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”.

Political lobbyist for trade organisation that files dormant accounts has also lobbied within parliament for undisclosed causes

  1. An individual working for an MP in parliament is the political lobbyist for a member-based trade organisation that has filed dormant accounts since incorporation on 4 October 2013. No one at the trade organisation, including the political lobbyist, has responded to emails asking why it continues to file dormant accounts. The trade body has paid members, according to its website. In the same emails I asked why its accounts don’t show the membership fees it receives. As well as acting for the opaque and unaccountable trade organisation, this person has at the same time lobbied within parliament for undisclosed causes. It’s unclear whether the MP is fully aware of all the organisations for which his staff member has and continues to lobby within parliament.
  2. On 31 July 2018, The Sustainable Energy Association (SEA; registered company number: 08718110) filed its latest accounts, made up to 31 October 2017. And again this set of accounts, its fourth year, was for a dormant company. Yet the SEA website displays annual membership rates, which vary by organisation type and size.
  3. What is SEA? The website says it’s “a member-based industry body offering innovative policy solutions that link up building-level technologies and the wider energy system to achieve a low carbon, secure energy future for the UK, benefits for UK consumers, and commercial growth for businesses working in the sector.”
  4. Companies House records show two founding directors, who are also the “persons with significant control”: Dave Sowden and Ecuity Consulting LLP (registered company number: OC373224). Mr Sowden identifies himself on the SEA website as “strategic adviser”. He was the first person there I emailed – twice in August 2018. No response. Later that month, I twice emailed Sandra Morris, “team project co-ordinator”. Again, nothing. Ron Bailey was the third person to whom I wrote – twice in September 2018. Mr Bailey, “head of parliamentary affairs”, didn’t reply, either (screen shot in Figure 1). Finally, in December 2018, I twice emailed Tim Minett, who, as chief executive of CPL Industries Ltd (registered company number: 02993245), is a member of the executive committee of SEA (screen shot in Figure 2). Again, Mr Minett was unresponsive.

    Figure 1. Ron Bailey: “head of parliamentary affairs” at Sustainable Energy Association

    Figure 2. Tim Minett: member of executive committee of Sustainable Energy Association

  5. The dormant accounts require explanation. So it’s disappointing no one at the trade organisation replied to emails about them.
  6. Mr Bailey works in parliament for Dr David Drew, Labour MP for Stroud, the register of interests of MPs’ staff shows. Thus SEA’s “head of parliamentary affairs” has a parliamentary pass.
  7. Mr Bailey made the same disclosure on the register both at 11 July 2018 and the next update, at 22 August 2018: “Head of parliamentary affairs, Sustainable Energy Association (member-based industry body). Employed by Ecuity Consultancy. Clients: Canetis Ltd.” (register at 11 july 2018) (register at 22 august 2018) Therefore, he didn’t reveal his contemporaneous lobbying activities within parliament for the United Kingdom Without Incineration Network (UKWIN), a national organisation campaigning against waste incineration in the UK.
  8. On 17 July 2018, UKWIN launched its report, “Waste Incineration and Particulate Pollution: A Failure of Governance”, at the House of Lords (screen shot in Figure 3). The official invitation to MPs and peers for the launch event shows Mr Bailey as named contact, with his parliament email address (screen shot in Figure 4).

    Figure 3. Launch of United Kingdom Without Incineration Network (UKWIN) report at House of Lords on 17 July 2018

    Figure 4. Invitation to launch of United Kingdom Without Incineration Network (UKWIN) report at House of Lords on 17 July 2018

  9. UKWIN and SEA are independent of each other.
  10. Shlomo Dowen is UKWIN national co-ordinator, according to its website. At the end of October 2018, I emailed him requesting confirmation Mr Bailey’s work for his organisation has nothing to do with his (Mr Bailey’s) role with SEA. Mr Dowen didn’t respond then, or to a reminder over two weeks later.
  11. Another undisclosed cause for which Mr Bailey has and continues to lobby within parliament is Power for People Ltd (registered company number: 10892473), a new campaign organisation. Incorporated on 1 August 2017, Steve Shaw is owner and sole director. Mr Bailey appears on the organisation’s website as “director of parliamentary strategy” (screen shot in Figure 5). The political lobbyist has been involved with Power for People since inception: he was joint author with Mr Shaw of its September 2017 report, “Energy: The Age of Clean” (screen shot in Figure 6).

    Figure 5. Ron Bailey: “director of parliamentary strategy” at Power for People

    Figure 6. Acknowledgements: Power for People report, “Energy: The Age of Clean”, published September 2017

  12. Mr Bailey doesn’t disclose his “director of parliamentary strategy” role at Power for People on the latest (at 27 December 2018) register, either. (register at 27 december 2018)
  13. Holders of parliamentary passes as MPs’ staff are required to disclose only paid roles on the register. Nevertheless some report relevant unpaid ones as well, if erroneously (see 22 November 2017 post).
  14. Perhaps, therefore, UKWIN didn’t pay Mr Bailey to lobby on its behalf. (The campaign organisation didn’t respond to emailed requests for comment, remember.) Yet his role at Power for People is, or at least has been, paid. For its “Energy: The Age of Clean” report, Mr Shaw and Mr Bailey acknowledge funding from charity Marmot Charitable Trust (registered charity number: 1106619) (Figure 6).
  15. On 1 November 2018, the Public Relations and Communications Association (PRCA) and the Association of Professional Political Consultants (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. The latest register, that from 1 September 2018 until 30 November 2018, comprises individual members as well as firms. Mr Bailey doesn’t appear on the register, so there we can’t find out on whose behalf he’s lobbying, either.
  16. I recently emailed Dr Drew about Mr Bailey’s lobbying within parliament, asking two questions. First, does the MP actually pay Mr Bailey to work for him at parliament? If so, what’s his exact role? Second, is Dr Drew fully aware of all the organisations for which Mr Bailey has and continues to lobby within parliament?
  17. The member for Stroud replied straightaway. Mr Bailey, he said, “works totally as a volunteer for me on my anti-incinerator campaign for which I give him one of my Westminster passes which he shares.” I then asked: did he mean UKWIN? UKWIN is “quite separate to us but clearly we have common objectives”, clarified Dr Drew in a second email. When I went on to point to Mr Bailey’s lobbying within parliament for UKWIN, the MP explained in a third message: “Ron Bailey lobbied on behalf of me for UKWIN.”
  18. Note, though, that Dr Drew isn’t one of the three parliamentarians – two MPs and a peer – who invited colleagues to the UKWIN report launch event at the House of Lords on 17 July 2018 (Figure 4).
  19. Meanwhile, the MP didn’t directly answer my second question. In his first email, he said: “I am well aware of the work he [Mr Bailey] undertakes given his brilliant reputation for environmental improvements in this country. I’m very lucky to be able to call upon his expertise and I’m pleased to say he’s made some major achievements already in the work that he volunteers for me.” When I pointed out his answer failed to directly address what I asked, Dr Drew didn’t comment.
  20. On SEA, the MP said he’s worked with it “throughout my time in parliament”, adding: “I’ve found them to be the most transparent of organisations”. When I explained why I perceive the trade organisation to be opaque and unaccountable, Dr Drew only responded: “…the submission of accounts is a matter for them not for me.”
  21. The lack of transparency and accountability around SEA’s money flows undermines public trust and confidence. Where exactly are the membership fees going and why? While its unresponsiveness only compounds the problems. A trade organisation should welcome public scrutiny. Then there’s its lobbying arrangements. SEA’s “head of parliamentary affairs”, who possesses a parliamentary pass as a member of an MP’s staff, has at the same time lobbied within parliament for hidden causes. SEA’s credibility is further damaged by such lobbying arrangements.

Lord Evans’ avoidable conflict of interest

  1. Lord Evans of Weardale, who joined the lords as a crossbencher on 3 December 2014, has several other paid roles. On 25 October 2018, the former director general of the Security Service, MI5, added another: chair of the Committee on Standards in Public Life. The day before, meanwhile, Lord Evans gave a talk at an event on cyber security – an event sponsored by one of the tech companies for which he’s a paid adviser (since 2013). These circumstances are problematic, I believe, for two reasons.

    Figure 1. Cyber security event at the London Stock Exchange Group on 24 October 2018 where Lord Evans spoke

  2. First, it’s unclear, at the very least, in what capacity Lord Evans spoke at the event, which took place at the London Stock Exchange Group (screen shot in Figure 1). (https://www.lseg.com/events/issuer-services-cyber-security-masterclass-24-october-2018) Darktrace Ltd was a sponsor (screen shot in Figure 2), and he’s a paid adviser to the firm, according to the register of lords’ interests. Was Lord Evans there as a member of the lords – or as an employee of Darktrace? Here he had an actual, potential, or perceived conflict of interest due to his other job with the firm. Worse, it’s an avoidable conflict of interest.

    Figure 2. Lord Evans is a paid adviser to Darktrace Ltd, a sponsor of the cyber security event

  3. Second, Lord Evans isn’t required to declare his role at the event on the register of lords’ interests, because he wasn’t paid for it. (The former head of MI5 confirmed via email he didn’t receive payment for speaking that day. Meanwhile, the register shows he‘s been paid for several “speaking engagements”.) Yet Darktrace, a firm for which Lord Evans works, was one of the sponsors. Thus it’s against the spirit of the register, I believe, for his role at the event not to be disclosed there.
  4. In response to my first point, Lord Evans said in an email: “As you will understand I speak at a variety of events in a variety of circumstances. I have never, so far as I recall, been invited to speak principally on the basis of my membership of the House of Lords.” While on the second point, he wrote: “I do not believe that there are any remunerated interests in respect of the London Stock Exchange event that I have failed to declare.”
  5. I then challenged his answer to my first point, saying his answer makes my point. There’s an unacceptable lack of clarity around the capacity in which Lord Evans spoke at the event. What is clear, though, is he’s a member of the lords, who also has other paid roles, including as adviser to Darktrace. So here, as I say, Lord Evans had an avoidable conflict of interest. I also called his attention to the fact that his answer to my second point fails to address what I said about the spirit of the register.
  6. In a further email, Lord Evans said: “I do not think that there are conflicts or undeclared interests here that are relevant to my role as a member of the House of Lords and I do not, therefore, have anything to add to my previous reply.”
  7. Note that Lord Evans didn’t address directly the central issue of the exact capacity in which he spoke at the event, despite my putting it to him twice. The lack of clarity around capacity is an inevitable consequence of Lord Evans multiple paid roles. The arising avoidable conflict of interest is, by definition, unnecessary. As such, then, it can and surely should be avoided.
  8. Lord Evans didn’t refer to “managing” the conflict of interest, either. Nonetheless, it’s much more satisfactory to avoid it (the conflict of interest) in the first place. Moreover, managing” conflict of interests – whatever it actually means – is usually far from straightforward.
  9. There are strong similarities between this case and Jake Berry MP’s previous avoidable conflict of interest involving a law firm, which I exclusively revealed on 15 January 2017. Back then, Mr Berry didn’t respond to requests for comment, though.
  10. The Committee on Standards in Public Life “advises the prime minister on ethical standards across the whole of public life in England”, says its website. As Private Eye magazine observed upon his appointment as chair of the eight-member committee (Eye 1481), Lord Evans several commercial roles risk calling into question his suitability for the post. Here I show that the concerns arent merely theoretical.
  11. There’s no suggestion that Lord Evans has done anything illegal.

Disclosure failings on the PRCA public affairs and lobbying register

  1. Each quarter, the Public Relations and Communications Association (PRCA) publishes online a publicly accessible public affairs and lobbying register. There companies that are members of the PR and communications trade body disclose employees involved in political lobbying, as well as all clients. Or at least that’s what’s supposed to happen. Here I show that disclosures made by a prominent member organisation call into question the accuracy and usefulness of the PRCA public affairs and lobbying register. Of equal concern is PRCA’s response to disclosure failings by members.
  2. Parliament’s latest (at 13 November 2018) register of journalists’ interests – and previous versions thereof – reveal an interesting declaration by Andrew Gimson of the influential ConservativeHome website: “consultancy” for leading political lobbying firm Lodestone Communications. (register at 13 November 2018)
  3. Journalists on the register possess a parliamentary pass. Mr Gimson hasn’t just become a parliamentary passholder: he appears on the register of journalists’ interests at 2 February 2017, for example, for the same sponsor, ConservativeHome. (https://web.archive.org/web/20170217224008/https://www.publications.parliament.uk/pa/cm/cmjournl/journalists.htm)
  4. Mr Gimson is a contributing editor to ConservativeHome, and biographer of Boris Johnson, the ex-foreign secretary. So why is Lodestone employing the journalist? The agency’s entry on the then latest static PRCA register, that for March-May 2018, showed him as having “conducted public affairs services” on its behalf in the last quarter. (PublicAffairsRegister March 2018 April 2018 May 2018) Another Lodestone employee allegedly involved in lobbying caught my eye there: Sonia Sodha. Ms Sodha is chief leader writer at Sunday newspaper The Observer, as well as deputy opinion editor at stablemate The Guardian. Thus the agency reported that two high-profile journalists carried out lobbying on its behalf.
  5. I emailed Lodestone, asking for which clients it disclosed on the register did Mr Gimson and Ms Sodha act. The agency didn’t respond to emails.
  6. I also separately contacted Mr Gimson and Ms Sodha about their alleged lobbying activities for Lodestone. Mr Gimson at ConservativeHome failed to reply to messages. Ms Sodha, meanwhile, wrote in an email: “I didn’t do any work, paid or otherwise, for Lodestone or its clients in that period.”
  7. Which obviously contradicts what’s on the register. So I then asked Ms Sodha in an email why she was named there. I received nothing, despite sending a reminder.
  8. Nicholas Dunn-Mcafee, head of public affairs, policy and research at PRCA, is contact for the register. Lodestone told him, he said in his email, that both Mr Gimson and Ms Sodha “don’t work on clients/provide lobbying – ‘for example, they speak at our events’ and in the past were added to the register for transparency”. Mr Dunn-Mcafee continued: “They understand that this is over-disclosure and will correct their future reporting accordingly.”
  9. In the next update of the static PRCA register, that for June-August 2018, Lodestone doesn’t list Mr Gimson or Ms Sodha.
  10. Then there’s another problem with the agency’s disclosures – one that means Lodestone, it appears, has breached the PRCA public affairs and lobbying code of conduct. (PRCA Code of Conduct – updated following review in September 2016) The relevant para is 11, which includes the requirement for PRCA members to report on the register “passholders and the relevant institution by placing ‘(Passholder – Institution)’”.
  11. On 25 September 2018, I therefore emailed Mr Dunn-Mcafee again to point out Lodestone doesn’t show Mr Gimson holding a parliamentary pass on the then latest static PRCA register, that for March-May 2018. In his response three days later, Mr Dunn-Mcafee said: “I appreciate you noting the parliamentary pass detail, and we obviously require members to declare employees with passes when those employees are required to appear on the register. I’ll pick up this point with Lodestone, but given his inclusion is a mistake.”
  12. Nevertheless I heard nothing more from PRCA – even after sending a reminder four weeks later (26 October 2018).
  13. As I say, Lodestone told Mr Dunn-Mcafee that neither Mr Gimson nor Ms Sodha actually provide lobbying services for any of its clients, despite the firm’s original disclosures on the PRCA register. Here Mr Gimson warrants particular scrutiny because of his access to parliament as a journalist. (Ms Sodha doesn’t hold a parliamentary pass.) The potential concern about anyone with a pass, journalist or not, is whether access to parliament is being abused for the purposes of lobbying.
  14. Lodestone’s disclosure failings risk undermining public trust and confidence in the PRCA public affairs and lobbying register. How many other political lobbying firms are misreporting their activities? Earlier this year, I revealed that PRCA secretly updated its latest supposedly static register after my discovery PLMR, another political lobbying firm, omitted to declare a client (see 13 February 2018 post). So this isn’t the first time PRCA’s actions, or lack thereof, in response to disclosure failings by a member call into question the credibility of the trade body.
  15. ADDENDUM: On 1 November 2018, PRCA announced on its website that it had merged with the Association of Professional Political Consultants (APPC), a hitherto independent membership body. APPC had maintained its own publicly accessible register of political lobbyists, where again members were required to list relevant staff and all clients.

Not quite the full story on Boris Johnson’s re-employment by the Telegraph

  1. In July 2018, Boris Johnson was re-employed by the Daily Telegraph newspaper on a salary of £275k a year for his weekly column, according to parliament’s latest (at 1 October 2018) register of MPs’ financial interests.
  2. There’s something interesting in the ex-foreign secretary’s disclosures on the register about the job. There he states: “I consulted ACOBA [Advisory Committee on Business Appointments] about this appointment.”
  3. That’s not quite the full story, though. True, Mr Johnson consulted the committee – but after his appointment had been announced. ACOBA duly rebuked him in August 2018 for failing to follow the ministerial code: he should have sought its advice prior to acceptance of a new role. Thus the committee refused to give retrospective advice.
  4. On 4 October 2018, The Guardian, among other newspapers, reported Mr Johnson’s newly revealed Telegraph salary – here’s the online report: http://www.theguardian.com/politics/2018/oct/03/daily-telegraph-rehires-boris-johnson-on-275000-salary. What a pity, though, it omitted to mention why the former foreign secretary’s disclosures on the register about the role were incomplete.

Extradition on the dance floor

  1. Extradition could be coming to a dance floor near you, thanks to a new firm set up by Lord Carlile and ex-MI6 chief Sir John Scarlett.
  2. Practising barrister (QC) Lord Carlile doesn’t say much about what Manet Solutions Limited (registered company number: 11351325) actually does on the latest House of Lords register of interests. There he only states providing advice in relation to extradition”.
  3. The firm has three directors: Lord Carlile, Sir John and Rowley Sword, according to Companies House records. The first two, both born in 1948, already work together as SC Strategy Limited (registered company number: 08248586). Mr Sword, meanwhile, is considerably younger: his year of birth is 1992. Manet Solutions is the first UK company where he’s been a director.
  4. Mr Sword and Oswald Miller are the founders of “Meatz & Beatz”, a music (live DJs) and catering entertainment service. The pair own the UK trade mark “Meatz and Beatz”.
  5. An unusual mash-up: extradition and partying. I asked Lord Carlile in an email whether Manet Solutions Limited will be working with Meatz & Beatz” in any way. He hasn’t replied.

Addendum: Fifth reason for astonishment at Tom Watson MP over Sky Bet

  1. Here’s a fifth reason why I’m astonished Tom Watson MP accepted the gift of four tickets for a football match from Sky Bet (see previous post). On 28 March 2018, gambling regulator the Gambling Commission fined Sky Bet £1m for “failing to protect vulnerable consumers” (http://www.gamblingcommission.gov.uk/news-action-and-statistics/news/2018/SkyBet-to-pay-1m-penalty.aspx).
  2. As I say, Mr Watson didn’t respond to requests for comment. I emailed him twice at parliament: 23 June 2018 and 27 June 2018. On both occasions, I immediately received an automated acknowledgement.