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Select Committee on Standards and Privileges Third Report


APPENDIX 1: MEMORANDUM FROM THE PARLIAMENTARY COMMISSIONER FOR STANDARDS





Complaint against Mr Jonathan Sayeed

The Complaint

1. On 29 August 2004 there appeared an article in the "Sunday Times" under the headline;

The article began:

    "A senior Tory MP is at the centre of a sleaze row after it emerged that a company he co-owns is charging American tourists $1,500 (more than £800) for guided tours of Parliament by him.".

A copy of this article and of a related, more extensive piece which appeared in the same edition of the paper is at Written Evidence (WE) 1 and 2 respectively. The articles identified the Member concerned as Mr Jonathan Sayeed (the Member for Mid-Bedfordshire) and the company as The English Manner Limited, a 30% shareholding in which Mr Sayeed had registered among his interests in the Register of Members' Interests. The paper commented:

    "By taking paying clients of a company that he jointly owns on guided tours, he [Mr Sayeed] risks breaching a long-held Commons principle that MPs must not use the Palace of Westminster for commercial purposes.".

2. Two days later the Member for Harwich, Mr Ivan Henderson, wrote asking me to investigate whether Mr Sayeed had abused Parliamentary privilege (in this case, Mr Sayeed's privileged access to Parliament) in respect of his association with The English Manner Limited and enclosing a dossier of material he had received from the Sunday Times. Mr Henderson said:

    "It has always been my belief that it is a principle of the House of Commons that MPs should not use their access to the House or its facilities for commercial gain. The principle also extends to third parties attempting to gain commercially from use of the facilities of the House of Commons, and the enclosed dossier appears to suggest that this principle has not been adhered to in this case.".

Mr Henderson also asked me to examine whether it was ethical for Mr Sayeed to employ Mrs Alexandra Messervy as his constituency assistant when she was also the majority shareholder (and chairman) of The English Manner Limited,

    "a dual role that may have resulted in an unacceptable conflict of interest.".

The evidence in support of the complaint

3. The text of Mr Henderson's letter is at WE 3. In it he gives a brief description of the evidence with which the Sunday Times had supplied him. It is not necessary for me to reproduce all of that evidence here as some concerns matters which are not in dispute (such as Mr Sayeed's entries in the Register of Members' Interests or Mrs Messervy's entry in the Register of Interests of Members' Secretaries and Research Assistants) and/or are not directly relevant to the assessment of Mr Henderson's complaint. Some of the material is, however, essential to an understanding of the complaint. It includes the following.

(A) THE TRANSCRIPT OF CONVERSATIONS BETWEEN AN UNDERCOVER REPORTER (POSING AS A POTENTIAL CLIENT) AND MRS BAMBI DUVALL

4. The text of the transcript is reproduced at WE 4. In the first of these conversations Mrs Duvall (a self-employed US agent acting within McCabe Bremer, a travel company acting for The English Manner Limited) indicates that it would be possible to arrange a behind-the-scenes tour of the House of Commons as part of an itinerary Mrs Messervy could put together for the potential client; that Mr Sayeed is the company's contact for these purposes; and that lunch at the House might also be possible, depending on Mr Sayeed's commitments. In the second Mrs Duvall indicates, in response to questioning, that the cost of a day at Parliament might be around $1,500, and that this cost would include any fee paid to a docent (ie to a tour guide). Later in the conversation the reporter asks whether there is a docent in Parliament and is told 'no'. Mrs Duvall confirms that any tour of the House would be led by Mr Sayeed, and perhaps Mrs Messervy.

(B) MATERIAL FROM THE COMPANY'S WEB-SITE

5. A series of extracts from material which had appeared at various points on the web-site of The English Manner Limited was contained in the material forwarded by Mr Henderson. This included the following statements:

i)  From an account of a visit arranged by the company—

ii)  From a description of the projected itinerary of a tour in July 2003—

    "After returning to the Goring Hotel to change, students will be given a private guided tour of the Palace of Westminster by a senior Member of the British Parliament, followed by Dinner in the House of Commons with other MPs or Peers and invited guests including tutors and directors of The English Manner. If Parliamentary business permits, it may be possible for students to listen to a debate in the Chamber of the House of Commons or the House of Lords. Our host will give a brief talk on the British constitution and the role of politics, discussing how the British Parliament works and essential differences between British Parliament and the US Senate.".

iii)  From a Personal Development, Summer Studies Abroad programme for 2004—

    "Depending on the time of year and if Parliamentary business permits, our farewell dinner will be held in the Palace of Westminster after a private guided tour of the House of Lords and House of Commons by a senior British Member of Parliament …".

iv)  From another 2004 programme description which appeared on the web-site—

    "… guests will be transported to the Palace of Westminster for a private tour and champagne reception with senior Members of Parliament and House of Lords, and directors of The English Manner, followed by a private farewell dinner and, if parliamentary business allows it, an opportunity to listen to the business of the day in the debating chamber of the Lords or Commons.".

v)  And from a further 2004 prospective itinerary—

    "Top all this off with the ultimate finale, a tour of the Palace of Westminster and lunch with a senior British Member of Parliament.".

(C) EXTRACTS FROM COMPANY PRESS RELEASE

6. The Sunday Times had also provided Mr Henderson with copies of a number of press releases by The English Manner Limited. They included a press release issued by the company on 7 February 2002 describing its inaugural courses in Washington DC to which Mr Sayeed contributed and a press release issued on 1 April 2003 which began:

It continued:

    "Guests on this unique trip will:
  • Enjoy the first-ever public concert in the 900 year history of Westminster Hall in the Palace of Westminster, following a special champagne reception with some specially invited guests of the Chairman of the Parliament Choir …
  • Attend a champagne reception hosted by a senior Member of Parliament and tour the House of Commons at the Palace of Westminster, followed by a sumptuous private dinner".

Mr Sayeed was at the time chairman of the Parliament Choir.

(D) ARTICLE BY MR BOB MORRIS

7. Finally the material forwarded to me by Mr Henderson included a copy of an article by a Mr Bob Morris from the November 2002 edition of "Travel and Leisure" magazine. The text of the article, which was entitled "English Class", is reproduced in WE 5. Describing the difficulties of Americans unaccustomed to English etiquette, it says that there is now "hope" for them in programmes arranged by The English Manner Limited, "which includes … a tour with members of Parliament". The article goes on to describe Mr Morris's experience of being given a tour and lunch by Mr Sayeed. It continues:

Relevant Rules of the House

8. There is no explicit provision in the Code of Conduct for Members approved by the House concerning misuse of the facilities (as opposed to the allowances) provided a Member by the House. Whether the Code should be amended in this respect is an issue I have already raised in the consultation paper on the review of the Code which I issued in July 2004.

9. Although the Code of Conduct does not include an explicit provision prohibiting the misuse by Members of the facilities of the House, it does include a provision that:

Members are also required to observe the seven general principles of public conduct identified in the First Report of the Committee on Standards in Public Life, including those of selflessness and integrity;

    "Selflessness: Holders of public office should take decisions solely in terms of the public interest. They should not do so in order to gain financial or other material benefits for themselves, their family, or their friends.".

    "Integrity: Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might influence them in the performance of their official duties.".

10. However it is clear from the rules, approved by Mr Speaker or the appropriate Committee, relating to the use of private dining and meeting rooms in the House that the use of these facilities for the direct financial or commercial benefit of a Member or of a company is not permitted. For example, regulation 5.2 of the Banqueting Regulations approved by the Catering Committee states:

    "… the private dining rooms are not to be used for direct financial or material gain by a Sponsor, political party or any other person or outside organisation.".

Registered charities and all-party Parliamentary groups are the only exceptions to this rule.

11. Following receipt of Mr Henderson's letter, I consulted the Serjeant at Arms whose Department administers, on behalf of Mr Speaker, the booking of rooms and the official arrangements for tours of the House. Commenting on the general issues raised by the complaint against Mr Sayeed, the Serjeant said:

    "I am certain that it is wrong in principle for any outside organisation to make admission to House facilities, which are provided for Members' use for Parliamentary purposes, conditional on the payment of fees. There is a long-standing convention that Parliamentary facilities should only be used for Parliamentary purposes … the leaflet "Committee Rooms, Conference, Meeting and Interview Rooms" … states in paragraph 4 that:

    "Meetings should be connected in some way with the Parliamentary duties of the Member who books the room. Rooms should not be used for purposes unrelated to the House, such as entertainment or the launch of any commercial or financial product.".

12. In my view, if a Member were to abuse the privileged access he or she had to the House and its facilities by exploiting it for the financial or commercial benefit of themselves or of a company in which he or she had a registrable financial interest, the Member would in many cases have breached rules laid down to prevent such exploitation. He or she would certainly have acted in a manner likely to bring the House into disrepute and to weaken the public's trust and confidence in the integrity of Parliament.

My Inquiries

13. Against the background of this understanding of the effect of the Code, I wrote to Mr Sayeed on 2 September enclosing a copy of Mr Henderson's complaint and seeking Mr Sayeed's explanation. A copy of my letter is at WE 6. I explained the essence of the complaint against Mr Sayeed in these terms:

At the same time I wrote to the Serjeant at Arms and the Directors of Catering and of Finance to seek their views on the issues raised (the Director of Finance particularly in relation to Mr Sayeed's employment of Mrs Messervy). I subsequently interviewed Mr Sayeed and corresponded with and interviewed Mrs Messervy (in the presence of her solicitor, Mr Aidan Mills-Thomas). I also met Mr Sayeed on 11 January 2005 to discuss his comments on the draft factual sections of this memorandum.

14. Rather than go through in turn the evidence of each of those concerned, I hope it will be for the convenience of the Committee if I describe the evidence I received in relation to the key issues I believe it will need to consider in order to assess Mr Henderson's complaint, beginning with those matters which are uncontentious. In what follows I draw on material given me by Mr Sayeed in letters dated 7 September, 26 October, 25 November and 8 and 14 December, which I have appended at WE 7, 9, 16, 19 and 21 to this report (at WE 6, 8, 15, 18 and 20 are my letters to which these are responses) and at our meeting on 3 November (an agreed note of which is at WE 11). I have also drawn on Mrs Messervy's letters to me of 1 and 26 November (WE 10 and 17) and the agreed note of my meeting with her and Mr Mills-Thomas on 5 November (a copy of which is at WE 12). I have not appended to the report all the other material referred to by Mr Sayeed and Mrs Messervy but will mention only what among it is essential to an understanding of the case

15. Mr Sayeed and Mrs Messervy have responded promptly and at length to all my inquiries. I should also make clear at the outset that Mr Sayeed has throughout strongly rejected the complaint against him and continues to assert his innocence of any wrongdoing, for the reasons I shall go on to set out. In his initial letter responding to the complaint he said:

    "The Sunday Times articles are based on partial or out of context quotes and innuendo and the thrust of their charge (ie that either or both of the English Manner and myself charge fees for giving tours of the Palace of Westminster) is quite simply wrong …

    Being an MP is a privilege and not one I have ever or would ever use for personal financial gain. I am meticulous in registering my outside interests and would not misuse or abuse my access to Parliament or my position as an MP."

(A) THE ENGLISH MANNER LIMITED

16. According to Mrs Messervy, The English Manner Limited was established by her in June 2001. It is not a travel company in the usual sense but:

Mrs Messervy is the chairman of the company, owning 60% of the shares. The other director, her friend Mrs Genie Ford who oversees the US end of the company's operation, owns 10%. The remaining 30% is owned by Mr Sayeed.

17. The company has not so far posted a profit or declared a dividend to its shareholders. According to Mr Sayeed;

In her letter of 1 November and at our meeting on 5 November, Mrs Messervy explained how the company charged its clients a fee for arranging a programme for them, based on the programme's content and duration.[44] The English Manner Limited did not, however, receive a straight percentage of the total cost of a programme to a group but a percentage of the charge made for each element of any itinerary which she (Mrs Messervy) had effected.

18. She is adamant that the company never charged clients a fee for tours of the Palace of Westminster. The only respect in which the company has received any money from clients in relation to the Palace has been, on 3 occasions, as straight reimbursement for the cost of meals provided there. (For details of these and other occasions, see paragraph 39 below.) It has not charged any commission in relation to these occasions.

(B) HOW THE COMPANY MARKETED ITSELF

19. The English Manner Limited has not advertised its services directly in the media but has attracted some media coverage and has operated a web-site "which is used as a marketing tool for those who seek it out".[45] It visits luxury travel agents to market itself in the United States and has developed a relationship with a number of them, principally McCabe Bremer. Mr Sayeed has accompanied Mrs Messervy on some of her visits to the USA, where they have introduced the company to selected travel agents.

20. It has been an essential part of the marketing thrust of the company that it offers access for its clients to people, institutions and places they would not find it easy to access without the company's assistance.[46] Mrs Messervy says that the company did not claim to give access to Parliament or to Mr Sayeed.[47] However some of the material which appeared on the company's web-site to which I have referred in paragraph 5 above may, with its references to "a private guided tour of the Palace of Westminster by a senior Member of the British Parliament," have given a different impression.

21. Mrs Messervy has readily conceded that material implying that privileged access to Parliament could be arranged should not have appeared on the web-site.[48] Indeed both she and Mr Sayeed go further and say that its appearance was contrary to clear instructions they both gave when the company was first established. According to Mr Sayeed, he had given repeated and very clear instructions (first issued in late 2001 or early 2002) that neither he nor Parliament were to be used as a promotional tool and that he would not use his position as an MP to promote the company.[49] Mrs Messervy supports this account, although no record of these instructions exists.[50] So too does Mrs Genie Ford, US director of the company, who in her statement of November 2004 says:

    "… as far back as early 2002, he [Mr Sayeed] specifically cautioned [***] and others working on The English Manner business that he was not permitted to use his position as a Member of the British Parliament for personal gain; that his name must not appear on any promotional material and that as anyone could visit Parliament in the UK it followed that The English Manner did not have a USP (unique selling point) in relation to Parliament and should not suggest that it had.".[51]

22. Whilst Mrs Messervy accepts overall responsibility as the company's chairman for the way it marketed itself, she did not personally authorise the material on the web-site. According to Mrs Messervy, control of the web-site rested with her American co-director Mrs Ford. Mr Sayeed had no input into the day-to-day marketing of the company and had probably never seen the material on the web-site.[52] Mrs Ford confirms that Mr Sayeed had no input into the company's promotional material.[53] Mrs Ford employed a *** to help promote the company. Mrs Messervy says that once it had been discovered that the web-site contained inappropriate material, *** was warned on more than one occasion not to use it. When she persisted in doing so, she was dismissed in May 2003 for this and other reasons, (although Mrs Messervy did not think the letter terminating her employment contained references to her failure to adhere to instructions).[54] [55]

23. This account is supported by the statement of Mrs Ford at WE 13. ***'s departure did not, however, lead to the immediate removal of inappropriate material from the web-site. Mrs Ford says that it took several attempts through the webmaster to remove inaccurate references from the web-site. It appears indeed that material implying that the company could provide clients with privileged access to Parliament was still being posted on the web-site in 2004—see the references to prospective 2004 programmes quoted at paragraph 5 (iii)-(v) above.

(C) MRS DUVALL'S CONVERSATIONS WITH THE "SUNDAY TIMES" REPORTER

24. That same impression was clearly given by Mrs Bambi Duvall (a self-employed US agent acting within McCabe Bremer, the travel company acting for The English Manner Limited) to Mr Joe Lauria, the Sunday Times reporter who spoke to Mrs Duvall on 25 and 26 August 2004 and the transcript of whose conversations is at WE 4. For example, after Mrs Duvall indicated that she normally put Mrs Messervy in touch with clients to discuss such matters, the conversation on 25 August included the following exchange:

    Mr Lauria: So maybe I can go behind the scenes in the House of Commons when they are in?

    Mrs Duvall: That is a definite. That is something that you can't find anywhere else. We have a great contact. He is a Member of Parliament, Jonathan Sayeed. And if his schedule allows it, then we have some times, you can have lunch there, sometimes it's behind the scenes tours."

25. The conversation the following day included a similar exchange in which Mrs Duvall confirmed the possibility of a behind the scenes tour of Parliament conducted by a Member. She mentioned that she had recently organised a day for a family of three which had included such a behind the scenes experience of Parliament and that the total itinerary for the day had cost about $1,500. (I give Mr Sayeed's and Mrs Messervy's account of this particular visit at paragraph 39(i) below.) When Mr Lauria asked:

    "So you are saying that a day at the Parliament would be comparable to that one day with etiquette around $1,500?".

Mrs Duvall replied:

    "Yeah, give or take.".

Later in the same conversation, Mrs Duvall says that the largest group The English Manner Limited can handle is:

    "twelve, anyway because if we do schedule lunch or dinner in the Parliament, in their dining facility the max is 12 people.".

26. Mrs Messervy has supplied a copy of a statement made by Mrs Duvall on 31 August, in the immediate aftermath of the "Sunday Times" story, in which extracts from her conversations with Mr Lauria were reported. In the statement (of which a copy is at WE 14) Mrs Duvall says that at no time did she ever say that Mr Sayeed was paid for tours of Parliament. She says she was misquoted regarding the $1,500 for a Parliament tour "as I explained it was for an entire package that included etiquette training as well as meals, transfers, hotels etc." After reporting the conversation to Mrs Ford and Mrs Messervy, she attempted to contact Mr Lauria again to make clear that The English Manner Limited "do not offer tours of Parliament for payment by Jonathan Sayeed or anyone else".

27. Mr Sayeed says he was astonished to read the transcript of the conversation between Mrs Duvall and Mr Lauria:

Mr Sayeed adds that while "Mrs Duvall is quite wrong in what she says and had no right to say it," he can understand why the Sunday Times wrote up the story on 29 August as it did.

    "I have given immediate instructions to The English Manner that my name must never be misrepresented by them in this way or anybody acting for them …".

28. In her letter of 1 November Mrs Messervy says that Mrs Duvall was not an employee of The English Manner Limited but an independent, part-time consultant associated with McCabe Bremer. She was not authorised to make the statements she did to the Sunday Times reporter:

    "We forthwith sent Bambi Duvall a reprimand for the statements she made and she was very apologetic and had not realised she had made such an important mistake.".[57]

(D) THE PRESS RELEASE AND THE ARTICLE BY MR BOB MORRIS

29. Having summarised the evidence presented by Mr Sayeed, Mrs Messervy and others in relation to the material on the web-site of The English Manner Limited and to Mrs Duvall's conversation with a Sunday Times reporter, it may be convenient if I briefly set out their evidence relating to the press release issued by the company, extracts from which I quote at paragraph 6 above, and to the article by Mr Morris at WE 5.

30. As regards both of the press releases forwarded by Mr Henderson, Mr Sayeed and Mrs Messervy say that these were issued without their knowledge or authority by ***, who has since been dismissed by the company (see paragraph 22 above). In her letter of 1 November Mrs Messervy says:

31. Mr Sayeed and Mrs Messervy say of the lunch Mr Sayeed hosted for Mr Bob Morris that they understood that Mr Morris was over in the United Kingdom researching the subject of English etiquette, on which Mrs Messervy was an acknowledged authority. Mrs Messervy says that she thought to involve Mr Sayeed only because he was 'a typical English gentleman'.[59] Mr Sayeed says of the lunch:

    "No other travel writer was present, indeed my understanding of Mr Morris's position was that he was here to write on English etiquette, the English way of life and parliamentary heritage. At no stage was any sales pitch made by myself or Mrs Messervy for The English Manner and I believe the approach was made to Mrs Messervy because of her background in the Royal Household. No payment was made by Mr Morris or anyone else for the lunch and neither I nor Mrs Messervy had any control over the article that he wrote. Indeed I am informed by Mrs Messervy that she asked Mr Morris to remove certain references to his visit to parliament and some items dealing with royalty but he declined to do so.".[60]

32. As can be seen from WE 5, Mr Morris's article nonetheless included, when it appeared in Travel and Leisure magazine, an account of Mr Morris's visit to the House and a number of favourable references to The English Manner Limited. The article was subsequently posted on the company's web-site, where—although it was not immediately apparent and had to be accessed via a link—it remained into 2004. Mrs Messervy readily admitted that, with the benefit of hindsight, it should have been removed along with other material from the site.[61]

(E) MR SAYEED'S RELATIONSHIP WITH THE ENGLISH MANNER LIMITED

33. I turn now to describe the evidence relating to Mr Sayeed's role in relation to The English Manner Limited. According to Mr Sayeed he has known Mrs Messervy, initially through a shared business interest, since before he became the Member for Mid-Bedfordshire in 1997. In July 1997 he employed her as his constituency assistant. She has also been variously Deputy Chairman (1995-2001 and 2004 to date) and Chairman (2001-2004) of his local constituency association.

34. When Mrs Messervy decided to set up The English Manner Limited, Mr Sayeed "agreed to help in a modest way".[62] Although Mrs Messervy had wished him to be a director of the company, he had declined because he had not wished to have any direct responsibility for what the company did.[63] (In conversation with me on 11 January, Mr Sayeed said that there was a clear distinction in his mind between the responsibilities of a director for the general conduct of a company and those of a consultant, who is only responsible to a company for the advice he or she gives in specific, defined and agreed areas.) In June 2001, he had agreed to take a 30% shareholding in the company and to act as a part-time consultant to the company "to advise on the formation of the company, its Articles of Association etc, provide continuing advice on company management, accountancy etc and to give strategic and marketing advice".[64] Mr Sayeed had never received a dividend as a shareholder but in his capacity as a part-time consultant had received, in the three and a quarter years since the company's formation a total of £1,875 in consultancy fees and been reimbursed £3,487 in expenses incurred on behalf of the company.[65] Mr Sayeed is adamant that he has never received any payment for hosting tours or meals for clients of The English Manner Limited in the House.

35. At my meeting with Mr Sayeed on 3 November I asked him how, if his role included giving marketing advice, he was unaware of the terms in which The English Manner Limited was representing itself to potential clients on its web-site and through its press releases. Mr Sayeed said that by marketing advice, he meant not "day to day marketing, most of which I was neither aware of, nor had any control over, but more for markets to approach and how best to tackle them".[66] There was a distinction between marketing and advising on how to approach markets or potential markets. He had known the company had a web-site and how it was constructed but had not been aware of the fine detail of the text: as consultant he had had no reason to be. He had no reason to believe the content would be contrary to the clear instruction he recalled having given before the official launch of the company that neither his name nor that of Parliament were to be used as a promotional tool.[67]

(F) REGISTRATION ASPECTS

36. The Rules approved by the House on the registration and declaration of Members' Interests provide that a Member must register any shareholding which is greater than 15% of the issued share capital of a company. Mr Sayeed wrote to the Registrar of Members' Interests on 20 December 2001 seeking advice on whether and how to register his interest in The English Manner Limited. The Registrar replied on 15 January 2002 and Mr Sayeed responded on 24 January. As a result the following entry appeared in the looseleaf version of the Register published on 1 February 2002:

    consultant to The English Manner Ltd. Occasional lectures and adviser to Board on strategic issues and marketing.

    6. Overseas Visits

    7-11 February 2002, to Washington DC, USA, for company launch, paid for by The English Manner Ltd (Registered 24 January 2002)

    9. Registrable shareholdings

    (a) The English Manner Ltd."

37. Mr Sayeed did not repeat the entry in relation to his shareholding when the Register was re-compiled following the changes to the Rules approved by the House on 14 May 2002. However, he wrote to the Registrar on 1 November 2002 asking for a 30% shareholding in The English Manner Limited to be registered and the following entry appeared in the edition of the Register published on 26 November 2002.

    "9. Registrable shareholdings

    (a) The English Manner Ltd."

A similar entry has appeared in subsequent editions of the Register.

38. Mr Sayeed has also registered a total of 6 trips to the USA in respect of which his expenses have been met by the company.[68] I understand from Mr Sayeed that these trips were undertaken for marketing and lecturing purposes. From the detailed information Mr Sayeed has supplied, it appears that some of the expenses of these trips are included in the figure of £3,487 given above but some are not.

(G) VISITS TO PARLIAMENT OF GROUPS OR INDIVIDUALS CONNECTED WITH THE ENGLISH MANNER LIMITED

39. I have discussed with Mr Sayeed and Mrs Messervy the circumstances in which various groups or individuals associated with The English Manner Limited have visited the Palace of Westminster. Altogether, based on the evidence they have supplied and information from the Refreshment Department of the House, I have identified 9 such occasions. Of these 5 appear to call for particular mention:

40. In paragraph 6(ii) above, I have mentioned the press release which appeared on the company's web-site referring to the planned concert in Westminster Hall by the Parliament Choir, of which at the time Mr Sayeed was the Chairman. Mr Sayeed gives a full account of this in section 6 of his letter of 26 October.[71] According to him and to Mrs Messervy, in the event only 2 guests of The English Manner Limited attended the concert and a private reception at the Goring Hotel which preceded it. No privileged access to Parliamentary facilities was involved.

41. To sum up the key points of the evidence presented by Mr Sayeed and Mrs Messervy in relation to the actual use made of Parliamentary facilities by people associated with The English Manner Limited:

    i)  On all occasions there was an element of personal friendship involved in the circumstances leading up to the meal and tour concerned;

    ii)  The meal and tour was not advertised in advance as a part of the programme of the group involved, nor did it constitute part of a programme for which payment was made (except as described in (iii) below);

    iii)  No fee was charged by The English Manner Limited for arranging the facilities. Where any charge was levied, it was purely in reimbursement for the cost of the meal involved;

    iv)  Mr Sayeed was not paid a fee for his part in the event.

42. Mr Sayeed also argues that:

    i)  The vast majority of entertainment for clients of the company took place away from the Palace of Westminster; [72]

    ii)  Because of the constraints of the Parliamentary timetable, and in particular his former responsibilities as a Shadow Minister, it was not always feasible for him to transact private business away from the House;[73]

    iii)  It is an acceptable use of House rooms and facilities to increase understanding of the British Parliament and constitution. This was an element in all events associated with the company in which he participated;

    iv)  While he agrees with the general principle enunciated by the Serjeant at Arms and the Director of Catering (and reflected in the Banqueting Regulations quoted in paragraph 9 above) that the facilities of the House should not be exploited for the financial or commercial benefit of a company, a test of reasonableness should be applied. Many Members:

      "who have remunerated and properly declared outside interests meet and entertain those commercial interests in the Palace of Westminster. I do not believe that such behaviour by MPs is regarded as being an abuse of the privilege of being an MP.".

The fullest exposition of these arguments is contained in Mr Sayeed's letter of 25 November at WE 16.

(H) THE PARLIAMENTARY EMPLOYMENT OF MRS MESSERVY

43. In his letter of 31 August 2004, Mr Henderson also asked me to examine whether it was ethical for Mr Sayeed to employ Mrs Messervy as his constituency assistant when she was also the majority shareholder and chairman of The English Manner Limited. Having surveyed the relevant evidence relating to Mr Sayeed's role in relation to the company, I turn to set out the evidence relating to Mrs Messervy's role as Mr Sayeed's constituency assistant.

44. Mr Sayeed first employed Mrs Messervy as his constituency assistant following his election as the Member for Mid-Bedfordshire in 1997. Her contract is dated 11 July 1997 and it describes her role as "constituency liaison." No job description was attached to the contract: although the form of contract presumed that a job description would be attached, it was not a requirement that Members' staff should have a job description until July 2001. The position Mrs Messervy held was described in the contract as "part-time and less than 13 hours per week." She was paid £4,000 pa on appointment: she is now paid £12,000 pa.

45. The Department of Finance and Administration (DFA) have consulted their records about whether Mrs Messervy was a full or part-time employee of Mr Sayeed and whether she was based in London or the constituency. In a letter to the Department dated 6 August 2001 Mr Sayeed described Mrs Messervy as a "full-time London based employee". He gave a similar description of her status in forms submitted to the Department relating to the financial years 2001-02, 2002-03 and 2003-04. These declarations were important because, under paragraphs 5.3.3-5.3.4 of the rules on Members' allowances then in force, Members with constituencies outside London received an enhanced staffing allowance for any employee(s) based wholly or mainly in London, to reflect the higher employment costs involved.[74]

46. Mr Sayeed insists that Mrs Messervy has always been part-time and constituency based, although she has occasionally helped out in his London office. In his letters of 8 and 14 December (WE 19 and 21), he offers an explanation of the discrepancy between this statement of the position and the statements on the letter and forms he sent to the DFA. In essence this is that in August 2001 his PA was pregnant and he anticipated that Mrs Messervy might have to become London-based in order to cover for her. Again in March 2002 when his PA actually went on maternity leave, he considered Mrs Messervy becoming full-time and London-based. He signed a form on 17 February 2003 again describing Mrs Messervy as full-time and London-based in error but, he says, this had no overall effect on the size of the staffing allowance to which he was entitled because he already had 3 other full-time London staff, the maximum allowed by the DFA.

47. The Department of Finance and Administration point out that when they allocate the staffing allowance for each year, they do so on the basis of the number of staff employed in London in April of the financial year in question, and not on the basis of Members' possible plans for the future. The fact that Mr Sayeed incorrectly told them that Mrs Messervy was full-time and employed in London could have affected the level of staffing allowance to which he was entitled. The Director concludes that in his view there was a breach of the House's provisions concerning the staffing allowance in that Mr Sayeed gave incorrect information about Mrs Messervy's status to the Department on four separate occasions. However, given the information Mr Sayeed has supplied to my inquiry, it does not appear that there has been an actual over-payment of the allowance.

48. As Mrs Messervy's contract did not include a job description, I asked both Mr Sayeed and Mrs Messervy to describe her role. In his letter of 26 October , Mr Sayeed responded:

    "… her role is to liaise between the press and others and myself relating to my parliamentary duties and constituency work. She also liaises between the officers and members of the constituency association regarding general constituency and parliamentary matters and diary. She acts as a "look out" for problems within the constituency …".[75]

A similar broad description was given by Mrs Messervy during our meeting on 5 November.[76]

49. In my letter of 6 December (WE 18) I put to Mr Sayeed whether duties involving liaison "between the officers and members of the constituency association regarding general constituency and parliamentary matters" were appropriately reimbursed from the Parliamentary staffing allowance. The Green Book on Members' allowances, etc describes the scope of the allowance as being:

    "to meet the costs wholly, exclusively and necessarily incurred on the provision of staff to help Members perform their Parliamentary duties.".

and makes clear that the allowance is not available for:

    "staff who are employed on party political duties or non-Parliamentary duties.".

As previously noted, throughout the whole period she has been employed by Mr Sayeed, Mrs Messervy has also been either Chairman or Deputy Chairman of his constituency association.

50. Mr Sayeed responded on 8 December:

    "From time to time Mrs Messervy liaises between the officers and members of my Association, many other interested parties and myself. She suggests to officers and members of the Association meetings I could attend in my role as their constituency MP, they jointly discuss visits they would like me to make to schools, hospitals, businesses etc, and they inform her of local problems which she researches and informs me about. In addition she drafts press releases, monthly newspaper columns, liaises with the local press and facilitates my attendance at local meetings. Such work enables me to perform my parliamentary duties as a constituency MP and it is for that and that alone that she is paid. She has not been paid for her party political activities or for being Chairman or Deputy Chairman of mid-Bedfordshire Conservative Association. Therefore the duties she has undertaken for me can be completely justified in terms of the requirements laid down in the Green Book.".[77]

51. In his letter of 31 August Mr Henderson raised in essence the question whether there was any conflict of interest between Mrs Messervy's role in relation to The English Manner Limited and her role as Mr Sayeed's constituency assistant. Members' staff are not prohibited from doing other paid work when they are not working for the Member. They are required to include in the Register of Interests of Members' Secretaries and Research Assistants any other paid employment or occupation which might benefit from their possession of a Parliamentary pass. Mrs Messervy first registered her interest in The English Manner Limited on 4 March 2002 and it has remained on the Register since.

52. Mr Sayeed and Mrs Messervy deny that there is any conflict of interest between Mrs Messervy's two roles. As Mrs Messervy's role as Mr Sayeed's constituency assistant is part-time, she is able to combine this with running the company. Mrs Messervy says in her letter of 1 November:

    "… you ask if my role in relation to the company interacted with my role in relation to Mr Sayeed. The answer to this is not at all … My role for Mr Sayeed as constituency liaison assistant is just that and quite separate.".[78]

Mrs Messervy says that she only used her Parliamentary pass to enter the Palace and visit the office of Mr Sayeed or his PA. Since the publication of the 'Sunday Times' report, she has surrendered her pass.

53. Mr Sayeed confirms this and says;

    "She [Mrs Messervy] has never used her employment to further her client base with The English Manner nor has she ever taken any guests for tours in the House of Commons.".[79]

At our meeting on 3 November, Mr Sayeed summed up his evidence on this point in this way:

    "As to … the suggestion that [his] employment of [Mrs Messervy] was unethical, he would contend that a separation of powers was in place; the company was small; he employed [Mrs Messervy] part-time; both had acted ethically.".

Findings of Fact

54. The English Manner Limited was established by Mrs Messervy in June 2001 to create instructional tour programmes, with a particular focus on etiquette, for affluent clients mainly from overseas. Mrs Messervy, as chairman, owns 60% of the shares in the company, the second (US) director of the company, Ms Ford, 10% and Mr Sayeed 30%. The company has never generated a profit or paid a dividend. Both Mr Sayeed and Mrs Messervy have registered their interest in the company in the appropriate Parliamentary Register.

55. The company has not advertised its services directly in the media but sought to attract clients through its web-site, through building links with luxury travel agents and personal recommendation, and through favourable coverage in the media. It has been an essential part of the marketing thrust of the company that it offers access for its clients to people, institutions and places they would not find it easy to access without the company's assistance.

56. Both Mr Sayeed and Mrs Messervy say that the company did not claim to give access to Parliament or to Mr Sayeed. Material which appeared on the company's web-site gives the opposite impression. Mr Sayeed, Mrs Messervy and Mrs Ford say that this material was unauthorised, indeed contrary to their explicit instructions. Mr Sayeed was not aware of the contents of the web-site and neither he nor Mrs Messervy controlled it. When Mrs Messervy became aware of such unauthorised material she attempted to have it removed. They similarly say that Mrs Bambi Duvall, a self employed agent acting within McCabe Bremer, the US travel company acting for The English Manner Limited, was not authorised to imply such privileged access to Parliament through Mr Sayeed when speaking to a Sunday Times reporter in August 2004, and that press releases and an article by Mr Bob Morris, a US travel writer, about English manners which made similar statements implying privileged access to the Palace of Westminster through the company were also either unauthorised or outside their control.

57. As well as being a shareholder in the company, Mr Sayeed is a part-time consultant to it on strategic and marketing issues. In this respect he has received in the three and a quarter years since its formation a total of £1,875 in consultancy fees and been reimbursed £3,487 in expenses incurred on the company's behalf. He has made 6 visits to the USA for marketing and lecturing purposes in respect of which the company has reimbursed his expenses: these have been (in the case of four) or will shortly be (in the case of the other two) the subject of entries in the Register of Members' Interests.

58. On a number of occasions Mr Sayeed has hosted people associated with The English Manner Limited, including some paying clients of the company, on tours and for meals in the Palace of Westminster. However, he and Mrs Messervy assert that:

I am not aware of any evidence which would contradict the evidence Mr Sayeed and Mrs Messervy have given on these points.

59. Mrs Messervy has been employed by Mr Sayeed as his part-time constituency assistant since he was elected as the Member for Mid-Bedfordshire in 1997. Although he represented her in error to the DFA four times between 2001 and 2003 as a full-time and London-based employee, she has in fact always been part-time and constituency based. Mr Sayeed's explanation of this error is given at paragraph 46 above. Whilst Mr Sayeed's repeated mis-representation to the Department of Mrs Messervy's position was wrong (a point Mr Sayeed accepts), it does not (on the basis of the information he has given my inquiry) appear that Mr Sayeed received any more in terms of staffing allowance than that to which he was entitled.

60. Both Mr Sayeed and Mrs Messervy are adamant that there was no conflict of interest between Mrs Messervy's role in relation to The English Manner Limited and her role as Mr Sayeed's constituency assistant, partly because of the part-time nature of the latter, partly because Mrs Messervy was careful to separate her two roles and never used her Parliamentary staff role or her possession of a Parliamentary pass to further her company's interest. They also assert that there was no confusion between Mrs Messervy's role as an officer of Mr Sayeed's constituency association and her Parliamentary role as his constituency assistant.

61. Following the Sunday Times articles about Mr Sayeed and The English Manner Limited on 29 August 2004, Mrs Messervy gave up her Parliamentary pass on 7 September. Mr Sayeed says that he has (letter of 26 October);

Mr Sayeed continues, however, firmly to deny that his actions in relation to The English Manner Limited have involved any abuse of his privileged position as a Member of the House.

Conclusions

62. As I have noted in paragraph 8 above, there is no explicit provision in the Code of Conduct for Members concerning misuse of the facilities of the House. However, it is clear from the Banqueting Regulations and the advice I received from the Serjeant at Arms (see paragraphs 10-11 above) that the use of these facilities for the financial or commercial benefit of a Member or of a company is not permitted.

63. The Code of Conduct includes a provision requiring Members to conduct themselves in a manner designed to strengthen public trust and confidence in the integrity of Parliament and not to do anything which would bring the House into disrepute (paragraph 9). If a Member were to exploit the privileged access he had to the facilities of the House for the financial or commercial benefit of a company in which he had a registrable financial interest, that would in my view be likely to bring the House into disrepute and to weaken public trust and confidence in the integrity of Parliament (paragraph 12).

64. Mr Sayeed registered his 30% shareholding in The English Manner Limited. This shareholding has not so far benefited him through the payment of a dividend but it does give him a stake in the future success of the company. He also has a stake in that success through his role as a consultant on strategic and marketing issues. In his capacity as a consultant and shareholder, he has paid 6 visits to the USA funded by the company, all of which he has again registered, although the two most recent of these were registered well after the 28 days deadline for such matters. He has received since the company was established £1,875 in consultancy fees and £3,487 in expenses reimbursed by the company. Mr Sayeed's financial interest in the company is clear.

65. The key question is whether Mr Sayeed has used or exploited his privileged access as a Member to the facilities of the House for the financial or commercial benefit of The English Manner Limited. Mr Sayeed, supported by Mrs Messervy, answers that question with a clear 'no'. The company never charged a fee when its clients were hosted by Mr Sayeed and Mrs Messervy at the House, merely (and then only in a few cases) the cost of the meal provided. Mr Sayeed never received a fee for hosting such occasions. The meal and tour of the House involved were not advertised to clients in advance nor were they part of their paid programme. In all cases, they assert, there was an element of private relationship or friendship with those who were being hosted.

66. Mr Sayeed concedes, however, that in view of the conversation Mrs Duvall had with Mr Lauria—in which Mrs Duvall indicated that Parliament was indeed one of the institutions to which the company could provide clients with privileged access—it was not surprising that the Sunday Times reported its story as it did on 29 August. Nor, I would add, is it at all surprising given the material on the company's web-site which I have summarised in paragraphs 5-7 above. Although some of this material had been archived prior to 2004, some if it was still on the site earlier that year, prior to the appearance of the Sunday Times story.

67. Mr Sayeed, supported by Mrs Messervy and Mrs Ford, says that Mrs Duvall was not authorised to make the statements she did to Mr Lauria. Nor had he authorised or was he aware of the material on the company's web-site. Indeed any reference to him or to privileged access to Parliament through him was contrary to an express instruction he had given before the company was launched. No record of this instruction exists but Mr Sayeed explains this by saying that the company was small and he had no reason to think his instruction would be disobeyed. He, Mrs Messervy and Mrs Ford point to the departure of *** in May 2003 as evidence of the company's intention to get these matters right.

68. It is difficult to understand how, if the placing by *** of unauthorised material on the web-site was a factor in her dismissal in May 2003 (paragraph 22), similar material was still posted on the web-site after her dismissal in relation to the company's 2004 programme (paragraph 23). The web-site was, according to Mrs Messervy, used by the company "as a marketing tool for those who seek it out". She acknowledges that, as chairman of the company, she must carry overall responsibility for what appeared on it, and at my meeting with her on 5 November did not demur when it was suggested that she had not exercised sufficient control over it. Mr Sayeed denies any responsibility for the web-site: as a consultant, his interest was in the development of prospective markets for the company. His role did not imply any responsibility for how the company currently marketed itself.

69. It appears from the instruction said to have been given by Mr Sayeed on the lines previously mentioned that he was clearly aware of the dangers of the company using his status as a Member or Parliament's name to promote its activities. It is therefore again surprising that Mr Sayeed apparently made no effort himself subsequently to check the terms in which the company was promoting itself. Whilst I acknowledge Mr Sayeed's argument that this was not an obligation on him flowing from his role within the company, it would certainly have been prudent given his obligations as a Member. In my view, the balance of evidence indicates that both Mrs Messervy, as chairman of the company, and Mr Sayeed, as a Member and as a significant figure in the company, failed to exercise effectively the responsibilities which could reasonably have been expected of them in relation to the way the company marketed itself, both through its web-site and through its US agents.

70. The other ways in which, according to Mr Sayeed and Mrs Messervy, The English Manner Limited promoted itself were through attracting favourable media attention and by personal recommendation. It is in this context that it is necessary, I submit, to view the various occasions on which Mr Sayeed hosted groups or individuals in the House, details of the most significant of which I have given in paragraph 39. Given that personal recommendation was one of the means by which the company sought to promote itself, it is not surprising that an element of personal relationship or friendship features in each of these occasions. And at least two of the occasions on which Mr Sayeed hosted meals in the House—the familiarisation tour (paragraph 39(ii)) and the lunch with Mr Bob Morris (paragraph 31)—involved the giving of hospitality to people (travel agents and a travel writer) who were in a position directly to promote the commercial interests of the company.

71. I have seen no evidence to suggest that either Mr Sayeed personally or The English Manner Limited benefited directly through the receipt of fees in relation to any of these occasions. I am in little doubt, however, that, taken as a whole, their effect was to give credibility to the company's overall marketing claim that it could gain access for its clients to institutions, people and places which it would otherwise be difficult for those clients to access. In doing this, the occasions promoted the commercial future of the company, a future in which Mr Sayeed had a clear beneficial interest. In this context, it would not matter that Mr Sayeed refrained from directly promoting the company on any such occasion. The mere fact that Mr Sayeed was hosting people in what his guests would see as such exclusive surroundings would be enough to establish the validity of the company's claim. When taken together with the material on the company's web-site the overwhelming impression left on clients, prospective clients and contacts in the travel trade would be that the company could indeed gain exclusive access for them, and that this could include access to Parliament.

72. I recognise the force of Mr Sayeed's argument that a test of reasonableness has to be applied to the way in which the relevant rules of the House relating to commercial benefit and a Member's financial interests should be interpreted. What, however, distinguishes this case from the other examples relating to Members which Mr Sayeed gives is, in my view, the fact that The English Manner Limited's claim to provide privileged access was central to the marketing of its services. I do not therefore see this case as requiring revision of the House's rules or having wider implications for the way in which those rules are currently interpreted by Members.

73. In my view, Mr Sayeed has a duty of care under the Code to protect the reputation of Parliament and not to bring it into disrepute. Taken as a whole, the evidence indicates that he has, at the least, been negligent or careless in respect of that duty.

74. I turn now to the issues raised by Mr Henderson in relation to Mr Sayeed's employment of Mrs Messervy. Mr Henderson asked me to consider whether it was ethical for Mr Sayeed to employ Mrs Messervy as his constituency assistant when she was also the majority shareholder (and chairman) of The English Manner Limited. Mr Henderson suggested that these dual roles may have resulted in "an unacceptable conflict of interest".

75. As I noted in paragraph 51, Members' staff are not prohibited from undertaking other paid work when they are not working for the Member. They are required to register any paid employment or occupation which might benefit from their possession of a Parliamentary pass. Mrs Messervy had registered her role in relation to The English Manner Limited.

76. There would have been a conflict of interest if Mrs Messervy had used her role as Mr Sayeed's constituency assistant to further the commercial interests of her company. Mrs Messervy and Mr Sayeed are adamant that she did not do so. There is no evidence to suggest that Mrs Messervy failed to complete the hours she was contracted to work for Mr Sayeed on Parliamentary duties or that she misused office or other facilities provided to her and Mr Sayeed by the House by using them to help her conduct the business of The English Manner Limited.

77. There is no doubt, however, that the manner in which Mrs Messervy's company marketed itself—with its claim to provide privileged access to Parliament—readily gave rise to the possibility of a perception of conflict of interest between Mrs Messervy's two roles. Mrs Messervy has acknowledged that, as chairman of The English Manner Limited, she must accept overall responsibility for the way the company marketed itself. Her decision to register her interest in the company indicates that she was alive to the possibility that her connection with Parliament through her employment by Mr Sayeed would be seen as potentially beneficial to the company. Yet she failed to ensure that the company of which she was chairman and majority shareholder and its agents avoided claiming to be able to give its clients privileged access to Parliament, and so laid both Mr Sayeed and herself open to the complaint which followed.

78. At his meeting with me on 3 November, Mr Sayeed contended that "a separation of powers was in place" between Mrs Messervy's various roles. Given the evidence set out in this report, it is not surprising that, whilst such a separation may have been apparent to Mr Sayeed and Mrs Messervy, it was not so apparent to any outside observer. In this context Mrs Messervy's decision to give up her parliamentary pass and Mr Sayeed's declaration that in future he will not personally conduct anyone introduced by The English Manner Limited around the Palace of Westminster nor entertain them there, whilst welcome, resound with the loud crash of a stable door being locked after the horse has bolted.

79. In paragraphs 44-50 of this report, I have identified issues raised by my inquiries relating to Mrs Messervy's lack of a job description, her full or part-time status and the nature of her role. I comment briefly on these in turn.

80. Whilst it was not obligatory for Mrs Messervy to be given a job description when she was appointed, it was a presumption that she should have one and it was certainly desirable that she should have one. Mr Sayeed has acknowledged this as a result of my inquiries and is remedying the deficiency.

81. Mr Sayeed gave incorrect information about whether Mrs Messervy was a full or part time employee to the Department of Finance and Administration on four separate occasions. Mr Sayeed says that this information was given in good faith, because of an expected change in his office needs consequent on the pregnancy of his PA. Nevertheless he acknowledged that he incorrectly described Mrs Messervy's status to the Department and, during discussion with me on 11 January of the factual sections of the memorandum, said that he apologised for this.[81]

82. Mr Sayeed acknowledges that Mrs Messervy's role includes liaison between himself and officers and members of his constituency association, and, that Mrs Messervy has herself been a prominent officer of the association during the whole period she has been employed by him. He denies, however, that this means she has crossed the line between Parliamentary and party political work. I have not uncovered evidence which would contradict that denial.

83. However, I am concerned that Mrs Messervy wore so many different hats in relation to Mr Sayeed after his election in 1997—as friend, officer of the association, fellow shareholder in The English Manner Limited and employee—that there was ample scope for her different roles to be confused, at least by any outside observer. A proper degree of separation between these roles, and consequently of transparency, was lacking.

84. To sum up, I have seen no evidence that Mr Sayeed and Mrs Messervy directly received fees in return for hosting clients of The English Manner Limited in the House. However, I believe that in their conduct in relation to The English Manner Limited both Mr Sayeed and Mrs Messervy have at the least been negligent in failing to exercise sufficient care to safeguard the reputation of Parliament and at worst have acted carelessly, in a manner which has allowed that reputation to be injured. The explanation for this may stem as much from a misplaced sense of the obligations of friendship as anything, but its effect has been to allow others to draw the conclusion that privileged access to the House and its facilities is a commodity to be marketed and is dependant on having the right connections, which can be obtained at a price. More generally, whilst the explanation they offer for each element in the complaint against them may be plausible, taken as a whole I do not find it a convincing justification of their position. The "separation of powers" or compartmentalisation of activities which Mr Sayeed claimed governed his various dealings with Mrs Messervy may have been evident to them, but in my view, it would not have been apparent to an outside observer.

85. I therefore recommend that Mr Henderson's complaint against Mr Sayeed in relation to his conduct concerning The English Manner Limited should be upheld. I find that the multiple roles Mrs Messervy fulfilled in relation to Mr Sayeed were such as to give rise at least to a perception of a conflict of interest, both between her role in relation to the company and her role as his constituency assistant and between her role as his assistant and as an officer of his constituency association. I find that Mr Sayeed gave misleading information to the Department of Finance and Administration on four separate occasions about Mrs Messervy's employment status, although this does not appear to have resulted in an overpayment of the staffing allowance. Finally, I note that in failing to notify the Registrar of Members' Interests until earlier this month of visits to the USA in February and April last year paid for by The English Manner Limited, Mr Sayeed breached the requirement on Members to notify changes in their registrable interests within four weeks of each change occurring. [82]

12 January 2005

Sir Philip Mawer





43   WE 9. Back

44   WE 10, WE 12. Back

45   WE 10. Back

46   WE 12, para 16. Back

47   WE 12, para 6.  Back

48   WE 12, para 10.  Back

49   WE 11, para 9. Back

50   WE 10; WE 12, paras 9 & 15. Back

51   WE 13. Back

52   WE 12. Back

53   WE 13. Back

54   I attempted to contact *** to obtain her confirmation of this account of events but without success.  Back

55   WE 12, paras 10 & 14. Back

56   WE 7. Back

57   WE 10. Back

58   WE 10. Back

59   WE 17. Back

60   WE 9. Back

61   WE 12. Back

62   WE 17. Back

63   WE 11, para 9. Back

64   WE 7. Back

65   WE 7. Back

66   WE 9. Back

67   WE 11, paras 9-13. Back

68   4 of these have already appeared in the Register. Notice of 2 further trips-made in February and April 2004 respectively-was given to my office by Mr Sayeed on 5 January 2005 and entries relating to them will appear in the next edition of the Register.  Back

69   WE 12. Back

70   WE 9. Back

71   WE 9. Back

72   WE 9. Back

73   WE 7. Back

74   The Green Book on Parliamentary Salaries, Allowances and Pensions published in April 2002. There is similar provision in paragraphs 6.3.3-6.3.4 of the current edition of the Green Book.  Back

75   WE 9. Back

76   WE 12, para 29. Back

77   WE 18. Back

78   WE 10. Back

79   WE 11. Back

80   WE 9. Back

81   WE 21. Back

82   Guide to the Rules relating to the Conduct for Members, paragraph 11, 2002 (HC 841). Back


 
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