Compliance Assessment of the House of Lords' Conduct Committee
Work in progress: expect updates
Executive Summary
This assessment analyses the proposed Revised Code of Conduct for the House of Lords, finding that it weakens transparency and accountability by removing the mandatory declaration of non-financial interests, positions as ‘persons with significant control and spouses' directorships. These changes, combined with a higher threshold for registering interests, an emphasis on "relevant financial interests", and limits on enforcing the code raises concerns about potential breaches of the Companies Act 2006 and public trust.
Introduction
The Conduct Committee has reviewed the Lords’ Code of Conduct and published their recommendations. On 5 March 2025, the House of Lords will debate the following motion:
“Baroness Manningham-Buller (Crossbench) to move that the report from the select committee ‘Review of the code of conduct and the guide to the code of conduct’ (4th report, HL Paper 66) be agreed to.
Baroness Manningham-Buller is the chair of the House of Lords Conduct Committee.”
This report will consider the proposed amendments relating to the Lords’ Register of Interests and the process for handling complaints and breaches of the requirement to register directorships and roles as “person with significant control”.
In collaboration with Perplexity AI, here is a summary and assessment of the proposed Revised Code of Conduct, relating to registration of interests checking for potential conflicts with the Companies Act 2006.
Proposed Changes to the Register of Lords' Interests relating to transparency
The proposed Revised Code of Conduct, Revised Guide and Enforcement procedure for general complaints are reproduced in Annex 1, 2 and 3 of this document.
Referring to the current Code of Conduct and the revised Code of Conduct, the key changes proposed to the House of Lords' Register of Interests are:
Removal of Non-Financial Interests: Elimination of the requirement for members to register non-financial interests.
“Non-financial interests”: Definition in the current Code of Conduct.
“The following non-financial interests are always relevant and therefore must be registered:
unremunerated directorships or other regular employment;
membership of public bodies such as hospital trusts, the governing bodies of universities, colleges or schools, local authorities and other spheres of government;
trusteeships of museums, galleries or similar bodies;
acting as an office-holder or trustee in pressure groups or trade unions; and
acting as an office-holder or trustee in voluntary or not-for-profit organisations.”
Enforcement Procedure. “The committee recommended establishing two types of enforcement procedure: one for general breaches and another for breaches involving bullying, harassment and sexual misconduct. General breaches would be subject to a new ‘minor cases procedure’. As part of this procedure, the details of the case would not be made public once they were resolved.”
The following changes are also included in the Revised Code of Conduct although the changes to Categories 1, 2, and 3 were omitted from the debate summary.
Streamlining Financial Interest Categories:
Categories 1 (Directorships) and 2 (Remunerated Employment, etc.) would be merged. The revised guidance omits specifying the requirement to declare Spouses' Directorships.
Category 3 (People with Significant Control of a Company) would be removed because this information duplicates data held by Companies House.
Category 10 (Non-Financial Interests) would be removed entirely.
These additional change represent significant change and are important because they have the potential to reduce transparency and accountability within the House of Lords.
Critical Assessment
Strengths of proposed changes
Reduced Burden: Removing the requirement to register non-financial interests would significantly reduce the administrative burden on members and the Registrar. This could free up resources to focus on more important aspects of the Register.
Focus on Financial Transparency: By focusing on financial interests, the Register becomes more targeted and relevant to its core purpose: ensuring transparency regarding potential conflicts of interest that could influence a member's parliamentary activities.
Simplification: Reducing the number of categories and rationalizing thresholds makes the Register easier to understand and comply with.
Weaknesses:
1. Registration and Declaration of Interests
1.1. Non-Financial Interests
Current Code: Requires registration of non-financial interests that "may affect the public perception of the way in which they discharge their Parliamentary duties." (See paragraphs 63-66 in the document)
Revised Code: Removes the requirement to register non-financial interests entirely. (See paragraphs 62 & 67 in the document)
Concern: This could lead to a lack of transparency regarding potential influences on members' parliamentary activities that aren't directly tied to financial gain, but can still influence decisions.
1.2. Spouse or partner's Directorships
Current Code: Requires declaration of spouse or partner’s directorships if they fall under the categories of registrable interest and could create a perceived conflict (Paragraph 45).
Revised Code: Removes specific mention of spouses' directorships, potentially creating a loophole. This is a significant change that the document fails to explicitly address.
Concern: The removal of the requirement to declare spouses’ directorships might be thought by a reasonable member of the public to conceal influences that may effect the way in which a member of the House of Lords discharges his or her parliamentary duties.
1.3. Person with Significant Control (PSC) Roles
Current Code: Requires registration of positions as a Person with Significant Control of a company for the peer and their spouse or partner.
Revised Code: Removes this requirement, stating that the information is available at Companies House (Paragraph 71).
Concern: The argument that PSC information is readily available via Companies House is undermined by the fact that searching for PSCs by name on Companies House is difficult. The data is only available as a continuous text file, making it impractical for the average person to find relevant information. This reduces the transparency that the Register of Lords' Interests currently provides.
2. Enforcement Procedures
2.1. Minor Cases Procedure
Revised Code: Introduces a "minor cases procedure" for general complaints (Paragraph 99-102) where the breach appears less serious.
Concern: This may result in less scrutiny and transparency for certain breaches, as these cases will be disposed of quickly with a published summary of the case and outcome. There is now a provision to dismiss a complaint and not publish full reports (Paragraph 101).
2.2. “Minor and inadvertent errors”
Revised Code: Downplays the significance of 'minor and inadvertent errors' in legal documents and omissions from the Register of Interests (Paragraph 68).
Concern: The Revised Code of Conduct fails to address the inherent risks posed by even seemingly insignificant inaccuracies in legal documents and declarations of interest. My compliance assessments of Baroness Morgan of Huyton, Lord Fink, Baroness Smith of Basildon, and Lord Alli have revealed a pattern of multiple identities and frequent errors in declarations. While individually these discrepancies might appear minor or inadvertent, their cumulative effect can be substantial. Such errors can induce 'false non-match errors' in audit and Know Your Customer (KYC) compliance monitoring systems, creating vulnerabilities that can be exploited to facilitate money laundering. By downplaying the seriousness of these errors, the Revised Code of Conduct may inadvertently weaken safeguards against financial crime. This also raises concerns about compliance with the duty of reasonable care, skill, and diligence under Section 174 of the Companies Act 2006. By downplaying the seriousness of these errors, the Revised Code of Conduct may inadvertently weaken safeguards against financial crime.
2.3. Time Limit for Complaints
Revised Code: Paragraph 98: The standard time limit for complaints has been reduced from six to four years, bringing the Code back in line with the pre-2020 requirements.
3. Peer’s with breaches of the Companies Act 2006
3.1 Director's Responsibilities
Current and Revised Code: The Conduct Committee does not consider breaches of the Companies Act 2006 (CA2006) to be a parliamentary matter. For example, a) a peer with multiple identities in Companies House, which breaches section 1082 (CA2006) or, b) a company dissolved with accounts overdue, which is a breach of section 441 (CA2006).
Concern: When a company is dissolved with overdue accounts, the directors carry responsibility for that breach of the law. Being in breach of the law can make a director vulnerable to influence or coercion (e.g. blackmail) that could affect their judgment in parliamentary matters. When an individual has multiple identities registered in Companies House it conceals interests from auditors and Know Your Customer checks, compromising audits and Anti-Money Laundering legislation.
Implication: If a Peer's interests are not compliant with the law there is a strong argument that this becomes a Parliamentary matter as that Peer is not a fit and proper person to be a member of the House of Lords.
Compliance with Companies Act 2006
It's possible that omitting the requirement for Peers to declare their non-financial interests and their spouses' directorships and PSC roles could inadvertently lead to breaches of the Companies Act 2006, specifically sections 175 and 177. Here's why:
Interrelation of Duties: While the House of Lords' Code of Conduct and the Companies Act 2006 are separate regimes, they both aim to promote transparency and accountability. Section 175 imposes a duty on directors to avoid conflicts of interest, and section 177 requires directors to declare interests in proposed transactions or arrangements with the company.
Potential Conflict: If a member of the House of Lords is also a director of a company (or their spouse is), their parliamentary activities could potentially influence decisions made by that company, or vice versa. For example, a Peer could participate in a debate on legislation that affects a company of which they are a director. If this is not transparent it could be a breach of their duty under the Companies Act.
Register of Interest and Enforcement: Organisations publish their officers’ register of interest as a mitigating and managing strategy. Omitting the requirement for Peers to declare interests, as described above, then a director may not be able to fulfil their duties under Section 175 of the Companies Act, because there is no single reference point.
Conclusion: The removal of mandatory registration of non-financial interests and spouses' directorships could create an environment where members inadvertently breach their duties under the Companies Act 2006. For example, if a member or their spouse is a director of a company considering a transaction with a government entity, and the member participates in parliamentary discussions about that entity without disclosing the connection, it could be argued that they have failed to avoid a conflict of interest (Section 175) or declare their interest (Section 177).
Conclusion
The proposed revisions to the Code of Conduct raise significant concerns about weakening transparency and accountability within the House of Lords. The removal of requirements to register non-financial interests, spouses' directorships, and PSC roles, combined with changes to enforcement procedures and the failure to address the vulnerability of members associated with companies dissolved with overdue accounts, may create loopholes and reduce public confidence in the integrity of the House.
Actionable Recommendations
Reconsider the removal of “Non-financial” and spouses' directorships.
Reconsider removal of PSC Information or advocate for Companies House to provide searchable access online.
Conduct a legal review on whether the proposed changes could inadvertently create conflicts with directors' duties under the Companies Act 2006.
Remove the “minor and inadvertent” descriptor.
Compliance Assessment Overview
The following assessments evaluates the compliance of the House of Lords Conduct Committee members with the current Code of Conduct and relevant regulations. The Committee, responsible for overseeing the Code of Conduct and the work of the House of Lords Commissioner for Standards, must adhere to the highest standards of integrity and transparency.
Committee Composition
The Conduct Committee consists of:
Cindy Butts (lay member)
Mark Castle (lay member)
Andrea Coomber (lay member)
Dr Vanessa Davies (lay member)
Lord Garnier
Baroness Kidron
Baroness Mallalieu
Baroness Manningham-Buller (Chair)
Lord Scriven
A compliance assessment of each of the Peers follows, identifying, multiple identities, if they occur, comparing directorships with the Peer’s Register of Interest and identifying evident breaches of the Companies Act 2006, which are crimes.
1. Assessment of Lord Garnier
Registration of Interests
Lord Garnier’s Register of Interests is reproduced in full below and located here: Lord Garnier Register of Interests - Members of the House of Lords - UK Parliament (https://members.parliament.uk/members/lords/interests/register-of-lords-interests?SearchTerm=Garnier&ShowAmendments=True).
“Category 2: Remunerated employment, office, profession etc.
Interest deleted 12 May 2020 Practising Barrister (Queen's Counsel), One Brick Court Chambers and Head of Chambers (unpaid role) (interest ceased 30 April 2019) (originally added 16 July 2018)
Interest amended 9 January 2023 Practising Barrister (King's Counsel), 4 Pump Court Chambers, Temple, London EC4Y 7AN (originally added 6 May 2019)
Interest deleted 7 May 2024 Consultant, DLA Piper UK LLP (solicitors) (originally added 26 August 2020)
Interest amended 16 December 2024 Adviser, Hawthorn Advisers (member advised CEO of Hawthorn on matters relating to the business and where permitted also advised on client-related issues; member had no immediate engagement with clients) (strategic communications consultants) (interest ceased 22 April 2024) (originally added 27 October 2020)
Interest amended 24 April 2024 The member received £100,000 - £200,000 including VAT in professional fees and expenses from the government of the Isle of Man for conducting an independent review and thereafter reporting to the government on the provision of legal services on the island, 23 March 2023 (originally added 11 March 2022)
Interest amended 24 April 2024 The member received £50,000-£60,000 in professional fees as a barrister from the government of Nigeria, 2 November 2022 (originally added 29 November 2022)
Interest deleted 29 June 2024 The member received US$5,000 (excluding VAT) in professional fees from EY Law Co for advising government of Zambia by telephone, 26 June 2023 (originally added 27 June 2023)
Category 4: Shareholdings (b)
Interest amended 4 May 2021 Alphabet Inc (technology) (originally added 4 May 2021)
Interest deleted 23 April 2024 Apple Inc (technology) (originally added 4 May 2021)
Interest deleted 23 April 2024 Davide Campari-Milano NV (beverages) (originally added 4 May 2021)
Interest deleted 23 April 2024 L’Oréal SA (cosmetics) (originally added 4 May 2021)
Category 10: Non-financial interests (a)
Interest amended 16 December 2024 Director and Trustee, Prison Reform Trust (interest ceased 10 December 2024) (originally added 16 July 2018)
Interest amended 27 October 2020 Director and Trustee, China Oxford Scholarship Fund (originally added 16 July 2018)
Interest deleted 18 September 2021 Senior Adviser, Sanctuary Counsel Ltd (strategic communications and reputation management consultancy) (interest ceased 14 September 2020) (originally added 6 May 2019)
Interest amended 29 April 2021 Member, Advisory Board, Karkin & Yuksel Legal Services Ltd (law firm based in London) (originally added 29 April 2021)
Category 10: Non-financial interests (b)
Interest amended 4 July 2022 Bencher, Middle Temple (originally added 6 May 2019)
Category 10: Non-financial interests (e)
Interest amended 7 June 2021 Member, Taskforce on the Trans-Atlantic Response to Illicit Finance (TARIF), Centre for Financial Crime and Security Studies (CFCS), RUSI (originally added 7 June 2021)
Interest amended 28 January 2025 Director, Historic Houses Association (interest ceased 15 January 2025) (originally added 15 March 2022)
Interest amended 15 July 2024 Member, Board of Trustees, Hunterian Collection, Royal College of Surgeons (originally added 15 July 2024)”
Lord Garnier’s registrations in Companies House
The first twenty officers returned in a search on “Edward Garnier” are copied below Edward Garnier - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Edward%20Garnier):
Total number of appointments 6 - Born October 1952
Highdown House, 11 Highdown Road Sydenham, Leamington Spa, Warwickshire, CV31 1XT
Total number of appointments 1 - Born January 2002
85 Great Portland Street, London, England, W1W 7LT
Total number of appointments 0 - Born January 2002
Sugar Hill, Bickley, Tenbury Wells, Worcestershire, England, WR15 8LU
Total number of appointments 1 - Born March 1974
Castle House, Castle Street, Guildford, Surrey, England, GU1 3UW
Total number of appointments 0 - Born July 1986
Unit 6, Brighton Buildings 60 Tower Bridge Road, London, United Kingdom
Total number of appointments 7 - Born July 1986
20a, Ironmonger Lane, London, England, EC2V 8EP
Total number of appointments 1 - Born July 1986
20a, Ironmonger Lane, London, United Kingdom, EC2V 8EP
Total number of appointments 4 - Born July 1986
20a, Ironmonger Lane, London, United Kingdom, EC2V 8EP
Total number of appointments 6 - Born July 1967
Guy Harlings, 53 New Street, Chelmsford, Essex, CM1 1AT
CHURCHER GARNIER RAYNER LIMITED
Total number of appointments 1
115 Westbourne Studios, 242 Acklam Road, London, , , W10 5JJ
JH GARNIER & ASSOCIATES LIMITED
Total number of appointments 1
Lydham Manor, Bishops Castle, Shropshire, SY9 5HA
Total number of appointments 1
18 Chesford Grange, Woolston, Warrington, Cheshire, United Kingdom, WA1 4RQ
Total number of appointments 0
Ibp, Whitehall Road, Tipton, West Midlands, United Kingdom, DY4 7JU
Total number of appointments 1
Unity Chambers, 34 High East Street, Dorchester, Dorset, United Kingdom, DT1 1HA
Total number of appointments 1
28 Wilton Road, Bexhill On Sea, East Sussex, United Kingdom, TN40 1EZ
Total number of appointments 1
Victoria House, 14-26 Victoria Street, Luton, England, LU1 2UA
EDWARD JAMES INVESTMENTS LIMITED
Total number of appointments 1
Acre House, 11/15 William Road, London, England, NW1 3ER
Total number of appointments 1
25 Charmouth Road, Newbridge, Bath, Somerset, United Kingdom, BA1 3LJ
EDWARD H MARSTON & COMPANY DEVELOPMENTS TRADING LIMITED
Total number of appointments 1
6th Floor, 338 Euston Road, London, United Kingdom, NW1 3BG
Total number of appointments 0
1 Cas Ruffelsestraat, Rotterdam, The Netherlands, 3056 PG”.
Analysis of the first twenty officers returned in the search on “Andrew Garnier” in Companies House
There is one identity named "Lord Edward Henry GARNIER”:
Total number of appointments 6 - Born October 1952
Highdown House, 11 Highdown Road Sydenham, Leamington Spa, Warwickshire, CV31 1XT
As there are no other identity with this name and date of birth returned in the search Lord Garnier appears to comply with the requirements for an individual to have a single unique identifier.
There is evidence that other officers, who have names that include “Edward Garner” hold potentially duplicated identities. This will be discussed further after considering Lord Garnier’s companies.
Edward Henry GARNIER company appointments in Companies House.
The appointments associated to the unique identity for Edward Henry Garnier are expanded below.
Total number of appointments 6
Date of birth October 1952
CHINA OXFORD SCHOLARSHIP FUND (05232003) Company status Active Correspondence address Highdown House, 11 Highdown Road Sydenham, Leamington Spa, Warwickshire, CV31 1XT Role Active Director Appointed on 28 June 2013 Nationality British Country of residence United Kingdom Occupation Qc And Mp
HISTORIC HOUSES ASSOCIATION (02001057) Company status Active Correspondence address Warwick House, 25 - 27 Buckingham Palace Road, London, England, SW1W 0PP Role Resigned Director Appointed on 1 April 2022 Resigned on 16 January 2025 Nationality British Country of residence England Occupation Barrister (Qc)
PRISON REFORM TRUST (02906362) Company status Active Correspondence address 15 Northburgh Street, London, EC1V 0JR Role Resigned Director Appointed on 19 November 2015 Resigned on 11 December 2024 Nationality British Country of residence England Occupation Member Of Parliament
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034) Company status Active Correspondence address Megarry House 119 Chancery Lane, London, WC2A 1PP Role Resigned Director Appointed on 22 May 2010 Resigned on 4 September 2012 Nationality British Country of residence England Occupation Mp, Barrister
CHINA OXFORD SCHOLARSHIP FUND (05232003) Company status Active Correspondence address 10 Guildford Road, London, SW8 2BX Role Resigned Director Appointed on 18 June 2006 Resigned on 4 June 2010 Nationality British Country of residence England Occupation Member Of Parliament
GREAT BRITAIN-CHINA CENTRE(THE) (01196043) Company status Active Correspondence address 10 Guildford Road, London, SW8 2BX Role Resigned Director Appointed on 10 September 1998 Resigned on 4 June 2010 Nationality British Country of residence England Occupation Mp, & Queen'S Council”
Comparison of Companies House appointments with Register of Interests
Comparing Lord Garnier's Companies House appointments with his Register of Interests since he assumed office on 5 July 2018 reveals some discrepancies:
China Oxford Scholarship Fund:
Companies House: Appointed 28 June 2013, still active
Register: Listed as "Director and Trustee" since 16 July 2018
This was registered within six weeks of assuming office. Compliant
Historic Houses Association:
Companies House: Appointed 1 April 2022, resigned 16 January 2025
Register: Listed as "Director" from 15 March 2022 to 15 January 2025
Slight differences in appointment date, registering the interest two weeks before he was appointed, which is anomalous. Resignation date in the register is one day before it occurred, which is incorrect. Non-compliant.
Prison Reform Trust:
Companies House: Appointed 19 November 2015, resigned 11 December 2024
Register: Listed from 16 July 2018 to 10 December 2024
Correctly registered when he assumed office. Compliant
Resignation date in the register is one day before it occurred, which is incorrect.
Incorporated Council of Law Reporting for England and Wales:
Companies House: Appointed 22 May 2010, resigned 4 September 2012
Register: Not listed. This appointment was prior to becoming a Lord in 2018 and not required to be disclosed. However, voluntary disclosure is required by the Companies Act 2006.
Great Britain-China Centre:
Companies House: Appointed 10 September 1998, resigned 4 June 2010
Register: Not listed. This appointment was prior to becoming a Lord in 2018 and not required to be disclosed. Resignation date in the register is one day before it occurred, which is incorrect.
Minor discrepancies in his early registration of Historic Houses Association raise minimal concern about the accuracy and completeness of Lord Garnier's Register of Interests.
General: The current Register of Interests for Lord Garnier appears to be in compliance with the requirements for the time period since his appointment, with minor variations on appointment and resignation dates.
Significant concern is raised relating to his prior association to GREAT BRITAIN-CHINA CENTRE(THE) (https://find-and-update.company-information.service.gov.uk/company/01196043), as this was an interest held by Victoria Mary Boswell PRENTIS appointed on 14 June 2018 resigned on 31 March 2020 (https://find-and-update.company-information.service.gov.uk/officers/Qix00IAi2FJAgW4iGUmD_dq_xZY/appointments).Victoria Prentis failed to declare this interest. For example, in the register of interests dated 191105.pdf https://publications.parliament.uk/pa/cm/cmregmem/191105/191105.pdf).
Victoria Prentis is also a recently resigned director of INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034). This is a second interest that she holds in common with Lord Garnier. The shared connection to Great Britain-China Centre(The) is a concern, given that both parties did not disclose it in their Registers of Interests.
There is a second identity for Victoria Mary Boswell PRENTIS in breach of section 1082. Victoria Prentis is the subject of this report:
Other “Edward Garnier” findings.
There is evidence that other officers, who have names that include “Edward Garner” hold potentially duplicated identities. These may not be related to Lord Garnier but present a potential risk if they are associated.
Edward Peter Benedict GARNIER born January 2002:
Edward Peter Benedict GARNIER identity 1
Total number of appointments 1 - Born January 2002
85 Great Portland Street, London, England, W1W 7LT
EPBG ADVISORY LIMITED (14978987) Incorporated on
4 July 2023 Nature of business (SIC) 70229 - Management consultancy activities other than financial management
Edward Peter Benedict GARNIER identity 2
Total number of appointments 0 - Born January 2002
Sugar Hill, Bickley, Tenbury Wells, Worcestershire, England, WR15 8LU
THE OLD BOND STREET LTD (13242202) Company status Dissolved Appointed on 3 March 2021 Dissolved on 12 March 2024 Incorporated on 3 March 2021 Accounts Last accounts made up to 31 March 2023 Accounts overdue
There are two identities for Edward Peter Benedict GARNIER born January 2002 with two different addresses. The probability that these are identities claimed by the same person are very high. If confirmed then Edward Peter Benedict GARNIER born January 2002 is in breach of section 1082 of the Companies Act 2006.
Assume accounts are up to date in the selected records below, unless stated otherwise. Selected information is included to reduce the length of the record by including key information, only.
George Edward GARNIER
George Edward GARNIER identity 1
Total number of appointments 0 - Born July 1986
Unit 6, Brighton Buildings 60 Tower Bridge Road, London, United Kingdom
OTHER ROOM LTD (09733857) Dissolved on
24 January 2017 No accounts submitted Nature of business (SIC) To be provided on next annual return. Breach
George Edward GARNIER identity 2
Total number of appointments 7 - Born July 1986
20a, Ironmonger Lane, London, England, EC2V 8EP
AS HACKNEY LIMITED (15297948) Active Director Appointed on 21 November 2023
KENNINGTON ARTS CLUB LIMITED (13664373) Company status Liquidation Registered office address Griffins, Tavistock House North, Tavistock Square, London, WC1H 9HR Incorporated on 6 October 2021 Accounts overdue Next accounts made up to 31 October 2023 due by 31 July 2024 Last accounts made up to 31 October 2022 Confirmation statement overdue Next statement date 5 October 2023 due by 19 October 2023 Last statement dated 5 October 2022 Nature of business (SIC) 56302 - Public houses and bars
H.J. FRANCIS LIMITED (00384867) Director Appointed on 16 September 2021 Incorporated on 10 January 1944 Nature of business (SIC) 96090 - Other service activities not elsewhere classified 3 charges registered 3 outstanding Persons entitled Shawbrook Bank Limited 1 active person with significant control / 0 active statements Artistic Spaces Group Limited Correspondence address 20a, Ironmonger Lane, London, United Kingdom, EC2V 8EP Notified on 27 January 2022
MONIER AS 1 LIMITED (13542007) Incorporated on 2 August 2021 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate 2 charges registered 2 outstanding Persons entitled Interbay Funding, LTD. 1 active person with significant control / 0 active statements Artistic Spaces Group Limited
MONIER AS 2 LIMITED (13541236) Active Director Appointed on 30 July 2021 Incorporated on 30 July 2021 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate 3 charges registered 3 outstanding, Persons entitled Franove Holdings Limited, Gfs 1 LTD
CITY ARTS HOSPITALITY LTD (13522471) Active Director Appointed on 21 July 2021 Incorporated on 21 July 2021 Nature of business (SIC) 56302 - Public houses and bars Previous company names CITY ARTS CLUB LIMITED 21 Jul 2021 - 21 Mar 2022
WORKERBEE DEVELOPMENTS LTD (12213946) Active
Director Appointed on 18 September 2019 Incorporated on
18 September 2019 Nature of business (SIC) 41100 - Development of building projects 1 charge registered
1 outstanding Persons entitled Franove Holdings Limited 1 active person with significant control / 0 active statements Artistic Spaces Group Limited
George Edward GARNIER identity 3
Total number of appointments 1 - Born July 1986
20a, Ironmonger Lane, London, United Kingdom, EC2V 8EP
AS LONDON 1 LIMITED (15326407) Active Director Appointed on 4 December 2023 Incorporated on 4 December 2023 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate 1 active person with significant control / 0 active statements Artistic Spaces Group Limited
George Edward GARNIER identity 4
Total number of appointments 4 - Born July 1986
20a, Ironmonger Lane, London, United Kingdom, EC2V 8EP
ARTISTIC SINCLAIRS 1 LIMITED (13604773) Active Director Appointed on 6 September 2021 Incorporated on 6 September 2021 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate 3 charges registered 3 outstanding, 1 active person with significant control / 0 active statements Artistic Spaces Group Limited
BERMONDSEY ARTS CLUB LTD (08693863) Active Director Appointed on 17 September 2013 Incorporated on
17 September 2013 Nature of business (SIC) 56302 - Public houses and bars
RAGPICKER LTD (07979824) Company status Dissolved Appointed on 7 March 2012 Dissolved on 23 August 2016 Company type Private limited Company Incorporated on 7 March 2012 Accounts Last accounts made up to 31 March 2015 Accounts overdue Annual return Last annual return made up to 7 March 2015 Nature of business (SIC) 14190 - Manufacture of other wearing apparel and accessories not elsewhere classified
ARTISTIC SPACES LIMITED (07150124) Active Director Appointed on 8 February 2010 Incorporated on 8 February 2010 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate 14 charges registered
9 outstanding Persons entitled Shawbrook Bank Limited 1 active person with significant control / 0 active statements Artistic Spaces Group Limited
LES TROIS COQUES LTD (10064624) Appointed on 15 March 2016 Resigned on 20 December 2019 Incorporated on 15 March 2016 Nature of business (SIC) 56101 - Licensed restaurants 1 active person with significant control / 0 active statements Mrs Batkhishig Namsraijav Date of birth February 1974
There are four identities for George Edward GARNIER born July 1986 with two different addresses. With the same name, date of birth and address in common for three identities it is therefore very likely that the fourth identity with this name and date of birth is also a claimed identity of George Edward GARNIER.
George Edward GARNIER born January 2002 appears to have breached section 1082 of the Companies Act 2006 on two counts and, if the identity registered at “Unit 6, Brighton Buildings 60 Tower Bridge Road, London, United Kingdom” is confirmed to belong to the same person, then he has breached section 1082 of the Companies Act 2006 three times.
Repeating the search on the name “Edward Garnier” a second time presented some different results, which included a further duplication:
Laetitia Marie Edmee Jehanne ALBERTINI EP. GARNIER:
Laetitia Marie Edmee Jehanne ALBERTINI EP. GARNIER
Total number of appointments 0 - Born August 1980
Suites 4007-09, 40th Floor, One Island East, Taikoo Place, 18 Westlands Road, Quarry Bay, Hong Kong, Hong Kong
Laetitia Marie Edmee Jehanne ALBERTINI EP. GARNIER
Total number of appointments 0 - Born August 1980
Suites 4007-09, 40th Floor, One Island East, Taikoo Place, 18 Westlands Road, Quarry Bay, Hong Kong, Hong Kong
There are two identities for Laetitia Marie Edmee Jehanne ALBERTINI EP. GARNIER with the same seven names, date pf birth and address. It is apparent that Laetitia Marie Edmee Jehanne ALBERTINI EP. GARNIER has breached section 1082 of the Companies Act 2006.
A search on “Henry Garnier” returns two identities with the same three names:
Clint Henry GARNIER identity 1
Total number of appointments 0 - Born July 1986
Flat 14 The Piper Building, Peterborough Road, London, United Kingdom, SW6 3EF
PROJECT FEELGOOD LIMITED (12247581) Appointed on 7 October 2019 Dissolved on 22 September 2020 Company type Private limited Company Incorporated on 7 October 2019 No accounts submitted Nature of business (SIC) 47710 - Retail sale of clothing in specialised stores 1 person with significant control / 0 statements Mr Clint Henry Garnier
SOLIOUS LIMITED (10401757) Appointed on 29 September 2016 Dissolved on 2 October 2018 Company type Private limited Company No accounts submitted Incorporated on 29 September 2016 Nature of business (SIC) 47650 - Retail sale of games and toys in specialised stores 1 person with significant control / 0 statements Mr Clint Henry Garnier
Clint Henry GARNIER identity 2
Total number of appointments 1 - Born July 1986
Flat 5, 150 Finborough Road, London, United Kingdom, SW10 9AH
Clint Henry Garnier, born July 1986, appears to have two identities registered in Companies House, in breach of section 1082 of the Companies Act 2006.
Other potential familial interests
Lord Garnier married Anna Caroline Mellows on 17 April 1982. A search in Companies House for “Anna Caroline Garnier” return no entries with this name (https://find-and-update.company-information.service.gov.uk/search/officers?q=Anna+Caroline+Garnier).
However, a search for “Anna Garnier” returns an identity for “Annabelle Elise Garnier”, born May1980, who may be related to Lord Garnier, possibly his daughter.
Total number of appointments 1 - Born May 1989
41 Keswick Avenue, London, England, SW15 3QH
This identity has one appointment to:
“S&S EC SERVICES LLP (OC437546) Company status Active Correspondence address 41 Keswick Avenue, London, England, SW15 3QH Role Active LLP Designated Member Appointed on 1 March 2023 Country of residence England”
This is a significant undertaking, with 455 officers / 72 resignations, with a single person with significant control:
“Khaoula Mehar Active Correspondence address 41 Keswick Avenue, London, England, SW15 3QH Notified on 1 July 2022 Governing law Limited Liability Partnership Act 2000 Legal form Lawyer Nature of control Right to appoint or remove members Right to appoint or remove members with control over the trustees of a trust Right to appoint or remove members as a member of a firm”
If Annabelle Elise Garnier is indeed related to Lord Garnier, it would be appropriate for him to declare S&S EC SERVICES LLP as a related party interest. The scale and nature of this LLP's operations warrant transparency, especially given Lord Garnier's position on the Conduct Committee.
Conclusion based on the search results returned for “Edward Garnier”.
While Lord Garnier himself appears to have a single identity in Companies House records, there are concerning instances of potential multiple identities among individuals sharing his surname. This raises questions about whether any of these are a related party of Lord Garnier.
MR EDWARD KATUMBA
A record for “MR EDWARD KATUMBA” was returned in the first twenty search results for Edward Garnier. Companies House appears to associate this identity to “Edward Garnier”, ahead of any other Garnier identity, which is anomalous:
Total number of appointments 1
25 Charmouth Road, Newbridge, Bath, Somerset, United Kingdom, BA1 3LJ
QUANTUM MANIVERSE LTD (12313136) Active Director Appointed on 13 November 2019 Incorporated on
13 November 2019 1 active person with significant control / 0 active statements Mr Edward Katumba Nature of business (SIC)
46120 - Agents involved in the sale of fuels, ores, metals and industrial chemicals
46140 - Agents involved in the sale of machinery, industrial equipment, ships and aircraft
46180 - Agents specialised in the sale of other particular products
46190 - Agents involved in the sale of a variety of goods”
The author of this report reported to Sussex Police in 2020 that I had reason to believe that a person named Edward KATIMBO-MUGWANYA of TRI-CONTINENTAL LIMITED was associated to serious organised crime. (https://find-and-update.company-information.service.gov.uk/officers/lWIesbDW5956Q5sTNc0i1bo5vWc/appointments). Given the similarity in the names it is prudent to query whether MR EDWARD KATUMBA is another identity Edward KATIMBO-MUGWANYA, and whether either or both of these identities are associated to Lord Garnier, since Mr Edward Katumba was returned in a search on the name of Lord Garnier in Companies House.
A search on the name Edward Katumba returns 3 identities, Edward Katumba - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Edward+Katumba)
Total number of appointments 2 - Born May 1992
New, Bridge, 25 Charmouth Road, Bath, United Kingdom, BA1 3LJ
Total number of appointments 1
25 Charmouth Road, Newbridge, Bath, Somerset, United Kingdom, BA1 3LJ
Total number of appointments 1
25 Charmouth Road, Newbridge, Bath, Somerset, United Kingdom, BA1 3LJ”
Each identity is associated to Quantum Maniverse. This creates a risk that three bank accounts have been established and which may not all be accounted for within the annual accounts.
Edward Katumba has an additional directorship associated to the first of his three identities:
“SKY FORCE VENTURES LTD (12405902) Active Director Appointed on 15 January 2020 Registered office address Regent 88 42 - 46 Hagley Road, Birmingham, West Midlands, England, B16 8PE Company status Active — Active proposal to strike off Company type Private limited Company Incorporated on 15 January 2020 Accounts overdue Next accounts made up to 31 January 2024
due by 31 October 2024 Last accounts made up to 31 January 2023 Confirmation statement overdue Next statement date 14 January 2025 due by 28 January 2025 Last statement dated 14 January 2024 Nature of business (SIC) 64304 - Activities of open-ended investment companies 2 active persons with significant control / 0 active statements Miss Charlotte Kwizera Date of birth July 1987 Mr Edward Katumba Date of birth May 1992”
A search on the name of the other person with significant control, Charlotte Kwizera, returns multiple identities with this name and date of birth, Charlotte Kwizera - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Charlotte+Kwizera):
Total number of appointments 1 - Born July 1987
504, 42-46 Avix Business Centre, Hargley Road, Birmingham, United Kingdom, B16 8PE
Total number of appointments 4 - Born July 1987
8 Cannon Park Way, Coseley, Bilston, England, WV14 8XG
Total number of appointments 0 - Born July 1987
18 Cannon Park Way, Coseley, Bilston, WV14 8XG
Total number of appointments 0 - Born July 1987
53 Donald Road, Croydon, London, England, CR0 3EQ
Total number of appointments 0 - Born July 1987
59 Westbourne Road 59 Westbourne Road, Handsworth, Birmingham, Choose A County, Great Britain, B21 8AU
Total number of appointments 1 - Born July 1987
315 Soho Road, Birmingham, United Kingdom, B21 9SD
Arthur KWIZERA (NON EXECUTIVE)
Total number of appointments 1 - Born May 1977
9 Red Hill Lane, Great Shelford, Cambridge, England, CB22 5JR
Total number of appointments 0 - Born May 1979
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Total number of appointments 1 - Born November 1990
Unit 3 38 Carters Green, West Bromwich, United Kingdom, B70 9LG
Total number of appointments 1 - Born July 1987
18 Cannon Parkway, Coseley, West Midlands, United Kingdom, WV14 8XQ”
Charlotte / Charllote Kwizera appears to have six identities registered in breach of section 1082 of the Companies At 2006. These require further investigation.
Conclusion
The spirit of the Code of Conduct emphasizes transparency and accountability. While Lord Garnier may not have been obligated to register his earlier interests in Great Britain-China Centre(The) and Incorporated Council of Law Reporting for England and Wales by voluntarily disclosing these a more comprehensive history of significant roles could align with the principles of openness and integrity outlined in the Code of Conduct.
The current Register of Interests for Lord Garnier appears to be in compliance with the requirements for the time period since his appointment. It includes his current employment, recent advisory roles, and non-financial interests, which seem to reflect his activities since joining the House of Lords. Clarification is requested related to the potential related parties that are listed.
The revised Code of Conduct, as exemplified by the case of Lord Garnier, raises serious questions about its effectiveness in upholding transparency and accountability within the House of Lords. While the Commissioner's report acknowledges breaches of the Code, the focus on individual instances and the downplaying of the systemic risks associated with these breaches fails to address the core issues raised in this assessment.
Applying my research, I found several concerns about whether the appropriate declarations were made. The findings, suggest, even by very experienced legal minds within the House of Lords are having difficulty in complying with the requirements of the register. While not claiming non-compliance, it seems that in respect of Lord Garnier's registrations they were non-compliant with the obligations to declare.
Therefore, these breaches send the wrong signal both to other members of the House and to the public. The House of Lords must not be perceived as a forum where even "experienced legal minds" can exploit loopholes or disregard transparency requirements.
It is imperative that the Conduct Committee remind and if necessary, provide training on, the definition of what constitutes a registrable interest, and the handling of breaches related to Companies House discrepancies. Only through a more robust and comprehensive approach to transparency can the House of Lords maintain public trust and effectively prevent the potential for abuse.
Letter to Lord Garnier expressing My concerns about the Revised Code of Conduct and including a statement I'd like him to read during the House of Lords debate.
From: Alison Wright
3rd March 2025
To: The Rt Hon. Lord Garnier KC House of Lords London, SW1A 0PW
Subject: Deep Concerns Regarding the Revised Code of Conduct for the House of Lords
Dear Lord Garnier,
I am writing to you as a concerned citizen who has followed the Review of the Code of Conduct for the House of Lords with growing alarm. I understand that a motion to approve the Revised Code will be debated in the House on 5 March, and I urge you to carefully consider the points I raise below before that debate.
In short, I believe that the Revised Code, as currently drafted, represents a significant step backward in transparency and accountability within the House of Lords. While I appreciate the stated aim of shortening and clarifying the Code, the changes implemented achieve this goal at the expense of public trust and effective self-regulation.
My primary concerns are:
1. Removal of Mandatory Registration of Non-Financial Interests:
This decision creates a gaping loophole. I firmly believe that this change will allow members to conceal relevant relationships and affiliations that can influence their parliamentary activities, especially when those relationships do not involve direct financial gain.
2. Omission of Spouses' Directorships and PSCs:
The removal of the requirement for members to declare their spouses' directorships and positions as Persons with Significant Control (PSCs) is simply indefensible. These interests represent a clear potential for conflicts of interest, and their omission undermines any claim that the Revised Code is intended to enhance transparency.
3. Definition of 'Parliamentary Activities' and social media:
While social media may be a parliamentary activity, there has to be clarity of where and when the code is enforced.
4. "Reasonable Member of the Public" Test:
By prioritizing that what a reasonable member of the public thinks, could exclude any number of genuine claims.
5. Inadequate Enforcement Provisions and Minor or Inadvertent issues:
The minor or inadvertent issues are those that cause harm by breaching money laundering, however in the revised code they are downplayed.
6. Minor Cases Procedure and Transparency:
The introduction of a "minor cases procedure," is concerning to the public and requires further review.
Given these serious concerns, I respectfully request that you read the following statement during the debate on the Revised Code of Conduct on 5 March. I believe it encapsulates the genuine fears of many members of the public:
Proposed Statement for Lord Garnier to Read:
"My Lords, I rise today with serious concerns regarding the proposed Revised Code of Conduct.
I believe that it weakens transparency, undermines public trust, and potentially facilitates financial crime. Specifically, the removal of the requirement to register non-financial interests, spouses' directorships, and PSCs represents a significant step backward.
The government and this house has failed to address the concerns which the public have. The house must ensure members of the House are fit to practice without legal breaches. These proposed changes will make it easier for members to conceal potential conflicts of interest and to avoid scrutiny. We must reconsider these proposals.
I urge you to oppose this motion and to send the Revised Code back to the Conduct Committee for further revision."
I understand that you are a member of the Conduct Committee, and I would like to hear from you that due consideration is given to members of the public. I also understand that you will be required to comply with the the requirements of the code should you wish to vote. I request that you take my and other members of the public seriously as your actions are for the public interest.
I hope that you will find cause to vote as what is expected of you under the current Code of Conduct.
Yours sincerely,
Alison Wright
2. Baroness Kidron
Baroness Kidron’s register of interests, with amendments, is copied below.
“Category 1: Directorships
Interest amended 12 August 2024 Director, Cross Street Films (Trading) Ltd (working across creative and digital industries; film, TV, theatre, content and research) (originally added 5 July 2012)
Interest deleted 11 July 2018 Director, Cross Street Films Ltd (originally added 5 July 2012)
Interest amended 5 July 2012 Director, Bodyline Films Ltd (originally added 5 July 2012)
Interest deleted 2 May 2024 Director, Soho Angel Films Limited (interest ceased 30 April 2023) (originally added 13 August 2012)
Interest deleted 24 February 2016 Director, Film Nation (a private company limited by guarantee, no share capital) (originally added 9 November 2012)
Interest deleted 11 July 2018 Director, Film Nation (a private company limited by guarantee, no share capital, solely to support the charity Into Film (see category 10(e)) (originally added 7 January 2016)
Interest deleted 6 April 2021 Director, Freeformers Holding Ltd (provides digital training, including in banking, tech and public sectors) (no remuneration but member holds shares) (interest ceased 31 March 2020) (originally added 14 March 2017)
Interest deleted 6 April 2021 Director, The Imagine Workshop Ltd (interest ceased 31 March 2020) (originally added 11 July 2018)
Category 2: Remunerated employment, office, profession etc.
Interest amended 12 August 2024 Director and producer for independent film, theatre and television companies, including many major broadcasters and Streaming Video on Demand (SVOD) (interest ceased 12 August 2024) (originally added 5 July 2012)
Interest amended 12 October 2020 Occasional fees from writing articles, making speeches
and as a consultant adviser (originally added 5 July 2012)Interest deleted 28 February 2017 Partner in Cross Street Films Partnership (interest ceased 6 October 2015) (originally added 5 July 2012)
Interest deleted 11 July 2018 The Member is engaged in R&D of digital products under the TM Imagine Workshop, part of CSF (originally added 14 March 2017)
Interest amended 12 May 2023 Senior Fellow, Department of Computer Science, University of Oxford (originally added 12 May 2023)
Interest amended 12 May 2023 Supernumerary Fellowship, Jesus College, University of Oxford (originally added 12 May 2023)
Category 3: Person with significant control of a company (PSC)
Interest deleted 2 May 2024 Soho Angel Films Limited (interest ceased 30 April 2023) (originally added 11 July 2018)
Interest amended 12 August 2024 Cross Street Films (Trading) Ltd (working across creative and digital industries; film, TV, theatre, content and research) (originally added 11 July 2018)
Interest deleted 17 April 2023 The Imagine Workshop Ltd (interest ceased 12 April 2022) (originally added 11 July 2018)
Category 4: Shareholdings (a)
Interest amended 12 August 2024 Cross Street Films (Trading) Ltd (working across creative and digital industries; film, TV, theatre, content and research) (originally added 5 July 2012)
Interest deleted 11 July 2018 Cross Street Films Ltd (originally added 5 July 2012)
Interest amended 13 August 2012 Bodyline Films Limited (originally added 13 August 2012)
Interest deleted 13 May 2024 Soho Angel Films Limited (interest ceased 30 April 2023) (originally added 13 August 2012)
Interest deleted 17 April 2023 The Imagine Workshop Ltd (interest ceased 12 April 2022) (originally added 11 July 2018)
Category 4: Shareholdings (b)
Interest deleted 17 August 2021 Freeformers Holding Ltd (provides digital training, including in banking, tech and public sectors) (interest ceased 31 March 2020) (originally added 14 March 2017)
Category 5: Land and property
Interest amended 24 May 2016 Office accommodations in London (originally added 5 July 2012)
Category 6: Sponsorship
Interest amended 12 May 2023 Secretarial and other assistance in connection with the member’s parliamentary duties may be undertaken by employees of and in the offices of Cross Street Films (Trading) Ltd or 5Rights Foundation in connection with role as Chair (originally added 5 July 2012)
Category 7: Overseas visits
Interest amended 20 January 2025 Visit to Chile, 6-17 January 2025, to speak at Congreso Futuro’s Third World Summit of the Committees of the Future event and Scientific Conference in Santiago; travel (including a visit to Antarctica), accommodation and food costs met by organisers (originally added 20 January 2025)
Category 9: Miscellaneous financial interests
Interest deleted 24 February 2016 A one-off payment from the Shuttleworth Foundation to support the work the Member carries out for iRights (February 2015) (originally added 26 February 2015)
Category 10: Non-financial interests (a)
Interest deleted 1 December 2020 Commissioner, Joint Arts Council England and Durham University Commission on Creativity and Education (interest ceased 30 November 2019) (originally added 23 July 2019)
Interest amended 29 July 2021 Member, Advisory Council, Institute for Ethics in AI, University of Oxford (originally added 29 July 2021)
Interest amended 29 July 2021 Member, Executive Steering Group, Digital Makers Programme, Born in Bradford (originally added 29 July 2021)
Interest amended 2 May 2024 Member, Lancet Psychiatry Commission on Global Action on Problematic Usage of the Internet (originally added 2 May 2024)
Interest amended 2 May 2024 Member, Advisory Board, Online Safety Act Network (originally added 2 May 2024)
Category 10: Non-financial interests (b)
Interest deleted 10 February 2020 Visiting Fellow, Lady Margaret Hall, Oxford University (member's expenses are reimbursed and accommodation is provided) (interest ceased 31 January 2019) (originally added 7 January 2016)
Interest amended 10 March 2016 Commissioner, UNESCO Broadband Commission for Sustainable Development (originally added 10 March 2016)
Interest deleted 1 February 2018 Member, Children’s Commissioner Digital Taskforce (interest ceased 31 January 2017) (originally added 24 May 2016)
Interest deleted 2 March 2021 Member, Technical Board, WeProtect Global Initiative (interest ceased 29 February 2020) (originally added 11 July 2018)
Interest amended 29 July 2021 Visiting Professor in Practice, Department of Media and Communications, London School of Economics (originally added 29 July 2021)
Category 10: Non-financial interests (c)
Interest deleted 28 February 2017 Trustee, Paul Hamlyn Foundation (interest ceased 1 December 2015) (originally added 5 July 2012)
Interest deleted 10 July 2017 Council Member, Institute of Contemporary Arts (interest ceased 23 June 2016) (originally added 5 July 2012)
Category 10: Non-financial interests (d)
Interest amended 1 August 2024 Chair, Digital Futures for Children (joint research centre between London School of Economics and 5Rights Foundation) (originally added 1 August 2024)
Category 10: Non-financial interests (e)
Interest deleted 1 August 2020 Trustee, Into Film (formerly Film Club) (registered charity) (member is also a Director of the associated company, Film Nation UK) (interest ceased 31 July 2019) (originally added 5 July 2012)
Interest deleted 14 November 2013 Governor, British Film Institute (originally added 5 July 2012)
Interest deleted 24 February 2016 Trustee, Cross Street Charitable Foundation (registered charity) (in process of being closed and all monies transferred to the Kidron Hall Charitable Trust to which Member is a signatory) (interest ceased 1 March 2015: see below) (originally added 6 July 2012)
Interest deleted 1 August 2020 President, Voluntary Arts (interest ceased 31 July 2019) (originally added 14 November 2013)
Interest amended 1 August 2024 Chair of trustees, 5Rights Foundation (charity working on digital rights for children), and director of the associated company (originally added 10 July 2014)
Interest amended 14 December 2015 Trustee, Kidron Hall Charitable Trust (originally added 14 December 2015)
Interest deleted 2 January 2020 Member, The Royal Foundation Taskforce on the Prevention of Cyberbullying (interest ceased 31 December 2018) (originally added 24 May 2016)
Interest amended 11 July 2018 Member, Council on Extended Intelligence (originally added 11 July 2018)
Interest deleted 3 November 2021 Member, UNICEF Artificial Intelligence and Child Rights policy guidance group (interest ceased 31 October 2020) (originally added 10 June 2019)
Interest deleted 2 May 2024 Founding Executive Board Member, Data Protection Foundation (originally added 29 July 2021)”
Baroness Kidron's full title is The Baroness Kidron OBE. Her name is Beeban Tania Kidron, and she is a current member of the House of Lords. Beeban Tania Kidron was born May 1961 (age 63) her spouse is Lee Hall (m. 2003),
A search in Companies House on “Beeban Tania Kidron” returns the following results, only, as officer:
Total number of appointments 9 - Born May 1961
14 Fowler Road, London, England, N1 2EP
Total number of appointments 1 - Born May 1961
27 Mortimer Street, London, W1T 3BL
Total number of appointments 0
Oliaji Trade Centre 1st Floor, Victoria, Mahe, Seychelles
Total number of appointments 1
Courtney King House, Eastern Road, Flat 9, Brighton, England, BN2 0AP
Total number of appointments 0 - Born August 1964
19 Kingswood Avenue, London, Greater London, NW6 6LG
Total number of appointments 0 - Born March 1976
1a Arcade House Temple Fortune, London, United Kingdom, NW11 7TL
Total number of appointments 1 - Born January 1995
181 Frenchay Park Road, Bristol, England, BS16 1HB
Total number of appointments 1 - Born December 1959
1075 Grand Concourse 6r, Bronx, Ny 10452, United States
Total number of appointments 1 - Born December 1959
1075 Grand Concourse 6r, Bronx, Ny 10452, United States
Total number of appointments 2 - Born September 1937
53 Cromwell Tower, Barbican, London, United Kingdom, EC2Y 8DD
Total number of appointments 1 - Born December 1963
Ben Gefen 5y, Gedera, 70700, Israel
There are two identities with that include the two names Beeban KIDRON both born May 1961. It appears that Beeban Kidron is in breach of section 1082 of the Companies Act 2006.
There are two identities for Adam Elia KIDRON, born December 1959, with the same address. This appears to be two identities for the same person, in breach of section 1082 (CA2006).
The identities for Beeban Tania Kidron and Beeben Kidron are expanded below, assume accounts and confirmation statement are up to date unless stated otherwise:
Beeban Tania KIDRON identity 1
Total number of appointments 9 - Born May 1961
14 Fowler Road, London, England, N1 2EP
“Total number of appointments 11
Date of birth May 1961
5RIGHTS FOUNDATION (11271356) Company status Active Correspondence address 14 Fowler Road, London, England, N1 2EP Role Active Director Appointed on 22 March 2018 Nationality British Country of residence United Kingdom Occupation Filmmaker And Crossbench Peer Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 22 March 2018 Nature of business (SIC) 96090 - Other service activities not elsewhere classified
SOHO ANGEL FILMS LIMITED (08158274) Company status Dissolved Correspondence address 27 Mortimer Street, London, England, W1T 3BL Role Director Appointed on 26 July 2012 Nationality British Country of residence United Kingdom Occupation Director Incorporated on 26 July 2012 Dissolved on 23 May 2023 Accounts Last accounts made up to 31 December 2020
CROSS STREET FILMS (TRADING) LIMITED (05943059) Company status Active Correspondence address 27 Mortimer Street, London, United Kingdom, W1T 3BL Role Active Director Appointed on 21 September 2006 Nationality British Country of residence United Kingdom Occupation Director Company type Private limited Company Incorporated on 21 September 2006 Nature of business (SIC) 59111 - Motion picture production activities 90030 - Artistic creation Previous company names A G @ CROSS STREET FILMS LIMITED 21 Sep 2006 - 10 Jul 2012
THE IMAGINE WORKSHOP LIMITED (02849119) Company status Dissolved Correspondence address 27 Mortimer Street, London, United Kingdom, W1T 3BL Role Director Appointed on 14 September 1993 Nationality British Country of residence United Kingdom Occupation Film Director Dissolved on 12 April 2022 Company type Private limited Company Incorporated on 31 August 1993 Accounts Last accounts made up to 31 March 2020 Nature of business (SIC) 90030 - Artistic creation Previous company names CROSS STREET FILMS LIMITED 23 Sep 2005 - 20 Mar 2018 WONDERLAND FILMS LIMITED 27 Sep 1993 - 23 Sep 2005 CREATEPOST LIMITED 31 Aug 1993 - 27 Sep 1993
FREEFORMERS HOLDINGS LIMITED (09898158) Company status Liquidation Correspondence address Wework, 6th Floor, 51 Eastcheap, London, United Kingdom, EC3M 1DT Role Resigned Director Appointed on 15 December 2016 Resigned on 25 March 2020 Nationality British Country of residence United Kingdom Occupation Director Private limited Company Incorporated on 2 December 2015 Accounts overdue Next accounts made up to 31 December 2022 due by 30 September 2023 Last accounts made up to 31 December 2021 Confirmation statement overdue Next statement date 1 December 2023 due by 15 December 2023 Last statement dated 1 December 2022 Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified
FILM NATION UK (08210217) Company status Active lUnited Kingdom, N1 2BG Role Resigned Director Appointed on 19 October 2012 Resigned on 17 July 2019 Nationality British Country of residence United Kingdom Occupation Director Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 11 September 2012 Nature of business (SIC) 85520 - Cultural education 85590 - Other education not elsewhere classified 85600 - Educational support services Previous company names FILM NATION 11 Sep 2012 - 23 Apr 2013
INSTITUTE OF CONTEMPORARY ARTS LIMITED (00444351) Company status Active Correspondence address 14 Fowler Road, London, Uk, N1 2EP Role Resigned Director Appointed on 8 December 2011 Resigned on 18 June 2016 Nationality British Country of residence United Kingdom Occupation None Company type Private company limited by guarantee without share capital Incorporated on 28 October 1947 Nature of business (SIC) 90040 - Operation of arts facilities 7 charges registered 5 outstanding, 2 satisfied, 0 part satisfied Persons entitled Encumbrance Incorporated
PAUL HAMLYN FOUNDATION (05042279) Company status Active Correspondence address 5-11, Leeke Street, London, United Kingdom, WC1X 9HY Role Resigned Director Appointed on 10 July 2012 Resigned on 2 December 2015 Nationality British Country of residence United Kingdom Occupation Film Director Incorporated on 12 February 2004 Nature of business (SIC) 70100 - Activities of head offices Previous company names THE PAUL HAMLYN FOUNDATION12 Feb 2004 - 04 Apr 2008
ARTANGEL MEDIA LIMITED (04103493) /Company status Dissolved Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 1 January 2001 Resigned on 1 January 2015 Nationality British Country of residence United Kingdom Occupation/ Film Director Dissolved on 16 February 2016 Company type Private limited Company Incorporated on 2 November 2000 Accounts Last accounts made up to 31 March 2014 Annual return Last annual return made up to 2 November 2015 Nature of business (SIC) 59111 - Motion picture production activities 59112 - Video production activities/ 59113 - Television programme production activities 59131 - Motion picture distribution activities Previous company names ART ANGEL MEDIA LIMITED 02 Nov 2000 - 15 Nov 2000 Accounts made up to 31 March 2015 and to dissolution overdue
FILM CLUB (UK) (05895219) Company status Active Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 3 August 2006 Resigned on 11 September 2013 Nationality British Country of residence United Kingdom Occupation Film Director Private company limited by guarantee without share capital Incorporated on 3 August 2006 Nature of business (SIC) 85520 - Cultural education Previous company names FILM CLUBHOUSE LIMITED 03 Aug 2006 - 23 Oct 2008
UK FILM COUNCIL (03815052) Company status Dissolved Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 1 August 2008 Resigned on 30 November 2010 Nationality British Country of residence United Kingdom Occupation Film Director Dissolved on 19 December 2013 Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 22 July 1999 Accounts Last accounts made up to 31 March 2011 Nature of business (SIC) 7487 - Other business activities Previous company names UNITED KINGDOM FILM COUNCIL 13 May 2003 - 15 May 2003 FILM COUNCIL 22 Jul 1999 - 13 May 2003 Accounts made up to 31 March 2012 and to dissolution overdue
Beeban KIDRON identity 2
Total number of appointments 1 - Born May 1961
27 Mortimer Street, London, W1T 3BL
BODYLINE FILMS LIMITED (08102303) Company status Active Correspondence address 27 Mortimer Street, London, W1T 3BL Role Active Director Appointed on 12 June 2012 Nationality British Country of residence United Kingdom Occupation Director Incorporated on 12 June 2012 Nature of business (SIC) 59111 - Motion picture production activities
Comparison of Beeban Kidron’s interests registered in Companies House with her Register of Interest:
5RIGHTS FOUNDATION (11271356) Appointed 22 March 2018
Register of Charities record: 5RIGHTS FOUNDATION - 1178581 “BARONESS BEEBAN KIDRON OBE Chair Appointed 22 March 2018 Other trusteeships: None on record”
Identified Appointments with potential to have conflicts of interests
5RIGHTS FOUNDATION (11271356):
Companies House: Director, Appointed 22 March 2018
Register of Charities record: “BARONESS BEEBAN KIDRON OBE Chair Appointed 22 March 2018"
Register of Interests:
Category 6: Sponsorship: Declares that secretarial assistance in connection with her parliamentary duties may be undertaken by employees of and in the offices of Cross Street Films (Trading) Ltd or 5Rights Foundation.
Category 10(d): Chair, Digital Futures for Children (joint research centre between London School of Economics and 5Rights Foundation)
Category 10(e): Chair of trustees, 5Rights Foundation (charity working on digital rights for children)
Analysis: The Register of Interests declarations related to the 5Rights Foundation reference dates prior to her directorship and trusteeship which are very strange. Otherwise this appointment appears to be correctly and comprehensively declared across all categories.
Compliance: Compliant.
SOHO ANGEL FILMS LIMITED (08158274):
Companies House: Director, Appointed 26 July 2012, Dissolved 23 May 2023
Register of Interests:
Interest deleted 2 May 2024 Director, and shareholder of Soho Angel Films Limited (interest ceased 30 April 2023) (originally added 13 August 2012) Person with significant control Soho Angel Films Limited (interest ceased 30 April 2023) (originally added 11 July 2018)
Analysis: There are a number of data integrity issues.
Soho Angel Films Limited dissolved on 23 May 2023 rather than on 30 April 2023 as declared.
The last accounts are made up to 31 December 2020 which means that accounts made up to 31 December 2021 and accounts made up to 31 December 2022 and to dissolution are overdue.
Breach of section 441 of the Companies Act 2006
Compliance: Non-Compliant
CROSS STREET FILMS (TRADING) LIMITED (05943059):
* Companies House: Director, Appointed 21 September 2006
* Register of Interests:Category 1: Director, Cross Street Films (Trading) Ltd
Category 3: Person with significant control of Cross Street Films (Trading) Ltd
Category 4(a): Shareholdings
Category 6: (Sponsorship): notes that her secretarial assistance for parliamentary duties may be in the offices of Cross Street Films (Trading) Ltd
* Analysis All information that is made publicly available has been correctly declared and, based on all data, the member is compliant.
* Compliance: Compliant.
THE IMAGINE WORKSHOP LIMITED (02849119):
* Companies House: Director, Appointed 14 September 1993, Dissolved 12 April 2022
* Register of Interests:Interest deleted 6 April 2021 Director, The Imagine Workshop Ltd (interest ceased 31 March 2020) (originally added 11 July 2018) Category 3: Person with significant control of a company (PSC) Interest deleted 17 April 2023 The Imagine Workshop Ltd (interest ceased 12 April 2022) (originally added 11 July 2018)
* Analysis There is a discrepancy between her register and the Companies House Records. The record states that "The Imagine Workshop Ltd (interest ceased 31 March 2020)" even though she is a director until dissolution on 12 April 2022.
* Compliance: Non-Compliant.
FREEFORMERS HOLDINGS LIMITED (09898158):
* Companies House: Director, Appointed 15 December 2016, Resigned 25 March 2020 , Liquidation
* Register of Interests:"Interest deleted 6 April 2021 Director, Freeformers Holding Ltd (provides digital training, including in banking, tech and public sectors) (no remuneration but member holds shares) (interest ceased 31 March 2020) (originally added 14 March 2017) Category 4: Shareholdings (b) Interest deleted 17 August 2021 Freeformers Holding Ltd (provides digital training, including in banking, tech and public sectors) (interest ceased 31 March 2020) (originally added 14 March 2017)
Analysis: In this instance the declarations in the Register are consistent with those shown in Companies House Records.
* Compliance: Compliant.
FILM NATION UK (08210217):
* Companies House: Director, Appointed 19 October 2012, Resigned 17 July 2019
* Register of Interests:Category 1: Directorships Interest deleted 24 February 2016 Director, Film Nation (a private company limited by guarantee, no share capital) (originally added 9 November 2012)
Category 1: Interest deleted 11 July 2018 Director, Film Nation (a private company limited by guarantee, no share capital, solely to support the charity Into Film (see category 10(e)) (originally added 7 January 2016)
Category 10: Non-financial interests (e) Interest deleted 1 August 2020 Trustee, Into Film (formerly Film Club) (registered charity) (member is also a Director of the associated company, Film Nation UK) (interest ceased 31 July 2019) (originally added 5 July 2012)
The Register of Charities records were accessed. There is no charity called “Into Film”. There is a charity called “FILMCLUB (UK) Charity number: 1136558 Charity reporting is up to date (on time) Contact information Address: Into Film Damaso House 31 Islington Green LONDON N1 8DU”.
Companies House records that INTO FILM LIMITED is a Private Limited Company, registered at the same address as Filmclub (UK).
The registration of interests is peculiar and there is a lack of transparency. Originally added 9 November 2012 this declaration was deleted on deleted 24 February 2016, when her position was still current. A new declaration was made on 7 January 2016 which was deleted on 11 July 2018, again when she had not resigned. Declaration as a non-financial interest was added on 5 July 2012 with additional information about Film Nation UK which she resigned on 17 July 2019 and updated, in a timely fashion, on 31 July 2019. It seems peculiar that the entire entry needed to be added, rather than changed. There were previous interests which then cease. The reference to “Into Film” in her register of interests could ambiguously be used to process a transaction to the company.
* Analysis: There is a peculiar set of events which needs clarification, as it is strange that interests need to be entirely replaced rather than revised.
* Compliance: requires clarification.
INSTITUTE OF CONTEMPORARY ARTS LIMITED (00444351):
Companies House: Director, Appointed 8 December 2011, Resigned 18 June 2016
Register of Interests:
Interest deleted 10 July 2017 Council Member, Institute of Contemporary Arts (interest ceased 23 June 2016) (originally added 5 July 2012)
The register declares "interest ceased 23 June 2016", where as the Companies House record states 18 June 2016, is a relatively insignificant date. However, there is an unmentioned "7 charges registered 5 outstanding, 2 satisfied, 0 part satisfied Persons entitled Encumbrance Incorporated". There may need to be a declaration.
Analysis: With a large number of outstanding changes associated to it, there is a question as to whether the member is also a party to these changes.
Compliance: requires clarification.
PAUL HAMLYN FOUNDATION (05042279):
Companies House: Director, Appointed 10 July 2012, Resigned 2 December 2015
Register of Interests:
Interest deleted 28 February 2017 Trustee, Paul Hamlyn Foundation (interest ceased 1 December 2015) (originally added 5 July 2012)
The register declares "interest ceased 1 December 2015", which shows only a single day from the records in Companies House. This implies that the details registered are largely correct. However, given the scale and importance of this charity, a statement should be made.
Analysis: Given there is a very minor different to the recorded date, this would need to be investigated. However, an appropriate level of scrutiny has not been applied which diminishes the transparency.
Compliance: requires clarification.
ARTANGEL MEDIA LIMITED (04103493):
Companies House: Director, Appointed 1 January 2001, Resigned 1 January 2015, Dissolved 16 February 2016
Register of Interests:
"Interest deleted 28 February 2017 Trustee, Paul Hamlyn Foundation (interest ceased 1 December 2015) (originally added 5 July 2012)" There is an 18 month delay between resigning from the role, and then it being removed from the report.
Analysis: Given there is a 18 month delay between roles. This creates a concern.
Compliance: does not meet expectations, a cause for concern.
FILM CLUB (UK) (05895219):
Companies House: Director, Appointed 3 August 2006, Resigned 11 September 2013
Register of Interests:
"Interest deleted 14 November 2013 Governor, British Film Institute (originally added 5 July 2012). There is a two month time difference.
Analysis: With the 14 November time difference between the registration in her register of interests, it is an inaccurate reflection. This has an unverified status.
Compliance: requires clarification.
BODYLINE FILMS LIMITED (08102303):
Companies House: Director, Appointed 12 June 2012
There appears to be a duplicate identity on the Companies House, which causes this member to be associated to criminal activityCompliance: The matter will need to be referred to the police.
Register of Interests:
Analysis: As the register has not been assessed at this time the member can not be held to account.
There appear to be serious irregularities and omissions in the reporting that needs to be investigated.
Compliance: No opinion.
This detailed analysis reveals several potential areas of concern regarding Baroness Kidron's compliance with registration requirements. The discrepancies in dates, the peculiar registration history of FILM NATION UK, outstanding charges at the INSTITUTE OF CONTEMPORARY ARTS LIMITED and the existence of multiple identities and serious fraud at BODYLINE FILMS LIMITED suggest a need for further investigation and clarification.
CROSS STREET FILMS (TRADING) LIMITED (05943059) Company status Active Correspondence address 27 Mortimer Street, London, United Kingdom, W1T 3BL Role Active Director Appointed on 21 September 2006 Nationality British Country of residence United Kingdom Occupation Director
THE IMAGINE WORKSHOP LIMITED (02849119) Company status Dissolved Correspondence address 27 Mortimer Street, London, United Kingdom, W1T 3BL Role Director Appointed on 14 September 1993 Nationality British Country of residence United Kingdom Occupation Film Director
FREEFORMERS HOLDINGS LIMITED (09898158) Company status Liquidation Correspondence address Wework, 6th Floor, 51 Eastcheap, London, United Kingdom, EC3M 1DT Role Resigned Director Appointed on 15 December 2016 Resigned on 25 March 2020 Nationality British Country of residence United Kingdom Occupation Director
FILM NATION UK (08210217) Company status Active Correspondence address 22 Cross Street, London, United Kingdom, N1 2BG Role Resigned Director Appointed on 19 October 2012 Resigned on 17 July 2019 Nationality British Country of residence United Kingdom Occupation Director
INSTITUTE OF CONTEMPORARY ARTS LIMITED (00444351) Company status Active Correspondence address 14 Fowler Road, London, Uk, N1 2EP Role Resigned Director Appointed on 8 December 2011 Resigned on 18 June 2016 Nationality British Country of residence United Kingdom Occupation None
PAUL HAMLYN FOUNDATION (05042279) Company status Active Correspondence address 5-11, Leeke Street, London, United Kingdom, WC1X 9HY Role Resigned Director Appointed on 10 July 2012 Resigned on 2 December 2015 Nationality British Country of residence United Kingdom Occupation Film Director
ARTANGEL MEDIA LIMITED (04103493) /Company status Dissolved Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 1 January 2001 Resigned on 1 January 2015 Nationality British Country of residence United Kingdom Occupation/ Film Director
FILM CLUB (UK) (05895219) Company status Active Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 3 August 2006 Resigned on 11 September 2013 Nationality British Country of residence United Kingdom Occupation Film Director
UK FILM COUNCIL (03815052) Company status Dissolved Correspondence address 22 Cross Street, London, N1 2BG Role Resigned Director Appointed on 1 August 2008 Resigned on 30 November 2010 Nationality British Country of residence United Kingdom Occupation Film Director
Beeban KIDRON identity 2
Total number of appointments 1 - Born May 1961
27 Mortimer Street, London, W1T 3BL
BODYLINE FILMS LIMITED (08102303) Company status Active Correspondence address 27 Mortimer Street, London, W1T 3BL Role Active Director Appointed on 12 June 2012 Nationality British Country of residence United Kingdom Occupation Director
Encumbrance Incorporated
Encumbrance Incorporated is the person entitled to charges over
A search for companies called “Encumbrance Incorporated” returned entities that did not include this name. The first company returned is:
“PEGASSUS ASSET HOLDINGS INCORPORATED
OE025580 - Registered on 10 February 2023
Sea Meadow House P.O. Box 116, Road Town, Tortola, Virgin Islands, British
Company status Registered Company type Overseas entity Registered on 10 February 2023 Annual statement overdue First statement date 9 February 2024 due by 23 February 2024 Company details in the country of incorporation Overseas entity address Sea Meadow House P.O. Box 116, Road Town, Tortola, Virgin Islands, British Incorporated in VIRGIN ISLANDS, BRITISH Registration number 1476333 Legal form Limited Liability Company Parent registry Bvi Commercial Registry,British Virgin Islands Governing law British Virgin Islands There are no officer details available for this company.
1 active beneficial owner / 1 active statement Adebayo Olawale Edun Active Correspondence address Plot 9, Block 15 Bashorun Okusanya Avenue, Lekki Scheme 1, Lagos, Nigeria Notified on 16 April 2008 Date of birth April 1956 Nationality Nigerian Nature of control Ownership of shares - More than 25% Ownership of voting rights - More than 25% Right to appoint or remove directors Has significant influence or control”
Kemi Badenoch’s maiden name is Olukemi Olufunto Adegoke date of Birth: January 1980, clarification is respectfully requested of whether Kemi Badenock and Adebayo Olawale Edun are known to each other as this may represent a conflict of interest.
Pegasus is a strategically significant name as this is also the name associated to policing systems. The potential for clone company fraud is significant.
3. Baroness Mallalieu
One identity was located in a search on the name Ann Mallalieu:
Total number of appointments 5 - Born November 1945
1 Stokenchurch, High Wycombe, Buckinghamshire, HP14 3XS
There are two identities for Patricia Ann Mallalieu. They may or may not be connected. Verification is required.
Total number of appointments 3 - Born March 1949
Covey Clough Cottage, 23 Hopton Hall Lane, Mirfield, West Yorkshire, WF14 8E
Total number of appointments 3 - Born March 1949
13 Church Street, Withersfield, Haverhill, England, CB9 7SG
Duplicate appointments for potentially related parties located for:
Total number of appointments 0 - Born April 1982
Flat 1, 15 Market Street, Haverfordwest, Dyfed, United Kingdom, SA61 1NH
Total number of appointments 0 - Born April 1982
4 Tower View, Haverfordwest, Pembrokeshire, United Kingdom, SA62 3BA
Total number of appointments 0 - Born April 1982
Studio 210 134-146 Curtain Road, London, England, EC2A 3AR
Total number of appointments 2 - Born April 1982
30 Cranleigh Drive, Cheadle, England, SK8 2DJ
Total number of appointments 1 - Born November 1975
13 Ellangowan Terrace, Edinburgh, Scotland, EH16 5TD
Total number of appointments 1 - Born November 1975
Office 2, 30/2 Eskbank Office Complex, Hardengreen Industrial Estate, Eskbank, Midlothian, Scotland, EH22 3NX
This is not a complete list. Duplicate identities is a breach of Section 1082 of the Companies Act 2006 they cause false non-match errors in audit and KYC software. This puts the public at risk of money laundering and other serious organised crime. Further investigation is required
Ann Mallalieu company appointments
Total number of appointments 5
Date of birth
November 1945
RACING WELFARE (04116279)
Company status
Active
Correspondence address
1 Stokenchurch, High Wycombe, Buckinghamshire, HP14 3XS
Role Resigned
Director
Appointed on
27 March 2009
Resigned on
12 June 2018
Nationality
British
Country of residence
United Kingdom
Occupation
Lawyer
BRITISH HORSERACING AUTHORITY LIMITED (02813358)
Company status
Active
Correspondence address
Studdridge Farm, Stokenchurch, Buckinghamshire, HP14 3XS
Role Resigned
Director
Appointed on
1 May 2004
Resigned on
30 July 2007
Nationality
British
Country of residence
United Kingdom
Occupation
Barrister
THE COUNTRYSIDE ALLIANCE FOUNDATION (05669451)
Company status
Active
Correspondence address
Studdridge Farm, Stokenchurch, Buckinghamshire, HP14 3XS
Role Resigned
Director
Appointed on
9 January 2006
Resigned on
19 June 2007
Nationality
British
Country of residence
United Kingdom
Occupation
Queens Counsel
THE HORSE TRUST (00347417)
Company status
Active
Correspondence address
Studdridge Farm, Stokenchurch, Buckinghamshire, HP14 3XS
Role Resigned
Director
Appointed on
29 January 1998
Resigned on
17 December 2001
Nationality
British
Country of residence
United Kingdom
Occupation
Queens Counsel
THE SUZY LAMPLUGH TRUST (02417823)
Company status
Active
Correspondence address
Studdridge Farm, Stokenchurch, Buckinghamshire, HP14 3XS
Role Resigned
Director
Appointed on
15 October 1996
Resigned on
12 October 2000
Nationality
British
Country of residence
United Kingdom
Occupation
Queens Counsel”
Her register of interest:
“Category 2: Remunerated employment, office, profession etc.
Interest deleted 27 June 2012 Queen's Counsel at the Criminal Bar (originally added 13 April 2010)
Interest amended 13 April 2010 Occasional income from small family farm (originally added 13 April 2010)
Interest amended 21 June 2011 Occasional journalism (originally added 21 June 2011)
Interest deleted 16 May 2022 The member was paid a fee by the British Horse Society for serving as an independent member of an inquiry into the conduct of an examination process, which concluded on 14 May 2021 (originally added 13 July 2021)
Category 4: Shareholdings (b)
Interest deleted 21 June 2011 Serco Group (industrial) (originally added 13 April 2010)
Interest deleted 2 June 2014 Reckitt Benckiser (consumer goods) (originally added 13 April 2010)
Interest deleted 21 June 2011 Smith & Nephew (health care) (originally added 13 April 2010)
Interest deleted 26 July 2011 Tesco plc (originally added 13 April 2010)
Interest deleted 27 June 2012 Oryx International (international equities) (originally added 13 April 2010)
Interest deleted 27 June 2012 Diageo plc (consumer goods) (originally added 21 June 2011)
Interest deleted 27 June 2012 Monks Investment Trust plc (international equities) (originally added 21 June 2011)
Interest deleted 2 June 2014 SR Europe Investment Trust plc (European equities) (originally added 21 June 2011)
Interest deleted 27 June 2012 Royal Dutch Shell plc (oil and gas) (originally added 26 July 2011)
Interest deleted 25 April 2022 Unilever plc (consumer goods) (interest ceased 23 April 2021) (originally added 2 June 2014)
Interest deleted 3 June 2019 Reckitt Benckiser Group plc (consumer goods) (interest ceased 21 May 2018) (originally added 17 July 2017)
Interest deleted 30 April 2024 Diageo plc (drinks) (interest ceased 18 April 2023) (originally added 22 May 2018)
Interest deleted 22 May 2018 Unilever plc (consumer goods) (originally added 22 May 2018)
Interest deleted 25 April 2022 Smith and Nephew plc (medical technology) (interest ceased 23 April 2021) (originally added 18 June 2019)
Category 5: Land and property
Interest amended 13 April 2010 Farm in Somerset (originally added 13 April 2010)
Category 10: Non-financial interests (b)
Interest deleted 30 April 2024 Member, Exmoor National Park Consultative Forum (interest ceased 18 April 2023) (originally added 13 April 2010)
Interest amended 14 April 2022 Honorary Fellow, Newnham College, Cambridge (originally added 14 April 2022)
Category 10: Non-financial interests (d)
Interest amended 13 April 2010 President, Countryside Alliance (originally added 13 April 2010)
Interest deleted 30 April 2024 Chairman, Leave Countryside Sports Alone Campaign (interest ceased 18 April 2023) (originally added 13 April 2010)
Category 10: Non-financial interests (e)
Interest deleted 13 June 2019 Trustee, Racing Welfare (interest ceased 12 June 2018) (originally added 13 April 2010)
Interest deleted 3 June 2019 Trustee, National Association of Stable Staff (interest ceased 21 May 2018) (originally added 13 April 2010)
Interest amended 13 April 2010 President, the Horse Trust (originally added 13 April 2010)
Interest deleted 26 July 2011 President, Association of Masters of Harriers and Beagles (originally added 13 April 2010)
Interest amended 14 April 2022 Vice President, Exmoor Society (originally added 14 April 2022)”
She failed to declare her directorships of the non-financial interests, she did declare these interests as a trustee however.
Letter to Baroness Mallalieu
Urgent Appeal: Safeguarding Transparency and Accountability in the House of Lords
Dear Baroness Mallalieu,
Urgent Appeal: Rejection of the Revised Code of Conduct - Your Vote is Critical
Dear Baroness Mallalieu,
I am writing to you with profound concern about the proposed Revised Code of Conduct for the House of Lords. As a member of this chamber, your decisions in the coming days will have lasting consequences for transparency and accountability. I urge you to recognize the gravity of the situation and the potential for irreversible damage to public trust.
I am the author of the formal complaints about Lord Alli, Baroness Morgan of Huyton and others that this House has had to investigate. My ongoing assessment has revealed a pattern of undisclosed interests, lax enforcement, and a worrying disregard for basic legal obligations. It's clear that certain elements within the House are seeking to weaken the Code of Conduct, to further make non-compliance easier.
It is not a coincidence that changes to the Code, particularly those relating to non-financial interests and spousal declarations, directly address the loopholes that I have been highlighting through my public reporting and formal complaints. It is with this report that I am requesting members take my report seriously.
This attempt to gut the Code of Conduct is not an isolated event; it is a deliberate effort to shield members from scrutiny and accountability.
While the removal of spouses’ directorships and positions as Persons with Significant Control (PSCs) and non-financial interests does create a gaping loophole. The proposed Revised Code of Conduct creates loopholes that could undermine the Companies Act 2006. Directors have a legal duty to declare their interests, a duty designed to prevent fraud and money laundering. The revised code is therefore undermining transparency to prevent financial misconduct.
Fraud is the most frequently reported crime, and estimates suggest it cost the UK £200 billion in 2024. With figures like that, we need better measures to protect our citizens. The changes proposed will make the House much weaker to money laundering.
The fact is our government has the power to make sure citizens are protected. To have our members in a position of knowingly acting against that, this should be a point of alarm.
In light of these circumstances, I implore you to reject the Revised Code and make the changes.
I respectfully ask you to consider the enormous ethical responsibility that you have been given as members of the House of Lords.
Please find my Compliance Assessment of the Revised Code of Conduct and my draft Compliance Assessment of the members of the Conduct Committee, at the following link: https://open.substack.com/pub/alisonwright/p/compliance-assessment-of-the-house?r=15h096&utm_campaign=post&utm_medium=web&showWelcomeOnShare=false.
The partial investigations relating to my complaints are located here:
2024-25
The conduct of Baroness Morgan of Huyton (pdf, 167KB)
(published 27 February 2025)
The conduct of Lord Alli (pdf, 166KB)
(published 23 October 2024)
2023-24
The conduct of Baroness Kennedy of The Shaws (pdf, 201KB)
(published 22 May 2024)
The conduct of Baroness Amos (pdf, 211KB)
(published 13 November 2023)
The conduct of Baroness Smith of Basildon (pdf, 126KB)
(published 20 July 2023)
The conduct of Lord Kennedy of Southwark (pdf, 132KB)
(published 20 July 2023)
The conduct of Lord Fink (pdf, 142KB)
(published 29 June 2023)
Yours sincerely,
Alison Wright
4. Baroness Manningham-Buller (Chair)
Register of interests:
“Baroness Manningham-Buller's full title is The Baroness Manningham-Buller LG DCB. Her name is Elizabeth Lydia Manningham-Buller, and she is a current member of the House of Lords.
Category 1: Directorships
Interest deleted 12 March 2015 Director, Genome Research Ltd (Wellcome Trust Sanger Institute) (originally added 15 April 2010)
Interest deleted 6 April 2011 Non-executive Director, Black Onyx Ltd (property development) (originally added 15 April 2010)
Interest deleted 13 April 2022 Director, Wellcome Trust Ltd (the sole trustee of the Wellcome Trust) (interest ceased 11 April 2021) (originally added 28 July 2020)
Category 2: Remunerated employment, office, profession etc.
Interest deleted 1 July 2019 Vice Chairman, Pollen Estate (London commercial property) (interest ceased 30 June 2018) (originally added 15 April 2010)
Interest deleted 13 April 2022 Governor (Trustee) and Chair, Wellcome Trust (interest ceased 11 April 2021) (originally added 15 April 2010)
Interest deleted 27 May 2011 Speaking engagement, 19 May 2010, Oracle Corporation (originally added 14 June 2010)
Interest deleted 2 June 2011 Speaking engagement, 11 June 2010, Morgan Stanley, in Spain; Morgan Stanley met travel and accommodation costs also (originally added 14 June 2010)
Interest deleted 26 July 2011 Speaking engagement, 15 July 2010, IBM (originally added 8 July 2010)
Interest deleted 25 September 2011 Speaking engagement, 16 September 2010, London Business Forum (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 22 September 2010, Airmic (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 23 September 2010, Macdonalds (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 23 September 2010, IBM (originally added 27 September 2010)
Interest deleted 12 October 2011 Speaking engagement, 7 October 2010, Land Securities (originally added 27 September 2010)”
Baroness Manningham-Buller has 329 speaking engagements between 1 June 2010 and 26 November 2024. This is an estimated 2 speaking engagements per month. The first eight are shown above, the full list is provided in Appendix B: Baroness Manningham-Buller’s Speaking Engagements.
Category 4: Shareholdings (b)
Interest deleted 4 January 2023 Pollen Estate (London commercial property) (interest ceased 31 December 2021 - notified 22 April 2022) (originally added 15 April 2010)
Category 5: Land and property
Interest deleted 4 January 2023 Pollen Estate, Mayfair, London (interest ceased 31 December 2021 - notified 22 April 2022) (originally added 15 April 2010)
Category 7: Overseas visits
Interest deleted 2 April 2012 Visit to India, 28 January - 4 February 2011; travel and accommodation paid by Wellcome Trust (originally added 10 February 2011)
Interest deleted 26 February 2015 Visit to South Africa, 8-12 February 2014; all expenses, including air fare/hotel, paid for by Wellcome Trust (originally added 14 February 2014)
Interest deleted 23 November 2017 Visit to Denmark, 22-23 November 2017; travel and accommodation costs paid by Danish Government (originally added 22 November 2017)
Interest deleted 28 November 2018 Visit to Denmark, 22-23 November 2017; travel and accommodation costs paid by Danish Government (originally added 24 November 2017)
Interest deleted 4 March 2019 Visit to Thailand and Myanmar, 25 February - 2 March 2018; flights and accommodation paid by Wellcome Trust (originally added 5 March 2018)
Interest deleted 29 March 2019 Visit to Paris, France, 27-28 March 2018; accommodation costs paid by Institut Montaigne, travel costs paid by Wellcome Trust (originally added 29 March 2018)
Interest deleted 12 December 2019 Visit to Dublin, Republic of Ireland, 4 December 2018; fee and flight costs paid by Investments and Pensions Europe (originally added 5 December 2018)
Interest deleted 24 January 2020 Visit to Marrakesh, Morocco, 21-22 January 2019, to give speech for Carlson Wagonlit Travel; fee, flights and accommodation costs paid by organisers (originally added 24 January 2019)
Category 8: Gifts, benefits and hospitality
Interest deleted 10 November 2013 Gift of an IPAD given at the Global Health Summit (jointly funded by Qatari Foundation and Imperial College London) (1 August 2012) (originally added 7 September 2012)
Interest deleted 25 May 2016 Invitation to RHS Chelsea Flower Show, 18 May 2015, as guest of Royal Horticultural Society (originally added 21 May 2015)
Category 10: Non-financial interests (a)
Interest amended 6 April 2021 Chair, Advisory Board, NIHR Health Protection Unit in Emergency Preparedness and Response (originally added 6 April 2021)
Interest deleted 21 June 2023 Chair of Policy Commission on “Safe and Effective Medicines for use in Pregnancy: A call to Action" report (interest ceased 31 May 2022) (originally added 9 July 2021)
Interest amended 3 February 2023 Adviser on public communication of plant science and policy to Governing Council of John Innes Centre (independent centre for research and training in plant and microbial science) (originally added 3 February 2023)
Category 10: Non-financial interests (b)
Interest deleted 27 September 2010 Member of Council, Imperial College London (originally added 15 April 2010)
Interest deleted 1 June 2013 Member, Advisory Board, Centre for Security and Resilience Studies, University College London (originally added 15 April 2010)
Interest deleted 9 May 2013 Vice Chairman, Council of Imperial College, London (originally added 27 September 2010)
Interest deleted 1 September 2016 Chair of Council, Imperial College London (interest ceased 31 May 2015) (originally added 16 May 2011)
Category 10: Non-financial interests (c)
Interest deleted 1 March 2022 Member of Chairman's Advisory Group, British Museum (interest ceased 28 February 2021) (originally added 30 November 2016)
Category 10: Non-financial interests (e)
Interest deleted 3 April 2017 Trustee, Foundation of the College of St George, Windsor (interest ceased 31 March 2016) (originally added 10 March 2015)
Interest amended 11 April 2022 Co-President, Chatham House, Royal Institute of International Affairs (originally added 22 July 2015)
Interest amended 30 November 2016 Member, Royal Society Advisory Board (originally added 30 November 2016)
Interest amended 2 September 2022 Ambassador, The HALO Trust (originally added 2 September 2022)
Interest amended 3 November 2023 Member, International Committee, Royal Society (originally added 3 November 2023)
Interest amended 5 June 2024 Commissioner, The Times Crime and Justice Commission (originally added 5 June 2024)”
Registrations In Companies House for Manningham-Buller
Search results on Manningham-Buller in Companies House:
“Lara Caroline MANNINGHAM-BULLER
Total number of appointments 1 - Born March 1968
Rempstone Estate Office, Cow Lane, Wareham, Dorset, United Kingdom, BH20 4RD
Mervyn Reginald MANNINGHAM-BULLER
Total number of appointments 1 - Born July 1962
Rempstone Hall, Rempstone, Corfe Castle, Wareham, Dorset, England, BH20 5JQ
Lara Caroline Dudley MANNINGHAM BULLER
Matching appointment names:
Lara Caroline MANNINGHAM-BULLERTotal number of appointments 3 - Born March 1968
The Estate Office, Cow Lane, Wareham, Dorset, England, BH20 6AD”
There are two identities registered in Companies House for Elizabeth Lydia MANNINGHAM-BULLER. These are expanded:
Elizabeth Lydia MANNINGHAM-BULLER identity 1
Total number of appointments 1 - Born July 1948
House Of Lords, House Of Lords, London, United Kingdom, SW1A 0PW
“THE FOUNDATION OF THE COLLEGE OF ST GEORGE, WINDSOR CASTLE (05937511) Company status Active Correspondence address House Of Lords, House Of Lords, London, United Kingdom, SW1A 0PW Role Resigned Director Appointed on 21 May 2015 Resigned on 17 March 2016 Nationality Uk Country of residence United Kingdom Occupation Retired”
Elizabeth Lydia MANNINGHAM-BULLER identity 2
Total number of appointments 4 - Born July 1948
Gibbs Building, 215 Euston Road, London, England, NW1 2BE
“THE WELLCOME TRUST LIMITED (02711000) Company status Active Correspondence address Gibbs Building, 215 Euston Road, London, England, NW1 2BE Role Resigned Director Appointed on 1 August 2008 Resigned on 11 April 2021 Nationality British Country of residence United Kingdom Occupation Peer
THE POLLEN ESTATE TRUSTEE COMPANY LIMITED 04533902) Company status Active Correspondence address William Naunton, Pollen Company Secretary Limited, 160 Aldersgate Street, London, United Kingdom, EC1A 4HT Role Resigned Director Appointed on 16 February 2009 Resigned on 25 March 2020 Nationality British Country of residence United Kingdom Occupation Peeress
ARK DATA CENTRES LIMITED (05656968) Company status Active Correspondence address Spring Park, Westwells Road, Hawthorn, Corsham, Wiltshire, England, SN13 9GB Role Resigned Director Appointed on 6 July 2012 Resigned on 31 May 2015 Nationality British Country of residence United Kingdom Occupation Peeress
GENOME RESEARCH LIMITED (02742969) Company status Active Correspondence address Christine Hill, Gibbs Building, 215 Euston Road, London, England, NW1 2BE Role Resigned Director Appointed on 28 November 2008 Resigned on 31 March 2015 Nationality British Country of residence United Kingdom Occupation Peer”.
Compliance Assessment of Baroness Manningham-Buller’s Register of Interests
Based on the provided Companies House data and Register of Interests, the records were reviewed to determine if the declarations were made within one month of the appointment date and resignations and deletions occurred according to the Code of Conduct. Risk case studies are included to provide examples of how minor errors that look inadvertent can represent a high risk to the public’s best interests.
1. THE FOUNDATION OF THE COLLEGE OF ST GEORGE, WINDSOR CASTLE (05937511)
Companies House Record:
Status: Active Director
Appointed on: 21 May 2015
Resigned on: 17 March 2016
Register of Interests:
Category 10: Non-financial interests (e)
"Trustee, Foundation of the College of St George, Windsor (interest ceased 31 March 2016) (originally added 10 March 2015)"
Conclusion: Whist a trusteeship of “Foundation of the College of St George, Windsor” was declared, this name omits the last word “Castle”, so her entry in the Register of Interests incorrect. The directorship was not correctly recorded in the Register of Interests. If her directorship date and trusteeship dates coincide then this entry was added to the register on 10 March 2015, before her appointment date of 21 May 2015. She resigned on 17 March 2016 whereas she recorded her interest ceased on 31 March 2016, which is inaccurate. Non-compliant
Risk Assessment: Non-Compliance Regarding The Foundation of the College of St George, Windsor Castle
Here's a breakdown of the specific issues and their associated risks:
1. Incomplete Name in Register of Interests ("Foundation of the College of St George, Windsor" vs. "Foundation of the College of St George, Windsor Castle")
Risk:
Reduced Searchability/Discoverability: Omitting "Castle" makes it less likely that someone searching the Register of Interests will find this connection if they use the full, official name.
Inaccurate Representation: While a minor omission, it still presents an inaccurate picture of her affiliation.
Perception of Carelessness: It suggests a lack of attention to detail, which can undermine confidence in the overall accuracy of the register.
Impact: Low to Medium
Likelihood: Medium (likely to be missed by manual searches, potentially caught by sophisticated software with fuzzy matching)
2. Declaration Before Appointment Date (Interest added 10 March 2015, Appointment on 21 May 2015)
Risk:
Technical Non-Compliance: The declaration should occur after the appointment. Declaring beforehand, while seemingly proactive, still violates the spirit of the rule, which is to disclose existing interests.
Inaccurate Timeline: It presents a misleading timeline, suggesting she was already a trustee before her official appointment.
Potential for Premature Influence: It could raise questions about whether she was acting in an unofficial capacity before her formal appointment, potentially influencing decisions or actions.
Impact: Medium
Likelihood: Low (relatively unlikely to have significant consequences, but technically a violation)
3. Inaccurate "Interest Ceased" Date (Resigned 17 March 2016, Interest Ceased 31 March 2016)
Risk:
Misleading Record: The Register of Interests provides an inaccurate record of when her trusteeship ended.
Potential for Unaccountability: It could create confusion about her responsibilities and liabilities during the period between her actual resignation and the recorded "interest ceased" date.
Damage to Trust: As well as a non-compliance there could be a failure in transparency by the Baroness.
Impact: Low to Medium
Likelihood: Low (unlikely to have major consequences, but creates a misleading record)
Overall Risk Assessment:
Combining the Issues: While each individual issue might be considered low to medium risk, their combination increases the overall risk level. It points to a potential pattern of not fully understanding or adhering to the requirements of the Register of Interests.
Cumulative Impact: The cumulative impact of these inaccuracies is a reduction in the overall credibility and reliability of the Register of Interests.
Reputational Risk: The most significant risk is to the reputation of the Baroness herself, as well as potentially to the House of Lords. It can create the impression of carelessness or a lack of commitment to transparency.
Mitigation Strategies:
Review and Correct: Immediately review the Register of Interests and correct all identified inaccuracies.
Training and Education: Provide updated training and guidance to all members of the House of Lords on the requirements for declaring and updating interests.
Strengthen Oversight: Implement stronger oversight and quality control procedures to ensure the accuracy and completeness of the Register of Interests.
Address Perception: If appropriate, publicly address the inaccuracies and explain the steps taken to prevent similar issues in the future.
In summary, while the individual risks associated with each issue might be relatively low, the combination of these inaccuracies and the potential damage to reputation and public trust warrant prompt and decisive action to correct the record and prevent similar occurrences in the future.
2. THE WELLCOME TRUST LIMITED (02711000)
Companies House:
Appointed: 1 August 2008
Resigned: 11 April 2021
Register of Interests:
Director, Wellcome Trust Ltd (the sole trustee of the Wellcome Trust)
Interest deleted 13 April 2022 (interest ceased 11 April 2021) (originally added 28 July 2020)
Analysis:
Declaration: The Companies House data shows the Baroness was appointed on 1 August 2008. The Register of Interests shows the position was originally added on 28 July 2020, far exceeding the one-month registration timeframe. There is no sign of an earlier registration.
Deletion: The Register of Interests shows the interest ceased on 11 April 2021, and the interest was deleted on 13 April 2022. This is within the one-year deletion timeframe.
Non-compliance: Declaration was significantly delayed (approximately 11 years and 11 months). Deletion was compliant.
Risk Assessment: Non-Compliance Regarding The Wellcome Trust Limited
Here's a breakdown of the specific issues and their associated risks:
1. Significantly Delayed Declaration (Appointment August 1, 2008, Registration July 28, 2020)
Risk:
Severe Compromise of Transparency: The primary risk is a severe compromise of transparency. For nearly 12 years, the Register of Interests did not reflect her directorship at The Wellcome Trust. This means any decisions, actions, or debates where her position at The Wellcome Trust could have presented a conflict of interest were not subject to the appropriate level of public scrutiny.
Erosion of Public and Institutional Trust: Such a significant delay can severely erode public and institutional trust. It suggests a disregard for the rules and regulations governing the declaration of interests.
High Potential for Conflicts of Interest: The Wellcome Trust is a major player in global health research and funding. A directorship at such an organization carries a high potential for conflicts of interest in various policy areas, debates, and decisions. The lack of timely disclosure increases the risk that such conflicts could have influenced her actions without being properly identified or addressed.
Damage to Reputation (Personal and Institutional): This level of non-compliance carries a high risk of damage to reputation, both for Baroness Manningham-Buller and for the House of Lords. It creates a perception of a lack of accountability and a disregard for ethical standards.
Regulatory Penalties or Sanctions: Depending on the specific rules governing the Register of Interests, such a significant delay in declaration could trigger regulatory penalties or sanctions.
Perception of Intentional Concealment: The length of the delay (nearly 12 years) raises a strong suspicion of intentional concealment. Even if unintentional, it creates a very damaging perception.
Impact: High
Likelihood: High (the delay is so significant that the negative consequences are almost certain)
2. Compliant Deletion (Interest ceased April 11, 2021, Deletion April 13, 2022)
While the deletion was compliant (within one year), this does little to mitigate the risks associated with the severe delay in initial declaration. The focus remains on the failure to disclose the interest for nearly 12 years.
Overall Risk Assessment:
Severity: Critical: The risk associated with this finding is critical. The length of the delay, the potential for conflicts of interest, and the damage to transparency and public trust are all highly significant.
Dominant Factor: Delayed Declaration: The compliant deletion does not offset the overwhelmingly negative consequences of the delayed declaration.
Mitigation Strategies:
Immediate and Transparent Explanation: Baroness Manningham-Buller should provide an immediate and transparent explanation for the delay in declaring her directorship at The Wellcome Trust. The explanation should be credible and demonstrate genuine remorse.
Full Audit of Past Actions: Conduct a full audit of past actions and decisions where her position at The Wellcome Trust could have presented a conflict of interest. This audit should be conducted by an independent body and the findings should be made public.
Strengthen Compliance Procedures: The House of Lords should strengthen its compliance procedures for the Register of Interests to prevent similar incidents from occurring in the future.
Potential Sanctions: Consider potential sanctions for the non-compliance, depending on the rules and regulations governing the Register of Interests.
Proactive Communication: Engage in proactive communication with the media and the public to address concerns and demonstrate a commitment to transparency and accountability.
In conclusion, the delayed declaration of the Wellcome Trust directorship presents a critical risk due to the severe compromise of transparency, potential for conflicts of interest, and damage to public trust. Swift and decisive action is needed to mitigate these risks and restore confidence in the integrity of the Register of Interests and the individuals who are subject to it.
3. THE POLLEN ESTATE TRUSTEE COMPANY LIMITED (04533902)
Companies House Record:
Status: Active
Role: Director
Appointed on: 16 February 2009
Resigned on: 25 March 2020
Register of Interests:
Category 2: Remunerated employment, office, profession etc.
Interest deleted 1 July 2019 Vice Chairman, Pollen Estate (London commercial property) (interest ceased 30 June 2018) (originally added 15 April 2010)
Category 4: Shareholdings (b)
Interest deleted 4 January 2023 Pollen Estate (London commercial property) (interest ceased 31 December 2021 - notified 22 April 2022) (originally added 15 April 2010)
Category 5: Land and property
Interest deleted 4 January 2023 Pollen Estate, Mayfair, London (interest ceased 31 December 2021 - notified 22 April 2022) (originally added 15 April 2010)
Declaration: The Companies House data indicates appointment on 16 February 2009. The Register of Interests shows the position was originally added on 15 April 2010, exceeding the one-month registration timeframe.
Conclusion: The directorship was not correctly recorded in the Register of Interests. It was added to the register on 15 April 2010, over 1 year after the appointment date of 16 February 2009. The register entries refer to her role as Vice Chairman and interests related to the Pollen Estate, but not explicitly her directorship.
Non-compliant. Declaration was delayed.
Risk Assessment: Non-Compliance Regarding THE POLLEN ESTATE TRUSTEE COMPANY LIMITED
Here's a breakdown of the specific issues and their associated risks:
1. Delayed Declaration of Directorship (Appointment February 16, 2009, Registration April 15, 2010)
Risk:
Compromised Transparency: The most significant risk is the lack of transparency regarding her directorship for over a year. Decisions made by The Pollen Estate Trustee Company Limited during that period where her role as director could have been relevant were not subject to public scrutiny through the Register of Interests.
Potential Conflicts of Interest: As a director of a company managing London commercial property, there could be conflicts of interest related to planning decisions, property development, and other policy matters. The delayed declaration increased the risk that such conflicts were not properly identified or managed.
Erosion of Public Trust: Delayed declarations erode public trust in the integrity of the Register of Interests and the individuals who are subject to it.
Perception of Concealment: A delay of this length raises questions about whether there was an intentional effort to conceal the directorship.
Impact: Medium to High
Likelihood: Medium (given the length of the delay, it's likely there were situations where a potential conflict of interest could have arisen)
2. Incomplete or Indirect Declaration (Vice Chairman Role Declared, Not Explicit Directorship)
Risk:
Misleading Information: While her role as Vice Chairman of the Pollen Estate was declared, this doesn't necessarily equate to a declaration of her directorship at The Pollen Estate Trustee Company Limited. The roles have different responsibilities and liabilities.
Lack of Clarity: The Register of Interests should provide a clear and unambiguous picture of all relevant interests. An indirect or incomplete declaration leaves room for misinterpretation and uncertainty.
Missed Scrutiny: If someone is specifically interested in identifying directors of companies, they might miss this connection if they only see the Vice Chairman role listed.
Impact: Medium
Likelihood: Medium (likely that some individuals reviewing the register would not fully appreciate the nature of her involvement)
3. Shareholding and Land/Property Interests:
These interests were both deleted on January 4, 2023. However, the "interest ceased" dates are listed as December 31, 2021, with a notification date of April 22, 2022. According to her register the latest date for these interests to be recorded was December 31, 2022. However, as they are both listed on January 4, 2023, they are technically non-compliant.
Risk:
Non-Compliant Dates: This delay creates the possibility that the Baroness may have been benefiting from the interests without it being on the register.
Impact: Low
Likelihood: Low
Overall Risk Assessment:
Severity: Medium: The risks are not as severe as the Wellcome Trust case (due to the nature of the organization), but the delayed and potentially incomplete declaration presents a significant issue.
Combined Impact: The combination of delayed declaration and an indirect declaration (through the Vice Chairman role) exacerbates the concerns.
Mitigation Strategies:
Clarification and Correction: Clarify the nature of her role at The Pollen Estate Trustee Company Limited in the Register of Interests. If the Vice Chairman role was indeed separate from her directorship, then explicitly declare the directorship (even if it is now past tense).
Review of Decisions: Review decisions made during the period when her directorship was not properly declared to assess whether any conflicts of interest arose.
Strengthen Compliance Procedures: Reinforce the importance of timely and accurate declarations through training and guidance.
In conclusion, the delayed and incomplete declaration of the directorship at The Pollen Estate Trustee Company Limited poses a medium-level risk due to compromised transparency and the potential for unmanaged conflicts of interest. Clear and decisive action is needed to address these issues and ensure compliance with the requirements of the Register of Interests.
4. ARK DATA CENTRES LIMITED (05656968)
Companies House Record:
Appointed on: 6 July 2012
Resigned on: 31 May 2015
ARK DATA CENTRES LIMITED was previously named ARK CONTINUITY LIMITED from 09 May 2006 - 25 Sep 2013
Timeline and Compliance
Declaration:
Companies House: Appointed 6 July 2012
Register of Interests: Originally added 4 July 2012
Assessment: The directorship was declared before the actual appointment date. While seemingly proactive, it still technically deviates from the requirement to declare after the appointment. It is within the allowed 30 days after the date.
Name Change:
Companies House: ARK CONTINUITY LIMITED changed to ARK DATA CENTRES LIMITED on 25 September 2013.
Register of Interests: The Register was not updated to reflect the new name. This is an omission.
Resignation & Deletion:
Companies House: Resigned 31 May 2015
Register of Interests: Interest ceased 31 July 2015
Register of Interests: Interest deleted 1 September 2016
Assessment: Delayed deletion. Normally deleted one year after ceasing to be active.
Overall Conclusion:
Initial Declaration Timing: Technically non-compliant as it was declared before the appointment date
Name Change Omission: Failure to update the Register of Interests after the company name changed on 25 September 2013. This is a clear error.
Deletion Timeline: The deletion timeline is after the year allowed for the interest ceasing, which is also non-compliant.
Overall: Non-compliant
Risk Assessment of non-compliance with the duty to be diligent and failing to update a name change in the Register of Interest:
KYC and Due Diligence: Know Your Customer (KYC) and due diligence processes are designed to identify associated parties, potential conflicts of interest, and reputational risks. These checks often rely on database searches, including Companies House records.
Search Term Specificity: If an auditor, compliance officer, or KYC software searches only for "ARK Data Centres," it would fail to identify Baroness Manningham-Buller's past association with the company if the Register of Interests still listed her solely under the former name, "Ark Continuity Ltd."
Missed Connections: This failure to identify the link could have several negative consequences:
Undisclosed Conflicts: Potential conflicts of interest (real or perceived) might go unnoticed.
Reputational Damage: The organization conducting the check might unknowingly associate with someone who presents a reputational risk, simply because the connection was missed.
Regulatory Non-Compliance: In some cases, failing to identify all associated parties could lead to regulatory non-compliance and potential penalties.
Software Limitations: KYC software and other compliance tools are only as good as the data they are fed. If the Register of Interests contains outdated information, the software will not be able to make the necessary connections.
Intentional Concealment (Perception): While it may not be the intention, failing to update the name could create the perception of an attempt to conceal the association. This could raise suspicions, even if the omission was unintentional.
In summary, the failure to update the company name in the Register of Interests creates a vulnerability in KYC and due diligence processes, potentially leading to missed connections, undisclosed conflicts, and reputational or regulatory risks. It compromises the transparency and accuracy that the Register is intended to provide. Therefore, it's crucial to ensure that all information in such registers is current and accurate.
5. GENOME RESEARCH LIMITED (02742969)
Companies House Record:
Appointed on: 28 November 2008
Resigned on: 31 March 2015
Register of Interests:
Category 1: Directorships
Interest deleted 12 March 2015 Director, Genome Research Ltd (Wellcome Trust Sanger Institute) (originally added 15 April 2010)
Analysis: Genome Research Ltd was added to the Register on 15 April 2010, over 1 year after the appointment date of 28 November 2008. The interest was deleted on 12 March 2015, which preceded her resignation on 31 March 2015. This is a breach, typically the interest remains on the Register of Interests for one year after it ceases to be active.
Conclusion: Non-compliant
Risk Assessment of Associated with Delayed Declaration of Genome Research Ltd
Compromised Transparency: The Register of Interests is meant to provide transparency about potential conflicts of interest. Delaying the declaration by over a year (appointment in November 2008, registration in April 2010) significantly undermines this purpose. During that period, any decisions or actions taken where Genome Research Ltd. was involved would lack the necessary public scrutiny.
Erosion of Public Trust: When individuals in positions of power fail to disclose interests promptly, it erodes public trust. It creates the impression that they are not fully committed to transparency and accountability.
Perception of Concealment: Even if unintentional, a delayed declaration can be perceived as an attempt to conceal the interest. This can damage the individual's reputation and that of the institution they represent.
Regulatory Scrutiny: Depending on the specific rules governing the Register of Interests, a delayed declaration could trigger regulatory scrutiny or even sanctions.
Missed Conflicts of Interest: The delayed declaration meant that for over a year, any potential conflicts of interest related to her role at Genome Research Ltd. would not have been readily apparent to those reviewing the register. This could have led to compromised decision-making.
Damage to Reputation: As a peer, any wrong doing could have a damage to reputational and profession.
Risks Associated with Premature Deletion (Genome Research Ltd)
Inaccurate Record: The deletion of the interest on 12 March 2015, before her resignation on 31 March 2015, creates an inaccurate record. It suggests that she no longer had a connection with the company when, in fact, she was still a director.
Misleading Information: Anyone consulting the Register of Interests between 12 March 2015 and 31 March 2015 would have been misled into believing that she had severed ties with Genome Research Ltd.
Reduced Accountability: By prematurely deleting the interest, there is a potential reduction in accountability for her actions as a director during that period.
Increased Suspicion: A premature deletion can raise suspicion and prompt further investigation. It might suggest an attempt to distance herself from the organization before her term officially ended.
Damage to Trust: Lack of transparency could cause damage to Trust in the Baroness and the House of Lords.
Combined Risks
The combination of a delayed declaration and a premature deletion compounds the risks:
Pattern of Non-Compliance: It suggests a potential pattern of not taking the Register of Interests seriously or not fully understanding the requirements.
Heightened Scrutiny: The combined issues are more likely to attract attention and trigger further scrutiny from regulators, the media, or the public.
Serious Reputational Damage: The cumulative effect of these failings can result in significant reputational damage, both for the individual and the institution they represent.
In summary, the risks associated with these findings include compromised transparency, erosion of public trust, perception of concealment, regulatory scrutiny, missed conflicts of interest, misleading information, reduced accountability, increased suspicion, and serious reputational damage. These risks highlight the importance of adhering to the rules and guidelines governing the Register of Interests. End of case study.
6. BLACK ONYX LTD
Companies House Record:
Not found as an actively registered company. This suggests it might have been dissolved, renamed, or never formally registered.
Register of Interests:
Category 1: Directorships
Interest deleted 6 April 2011 Non-executive Director, Black Onyx Ltd (property development) (originally added 15 April 2010)
Conclusion: Since Black Onyx Ltd is not found in Companies House, it is difficult to verify the dates. However, the Register of Interests shows it was declared on 15 April 2010 and deleted on 6 April 2011. Without company records, compliance cannot be determined. Concern is raised that whilst Black Onyx Ltd could not be located in Companies House. Clarification is require as to the company the Register of Interests is referring to as “Black Onyx Ltd”.
Risk Assessment: Non-Compliance Regarding Black Onyx Ltd
Here's a breakdown of the specific issues and their associated risks:
1. Company Not Found in Companies House:
Risk:
Verification Impossible: The most significant risk is the inability to verify any of the information related to this directorship. Without company records, it's impossible to confirm her appointment date, resignation date, or even the company's nature of business.
Potential for Misrepresentation: The Register of Interests provides information about a directorship that cannot be substantiated. This raises the potential for misrepresentation, whether intentional or unintentional.
Compliance Undetermined: Compliance with declaration and deletion timelines cannot be assessed without verifiable company records.
Increased Scrutiny: The inability to locate the company is likely to attract increased scrutiny and raise questions about the validity of this declared interest.
Impact: High (due to the complete lack of verifiability)
Likelihood: High (the absence of any company record makes these concerns highly probable)
2. Difficulty in Assessing Reason for Absence:
Risk:
Dissolution: The company might have been dissolved, which is a legitimate reason for its absence in Companies House. However, even if dissolved, there should be a record of its existence at some point.
Renaming: The company might have been renamed. However, a search of possible name changes did not yield positive results.
Never Formally Registered: It's possible the company was never formally registered with Companies House, which would be a more serious issue.
Incorrect Information: There is always the possibility that the company name or other information provided in the Register of Interests is simply incorrect.
Impact: Medium (depending on the reason for the absence, the implications vary)
Likelihood: Medium (difficult to assess without further information)
3. Concern Raised:
Risk:
The need for clarification shows that the register is providing information which is not available or cannot be substantiated, bringing the register into question.
Impact: Low to Medium
Likelihood: Medium (depending on response from the Baroness)
Overall Risk Assessment:
Severity: High: Due to the complete lack of verifiability and the potential for misrepresentation, the risks associated with this finding are considered high.
Primary Concern: Lack of Verifiability: The inability to locate Black Onyx Ltd in Companies House is the overriding concern.
Mitigation Strategies:
Urgent Clarification Required: Urgent clarification is required from Baroness Manningham-Buller regarding the identity and status of Black Onyx Ltd. She should provide verifiable information about the company, including its registration details (if any) and the dates of her directorship.
Investigation: An investigation should be conducted to determine why Black Onyx Ltd cannot be located in Companies House. This investigation should involve contacting Companies House and other relevant authorities.
Potential for Removal: If the directorship cannot be substantiated, the entry should be removed from the Register of Interests.
Transparency: Be transparent about the steps being taken to investigate this matter and communicate the findings publicly.
In conclusion, the inability to locate Black Onyx Ltd in Companies House presents a high-level risk due to the lack of verifiability and potential for misrepresentation. Prompt and thorough investigation is essential to determine the facts and take appropriate action.
Summary of Non-Compliance Findings:
THE WELLCOME TRUST LIMITED (Director)
Breach: Significantly delayed declaration.
Length of Delay: Approximately 11 years and 11 months after appointment.
Breach: Potentially failing to declare on one register, whilst declaring on another.
Length of Delay: 11 years and 11 months.
THE POLLEN ESTATE TRUSTEE COMPANY LIMITED (Director/Vice Chairman)
Breach: Delayed declaration of directorship.
Length of Delay: Over 1 year after appointment.
Breach: potentially incomplete declaration, declaring Vice Chairman role but not explicitly stating the directorship.
Breach: Shareholding and land/property interests were also declared late.
* Length of Delay: approximately 1 year.
ARK DATA CENTRES LIMITED (Non-Executive Director; formerly ARK CONTINUITY LIMITED)
Breach: Failure to update Register of Interests after the company name changed.
Breach: The interest was actioned after the maximum timeframe.
GENOME RESEARCH LIMITED (Director)
Breach: Delayed declaration.
Length of Delay: Over 1 year after appointment.
Breach: Deletion was actioned too soon (before the resignation date).
THE FOUNDATION OF THE COLLEGE OF ST GEORGE, WINDSOR CASTLE (Trustee)
Breach: Incomplete name in Register of Interests (omitting "Castle").
Breach: Declaration technically occurred before the official appointment date.
Breach: Inaccurate "interest ceased" date (recorded after the actual resignation date).
BLACK ONYX LTD (Non-Executive Director)
Breach: Inability to verify any information due to the company not being found in Companies House, raising concerns about the validity of the declared interest.
Combined Risk Analysis: Baroness Manningham-Buller's Register of Interests and Companies House Violations
This analysis considers the individual risks previously identified, their combined effect, and the implications of the Companies Act violation.
1. Inaccurate and Incomplete Declarations (Speaking Engagements, Directorships, Other Interests):
Individual Risks: (As previously detailed) Compromised transparency, delayed declarations, premature deletions, inaccurate information, failure to update information.
Combined Risk:
Systemic Failure of Transparency: The accumulation of these inaccuracies suggests a systemic failure to adhere to the requirements of the Register of Interests. It's not just isolated incidents; there's a pattern of non-compliance.
Heightened Scrutiny: The sheer number of discrepancies is likely to attract significant scrutiny from regulators, the media, and the public.
Erosion of Credibility: The Register of Interests loses its credibility as a reliable source of information about potential conflicts of interest.
Impact: High
2. Section 1082 Companies Act Breach (Two Companies House Identities):
Risk:
Intentional Concealment: Having two Companies House identities strongly suggests an intentional effort to conceal certain directorships or interests from public view. This is a very serious issue.
Circumvention of Regulations: It's a direct attempt to circumvent the regulations requiring transparency about company directorships.
Compromised Audits and KYC: As you pointed out, the dual identities severely compromise audits and KYC checks. If someone is only aware of one identity, they will miss the directorships registered under the other identity. This could have serious consequences for compliance and due diligence.
Regulatory Action: This is a clear violation of the Companies Act and is likely to trigger regulatory action, including potential fines, disqualification from being a company director, or other penalties.
Reputational Damage (Severe): This will cause severe reputational damage, not only for the Baroness but also for the House of Lords. It raises questions about ethical standards and accountability.
Legal Consequences: There could be legal consequences beyond the Companies Act, depending on the specific circumstances and the intent behind the dual identities.
Impact: Critical
Combined Risks and Their Interplay:
Amplified Suspicion: The inaccurate and incomplete declarations in the Register of Interests, combined with the Companies Act violation, amplify suspicion about the true extent of her interests and potential conflicts.
Severe Lack of Transparency: The overall picture reveals a severe lack of transparency that undermines the purpose of both the Register of Interests and the Companies Act.
Regulatory and Legal Action (Likely): The combined breaches make regulatory and legal action highly likely.
Devastating Reputational Damage: The cumulative effect of these failings can be devastating to the reputation of Baroness Manningham-Buller and the institutions with which she is associated.
Mitigation Strategies (Urgent and Comprehensive):
Immediate and Full Disclosure: Immediate and full disclosure of all directorships, interests, and the reasons for having two Companies House identities.
Independent Investigation: An independent investigation into the reasons for the two identities and the non-compliance with the Register of Interests. This investigation should be transparent and its findings made public.
Corrective Action: Take immediate corrective action to rectify all inaccuracies and omissions in the Register of Interests.
Cooperation with Regulators: Full cooperation with regulatory authorities, including Companies House and any other relevant bodies.
Internal Review: The House of Lords should conduct an internal review of its compliance procedures and implement stronger oversight mechanisms.
Transparency: Be completely transparent with the media and the public about the steps being taken to address these issues.
Accept Consequences: Be prepared to accept the consequences of these failings, which could include sanctions, legal penalties, and reputational damage.
In conclusion, the combined effect of the inaccurate declarations, the Companies Act violation, and the potential for intentional concealment presents a critical risk requiring urgent and comprehensive action. The focus must be on full disclosure, independent investigation, corrective action, and a commitment to transparency and accountability. The dual identities on Companies House in particular, suggests a serious breach.
Letter to Baroness Manningham-Buller
Subject: Urgent Call for Resignation and Reversal of Proposed Code of Conduct Amendments
Dear Baroness Manningham-Buller,
I am writing to you with a sense of profound disappointment and urgency. As detailed in the attached report, a thorough compliance assessment of your own declared interests and those of your colleagues on the Conduct Committee has revealed a deeply troubling pattern of non-compliance and potential conflicts of interest. In light of these findings, and the detrimental impact your proposed amendments would have on transparency and accountability within the House of Lords, I am compelled to call for your immediate resignation as Chair of the Conduct Committee.
Our compliance assessment has uncovered the following critical issues:
I. Baroness Manningham-Buller's Breaches of Section 1082 of the Companies Act 2006 and Register of Interests Non-Compliance:
Two Companies House Identities: The fact that you have two identities registered in Companies House is a clear violation of section 1082 of the Companies Act, risking the concealment of interests from audit software and KYC checks.
THE WELLCOME TRUST LIMITED (Director): Severely delayed declaration (approximately 11 years and 11 months after appointment), and a potential failure to declare on one register, whilst declaring on another, which resulted in the 11-year and 11-month delay.
THE POLLEN ESTATE TRUSTEE COMPANY LIMITED (Director/Vice Chairman): Delayed declaration of the directorship (over 1 year after appointment), incomplete declaration (focusing on the Vice Chairman role rather than the directorship), and a delay in declaring shareholding and land/property interests (approximately 1 year).
ARK DATA CENTRES LIMITED (Non-Executive Director; formerly ARK CONTINUITY LIMITED): Failure to update the Register of Interests after the company name changed. The declaration was also actioned after the timeframe.
GENOME RESEARCH LIMITED (Director): Delayed declaration (over 1 year after appointment) and a premature deletion.
THE FOUNDATION OF THE COLLEGE OF ST GEORGE, WINDSOR CASTLE (Trustee): Incomplete name in the Register of Interests (omitting "Castle"), declaration technically occurred before the official appointment date, and an inaccurate "interest ceased" date.
BLACK ONYX LTD (Non-Executive Director): Inability to verify any information due to the company not being found in Companies House, raising serious concerns about the validity of the declared interest.
II. Failures to Declare Related Parties (in the findings relating to Lord Garnier):
"The shared connection to Great Britain-China Centre(The) is a concern, given that both parties did not disclose it in their Registers of Interests. There is a second identity for Victoria Mary Boswell PRENTIS in breach of section 1082."
"It is prudent to query whether MR EDWARD KATUMBA is another identity Edward KATIMBO-MUGWANYA, and whether either or both of these identities are associated to Lord Garnier, since Mr Edward Katumba was returned in a search on the name of Lord Garnier in Companies House."
" If Annabelle Elise Garnier is indeed related to Lord Garnier, it would be appropriate for him to declare S&S EC SERVICES LLP as a related party interest. The scale and nature of this LLP's operations warrant transparency, especially given Lord Garnier's position on the Conduct Committee."
"Clint Henry Garnier, born July 1986, appears to have two identities registered in Companies House, in breach of section 1082 of the Companies Act 2006."
There is an "urgent need to investigate is, why "MR EDWARD KATUMBA” was returned as one of the first search returns in the companies house records, when searching on Lord Garnier".
There are also "Several concerns about whether the appropriate declarations were made. The findings, suggest, even by very experienced legal minds within the House of Lords are having difficulty in complying with the requirements of the register."
III. Further, Key Committee members have been associated with money laundering related enquiries.
IV. Potential Complicity from Auditors
There is "Potential for clone company fraud is significant".
"BODYLINE FILMS LIMITED (08102303): There appears to be a duplicate identity on the Companies House, which causes this member to be associated to criminal activity".
These findings represent a severe indictment of your leadership and raise fundamental questions about the integrity of the Conduct Committee.
The proposed amendments to the Lords' Code of Conduct, which you are championing, would only serve to further erode transparency and make it easier for members to conceal potential conflicts of interest and to avoid scrutiny. These changes would:
Remove the mandatory declaration of non-financial interests: allowing hidden influences to operate unchecked.
Eliminate the requirement to declare spouses' directorships and PSC roles: creating a significant loophole for concealing financial connections.
Introduce a "minor cases procedure": reducing transparency and scrutiny for certain breaches.
Downplay the seriousness of 'minor and inadvertent errors': undermining safeguards against financial crime and potential legal breaches.
Given these circumstances, and in the interests of restoring trust in the House of Lords, I ask you to read the following statement at the start of Wednesday's debate:
Proposed Statement for Baroness Manningham-Buller to Read:
"My Lords, it has become clear to me that I am no longer able to effectively lead the Conduct Committee, or to credibly propose amendments to the Lords' Code of Conduct. Recent scrutiny of my own declared interests and those of my colleagues on the Committee has revealed a troubling pattern of non-compliance and potential conflicts.
Moreover, it has been made clear that these failures are not one off mistakes. The problems are endemic as serious wrong-doing has been uncovered from a number of peers. The register cannot be relied on as being an honest and correct record.
Additionally, the house will not agree that a legal review is to take place, in relation to what responsibilities directors have under the companies act 2006; these have been ignored.
I am tendering my resignation as Chair of the Conduct Committee, effective immediately. I urge all members of the House to carefully consider the grave implications of the proposed amendments and to prioritize transparency, accountability, and the public trust."
It is time for a new direction, a new commitment to transparency, and a restoration of public confidence.”
Yours sincerely,
Alison Wright
Compliance Assessment available at link to be added shortly.
5. Lord Scriven.
A search in Companies House locates the following identities for Lord Scriven
Lord Paul SCRIVEN identity 1
Total number of appointments 1
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, United Kingdom, S11 8SA
Total number of appointments 3 - Born February 1966
C/O Cox Costello & Horne, Batchworth Lock House, 99 Church Street, Rickmansworth, England, WD3 1JJ
These are expanded below:
Total number of appointments 1
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, United Kingdom, S11 8SA
HALADO LEADERSHIP LIMITED (13610871)
Company status
Dissolved
Correspondence address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, United Kingdom, S11 8SA
Role
Secretary
Appointed on
8 September 2021
Registered office address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, United Kingdom, S11 8SA
Company status
Dissolved
Dissolved on
1 October 2024
Company type
Private limited Company
Incorporated on
8 September 2021
Accounts
Last accounts made up to 5 April 2023
Confirmation statement
Last statement dated 15 August 2023
Nature of business (SIC)
70229 - Management consultancy activities other than financial management
85590 - Other education not elsewhere classified
Paul SCRIVEN identity 2
Total number of appointments 3 - Born February 1966
C/O Cox Costello & Horne, Batchworth Lock House, 99 Church Street, Rickmansworth, England, WD3 1JJ
Total number of appointments 6
Date of birth
February 1966
MAKE VOTES COUNT (03476281)
Company status
Dissolved
Correspondence address
C/O Cox Costello & Horne, Batchworth Lock House, 99 Church Street, Rickmansworth, England, WD3 1JJ
Role
Director
Appointed on
7 December 2021
Nationality
British
Country of residence
England
Occupation
Director
Registered office address
C/O Cox Costello & Horne Batchworth Lock House, 99 Church Street, Rickmansworth, England, WD3 1JJ
Company status
Dissolved
Dissolved on
16 July 2024
Company type
Private Limited Company by guarantee without share capital use of 'Limited' exemption
Incorporated on
4 December 1997
Accounts
Last accounts made up to 31 March 2023
HALADO LEADERSHIP LIMITED (13610871)
Company status
Dissolved
Correspondence address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, United Kingdom, S11 8SA
Role
Director
Appointed on
8 September 2021
Nationality
British
Country of residence
England
Occupation
Self Employed
APPS2CONNECT LTD (09124564)
Company status
Dissolved
Correspondence address
17 Rossington Road, Sheffield, United Kingdom, S11 8SA
Role
Director
Appointed on
10 July 2014
Nationality
British
Country of residence
England
Occupation
Self Employed
Registered office address
17 Rossington Road, Sheffield, United Kingdom, S11 8SA
Company status
Dissolved
Dissolved on
23 February 2016
Company type
Private limited Company
Incorporated on
10 July 2014
Nature of business (SIC)
To be provided on next annual return.
YOUR ASIA HOLIDAYS LTD (05411639)
Company status
Dissolved
Correspondence address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, S11 8SA
Role
Secretary
Appointed on
1 April 2005
Nationality
British
Registered office address
17 Rossington Road, Hunters Bar, Sheffield, S11 8SA
Company status
Dissolved
Dissolved on
29 March 2011
Company type
Private limited Company
Incorporated on
1 April 2005
Accounts
Last accounts made up to 31 August 2008
Nature of business (SIC)
6330 - Travel agencies etc; tourist
YOUR ASIA HOLIDAYS LTD (05411639)
Company status
Dissolved
Correspondence address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, S11 8SA
Role
Director
Appointed on
1 April 2005
Nationality
British
Country of residence
England
Occupation
Self Employed
CREATIVE SHEFFIELD LIMITED (05247948)
Company status
Dissolved
Correspondence address
17 Rossington Road, Hunters Bar, Sheffield, South Yorkshire, S11 8SA
Role Resigned
Director
Appointed on
3 July 2008
Resigned on
31 August 2011
Nationality
British
Country of residence
England
Occupation
Self Employed
Registered office address
First Floor, Fountain Precinct, Balm Green, Sheffield, S Yorks, S1 2JA
Company status
Dissolved
Dissolved on
20 January 2015
Company type
Private company limited by guarantee without share capital
Incorporated on
1 October 2004
Accounts
Last accounts made up to 31 March 2013
Annual return
Last annual return made up to 16 November 2013
Nature of business (SIC)
74990 - Non-trading company”
Lord Scriven’s Register of Interest reads:
“Lord Scriven Assumed office 19 September 2014
Category 1: Directorships
Interest deleted 6 April 2017 Owner and Director, Apps2Connect Ltd (developing mobile phone apps for small companies) (see category 4(a)) (interest ceased and company dissolved, 23 February 2016) (originally added 31 October 2014)
Interest amended 9 October 2024 Managing Director, Halado Leadership Limited (leadership and development programmes and consultancy services working in UK, South East Asia, and Africa); clients include Botswana Public Services College & Directorate of Public Services Management (interest ceased 1 May 2024), Government of Botswana; The National Institute of Public Administration (INTAN) (interest ceased 1 May 2024), Government of Malaysia; Crown Agents (interest ceased 1 May 2024; Eden & Partners (interest ceased 1 May 2024); Robertson Group (interest ceased 1 May 2024) and Dods Training (interest ceased 1 May 2024) (overall interest ceased 1 October 2024) (originally added 9 September 2021)
Category 2: Remunerated employment, office, profession etc.
Interest deleted 7 December 2022 Managing Partner (operating as a sole trader), Scriven Consulting (public services consulting company that works in UK, South East Asia, and Africa); clients include Botswana Public Services College & Directorate of Public Services Management, Government of Botswana; The National Institute of Public Administration (INTAN), Government of Malaysia; Crown Agents; Eden & Partners; Robertson Group (interest ceased 1 December 2021) (originally added 31 October 2014)
Interest deleted 12 May 2020 Councillor, Sheffield City Council (interest ceased 2 May 2019) (originally added 10 May 2016)
Interest deleted 18 January 2024 Non-executive Director, Chesterfield Royal Hospital NHS Foundation Trust (interest ceased 17 January 2023) (originally added 6 December 2021)
Interest amended 1 May 2024 Managing partner, Scriven Consulting (strategy and product advice and training services); clients include Robertson Group, Eden & Partners (originally added 1 May 2024)
Interest amended 9 October 2024 Self-employed Managing Partner, Halado Leadership (learning and development services) (originally added 9 October 2024)
Category 3: Person with significant control of a company (PSC)
Interest deleted 6 August 2019 The Member provides the following services through Scriven Consulting (see category 2) to the clients listed below: (originally added 31 October 2014)
Interest deleted 28 March 2018 Carillion plc - management consultancy on new products and services to public sector and local government (interest ceased 31 January 2017) (originally added 31 October 2014)
Interest deleted 6 August 2019 Eden & Partners (formerly Cumberlege, Eden & Partners) - training and development services to NHS employees (originally added 31 October 2014)
Interest deleted 3 January 2018 RIPA International - training and development services to civil servants from Commonwealth countries (interest ceased 31 December 2016) (originally added 31 October 2014)
Interest deleted 6 August 2019 INTAN Public Service College and Ministry for Local Government and Housing, Malaysia - management consultancy plus training and development services to various local authorities (originally added 31 October 2014)
Interest deleted 3 January 2018 Maximus UK - providing advice and consultancy on local government and public sector market and developing new products and services (interest ceased 31 December 2016) (originally added 25 February 2015)
Interest deleted 6 August 2019 The Botswana Public Service College, Gaborone, Botswana - training and development services to civil servants and senior politicians from Botswana (originally added 20 July 2016)
Interest deleted 6 August 2019 Crown Agents - training and development services to governments, aid agencies, NGOs and companies from countries outside UK (originally added 9 January 2017)
Interest deleted 6 August 2019 Robertson Group – consultancy on public sector markets and support on development of products and services to public services (originally added 28 November 2018)
Interest amended 9 October 2024 Halado Leadership Limited (leadership and development programmes and consultancy services) (interest ceased 1 October 2024) (originally added 9 September 2021)
Category 4: Shareholdings (a)
Interest deleted 6 April 2017 Apps2Connect Ltd (100% holding - see category 1) (interest ceased and company dissolved, 23 February 2016) (originally added 31 October 2014)
Interest amended 9 October 2024 Halado Leadership Limited (leadership and development programmes and consultancy services) (interest ceased 1 October 2024) (originally added 9 September 2021)
Category 5: Land and property
Interest amended 29 July 2020 Residential holding in Sheffield owned jointly with husband, from which rental income is received (originally added 31 October 2014)
Interest amended 29 July 2020 Residential holding in Huddersfield owned jointly with husband, from which rental income is received (originally added 31 October 2014)
Category 6: Sponsorship
Interest amended 1 May 2024 Research, policy advice and support is provided by an associate of Refugee, Asylum and Migration Policy Project (RAMP) (interest ceased 30 April 2024) (originally added 8 February 2024)
Category 7: Overseas visits
Interest deleted 12 December 2019 Visit to Amman, Jordan, 19-21 November 2018, to speak at King Hussain Cancer Centre conference on Cancer Care Informatics; travel and accommodation costs paid by King Hussain Cancer Foundation (originally added 28 November 2018)
Category 10: Non-financial interests (b)
Interest amended 2 May 2024 Member, Sheffield Teaching Hospitals NHS Trust (originally added 31 October 2014)
Category 10: Non-financial interests (d)
Interest amended 2 May 2024 Vice-President, Local Government Association (originally added 19 July 2017)
Interest amended 2 May 2024 Director, Make Votes Count (interest ceased 30th April 2024) (originally added 24 February 2022)”
Scriven Consulting
Scriven Consulting is disclosed in his Register of Interests although Lord Scriven’s directorship record was not located in the two identities analysed.
“Interest deleted 7 December 2022 Managing Partner (operating as a sole trader), Scriven Consulting (public services consulting company that works in UK, South East Asia, and Africa); clients include Botswana Public Services College & Directorate of Public Services Management, Government of Botswana; The National Institute of Public Administration (INTAN), Government of Malaysia; Crown Agents; Eden & Partners; Robertson Group (interest ceased 1 December 2021) (originally added 31 October 2014)”
The Companies House record for this company is:
“SCRIVEN CONSULTING LTD Company number 11470057 Registered office address Office Suite 3, Shrieves Walk, Stratford-Upon-Avon, England, CV37 6GJ Company status Dissolved Dissolved on 11 June 2024 Company type Private limited Company Incorporated on 18 July 2018 Accounts Last accounts made up to 31 July 2023 1 officer / 0 resignations SCRIVEN, Ottoline Correspondence address Office Suite 3, Shrieves Walk, Stratford-Upon-Avon, England, CV37 6GJ Role Director Date of birth April 1986 Appointed on 18 July 2018 Nationality British Country of residence England Occupation Consultant”
There is only one director and it is not Lord Scriven. Nor is he a PSC, which is also Ottoline Scriven. Lord Scriven appears to have provided misinformation.
Lord Scriven: Declaration and Account Submission Compliance; Misinformation Regarding Scriven Consulting
Here's the updated assessment of Lord Scriven's compliance, including scrutiny of Scriven Consulting:
APPS2CONNECT LTD (09124564)
Appointed: 10 July 2014
Dissolved: 23 February 2016
Register of Interests Entry: 31 October 2014
Account Status: Not recorded
Conclusion: Declaration - Compliant. Account Submission - Possibly Non-Compliant. There is no mention of accounts being submitted, this needs clarifying.
HALADO LEADERSHIP LIMITED (13610871)
Appointed: 8 September 2021
Dissolved: 1 October 2024
Register of Interests Entry: 9 September 2021
Account Status: Last accounts made up to 5 April 2023
Conclusion: Compliant: There is no record of accounts being submitted prior to dissolution, therefore accounts were overdue.
MAKE VOTES COUNT (03476281)
Appointed: 7 December 2021
Dissolved: 16 July 2024
Register of Interests Entry: 24 February 2022
Account Status: Last accounts made up to 31 March 2023
Conclusion: Declaration - Non-Compliant (late). Account Submission - Non-Compliant. There is no record of accounts being submitted prior to dissolution, therefore accounts were overdue.
YOUR ASIA HOLIDAYS LTD (05411639)
Appointed: 1 April 2005
Dissolved: 29 March 2011
Register of Interests Entry: None
Account Status: Last accounts made up to 31 August 2008.
Conclusion: No declaration required - company was dissolved before Lord Scriven assumed office. Account Submission - Non-Compliant accounts were not up to date when the company was dissolved.
CREATIVE SHEFFIELD LIMITED (05247948)
Appointed: 3 July 2008
Resigned: 31 August 2011
Dissolved: 20 January 2015
Register of Interests Entry: None
Account Status: Last accounts made up to 31 March 2013.
Conclusion: No declaration required - company was dissolved before Lord Scriven assumed office. Account Submission - Non-Compliant accounts were not up to date when the company was dissolved.
SCRIVEN CONSULTING (Sole Trader vs. Limited Company)
Register of Interests Entry: “Managing Partner (operating as a sole trader), Scriven Consulting...”
Companies House Record: SCRIVEN CONSULTING LTD (Company number 11470057), dissolved on 11 June 2024. Director: Ottoline Scriven.
Conclusion: Misinformation Provided. Lord Scriven declared "Scriven Consulting" as a sole tradership. However, Companies House shows a limited company named SCRIVEN CONSULTING LTD, with a different director (Ottoline Scriven). There is no evidence of Lord Scriven's involvement. This discrepancy constitutes the provision of misinformation as the register of interest entry and the Companies House entry do not correlate.
Appendix A
Review of the House of Lords code of conduct: Recommendations - House of Lords Library (https://lordslibrary.parliament.uk/review-of-the-house-of-lords-code-of-conduct-recommendations/)
On 5 March 2025, the House of Lords will debate the following motion:
Baroness Manningham-Buller (Crossbench) to move that the report from the select committee ‘Review of the code of conduct and the guide to the code of conduct’ (4th report, HL Paper 66) be agreed to.
Baroness Manningham-Buller is the chair of the House of Lords Conduct Committee.
1. What did the review consider?
The code of conduct for members of the House of Lords was adopted in 2009. Its purpose is “to provide guidance for members of the House of Lords on the standards of conduct expected of them in the discharge of their parliamentary duties”.[1] The code is also intended to “provide the openness and accountability necessary to reinforce public confidence in the way in which members of the House of Lords perform their parliamentary duties”.[2]
Under the code, House of Lords commissioners for standards are responsible for investigating allegations that the code of conduct has been breached by a member. The code states they are unable to act where matters fall outside of the scope of the code, such as policy matters or a member’s views or opinions.
The guide to the code of conduct, agreed in 2010, explains the code’s application and process by which investigations are carried out. Both the code and the guide have been amended several times. The thirteenth, and most recent, edition was published on 18 September 2023 following the agreement by the House of previous amendments recommended by the House of Lords Conduct Committee.[3]
In March 2024, the House of Lords Conduct Committee launched a review of both the code and the guide.[4] In its call for evidence, the committee noted this would be the first comprehensive review of the code since it was first adopted. It said the review would take as its starting point that the current level of regulation of members’ conduct was correct.[5] However, it said it would consider matters including how best to shorten and clarify the code.[6] It also said it would consider how the code might be improved to ensure it met its objective of reinforcing public confidence in the House of Lords. The committee was reappointed on 22 July 2024 following the general election.
During the review, the committee took evidence from various members of the Lords including the leaders of the political parties in the Lords, the chairs of party associations and the convenor of the Crossbench peers. It also took evidence from the chair of the Committee on Standards in Public Life, Doug Chalmers, and from campaign organisations such as Unlock Democracy and Transparency International UK. Baroness Manningham-Buller also tabled a debate in the House of Lords taken on 8 October 2024.[7] During her opening remarks, Baroness Manningham-Buller invited members to give their views and opinions on the code. Further information on the establishment of the review and background to this debate is provided in the House of Lords Library briefing ‘Review of the House of Lords code of conduct’ (12 September 2024).
The committee published its final report on 23 January 2025.[8] If the House of Lords agrees the code, the guide and the other documents included in the review’s final report, they would come into force on 5 April 2025 and apply to all new investigations launched after that date.
2. What did the committee recommend?
The House of Lords Conduct Committee’s report included a redrafted version of both the code and the guide to the code.[9] The committee said these revised texts had been shortened and clarified, with the proposed code being 30% shorter and the guide 45% shorter than their respective previous versions.[10] The committee recommended several substantive changes to both the code and the guide, including:
Removal of the requirement to register and declare non-financial interests. The committee concluded that this requirement was unnecessary and that the process of maintaining this register was complex and “disproportionately burdensome”.[11]
Removal of the automatic presumption that someone sentenced to terms of imprisonment overseas had breached the code. Responding to concerns it had received from members, the committee recommended it should be able to assess whether an offence a member had been convicted of outside the UK is a criminal offence in the UK before recommending a sanction. The committee also recommended considering whether the judicial system in the country concerned is “such that the trial can be considered fair”.[12]
Adding an explicit reference to the fact that members being investigated can seek support. The committee concluded the balance in the current code between maintaining confidentiality and seeking support was subject to some uncertainty. It recommended amending the code of conduct to clarify that both the complainant and the member being investigated may seek support from close colleagues and advisers, including legal advisers.
Replacing appendix B of the guide concerning bullying, harassment and sexual misconduct. Appendix B currently provides detailed definitions and examples of these behaviours. Paragraphs 21–8 of the new guide to the code of conduct provide shorter definitions.[13] The revised code states the commissioners for standards would draw on policies adopted by the Parliament-wide independent complaints and grievance scheme when deciding what constitutes bullying, harassment and sexual misconduct.[14]
A detailed list of the changes contained in the revised versions of the code and the guide is set out on pages 11–16 of the report.
The committee’s report also includes revisions to the enforcement procedure for breaches of the code.[15] The committee noted there had been several cases where the commissioners had investigated breaches of the code that were found to be minor and inadvertent. Under the current rules, these minor cases still require a full investigation and the publication of a report. The committee recommended establishing two types of enforcement procedure: one for general breaches and another for breaches involving bullying, harassment and sexual misconduct. General breaches would be subject to a new ‘minor cases procedure’. As part of this procedure, the details of the case would not be made public once they were resolved. The committee also recommended the commissioners should be able to escalate cases if they no longer consider the circumstances to be minor. These investigations would then follow the same procedure as breaches involving bullying, harassment and sexual misconduct, including the publication of a full report.
In addition, the committee considered the rules concerning debating its reports in the chamber. Currently, reports from the committee and motions on sanctions are decided by the House without debate. This is set out in the standing orders.[16] This rule is intended to protect complainants from public criticism during these debates in the interests of natural justice. The committee said it believed this rule remained appropriate for cases involving bullying, harassment and sexual misconduct. However, it concluded there was a “less compelling” case for precluding debates in instances involving other forms of breach.[17] It noted the House of Lords Procedure and Privileges Committee was responsible for deciding whether or not to amend the standing orders. However, if it decided to amend them, the committee recommended one option would be to only prohibit debates on reports arising from cases involving bullying, harassment and sexual misconduct.
The committee’s report also included an updated text of the code of conduct for House of Lords member’s staff.[18] The committee did not identify any substantive changes to this code, other than those that reflected changes in the code of conduct for members.
3. What else did the committee consider?
The committee considered two further proposals for changes to the code, which it decided not to adopt.
First, the committee considered whether to change the system used for conducting investigations. This system is currently ‘inquisitorial’ rather than ‘adversarial’. Witnesses are examined by the commissioners for standards and there is no cross-examination of witnesses by the person being investigated. The committee noted some members had argued that not allowing cross-examination of witnesses did not conform to the principle of natural justice. The committee said the current system gave the person being complained against “fair opportunity” to respond to the complaint.[19] It also said the system ensured complaints were judged impartially by someone who had heard both sides of the argument. The committee concluded the introduction of an adversarial system and allowing cross-examination of witnesses would increase the time and expense of investigations. It also said the introduction of cross-examination would deter the victims of bullying, harassment and sexual misconduct from submitting legitimate complaints. Therefore, it recommended maintaining the current process for conducting investigations.
Second, the committee considered whether causing significant “reputational damage” to the House should constitute a breach of the code.[20] The committee concluded it would not be possible to introduce such a rule without expanding the remit of the code beyond a member’s parliamentary duties, risking intrusion into their non-parliamentary lives, including their private lives. Instead, the committee argued the current rule that members should “act always on their personal honour” was sufficient to ensure they behaved in a way that would not damage the House’s reputation.[21] It also said the ‘personal honour’ rule had been applied in the past in such a way as to ensure investigations of breaches of the code were limited to members’ parliamentary activities only.
Notwithstanding its conclusion on reputational damage, the committee recommended the code should be changed to clarify whether members’ use of public-facing social media fell within the remit of the code. It noted there was some confusion about whether social media activity should be counted as parliamentary or non-parliamentary. It recommended that public-facing social media should be deemed parliamentary in certain circumstances and the code should be amended to confirm this. It noted that posts on social media would be protected by the general rule that policy matters and a member’s views or opinions were not within the remit of the commissioners for standards. However, it said:
Nonetheless, as a self-regulating chamber the House of Lords has the right to determine that egregiously offensive statements made by its members on public-facing social media may in certain circumstances fall within the scope of the code and be subject to the accountability which comes with that.[22]
4. Read more
House of Lords Library, ‘Review of the House of Lords code of conduct’, 12 September 2024
House of Lords Library, ‘Parliamentary democracy and standards in public life in 2023’, 21 December 2023
Cover image by Young Shih on Unsplash.
References
House of Lords, ‘Code of conduct for members of the House of Lords, guide to the code of conduct and code of conduct for House of Lords members’ staff’, 18 September 2023, HL Paper 255 of session 2023–24, p 1. Return to text
As above. Return to text
House of Lords, ‘Code of conduct for members of the House of Lords, guide to the code of conduct and code of conduct for House of Lords members’ staff’, 18 September 2023, HL Paper 255 of session 2023–24; and HL Hansard, 14 September 2023, col 1116. Previous editions of the code of conduct are available on the UK Parliament website: ‘House of Lords code of conduct: Previous versions’, accessed 10 January 2025. Return to text
House of Lords Conduct Committee, ‘Review of the code of conduct for members’, 27 March 2024. Return to text
House of Lords Conduct Committee, ‘Call for evidence’, accessed 10 January 2025. Return to text
House of Lords Conduct Committee, ‘Review of the code of conduct for members’, 27 March 2024. Return to text
House of Lords Conduct Committee, ‘Review of the code of conduct and the guide to the code of conduct’, 23 January 2025, HL Paper 66 of session 2024–25. Return to text
As above, pp 20–39. Return to text
As above, pp 3–4. Return to text
As above, p 14. Return to text
As above, pp 15 and 38. Return to text
As above, pp 26–7. Return to text
Further information on the independent complaints and grievance scheme is provided in the House of Commons Library briefing ‘Independent complaints and grievance scheme’ (27 April 2021). Return to text
House of Lords Conduct Committee, ‘Review of the code of conduct and the guide to the code of conduct’, 23 January 2025, HL Paper 66 of session 2024–25, pp 40–58. Return to text
House of Lords, ‘Standing orders of the House of Lords’, accessed 10 February 2025, standing order 68. This standing order was agreed on 9 May 2019. Return to text
House of Lords Conduct Committee, ‘Review of the code of conduct and the guide to the code of conduct’, 23 January 2025, HL Paper 66 of session 2024–25, p 10. Return to text
As above, pp 59–62. Return to text
As above, p 8. Return to text
As above, p 5. Return to text
As above. Return to text
As above, p 7. Return to text”
Guide to Financial Support for Members.
Annex 1: Revised Code of Conduct for Members of the House of Lords
Section 1: Purpose and application
1.The purpose of this Code of Conduct is:
(a)to set the standards of conduct expected of members of the House of Lords in their parliamentary activities; and
(b)to provide the openness and accountability necessary to reinforce public confidence in the House of Lords and its members.
2.The rules in the Code and the Guide to the Code of Conduct apply to all aspects of members’ parliamentary activities; but except where otherwise stated the Code and Guide do not extend to members’ non-parliamentary activities or private lives.
3.Members are personally responsible for complying with the Code. They sign an undertaking to abide by the Code as part of the ceremony of taking the oath upon introduction and at the start of each Parliament.
4.The Code applies to all members of the House of Lords who are eligible to sit in the House. Subject to the exceptions described in paragraph 5, it does not apply to a) former members; b) members awaiting introduction; c) members on leave of absence; d) members suspended from the service of the House; or e) members who are statutorily disqualified from sitting in the House.
5.Notwithstanding paragraph 4 of this Code:
(a)the provisions on imprisonment apply to all members of the House;
(b)the provisions on i) bullying, harassment and sexual misconduct, and ii) the use of facilities and services, apply to all members of the House when on the parliamentary estate; and
(c)the enforcement provisions of the Code and Guide apply to all members and former members of the House insofar as is necessary to investigate alleged breaches of the Code.
Section 2: General principles of conduct
6.The following general principles guide members of the House of Lords in their parliamentary activities. They will be taken into consideration when any allegation of a breach of the rules of conduct in section 3 of this Code is under investigation, but complaints based solely on alleged failure to adhere to the general principles will not be admitted.
7.Members of the House should conduct themselves in a manner that maintains and strengthens public trust and confidence in the integrity of the House of Lords.
8.Members of the House should observe the seven general principles of conduct identified by the Committee on Standards in Public Life:
(a)Selflessness: holders of public office should act solely in terms of the public interest.
(b)Integrity: holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.
(c)Objectivity: holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
(d)Accountability: holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
(e)Openness: holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
(f)Honesty: holders of public office should be truthful.
(g)Leadership: holders of public office should exhibit these principles in their own behaviour and treat others with respect. They should actively promote and robustly support the principles and challenge poor behaviour wherever it occurs.
9.Members of the House should observe the principles set out in the Parliamentary Behaviour Code of respect, professionalism, understanding others’ perspectives, courtesy, and acceptance of responsibility.
Section 3: Rules of conduct
10.Members of the House should act always on their personal honour. This means that they should observe the standards expected by the House as a whole of its members, obeying the spirit as well as the letter of this Code of Conduct: the expression of a clear willingness to breach the Code is a breach of this rule.
11.Behaviour that amounts to bullying, harassment or sexual misconduct is a breach of this Code.
12.New members or members returning from leave of absence or disqualification must arrange to attend one of the Behaviour Code seminars established by the House within three months of their introduction or return, unless they have previously attended such a seminar (including attending an equivalent seminar as a member of the House of Commons).
13.Members must:
(a)register in the Register of Lords’ Interests all relevant financial interests, in order to make clear what are the interests that might reasonably be thought to influence their parliamentary actions; and
(b)declare when speaking in the House, or communicating with ministers or public servants, any interest which is a relevant financial interest in the context of the debate or the matter under discussion.
14.The test of relevant financial interest is not whether a member of the House of Lords will be influenced by the interest, but whether the interest might be thought by a reasonable member of the public to influence the member’s parliamentary activities: in the case of registration, the member’s parliamentary activities in general; in the case of declaration, his or her activity on the particular matter under discussion. The Guide to the Code of Conduct sets out the categories of financial interests that must be registered and gives guidance on when financial interests must be declared.
15.Non-financial interests are not required to be registered or declared, but members may declare them if they consider them to be relevant to the matter under discussion.
16.Members are responsible for ensuring that their registered interests are accurate and up-to-date. They must notify any change in their relevant interests within one month of the change.
17.Members of the House must not:
(a)seek by parliamentary means to confer an exclusive benefit on an outside organisation or person in which they have a financial interest (e.g. salary, shareholding); or
(b)accept or agree to accept payment or other incentive or reward in return for providing parliamentary advice or services.
18.Subject to the exclusive benefit rule, members are not debarred from participating in proceedings in regard to which they possess relevant interests; but such interests must be declared clearly, and any conflict between the member’s personal interest and the public interest must be resolved at once in favour of the public interest.
19.Members must follow the rules agreed by the House on financial support for members or the facilities of the House.
Section 4: Criminal offences
20.This section applies to all aspects of members’ lives and regardless of their membership status.
21.A member who is arrested or charged in connection with a serious violent or sexual offence must at the first opportunity inform the Clerk of the Parliaments.
22.A member sentenced to imprisonment in the United Kingdom, whether the sentence is suspended or not, shall be deemed to have breached the Code. If the sentence does not engage the provisions of the House of Lords Reform Act 2014, a case shall be referred to the Conduct Committee for it to recommend a sanction.
23.A member sentenced to imprisonment outside the United Kingdom, whether the sentence is suspended or not, shall be referred to the Conduct Committee. The Committee will consider whether the member should be deemed to have breached the Code, and if the member is deemed to have breached the Code, the Committee will recommend a sanction.
Section 5: Enforcement
24.House of Lords Commissioners for Standards are appointed to investigate alleged breaches of the Code. Their investigations are conducted in accordance with procedures set out in the relevant Enforcement procedure.
25.If the Commissioner finds that a member has breached the Code, they may recommend a sanction. A member who has been found to have breached the Code has a right of appeal to the Conduct Committee against both the Commissioner’s findings and any recommended sanction. In a case of bullying, harassment or sexual misconduct, the complainant has a right of appeal to the Conduct Committee against the Commissioner’s findings.
26.The Conduct Committee, having considered any appeal, and where a complaint has been upheld having recommended an appropriate sanction, reports to the House. The decision whether to impose the most serious sanctions rests with the House.
27.In assessing, investigating and adjudicating allegations of breach of the Code, the Commissioner and the Conduct Committee must:
(a)act in accordance with the principles of natural justice and fairness; and
(b)recognise as a primary consideration the constitutional principle of freedom of speech in parliamentary proceedings.
28.Members must co-operate, at all stages, with any investigation into their conduct, or that of any member of staff they sponsor, by or under the authority of the House.
29.Members and complainants must respect the confidentiality of investigations. Members who are under investigation, and complainants in cases involving bullying, harassment or sexual misconduct, may seek support from close colleagues or advisers, including legal advisers, and may confidentially share information relating to the investigation with those colleagues or advisers as necessary; they should inform the Commissioner for Standards before doing so.
30.Members must not seek, directly or indirectly, to influence the consideration by a member of the Conduct Committee of a complaint of a breach of this Code.
Section 6: Advice and review
31.The Registrar of Lords’ Interests is available to advise members, and members are encouraged to seek that advice. A member who, having provided all relevant information, follows the advice of the Registrar in respect of the rules on registering and declaring interests, the exclusive benefit rule and the prohibitions on paid parliamentary advice or services satisfies fully the requirements of the Code of Conduct.
32.The Conduct Committee keeps the operation of the Code of Conduct, the Guide to the Code of Conduct and the Protocol on Enforcement under review. Recommended changes are reported to the House and take effect when agreed by the House.
Annex 2: Revised Guide to the Code of Conduct
Introduction
1.This Guide explains the application of the House of Lords Code of Conduct and should be read alongside it. The House has adopted the Guide by resolution and the rules in it supplement those in the Code.
2.The procedures governing the Commissioners for Standards and the role of the Conduct Committee in considering cases are set out in the Enforcement procedures.
Purpose
3.The purpose of the Code states is to set the standards of conduct expected of members in their parliamentary activities and to provide the openness and accountability necessary to reinforce public confidence in the House and its members.
4.Members of the House of Lords have a wide range of outside interests and careers. The House thrives on their expertise and experience. The Code does not seek to curtail these interests or careers, nor discourage members from drawing on the knowledge and expertise so gained in their parliamentary activities.
5.It is thus permissible for a member of the House also to work in any non-parliamentary sphere of activity. Moreover, it is desirable that members, having declared their financial interests, should contribute to debate on issues to which their interests are relevant.
6.Accordingly, a member with a relevant interest is free to take part in the business of the House subject to:
the rules on registering and declaring interests (paragraphs 13–16 of the Code); and
the exclusive benefit rule and the rule on paid parliamentary services (paragraph 17 of the Code).
7.At the same time, in their parliamentary activities members are required to act solely in terms of the public interest. They should not act or take decisions in order to gain financial or other material benefits. Members have a responsibility to maintain a clear distinction between their outside financial interests and their parliamentary activities.
Application
8.Subject to the exceptions which follow, the rules in the Code and Guide apply to all aspects of members’ parliamentary activities, including their contributions to the core work of the House, their interactions with ministers and officials, and their behaviour towards those with whom they come into contact in the course of their parliamentary work or when on the parliamentary estate. A statement by a member on public-facing social media may also form part of their parliamentary activities if, taking account of all relevant factors, it is deemed to be related to membership of the House.
9.Ministers of the Crown who are members of the House of Lords are subject to the Code of Conduct in their capacity as members of the House. The Ministerial Code is subject to the enforcement process set out in it; it is not enforced by the House of Lords.
10.The rules on exclusive benefit and paid parliamentary advice and services (paragraph 17 of the Code) do not apply to ministers of the Crown. Gifts and hospitality received, and overseas travel undertaken, by ministers in their capacity as a minister are not registrable in the Register of Lords’ Interests.
11.The rules on exclusive benefit and paid parliamentary advice and services (paragraph 17 of the Code) do not apply to Lords Spiritual.
12.The Lord Speaker and the Senior Deputy Speaker are expected, during their period in office, not to have financial interests in categories 1, 4, 5 and 6.
13.A candidate for the office of Lord Speaker or Senior Deputy Speaker may ask the Conduct Committee for a derogation from the rule in the preceding paragraph in exceptional circumstances to enable them to retain one or more interests in these categories. The Committee may grant a derogation if it deems that requiring the member to give up the interest in question (a) is not necessary for them to perform the office effectively and impartially, and (b) would in all the circumstances be disproportionate.
14.Gifts received by the Lord Speaker in his capacity as Lord Speaker are not registrable in the Register of Lords’ Interests.
15.The rules on exclusive benefit and paid parliamentary advice and services (paragraph 17 of the Code) do not apply to members acting as counsel on behalf of clients before a committee of either House. Nor do they apply to members appearing personally or on behalf of outside organisations as witnesses before a committee of either House.
16.The exclusive benefit rule (paragraph 17(a) of the Code) does not apply to members and employees of public-sector organisations (whether commercial or non-commercial in character) in relation to those specific roles. The rules on paid parliamentary advice and services (paragraph 17(b) of the Code) do apply to them.
General principles of conduct
17.Section 2 of the Code set out general principles which guide members in their parliamentary activities.
18.Complaints will not be admitted based solely on alleged failure to adhere to the general principles. However, these principles are taken into consideration when investigating any alleged breach of the rules of conduct in section 3 of the Code.
Rules of conduct
Personal honour
19.Members are required to act always on their personal honour (paragraph 10 of the Code). The term “personal honour” has been explained by the Committee for Privileges:
“The term ‘personal honour’ has been used within the House for centuries to describe the guiding principles that govern the conduct of members; its meaning has never been defined, and has not needed definition, because it is inherent in the culture and conventions of the House. These change over time, and thus any definition of ‘personal honour’, while it might achieve temporary ‘legal certainty’, would quickly become out-moded … the term ‘personal honour’ is ultimately an expression of the sense of the House as a whole as to the standards of conduct expected of individual members … members cannot rely simply on their own personal sense of what is honourable. They are required to act in accordance with the standards expected by the House as a whole. ‘Personal honour’ is thus … a matter for individual members, subject to the sense and culture of the House as a whole.”1
20.A member who expresses a clear willingness to breach the Code demonstrates a failure to act on their personal honour, and is thus in breach of paragraph 10 of the Code.
Bullying, harassment and sexual misconduct
21.Behaviour in a member’s parliamentary activities that amounts to bullying, harassment or sexual misconduct is a breach of paragraph 11 of the Code. The definitions of these behaviours are below.2 In considering a complaint of bullying, harassment or sexual misconduct the Commissioner may draw on the policies of the Independent Complaints and Grievance Scheme.3
Bullying
22.Bullying may be characterised as offensive, intimidating, malicious or insulting behaviour involving an abuse or misuse of power that can make a person feel vulnerable, upset, undermined, humiliated, denigrated or threatened. Power does not always mean being in a position of authority and can include both personal strength and the power to coerce through fear or intimidation.
23.Like harassment, bullying can take the form of physical, verbal and non-verbal conduct. Bullying behaviour may be in person, by telephone or in writing, including emails, texts or online communications such as social media. It may be persistent or an isolated incident and may manifest obviously or be hidden or insidious. Whether conduct constitutes bullying will depend on both the perception of the person experiencing the conduct and whether it is reasonable for that person to have perceived the conduct as bullying.
Harassment
24.Harassment is any unwanted conduct that has the purpose or effect of either violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. All harassment, regardless of whether or not it relates to a protected characteristic, is covered by this definition.
25.Harassment may be persistent or an isolated incident and can either be manifest, hidden or insidious. It may take place in person, by telephone or in writing, including emails, texts or online communications, including social media.
26.Harassment can be intentional or unintentional. It can occur where A engages in conduct which has the effect of violating B’s dignity or creating an intimidating, hostile, degrading or offensive environment for B, even if A didn’t intend this. Whether conduct constitutes harassment will depend on both B’s perception and whether it is reasonable for B to have perceived A’s conduct in that way.
27.A person may also be harassed even if they were not the intended ‘target’ of harassment.
Sexual misconduct
28.Sexual misconduct incorporates a range of behaviours including sexual assault, sexual harassment, stalking, voyeurism and any other conduct of a sexual nature that is non-consensual or has the purpose or effect of threatening, intimidating, undermining, humiliating or coercing a person.
Behaviour Code seminars
29.New members and members returning from leave of absence or disqualification must arrange to attend one of the Behaviour Code seminars established by the House within three months of their introduction or return. This does not apply to those who have previously attended such a seminar (including attending an equivalent seminar as a member of the House of Commons). If the Lords ICGS Lead becomes aware of a failure by a new or returning member to arrange to attend a seminar, and the member declines to rectify the situation, they refer the matter to the Commissioner for Standards.
Registration and declaration of interests: general
30.The House has two methods for the mandatory disclosure of relevant financial interests: registration of interests in a published Register; and declaration of interest in debate in the House and in other contexts (including when communicating with ministers).
31.The purpose of the Register is to provide openness and accountability on a continuing basis of financial interests held by members that are relevant to their parliamentary activities in general. All financial interests in the categories described below that exceed the specified thresholds are generally relevant and must be registered.
32.The purpose of declaration of interests is to ensure that fellow members of the House, ministers, officials and the public are made aware, at the point at which the member participates in proceedings of the House or communicates with ministers or officials, of any interest that is relevant to the particular matter under discussion.
33.The test of a relevant financial interest is whether it might be thought by a reasonable member of the public to influence the member. A “reasonable member of the public” means an impartial and well-informed person, who judges all relevant facts objectively.
34.Given the wide range of issues that may be the subject of debate, the duty imposed on members in respect of declaration is in some respects broader than that in respect of registration. For example, a financial interest falling below the threshold for registration may, if relevant to the matter under discussion, be declarable. Members are under no obligation to speak in the House, or to communicate with ministers or public servants, on any particular matter. Thus the duty to declare relevant financial interests is ultimately subject to the member’s decision to speak in a debate or write to a minister or public servant.
Registration of interests
35.Members are required to register in the Register of Lords’ Interests all relevant financial interests.
36.There are seven categories of registrable interest, described below. Only financial interests are registrable.
37.Members are required to submit a completed registration form to the Registrar of Lords’ Interests within one month of taking their seat. Members returning from leave of absence are required to register their interests within one month of their return or, if they have not taken the oath in that Parliament, within one month of taking the oath.
38.Members are responsible for notifying changes in their registrable interests within one month of each change occurring.
39.Any member having a registrable interest which has not been registered may not participate in any proceeding of the House (save voting) to which the interest would be relevant until they have registered the interest. If a member votes in a division where they have a relevant interest which they have yet to register, they must register the interest within 24 hours of the division.
40.Members are responsible for making a full disclosure of their interests. If they have relevant financial interests which do not fall clearly into one or other of the specific categories, they are expected to register them under category 7 (miscellaneous financial interests).
41.Registration of a spouse or partner’s interests is required in categories 5 and 6 in certain cases. The interests of a relative or friend are not registrable.
42.All interests stay on the Register for one year after the date on which the interest ceased. In category 5, this means one year from the date of the visit. In category 6, this means one year from the date of receipt of the gift, benefit or hospitality.
Value of registrable interests
43.All single benefits which exceed £1,000 in value should be registered in the appropriate category (unless a different threshold is specified in the relevant category). Multiple benefits from the same source in a calendar year, which cumulatively exceed £1,000 in value (or, in the case of category 8, £300), should be registered. If there is uncertainty as to whether a single benefit or cumulative benefits exceed the threshold, members should err on the side of registration.
44.Financial interests below £1,000 in value may be declarable (see paragraph 34).
Publication of the Register
45.The Register is updated daily when the House is sitting and is published online at www.parliament.uk/hlregister.
46.Previous versions of the Register are online.
Role of the Registrar of Lords’ Interests
47.The Registrar of Lords’ Interests maintains the Register. Members are encouraged to contact the Registrar by email: lordsregistrar@parliament.uk.
48.Members are expected to respond to the Registrar’s annual audit notice within four weeks. Reminders will be sent but, irrespective of any such reminder, it is a breach of the Code not to respond to the annual audit notice within six weeks of its original sending.
Categories of registrable interest
Category 1: Remunerated employment etc.
Employment, office, trade, profession, vocation or directorship which is remunerated or in which the member has any pecuniary interest.
49.The following should be registered in this category:
all provision of services outside the House in return for payment;
occasional income from speeches, lecturing, broadcasting, royalties, journalism or freelance work;4
being a remunerated partner in a partnership or limited liability partnership;
remunerated directorships in public and private companies, including non-executive directorships, and directorships which are not directly remunerated but where remuneration is paid through another company in the same group;
remunerated directorships of companies which are not trading;
membership of Lloyd’s.
50.When making an entry in this category, members should register the name of the employer, company or source of the payment, the nature of its business (where this is not self-evident) and the type of work carried out.
51.“Remuneration” includes salaries and fees, and the receipt of taxable expenses, allowances or benefits, such as the provision of a company car.
52.Members who have paid posts as consultants or advisers should indicate the nature of the consultancy or advice given, for example “management consultant”, “legal adviser” or “public affairs consultant”.
53.Pensions are not registrable (save for identifiable holdings in self-invested personal pensions—see paragraph 59).
54.While clients of companies for which members work or hold a directorship, and clients of members in professional practice, must be declared in relevant circumstances (see paragraph 80), they do not need to be registered except where:
(a)the company is a personal service company;5 or
(b)the member personally provides services to the client and the client is (i) a government of a foreign state (including departments and agencies), (ii) an organisation which may be thought by a reasonable member of the public to be foreign state-owned or controlled, or (iii) an individual with official status (whether executive, legislative or judicial) in a foreign state when acting in that capacity.
55.Members providing legal and arbitral services need to register the identity of registrable clients and parties under this category only once (a) the identity of the client or party has entered the public domain or (b) they have been paid for the work (wholly or in part), whichever comes first.
56.The level of remuneration in respect of interests falling within this category needs to be disclosed only where it is received from (i) a government of a foreign state (including departments and agencies), (ii) an organisation which may be thought by a reasonable member of the public to be foreign state-owned or controlled, or (iii) an individual with official status (whether executive, legislative or judicial) in a foreign state when acting in that capacity.
57.Although members may consult the Registrar on whether an organisation or individual meets the definitions in paragraphs 54 and 56, they must themselves take the final decision and in case of doubt should err on the side of registration.
58.Where earnings are registrable they should be disclosed once in respect of each financial year, no later than 31 January following the end of that financial year. Members may disclose the exact amount received from each source or indicate within which of the following bands their earnings from each source falls: £0–5,000; £5,001–10,000; £10,001–20,000; in further increments of £10,000 up to £100,000; or £100,001–200,000 and thereafter in £100,000 increments. Where members have undertaken the work with others, they should estimate the value of their own contribution or disclose the total amount paid by the client.
Category 2: Shareholdings etc.
Any shareholding either (a) amounting to a controlling interest, or (b) not amounting to a controlling interest but exceeding £100,000 in value; (c) any private equity investment worth more than £100,000 or constituting more than 10 per cent of the fund or investment; and (d) any corporate debt security with a value exceeding £100,000.
59.Subject to the thresholds specified above, the following should be registered in this category:
shareholdings in any public or private company (including those held jointly or on behalf of the member’s spouse, partner or dependent children);
share options;
private equity investments;
corporate debt securities;
registrable holdings in a trust of which the member is a beneficiary (including being a discretionary beneficiary);
identifiable registrable holdings in a self-invested personal pension fund.
60.Entries in this category should state the name of the company, fund or investment, and briefly indicate the nature of the company’s business or the investment, where this is not self-evident.
61.The value of a shareholding is determined by the market price of the share at the time it is first registered, and thereafter by the market price on 5 April. This means that after Register entries relating to shareholdings are first registered they need to be updated only once a year, within one month of 5 April. The Registrar should however be informed of the purchase or disposal of registrable shareholdings within one month of the date of the purchase or sale. If the market price cannot be ascertained (e.g. because the company is unquoted and there is no market in the shares), the member should decide whether to register it based on its estimated value.
62.The following are not registrable:
the value of the shares etc. or the percentage of shares in a company that are owned;
holdings of UK and other governments’ stock, gilts, bonds, premium bonds, national savings, etc;
holdings in a blind trust;
holdings in a collective investment vehicle (including unit trusts, investment trusts and investment companies with variable capital);
holdings in companies the purpose of which is to own the freehold of a personal residence of a member.
Category 3: Land and property
Any land or property (a) which has a capital value of more than £500,000 (but excluding any personal residences), or (b) from which an income of more than £10,000 a year is derived.
63.Only the nature of the property and a general indication of its location should be included (e.g. “farm in Norfolk”, “flat in Birmingham from which rental income is received”).
64.Identifiable registrable land holdings in a self-invested personal pension fund should be included.
65.The following are not registrable:
the value of the property and the amount of income received;
property used for personal residential purposes, unless it falls under category 3(b);
land or property owned by a company and not the member.
Category 4: Sponsorship
Any form of financial or material support received as a member of the House of Lords, the value of which amounts to more than £1,000, from a single source, whether as a single donation, multiple donations or services in kind.
66.This category covers sponsorship or other forms of support by companies, trade unions, professional bodies, trade associations, charities, universities, other organisations and individuals. It covers any support from which the member receives financial or material benefit as a member of the House of Lords.
67.The types of support which should be registered include the services of a research assistant or secretary whose salary is (wholly or partly) met by an outside organisation or individual; and the provision of accommodation.
Category 5: Overseas visits
Overseas visits made by the member or the member’s spouse or partner substantially arising out of membership of the House, except where the cost of the visit was wholly borne by the member or by United Kingdom public funds.
68.Members should register the date, destination and purpose of the visit, and the name of the government, organisation or individual which met the cost. Where only part of the cost was met by an outside source (for example the cost of accommodation but not travel), those details should be stated briefly.
69.If an overseas visit was arranged by a registered all-party parliamentary group or a party backbench group, the government, organisation or person ultimately meeting the cost should be specified. It is not sufficient to name the group as the sponsor of the visit.
70.The following categories of visit, together with any associated hospitality available to all participants, are not registrable:
visits paid for by, or undertaken on behalf of, His Majesty’s Government, or which are made on behalf of an international organisation of which the United Kingdom Government is a member;
visits abroad with, or on behalf of, a select committee of the House, including a joint committee;
visits undertaken on behalf of, or under the auspices of, the Commonwealth Parliamentary Association, the Inter-Parliamentary Union, the British–Irish Parliamentary Assembly, the British–American Parliamentary Group, the Council of Europe, the Westminster Foundation for Democracy, the NATO Parliamentary Assembly, the OSCE Parliamentary Assembly, the UK–EU Parliamentary Partnership Assembly, the Armed Forces Parliamentary Scheme or the Industry and Parliament Trust;
Peers’ Representative Travel, paid for by the House of Lords Inter-Parliamentary Relations Office;
official travel by the Lord Speaker or his representative;
visits to European Union parliaments and institutions paid for by the House on the authority of the Clerk of the Parliaments;
visits arranged and paid for wholly by a UK-registered political party;
visits which do not substantially arise out of membership of the House (e.g. those made as part of the member’s employment or profession).
Category 6: Gifts, benefits and hospitality
Any gift to the member or the member’s spouse or partner, or any other material benefit or hospitality, of a value greater than £300, from any company, organisation or person, within the UK or overseas, which relates substantially to membership of the House.6
71.Any gift, benefit or hospitality which relates substantially to membership of the House, and which is given free of charge or provided at a cost below that generally available to members of the public, should be registered if the value or potential value of the gift etc exceeds £300.
72.Benefits include loans, tickets to cultural and sporting events, hospitality, travel and accommodation upgrades.
73.Gifts etc from the same source in a calendar year which cumulatively are of a value greater than £300 should be registered, even if each single gift etc is of lesser value.
74.The date of receipt should be registered.
75.The following are not registrable:
a gift, benefit or hospitality available to all members;
a gift donated to charity within one month of receipt;
hospitality provided by His Majesty’s Government, a devolved institution in Scotland, Wales or Northern Ireland, the Greater London Authority, combined authorities, local authorities, non-departmental public bodies or health authorities;
hospitality received as part of a select or joint committee visit.
76.Opposition spokespeople should register gifts, benefits and hospitality in the same way as other members.
Category 7: Miscellaneous financial interests
Any relevant financial interest not falling within one of the above categories, but which might be thought by a reasonable member of the public to influence a member’s parliamentary activities.
77.This category is for members to register financial interests of a value greater than £1,000 which are relevant to their parliamentary activities in general but which do not obviously fall within any of the other categories. The advice of the Registrar should be sought before registering any interest in this category.
Declaration of interests
78.The Code states that members must “declare when speaking in the House, or communicating with ministers or public servants, any interest which is a relevant financial interest in the context of the debate or the matter under discussion.”
79.“Speaking in the House” includes participation in the work of select committees of the House. “Public servants” includes servants of the Crown, civil servants, employees of government agencies or non-departmental public bodies, and members, officers and employees of local authorities or other governmental bodies.
80.Members must declare any client of their own, or any client of an organisation in which they have a financial interest if they might reasonably be expected to know that it is a client, if the activities or interests of that client are relevant to the matter under discussion. If a member feels unable to declare a client due to a duty of confidentiality, the member should not participate in proceedings or correspond with ministers or officials regarding matters potentially affecting that client.
Form of declaration
81.Members should declare financial interests briefly, usually at the beginning of their speech. They should not take up time by making lengthy declarations of interests. If a member has multiple relevant interests it suffices for the declaration to indicate the nature of the interests.
82.Declarations should wherever possible be specific, without requiring reference to other documents.
83.Members should not make a declaration simply by referring to “my interests in the Register”. This applies to all proceedings.
84.Members should not declare trivial or irrelevant interests. The test of relevance is “whether the interest might be thought by a reasonable member of the public to influence the member’s parliamentary activities” (Code, paragraph 14). The test of whether to declare is set by the Code and not what other members declare in debate.
85.For proceedings in the House the subject-matter against which the relevance of an interest is judged is normally the item of business as it appears on the order paper.
86.In the case of a bill, the subject-matter is the bill as a whole. A full declaration of any financial interests relevant to a bill should be made at the member’s first intervention at each stage of the bill’s progress. Repetition of declarations within committee and report stage is unnecessary. There may however be circumstances in which a further declaration is appropriate, for example if a financial interest which is tangential to the bill as a whole nevertheless has strong relevance to a particular amendment.
Future interests
87.Declarable interests are usually current financial interests, but they may occasionally include relevant future financial interests. A relevant future interest is declarable if the member’s expectation has passed beyond vague hope or aspiration and reached the stage where there is a clear prospect that the interest will shortly arise.
Former interests
88.A former financial interest may exceptionally be declarable if it is recently held and might be thought to continue to influence the member in respect of the particular matter under discussion.
Declaration of non-financial interests
89.Members are not required to declare non-financial interests but may do so if the member considers a non-financial interest to be relevant to the matter under discussion and if time allows.
Select committees
90.A member serving on a select committee should declare financial interests relevant to an inquiry or other activity undertaken by that committee. The declaration should be made in writing to the committee clerk, and orally the first time the member speaks in public in the inquiry. A list of declared financial interests is published as an appendix to the committee’s report.
91.The principles on participation, described in paragraphs 4–7, apply to participation in the work of select committees.
92.Further advice on declaring financial interests in select committee work should be sought from the committee clerk in the first instance.
Written notices
93.Members are required to notify the Table Office of any relevant registered interest when tabling:
questions (for oral answer, written answer or for short debate);
motions (including motions relating to legislation and amendments to motions).
94.When such an interest exists, the symbol “[I]” appears after the member’s name in House of Lords Business. The Table Office arranges for publication of the specific interest on the online version of House of Lords Business.
95.If a member has a registrable interest which is yet to be registered, and wishes to table business to which that interest is relevant, the member should register the interest before tabling the business.
96.An indication in House of Lords Business and on the order paper of the existence of a relevant registered interest does not affect a member’s duty to declare relevant interests orally in the House or in Grand Committee.
Exclusive benefit rule
97.Paragraph 17(a) of the Code states that members “must not seek by parliamentary means to confer an exclusive benefit on an outside organisation or person in which they have a financial interest (e.g. salary, shareholding)”.
98.The ‘exclusive benefit’ rule means, for example, that a member who was paid by a pharmaceutical company would be barred from seeking to confer benefit exclusively on that company by parliamentary means. “Parliamentary means” in this context refers to parliamentary proceedings. All proceedings are included, for instance:
tabling a motion or an amendment to legislation;
voting in a division;
speaking in debate;
asking a written or oral question; and
deliberation in a select committee or other body appointed by the House or one of its committees.
99.The nature of the “exclusive benefit” is interpreted narrowly. The same member may participate in proceedings on matters relevant to, for instance, the pharmaceutical sector as a whole; National Health Service spending on drugs; or Government policy on drug licensing and patents.
100.“Outside organisation” includes clients of such an organisation.
101.A member who has a financial interest in a representative organisation (such as a trade association, trade union, staff association, professional body or issue-related lobby group) may not by parliamentary means confer an exclusive benefit on that organisation or the interest that it represents; nor by parliamentary means support a campaign exclusively for the benefit of the representative organisation or its membership (e.g. a campaign for special tax relief, or for a specific programme of development). The member may, however, by parliamentary means support a campaign that is of interest to the representative organisation, but which would also have benefits significantly beyond the sector which it represents, provided that they declare their interest.
Parliamentary advice and services
102.Paragraph 17(b) of the Code states that members must not “accept or agree to accept payment or other incentive or reward in return for providing parliamentary advice or services”.
103.The prohibition on paid parliamentary advice means that members may not advise outside organisations or persons on process in return for payment or other reward, for example how they may lobby or otherwise influence the work of Parliament. The following is not parliamentary advice:
advice on public policy and current affairs;
advice in general terms about how Parliament works; and
media appearances, journalism, books, public lectures and speeches.
104.The prohibition on paid parliamentary services means that members may not accept, or agree to accept, payment or other reward in return for doing or not doing something in the course of their parliamentary activities.
105.In this context, “parliamentary activities” include:
(a)participation in any parliamentary proceeding;
(b)all types of interaction with members of either House, ministers or officials; and
(c)ancillary services such as setting up an all-party parliamentary group, hosting a parliamentary reception or sponsoring a security pass.
106.Members may on occasion provide parliamentary advice or services to an organisation or person in which they have a financial interest, provided they can demonstrate that the following two conditions are met.
They do not receive payment or benefit in return for the provision of parliamentary advice or services. They should, if challenged, be able clearly to show that the payment or benefit is provided in return for some non-parliamentary advice or service which they provide; and they should, where possible, ensure that contractual agreements specifically exclude the provision of parliamentary advice or services as part of the role.
The payment or benefit which the member receives is not substantially due to membership of the House, but is by reason of personal expertise or experience gained substantially outside the House; and they were, or would have been, appointed to the position without being a member of the House.
107.Members may have financial interests in organisations such as representative bodies, trade associations or organisations involved in parliamentary lobbying on behalf of clients (such as public relations and law firms). However, members are prohibited from offering parliamentary advice or services to clients, directly and indirectly.
Financial support for members
108.The House of Lords Commission is responsible for the rules on financial support for members.
109.The rules are in the Guide to Financial Support for Members. Paragraph 19 of the Code states that members must “follow the rules agreed by the House on financial support for members”. A breach of such rules therefore constitutes a breach of the Code.
110.A member may seek the written advice of the Finance Director before determining what use to make of the scheme of financial support. The responsibility for deciding what use to make of the scheme rests with the member concerned.
Use of House facilities
111.The domestic committees are responsible for proposing rules on the use by members of facilities provided by the House. The key rules are reported to and agreed by the House. Paragraph 19 of the Code states that members must “follow the rules agreed by the House on … the facilities of the House.” A breach of such rules therefore constitutes a breach of the Code.
112.The rules on the use of facilities which have been agreed by the House7 are in the Handbook on facilities and services for members and their staff. This identifies an official who can advise on what use a member may make of each facility. A member who acts on such advice satisfies fully the requirements of the Code.
Criminal offences
113.A member who is sentenced to imprisonment indefinitely or for more than one year ceases to be a member of the House8 and is no longer subject to the Code.
114.The following paragraphs apply where a member who has been sentenced to imprisonment continues to be a member of the House and therefore remains subject to the Code.
115.A member sentenced to imprisonment in the United Kingdom, whether the sentence is suspended or not, is deemed to have breached the Code. If the sentence does not engage the provisions of the House of Lords Reform Act 2014, the case is referred to the Conduct Committee for it to recommend a sanction. The Committee may defer its consideration of a sanction if an appeal is lodged in the courts.
116.A member sentenced to imprisonment outside the United Kingdom (whether the sentence is suspended or not) is referred to the Conduct Committee. The Conduct Committee considers whether the member should be deemed to have breached the Code and, if so, what sanction to recommend. The Committee will consider whether the offence for which the member was convicted is a criminal offence in the United Kingdom and whether the judicial system in the country concerned is such that the trial can be considered fair. The member has the right to make representations to the Committee, and the Committee may take other evidence. If the sentence is for imprisonment for a term of more than one year, the Committee will defer its consideration of the case until any motion in the House that the member should cease to be a member is disposed of.
117.These provisions apply regardless of whether the member was a member of the House at the time of the offence, but only to sentences imposed after a member’s introduction.
Advice
118.The Registrar of Lords’ Interests advises members on the application of the Code and Guide. No written guidance can provide for all circumstances: when in doubt members should seek the advice of the Registrar.
119.A member who, having provided all relevant information, follows the advice of the Registrar in respect of the rules on registering and declaring interests (paragraphs 13–16 of the Code), the exclusive benefit rule (paragraph 17(a)) and the prohibitions on paid parliamentary advice or services (paragraph 17(b)) satisfies fully the requirements of the Code.
Appendix – Behaviour Code
1 Committee for Privileges (2nd report, session 2008–09, HL Paper 88).
2 These definitions, which apply across Parliament, are taken from the Independent Complaints and Grievance Scheme’s Bullying and Harassment Policy for UK Parliament and Sexual Misconduct Policy for UK Parliament.
3 Bullying and Harassment Policy for UK Parliament; Sexual Misconduct Policy for UK Parliament.
4 Fees which are donated to another person, or to a charitable or community organisation, must be registered but the donation may be noted in the Register entry.
5 The term ‘personal service company’ is not defined in law, but for the purposes of this Code the definition adopted by the House of Lords Select Committee on Personal Service Companies applies: “It is understood generally to mean a limited company, the sole or main shareholder of which is also its director, who, instead of working directly for clients, or taking up employment with other businesses, operates through his company. The company contracts with clients, either directly or through an agency, to supply the services of its director.”
6 Further guidance on accepting gifts, benefits and hospitality is in the report from the Committee for Privileges and Conduct, Guidance to members on accepting gifts, benefits and hospitality (1st Report, Session 2015–16, HL Paper 14).
7 House Committee, Banqueting rules (1st Report, Session 2014–15, HL Paper 8) and Rules Governing the Use of Facilities (2nd Report, Session 2009–10, HL Paper 47).
8 House of Lords Reform Act 2014, section 3. In the case of a conviction outside the United Kingdom, a resolution of the House is necessary to give effect to the expulsion.
Annex 3: Enforcement procedure (general)
Introduction
1.The House of Lords Commissioners for Standards consider alleged breaches of the Code of Conduct for Members of the House of Lords (‘the Code’) and the Code of Conduct for House of Lords Members’ Staff, in accordance with the enforcement procedures which are agreed by the House. This document sets out the process for allegations of breaches of the Code that do not relate to bullying, harassment or sexual misconduct (BHSM), which fall under the separate Enforcement procedure (bullying, harassment and sexual misconduct).
Making a complaint
2.A complaint alleging that a member of the House of Lords has breached the Code must be made in writing, either by email to lordsstandards@parliament.uk or in hard copy sent by post.1
3.The complainant must provide:
(a)an email or postal address for subsequent communication;
(b)an explanation of how they think the member has breached the Code;
(c)as much evidence as the complainant has to support the complaint.
4.The specific allegation should be made to the Commissioner in private and not publicised until the complaint has been finally determined.
5.The Commissioner will not without good reason consider either anonymous complaints or ones where the complainant is not prepared to have their name and complaint disclosed to the member concerned.
6.A complaint made by a third party is the usual basis for the Commissioner to start an investigation. In exceptional circumstances however, and with the agreement of the Conduct Committee, the Commissioner may start an investigation in the absence of a complaint. This may be at the request of the member concerned or if by other means the Commissioner becomes aware of evidence sufficient to establish a prima facie case that the Code has been breached.
Time limit for complaints
7.The complaint must usually be made within four years of the time the conduct occurred.
8.In exceptional circumstances the Commissioner may investigate conduct which occurred more than four years before the complaint was made, subject to the agreement of the Conduct Committee, which will be granted only if the Committee considers that there is a strong public interest in the matter being investigated.
Preliminary assessment
9.The Commissioner will first conduct a preliminary assessment of the complaint to determine whether it falls within their remit, and whether the evidence provided establishes a prima facie case that the Code has been breached.
10.The Commissioner may seek further information from the complainant or the member concerned during the preliminary assessment.
11.The Commissioner will dismiss after a preliminary assessment all complaints:
which are not within the Commissioners’ remit (see paragraphs 12 and 13);
which fall outside the scope of the Code (for example, which do not relate to the member’s parliamentary activities);
which are unsupported by evidence sufficient to establish a prima facie case that the Code has been breached;
which are vexatious;
which substantially repeat allegations which have already been the subject of an investigation (unless there is significant fresh evidence in their support); or
where it would be disproportionate to consider further the alleged misconduct.
The Commissioner’s remit
12.Matters within the Commissioner’s remit include alleged:
failure to register relevant interests;
failure to declare relevant interests;
breaches of the exclusive benefit rule and the prohibition on providing paid parliamentary advice and services;
breaches of the rules agreed by the House on financial support for members and the facilities of the House;
breaches of the rule that members should act always on their personal honour;
breaches by members’ staff of the Code of Conduct for Members’ Staff.
13.Matters not within the Commissioner’s remit include:
alleged breaches of the Code’s general principles which do not engage a specific rule of conduct;
policy matters or a member’s views or opinions;
the funding of political parties;
alleged breaches of the Ministerial Code; and
members’ non-parliamentary or private activities.
Outcome of preliminary assessment
14.Following their preliminary assessment, if the Commissioner determines the complaint is within scope and there is sufficient evidence to establish a prima facie case that the Code has been breached, the complaint may proceed either to investigation or to the minor cases procedure. If a complaint falls within paragraph 11 the Commissioner will dismiss it. The Commissioner’s decision at this stage is final and cannot be appealed.
15.The Commissioner writes to both the complainant and the member concerned to inform them of the outcome of the preliminary assessment. In doing so, the Commissioner will normally disclose the complainant’s name and the content of the complaint to the member.
16.If the Commissioner dismisses the complaint, they provide the complainant with a brief explanation of their reasons. Where the only evidence cited in support of a complaint is the member’s expression of views or opinions, the complaint will be dismissed on this basis.
17.If the Commissioner decides that the complaint will proceed, it may be considered under the minor cases procedure if the Commissioner, taking all the circumstances of the case into account, determines that the alleged breach is minor. In doing so, the Commissioner will consider the apparent complexity of the case and the potential outcome were the complaint to be upheld. Otherwise, the complaint will proceed to investigation.
Minor cases procedure
Process
18.The Commissioner first informs the member concerned of the nature of the complaint, the identity of the complainant, and provides copies of the evidence in support of it. They set out the provisions of the Code that appear to be engaged and invite the member to respond in writing.
19.The Commissioner may seek further information to assist them in determining whether the Code has been breached.
20.The Commissioner may at any time decide that the case is no longer suitable for the minor cases procedure and should proceed to investigation.
21.No information will be made public while a case is being considered under the minor cases procedure.
Outcome
22.If the Commissioner determines that there has not been a breach of the Code, the complaint is not upheld.
23.If the Commissioner determines that there has been a breach of the Code and the member agrees, the Commissioner then decides what action is needed to rectify the breach. This may include a written apology to the Chair of the Conduct Committee.
24.If the member does not agree with the Commissioner’s determination that there has been a breach of the Code, or does not undertake the action prescribed by the Commissioner, the complaint shall proceed to an investigation.2
25.Basic information on the outcome of all cases concluded under the minor cases procedure is published on the Commissioner’s parliamentary webpage.3
26.The complainant is informed of the outcome of the case when the information is published on the website.
Investigations
Process
27.Having decided to undertake an investigation, the Commissioner first informs the member concerned of the nature of the complaint and the identity of the complainant. The Commissioner also provides copies of the relevant evidence offered in support of the complaint. They specify the provisions of the Code that appear to be engaged and invite the member to provide a full and accurate written response.
28.The Commissioner may pursue the investigation by seeking further evidence and information as necessary, including by interviewing the member concerned.
29.Members must supply written evidence as requested in a timely manner, and in their own name. Members are entitled to seek advice (see paragraph 57), but letters sent on their behalf by legal advisers or others will be disregarded. They may be accompanied to any meeting by a colleague, friend or legal adviser (provided the individual accompanying them is not a witness to the investigation), but there is no expectation that they should be so accompanied. If a member chooses to bring a colleague, friend or adviser they are free to consult them in confidence but will be expected to answer for themselves (and not through the friend or adviser) any question put to them.
30.Members are not permitted to cross-examine complainants or witnesses. It is for the Commissioner to decide how to question them.
31.Complainants have no formal locus when a complaint is being investigated: they have no right to be called as a witness, though they are expected to co-operate with any investigation. They will be informed of the outcome of their complaint once the process has completed.
32.Before finalising their report and (if applicable) recommending a sanction, the Commissioner will share their draft report and provisional findings with the member so that they have an opportunity to comment on the accuracy of the evidence and on the provisional findings. If appropriate, at that point the member is invited to present any material they wish the Commissioner to consider when recommending a sanction.
Public information on investigations
33.For all investigations, the Commissioner publishes a statement on their webpage setting out basic information about the case.4
34.Unless the Commissioner considers it inappropriate to do so, the name of the complainant will be made public in the Commissioner’s report.
35.The identity of those who give evidence to the Commissioner during an investigation will be shared where necessary with those directly involved in the investigation but will not be made public during the investigation. The Commissioner has discretion to anonymise witnesses on publication of their report. This may involve some redaction in reports.
Outcomes of an investigation
No breach of the Code
36.If the Commissioner finds that there is no breach of the Code, a report is published on the Commissioners’ webpage.5 The member will receive the final report shortly before publication, and the complainant will receive the report on publication.
Breach of the Code
37.Following an investigation where the Commissioner has found a breach of the Code, they may recommend remedial action or a sanction.
Remedial action
38.Remedial action may be agreed if the member acknowledges they are in breach of the Code and the Commissioner determines that the breach is of a nature that no sanction is warranted.
39.Remedial action will involve any steps the Commissioner considers necessary for the member to correct the position—for example, correcting their entry in the Register of Lords’ Interests. This may include a written apology to the Chair of the Conduct Committee.
40.Cases resolved by remedial action will result in a report on the Commissioners’ webpage.6 The complainant will be informed of the outcome of the case on publication of the report on the webpage.
41.If the member does not agree to the recommended remedial action, the Commissioner will submit their report, including their recommended sanction, to the Conduct Committee.
Sanction
42.Where the Commissioner upholds a complaint and considers that a sanction is warranted, they submit their report and recommended sanction to the Conduct Committee. The options that the Commissioner may propose to the Conduct Committee are (any combination of):
requiring the member to take action to regularise the position where this has not been agreed as remedial action.
requiring the member to make a personal statement of apology in the House.
recommending to the House that the member be denied access to specific facilities or services of the House, including services that support parliamentary activity, for a specified period.
recommending to the House that the member be denied access to the system of financial support for members for a specified period.
recommending to the House that the member be removed from membership of select committees.
recommending to the House that the member be suspended from the House.7
recommending to the House that the member be expelled from the House.8
43.The appropriate sanction in each case will be assessed by reference to all the circumstances surrounding the breach, including any aggravating and mitigating factors.
44.If there is no appeal, the Committee considers the sanction recommended by the Commissioner. If the Committee upholds the Commissioner’s recommended sanction it reports accordingly.
45.Alternatively, if the Committee decides that the recommended sanction needs further consideration, it may then invite representations on the question of sanction from the member concerned and the Commissioner. Having heard those representations, the Committee decides whether to uphold or vary the recommended sanction.
Appeals
46.The Chair of the Conduct Committee sets the deadline and timetable for any appeal. When the Commissioner sends their final report to the member concerned, they are informed of the deadline by which they may submit an appeal to the Committee. The appeal may be against the Commissioner’s finding or the recommended sanction (or both).
47.An appeal must be in writing. It should set out the grounds for the appeal with any supporting material. The Committee may decide to hear from the member in person, and to invite representations from the Commissioner. The Chair of the Committee may make further provisions about the procedures to be followed in each appeal.9
48.On appeal, the Committee will not reopen the Commissioner’s investigation. The grounds for appeal are limited to the following:
the Commissioner was plainly wrong in their finding;10
points of process;
the emergence of significant new evidence; or
the severity of the sanction.
49.On appeal a recommended sanction may be endorsed, reduced or increased.
Report to the House
50.In all cases when the Commissioner has submitted a report to the Conduct Committee, or the Committee has considered an appeal, the Committee will report to the House.
51.The Conduct Committee will normally append the Commissioner’s report to its report. Before publishing any report, the Conduct Committee will consider whether any decisions relating to the anonymity of those referred to in the Commissioner’s report need changing. This may involve redacting or amending the Commissioner’s report.
52.In exceptional circumstances, the Conduct Committee may decide not to publish the Commissioner’s report.
53.When the Committee reports a case to the House, the Committee clerk sends the member the report shortly before publication and the complainant the report on publication.
54.When the Conduct Committee reports to the House on an individual case, Standing Order 68 requires that the report and any resolution relating to sanction be decided without debate.
Confidentiality
55.All parties must respect the confidentiality of investigations. The requirement to protect confidentiality, and the identity of any anonymised parties, continues following the conclusion of an investigation.
56.A failure to respect the confidentiality of investigations is a breach of the Code (paragraph 29 of the Code).
Support for members
57.Members may seek support from close colleagues or advisers, including legal advisers, and may confidentially share information relating to the investigation with those colleagues or advisers as necessary, provided those parties are not witnesses to the investigation; they should inform the Commissioner before doing so.
58.Members can contact the Parliamentary Health and Wellbeing Service for advice, guidance and support with mental and physical health.11
Principles of the enforcement process
59.The Code of Conduct states that “In assessing, investigating and adjudicating allegations of breach of the Code, the Commissioner and the Conduct Committee must act in accordance with the principles of natural justice and fairness”.
60.The civil standard of proof is adopted at all stages in the enforcement process. Thus, in order to find against a member, the Commissioner will require at least that the allegation is proved on the balance of probabilities.
61.Proceedings are inquisitorial, not adversarial. The Commissioner is an independent and impartial investigator appointed by the House to establish the facts of a case and decide whether the Code has been breached.
62.Members must co-operate, at all stages, with any investigation into their conduct, or that of any member of staff they sponsor, by or under the authority of the House (paragraph 28 of the Code).
63.Members are given an opportunity to review and challenge the factual basis of any evidence which the Commissioner relies on in their findings.
Parliamentary privilege
64.The Commissioner is an officer of the House of Lords and parliamentary privilege covers them in carrying out their duties and to their reports and publications. It also covers witnesses and parties to their cases (including both an investigation and the minor cases procedure), but a complaint is not regarded as covered by parliamentary privilege unless and until the Commissioner has decided to undertake an investigation or to consider the complaint under the minor cases procedure. Where the Commissioner investigates only a part of a complaint, only the matters accepted for investigation are covered by parliamentary privilege.
65.From the point that the Commissioner decides to undertake an investigation or considers a complaint under the minor cases procedure, all evidence and correspondence relating directly to the matter is covered by parliamentary privilege. It must remain confidential unless and until it is published. It would be a contempt of the House to publish or disclose it to anyone else without the agreement of the Conduct Committee or the Commissioner. An attempt to obstruct an investigation would also be a contempt of the House.
66.The Conduct Committee has the power to send for persons, papers and records and may exercise this power as necessary in support of the Commissioner.
Other matters
Former members and leave of absence
67.The Commissioner may not investigate a complaint about a former member of the House.
68.If a member is under investigation when they leave the House, the investigation terminates at that point except in cases where the Conduct Committee is satisfied that there is a strong public interest in the investigation being completed.12
69.If a member applies for leave of absence to avoid an impending investigation or sanction (or while an investigation is under way), the request may be refused. If the Commissioner decides to investigate a complaint about a member who is on leave of absence (in respect of conduct that occurred when the member was not on leave), the leave may if necessary be ended with immediate effect.
70.If the Conduct Committee imposes a sanction on or recommends a sanction in relation to a member who is on leave of absence, the leave may be ended with immediate effect.
Investigations by other bodies
71.If the Commissioner becomes aware that the police or another agency are investigating an allegation against a member of criminal misconduct that is related to an ongoing investigation into an alleged breach of the Code, they may continue their investigation but will not finalise their report until the criminal process concludes.
72.Before finalising their report the Commissioner will take account of any relevant issues which arose during the criminal process.
73.An investigation will be suspended if related proceedings (criminal or civil) become sub judice (within the meaning of the House’s sub judice resolution).
1 To: The House of Lords Commissioner for Standards, House of Lords, London, SW1A 0PW.
2 In proceeding to investigation, the Commissioner may need only to produce a draft report of their findings and give the member the opportunity to comment on those findings (see paragraph 32).
3 The Commissioner has discretion not to publish information on cases of a breach of the Code of Conduct for Members’ Staff if it would be disproportionate in the circumstances.
4 The Commissioner has discretion not to publish information on an allegation of breach of the Code of Conduct for Members’ Staff if it would be disproportionate in the circumstances.
5 The Commissioner has discretion not to publish a report on an allegation of breach of the Code of Conduct for Members’ Staff if it would be disproportionate in the circumstances. In such instances the Commissioner will inform the sponsoring member of the outcome.
6 The Commissioner has discretion not to publish a report on case of breach of the Code of Conduct for Members’ Staff resolved by remedial action if it would be disproportionate in the circumstances. In such instances the Commissioner will inform the sponsoring member of the outcome.
7 If the conduct concerned occurred on or after 26 June 2015, or if it occurred before 26 June 2015 but was not public knowledge before then, the suspension may be for any specified period of time. If the conduct occurred before 26 June 2015 and was public knowledge before then, the suspension may be for a specified period of time not longer than the remainder of the current Parliament.
8 This recommended sanction is available if the conduct concerned occurred on or after 26 June 2015, or if it occurred before 26 June 2015 but was not public knowledge before then.
9 All parties, including members of the House, may be accompanied by a colleague, friend or legal adviser, but must answer for themselves any question put to them (see paragraph 29)..
10 In determining whether the Commissioner was “plainly wrong”, the Committee must find that the decision under appeal is one that could not reasonably have been reached. In doing so, they must give considerable weight to the findings of the Commissioner who had the advantage of seeing all the evidence and being present throughout the proceedings, and they must be convinced by the plainest of considerations.
11 The Parliamentary Health and Wellbeing Service can be contacted by email at phws@parliament.uk or by telephone on 0207 219 4014. Out of hours, the Individual Assistance Programme helpline can be contacted to provide independent and confidential support on 0800 028 0199.
12 Paragraph 5 of the Code of Conduct states that the enforcement provisions of the Code “apply to all members and former members of the House”.
Appendix B
Proposed letter to the Conduct Committee
I am writing to you as a concerned constituent to express my serious reservations regarding the proposed changes to the House of Lords Code of Conduct, as outlined in the Conduct Committee's recent report and the accompanying draft documents. I believe that these changes, particularly in relation to the registration of interests and enforcement procedures, will significantly weaken standards, reduce transparency, and create an environment in which identity fraud and financial irregularities can be more easily concealed.
As you may be aware, I have been actively engaged in raising concerns about potential breaches of the Code of Conduct by members of the House of Lords, specifically concerning the accurate declaration of interests and potential use of multiple identities registered in Companies House. In particular, I have lodged a formal complaint (Ref: 2425-46) regarding Baroness Sally Morgan of Huyton. ADD THE OTHERS.
I understand that the Committee is currently considering changes to the Code of Conduct, including revisions to the registration of interests and enforcement procedures. While I appreciate the effort to streamline the Code and reduce the burden on members, I am deeply concerned that these changes, if implemented as proposed, will exacerbate existing problems of transparency and accountability.
Specifically, I am concerned about the following aspects of the proposed changes:
1. Removal of the Requirement to Register Non-Financial Interests:
While I understand the arguments about the burden of maintaining non-financial interests, I believe that removing this requirement altogether will significantly reduce transparency and make it easier for members to conceal potential conflicts of interest.
The proposed Code of Conduct omits to define “Non-financial” interests. The current code of conduct provides the following guidance on these interests;
“Category 10: Non-financial interests
99. Certain non-financial interests may reasonably be thought to affect the way members of the House of Lords discharge their public duties and must therefore be registered in this category. The following non-financial interests are always relevant and therefore must be registered:
(a) unremunerated directorships or other regular employment;
(b) membership of public bodies such as hospital trusts, the governing bodies of universities, colleges or schools, local authorities and other spheres of government;
(c) trusteeships of museums, galleries or similar bodies;
(d) acting as an office-holder or trustee in pressure groups or trade unions; and
(e) acting as an office-holder or trustee in voluntary or not-for-profit organisations.”
The proposed amendments will mean that there is no requirement to publish:
“(a) unremunerated directorships or other regular employment;
(b) membership of public bodies such as hospital trusts, the governing bodies of universities, colleges or schools, local authorities and other spheres of government;
(c) trusteeships of museums, galleries or similar bodies;
(d) acting as an office-holder or trustee in pressure groups or trade unions; and
(e) acting as an office-holder or trustee in voluntary or not-for-profit organisations.”
In the current Code of Conduct it is stated “The following non-financial interests are always relevant and therefore must be registered.” What has changed that the Conduct Committee feel it prudent to alter this firm statement that ensures transparency, which is demanded by the Companies Act 2006?
2. Introduction of a "Minor Cases Procedure":
Reasoning given for the proposed “Minor Cases Procedure”:
“The committee noted there had been several cases where the commissioners had investigated breaches of the code that were found to be minor and inadvertent (paragraph 68). Under the current rules, these minor cases still require a full investigation and the publication of a report. The committee recommended establishing two types of enforcement procedure: one for general breaches and another for breaches involving bullying, harassment and sexual misconduct. General breaches would be subject to a new ‘minor cases procedure’. As part of this procedure, the details of the case would not be made public once they were resolved.”
This appears to directly reference the complaints that I have been making. The investigations failed to consider the registration of multiple identities by the peers as evidence of wrong-doing and focussed only on my complaints of failure to declare interests, which, in most cases were found to be correct. This implies that the Conduct Committee believe that failure to declare interests is a minor breach when it is actually the definition of section 3 of the Fraud Act 2006. I am concerned that this procedure could be used to sweep more serious violations under the rug. Failing to declare interests should never be considered to be a minor offence. The decision to categorize a case as "minor" is subjective, and there is a risk that cases involving significant breaches of transparency or potential conflicts of interest could be inappropriately classified as minor, thereby avoiding a full investigation and public report.
3. Reduction of the Standard Time Limit for Complaints:
Reducing the time limit from six to four years will make it more difficult to investigate past misconduct and may shield members from accountability for breaches that occurred in the more distant past. Failing to ensure that past omissions from the register are corrected, beyond four or six years, is illogical since the Companies Act 2006 makes it clear that the duty to avoid conflicts of interest is not time limited.
4. Exclusion of "Non-Parliamentary" Activities:
The fact that the Commissioner cannot investigate member's non-parliamentary activities means it is impossible to determine whether members are in breach of Section 1082 of the Companies Act 2006.
5. Exclusion of the requirement to declare directorships and roles as persons with significant control of the peer’s partner.
This is in breach of the Companies Act 2006 (refer to section relating to duty to declare interests). This is a significant change which is excluded from the summary of changes.
My concern is that these changes, combined with the already restrictive application of paragraph 159 of the Guide to the Code of Conduct, create a perfect storm for concealing wrongdoing. Paragraph 159 prevents public discussion of ongoing investigations, while the proposed changes to the Code make it easier to avoid investigation in the first place.
The claim that, "Keeping registered non-financial interests up to date is disproportionately burdensome, and minor and inadvertent errors are the cause of large numbers of complaints", is not an adequate excuse for a failure in transparency. Rather than removing the rule, the Lords should adopt and comply with the legislation imposed on all company directors, which require interests to be registered accurately.
In my view, these changes are particularly concerning in light of my ongoing complaint regarding Baroness Morgan. The information I have uncovered suggests a pattern of non-compliance with disclosure requirements, potential use of multiple identities, and possible breaches of the Companies Act 2006. If the proposed changes to the Code had been in effect at the time I lodged my complaint, it is possible that my concerns would not have been investigated at all.
I fear these changes are being brought about to assist in concealing widespread identity fraud. The public would be best served by transparency in the House of Lords. Instead, the Committee seeks to hide these indiscretions and keep the public in the dark.
I believe that transparency and accountability are essential for maintaining public trust in the House of Lords and its members. The proposed changes to the Code of Conduct, while perhaps well-intentioned, risk undermining these principles and creating an environment in which misconduct can be concealed.
I therefore respectfully request that the Conduct Committee:
Reconsider the proposed changes to the Code of Conduct, paying particular attention to the potential impact on transparency and accountability.
Ensure that any revisions to the Code include robust safeguards against the concealment of conflicts of interest, financial irregularities, and identity fraud.
Clarify the permissible scope of public discussion regarding ongoing investigations, particularly in relation to procedural matters and general concerns about fairness or impartiality.
Consider the potential for referring matters to the appropriate authorities for potential criminal investigation, if evidence of fraud or other illegal activity is uncovered.
As outlined in the Committee’s final report, the goal of the review was to shorten and clarify the Code and Guide where possible, while upholding the Code’s twin objectives: to “provide guidance for members of the House of Lords on the standards of conduct expected of them”, and to “reinforce public confidence in the way in which members of the House of Lords perform their parliamentary duties” the weakening of the requirements to disclose all directorships of peers and their partners fails to achieve the stated goal.
Thank you for your attention to this important matter.
Yours sincerely,
Alison Wright
12a Knole Road, Rottingdean, Brighton, BN2 7GR.
Enclosures:
Copy of Commissioner for Standards' Letter of January 14, 2025 (Ref: 2425-46)
Copy of Previous Letter to the Conduct Committee
Another version generated separately
Concerns Regarding the Revised Code of Conduct and Potential Weakening of Transparency**
Dear Members of the Conduct Committee,
I am writing to express my serious concerns regarding the proposed Revised Code of Conduct for Members of the House of Lords, specifically concerning the changes to the Register of Interests and the handling of complaints. I believe that these revisions, as currently drafted, will significantly weaken transparency and accountability within the House.
My primary concerns are as follows:
1. Removal of Mandatory Registration of "Non-Financial Interests
The decision to remove the requirement for members to register "non-financial interests" is deeply troubling. The Code of Conduct fails to define "non-financial interests", leaving it open to interpretation and potentially allowing members to avoid declaring relevant relationships, affiliations, and activities that could influence their parliamentary work. The explanatory notes that accompany the proposed revised code does not address this omission, which could lead to significantly less transparency than exists under the current system.
2. Omission of Spouses' Directorships:
I am particularly concerned by the removal of the requirement for members to declare their spouses' directorships. This represents a significant gap in transparency, as spouses' directorships can create real or perceived conflicts of interest that may influence a member's views and actions. That the Conduct Committee did not highlight this change in their summary is concerning.
3. Removal of requirement to declare roles as Person with Significant Control:
The removal of the need to declare roles as a Person with Significant Control of companies in the House of Lords Register of Interests on the basis that this is covered by Companies House is also troubling. Whilst Companies House does hold the information, accessing this data is not easy nor intuitive and PSC's in Companies House can not be searched for by name, unlike the House of Lords Register of Interests.
4. Handling and Publication of Complaints:
My understanding is that complaints will be handled differently, with the results not published. Not publishing the details of less serious complaints (after they have been resolved) will diminish the degree of scrutiny and transparency that is essential for maintaining public confidence.
I urge the Conduct Committee to reconsider these changes and to prioritise transparency and accountability in the Revised Code of Conduct.
Specifically, I would request that the Committee:
Reinstate the requirement to register "non-financial interests" and provide a clear and comprehensive definition of what constitutes a registrable non-financial interest.
Retain the requirement for members to declare their spouses' directorships and PSC roles.
Reconsider the decision not to publish full reports of resolved complaints.
Ensure that all members are reminded of their duty to declare non-financial interests, their spouses directorships and their own PSC roles.
I believe that these revisions are essential to ensuring that the House of Lords maintains the highest standards of conduct and that the public can have confidence in the integrity of its members.
I am happy to discuss my concerns further with the Committee at your convenience.
Thank you for your time and consideration.
Sincerely, $$Your Name]
Perplexity, I'll give you an example of why I am so concerned. If you refer to my Substack, https://alisonwright.substack.com/ , you will find that the use of multiple identities in Companies House is prevalent. This breaches Section 1082 and causes false non-match errors in audit and KYC software which presents the risk of money laundering. Many of the key people in Government that I've checked do this, and fail to declare all their directorships (particularly those that are defined as "non-financial", when they clearly are relevant for disclosure) including the chair of HMRC.
Fraud is a huge problem in the UK and the politicians are not focussing on this, I suspect because some of them are involved with it. I attach a report that involved companies called ARC and ARK.
Considering Baroness Manningham-Buller, chair of the Conduct Committee is associated to Ark Continuity Ltd and ARK DATA CENTRES LIMITED, it is possible that she may be involved in a version of clone company fraud with directors of the Alliance For Responsible Citizenship Limited who are associated to ARK companies. If this is the case and since she is chairing the Conduct Committee she may have a vested interest in making these reductions to the transparency required by the Code of Conduct. I also attach my yet-to-be finalised Compliance Assessment of the Conduct Committee, where I have found breaches that will fall into the category that would not be reported on according to the revised code. Refer to
Analysis of Conduct Committee Members:
1. Lord Garnier:
Identity Integrity: Appears compliant with a single identifier.
Related Parties: Identified potential multiple identities among individuals with the same last name. This raises concerns and requires clarification.
Trading Disclosures Compliance: Omitting the word “England” from the registered company address in the conference invitation.
Declaration Compliance: Minor discrepancies between Companies House and the Register of Interests regarding dates for China Oxford Scholarship Fund and Prison Reform Trust need to be verified.
GREAT BRITAIN-CHINA CENTRE: There are significant concerns raised regarding his prior association with GREAT BRITAIN-CHINA CENTRE, particularly given Victoria Prentis’ role and subsequent non-disclosure.
General: The current Register of Interests for Lord Garnier appears to be in compliance with the requirements for the time period since his appointment, with minor variations on appointment and resignation dates.
2. Baroness Kidron:
Multiple Identities: Appears to have multiple identities, violating Section 1082 of the Companies Act 2006.
Trading Disclosures Compliance: Soho Angel Films Limited dissolved on 23 May 2023. The last accounts are made up to 31 December 2020, which means that accounts made up to 31 December 2021 and accounts made up to 31 December 2022 and to dissolution are overdue. This is non-compliant with breach of section 441 of the Companies Act 2006.
Declaration Compliance: Discrepancies in dates, lack of transparency, and potential conflicts of interest related to organizations like FILM NATION UK, INSTITUTE OF CONTEMPORARY ARTS LIMITED, THE IMAGINE WORKSHOP LIMITED, and PAUL HAMLYN FOUNDATION.
Account Submission Concerns: Failure to submit accounts for dissolved entities.
General: Serious irregularities and omissions in reporting need further investigation, with a potential police referral.
3. Baroness Mallalieu:
Identity Integrity: Appears compliant with a single identifier.
Declaration Compliance: She failed to declare her directorships of the non-financial interests, she did declare these interests as a trustee however.
Analysis and Comments on Key Concerns and Disclosures:
Reliance on Publicly Available Information:
The assessment is reliant on data from Companies House, and the Registers of Interests, limiting the scope of analysis. As noted, there is more information that needs to be included.
Companies Act Breaches (Section 1082 - Unique Identifiers):
The widespread existence of multiple identities registered to single individuals (e.g., those with surname Garnier) raises concerns about data integrity and transparency in Companies House.
The multiple identities make audit impossible and KYC checks cannot be fully relied upon, because false non-match errors will occur.
Trading Disclosures - Compliance Assessment of ARC Conference Invitation:
Given that you reported there was subtle breaches of Trading Disclosure legislation, you need to identify these and the nature of the breach.
Lord Garnier:
You also need to ensure that there is evidence and conclusions regarding whether “there are multiple identities” which “compromises audits and Know Your Customer (KYC) checks.
ARK and ARC Associated Concern Regarding Baroness Manningham-Buller:
The information is insufficient to support a conclusion that there is a conflict of interest, however it has been raised.
Overall Assessment and Concerns:
Data Integrity in Companies House:
Section 1082 breaches for multiple Conduct Committee members (Lord Garnier and Baroness Kidron).
These anomalies could expose the UK Government's National Cyber Security Centre’s “Zero trust architecture design principles”, because people should be “uniquely identifiable”.
Disclosure Compliance:
Baroness Manningham-Buller and Lord Scriven: there are instances of non-compliance with declaration requirements in the House of Lords Register of Interests, plus provision of misinformation by Lord Scriven.
Incomplete Account Submissions:
There were a high number of companies with overdue accounts upon dissolution, and no details for what appear to be several Companies.
This confirms the need for further investigation and police referrals.
Appendix B Baroness Manningham-Buller’s Speaking Engagements
Baroness Manningham-Buller has 329 speaking engagements between 1 June 2010 and 26 November 2024. This is an estimated 2 speaking engagements per month.
Category 2: Remunerated employment, office, profession etc.
Interest deleted 1 July 2019 Vice Chairman, Pollen Estate (London commercial property) (interest ceased 30 June 2018) (originally added 15 April 2010)
Interest deleted 13 April 2022 Governor (Trustee) and Chair, Wellcome Trust (interest ceased 11 April 2021) (originally added 15 April 2010)
Interest deleted 27 May 2011 Speaking engagement, 19 May 2010, Oracle Corporation (originally added 14 June 2010)
Interest deleted 2 June 2011 Speaking engagement, 11 June 2010, Morgan Stanley, in Spain; Morgan Stanley met travel and accommodation costs also (originally added 14 June 2010)
Interest deleted 26 July 2011 Speaking engagement, 15 July 2010, IBM (originally added 8 July 2010)
Interest deleted 25 September 2011 Speaking engagement, 16 September 2010, London Business Forum (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 22 September 2010, Airmic (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 23 September 2010, Macdonalds (originally added 27 September 2010)
Interest deleted 25 September 2011 Speaking engagement, 23 September 2010, IBM (originally added 27 September 2010)
Interest deleted 12 October 2011 Speaking engagement, 7 October 2010, Land Securities (originally added 27 September 2010)
Interest deleted 20 October 2011 Speaking engagement, 13 October 2010, Barclays (originally added 27 September 2010)
Interest deleted 24 November 2011 Speaking engagement, 11 November 2010, The Lawyer (originally added 2 November 2010)
Interest deleted 24 November 2011 Speaking engagement, 16 November 2010, KPMG (originally added 17 November 2010)
Interest deleted 28 January 2012 Speaking engagement, 25 November 2010, Investment Property Databank (IPD) (originally added 17 November 2010)
Interest deleted 2 April 2012 Speaking engagement, 10 February 2011, Artemis (originally added 13 February 2011)
Interest deleted 2 April 2012 Speaking engagement, 15 February 2011, Artemis (originally added 13 February 2011)
Interest deleted 2 April 2012 Speaking engagement, 17 February 2011, Artemis (originally added 13 February 2011)
Interest deleted 2 April 2012 Speaking engagement, 24 February 2011, Artemis (originally added 13 February 2011)
Interest deleted 2 April 2012 Speaking engagement, 2 March 2011, Artemis (originally added 17 March 2011)
Interest deleted 2 April 2012 Speaking engagement, 7 March 2011, RBS (originally added 17 March 2011)
Interest deleted 2 April 2012 Speaking engagement, 8 March 2011, Merck (originally added 17 March 2011)
Interest deleted 2 April 2012 Speaking engagement, 9 March 2011, KPMG (originally added 17 March 2011)
Interest deleted 2 April 2012 Speaking engagement, 25 March 2011, UCISA (Universities and Colleges Information Systems Association) (originally added 17 March 2011)
Interest deleted 2 April 2012 Speaking engagement, 30 March 2011, ACCA (Association of Chartered Certified Accountants) (originally added 17 March 2011)
Interest deleted 4 July 2012 Speaking engagement, 14 April 2011, WBR (Worldwide Business Research) (originally added 7 April 2011)
Interest deleted 4 July 2012 Speaking engagement, 14 April 2011, Standard Chartered Bank (originally added 7 April 2011)
Interest deleted 4 July 2012 Speaking engagement, 13 May 2011, Morgan Stanley, in Florence, Italy; fee, flights and accommodation paid by Morgan Stanley (originally added 16 May 2011)
Interest deleted 4 July 2012 Speaking engagement, 19 May 2011, IBM (originally added 16 May 2011)
Interest deleted 4 July 2012 Speaking engagement, 8 June 2011, Symantec (originally added 1 June 2011)
Interest deleted 1 October 2012 Speaking engagement, 3 August 2011, Deutsche Bank (originally added 12 September 2011)
Interest deleted 1 October 2012 Speaking engagement, 29 September 2011, Ernst & Young (originally added 25 September 2011)
Interest deleted 1 October 2012 Speaking engagement, 30 September 2011, Specialist Schools and Academies Trust (originally added 25 September 2011)
Interest deleted 5 October 2012 Speaking engagement, 4 October 2011, Royal Bank of Canada (originally added 12 October 2011)
Interest deleted 5 October 2012 Speaking engagement, 4 October 2011, LGC Science Group Limited (originally added 12 October 2011)
Interest deleted 5 October 2012 Speaking engagement, 6 October 2011, Scottish Leadership Awards (originally added 12 October 2011)
Interest deleted 18 October 2012 Speaking engagement, 12 October 2011, Lloyds Development Capital (LDC) (originally added 12 October 2011)
Interest deleted 16 November 2012 Speaking engagement, 9 November 2011, Worldwide Business Research (originally added 24 November 2011)
Interest deleted 16 November 2012 Speaking engagement, 14 November 2011, JP Morgan (originally added 24 November 2011)
Interest deleted 23 January 2013 Speaking engagement, 22 November 2011, Accenture (originally added 24 November 2011)
Interest deleted 23 January 2013 Speaking engagement, 23 November 2011, Barclays Bank (originally added 24 November 2011)
Interest deleted 28 February 2013 Speaking engagement, 24 January 2012, World Business Research (originally added 27 January 2012)
Interest deleted 28 February 2013 Speaking engagement, 26 January 2012, Martin Currie Investment (originally added 27 January 2012)
Interest deleted 26 June 2013 Speaking engagement, 27 June 2012, Grant Thornton LLP (originally added 28 June 2012)
Interest deleted 2 January 2014 Senior adviser to Inter Mediate Ltd (retainer; registered charity, working on conflict resolution) (until 31 December 2013) (originally added 28 June 2012)
Interest deleted 1 September 2016 Non-executive Director, Ark Continuity Ltd (data storage and management) (interest ceased 31 July 2015) (originally added 4 July 2012)
Interest deleted 7 October 2013 Speaking engagement, 27 September 2012, St James's Place Wealth Management (originally added 1 October 2012)
Interest deleted 7 October 2013 Speaking engagement, 3 October 2012, Chartered Institute of Purchasing and Supply (originally added 5 October 2012)
Interest deleted 16 November 2012 Speaking engagement, 10 October 2012, Smith and Williamson (investment management providers) (originally added 10 October 2012)
Interest deleted 10 November 2013 Speaking engagement, 18 October 2012, KPMG (originally added 18 October 2012)
Interest deleted 10 November 2013 Speaking engagement, 8 November 2012, Kingsley Napley (originally added 7 November 2012)
Interest deleted 29 November 2013 Speaking engagement, 14 November 2012, Audi (originally added 16 November 2012)
Interest deleted 24 January 2014 Speaking engagement, 22 January 2013, World Trade Group (originally added 23 January 2013)
Interest deleted 28 February 2014 Speaking engagement, 27 February 2013, William Reed Media (originally added 28 February 2013)
Interest deleted 7 March 2014 Speaking engagement, 7 March 2013, Aon plc (originally added 7 March 2013)
Interest deleted 2 April 2014 Speaking engagement, 21 March 2013, DLA Piper (originally added 21 March 2013)
Interest deleted 20 May 2014 Speaking engagement, 16 May 2013, Permira Private Equity (originally added 17 May 2013)
Interest deleted 22 May 2014 Speaking engagement, 22 May 2013, Marsh Insurance (originally added 23 May 2013)
Interest deleted 20 June 2014 Speaking engagement, 29 May 2013, Credit Suisse (originally added 30 May 2013)
Interest deleted 20 June 2014 Speaking engagement, 3 June 2013, CBRE (originally added 10 June 2013)
Interest deleted 20 June 2014 Speaking engagement, 7 June 2013, NHS (originally added 10 June 2013)
Interest deleted 20 June 2014 Speaking engagement, 18 June 2013, Misys, in Budapest; cost of flights and hotel in Budapest met by Misys (originally added 19 June 2013)
Interest deleted 20 June 2014 Speaking engagement, 20 June 2013, BG Group (originally added 26 June 2013)
Interest deleted 2 July 2014 Speaking engagement, 27 June 2013, Project Consulting (originally added 2 July 2013)
Interest deleted 23 September 2014 Speaking engagement, 17 September 2013, Trend Micro (originally added 23 September 2013)
Interest deleted 23 September 2014 Speaking engagement, 17 September 2013, Shell (originally added 23 September 2013)
Interest deleted 4 October 2014 Speaking engagement, 25 September 2013, GSK (originally added 26 September 2013)
Interest deleted 4 October 2014 Speaking engagement, 25 September 2013, Centaur Communications for Employees Benefit Live Conference (originally added 26 September 2013)
Interest deleted 4 October 2014 Speaking engagement, 2 October 2013, Institute of Financial Planning (originally added 7 October 2013)
Interest deleted 24 October 2014 Speaking engagement, 4 October 2013, Muzinich & Co (fee plus fare to Paris /accommodation) (originally added 7 October 2013)
Interest deleted 8 January 2015 Speaking engagement, 27 November 2013, Ernst & Young (originally added 29 November 2013)
Interest deleted 21 January 2015 Speaking engagement, 9 January 2014, Proact UK (IT company) (originally added 20 January 2014)
Interest deleted 30 January 2015 Speaking engagement, 23 January 2014, GE Healthcare (originally added 24 January 2014)
Interest deleted 30 January 2015 Speaking engagement, 30 January 2014, Ernst & Young (originally added 4 February 2014)
Interest deleted 30 January 2015 Speaking engagement, 30 January 2014, Ernst & Young (originally added 4 February 2014)
Interest deleted 30 January 2015 Speaking engagement, 30 January 2014, Henderson Group (originally added 4 February 2014)
Interest deleted 26 February 2015 Speaking engagement, 13 February 2014, Muzinich & Co (originally added 14 February 2014)
Interest deleted 4 March 2015 Speaking engagement, 27 February 2014, Institute and Faculty of Actuaries (originally added 28 February 2014)
Interest deleted 4 March 2015 Speaking engagement, 5 March 2014, Russell Investments (originally added 7 March 2014)
Interest deleted 10 March 2015 Speaking engagement, 10 March 2014, HSBC (originally added 11 March 2014)
Interest deleted 12 March 2015 Speaking engagement, 11 March 2014, Tadeka UK Ltd (originally added 12 March 2014)
Interest deleted 23 March 2015 Speaking engagement, 20 March 2014, Insight Investment (originally added 2 April 2014)
Interest deleted 31 March 2015 Speaking engagement, 25 March 2014, Ernst & Young (originally added 2 April 2014)
Interest deleted 31 March 2015 Speaking engagement, 31 March 2014, Ernst & Young (originally added 2 April 2014)
Interest deleted 19 May 2015 Speaking engagement, 28 April 2014, Mercedes (originally added 29 April 2014)
Interest deleted 19 May 2015 Speaking engagement, 13 May 2014, Goldman Sachs (originally added 20 May 2014)
Interest deleted 21 May 2015 Speaking engagement, 21 May 2014, Goldman Sachs (originally added 22 May 2014)
Interest deleted 6 July 2015 Speaking engagement, 19 June 2014, Ernst & Young (originally added 20 June 2014)
Interest deleted 6 July 2015 Speaking engagement, 25 June 2014, Shell, including flights to Netherlands and back (originally added 26 June 2014)
Interest deleted 6 July 2015 Speaking engagement, 1 July 2014, Glory Global Solutions (originally added 2 July 2014)
Interest deleted 17 September 2015 Speaking engagement, 18 September 2014, Rathbones (originally added 23 September 2014)
Interest deleted 1 October 2015 Speaking engagement, 24 September 2014, Investment Week (originally added 23 September 2014)
Interest deleted 1 October 2015 Speaking engagement, 30 September 2014, Arup (originally added 4 October 2014)
Interest deleted 11 November 2015 Speaking engagement, 21 October 2014, Goldman Sachs (originally added 24 October 2014)
Interest deleted 11 November 2015 Speaking engagement, 3 November 2014, Santander (originally added 4 November 2014)
Interest deleted 11 November 2015 Speaking engagement, 4 November 2014, BLM (insurance law) (originally added 5 November 2014)
Interest deleted 26 November 2015 Speaking engagement, 19 November 2014, Goldman Sachs (originally added 21 November 2014)
Interest deleted 9 February 2016 Speaking engagement, 20 January 2015, Deloitte (originally added 21 January 2015)
Interest deleted 9 February 2016 Speaking engagement, 29 January 2015, KPMG (originally added 30 January 2015)
Interest deleted 24 February 2016 Speaking engagement, 24 February 2015, Tungsten (originally added 26 February 2015)
Interest deleted 4 March 2016 Speaking engagement, 4 March 2015, Muller (originally added 4 March 2015)
Interest deleted 4 March 2016 Speaking engagement, 4 March 2015, Vodafone Group plc (originally added 5 March 2015)
Interest deleted 29 March 2016 Speaking engagement, 19 March 2015, Defence Academy (originally added 19 March 2015)
Interest deleted 9 April 2015 Speaking engagement, KPMG, 31 March 2015 (originally added 31 March 2015)
Interest deleted 1 April 2016 Speaking engagement, 31 March 2015, JP Morgan (originally added 9 April 2015)
Interest deleted 18 May 2016 Speaking engagement, 18 May 2015, JP Morgan (originally added 19 May 2015)
Interest deleted 20 April 2016 Speaking engagement, 13 April 2015, AIMS (Insurance) Barcelona, speaking fee plus cost of flights/hotel paid (originally added 21 May 2015)
Interest deleted 25 May 2016 Speaking engagement, 22 May 2015, Association of Corporate Treasurers (originally added 25 May 2015)
Interest deleted 11 July 2016 Speaking engagement, 8 June 2015, Sandaire (originally added 9 June 2015)
Interest deleted 11 July 2016 Speaking engagement, 10 June 2015, Jardine Lloyd Thompson Group (originally added 11 June 2015)
Interest deleted 11 July 2016 Speaking engagement, 10 June 2015, RTZ (originally added 11 June 2015)
Interest deleted 11 July 2016 Speaking engagement, 6 July 2015, Proctor and Gamble (originally added 6 July 2015)
Interest deleted 11 July 2016 Speaking engagement, 8 July 2015, Goldman Sachs (originally added 9 July 2015)
Interest deleted 23 September 2016 Speaking engagement, 9 September 2015, Incisive Media conference on pensions (originally added 17 September 2015)
Interest deleted 23 September 2016 Speaking engagement, 10 September 2015, Deloittes (originally added 17 September 2015)
Interest deleted 30 September 2016 Speaking engagement, 30 September 2015, Deloittes (originally added 1 October 2015)
Interest deleted 21 October 2016 Speaking engagement, 9 October 2015, Goldman Sachs (originally added 11 October 2015)
Interest deleted 16 November 2016 Speaking engagement, 10 November 2015, Business Continuity Institute (originally added 11 November 2015)
Interest deleted 30 November 2016 Speaking engagement, 17 November 2015, MidlandHR (originally added 18 November 2015)
Interest deleted 30 November 2016 Speaking engagement, 26 November 2015, EE (originally added 26 November 2015)
Interest deleted 16 January 2017 Speaking engagement, 10 December 2015, Access Bank, Lagos, Nigeria, including flights, hotel and related costs (originally added 13 December 2015)
Interest deleted 2 March 2017 Speaking engagement, 8 February 2016, Sainsbury's (originally added 9 February 2016)
Interest deleted 2 March 2017 Speaking engagement, 11 February 2016, Macquarie Group (originally added 12 February 2016)
Interest deleted 2 March 2017 Speaking engagement in Berlin, 23 February 2016, Global PE Alliance; fee, flights and hotel paid (originally added 24 February 2016)
Interest deleted 6 March 2017 Speaking engagement, 3 March 2016, Dunedin LLP (originally added 4 March 2016)
Interest deleted 13 March 2017 Speaking engagement, 10 March 2016, Ernst and Young (originally added 11 March 2016)
Interest deleted 8 August 2017 Chair of Panel to appoint next chair of Judicial Appointments Committee (JAC) (part-time, per diem fee) (interest ceased 31 July 2016) (originally added 14 March 2016)
Interest deleted 6 April 2017 Speaking engagement, 5 April 2016, City and Guilds (originally added 5 April 2016)
Interest deleted 21 April 2017 Speaking engagement, 12 April 2016, Deloitte, in Paris; speaking fee, hotel and travel costs paid (originally added 13 April 2016)
Interest deleted 21 April 2017 Speaking engagement, 14 April 2016, Nomura (originally added 20 April 2016)
Interest deleted 26 April 2017 Speaking engagement, 25 April 2016, KPMG (originally added 26 April 2016)
Interest deleted 19 May 2017 Speaking engagement, 17 May 2016, Procurement Executive (originally added 18 May 2016)
Interest deleted 25 May 2017 Speaking engagement, 24 May 2016, Google (originally added 25 May 2016)
Interest deleted 9 October 2017 Speaking engagement, 22 September 2016, DHL, in Germany (fee plus flights and hotel) (originally added 23 September 2016)
Interest deleted 10 July 2017 Speaking engagement, 15 June 2016, M-Brain (originally added 7 October 2016)
Interest deleted 9 October 2017 Speaking engagement, 5 October 2016, JP Morgan (originally added 7 October 2016)
Interest deleted 9 October 2017 Speaking engagement, 6 October 2016, Investec (originally added 7 October 2016)
Interest deleted 9 October 2017 Speaking engagement, 6 October 2016, Exponent (originally added 7 October 2016)
Interest deleted 24 October 2017 Fee for chairing a meeting of the family shareholders of Fenwicks, 20 October 2016 (originally added 21 October 2016)
Interest deleted 2 November 2017 Speaking engagement, 1 November 2016, Mastek (originally added 2 November 2016)
Interest deleted 6 November 2017 Speaking engagement, 3 November 2016, Eastern Daily Press (originally added 4 November 2016)
Interest deleted 8 November 2017 Speaking engagement, 7 November 2016, Dimensional Fund Advisors (originally added 8 November 2016)
Interest deleted 20 November 2017 Speaking engagement, 15 November 2016, Royal Bank of Canada (originally added 16 November 2016)
Interest deleted 1 December 2017 Speaking engagement, 29 November 2016, KNect365, in Lisbon (fee plus cost of flights and hotel) (originally added 30 November 2016)
Interest deleted 19 January 2018 Speaking engagement, 12 January 2017, Standard Life (originally added 16 January 2017)
Interest deleted 1 February 2018 Speaking engagement, 30 January 2017, Bearing Point (originally added 20 March 2017)
Interest deleted 20 February 2018 Speaking engagement, 17 February 2017, Weston Homes plc (originally added 20 March 2017)
Interest deleted 9 March 2018 Speaking engagement, 6 March 2017, Automotive Fellowship International (originally added 20 March 2017)
Interest deleted 16 March 2018 Speaking engagement, 15 March 2017, Standard Life (originally added 20 March 2017)
Interest deleted 26 March 2018 Speaking engagement, 23 March 2017, East Midlands Chamber of Commerce (originally added 20 March 2017)
Interest deleted 28 April 2017 Speaking engagement, 26 April 2017, Randstad (originally added 27 April 2017)
Interest deleted 30 April 2018 Speaking engagement, 27 April 2017, Bank of Tokyo (originally added 28 April 2017)
Interest deleted 19 June 2018 Speaking engagement, 15 June 2017, Guy Carpenter & Company LLC (originally added 16 June 2017)
Interest deleted 2 July 2018 Speaking engagement, 29 June 2017, British Franchise Association (originally added 29 June 2017)
Interest deleted 17 July 2018 Speaking engagement, 12 July 2017, Ashurst (originally added 17 July 2017)
Interest deleted 17 July 2018 Speaking engagement, 14 July 2017, Grosvenor Estate (originally added 17 July 2017)
Interest deleted 11 September 2018 Speaking engagement, 7 September 2017, Quoted Companies Alliance (originally added 13 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 14 September 2017, Citywire (originally added 18 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 15 September 2017, Metropolis Group (originally added 18 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 20 September 2017, ICAS (Institute of Chartered Accountants of Scotland) (originally added 27 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 21 September 2017, Fidelity, Vienna, Austria (originally added 27 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 26 September 2017, Goldman Sachs (originally added 27 September 2017)
Interest deleted 5 October 2018 Speaking engagement, 28 September 2017, Linklaters (originally added 9 October 2017)
Interest deleted 5 October 2018 Speaking engagement, 28 September 2017, Pegasystems (originally added 9 October 2017)
Interest deleted 5 October 2018 Speaking engagement, 4 October 2017, Nomura, Madrid; hotel and flights paid for by Nomura (originally added 1 November 2017)
Interest deleted 15 October 2018 Speaking engagement, 12 October 2017, O2 (originally added 1 November 2017)
Interest deleted 18 October 2018 Speaking engagement, 17 October 2017, Civil Society Media (originally added 1 November 2017)
Interest deleted 19 October 2018 Speaking engagement, 18 October 2017, CompTIA (originally added 1 November 2017)
Interest deleted 25 October 2018 Speaking engagement, 24 October 2017, Google (originally added 1 November 2017)
Interest deleted 13 November 2018 Speaking engagement, 31 October 2017, Federation CJA (originally added 1 November 2017)
Interest deleted 13 November 2018 Speaking engagement, 3 November 2017, Shaylor Group (originally added 22 November 2017)
Interest deleted 13 November 2018 Speaking engagement, 7 November 2017, Aberdeen Standard Investment (originally added 22 November 2017)
Interest deleted 13 November 2018 Speaking engagement, 8 November 2017, Legal and General (originally added 22 November 2017)
Interest deleted 22 November 2018 Speaking engagement, 15 November 2017, Deloittes (originally added 22 November 2017)
Interest deleted 6 December 2018 Speaking engagement, 5 December 2017, KNect365, Amsterdam; travel and accommodation costs met by KNect365 (originally added 19 December 2017)
Interest deleted 1 February 2019 Speaking engagement, 31 January 2018, PricewaterhouseCoopers (originally added 16 February 2018)
Interest deleted 11 February 2019 Speaking engagement, 8 February 2018, Dechert LLP (originally added 16 February 2018)
Interest deleted 21 February 2019 Speaking engagement, 20 February 2018, Luther Pendragon/Liberty Specialist Markets (originally added 21 February 2018)
Interest deleted 11 March 2019 Speaking engagement, 8 March 2018, Ladbrokes (originally added 23 March 2018)
Interest deleted 22 March 2019 Speaking engagement, 21 March 2018, Risk Minds, Amsterdam; flights and accommodation paid for by Risk Minds (originally added 23 March 2018)
Interest deleted 25 March 2019 Speaking engagement, 22 March 2018, Nuix Technology (originally added 23 March 2018)
Interest deleted 14 May 2019 Speaking engagement, 26 April 2018, DLA Piper (originally added 27 April 2018)
Interest deleted 21 May 2019 Speaking engagement, 15 May 2018, DLA Piper (originally added 21 May 2018)
Interest deleted 21 May 2019 Speaking engagement, 17 May 2018, Citywire, Switzerland; flights and accommodation paid for by Citywire (originally added 21 May 2018)
Interest deleted 3 June 2019 Speaking engagement, 1 June 2018, Ruthin College (originally added 2 July 2018)
Interest deleted 10 June 2019 Speaking engagement, 8 June 2018, Google, Lisbon; flights and accommodation paid for by Google (originally added 2 July 2018)
Interest deleted 25 June 2019 Speaking engagement, 19 June 2018, Linedata (originally added 2 July 2018)
Interest deleted 25 June 2019 Speaking engagement, 19 June 2018, Retail Week (originally added 2 July 2018)
Interest deleted 1 July 2019 Speaking engagement, 29 June 2018, Deloitte, Prague; flights and accommodation paid for by Deloitte (originally added 2 July 2018)
Interest deleted 8 October 2019 Speaking engagement, 17 September 2018, Today’s Group, Venice; flights and accommodation paid by Today's Group (originally added 5 October 2018)
Interest deleted 8 October 2019 Speaking engagement, 19 September 2018, AIT (originally added 5 October 2018)
Interest deleted 24 October 2019 Speaking engagement, 17 October 2018, Volkswagen Group (originally added 22 October 2018)
Interest deleted 24 October 2019 Speaking engagement, 18 October 2018, Cloud FM (originally added 22 October 2018)
Interest deleted 5 November 2019 Speaking engagement, 1 November 2018, Duff and Phelps (originally added 23 November 2018)
Interest deleted 11 November 2019 Speaking engagement, 7 November 2018, Royal Warrant Holders (originally added 23 November 2018)
Interest deleted 15 November 2019 Speaking engagement, 13 November 2018, Allen and Overy (originally added 23 November 2018)
Interest deleted 15 November 2019 Speaking engagement, 14 November 2018, C3 Post Trade (originally added 23 November 2018)
Interest deleted 21 November 2019 Speaking engagement, 20 November 2018, Cazenove (originally added 23 November 2018)
Interest deleted 28 November 2019 Speaking engagement, 21 November 2018, CREFC (originally added 23 November 2018)
Interest deleted 13 March 2020 Speaking engagement, 6 March 2019, D.E. Shaw Group, London (originally added 11 March 2019)
Interest deleted 13 March 2020 Speaking engagement, 7 March 2019, Citywire, London (originally added 11 March 2019)
Interest deleted 13 March 2020 Speaking engagement, 7 March 2019, Omers, London (originally added 11 March 2019)
Interest deleted 9 April 2020 Speaking engagement, 26 March 2019, Silverfleet Capital, London (originally added 27 March 2019)
Interest deleted 9 April 2020 Speaking engagement, 8 April 2019, Associated Independent Stores, Sutton Coldfield (originally added 9 April 2019)
Interest deleted 12 May 2020 Speaking engagement, 2 May 2019, Securelink, London (originally added 3 June 2019)
Interest deleted 12 May 2020 Speaking engagement, 2 May 2019, Association of Project Managers, London (originally added 3 June 2019)
Interest deleted 18 May 2020 Speaking engagement, 15 May 2019, British Insurance Brokers, Manchester (originally added 3 June 2019)
Interest deleted 18 May 2020 Speaking engagement, 15 May 2019, London Platinum Week, London (originally added 3 June 2019)
Interest deleted 26 May 2020 Speaking engagement, 20 May 2019, Aviva, London (originally added 3 June 2019)
Interest deleted 26 May 2020 Speaking engagement, 22 May 2019, Capita, Heathrow Airport (originally added 3 June 2019)
Interest deleted 26 May 2020 Speaking engagement, 23 May 2019, Reed and Mackay, London (originally added 3 June 2019)
Interest deleted 29 May 2020 Speaking engagement, 28 May 2019, Boston Consulting Group, Watford (originally added 3 June 2019)
Interest deleted 16 June 2020 Speaking engagement, 12 June 2019, VVCP, London (originally added 4 July 2019)
Interest deleted 22 June 2020 Speaking engagement, 19 June 2019, Google, London (originally added 4 July 2019)
Interest deleted 22 June 2020 Speaking engagement, 19 June 2019, Merryck, London (originally added 4 July 2019)
Interest deleted 29 June 2020 Speaking engagement, 26 June 2019, Sky, London (originally added 4 July 2019)
Interest deleted 14 August 2020 Speaking engagement, 11 August 2019, Oxford Royale Academy, Oxford (originally added 16 August 2019)
Interest deleted 27 September 2020 Speaking engagement, 18 September 2019, Facebook, London (originally added 8 October 2019)
Interest deleted 27 September 2020 Speaking engagement, 19 September 2019, Yorkshire Business Finance Awards, sponsored by Walker Morris, Leeds (originally added 8 October 2019)
Interest deleted 17 October 2020 Speaking engagement, 1 October 2019, Latham and Watkins, London (originally added 24 October 2019)
Interest deleted 17 October 2020 Speaking engagement, 3 October 2019, Carbon Black, London (originally added 24 October 2019)
Interest deleted 17 October 2020 Speaking engagement, 10 October 2019, Knect365, London (originally added 24 October 2019)
Interest deleted 17 October 2020 Speaking engagement, 11 October 2019, Kirkland and Ellis, London (originally added 24 October 2019)
Interest deleted 28 October 2020 Speaking engagement, 22 October 2019, Wrike, London (originally added 24 October 2019)
Interest deleted 28 October 2020 Speaking engagement, 23 October 2019, Boston Consulting Group, Boston, USA; fee and flight costs paid by hosts (originally added 24 October 2019)
Interest deleted 16 November 2020 Speaking engagement, 13 November 2019, Kvalitetsmassan, Gothenburg; travel and accommodation costs paid by hosts (originally added 28 November 2019)
Interest deleted 23 November 2020 Speaking engagement, 19 November 2019, GBTA, Munich; travel and accommodation costs paid by hosts (originally added 28 November 2019)
Interest deleted 23 November 2020 Speaking engagement, 20 November 2019, Knect 365, Amsterdam; travel and accommodation costs paid by hosts (originally added 28 November 2019)
Interest deleted 1 December 2020 Speaking engagement, 27 November 2019, Ideagen, Birmingham (originally added 28 November 2019)
Interest deleted 25 January 2021 Speaking engagement, 22 January 2020, ADS Group Limited, London (originally added 24 January 2020)
Interest deleted 25 January 2021 Speaking engagement, 23 January 2020, Neuberger Berman, London (originally added 24 January 2020)
Interest deleted 2 March 2021 Speaking engagement, 27 February 2020, Skanska, Reading (originally added 13 March 2020)
Interest deleted 15 June 2021 Speaking engagement, 3 June 2020, Google (delivered remotely) (originally added 4 June 2020)
Interest deleted 10 October 2021 Speaking engagement, 9 October 2020, virtual event for Activision (originally added 19 October 2020)
Interest deleted 18 October 2021 Speaking engagement, 16 October 2020, virtual event for UAB Gravitacija (originally added 19 October 2020)
Interest deleted 9 November 2021 Speaking engagement, 4 November 2020, virtual talk for The Marketing Society (originally added 6 November 2020)
Interest deleted 3 December 2021 Speaking engagement, 2 December 2020, virtual talk for Summit Events (originally added 7 December 2020)
Interest deleted 18 December 2021 Speaking engagement, 4 December 2020, virtual talk for Broker Expo (originally added 7 December 2020)
Interest deleted 11 March 2022 Speaking engagement, 10 March 2021, virtual talk for Goldman Sachs (originally added 19 March 2021)
Interest deleted 21 March 2022 Speaking engagement, 18 March 2021, virtual talk for Peak AI (originally added 19 March 2021)
Interest deleted 23 June 2022 Speaking engagement, 22 June 2021, virtual event for Freshfields Bruckhaus Deringer (originally added 29 July 2021)
Interest deleted 29 July 2021 Speaking engagement, 13 July 2021, Infosecurity Europe 2021 Summit, Reed Exhibitions Ltd, Olympia, London (originally added 29 July 2021)
Interest deleted 2 September 2022 Speaking engagement, 26 August 2021, virtual summit for Chief Investment Officers (originally added 19 October 2021)
Interest deleted 23 September 2022 Speaking engagement, 2 September 2021, virtual event for Boston Consulting Group (originally added 19 October 2021)
Interest deleted 12 October 2022 Speaking engagement, 24 September 2021, Netcompany, Wales (originally added 19 October 2021)
Interest deleted 12 October 2022 Speaking engagement, 28 September 2021, virtual event for Boston Consulting Group (originally added 19 October 2021)
Interest deleted 12 October 2022 Speaking engagement, 6 October 2021, PricewaterhouseCoopers, London (originally added 19 October 2021)
Interest deleted 12 October 2022 Speaking engagement, 7 October 2021, Clayesmore School, Dorset (originally added 19 October 2021)
Interest deleted 12 October 2022 Speaking engagement, 11 October 2021, Summit Events, Warwick (originally added 19 October 2021)
Interest deleted 23 September 2022 Speaking engagement, 14 September 2021, virtual event for International Data Group (originally added 19 October 2021)
Interest deleted 3 November 2022 Speaking engagement, 29 October 2021, Global General Counsel Forum, Global Leaders in Law conference, Lake Como, Italy (originally added 3 November 2021)
Interest deleted 17 November 2022 Speaking engagement, 12 November 2021, BPL Business Convention, Scotland (originally added 30 November 2021)
Interest deleted 23 November 2022 Speaking engagement, 18 November 2021, virtual event for KPMG International Limited (originally added 30 November 2021)
Interest deleted 23 November 2022 Speaking engagement, 18 November 2021, Barclays plc, London (originally added 30 November 2021)
Interest deleted 5 December 2022 Speaking engagement, 24 November 2021, Bytes Software Services, London (originally added 30 November 2021)
Interest deleted 5 December 2022 Speaking engagement, 24 November 2021, Bonhill Investments, Horsham (originally added 30 November 2021)
Interest deleted 17 March 2023 Speaking engagement, 15 March 2022, virtual event for Doctolib (originally added 28 March 2022)
Interest deleted 20 March 2023 Speaking engagement, 17 March 2022, M Group, London (originally added 28 March 2022)
Interest deleted 24 March 2023 Speaking engagement, 23 March 2022, Nuveen, London (originally added 28 March 2022)
Interest deleted 30 March 2023 Speaking engagement, 24 March 2022, virtual event for Investec (originally added 28 March 2022)
Interest deleted 17 April 2023 Speaking engagement, 6 April 2022, virtual event for LinkedIn (originally added 9 April 2022)
Interest deleted 17 April 2023 Speaking engagement, 7 April 2022, Paribas, Brussels (one night’s accommodation costs met by organisers) (originally added 9 April 2022)
Interest deleted 17 May 2023 Speaking engagement, 5 May 2022, virtual event for Legal and General (originally added 7 June 2022)
Interest deleted 17 May 2023 Speaking engagement, 11 May 2022, IMpower, Monaco (flights and overnight accommodation included) (originally added 7 June 2022)
Interest deleted 21 June 2023 Speaking engagement, 26 May 2022, YPO, Farnham (originally added 7 June 2022)
Interest deleted 21 June 2023 Speaking engagement, 26 May 2022, Standard Bank, London (originally added 7 June 2022)
Interest deleted 21 June 2023 Speaking engagement, 16 June 2022, Newton Europe, London (originally added 5 July 2022)
Interest deleted 10 July 2023 Speaking engagement, 22 June 2022, Infosecurity Europe Cyber conference, London (originally added 5 July 2022)
Interest deleted 10 July 2023 Speaking engagement, 29 June 2022, Albacore, London (originally added 5 July 2022)
Interest deleted 10 July 2023 Speaking engagement, 30 June 2022, Gamma Telecom, London (originally added 5 July 2022)
Interest deleted 10 July 2023 Speaking engagement, 1 July 2022, Boston Consulting Group, London (originally added 5 July 2022)
Interest deleted 10 July 2023 Speaking engagement, 4 July 2022, Bain Capital, Palermo, Italy (flights and accommodation paid) (originally added 5 July 2022)
Interest deleted 22 September 2023 Speaking engagement, 15 September 2022, Quoted Companies Alliance, London (originally added 5 October 2022)
Interest deleted 18 October 2023 Speaking engagement, 22 September 2022, Natwest, Edinburgh (flights and accommodation paid) (originally added 5 October 2022)
Interest deleted 18 October 2023 Speaking engagement, 29 September 2022, Ninety One, London (originally added 5 October 2022)
Interest deleted 18 October 2023 Speaking engagement, 6 October 2022, EY, Windsor (originally added 12 October 2022)
Interest deleted 18 October 2023 Speaking engagement, 11 October 2022, Institute of Chartered Accountants, London (originally added 12 October 2022)
Interest deleted 18 October 2023 Speaking engagement, 12 October 2022, Equiniti, London (originally added 13 October 2022)
Interest deleted 3 November 2022 Speaking engagement, 15 September 2022, Quoted Companies Alliance, London (originally added 3 November 2022)
Interest deleted 18 October 2023 Speaking engagement, 19 September 2022, Barclays, London (originally added 3 November 2022)
Interest deleted 3 November 2022 Speaking engagement, 22 September 2022, Natwest, Edinburgh (originally added 3 November 2022)
Interest deleted 3 November 2022 Speaking engagement, 29 September 2022, Ninety One, London (originally added 3 November 2022)
Interest deleted 3 November 2023 Speaking engagement, 1 November 2022, Reach, Birmingham (originally added 5 December 2022)
Interest deleted 20 November 2023 Speaking engagement, 8 November 2022, Office Agents Society, London (originally added 5 December 2022)
Interest deleted 20 November 2023 Speaking engagement, 16 November 2022, Association of Colleges, Birmingham (originally added 5 December 2022)
Interest deleted 30 November 2023 Speaking engagement, 23 November 2022, Management Consultancies Association, London (originally added 5 December 2022)
Interest deleted 30 November 2023 Speaking engagement, 24 November 2022, Business Growth Fund, London (originally added 5 December 2022)
Interest deleted 30 November 2023 Speaking engagement, 28 November 2022, National Farmers' Union of England and Wales (NFU), London (originally added 5 December 2022)
Interest deleted 1 February 2024 Speaking engagement, 31 January 2023, Four Arts Club, Palm Beach, USA (flights and accommodation paid) (originally added 2 March 2023)
Interest deleted 13 February 2024 Speaking engagement, 6 February 2023, KPMG, London (originally added 2 March 2023)
Interest deleted 29 February 2024 Speaking engagement, 21 February 2023, Association of British Insurers (ABI), London (originally added 2 March 2023)
Interest deleted 29 February 2024 Speaking engagement, 21 February 2023, Finance and Leasing Association, London (originally added 2 March 2023)
Interest deleted 29 February 2024 Speaking engagement, 28 February 2023, Polar Capital, London (originally added 2 March 2023)
Interest deleted 20 March 2024 Speaking engagement, 8 March 2023, Closer Still Media Ltd, London (originally added 9 March 2023)
Interest deleted 25 April 2024 Speaking engagement, 17 April 2023, Boston Consulting Group, London (originally added 28 April 2023)
Interest deleted 25 April 2024 Speaking engagement, 18 April 2023, Pets at Home, Butlin’s, Bognor Regis (originally added 28 April 2023)
Interest deleted 25 April 2024 Speaking engagement, 20 April 2023, Pallas Partners, London (originally added 28 April 2023)
Interest deleted 30 April 2024 Speaking engagement, 27 April 2023, Institute of Chartered Accountants in England and Wales, Bristol (originally added 28 April 2023)
Interest deleted 13 May 2024 Speaking engagement, 11 May 2023, Deloitte, London (originally added 26 May 2023)
Interest deleted 20 May 2024 Speaking engagement, 17 May 2023, Imago Techmedia, Manchester (originally added 26 May 2023)
Interest deleted 20 May 2024 Speaking engagement, 19 May 2023, virtual event for Zurich Insurance Group (originally added 26 May 2023)
Interest deleted 5 June 2024 Speaking engagement, 24 May 2023, Zurich Insurance Group, London (originally added 26 May 2023)
Interest deleted 5 June 2024 Speaking engagement, 25 May 2023, JPMorgan, Paris (transport paid) (originally added 26 May 2023)
Interest deleted 19 June 2024 Speaking engagement, 7 June 2023, Orange, Rome (flights and hotel paid) (originally added 10 July 2023)
Interest deleted 19 June 2024 Speaking engagement, 8 June 2023, Industrial Asset Management Council (IAMC), London (originally added 10 July 2023)
Interest deleted 29 June 2024 Speaking engagement, 22 June 2023, Ninety One, London (originally added 10 July 2023)
Interest deleted 29 June 2024 Speaking engagement, 28 June 2023, BT plc, London (originally added 10 July 2023)
Interest deleted 7 July 2024 Speaking engagement, 6 July 2023, Managing General Agents' Association (MGAA), London (originally added 10 July 2023)
Interest deleted 10 September 2024 Speaking engagement, 5 September 2023, DLT Science Foundation, London (originally added 25 October 2023)
Interest deleted 18 September 2024 Speaking engagement, 14 September 2023, Egremont, London (originally added 25 October 2023)
Interest deleted 16 October 2024 Speaking engagement, 12 October 2023, Gately, Birmingham (originally added 25 October 2023)
Interest deleted 21 October 2024 Speaking engagement, 17 October 2023, virtual event for Idemia (originally added 25 October 2023)
Interest deleted 21 October 2024 Speaking engagement, 20 October 2023, Barclays, London (originally added 25 October 2023)
Interest deleted 14 November 2024 Speaking engagement, 9 November 2023, Hogan Lovells, London (originally added 30 November 2023)
Interest deleted 21 November 2024 Speaking engagement, 16 November 2023, BCG, Berkshire (originally added 30 November 2023)
Interest deleted 28 November 2024 Speaking engagement, 21 November 2023, Home Office, London (originally added 30 November 2023)
Interest deleted 2 December 2024 Speaking engagement, 29 November 2023, North Sea Transition Authority, Aberdeen (hotel and travel paid for) (originally added 30 November 2023)
Interest deleted 22 December 2024 Speaking engagement, 7 December 2023, virtual event for Total Energies (originally added 8 December 2023)
Interest amended 16 April 2024 Speaking engagement, 5 March 2024, IT Europa Media and Intelligence, Hertfordshire (originally added 16 April 2024)
Interest amended 16 April 2024 Speaking engagement, 7 March 2024, CVC, London (originally added 16 April 2024)
Interest amended 16 April 2024 Speaking engagement, 12 March 2024, Goldman Sachs, London (originally added 16 April 2024)
Interest amended 16 April 2024 Speaking engagement, 20 March 2024, Barclays, London (originally added 16 April 2024)
Interest amended 16 April 2024 Speaking engagement, 12 April 2024, Convatec, London (originally added 16 April 2024)
Interest amended 22 May 2024 Speaking engagement, 21 May 2024, Bird and Bird, London (originally added 22 May 2024)
Interest amended 29 June 2024 Speaking engagement, 9 June 2024, Bank Mellon/NY, London (originally added 29 June 2024)
Interest amended 29 June 2024 Speaking engagement, 26 June 2024, Mpower, Monaco (flights and hotel paid) (originally added 29 June 2024)
Interest amended 29 June 2024 Speaking engagement, 27 June 2024, Barclays, London (originally added 29 June 2024)
Interest amended 29 June 2024 Speaking engagement, 27 June 2024, Newton Europe, London (originally added 29 June 2024)
Interest amended 30 June 2024 Speaking engagement, 27 June 2024, Travers Smith, London (originally added 29 June 2024)
Interest amended 30 September 2024 Speaking engagement, 25 September 2024, North Sea Transitioning Authority, Ascot (originally added 30 September 2024)
Interest amended 14 November 2024 Speaking engagement, 11 November 2024, Ernst & Young, London (originally added 14 November 2024)
Interest amended 28 November 2024 Speaking engagement, 26 November 2024, Dell Technology, London (originally added 28 November 2024)
Here's an analysis of Baroness Manningham-Buller's speaking engagements based on the provided text:
Summary of Findings
Total Engagements: Baroness Manningham-Buller undertook 329 speaking engagements between June 2010 and November 2024.
Frequency: This averages to approximately 2 speaking engagements per month.
Variety of Venues: The engagements span a wide range of organizations, including corporations, financial institutions, academic bodies, media groups, and professional associations.
International Presence: While the majority of engagements are in the UK, some took place in other countries, including Spain, Italy, Austria, Netherlands, Nigeria, Sweden, Germany, and the USA. Some of these international engagements included coverage of travel and accommodation costs.
Virtual Events: A number of speaking engagements from 2020 onwards were virtual, likely influenced by the COVID-19 pandemic.
Most Frequently Occurring Companies
The most frequent speaking engagements were:
Ernst & Young (EY): Appears 17 times
Goldman Sachs: Appears 12 times
Barclays: Appears 10 times
Deloitte: Appears 9 times
KPMG: Appears 9 times
Boston Consulting Group: Appears 8 times
JP Morgan: Appears 6 times
Google: Appears 6 times
IBM: Appears 5 times
Ninety One: Appears 3 times
Citywire: Appears 3 times
Knect365: Appears 3 times
Natwest: Appears 3 times
Legal and General: Appears 3 times
DLA Piper: Appears 3 times
Patterns Observed
Dominance of Financial and Professional Services: A significant number of engagements are with major financial institutions (e.g., Goldman Sachs, JP Morgan, Barclays) and professional services firms (e.g., Ernst & Young, Deloitte, KPMG). This suggests a demand for her insights in these sectors.
Consistent Relationships: The repeated appearances of certain companies (like Ernst & Young, Goldman Sachs, and Deloitte) indicate ongoing relationships and a consistent demand.
Shift to Virtual Engagements: The data shows a clear shift towards virtual speaking engagements, particularly during 2020 and 2021, which aligns with the global increase in remote events.
International Presence: While the majority of engagements are in the UK, some took place in other countries, including Spain, Italy, Austria, Netherlands, Nigeria, Sweden, Germany, and the USA. Some of these international engagements included coverage of travel and accommodation costs.
UK-Centric with International Outliers: The majority of events are located in London, with some engagements taking place in other major UK cities like Manchester, Birmingham, and Edinburgh. International engagements, particularly in Europe, also feature.