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.files.wordpress.com/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
  1. 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?
  2. 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.
  3. 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.
  4. 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.”
  5. 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.
  6. 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).

Third Sector reports my exposé of V&A trustee Ben Elliot

  1. On 26 May 2022, Third Sector, “the UK’s leading brand for charity professionals”, reported my exposé of V&A trustee Ben Elliot (see 12 March 2022 post).
  2. Here’s the article, “V&A urged to address alleged conflicts of interest after trustee hosted private events at museum”: https://www.thirdsector.co.uk/v-a-urged-address-alleged-conflicts-interest-trustee-hosted-private-events-museum/governance/article/1787847.

Is Rory Brooks a shareholder of Quintessentially (UK) Ltd?

  1. Rory Brooks, chair of private equity group MML Capital Partners, is also a philanthropist and major Tory donor. There is conflicting information on the public record whether Mr Brooks is a shareholder of Quintessentially (UK) Ltd.
  2. In 2000, Ben Elliot, co-chair of the Conservative Party, co-founded the global Quintessentially Group, and continues to serve as a director of UK-registered Quintessentially (UK) Ltd (“Quintessentially”). Quintessentially is a luxury concierge service for the super-rich: members access its “global network of personal lifestyle managers”, who “are ready to bring every wish, new and old, big and small, to fruition”.
  3. Mr Elliot served as chair of linked charity Quintessentially Foundation (“QF”) from 2008 until 2020, and remains a trustee. Mr Brooks succeeded Mr Elliot as QF chair.
  4. On 19 February 2019, I revealed QF spent £2.15m in 2017 – but just £1.12m (51.9 per cent) went to other charities. QF is a grant-making charity that supports other charities only.
  5. Mr Brooks is a shareholder of Quintessentially, according to the “related-party disclosures” note in the latest accounts for QF, those made up to 31 December 2020.
  6. However, Mr Brooks’ name does not appear in the list of Quintessentially shareholders disclosed in the firm’s “confirmation statement” at Companies House dated 16 November 2021.
  7. If Mr Brooks had ceased to be a shareholder since the date of the previous confirmation statement, 16 November 2020, his name would still be listed in the document dated 16 November 2021. The confirmation statement dated 16 November 2020 reports no changes from the previous year.
  8. At date of publication the accounts for Quintessentially are long overdue: the next accounts, those made up to 30 April 2020, were due by 30 April 2021.
  9. QF and Mr Brooks didn’t respond to requests for comment.

Hawthorn Advisors acted for two energy producers in run-up to new energy security strategy

  1. In 2013, Ben Elliot, co-chair of the Conservative Party, and John Evans founded consultant lobbyist Hawthorn Advisors Ltd (“Hawthorn Advisors”). I last wrote about the well-connected firm, where Mr Evans is chief executive, on 10 January 2022.
  2. As a consultant lobbyist, Hawthorn Advisors must register with the Office of the Registrar of Consultant Lobbyists (“ORCL”) and disclose its clients on the statutory Register of Consultant Lobbyists (“the Register”).
  3. The latest update of the Register – January to March 2022 – shows the lobbying firm has started acting for two energy producers: IGas Energy PLC (“IGas”) and Newcleo Ltd (“Newcleo”).
  4. For the avoidance of doubt, neither company was shown as a client the previous quarter, October to December 2021.
  5. IGas is “a leading onshore oil and gas exploration and production business,” according to its website. Newcleo, meanwhile, is developing a new type of nuclear power technology, enabling better reactors.
  6. The ORCL defines consultant lobbying as lobbying of ministers and permanent secretaries on behalf of a third party, in return for payment. Therefore, Hawthorn Advisors is now lobbying ministers and permanent secretaries on behalf of the two energy producers, among others. (The others continue to include Huawei, the controversial Chinese tech giant.)
  7. Then there is Guto Harri.
  8. In February 2022, Mr Harri quit as a board director of Hawthorn Advisors to become the prime minister’s director of communications. Mr Harri was thus still working for the lobbying firm when it acquired IGas and Newcleo as clients.
  9. Concern rightly persists about the exact relationship between Mr Elliot’s role as Tory co-chair and the activities of his firm Hawthorn Advisors. Equally, there should be scrutiny of Mr Harri now he’s at Number 10.
  10. The latest update of the Register is the last to overlap with Mr Harri’s time at the lobbying firm. What a pity he didn’t see fit to wait before becoming the prime minister’s director of communications.
  11. By happy chance, the government finally published its long-delayed energy security strategy on 7 April 2022.
  12. The ambition to build “up to eight new nuclear reactors” this decade was the policy paper’s “most eye-catching announcement,” said The Times in its leader the following day. The newspaper was far from convinced: “The number eight appears to have been plucked out of the air.” One thing we do know, though, is that Newcleo – thanks to Hawthorn Advisors – had the ears of ministers in the weeks before the government’s new energy security strategy finally appeared.
  13. And what of onshore oil and gas? On 5 April 2022, the government announced that it has commissioned the British Geological Survey to advise on the latest scientific evidence around shale gas extraction. Its report is “expected before the end of June 2022”. In its same-day response, IGas welcomed the news – chief executive Stephen Bowler said in a regulatory filing: “This is a significant development by the government and we welcome the opportunity to demonstrate how shale gas can provide safe, secure and affordable energy for the UK.” Money well spent on Hawthorn Advisors, Mr Bowler?

Ben Elliot, the Royal Albert Hall and the Prince’s Foundation

  1. More on Ben Elliot, co-chair of the Conservative Party, and his roles at charities that run world-leading cultural assets in London.
  2. In addition to his post as a trustee of the Victoria and Albert Museum (“V&A”) (see 12 March 2022 post), Mr Elliot is chair of the Philanthropy Board of the charity that maintains concert venue the Royal Albert Hall (“RAH”), the Corporation of the Hall of Arts and Sciences. Both the V&A and RAH are located in swanky South Kensington, central London.
  3. At date of publication the Philanthropy Board is mentioned only once on the RAH website, where its members are listed (screen shot in Figure 1).
Figure 1. Philanthropy Board: Royal Albert Hall website at 11 March 2022
  1. The Philanthropy Board appears to have been established in 2017, as it was first referred to in the RAH annual report for that year. Mr Elliot has been chair since then.
  2. The Philanthropy Board, as its name suggests, is involved in fundraising. The latest annual report, for 2020, says: “The Philanthropy Board performs an introductory function, allowing the [fundraising] team to meet more potential supporters with an interest in the Royal Albert Hall.”
  3. As Tory co-chair, Mr Elliot is party fundraiser.
  4. Yet another of Mr Elliot’s interests is international group Quintessentially, which he co-founded in 2000 (see 12 March 2022 post). Mr Elliot remains as a director of Quintessentially, which provides a luxury concierge service for the super-rich.
  5. Quintessentially has an office in Moscow, while its London service has previously boasted of its wealthy Russian clients. Further, Russian oligarch Roman Abramovich, the sanctioned billionaire owner of Chelsea Football Club, was a member of Quintessentially.
  6. It is reported that Quintessentially has now closed its Moscow office in the wake of Russia’s unprovoked and premeditated invasion of Ukraine.
  7. Given Quintessentially’s Russian clients and Mr Elliot’s role at RAH, a couple identified as a “major donor” on the RAH website deserves scrutiny: Oleg and Galina Smirnov (screen shot in Figure 2). It is reasonable to ask whether the Russian couple are or have been Quintessentially clients.
Figure 2. Oleg and Galina Smirnov are a “major donor”: Royal Albert Hall website at 11 March 2022
  1. Billionaire Mr Smirnov is co-founder of the SNS Group of companies, a leading distributor of cigarettes, energy drinks and other products in Russia.
  2. In January 2016, the Tories received a donation of £100k from Global Functional Drinks Ltd, a UK subsidiary of Swiss firm Global Functional Drinks AG, which is in turn controlled by SNS Group.
  3. The Smirnovs have also donated to the Prince’s Foundation, a scandal-hit charity registered in Scotland. Their donation went towards the charity’s Dumfries House in Scotland (screen shot in Figure 3).
Figure 3. Oleg and Galina Smirnov are “supporters”: Prince’s Foundation website at 11 March 2022
  1. Prince Charles is president of the Prince’s Foundation. That the couple have also supported one of Prince Charles’ charities is another reason it is reasonable to ask whether they are or have been Quintessentially clients.
  2. Mr Elliot is nephew of Camilla, Duchess of Cornwall, who is married to Prince Charles.
  3. Last year, Tory donor Mohamed Amersi alleged that Mr Elliot had arranged for him to have dinner with Prince Charles at Dumfries House back in 2013. At the time an “elite” member of Quintessentially, shelling out £15k per year, Mr Amersi went on to donate to Prince Charles’ charities. Mr Amersi says Mr Elliot via Quintessentially operates an “access capitalism” system. Others have called it “cash for access”.
  4. Also last year, the Prince’s Foundation became engulfed in an alleged “cash-for-honours” scandal involving a billionaire Saudi donor, leading to the resignation of both its chair and chief executive. Charity watchdog the Office of the Scottish Charity Regulator duly opened an investigation into the Prince’s Foundation and its governance. The investigation is ongoing.
  5. In February 2022, the Metropolitan Police announced it, too, had begun its own investigation into the Prince’s Foundation.
  6. There is no suggestion anyone has done anything illegal. For the avoidance of doubt, I am not anti-Russian.
  7. I asked RAH the following three questions in emails. First, did Mr Elliot “introduce” the Smirnovs to RAH? Second, have the Smirnovs ever been Quintessentially clients? Third, how many of the potential donors “introduced” to RAH by Mr Elliot are or have been Quintessentially clients?
  8. RAH didn’t answer the questions or provide a comment.
  9. Meanwhile, I put the following two questions to the Prince’s Foundation. First, has Mr Elliot and/or Quintessentially ever arranged for Prince’s Foundation donors the Smirnovs to meet Prince Charles? Second, has Mr Elliot and/or Quintessentially ever arranged for any Prince’s Foundation donors, actual or potential, to meet Prince Charles?
  10. Again, the Prince’s Foundation didn’t answer the questions or provide a comment.
  11. Mr Smirnov didn’t respond to requests for comment, either. Nor did Mr Elliot.

V&A trustee Ben Elliot hosts Quintessentially events at museum about exhibitions

  1. Ben Elliot, co-chair of the Conservative Party, has been a trustee of charity the Victoria and Albert Museum (“V&A”) since 2017.
  2. In 2000, Mr Elliot co-founded the global Quintessentially Group, and continues to serve as a director of UK-registered Quintessentially (UK) Ltd (“Quintessentially”). Quintessentially is a luxury concierge service for the super-rich: members access its “global network of personal lifestyle managers”, who “are ready to bring every wish, new and old, big and small, to fruition”.
  3. In 2018, the V&A staged an exhibition about Mexican artist Frida Kahlo, which ran from 16 June until 18 November (“Frida Kahlo: Making Her Self Up”). On 18 June 2018, Mr Elliot hosted a Quintessentially event at the museum: “a special breakfast and behind-the-scenes talk” on the new exhibition (screen shot in Figure 1).
Figure 1. Quintessentially event at the V&A in 2018 for its Frida Kahlo exhibition: company website at 10 March 2022
  1. The next year, Quintessentially members were invited to attend Mr Elliot’s event at the V&A to mark the opening of its Christian Dior exhibition, which ran from 2 February until 1 September (“Christian Dior: Designer of Dreams”). The Quintessentially breakfast took place on 21 March 2019 (screen shot in Figure 2).
Figure 2. Quintessentially event at the V&A in 2019 for its Christian Dior exhibition: company website at 10 March 2022
  1. The V&A’s financial year runs from 1 April until to 31 March the following year.
  2. The related-party transactions note in the V&A accounts made up to 31 March 2019 – the 2018 accounts – shows Quintessentially paid £1k to the charity that year – but the accounts omit to disclose the reason(s) for the transaction.
  3. Both Mr Elliot’s event for the Kahlo exhibition and that for the Dior one occurred in the financial year reported in the 2018 accounts. Nevertheless the relationship, if any, between the £1k transaction and the two events is unclear.
  4. Meanwhile, the related-party transactions note in the V&A accounts made up to 31 March 2020 – the 2019 accounts – reveals Quintessentially once more paid £1k to the charity the next year – but again no reason(s) for the transaction is reported.
  5. Mr Elliot has multiple roles, and interests in multiple businesses. One such is Hod Hill Ltd (“Hod Hill”), which he owns and where he is one of two directors.
  6. Jakob Widecki, the other director, used to work for Quintessentially, The Times newspaper reported in August 2021. In addition to his Hod Hill role, Mr Widecki has a post in Mr Elliot’s team at Conservative headquarters.
  7. Incorporated on 8 May 2015, Hod Hill is opaque: the firm doesn’t have a website, for example. What’s more, Mr Elliot omits to mention Hod Hill in his Who’s Who 2022 entry.
  8. However, the related-party transactions note in the V&A accounts made up to 31 March 2018 – the 2017 accounts – shows Hod Hill paid £1k to the charity that year. Again, the accounts fail to explain the transaction.
  9. V&A trustee Mr Elliot is using his unpaid role at the charity to derive personal benefit via his commercial companies. It is astonishing the board of trustees is allowing this to happen. What’s more, the V&A is a world-leading institution, one whose trustees are appointed by the prime minister.
  10. Equally concerning is the lack of transparency in the V&A accounts for the basis of the transactions between Mr Elliot’s businesses and the charity. The non-disclosure is unacceptable.
  11. The V&A is a non-departmental public body sponsored by the Department for Digital, Culture, Media & Sport (“DCMS”), and a charity exempt from registration under the Charities Act of 2011.
  12. There is no suggestion anyone has done anything illegal.
  13. When asked for comment, a spokesperson for the V&A said in an email: “We work closely with a number of corporate partners to hold paid-for events within the V&A which allows us to offer a rich series of experiences and access to our collections, such as early morning views to our award-winning exhibition programme.”
  14. They continued: “In all instances of working with corporate partners, including those events that you referenced below, our partners pay fees which are clearly documented within our accounts.”
  15. Mr Elliot, by contrast, didn’t respond to requests for comment.

Has Hawthorn Advisors made an inaccurate disclosure on the Register of Consultant Lobbyists about compliance with relevant code of conduct?

  1. In 2013, Ben Elliot, co-chair of the Conservative Party, and John Evans founded consultant lobbyist Hawthorn Advisors Ltd (“Hawthorn Advisors”). I last wrote about the well-connected firm, where Mr Evans is chief executive, on 3 April 2021.
  2. As a consultant lobbyist, Hawthorn Advisors must register with the Office of the Registrar of Consultant Lobbyists (“ORCL”) and disclose its clients on the statutory Register of Consultant Lobbyists (“the Register”).
  3. Hawthorn Advisors states on the Register that there’s “in place an undertaking by this organisation to comply with a relevant code of conduct” (screen shot in Figure 1).
Figure 1. Hawthorn Advisors Ltd: the Register of Consultant Lobbyists at 11 November 2021
  1. Hawthorn Advisors declares a relevant code of conduct: the Public Affairs Code, which is published by the PRCA Public Affairs Board. There the firm says it “adheres to the Public Affairs Code”.
  2. Meanwhile, it’s a matter of public record that Hawthorn Advisors isn’t a member of the Public Affairs Board: the firm doesn’t appear on the Public Affairs Board’s Public Affairs Register.
  3. Which is a problem for Hawthorn Advisors and its relation to the Public Affairs Code. Koray Camgoz, Director of Communications and Marketing at the PRCA, said in an email: “Companies that are not PRCA Public Affairs Board members are not permitted to declare that they adhere to the Public Affairs Code.” (For the avoidance of doubt, Mr Camgoz wasn’t commenting on Hawthorn Advisors. It was a general comment.)
  4. Therefore, it appears that Hawthorn Advisors has made an inaccurate disclosure on the Register in relation to relevant code of conduct.
  5. What’s more, ORCL apparently failed to check whether Hawthorn Advisors is a member of the Public Affairs Board.
  6. In November 2021, I brought these issues to the attention of ORCL in an email. It responded: “Further to this, when registrants declare the Public Affairs Code, we check with the PRCA. You are right that Hawthorn Advisors do not appear on the Public Affairs Board register and thank you for raising this with us. The PRCA have assured us that Hawthorn Advisors subscribe to their Public Affairs Code and are resolving this issue.”
  7. At the same time, I went back to the PRCA for comment, when Michael Collins, Head of Communications, wrote: “I can confirm that due to a rare admin error, Hawthorn Advisors did not appear on the [PRCA Public Affairs Board] register. We are working to correct the issue now.”
  8. Back at ORCL: in December 2021, I noticed a change on the Register for Hawthorn Advisors. The section entitled “Relevant code of conduct details” has been amended. No code of conduct is now declared (screen shot in Figure 2).
Figure 2. Hawthorn Advisors Ltd: the Register of Consultant Lobbyists at 24 December 2021
  1. Thus I asked ORCL to comment on its earlier statement in light of the fact that Hawthorn Advisors no longer declares a relevant code of conduct. By reply, ORCL wrote: “That is right, the PRCA have assured us that Hawthorn Advisors subscribe to their Public Affairs Code and are resolving this issue. We have marked as no relevant code of conduct while this is being resolved.”
  2. At the turn of the year the PRCA Public Affairs Board duly published its updated register – that for 1 September 2021 until 30 November 2021. Again, at date of publication Hawthorn Advisors isn’t listed.
  3. Without reference to the new update, I asked Mr Collins in an email whether his organisation stood by his previous comment. His response: “Yes, correct, our position remains the same.”
  4. I then pointed out that Hawthorn Advisors continues not to appear on the Public Affairs Board’s Public Affairs Register; and asked him why.
  5. Mr Collins didn’t reply this time, despite a reminder.
  6. Mr Evans didn’t respond to requests for comment.

The PM, Daylesford and Hawthorn Advisors

  1. Today (5 March 2021) the first four pages of the Daily Mail newspaper have more revelations about prime minister Boris Johnson and girlfriend Carrie Symonds, and their life in Downing Street.
  2. The headline across p2-3 is “Takeaways for Boris and Carrie from UK’s poshest farm shop… costing £12 500”. The “UK’s poshest farm shop” is one of a range of shops operated by Daylesford Organic Limited (“Daylesford”).
  3. Daylesford is owned by its founder, Lady Bamford, who is married to JCB magnate Lord Bamford. The billionaire peer is a major Tory donor.
  4. Ruth Kennedy is a director of Daylesford, according to Companies House records.
  5. On 27 January 2021, I revealed that Ms Kennedy, also known as Lady Dundas, owns Ben Elliot’s Hawthorn shares in a trust.
  6. Mr Elliot, co-chair of the Conservative Party, is co-founder of Hawthorn Advisors, the well-connected, though opaque, political lobbyist.
  7. Ms Kennedy appeared on the Hawthorn website as a “board advisor”, but then vanished (see 27 January 2021 post).
  8. On 8 July 2020, the Daily Mirror newspaper quoted the Conservative Party: “Ben Elliot has nothing to do with the running of Hawthorn or its clients.”
  9. As the owner of Mr Elliot’s Hawthorn shares in a trust, Ms Kennedy is acting in his interest with his authority. In addition, she is or was a “board advisor”.
  10. Mr Elliot is or was therefore hardly uninvolved at Hawthorn while Ms Kennedy is or was a “board advisor”.
  11. As I wrote on 27 January 2021, none of Ms Kennedy, John Evans (co-founder and chief executive of Hawthorn) or the Tory party responded to requests for comment.

The Lady Vanishes

  1. Ben Elliot is co-chair of the Conservative Party. Therefore, his business activities are of public interest.
  2. Mr Elliot was until last year a director of Hawthorn Advisors Holdings Limited, the holding company of Hawthorn Advisors, the well-connected, though opaque, political lobbyist (see 6 January 2021 post).
  3. Huawei, the controversial Chinese big tech firm, is a longstanding Hawthorn client.
  4. Companies House records show co-founder and joint owner Mr Elliot resigned as a director of Hawthorn Advisors Holdings Limited on 1 April 2020. His 40 “A” ordinary shares were transferred to Ruth Kennedy a month later (4 May 2020).
  5. Last year, it was reported that Mr Elliot had put his Hawthorn shares in a trust. As such Mr Elliot would be the “settlor”, the person who puts assets into a trust.
  6. The “trustee”, the person who manages the trust, is legal owner of the assets held therein. Thus it would appear Ms Kennedy is a trustee holding the shares for the benefit of Mr Elliot.
  7. When I first asked Ms Kennedy in an email for comment on this matter in July last year, she didn’t appear on the Hawthorn website. I didn’t receive a response.
  8. A few months later, Ms Kennedy appeared on the political lobbyist website – as a “board advisor” (screen shot in Figure 1). This prompted a second email to her in October 2020; but again no reply.
Figure 1. Ruth Kennedy, “board advisor”: Hawthorn Advisors website at 16 October 2020
  1. Perhaps John Evans, co-founder and chief executive of Hawthorn, would enlighten me. Nevertheless Mr Evans didn’t respond to emails, either (December last year).
  2. Ms Kennedy has since vanished from the Hawthorn website.
  3. Married to Lord Bruce Dundas, Ms Kennedy is also known as Lady Dundas. On 2 December 2015, The Independent online newspaper published an interview of Ms Kennedy. There it gushed: “Together, she and her husband move in some of London’s wealthiest and best-connected circles and are used to solving problems by engaging the help of friends and experts.”
  4. On 8 July 2020, the Daily Mirror newspaper quoted the Conservative Party: “Ben Elliot has nothing to do with the running of Hawthorn or its clients.”
  5. As the owner of Mr Elliot’s Hawthorn shares in a trust, Ms Kennedy is acting in his interest with his authority. In addition, she is or was a “board advisor”.
  6. Mr Elliot is or was therefore hardly uninvolved at Hawthorn while Ms Kennedy is or was a “board advisor”.
  7. The Tory Party didn’t respond to a request for comment.