Schedule to Neil Hamilton's Statement
dated 10 February 1997
1. The two written Parliamentary questions were
tabled on or about 7 November 1985.
1.1 In February 1984 Sir Peter Hordern,
Parliamentary Consultant to The House of Fraser, invited all the
Officers for the Conservative back bench Trade and Industry Committee
to lunch with Professor Roland Smith and his fellow directors
of The House of Fraser. At that time I was an officer of the back
bench Trade and Industry Committee, and I accepted the invitation.
1.2 Although Peter Hordern discussed the
takeover battle with me from time to time, I believe that my first
connection with the Al-Fayeds was a telephone call I received
on or about 29 October from Ian Greer. He told me that he had
been retained by HoF to handle the Parliamentary side of their
defence against the Lonrho attack, and asked me whether I would
be prepared to support the Al-Fayeds against Lonrho. I agreed
to do so.
1.3 On or about 7 November 1985, I tabled
two written Parliamentary Questions relating to the suspected
use by Tiny Roland of The Observer to
promote Lonrho's interests, contrary to the undertakings given
to him by the DTI in order to permit the takeover.
1.4 The suggestion that I was paid for tabling
these WPQs is a fabrication. Nor is it a credible suggestion:
it is a routine matter for a Member of Parliament to table WPQs
following requests from members of his constituency or other
persons whose interests he is prepared to support in the context
of his political beliefs and aspirations. No evidence has been
adduced to justify the allegation that I was paid for tabling
2. Member of a Group
Sub-paragraph 4 of the particulars of The
Guardian's Defence alleges that I was a member of a group of four
Members of Parliament; the allegations made against me by The
Guardian and Mr Al-Fayed in the context
of the current enquiry refer to a group of five Members of Parliament;
the additional Member is Sir Andrew Bowden.
2.1 Sir Michael Grylls, Tim Smith and myself
were all Officers of the Conservative Back-bench Trade and Industry
Committee; this reflected my interest in economic affairs; I have
been associated with the Institute of Economic Affairs since
1970 and, as is well known, was strong in my support for Margaret
Thatcher's economic policies. Sir Peter Hordern was Consultant
to The House of Fraser prior to its acquisition by Al-Fayed.
2.2 It is a commonplace of political life
that members with similar views co-operate and espouse the same
or similar causes; we met from time to time to discuss the dispute
between The House of Fraser and Lonhro, reflecting our individual
views, and there are no grounds for inferring improper motive
or conduct from my association with them.
2.3 It has been suggested that activities of
the Members of the Back-bench Trade and Industry Committee were
in some way co-ordinated by Ian Greer in an improper manner or
for an improper motive. Some of the WPQ and EDMs tabled by me
and others were prepared, by way of an initial draft, by Ian Greer,
or indeed The House of Fraser; this is perfectly normal practice,
as outlined in the witness statement signed by Ian Greer on 27
June 1995. It is not unusual for Parliamentary lobbyists to prepare
such drafts as part of representations made to Members of Parliament
in the hope that the concerns of those companies or charities
which they represent can be adequately considered and addressed
by those responsible for making policy decisions. Royston Webb,
for example, routinely provided Dale Campbell-Savours MP with
draft WPQs and EDMs.
2.4 In the UK there are about 50 professional
consultants who operate lobbying departments (in the US there
are 6,500 and approximately 100 operate in Brussels); lobbyists
are routinely employed by most of the larger corporations and
trade unions and charities in the United Kingdom whose job it
is, inter alia, to ensure that legislators are properly
informed when it comes to making decisions and drafting legislation.
Lobbying organisations can and are properly regarded as a legitimate
and valuable vehicle for conveying information to the legislative
body. Both The Guardian and Channel 4 retained IGA, for
example; and Lovell White Durrant, formerly The Guardian's
solicitors, provide parliamentary lobbying services.
2.5 I am not embarrassed by the disclosure that
I was consulted by either Mr Fayed or Ian Greer for the purpose
of tabling WPQs or EDMs. Had I, however, received a fee specifically
for doing so, it would have constituted a corrupt practice. I
never received any payment from Al-Fayed, The House of Fraser
or any person connected with them.
3. I tabled the following Parliamentary Questions
on the following dates for written answer.
(i) On or about 24 February 1987, I
pressed the Secretary of State for Trade and Industry to respond
to letters from Al-Fayed and one of his professional advisers.
(ii) On 27 May 1988, I tabled two written
questions to the Chancellor of the Duchy of Lancaster querying
the costs and delay of the Department of Trade and Industry enquiry.
(iii) At the beginning of April 1989, I
tabled four Parliamentary Questions relating to Lonrho and its
associates. See document no. 365 in the Jury Bundle.
The two written questions tabled in May 1988
were drafted by me. The first draft of each of the remainder
of the questions referred to above was prepared by Al-Fayed's
legal advisers, Mr Michael Palmer and/or Mr Royston Webb, and
Mr Greer and/or the IGA advised further on the wording, subject
to my approval.
There is nothing unusual or inherently improper
in an individual drafting Parliamentary Questions for the approval
of a Member of Parliament or agreeing the wording of a question
with a Member of Parliament. Journalists sometimes do this in
pursuit of a story. David Hencke prompted the Labour Party to
raise on the Floor of the House on the night of 19 October 1994
the allegations which were to appear in his article in the following
morning's issue of The Guardian.
4. I tabled the following Early Day Motions on
the following dates:
(i) On 10 March 1987, I tabled an EDM
deploring Parliamentary attacks on Al-Fayed and congratulating
the Government for allowing Al-Fayed's company to acquire Harrods.
(ii) On 14 July 1988, I tabled an EDM
condemning the "barrage of libellous and vicious propaganda"
issued by Mr Rowland with reference to The House of Fraser and
requesting the Secretary of State for Trade and Industry to call
upon the Inspectors to complete their Inquiry without delay of
another Member's EDM. See document 336 in the Jury Bundle.
(iii) On 18 April 1989, I signed, with
others, an EDM calling upon Mr Rowland to divest himself of his
interest in The Observer. See
document No. 367 in the Jury Bundle.
(iv) On 3 May 1989, I tabled an EDM calling
for an investigation into Lonhro's operations in the light of
its close links with Colonel Gadafi. See document No. 372 in the
(v) In May and June 1989, I signed, with
others, four EDMs condemning Mr Rowland's interference with The
Observer newspaper and criticising Mr Rowland in various respects.
See document 373 in the Jury Bundle.
I played no part in drafting or tabling the
EDMs dated 18 April or any of those tabled during the months of
May or June. I was merely an additional signatory.
I repeat once again that there was and is nothing
wrong or improper in tabling such motions in The House of Commons
concerning matters which accorded with my political beliefs and
which were, in my opinion, appropriate matters to draw to the
attention of the House.
5. The £18,000
5.1 The use to which the £18,000 paid
by Al-Fayed to Ian Greer was put is well documented: it was used
to cover General Election expenses for the election held in June
5.2 £29,250 was distributed between
various constituencies, mostly to contribute towards the fighting
funds for the election. Attached to this schedule, marked A,
is an extract from the IGA papers, which sets out in detail how
the money was accounted for. It will be noted that the Members
of Parliament and unsuccessful candidates listed are drawn from
all parties, and that my name was not among them.
5.3 I am informed, by Andrew Smith, who was
employed by IGA, latterly as Managing Director of the company,
that the manuscript notes at the foot of the page represent contributions
to items of office equipment such as a new photocopier (for Andrew
Bowden's constituency), the cost of providing security for Lynda
Chalker's Constituency Offices, the election booklet published
by IGA and a contribution towards the Liberal campaign in the
5.4 I understand that copies of all cheques
and bank statements continue to be available at IGA's then bankers,
5.5 So far as I am aware The Guardian
have never supplied any documentary evidence for their statement
that "IGA paid over part of the [£18,000] to me"
(sub-paragraph 7 of The Guardian's Particulars of Justification).
The allegation is fabricated, as is confirmed by Ian Greer (see
page 13 of the witness statement he signed on 27June 1995).
5.6 The fact that this allegation is proved
wholly false substantially reduces the credibility of the other
allegations set out in your letter of 7 January.
6. Cash for Questions
6.1 The allegation that I received payments
in cash for Parliamentary services provided to Al-Fayed has varied
as to the amount, the manner of payment and the purposes for which
they were alleged to have been made.
6.2 The first occasion on which these payments
were drawn to my attention was in the form of a typed note handed
to me by Sir Robin Butler in the late Summer of 1994. The allegation
then was that I had received the sum of £50,000 via Ian
Greer to ask 17 Parliamentary Questions on behalf of Mr Fayed
(see the witness statement I signed on 27 June 1995, paragraph
88). This equates to £2,941.18 per question.
6.3 On October 20 1994 The Guardian
published an article stating that the monthly payments to IGA
varied according to how many PQs had been tabled; this repeated,
in principle, the allegation that the payments were, firstly,
channelled through IGA, and secondly that their amount was geared
to the number of questions asked.
6.4 Later on the same day Royston Webb,
legal director of the House of Fraser, denied any knowledge that
money was paid by the House of Fraser in exchange for the tabling
of PQs. He also stated that, to his knowledge, the agreed annual
fee was paid monthly, and did not vary in amount apart from "the
odd expenses here and there".
6.5 On 6 December 1994 Fayed stated in his letter
to Sir Geoffrey Johnson-Smith, that he personally paid me £28,000
in cash and gift vouchers. This was the first occasion upon which
it was alleged that I was paid cash direct rather than via IGA
6.6 On 14 December 1994 it was alleged, in The
Guardian's defence (paragraph 10), that I received a total
of £28,000 (or thereabouts) in instalments of £2,500,
or alternatively Harrods gift vouchers in £100.00 denominations.
These were said to have been handed over to me personally either
at Harrods or at Al-Fayed's Park Lane offices on various dates
between 1987 and 1989. The Guardian's Defence also stated
(paragraph 9) that Al-Fayed gave to Greer cheques totalling £18,000
for the specific purpose of making payments to myself and Smith
for tabling PQs. There was no suggestion in the Defence that Greer
(i) Paid cash.
(ii) Received funds for his own benefit
other than in the normal course of business.
6.7 On June 23 1995 Al-Fayed signed a witness
statement in which he stated that he had informed The Guardian
in the Autumn of 1994, that he had paid me "£2,000 per
question". On this basis, having tabled nine PQs/motions,
I would have received £18,000. In the same witness statement
he acknowledged that the figure he had given to The Guardian,
which by inference purported to be accurate at the time, was in
fact "a rough guess".
6.8 In the same witness statement (paragraph
7) he refers to three cheques he gave to Ian Greer amounting
in total to £31,333, "to enable [Greer] to pay [myself]
and Tim Smith for Parliamentary work". Added to the amount
of cash I was alleged to have received (Guardian's Defence
paragraph 10), and deducting the £6,000 said to have been
paid to Tim Smith the overall total amounts to £53,333.
6.9 In paragraph 4 of his witness statement
Al-Fayed states that the money he gave to me "did not correspond
to a particular tariff for services". This directly contradicts
his earlier statement (paragraph 6.7 above).
6.10 In September 1996 documentary evidence
was produced by Greer showing that the three cheques referred
to in paragraph 6.8 above represented legitimate payments no part
of which, moreover, were intended for or received by me.
6.11 The Guardian responded to the disclosures
in paragraph 6.10 above by alleging, for the first time that
Greer/IGA received regular cash payments in a sealed envelope
(paragraph 5B). It is not suggested that the cash was destined
6.12 Paragraph 4 of Al-Fayed's witness statement
records that my meetings were with him alone and that "no
one else would have seen the money being given to Mr Hamilton".
6.13 A few days before the scheduled date
for the trial, in September 1996, Al-Fayed's solicitor served
a witness statement sworn by Alison Bozek in which she states
that she inserted bundles of cash into envelopes, the back of
which she signed. This contradicts Al-Fayed's witness statement.
6.14 A further witness statement was served
at the same time by a Mr Bromfield, employed by Al-Fayed as Security
Officer. In paragraph 3 of the statement he states that he handed
me envelopes on two separate occasions. This also conflicts with
the statement that "no one else would have seen the money
being given to Mr Hamilton".
6.15 Iris Bond records, in paragraph 4 of her
witness statement, that "Fayed would in my presence place
two bundles of £2,500 notes in £50.00 denominations
in a plain envelope which he would then instruct me to deliver
to Mr Greer". It is not clear why it was necessary for Al-Fayed
to maintain secrecy with regard to the payments allegedly made
to me, but not with regard to the payments allegedly made to Mr
6.16 In paragraph 4 of Bromfield's statement
it is recorded that Mr Greer also collected envelopes from the
front desk; the inference is that the envelopes contained cash.
This allegation had not been made before; it appears neither
in Al-Fayed's witness statement nor in The Guardian's defence.
6.17 It is not clear how a business-man
of the seniority of Al-Fayed makes a routine practice of parting
with substantial sums in cash without maintaining any record
of how much was paid and to whom.
6.18 It is equally unclear how a business-man
of the apparent perspicacity of Al-Fayed can routinely part with
large sums of money without specifying, either on paper or verbally,
what he expected to receive in return.
6.19 It is not clear whether these alleged cash
payments were drawn from his own personal bank account or whether
they represented monies belonging to the House of Fraser; if the
latter, no evidence has been submitted as to how the withdrawals
of cash were described in the company accounts, or whether the
monies allegedly paid to me and others were deducted from the
company's profits for the purpose of assessing tax.
6.20 On pages 21-24 of my draft submissions
I have set out the chronology of the alleged payments and the
relationship between them and my Parliamentary activities. The
schedule demonstrates that large amounts of money were allegedly
paid for doing nothing, and bursts of activity on my part went
6.21 It is evident from the documents produced
on discovery, and from Fayed's telephone message records, that
Ian Greer was meticulous in reporting back to Al-Fayed on all
Parliamentary activities undertaken which affected the interests
of the House of Fraser. There is, however, no record of the payments
alleged to have been made either to Greer or to me in exchange
for these activities (other than those made by cheque to IGA in
the proper course of business). This inconsistency requires explanation.
6.22 Al-Fayed maintains that I was given
Harrods' gift vouchers in units of £100.00; his aide records,
in the News of the World on 23 October 1994, that I was
given £1,000 vouchers. Likewise, whereas Fayed has consistently
maintained that I was given gift vouchers to the value of £8,000,
his aide referred to their total value as "around £15,000".
6.23 Since Harrods gift vouchers constitute
a contingent liability of the issuing company, for which provision
would have to be made in its accounts, it is difficult to believe
that Harrods accounting systems would fail to record both the
issue of gift vouchers and their receipt at the till in exchange
for goods. No evidence has been given as to the manner in which
Harrods accounted, at that time, for the distribution and use
of gift vouchers.
6.24 It was alleged that I received payments
in either cash or Harrods gift vouchers on 20 February 1989.
Timothy O'Sullivan, who was with me throughout the meeting, records
in paragraph 5 of the witness statement he signed on 26 June
1995 that: "Neil was not at any time alone with Mr Al-Fayed.
Mr Al-Fayed did not at any time during the visit give Neil any
money, whether in the form of cash, cheques or otherwise. Nor
did Mr Al-Fayed give Neil any vouchers".
The inconsistency of the gift voucher allegations
is explored further in chapter 2 of my submissions, commencing
on page 9.
6.25 Copies of Al-Fayed's bank statements showing
the cash withdrawals over the relevant period have not been produced.
6.26 The inconsistency of the cash allegations
is explored further in Chapter 2 of my submissions.
6.27 The issue at the heart of these allegations
is the credibility of Al-Fayed and his three witnesses. Reference
is made in this context to the Christoph Bettermann case, the
DTI Inspector's report of 1990, Professor Barry Rider's evidence,
and the documentary evidence volunteered by Mr Tiny Rowland of
Al-Fayed's abortive attempts to persuade him to sign a false
affidavit. (See appendices 1-4 of my draft submissions.) Further
evidence will be forthcoming of other victims of Al-Fayed's vengeful
7. Further unspecified sums in cash
7.1 I repeat the same comments in relation
to this allegation as I have made in paragraph six, and I repeat
7.2 No explanation is offered as to why Al-Fayed
can remember the dates referred to in paragraph six above with
such apparent precision, but fails to have even an approximate
recollection of the dates upon which the payments referred to
in paragraph seven were alleged to have been made.
7.3 The same comment applies with regard
to the amounts of cash alleged to have been paid.
7.4 If I am to be charged with corruption,
it is incumbent upon those making the allegations to provide
more than the bald statement that I received "unspecified
further sums in cash on unspecified dates".
7.5 The comments contained in paragraph 6
above apply equally to the allegation that I received between
£2,000 and £3,000 in cash prior to my departure for
Paris ("the Paris cash").
7.6 No date is given by Al-Fayed for the
collection of the Paris cash; given that he is fully aware of
the dates upon which I stayed at the Ritz, this admission is
7.7 Mrs Hamilton and I drove to Paris direct
from my constituency, staying the night with my parents in Portsmouth
on the way. We did not drive through London.
7.8 The journey to Paris took place in the
middle of the summer recess. I left London at the beginning of
the recess, and did not return there until after our return from
Paris. There was no reason to do so.
8. Introductory Commissions
8.1 I am informed that it is usual practice
in the lobbying industry for introductory commissions to be paid
to persons introducing new clients. IGA adheres to this practice,
and in that context I was paid two commissions: £4,000 in
respect of the National Nuclear Corporation ("NCC")
and £6,000 on account of US Tobacco Inc ("UST").
The commission payment was calculated at the rate of 10 per cent
for the fees paid to IGA by National Nuclear and 5 per cent with
regard to US Tobacco. With regard to the former, part of the payment
was paid in kind, by discharging the three accounts referred
to in paragraph 1, 2 and 3 of paragraph 8 of your letter; the
balance was paid by cheque on 13 July 1989. Payment of the £6,000
commission payment from UST was paid at the same time.
8.2 The circumstances in which I introduced
both companies to IGA are set out in my submission.
8.3 I was not required or expected to undertake
any services in exchange for this payment, nor did I; it was
paid solely on account of the introduction. I did not think at
the time that such payments could reasonably be thought to influence
my conduct in the House, nor in fact did they do so.
8.4 I was not aware that it was normal
practice to pay fees for introducing clients at the time I introduced
NNC to Greer.
8.5 I served as a consultant to NNC for a
period of one year from 1 November 1987; my interest was registered
in the normal way.
9. US Tobacco
9.1 I have referred in the foregoing paragraph
to the introductory fee I received from IGA in relation to US
Tobacco. The circumstances in which this came about are set out
in my submission. I was not a consultant to the company. I did
not table any PQ's relevant to the tobacco industry.
9.2 The tabling of the EDM referred to in
paragraph 9(iii) of my statement was a function of my long-standing
conviction that those who wished to enjoy tobacco should have
the right to do so. I have been a supporter on FOREST's mailing
list since its inception in 1984.
9.3 In October 1989, I visited the United
States with the Treasury Select Committee. Our itinerary included
two days in New York. On account of my connection with US Tobacco
and my friendship with the Senior Vice-President of Marketing,
I informed them in advance that I was intending to be in New York.
The Vice-President wished to return hospitality I had given to
him in London, and I was invited to extend my visit in New York
to attend a dinner party. I was invited to stay in the rooms permanently
retained by US Tobacco at Essex House for those two days. He
suggested that, rather than switch accommodation, I should stay
at Essex House for the time during which I was present in New
York as part of the Treasury Select Committee, while they stayed
at the Intercontinental Hotel, an hotel of comparable standard.
9.3 I stayed for one night at St James'
Court Hotel at Buckingham Gate, Westminster during the Summer
recess in 1989. This was paid for by US Tobacco. I was invited
to attend a dinner with them in London. My flat at the time was
lent to American friends on holiday in London, and it was not
possible to return to my home in the constituency following the
dinner. Hence US Tobacco offered me a night's accommodation.
9.4 Neither accommodation can reasonably
be described as a "benefit", in that on both occasions
the accommodation was a direct consequence of, and necessary
for, the discussions between myself and US Tobacco. The function
of the discussion was to obtain information so that I could exercise
my judgment as a Member of Parliament and make informed decisions
on a matter of political interest to me.
10. Meetings with Ministers regarding The House
10.1 I am not embarrassed to confirm that
I met, and wrote to, Ministers to advance the cause of Mr Al-Fayed
and/or the House of Fraser. This was a routine and legitimate
activity engaged in by Members of Parliament in pursuit of their
adopted political objectives.
10.2 I did not disclose "the fact"
that I was being paid by Mr Ian Greer and/or Mr Al-Fayed because,
as outlined earlier in this schedule, I neither sought nor received
any such payment. The two payments I received from Mr Greer had
no connection with Al-Fayed.
11. The Ritz
11.1 The hospitality which Mrs Hamilton and
I accepted at the invitation of Al-Fayed at the Ritz Hotel in
Paris has been well documented. I now recognise that it was a
mistake to accept the invitation. Nonetheless, a number of misconceptions
have arisen about it, which I clarify below: 11.2 The invitation
to stay at the Ritz emanated from Al-Fayed through a letter written
to me by Ian Greer on 3 April 1987. Al-Fayed's statement on Channel
4 on 16 January that I invited myself is a fabrication.
11.3 The specified purpose of the invitation
(which was extended to a number of others at the same time) was
to see the Duchess of Windsor's villa in the Bois de Boulogne;
as a member of the SPAB, the Victorian Society and other similar
organisations I had a personal interest in seeing the villa.
11.4 The invitation was postponed following
the announcement of the appointment of inspectors to examine
the House of Fraser takeover, but later renewed by Al-Fayed personally.
11.5 At the time, my relationship with Al-Fayed
was bordering on, if it had not reached, one of personal friendship,
and it was apparent to me that the invitation was extended to
us in that context.
11.6 Mrs Hamilton and I did not ask for private
rooms; we were taken to room 356 (an ordinary double room, as
Fayed confirms in his witness statement, paragraph 10) with which
we were more than content.
11.7 I did not ask to stay at the Ritz
a second time, on our way back to London: we were planning to,
and did, take a return route which went nowhere near Paris.
11.8 Bottles of wine were not itemised on
the Ritz bill. I cannot now remember the cost of the bottles we
consumed, but I do remember they were not excessive in the context
of the Ritz wine list.
11.9 It was not suggested by Al-Fayed, nor
was it so regarded, that our stay at the Ritz was by way of exchange
for services rendered. Insofar as I had rendered services to Al-Fayed
and/or the House of Fraser, it was because my political views
coincided with their interests in relation to the national issues.
My actions were wholly consistent with my long-held and well
documented views on these issues generally.
12. Estate in Scotland
12.1 Mrs Hamilton and I spent two nights
in a flat above some converted stables on Al-Fayed's estate in
Scotland in 1989 in company with Sir Peter and Lady Hordern.
We were on a touring holiday in Scotland. The invitation to stay
there was offered by Al-Fayed in his capacity, as I thought, as
a personal friend. The invitation was not extended, in return
for services rendered, nor did I regard the invitation as such.
13. Harrods gifts
13.1 I have nothing to add to the information
contained in my letter of 17 January, save two points: 13.2
The value of the gifts received from Al-Fayed bore an approximate
relationship to the value of gifts given by me to him in exchange.
13.3 Al-Fayed is well known for distributing
gifts of this kind to a substantial number of persons in a position
of influence, including Mr Hencke (a teddy bear - see his witness
14. Registration of Interests
14.1 I did not declare the payments referred
to in paragraphs 5, 6 and 7 because I did not receive them.
14.2 I did not declare the accommodation
referred to in paragraphs 9, 11 and 12 on the grounds that I did
not believe that, under the rules prevailing at the time, they
were registrable interests; and in relation to the accommodation
in paragraphs 9 and 12 the value of the benefits received is,
in my opinion, de minimis.
14.3 I accept that, in the current climate,
both my stay at the Ritz in Paris, and the receipts of commission
payments should have been registered. Under the rules prevailing
at the time the position was a great deal less clear, and I draw
attention in particular to the statements made by the Members
Interests Committee in the First Report, Session 1994-95 at paragraphs
13 and 17. My submissions on the registration issue will follow
in due course.