Below is the text of my letter of complaint to Martin Jelley QPM, the Lords’ Commissioner for Standards. Which resulted in this Report from the Commissioners for Standards The conduct of Baroness Smith of Basildon: conduct-of-baroness-smith.pdf (parliament.uk)
Mr Jelley failed to address the core complaint, the use of multiple identities to obscure accountability. It’s a significant issue because this deceptive behaviour is fraudulent and breaches the legislation that provides security against money laundering and terrorism financing. Unfortunately, many people who are in positions of control also exhibit this behaviour, such as Prime Minister Rishi Sunak and Attorney General Victoria Prentis. I have a petition that I’d appreciate your support with: Investigate synthetic identity fraud by MPs | 38 Degrees.
7 July 2023
Martin Jelley, QPM
Commissioner for Standards,
House of Lords.
Dear Sir,
I am writing in response to your letter dated 6 July regarding the conduct of Baroness Smith of Basildon. I appreciate the preliminary assessment carried out on my complaint, but I would like to address some concerns and seek further clarification.
Angela Evans Smith holds four identities in Companies House. This has a material impact on audits and due diligence for anti-money laundering and counter-terrorism financing, as interests held in other identities are concealed from audits and due diligence assessments. The use of synthetic identities has significant implications for transparency, accountability, and integrity within the parliamentary system. She also failed to register these Category 1 interests in the Lords' Register of Interest. The identities and appointments are listed below:
Angela Evans SMITH
Total number of appointments 1
Date of birth January 1959
THE PRODUCTION EXCHANGE LIMITED (08564622)
Role RESIGNED Director
Appointed on 13 March 2014
Resigned on 14 June 2023
Angela Evans SMITH
Total number of appointments 2
Date of birth January 1959
THE HOLOCAUST MEMORIAL CHARITABLE TRUST (11796550)
Role ACTIVE Director
Appointed on 28 September 2019
THE PRODUCTION EXCHANGE LIMITED (08564622)
Role RESIGNED Director
Appointed on 1 June 2017
Resigned on 30 March 2018
Angela Evans SMITH
Total number of appointments 1
ABERAVON ACCOUNTING LTD (05052381)
Role RESIGNED Secretary
Appointed on 6 April 2004
Resigned on 28 February 2016
Angela Evans SMITH
Total number of appointments 1
Date of birth January 1959
RESOLVING CHAOS C.I.C. (07962530)
Role Resigned Director
Appointed on 11 December 2012
Resigned on 15 April 2015
The creation of multiple identities is a result of an error in Companies House de-duplication system, caused by a different name, date of birth or usual residential address. The creation of a duplicate identity is an unwanted outcome and is known as a synthetic identity. From a systems' point of view, there are four people called Angela Evans Smith, and this allows permissions as four people. This represents a security risk as she could use these identities to acquire multiple security clearances. The information provided with each record is misleading, for example "Total number of appoints 1" is an untrue statement.
For the period 1 June 2017 to 30 March 2018 she held dual registrations as director of The Production Exchange Limited, using 2 registered identities. This is a serious breach of the Companies Act 2006.
Please investigate how Baroness Smith created her 3 synthetic identities. I suspect that it is by using different usual residential addresses, or different spelling of her usual residential address. If so, this is evidence of deliberate deception and I anticipate that you, together with Companies House, will prosecute her for providing false or misleading information to gain synthetic identities. That she fails to register her interests correctly in the Lords' Register of Interest, is evidence that she created the synthetic identities in order to conceal her directorships of these interests. This breaches cybersecurity requirements in zero trust architectures of a unique identity.
I allege that on 11 December 2012, 13 March 2014 and 1 June 2017, Baroness Smith provided false information to the Registrar of Companies House to establish synthetic identities. These had the material effect of concealing all of her interests from audits, by acting as if she were four people. This corrupts audits of these organisations. If proven true, and it is found that she also failed to declare interests held in synthetic identities, this would prove the deliberate intent behind provision of false information to establish synthetic identities. This meets the definition of fraud by false representation and fraud by failing to disclose interests and I anticipate that you and Companies House, upon finding these allegations are correct will ensure prosecution of these infringements as fraud.
Limited scope: The Commissioner cites paragraph 137 of the Guide to the Code of Conduct, stating that their remit does not extend to investigating conduct that does not relate to a member's parliamentary duties or activities. However, by solely focusing on the narrow interpretation of parliamentary aspects, the Commissioner fails to acknowledge the broader implications and potential misconduct arising from the use of synthetic identities. The concealment of undisclosed interests behind these synthetic identities, coupled with the failure to register them, directly undermines the principles of transparency, accountability, and integrity that are crucial for maintaining public trust in the parliamentary system.
Failure to recognise relevance: The Commissioner dismisses the issue of synthetic identities as a matter for Companies House to address, claiming that it does not engage the Code of Conduct. However, the use of synthetic identities can be seen as a breach of the Code, particularly in terms of transparency, accountability, and integrity, which are essential for maintaining public trust in the parliamentary system.
Lack of consideration for the Code's principles: The response does not address the concerns raised in the original complaint regarding the disrespectful and discourteous nature of concealing interests behind synthetic identities and failing to register them. These actions undermine the principles of the Code of Conduct, including accountability and honesty, which should be upheld by all members of the House.
Overall, the Commissioner's response fails to acknowledge the significance and potential misconduct associated with the use of synthetic identities and does not provide a satisfactory explanation for not considering this aspect of the complaint.
Furthermore, I respectfully request that the following breaches should also be considered:
Compliance and personal honour: Paragraph 9 of the Code of Conduct highlights the obligation for members of the House to adhere to the Code and uphold their personal honour while performing their parliamentary duties and activities. This provision entails a responsibility to maintain the standards and expectations set by the House as a whole, transcending an individual's subjective understanding of honour.
The concept of "personal honour" is not explicitly defined within the Code, but it is deeply rooted in the collective sense and culture of the House. It represents the prevailing standards of conduct expected from all members, which may evolve over time to reflect the evolving ethical landscape. Consequently, individual members cannot solely rely on their personal interpretation of honour, but must align their behaviour with the broader standards expected by the House as a whole.
In the case at hand, the use of synthetic identities and the failure to disclose relevant interests can be seen as breaches of personal honour, as they compromise the transparency, integrity, and accountability that are integral to the functioning of the parliamentary system. By concealing interests behind synthetic identities and failing to register them, the member disregards the standards and expectations set by the House and undermines the principles of personal honour.
It is essential that any investigation into allegations of misconduct takes into account the overarching principles of compliance and personal honour, as outlined in Paragraph 9 of the Code of Conduct. By doing so, the investigation can assess whether the actions of the member align with the standards expected by the House and uphold the values of transparency, integrity, and accountability that are essential for public trust in the parliamentary system.
Freedom of speech and fairness: Paragraph 29 emphasises the importance of upholding freedom of speech in parliamentary proceedings. However, it is crucial to recognise that the use of synthetic identities can potentially undermine the principles of fairness and fairness in the context of the Code of Conduct.
Synthetic identities, by their nature, create an environment where true identities are concealed or misrepresented. This can have a detrimental impact on fair and transparent parliamentary processes. It can allow individuals to manipulate their identities to evade scrutiny, hide conflicts of interest, or engage in fraudulent activities. Such actions undermine the fairness of the parliamentary system, eroding public trust and compromising the integrity of decision-making processes.
Therefore, when assessing, investigating, and adjudicating allegations of non-compliance with the Code, it is essential to consider the potential implications of synthetic identities on the principles of freedom of speech and fairness. These considerations involve ensuring that all individuals are held accountable for their actions, irrespective of the identities they assume, and that the investigation process is conducted in a fair, impartial, and transparent manner.
By acknowledging the impact of synthetic identities on the principles of freedom of speech and fairness, we can strive for a more comprehensive understanding of the challenges posed by these fraudulent practices and work towards safeguarding the integrity of the parliamentary system.
In light of these additional points, the Commissioner's response can be further criticised for not fully considering the principles of personal honour, compliance with the Code, and the standards expected by the House as a whole. The use of synthetic identities and failure to disclose interests can be seen as potential breaches of these principles and the Code, requiring a more comprehensive investigation and assessment.
Simply getting Baroness Smith of Basildon to update the Register of Interests, without investigating the allegations of synthetic identity fraud and other potential breaches, would be an inadequate response for several reasons:
Failure to address the root issue: Updating the Register of Interests alone does not address the underlying concerns regarding the use of synthetic identities and potential fraudulent activities. It is crucial to thoroughly investigate and assess whether there have been deliberate attempts to conceal interests and deceive the system.
Integrity of the parliamentary process: The Code of Conduct and the Register of Interests are essential tools for ensuring transparency, accountability, and public trust in the parliamentary process. Ignoring the allegations of synthetic identity fraud undermines the integrity of these systems and fails to uphold the standards expected of members of the House.
Fairness and impartiality: The investigation should be conducted by individuals who do not hold multiple identities themselves to ensure an unbiased and impartial assessment. Failure to consider the impact of synthetic identities and address the allegations adequately could compromise the fairness of the investigation and raise concerns about potential conflicts of interest.
Deterrence and prevention: Taking appropriate action in response to allegations of misconduct, including synthetic identity fraud, is essential for deterrence and prevention. It sends a strong message that such behaviour is not tolerated and helps maintain the integrity of the parliamentary process.
Despite the gravity of these allegations, I have previously observed a case where a similar complaint resulted in a response that simply involved updating the Register of Interests without addressing the synthetic identity fraud allegations. Such a response is inadequate, as it fails to address the root issue and undermines the integrity of the parliamentary process.
Therefore, I urge you to conduct a thorough investigation into the allegations of synthetic identity fraud, fraudulent non-disclosure of interests, and potential breaches of the Code of Conduct. It is essential to ensure that the investigation is impartial, conducted by individuals without multiple identities themselves, or their close relatives, and that appropriate action is taken to address any substantiated findings.
Please take into account your potential personal connections when considering this complaint. It is important to assess whether any of the following individuals are related to you: Martin Richard Jelley, born February 1959, with 2 identities; Brent Tristram Jelley, born March 1965, with 5 identities; Caroline Jelly, born May 1969, with 2 identities; Christopher Graham Jelley, born July 1970, with 2 identities. While this list is not exhaustive, it highlights the significance of personal relationships and potential conflicts of interest that may impact the impartiality of your assessment.
Request for Additional Legal Actions to Address Synthetic Identity Fraud
I request the consideration and implementation of additional legal actions to effectively address the pervasive issue of synthetic identity fraud. As outlined in my previous correspondence, the current response to the allegations of synthetic identity fraud and related misconduct has been inadequate, requiring further measures to ensure accountability, transparency, and the protection of our institutions. Therefore, I kindly request your attention to the following points:
Identify, Investigate, and Prosecute:
Conduct thorough investigations to identify individuals who have engaged in synthetic identity fraud, beyond the cases previously reported. This includes uncovering potential networks and patterns of fraudulent activity that may extend beyond the documented instances.
Regulatory Reforms:
2. Advocate for regulatory reforms that mandate a complete audit rotation within businesses and organisations. Furthermore, introduce requirements for audits to incorporate screening measures specifically designed to detect and prevent synthetic identity fraud. This would enhance the effectiveness of audit processes and hold entities accountable for implementing robust measures to address the risks associated with synthetic identities.
Collaboration with Law Enforcement:
3. Facilitate collaboration and coordination among relevant regulatory bodies, law enforcement agencies, and other stakeholders to establish protocols for detecting, investigating, and prosecuting synthetic identity fraud cases. By fostering cooperation and information sharing, we can create a comprehensive and united front against this form of fraudulent activity.
Enhanced Due Diligence:
4. Implement stricter due diligence procedures, particularly in sensitive sectors such as finance, government, and law enforcement. This would ensure rigorous screening for synthetic identity fraud during the onboarding process and continuous monitoring of individuals involved. Such measures will help mitigate risks and protect against potential threats to the integrity of our institutions.
Cybersecurity Considerations:
5. Recognize the critical role of unique identities in cybersecurity, particularly within a zero trust architecture. Multiple synthetic identities directly breach cybersecurity requirements, compromising the effectiveness of security measures and creating vulnerabilities within our systems. Therefore, it is imperative to address synthetic identity fraud not only from a regulatory and legal perspective but also as a fundamental cybersecurity concern.
Public Awareness and Education:
6. Launch public awareness campaigns and educational initiatives to increase awareness about synthetic identity fraud, its far-reaching consequences, and preventive measures. These efforts will empower individuals, businesses, and organisations to recognise the risks associated with synthetic identities and take proactive steps to prevent and report fraudulent activities.
By addressing these crucial aspects, we can fortify our legal framework, enhance enforcement capabilities, and foster a culture of accountability and integrity. It is essential to undertake these additional legal actions to effectively combat synthetic identity fraud and ensure a fair, transparent, and trustworthy system for all stakeholders.
Thank you for your attention to this matter. I remain committed to supporting the efforts aimed at combating synthetic identity fraud and preserving the integrity of our institutions.
Yours sincerely,
Alison Wright.