Select Committee on Standards and Privileges Third Report


Written evidence received by the Parliamentary Commissioner for Standards

NOTE: Any enclosures mentioned in the documents listed are not appended.

1.  Letter to the Commissioner from Mr John Mann and Mr Kevan Jones, 23 November 2006

Please find enclosed a file on the actual and possible misuses of Parliamentary facilities for party political fundraising. You will note this has been raised by oral and written question and we are aware of the existence of at least two current journalistic investigations.

It is clear that there is a systematic use of 'patrons clubs' to dine in the Commons and Lords explicitly to fundraise for the Conservative Party.

We have so many examples and individual complaints that we enclose them as one file.

Our analysis of room bookings is that this is only the tip of the iceberg and that there are perhaps hundreds of such fundraising events.

We have had great difficulty in finding proof, but we enclose what appears to us to be categorical proof of misuse.

You will note that this matches precisely the system explained in the academic analysis of the Political Quarterly article of 1991 (enclosed).

In our view the money raised, inadvertently or deliberately outside the rules, must be paid over to charity in full. Clearly there needs to be an immediate cessation of this activity and a full analysis of all dining room bookings.

We are of course happy to co-operate fully with any inquiry.

23 November 2006

2.  Article from the Political Quarterly, April 1991

Patrons' Clubs in the Conservative Party: a special kind of membership

Membership of the Conservative Party is by individual subscription to local Conservative Associations. There is no central party membership register nor is there a set subscription, although £5 per annum is the recommended Central Office subscription target. However, Central Office emphasises that £5 should be taken as a constituency average so as not to discourage those who can only afford to pay a little. This subscription target is achieved in a substantial number of constituencies although the average subscription figure in seats in urban and inner-city areas can be as low as £1.50 or thereabouts.

The Houghton Committee estimated the party's average constituency membership to be 2,400 which yields a national membership figure of 1.5 million. This figure is currently claimed by the party. However, a survey of forty-eight Conservative Associations carried out by the author—plus interviews with Central Office officials and constituency agents and workers—suggests that the actual national membership figure is nearer 1 million. A major feature of the membership levels in the Associations surveyed is the wide variation according to electoral environment. In safe seats (held by the Conservative Party with majorities of 10 per cent or more of the total 1987 General Election poll) average membership was found to be 1,877. In marginal seats (held by the Conservative Party or other parties with majorities of 5 per cent or less of the total poll) the average membership level fell to 903. Finally, membership in 'unwinnable' seats (held by other parties with majorities of 10 per cent or more of the 1987 poll) amounted to only 277.

However, in addition to yielding information on membership levels and variations by electoral environment, the survey revealed the existence of a special category of member found in a number of safe seats and some marginal constituencies. These are the members of Patrons' Clubs. Members of such Clubs are offered a privileged position within Associations in return for a substantial annual subscription. Patrons' Clubs are specifically designed to attract and involve local 'notables', and as such their members constitute an elite inside some Conservative Associations. They seek to enlist the financial support of local notables for whom ordinary membership may have little attraction or who have no time to become more actively involved. The literature of a Patrons' Club in the South West makes this point clearly.

There are many who strongly agree with the aims and policies of the Conservative Party but who, because of business, professional, or other commitments do not have the time to become actively involved in the Conservative organisation. With this in mind, the Patrons' Club was formed as a means of channelling this support.

Patrons' Clubs are organised by Association officers and/or constituency agents and subscribers are entirely separate from other members. Names and subscription details are kept private and confidential and will not be found in the Association's 'public' membership records.

The basic recommended subscription is £100 per annum for a single person and £150 per annum for a member and spouse. However, there are considerable variations between and within Patrons' Clubs. In the North, the reported annual subscription is £80 for a single person and £120 for a couple. Subscription income from Patrons' Clubs can be considerable. One Patrons' Club in the South East, founded in 1984, has a target of one hundred members subscribing a total of £33,000 per annum. This is broken down into sixty members subscribing £150, twenty members subscribing £250, ten members subscribing £500, three members subscribing £1,500, one member subscribing £2,000 and finally, one member subscribing £2,500. It has almost achieved this target. A Patrons' Club in a Yorkshire constituency included in the survey has a member who subscribed £1,000 per annum. In the run up to the 1987 General Election, a Patrons' Club in the South West declared that its aim was to raise £10,000 per year to fund the coming campaign.

Three important features of all Patrons' Clubs are (i) the social programme, (ii) special links with their Conservative Member and government figures and (iii) the provision of financial assistance to other constituencies. An annual dinner and reception are two events which figure in all Club programmes and they are a source of additional income. The dinner is usually held at the House of Commons. Clubs which do not have a Conservative Member will usually be hosted by a Peer. Members take it in turn to host the local reception and it is, perhaps, not surprising that the membership of wives is reckoned to be an important factor in any Club's success. One of the main purposes of Patrons' Clubs is to raise large sums of money to fund major initiatives and campaigns at the local level and, most importantly, to channel vital financial support to less fortunate constituencies, especially marginals. One Patrons' Club calls itself 'The Mutuals' in recognition of this important aim. This Club already pays for a trained agent in a neighbouring marginal constituency and hopes to do more. Almost without exception, Patrons' Clubs are pledged to raise money to support the party's efforts in other seats. Finally, Patrons' Clubs emphasise that their members will have privileged and direct contact with their MP and/or other senior members of a Conservative government. Most provide subscribers with a regular newsletter or bulletin from their Member.

There are currently about one hundred Patrons' Clubs which, by their very nature, are overwhelmingly concentrated in safe Conservative seats. Their total membership is unlikely to be much more than 5,000 but, with an average subscription of £100, members of Patrons' Clubs probably generate something in the region of £500,000 annually for the party. The total figure may well be considerably more, especially in General Election years when fund-raising and appeals are stepped up. They function as an important channel along which resources can be moved to areas of greater need.

In many ways, Patrons' Clubs are reminiscent of the first Conservative Associations formed in the 1830s. Lacking a mass electorate—and hence any need for a mass membership—these Associations were essentially groupings of local 'notables' whose social activities maintained the party's presence in the constituencies. They provided funds which were employed to get supporters onto the new post-1832 electoral register. They also provided the finance to support contests in the associated Registration Courts which dealt with disputed claims. Patrons' Clubs house a special kind of party member. They raise what are clearly large sums of money, thus enabling others to carry on the electoral struggle. They have a very strong social dimension. Indeed, several Patrons' Clubs actually have the label 'Dining Club' in their title. Electoral times have changed but, in the Conservative Party at least, something of the original melody lingers on.

April 1991

3.  House of Commons Banqueting Regulations in force currently

1.  Eligibility

1.1  A Member of Parliament, an Officer of the House of Commons, or Member of the House of Lords who was formerly a Member of Parliament, must sponsor all functions, except as noted in 1.2 below.

1.2  Accredited, authorised all-party and House of Commons Committees are permitted to book the private dining rooms in their own right. Further details are available from the banqueting office.

2.  Duties of Sponsor

2.1  The Sponsor is responsible for the good conduct of the function and for ensuring that the terms and conditions of booking are complied with.

2.2  No Sponsor may hold more than 6 bookings are any time.

2.3  The Sponsor must be present throughout the function, except when required to vote in the House.

2.4  It is the duty of the Sponsor to find a suitable replacement in the event that he/she is unable to attend. The banqueting office must be notified of any change.

2.5  The Sponsor is responsible for ensuring the bona fides of any organisation on whose behalf they sponsor a function.

2.6  The Sponsor is responsible for ensuring that the Private Dining Confirmation Form is completed and signed.

2.7  The Sponsor may delegate the responsibility of co-ordinating a function to an Organiser, in which case a Sponsorship Agreement Form must be completed and signed. These are available from the banqueting office.

2.8  The Sponsor is liable for all costs associated with an event.

3.  Duties of the Organiser

3.1  Organisers to whom the co-ordination of a function has been properly agreed and authorised may deal directly with the banqueting office in making all arrangements for the function.

3.2  Organisers are responsible for all liaison with their Sponsor to ensure that the terms and conditions of the booking are met.

3.3  Organisers of sponsored events shall have the status of GUEST only.

4.  Declaration of Interest

4.1  The Sponsor is directly and personally responsible for the declaration of any relevant interest relating to their sponsorship of a function.

4.2  The Sponsor must complete the relevant section of the Private Dining Confirmation Form to indicate whether or not there is a relevant interest.

4.3  In the event that there is any relevant interest, invitations must clearly state "relevant interest declared".

4.4  Any Sponsor in doubt about the requirements to declare any interest should consult the Parliamentary Commissioner for Standards.

5.  Use of Private Dining Rooms

5.1  Subject to the exclusions in 5.2, 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.

5.2  Use of the private dining rooms for direct financial or material gain by all-party Parliamentary groups or by registered charities is acceptable.

5.3  The private dining rooms may not be used as an inducement to recruit new members of outside organisations or non-parliamentary associations.

5.4  No commercial presentation, promotion or demonstration is permitted.

5.5  Subject to the rules on the declaration of interest and 5.1 above, it is appropriate for the private dining rooms to be used for political functions or for "lobbying purposes".

5.6  All functions must be brought to a close by 10.30pm and guests should leave the Parliamentary Estate by 11.00pm. The Refreshment Department reserves the right to recover additional costs incurred in the event of a late vacation of the premises.

5.7  With the exception of Wedding/Special Event cakes, no food or drink, other than that supplied by the House of Commons Refreshment Department, may be consumed on the premises.

5.8  No betting or gaming may be carried out on the premises.

5.9  Concerts, loud music or other activities likely to cause a noise nuisance are NOT permitted. Background music may be permitted by prior agreement at times when neither House is sitting and adjacent rooms are not in use for other events. The Sponsor should apply in writing to the Chairman of the Administration Committee who will advise the Speaker.

6.  Publicity, Photography & Media

6.1  Any publicity, invitation, circular, literature or announcement in connection with the function must bear prominently the name of the sponsoring Member or Officer of the House of Commons, or Member of the House of Lords and must be submitted to the banqueting office for approval prior to publication.

6.2  Any media interest must be notified in writing to the banqueting office and copied to the Sponsor.

6.3  All representatives of the media must possess a formal invitation.

6.4  Television cameras must be hand-held and any filming or photography is restricted to the confines of the function room.

6.5  Photographers, television crews and radio crews authorised by the Sponsor must obtain a permit from the Director of Catering Services via the banqueting office.

7.  Booking

7.1  Provisional bookings will be held for a maximum of ten working days. If the banqueting office does not receive the signed confirmation of Booking within this time, the reservation will be automatically cancelled without further notice.

7.2  Reservations can be made for a maximum period of 18 months in advance of the function date.

8.  Cancellation by the Sponsor

8.1  Cancellation must be confirmed in writing to the banqueting office.

8.2  Cancellation of a confirmed booking will incur the following charges, unless the banqueting office is able to subsequently re-let the room:

9.  Cancellation by the House of Commons

9.1  In the event of the dissolution of Parliament, all functions during this period will be cancelled without any liability to the Sponsor or Organiser.

9.2  The House of Commons Refreshment Department may also cancel a function without liability to the Sponsor or Organiser if:

  • The House is unexpectedly recalled during a recess.
  • The House of Commons premises or any part of them are closed for reasons beyond the control of the House authorities.
  • The Sponsor ceases to hold a position eligible to host a function.
  • The Sponsor or Organiser is in breach of the terms and conditions of the booking.

10.  Charges

10.1  An estimate of number of persons attending functions must be provided by Sponsors or Organisers when completing the booking form.

10.2  Charges will be based on the final attendance numbers confirmed. Final numbers must be confirmed to the banqueting office not less than 3 working days before the date of the function.

10.3  Where catering is less than the required minimum food spend or the minimum required number of guests per room, the advertised Room Hire charge will be levied. Room Hire is applied to each time slot throughout the day.

10.4  All functions taking place on Friday evenings and Saturdays will incur a weekend supplement. Details are set out in this brochure.

10.5  If numbers attending fall below the minimum required for the room booked, the Refreshment Department reserves the right to relocate the function to a smaller room. Should no such room be available, the advertised minimum numbers for the booked room will be charged.

10.6  All charges will be based upon the banqueting tariff current on the date of the event, not the date of booking. Organisers are therefore advised to allow a contingency for any such price increases when allocating budgets to a function.

10.7  As a general rule, banqueting tariffs are reviewed annually in April.

10.8  Prior to departure at the end of their function, Organisers and Sponsors are advised to agree and sign for all drinks consumed. The Refreshment Department cannot be held responsible for a discrepancy after the event.

10.9  The final account charged to the Sponsor's Refreshment Department Account will remain as an outstanding debt until it has been paid by either the Sponsor or Organiser.

10.10  All queries relating to the invoice should be addressed to the banqueting office.

10.11  Cheques must be crossed and payable to the House of Commons Refreshment Department.

10.12  All menu and wine/bar prices are quoted inclusive of service charge @ 12.5% and VAT @ 17.5%.

11.  Access

11.1  Entrance to the Palace of Westminster is via St Stephen's Entrance for all guests, or at 1 Parliament Street for the Astor Suite or Bellamy's Clubroom.

11.2  All guests attending an event must be in possession of an official invitation, to be shown on demand to the House of Commons Security. This invitation card is to be produced by the event organiser and verified by the Banqueting Office before going to print. See below for an example of the approved wording.

An enlarged example of the above can be found under Banqueting Additional Services

11.3  A typed list of attendees' names must be supplied to the banqueting office a minimum of 24 hours in advance of the function.

11.4  The banqueting office will be pleased to advise on access arrangements for disabled guests.

11.5  No car parking facilities are available. Coaches and cars may set down and pick up guests at St Stephen's entrance or outside the entrance to 1 Parliament Street.

12.  General

12.1  No display of any sort is permitted outside the room hired for the function.

12.2  Sponsors or Organisers must ensure that all stage sets, stands, materials and decorations are non-flammable and comply with all relevant safety regulations.

12.3  No flammable, noxious or dangerous items may be brought into the Parliamentary premises.

12.4  All fire exists, stairways, gangways and doors must be kept clear and free from obstruction at all times.

12.5  The House of Commons accepts no responsibility for any errors or omissions appertaining to function details not confirmed in writing to the banqueting office.

12.6  The Director of Catering Services has the authority to accept, refuse or re-schedule bookings at any time. Such authority will not be exercised unreasonably.

12.7  The banqueting office is happy to advise Organisers about catering for special dietary needs. Organisers should enquire whether their guests have any special dietary requirements or food intolerances and should communicate this information to the banqueting office before the function.

12.8  All menus must state 'Guests who have food allergies, should ask the supervisor for assistance'.

12.9  A no smoking policy operates in all House of Commons Banqueting areas.

12.10  The Refreshment Department is unable to offer storage facilities either prior to an event or after an event has taken place. The Refreshment Department will not take responsibility for any items left on the Parliamentary Estate.

4.  House of Commons Banqueting Regulations in force prior to 13 December 2000

1.  Eligibility

1.1  A Member of Parliament, an Officer of the House of Commons, or Peer who was formerly a Member of Parliament, must sponsor all functions, except as noted in 1.2 below.

1.2  Accredited, authorised all-party parliamentary organisations are permitted to book the private dining rooms in their own right. Further details are available from the banqueting office.

2.  Duties of Sponsor

2.1  The Sponsor is responsible for the cost and good conduct of the function and for ensuring that the terms and conditions of booking are complied with.

2.2  No Sponsor may hold more than three bookings at any time.

2.3  The Sponsor must be present throughout the function, except when required to vote in the House.

2.4  It is the duty of the Sponsor to find a suitable replacement in the event that he/she is unable to attend. The banqueting office must be notified immediately of any change.

2.5  The Sponsor is responsible for ensuring the bona fides of any organisation on whose behalf they sponsor a function.

2.7  The Sponsor may delegate the responsibility of co-ordinating a function to an Organiser, in which case a Sponsorship Agreement Form must be completed and signed. These are available from the banqueting office.

3.  Duties of the Organiser

3.1  Organisers to whom the co-ordination of a function has been properly agreed and authorised may deal directly with the banqueting office in making all arrangements for the function.

3.2  Organisers are responsible for all liaison with their Sponsor to ensure that the terms and conditions of the booking are met.

3.3  Organisers of sponsored events shall have the status of GUEST only.

4.  Declaration of Interest

4.1  The Sponsor is directly and personally responsible for the declaration of any relevant registered interest relating to their sponsorship of a function.

4.2  The Sponsor must complete the relevant section of the Private Dining Confirmation Form to indicate whether or not there is a relevant registered interest.

4.3  In the event that there is any relevant interest, invitations must clearly state "relevant registered interest declared".

4.4  Any Sponsor in doubt about the requirement to register any interest should consult the Parliamentary Commissioner for Standards.

5.  Use of Private Dining Rooms

5.1  The private dining rooms may NOT be used for any purpose involving direct commercial gain, or as an inducement to recruit new members of outside organisations or non-parliamentary associations.

5.2  No commercial presentation, promotion or demonstration is permitted.

5.3  Subject to the rules on the declaration of interest, it is appropriate for the private dining rooms to be used for political functions or for "lobbying purposes".

5.4  All functions must be brought to a close by 10.30pm and guests should leave the Parliamentary Estate by 11.00pm.

5.5  With the exception of Wedding/Special Event Cakes, no food or drink, other than that supplied by the House of Commons Refreshment Department, may be consumed on the premises.

5.6  No betting, gaming or auction activity may be carried out on the premises. Raffles may only be drawn on the premises.

5.9  Concerts, loud music or other activities likely to cause a noise nuisance are NOT permitted. Background music may be permitted by prior agreement at times when neither House is sitting and adjacent rooms are not in use for other events.

6.  Publicity, Photography & Media

6.1  Any publicity, invitation, circular, literature or announcement in connection with the function must bear prominently the name of the sponsoring Member/Officer/Peer and must be submitted to the banqueting office for approval prior to publication.

6.2  Any media interest must be notified in writing to the banqueting office and to the Sponsor.

6.3  Television and radio crews, and representatives of the media must possess a formal invitation.

6.4  Television cameras must be hand-held, and any filming or photography is restricted to the confines of the function room.

6.5  Photographers authorised by the Sponsor must obtain a permit from the banqueting office.

7.  Booking

7.1  Provisional bookings will be held for a maximum of ten working days. If the banqueting office does not receive the signed Confirmation of Booking within this time, the reservation will be automatically cancelled without further notice.

7.2  Reservations can be made for a maximum period of 18 months in advance of the function date.

7.3  No event may be provisionally booked for more than two dates.

8.  Cancellation by the Sponsor

8.1  Cancellation must be confirmed in writing to the banqueting office.

8.2  Cancellation of a confirmed booking will incur the following charges, unless the banqueting office is able to subsequently re-let the room:

9.  Cancellation by the House of Commons

9.1  In the event of the dissolution of Parliament, all functions during this period will be cancelled without any liability to the Sponsor or Organiser.

9.2  The House of Commons Refreshment Department may also cancel a function without liability to the Sponsor or Organiser if:

  • The House is unexpectedly recalled during a recess.
  • The House of Commons premises or any part of them are closed for reasons beyond the control of the House authorities.
  • The Sponsor ceases to hold a position eligible to host a function.
  • The Sponsor or Organiser is in breach of the terms and conditions of the booking.

10.  Charges

10.1  At the time of booking, the Sponsor or Organiser must provide an estimate of the number of persons attending the function.

10.2  Charges for food and beverage will be based on the final attendance numbers confirmed. Final numbers must be confirmed to the banqueting office not less than 3 working days before the date of the function.

10.3  Where catering is less than the required minimum food spend, the advertised Room Hire charge will be levied.

10.4  All functions taking place on Friday evenings and Saturdays will incur a weekend supplement. Details are set out in this brochure.

10.5  Should numbers attending fall below the minimum required for the room booked, the Refreshment Department reserves the right to relocate the function to a smaller room. Should no such room be available, the advertised minimum numbers for the booked room will be charged.

10.6  All charges will be based upon the banqueting tariff current on the date of the event, not the date of booking. Organisers are therefore advised to allow a contingency for any such price increases when allocating budgets to a function.

10.7  As a general rule, banqueting tariffs are reviewed annually at the beginning of September.

10.8  Prior to departure at the end of their function, Organisers and Sponsors are advised to agree and sign for all drinks consumed.

10.9  The final account for the function will be invoiced to the Sponsor or Organiser, and is payable upon receipt.

10.10  All queries relating to the invoice should be addressed to the banqueting office.

10.11  Cheques must be crossed and payable to the "House of Commons Refreshment Department".

10.12  All menu and wine/bar prices are quoted inclusive of service charge @ 12.5% and VAT @ 17.5%.

11.  Access

11.1  Entrance to the Palace of Westminster is via St Stephen's Entrance for all guests, or at 1 Parliament Street for the Astor Suite or Bellamy's Club Room.

11.2  A typed list of attendees' names must be supplied to the banqueting office a minimum of 24 hours in advance of the function.

11.3  All guests attending an event must be in possession of an official invitation, to be shown on demand to the House of Commons Security.

11.4  The banqueting office will be pleased to advise on access arrangements for disabled guests.

11.5  No car parking facilities are available. Coaches and cars may set down and pick up guests at St Stephen's entrance or outside the entrance to 1 Parliament Street.

12.  General

12.1  No display of any sort is permitted outside the room hired for the function.

12.2  Sponsors or Organisers must ensure that all stage sets, stands, materials and decorations are non-flammable and comply with all relevant regulations.

12.3  No flammable, noxious or dangerous items may be brought into the Parliamentary premises.

12.4  All fire exists, stairways, gangways, passages and doors must be kept clear and free from obstruction at all times.

12.5  The House of Commons accepts no responsibility for any errors or omissions appertaining to function details not confirmed in writing to the banqueting office.

12.6  The Director of Catering Services has the authority to accept, refuse or re-schedule bookings at any time. Such authority will not be exercised unreasonably.

5.  Letter to Rt Hon Michael Ancram from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of your constituency association's list of forthcoming events, which includes a Patrons' Club luncheon at the House of Commons on 29 November 2006, to be hosted by your and your wife.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that your Patrons' Club is a fund-raising device for your constituency association; that the luncheon on 29 November was not charged at cost; and that therefore in hosting it you breached paragraph 5.1 of the Banqueting Regulations which provides that the House's private dining rooms (and by implication, its other catering facilities) are not to be used for "direct financial or material gain by a ….political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

6.  Letter to the Commissioner from Rt Hon Michael Ancram, 19 December 2006

Thank you for your letter of 7 December. I am most surprised by the complaint from Mr Mann and Mr Jones.

For background, my constituency Patrons' Club, which is composed of people who have paid an enhanced subscription, has for many years attended a number of functions which I have hosted or at which I have been present.

In a typical year these would include a drinks party with my wife and myself at our home in the constituency, an evening somewhere in the constituency at which politics is seriously discussed and a meal in London which sometimes has been at the House of Commons and sometimes at clubs in London and at which there is normally a prominent political speaker.

I had never considered that on the occasions when this took place in the House of Commons this offended against paragraph 5.1 to which you refer. I had always taken the view that this prohibition referred to a Member making available the use of a private dining room in direct exchange for money or some other material gain rather than what I had always assumed in the case of my Patrons' Club was a social/political event.

As you will see from the foregoing there is no question of tickets being sold or any other form of direct financial or material gain as set out in paragraph 5.1. The attraction of such events for the members of the Patrons' Club is to hear a prominent speaker whether that event takes place in the House of Commons or elsewhere.

If there remain any questions in your mind about this I would be more than happy to come and speak to you about them.

19 December 2006

7.  Letter to Mr Richard Bacon from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of two pages from the web-site of the South Norfolk Conservative Association, on the second of which is reference to a Westminster Group dinner at the House on 27 November 2006 at which the Rt Hon David Cameron MP was expected to be present. Mr Mann and Mr Jones assert that there is a fee (which they believe to be £15) to join the Group.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the Westminster Group is a fund-raising device for your constituency association; that there is a membership fee to join it; and that your sponsorship of the dinner at the House of Commons is a breach of paragraph 5.1 of the Banqueting Regulations, which says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

Mr Cameron is named with you in the complaint I have received, and I am therefore writing separately to him about this matter. I am also copying this letter to him so that he is aware of the nature of the complaint. I should make clear, however, that responsibility for ensuring that the terms of the Banqueting Regulations are met rests with the sponsor of, not any speaker at, the event (paragraph 2.1 of the Regulations refers).

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

8.  Letter to the Commissioner from Mr Richard Bacon, 18 December 2006

Thank you for your letter of 7 December concerning the complaint by John Mann MP and Kevan Jones MP.

From your letter and enclosures, I understand that Mr Mann and Mr Jones are claiming that certain dining clubs run by a number of Conservative constituency associations raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription, and that the Westminster Group run by South Norfolk Conservative Association is such a dining club.

Please allow me to explain why I do not believe these claims are justified.

The Westminster Group offers its members the opportunity to attend three dinners each year (two dinners in South Norfolk and one dinner in Westminster) and to hear interesting speakers on current topics.

Recent speakers in South Norfolk have included the chief executive of the local Norfolk and Norwich University Hospital, and the manufacturing director of Group Lotus, which is a large employer in my constituency.

Speakers in Westminster are usually leading figures in the Conservative Party In recent years they have included Liam Fox MP, John Bercow MP and Rt Hon David Davis MP. On Monday 27 November we were due to have had Rt Hon David Cameron MP as the speaker but he was unable to attend due to a visit to Iraq, and instead we had Oliver Letwin MP.

Membership costs £150. This is designed to cover the cost without further charge of participation at three separate 3-or 4-course dinners, including the cost of all food and wine. The Westminster Group is not a fund-raising device for my constituency association. It is designed to cover its costs while enabling those who wish to join to hear interesting speakers.

Membership of the Westminster Group does not confer membership of South Norfolk Conservative Association and there is no requirement for Westminster Group members to join the Conservative Party, locally or nationally.

I hope this helps. If you would like any further assistance, please do not hesitate to let me know.

18 December 2006

9.  Letter to Mr Tony Baldry from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from these two Members relating to your Patrons' Club.

The complaint is linked to a wider series of complaints made by Mr Mann and Mr Jones against a number of Conservative Members, about the alleged use of the House of Commons dining facilities for fundraising by the Conservative Party.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

As you will see the letter dated 1 February, which I received from Mr Mann and Mr Jones at the end of last week, was accompanied by a copy of the report and accounts of the North Oxfordshire Conservative Association for the year ended 31 December 2005. These include a number of references to the Patrons' Club run by the Association, which also appears to be known as the Quorum Club. Page 8 of the report indicates that the Club, with 71 members, "held an excellent Dinner at the House of Commons in November [2005] when Alan Duncan MP came and spoke". Pages 3 and 4 of the Accounts report income from the Club in 2005 of £17,462, as against expenditure of £1,712. The budget for 2006 on the final page shows anticipated income of £16,000 from the Club.

The complaint which Mr Jones and Mr Mann appear to be making is, in essence, that your Patrons' Club is a fundraising device for the Conservative Party, and that the dinner it held at the House in November 2005 breached paragraph 5.1 (and possibly 5.3) of the Banqueting Regulations. This was so in that either an inflated membership subscription was charged for the Club (out of which the expenses of the dinner were met) or that, while the event was charged for separately, membership of the Club was a pre-condition of attendance at the dinner.

I should be grateful if, in accordance with the enclosed procedural note, you would let me have your response to the complaint. It would be helpful if that could include information on:

1.  The membership, activities and aims of your Patrons' Club.

2.  How its activities are funded, including any subscription paid by Members.

3.  How it raises any funds it donates to your Constituency Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years, when, and how these have been funded (whether charged for directly or funded from subscriptions, and if the former whether or not the events have been charged for at cost or have made a profit).

5.  How much it has donated to the Association in each of the last 5 years.

If you would like a word about the matter, please do not hesitate to ring me on the number above. An early reply to my letter would be helpful as I am keen to report on the matter to the Committee on Standards and Privileges reasonably speedily.

I am copying this letter and enclosures to the Director of Catering Services, with whom I am in contact about the interpretation of the Banqueting Regulations and whom I shall consult as necessary on your reply.

6 February 2007

10.  Letter to the Commissioner from Mr Tony Baldry, 7 February 2007

Thank you for your letter of 6 February.

It is not my Patrons' Club. It is the Patrons' Club of the North Oxfordshire Conservative Association.

The membership fees of the Patrons' Club include the cost of one free dinner per year in London, and that is held either in the House of Commons or the House of Lords, or in the Carlton Club.

No fundraising takes place at these dinners. They are simply an opportunity for members of the Club to hear a political speaker and ask questions.

I am aware of the rules, and am confident that they have not been broken.

7 February 2007

11.  Letter to Mr Tony Baldry from the Commissioner, 12 February 2007

Thank you for your letter of 7 February in reply to mine of 6 February about this complaint.

I appreciate the speed of your reply, and note your confidence that the Rules of the House have not been broken. It would help me to understand the manner in which the Patrons' Club of the North Oxfordshire Conservative Association operates if you could supplement your letter by responding to the five questions listed on page 2 of my letter. I am keen to know in particular:

1.  How many members the Association's Patrons' Club has.

2.  What is the subscription charged to members.

3.  How the Club raises any funds it donates to the Constituency Association.

4.  How many events the Club has held at the Houses of Parliament (including how many in the House of Commons) in the past 5 years, and when.

5.  How much the Club has donated to the Association in each of the last 5 years.

It is clear to me from my contacts with other Members named by Mr Mann and Mr Jones that the manner in which such Clubs operate varies considerably and so therefore does the manner in which they are affected by the House's rules. Hence my request for clarification on these points.

12 February 2007

12.  Letter to the Commissioner from the Agent of the North Oxfordshire Conservative Association, 6 March 2007

I have been asked by Tony Baldry MP to supply you with the information you have requested regarding our association Patrons' Club.

1.  The Association had 66 Patrons in 2006, this number can vary from year to year but would be between 50-75 members.

2.  The subscription is £350+.

3.  The Club income is membership subscriptions, which includes membership of the Constituency Conservative Association.

4.  The Club has held 24 events since 1st Jan 2001, of which two were held at the House of Commons and one at the House of Lords. Members are circulated with details of events and are free to choose which they would like to attend.

5.  From January 2001 to 31st December 2006 the Patrons Club has raised £50,430 after expenses for Association funds.

I hope this information is useful to you.

6 March 2007

13.  Letter to Rt Hon David Cameron from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of two pages from the web-site of the South Norfolk Conservative Association, on the second of which is reference to a Westminster Group dinner at the House on 27 November 2006 at which you were due to be present.

Mr Mann and Mr Jones assert that there is a fee (which they believe to be £15) to join this Group and therefore that both you and the Member for South Norfolk, Mr Richard Bacon, have, in effect, broken paragraph 5.1 of the Banqueting Regulations which says that the House's private dining rooms (and, by implication, its dining facilities) should not be used for "direct financial or material gain by a . . . political party." I enclose a copy of the letter I have sent Mr Bacon putting this matter to him.

You will see from this letter that responsibility for ensuring that the Banqueting Regulations are adhered to rests with the sponsor of an event, not any speaker at it, and on that ground I do not see that the particular complaint made against you by Mr Mann and Mr Jones can stand. However, there may be other relevant matters you wish to draw to my notice—hence this letter to you.

You will also see that the precise point put to me by Mr Mann and Mr Jones is considerably narrower than the allegations made in the enclosed article from the "Sunday Times" of 3 December. The article alleges that your own constituency association in Witney runs a Patrons' Club with a membership fee of £480 a year, which offers members up to two lunches hosted by you at the House of Commons a year. It also says that you are "alleged to have booked dining rooms and hosted lunches and dinners for fellow Tory MPs." I should welcome your comments on these allegations also.

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

14.  Article from the Sunday Times, 3 December 2006

Cameron faces inquiry on lucrative lunches

David Cameron, the Conservative party leader, is facing an official investigation for hosting a series of fundraising events in the House of Commons.

He and other senior Tories have hosted 32 fundraising lunches or dinners in private parliamentary rooms in the past two months. They are thought to have raised more than £100,000.

Last week, two backbench Labour MPs filed a formal complaint with Sir Philip Mawer, the parliamentary commissioner for standards.

Parliamentary rules ban the use of Commons dining facilities for fundraising. They state: "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."

The money raised by Cameron's events, via his "patrons' club", is thought to be used to fund his Witney constituency. Cameron is also alleged to have booked dining rooms and hosted lunches and dinners for fellow Tory MPs.

Last Thursday, Nick Gibb, shadow minister for schools, held a Commons lunch for his patrons' club, which was also attended by Theresa May, shadow Leader of the House.

The Commons charges about £35 a head for a three-course meal in the private dining rooms, enabling the Tories to make a profit from a higher fee. Most functions are thought to be attended by about 50 patron club members.

Kevan Jones, Labour MP for North Durham, who lodged the complaint, said: "The misuse of the parliamentary facilities is blatant and disgraceful. These rooms are being block-booked by the Tories months in advance for fundraising functions.

"We have presented enough evidence to the parliamentary commissioner to justify a detailed investigation. Cameron should have to repay every penny his party has raised through these illicit events." John Mann, Labour MP for Bassetlaw, also made the complaint.

A copy of the letter sent to potential members of patrons' clubs, circulated between Tory MPs, advises them to write to potential members saying: "The club holds dinners in the House of Commons twice a year as well as a reception in the constituency. The membership fee is £225 which includes the cost of one dinner for yourself and a guest. The second dinner and further guest tickets costs £35 to include wine and a three-course dinner."

Last week, an undercover reporter approached eight constituency parties and was offered the chance to attend parliamentary dinners or lunches by six.

At Cameron's association the reporter was told £480 would buy access to up to two parliamentary lunches hosted by the leader, plus two dinners at the homes of wealthy local members—who cover the cost and do not charge the party. Cameron's constituency is thus able to profit from the parliamentary functions.

"The Principal Patrons (club)…. have lunches in London and they are at the House of Commons," said a local official.

In Tunbridge Wells, the constituency of Greg Clark, shadow minister for charities, the patrons' club costs £160 per person or £265 for a couple for "a dinner in the Houses of Parliament or the Carlton Club."

An official told the report. "It's quite expensive because—to be honest—you pay a lot to dine in the House and sit in those horribly uncomfortable green leather chairs."

The official went on to describe how the donors could also have tea on the parliamentary terrace reserved for MPs. "If it's a nice afternoon, the doors are always open and you can go and stroll up and down and wave at the tourists," she said.

The Wycombe Conservative Association's website explains that its patrons' club is "for those who wish to support the party but do not have the time to be fully involved in all its activities".

As association official added that the club was for their "more wealthy donors" and that the last event was attended by George Osborne, the shadow chancellor. Paul Goodman is the local MP.

The sale of dinners in the Commons is the latest fundraising controversy to hit Cameron. Last week the Tories disclosed they had taken substantial loans running into millions of pounds from several offshore trusts and companies at rates below those offered by conventional banks.

This week, Cameron will mark his first anniversary as party leader. Yesterday, he laid down the gauntlet to Tory activists and warned they must support his modernising drive or risk losing a fourth election.

A Conservative spokesman said they would be writing to the parliamentary commissioner to "clarify" the rules. He accepted that the patrons' club and their dinners may be used to raise funds for local constituencies.

A party statement said: "The rules state that rooms at the House of Commons can be used for party political purposes and MPs may hire out the rooms for a charge. This appears to be an issue which affects all the political parties."

3 December 2006

15.  Article from the Sunday Times, 31 December 2006

David Cameron has raised more than £100,000 from a private club which offers fundraising lunches at the House of Commons.

Oxfordshire residents are charged £480 a year for membership of the club, of which the main perk is two private lunches in the parliamentary dining rooms. The membership fees have netted Cameron's constituency up to £29,954 a year since his election in 2001.

Earlier this month The Sunday Times revealed that Tory constituencies—including Cameron's—were effectively selling invitations to parliamentary dinners with shadow ministers for hundreds of pounds each.

Last week it emerged that Sir Philip Mawer, the parliamentary standards commissioner, has launched a formal investigation into the Conservative dining clubs. It is against parliamentary rules to use the dining rooms for fundraising.

This weekend the scale of the activities—revealed in the accounts filed by local constituencies—can be disclosed for the first time.

According to the accounts of Cameron's Witney constituency party, his Principal Patrons club brought in £29,954 last year and £25,167 the year before.

The outgoings for the club were just £3,226 last year, so it made a profit of £26,728.

The club is described as a "major income contributor" and is the largest source of funds for the constituency, even outstripping money raised from membership fees.

Other shadow cabinet members are also reliant on the thousands of pounds raised from their patrons' clubs. Tatton, the Cheshire constituency of George Osborne, the shadow chancellor, has made more than £40,000 from his patrons' club since he was elected in 2001.

The patrons' club of Alan Duncan, the shadow trade and industry secretary, has raised more than £20,000 in the past two years for his Rutland and Melton constituency.

The party accounts for last year also refer to a Christmas lunch that was held at the Commons with Cameron as the guest speaker.

The Tory MPs are alleged to have broken parliament's banqueting rules which state: "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."

The Conservatives have denied that the membership fees were a direct payment for the dinners. A spokesman said: "The rules state the rooms may be used for party political purposes and MPs can hire out the rooms for a charge. We have asked Sir Philip to clarify the rules. We believe we have broken no rules."

31 December 2006

16.  Letter to the Commissioner from Rt Hon David Cameron, 9 January 2007

Thank you for your letter of 7th December 2006, regarding the complaint by John Mann MP and Kevan Jones MP into the use of House of Commons facilities. I am very grateful to you for allowing me to reply after the Christmas break.

I have looked carefully at the current rules governing the use of dining facilities at the House of Commons. They seem to contain considerable ambiguity. I do not think that I have broken any rules relating to the use of private dining rooms or other House of Commons facilities, although I will of course be guided entirely by what you conclude.

Let me deal first with the specific complaint made by John Mann MP and Kevan Jones MP in relation to the dinner of the Westminster Group hosted by Richard Bacon on 27 November 2006, at which I was due to speak. As you acknowledge in your letter to me, I see no reason to suppose that my presence—or that of any other Member—as a speaker to a Patrons Club could be held to contravene either paragraph 14 of the Code of Conduct for Members or the Banqueting Regulations. As a speaker, the Member in question is not using 'expenses, allowances, facilities and services provided from the public purse' (as set out in paragraph 14 of the Code of Conduct), and does not—as you point out—carry the responsibility for ensuring that the Banqueting Regulations are adhered to.

Turning to the broader allegations contained in the article in The Sunday Times on 3 December 2006, the West Oxfordshire Conservative Association has a Principal Patrons Club. This was established in 2000, when I was the Parliamentary Candidate for Witney. I attach a copy of the letter inviting recipients to join as a founder member and subsequent correspondence. The Club meets several times a year at various locations in the Witney constituency and at other London venues. It has held two lunches at the House of Commons since I have been the Member for Witney—one on 7th April 2004, addressed by Lord Saatchi, and the other on 16th June 2005, at which the journalist Melanie Phillips was the guest speaker. No activity designed to generate 'direct financial or material gain''(paragraph 5.1 of the Banqueting Regulations) took place at them. I would, of course, be happy to supply any other details of the operation of my Patrons Club since I have been a Member of Parliament, if that would be helpful.

Paragraph 5.5 of the Banqueting Regulations states that 'Subject to the rules on the declaration of interest and 5.1 above, it is appropriate for the private dining rooms to be used for political functions'. My Patrons Club is a 'political function' and is therefore clearly covered by paragraph 5.5. Paragraph 5.1, to which paragraph 5.5 refers, prevents use of private dining rooms by Patrons Clubs for 'direct financial or material gain'. Since funds were not raised at, or in direct connection with, the meals held by the Patrons Club in the House of Commons, I do not believe that my Patrons Club contravenes paragraph 5.1.

Some have argued that the fact there are meals held in the House of Commons as part of the normal round of Patrons Club events could be 'an inducement to recruit new members' as outlined in paragraph 5 3, and could therefore contravene this regulation. However, as you can see from the original letter sent out to potential members, my Patrons Club did not recruit members with the inducement of dinner in the House of Commons. As you can see from the enclosed material, a wide range of functions have been offered to members of the Patrons Club. I attach a list of the breakfasts, lunches and dinners which have been held by my Patrons Club since its inception: only two of the twenty-three events have taken place at the House of Commons.

These Clubs have been custom and practice for many years and, as the complaint against me states, have even been the subject of academic research. In interpreting what are—as you have noted—somewhat ambiguous Banqueting Rules, I would hope that you will be ready to take this into account.

If you require any more information I would be happy to assist in any way I can

9 January 2007

17.  Letter to Mr Jonathan Djanogly from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a list of events held recently in the House. The list includes a reference to an event you hosted for Huntingdon Conservative Association on 18 October, which Mr Mann and Mr Jones say was a meal. They have asked why this event was not posted on Huntingdon Conservatives web-site (a page from which is enclosed) and whether the failure to post it indicates that you charged for the event at more than cost and were aware that you should not have done so.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the event on 18 October was used as a means of raising funds for your constituency association, contrary to paragraph 5.1 of the Banqueting Regulations which says that the House's private dining rooms may not be used for "direct financial or material gain by a . . . political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

18.  Letter to the Commissioner from Mr Jonathan Djanogly, 11 December 2006

Thank you for your letter of 7 December 2006 concerning the complaint by John Mann MP and Kevan Jones MP.

My first point would be that the entry in the list of events, which you provided for 18 October 2006, is incorrect. The entry is wrongly stated as being the "Huntingdon Conservative Association" whilst it should be the "Huntingdon Industrial Advisory Council" (HIAC).

HIAC is an organisation, founded over 25 years ago, which exists for business people living in or connected with Huntingdonshire. There is no need for members of HIAC to be members of the Conservative Party and HIAC itself is not part of the national or local Conservative Party.

My understanding is that members of HIAC pay an annual subscription which entitles them to attend a number of events each year. This includes dinners at the House of Commons or House of Lords, some of which have been booked in my name. Members are entitled to invite guests to HIAC functions and the main purpose of such functions is as a local social networking group with speeches given by notable people, including Members of Parliament.

Accordingly I do not believe that this activity is in breach of section 5.1 of the Banqueting Regulations.

11 December 2006

19.  Letter to the Commissioner from Mr Jonathan Djanogly, 21 December 2006

Thank you for your letter of 14 December.

With regard to your final paragraph, I am not sure how my letter of 11 December could be interpreted to say that the Huntingdon Industrial Advisory Council (HIAC) does not contribute funds to the Conservative Party.

My understanding of the position is that HIAC has its own bank account which is used to receive membership subscriptions and then to pay the money received to fund events. If at the end of the year there is money left over, in the past HIAC has decided to make payments to the Huntingdon Conservative Constituency Association (HCCA).

However, I would make the points that the giving of such money by HIAC to HCCA is:

(a) ancillary to the primary purpose of HIAC, which is to promote the linking of local business to other local stakeholders, including other businesses and politicians; and

(b) to a significant extent, used by HCCA to cover the administrative expenses of HIAC—on the basis that HCCA provides administration services for HIAC.

I hope that this clarifies the position for you.

21 December 2006

20.  Letter to the Commissioner from Mr Jonathan Djanogly, 11 January 2007

Thank you for your letter of 5th January. I have now discussed this with the Secretary of HIAC and can report back as follows:

In confirmation of my previous letter, HIAC was set up some 25 years ago as a forum for business in and connected with the Huntingdon Constituency to meet with the Member of Parliament to discuss and deal with matters of political and economic interest to the business community. It is not seen as a vehicle for raising funds for the Conservative Party.

The annual membership of HIAC has been £300 for the past three years. In the light of increasing catering costs they have decided to increase this to £400 for 2007.

HIAC normally hosts two dinners each year, the majority of which are held in the House of Commons. Occasionally, other venues have been used and other events have also been held. The payment of the membership subscription entitles each member to two tickets at each of the events.

The contributions to the Huntingdon Constituency Conservative Association (HCCA) vary in each year. I should make the point that the administration of HIAC is undertaken within the HCCA office by its staff. Therefore the contributions made should be treated in the most part for payment of administration costs and services.

The annual sums for the past four years paid by HIAC to HCCA are:

2003 £3470

2004 £5810

2005 £4000

2006 £3900

Out of these sums must be taken the administration costs. Detailed figures are not readily available. However, this would annually include several mailings, postage costs, stationery costs, secretarial and event organiser staff expenses, telephone, table decoration and printing of menu cards, as well as payment for alcoholic refreshment consumed during dinners.

Accordingly, I am informed that the net profit element going to HCCA is minimal in all years and sometimes loss making.

Please let me know if I can be of further assistance.

11 January 2007

21.  Letter to Mr James Duddridge from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of an extract from the Register of Members' Interests showing that your constituency party received a donation from the United and Cecil Club.

According to Mr Mann and Mr Jones, the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club". In 2001, it was among the top 50 donors to the Conservative Party.

The essence of the complaint which Mr Mann and Mr Jones appear to be making against you is therefore that your constituency party has received money from a club which they believe to be making improper use of the House's dining facilities to raise money for the Conservative Party. Paragraph 5.1 of the Banqueting Regulations says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to this complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

22.  Letter to Mr Alan Duncan from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from the above two Members relating to your Patrons' Club and its alleged use of House of Commons dining facilities for fundraising purposes.

The complaint is part of a wider series of complaints of a similar nature which I have received from Mr Jones and Mr Mann against a number of Conservative Members. You will see that two other Members are named alongside you in the enclosed letter.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

With their letter dated 31 January, Mr Mann and Mr Jones sent me a copy of the Annual Report and Accounts of the Rutland and Melton Conservative Association for the year ended 31 December 2005. I enclose a copy for your convenience. Page 6 of these includes a section on the Patrons' Club, which indicates that the Club's 2005 Christmas Lunch was held at the House of Commons. The report continues: "The Patrons' Club provide a significant part of the income needed to finance our organisation …". Page 10 of the accounts show an overall income from fundraising in 2005 of £48,628.

Other material sent to me by the complainants indicates that your Association's Patrons' Club held another event at the House on 15 November 2006. You may also have seen the reference to the Club in the Sunday Times on 31 December 2006: I enclose a copy of the relevant article.

In the light of this material, the complaint which Mr Mann and Mr Jones make is, in essence, that your Association's Patrons' Club is a fundraising device for the Conservative Party. By offering events at the House in return for a membership fee, (the 'profit' on which goes to Party funds) and/or by charging directly for those events it is using the rooms in breach of paragraph 5.1, and probably also of paragraph 5.3, of the Banqueting Regulations.

I should be grateful if, in accordance with the procedures set out in the enclosed note, you will let me have your response to the complaint. It would be helpful if this could include information on:

1.  The membership, aims and activities of your Patrons' Club.

2.   How these activities are funded, including any subscription paid by members.

3.  How the Club raises any funds it donates to your local Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit).

5.  What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years.

If you would like a word about this matter, please do not hesitate to ring me on the number above. I am keen, in the interests of the House, to report reasonably speedily to the Committee on Standards and Privileges on all these related complaints if I can, and a reply by Monday, 19 February, when the House returns from the half-term recess, would therefore be helpful if at all possible.

I am copying this letter and enclosures to the House's Director of Catering Services, with whom I am in touch about these matters and whom I shall consult as necessary on your reply.

6 February 2007

23.  Letter to the Commissioner from Mr Alan Duncan, 19 February 2007

Thank you for your letter of 6th February about the Rutland & Melton Patrons' Club.

My association employs a fully-qualified professional agent who is responsible for all the political organisation in my constituency. In everything we do we endeavour to meet the highest standards, and pride ourselves in trying to be a model constituency in the way we behave. I firmly believe that the organisation of our Patrons' Club fully meets these standards.

To assist you in your investigations I asked my agent for all the information he can muster from the last few years, and I have included in full here with my own letter the report he has sent to me.

In essence, the Patrons' Club is a higher category of local party membership which secures a larger annual subscription from a group who happen to be willing both to pay a little more and who also want to engage, through social events, a bit more in politics.

What we say to them (and there is no promotional literature associated with the Club) is that in return for their annual fee of £250 they will enjoy party membership and in addition can, at no further charge, attend a summer champagne drinks party in the constituency, and a winter lunch in London, each with a guest speaker.

At no stage, nor in any way whatsoever, is there ever any mention or promise of a meal in, or visit to, the House of Commons. In the course of the last 10 or so years, I believe it is true to say that the majority of the lunches have been outside the Commons We are just as happy to go to the Army & Navy, the Carlton or the St Stephen's Club, and some members actually prefer the variety that stems from going to different places.

In the event additional guests attend the lunch, no profit is sought from the booking; the primary purpose of the lunch is so that Patrons can listen to a speaker; and in no respect whatsoever is it true to assert that we have offered anything to do with the House in return either for membership or for profit. At the last review of the Club's finances it was, if anything, marginally more expensive to dine in the Commons, and so it was more of a cost than a benefit for us.

The complainants assert that the Patrons' Club has contributed as much as £48,628 to my association's funds. I wish it were so! This figure, and similar such figures in any other year, are a total from all fund-raising activity in that year, and have no connection with the Patrons' Club. The income from the Patrons falls under the heading 'subscriptions', and the total annual contribution from the balance left after costs is about £7,000.

I feel very strongly that the conduct of my Patrons' Club both adheres to the rules of the House, and also appears to do so in all respects.

I hope this letter and the accompanying documents satisfactorily address all and any concerns. Please do not hesitate to contact me if I can clarify anything further.

19 February 2007

24.  Agent's report on Rutland and Melton Patrons' Club

Patrons' Club Report

Question 1

The Membership of the Patrons' Club as at 31 December 2006 is 69 paying an average membership of £155.14.

Aims and objectives:—to enable members to engage in political discussion at social occasions.

Question 2

Annual membership is currently £250 per person, £300 per couple.

This includes membership to the Party of £25 per person.

Also included are invitations to two social events during the year.

Summer Event—typically a Champagne Reception or Cocktail/Pimms Party at a private house in the constituency.

Autumn Event—Lunch in London including Champagne Reception, wine and three course meal with coffee. As you can see from my answer to Question 4 the House of Commons is sometimes used as a venue: however no promises are made to new or existing members that the House of Commons will be the preferred venue. Patrons may bring a limited number of guests to the lunches. Patrons are charged at cost for these guests; charge calculated on per capita basis and includes administration cost.

Question 3

At the summer event raffles and auctions may be organised and any monies raised are donated to the Association. Funds left after costs of membership, events and administration are absorbed into the Association.

Question 4

Autumn events organised by R&MCA Patrons' Club

Wed 15 November 2006  House of Commons  Guest Speaker  Jonathan Djanogly MP

Mon 28 November 2005  House of Commons  Guest Speaker  David Cameron MP

Fri 26 November 2004  Army & Navy Club  Guest speaker  Mark Field MP

Thu 6 November 2003  St Stephen's Club    Guest Speaker  Theresa May MP

Fri 22 November 2002  Carlton Club    Guest Speaker   Michael Brown

Mon 17 December 2001  House of Commons  Guest Speaker  Rt Hon David Davis MP

Tues 19 December 2000  House of Commons  Guest Speaker  Boris Johnson MP

Thu 2 December 1999  St Stephen's Club    Guest Speaker   Matthew Parris

Question 5

The Patrons' Club, as with the Association's 200 Club and Women's Lunch Club, is fully integrated into the Association (see membership report attached) and all administration is undertaken by the constituency office and its staff. All subscription collection and events are administered by association staff.

Income from the Patrons' Club's Subscriptions is reported in the Annual Accounts as a gross figure as with all membership. However common sense tells you that if you take the average subscription from the attached report of £155.14 per member and then deduct membership to the Party £25 (formally £15) along with the cost of the Autumn Champagne Reception and lunch as well as the cost of the Summer Cocktail/Pimms/Champagne Party, there are little funds available for administration.

Patrons' Club's real benefit to the Association is by way of Raffles, Fighting funds and specific appeals.

25.  Letter to Mr Michael Gove from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This includes:

1.  a copy of some pages from the Surrey Heath Conservatives web-site, which include at the end a reference to 'Strangers Gallery', a Parliamentary Luncheon Club which holds "luncheon meetings four times a year at the House of Commons and an annual dinner."

2.  your entry in the Register of Members' Interests showing that "Contributions to Surrey Heath Conservative Association are received from: Strangers Gallery Lunch Club."

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that Strangers Gallery Lunch Club is a means of raising funds for your constituency association and that it is improperly using Parliamentary dining facilities for this purpose, in so far as paragraph 5.1 of the Banqueting Regulations provides that the House's private dining rooms (and, by implication, its other dining facilities) should not be used for "direct financial or material gain by a. . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

26.  Letter to the Commissioner from Mr Michael Gove, 4 January 2007

Thank you very much for your letter of the 7th very kindly informing me of the complaint which has been made by John Mann MP and Kevan Jones MP. I am grateful to you for the trouble you have taken to provide me with the fullest possible background and guidance.

You were kind enough to indicate that "the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that Strangers Gallery Lunch Club is a means of raising funds for your constituency association and that it is improperly using Parliamentary dining facilities for this purpose, in so far as paragraph 5.1 of the Banqueting Regulations provides that the House's private dining rooms should not be used for 'Direct financial or material gain by a … political party'."

Let me try to deal with each of the questions raised.

HISTORY OF THE CLUB

By way of background, I should explain that Strangers Gallery has been in existence as an executive lunch club for business and professional men and women who work or reside in the Surrey Heath area since 1974, when Surrey Heath Borough Council came into existence. It provides a networking facility for local business people and one of its principal functions is the opportunity it provides for discussion on matters of shared interest.

As I am sure you are aware, Surrey Heath Conservative Association had a spotlight shone on its activities following the decision to deselect my predecessor in 2004. During, and after, that period no suggestion was made that there was anything untoward about Strangers Gallery.

Given the Club's existence for over 30 years, its regular pattern of operations over that time, the fact that no-one troubled to complain beforehand, and the fact that no complaint was made about the Club, even during a time when there was detailed media and political scrutiny of the Association—all this inclined me to believe, as a new Member, that the Club was a highly respected organisation in good standing with the Commons authorities.

THE CLUB'S OPERATIONS—IS WESTMINSTER DINING AN INDUCEMENT TO JOIN?

The Club has played a valuable role in keeping me as a Member of Parliament, and my predecessors, informed about the views and concerns of my constituents and those who employ them. To make it easier for me to stay regularly in touch, the Club meets four times a year in Westminster, on a weekday, for lunch. Given the constraints on my timetable, and theirs, a lunch meeting in Westminster during the week is the most time-efficient way of keeping in touch.

It should be noted, however, that the Club organises a range of events outside Westminster to allow members to socialise and network. Events have included a trip to Leeds Castle, a boat trip down the Thames and a dinner on HMS Belfast. The Club also organises regular informal dinners in the homes of Committee members which create a further opportunity for networking.

Club members also enjoy first refusal for tickets to major SHCA events such as our Summer and Winter Balls, Burns Supper and other major speaker meetings.

It is, I believe, un-knowable to what extent the fact that when I meet with Club members it is in Westminster acts as an incentive to join.

To my mind there are other factors which are the prime motivating reasons in persuading members to become involved—the chance to network with other members, the chance to meet their Member of Parliament, the chance to hear entertaining and informative speakers and the opportunity to enjoy a wide range of social occasions with like-minded people.

Dining in Westminster certainly suits my busy diary, and very often it suits the guest speaker, but I have no doubt that another congenial central London location with high standards of service and cuisine would be equally attractive to the membership. The only losers would be me, in terms of time lost in travel which I could devote to my other parliamentary duties, and the House's Catering Department which would lose valuable custom.

DIRECT FUND-RAISING?

Monies raised at events in the constituency organised by Strangers Gallery members do contribute to party funds. But the Club is not run in such a way as to maximise the amount of money which could be raised for the party. It is run to provide members with a congenial social forum. The Club is allowed, by the terms of its founding constitution, to have up to 100 members, but it currently has just 74. That is a consequence of decisions taken by the Committee who wish to preserve the Club on terms which suit their interests. Needless to say, if the Club were being run primarily as a Conservative Party fund-raising exercise, a much more pro-active approach would have been taken to growing membership and gathering in funds.

The lunches which take place in the House of Commons are priced in such a way as to barely cover the costs of all those involved. Each lunch—including wine and three courses—costs £55. Club accounts show that the regular operating surplus on each lunch is between £5 and £8 head. The last lunch had 58 people dining and made an operating surplus of just £404. Organising each lunch is a major administrative task for the Club Secretary, who operates from his own accountancy practice, not from any Conservative premises. The operating surplus from each lunch, at around £400, barely covers the effective cost of the time he commits to each event.

It would appear to me, on that basis, that these lunches do not constitute the use of Commons facilities for "direct financial or material gain" by a political party. No fund-raising activity takes place during lunches. And given the net worth of many of the individuals present, the decision to charge only slightly above cost reflects a commitment to respect the rules of the House.

4 January 2007

27.  Letter to Rt Hon John Gummer from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from the above two Members relating to your Westminster Club and its alleged use of House of Commons dining facilities for fundraising purposes.

The complaint is part of a wider series of complaints of a similar nature which I have received from Mr Jones and Mr Mann against a number of Conservative Members. You will see that two other Members are named alongside you in the enclosed letter.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

With their letter dated 31 January, Mr Mann and Mr Jones sent me a copy of the Annual Report and Accounts of the Suffolk Coastal Conservative Association for the year ended 31 December 2005. I enclose a copy for your ease of reference. On page 3 of the report, there is a reference to a Westminster Club as one of the money-raising activities of the Association. Page 5 reports total income from fundraising in 2005 of £19,486. Information supplied separately to me by the complainants indicates that your Association's Westminster Club held an event at the House on 6 November 2006.

In the light of this material, the complaint which Mr Mann and Mr Jones make is, in essence, that your Association's Westminster Club is a fundraising device for the Conservative Party. By offering events at the House in return for a membership fee, (the 'profit' on which goes to Party funds) and/or by charging directly for those events it is using the rooms in breach of paragraph 5.1, and probably also of paragraph 5.3, of the Banqueting Regulations.

I should be grateful if, in accordance with the procedures set out in the enclosed note, you will let me have your response to the complaint. It would be helpful if this could include information on:

1.  The membership, aims and activities of your Westminster Club.

2.   How these activities are funded, including any subscription paid by members.

3.  How the Club raises any funds it donates to your local Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit).

5.  What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years.

If you would like a word about this matter, please do not hesitate to ring me on the number above. I am keen, in the interests of the House, to report reasonably speedily to the Committee on Standards and Privileges on all these related complaints if I can, and a reply by Monday, 19 February, when the House returns from the half-term recess, would therefore be helpful if at all possible.

I am copying this letter and enclosures to the House's Director of Catering Services, with whom I am in touch about these matters and whom I shall consult as necessary on your reply.

6 February 2007

28.  Letter to the Commissioner from Rt Hon John Gummer, 19 February 2007

Thank you very much for your letter. Clearly I needed to get the information required from the Chairman of the Suffolk Coastal Conservative Association as I have nothing to do with the financial arrangements of the Association and, indeed, it would be severely frowned on were I to attempt any such thing. He has written back to me with the enclosed letter, detailing the circumstances of the Westminster Club. You will see that the reason for holding these meetings in the House of Commons is primarily because of the ability to attract notable speakers, who are clearly more able to attend when the event does not require any travel.

You will see that the new Honorary Treasurer of the Association changed the format in which the accounts were presented and put all incoming money, including my own payment for office facilities and services under "Fund-raising". Clearly this was not a suitable appellation for the items included and in future he will present the accounts in a way which is less liable to misinterpretation. This problem would not have occurred if the Registered Treasurer of the Association had not been incapacitated for much of last year when the accounts were being prepared.

I have to say that it had never occurred to me that anyone might believe that there might be something improper at a political club holding a lunch in the House of Commons. Even now one would have to say that it would be odd if such a lunch were available for members of organisations in my constituency, for whom I am always happy to sponsor such an occasion, but not specifically to those who have an interest in politics. There has therefore never been an intention either by me or by my Association, to do other than obey the rules of the House.

There is a difficulty that arises from budgeting to ensure that a loss is not made at such lunches and if your view is that it would be better were we to offer to return any money over and above the sums required for the lunches at the end of the year, I am sure that offer could certainly be made. I am anxious that we should offend neither the spirit nor the letter of the law, but at the same time clearly I would not like to lose the real advantage of enabling people to meet senior politicians and to exchange views with them.

I ought also to say that, to my knowledge, I have never refused to sponsor a function in the House of Commons for any of my constituents, irrespective of their party political allegiance or interests and that continues to be true.

If I can be of any further assistance, please let me know.

I am told that the figures I include have had to be extracted from the records as the breakdown has not hitherto been made. I fear that there are no similar breakdowns for earlier years. Obviously—if you wanted—I could ask for some attempt to be made to make similar figures available for previous years. They would be likely to show smaller surpluses and would take some time to obtain. Nevertheless, if you need them, I shall ask for someone to try to abstract them in this form.

19 February 2007

29.  Note by the Chairman of the Suffolk Coastal Conservative Association

You have asked for clarification of the role of our Westminster Club following an enquiry from the Office of the Parliamentary Commissioner for Standards.

The Westminster Club was created and exists to connect with Suffolk's Business and Professional Communities, for the benefit of all parties involved. It has a diverse membership which includes farmers, estate agents, motor dealers, local manufacturers and retailers, and those involved in tourism. It provides an opportunity to hear the views, question and debate key issues with senior members of the Party, and sometimes with local notables whose position is wholly apolitical.

The Club has its own Chairman who is not a member of the Association's Executive, and its own Officers. A lot of work goes into organising the three events and this is effected by the Secretary hiring the necessary support from the Woodbridge office. Those who join are automatically made a Member of the Conservative Association and a subscription of £15—the minimum figure required by the Party Organisation—is taken.

Three events are held each year—one Breakfast Meeting at a hotel in Suffolk to discuss local matters—often with a non-party political speaker—and two in London, currently at the House of Commons, where national and international issues are discussed. It would be totally inappropriate for any money raising activity to take place at these events.

The Palace of Westminster has been used as it provides ready access to the top speakers. As with all our events, it is clear that it is the speaker and not the location that generates the demand for places and additional guests. Given the growing popularity of the Club, due to the quality and relevance of the speakers—David Cameron, William Hague, George Osborne—we are having to consider returning to other nearby venues which can accommodate a larger attendance than that available at the Palace of Westminster.

Our membership numbers over the past five years are:

2002

15 Full Members

1 Part Year Member

7 Guests

2003

17 Full Members

2 Part Year Members

15 Guests

2004

25 Full Members

5 Part Year Members

11 Guests

2005

27 Full Members

2 Part Year Members

35 Guests

When establishing the annual subscription (which covers all costs for the year) we have to take account of a number of variables outside our control, notably the demand for membership, the number of guests, the number of "no shows" by members and guests at the three events and the level of imbibing! There are of course meals at events which are paid for but not taken and, if we have adequate notice, these may not have to be paid for by us. Details are shown on the attached sheets. Needless to say, we budget to break even.

Up to 2005, any surplus was rightfully identified as "Donation from Association Bodies" along with the sums received from the MP for support and services rendered by the Association's office here.

A re-examination of the 2005 accounts prompted by this enquiry reveals however that the new Honorary Treasurer made a number of changes and incorrect allocations of which fund raising was one. This is confirmed by the marked difference between Donations and Fundraising in 2004 and 2005.

As you will see from the two financial statements enclosed, there was a surplus of £502 in 2005, up from previous years, largely because of David Cameron's attendance in November 2005 during the leadership race, which realised a sell out. This was a lucky break for us as we could not predict this when planning our events far in advance. I fear that we have no detailed accounts for those earlier years.

Money raising may be difficult but I can assure you that there are many easier ways of generating funds than by operating a separate club within this organisation but our Westminster Club is highly valued by both the business and professional communities locally, this Association, and those Members of Parliament who address these meetings, in fulfilling the objective set out previously.

Please let me know if any more information is required.

30.  Letter to Mr Charles Hendry from the Commissioner, 31 January 2007

Further to our telephone conversation earlier today, I enclose a copy of the letter I have received from the above 2 Members dated 30 January (my e-mail of today to you also refers).

When I spoke to Mr Jones this morning, he referred me to a list of events in the House in October and November 2006, a copy of which I also enclose. You will see that this includes reference to a dinner which you are said to have hosted at the House on 29 November 2006 for the "Sir Winston Churchill 50 Dining Club".

An earlier version of this list was included in the material which Mr Mann and Mr Jones sent me with their original complaint about dining clubs on 23 November last year. However, the last entry on the version I received then was dated 15 November and so the entry relating to you was not included in the material I received at that point. Nor had I, indeed, seen the enclosed version of the list until this morning.

In view of the letter Mr Mann and Mr Jones have now sent me, I feel obliged to put their complaint to you in order that you may have the opportunity to respond to it. As I understand it, the allegation they are making is in essence, that the "Sir Winston Churchill 50 Dining Club" is a fund raising device for the Conservative Party akin to the Patrons' Clubs to be found in other constituencies. These Clubs typically offer their members the opportunity to dine at the House (as well as other social events) in return for an inflated annual membership subscription. The surplus of the funds raised is paid out to the Conservative Party. Mr Mann and Mr Jones argue that the use of the House's dining facilities in this way is contrary to:

I should welcome your response to this complaint, in accordance with the procedure set out in the enclosed note. It will be helpful if this includes information on:

1.  the nature, objectives and membership of the Club

2.  its funding

3.  in particular, how the dinner at the House on 29 November was funded, and

4.  whether the Club has made donations to your constituency association and, if so, of how much and when.

I hope this makes the position clear but if you are left with any queries, please do not hesitate to ring me on the number above.

I look forward to receiving your reply.

31 January 2007

31.  Letter to the Commissioner from Mr Charles Hendry, 9 March 2007

Thank you for your letter regarding the dinner I hosted in Dining Room A for the Sir Winston Churchill Fifty Dining Club on 29 November.

The Club has no links whatsoever either to me or to my constituency association. I understand it was founded in the 1960s for people living or working in, or having an interest in, the Parliamentary constituencies of Brighton Kemptown, Brighton Pavilion and Hove. It is limited to 50 members, who are not necessarily members of a political Party, who pay a joining fee of £100 and an annual membership of £200.

The Club is administered by Hove Conservative Association. Members receive three dinners a year, usually held in the House of Commons, with a Conservative spokesman as the guest speaker. The costs of these dinners are covered by the members' annual subscription. Additional guests can be invited at a cost of £45/head. There is no fund-raising at the dinners nor does the Club take part in more general fund-raising activities although it has made occasional donations to the Conservative Party where surplus funds have made this possible.

The dinners are hosted in Westminster/near Westminster for the convenience of the guest speaker and to ensure that the speaker would not need to cancel because of parliamentary business. My impression is that the guests attend to hear the speaker rather than because the dinner is in the House of Commons.

As there is currently no Conservative MP in Hove, neighbouring MPs have been asked to host the dinners and I was asked to host the one which took place on 29 November. It is the first such dinner I have been asked to host and I derived no financial or other benefit either for myself or for my own constituency association.

With regard to the specific complaint:

The Club made the room booking through my office and they secured the Guest Speaker themselves.

I understand that the membership fee covers the full costs of the meal, together with the wine, pre-meal drinks, dinner menu, associated printing and administrative costs, as well as the meal costs of the Guest Speaker.

I understand that the list of benefits of membership does refer to the dinners being held in Westminster. Given the name of the club and its purpose—giving Brighton & Hove-based businesses the chance to network with each other and with senior Conservative Party spokesmen—the listing of the event at Westminster is intended to be factual and is not intended as an undue inducement. Indeed, not to mention the dinner at Westminster would seem perverse.

I hope this enables you to complete your investigation and I hope this helps to reassure you about this particular one-off event. For the sake of completeness, I should add that my own constituency Patrons' Club does not use House of Commons facilities.

9 March 2007

32.  Further letter to the Commissioner from Mr Charles Hendry, 9 March 2007

I am attaching my formal reply to your letter regarding the complaint which has been made against me by Kevan Jones MP and John Mann MP.

In addition to your investigation into this issue, I would also be grateful if you would look into the way this complaint has been handled and to clarify the guidelines on the appropriate way for such things to be done.

As you will be aware, I was notified of this complaint by a journalist from the Brighton Argus. I told him that I was not aware of a complaint being made and had not been notified as such either by the two MPs involved or by yourself. Nevertheless, this led to two damaging stories in the local papers, one under the headline: 'MP is under investigation'. As you will recall, I then contacted you and you advised me that no such complaint had been received.

I relayed this to the journalist who then contacted Kevan Jones, who informed him that my name had not been included in the initial complaint, but that he would now lodge a complaint about the dinner I hosted in November.

On legal advice, I have written to the paper to say that the articles they wrote were clearly libellous, as no such complaint had been made, but we have decided to wait until the completion of your investigation before taking matters forward. They fully recognise the inaccuracy of the story.

I would be grateful if you could express an opinion on whether this is an acceptable way for Members to behave—to notify the press of a complaint before they have had the courtesy of advising the Member concerned or before even making a complaint to your office? Surely Members should hear from you first, before hearing from the media?

Perhaps it might be a useful opportunity to remind all colleagues of appropriate procedure in making a complaint?

The local newspapers are concerned to correct what they accept was a seriously incorrect story, but should it result in legal action, then it would lead to the very unfortunate situation of another Member having to be named in that action. Had proper procedures been followed, that situation would not have arisen.

I am copying this letter to Kevan Jones, John Mann, Sir George Young, Patrick McLoughlin and Tommy McAvoy.

9 March 2007

33.  Letter to Mr Charles Hendry from the Commissioner, 12 March 2007

Thank you for your two letters of 9 March.

First, may I acknowledge your letter in formal reply to this complaint? In accordance with the procedures set out in the note I sent you on 31 January, I will let you have shortly the draft of the factual sections of my report relating to the complaint against you. I shall be grateful if you will let me have any comments on this as soon as possible, so that I may complete the report and submit it for the Committee on Standards and Privileges to consider.

Secondly, in your letter covering your formal reply, you ask me to look into the way the complaint by Mr Mann and Mr Jones has been handled and to clarify the guidelines on the appropriate way for such things to be done. You particularly have in mind the failure of Mr Mann and Mr Jones to inform you or me that they had made the complaint against you before they informed the press of it.

The House's expectations on this matter are very clear. Paragraph 85 of the Guide to the Rules relating to the Conduct of Members says:

"It is a basic courtesy that a Member making a complaint to the Commissioner should at the same time send a copy of the letter of complaint to the Member concerned."

It is, of course, implicit in this that the Member complaining will inform me at the same time as telling the Member concerned, and before informing any third party.

I set out in my letter to you of 31 January what I know of the circumstances surrounding the communication to you and to me of the complaint against you. Only Mr Jones and Mr Mann can provide an explanation from their point of view.

I shall, as you request, draw this aspect of the matter to the attention of the Committee when submitting my report on the linked series of complaints by Mr Mann and Mr Jones. It will be for the Committee to decide, but it may well be that it will wish to reiterate the importance of Members complying with the House's expectations on this point when it in turn reports to the House on these complaints.

I am copying this letter to the recipients of yours.

12 March 2007

34.  Letter to the Commissioner from Mr John Mann and Mr Kevan Jones, 14 March 2007

Thank you for your letter of 12th March enclosing your letter to Charles Hendry.

We are pleased to be able to confirm what was explained on the telephone on the morning of 30th January: that we had always believed that Charles Hendry's name had been included in the dossier of evidence submitted to you before Christmas 2006.

That is why when a journalist from the Brighton Argus contacted the office of Kevan Jones in January the office stated that Charles Hendry's name was amongst those submitted to you.

It was always our intention that Charles Hendry's dinner be investigated; that is why when it became apparent that you did not have this information we submitted it to you in the letter of 30th January. In addition, we enclose copies of his constituency accounts which detail the income received from the Patrons' Club as well as a Patrons' Club event that was hosted by Lord Saatchi at the House of Lords.

14 March 2007

35.  Letter to Mr John Mann and Mr Kevan Jones from the Commissioner, 15 March 2007

Thank you for your letter of 14 March responding to mine of 12 March. I have noted your explanation of the circumstances in which you did not inform Mr Hendry in advance of your complaint against him and I will include a summary of the position in my report.

Thank you also for the copies of Mr Hendry's constituency accounts you sent me. I note that in 2004 his Association's Patrons' Club held a dinner addressed by Lord Saatchi in the House of Lords but as you know I do not have jurisdiction in respect of the Upper House. Mr Hendry has separately informed me that his constituency Patrons' Club does not use House of Commons facilities.

I will let you know when I have submitted my report to the Committee on Standards and Privileges.

15 March 2007

36.  E-mail containing sample letter of invitation to prospective members of the Fareham Patrons' Club

I am writing to you as President of the Fareham Patrons' Club, an informal group that supports my work and that of the Fareham Conservative Association.

The Club holds two dinners in the House of Commons twice a year as well as a reception in the constituency. At our dinners in London, the aim is to provide the opportunity for people to listen to a keynote speaker as well as have a convivial dinner in pleasant surroundings. The reception in Fareham is a more informal event, giving members the opportunity to meet each other as well as introducing potential new members to the Club.

Our next dinner is on Monday 10th June at the House of Commons, when the speaker will be Damian Green MP, the Shadow Secretary of State for Education, who is a rising star in the Shadow Cabinet. He is one of the best speakers in the House, with a powerful combination of wit and incisiveness. The second dinner will be held on 5th November and details of the speaker will be confirmed nearer the time. The membership fee for this year is £225, which includes the cost of one dinner for yourself and a guest. The second dinner and any further guest tickets cost £35 to include wine and a three-course dinner.

The Club plays a very important role in sustaining the work of the Association and ensuring that we elect Conservatives to represent us at all levels from the European Parliament to the Borough Council and I hope that you will consider joining. I know from my own experience that it is a very enjoyable and sociable group of people.

If you would like to join, then perhaps you could write to me at the above address enclosing a cheque for £225 and enclosing details of your guest for the dinner on 10th June. If you have any questions please do not hesitate to contact me in London on 020 7219 8228.

I look forward to seeing you on 10 June 2002

37.  Letter to Mr Mark Hoban from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a photocopy of what appears to be an e-mail from your assistant [name withheld] to Stewart Jackson MP forwarding a sample letter of invitation to join the Fareham Patrons' Club. The letter indicates that the fee for joining the Club is £225, and that the Club holds two dinners a year in the House of Commons, the cost of one of which (for 2 people) is included in or met from the membership fee.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that you have breached the Banqueting Regulations in that:

1.  your Patrons' Club charges a fee in excess of the actual cost arising from the events it organises, including the actual cost of dinner at the House

2.  the profit so raised goes into the funds of your constituency association or otherwise to benefit the Conservative Party

3.  this constitutes a breach of paragraph 5.1 of the Regulations in so far as the private dining rooms (and other dining facilities at the House) are not to be used for "direct financial or material gain by a… political party."

4.  you have also breached paragraph 5.3 which provides that the rooms "may not be used as an inducement to recruit new members of outside organisations or non-parliamentary associations".

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

38.  Letter to the Commissioner from Mr Mark Hoban, 19 December 2006

Thank you for your letter of 7 December regarding the complaint made against me by Kevan Jones MP and John Mann MP based on an e-mail sent to Stewart Jackson MP by his assistant, [Ms A]. Can I start by apologising for the length of this response as the issues that have been raised are not straightforward and nor is the history of the Fareham Patrons Club and its operations.

You ought to be aware that Stewart Jackson MP has made a formal complaint to the Sergeant at Arms about the method by which the e-mail was acquired by the complainants. I have enclosed a copy of Stewart's complaint for your information.

For clarity, I would also point out that [Ms A] was my PA at the time the letter was drafted in May 2002, shortly after I was first elected. [Ms A] started work for Stewart after the 2005 General Election and it appears that [she] retained a copy of the draft letter following the termination of her employment with me.

Introduction

The Fareham Patrons Club was established by my predecessor, Sir Peter Lloyd, and I inherited it and its organisation from him when I was elected in 2001. The Club is based on the boundaries of the Fareham Constituency up until the 1997 General Election and covers both the current Fareham constituency and that part of the Winchester constituency known as the Meon Valley.

I am the President of the Club, but the day to day running of the Club is undertaken by its chairman and treasurer with administrative assistance from the Fareham Conservative Association office. All monies are paid directly to the Club, which has its own bank account and is separate from the Fareham and Winchester Conservative Associations. Notwithstanding the over-simplification in the draft letter, the chairman and treasurer of the Club decide whether to make any donations from Club funds and I understand that this has always been the case.

From my own perspective, the Club provides a forum for its members to meet, listen and talk to senior politicians. It supports me in my work by enabling me to understand the views of Club members and their reactions to political developments at local and national level. The reaction of members to Party policy helps shape my views and enable me to provide feedback to the Party.

Its dinners are held at the House of Commons, primarily for my convenience and that of the speaker. A dinner outside the House is less attractive to me and colleagues because divisions could disrupt the evening if there was a running whip. We also hold a summer reception in the constituency too, so the Club's activities go beyond Westminster.

As I understand it the complaint against me, as you have explained it, is that my use of the dining room might be in breach of Section 5, paragraphs 5.1, 5.3, and 5.5 of the Banqueting Regulations. I am grateful for your clarification as the letter sent to me by the complainants makes no attempt to explain why I might be in breach of the rules of the House, which I find surprising given the seriousness of the allegations made.

Paragraph 5.1

I receive no direct financial or material gain from the Club and nor does the Conservative Party as the Club maintains its own bank account and makes its own decisions about donations.

The Club's costs include the actual cost of the meals, including the speaker's meal, menu cards, place cards and the administrative costs of the Club. There has been, in the past, a subsidy paid out of the membership fee to cover the cost of additional meals as the amount charged for the second dinner and subsequent guests was insufficient to cover the full cost of the meal. The chairman of the Club has funded the summer reception in recent years and if he chose not to do so in the future then this cost would have to be met from the membership subscription. The extent to which the Club's income exceeds its costs is likely to be modest and variable. Where this is the case and the Club has sufficient cash to meet its immediate needs, then the Club's chairman and treasurer can make a donation to the Fareham and Winchester Conservative Associations.

Paragraph 5.3

I do not believe that the private dining rooms are being used as an inducement to recruit new members. In the draft letter, there is only one reference to the dining rooms, when I describe them as "pleasant surroundings". Indeed, I would argue that there is greater emphasis in that letter on the political element of the Club than on the dining rooms. As I look at the letter again four years later, it is still my assessment that the Club performs, primarily, a political function, informing members of Party policy and helping me to gauge reaction to it. Of course, there is also the summer reception held in Fareham as a further benefit of membership.

Paragraph 5.5

As I have already mentioned, I believe that these events are predominantly political functions, for example, every dinner since I was elected was addressed by a politician and political events are not prohibited by the rules.

Conclusion

It is clear from the complaint made by John Mann MP and Kevan Jones MP and my response to it that Members have differing interpretations of the Banqueting Regulations, particularly 5.1. It would be in the interests of all Members and those organisations whose events they sponsor for the rules to be clear, so that no Member can be the subject again of what might appear to be a speculative complaint.

It would be helpful too if some thought was given to the objectives of the Banqueting Department. It must be in the economic interests of the House as a whole for these facilities to be well used. Any changes in rules which lead to a reduction in occupancy will mean that the fixed cost of the facilities will be recovered from fewer events thus forcing the prices up and further reducing the attractiveness of the dining rooms to Members. The impact of any clarification of the Banqueting Regulations on the economics of the department should be carefully considered.

I hope that this clarifies the basis on which the Fareham Patrons Club operates and why I believe I have not contravened paragraphs 5.1, 5.3 and 5.5 of the Banqueting Regulations.

I am, of course, happy to discuss this with you further and furnish you with any other information that you might need.

19 December 2006

39.  Letter to Mr Mark Hoban from the Commissioner, 21 December 2006

Thank you for your letter of 19 December in reply to mine of 7 December about this complaint.

You mention that Stewart Jackson MP has made a formal complaint to the Serjeant at Arms about the method by which Messrs Jones and Mann obtained a copy of Ms [A] e-mail to Mr Jackson of 22 March 2006. I understand that the Serjeant is taking steps to investigate this matter.

As regards the complaint by Messrs Jones and Mann against you, I am grateful for the explanation you have given in response to the complaint. As I mentioned in my earlier letter, I am in touch with the House's Director of Catering Services and the Clerk to the Administration Committee about it. I plan to meet them early in the new year to obtain their advice on the issues raised. I will be in touch with you again after the House returns in January, when I have been able to reflect on the issues in the light of their advice, to let you know how I intend to proceed.

For the present there was just one point in your recent letter which I did not fully follow. In the fifth paragraph on page 2 you say "The extent to which the Club's income exceeds its costs is likely to be modest and variable." If the membership fee for the Club in 2002 was £225 and the only costs per member accruing were 2 dinners in the House (at say £45-50 per head) plus some modest subsidy of the charge for a second dinner (say £15) plus the administrative costs of running the Club (say, a further £15), this would leave a proportionately sizable sum in surplus. I should be grateful if you could explain how you would see the calculation I have just set out (is it reasonable or are there other costs I have overlooked?). I should also be grateful if you would let me know how much, in each of the last 5 years (ie since 2001) your Patrons' Club has contributed to your constituency association, Fighting Fund or other Conservative party funds.

I look forward to hearing from you on these points.

21 December 2006

40.  Letter to the Commissioner from Mr Mark Hoban, 24 January 2007

Thank you for your letters of 21st December and 22nd January and I am now in a position to give the further information you requested in your letter of 21st December.

You asked for a breakdown of the cost of the Patron's Club for 2002.

The fee charged that year was £225.

As you will recollect the subscription includes two free dinners and an additional charge is made for the second dinner. In practice, members are accompanied by their spouses at both dinners and, therefore, pay for two second dinners and any shortfall is borne by the club.

The cost of the first dinner was £97 per member.

The subsidy for the second dinner was £20 per member.

The secretarial and other administration costs that year were £25 per member.

You will recollect that there is a summer reception in the constituency and the Chairman of the Patrons Club generously donates the cost of the food and wine. If he were not to do so, we would incur an additional cost of, say, £20 per member.

The surplus was, therefore, £83 per member or £63 allowing for the notional cost of the summer reception.

For convenience, I have calculated these sums based on the number of members that year. It is the case that in some years not all members have attended the dinners.

You also asked how much was donated to the Fareham Conservative Association since 2001.

2001—£900

2002—£700

2003—£1000

2004—£1000

2005—£900

2006— £900

It donated the following sums to the Winchester Conservative Association (in 2006 the donation was made to the Meon Valley Conservative Association).

2001—£900

2002—£700

2003—£500

2004—£500

2005—£600

2006—£750

No other donations were made to the Conservative Party.

I very much share your view that there should be a prompt resolution to this matter and I look forward to receiving a draft of the factual content of your report as it relates to the Fareham Patrons Club.

24 January 2007

41.  Letter to Mr John Horam from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a list of events held recently in the House of Commons which includes one on 1 November marked as a Terrace Club Luncheon, which you are said to have hosted.

Based on this and the other material I have enclosed, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the Terrace Club is a fund-raising device for the Conservative Party; and that in hosting its lunch on 1 November you breached paragraph 5.1 of the Banqueting Regulations, which says that the House's private dining rooms (and, by implication, its other catering facilities) may not be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

42.  Letter to the Commissioner from Mr John Horam, 21 December 2006

Thank you for your letter of 7 December.

The Terrace Club was founded as a social and political club for women in the Bromley area, with the assistance of one of my predecessors. My role is to book a room and invite a speaker when they have lunches in the House of Commons.

I have no involvement in, or knowledge of, the club's finances and I make no direct financial and material gain from my role.

I trust this answers the questions which have been raised.

21 December 2006

43.  Letter to the Commissioner from Mr John Horam, 11 January 2007

Thank you for your letter of the 5th January. The Secretary of the Terrace Club is Mrs [B]. I am sure she will provide you with the information about the Terrace Club that you are seeking.

The Terrace Club did make a donation to my constituency association prior to the last general election, but my understanding is that this comes from money raised by the Terrace Club from the lunches they hold in members' homes. In the case of the House of Commons lunches they simply cover costs.

11 January 2007

44.  Letter to the Commissioner from the Chairman of the Terrace Club, 24 January 2007

Thank you for your letter of 16th January 2007 addressed to Mrs [B] which has been passed to me as chairman to reply to on behalf of the Terrace Club.

The Terrace Club was founded in October 1967 as a "ginger group". In those days it was felt that women's views were largely ignored by politicians who were mostly male. John Hunt, the then Member of Parliament for Bromley, helped set up the Club and the inaugural luncheon was held at The House of Commons on 18th December 1967 and was sponsored by Mr Hunt. We were not founded to raise money for the Conservative Party but it was agreed that if any profit was made it would be distributed at General Elections to aid marginal constituencies in the London South East Region. We are not affiliated to any association and our funds, if any, are donated to needy constituencies by agreement of the committee.

Over the last forty years we have been lucky and privileged enough to visit The House of Commons at least once a year and have held either Luncheons or Dinners in Dining Room A. We are a group of ladies aged between 55 and 85 who have a great interest in politics at both local and national level and do of course enjoy being able to visit the "seat of power" of our country. At these functions our sponsor organises another Member of Parliament to address the club. At all other functions we organise the speakers ourselves and they may or may not be political.

Our members pay an annual subscription and from this the Club subsidises one Luncheon a year. The cost of functions is collected from members in advance of the event. The luncheon held on 1st November 2006 which is the subject of the Labour Members' complaint was indeed the luncheon for this season subsidised from the subscriptions. Members attending settled their own accounts for drinks in cash. It should also be noted that not all members attended this event. As the cost of dining at the House is so great we do not make any profit from luncheons there and only aim to cover our costs. We hold a number of functions during the Club's year and do raise monies from all but the House of Commons Luncheons.

Membership of the Terrace Club is by invitation and new members are proposed and seconded by current members. Our membership is drawn mainly from the three constituencies in the London Borough of Bromley. New members are not promised luncheons at The House of Commons but as we have been in existence for forty years it is well known that we try to include a visit to The House in our programme of events. We are a successful club and over the past five years have donated £15,521.00 to marginal constituencies in the London South East Region.

Mr John Horam has been our sponsor for House of Commons Luncheons since 1998 after Sir John Hunt retired from Parliament. He has no knowledge of our financial position and has no input into how we donate our funds at election time. We are amazed that his connection to The Terrace Club is being subjected to such a complaint and trust that this information will enable you to close the case against him.

If I can be of any further assistance do not hesitate to contact me.

24 January 2007

45.  Letter to Rt Hon Michael Howard from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of a page from the Conservative Party web-site indicating that you addressed a luncheon held at the House of Commons on 2 November 2006 by Nottingham City Conservatives Business Club, for which tickets were priced at £62. It is not clear from the enclosure, however, whether you hosted the event (and if not, who did) or simply addressed it.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that Nottingham City Conservatives Business Club is a fund-raising device for Nottingham South Conservatives; that the price charged for the event did more than cover the cost involved; and that the provision in paragraph 5(1) of the Banqueting Regulations which says that the House's private dining rooms (and by implication, the House's other dining facilities) may not be used for "direct financial or material gain by a . . .political party" has therefore been breached.

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

46.  Letter to the Commissioner from Rt Hon Michael Howard, 14 December 2006

Thank you for your letter of 7 December.

I consider the complaint from Mr Mann and Mr Jones to be thoroughly misconceived.

So far as the luncheon held in the House of Commons on 2 November 2006, my sole involvement was as the guest speaker at the lunch. I did not host the event nor was I in any way aware of the price of the tickets or any of the arrangements for the event.

In any event, however, I believe the complaint is based on a misinterpretation of the relevant paragraph of the rules relating to the use of private dining rooms at the House to which you refer in your letter.

As I am sure you will have noted, paragraph 5.1, 'prohibits the use of the private dining rooms for direct financial or material gain by a sponsor, political party, or any other person or outside organisation'.

In my view this prohibits the making available of such a room by a Member in direct exchange for money or some other material gain. It does not prohibit political events in the dining room. Similar considerations apply to the interpretation of paragraph 5.3.

In my experience, the attraction, if any, of events such as the lunch to which reference is made in your letter lies in the opportunity to listen to a prominent speaker on events of the day. If that speaker is a Member of Parliament it will frequently be more convenient for him or her to attend if the event is held in the House of Commons. In my view the venue is not normally a material consideration in attracting people to the event.

I would, of course, be more than happy to discuss the matter with you.

14 December 2006

47.  Letter to the Commissioner from Mr Richard Ottaway, 16 January 2007

City of Nottingham Conservatives Business Club Lunch

Thank you for your letter of 19th January. It is not clear whether there is a complaint against myself or indeed what it is. However I am happy to co-operate.

As I understand the complaint it is that the private dining rooms of the House have been used to raise funds for the Conservative Party. This raises two questions. The first is whether they can be used for party political purposes. The second is that, in the event they are, can they be used for fund raising.

The rules and regulations governing the use of private dining rooms are silent on the first point. This is unsurprising. After all, what are these dining rooms for if political debate in them is prohibited? This is the 'Mother of Parliaments' and political debate is central to its activity.

The rules are far from clear on the second point. I agree with the view of Michael Howard in his letter of 15th December, that the only prohibition is on direct financial gain by the sponsor or the Party. This suggests a ban on the sponsor or Party from charging for hosting an event.

On the assumption that political functions are acceptable, indirect fund raising is inevitable. Numerous functions held by all parties in the House's facilities are attended by those who make financial contributions either as members of political parties, sponsors or trade unionists. If we ban those people from attending functions in the House of Commons banqueting facilities because funds are raised indirectly, the use of those facilities will significantly fall. I sincerely hope it doesn't come to this. Whether someone is a member of a Trade Union which supports the Labour party or a member of a Patrons club which supports the Tory party, Members of Parliament should be able to entertain them in the House.

I now turn to the specific event raised by Messrs Mann & Jones. For historical reasons I am the president of the City of Nottingham Conservatives Business Club. You will recall that I was MP for Nottingham North from 1983-7. I founded this club during my tenure! My sole contribution to it nowadays is to sponsor their annual lunch in the House. Accordingly I can confirm that I was the sponsor of this function and that Michael Howard was our guest speaker by invitation.

I attach herewith a copy of a memo from the City of Nottingham Conservatives, which explains the financial arrangements for the function.

16 January 2007

48.  Letter to Mr Stewart Jackson from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of an extract from the Register of Members' Interests showing that your constituency party received a donation from the United and Cecil Club.

According to Mr Mann and Mr Jones, the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club". In 2001, it was among the top 50 donors to the Conservative Party.

The essence of the complaint which Mr Mann and Mr Jones appear to be making against you is therefore that your constituency party has received money from a club which they believe to be making improper use of the House's dining facilities to raise money for the Conservative Party. Paragraph 5.1 of the Banqueting Regulations says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to this complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

49.  Letter to the Commissioner from Mr Stewart Jackson, 11 December 2006

I am in receipt of your letter and enclosures dated 7 December 2006, regarding issues relating to fundraising and dining facilities in the House of Commons.

Having read the Code of Conduct for Members and, in fact, all the documentation attached to your letter, my considered response is as follows.

The money donated to my local constituency party was received prior to the General Election and before my election to the House of Commons. As far as I am aware, the money was raised legitimately and was certainly received by me in good faith. To the best of my knowledge, the United and Cecil Club is a properly constituted and legitimate organisation and on that basis their donation was permissible under the relevant Act and was, therefore, properly registered in the Register of Members' Interests on 21 November 2005.

Since my election to Parliament, I have not attended, sponsored or organised any United and Cecil Club events or functions in the House of Commons; and the precise circumstances concerning the generation of the specific donation of £1,200, as a donation to my General Election Fighting Fund, are not known to me or to any officers of my association.

I would respectfully suggest that my conduct and behaviour has been quite proper in respect of this matter and is tangential to the main complaint made by Messrs Mann and Jones and certainly falls outside paragraph 14 of the Code of Conduct for Members.

I do hope this clarifies matters to your satisfaction, but, if not, I would be delighted to put some time aside to answer any further points you may raise.

11 December 2006

50.  Letter to Mr Robert Key from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from the above two Members relating to your Patrons' Club and its alleged use of House of Commons dining facilities for fundraising purposes.

The complaint is part of a wider series of complaints of a similar nature which I have received from Mr Jones and Mr Mann against a number of Conservative Members. You will see that two other Members are named alongside you in the enclosed letter.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

With their letter dated 31 January, Mr Mann and Mr Jones sent me a copy of the Annual Report and Accounts of the Salisbury Conservative Association for the year ending 31 December 2004. I enclose a copy for your ease of reference. Page 7 reviews the Association's fundraising activities and refers to a House of Commons dinner on 9 February 2004. Page 8 indicates total income from fundraising to the Association in 2004 of £29,492

In the light of this material, the complaint which Mr Mann and Mr Jones make is, in essence, that your Association's Patrons' Club is a fundraising device for the Conservative Party. By offering events at the House in return for a membership fee (the 'profit' on which goes to Party funds) and/or by charging directly for those events it is using the rooms in breach of paragraph 5.1, and probably also of paragraph 5.3, of the Banqueting Regulations.

I should be grateful if, in accordance with the procedures set out in the enclosed note, you will let me have your response to the complaint. It would be helpful if this could include information on:

1.  The membership, aims and activities of your Patrons' Club.

2.   How these activities are funded, including any subscription paid by members.

3.  How the Club raises any funds it donates to your local Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit).

5.  What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years.

If you would like a word about this matter, please do not hesitate to ring me on the number above. I am keen, in the interests of the House, to report reasonably speedily to the Committee on Standards and Privileges on all these related complaints if I can, and a reply by Monday, 19 February, when the House returns from the half-term recess, would therefore be helpful if at all possible.

I am copying this letter and enclosures to the House's Director of Catering Services, with whom I am in touch about these matters and whom I shall consult as necessary on your reply.

6 February 2007

51.  Letter to the Commissioner from Mr Robert Key, 15 February 2007

Thank you for your letter of 6th February 2007.

The Patrons Club run by Salisbury Conservative Association is a political dining club that also raises funds for the Salisbury Conservative Association. I have discussed the complaint with the Chairman of the Association, Mrs [C] (who is also Chairman of the Patrons Club), with the Treasurer of the Association, Mr [D], and with the Association's Agent, Mr [E].

I believe the Patrons Club is not in breach of Rule 5.1 because it does not set out to make financial or material gain from the dinners in the dining rooms—in fact on each of the two occasions the Club met at The House, the dinners made a loss and were subsidised. This is demonstrated in the attached e-mail from the Agent.

Nor do I believe the Patrons Club to be in breach of rule 5.3 (inducement). As can be seen from the attached letter sent out in February 2004 (the year referred to in the complaint) by the then Chairman of Salisbury Conservative Association inviting membership of the Patrons Club, there is no reference whatever to The House.

I am very happy to respond to your five requests for information.

As the Agent has explained in his communication with me dated 14th February 2007, membership of the Patrons Club is open to anyone in my constituency, not just Conservative Party members. Mr [E] lists the aims and activities of the club. As explained in the third paragraph of the letter to potential members dated 12th February 2004, 'unusual locations, excellent food and an interesting speaker will be part of the mixture'.

The Club is funded by annual subscription (the fundraising element) and each dinner is planned to be paid for individually and at cost.

The Agent explains that the subscriptions help to fund the running of the Salisbury Conservative Association.

I have hosted two Patrons Club dinners at The House in the course of the last five years—in 2004 and in 2006. On each occasion they were paid for by ticket, not out of the subscription and both dinners made a loss.

The Agent explains that the Club is a branch of Salisbury Conservative Association and is chaired by the Chairman of the Association. The sums donated by the Patrons Club in each of the last five years are listed by the Agent.

Turning specifically to your reference to the Annual Report and Accounts of the Salisbury Conservative Association for the year ending 31 December 2004, you are quite right to point to the implication on page 7 that the dinner at The House could be construed to be a fundraising activity. As the attached figures demonstrate, it actually made a loss. But it was wrong even to suggest that the dinner was for fundraising. This was pointed out by the current Treasurer, who was not in office at the time. The mistake was not repeated in the Association Accounts in subsequent years.

My motive in hosting two dinners for the Patrons Club in The House has always been to pursue the objective of any political dining club—to enjoy good food and company and to listen to political speakers. It is very difficult to persuade senior Party figures to visit rural seats like mine. Instead, I brought constituents to Westminster to hear them. On the first occasion in 2004 Michael Howard was our guest speaker. In 2006 David Cameron was due to come but in the event he could not and William Hague very kindly stepped in.

I hope that I have answered your enquiries fully and openly. Please do not hesitate to ask if you need further information. Both I and the Salisbury Conservative Association are keen to assist you. It has always been my intention to abide by all the rules of The House—and I believe I have always done so. However, in view of the national media attention already given to this issue, and in the light of the 'class action' pursued by Mr Mann and Mr Jones, I understand why this is perceived to be a grey area. If you believe that I have erred, I would wish to apologise unreservedly. In those circumstances I would also be grateful if you and the Committee on Standards and Privileges would consider clarifying the rules.

15 February 2007

52.  Letter to Mr Robert Key from his Constituency Agent (undated)

Thank you for your note from Sir Philip Mawer regarding the complaints from two Members of the House about the Salisbury Patrons Club. They accuse the Club of using the House's Banqueting facilities for fundraising purposes.

I cannot stress enough that this is not the case. On the last occasions the Patrons Club has met in Dining Room A, the ticket price set was to cover the costs of the evening and not to make a profit. The Salisbury Patrons Club makes a profit from the membership fee charged. Sometimes, a profit is made on the events outside the House. This is because of the personal generosity of the host; this is not the case with the House of Commons. Although last year we met in the House, it is never stated that the Club will meet in the House as a matter of course.

I append the answers to Sir Philip's questions.

I. Membership, aims and activities of the Patrons Club

Membership is open to anyone in the Salisbury Constituency who wishes to become a member.

The aim of the Patrons Club is to raise money for the Salisbury Conservative Association.

The activities are to include two to three events in a 12 month period.

2. How these activities are funded including any subscription paid by members?

A membership fee of £300 per annum is set.

The cost of each event held is met by each attending member—the profit for the Patrons Club is achieved by the annual membership fee.

3. How the Club raises any funds it donates to your local Association?

The funds raised, through the membership fees and any small surplus from events, are paid direct to Salisbury Conservative Association.

4. How many events it has held in the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit)?

Events held are just 2, in 2004 and 2006. There was no Patrons Club activity during 2005.

These events were funded by a ticket price paid by the attending member that was costed up to cover the price of the dinner, wine, after dinner drinks and, where appropriate, the cost of travel (2004 only).

The events were not funded out of subscriptions.

The event in [date omitted] was not exclusive to Patrons and members of the Association were invited. 2004 broke even and the event in 2006 made a small loss. This loss was borne by the Patrons Club and Association.

Dinner in the House with Michael Howard 2004

Income:        Expenditure

Ticket sales:  £1,982.00  Banqueting  £1,624.15

        Coach Hire  £450.00

        Total    £2,074.15

        Loss:    £92.15

Dinner in the House with William Hague 2006

Income:        Expenditure:

Ticket Sales:  £1,420.00  Banqueting  £1,537.35

        Total    £1,537.35

        Loss:    £117.35

5. What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years?

The Patrons Club is a branch of the Association and is owned by the Association and run by a named individual from the Association. The Chairman of the Association is also the Chairman of the Patrons Club.

The Club was reformed in 2006 and contributed £7,000 to the Association's funds in that year.

In 2005 the Club did not meet and membership was low; it contributed no more than £3,000 to the Association; in 2004 the Club met twice and contributed £2,000 to Association fundraising. The dinner in the House that year did not make a profit.

Although unintentional, it was misleading to refer to the event in the House in the 2004 Report as fundraising. Also, under item 11 List of Fundraising Activities, it should read Patrons Club and not Patrons Club events. These have been corrected in the 2005 accounts.

53.  Letter to Mr John Mann and Mr Kevan Jones from the Commissioner, 16 January 2007

Thank you for your letter of 3 January enclosing a copy of an article in the Sunday Times on 31 December and saying that in the light of it you wish to add a formal complaint about the Rt Hon David Cameron and Mr George Osborne to your earlier complaint.

You identified Mr Cameron when you originally wrote to me about these matters, so there is no need to add a complaint about him. The Sunday Times article does not add any substantive new point to what was already known. I will therefore simply take what the article says into account when considering the earlier material you sent me.

Mr Osborne, however, was not mentioned by you earlier. On the other hand the Sunday Times article does not contain any evidence that Mr Osborne may have broken the House's rules. It simply says that his constituency association "has made more than £40,000 from his Patrons' Club since he was elected in 2001". The key question—how that money was raised and whether any of it was raised in alleged contradiction of the House's rules—is not addressed directly by the article, only by implication.

If you have direct evidence on that point which you wish to give me, please do so. Without it, there is no basis on which I could accept a complaint against Mr Osborne. Nor is it in fact necessary for me to have such a complaint in order to consider the point of substance at the heart of all your existing complaints, vis. whether the fundraising activities of a number of Conservative Party dining clubs are in breach of the rules of the House.

16 January 2007

54.  Letter to Mr Mike Penning from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a list of events held recently in the House, which includes reference to one for Hemel Hempstead Conservative Association (which they say was a meal) which you hosted on 25 October. Mr Mann and Mr Jones note that the event was not posted on your Association web-site (a copy of the relevant page from which is also enclosed).

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the event you hosted on 25 October was a fund-raising one (if only in the sense that tickets for it were not charged at cost); and that you have breached paragraph 5.1 of the Banqueting Regulations, which says that the House's private dining rooms (and by implication, its other catering facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2007

55.  Letter to the Commissioner from Mr Mike Penning, 3 January 2007

Thank you very much for your letter and enclosures of 7th December regarding the complaint made by John Mann MP and Kevin Jones MP.

I am truly sorry that these MPs have decided to embark upon what seems to be a fishing exercise which, although I do not want to pre-empt your conclusions, appears to be a complete waste of tax payers' time and money.

You refer in your letter to a dinner hosted by myself at the House of Commons on the 25th October for my Association's Patrons Club. For background information I would advise this is a subscription only club which has been running I believe for at least 20 years. The annual subscription for this club entitles the members to a lunch, hosted in the constituency, and an annual dinner, the dinner being held either at the Carlton Club, St Stephens Club or, occasionally, at the House of Commons. Also included in the subscription is the cost of transport to and from the venue.

I would also advise that the subscriptions, being over the £200 threshold, are automatically notified to the relevant authority by my Association.

The event would not be advertised on the Hemel Hempstead Association's web page as only Patrons Club Members are invited. They can, if they wish, bring a guest but the price of the guest ticket includes not only the cost of the meal but transport to and from the venue.

Personally, I feel this complaint has no foundation whatsoever and is, I believe, the first time a complaint of this kind has been put before you. I am fully aware of the rules relating to existing regulations and I was sure that this event fell well within the rules although I would, of course bow to your decision on this matter.

I am deeply disturbed that this is a clear attempt to not only smear my good name but also that of the Party which I represent. I may find it necessary to bring a complaint against these two MPs for wasting taxpayers' time and money. However, I am conscious that this would also incur costs and would ask your advice before proceeding with such a complaint.

3 January 2007

56.  Letter to Mr Mike Penning from the Commissioner, 9 January 2007

Thank you for your letter of 3 January in reply to mine of 7 December about this complaint.

I am grateful for the explanation you have given me in response to the complaint. There are just a couple of factual points arising from your letter, answers to which would help me better understand the nature of your Patrons' Club:

1.  You say that subscriptions to the Club are over £200 but do not mention the actual figure. I should be grateful if you would let me have it.

2.  You do not say whether the Club is a fundraising vehicle for your Constituency Association and, if so, how it goes about raising money.

I seek clarification on these points not to imply wrong doing or to prolong matters but simply to ensure that any conclusion I reach on the complaint is solidly based on a full knowledge of the relevant facts.

I note your concern about what you regard as the time-wasting nature of the two Members' complaint. I will make sure the Committee on Standards and Privileges is aware of that concern and suggest it would be better to await the outcome of the Committee's consideration of the complaint before deciding if you wish to pursue this aspect further.

I look forward to hearing from you. If you want a word, please do not hesitate to get in touch.

9 January 2007

57.  Letter to the Commissioner from Mr Mike Penning, 15 January 2007

Many thanks for your letter of 9th January with regard to the above and I would confirm the following:

1.  Patrons Club Subscriptions  £225 Single Membership

£375 Joint Membership

2.  As to the point of whether this club is a fundraising vehicle, I would advise that all subscriptions are, naturally, paid into the Hemel Hempstead Conservative Association's bank account. Out of this account are paid all charges with regard to the Lunch in the Constituency and the Dinner in London. Also included in the subscription is the cost of transport to and from the venues.

3.  I would stress, however, that the Dinner in London is not automatically held at the House of Commons. Other venues are used which include the Carlton Club and St Stephens Club; the Carlton Club being the most popular.

4.  The club does not hold specific fundraising events.

I hope this information clarifies matters for you but please do not hesitate to contact me if you wish further information.

15 January 2007

58.  Letter to Mr Mark Prisk from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This includes:

1.  a copy of the Westminster Club Newsletter for Autumn 2006 issued by Hertford and Stortford Conservative Association. This indicates that one of the benefits of joining the Club is "one special event at the Palace of Westminster." Page 4 of the newsletter refers to the annual dinner of the Club, to be held "in the Churchill Room of the House of Commons on Thursday, 7 December";

2.  a copy of related pages from your web-site.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the Westminster Club is a fund-raising device for your constituency association; that the promise of a special event at the Palace of Westminster is offered as an inducement to join the Club (contrary to paragraph 5.3 of the Banqueting Regulations); and that the use of the House's dining facilities by the Club breaches paragraph 5.1 of the Regulations.

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2007

59.  Letter to the Commissioner from Mr Kevan Jones and Mr John Mann, 14 December 2006

Further to our recent letter enclosing information about the misuse of the refreshment facilities in the House of Commons, we have additional information which we hope will form part of your investigation.

On the evening of the 7th December Mark Prisk MP hosted a dinner for the 'Westminster Club' in the House of Commons. Please find enclosed a menu from the event.

The 'Westminster Club,' according to information on Mr Prisk's website, "provides a link between business and politics in the Hertford and Stortford Constituency." It also provides "opportunities to bend your MP's ear, members will also find useful access to local and county councillors".

This organisation has a number of membership fees, depending on the size of your business, details of which are found in Westminster Club's latest newsletter, which is also enclosed.

Also in this newsletter, in the section headed "Chairmen's Chunterings", the newsletter states that the event in the House of Commons on the 7th December "became a sell-out almost before it was publicised".

We believe this information indicates that tickets were sold for this event.

Please do not hesitate to contact us if you have any questions or require any clarification.

14 December 2006

60.  Letter to the Commissioner from Mr Mark Prisk, 18 December 2006

Thank you for your letter dated the 7th December. I have now had time to consider the complaints made and the facts.

The Westminster Club was started in Hertford & Stortford some years ago, by my predecessor Bowen Wells. It therefore operates on long-standing procedures. It is currently chaired by a local businessman [Mr F] and administered by [Ms G], who is also the secretary of the local Conservative Association. As the MP, I am the Club President.

The Club has its own bank account, separate from the Conservative Association. The Club charges members a fee to join. The member businesses range from sole traders through to Glaxo Smith Kline plc, which has a large Research & Development and manufacturing business in Ware. The Club is the only local business club which extends across East Hertfordshire district and so there's an emphasis on local businesses networking.

Each year the club organises a programme of meetings, usually four in the constituency and one at Westminster. There is also a newsletter and this is distributed by [Ms G] to club members.

From your letter the complaints made against me are in relation to 5.1 and 5.3 of the Banqueting Regulations. I have responded to these below.

Use of House facilities (5.1)

I sponsor the room booking for the Churchill Room and secure a Guest Speaker.

The price of the ticket is set by the Chairman and depends on the costs involved which include the meal, wine, pre-meal drinks, dinner menu, place cards and the mailing costs of promoting the event to members. The ticket price also covers the meal costs of our Guest Speaker.

Club members can invite as many guests as they wish and often invite their clients or customers. For many of our smaller local firms this is a special occasion for them. I have no say in the finances of the club, nor do I or the Chairman receive any recompense. The income and costs involved are managed through the club's own account, not that of the Conservative Association.

Inducement (5.3)

The list of benefits of membership does indeed mention the dinner at Westminster, along with the other club functions. ([Mr F] and I originally called the dinner a special 'event' simply because we were unsure whether to have a buffet or a dinner and 'event' covered all eventualities).

Given this, it is highly unlikely that the dinner itself induces people to join, beyond any other item in the club's programme, or the attraction of a particular speaker From my conversation with members they enjoy the opportunity to network and mix socially and the chance to raise their concerns with me, as their MP.

As to the wider point as to whether the Conservative Party directly benefits financially, the Club's income comes from three principal sources: its membership fees, from the business breakfasts and from the dinner at Westminster. Its aim is to be self-financing. However, in recent years the club has been increasingly popular, largely due to [Mr F]'s organisation, and the membership fees have created a surplus of income.

At the same time, the costs of administering the club, in terms of [Ms G] time and the printing and mailing costs have been absorbed by the Conservative Association. In recognition of this [Mr F] has agreed to make some transfers from the Club to the Association, but only when he is satisfied that the club has the funds it needs to operate for the coming year. Indeed in my first two years as MP, the club only just covered its own costs.

My understanding is this ad-hoc arrangement does not breach the Banqueting Regulations as no direct gain is made by the Conservative Party from the booking of the Churchill Room, nor is the event fundraising for the Party. However, I fully understand that you must investigate the accusations, and if I can furnish any other information please do not hesitate to ask.

Lastly, I would like to say that I am concerned at the effect these allegations may have on the excellent Refreshment Department at the House. If legitimate events are transferred away from Westminster, it will further undermine the viability of the department. It would also mean that the 100 people who come each year—many for the first time—would no longer visit Westminster, and I believe that that would be a retrograde step.

18 December 2006

61.  Letter to Mr Grant Shapps from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This includes:

1.  a copy of some pages from your website, in which there is a reference to a meeting of your Parliamentary Club at the House of Commons on 18 December 2006, to be addressed by Frederick Forsyth;

2.  an extract from your entry in the Register of Members' Interests showing that your constituency party receives a donation from the United and Cecil Club.

Mr Mann and Mr Jones say that the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club". In 2001 it was among the top 50 to donate to the Conservative Party.

Based on this material Mr Mann and Mr Jones speculate on the existence of a link between the meeting your Parliamentary Club on 18 December and the activities of the United and Cecil Club. The implication is either that your Parliamentary Club is itself a fund-raising device or that the United and Cecil Club is improperly using House facilities to raise money for the Conservative Party, or both.

In accordance with the procedures set out in the enclosed note, I now invite your response to the allegations made by Mr Mann and Mr Jones. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2007

62.  Letter to the Commissioner from Mr Grant Shapps, 12 December 2006

Thank you for your letter of 7th December 2007 following a complaint made by John Mann MP and Kevan Jones MP.

I'm pleased to confirm that the Welwyn Hatfield Parliamentary Club does not and never has fundraised for the United and Cecil Club, nor does it fundraise through dinners at the House of Commons for itself or the Conservative Party. Furthermore the Welwyn Hatfield Parliamentary Club does not charge a joining fee of any kind and has never done so.

The Welwyn Hatfield Parliamentary Club is intended as an outlet for constituents who are interested in discussing politics and as well as hearing from politicians and political commentators. We hold dinners in the constituency and at Westminster and the dinners at the House of Commons are typically charged at £65 depending on the exact menu chosen and this price includes pre-dinner drinks with an open bar, all wine served with the meal, port or brandy after the meal, name and menu cards and all the administration and postage required to organise the event. In reality we probably end up marginally subsidising such dinners, hardly a great fundraiser!

I should mention that the Welwyn Hatfield Parliamentary Club does try to have one large fundraising dinner each year. However, this has always been held at the Carlton Club and we charge £1,000 a plate. Our guest speaker this year was Boris Johnson. This kind of event takes quite a bit of organising and we did not in fact manage to schedule anything last year, so the Club raised no money whatsoever in 2005/6. Incidentally, the attendees at the £1,000 Carlton Club dinner are not even the same people who attend Parliament, since as you might imagine, this big ticket event draws in a rather different crowd.

I can confirm that our forthcoming Welwyn Hatfield Parliamentary Club dinner on Monday 18th December is with Frederick Forsyth and there is no connection whatsoever with the United and Cecil Club.

The United and Cecil Club will no doubt answer for their own activities but my understanding is that they charge a similarly low sum for dinner at the House of Commons to listen to leading politicians—on the one occasion I was involved David Willets MP was the speaker and I recall that they charged £65 or £68. I received no benefit or donation in return. I understand that they actually fundraise at other big ticket events held at a variety of London clubs and venues. For example, David Cameron was a recent speaker for them elsewhere.

Please let me know if you require any further information.

12 December 2006

63.  Letter to the Commissioner from Mr Kevan Jones and Mr John Mann, 12 December 2006

Further to our recent letter enclosing information about the misuse of the refreshment facilities in the House of Commons, we have additional information which we hope will form part of your investigation.

On the evening of 11th December Dr Bob Spink MP hosted a dinner in the House of Commons advertised on the Refreshment Department notice board as being for 'Basildon Conservatives'. However, inspection of the menu for this event shows that it was actually for the 'Basildon House of Commons Dining Club'; please find enclosed a copy of the menu.

This organisation is registered with the Electoral Commission and donated £5,000 to Basildon Conservative Association in June 2001.

We should also point out that Dr Spink has no connection with the constituency of Basildon, which is a marginal seat held by Labour Minister Angela Smith. It would appear that the 'Basildon House of Commons Dining Club' and Dr Spink are using the House facilities to raise money to unseat a Labour MP, in clear contravention of the rules.

Please do not hesitate to contact us if you have any questions or require any clarification.

12 December 2006

64.  Letter to Dr Bob Spink from the Commissioner, 18 December 2006

I have received a complaint against you from the above two Members. A copy of the letter of complaint (dated 12 December) is enclosed.

You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that you hosted the annual Christmas dinner of the 'Basildon House of Commons Dining Club' at the House on 11 December; that the Club is a fund-raising organisation on behalf of the Conservative Party in Basildon; and that the event was therefore in breach of the Banqueting Regulations governing the use of dining facilities, a copy of which I enclose. Paragraphs 5.1, 5.3 and 5.5 of the Regulations are particularly relevant.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. It would be helpful if this could include a description of the nature and composition of the 'Basildon House of Commons Dining Club' and of how it goes about its alleged fund-raising activities.

I should add that this complaint by Mr Jones and Mr Mann against you is similar to complaints they have recently made against a number of other Conservative Members. As the outcome of all the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

18 December 2007

65.  Letter to the Commissioner from Dr Bob Spink, 21 December 2006

Thank you for your letter of 18 December regarding a complaint by John Mann and Kevan Jones. You may well have received my response regarding that complaint which I sent direct to John and Kevan.

Although John Mann's letter of complaint was dated 12 December, I was not made aware of it until 19 December, when I spoke with John, in addition to writing him my letter of that date.

I have no direct contact with the Basildon Association or Dining Club, other than through a long-term acquaintance, Cllr Mike Revell, who approached me a couple of years ago and asked me if I would be the sponsoring MP for events that they held from time to time at the House of Commons. I agreed to do this and have on three or so occasions sponsored events, but my only involvement has been to sign the normal banqueting documentation as sponsoring MP, and I note that the event complained of was described as 'Christmas dinner—Basildon H of C Dining Club'. I contacted Mike Revell on 19 December and he told me that the tickets for the dinner cost £65 and that that essentially covered all the costs, including transport, and that should there be any surplus, the money would be used for charitable purposes. I must say that I was surprised to see my name so prominently displayed on the event menu, as my involvement was merely a "technicality" as host although I accept without question that this makes me the responsible person so far as the House of Commons is concerned. I did attend the dinner in part and consumed a small amount of the main course only.

Should you wish to contact Mike Revell yourself, his address and telephone number are as follows…

In the meantime, perhaps you would advise me if it is appropriate to copy correspondence to Mike Revell, I will not do so unless you advise it necessary and appropriate.

I will not, in future, be sponsoring any events for external organisations in view of the obvious risk that this brings.

John informs me that he now withdraws the complaint regarding myself and I have accepted that. Perhaps you would clarify whether this ends the matter or whether you wish me to make a full response to your letter of 18 December.

I should inform you that I was also contacted on 19 December by a lobby journalist for the Guardian and that he subsequently spoke with John Mann to confirm that John had withdrawn his complaint against me.

21 December 2006

66.  Letter to Dr Bob Spink from the Commissioner, 5 January 2007

Thank you for your letter of 21 December in reply to mine of 18 December about this complaint. I am grateful for your explanation of your involvement in the dinner held at the House by the Basildon House of Commons Dining Club. I note that you say that in view of your explanation, Messrs Mann and Jones have withdrawn their complaint against you.

You ask whether that is an end to the matter. I am afraid it is not. Once a complaint has been lodged with me, it is for me or for the Committee on Standards and Privileges, advised by me, to determine its outcome. So both I and the Committee as necessary will need to continue to consider the complaint on its merits in order to decide what should happen.

Looking at the merits of the complaint, I understand you to be saying that whatever the nature of the Dining Club, the event it held in the House on 11 December was not a fund-raising occasion but was charged for at cost, with any surplus going to a charitable purpose.

I am writing to Mr Revell with one or two supplementary questions but, assuming that the answers he gives support what you have said, it would seem that the complaint by Messrs Mann and Jones is not backed by the available evidence. I will write to you again when I have heard from Mr Revell to let you know what conclusion I have finally reached and how I intend to proceed.

I have no objection to you copying earlier correspondence to Mr Revell provided he understands that it is strictly confidential and that any breach of that confidentiality could constitute a contempt of the House.

5 January 2007

67.  Letter to Mr Mike Revell from the Commissioner, 5 January 2007

As you know, I have received a complaint against Dr Spink in respect of the event he sponsored held at the House of Commons on 11 December 2006 by the 'Basildon House of Commons Dining Club.' The essence of the complaint—made by John Mann MP and Kevan Jones MP—is that the Club is a fundraising organisation on behalf of the Conservative Party in Basildon, and that the event breached the House's Banqueting Regulations which prohibit the use of the House's private dining rooms for direct fundraising for a political party.

Dr Spink (to whom I am copying this letter) tells me that he has discussed this matter with you and you have assured him that the cost of tickets for the recent event was £65. This was intended purely to cover the cost of the event (including transport), with any surplus being used for a charitable purpose.

In these circumstances it would seem that the complaint made to me is based on a false premise in respect of the funding of the recent event. However, the two Members who complained to me have insisted that the Club is a fundraising organisation, registered as such with the Electoral Commission and that in June 2001 it donated £5,000 to the Basildon Conservative Association.

In order that I can be sure that any conclusion I reach on this matter is based on a sound understanding of the facts, I should be grateful if you could clarify for me the relationship between your Club and the Conservative Party. In particular, could you advise me as to:

1.  the nature, objects and membership of the Club;

2.  the membership fee charged, and what it is intended to cover;

3.  how many events a year are held at the House and how the cost of these is met;

4.  how the Club raises funds for the Conservative Party or local Conservative Association and how much it has donated to each of these since 2001.

I should be happy to discuss this matter with you if you would find that helpful. My telephone number is above. I am enclosing a note setting out the procedure I follow when considering a complaint which you may also find useful.

5 January 2007

68.  Letter to the Commissioner from Mr Mike Revell, 12 January 2007

I reply to your letter dated 5th January 2007.

Firstly I would confirm that I was the organizer for the dinner hosted by Dr Bob Spink MP on 11th December 2007(sic). There were approximately 30 people attending paying £65.00 per head which will cover our costs with, hopefully, a small profit. That profit will go to charity.

I would add that there is no restriction made to our guests as to their political preference, or indeed are they ever asked. There was no lobbying for party funds at the meeting, it was held as an opportunity for business people in our area to meet with Dr Bob Spink in a very social gathering.

Dr Spink asked for no money for himself or for the Conservative Party and none was given.

The present Basildon House of Commons Club does not charge a membership fee and is not an organized group as such. I was not the organizer in June 2001 so cannot tell you how £5,000.00 was paid at that time. I can however say that Bob Spink MP was not involved with Basildon at that time; indeed I do not think he was then an MP.

The original Dining Club was sponsored by David Amess MP, but I understand this ended soon after he became the MP for Southend West. I used the old name as a title when organizing for the December event.

12 January 2007

69.  Letter to Mr Richard Spring from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a list of events held recently in the House of Commons, which includes reference to an event (said to be a meal) which you hosted for the Conservative City Circle on 23 October. Mr Mann and Mr Jones say that no reference to this event was made on your constituency association web-site.

Based on the enclosed material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the Conservative City Circle is a fund-raising device for the Conservative Party; and that the event you hosted was therefore contrary to paragraph 5.1 of the Banqueting Regulations which says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

70.  Letter to the Commissioner from Mr Richard Spring, 11 December 2006

Thank you very much for your letter of 7 December, concerning the complaint made by John Mann MP and Kevan Jones MP. They highlight an event which I sponsored on 23 October.

It is true that the booking was made for the Conservative City Circle of which I am co-chairman, but the party was absolutely not an attempt to raise funds for the group, let alone my constituency, which had nothing whatsoever to do with the event The purpose of the party was simply a social one, for young City lawyers to meet each other. I can only repeat that no fundraising was involved at all. It was paid for by the Society of Conservative Lawyers.

I would like, in the strongest possible terms, to protest about this allegation which was made without initially referring the matter to me. I consider this a total lack of courtesy on behalf of these two Members of Parliament. It is clear to me that this was some sort of fishing exercise, based upon some misplaced party political interest, and that the complaint should never have been made.

I do not want to waste your time by getting into a back and forth complaint situation, but I would certainly consider making a complaint against these two Members of Parliament for deliberately trying to make trouble, by making a complaint which had absolutely no foundation whatsoever.

11 December 2006

71.  Letter to the Commissioner from Mr Richard Spring, 18 December 2006

Thank you so much for your letter of 14 December regarding the above complaint.

Just very briefly to clarify one minor point—it was a reception on the Terrace not a dinner. The only aspect of fundraising was that the sponsor, the Society of Conservative Lawyers, invited people to consider becoming members. Certainly in no way whatsoever were either myself, my constituency or City Circle beneficiaries, and in any case this all fully falls within the rules.

18 December 2006

72.  Letter to Mr Graham Stuart from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of an extract from the Register of Members' Interests showing that your constituency party received a donation from the United and Cecil Club.

According to Mr Mann and Mr Jones, the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club". In 2001, it was among the top 50 donors to the Conservative Party.

The essence of the complaint which Mr Mann and Mr Jones appear to be making against you is therefore that your constituency party has received money from a club which they believe to be making improper use of the House's dining facilities to raise money for the Conservative Party. Paragraph 5.1 of the Banqueting Regulations says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to this complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

73.  Letter to the Commissioner from Mr Graham Stuart, 30 January 2007

Thank you for your letter of 7th December and my apologies for not responding sooner.

The United & Cecil Club runs dinners at various locations in London and elsewhere. It also contributes to the Conservative Party. I'm sure that Club officers will be happy to answer any questions about how they conduct themselves. I did receive a contribution to my election campaign from the Club but fail to see how this forms the grounds for a complaint.

It would be a pity if dinners held by such groups (or indeed patrons' clubs) were driven out of the Palace to other venues. Those individuals who help fund local politics in this country are playing an important role in maintaining our democracy and it would be perverse if they were uniquely barred from dining (at commercial rates) in Parliament.

This complaint has all the hallmarks of a Labour Party "operation" designed to characterise any entertainment of Conservative supporters in Parliament as some sort of sleaze. More importantly it is designed to deflect attention from the real issues of corruption surrounding the "Honours for sale" investigation and Labour's continuing unhealthy relationship with its big union backers.

If you do decide to take the investigation further I hope you will conduct a thorough review of all bookings in private dining rooms as I'm sure you will find that financial supporters (in whatever form) are entertained in Parliament by politicians of all parties, not just the Conservatives. Efforts to gain such a list have I understand, so far been thwarted by the Catering Department (although, in my opinion, such an approach would not survive a Freedom of Information request).

I believe, however, that the Labour MPs' complaint is without merit and that, if clarification is needed on the use of dining facilities, then it should be quickly provided but avoid perverse results.

30 January 2007

74.  Letter to the Commissioner from Mr John Mann and Mr Kevan Jones, 18 January 2007

Re: United and Cecil Club

We have been given documents relating to a dinner this Tuesday in Parliament which I enclose for your information.

These documents confirm what we have already deduced:

1.  This club exists to fundraise for the Conservative Party;

2.  It has monthly dinners (on the third Tuesday);

3.  Half its dinners are held in Parliament;

4.  MPs are asked to sponsor bookings on behalf of the Conservative Party.

In this case it appears Mr Hands was not even required to be present.

We would like to draw your attention to what we see as a systematic breach of rules (given the blatantly promotional menu) rather than an "ignorance" of the rules.

18 January 2007

75.  Letter to Hon Bernard Jenkin from the Commissioner, 19 December 2006

As I mentioned when we spoke on the telephone last week, I have received a complaint from the above two Members naming 16 Conservative Members in connection with the alleged misuse of House of Commons dining facilities for party fund-raising purposes. The United and Cecil Club—of which I understand you are now the Chairman—is named in connection with 4 Members and I am writing to let you know this formally and to invite your comments on the complaint.

The focus of all the complaints is the allegation that certain Conservative Party dining clubs raise money for Party funds by offering their members the opportunity to dine in the House. The claim is either that an inflated price is charged for the events held in the House and/or that an inflated fee is charged for membership of the club in question. The Patrons' Clubs run by a number of Conservative constituency associations are cited as a particular example of the latter practice.

It is claimed that these activities are contrary to the House's current Banqueting Regulations, a copy of which I enclose. Sections 5.1, 5.3 and 5.5 of these are particularly relevant. I also enclose as background a copy of the letter to me dated 23 November from the two Members who have made the complaint, and of the article from the "Political Quarterly" to which it refers.

In the large file of material which accompanied their complaint (relevant items from which I enclose), Messrs Mann and Jones say that the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club." In 2001, it was among the top 50 donors to the Conservative Party.

They mention 4 Members—Grant Shapps, Graham Stuart, Stewart Jackson and James Duddridge—as having received funding from the Club. (Each of the 4 has registered the receipt of such a donation in the Register of Members' Interests.) They then imply or speculate on a link between these donations and the use of House dining facilities by the Club.

I should be grateful for your observations on the complaint from the perspective of your responsibility for the Club. It would be helpful if these could include information about:

1.  the nature and purpose of the Club;

2.  its membership and any membership fee that may be charged;

3.  the pattern of the Club's activities including the use it makes of the House's dining facilities;

4.  how events held at the House are charged for; and

5.  how it raises funds for the Conservative Party.

I shall fully understand, in view of the timing of this letter immediately prior to the recess, if your comments do not reach me until after the House resumes in January.

Clearly the interpretation of the current Banqueting Regulations is likely to be a significant issue in relation to determining the outcome of the complaint and I am in touch with the House's Director of Catering Services and the Clerk of the Administration Committee about this and related matters. I shall consider their advice and your response carefully before deciding how to proceed.

If you would like a further word about the complaint, please do not hesitate to ring me on the number above.

19 December 2006

76.  Letter to the Commissioner from Hon Bernard Jenkin, 8 January 2007

Thank you for your letter of 19th December 2006, following our telephone conversation the previous week, concerning the above complaint that House dining facilities may be being used contrary to the Regulations.

As I said on the telephone, I took over as Chairman of the United & Cecil Club ('the U&C') only a year ago and have merely continued with the established tradition and practice of a dining and discussion club which meets in the House of Commons and also contributes to a political party. If the U&C is doing anything improper, please tell us and we will mend our ways accordingly. Until we receive such advice, we will proceed as normal. Our next dinner is with Lord Rees Mogg on Tuesday 16th January.

As I also mentioned to you, when I first entered the House of Commons in 1992, I inherited the Colchester Area Business Advisory Committee ('CABAC'), which also meets twice per year in a House of Commons private dining room. This would be more akin to a constituency "patrons" club and may be affected by re-interpretation of the Regulations. If you require details of this organisation, please let me know and I will reply by separate cover. Again, unless you advise to the contrary, we will proceed with plans for 2007.

I have always taken the spirit of the Regulations to mean that rooms should not be booked on behalf of political parties themselves for overt fundraising, but only for a purpose connected with your constituency or a legitimate political purpose, such as debate and discussion of issues of the day. However, the use of the word "direct" in the Regulations is clearly intended to provide some latitude in interpretation.

I would add that fundraising for political parties is a perfectly respectable activity, now recognised and regulated by law. All politicians are involved with it, one way or another (and will remain so, unless the law changes and we move to exclusively state funded political parties). In that case, it would seem unrealistic and indeed unhealthy for activities in the Palace of Westminster to be unreasonably divorced from the reality of politics. If activities of "patrons" clubs and of organisations like the U&C effectively be banned from the Palace of Westminster, what public interest would be served?

However, if there are to be changes, it would not be unreasonable to expect that such changes avoid favouring one political party over another. For example, would trade unions be treated in the same way as "patrons" clubs? Can we take it that Labour MPs who book rooms for trade unions are completely disinterested in the role that they play in funding the Labour Party?

I deal with each of your enquiries in order.

1.  The nature and purpose of the United & Cecil Club ('the U&C') is best explained by its history (which is on the club's website):

The history of the Club

In 1881, after the death of Benjamin Disraeli, the Party's leader for thirteen years and the mainstream of its ideas for even longer, the Party responded in three ways:-

—  Robert Cecil, Third Marquess of Salisbury, a man of clear vision and pre-eminent intellectual capacity, became the new leader.

—  A shrewd old hand, John Gorst, was recalled to Central Office.

—  The rank and file began to reorganise.

In 1881 a group of barristers formed 'The Constituencies Union', pledging to go out and work for the Party in difficult constituencies. John Gorst persuaded them to work in close harmony with Central Office. In 1891, they changed their name to 'The United Club'.

In 1882 a group of ex-ministers and rising stars in the Party met in the Junior Carlton Club. Here they formed 'The National Review and Cecil Club'. The Cecil Club, as it became known, continued to meet throughout the first half of the 20th Century.

When coalition governments were formed to face crises, as in 1915, 1931 and 1940, the Clubs helped maintain Conservative thinking and discussion. In 1949, Sir Winston Churchill, President of both Clubs, asked them to merge, becoming 'the United and Cecil Club'.

From this time we have provided contact with the Party leadership and raised funds for target seats and those of our members who stand at the General Election.

With all that has happened within the Parliamentary Party, we too have gone through a rebirth, and the aim of our members remains to support the Party leadership.

Our membership is drawn from Members of Parliament, leading Councillors and members of the business and professional community. We dine monthly whilst Parliament is sitting and invite either a member of the Shadow Cabinet or a person of interest to dine with us and address the members. We usually dine at the House of Commons but at times (through pressure of numbers) we have to dine elsewhere.

2.  The U& C has a total membership of around 400. There is an annual membership fee of £100 per year.

3.  The U&C's main activities are dining and discussion. It meets about eight times per year, of which around four dinners per year are held in the House of Commons.

4.  A ticket price of around £79 is charged for each member or guest attending a dinner in the House of Commons. This includes wine with the meal and broadly reflects the costs (including printing of tickets, menus, flowers etc), though erring on the side of a surplus rather than a loss. This can fairly be regarded as a contribution towards the administrative costs of the club (£6,500 p.a.). We do not hold auctions or raffles.

5.   The U&C raises funds for the Conservative Party, but from its members' subscriptions and from fundraising events which are not held in the House of Commons. For example, dinners with John Major at the end of 2005 and with David Cameron in June 2006 were held outside. It is for this reason that the U&C is a "membership organisation" under the terms of the Political Parties, Elections and Referendums Act (2000).

This addresses your direct enquiries as best I can, though I am of course very willing to respond to any further enquiries you may have.

8 January 2007

77.  Letter to the Chairman of the "Conservative Mainstream" Patrons' Club from the Commissioner, 2 February 2007

Following my recent telephone conversation with Mr Damian Green MP and Ms [H] (to both of whom I am copying this letter), I am writing to seek your comments on a complaint I have received from Mr John Mann MP and Mr Kevan Jones MP in relation to the Patrons' Club of "Conservative Mainstream". The complaint is part of a wider series of complaints I have received from these two Members about the alleged misuse of Parliamentary dining facilities for the purpose of fundraising for the Conservative Party. You may have noticed some reference to this in the press.

Mr Mann and Mr Jones originally wrote to me about this matter on 23 November 2006. A copy of their letter of that date and of the article from the Political Quarterly to which it refers are enclosed.

With their letter Mr Mann and Mr Jones sent me a voluminous file of material, among which were some pages from Conservative Mainstream's website about your Patrons' Club and extracts from the Reformer Magazine for Autumn 2002 and Spring 2003 (copy enclosed). These indicated that your Club had, in 2002, an annual membership subscription of £300. In return for this, members (and a guest) were invited to a Patrons' dinner in the late autumn and a summer reception. The material indicated that the Club's first dinner had been held in the House of Lords, hosted by Lord Hunt. This dinner is also mentioned in the enclosed extract from the Reformer for Spring 2003.

The general thesis put forward by Mr Mann and Mr Jones is that various dining clubs associated with the Conservative Party—notably the Patrons' Clubs which exist in a number of constituencies—offer their members (and would-be members) a regular opportunity to dine in the House in return for an inflated membership subscription. The surplus from that fee (along with any profit on events held in the House) is then paid over to the Party. Mr Mann and Mr Jones allege that this is contrary to the Banqueting Regulations which govern the use of the private dining rooms (and by analogy of other dining facilities) in the House, especially paragraph 5.1—which prohibits the use of the rooms for "direct financial or material gain by a political party"—and paragraph 5.3, which says that the rooms "may not be used as an inducement to recruit new members of outside organisations or non-parliamentary associations".

The material Mr Mann and Mr Jones originally sent me did not name any MPs in connection with the activity of your Patrons' Club. Nor did the material indicate that the prospect of using dining facilities in the House of Commons was being held out as an inducement to prospective members. The only Parliamentary event clearly mentioned was the dinner hosted by Lord Hunt in the House of Lords. However, Members of the Upper House do not normally fall within my jurisdiction and there is in fact no equivalent rule in the Lords to paragraph 5.1 of the Commons Banqueting Regulations. For all these reasons, I did not pursue the matter with Mr Green at the time (there being no indication in the material sent me that a breach of the Commons rule had occurred).

On 11 January 2006, Mr Mann sent me a further letter specifically relating to "Conservative Mainstream" and enclosing some material about your Club and about "Parliamentary Mainstream". A copy of this is also enclosed. However the material did not add anything of substance to that which Mr Mann and Mr Jones had earlier sent me, nor did Mr Mann's letter name any Members as being the subject of a complaint by him arising from the material.

I was surprised therefore to be telephoned last week by Mr Green to be told that Mr Mann had written to all the members of the Parliamentary Mainstream Board saying that he had made a complaint about them to me. I enclose a copy of his letter to this effect to Mr Green.

I have since spoken to Mr Mann, who has apologised for the lack of clarity in his letter to me of 11 January. He has also sent me again a copy of the material he had earlier sent me. In my telephone conversation with him, he referred to what he believed to be a fundraising dinner held by your Club in 1 Parliament Street on 31 October 2006, although there is no reference to this in the enclosed documents.

In the light of all that has happened (and I apologise for boring you with the story), I think it right to alert you to Mr Mann's complaint and to give you the opportunity to reply to the allegation which is being made about the "Conservative Mainstream" Patrons' Club. In effect, I understand Mr Mann to be alleging that your Club has, with the assistance of Conservative Members who have booked the facilities used, been making use of the House's dining facilities to raise money for "Conservative Mainstream", contrary to paragraph 5.1 of the Banqueting Regulations. The Club may also, it is alleged, have encouraged new members to join by reference to social events held in the House (contrary to paragraph 5.3).

I should be grateful to receive your response to this allegation. In that connection it would be helpful to know:

1.  how many members the Club has currently and what is the present level of membership subscription

2.  what is the relationship between the Club and the Board of "Parliamentary Mainstream"

3.  how the Club goes about raising funds for "Conservative Mainstream" and any other associated bodies

4.  whether the Club has ever used the prospect of social events in the House to attract new members

5.  how many meetings the Club has held in respectively, the Commons and the Lords; how those were funded; and whether any of these (particularly any meetings in the Commons) had a fundraising purpose.

I am enclosing a note which briefly sets out the procedure I follow when investigating complaints and am copying this letter and enclosures to Mr Green and Ms [H]. If you or they want a word, please do not hesitate to get in touch.

As I am now engaged in preparing a report to the Committee on Standards and Privileges about the complaint by Mr Mann and Mr Jones, I should very much appreciate an early reply.

2 February 2007

78.  Letter to the Commissioner from Mr Richard Pullen and Mr Damian Green, 6 February 2007

Thank you for your letter of 2nd February concerning Conservative Mainstream and the Mainstream Patrons Club.

We are happy to provide answers to your questions (the numbers relate to the numbers in your letter) as follows:

1.   The Mainstream Patrons' Club has approximately 40 members. The subscription is £300 per annum.

2.  The Patrons' Club was set up to support three groups: The Tory Reform Group, Parliamentary Mainstream and the Conservative Group for Europe. It makes donations to each of these groups. Parliamentary Mainstream is an informal grouping of Conservative Parliamentarians and candidates, which discusses policy on a regular basis. Its Board consists of MPs, whose role is to direct the policy discussions and publications which flow from them.

3.  The Mainstream Patrons' Club offers each member, with a guest, two functions a year: one dinner and one champagne reception. The profit is shared between the three groups above. In 2006 each group received £4,100 from the Patrons' Club.

4.  The Mainstream Patrons' Club has never used the prospect of social events in the House of Commons to attract new members.

5.  The Mainstream Patrons' Club has held no meetings or functions in the House of Commons. One dinner was held in the House of Lords in 2002. This, in common with all other events held by the Patrons' Club, was funded by members' subscriptions. Attendees paid no separate amount to attend this event. We have removed the reference to the dinner in the House of Lords from our website to ensure that in future there is no opportunity for drawing the conclusion that we are using events in the Palace of Westminster to recruit members.

In addition to the answers above, I would like to offer the following information which you may find helpful.

You refer in your letter to the dinner held on 31st October. This was in fact held in Dining Room B, not 1 Parliament Street and was a Parliamentary Mainstream dinner, not a Mainstream Patrons' Club dinner It was attended solely by Members of Parliament who were each asked to pay a sum which was intended merely to cover the cost of their dinner. It was therefore neither a fundraising event nor one designed to increase membership.

Parliamentary Mainstream regularly holds lunches in the House of Commons primarily for Parliamentarians. The lunches are attended by members of both Houses. Others who attend tend to be those who have stood for parliament, or intend to stand and former parliamentarians. The lunches offer an opportunity for political discussion on a topic of current interest. No charge is made for these sandwich lunches and Parliamentary Mainstream is not a membership organisation. Therefore these lunches are also neither fundraising events nor designed to increase membership.

If you require further clarification on any point, or any further information please do not hesitate to contact us.

6 February 2007

79.  Letter to Ms Julie Kirkbride from the Commissioner, 12 February 2007

As you may be aware, I have received a series of complaints from John Mann MP and Kevan Jones MP about alleged misuse by Conservative Members of the dining facilities at the House for the purposes of party fundraising.

Mr Mann came to see me on 7 February to express concern about two related matters. One of these was prompted by sight he had had of the report and accounts of the Bromsgrove Conservative Association for the year ended 31 December 2005. I enclose a copy of these, for ease of reference.

Mr Mann's concern had been stimulated by the section on fundraising on page 7 of the enclosed document. This states:

"The Association runs a number of fundraising activities directly as well as through the Branches and the Member of Parliament. These activities include:

Visits to the Houses of Parliament."

Mr Mann's concern is that the facilities of the House and access to the House should not be charged for and used to raise funds for any political party. He said that he did not wish to make a formal complaint about you and the Bromsgrove Association because it was not clear from the brief reference in the enclosed document whether or not, for example, the visits to Parliament had themselves been deliberately charged for in a way which had generated a profit to the Association or whether any funds generated had been generated incidentally (e.g. through a raffle held in association with the event). However, he was concerned that the facts be established and that, as a result, the limit of what is or is not permissible in this area should be made clear.

As you will appreciate, the basic principle is that the Parliamentary estate is provided for Parliamentary purposes. Clearly one aspect of a Member's Parliamentary role is the meeting and greeting there of constituents, whether party supporters or not. And the House as a whole is concerned to maximise engagement with the public and access to the House for this purpose.

The facilities of the House (including its catering facilities) are not, however, provided to enable direct financial or material gain by any person, business or political party. And paragraph 14 of the Code of Conduct for Members provides:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

I am writing therefore, in the light of Mr Mann's approach to me, to ask you to explain the background to the reference in the Bromsgrove Association's report and accounts to "Visits to the Houses of Parliament" as a fundraising activity by the Association. In particular it would be helpful to me to know:

1.  How many such visits have taken place in the last 5 years and how many people have been involved in them.

2.  What has been the nature of/programme for the visits.

3.  How have they been charged for and funded.

4.  What contribution have they made to the Association's fundraising over the 5 year period.

I am enclosing a copy of a note I send all Members who are the subject of inquiries by me. I am also copying this letter to the Serjeant at Arms and the Director of Catering Services in view of their potential interest in this matter.

If you would like a word about the issue raised by Mr Mann, please do not hesitate to ring me. I should add that I am trying to conclude consideration of the various matters raised by Mr Mann reasonably speedily, in the interests of all concerned. Whilst I appreciate that this letter will reach you in the recess, I shall be grateful if, once the House has resumed, you can respond to it as soon as you are able to do so.

12 February 2007

80.  Letter to the Commissioner from Ms Julie Kirkbride, 19 February 2007

Thank you for your letter setting out the queries raised by Mr Mann. I have to say that I hope his researches took him a great deal of time and effort as he will be sorely disappointed by the facts.

As you wanted a quick response I shall do so from memory. I think two trips have been organised by my Association to the House of Commons in the last five years—although it just might be three, I doubt whether we keep diary records over that length of time.

Clearly, I am very keen to engage all my constituents in the parliamentary process and even more so those who volunteer to give me an annual financial contribution towards keeping democracy in Britain alive.

As such, and in return for the organisation of the coach and any other activities outside Parliament undertaken by the group when they get to London, my Association charge a set fee. I normally also buy a bottle of whisky and have it signed by the party leader (depending on who it is at the time) which also raises a tidy sum in the coach raffle.

As to when they arrive, I like to take a party (booked in through the proper channels) on a tour, as does my husband, so that my party workers might see the more intimate side of an MP's life. If I can, I also book the Jubilee Room for a sandwich lunch which we get catered by outside organisations in Bromsgrove and bring with us—as that way it keeps the costs of the day-out down to a modest amount. Clearly, in deciding that amount—which I think was around £35 per person last time—real costs of the coach and food, my office manager's time and a perfectly reasonable expectation among my Association members that the trip would raise a little cash too were factored in.

As to the amount of profit made at these events, it would amount to a few hundred pounds, which is a tiny proportion of my overall fundraising, all of which is recorded and published by the proper channels. I have to say that given the overall effort involved in bringing a coach party to London versus the amount of money it perfectly properly raises without infringing any rules of the House, my staff in Bromsgrove are not chomping at the bit to set a date for the next!

I hope that is helpful but please do not hesitate to get back to me if you need any further clarification.

19 February 2007

81.  Letter to the Commissioner from Ms Julie Kirkbride, 13 March 2007

Thank you for the courtesy of returning my call. I appreciate the chance to put some of the further points I made in writing.

Can I begin by saying that I strongly object to any inference that organising a trip to visit the Houses of Parliament by my constituency office should constitute a breach of the rules of the use of the House.

I note the comments of the Sergeant at Arms, but surely as Honourable Members, a question of proportion and intention to break the spirit of the rules should be applied?

I fear that sometimes the servants of the House who are not elected lose sight of the point of it all. My party members—and sympathisers—want to come and see the House and share in an insight of my work here. It is that interest and that sense of public duty that propels them to give the Association an annual fee and tramp the streets of Bromsgrove at election time to offer the public a democratic choice. They would be aggrieved if in organising a trip like this we didn't use the occasion to raise a modest sum for party funds.

The question of 'modest' is clearly one of judgement. But surely we can rely on Members to act within the spirit of the rules and not to have to be subjected to the naughty schoolboy approach of the Sergeant who believes it would be 'difficult to draw a line'.

The fact is that most of the money raised on such a trip is in the coach raffle. The rest of the 'profit' made could easily be dubbed a payment for the person in my office who did the organisation. But who is to decide what these relevant sums are if not the Member?

I have a trip organised by the local WI coming to Parliament in the summer. I strongly suspect that the organisers will make a modest 'profit' out of this trip to help towards their funds. Does it not seem ridiculous that while the rules of the House would have no problem with outside organisations raising funds by a visit, we might have an issue with a similar trip organised by the Bromsgrove Conservative Association? If, however, my Association made a profit from organising a trip to Buckingham Palace instead, there would be no problem!

Surely we have to use a test of common sense and reasonableness in assessing rules for the use of Parliament as in no way do I accept that I was breaking the rules or the spirit of the rules. Quite the contrary, I believe I was acting honourably in seeking to help share the experience of the Houses of Parliament with my constituents in Bromsgrove.

It goes without saying that I offer hospitality and organise trips for a great many of my constituents who make their own way to Westminster and I welcome their visit. It would, however, be a great shame if an innocent and perfectly reasonable way of encouraging more people to share in the experience of the House were banned due to a determination to apply pettifogging rules in a disproportionate fashion.

I very much hope that I can rely on your judgement to agree.

13 March 2007

82.  Letter to the Commissioner from Rt Hon the Lord Hunt of Wirral, 11 December 2006

Thank you for your letter of 7 December, although I have not had any notification from John Mann MP or Kevan Jones MP that they are making any complaint against me.

In any event, I did not entertain the Club to lunch in the House of Lords this summer and I have written to Wirral West Conservatives asking them to correct their website.

I did, however, host a luncheon for retired Conservative agents on Monday, 4 July 2005 in the Cholmondeley Room, but this event, nor any other I have hosted, was not for the "direct financial or material gain by a … political party". I would be grateful if I could please have a copy of the complaint which has been made against me.

As you have been in touch with Lord Woolf, I am sending a copy of this letter to him.

11 December 2006

83.  Letter to Rt Hon the Lord Hunt of Wirral from the Chairman of the Wirral West Patrons' Club, 22 December 2006

I understand that a complaint has been made against you alleging that you have tried to raise money for party funds by offering Members the opportunity to dine in the Houses of Parliament in return for an inflated membership subscription to our Patron's Club. Furthermore, that you entertained our Patrons to a splendid lunch in the House of Lords this summer.

First, may I say how much we appreciate the way in which you have maintained close contact with Wirral West Conservatives and the Patrons Club, which you started 20 years ago. I would however point out that there was an error on the old website, and I confirm that you did not entertain us to lunch at the House of Lords this year. Having been Chairman of the Patrons' Club since its inception, I would like to stress that on every occasion that we have arranged visits to the Houses of Parliament, the costs of any facilities have been paid for by Wirral West Conservative Association. No facilities in either House have ever been used for 'direct financial or material gain by the Conservative Party'.

I do hope this will enable you to respond to the complaint, which has been made against you, but please do let me know if you need any further information.

22 December 2006


 
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