

4. Paragraph 14(a) of the Code of Conduct states: “In order to assist in openness and accountability members shall […] register in the Register of Lords’ Interests all relevant interests, in order to make clear what are the interests that might reasonably be thought to influence their parliamentary actions.”

5. Paragraph 17 of the Code of Conduct states: “Members are responsible for ensuring that their registered interests are accurate and up-to-date. They should register any change in their relevant interests within one month of the change.”

6. Members are required to register unremunerated interests under category 10 (non-financial interests) of the Register of Lords’ Interests, including “unremunerated directorships or other regular employment” and “acting as an office-holder or trustee in voluntary or not-for-profit organisations.”

7. Category 1 is for remunerated directorships. Paragraph 54 of the Guide to the Code of Conduct, which explains this category, states: “Other unremunerated directorships should be registered under category 10 (non-financial interests) so that in one category or another all directorships should be registered.”

Preliminary assessment

8. As part of my preliminary assessment, I reviewed Baroness Morgan’s entries in the Companies House register and the Charity Commission’s register of charities. I also reviewed Baroness Morgan’s entries in the current and historical versions of the Register of Lords’ Interests.

9. I considered there to be sufficient prima facie evidence to investigate whether the Code of Conduct had been breached in relation to Baroness Morgan’s registration of her current or former interests in:

(a) Education Policy Institute

(b) Ambition Institute

(c) The Frontline Organisation

(d) National Heart and Lung Foundation

(e) Labour Together Limited.

Summary of investigation

10. I wrote to Baroness Morgan on 14 January to inform her that I had begun an investigation. I provided Baroness Morgan with a copy of the complaint and invited her to provide a written response to the allegations I was investigating. Baroness Morgan responded on 26 January.

Education Policy Institute

11. The complaint alleged that Baroness Morgan had failed to register her role as an unremunerated director of Education Policy Institute.

12. Baroness Morgan has the following entry in the Companies House register:

• Director, Education Policy Institute (appointed 8 July 2015)

13. Baroness Morgan has the following entry in the Charity Commission’s register of charities:

• Trustee, Education Policy Institute (appointed 8 July 2015)

14. There is no record of Baroness Morgan having registered her directorship of Education Policy Institute in the Register of Lords’ Interests. However, Baroness Morgan had registered the following interest under category 10(e): • Trustee, Education Policy Institute (registered 11 July 2019)

Baroness Morgan’s response

15. Baroness Morgan acknowledged that she had neglected to register that she was a director of Education Policy Institute, an independent research institute, but that she had registered her role as trustee. She wrote:

“Erroneously I had thought that I was required to select single sub categories in 10 a)-e) and had thought that sub-category e) was the appropriate choice. I have asked to Registrar to update my entries to ensure that where I am both a trustee and a director this is recorded […].”

16. She added:

“Although I fully accept that there is a distinction between being a trustee and being a director as far as my fiduciary and statutory responsibilities are concerned I submit that within the meaning of Paragraph 14 (a), no proper distinction can be drawn between acting as a charity trustee and acting as an unpaid director for an associated company.”

17. Baroness Morgan also confirmed that her role as trustee of Education Policy Institute was registered late. She wrote that she became involved in the Institute in July 2015 and did not register her interest until July 2019. She explained “my failure to register in time was entirely an oversight. I do not seek to put forward any excuse for the late registration.”

Findings

18. The key issue is the nature of Baroness Morgan’s unremunerated interests in Education Policy Institute. She correctly registered her substantive interest in this organisation in category 10. However, she also is a director of the associated company. It is common for a charity to comprise a trust and a company, with often the trustees and the directors being the same individuals. However, as Baroness Morgan acknowledged, the two roles involve different legal responsibilities. Paragraph 54 of the Guide makes clear that all directorships should be registered. Therefore, when a member is a trustee or board member of a charity and a director of the associated company, their register entry should cover both posts. This is a well-established principle.²

19. I recognise that Baroness Morgan believed that she had correctly registered her interests in Education Policy Institute in category 10(e). However, this was insufficient as it omitted her directorship of the associated company.

20. I find that Baroness Morgan should have included in her entry on the Register of Lords’ Interests her position as an unremunerated director of Education Policy Institute. By not doing so, she was in breach of paragraphs 14(a) and 17 of the Code of Conduct.

21. Baroness Morgan confirmed that her role as trustee of Education Policy Institute began in July 2015 but was not registered until July 2019.

22. I find that Baroness Morgan’s late registration of her interest as a trustee of Education Policy Institute breached paragraph 17 of the Code of Conduct.

Ambition Institute

23. The complaint alleged that Baroness Morgan had failed to register her role as an unremunerated director of Ambition Institute.

24. Baroness Morgan has the following entry in the Companies House register:

• Director, Ambition Institute (appointed 9 March 2012; resigned 1 September 2019)

25. There is no record of Baroness Morgan having registered her directorship of Ambition Institute in the Register of Lords’ Interests. However, Baroness Morgan had registered the following interest under category 10(e):

• Chair, Ambition School Leadership (formed from Future Leaders and Teaching Leaders) (registered 10 January 2017; interest ceased 31 August 2019)

Baroness Morgan’s response

26. Baroness Morgan acknowledged that she had not stated explicitly in her register entry that she was previously a director of Ambition Institute, but she had registered her substantive role as chair. She wrote:

“AI is a charity […]. Previously I had been trustee of Future Leaders and Teaching Leaders and had notified both roles to the Registrar. As far as I can now recall, in 2016 the two organisations merged and formed Ambition School Leadership, later renamed to Ambition Institute. I failed to notify the Registrar of the merger within the requisite period. This was an oversight which I later rectified. I resigned from the board of AI on 31 August 2019.”

Finding

27. While Baroness Morgan did not specify her role as an unremunerated director in the Register, I consider that her entry as chair can be reasonably thought to encompass her role as chair of the board of trustees and as chair of the board of directors of the associated company.

28. I find that Baroness Morgan’s entry in the Register of Lords’ Interests as chair sufficiently reflected her position as unremunerated chair of the board of directors of Ambition Institute. Therefore, I find there has been no breach of the Code in this instance.

The Frontline Organisation

29. The complaint alleged that Baroness Morgan had failed to register her role as an unremunerated director of The Frontline Organisation.

30. Baroness Morgan has the following entry in the Companies House register:

• Director, The Frontline Organisation (appointed 22 May 2015; resigned 4 July 2019)

31. There is no record of Baroness Morgan having registered her directorship of The Frontline Organisation in the Register of Lords’ Interests. However, Baroness Morgan had registered the following interests under category 10(e):

• Member of Development Board, Frontline (registered 5 June 2013; interest ceased 11 March 2016) and Trustee, Frontline (registered 10 March 2016; interest ceased 3 July 2019) Baroness Morgan’s response

32. Baroness Morgan acknowledged that she had neglected to register that she was previously a director of The Frontline Organisation, but that she had registered her roles as board member. She said:

“Frontline is a charity […] My initial involvement with Frontline was as a member of a Development Board. This was correctly registered. In May 2015 a limited company was formed. Due to an oversight I did not record the change. I resigned from Frontline in July 2019.”

Finding

33. I find that Baroness Morgan should have included in her entry on the Register of Lords’ Interests her position as an unremunerated director of The Frontline Organisation. By not doing so, she was in breach of paragraphs 14(a) and 17 of the Code of Conduct.

National Heart and Lung Foundation and Labour Together Limited

34. The complaint alleged that Baroness Morgan had registered her role as an unremunerated director of two companies late: National Heart and Lung Foundation, and Labour Together Limited.

35. Baroness Morgan has the following entries in the Companies House register:

(a) Director, National Heart and Lung Foundation (appointed 20 November 2023)

(b) Director, Labour Together Limited (appointed 29 November 2023)

36. Baroness Morgan has registered the following interests under category 10(e) of the Register of Lords’ Interests:

(a) Director, National Heart and Lung Foundation (charity) (registered 15 April 2024)

(b) Director, Labour Together Limited (political think tank) (registered 12 January 2024)

Baroness Morgan’s response

37. Baroness Morgan confirmed that there was a delay in registering her interest as a director of National Heart and Lung Foundation.

38. Baroness Morgan said that there was a short delay in registering her role as a director of Labour Together Limited, as she was out of the country when the deadline for registering it was reached.

Finding

39. Paragraph 17 of the Code of Conduct is clear that members should register any change in their relevant interests within one month of the change.

40. While Baroness Morgan registered her role as director of National Heart and Lung Foundation in April 2024, according to Companies House she became a director in November 2023. While she registered her role as director of Labour Together Limited in January 2024, according to Companies House she became a director in November 2023.

41. I find that Baroness Morgan’s late registration of her interests as a director of National Heart and Lung Foundation and Labour Together Limited breached paragraph 17 of the Code of Conduct. 8 THE CONDUCT OF BARONESS MORGAN OF HUYTON

Outcome

42. In her response Baroness Morgan apologised for the breaches. She explained that “my administrative oversights were not due to any desire by me to be anything less than transparent.” She emphasised that, though the oversights were regrettable, her role in each organisation “is or was entirely voluntary and unpaid”.

43. In light of this I consider these to be minor breaches for which remedial action is appropriate.

44. While I consider each individual breach of the Code to be minor, I have found there to be five breaches in total and have therefore recommended that Baroness Morgan write a letter of apology to the Chair of the Conduct Committee, Baroness Manningham-Buller (Appendix 1).

45. Baroness Morgan has already updated the Register as far as is possible, so no further action is required to rectify the position.

46. I am grateful to Baroness Morgan for her cooperation and for her prompt response.

Appendix 1:

LETTER FROM BARONESS MORGAN OF HUYTON TO BARONESS MANNINGHAM-BULLER, CHAIR OF THE CONDUCT COMMITTEE

Dear Baroness Manningham-Buller,

[…]

I have carefully reviewed the draft report from the House of Lords Commissioner for Standards […]. I would like to thank Ms Wright for alerting me to breaches of my duty to register some unremunerated interests in the Register of Interests, all of which have now been resolved.

I am grateful to the Commissioner and his team for their courteous communications and their thorough efficiency. I am pleased that the Commissioner states that I have cooperated fully and responded promptly.

The Commissioner comments in his draft report that he considers each individual breach to be minor. Although I stress that the administrative oversights were not due to any desire by me to be anything less than transparent, nevertheless I do regret my lack of rigour and my misunderstanding of the detail and extent of the requirements.

I wish to make clear that I fully accept the findings of the Commissioner.

I have now taken steps to ensure that in future I will fully comply with all the requirements and will ensure I do so in a timely manner.

I do hope you and the members of your Committee will accept my genuine and unreserved apology for my breaches and for the time that has been spent in the investigation.

Yours sincerely,

Baroness Morgan of Huyton

Initial thoughts:

1. Multiple identities considered out of scope. The refusal to consider my complaints about multiple identities is a dereliction of duties. Far from being a non-parliamentary matter company registration, audit integrity and compromised KYC checks are central issues. The UK is burdened with an estimated annual fraud of £200 billion fraud and the loopholes in Companies House, relating to multiple identities and dissolved companies with accounts overdue, are facilitators of such crime.

2. Conflict of interest can occur at any time. The complaints about directorships held over 6 years ago which were not declared were excluded from the investigation even though conflict of interest can occur at any time were incorrectly dismissed. Baroness Morgan had a duty to declare them when she entered the Lords and in the subsequent years. Therefore. the register should be updated to reflect her past directorship of Future Leaders Charitable Trust Limited, Schools and Teachers Innovating for Results, Copthorn Holdings Limited, Tooley Energy Limited, Currys PLC, Mayor’s Fund for London, and TalkTalk Telecom Holdings Limited.

3. “Fully comply … in a timely manner”. Baroness Morgan has already broken her promise “I have now taken steps to ensure that in future I will fully comply with all the requirements and will ensure I do so in a timely manner.” She fails to declare that she became a person with significant control of Labour Together Limited on 12 November 2024, LABOUR TOGETHER LIMITED persons with significant control (https://find-and-update.company-information.service.gov.uk/company/09630980/persons-with-significant-control).

The investigation and report were completed by Martin Jelley QPM DL.

1.

For example, see Commissioner Report 2023–2024/5, The conduct of Lord Kennedy of Southwark; Commissioner Report 2023–2024/8, The conduct of Baroness Amos; Commissioner Report 2023– 2024/13, The conduct of Baroness Kennedy of The Shaws; Commissioner Report 2024–2025/2, The conduct of Lord Alli.

2.