Code of Conduct
- The Office of the Registrar of Consultant Lobbyists in the UK was established following the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014, to create and administer the statutory the Register of Consultant Lobbyists. C|T Group (UK) Trading Limited are registered.
- We work with our clients on a confidential, legal and appropriate basis at all times. By registering as consultant lobbyists, all employees of the registered business units are adhering to the principals of transparency and good governance in client work which may involve lobbying (as set out in the Registrar of Consultant Lobbyist’s Guidance, see below).
- Ethical and professional behaviour is at the heart of C|T Group’s business, and those values should be followed at all times.
- This policy provides specific guidance on the conduct of staff when pursuing activities related to lobbying in the UK, and is part of a framework of policies covering all aspects of our work. It is essential that you follow this code and it should guide you on how to behave. We want the policy to be accessible and clear to you and to our clients. Our aim is that anyone who reads this can understand what to expect from us as well as providing clarity about the regulatory regime with which we must comply.
- This policy applies to anyone working for the registered business units and anyone from another C|T Group company that is temporarily working in support of those companies on lobbying services. No one may work on any project that involves lobbying in the UK unless they have read and understood this policy, and had training from us where required.
- As enshrined in our guiding principles we expect all staff to work with integrity. We never do anything we cannot justify publicly, and only ever work in a legally compliant manner. This mean we do not undertake any work that is prohibited by government regulation or the laws of England and Wales, or by government regulation or the laws of any jurisdiction in which its work is carried out or in which the Client is incorporated, has its principal place of business or resides.
- Our staff are expected to always work in accordance with the standards of behaviour set out in the Staff Handbook whenever they are working for, or representing the C|T Group and/or its clients. This includes when they are in the workplace, taking business trip, attending work-related social events or representing the business in any other way. A failure to meet those standards may result in action including disciplinary action, which might include termination of employment.
- We will not work with clients where we have a conflict of interest or where we have ethical or other legitimate concerns regarding that potential client.
- We must not lobby in relation to a matter or particular aspect of it if our clients have a conflict of interest with one another or ourselves, or a significant risk of such a conflict in relation to that matter or aspect of it, unless: the clients have a substantially common interest in relation to the matter or the aspect of it, as appropriate; or are competing for the same objective, and they have consented to our representing and lobbying for them both in these circumstances.
- Clients must have given informed consent, evidenced in writing, and you must have effective safeguards to protect each clients’ confidential information. You should seek advice from your line manager if you are not satisfied it is reasonable for you to act for a client.
- All new clients are subject to KYC checks, and as far as possible we determine whether there are conflicts which would preclude our involvement. This includes sanctions checks in the UK (the Office of Financial Sanctions Implementation (OFSI), HM Treasury) in the US, the Office of Foreign Assets Control (OFAC), Department of the Treasury; and in Australia (the Department of Foreign Affairs and Trade’s Consolidated List in Australia). We do not represent clients who are the subject of relevant Government or international sanctions.
- You may only lobby for clients where their instructions are clear and clearly from the client. This means instructions from someone properly authorised to provide instructions to us that bind the client. If you have reason to suspect that the instructions do not represent the client’s wishes or interests you must speak to your line manager. Never act unless you have satisfied yourself that you know what the client expects and you have clear instructions.
The Register of Consultant Lobbyists
- The UK the Register of Consultant Lobbyists was set up under the Transparency of Lobbying, Non Party Campaigning and Trade Union Administration Act 2014. Any organisation that conducts the business of consultant lobbying, as defined by the act, is required to join the register.
- The Government’s intention behind the introduction of the Register of Consultant Lobbyists was to enhance the transparency of those seeking to lobby Ministers and Permanent Secretaries on behalf of a third party.
- Registrants must submit quarterly returns and list the clients they have lobbied for.
- We do not have to list every single client we have, only those where we lobby.
- We do not have to submit any details of the conversation, and confidentiality must always be respected.
- It is essential you follow instructions from line managers on what to record to ensure we operate compliantly.
- The Register of Consultant Lobbyists is public and can be found here:
- If you have any concerns seek advice from your line manager and/or the Chief Compliance Officer, and always look to the source of the law; The Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (‘the Act’).
- The Act in Section 2, coupled with Schedule 1, explains lobbying and who must register. Specifically, section 2 (3) makes clear that lobbying must be of ‘a Minister of the Crown or Permanent Secretary,’ and in Part 3 of Schedule 1 to the Act the persons of equivalence to those in Section 2 are given as; Cabinet Secretary; Chief Executive of Her Majesty’s Revenue and Customs; Chief Medical Officer; Director of Public Prosecutions; First Parliamentary Counsel; Government Chief Scientific Adviser; Head of the Civil Service; Prime Minister’s Adviser for Europe and Global Issues.
- Lobbying occurs where a person or entity has had direct oral, written or electronic communications personally with: A Minister of the Crown, Permanent Secretary (or equivalents) currently in post, referred to as ‘Government Representatives’ relating to items such as:
- The development, adoption or modification of any proposal of the Government to make or amend primary or subordinate legislation;
- The development, adoption or modification of any other policy of the Government;
- The taking of any steps by the Government in relation to any contract, grant, financial assistance, licence or authorisation; or
- The exercise of any other function of Government.
- This communication is made in the course of business and in return for payment on behalf of a client, or payment is received with the expectation that the communication will be made at a later date.
- Lobbying is legal and part of our democratic process. The Government needs access to the knowledge that lobbyists can provide, which in turn helps to inform the policy process. However, we must do this with integrity in compliance with this code and the law.
- Direct oral, written or electronic communications …
- This includes any conversation, letter or email to influence a function of Government such as:
- Development of a policy/proposal/legislation
- Adoption of a policy/proposal/legislation
- Modification of a policy/proposal/legislation
- Financial assistance
- You need to record your interactions for our regulatory compliance, here is some guidance on what is a communication to help you comply:
- It is the UK only and does not include the EU.
- It does not matter where the contact is made, for example if you send an email from another country or if you are at party conference.
- The communication has to be made directly to a Minister/official.
- If the Minister/official initiates at a meeting, and in the course of that meeting there is a conversation relating to a government function, this is lobbying.
- It is a requirement of our code that you keep appropriate records of these communications and if in doubt as to what to record seek advice from your line manager.
- This includes any conversation, letter or email to influence a function of Government such as:
- …personally to a Minister of the Crown, Permanent Secretary currently in post
- A list of Government representatives can be found on their website here.
- Permanent Secretaries are the most senior civil servants in a department. A list can be found here.
- Relevant communications must be made in the course of a business from within our IT systems. Please bear in mind that:
- If multiple clients were benefiting from the communication, each client would need to be listed on the Register of Consultant Lobbyists after registration.
- Payment by a third party would still meet the criteria.
- Failure to comply with the statutory requirements could result in a fine. The registrar does have criminal enforcement powers to investigate. If in doubt our code requires you to seek advice from a line manager on whether the planned activity is lobbying and what is to be recorded.
- If you are suspected to have breached this code or the statutory requirements you will be subject an internal investigation, and then if you have breached this code or the statutory requirements to the discipline process and procedure in your employment terms and the employee handbook.
C|T Group’s Expectations
- Staff must:
- Act with honesty, integrity and use all reasonable endeavours to satisfy themselves of the truth and accuracy of statements made or information provided whether directly or on behalf of clients;
- Be transparent in disclosing the identity of the client and ensure that quarterly reporting for the Registrar of Consultant Lobbyist is complete and accurate. The Chief Compliance Officer must be informed of any oral, written or electronic communication (this includes social media) with relevant persons, via the correct channel. Full details will not be made public – only the client’s name is registered quarterly – but are an important part of our accurate record keeping;
- Do not misrepresent the interests of clients;
- Do not exaggerate C|T Group’s lobbying capabilities or network;
- Do not employ, use as a paid consultant or contract through a third party, any MP, Member of the House of Lords, member of the Scottish Parliament or the National Assembly for Wales or the Northern Ireland Assembly or the London Assembly to conduct lobbying work on our behalf;
- All C|T Group staff, regardless of their role, must attend training, read this policy and supporting documents during induction (and attend annual refresher training on this and other compliance issues). Staff are required to sign a form to confirm they have understood the rules relating to the Register of Consultant Lobbyists and the training material.
- All staff must in addition read guidelines from the Registrar of Consultant Lobbyists’ here:
- In all you do ask yourself: are you able to justify your decisions and actions in order to demonstrate compliance with our obligations?
Raising A Concern
- If you wish to raise a concern about our work or the conduct of a member of C|T Group staff please refer your concerns to either:
- Your line manager, or the Chief Operating Officer or the Chief Compliance Officer. Please see the Staff Handbook on Whistleblowing.
- Alternatively, whether or not you are a member of staff, you can report your concerns to our independent monitor, Mark Davis, a senior and well respected lawyer. https://integritasadvisory.co.uk/team/. Not only in his capacity as a corporate lawyer but also having sat on the boards of several global companies, investment committees, audit committees and chaired nominations and remuneration committees, he is experienced at conducting ‘whistleblower’ investigations. To contact Mark on a confidential basis please use one of the following:
- Telephone: +44 (0) 7701 392 834
- Or email either [email protected] or [email protected]. Both email addresses go directly to him.
If you have any questions please immediately contact the Group Chief Compliance Officer.