Hawthorn Advisors: ORCL passes the buck to PRCA on code of conduct

1. The Office of the Registrar of Consultant Lobbyists (“ORCL”) is passing the buck to trade body the Public Relations and Communications Association (“PRCA”) on code of conduct for consultant lobbyists – despite the fact PRCA has again shown itself to be ineffective and unaccountable.
2. Consultant lobbyists must register with ORCL and disclose their clients on the statutory Register of Consultant Lobbyists (“the Register”).
3. A consultant lobbyist can, if applicable, state on the Register that it complies with a relevant code of conduct. One such code of conduct is the Public Affairs Code, which is administered by external body the PRCA Public Affairs Board.
4. The PRCA Public Affairs Board maintains its own register, the Public Affairs Register, where members disclose their public affairs clients.
5. Consultant lobbyist Hawthorn Advisors Ltd (“Hawthorn Advisors”), while a member of PRCA, isn’t a member of the PRCA Public Affairs Board. As such the firm hides its public affairs clients.
6. Hawthorn Advisors was founded in 2013 by Ben Elliot, co-chair of the Conservative Party, and John Evans. I last wrote about the well-connected firm, where Mr Evans is chief executive, on 15 April 2022.
7. The Public Affairs Code makes clear it applies to members of the Public Affairs Board only. So I was surprised to see Hawthorn Advisors says on the Register that it abides by the Public Affairs Code (see 10 January 2022 post).
8. After I brought the matter to ORCL’s attention, it amended Hawthorn Advisors’ entry on the Register to show no relevant code of conduct, while it sought a clarification from PRCA – something I’d already done. Back then I received contradictory responses from PRCA, however (see 10 January 2022 post).
9. Here’s the current version of the Public Affairs Code, downloaded from the PRCA Public Affairs Board website on 27 June 2022: https://dralexmay.wordpress.com/wp-content/uploads/2022/06/public-affairs-code-february-2021-23.2.2021.pdf.
10. Meanwhile, I recently noted Hawthorn Advisors again states on the Register that it complies with the Public Affairs Code (screen shot in Figure 1). Further, on 26 May 2022, ORCL said in an email: “Following a clarification from PRCA, all PRCA members are governed by the Public Affairs Code in their conduct of public affairs.”

Figure 1. Hawthorn Advisors Ltd: the Register of Consultant Lobbyists at 30 May 2022

11. Yet, as I say, the Public Affairs Code makes clear it applies to members of the Public Affairs Board only. How is it therefore possible for Hawthorn Advisors to subscribe to the Public Affairs Code?
12. I therefore emailed PRCA for comment in light of ORCL’s last email. Michael Collins, Head of Communications, didn’t respond to requests for comment.
13. I then told ORCL in an email I was surprised it is apparently happy with the latest information it received from PRCA. Why? Because the information is nonsensical in relation to the Public Affairs Code, which is published by the PRCA Public Affairs Board. There I also informed ORCL of PRCA’s non-response to my latest requests for comment, and offered to share the emails to PRCA.
14. By reply, ORCL wrote: “PRCA have provided assurance that all PRCA members are governed by the Public Affairs Code in their conduct of public affairs. If you have any further questions about the PRCA or the Public Affairs Board, you will need to direct them to the PRCA.”
15. A clear cop-out by ORCL. It is fully aware I’ve already communicated extensively with PRCA on this matter. As I’ve repeatedly made clear to ORCL, it – not PRCA – is responsible for ensuring the accuracy of the information on the statutory Register. That ORCL is apparently happy with the latest information it received from PRCA risks undermining the credibility of the Office.
16. Previously I’ve shown both the PRCA Public Affairs Board and its system of self-regulation for lobbyists lack credibility, given how it handled my complaint about the conduct of ex-lobbyist Paul Bristow MP (see 5 November 2020 post). Another case where the PRCA Public Affairs Board failed to deal appropriately with a complaint is that of former culture minister Ed Vaizey (Lord Vaizey) and lobbying firm FTI Consulting (see 10 September 2021 post).

Why did Paul Bristow MP remove interest from the register of MPs’ financial interests?

1. Ex-lobbyist Paul Bristow MP recently removed an interest from the register of MPs’ financial interests.
2. The register as at 19 April 2022 shows “two tickets with hospitality to Cheltenham Races, value £660” that the MP for Peterborough had recently received from Tracingboard Ltd, a company owned and run by Steve Dechan.
3. On 25 April 2022, I published a post about the new registered interest. There I revealed that the lobbying firm owned by the MP’s wife, Sara Bristow, continues to act for Platform-14, another of Mr Dechan’s firms. There is thus a demonstrable link between the MP’s activities and those of his wife’s lobbying firm.
4. Following publication of that post, Mr Bristow removed the registered interest from the register of MPs’ financial interests: it vanished in the next update (as at 3 May 2022). There is no record of the removal thereon.
5. I then asked the MP in emails why he’d removed the interest from the register. But answer, there came none. So much for transparency and accountability.
6. The conduct of Mr Bristow raises a general question. How many other MPs, if any, are also quietly deleting interests from the register, without explanation?
7. The Office of the Parliamentary Commissioner for Standards told me MPs are not required to record the removal of an interest on the register. The interest simply vanishes, without explanation. Blink and you’ll miss it.

Health secretary’s daughter works for consultant lobbyist engaging ministers and permanent secretaries on behalf of pharmaceutical companies

1. The daughter of Sajid Javid MP, the health secretary, works for a consultant lobbyist that is engaging ministers and permanent secretaries on behalf of pharmaceutical companies.
2. There is evidence Mr Javid was late registering an interest on the register of MPs’ financial interests.
3. On 31 May 2022, Mr Javid made the following disclosure under Category 10 (family members engaged in lobbying): “My daughter, Sophia Javid, is an Account Executive at Hanover Communications.”
4. However, Sophia Javid has been conducting public affairs activities for Hanover Communications since the quarter from 1 June 2021 until 31 August 2021, according to the PRCA Public Affairs Board register.
5. It therefore appears Mr Javid was late registering his daughter’s job with the lobbying firm.
6. Meanwhile, the Office of the Registrar of Consultant Lobbyists defines consultant lobbying as lobbying of ministers and permanent secretaries on behalf of a third party, in return for payment.
7. Hanover Communications currently has six such clients, according to the latest update of the statutory register of consultant lobbyists (January to March 2022): American Pharmaceutical Group; Bristol Myers Squibb; Infection Management Coalition; Lilly; Northern Health Science Alliance; and Valero.
8. The first four are pharmaceutical companies or groups thereof. While the Northern Health Science Alliance, as its name suggests, is health-related: it is “a health and life sciences partnership between the leading NHS trusts, universities and Academic Health Science Networks in northern England”.
9. Valero, by contrast, is a US energy company. It is “the largest independent petroleum refiner in the world and the world’s second largest renewable fuels producer”.
10. Mr Javid as health secretary has a conflict of interest, actual, potential, or perceived, because his daughter works for a consultant lobbyist that is engaging ministers and permanent secretaries on behalf of both pharmaceutical companies and the North’s health sciences, which work closely with industry.
11. The Department of Health and Social Care didn’t respond to requests for comment.
12. A spokesperson for Hanover Communications said in an email: “Hanover abides by the PRCA Public Affairs Code, which covers disclosure of consultants and conflict of interest. Sophia does not work in our healthcare team, nor with any health and social care clients – to suggest otherwise is incorrect.”

Tom Tugendhat MP accepts £10k donation from China-focused company behind education bond for Chinese students in UK

1. On 14 April 2022, senior Conservative MP Tom Tugendhat accepted a £10k donation from InvestUK (Group) Ltd (“InvestUK”) “to pay for an extra member of staff to support my work as the chair of the foreign affairs committee”, according to the register of MPs’ financial interests.
2. Mr Tugendhat is also co-founder and co-chair of the China Research Group (“CRG”) of Tory MPs, which was established in April 2020 “to promote debate and fresh thinking about how Britain should respond to the rise of China”.
3. As both chair of the prominent Commons committee and co-chair of CRG, Mr Tugendhat has repeatedly warned about Chinese influence on both UK companies and universities, among other areas.
4. In September 2021, for instance, Mr Tugendhat wrote a strongly-worded article in The Times newspaper raising the alarm about Chinese influence on UK universities and research institutions (“British universities are too reliant on Chinese money”). Our universities are too dependent on Chinese students was one message.
5. InvestUK is a China-focused company founded by Rupert Gather, who is executive chair and sole “person with significant control”. It is “the UK’s leading foreign direct investment specialist”, boasts the website. Mr Gather states on his LinkedIn profile: “Clients [of InvestUK] come from all over the world but are strongly weighted to China.” (screen shot in Figure 1)

Figure 1. Rupert Gather: LinkedIn profile at 31 May 2022

6. The InvestUK website shows the firm is a member of both the China-Britain Business Council and the British Chamber of Commerce in China.
7. Among other products and services, InvestUK offered an education bond – “a £1 billion opportunity designed for Chinese students in the UK, aiming to combine the three key drivers of UK education, property investment and the ability to earn permanent residence into one simple, secure product” (Figure 1).
8. On 9 August 2018, InvestUK tweeted a photo of Mr Gather giving a speech in Hong Kong about the education bond (screen shot in Figure 2).

Figure 2. InvestUK tweet dated 9 August 2018

9. There his company tagged The UK Education Bond (@edbonduk), whose Twitter biography proclaims: “This programme is a smart way for international students to finance a UK education by investing in the UK while qualifying for permanent residency.” (screen shot in Figure 3)

Figure 3. The UK Education Bond: Twitter biography at 31 May 2022

10. The @edbonduk Twitter biography also links to more information about the education bond, which is published on the Hilden Associates website (screen shot in Figure 4).

Figure 4. The UK Education Bond: information on Hilden Associates website at 31 May 2022

11. Hilden Associates, a “global independent financial services distribution/consultancy company” (screen shot in Figure 5), is, we are told, located in south-west England (Figure 3). Companies House records show Hong Kong resident Matt Denness is owner and sole director of Hilden Associates UK Ltd, whose registered office address is the trading address of a Dorset accounting firm. The phone number on the Hilden Associates website is a Hong Kong one, although this isn’t disclosed (screen shot in Figure 6).

Figure 5. About us page: Hilden Associates website at 1 June 2022

12. Hilden Associates UK Ltd was and continues to be an active company. Its Companies House filings are up to date.

Figure 6. Contact us page: Hilden Associates website at 1 June 2022

13. In the UK, nearly all financial service activities must be authorised by City watchdog the Financial Conduct Authority (“FCA”). Hilden Associates UK Ltd is an unauthorised financial services firm: it isn’t listed on the FCA financial services register.
14. Following my first email to him, Mr Denness deleted both the @edbonduk Twitter account and the education bond page on the Hilden Associates website. He said in an email: “…we did not promote the product in the UK as we knew we were not regulated. We also had the required disclaimers in place. All my potential clients were and are overseas. No promotion was done in the UK.” As to the tweet by InvestUK dated 9 August 2018, Mr Denness wrote: “If Mr Gather wishes to tag us then so be it.”
15. Yet anyone in the UK could access the information about the education bond – the financial promotion – on the Hilden Associates website.
16. The “required disclaimers” are not sufficient. In other words, the information about the education bond on the Hilden Associates website was an unauthorised financial promotion.
17. The Hilden Associates website soon vanished; and at date of publication remains unavailable.
18. InvestUK (Group) Ltd doesn’t appear on the financial services register, either. Yet Mr Gather does as an individual, where it states: “regulatory approval no longer required”. The register shows he was connected to three firms: Anglo-Sino Capital Partners Ltd, Claridge Capital Partners LLP and InvestUK Ltd.
19. On 13 February 2022, I revealed that Mr Tugendhat is a shareholder of two independent tech companies where China-linked billionaire Nicolas Berggruen is a fellow investor.
20. Mr Tugendhat is right to be concerned about the rise of China, and UK universities’ over-dependence on Chinese students in particular. So it is surprising the MP is happy to accept funding from InvestUK, a China-focused firm whose products and services included an education bond for Chinese students in the UK. What’s more, InvestUK used an unauthorised financial services firm to promote its education bond.
21. When asked for comment, Simon Peacock, InvestUK Operations Director, said in an email: “There is little we can comment on other than to clarify that we were involved in developing a product that we named The Education Bond which we had enlisted the help of Hilden Associates to communicate this product to their network in Hong Kong back in 2018. The Education Bond briefing session shown in the tweet was not a sales pitch, it was simply information sharing as part of a wider communication strategy explaining the benefits of setting up a business and/or working in the United Kingdom. The Education Bond never formally went to market and in any event is now defunct.”
22. Mr Peacock added: “Unfortunately, I was unable to find the Hilden Associates (UK) website and the reference they have made to the Education Bond but we have written to the principal to remind them that it is no longer operative and must not be referred to in any marketing materials.”
23. Mr Tugendhat didn’t respond to requests for comment.

The Mail on Sunday picks up Parliamentary Commissioner for Standards’ verdict on the conduct of boxing APPG and its chair Chris Evans MP

1. On 12 June 2022, The Mail on Sunday newspaper picked up the Parliamentary Commissioner for Standards’ verdict on the conduct of the boxing all-party parliamentary group (“APPG”) and its chair, Labour MP Chris Evans (see previous post) (screen shot in Figure 1).

Figure 1. The Mail on Sunday (12 June 2022)

Parliamentary Commissioner for Standards upholds my complaint about the conduct of boxing APPG and its chair Chris Evans MP

1. On 8 June 2022, the Parliamentary Commissioner for Standards, Kathryn Stone, upheld my complaint about the conduct of the boxing all-party parliamentary group (“APPG”) and its chair, Labour MP Chris Evans (see 20 February 2022 post).
2. Here’s the Commissioner’s report: https://www.parliament.uk/globalassets/documents/pcfs/rectifications/rectification-appg-boxing-mr-chris-evans-mp.pdf.