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Contents
Summary 2
Mr Tim Farron MP: Resolution Letter 3 Letter from the Commissioner to the complainant, 21 April 2021 3
5 Written evidence 4 1. Email from the complainant to the Commissioner, 3 March 2021 4 2. Letter from the Commissioner to Mr Tim Farron MP, 9 March 2021 5 3. Letter from Mr Tim Farron MP to the Commissioner, 17 March 2021 12 4. Letter from the Commissioner to Mr Tim Farron MP, 18 March 2021 14 10 5. Email from Mr Tim Farron MP to the Commissioner, 29 March 2021 16
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Summary
The allegation I investigated, following a complaint from a member of the public, was that the Member had failed to register four interests (all donations) within the time limit contained in the Guide to the Rules relating to the Conduct of Members. 5 This allegedly put the Member in breach of the requirements of Paragraph 14 of the Code of Conduct.
I upheld the allegation.
I concluded, and the Member agreed, that all four interests had been registered outside the 28-day time limit required by Paragraph 2 of Chapter 1 of the Guide to 10 the Rules relating to the Conduct of Members. I was satisfied that the late registration of each interest amounted to a breach of the requirement set by the House and a breach of Paragraph 14 of the Code.
The Member accepted my decision, acknowledged his breaches of the Rules, and apologised for these breaches. The Member also explained the steps he has taken 15 to ensure that future interests are registered within the time limit set by the House. The Member has also agreed to the annotation of the relevant interests in the Register of Members' Financial Interests to show that they have been subject to an inquiry. I considered the Member's apology and remedial actions to be an appropriate outcome and I have concluded the matter by way of the rectification 20 procedure available to me under Standing Order No. 150.
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Mr Tim Farron MP: Resolution Letter
Letter from the Commissioner to the complainant, 21 April 2021 I wrote to you on 9 March 2021 to tell you that I had begun an inquiry into your allegation that Mr Tim Farron MP had breached paragraph 14 of the House of 5 Commons' Code of Conduct for Members by failing to register three donations within the time limit set by the House.
Having investigated this matter, and also considered an additional donation, I found that Mr Farron has breached the Code. I concluded, and Mr Farron agreed, that all four donations had been registered outside the 28-day time limit required by 10 Paragraph 2 of Chapter 1 of the Guide to the Rules relating to the Conduct of Members. I was satisfied that the late registration of each interest amounted to a breach of paragraph 14 of the Code and I therefore uphold your allegation.
My full decision and rationale will be published on my webpage in due course, which will include the correspondence I exchanged with Mr Farron.
15 Mr Farron has accepted my decision. He has acknowledged his breaches of the rules, apologised, and agreed to the annotation of these interests to show that they have been subject to an inquiry. I have therefore concluded the matter by way of the rectification procedure available to me under Standing Order No. 150. I will notify the Committee on Standards in due course of this outcome.
20 21 April 2021
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Written evidence
1. Email from the complainant to the Commissioner, 3 March 2021 I wish to raise an issue with regard to Tim Farron MP and his declarations in the MP’s Register of Interests
5 From looking at the latest Register, he has declared several donations late and well beyond the 28 days in which they should be registered
Below are the 3 declarations that are late:
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
10 Amount of donation or nature and value if donation in kind: The services of a public relations company to the value of £14,400
Date received: 1 March 2020 - 28 February 2021
Date accepted: 1 March 2020
Donor status: company, registration 11134849
15 (Registered 19 February 2021)
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
Amount of donation or nature and value if donation in kind: The services of two policy advisers for a total of 30 hours a week between 1 20 April 2020 and 11 December 2020, and 22.5 hours a week between 1 January 2021 and 31 March 2021, total value £22,918
Date received: 1 April 2020 - 31 March 2021
Date accepted: 1 April 2020
Donor status: company, registration 11134849
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(Registered 19 February 2021)
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
Amount of donation or nature and value if donation in kind: The 5 services of an intern for 22.5 hours a week between 1 September 2020 and 31 July 2021, value £11,368
Date received: 1 September 2020 - 31 July 2021
Date accepted: 1 September 2020
Donor status: company, registration 11134849
10 (Registered 19 February 2021)
The date of the registrations are 19th February 2021, yet the acceptance of these donations were 1st March 2020, 1st April 2020 and 1st September 2020
I feel that the late registration of these donations breach of the Code of Conduct for Members of Parliament and should be investigated.
15 3 March 2021
2. Letter from the Commissioner to Mr Tim Farron MP, 9 March 2021 Following receipt of an allegation I have received from [the complainant] about your compliance with paragraph 14 of the House of Commons Code of Conduct for Members, I have decided to open a formal inquiry. I enclose a copy of [the 20 complainant's] submission and a copy of your current entry in the Register of Members’ Financial Interests.
In addition to the interests highlighted by [the complainant], I also intend to include in my inquiry the donation made to you by The Refugee, Asylum and Migration Policy Project (RAMP) on 1 January 2021.
25 The scope of my inquiry
My inquiry will focus on whether you have acted in breach of paragraph 14 of the House of Commons’ Code of Conduct for Members through the late registration of financial interests. If the scope of my inquiry changes, I will update you in writing.
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The relevant rules of the House
The overarching rules are found in the House of Commons’ Code of Conduct for Members. Paragraph 14 of the Code states:
Members shall fulfil conscientiously the requirements of the House in 5 respect of the registration of interests in the Register of Members’ Financial Interests. They shall always be open and frank in drawing attention to any relevant interest in any proceeding of the House or its Committees, and in any communications with Ministers, Members, public officials or public office holders.
10 The Guide to the rules relating to the conduct of Members, which is appended to the Code, contains more detail about the registration of financial interests. Chapter 1, paragraph 2 outlines the requirement of the House in relation to the timeframe for registering new interests:
The House requires new Members, within one month of their election, 15 to register all their current financial interests, and any registrable benefits (other than earnings) received in the 12 months before their election. After that, Members are required to register within 28 days any change in those registrable interests. Such a change includes both the acquisition of a new interest and the ceasing of any registered 20 interest, for example because an employment has ceased or because a holding has reduced in value or been sold.
Next steps
I would welcome your comments on the allegation that your late registration of the interests highlighted by [the complainant], and the further interest highlighted by 25 me, amount to breaches of paragraph 14 of the Code of Conduct for Members. I would also be grateful for your answers to the following specific questions:
(1) Are you aware of the requirement to register all new financial interests within 28 days of acquisition?
(2) What prompted you to register the three donations from Faith in Public 30 on 19 February 2021?
(3) What prompted you to register the donation from The Refugee, Asylum and Migration Policy Project (RAMP) on 19 February 2021?
(4) Please can you outline the circumstances that caused these interests to be registered late?
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(5) If, on reflection, you accept that these interests were registered outside of the House’s deadline, please can you confirm what steps you will now take to prevent any further late registrations?
(6) Are you satisfied that your current entry in the Register of Members’ 5 Financial Interests is complete and accurate in all other respects and in line with Chapter 1 of the Guide to the rules?
i) If it is not, please contact the Registrar now to bring it up to date.
ii) If it is, please describe the steps you have taken to satisfy yourself of this.
10 It would be helpful to receive any evidence to support your responses when you reply to this letter. Any other points you wish to make to help me with this inquiry would also be welcome.
Important information
owing the decision taken by the House 15 on 19 July 2018, I will not publish the fact that I am conducting an inquiry into an My inquiries are conducted in private. Foll the inquiry to third parties. They will answer direct factual questions about the processesalleged breach I follow, of the and Code the of Conduct. standards My system office willmore not generally, comment buton anywill aspect neither of
20 Thisconfirm letter nor and deny any that subsequent I have begun correspondence an inquiry. between us in connection with this inquiry is prot [the complainant]. ected by parliamentary privilege. It should be kept confidential until the outcome of my inquiry is published. The same requirement extends to Procedure
25 I enclose a copy of the Commissioner’s Information Note, which sets out the procedure for inquiries. Please note that this has not yet been updated to reflect the changes flowing from the decision of 19 July 2018.
While I do not, at this stage, know whether it will be necessary to interview you about this matter, it would be open to y 30 I am, of course, very happy to meet with you at any stage if you would find that helpful. ou to be accompanied at any such interview.
I should say now, as a matter of courtesy, that I may seek the advice of the House authorities and others as part of thi correspondence with you. s inquiry. If I do so, I will share that
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Information provided to me during the course of my inquiry will be retained, and disposed of, in accordance with the House of Commons’ Authorised Records Disposal Policy.
Potential outcomes
5 Inquiries are generally concluded in one of three ways. If the evidence does not substantiate the allegation, it will not be upheld. If the evidence demonstrates a breach of the rules, I may, in circumstances defined by Standing Order No. 150, uphold the allegation and conclude the inquiry using the rectification procedure, without making a referral to the Committee on Standards. Where an allegation is 10 not upheld or is rectified, the investigation material, including our correspondence, will be published on the Parliament website.
If I uphold the allegation, and it is either unsuitable for the rectification procedure, or you do not accept my decision, I must make a referral to the Committee on Standards. My memorandum to the Committee will be published as an appendix to 15 the Committee’s own Report.
Regardless of the outcome of my inquiry, I must emphasise that all the relevant evidence, including our correspondence, will be published when this inquiry is concluded. I routinely redact the personal data of third parties unless it is relevant to my decision(s). Please tell me if you provide sensitive material that you think I 20 should redact. I will consider carefully any such request.
Action
I would be grateful to have your response to this letter as soon as possible and no later than Thursday 18 March 2021 please.
If you would prefer me to communicate with you by a different email address, please 25 give the details when you reply to this letter. It would also be helpful if you were willing to provide a telephone number through which I might contact you.
Due to the current health crisis, my team are working from home only, so I would be grateful if you could send your response electronically to; [email protected]
30 Thank you for your cooperation with this matter.
Enclosure 1: Email from the complainant, 3 March 2021 (as above)
Enclosure 2: Extract from the Register of Members’ Financial Interests as of 1 March 2021
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Farron, Tim (Westmorland and Lonsdale)
2. (b) Any other support not included in Category 2(a)
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
5 Amount of donation, or nature and value if donation in kind: the services of two policy advisers for a total of 30 hrs per week between 16 April 2018 and 1 April 2020, total value £50,319 (£25,289 in 2018/19 and £25,030 in 2019/20)
Date received: 16 April 2018 - 1 April 2020 (expected)
Date accepted: 16 April 2018
10 Donor status: company, registration 11134849
(Registered 16 May 2018)
Name of donor: Good Faith Partnership LLP
Address of donor: The Courtyard, High St, Ascot SL5 7LP
Amount of donation, or nature and value if donation in kind: Services of a policy 15 adviser for two days a week from 1 January 2020 to 30 June 2020, max estimated value £9,100
Date received: 1 January 2020 to 30 June 2020
Data accepted: 1 January 2020
Donor status: company (LLP), registration OC412989
20 (Registered 10 January 2020)
Name of donor: The Refugee, Asylum and Migration Policy Project (RAMP)
Address of donor: The Courtyard, High St, Ascot SL5 7HP
Amount of donation or nature and value if donation in kind: the services of a Policy Adviser for 2 days per week from 1 July 2020 - 31 December 2020; max. value 25 £9,100
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Date received: 1 July 2020 - 31 December 2020
Date accepted: 1 July 2020
Donor status: company, registration 12373468
(Registered 20 July 2020)
5 Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
Amount of donation or nature and value if donation in kind: The services of a public relations company to the value of £14,400
Date received: 1 March 2020 - 28 February 2021
10 Date accepted: 1 March 2020
Donor status: company, registration 11134849
(Registered 19 February 2021)
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
15 Amount of donation or nature and value if donation in kind: The services of two policy advisers for a total of 30 hours a week between 1 April 2020 and 11 December 2020, and 22.5 hours a week between 1 January 2021 and 31 March 2021, total value £22,918
Date received: 1 April 2020 - 31 March 2021
20 Date accepted: 1 April 2020
Donor status: company, registration 11134849
(Registered 19 February 2021)
Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
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Amount of donation or nature and value if donation in kind: The services of an intern for 22.5 hours a week between 1 September 2020 and 31 July 2021, value £11,368
Date received: 1 September 2020 - 31 July 2021
Date accepted: 1 September 2020
5 Donor status: company, registration 11134849
(Registered 19 February 2021)
Name of donor: The Refugee, Asylum and Migration Policy Project (RAMP)
Address of donor: The Courtyard, High St, Ascot SL5 7HP
Amount of donation or nature and value if donation in kind: The services of a policy 10 adviser for two days per week from 1 January 2021 to 31 May 2021, value £7,584
Date received: 1 January 2021 - 31 May 2021
Date accepted: 1 January 2021
Donor status: company, registration 12373468
(Registered 19 February 2021)
15 Name of donor: Faith in Public Ltd
Address of donor: 10 Queen Street Place, London EC4R 1BE
Amount of donation or nature and value if donation in kind: The services of a public relations company to the value of £14,400
Date received: 1 March 2021 - 28 February 2022
20 Date accepted: 1 March 2021
Donor status: company, registration 11134849
(Registered 01 March 2021)
3. Gifts, benefits and hospitality from UK sources
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Name of donor: National Liberal Club
Address of donor: Whitehall Place, London SW1A 2HE
Amount of donation or nature and value if donation in kind: honorary life membership as Leader of the Liberal Democrats; value £735 pa plus £367.50 5 entrance fee.
Date received: 1 August 2015
Date accepted: 1 August 2015
Donor status: friendly society
(Registered 10 August 2015)
10 8. Miscellaneous
From 20 January 2021, Advisory Board Member of BOMAD Investments Ltd (trading as HomeNow), an affordable housing scheme. This is an unpaid role. (Registered 21 January 2021)
9 March 2021
15 3. Letter from Mr Tim Farron MP to the Commissioner, 17 March 2021 I’m responding to your letter of 9 March 2021 in connection with a number of my declarations on the Register of Member’s Financial Interests from Faith in Public and RAMP.
I have always endeavoured to be open and frank in respect of any financial interest 20 I have, and to comply with Paragraph 14 of the Code of Conduct. Certainly, these donations are not something I have ever looked to hide – previous donations from both organisations have appeared on the Register, and my connection with Faith in Public is regularly covered in the media.
That said, it is clear that during the COVID-19 pandemic things have slipped, and a 25 number of these donations were declared late unintentionally.
Turning to your questions –
1. Are you aware of the requirement to register all new financial interests within 28 days of acquisition?
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Yes, I am aware of this requirement.
2. What prompted you to register the three donations from Faith in Public on 19 February 2021?
3. What prompted you to register the donation from The Refugee, Asylum and 5 Migration Policy Project (RAMP) on 19 February 2021?
My Communications Manager noticed that the donations were missing at the time that I registered my unpaid role for BOMAD Investments, and we took immediate action to rectify the omissions.
4. Please can you outline the circumstances that caused these interests to be 10 registered late?
Both Faith in Public and RAMP have been supporting myself and my parliamentary office with staff members and other support for a number of years now – and these arrangements have continued uninterrupted – although they need declaring in discrete time periods on the Register.
15 The latest declarations for these arrangements were due at the beginning of the COVID-19 pandemic when, in common with most of my colleagues, we were being deluged with huge volumes of correspondence from constituents while also trying to set the team up to work remotely away from the Parliamentary estate.
I was also ill with suspected COVID-19 myself – although at a point when mass 20 testing wasn’t available – which put me out of action for 2-3 weeks and put more pressure on my staff team.
In amongst all of that, we clearly just lost track of when the declarations had been made up to and when they needed renewing.
5. If, on reflection, you accept that these interests were registered outside of 25 the House’s deadline, please can you confirm what steps you will now take to prevent any further late registrations?
As a result of this incident, we have now implemented a more robust procedure within my office to make sure all financial interests are declared on time, and have now diarised when these continuing arrangements need to be renewed.
30 6. Are you satisfied that your current entry in the Register of Members’ Financial Interests is complete and accurate in all other respects and in line with Chapter 1 of the Guide to the rules?
a) If it is not, please contact the Registrar now to bring it up to date.
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b) If it is, please describe the steps you have taken to satisfy yourself of this.
Again, as a result of this incident, my team and I have reviewed each of my entries on the Register, and I am satisfied that they are all complete and accurate.
I hope that this letter provides you with enough information about this incident. As 5 I say at the outset I have always endeavoured to be open and honest in my dealings with the House. Clearly I am also determined that this doesn’t happen again, pandemic or no pandemic, and that future donations are always declared on time.
17 March 2021
4. Letter from the Commissioner to Mr Tim Farron MP, 18 March 2021 10 Thank you for your letter of 17 March 2021 with your response to my formal inquiry. I have reviewed that information and consequently believe that we can now bring my inquiry to a close.
My decision
I have considered the content of our correspondence, the published rules and 15 guidance concerning the registration of interests, carefully before coming to a decision. I have decided that your failure to register the three donations received from Faith in Public Ltd, and the single donation from The Refugee, Asylum and Migration Policy Project (RAMP), within the time limit set by the House amount to breaches of paragraph 14 of the Code of Conduct for Members of Parliament (“the 20 Code”):
Members shall fulfil conscientiously the requirements of the House in respect of the registration of interests in the Register of Members’ Financial Interests. They shall always be open and frank in drawing attention to any relevant interest in any proceeding of the House or its 25 Committees, and in any communications with Ministers, Members, public officials or public office holders.
Rationale
Paragraph 2 of Chapter 1 of the Guide to the Rules relating to the Conduct of Members (“the Guide”) lays out the House’s time limit for the registration of new 30 interests:
The House requires new Members, within one month of their election, to register all their current financial interests, and any registrable benefits (other than earnings) received in the 12 months before their election. After that, Members are required to register within 28 days
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any change in those registrable interests. Such a change includes both the acquisition of a new interest and the ceasing of any registered interest, for example because an employment has ceased or because a holding has reduced in value or been sold.
5 I believe it is common ground that the donations in question were accepted and registered on the dates below:
• Faith in Public Ltd (donation 1): accepted on 1 March 2020 and registered on 19 February 2021
• Faith in Public Ltd (donation 2): accepted on 1 April 2020 and registered 10 on 19 February 2021
• Faith in Public Ltd (donation 3): accepted on 1 September 2020 and registered on 19 February 2021
• The Refugee, Asylum and Migration Policy Project (RAMP): accepted on 1 January 2021 and registered on 19 February 2021
15 I believe it is also common ground that the registration of these four donations are all outside the 28-day time limit set by the House and I am satisfied that the late registration of these interests amounts to a breach of the House’s requirements and a breach of paragraph 14 of the Code.
However, I also recognise and understand the circumstances that caused these 20 donations to be registered late. Although I appreciate the mitigating circumstances that you have described, at the start of the pandemic the House did not decide to amend or waiver the time limit for the registration of interests and as such I am required to enforce the House’s requirements as they stand. I am also grateful for your explanation of the steps that you have already taken to ensure that future 25 interests are monitored and registered in time.
Next steps
As you may be aware, having decided that the rules have been breached, I can, with the co-operation of the Member concerned, rectify less serious breaches using the powers available to me under Standing Order number 150. For more serious 30 breaches, or in instances where the Member rejects rectification, I would refer the matter to the Committee on Standards.
I have decided that a referral to the Standards Committee is not necessary and that I can resolve these four breaches of the rules through rectification.
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To do so, the Committee would generally expect the Member to have accepted my decision, acknowledged and apologised for their breach of the rules, and to have taken any steps necessary to rectify their breach. On this occasion, I consider the necessary step to rectify your breach is for these four donations to be annotated in 5 the Register so that readers will be aware that they have been subject to an inquiry. This is line with my usual practice for inquires that concern the late, or non, registration of an interest.
If you are content for me to conclude the inquiry in this way, please write to me to confirm that you accept my decision along with the necessary acknowledgement 10 and apology, and with confirmation that you agree for these donations to be annotated in the Register, by 30 March 2021.
If we are able to rectify and close this matter, I will share my written evidence pack with you, so that you can check its factual accuracy before publication. I will also report the outcome to the Committee on Standards in due course as a matter of 15 routine. You are, of course, entitled to decline my proposed rectification, in which case I will refer this matter to the Committee on Standards for their review.
In the meantime, our correspondence remains protected by parliamentary privilege and I must ask that you continue to maintain the strict confidentiality of the inquiry.
As you know, due to the current health crisis, my team are currently working from 20 home only, so I would be grateful if you could please send your response electronically to [email protected].
18 March 2021
5. Email from Mr Tim Farron MP to the Commissioner, 29 March 2021 I am writing to you to confirm that I accept your decision in response to your formal 25 inquiry. I acknowledge and apologise for my breach of the rules and will undertake every effort to ensure this does not happen again. I also confirm that I agree for these donations to be annotated in the Register.
29 March 2021