The problematic links between the ex-sports minister’s two new other jobs

  1. Ex-sports minister Tracey Crouch MP has recently acquired two apparently unrelated other jobs. Here I reveal the problematic links between them.
  2. As of 1 February 2019 the Conservative MP for Chatham and Aylesford is a “senior adviser” to The Playbook, a PR agency for sport, consumer, tech and business brands. Ms Crouch is paid £4.25k a month for “providing advice on the benefits of sport”, according to the register of MPs’ financial interests. It requires “20 hrs a month”. On 24 April 2019, meanwhile, she was appointed as an “independent” member of British racing’s Horse Welfare Board. The former minister will receive “£27k per annum plus reimbursed expenses” for “10 hrs a month”.
  3. The first problematic link arises because The Playbook’s clients include Great British Racing Limited (GBR), the agency website shows (screen shot in Figure 1). GBR is horseracing’s “official marketing and promotional body, working with all of racing’s stakeholders”, says the GBR website. The firm is owned and controlled by the British Horseracing Authority (BHA), according to Companies House records. GBR and BHA share the same address, too (screen shot in Figure 2). The Horse Welfare Board, by happy chance, is also at BHA, as the register of MPs’ financial interests confirms.

    Figure 1. Great British Racing is a client of The Playbook: The Playbook website at 10 May 2019

    Figure 2. Great British Racing contact details: Great British Racing website at 10 May 2019

  4. Ms Crouch was already working for The Playbook, therefore, when she joined the Horse Welfare Board. Thus the MP is actually non-independent given GBR is a client of the agency.
  5. The second problematic link is via political lobbyist Hanover Communications. The Playbook is owned and controlled by Hanover Communications – whose lobbying clients include BHA, according to the latest public affairs register, 1 December 2018-28 February 2019, at the Public Relations and Communications Association (PRCA) website. While the ex-sports minister isn’t working directly for the political lobbyist, The Playbook acts for GBR, a subsidiary of BHA. Further, BHA hosts the Horse Welfare Board, two of whose eight members work for BHA.
  6. Also, Hanover Communications and The Playbook are at the same address.
  7. Because of Ms Crouch’s involvement, the Horse Welfare Board deserves scrutiny. The BHA press release on 18 April 2019 announcing her appointment as an “independent” member says the Horse Welfare Board “will also look at how the sport’s welfare standards are communicated and how they are perceived by the sport, the public and other audiences” (screen shot in Figure 3). It says nothing about engaging politicians and government, then. Contrast the earlier BHA press release (25 March 2019) marking Barry Johnson’s appointment as independent chair of the Horse Welfare Board: it’s explicit about the body engaging politicians and government (screen shot in Figure 4). Presumably Hanover Communications will play a role in political lobbying by the Horse Welfare Board. Regardless, there’s a need for clarity and transparency around how exactly the body will engage politicians – besides Ms Crouch! – and government.

    Figure 3. Tracey Crouch MP appointed as an “independent” member of the Horse Welfare Board: British Horseracing Authority press release on 18 April 2019

    Figure 4. Barry Johnson appointed as independent chair of the Horse Welfare Board: British Horseracing Authority press release on 25 March 2019

  8. On 12 March 2019, the Advisory Committee on Business Appointments (ACOBA) published its advice letter to Ms Crouch about her role at The Playbook. There the committee stipulated: “for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government on behalf of The Playbook or its parent company [Hanover Communications] or clients”. Thus the ACOBA advice letter only reinforces the concerns about the Horse Welfare Board and its contacts with politicians and government.
  9. At date of publication ACOBA hasn’t published its advice letter to Ms Crouch about her role at the Horse Welfare Board.
  10. Finally, there’s something else about The Playbook: it also works for gambling company 888sport, the agency website shows. In addition, gambling is central to client GBR: one of the thirteen questions in the FAQs on the GBR website, for example, is simply “How do I bet?” Answer: “Placing a bet is simple. To help you out, why not take a look at the easy-to-follow betting content in our Guides section.” Hanover Communications, meanwhile, acts for FTSE 100 bookie Paddy Power Betfair as well as BHA (plus many other clients).
  11. With gambling closely linked to both new other jobs, it’s strange to recall the circumstances around Ms Crouch’s resignation as sports minister on 1 November 2018. Back then she lambasted the government for delaying until October 2019 reduction of the maximum stake on fixed-odds betting terminals (FOBTs) from £100 to £2. (In fact, the stake cut on FOBTs came into effect on 1 April 2019.) Ms Crouch was widely hailed at the time for her perceived principled resignation. So why is the MP now working for both The Playbook, which promotes gambling, and the Horse Welfare Board, which sits within BHA, the organisation responsible for a sport dependent on gambling?
  12. Ms Crouch didn’t respond to emailed requests for comment.

How can a dormant company without assets pay Mark Pritchard MP £1 666.66 a month?

  1. Mark Pritchard MP, a government trade envoy, worked for the SmartWater Foundation from 1 November 2017 until 31 March 2019, according to the register of MPs’ financial interests. Providing strategic advice”, the Conservative MP for the Wrekin was paid £1 666.66 a month for “an expected commitment of 18 hours”. The SmartWater Foundation “provides not-for-profit forensic technology solutions”, says Mr Pritchard on the register. It’s unclear, though, how the Telford-based organisation could employ the local MP.
  2. The last publicly available accounts for SmartWater Foundation Limited (registered company number: 06181622) are made up to 31 March 2018. These show the company appears to be dormant and there are no assets.
  3. Why do I say appears to be dormant”? Because the last accounts contain no evidence the company is doing business (“trading”). Further, there’s no evidence there the firm has any other income, either. ( Thus the inference is a reasonable one.
  4. Mr Pritchard began working for the company on 1 November 2017. So the last accounts include the first five months of the MP’s job.
  5. Companies House records show SmartWater Foundation Limited is a private company limited by guarantee, a legal structure often used by not-for-profit organisations. Nevertheless the fact remains it’s unclear how the firm could employ Mr Pritchard, when its last accounts don’t contain any evidence of business activity, let alone any evidence of employing – and therefore paying – the Tory MP or anyone else.
  6. The SmartWater Foundation is part of the multinational SmartWater group of companies, which includes UK-based SmartWater Technology Limited (registered company number: 02875523). For the avoidance of doubt, the SmartWater Foundation isn’t a registered charity.
  7. When asked for comment, a member of Mr Pritchard‘s office at parliament, Daniel Pycock, answered on his behalf. Mr Pycock challenged my assertion SmartWater Foundation Limited appears to be dormant. When I gave the reasons for the inference, he didn’t reply. Separately, I requested a comment from the SmartWater Foundation via the enquiry form on the SmartWater website ( An immediate, automated email acknowledgement was the only response I received.

ACOBA is wrong: senior Tory MP’s new job is linked to former role as minister

  1. Former minister Sir John Hayes recently bagged another outside job – his fourth! As of 5 January 2019 the Tory MP is “non-executive director” to Esharelife, an organisation he describes as “a charitable foundation” on the register of MPs’ financial interests. Sir John is paid £6k per quarter to “promote Esharelife’s charitable work”, which will require “an estimated maximum of 1.5 days per month”. The Advisory Committee on Business Appointments (ACOBA) gave its blessing to the MP taking up the new appointment. The new job had no connection, said ACOBA in its advice letter, with Sir John’s last ministerial role at the Department for Transport. The committee “particularly noted” the ex-minister “had no prior dealings” with Esharelife. Here I show ACOBA appears to have overlooked the pre-existing association between Sir John and Dr Maurizio Bragagni, founder and chair of Esharelife (full name: Esharelife Limited), as well as sole “person with significant control” (PSC).
  2. Italian Dr Bragagni is chair and chief executive of Tratos (UK) Limited, the UK arm of his family’s global cable-manufacturing business, Tratos Group. Dr Bragagni and his firm were linked to Sir John while he was transport minister from July 2016 until January 2018. Below follows four pieces of evidence for the association back then.
  3. First, the then transport minister gave the welcome address at the Port Equipment Manufacturers Association (PEMA) AGM 2017, which took place in London in February 2017 (screen shot in Figure 1). Tratos was the event’s main sponsor. The company website says it was Dr Bragagni who invited Sir John to attend in his capacity as transport minister (screen shot in Figure 2). At the time Dr Bragagni was also PEMA vice president.

    Figure 1. Then transport minister Sir John Hayes speaking at the Port Equipment Manufacturers Association (PEMA) AGM 2017: Tratos website at 28 February 2019

    Figure 2. Dr Bragagni invited then transport minister Sir John Hayes to speak at the Port Equipment Manufacturers Association (PEMA) AGM 2017: Tratos website at 28 February 2019

  4. Second, later in 2017, Tratos donated £6k to Sir John’s local constituency Conservative association, South Holland and The Deepings. (At date of publication Tratos has given £238k to the Tories, nearly all to the central party. Dr Bragagni has also individually donated £182k, again almost all to the central party.)
  5. Third, Dr Bragagni is “principal patron” of the Westminster Italian Conservative Group (screen shot in Figure 3). Tratos sponsored its reception on 3 October 2017 at the 2017 Tory party conference in Manchester (screen shot in Figure 4). As you can see, the then transport minister was one of the advertised “special guests”.

    Figure 3. Dr Bragagni is “principal patron” of the Westminster Italian Conservative Group: website at 28 February 2019

    Figure 4. Westminster Italian Conservative Group reception at the 2017 Tory party conference in Manchester: Facebook at 28 February 2019

  6. Fourth, in February 2018, Dr Bragagni published a book, “Brexit, Business and A Better Britain”. There in the acknowledgements he thanked Sir John “for his consistent support for Tratos’ push for higher industry standards” (screen shot in Figure 5).

    Figure 5. Dr Bragagni thanks Sir John Hayes in his book: PDF at 28 February 2019

  7. Incorporated on 19 February 2016, Esharelife (Esharelife Limited) itself warrants scrutiny. Here I make two points.
  8. First, at date of publication the self-proclaimed “charity foundation” (screen shot in Figure 6) isn’t registered as a charity with the Charity Commission. The last publicly available accounts, made up to 31 December 2017, say the registered charity number is “to follow”. Those accounts, its second set, were filed at Companies House on 26 September 2018. Yet the organisation still isn’t on the commission’s online public register of charities.

    Figure 6. “Charity foundation” Esharelife homepage at 28 February 2019

  9. Second, given Dr Bragagni is sole PSC of Esharelife, it and Tratos are related parties. Besides sole PSC and director Dr Bragagni, the “charity foundation” has three other directors. All three are either existing or former directors of Tratos, according to Companies House records! Unsurprisingly, Tratos appears prominently on the Esharelife website (screen shot in Figure 7).

    Figure 7. Tratos on the Esharelife homepage at 28 February 2019

  10. This is only the latest instance of ACOBA complacency and incompetence I’ve exposed (see 27 December 2018 and 25 February 2019 posts).
  11. Sir John didn’t respond to emailed requests for comment.
  12. There’s no suggestion that anyone has done anything illegal.

Inconsistencies in interpretation of a rule for the register of interests of MPs’ staff

  1. A government minister claims I have a “misunderstanding” of the register of interests of MPs’ staff. I’m wrong to infer, he says, that his staffer’s second job as disclosed on the register is “advantaged” by his [staff member’s] possession of a parliamentary pass. The minister goes on: “I … disagree that this declaration is some kind of confession of benefit.” Rather, “the sole reason for declaration is for transparency”. Thus not only does the minister appear to contradict what his fellow minister, Stephen Hammond MP, told me separately about the register (see first post on 30 March 2019). But also the minister’s position seems to be inconsistent with a key rule that governs the register.
  2. The register introduction is clear. It says MPs’ staff must register “any occupation or employment for which you receive over £385 from the same source in the course of a calendar year, IF THAT OCCUPATION OR EMPLOYMENT IS IN ANY WAY ADVANTAGED BY THE PRIVILEGED ACCESS TO PARLIAMENT AFFORDED BY YOUR PASS [my emphasis].”
  3. Nadhim Zahawi MP has been minister for children and families since January 2018. Parliament’s then latest (at 11 July 2018) register of interests of MPs’ staff showed Matthew Clark working for Mr Zahawi. (register at 11 July 2018) There Mr Clark disclosed a second job as “parliamentary liaison” for Elected Technologies (ET), a tech company producing software “solutions” for “elected representatives, individuals and political parties seeking elected office”, according to its website. Mr Clark – actually just “Matt” – appeared as “parliamentary liaison” on the ET website then as well (screen shot in Figure 1). The company website said nothing about what “parliamentary liaison” involves, however. There’s a lack of clarity and transparency around what Mr Clark is doing for the firm. I therefore emailed him at ET for comment, twice. I received nothing.

    Figure 1. “Matt”, “parliamentary liaison”: Elected Technologies website at 16 August 2018

  4. So I wrote to Mr Zahawi in August 2018. In his response, the minister said that “part-time researcher” Mr Clark doesn’t work in his parliamentary office. Rather, he works “remotely”. Mr Zahawi continued: “This work could conceivably require occasional access to me in parliament, which is why he is listed as a passholder. However, in reality, Matthew has not been to parliament in 2018 [at August 2018].” He finished: “His work with me is in no way related to, affected or impacted by his entirely separate, full-time job with Elected Technologies, and vice versa.”
  5. The address shown on the ET website for its UK office is within Mr Zahawi’s constituency, Stratford-on-Avon. It’s the firm’s registered office address as well, according to Companies House records.
  6. I then emailed the minister again, saying that, despite the lack of clarity and transparency around what Mr Clark is doing for ET, we do know that possession of a parliamentary pass is advantageous to Mr Clark’s role at ET: otherwise he wouldn’t have registered his job with the firm on the register of interests of MPs’ staff (here I cited “register introduction”). In another point, I said it’s a matter of record that the chief executive and founder of ET, Simon Smethurst-McIntyre, used to work in his parliamentary office. Therefore, I went on, it’s reasonable to ask whether he might want to help former employee Mr Smethurst-McIntyre and his firm. Authorising a parliamentary pass for Mr Clark is one way the minister could help ET (or it could reasonably be perceived as such).
  7. In his second email, Mr Zahawi wrote: “I believe that you have a misunderstanding of the register of Member’s [sic] staff interests. Members [sic] staff are required to register any outside employment for which they receive more than £385 a year. Registration is not linked to any benefit, which seems to be the false basis of your allegations. The sole reason for declaration is for transparency.” The minister continued: “… Any suggestion that I have authorised a parliamentary pass to benefit Elected Technologies, or anyone else, is libellous. As I explained before, Matthew Clark has a parliamentary pass because he works part time for me, and therefore might need to access me in parliament in order to complete the work I employ him for.” Mr Zahawi concluded: “He has not used his parliamentary pass in conjunction with his work for Elected Technologies, or indeed for anything other than his work with me, and to suggest otherwise would also be a libellous accusation.”
  8. For the avoidance of doubt, I didn’t and don’t intend to libel anyone or any organisation. I had asked Mr Zahawi a reasonable question given the chief executive and founder of ET formerly worked in his parliamentary office. Thus there’s a connection between the MP and the firm in his constituency that predates that due to Mr Clark. Another reason it was and is a reasonable question is Mr Clark, too, previously worked in Mr Zahawi’s parliamentary office.
  9. In my final message to the minister, I said I disagree that I have a “misunderstanding” of the register of interests of MPs’ staff. This time I explicitly quoted the relevant rule from the register introduction. That Mr Clark has registered his job with ET on the register indicates, I went on, his other role is “advantaged” by his possession of a parliamentary pass. Then I made a new point: we mustn’t forget Mr Clark’s role at ET is “parliamentary liaison”. It’s reasonable to suggest from job title alone, I wrote, that a parliamentary pass would be helpful to the ET employee. Finally, I highlighted the fact that Mr Clark has now changed his registration in relation to ET – after I first wrote to both of them, of course. Thus he’s ditched “parliamentary liaison”, instead putting “head of marketing” on the then latest (at 22 August 2018) register. (register at 22 August 2018)
  10. On 11 September 2018, the minister replied. Mr Clark informed him, said Mr Zahawi, that “following a restructuring, and new staff hires, his job position was changed to head of marketing at the end of July. His job remains much the same, even though the title of ‘parliamentary liaison’ appears to have inspired a very different image in your mind of what his job involves. This nominal change meant he was obliged to update his register, as is required. The register is published on a 6 weekly basis and reflects that change.”
  11. As I say, Mr Zahawi’s last message was on 11 September 2018. Yet the next day Mr Clark – sorry, “Matt” – still appeared as “parliamentary liaison” on the tech company’s website! (screen shot in Figure 2) I don’t know what the “parliamentary liaison” role involves, of course; and have never claimed to do so. Nevertheless it’s parliament-related, by definition. As such, then, it’s reasonable to suggest from job title alone that a parliamentary pass would be helpful to the ET employee. As I say, this is a legitimate point about the job title only – nothing more. (On 13 September 2018, I noticed the ET website showed “Matt” as “head of marketing”.)

    Figure 2. “Matt”, “parliamentary liaison”: Elected Technologies website at 12 September 2018

  12. Turning to the register, the minister wrote: “I urge all of my staff to be whiter than white with their declarations of outside interests, and disagree that this declaration is some kind of confession of benefit. As I stated before, this is in the interests of transparency. I too declare everything on my register of interests.” Mr Zahawi finished: “I believe the above is a full, honest and complete declaration of the situation. If you have any evidence of any benefit to support any allegations you wish to make about this or anything else please submit that evidence to me, and I would advise you to also submit anything to Elected Technologies that affects their own reputation. Unless you have any other evidence that you can put forward to me, I would personally view continued baseless accusations as libellous. If you continue to suggest anything else, with no further evidence, in any form or using any medium, that is how I shall have to treat your further communications.”
  13. Again, for the avoidance of doubt, I didn’t and don’t intend to libel anyone or any organisation. There’s no malice involved. Nor is this work politically motivated. Equally, it has been done in good faith. None of my emails to Mr Zahawi and Mr Clark was abusive in any way. Rather, each time I sought comment on issues I raised. Right of reply is important. The emails were reasonable journalistic inquiries.
  14. The register of interests of MPs’ staff is published online and publicly accessible. The disclosures there and their interpretation are legitimate matters of public interest. I have a long-term interest in the register, first writing about problems with it on 15 February 2016. On 9 November in the same year, meanwhile, I exclusively revealed how the register of interests of MPs’ staff is always incomplete at any time because not all staff with parliamentary passes are included. Then on 22 November 2017, I exposed how a staffer had erroneously declared a relevant unpaid role on the register, without making clear it was unpaid – holders of parliamentary passes as MPs’ staff are required to disclose paid roles only on the register.
  15. Mr Clark no longer possesses a parliamentary pass, as he doesn’t appear on the latest (at 22 March 2019) register of interests of MPs’ staff. Meanwhile, at date of publication Mr Clark remains on the ET website, still simply as “Matt”, “head of marketing”.
  16. There are many problems with the register of interests of MPs’ staff. Here I show there’s an urgent need for clarity on a key rule that governs the register. Inconsistencies in interpretation of the rule, including, it seems, between ministers Mr Hammond and Mr Zahawi, risk undermining public trust and confidence in the register and its contents.
  17. There’s no suggestion that anyone has done anything illegal.

Solicitor lobbying politicians on gambling employs an MP’s member of staff – but to do what exactly?

  1. More on Louise Stevens, who works for health minister Stephen Hammond in parliament, and her gambling-related other roles (see previous post).
  2. Parliament’s register of interests of MPs’ staff at 15 June 2016 shows Mr Hammond‘s employee Ms Stevens then had a second job as a “marketing consultant” for LMM Associates. (
  3. Who are LMM Associates? Well, it isn’t a UK-registered company. Rather, it’s sole practitioner Leslie MacLeod-Miller, as his speaker biography in the official brochure for the 2016 annual meeting of the Gaming Regulators European Forum (GREF) shows (screen shot in Figure 1). There Mr MacLeod-Miller, who is a solicitor, describes himself as “a sole practitioner specialising in gaming regulation and compliance”.

    Figure 1. Leslie MacLeod-Miller profile: Gaming Regulators European Forum (GREF) Conference 2016 – official brochure

  4. His speaker biography finishes: “In the UK gambling regulatory environment he acted as a negotiator with the Department of Media and Sport and the Gambling Commission regarding policy/secondary legislation drafting and implementation, drafting amendments for the House of Commons and the House of Lords.” The same sentence appears in another profile, on the website of firm Ravensbeck Ltd (registered company number: 02037240), where Mr MacLeod-Miller is an “associate” (screen shot in Figure 2).

    Figure 2. Leslie MacLeod-Miller profile: Ravensbeck Ltd website at 12 July 2018

  5. Mr MacLeod-Miller‘s previous roles include as chief executive of the British Amusement Machine Association (BACTA), a gambling trade association he describes as “the largest gaming lobbying organisation in the UK” (Figure 1).
  6. Political lobbying firms that are members of the Association of Professional Political Consultants (APPC) disclose their political lobbying clients on a public register. The APPC register contemporaneous to the register of interests of MPs’ staff at 15 June 2016, that from 1 June 2016 until 31 August 2016, reveals that LMM Associates was then a client of Interel. (APPC-Register-Aug-2016) (Previous editions of the APPC register are available on the Public Relations and Communications Association (PRCA) website. On 1 November 2018, PRCA and APPC merged. Both were independent member-based bodies, each maintaining its own publicly accessible register of political lobbyists, where members were required to list relevant staff and all clients. There’s now one joint register, available at the PRCA website.)
  7. Thus back in 2016, while working for Mr Hammond in parliament, Ms Stevens had a second job with Mr MacLeod-Miller – who was also using the services of political lobbyist Interel at the same time. Use of a political lobbyist, by definition, indicates the solicitor wanted to engage and influence politicians in parliament.
  8. There’s no suggestion that anyone has done anything illegal. Nevertheless Mr MacLeod-Miller, a solicitor “specialising in gaming regulation and compliance”, was lobbying politicians in parliament. So Ms Stevens second job as a “marketing consultant” for the solicitor deserves scrutiny, because of her role as an MP’s member of staff and the privileges it affords. What exactly was Ms Stevens doing for Mr MacLeod-Miller?
  9. Interel acts as the secretariat for the fixed odds betting terminals (FOBTs) all-party parliamentary group (APPG). Mr MacLeod-Miller’s company LM Consultants Ltd (registered company number: 09050186) is listed as an “associate member” of the APPG, and has “contributed more than £1.5k to the running of the group” (screen shot in Figure 3). Mr MacLeod-Miller is owner and sole director, according to Companies House records. Meanwhile, Mr MacLeod-Miller as LMM Associates is also involved with the APPG: he’s identified as such in the minutes of the group’s extraordinary meeting that took place at parliament on 19 March 2018, for example. (FOBT-APPG-Minutes-Extraordinary-Meeting-19.03.18) (The minutes are published on the APPG’s website.)

    Figure 3. Fixed odds betting terminals (FOBTs) all-party parliamentary group (APPG): associate members at 12 July 2018

  10. I emailed Mr MacLeod-Miller for comment at charity Never Such Innocence (registered charity number: 1156148), where he’s chair and a trustee, according to its website. (I couldn’t find a LMM Associates email address for him.) He replied from a LMM Associates address, saying: “Louise was never involved in any business activities or lobbying whatsoever, nor was she at any time client facing and at no time was involved or in contact with Interel. Louise worked for me for a period of time which ended over 2 years ago as my personal [sic] PA (diary management, travel arrangements and typing) for a few hours a week while she was in between jobs and subsequently when she worked part time for Mr Hammond.”
  11. I then went back to Mr MacLeod-Miller for clarification on two points. I first asked whether he really meant “personal PA”. PA is the standard abbreviation for personal assistant. Therefore, “personal” is surely unnecessary in front of PA. Or did he mean something else by PA? For the purposes of my second question, I said I assumed Mr MacLeod-Miller meant personal assistant. I then asked if, as he says, Ms Stevens was his “personal assistant” and performed the tasks he describes, why did she disclose the role on parliament’s register of interests of MPs’ staff as “marketing consultant”?
  12. Having heard nothing a week later, I sent Mr MacLeod-Miller a polite reminder, to which he immediately replied. He wrote: “I have no knowledge of you or how you obtained my e-mail contact. In any case: 1. Matters of employment are private and confidential, and I am not at liberty to make any further comment; 2. I require you to permanently delete my e-mail address from your records in accordance with GDPR regulations; 3. I find your unrequested contact and your previous communications alarming, distressing and unreasonable and believe that your behaviour is calculated to produce such alarm and distress; and 4. You are not to seek to contact me in the future.”
  13. For the avoidance of doubt, I only had MacLeod-Miller’s email address at LMM Associates because he’d sent me a message from it!
  14. I didn’t contact Mr Hammond for comment, after he’d told me not to email again about Ms Stevens (see previous post). Without permission to reach the MP that way, I was thus unable to invite comment from Ms Stevens, too. I couldn’t find a parliament email address for her as an individual, either.
  15. In January 2019, the FOBTs APPG changed its name to the gambling-related harm APPG, following the success of its campaign to reduce the maximum stake on FOBTs from £100 to £2. The stake cut on FOBTs comes into effect on 1 April 2019.

Why won’t DLA Piper comment on its gambling consultant who works for an MP in parliament?

  1. The then former government minister couldn’t have been clearer. My employee “has no association with DLA Piper and works full time in my [parliamentary] office,” said MP Stephen Hammond in an email. He was replying to my query about Marie Stevens, who had disclosed on parliament’s then latest (at 30 May 2018) register of interests of MPs’ staff her role as a consultant on gambling to the multinational law firm. (register at 30 May 2018) Ms Stevens‘ full name is Marie-Louise Stevens, wrote the senior Conservative MP, but she calls herself Louise Stevens. Yet Mr Hammond‘s answer on DLA Piper obviously begs the question: why had Ms Stevens made such a disclosure on the register, if, as he says, it’s inaccurate?
  2. In fact, Ms Stevens does (or at least did) have an “association” with DLA Piper.
  3. Mr Hammond wrote in a later email: “Louise worked privately out of working hours on a one-off project [for DLA Piper] which was nothing to do with her work in parliament nor was it advantaged by having a pass. It was placed on the register in error (by Louise who believed any external source of income should be declared, and not just those which are only [sic] advantaged by having a parliamentary pass) and will be removed on its next publication.”
  4. The next update of the register (at 11 July 2018) showed Ms Stevens with no disclosures. (register at 11 July 2018)
  5. Ms Stevens appears as Marie Stevens on the register, remember. The name immediately caught my attention: there‘s a well-known solicitor of that name who has held board positions with bookmakers including Ladbroke Group PLC (now part of GVC Holdings PLC), 888 Holdings PLC and, most recently, Sportingbet PLC. Also, from 1999 until 2004 the same Ms Stevens served as a member of the Gaming Board for Great Britain, the predecessor to gambling regulator the Gambling Commission. Ms Stevens has been a “regulatory consultant to [the] gaming industry, since 2004”, says her Who’s Who 2019 entry.
  6. When I first wrote to Mr Hammond, I asked whether his employee was the solicitor. The parliamentarian, who was at the time a member of the influential Treasury committee, responded: “She [Louise Stevens] is not and has never been a solicitor. The person to whom you refer may be her mother who I have never met.I duly wrote back to Mr Hammond saying there’s a need for clarity, I believe, over the relation, if any, between solicitor Marie Stevens and Louise Stevens. Why? Louise Stevens disclosed role as a consultant to DLA Piper on gambling.
  7. So it’s reasonable to ask Mr Hammond whether the solicitor is related to his employee. And if so, how? His statement hadn’t resolved the issue (“may be her mother”). Therefore, I requested a clarification, apologising for prolonging the exchange. I made clear it was the final point; and wasn’t abusive in any way.
  8. Nevertheless the then former government minister didn’t answer the question. Instead Mr Hammond wrote: “I have answered your points fully and clearly. Your last email could fairly be described as harassment. If you persist or publish anything that suggests I have acted improperly I shall report you to the relevant authorities.”
  9. There’s no suggestion that anyone has done anything illegal. But its in the public interest, I believe, to establish whether Louise Stevens is related to solicitor and “regulatory consultant” to bookmakers Marie Stevens, given Louise Stevens role as a consultant to DLA Piper on gambling, while working for Mr Hammond in parliament. As everyone knows, there are many controversies around the gambling industry and its regulation. Thus links between parliament and law firms on gambling should be scrutinised.
  10. Solicitor Marie Stevens didn’t respond to requests for comment. (I used the email address she lists in Who’s Who 2019.)
  11. Then there’s a wider point on parliament and law firms beyond gambling. On 15 January 2017, I exclusively revealed an avoidable conflict of interest that arose for Jake Berry MP because of his then second job as a paid consultant to another multinational law firm, Squire Patton Boggs. Mr Berry worked for the law firm from September 2016 until June 2017, before becoming a government minister. Here it’s not Mr Hammond who has or had a role with a law firm, of course, but his employee in parliament. But the problem is the same: law firms are opaque and secretive, so it’s always unclear why exactly they’re paying MPs or their staff. And without transparency, there can’t be public trust and confidence.
  12. (For the avoidance of doubt, here transparency is necessary but not sufficient for public trust and confidence.)
  13. DLA Piper didn’t respond to requests for comment. Therefore, not only is the law firm opaque and secretive. It’s unresponsive and unaccountable, too.
  14. On 16 November 2018, Mr Hammond returned to government as health minister.

Lord Dannatt is chair and director of firm whose “head office” is merely a virtual office

  1. On 7 January 2019, I wrote to Lord Dannatt requesting comment on five issues relating to his involvement with Cadence Consultancy Ltd (registered company number: 09349330). The British Army’s former Chief of General Staff Army acknowledged receipt of my email, saying: “I am checking the facts with regard to Cadence.” Nevertheless I didn’t receive anything further, despite sending a reminder. Meanwhile, Lord Dannatt duly corrected an error on the register of lords’ interests and presumably arranged the changes to the firm’s website I describe below.
  2. The error on the parliamentary register was the first issue. The peer had got the business name wrong, referring to Cadence “Consulting”, instead of Cadence Consultancy Ltd (screen shot in Figure 1). As I say, that mistake has now been rectified.

    Figure 1. Lord Dannatt: register of lords’ interests at 4 January 2019

  3. Then there’s the fact that Cadence Consultancy’s latest accounts, made up to 31 December 2017, show two directors only, Chesney Clark and Howard Chaganis (screen shot in Figure 2). Yet Companies House records indicate Lord Dannatt and three others were appointed as directors on 1 October 2017. So why aren’t the four new directors listed in the latest accounts?

    Figure 2. Cadence Consultancy Ltd 2017 accounts: company information

  4. The third issue concerns the “contact us” page of Cadence Consultancy’s website, which gives the address of “head office” (screen shot in Figure 3). It’s misleading to identify that address as head office. Cadence Consultancy doesn’t actually have any staff – let alone head office – at that location: it’s only a so-called virtual office! It’s laughable to label such as head office. Worse, it’s a common trick of scammers to represent a virtual office as a real office. So why is Cadence Consultancy risking the perception that it’s a scammer?

    Figure 3. Cadence Consultancy Ltd website: “contact us” page at 4 January 2019

  5. The fourth issue relates to two documents available at the foot of the website, the “website privacy notice” (screen shot in Figure 4) and “website terms of use” (screen shot in Figure 5). The bottom of each page in both bears Cadence Consultancy’s “registered address”, which is the address of the virtual office. It’s misleading to refer to that address as “registered address”, when Companies House shows a different registered office address.

    Figure 4. Cadence Consultancy Ltd website: “website privacy notice” at 4 January 2019

    Figure 5. Cadence Consultancy Ltd website: “website terms of use” at 4 January 2019

  6. Finally, the website failed to show both registered company number and registered office address. It also omitted to disclose that Cadence Consultancy is a limited company (screen shot in Figure 6). Although some, but not all, of these company details are revealed in the two documents I refer to in para 5, they all must be clearly shown on the website. While the website now clearly states both registered company number and company type, the registered office address remains undisclosed (at date of publication).

    Figure 6. Cadence Consultancy Ltd website: homepage at 5 January 2019

  7. It’s surprising chair and director Lord Dannatt failed to get the company name right on the register of lords’ interests. More surprising, though, is the firm’s false representation of a virtual office address as “head office”. For the avoidance of doubt, the problem isn’t use of a virtual office address. Rather, it’s the false claim the virtual office address is “head office”.