Dentons Global Advisors shows the PRCA Public Affairs Code is meaningless

1. On 6 February 2024, I showed that consultant lobbyist Dentons Global Advisors (“DGA”) appears to have breached the PRCA Public Affairs Code.
2. The Public Relations and Communications Association (“PRCA”) is the leading trade body for the PR industry, billing itself as “the world’s largest professional PR body”.
3. DGA lists James Price as a public affairs practitioner on the latest PRCA Public Affairs Register.
4. Meanwhile, Mr Price also works as an MP’s staffer, and possesses a parliamentary pass. Not any old MP – former chancellor Nadhim Zahawi, the Conservative MP for Stratford-on-Avon.
5. The PRCA Public Affairs Code, a relevant code of conduct, expressly forbids public affairs practitioners holding a parliamentary pass. Thus it would appear DGA has breached the PRCA Public Affairs Code.
6. On 7 February 2024, I therefore complained to PRCA, which acknowledged receipt the next day.
7. On 19 February 2024, meanwhile, I received another email from DGA – this time from Katherine Morgan, a partner at the consultant lobbyist. Ms Morgan wrote: “Further to your earlier email regarding James Price, we immediately approached the PRCA to clarify matters noting that it was an oversight and a genuine mistake on our behalf. The PRCA have since provided advice, which we have acted on swiftly to ensure that we are compliant with the Code.”
8. By same-day reply, I asked Ms Morgan the following three questions that arise from what she wrote.
9. First, it appears Ms Morgan has plagiarized what consultant lobbyist Beyond 2050 Ltd said to me in an email on 4 August 2023 (see 4 August 2023 post). Why the plagiarism?
10. Second, if DGA, as she says, “immediately approached the PRCA” upon receipt of my earlier emails, why didn’t her colleague Francis Mallinson tell me this in his responses?
11. Third, the register of interests of MPs’ staff has recently been updated: it’s now as at 16 February 2024. There Mr Price continues to work for MP Mr Zahawi. Thus the former still has a parliamentary pass, despite also working for DGA. What, if anything, has really changed?
12. In response, Ms Morgan said in an email: “As I note below [referring to her previous message], DGA has approached the PRCA to notify them that this was a mistake and oversight on our behalf. We have acted swiftly to ensure we are compliant with the PRCA code. James Price is a senior advisor to DGA and does not directly advise clients.”
13. Thus Ms Morgan failed to answer the three questions.
14. On 20 February 2024, meanwhile, I heard again from PRCA. Louise Whatham, senior public affairs and policy manager, wrote: “Further to your email on Wednesday the 7th February, we are writing to let you know that the PRCA doesn’t comment on individual complaints, but we understand that Dentons Global Advisors have been in touch to respond to you.”
15. So much for transparency and accountability. The secrecy only undermines trust and confidence in PRCA and its Public Affairs Code.
16. I confirmed to Ms Whatham that I had indeed received a further response from DGA – but added it was inadequate and only raised more questions. I then shared with Ms Whatham my latest exchange with DGA, inviting comment. PRCA didn’t respond.
17. As I asked both DGA and PRCA: What, if anything, has really changed?
18. ADDENDUM: Unfortunately, this is only my latest unsatisfactory experience with PRCA. For another, please see “Is PRCA a serious organisation?” (5 June 2023).
19. What’s more, following my experience with PRCA and its Public Affairs Code on the Beyond 2050 Ltd case (see 4 August 2023 post), I wrote to the Registrar of Consultant Lobbyists, Harry Rich.
20. The Registrar is responsible for keeping and publishing the statutory Register of Consultant Lobbyists. All consultant lobbyists must be registered.
21. Yes, Mr Rich has nothing to do with PRCA. But his register lends credibility to the organisation and its Public Affairs Code, by permitting registrants to disclose the latter as a relevant code of conduct.

Policing minister fails to register all relevant shareholdings

1. Policing minister Chris Philp MP lists shareholdings in six companies on the register of MPs’ financial interests. One of these is Millgap Ltd, whose business is “consulting, advisory and investment”, says Mr Philp.
2. Companies House records show the minister is owner and sole director of Millgap Ltd, which is a private limited company.
3. “Millgap is not actively trading but holds co-investments in the Pluto group of companies on behalf of the minister,” according to the latest list of ministers’ interests, as at December 2023. There Mr Philp doesn’t disclose the companies whose shares he holds via Millgap Ltd this way.
4. I quickly found two of the firms at Companies House: Stretch Senior Co-Invest Ltd and HL Stretch Co-Invest Ltd.
5. In both cases, Millgap Ltd is a “person with significant control”, owning more than 25 per cent of the shares. Thus both should be registered under Category 7 on the register of MPs’ financial interests, given the threshold for registration is 15 per cent of issued share capital. Yet neither is shown on the register of MPs’ financial interests.
6. The shares in both companies are therefore not held by the minister as an individual. Rather, they are held by Millgap Ltd, where Mr Philp has full control. The arrangement is about administration only: how the minister organises his personal shareholdings.
7. On 27 January 2022, meanwhile, the members of Stretch Senior Co-Invest Ltd began winding up the company. It is due to be dissolved on 7 March 2024, according to Companies House records. For the avoidance of doubt, this is a members’ voluntary liquidation – an event that can only take place if the company is solvent.
8. As a member of Stretch Senior Co-Invest Ltd, Mr Philp was, by definition, involved in the decision to wind up the company voluntarily. The minister’s involvement in the process shows he isn’t merely a passive investor in the firm.
9. Mr Philp has no other roles, according to the register of MPs’ financial interests. Yet his involvement in the members’ voluntary liquidation of Stretch Senior Co-Invest Ltd raises serious questions about his business activities outside of parliament. Here there needs to be clarity and transparency, not opacity.
10. For a start, Mr Philp should tell us whether he (partially) controls any other companies via Millgap Ltd this way.
11. Mr Philp didn’t respond to requests for comment.
12. On 29 November 2022, Labour MP Sir Chris Bryant, the then chair of the Commons standards committee, called attention to what he considers Mr Philp’s inadequate disclosures on both the list of ministers’ interests and the register of MPs’ financial interests. Sir Chris was speaking in a Westminster Hall debate on the Ministerial Code.

Has James Price breached the business appointment rules?

1. More on lobbyist James Price, who works for former chancellor Nadhim Zahawi, the Conservative MP for Stratford-on-Avon, and possesses a parliamentary pass (see previous post).
2. On 29 January 2023, Mr Price left the Civil Service, quitting his role as a special adviser to minister Mr Zahawi, according to business appointment rules advice published on the Cabinet Office website. This also shows the department approved Mr Price’s application for business appointment rules advice for two new “senior adviser” roles: one with lobbying firm Dentons Global Advisors (“DGA”) (screen shot in Figure 1); the other at the Adam Smith Institute (“ASI”), the leading thinktank (screen shot in Figure 2).

Figure 1. James Price business appointment rules advice – Dentons Global Advisors: Cabinet Office website

3. In both cases, the Cabinet Office issued the standard two-year lobbying ban. So what happened?

Figure 2. James Price business appointment rules advice – Adam Smith Institute: Cabinet Office website

4. On 13 June 2023, Mr Price joined DGA (Figure 1) – less than five months after leaving the Civil Service!
5. Has Mr Price therefore breached the two-year lobbying ban?
6. That he was and is working for a consultant lobbyist before expiry of the ban doesn’t necessarily mean Mr Price was and is personally involved in lobbying government, of course. Nevertheless it is reasonable to ask whether he is lobbying government, given that’s what DGA does!
7. Meanwhile, what does Mr Price actually do at ASI? He’s “director of government engagement” (screen shot in Figure 3)! From job title, it’s difficult to see how his thinktank post is permitted under the two-year lobbying ban.

Figure 3. James Price is “director of government engagement”: Adam Smith Institute website

8. Further, is Mr Price paid for his role at ASI? If so, he must register the job on the register of interests of MPs’ staff. For the avoidance of doubt, Mr Price has registered his post at DGA (see previous post).
9. Boss Mr Zahawi has been a “patron” of ASI since 14 June 2023, according to the register of MPs’ financial interests. Mr Price joined the thinktank six days later (Figure 2). Small world!
10. Mr Price didn’t respond to requests for comment.

Ex-chancellor’s staffer with parliamentary pass also works for lobbying firm

1. The latest register of interests of MPs’ staff, as at 5 January 2024, shows James Price works for former chancellor Nadhim Zahawi, the Conservative MP for Stratford-on-Avon, and possesses a parliamentary pass.
2. There Mr Price discloses another paid role: “senior advisor” at Dentons Global Advisors (“DGA”), a firm, he says, that provides “integrated advisory services”.
3. Registered as a consultant lobbyist, DGA complies with the PRCA Public Affairs Code, according to the statutory Register of Consultant Lobbyists, which is maintained by the Office of the Registrar of Consultant Lobbyists.
4. The Public Relations and Communications Association (“PRCA”) is the leading trade body for the PR industry, billing itself as “the world’s largest professional PR body”.
5. However, the PRCA Public Affairs Code, a relevant code of conduct, expressly forbids public affairs practitioners holding a parliamentary pass.
6. Thus it would appear DGA has breached the PRCA Public Affairs Code.
7. There’s no suggestion that anyone has done anything illegal.
8. When asked for comment, Francis Mallinson of DGA said in an email: “As you note, Mr Price is a Senior Advisor to DGA, he does not directly advise clients.”
9. By reply, I pointed out DGA lists James Price as a public affairs practitioner on the latest PRCA Public Affairs Register (screen shot in Figure 1). I then repeated the fact that the PRCA Public Affairs Code expressly forbids public affairs practitioners holding a parliamentary pass (see para 15). The PRCA Public Affairs Code is clear on this point.

Figure 1. James Price is listed by Dentons Global Advisors on current PRCA Public Affairs Register (from 1 September 2023 until 1 December 2023)

10. Mr Mallinson responded: “As we have said, Mr Price is a Senior Advisor to DGA, he does not directly advise clients.”
11. DGA began providing consultant lobbying services after acquiring lobbying firm Interel (see 24 January 2020 post).
12. On 1 August 2023, I revealed that a staffer of the then City minister, Andrew Griffith MP, also worked for a lobbying firm.

The Standards Commissioner & Angela Rayner MP: a secret intervention

1. On 18 December 2023, I complained to the Parliamentary Commissioner for Standards about the conduct of Angela Rayner MP in relation to registration of interests.
2. There I identified two problems with Ms Rayner’s entry on the register of MPs’ financial interests. Here I wrote about one of the problems (see 3 January 2024 post).
3. On 17 January 2024, I received a letter from the Commissioner, Daniel Greenberg. He said it “would not be proportionate” to investigate my complaint. Mr Greenberg added: “Instead, I have decided to resolve this matter using one of the alternative resolutions available to me under Standing Order No.150.”
4. So that was the end of that.
5. Meanwhile, the latest update of the register of MPs’ financial interests, as at 22 January 2024, shows Ms Rayner addressed the two problems via “updates” on 17 January 2024.
6. As far as I’m aware, there is no public record of Mr Greenberg’s intervention and what prompted it. Thus the public is simply unaware of what has happened: both process and outcome are hidden.
7. What’s more, the lack of transparency is presumably not limited to the case of Ms Rayner. Thus the public has no idea of how often the Commissioner intervenes this way.
8. The secrecy risks undermining trust and confidence in both MPs and the parliamentary standards system.
9. I wrote again to Mr Greenberg, making these points. By reply, his office wrote: “The Commissioner has noted your remarks, but he will not comment further and the matter is now closed.”