Letter to Baroness Manningham-Buller

Subject: Urgent Call for Resignation and Reversal of Proposed Code of Conduct Amendments

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

Further analysis is available here: