Select Committee on Standards and Privileges Written Evidence

7.  Written statement by Mr Iain Duncan Smith, 9 December 2003

[See also Volume III, PCS Oral Evidence 3]

Complaint by Michael Crick (13-17 October 2003) against Iain Duncan Smith MP

I, Iain Duncan Smith, Member of Parliament, House of Commons, London, SW1A 0AA, believe that the contents of this statement are a full and truthful account of the matters in question to the best of my knowledge and belief:


1.  This statement is made in response to letters received by me from Sir Philip Mawer, the Parliamentary Commissioner for Standards ('the Commissioner') dated 13 and 20 October 2003 in relation to a series of complaints made to him by Mr Michael Crick, copies of which are exhibited to this statement,[13] and arising from an investigation carried out by Mr Crick over the previous five months for the BBC Newsnight programme. I will at times have to be critical of some witnesses, not because it is in any way relevant to deciding the substance of the complaints made against me because these witnesses have made statements about me which I believe I am entitled to comment in order to put the record straight. I regret that I also have some concerns about the procedures for this investigation, some of which appear sufficiently in my narrative, and I shall be taking these up with the Commissioner in person.

2.  This statement is also made in response to a letter from the Commissioner dated 5 November 2003, containing specific questions addressed to me, a copy of which exhibited to this statement.[14] This letter was sent after the Commissioner had conducted extensive interviews with witnesses including my personal staff. Accompanying the Commissioner's letter were some documents, as selected by the Commissioner, that he invited me to comment on, including written statements and part-transcripts of interviews between the Commissioner and some of the witnesses. I understand from the Commissioner's letter that these documents contain the statements which the Commissioner regards as supporting the complaints against me.

3.  I categorically deny each and every allegation that the Commissioner has notified to me in the course of his investigation of the complaint from Mr Crick.

4.  In order to deal with each of the Commissioner's requests I have structured my statement in the following manner:

Section 1—My response to the specific questions set out in the Commissioner's letter of 5 November.

Section 2—My comments in response to the Commissioner's letters of 13 and 20 October setting out the general allegations against me, which inevitably includes some consideration of procedural issues.

Section 3—My specific observations on selected statements by witnesses as supplied to me by the Commissioner with his letter of 5 November or subsequently. For the avoidance of doubt, I should not be taken to accept any adverse allegation or suggestion in any statement because I do not comment on it in this statement. I intend to, separately, make written submissions concerning the material the Commissioner has provided.

Section 4—My understanding of the conduct and motivations of Vanessa Gearson and Mark MacGregor.[15]

5.  I fully recognise that Section 4 is not strictly necessary to determining the allegations as set out by the Commissioner in his correspondence but it is nevertheless important that as these people have stated their own opinions and assertions concerning me on the record I should respond to them and also state what I believe to be their real conduct and motivations in doing so for the benefit of the Commissioner and the Committee.

Section 1

The following answers relate to the letter from the Commissioner dated 5 November 2003[16] and I have adopted his numbering system for the questions.

A1. Can you briefly run through the nature of the work your wife did for you before you became Leader and how that changed (if it did) in nature and volume after you were elected to that position?

6.  I have read my wife's statement to the Commissioner. The nature of the work my wife did for me prior to becoming Leader of the Opposition is set out in her statement [paragraphs 5-11, 27, 78-80]. Details of the nature of her work after I was elected Leader are also set out in her statement [paragraph 18-81]. I adopt my wife's statement as my own on these matters and elsewhere where I refer to it.

A2. You say in paragraph 2 of your joint submission that your wife worked considerably longer than 25 hours a week. To what period does that relate? How do you justify that statement?

7.  I confirm, as set out in my wife's statement [paragraph 29], that my wife worked at least 25 hours a week for the whole of the relevant period, from my election as Leader in September 2001 to 31 December 2002. The evidence for that statement is set out in my wife's statement [paragraphs 29-37].

A3. You refer in your joint submission to the move to Swanbourne "where an office was established at home" (para 4). What was the nature of the office which was established? When was it established? The e-mail from Dr Gearson of 30 January 2003 (of which you already have a copy) suggests that substantial work equipping a new office at Swanbourne was undertaken towards the end of 2002 or early in 2003. What is your explanation in respect of the timing of this work? (para 7 of your submission is also relevant).

8.  The office was a dedicated suite for the use of my wife in her employment. It was in use immediately after my wife and I moved to Swanbourne to live. My wife describes the office and its contents at paragraph 46 of her statement. I adopt what my wife says about Offices 1, 2 and 3 in her statement [paragraphs 46-48, 50-52]. My wife sets out in detail the works carried out equipping and refurbishing an office for her use at [paragraphs 47-48, 52]. The e-mail from Vanessa Gearson refers to invoices which were for re-wiring. There was no new office, there had always an office, as Vanessa Gearson would have known if she had ever visited Swanbourne. I enclose a copy of the original invoice specifying those works which Vanessa refers to in her e-mail.[17] No explanation is required for the timing of this refurbishment, Vanessa never visited Swanbourne and her assumptions are erroneous.

A4. In paragraph 5 of your submission, you refer to the role of your wife in providing continuity as you set up your new office as Leader. What was the substance of this role? What was the substance of your wife's work in "an advisory and supporting capacity" during the various subsequent changes and upheavals in your office (para 10).

9.  I have set out in Section 2 the role of my wife in providing continuity and in an advisory and supporting capacity.

A5. Also in paragraph 5 of your submission, you say that it was your joint intention with your wife that she should give up work "once all the appointments were settled". When did you conceive this intention? Did you communicate it to anyone else? If so, how and when?

10.  As I explain in more detail in Section 2 [paragraph 37], my wife and I had serious discussions about her giving up work in early summer, 2002. Those discussions were mentioned to Christine Watson (to whom I gave responsibility for administering my staffing allowance) in September/October. The decision to take Betsy off the payroll was made well before the end of November 2002 after discussions earlier that month with Alistair Burt, Owen Paterson and Christine.

A6. In paragraph 6, there is a reference to BDS assisting in clearing an initial backlog of correspondence. How much assistance did she give?

11.  My wife gives details of the work she carried out in this regard at paragraph 27 of her statement.

A7. Paragraphs 8-9 and 11 of your submission describe some of your wife's key working relationships and the content of your wife's work for you. Can you add to this description? The question of evidence in the form of records etc, about which I wrote to you on 20, 27 and 28 October is relevant here. So too is the question whether your wife's work related to your role as a constituency MP or whether it also included your roles as Leader of the Opposition and of the Conservative Party.

12.  My wife provides detailed information about her key working relationships at paragraph 75 of her statement. I have added my own observations in Section 2. My wife's role related to my parliamentary work, both constituency and as Leader of the Opposition.

A8. When did Owen Patterson first raise the matter of Mrs Duncan Smith's employment with you in the autumn of 2002 (paragraph 16)? Why; how did you respond; and with what result? Did your other Parliamentary Private Secretary, Alistair Burt, raise the matter with you (as he informed me he did)? When and in what terms did you inform the Fees Office that you wished to end your wife's employment? Why did you write the letter when you did?

13.  I do not recall precisely when Owen raised the matter with me but I believe it was during the conference in October. I have set out in detail in Section 2 my response [para 67], which, to summarise, was that Betsy was on a contract and I explained the work she did and asked Owen to pass that information on to Vanessa and to ask her to come to me if she still had any concern. The result was that Vanessa never once raised such a concern with me directly so I assumed she had no concern. Alistair also raised the matter with me in November 2002 but in a completely different context as he has informed the Commissioner [transcript, p10]—Christine was anxious that we settle when Betsy was coming off the payroll, part of ongoing discussions we were having, and had raised that with him as part of her concern that we should finalise the staffing allowance budget for the year. Within days, the middle of November, I instructed Christine that Betsy would cease in December and she could notify the Fees Office and we then agreed who the staff would be going forward. Christine Watson, because she administered the staffing allowance, verbally informed the Fees Office of that decision in December and drafted a letter which I signed confirming her instructions to the Fees Office. I can only presume that the means of notice and its timing was selected by Christine because it was what the Fees Office required in order to take Betsy off the payroll at the end of December 2002.

B1. What explanation can you offer for the evidence of successive administrative heads of your office and other staff that they had no knowledge of any significant work being done by your wife for you in the capacity of an employee, prior to your wife's employment being drawn to Dr Gearson's attention by Mrs Watson in September/October 2002?

14.  I have only ever had one administrative head of my office which was Vanessa Gearson, from September 2002 when she joined until she left the job in 2003. Christine Watson informs me that she does not recall drawing the matter of my wife's employment to Vanessa's attention which I believe she would if it had been a concern to her. Jenny Ungless was my former Chief of Staff. Simon Gordon was never an office manager, as he informs the Commissioner in his interview [transcript, p15 bottom of page]. I have set out in detail in Section 2 precisely how Jenny's position was altogether different from Vanessa's position [paragraphs 60 and 61].

15.  All of the members of my staff with whom my wife dealt with in the period after I became Leader to 31 December 2002, Annabelle Eyre, Christine Watson, Andrew Whitby-Collins and Rikki Radford have all given statements that they had knowledge of the work being done by my wife, as have my wife and I. Furthermore, the Commissioner had statements to that effect from these people and my wife on 13 October 2003, prior to his decision to embark on a full investigation on 14 October. It is wholly unremarkable that other members of staff who joined the Leader's Office after I became Leader and, therefore, after Besty had begun working from home in Swanbourne which includes in order of joining Simon Gordon, Jenny Ungless and Vanessa Gearson, and who had no professional reasons to contact or deal with her, would have seen little or no sign of her work. My wife was working with a very limited group of people, focussed on the private office.

16.  Indeed, Vanessa Gearson joined the Leader's Office in September 2002 during the recess and, allowing for the party conference in October, the 2 weeks she spent away from the office in November visiting her father in Florida, and for the Christmas to New Year recess, had only been in the office for perhaps three months before my wife finished her employment in December during which Betsy was winding down her role. That period from September to December was anything but typical, given that I was often out of the office (at conference, on tour or at home during the recess) and because of the staffing changes going on. Simon Gordon recalls from the previous year after I became Leader, in 2001, that although "I did not have an overview at all of who was doing what"[18] "I recall occasional mentions that Betsy was dealing with something or other, which I would assume meant that she was working with Annabelle Eyre on some project"[19]. The same limiting factors must be applied to the statements of anyone who did not work in the Leader's Office, namely Mark MacGregor, Stephen Gilbert and Theresa May. All of these people took up their various postions in CCO after my wife had begun working from Swanbourne. My wife was employed by me, not CCO, and she was employed to assist me with my parliamentary work as opposed to party-political activities, so she had no reason to come into contact with any of these people in a professional capacity. Not one single witness interviewed by the Commissioner even attempts to claim that they knew that my wife was not, or could not have been, doing the work which the Commissioner has been informed by me that she was doing. They all concede that she could have. At highest, their statements are that they saw no evidence of her work which is in no way inconsistent with what the witnesses who did work with Betsy, and who have given statements, are saying.

B2. Whether your recollection of the events of the autumn of 2002 chimes with that of Dr Gearson and Mr MacGregor, in that they assert that you only took action to end your wife's employment after the Michael Trend story broke (on 15 December 2002)

17.  The Michael Trend story first broke in The Mail on Sunday on 15 December 2002. That was the first time I learned of the allegations as the members of the Press Office at CCO can confirm. No-one in the Leader's Office or anyone at CCO knew of the allegations against Mr Trend prior to that date. For the avoidance of doubt, I can confirm that Mr Trend had not privately informed me about the matter prior its publication. As the Leader of the Opposition I would have been one of the first people informed had it been known the story was about to break. My decision to end my wife's employment as I have previously said was taken before the end of November 2002. The suggestion, therefore, that Trend was a factor is unsustainable.

18.  Furthermore the Commissioner has misstated the allegation which is made by Vanessa and Mark; what they in fact allege is that the Trend allegations broke in mid November and that it was a factor in my decision to end my wife's employment. Owen Paterson had informed Vanessa of my decision to take Betsy off the payroll in November and certainly no later than the beginning of December.[20] He would also have notified that decision to the CCO communications group of which Mark was a member. As Vanessa and Mark knew that I had taken the decision to end Betsy's employment in November the allegation that Trend was a factor is one that can only work if the Trend allegations were known in mid November. That is why I believe, they have deliberately claimed and maintained it was mid November when they knew about Trend—to use the Trend case to smear me. There can be no coincidence or doubt that they are both saying they knew about Trend in November because they are also saying that it did influence me to take Betsy off the payroll, a decision they know I took in November. I categorically deny knowing anything about Trend until it was published on 15 December and it had no bearing whatsoever on my decision to take Betsy off the payroll.

19.  Furthermore the allegations against Michael Trend have no relevance to my employment of my wife or the decision of my wife and I that she would quit employment by the end of December. As the Commissioner is well aware the allegations which were made against Mr Trend concerned his claims against the additional costs allowance in respect of expenditure in relation to his main home (and constituency house) in Windsor. I fail to see how such an allegation could have raised any issue in my mind about whether I should be employing my wife, or in the mind of any other MP who was employing his spouse at that time. I see nothing in the statements of Vanessa Gearson or Mark MacGregor which even attempt to explain why the Trend allegations might have been thought relevant to the issue or produced a link in their minds or anyone else's to my employment of my wife. If the Trend allegations had in fact triggered a concern in Vanessa in November as she claims (which assumes she had knowledge which neither I, the shadow cabinet, the Chairman or the CCO Press Office had), or even in December when the allegations were published why is it we see no evidence of that particular concern prior to her 30 January 2003 e-mail, a full month after my wife had ceased employment and over two months since the decision had been taken? Vanessa's reference to the Trend allegations, and for that matter to a 'Crick style investigation', seem to me to have been inserted into her e-mail of 30 January to give it greater impact particularly if it was her intention to leak it to the media at a later stage.

B3. Whether you accept Dr Gearson's account of the circumstances leading up to the dispatch of her e-mail of 31 January.

20.  For the reason's set out in Sections 2-4 of my statement I do not accept Vanessa Gearson's account of the circumstances of the dispatch of her e-mail of 31 January. Furthermore, I do not believe that Vanessa ever sent the e-mail of 31 January in the form of the copies of the e-mails presented to the Commissioner. The copies at Appendices 3, 8 and 9 of her written statement are all drafts; there is no copy of the e-mail as sent, bearing a time and date. My recollection of the e-mail as sent, which Owen confirms is also his recollection, is that it was only three or four lines long which does not accord with the drafts that Vanessa has provided the Commissioner. If Vanessa kept all of these drafts she must also have kept a copy of the e-mail as sent and the Commissioner should insist on having sight of that to confirm its contents and that the e-mail was in fact sent. The Commissioner will observe that the copy of the 30 January e-mail which was submitted has a date and time of sending.

21.  I further deny Vanessa's allegation that she produced the draft e-mail under any implied threat that her job was at stake. Vanessa's explanation is an utterly perverse explanation as it requires one to accept not only there was unspoken coercive conduct on my part but also inappropriate and dishonest behaviour on her part in that she produced and sent an e-mail, the contents of which she now claims she knew not to be true, to the most senior members of the Conservative Party, including the Chairman, Theresa May, with whom she had a close relationship. Vanessa was a councillor and prospective parliamentary candidate for Cheltenham at that time. Is it credible that she was prepared to jeopardise a parliamentary career because she thought that she might otherwise have to resign? Why would she so desperately want to continue to work for me if she believed I was that compromised and compromising? If fact she continued to work with me for another six months until she was transferred back to work at CCO for the Chairman, where she had a position liasing between both offices—even though she informs the Commissioner she wanted to remain in the Leader's Office working for me.

B4. Whether you accept her account of events before, during and after the Party Conference in October 2003?

22.  For the reasons set out in my statement below I do not accept Vanessa's account of events before, during or after the party conference in October 2003 [paragraphs 73-89]. I specifically question her conduct and motives in Section 4 of my statement.

Section 2

23.  The Commissioner's letter of 20 October 2003 was accompanied by a bundle of statements relied on by Mr Crick to support the complaint, which included statements from three anonymous sources, described by Mr Crick as "top-rank anonymous Conservative sources", and transcripts of telephone conversations with Rikki Radford, my constituency agent, and seven councillors from my Chingford constituency. It is my understanding that neither Mr Radford nor the councillors were informed that their conversations were being recorded and, it is clear from the transcripts, that they were deliberately misled about the true subject of the investigation (see Crick's document marked 'MC7') e.g. Louise Weston of the BBC to Geoffrey Walker: "we're just looking at the role of MPs within their local constituency"[21] and same formula is recited to Michael Fish, Linda Huggett, Laurie Braham, Matthew Davis), which was my wife's employment. These appear to me to be serious breaches of the BBC's Producers Guidelines. I have instructed my solicitors to ask the Director-General of the BBC for an explanation of this conduct and whether this conduct was authorised by senior management as the Guidelines require.

24.  The allegations made by Mr Crick concerning my wife had, in apparent frustration, been passed to the media by him when the BBC failed to broadcast his programme as planned on 2 October, including rival broadcasters ITV and Channel 4. The media briefing must have taken place the same day, Thursday 2 October, because the Conservative Central Office ('CCO') Press Office was inundated with calls that day concerning the allegations. The allegations were then reported in the national press on Sunday, 5 October. Further allegations by Vanessa Gearson were published on Sunday, 12 October. Mr Crick made a complaint to the Commissioner on 13 October. Despite Mr Crick's denials that he was responsible for briefing the press, a number of papers were indicating at the outset that the allegations came from Crick and using phrases such as "what Crick is saying is ...". I was subsequently informed by Greg Dyke (and it has also been reported in the press) that Crick has been suspended by the BBC pending the outcome of this investigation.

25.  I was first contacted by Mr Crick by telephone on 29 September 2003. Mr Crick then sent a letter to me dated 29 September, after he has now informed the Commissioner he had been investigating the matter since May, fishing to see if Betsy was still working for me in 2003 which says something about the quality of his research and information, and borne out by the fact that he had to change the nature of his complaint after the initial complaint on 13 October.

26.  From the outset when we were first contacted by Newsnight it was suggested to them that if they considered they had credible material they should take it to the Commissioner. Some years ago I sat on the Nolan Committee and subsequently the Committee on Standards and Privileges which established the current role of the Commissioner and his procedures [Third Report, session 1995-95, see particularly paragraphs 66-69]. Accordingly, I thought that process would provide a confidential and rapid resolution of the matter. Particularly bearing in mind that the original allegation fell within such a very narrow compass, as set out in the letter from the Commissioner to me of 13 October. I was also aware of the strict contempt of Parliament rules of procedure which I hoped would prevent a trial by media while this matter was being investigated by the Commissioner. Instead, however, Crick chose to make his allegations to the media and they were published in his own name (and some re-published from 5 October) on Sunday 12 October and Crick and some of his witnesses appear throughout to have ignored these rules by leaking their evidence and briefing the media.

27.  Once Crick's allegation that my wife was being paid for doing no work (the same allegation he made to the Commissioner on 13 October) was made public I decided that I would proactively rebut it to the Commissioner and I presented him with a bundle of documents during a meeting with him on 13 October, which included a summary of the statements my wife and I could give if he considered that a full investigation was warranted. The same day, with prior notice to the Commissioner, I responded to the attack on me and my wife through the Press Office by providing details of the work my wife did and selected statements from the members of staff who had worked with Betsy. It was politically imperative that I make it clear to the media that the allegations were denied and that there was evidence supporting the denial. Following that press release, neither myself or any of my staff briefed the press concerning our statements to the Commissioner. I observe that Mr Crick's documents passed on to me by the Commissioner includes one which is entitled 'Analysing the Central Office press statement'[22] in which he poses questions for the Commissioner to ask of the witnesses which did not support his complaints.

28.  The Commissioner notified me in a letter dated 14 October, and confirmed in a letter to me dated 20 October, that he had resolved to conduct a full investigation the day after Mr Crick made his complaint (14 October). The Commissioner knew at that time that Mr Crick had not submitted all of the documents he intended to, or articulated all of his complaint. The Commissioner issued a press statement on 14 October.[23] Mr Crick's complaint was not finalised until Friday, 17 October, by which time it had expanded considerably into wholly novel areas concerning other members of my staff. The letter of 20 October from the Commissioner also informed me for the first time of the new allegations made against me by Mr Crick and that the Commissioner had already commenced interviewing people he thought were relevant to the allegations as part of his full investigation.

29.  I believe Mr Crick's attitude has been influenced as much by his need to protect his reputation and to establish his credibility in the eyes of the BBC who did not feel there was sufficient material to support his Newsnight programme and who subsequently suspended him. I do not understand, however, why Mr Crick was given further time to produce more documents and allegations when he chose following a five month investigation to make the complaint on 13 October, a complaint which had already been briefed to and reported by the press on the two previous weekends, and after I had prepared and entered documents on 13 October to rebut the complaint which was made that day by Mr Crick.

30.  I subsequently requested that the Commissioner provide me with a statement setting out his assessment of the nature of the allegations and the standard of proof by which he would assess them, which I understood was the procedure followed by the Commissioner and approved by the Committee in its report on the complaint against Mr John Maxton and Dr John Reid [Second Report, 2000] ('Reid'). By "nature" I mean, of course, whether the allegation is one of negligence or dishonesty etc. In a letter dated 23 October from the Commissioner I was informed that he had formed no view on which standard of proof might be appropriate.[24] I was subsequently informed by the Commissioner by letter dated 30 October that he would consider the standard of proof question when he came to draft his report to the Committee.[25] I presume he will also consider the nature of the allegations at that time as well. It appears to me, therefore, the Commissioner could not have carried out a preliminary investigation of the Crick complaint.

31.  I also requested from the Commissioner an assurance that I would be provided with copies of all of the statements received by the Commissioner in the course of his investigation, so that I would have the opportunity to comment on those statements or make submissions based upon them to the Commissioner and the Committee. Again, that is the procedure which I understood was followed by the Commissioner [paragraph 112 of her Memorandum to the Committee, Appendix 1 to the 2nd Report] and approved by the Committee in the Reid decision [paragraph 11 of the 2nd Report]. However, I was informed by the Commissioner in his letter of 30 October that I will only be provided with the material which the Commissioner judges to be relevant to the preparation of his report to the Committee. I received such a bundle of material with the Commissioner's letter 5 November. It does not seem fair to me that I should not be aware of all of the material received as I am having to defend myself against serious allegations and I may want to rely in my defence on material, or make submissions about, material which is not being provided to me.

My wife's role and the staff changes

32.  I have read my wife's statement to the Commissioner and adopt it as my own so far as it is relevant to my statement and within my knowledge and belief.

33.  My employment of my wife has always been completely transparent. Her employment and salary has been administered from the beginning to the end by the Fees Office, who have never raised any inquiry concerning her employment. The Fees Office only lays down very general rules concerning employment. I exhibit a statement from the Fees Office setting out all of the salary payments which Betsy received.[26] Those payments were never more than was recommended by the Department of Finance and Administration for a senior secretary. It is common practice for MPs to employ spouses and other family members, perhaps unsurprisingly given they need to be able to trust their staff implicitly and that they have limited resources in the way of wages to offer their staff.

34.  I employed my wife from 1992 to the end of 2002. Before Betsy came to work for me she was already an experienced senior secretary and personal assistant. Having worked with me for 10 years, my wife was the longest serving member of my Parliamentary staff and a person on whom I relied completely during that period. Betsy has the longest knowledge of my constituency matters and how I worked as an MP. Her work was always of the highest standard and she is one of the most efficient people I had ever met. Without her my job would have been unmanageable in those first fourteen months after I became Leader.

35.  At all times my wife answered directly to me as her employer and not the Fees Office or, indeed, any other person in my constituency office or the Leader's Office. As her employer I decided what work was to be done and it was for me to determine what work she did and for me to be satisfied that she did a satisfactory job. Her work was always satisfactory.

36.  When the Fees Office in 1997 introduced the requirement for a written agreement my wife and I settled its contents together. At that time I was not the Leader and it was not prepared with that possibility in mind. However, the scope of the duties referred to in that contract is sufficient in my opinion to cover her duties in working from the office in Swanbourne, notwithstanding that she was not the 'Diary Secretary' after Andrew Whitby-Collins took over that job.

37.  We had always agreed that Betsy would fulfil her employed role until we felt that the Leader's Office I had yet to establish was functioning satisfactorily. From the time I became Leader Betsy was under considerable pressure to take a larger role in my public life and to accompany me on tours, which she could not do and work at the same time. Betsy and I first seriously discussed her giving up her job in early summer of 2002. By the end of July 2002, however, I realised that several staff changes had to be made in the constituency and Leader's Office. With the increasing workload, and the re-shaping of the office I had planned, that took far longer than we anticipated. The staffing changes took place from September to late November. My wife ended up working longer than we wanted her to because my offices had not yet reached the point where the staffing moves and new staff employed in late 2002 had settled into their roles. That meant increased pressure on Betsy and me post-conference (in October) when I went on tour, and most work was done at home on weekends and while my Private Secretary, Christine Watson, was preoccupied training Cara Walker to be the Constituency Secretary and Paula Malone was learning the 'ropes' as the new Diary Secretary. Indeed I was out of the office for most of September and October and parts of November and December. It was not until mid November that I was sufficiently confident with the running of the offices to confirm to Christine Watson that Betsy would go off the payroll in December. That decision was also notified to my Parliamentary Private Secretaries.

38.  Mr Crick's original complaint was that my wife was not working at all in the period from 14 September 2001 to 31 December 2002. The Commissioner then informed me that he has added to that complaint (1) to the extent Betsy carried out tasks they were minimal and (2) that any work undertaken did not amount to 25 hours a week and so did not justify her salary and (3) that some of that work undertaken was party-political and so did not qualify for payment from my parliamentary allowance. The 25 hour figure was originally inserted in the contract for the benefit of my wife and at a time when I was only an MP; it was an indication of the hours which we calculated at that time she would be available to work in the office (10am-3pm) because my wife also delivered and picked up our children from school. However, Betsy often worked longer hours from home. We had a fully functioning office in Tournay Road throughout. She was always on call the way no other member of staff would have been. That continued when we moved to Swanbourne in summer 2001.

39.  When I also became Leader of the Opposition my workload increased dramatically and my wife ended up working more than 25 hours a week, until she finally left in December 2002, along with my other Parliamentary staff who also worked far in excess of their contractual hours. Having said that, anyone who knows anything about the business of Parliament knows that it is not a field in which MPs or their staff, let alone the Leader's staff, can expect to work to set hours or within a fixed job description all of the time. More often it is the case in Parliament that the job you do is what needs to be done. For example, Betsy, in addition to her role as Diary Secretary, filled in for Fiona Walker my Constituency Secretary when she went on maternity leave in 1996 and would also fill in for Annabelle Eyre if Annabelle was on leave. Annabelle and Betsy worked together for five years and complemented each other very well.

40.  My wife rarely used her surname in doing her work. She did not want the fact that she was my wife to interfere with the way people interacted with her. For this reason many people who had dealings with her did not know she was my wife and knew her only as "Betsy" or "IDS" diary secretary'. I enclose copies of letters sent to me from people who had read newspaper reports of this investigation, confirming this to be the case.[27] It's my experience, in any event, that people are not as good at remembering my secretaries' names as opposed to their titles. People usually focus on me because I am the Member of Parliament.

41.  With the increase in work that came with being the Leader I decided that I needed an office at home. Prior to moving to Swanbourne in August 2001, we always had an office at our house in Fulham, but it was used primarily after hours. From 14 September 2001 to 31 December 2002 my wife was effectively employed to do all that was necessary to ensure all of my offices operated effectively and together. Significantly, Betsy's working at home allowed me to extend my working week into the evenings and weekend.

42.  There were numerous staffing changes as a result of the need to establish the Leader's Office from scratch. These are political appointments so one does not have the Civil Service the way one would if one were an incoming Prime Minister. As was usual, Mr Hague's staff had all vacated the Leader's Office prior to our arrival and the offices were empty. There were one or two people at CCO who had previously worked with Mr Hague, including a speechwriter but they were not on my staff. Betsy handed over to Andrew Whitby-Collins her day to day Diary role, but she continued to have daily dealings with him concerning the diary. It was a particularly important part of her job to be a progress chaser; ensuring tasks were followed up and done. She contributed to the smooth running of the offices by being a central point of contact for the key staff.

43.  I had hoped that both of my offices, constituency and the Leader's, would be working smoothly by the summer of 2002 and that Betsy would be able to quit. However, Jenny Ungless had not been a success as my chief of staff and so we agreed to wait until the further staff changes had bedded in. I was concerned that although we were getting by the structure of the office meant that we weren't able to focus far enough ahead.

44.  The next shake up took place during August to September 2002. I created the new post of 'Tours' because I realised that the organisation of tours was haphazard and that it had put extra pressure on the Dairy and the private office, one of the reasons why Betsy remained so involved. I also discovered that William Hague also had one person in charge of that role towards the end of his term as Leader. Having watched the early planning of the October/November tour I decided to put Annabelle into this position. I had also observed over the previous eleven months that Christine Watson was efficient and very organised. I brought her in to take over the role of Private Secretary from Annabelle. I asked her to re-order the Box and both Betsy and I explained the shortcoming of the existing system (as it was Betsy and I who went through the Box on weekends). Christine was the only other person apart from myself who had a key to the Box. Cara Walker was employed by me on Christine's request to be the Constituency Secretary. Cara was in the early stages an unknown quantity because so much would depend upon her training with Christine. In that initial two month period I warned Betsy that if it didn't work out she would have to step in and help for a short while until we found someone else. However, Christine felt certain it would work and she was right. Andrew Whitby-Collins left the Leader's Office and the position he had occupied of Diary Secretary to go to the Candidates Department.

45.  Vanessa Gearson was asked to become the Diary Secretary in July following some discussions she had with Annabelle. She declined. I then asked another secretary, Shana Hole who worked in the Whip's office, to do the job and she said she would think about it but also declined. It was after that I interviewed Paula Malone and appointed her. She did not take over from Andrew until the October conference was over. Paula was not up to speed with the work required until November. Vanessa Gearson was eventually employed to oversee the administration of the London office, and to provide as much assistance to Christine as possible. As Vanessa had worked in the Chairman's office as his secretary, she had a knowledge of its workings that I thought would be useful in the Leader's Office as I was keen that those two offices should be closely integrated. I placed particular emphasis on her sorting out the Correspondence Unit which was not functioning as it should. Vanessa did not recruit staff other than in relation to the Correspondence Unit but I expected her to attend to the administration of staff matters such as ensuring contracts were put in place. I personally appointed or approved all staff working for me. No-one could hire or fire staff working for me except with my approval. I made it clear to Vanessa that I had already decided on the changes to the private office. Tom Hooper was the last person to be employed, in November in relation to the constituency.

46.  I also explained to Vanessa that I was not going to re-create the role of Chief of Staff until I decided who would best fulfil that role. The wide remit of the political side of such a position was a key responsibility and would require someone with proven political experience which ruled out Vanessa whose prior experience was limited to working as a secretary/personal assistant. The title I agreed she could have of 'Administrative Head of the Leader's Office' was one she had asked for at the time of our August discussion. I had originally envisaged her title as Administration Manager or Executive Secretary. I had no idea at the time that Mark MacGregor had suggested she should apply for the Chief of Staff vacancy. I explained to her in August before she started she would in due course report to a Chief of Staff. Vanessa to my surprise pressed very hard for the title of 'Administrative Head of the Leader's Office'. I was concerned that it might be misleading as it did not accurately describe her role but it was too trivial a matter to spend time on. I was surprised when I checked the files after this investigation had begun to discover that she had been using the title 'Head of the Leader's Office' and 'Chief of Staff' in correspondence with people outside the office. I should point out in this context that I do not have or use a computer myself so I would not expect to see how Vanessa or anyone else for that matter were describing themselves in e-mails. I was away from the office when Vanessa started but I now have cause to question whether when Vanessa joined the office she introduced herself to the other staff by the formal title I had agreed.

47.  In September 2002 I worked from home when not required in London for meetings or interviews or on visits or tours. I worked on the conference arrangements in October, and the speech I was to deliver at the end of the conference. This speech was to bring together the first phase of our policy development programme which I worked on through September. I brought the speech writing team to Swanbourne to get away from the day to day pressure of CCO and we worked on the early drafts and ideas at those meetings. Betsy and I worked together throughout that period in 2001 and 2002. Betsy was the central point of contact for Andrew, Annabelle and Christine. I was away from my Commons office for an unusually long time in late 2002 because after the conference (7-10 October) I went on tour for three weeks (starting 14 October) which took me to 6 November. Annabelle joined me on that tour. While on tour, all of my other work had to be dealt with in the evenings and weekends with Betsy. At the same time, that September 2002, Annabelle Eyre took leave * * *. As it happens, I also agreed Vanessa could go also go on leave to Florida for two weeks between 6-18 November * * *, and again in early 2003 for the same reason. So Christine Watson came into the Leader's Office when Annabelle and I were absent on tour and Andrew was leaving (he left in October after conference). She was effectively on her own alone in the Commons office, with the added strains of adjusting to her new role as Private Secretary, training Cara Walker, and negotiating her new contract with CCO which was not finalised until November. In such circumstances I can understand the frustration that prompted her to accede to Vanessa's request to produce the 22 October memo, particularly in the context that she was being asked to justify her position to CCO and that she thought Vanessa would be able to assist her in transferring her constituency employment contract to a CCO Leader's Office contract. However, Vanessa did not help her and Christine sent me a memorandum in November saying how disappointed she was with Vanessa. At the same time Vanessa also requested Rebecca Layton to produce a report which Vanessa has also produced to the Commissioner.[28] It is worthy of note that that despite Vanessa's claim to be concerned about Betsy, Vanessa sent no such request to Betsy to explain her role. She did not even try to arrange a meeting with her. If she wanted to know what Betsy did, that would have been the natural thing for her to do.

48.  My Parliamentary duties always extended beyond my duties to my constituency. Every MP has duties beyond those owed to members of the constituency as they also serve the national interest. As the Leader of the Opposition I had numerous Parliamentary duties in addition to those of an MP including speaking in the House, Prime Minister's questions, speeches and visits in the community, ceremonial and official functions. In the period 14 September 2001-December 2002 I had three roles: Member of Parliament, Leader of the Opposition and Leader of the Conservative Party. Only the latter role is a party-political role which is why it is fully supported in its key functions (press, campaigns and donations) by staff paid by the Conservative Party. Conservative MPs also act, unpaid, as my Parliamentary Secretaries ('PPSs') supporting my functions as Leader of the Party and the Opposition. However, I would not accept that there is always a clear dividing line over what is party-political. I observe that the Committee on Standards and Privileges considered that it may be no more than a grey line [Reid Paragraph 45, 2nd Report].[29] Neither would I accept that there is a clear distinction between my work as an MP and as the Leader of the Opposition, as they are both are parliamentary positions.

49.  Betsy did not assist me with party-political tasks in the course of her employment which explains why she had next to no contact with Mark MacGregor, Stephen Gilbert, Theresa May or even my PPSs. The closest Betsy would have come to political work would be in typing up speeches for me or my notes for the party conference but that was only natural given I was working from home on everything at the time prior to the October conferences. The suggestion made by Crick, for example in his Rikki Radford telephone transcript, that my wife might be involved in political activities such as speech writing or with the CCO research department is ludicrous, as Rikki's reaction confirms. In any event as an illustration of the blurred distinctions, Short Money and Parliamentary Allowances can both be used to fund research. It only demonstrates that Crick simply knew nothing whatsoever of Betsy's actual role before she ceased to work for me in 2002.

50.  All of my work needed to be entered in my diary and verified. The Diary is the central reference point so it includes all appointments whether parliamentary, party-political or personal. My wife and I would review the issues of the day and the diary each evening and she would chase up those items that I requested her to. She helped to follow up the issues of the day. For, example, if I had attended evening meetings or dinners very often these would need following up.

51.  My wife worked in the Swanbourne office between 10am-3pm each week day and otherwise on call. Each weekday night, often quite late, my wife and I would go through what work needed to be done or to be chased up. My diary secretary, Andrew Whitby-Collins, Annabelle and Christine would also regularly call Betsy during the day and into the evenings as they often worked very late and they knew she was on call to deal with work matters. On weekends Betsy and I would go through the diary and the Box which took at least five hours. As a result I knew Betsy was working more than 25 hours a week in the period from 14 September to 31 December 2002 and she was on call 24 hours a day.

52.  Overall it is unsurprising that as Betsy was working from home and liasing with a very limited group of my staff in my private office that the hours she put in and the work she was doing was not obvious to people outside the private office or with whom she was not in contact. Betsy has always reported directly to me and no-one else. Mark MacGregor joined CCO as its Chief Executive, and Jenny Ungless joined as Chief of Staff after Betsy was already working from home. In any event, these people had party political roles, and were paid by CCO, so there was no reason why they would come into contact with Betsy. Vanessa Gearson only joined the Leader's Office in the last four months of Betsy's employment and for a large portion of those months I was out of the office and so was Vanessa, whether for recesses, tours, conference or holidays. Again, as an example of the blurred distinctions in this field, one can say that there is an overlap in the analysis of the roles of the Chief of Staff viz party-political and parliamentary. As a result none of the people beyond the private office and my agent Rikki Radford had knowledge of what Betsy was doing, had no professional relationship with her and there was no reason why they should.

53.  There has always been a dedicated office at Swanbourne in the time my wife was working there for me. Betsy provides full details in her statement of the offices and the changes in the office over the relevant period and I have already adopted her statement concerning those matters as my own. The office at Swanbourne was supported by CCO IT staff for the simple reason that we needed to be integrated with CCO which was initially where the Leader's Office was located in 2002.

54.  Various members of my shadow cabinet visited us at Swanbourne including Liam Fox, Michael Howard, Michael Ancram and David Davis. Occasionally journalists would visit us. By the end of 2002 I had decided that I would expand the facilities at Swanbourne to allow Leader's Office staff, or campaign staff, to work from there which is why I had multiple telephone lines installed at that time. These facilities were discussed with and approved by Mark MacGregor in advance of the works and following a visit to Swanbourne by him [see paragraph 47 of Betsy's statement].

Vanessa Gearson

55.  As the risk of being repetitive I will expand on what I have already said about Vanessa above to provide a complete picture. Vanessa was hired in August 2002 and started in September at a time when I was working from Swanbourne. Prior to that Vanessa had been working as a secretary to David Davis in CCO and prior to that as an MP's secretary in the Commons. She had been helpful to me when I had needed to contact David in Florida earlier that year. Vanessa had approached Annabelle to see what work there might be for her in the Leader's Office. Annabelle and I discussed the possibility of her taking on in the role of Diary Secretary, as we knew Andrew was leaving, and she was offered the position that July but it was rejected. Subsequently Owen Paterson suggested to me that she might be able to assist in facilitating the changes in the office that I was contemplating, particularly the reorganisation of the Leader's Office and the staff changes which were imminent.

56.  I exhibit a copy of Vanessa's letter of appointment from Owen Patterson dated 12 August 2002.[30] I intended that she would have overall charge of administration in the Leader's Office, excluding the constituency office which was supervised by Christine, and work closely with Christine Watson to ensure that both offices ran smoothly. Vanessa did not have any direct responsibility for the staff in the Leader's Office, their appointments and salaries were administered by CCO but she was expected to facilitate such matters with CCO. I placed Christine in charge of my staffing allowance from which the constituency office salaries were paid as I controlled that allowance directly. In the absence of a Chief of Staff I approved all appointments to my staff personally. As Vanessa's letter of appointment states: "Christine Watson will handle the day to day detail and the exact manner in which you work with her will be finalised by Iain".[31] She was appointed with the title of "Administrative Head of the Leader's Office", a title on which she insisted. I had envisaged the role as one more appropriately titled office manager or executive secretary,[32] as it encompassed tasks such as arranging supplies for the office and payment of invoices. Vanessa wanted to be called 'Head of the Leader's Office' but I refused her that title. From the outset I made it clear to her that I intended to bring in a new chief of staff once the offices had been reorganised, and that she was not in the running for that position.

57.  When Vanessa had been offered the administrative job, she rang me in Italy in August while I was on holiday to ask what would happen to her if I were no longer the Leader. That question surprised me. She called me again a couple of days later and was apologetic about the matter saying she would like to accept the job. The very fact she was able to say that to me demonstrates that she was a strong-willed person with a clear sense of what she wanted for herself. That is a matter to be borne in mind having regard to her failure to ever raise any concern over Betsy's employment directly with me. Although she had befriended Annabelle Eyre and Andrew Whitby-Collins prior to her arrival in the Leader's Office she soon fell out with Annabelle, who is self-evidently the subject of both of the memorandums that Vanessa solicited from Christine Watson and Rebecca Layton (24 October e-mail) in October 2002.[33]

58.  Both Annabelle and Christine experienced active resistance from Mark MacGregor in arranging new contracts with CCO, although there should have been plenty of parliamentary funds (Short Money) for the support of the Leader's Office. When Christine finally received a draft contract there was a clause in Christine's contract which said she should report to Vanessa. That in itself was odd as both Christine and Vanessa already worked for me, and they both reported to me. Christine was concerned that this would effect her working with me. I reassured Christine that it would make no difference as I had full control of arrangements in the Leader's Office and she should go ahead and sign it so she could be paid. Annabelle's difficulties, however, were not resolved until I removed MacGregor from his position in February 2003.

59.  By the time Vanessa joined the office my wife knew she was coming to the end of her employment with me. There was no reason for Betsy and Vanessa to interact. Vanessa had only an administrative role and my wife was already communicating with Christine, as she had previously through Annabelle, on administrative matters such as requesting office supplies and Commons stationery (contrary to what Vanessa informs the Commissioner).

60.  Vanessa was not the 'Head' of the Leader's Office, although simply to drop the 'Administrative' from her title at first blush may not appear to be of much significance. However, for her to describe herself as Head of the Leader's Office implies that she was the 'Chief of Staff', when she was nothing of the kind. I raise the matter of Vanessa's title and her role in my office, only because she places much significance on describing herself as, and has made much in her statements to the Commissioner about being, 'Head of the Leader's Office' and 'the replacement for Jenny Ungless'. I subsequently discovered during this investigation that, without my knowledge or permission, she had seriously inflated and misrepresented her title and role in my office by signing correspondence "Chief of Staff" and "Head of the Office of the Leader of the Opposition".[34] Had I known this was happening at the time I would have put a stop to it. In hindsight it is clear that I did not appreciate the extent of Vanessa's ambitions or what she was prepared to do to achieve them.

61.  The Head of the Leader's Office, that is to say the Chief of Staff, is the closest adviser to the Leader of the Opposition. It is first and foremost a senior party-political appointment. That person would be expected to attend all of the Leader's meetings and to have overall running of the Leader's Office. They would have significant political input, working on speeches and writing policy articles. Vanessa did none of these things. Jenny Unglass had been my Chief of Staff and had that key political role. Unfortunately the relationship with Jenny was not a success. After she left I was wary of having another person in that role. What I had realised by then was that you must know the person and their qualities before they can even be considered for such a role.

62.  Eventually, the person I decided I did want as the Chief of Staff, after Jenny Ungless was Barry Legg. I had already resolved to remove Mark MacGregor as the Chief Executive at CCO in December 2002 because I did not think he was doing a good job, and did so on 15 February 2003. Prior to that I made a written offer to Barry Legg on 22 January 2003. The first draft offer to Barry was produced in December or beginning of January following discussions with Owen and Alistair. Other staff in the office could have known of my plans by overhearing conversations or seeing correspondence lying around. It was a small set of offices. In this context it is worth noting that Vanessa's makes statements to the Commissioner that she knew what was going on in the Leader's Office and that she listened in on other people's conversations. Vanessa was very upset at the prospect of Barry's appointment, as she made known to Andrew Whitby-Collins at the time because, as she expressed it to him, she felt that Barry was being brought in over her head. I had, however, told her at the outset that it was my intention all along to appoint a new Chief of Staff when the office was re-organised. Ultimately, however, Barry was not confirmed as Chief Executive because the CCO Board decided to abolish that position. Although I still wanted him as Chief of Staff, Barry turned the job down because he could also not be Chief Executive. With Jenny Ungless having left, and Barry Legg turning down the job, Owen Patterson continued to be a very important political adviser and helped to fill the role the Chief of Staff would have done. Alastair Burt was appointed in October 2002 as a PPS and also became another close political adviser.

63.  I know that my offer to appoint Barry caused Vanessa some distress because Andrew Whitby-Collins informs me she went to him at the time in tears saying that my action had 'undermined her'. I now understand her concern, because I know now she was describing herself in correspondence as 'Head of the Leader's Office' and 'Chief of Staff' prior to me sending that offer to Barry Legg on 22 January 2003. I now also realise that the matter was of critical significance to Vanessa as she put in for pre-selection for the Conservative seat of Cheltenham at that time, successfully as it turned out. In the course of her selection process Vanessa gave a speech, a copy of which is exhibited to this statement,[35] in which she misrepresented her position as "Head of the Office of the Leader of the Opposition" and falsely claimed that she was involved in "developing policy and strategy at Westminster". These claims are simply untrue. Speech writing, policy and matters of political judgment were not matters in which she was involved. She did attend meetings with me in a secretarial capacity to take notes. Vanessa would occasionally ask Christine to cover for her. For example, I attach a copy of an e-mail dated 13 May 2003 in which Vanessa explains her role in Shadow Cabinet meetings as: "I sit at the side more or less behind Iain in case he needs or wants anything and take notes on the items on the agenda and then the points raised".[36]

64.  Vanessa did re-structure the Diary and she was involved in diary meetings—she did not initiate them. She also had responsibility for the Correspondence Unit. She attended meetings with me in the Commons as my secretarial support and meetings in CCO on her own or with Owen. Although it had been expected that she would work on the Box, Christine covered that task on her own because Vanessa was more often than not out of the office when it had to be done. Vanessa attended many meetings with me, including those I have referred to above to take minutes, and many more at CCO with which I had no involvement. Vanessa's style was to communicate with people by e-mail rather than face-to-face, often with a 'please explain' tone, usually over invoices or the like, which got other staff offside. I did have cause to speak to Vanessa about the manner of her dealings with other staff because some members of staff complained she always assumed they were at fault. She never seemed concerned with their explanation. The example of questioning Annabelle about the cost of mobile phones during the tours in October 2002 is a good example of this. Annabelle was able to demonstrate that Vanessa simply had no idea why it was necessary to incur the costs and she had not asked Annabelle before sending the e-mail.

65.  I think as a result of such behaviour and of becoming increasingly pre-occupied with matters outside the office, at CCO, as a councillor, school governor and later in her constituency she became rather remote from the other members of the Leader's Office. As the Conservative candidate for Cheltenham Vanessa took time off on Fridays and latterly Monday mornings. She spent a considerable amount of time at work on the telephone.

The events surrounding Vanessa's e-mails

66.  Given Vanessa's administrative role in the office I was puzzled when I learned that Vanessa had raised the question of my wife's salary with Owen Patterson. First, as she knew, it is common practice for MPs to employ family members, particularly spouses. Second, Vanessa had no responsibility for the staffing allowance or other financial matters concerning the constituency office nor did Owen Paterson. The staffing allowance was administered by Christine and the Short Money was administered by CCO. Vanessa did not do the Box. Neither did Vanessa have anything to do with my constituency work and so far as I was aware knew nothing about it. As a result Vanessa had no contact with my wife or any reason to come into contact with her. Nor did I discuss constituency matters with Vanessa.

67.  I discussed Betsy's employment with Owen when he raised it with me, explaining Betsy's continuing role and I asked him to explain that to Vanessa and to ask Vanessa to see me if she still had a concern. I understood that he did then speak to her and tell her that. As Vanessa never said anything to me about it I, naturally, assumed she had no further concern. In any event, by November I had all my key staff in place and Betsy and I decided that Betsy could give up employment. I informed Owen of that decision and I understand he informed Vanessa. I was aware of Christine's budgetary concerns about the staffing allowance for some time and they had also been raised with me on her behalf by Alistair. Indeed, Christine had asked for support earlier in the year when she was still the Constituency Secretary. I agreed with Christine's suggestions on how the staffing allowance would be spent. I recall those discussions were in November and the decision was well before the end of the month. Betsy's notice was given to the Fees Office verbally by Christine and confirmed in writing.

68.  I cannot recall whether it was Owen Patterson or Paul Baverstock who first called me to inform me of Vanessa's e-mail of 30 January 2003. We were taken aback, to say the least, at the contents of the e-mail particularly as Betsy's employment had already ceased in December 2002. Neither Owen nor I were copied in on the e-mail. I emphasise that Vanessa's office was only about 12 feet away from my Office in the Commons. Initially the Leader's Office was dividing its time between CCO and the Commons, with the team moving to the Commons around midday—a practice inherited from William Hague's time—but it needed to be changed because of changes in the parliamentary timetable, so we quickly established ourselves the Commons Offices full time. Although Vanessa could have raised the issues in her e-mail of 30 January directly with me at any time she never did so. As far as I was aware Owen has told her to do so if she had any continuing concern. Furthermore, Vanessa had known Andrew Whitby-Collins for some time prior to joining the office and was friendly with him. She could have discussed the matter with Andrew at any time but he informs me that she never did.

69.  Having received a copy of the e-mail I wanted to meet with Vanessa. I was expected to be in the constituency the following day, Friday, 31 January, but the meeting was cancelled and I went to the Commons instead. Vanessa was late so I called her to ask if she was coming in. I did not mention the e-mail, I simply asked her to see me when she came in. In the meeting, I presented her with the e-mail and asked her to explain why it had been sent without her having first discussed the matters concerned with me. I explained about Betsy's role and about her having a contract. I explained that the IT expenses had been for an upgrade to the home office, and had been agreed with Mark MacGregor on behalf of CCO the previous year. As to the matter of private flights, I informed her that every flight has been entered in the Members Register and the problem had been caused because Owen had to make two last minute changes. As a result he had to had request one flight at very short notice—it was essentially a diary issue. The donor's only concern was that he had been unable to help because of such short notice. In any event, as I informed her, that particular problem had already been corrected because of the changes made to the Diary and has not been repeated from that day to this. Vanessa did not ask me any questions about these matters so I asked her whether she was satisfied with my explanation of all of the matters in her e-mail and she agreed that she was.

70.  Although I was relaxed about the matters referred to in the e-mail because I knew there was no substance where Betsy was concerned, and the other two matters had by then been dealt with by then. However, the act of writing and sending the e-mail was either an act of striking political naïveté or deliberate. I made the point to Vanessa that whether or nor she had such concerns, recording them in them in an e-mail without discussing them with me would be politically damaging if it were leaked, particularly as it suggested knowledge that she didn't in fact possess. She accepted this at once and unreservedly as she informs the Commissioner. She apologised and accepted that she should not have sent the e-mail.

71.  Vanessa said she wanted to put the matter right and it was agreed she would send another e-mail to those who had received her previous one. Again, I was not copied in on that e-mail but I did receive a hard copy. I had no part in drafting her e-mail. She did show it to me and I suggested an amendment concerning the matter of the planes, because that was a matter covered by the diary changes and I wanted people at CCO to be clear about that. I did not put any pressure on Vanessa whatsoever to produce or send the e-mail. Vanessa is a strong-willed person who is able to look out and speak up for herself. She had been in political circles for some years at this time was a well-educated, constituency candidate. I do, however, find it exceedingly odd that Vanessa kept draft copies of her e-mail let alone the draft with my handwritten annotation. As I have said, I knew there was no substance to concerns expressed in the e-mail of 30 January so my state of mind was completely relaxed, so much so such that I did not keep copies of either the 30 or 31 January e-mails. Vanessa appeared so genuine in expressing regret that I was not suspicious of her and I did not reprimand her. I subsequently forgot about the matter.

72.  When I appointed Vanessa I had thought that I needed an office manager but after I moved Annabelle to Tours, Andrew became far more effective on the Diary and Christine found her feet very quickly in the role of Private Secretary and managed the Box even more effectively that I had hoped. Both Paula and Cara very quickly settled into to their roles. So as the office efficiency improved Vanessa's role became focused on liaison with the Chairman's office. By June 2003 I had found a good candidate, Tim Montgomerie, who could do the job of Political Secretary which I wanted to encompass most of the tasks of the Chief of Staff. I thought that Vanessa would be better placed working for the Chairman, as a liaison between the Leader and Chairman's offices and that is what happened later that summer of 2003. Both the Chairman and I felt that would give her more time for her Cheltenham constituency.

Events leading up to and after the conference in October 2003

73.  In the run up to the party conference in October 2003, it became clear in the last week of September that the BBC Newsnight programme was intending to broadcast a story making allegations about my employment of Betsy. We suspected, and the BBC subsequently confirmed, that the investigation was based on Vanessa's e-mail of 30 January 2003. Given Vanessa's unusual turn of phrase 'Crick style investigation' it struck me as more than a coincidence that it and other documents were leaked to Michael Crick who was conducting the investigation. I engaged my lawyers to deal with the BBC because the BBC were refusing to put to me precise allegations or provide me with the material on which they were based, so that I would have the opportunity to respond to the allegations before they were broadcast. In particular, the BBC refused to and never did provide me with a copy of Vanessa's e-mail of 30 January despite repeated requests for it. By that time I was unable to obtain a copy of it from any other source.

74.  Once I knew the story was based on Vanessa's e-mail of 30 January, I informed my solicitors about her January 31 e-mail and they informed the BBC. At the same time I was desperately trying to obtain a copy of it so I could provide a copy to the BBC. Although I had not kept a hard copy of either e-mail, Owen Paterson had kept copies of both. Clearly it was an important document for Owen to keep because it counteracted the first e-mail that had questioned his competence. He looked for the second e-mail in his files but discovered that it had been removed along with that of 30 January. He also discovered a number of other documents were missing.

75.  On Wednesday, 1 October 2003, I had a short meeting with Vanessa in my Commons office to inform her about the Newsnight allegations because they were based on her e-mail of 30 January. The programme was expected to be broadcast on 2 or 3 October. Tim Montgomerie, also attended the meeting. In the course of the meeting we went over the events of 30 and 31 January and Vanessa confirmed my recollection that she sent the second email on 31 January and that she had no residual doubts concerning any of the matters contained in her email of 30 January. I attach a copy of a note of Tim Montgomerie's recollection of that meeting.[37] This meeting was yet another, crucial, opportunity for Vanessa to inform me if she still had any concerns over the contents of her e-mail of 30 January. It was absolutely critical that she inform me if she was not going to stand by the contents of her e-mail of 31 January as that was what she had decided to do. She did neither. I emphasize that Vanessa was employed in CCO by then. The Chairman was, in effect, her employer. I had no control over her employment by CCO so she cannot claim that I was in a position of influence over her. Apart from that, one would expect a parliamentary candidate and fellow party official to act with candour in such a situation.

76.  I could not recall the exact contents of the e-mails as I had not kept copies of them, so I asked Vanessa about them in the meeting and she had a remarkably good recollection. I asked Vanessa if she had kept copies of her e-mails and she told me she had destroyed them. As she had sent copies of the e-mail to the Chairman I asked her to check if the Chairman's office had kept copies of the e-mails and she promised to do so. Vanessa soon after rang Tim and said the Chairman did not have copies of either e-mail. I attach a further note from Tim with an e-mail from the Chairman's PA, Anna Hartropp, confirming these facts.[38] I was, therefore, simply astonished to learn Vanessa had both e-mails all along (and even drafts of the e-mail of 31 January) when she submitted them with her written statement to the Commissioner in this investigation. That meant that she had deliberately lied to me in the meeting on 1 October and subsequently deliberately deceived Tim and me by her conduct in pretending to search for the e-mails in the Chairman's Office when she had the e-mails at all times. Vanessa knew following her meeting with me that I did not have copies of either e-mail. As an employee of the Conservative Party she was duty bound to be frank and honest with me and to assist me by providing me with copies of those e-mails.

77.  If Vanessa had given me the e-mails, particularly the second e-mail, I could have provided a copy of it to the BBC which would have put an altogether different complexion on their investigation. It would certainly have given them serious pause to reconsider. Obviously Vanessa did not want that to happen. I'm also confident that Vanessa, notwithstanding she knew Crick had the e-mail of 30 January, did not provide him with a copy of her e-mail of 31 January either. Had she done so Crick would have been duty bound to deal with that matter in his briefing to the BBC and later to other media and to supply a copy of the e-mail to the Commissioner on 13 October. Of course I too would have included copies of both e-mails in my materials to the Commissioner. By the time Vanessa did produce the second e-mail to the Commissioner the damage to my reputation had already been done through the media and this investigation was already under way.

78.  Newsnight planned to broadcast Crick's allegations on 2 October, effectively the eve of the 2003 Conference. The timing of the programme was calculated to obtain maximum exposure and cause maximum embarrassment to me. However, by the weekend prior to the conference the BBC had not broadcast the story as a result of doubts raised by my solicitors. In frustration, according to media reports, Michael Crick then gave his story to the media in order to get his allegations out to the public and to put pressure on the BBC to transmit his programme. As a result The Sunday Telegraph and The Sunday Times among others published Crick's allegation concerning Betsy on Sunday, 5 October.[39]

79.  I called Vanessa three times that Sunday. First from the car, on the way to the conference in Blackpool, to bring her up to speed on the press and to say I was sorry she had been dragged in. After thinking about the issue on the flight to Manchester, I called her again to say that a short press release from her might be the way to end this interest in her. I said that I was thinking out loud but I stressed that nothing would be done unless that was what she wanted. I said I would call Nick Wood and ask what his thoughts were.

80.  Immediately after that call I rang Nick Wood my Press officer. Nick said he didn't want us to do anything as there was no need. That morning we had launched our pension policy and anything else would draw attention away from that story. I asked him to call Vanessa and re-assure her and he agreed to do that. I then called Vanessa again to say that I agreed with Nick that there was no need for any comment at all and I asked her to see Nick to discuss how to handle any press interest. I understand that Nick did subsequently meet Vanessa that day and he confirmed my comments that we should let the matter blow over. I saw Nick later that Sunday evening and he advised me to let the matter fizzle out. I accepted his advice. I spoke to Theresa May later that day and brought her up to speed on these exchanges.

81.  I took Vanessa aside the following day, Monday, 6 October, in the 'Green Room' at the Conference venue, just before the Chairman's speech. I told her that Nick was right and that hopefully the story would die out quickly. She sat beside me during that speech and was completely relaxed—scarcely something she would have done if she had just been subjected to pressure to make a false statement. To the best of my recollection I also said to her: "If you have any issues please let me know now. I want to get you out of this if I can. This is a deliberate and planned attempt to get at me and I am sorry you have been dragged in". She confirmed to me yet again she had no issue with any of the press allegations and said she was very sorry to have been the cause of them. That is also Tim's recollection.[40]

82.  There has been considerable and continuing press speculation that I presented Vanessa with a prepared statement for her to sign which is untrue. Vanessa was never presented by me or by anyone on my behalf with a statement for her to sign. Neither did I nor anyone on my behalf put pressure on or even ask Vanessa to produce a statement supporting me. As I have already stated, I had discussed with her on the Sunday that it might clear her from the story if she were to make a statement. However, I was always in two minds about this and I had accepted Nick Wood's advice that the matter was not worth pursuing. I also mentioned during our meeting on 1 October that if any sections of the media were to publish false allegations concerning my wife I would consider issuing proceedings. My solicitors had already warned the BBC that was my position. In that context I said to Vanessa that it might be that she would want to make a statement but it was unlikely to come to that and in any event some way off. As Vanessa's e-mail was the basis for the story I naturally thought she would have something to say about it. However, there was and is no court case and, therefore, I have never asked or had cause to ask Vanessa to make a statement.

83.  I would have asked Vanessa to make a statement to the Commissioner in respect of this investigation, but for obvious reasons, it was clear following a letter sent to me from her solicitor on 10 October 2003, that she was making false allegations about the events of 31 January 2003 and again during the conference, that she was lying about the circumstances in which she sent the e-mail of 31 January and that she now resiled from its contents and was setting out in no uncertain terms to discredit it. In this context Crick's proposition to the Commissioner that it was odd I did not produce a statement from Vanessa to this investigation, or that I did not produce statements from Mark MacGregor or Jenny Ungless given the circumstances in which they were removed from their offices, is a facile comment.

84.  The next event was that an article appeared in The Independent on 7 October 2003, during the conference, identifying Vanessa as the source of e-mail and reporting (falsely) that I had sought to have Vanessa removed as a result.[41] It also suggested that Vanessa had consulted lawyers who advised her that such action would constitute unfair dismissal. I have no knowledge of whether Vanessa consulted her lawyers and know of no reason why she would have had cause to. I would be interests to know if she did and, if so, why. We didn't pay any attention to the article. Vanessa, however, accordingly to her letter from Healys (see below) seems to have been panicked by this article and thought that Owen Paterson or someone else in the Leader's Office or CCO was briefing the press against her. As a result I believe she responded by briefing Michael Crick and leaking documents to him and other media sources. I refer to her earlier dealings with Crick in paragraph 173 below.

85.  Quite understandably, the reference to "Crick style investigation" in Vanessa's email of 30 January was picked up by The Independent article of 7 October 2003. Her comment about Crick demonstrates such a remarkable degree of foresight that it was bound to be questioned. And one might be forgiven for asking what is this 'Crick style' of investigation that it should merit its appearance in her e-mail of 30 January? Crick, through Newsnight, had a done a story on certain details in my CV which went out in Autumn 2002 but it contained nothing about financial matters.

86.  I now know Vanessa went to see her solicitor at Healys on Thursday and Friday, 9-10 October. This led to the bizarre episode of the letter sent by Ms Gill Sage of Healys (solicitors) to me on Friday afternoon, 10 October, which was marked to be copied to a number of people, including Mark MacGregor notwithstanding that he had no position in CCO since February. The letter came completely 'out of the blue'. At no stage before the letter was received was I aware that Vanessa did not stand by her e-mail of 31 January. My immediate reaction was to say to my solicitor, David Hooper, after I had read the letter, "this is destined for the Sunday papers". I was proved right by The Sunday Times and Independent on Sunday.[42] As Mr Hooper pointed out in response to Ms Sage, the letter was not only grossly offensive and defamatory it was also quite perverse in the context of the week's events at the conference. Vanessa Gearson was CCO liaison officer between the Chairman's Office and the Leader's Office. She had been with me that week at the party conference and not once had she raised her concerns with me at any time or said she did not stand by her e-mail of 31 January, just the opposite. Rather, once again, she chose instead to set out insupportable allegations in a self-serving document. I had met with David Hooper during conference week to discuss the Newsnight issue. The feeling among my advisors was that the issue had died down finally and that there was nothing new that had not already been written. As a result, however, of the leaking of Vanessa's letter dated 10 October from Healys solicitors, the allegations flared up again that Sunday, 12 October.

87.  There were other peculiarities about the letter from Ms Sage and the conduct of both her and Vanessa over the weekend of 10-12 October, which Mr Hooper set out in detail in his letter to the Commissioner of 12 November.[43] Chief amongst these was that Ms Sage first informed Mr Hooper that she had circulated her letter of the 10th to Owen Patterson, Theresa May, Sir Stanley Kalms, Mark MacGregor and Paul Baverstock. She subsequently informed Mr Hooper that she had intercepted the letter to Sir Stanley and Mark MacGregor. She also informed Mr Hooper at his inquiry that Mark MacGregor was a client of hers. Copies of the letter duly arrived by post at CCO on Monday morning for May, Patterson and Gilbert. They had not been faxed to those people. If what Ms Sage told me about not sending letters to Sir Stanley and Mark MacGregor was true then only Vanessa or Ms Sage could have been the source of the leak to the Sunday papers that weekend, as it was clear from their numerous inquiries to the Press Office that they were clearly briefed about the letters and their contents. Accordingly, it came as no surprise to me to subsequently learn that Vanessa's solicitor, Gill Sage appeared on television on Monday, 13 October to further brief the media. I adopt all Mr Hooper says about the matter in his letter to the Commissioner dated 12 November 2003 as my own statement of events.[44] I have not the slightest doubt that Vanessa dictated the contents of the letter sent to me by Healys on 10 October (and further exchanges that weekend),[45] and that the allegations that it contained were invented to counteract the embarrassing existence of her 31 January e-mail and to maintain her credibility with Crick. Its leaking was, therefore, crucial to Vanessa's purpose in sending it.[46]

88.  After that episode, other matters then fell into place. Although Vanessa had told me she had destroyed both e-mails of 30 and 31 January, the 30 January email was leaked to Crick and was quoted widely in the press. The Christine Watson memo is another document that she clearly kept (as she submitted it to the Commissioner) and leaked to Crick (who also submitted it to the Commissioner, but, notably, only on 14 October)—Christine only sent her memo to Vanessa so only Vanessa could have done this. Christine plainly did not leak it and, of course, it is obvious from its contents that Christine wanted and expected her memo to remain confidential. Then there is the matter that Vanessa had her e-mail of 31 January all the time but never supplied a copy of it to either Crick or to me.

89.  I think it is significant that Christine's memo was not a document which Crick submitted to the Commissioner on 13 October. The Commissioner was only provided with the memorandum the following day, 14 October, together for the first time with additional allegations based upon it (which Crick was unable to fully formulate until the Friday, 17 October), after Vanessa and Crick knew that I had submitted documents to the Commissioner including statements from Christine and Annabelle that refuted the allegations concerning Betsy. Crick would naturally have submitted the memo on 13 October with a clear list of allegations if he had had it before that date. He clearly didn't have it when he saw the Commissioner that day. The late leaking of the memorandum to Crick was I believe a desperate attempt by Vanessa to discredit Christine and Annabelle and perhaps to drive a wedge between them. It was only deployed when it was clear that both of them were had given statements which did not support Crick's complaint. Only Vanessa could have done this which confirms her in my mind as one of Crick's sources.

Section 3

Materials submitted by Michael Crick to the Commissioner

90.  At no time did Crick or the BBC put the allegations concerning my wife to me other than in general terms. I was not asking the BBC to betray its sources but rather making the point that if they were suggesting that points had been raised with me regarding the payment with my staff and I have ignored them I needed to know what these points were, who they were raised by and when in order to deal with them. Despite repeatedly making that point to the BBC they declined to put the allegations specifically. I contrast Crick's demand for information from me via the Commissioner with his own refusal to provide information to me while he was pursuing his investigation. Crick and the BBC consistently refused to disclose any material to me. Indeed, I did not see any material from Mr Crick until the allegations had been reported in the press and the documents that Crick had submitted to the Commissioner were then disclosed to me in the course of this investigation.

91.  Having received the Crick documents I was astonished and appalled to learn of the manner in which Crick has conducted his "investigation". He has sought to rely on transcripts of conversations with three anonymous sources, knowing full well that anonymous material is contrary to the Commissioner's rules and an abuse of Parliament's process because I would be denied the opportunity test the veracity of those statements.

92.  For reasons fully set out in Section 4, below, I have identified "Source C" as Vanessa Gearson, as it is relevant to assessing her subsequent testimony to the Commissioner. I also note from Crick's document to the Commissioner entitled "Interpreting the Christine Watson memo"[47] under the heading "Glossary" he states "The 'Chief of Staff'…was Jenny Ungless, who was effectively Vanessa Gearson's predecessor running IDS's office, though she carried a different title". This piece of misinformation can only have come from Vanessa and, indeed, it chimes precisely with what she tells the Commissioner in her statement[48] and in interview.[49] Vanessa inflates her title and role to Crick and to the Commissioner in order to bolster her credibility and add weight to her allegations.

93.  The other primary material submitted by Crick includes taped telephone conversations with Chingford & Woodford Green councillors and my constituency agent, Rikki Radford, without informing them or requesting their consent and deliberately misleading them about the nature of the investigation. What the interviews do show is that Crick's assistant was lying as a matter of course and speaking to a formula to the effect that this was a general investigation into MPs. I am still seeking an explanation of this behaviour from the Director-General of the BBC.[50]

94.  Furthermore, putting questions to these councillors about whether they contacted me through my wife was in itself misleading. The Councillors usually contact me through the constituency association or my agent, Rikki Radford. My wife was not at the time working for me and had ceased her employment for over nine months at the time these questions were being asked. However, if the councillors had previously had reasons for dealing with Betsy on constituency matters then I expect they would remember her from that time. The tenor of the questions may suggest, however, that neither Crick or the other BBC journalists attempting to find out if Betsy was still working for me. Certainly, in Mr Radford's case, it is clear from the transcript, and he had confirmed, that he understood Crick to be asking whether my wife was currently working for me and he confirmed that in his statement of 13 October 2003.

95.  The manner in which Mr Crick carried out his investigation is offensive to me because it presumes that surreptitious means were necessary to uncover details of my wife's employment. In fact the details of her employment were transparent and available from the Parliamentary Fees Office. There was a written contract of employment. All of this information would have been provided to Mr Crick by the Press Office if he had but taken the obvious and responsible course of contacting them or myself and asking a straight question. However, Mr Crick's conduct in this matter, and that of the BBC as his employer, fell well short of any concept of responsible journalism, or even the BBC's own standards of journalism as set out in its Producer's Guidelines.

Michael Crick's Transcript (undated), pp8-32 supplied

96.  [p8] Crick confirms that on 13 October 2003 when he made his complaint to the Commissioner that the sole allegation was that Betsy was doing no work for me in the period September 2001 to 31 December 2002.

97.  [p9] It is the Commissioner that makes the separate allegations concerning my wife, Annabelle and Christine on this page, not Crick. Crick finds the Commissioner's thoughts to be novel, he says: "I think the distinctions you make are interesting and important ones. I am sorry, I should have written them down.". Crick also confirms that his investigation of my wife (from May to September 2003) is based on the mistaken premise that she was my 'Diary Secretary' over the period in question. In fact she was had not been the Diary Secretary for any part of that period, Andrew Whitby-Collins was the Diary Secretary followed by Paula Malone in late 2002. Crick was wrong about this as were the 'anonymous sources' he claims told him that Betsy was acting the Diary Secretary. Similarly, that false premise exposes the interviews with the Chingford councillors as having no probative value.

98.  The Commissioner then asks whether the information comes from the anonymous sources identified as A, B and C. Crick states he is speaking only about A and B, not C. For the reasons I have set out in Section 4, I believe 'source C' is Vanessa Gearson and she would have known that Andrew then Paula were the diary secretary. It also confirms that sources A and B are the ones Crick refers to as being "at the early stage" and that 'C', Vanessa, is one of those two others who "cropped up much more recently". The Commissioner was bound to reject anonymous statements and confirmed that to me in our meeting on 13 October and his letter of 30 October. No mention of this rule of procedure is raised with Crick during the interview. The anonymous statements could have been rejected by the Commissioner forthwith and should have been no part in the Crick interview unless they were named.

99.  [p10] Crick's allegation now changes to "It is my hunch, my strong belief that she probably was not doing any work, of a substantial nature anyway." This 'hunch' is predicated on his assumption that Betsy was the Diary Secretary and was dealing with Chingford councillors in that capacity. Both of these assumptions are wrong. Andrew was the Diary Secretary and he did not make diary arrangements with Chingford councillors, these were made by my constituency agent Rikki Radford and Christine in consultation with Betsy.

100.  [p11-12] On the Commissioner's prompting Crick confirms that it is no part of his complaint that at any time was improper pressure brought to bear on anybody. He does, however, go on to say that he suspects the Commissioner will hear more about that from other people. That is, of course, a reference to Vanessa's allegations of 'duress' and "improper pressure". Both Vanessa Gearson and Mark MacGregor are among his 'anonymous' sources and he therefore knew the testimony they intended to, and do, give the Commissioner in an attempt to discredit the 31 January e-mail. That smear is backed up by the letter sent to me on 10 October making further false allegations about duress and pressure. Given that neither Mark or Vanessa supplied Crick with a copy of that e-mail or their explanation for it prior to making his complaint, Crick must have belatedly suspected that they had their own agenda and he therefore decides not to adopt any further allegations made by them as part of his complaint.

101.  [p15] Annabelle and Andrew were working for me in the Leader's Office assisting me with my parliamentary work until Andrew left to take up a new job in CCO and Annabelle transferred to Tours. Crick is mistaken thinking they were doing party-political work and it leads to the mistaken assumption they primarily discussed such matters with Betsy. They did not.

102.  [p16] It seems to me that Crick misunderstands the nature of the Commissioner's investigation, it is not a question of how many witnesses I can produce to say that Betsy was working. I do not have to prove my innocence, that is presumed as the rules expressly state. The relevant question is what positive material does he have to support the allegation that she was not working and does it satisfy the standard of proof? As far as I can see he has none; not one single witness who can state from their own knowledge Betsy was not doing the work Betsy and I say she was doing.

103.  [p17] Crick's comments about getting statements from Jenny, Mark and Vanessa are self-serving, misleading and disingenuous; some or all were his sources at that time or had been prior to the complaint and Vanessa's e-mail was leaked to him as the basis of the allegations.

104.  [p19] I observe that the Commissioner is following the case against me in the press from his comment "Indeed, the papers refer to it". Crick seeks to bolster Vanessa's credibility by saying "she still works for the Conservative Party so still does work within (my) command". Again, his comments are wholly disingenuous, misleading and self-serving because he does not inform the Commissioner (so far as I am aware) that Vanessa is one of his sources or indeed, raise the matter of her letter to me on 10 October.

105.  [p20] In my meeting with the Commissioner on 13 October he assured me that anonymous statements would not be counted against me if the source remained anonymous [Commissioner's file note, paragraph 15].[51] Therefore, I find the conversation regarding the anonymous sources disturbing. It raises some questions I think I am entitled to have answers to given that the rules specify that the Commissioner shall not entertain anonymous material. Why was Crick not directly asked to name them? Did Crick ever identify these sources to the Commissioner? Who does the Commissioner think they are; he has clearly formed some views: "Yes, I think I may be able to divine who they are already"? Did the Commissioner subsequently ask certain witnesses to confirm they were the sources and were their Crick-transcripts then discussed 'off the record' with the Commissioner or as part of the material which has not been disclosed to me? It needs to be borne in mind that it is Crick (and no-one else) who is making the complaint.

106.  [pp22-26] This covers discussion of the transcripts of Chingford & Woodford Green councillors. I have already set out above the reasons why these transcripts have no probative value, because they were obtained by deception and on the basis of false assumptions, and that, in any event, they were obtained by express misrepresentation to the councillors. However, the Commissioner's dissection of their contents further demonstrates that they are equivocal, in any event. Of the Michael Fish transcript the Commissioner puts it to Crick that "It does not prove one thing or another". Crick responds "no it does not" [p23].

107.  [p27] Crick seeks to put a sinister interpretation on Christine Watson's memo which it simply cannot bear. I had never seen this memo before it had been reported in the press during this investigation. Having read the memo is confirms to me only those concerns that she expressed to me and to Alistair Burt at that time, which were to do with the staff budget. The fact that she is also critical of Annabelle is quite irrelevant.

108.  [p28] There was always a functioning office at Swanbourne when we moved there in August 2001 and thereafter from which Betsy worked. Crick's speculation about the equipment and the office at Swanbourne is wrong. It is wrong because he is relying on Vanessa's e-mail of 30 January and what Vanessa has subsequently told him. However, Vanessa has never been to Swanbourne.

109.  [p30] Crick raises the suggestion that Betsy came off the payroll in December as a result of the "controversy surrounding Michael Trend in other words, as some of my sources have suggested". The only witnesses who have made that allegation to the Commissioner in the material I have seen are Vanessa Gearson and Mark MacGregor which I believe, on Crick's own words, confirms them as Crick's sources.

110.  [p30-31] Crick seeks to insinuate that people other than Owen Patterson discussed Betsy's employment with me prior to Vanessa's e-mail of 30 January. However, none of his sources, not even Vanessa Gearson who says she had concerns, or even Mark MacGregor, claim that they ever raised these concerns with me. The reason being that it was never a real concern or it would have been raised with me. The people who work in CCO are not the craven functionaries that Crick paints them to be, endlessly discussing "How are we going to present this to IDS?". If a member of the communications committee thought there was a real issue they would have raised it with me. Crick simply has no evidence but makes the allegation regardless.

111.  So what does Crick's material amount to? Three anonymous transcripts that the Commissioner has confirmed he is bound to disregard. Transcripts of conversations with six Chingford councillors, obtained by deliberate misrepresentation, asking questions based on false assumptions resulting in answers which are at best equivocal. A conversation with Rikki Radford over which Crick again came to false conclusions, but on which Rikki put him straight in his statement of 13 October. A memorandum from Christine Watson, leaked by Vanessa Gearson at the last moment in an attempt to discredit Christine and Annabelle, which as Christine can confirm refers only to her budgetary concerns. Is it any wonder the BBC refused to broadcast Crick's Newsnight programme?

Vanessa Gearson's written statement

112.  A striking aspect of this statement hits me straight away—on the first page under 'KEY CONCLUSION' in which she informs the Commissioner that "it was my conclusion that the press allegations made regarding the employment of Mrs Duncan Smith were significantly more likely to be true than not" (emphasis added). First, they were not 'press allegations', they were Vanessa's allegations as set out in her e-mail of 30 January, which she maintains by her written statement to the Commissioner and in her interview with the Commissioner. She acts throughout as an advocate in her own cause. Second, the phrase I have highlighted is very significant. It is has been taken by Vanessa word for word from the Committee's Report in Reid (at Paragraph 20) which comes under the heading "The standard of proof".[52]

113.  The Committee in Reid had cause to consider with some care the issue of standard of proof (Paragraphs 16-20). In rejecting the standard of proof applied by the Commissioner the Committee came up with its own novel formulation for allegations which go beyond negligence: "A case such as this has serious implications for holders of public office. Accordingly, we have concluded that we should need to be persuaded that these allegations were significantly more likely to be true than not to be true before we would uphold them". The Committee's formulation is not used in any other legal forum; it is not applied in any Courts in the United Kingdom which apply the widely-known formulations for criminal (beyond reasonable doubt) and civil (balance of probabilities) proof. Accordingly, Vanessa could only have come across that formulation after careful consideration of the Reid decision. In effect, Vanessa informs the Commissioner that she has applied the Reid standard of proof to her allegations against me and found me guilty. This is not the behaviour of an independent, disinterested witness.

114.  Vanessa sticks rigidly to her mantra throughout her statements. The last sentence in her statement [p17] is: "It remains my conclusion that the press allegations made regarding the employment of Mrs Duncan Smith are significantly more likely to be true than not". And again at the very end of her interview with the Commissioner she says:[53] "That is the conclusion I have come to, that the press allegations at the end of the day were significantly more likely to be true than not. I leave that with you". Indeed she does.

115.  In addition, Vanessa makes the allegation that she sent the e-mail of 31 January under pressure.[54] She claims that in no way did she agree with its contents, although she drafted it and sent it, in her own words, to "the most senior people at CCO" . She further claims that I have proved my determination "to place her under pressure in order that I support his statement on the matter". This is nothing but another concocted allegation lifted straight from Reid, where the Committee considered the allegation "witnesses felt under considerable pressure as to what they should or should not say [to the Commissioner] and how far, if at all, they should co-operate with her inquiry" [paragraph 49]. Accordingly, Vanessa knew full-well that making that allegation to the Commissioner (and leaking it to the press) was as damaging as anything that Crick had alleged in his complaint. She highlights that to the Commissioner saying that the events are as disturbing as anything in the Commissioner's remit concerning the complaint. I categorically deny these allegations of improper pressure. Based on Reid Vanessa has made them deliberately and maliciously, with cool calculation as to their effect. Finally, Vanessa suggests that she was in effect being asked "to perjure ourselves to protect the Leader" and "committing an act of perjury before the Court". These allegations are monstrous and self-evidently absurd—first, there is no court case and, second, how would I be able to procure 'perjury' from her if there was? If I asked her to make statement she could say 'no'. If she was called to give testimony she would be required to tell the truth or face the consequences. The only possible purpose in using the word 'perjury' can have been to excite press interest.

116.  Vanessa states that "By mid November, the complaint against Michael Trend MP had been made public. In my mind, this heightened the need to resolve the issue….". However, the Trend story broke on 15 December. Vanessa deliberately suggests (and Mark MacGregor also) that it was in mid-November because she knew from being told by Owen that I made the decision to end Betsy's employment towards the end of November. Her attempt (and Mark's attempt) to link the Trend story and my wife's resignation is exposed for what it is, an opportunistic attempt to smear me.

117.  Vanessa makes another false statement about her title and role in the Leader's Office on: "a chance meeting with Tim Montgomerie, who had succeeded me as Political Secretary to the Leader". Vanessa was never my 'Political Secretary'. This further demonstrates that Vanessa will assume titles for herself which she was never given as it suits her purpose.

118.  Vanessa's conduct appears to me to be that of someone who is motivated and following a carefully considered strategy to persuade the Commissioner to a particular conclusion, namely that the complaint (and therefore her allegations) should be upheld.

Vanessa Gearson's transcript (undated), pp6-65 supplied[55]

119.  [p6] She refers to herself as Head of the Leader's Office. She never was. When I asked Vanessa to take on this new role it was to help in re-organising the Leader's Office, as she acknowledges [transcript, p6, last paragraph]. It was not a political job. She also misrepresented herself as Head of the Leader's Office in her speech seeking at Cheltenham. She was not authorised to do so.

120.  Vanessa says she approached me in July. This is not correct. She was asked if she would like to be considered as Diary Secretary to replace Andrew Whitby-Collins who was going to leave to take up a post in the Candidates Department at CCO. I did not speak to her about the administration job until August. I spoke to her about the administration job, whilst on holiday in Italy and said I would confirm details with her on my return.

121.  [p19] Vanessa makes a peculiar statement about her employment with the Leader's Office. She said that Jenny left the Leader's Office in the summer of 2002 and that within a very short period of time it was clear to them (presumably my staff in the Leader's Office) that she would be appointed to this role. She was never appointed to that role and I never informed anyone at that time or afterwards that she would be considered for chief of staff or as a replacement for Jenny.

122.  [p7] Cara Walker sat in the adjoining office for a very limited period after starting. By early October 2002 she had moved to an office in the House of Commons. Vanessa had next to no involvement with her. Both Cara and constituency matters were outside her brief.

123.  [p10] The statement 'Staff were appointed without consideration of the budget' is incorrect. I approved the staff appointments and Christine was in charge of the staffing allowance. Christine carefully considered the question of budget with the Fees Office. It is simply untrue that when she joined the office there was no structure or organisation. She behaved in a officious manner. She never asked staff why things were done. She used to send off e-mails raising issues instead of speaking to staff and obtaining information from them in advance. Vanessa's e-mail concerning the Leader's tour in October 2002 is an example she provides to the Commissioner. However, she does not provide the Commissioner with the comprehensive response from Annabelle which put her straight on matters she clearly knew nothing about.

124.  [p11] All of my Constituency claims are recorded in the Fees Office and were in accordance with the rules. The reference to my constituency office in Chingford is gratuitous, vague and unsupported. Vanessa had no involvement with my constituency work or office. Additional cost claims were arranged between Christine Watson and myself in accordance with the rules. In August and September Christine and I discussed the composition of the constituency office. In September and October 2002 Christine asked the Fees Office to produce summary projections based on the staffing allowance and staff numbers. Betsy's departure was part of this. A final decision of the staffing changes was made in mid-November.

125.  [p12] There was never any issue about a change of address, or doubt about which property I was claiming for, or lack of paperwork, as the Fees Office can confirm. The Fees Office never raised with me, or investigated, in October 2002 or at any other time Vanessa was in the Leader's Office, concerns about allowances for my Chingford property. Accordingly, Vanessa's statement that "I cannot confirm whether those concerns were intimately proven to be true or not at the end of the day by the Fees Office" is simply malicious and prejudicial.

126.  [p13] The role of any Private Secretary is not political, it is functional. A great deal of it has to do with my activities in and around Parliament. Christine did the same work as Annabelle had before her but also co-ordinated my constituency work. This work included my claims to the Fees Office, administration of the staffing allowance and matters relating to stationery beyond the Leader's Office.

127.  Vanessa makes a series of statements about Christine's attitude on taking up her job. The fact of the matter is that Christine was pressing CCO to put her on its Leader's allowance and she was being blocked by Mark MacGregor who would not supply her with a contract. Christine sought Vanessa's help in dealing with CCO but she didn't receive any and their relationship deteriorated during October until Vanessa began to interfere in Christine's work by attempting to restrict Christine's access to me and to take over the Box. When I learned about this I made it clear that Christine would continue to have direct access to me. So far as I am aware Christine went to the Fees Office of her own initiative and Cara went with her, initially because the Fees Office had lost Cara's employment paperwork.

128.  [p14] Vanessa says that 'Mrs Duncan Smith was not showing evidence of carrying out a substantial amount of work'. My wife was my employee not Vanessa's, nor did she at any time answer to Vanessa. On what basis would she expect to see 'evidence'? She certainly did not ask me or anyone else in the outer office for 'evidence'? Did she expect her knowledge to be superior to mine on the matter? Also she constantly refers to the 'Office Cost Allowance' and Betsy being paid from it. In fact, Betsy was paid from my Staffing Allowance as she would have known if she had ever asked me or picked up the telephone and asked the Fees Office. This reference to 'Office Costs Allowance" is carried through into Crick's complaint and MacGregor's statements because Vanessa is the originating source of the allegation.

129.  [pp15-16] Vanessa was very regularly away from the office in meetings with me, at CCO, Hendon (where she was a councillor) or Cheltenham. Christine worked very long hours and often until 9.00pm or 10.00pm. Vanessa rarely stayed after 6.00pm. That is why Christine had to be responsible for the Box. Vanessa speaks of listening to telephone calls and watching what was going on. Yet she asks the Commissioner to accept she could do this from where she sat in the room next door to that in which Christine worked, from where it is simply not possible to see Christine. And is she suggesting she had no tasks of her own other than to observe Christine? Then there is the fact that she spent a lot of time out of the office at meetings or CCO and spent Friday and part of Monday morning at her constituency.

130.  I put Vanessa's claims to the test by sitting in the position Vanessa sat and asking Christine to make a telephone call. Vanessa occupied an office behind a wall some 15 feet away from Christine. I could not see Christine at all from where Vanessa had sat. It is very difficult to listen to conversations on the telephone even from very close. In a busy office where there where other people working, as there were in the outer office, it is all but impossible and Christine was seated in the direction facing away from where Vanessa was seated. These are, of course, all matters that the Commissioner can verify for himself by viewing the offices himself.

131.  [pp16-18] On these pages Vanessa purports to have information about the circumstances surrounding the setting up of the Leader's Office after I became the Leader in 2001. Vanessa was not part of my election team, she did not work for me or the Leader's Office at that time or until a year later. Nor had she worked for Mr Hague or the Leader's office before me. She did not even work in CCO at the time. I ask rhetorically, why is she making statements about events in which she played no part and of which she has no experience? Yet she goes on for three full pages without informing the Commissioner that she was not in a position to know about these matters this or stating how she would have known this when she was not in the Leader's Office or even at CCO. The fact is there were no staff in the Leader's Office when I took over apart from the correspondence unit attached to the Leader's Office in CCO and a speech writer in CCO. All of Mr Hague's staff had left the Commons offices as per usual. I did not second staff to the office and there was no "bedrock of support" awaiting me. I didn't even have any proper furniture in my office (see Simon Gordon's statement). Vanessa's account concerning the Leader's Office in 2001 is fiction and self-evidently so. Vanessa only came to CCO to work as a Secretary/PA to the then Chairman in mid May 2002. I had never met or dealt with her before then.

132.  [p19] The transition period was not August it was September to November. It could not have been 'clear to them' as I have never suggested to my staff or anyone else that Vanessa was to be a replacement for Jenny, she was not a replacement for Jenny and she was not the Head of the Leader's Office or my Chief of Staff or anything of the kind. Christine was not familiar with workings of CCO and she had no reason to be either as constituency secretary or as my private secretary because she never had a political role. Christine's experience of CCO in the first few months as Private Secretary was merely obstruction over the matter of her new employment contract.

133.  [p21] Cara Walker had little or nothing to do with arranging my constituency visits. It is not surprising that Vanessa would not know this as she had no dealing with my constituency work or visits. Visits were organised by Christine and Rikki Radford in consultation with Betsy. The reference to the Diary and Betsy are simply wrong—Vanessa never spoke to Betsy, Christine did. Vanessa clearly has no idea of what was discussed or how these visits were arranged. The suggestion that Betsy did not attend diary meetings is facile. Diary meetings took place in the Commons and Betsy was not going to make a four hour round trip from Swanbourne to attend them. The Diary Secretary, Andrew, would discuss the diary with Betsy by telephone, another arrangement about which Vanessa is ignorant.

134.  Betsy was always contacted about my invitations. Vanessa may say she did not contact Betsy but Christine, Annabelle and Paula Malone did. Throughout her testimony Vanessa demonstrates a complete lack of knowledge concerning the arrangements in my constituency office while claiming she was 'intimately involved'. However, Christine, Annabelle, Andrew, Rikki, and Cara, as well as of my wife and I, confirm that she was not involved at all.

135.   [p22] During Vanessa's time in the Leader's Office the Box was done and organised by Christine. Although when I asked Vanessa to do this job of administrative head it was envisaged that the role would include the Box, that never eventuated. Christine, because she stayed so late, took responsibility for the Box. Only Christine and I had a key to the Box. Christine would liase with me last thing in the evening and see me first thing me in the morning to deal with the Box. Contrary to what Vanessa suggests, Christine packaged up constituency work as well as other work and put it in the Box, if it would fit. Vanessa's involvement was limited to passing on documents to Christine to be placed in the Box if required. I never discussed items in the Box with Vanessa unless I had a particular reason to do so. I went through items from the Box with Christine each morning if that was necessary or Christine simply distributed them. Christine also liaised with Besty about the Box before and after the weekends.

136.  [pp22-23] Vanessa then suggests that I wasn't 'assiduous' in clearing my Box. That is nonsense. Also I was not a Minister and did not work like one; considering Vanessa didn't 'empty the Box' in the morning or see that happening her comments are gratuitous as is her comment about William Hague. So far as I am aware Vanessa had no experience concerning Mr Hague's conduct of the Box either.

137.  [p23] Vanessa's knowledge about the Box is flawed and exposed here. She says she constituency material was kept separate to the Box, it wasn't. Nor would Vanessa have seen the constituency material, Christine handed it directly to Cara and the other members of the constituency office.

138.  [p23-24] I never received any complaints from Christine or Cara relating to clearance of the Box, nor do I see anything by Christine or Cara in the materials that the Commissioner has supplied which support anything Vanessa says in this respect. Vanessa is nevertheless willing to make assertions often in personally offensive terms on matters where she must have realised that she had no knowledge of the facts.

139.  [p24] Because Vanessa was not acting in the political role of Chief of Staff I would often talk to Shadow Cabinet Ministers or key CCO staff on matters of policy and strategy.

140.  [p25] She keeps talking about their seeing no evidence of progress chasing but she was not part of the private office and she never asked for any from those in it. Not from me, Annabelle, Christine or Andrew. Why would anyone provide evidence if those who worked with Betsy were not asked about her?

141.  [p26] Vanessa says I did not sign letters in response to Members of Parliament. This demonstrates a breathtaking lack of knowledge of the Parliamentary system. Owen Patterson would ensure that a colleague would receive an instant acknowledgment of their letter. Then he would give me a list of those who had written. For the most part, I would hand write the reply. It is considered a Parliamentary courtesy to handwrite a letter to colleagues. However, if a more complicated reply was required, it might be typed and I would always sign it. She makes a wide-sweeping statement on the basis of having seen the odd letter acknowledged by Owen and therefore assumes he did all this correspondence.

142.  Vanessa also goes on to say that I signed very few letters in my own hand. Again, this is incorrect. It flatly contradicts what she says on p6 of her written statement to the Commissioner, that on Thursdays and Fridays there was a significant amount of correspondence ("more than one hundred letters") for me to sign and that these would usually be returned the following Monday. On an 'easy' week I would sign around 100-200 letters. On a difficult one well in excess of that. Whilst it's difficult to give an accurate estimate of the proportion it would roughly be two-thirds constituency, one-third non-constituency although that could be reversed in difficult weeks. Vanessa hardly ever generated any letters for me to sign.

143.  [p27] Vanessa talks of being unaware of correspondence being generated by my constituency agent, Rikki. Yet she never spoke to him. He liased with Christine or Cara in the Commons office and Betsy at the home office.

144.  Vanessa also says she did not see requests for envelopes or letter headed paper from Betsy. In fact Betsy was constantly supplied with stationery and franked envelopes by Annabelle and subsequently by Christine. Betsy would inform Christine of what was required and she would supply it. We kept a good stock of all stationery requirements in our office in Swanbourne.

145.  [p28] Vanessa says at the outset of her written statement and confirms in her interview that she has never been to Swanbourne. Therefore I am puzzled as to what basis she claims to be able to give evidence about the state of the property and what we were doing with it. We did not have a 'dilapidated' home. We lived in the home from August 2001 until March 2003 when we commenced some building work.

146.   [p30-31] Vanessa speaks of an unspoken understanding. Why would anyone reach an adverse conclusion on that basis of what they did not know? Vanessa also talks of "banging the drum". Yet throughout she insisted on speaking to the same people in CCO who knew nothing about the operation of the Leader's Office or the constituency office. The simple question remains why didn't Vanessa ask me, as I was her employer and Betsy's employer, Christine who was managing the staffing allowance or Andrew who was managing the Diary? Vanessa formulates during her interview some quotes at the top of p31 which she then goes on to explain are no more than the "atmosphere I picked up as soon as I started in the office" (emphasis added). It was a rarefied atmosphere, one that of all the people in the Leader's Office, only she seemed breathe.

147.  [p32] There was nothing sensitive about the matter of Betsy's employment except in Vanessa's mind. That she chose to remain in that state of ignorance until I set her straight on 31 January 2003, is a matter for her to explain. Again Vanessa formulates quotes which were never actually spoken to her. This is just nonsense. When Owen mentioned the matter to me to me I explained I explained the situation to him, he was satisfied. I left it for him to go back to Vanessa and I said that if Vanessa was still unsure she should see me. She never did. Of course, if I had the least concern regarding the matter I would have spoken to Vanessa myself but of course I didn't because I knew exactly what Betsy was doing and why I was employing her.

148.  [p33] Vanessa deliberately claims a connection between Michael Trend and Betsy's resignation. I have dealt with that fake allegation above, in her written statement.

149.  [p35] Vanessa first claims that she did not know Alistair Burt was my PPS at the time. Alistair was appointed in October as both the Commissioner and Ms Barry correctly state. Then she says that he did not attend communications meetings which is beside the point. Vanessa can provide no reason why she did not raise the issue the question with Alistair if she wasn't happy with Owen. Surely if she didn't want to speak to me she could have spoken to him.

150.  [p36] The reference to Crick in the e-mail again begs questions. What evidence is there that Crick was looking into parliamentary allowances? How would Vanessa know this? Crick's evidence to the Commissioner is that he did not start his investigation into the employment of my wife until late May 2003 and only after the issue was raised with him by anonymous 'Conservative' sources [transcripts, p9; and at p26 he notes the producer came into the project on 'May 23/24' 2003]. His investigation was clearly after the fact of the 30 January e-mail and its leaking. In that regard the language of the e-mail was no coincidence, it was selected so that it could be released to the media with maximum impact.

151.  [p37] Vanessa attempts to say that Betsy's employment was only mentioned in passing. But why mention it at all? The fact of the matter is that the other matters in the e-mail are trivial and/or without substance in comparison with the suggestion that there was something wrong about the employment of my wife. Vanessa accepts it was the most important issue if it became public at the bottom of p. 37. As my wife's employment had already ceased, and as Vanessa states [on p36] she knew that to be case (Owen having told her in November or early December at the latest), its appearance in the e-mail is deliberate. Vanessa had been in politics long enough to know the consequences of putting such an allegation in writing. And if this was a bona fide query then why was Owen left off the mailing list?

152.  On pages 35-36 Vanessa keeps saying that she raised Betsy's employment with Owen but received no answer. Owen knew, along with Christine that I had decided that Betsy would come off the payroll before the end of November. Yet on p36 Vanessa says that she did know that Betsy had come off the payroll. She knew because as Owen states in his interview with the Commissioner he informed her of that by the end of November or early December. Yet Vanessa claims throughout that he didn't reassure her when he not only reassured but informed her the matter had been dealt with.

153.  [p37] Vanessa does not explain how she goes from a programme about my CV to believing that "In the light of Trend….and my ongoing and continued concerns regarding his financial affairs I sensed [Crick] was not far behind us"? In fact Crick says he was not involved before May 2003. Crick only has a complaint because Vanessa sent her e-mail. Vanessa's comments require a full explanation.

154.  [p38] This account of our meeting is quite incorrect as I set out in Section 2 above.

155.  Everything that Vanessa says in her statement and interview about my emotional states and my behaviour as an MP and individual is wholly at odds with my reputation amongst my staff and colleagues and would, I believe, be contradicted by their statements.

Mark MacGregor

156.  During his time as chief executive at CCO Mark had minimal contact with Betsy and he would not have known what she was doing when she was employed by me at Swanbourne. He never raised the issue of Betsy's employment with me either of his own volition or following Vanessa Gearson's e-mails in January 2003. If he thought it was an issue at the time then it would be have been remarkable for him, as Chief Executive, not to mention it to me as I spoke to him regularly and he had direct access to me at all times. He was never shy about expressing his views.

157.  Mark did have cause to visit Swanbourne on one occasion in late August 2002 so I know he saw the office we had there. He also saw the facilities that were being made ready for the refurbished office and approved them. However, in addition to the office it had a conference room and beds so that people could stay over and it was considerably cheaper than having people stay at hotels for the conference facilities. There is also the matter of an alarm system which had been a security upgrade recommended by the police after I was elected Leader.

158.  Rather than deal with Mark's statement and transcript which largely replicates what Vanessa Gearson has said, I have dealt with their conduct and motivation in Section 4 below.

Other former members of staff

159.  A number of individuals helped me during my leadership campaign in the summer of 2001. The majority of those who assisted me were volunteers and received no payment for their work. Upon my election as Leader of the Conservative Party I felt obliged therefore to take on all the volunteers. It was however apparent that not all the staff could be taken on permanently so initially the members of staff were employed on temporary contracts. There were a number of people who were not employed on a permanent basis: amongst others Belinda McCammon and Simon Gordon. These employees may have resented losing their positions in this way.

Simon Gordon's transcript (undated), pp5-20[56]

160.  When I first met Simon Gordon he was Chairman of London North East Conservative Association. He met my wife in her capacity as Diary Secretary during that time. I remember him speaking to her on a number of occasions in the course of arranging events for me to attend.

161.  Simon Gordon recalls from 2001 after I became Leader that although "I did not have an overview at all who was doing what" [p16] "I recall occasional mentions that Betsy was dealing with something or other, which I would assume meant that she was working with Annabelle Eyre on some project" [p15].

162.  Simon was not the office manager. As he testifies, the title "did not mean that I managed the office at all because, for a start, I would not have been allowed to have managed Annabelle Eyre, Andrew Whitby-Collins or Jonathan Hellewell. They would only have worked to Mr O'Brien. In fact, they would have only worked to the Leader … there was no way, as such, I was able to be an office manager in the truest sense of the word … So, I did not have an overview at all as to who was doing what" [pp15-16].

163.  Simon goes on to record that in relation to Betsy's employment "Nobody ever expressed any disquiet to me while I was there" [p17, last line].

164.  Lastly, Simon was a member of staff when I was establishing the new Leader's Office and he says this say about the conditions when we arrived in 2001: "when a new leader comes in, you will inevitably have chaos to a certain extent …We did literally arrive and there were no books at all. There was nothing. There was only one member of William Hague's team who remained and he was a Central Office employee. So, it was an entirely new team that came in and you may get a mismatch of talents or abilities" [p18]. Simon's comments are to be contrasted with Vanessa's, who was not there, at pp16-18 of her transcript.

Belinda McCammon, e-mail dated 18 November to the Commissioner in response to e-mail from Commissioner dated 29 October 2003[57]

165.  Although Belinda McCammon represents a very minor aspect of this matter, I will deal with what she says as shortly as I can. I refer to what Mike Penning and my wife told the Commissioner. Belinda joined my leadership campaign, having previously worked at Scottish Conservative Central Office. She assisted the press spokesman, Mike Penning, and the Press Officer, Vanessa Finneran.

166.  Belinda came to work for the Conservative Party at the end of campaign together with a number of other volunteers on a temporary contract. She did not have any defined role. She was not employed as a press officer.

167.  Initially Belinda was based in 32 Smith Square—far away from the Leader's private office. She was not aware Betsy was employed or, therefore, of the work that Andrew and Annabelle did with Betsy. Belinda was later moved to share an office with Simon Gordon in 34 Smith Square this was a corner office some distance away from my private office. She would not have been able to judge the amount the work being undertaken by Betsy from such short visits. However, she does state that she saw Betsy come into the office on a number of occasions and that "During these times she took the opportunity to go through the diary with the diary secretary".

168.  As Belinda did not know Betsy was employed or what work she was actually doing with Annabelle and Andrew during her short time on my staff, she states that she did not think "the involvement was anything more than a politician's spouse being kept in the loop". That was mere speculation on her part and she does not seem to have inquired into the matter with either Annabelle or Andrew.

169.  Belinda confirms Simon Gordon's evidence that she had no concerns about Betsy's employment; she could not have any as she did not know Betsy was employed.

170.  Jenny Ungless terminated Belinda's contract in December 2001. Belinda was suspected to have leaked material to the press. Shortly after she was dismissed Belinda gave a critical interview which was broadcast on 'PM' a Radio 4 news programme.

Section 4[58]

* * *

9 December 2003

13   See PCS Written Submission 3 and 4.  Back

14   Not appended by the Commissioner.  Back

15   Not appended by the Commissioner-see Volume I, Appendix 1, para 152.  Back

16   Not appended by the Commissioner.  Back

17   Not appended by the Commissioner.  Back

18   See Volume III, PCS Oral Evidence 11.  Back

19   See Volume III, PCS Oral Evidence 11.  Back

20   See Volume III, PCS Oral Evidence 18.  Back

21   See PCS Written Submission 30. Back

22   Not appended by the Commissioner. Back

23   Not appended by the Commissioner.  Back

24   Not appended by the Commissioner.  Back

25   Not appended by the Commissioner. Back

26   Not appended by the Commissioner.  Back

27   Not appended by the Commissioner.  Back

28   Not appended by the Commissioner.  Back

29   Not appended by the Commissioner.  Back

30   Not appended by the Commissioner.  Back

31   Not appended by the Commissioner.  Back

32   Not appended by the Commissioner.  Back

33   Not appended by the Commissioner.  Back

34   Not appended by the Commissioner.  Back

35   Not appended by the Commissioner.  Back

36   Not appended by the Commissioner.  Back

37   Not appended by the Commissioner.  Back

38   Not appended by the Commissioner.  Back

39   Not appended by the Commissioner.  Back

40   Not appended by the Commissioner.  Back

41   Not appended by the Commissioner.  Back

42   Not appended by the Commissioner.  Back

43   Not appended by the Commissioner.  Back

44   Not appended by the Commissioner.  Back

45   Not appended by the Commissioner.  Back

46   See PCS Written Submission 48.  Back

47   Not appended by the Commissioner.  Back

48   See PCS Written Submission 13.  Back

49   See Volume III, PCS Oral Evidence 9. Back

50   Not appended by the Commissioner.  Back

51   See PCS Written Submission 3.  Back

52   Not appended by the Commissioner.  Back

53   See Volume III, PCS Oral Evidence 9.  Back

54   See PCS Written Submission 13.  Back

55   See Volume III, PCS Oral Evidence 9 Back

56   See Volume III, PCS Oral Evidence 11.  Back

57   See PCS Written Submission 16. Back

58   Not appended by the Commissioner-see Volume I, Appendix 1, para 152. Back

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