Sir John Butterfill, Mr Stephen Byers, Ms Patricia Hewitt, Mr Geoff Hoon, Mr Richard Caborn and Mr Adam Ingram - Standards and Privileges Committee Contents

6  Rt Hon Adam Ingram

138.  Letter to Rt Hon Adam Ingram MP from the Commissioner, 31 March 2010

I would welcome your help on a complaint I have received from Mr Greg Hands MP about your conduct in respect of an interview you gave to an undercover reporter, in respect of an alleged possible appointment.

I attach the complainant's letter of 28 March inasmuch as it affects the complaint against you.[606] I know you will have seen the Sunday Times report of 28 March[607] on which this complaint is based.

In essence, the complaint is that you may have been engaged in lobbying activities in a way which is contrary to the rules of the House; that your conduct during an interview with a person who subsequently revealed herself as a journalist was contrary to the rules; that that conduct was not such as to maintain or strengthen the public's trust in the integrity of Parliament; and that it brought the House of Commons into disrepute.

The Code of Conduct for Members of Parliament provides the following rules of Conduct:

"9. Members shall base their conduct on a consideration of the public interest, avoid conflict between personal interest and the public interest and resolve any conflict between the two, at once, and in favour of the public interest.

10. No Member shall act as a paid advocate in any proceeding of the House.

11. The acceptance by a Member of a bribe to influence his or her conduct as a Member, including any fee, compensation or reward in connection with the promotion of, or opposition to, any Bill, Motion, or other matter submitted, or intended to be submitted to the House, or to any Committee of the House, is contrary to the law of Parliament.

12. In any activities with, or on behalf of, an organisation with which a Member has a financial relationship, including activities which may not be a matter of public record such as informal meetings and functions, he or she must always bear in mind the need to be open and frank with Ministers, Members and officials.

13. Members must bear in mind that information which they receive in confidence in the course of their parliamentary duties should be used only in connection with those duties, and that such information must never be used for the purpose of financial gain.

[...]

15. Members shall at all times conduct themselves in a manner which will tend to maintain and strengthen the public's trust and confidence in the integrity of Parliament and never undertake any action which would bring the House of Commons, or its Members generally, into disrepute."

The Code provides also in respect of the registration and declaration of interests as follows:

"16. Members shall fulfil conscientiously the requirements of the House in respect of the registration of interests in the Register of Members' Interests and shall always draw attention to any relevant interest in any proceeding of the House or its Committees, or in any communications with Ministers, Government Departments or Executive Agencies."

The Guide to the Rules sets out categories of registrable interests including Category 2 as follows:

"Remunerated employment, office, profession, etc: Employment, office, trade, profession or vocation (apart from membership of the House or ministerial office) which is remunerated or in which the Member has any financial interest. Membership of Lloyd's should be registered under this Category."

The rules in relation to Category 2 set out in the Guide for 2005 (which may be the one most relevant to this part of the complaint) include the following in paragraph 19:

"All employment outside the House and any sources of remuneration which do not fall clearly within any other Category should be registered here if the value of the remuneration exceeds 1 per cent of the current parliamentary salary. When registering employment, Members should not simply state the employer company and the nature of its business, but should also indicate the nature of the post which they hold in the company or the services for which the company remunerates them. Members who have paid posts as consultants or advisers should indicate the nature of the consultancy, for example 'management consultant', 'legal adviser', 'parliamentary and public affairs consultant'."

The Guide to the Rules also sets out the requirements where a Member has an agreement for the provision of services in his or her capacity as a Member of Parliament. It includes the following:

"Any Member proposing to enter into an agreement which involves the provision of services in his capacity as a Member of Parliament shall conclude such an agreement only if it conforms to the Resolution of the House of 6th November 1995 relating to Conduct of Members; and a full copy of any such agreement including the fees or benefits payable in bands of: up to £5,000, £5,001-£10,000, and thereafter in bands of £5,000, shall be deposited with the Parliamentary Commissioner for Standards at the same time as it is registered in the Register of Members' Interests and made available for inspection and reproduction by the public."

More detailed provisions are set out in paragraph 49 to 54 of the 2005 guide.

Section 2 of the 2005 Guide deals with the Declaration of Members' Interests. You may wish to read this in full. Paragraph 55 of the 2005 Guide provides as follows:

"In 1974 the House replaced a long standing convention with a rule that any relevant pecuniary interest or benefit of whatever nature, whether direct or indirect, should be declared in debate, or other proceeding. The same rule places a duty on Members to disclose to Ministers, or servants of the Crown, all relevant interests. The term 'servants of the Crown' should be interpreted as applying to the staff of executive agencies as well as to all staff employed in government departments."

The rules in relation to lobbying for reward or consideration are set out in section 3 of the Guide. You will wish to read this in full.

Paragraph 72 of the 2005 Guide provides as follows:

"This Resolution prohibits paid advocacy. It is wholly incompatible with the rule that any Member should take payment for speaking in the House. Nor may a Member, for payment, vote, ask a Parliamentary Question, table a Motion, introduce a Bill or table or move an Amendment to a Motion or Bill or urge colleagues or Ministers to do so."

Paragraph 73 provides:

"The Resolution does not prevent a Member from holding a remunerated outside interest as a director, consultant, or adviser, or in any other capacity, whether or not such interests are related to membership of the House. Nor does it prevent a Member from being sponsored by a trade union or any other organisation, or holding any other registrable interest, or from receiving hospitality in the course of his or her parliamentary duties whether in the United Kingdom or abroad."

I would welcome your comments on the allegations made against you in the light of this summary of the rules. In particular, it would be helpful if you could:

1. Give me a full account of the circumstances in which you came to be interviewed by someone who subsequently revealed himself to be a journalist;

2. Confirm what you are reported to have said during that interview, and whether each such statement is true in particular in relation to the following:

a. That you said, "There's going to be a lot of ex-Ministers … and they then become a point of contact in the political network. 'Who do you know in that Department? Who can you suggest to talk to?' And that becomes a point of contact. So all of that can be established.", and if true, what you meant in apparently suggesting a network of former Ministers who could be used to arrange contacts;

b. That you said, "It's worthwhile sometimes cultivating a Minister … but decision-makers really … are the civil service structure, because they do all the definitions of how you're going to deliver on a particular project. They draw up invitations to tender, they then make all the recommendations which may not cross the Minister's desk.", and that you said that you had good contacts with civil servants from your time as a Minister; and if true, what you had in mind in making this statement; if you have ever had contacts with civil servants on behalf of a client; and if so, what were the circumstances and whether you declared your interest;

c. That you were helping to put together a consortium to bid for work that the Ministry of Defence outsources to private companies; and if true, whether you have been paid for these services and whether they involve you in contacts with Ministers or civil servants and, if so, what the circumstances were and whether you declared an interest;

d. That you have been involved in two British firms which were helping to create a defence academy in Libya, and if true, what were the circumstances, whether you were paid or expect to be paid for these services, and whether they involved you in meetings with Ministers or civil servants on behalf of the clients, and if so, what were the circumstances and whether you declared your interest;

e. Whether you arranged for another firm to supply the Libyan academy's teachers, and if so, what were the circumstances, whether you were paid for these services, whether they involved meetings with Ministers and civil servants on behalf of your client, and if so, whether you declared an interest;

f. That you said that you were paid £1,500 a day for your consultancy work, and if so, what payments you have received from your clients at this level and whether you registered all of those payments.

3. Confirm what subsequent communications you or your legal advisers had with the reporters;

4. Confirm, if any of the allegations are true, whether you considered you had an obligation to make a Register entry or declaration, or both, in respect of any financial interest you had in these alleged activities; and what action you took accordingly.

5. Confirm, if any of what you said was untrue, why you spoke as you did.

Any other points you may wish to make to help me with this inquiry would, of course, be most welcome.

I am writing to the Channel 4 programme makers to invite them to let me have your full interview and, if they do so, I may need to ask you about further points.

I would be grateful for a response to this letter by the end of April. You will appreciate, I know, that we are now very close to the Dissolution of Parliament. I do not expect, therefore, to be able to conclude this inquiry before then. I will, however, resume it once Parliament has been re-established and I know I will be able to look to you for cooperation on this after you have left the House.

I enclose a note which sets out the procedure I follow. If you would like a word about any of this please contact me at the House.

I look forward to your help on this matter.

31 March 2010

139.  Letter to Rt Hon Adam Ingram from the Commissioner, 2 June 2010

I have now received a certified transcript of your interview and of your telephone conversation on 1 March with the undercover reporter which, as you know, is the subject of this complaint.

I enclose a copy of the certified transcript of your telephone conversation and of your interview with the undercover reporter. This material is confidential to my inquiry and subject to parliamentary privilege. If it were disclosed to anyone else during the course of my inquiries, that would, as you know, be a contempt of the House. I would be grateful, therefore, if you did not disclose these transcripts further or use them for any other purpose.

When we spoke on the telephone on 6 April, you said that you would like to receive a copy of this transcript before responding to my letter to you of 31 March. I said in that letter that I might need to ask you about further points as a result of seeing the transcript.

The further points I would like to ask you about are:

1.  If you could let me have a list of the companies which in 2009-10 you worked for, and confirmation that these were fully registered in the Register of Members' Financial Interests;

2.  On page 22 of the transcript, you refer to your work for EDS. You say that "my arrangement with them is that I would only do work on an MP and then it would probably come to the end of the arrangement." You suggest that you were meeting the "new people" shortly to talk through whether they wanted you to continue. Could you let me know why you expected to stop this work once you were no longer a Member of Parliament? Was that appointment linked to your membership of the House? If so, can you confirm that you took the appropriate steps in registering that in the Register of Members' Financial Interests?

3.  You discussed from pages 31 to 34 identifying former civil servants who, I assume, might join the proposed advisory board. Could you briefly explain how, as a Member of Parliament, you maintained your relationships with civil servants, and whether you did so in order to recommend them for future employment opportunities once they had left the civil service?

4.  Pages 46 and 47 record that you confirmed that you would work with the company to help them develop relationships with Ministers and civil servants. Could you explain briefly what you had in mind in making that undertaking?

5.  Pages 54 and 55 record your comment that you would be talking to a Conservative colleague who you believed was likely to become the Defence Minister in a future Conservative administration. Could you let me know whether the implication of that was that you would use that contact to the benefit of a company which might employ you on its advisory board?

6.  Finally, could you confirm the date of your interview?

I would be very grateful if you could respond to these points at the same time as you respond to the points in my letter to you of 31 March.

I would also welcome any points you may wish to draw to my attention from the transcript in terms of the context and the specific statements which you made at the time.

It would be most helpful if you could let me have a response to this letter by the end of this month. Thank you for your help.

2 June 2010

140.  Dispatches 'Politicians for Hire'—Transcript of Telephone Conversation with Rt Hon Adam Ingram MP on 1 March 2010

Telephone conversation between [reporter], under the name Claire Websters ("CW") and Adam Ingram ("AI")

CW is calling AI
AI	Hello.
CW	Hello.
AI	Hello. Claire?
CW	Yes, hello, is that Adam Ingram MP?
AI	It is, yeah. Claire, I'm actually, I'm driving at the moment but I'm hands free so it's OK.
CW	OK that's good [laughs]. I'm sorry I missed you on Friday. I ended up being in meetings for the whole day practically. So I'm sorry I couldn't talk then. The reason I left a message in your constituency office is we're an American company and I've just set up our London office and one of the things I'm looking to do over the next couple of months is er, set up an advisory board for our company, we're a communications company really...
AI	OK.
CW	...but what we are looking for is a number of people who can give us advice on what we should be doing in the UK and how we should be expanding and also give our clients some advice as well. So, our companies range from kind of health care companies through to, I don't know, Middle East investors really and defence companies as well...
AI	OK.
CW	...and I just wondered if this is the kind of thing you'd be interested in doing.
AI	(...INAUDIBLE...) more than happy to talk to you. I'm doing work with number of companies at the moment and I don't think there are any conflicts of interest but we'd have to talk through all of that.
CW	Yes of course yes.
AI	Yeah, yeah.
CW	Well maybe the thing to do I don't know whether you might want to pop to my office for a cup of tea or coffee one day?
AI	Yeah, I'd love to do that. I tell you, I mean, I'm down in London thisweek. You of course know I'm standing down from Parliament. Are you aware of that?
CW	Yes I am aware of that. I don't see that that would be a problem.
AI	No, actually I think it's a better position to be in because I think there's much more of an issue now with serving members of Parliament having outside interests.
CW	Right. OK.
AI	And my sense of this is that it can detract from what companies are trying to achieve.
CW	Mmm.
AI	Because there's a kind of negative reaction er if you're lobbying people think even though you're not. We could talk through some of that sort of stuff. What sector are you in? What do you do?
CW	We do, we're kind of a very broad communications kind of company really, so we help our clients with a number of things. Sometimes it's dealing with press but also it's advising them on investments they might want to get involved in. I suppose what they call it in America is a kind of bespoke consultancy, which kind of means we do everything. [laughs]
AI	I understand, anything, anything goes. [laughs]
CW	Exactly! [laughs]. So what's your availability this week if you're in London?
AI	Well I don't have my diary at the moment.
CW	Of course, yeah.
AI	The best thing is er, if I give you, I'll be back in my office in my constituency in maybe about a couple of hours.
CW	Yeah fine.
AI	I'll give you a call back and we can then arrange something for next week if that's possible?
CW	That sounds like a great idea.
AI	Where are you located? Where's your base?
CW	St James's Square.
AI	Alright, OK, well that's very handy. OK.
CW	OK brilliant. Well I'll speak to you later today then.
AI	That's great. Thanks very much. OK.
CW	Have a nice morning.
AI	You as well. Bye.
CW	Bye.
[There is a subsequent telephone conversation later that day in which the meeting is arranged.]

141.  Dispatches 'Politicians for Hire'—Transcript of Rt Hon Adam Ingram MP meeting, 9 or 10 March 2010

Audio file M2U00150
		Chat and moving around, getting tea and coffee from 00:00:00 to 00:19:00.
AI	00:19:24	Are you, do you occupy all of this building?
CW		No, unfortunately not the whole building, just a floor upstairs. At the moment we actually we've got um, a smaller office base but we're...
[Chat about tea]
AI	00:20:11	So how long have you been here?
CW		Not very long actually um, I think as I said on the phone we're an American company. Er my job is to kind of open up the London office which I've just done in the last er month or so.
AI		Wonderful.
CW	00:20:23	Err, yeah, it's going well. It's a great location actually, a nice kind of place to be. It's really, really central um and one of the things I'm looking to do over the next couple of months is set up an advisory board for Alice and Perry and also our clients. Um and also I want to take on a couple of consultants um, presume I would guess on a retainer kind of basis um to do more specific work for um some of our clients. Sorry, I'm just going to tip that out.
AI		Have you got your client base established and that?
CW	00:20:50	Yes we have and though, you know, you should always be trying to expand, I think. Um, so most of our clients are in the States or in the Middle East, though we have err one or two in Asia. And their kind of interests vary.
AI		OK.
CW	00:21:14	So, um, we have one that's a, a health company that does kind of elderly care in the States and they're looking to expand in the UK. And we also look after a defence company in the States and they make chassis for MPVs. Um, so yeah, they, we're involved in that. And of course, they're looking to expand in um the UK too as are er an organisation we represent in Singapore, they're involved in kind of mending um aircraft. So, they kind of have world, worldwide interest.
AI	00:21:35	Is it engines or fuel?
CW		Yes, engines yeah. So, quite kind of technical work on something actually I know very little about, the kind of nitty gritty of, though obviously, I know about the company. Um, and so really I just wanted to speak to you to find out what kind of thing you might be interested in doing, what you've been doing before and just really see if we could make something work.
AI		OK.
CW		Um, I'm looking for about four to six people for the
	00:21:57	advisory board and of course a chair. Um, I don't know if that's a role you might be interested in or not.
AI	00:22:28	No I would probably be interested in it. I don't want to be with my background, my background well, for 23 years I've been a Member of Parliament, um. For all that kind I've been in the the forefront of politics. Er I worked in the early days with Neil Kinnock in the build up to the, the 1992 election, I was one of his key people. And we didn't win that election. Er, yeah, I did some stuff on Trade and Industry, I decided not to go on the front bench because I, I had, had very little back bench experience.
CW	00:22:35	Right.
AI		You familiar with the background of Parliament?
CW		Yes I am, though my background is more PR so I'm kind of not well versed.
AI	00:23:02	Well, back benchers speaks obviously to back benchers you're, you're not front bench about policy. And then it was all Trade and Industry stuff and it was on airspace and energy, energy policy which was one my big areas of interest. And the whole of err such of airspace and space was another area, we did two big studies into that as a Select Committee and I was very happy doing that. And then, but then we looked at the party and John Smith said he wanted to put me on the front bench er and I said "okay, you're going to give me something I know nothing about", to which he said "yes", er I said "you're going to give me social security?", he said "yes". I said "you're a bastard". And he said "well, er I've got to tell you you're the only person that's sworn at me when I'm promoting them". I said "I know nothing about this", he said "well, that's why I'm doing it" because I'm a fresh mind. And so it was, it was pension policy, it was all on the back of the Maxwell scandal.
CW		Oh right.
AI	00:23:41	And the bigger pension Bill of 1993 I believe. And er, and also the Child Support Agency so there was two big issues that I was asked to do and terrific bruising jobs as well. Er and then John Smith died. Tony Blair then asked me to take on the Science and Technology role. Er so I wrote er, I wrote the party policy for science. I'm not a scientist, I'm a technician I'm a technologist err but again it's logical thinking it's define the problem.
CW		Yeah.
AI	00:24:13 00:24:36	Somebody else could give the best answers then you can, you can knit it together. Er so, I did the science policy and the anticipation was that we moved into to win the election in 97 to move into the Trade and Industry side. And energy was a big (...INAUDIBLE...) factor, it was the thing I had a heavy interest in. Er but Tony Blair decided not to do that. He put me in Northern Ireland as security Minister. But I was also an Economy Minister there, and that was
CW		In Northern Ireland?
AI	00:25:07 00:25:48 00:26:08 00:26:44 00:27:22 00:28:03	In Northern Ireland, during the peace process, I was part of the peace process, all those negotiations, and err I, I, took a number of portfolios as a (...INAUDIBLE...) Minister err so I mean, I put higher my education and other things as well, it took me 8 months. My main job was security err as senior Minister and Secretary of State and also the economy er, there's a long story to that, I managed to put two portfolios, against all the advice and I said these two have to run together. You can't you can't have picking up the (...INAUDIBLE...) without stable security and good economic development helps (...INAUDIBLE...) state security. Something occasional, I can't do it, it's in the system, I said well I'm doing it and that's it er and I did it very, I think very successfully er. And it was a good time because the economy was growing (...INAUDIBLE...) the east coast but not exclusively so I, I had a quite heavy industry er interface as well as doing my main job of security. And then Tony Blaire put me in after that, er after four years, er into the Armed Forces, as Armed Forces Minister err. And that was a job I was so suited for because of my past. I didn't think we were going to Iraq and Afghanistan and all the rest of it and that was a massive portfolio as well as having two wars out there to attend to. I was heading up as Minster, um, the way, the way the department was structured then, the Secretary of State, you had me as senior Minister and two junior ministers. And er, I was the kind of the capability Minister so your (...INAUDIBLE...) I took a lot of stuff out and gave it to another Minister so he became the kind of welfare Minister, personnel, pay clashes and another one was procurement and I had the capability I, sort of tried to knit this together but I always had the responsibility for a very big bit of the delivery of defence as well as the whole Armed Forces stuff er. (...INAUDIBLE...) It was then called the Defence Logistics Organisation which had a six billion pound budget with a hundred thousand people and during that period we made some very fundamental changes to structure. We drove, we drove probably globally in excess of two hundred (...INAUDIBLE...) pounds out of the cost base by just taking some very tough choices. And er on the basis of how you can drive down the cost base (...INAUDIBLE...) was entertained as defence expenditure. So, I had ten years of ministerial roles, I've been very heavy and very committed. It's given me a big breadth of experience. Currently I've got Directorships in a number of places, I can talk to you about that, and I'm doing a lot of work still within the defence sector er I had a two day secret exercise, at a very top level last week um, where they do this, it's called an experiment, it's like a scenario and you take the scenario. You take a hostile um situation and then you, you learn to problem solve and so if you're only three or four star, an attorney general is a three star and a full general is four star, an admiral is four star.so it was full of threes and fours and two stars (...INAUDIBLE...) RAF and the Navy and senior civil servants and security personnel as well and it was all about problems with you, problem solving, and my role was just to say just remember who makes decisions in Government? It's ministers, it's not you delivery agents, it's Ministers who decide it. Er so I'm used to work on that basis.
CW	00:28:33	And were you doing that as an MP or a Minister?
AI		I am still an MP. I'm standing down at the next election but they just call up on me because of my expertise
CW		Because of your expertise.
AI	00:28:42	It's because of my expertise plus I'm a straight talker, a logical thinker, I think. Er a big breadth of knowledge nobody's an expert err you know, everyone's got different expertise. I do stuff at Kings College. I lecture at Kings College to PhD students.
CW		In the war studies department?
AI		In the war studies department.
CW	00:29:03	I went to Kings College, you see so I.
AI		It's a great, it's a great college.
Male		Did you do (...INAUDIBLE...)?
CW		I didn't, I did English.
AI		You did English.
CW	00:29:11	Slightly different.
AI	00:29:33	Again, that's because I did work, when I stood down as a Minister in 2007, the Prime Minister asked me to do a major study into Defence's contribution to counter terrorism and, and a result they actually said (...(...INAUDIBLE...).... I said you've got to look at resilience as well you've got to look at the effects of terrorism and, and what goes on overseas (...INAUDIBLE...) one study err resourced by the Minister of Defence, quite a powerful report err which was then presented to the Prime Minster, it's a secret report, that touched on quite sensitive areas. And I'm just currently doing a wrap up I said "if you want me to do that, and you will need an audit. I'll give you a year to implement, don't tell me to do the report and then put it on the shelf." Err And everyone said it's a great report, I said I'm coming back in a year's time to check.
CW	00:30:03	Yeah, what to check that they'd done it?
AI		Yeah, so I am currently doing an audit and er I'm doing a wrap up so I've just got to see senior people in the Foreign Office and some in civil contingency (?). I need to get the report published, not published but presented to the Prime Minister.
CW	00:30:20	Oh that's very exciting.
AI		So, I will have a I've been kept extremely busy as well as, and the industry err jobs I've taken on err mainly in homeland security from the terror.
CW		Yeah.
AI		Yeah OK err, of which there's a lot of training in counter IEDs, improvised explosive devices err we have there which provides one of the places.
Audio file M2U00151
AI	00:00:00	A big facility in the RAF base in Wiltshire and, err, we train in Afghanistan, we train in North Africa, we train a lot of people here. It's like a fledgling company, it's suffering cash flow problems at the moment because a huge amount of business we're waiting on have been paying all these wages and it's pretty hand to mouth stuff at the moment.
CW	00:00:22	How long have you been doing um?
AI	00:00:23	Well, I am I director, that's about a year and a half, two years and then for the other company which has a big interest in Libya and that, you, they asked me to engage with them because it was to do with the building of a defence academy and we've a big defence academy in the UK, one of the best in the world. And, um, err, the idea was Gaddafi wanted a defence academy built and people I'm with have got very good points of contact in the Libyan regime, err, at the good end, good end and bad end of Libya and we're working with the good end, the foremost, because it's absolute—Libya is absolutely strategic to the UK, they are just fundamentally strategic.
CW	00:01:08	Is it? In what way?
AI	00:01:10	Well, because it's, because of its, its oil and gas base, but also because, it, one of the, one of the effects of the Iraq war, one of the reported effects, nobody's ever, nobody had really takes this on board was that that Gaddafi, when he saw the Iraq conflict happen and the basis upon which we went to that Iraq conflict on WMD, he was actually doing it as well. He then made contact through his people with our security forces and security apparatus, err, he then opened the books to all his other stuff he was doing in nuclear, what he was doing in biological, what he was doing in chemical but that's probably it.
CW	00:01:47	Yeah.
AI	00:01:48	The extent of that was not known but the headlines are, as a result of which, he then disposed of all that. He then decided to turn his country over to the people on the people, (...INAUDIBLE...) but err, and he's very volatile. And he (...INAUDIBLE...). called 'Green in the Desert' and as well as the strategic from the mainly the gas sector but also oil, there are British companies that have, British companies that have a lot of investment in that, but also in a whole lot of other things he's doing and to the tune of hundreds of millions of pounds it's a very rich country because of his, his err, his, his hydrocarbon base. And I was talking to a company the other day (...INAUDIBLE...) and they'd like to bring something like a hundred million pound project for bringing water from the south up to Tripoli.
CW	00:02:38	Oh really?
AI	00:02:39	So it's a big engineering project.
CW	00:02:40	Yeah. That's interesting.
AI	00:02:42	And, Libya looks to us, they won't look to the Americans, they're a bit iffy with every, they play, they play everyone against each other, but they're a bit iffy about the Americans, and the, the defence academy has now, this is a consortium of companies, wee companies was Arab .(...INAUDIBLE...) engineering company err, for southern engineers and that, that end of it has been put to bed, importantly we have been paid, so everyone in that consortium is cash rich.
CW		Yeah.
AI		They've been paid, ah, proper rate, ah, and now it's a question of getting the defence academy built, it's like the Turkish construction company will do it, that's all been determined and everything in the Arab world goes slow time.
CW	00:03:23	Yeah, I imagine.
AI		Get some into position(...INAUDIBLE...) and, ah, and, and once the defence academy is built, they did, have been able to get the defence academy here to become engaged with that, so we would populate it with our teaching. So that brings them in to our ambit so strategically very important, and the whole north African issue because of migration, people migration.
CW		Yeah.
AI	00:03:48	all coming through from Africa, sub-Saharan Africa is a, is a very big issue. So it's strategic. So that's, that's, ah, that's that company, and the other one, and there was another one which was in the, ah, ah, to this day I don't know why people pick up (...INAUDIBLE...), were actually offering things almost for nothing to Government on the basis that it was shared interest that, ah, and it was, it was both. The original concept, was a missing person's concept.
CW		Right.
AI	00:04:16	So the problem we have in this country is a gap, that is someone goes missing, take Madeleine McCann, to get the information out globally, well, you know, across the country is, is, ah, is difficult, ah in how do you communicate? So what we had, we have a, a particular piece of software that is able to assimilate a lot of data and then stream it and burst it down.
CW		To all different countries?
AI	00:04:43	No officially to the UK only, you burst it out to your responders and, and it, some countries don't do this, where you have screens in (...INAUDIBLE...) points of the shopping malls, you know.
CW		Train stations or?
AI	00:04:56	Well let's say a child went missing in a, in a bit of, of Manchester. And so you've all these, people standing at a bus stop, a child missing. And the Americans have a thing called Amber Alert, ah, and there's a good evidence base in this, if you get that information out, there's a very high success rate of getting that missing person.
CW		Oh really?
AI	00:05:20	Because in most cases it's not a malign missing person, it could be the, it could be the father's taken the child, the mother, that type of thing, but you still need to get that child. And, and so the emergency responders are, are ready to do that. so and we can get it to you effectively for nothing, but you've always got to do some back, background support of it, but you're, you're going to do that anyway, and we make it easier and better (...INAUDIBLE...) we will pay for the screens. How do you pay for, how do; you pay for? Very simply, you get 40% as a responder, we get 60% when we advertise on that.
CW	00:05:56	So you can advertise on the screen the rest of the time?
AI		The rest of the time it's not being used for anything.
CW		Yeah.
AI	00:06:00	And if you run (...INAUDIBLE...) the police, you've got a missing child, you've got what's called a golden key, you (...INAUDIBLE...) crash in and take that out.
CW		Yeah, crash in, take the advertising out.
AI	00:06:11 00:06:54	So simple, straightforward solution, can't get by it. And, ah, it's because the Government is very reluctant to be innovative, and what it doesn't like is people bringing solutions. It doesn't mind you saying we now need a solution, and lets go and find an answer, but if you say there, there is something you need. Now there actually is a working party and half the Government is going nowhere just looking at this issue, the missing persons issue, cos there's a, there's been a, there's a, a terrible...... it's not a treaty, a terrible European Parliament, where if so many nations sign up to, and so many parliamentarians sign up, it becomes a kind of edict, it's not, it's not by law, but it's a, it's a, it's a, it's a, a request, almost like an instruction to, to governments, and they must now, they must now begin to deliver on this objective, and they can do it in their own way.
CW		Right.
AI	00:07:00	So the working party has been set up, ah, by the Government and it's looking at, as I said, (...INAUDIBLE...) Because the emergency responders, especially police, they don't have a lot of good expertise to be able to do this, so they, they actually scare people when they.
CW		They think this would be too hard?
AI	00:07:18 00:07:58	Yeah, you scare them cos you're actually, you're, you're going beyond their level of competence. So they, so they, so they do it at a different level and it's the way they always do it (...INAUDIBLE...) encourage a bit more. So, so that, that, ah, we've kind of refocused that company a bit and, and it's been out in, in the Middle East and Abu Dhabi, ah, and it would be very hot at a point in time putting emergency systems in. But it doesn't just relate to missing persons, it can then, then adapt it to, if you're able to take a lot of data, assimilate it and then burst it out to key responders, ah, you know, so we've been doing stuff with the maritime agency out there and or course the.(...INAUDIBLE...) agency ah, and that has become a very hot potential for that kind of which has gone cold, just (...INAUDIBLE...)
CW		Isn't it?
AI	00:08:06	The sovereign funds just, we've got oodles of money, they'll say they've got to do something, yeah, it's very exciting, everyone is excited, and then they just sit there.
CW		And they kind of go off it.
AI	00:08:14	And on somewhere else. But that was, you know, so that's the kind of, the range of companies and there's another, I've been doing, I've been doing advisory work, done a lot initially, not so much recently, with the EDS, which is now part of HP, and actually just talking to them about, really just about Government relations, and what to look for in Government becomes, department (...INAUDIBLE...) there's a kind of standard way in which governments tend to operate.
CW		What do they do, EDS I think I've heard of them?
AI	00:08:46	Well EDS are computer, they do, they do all the outsourcing of, of, so they'll, they'll provide like, ah,...pay personnel and they'll do work in the health service, it's a computer based thing.
CW		Oh right.
AI	00:08:56	So it's a big operation. Instantly they want to buy a bit of, of HP, which is a massive company, but, but which is a manufacturing company, but they have a, a service company sitting alongside EDS which was massive, so they were interested in acquisition and HP said, no we'll just buy you, (...INAUDIBLE...) EDS. And, ah, they (...INAUDIBLE...) they're doing. And, ah, my arrangement with them is that I would only do work on an MP and then, um, ah, it would probably come to the end of the arrangement, however meeting the new people, I think next week or the week after, just to talk through this, whether they're wanting one to continue.
CW		Whether you might continue to be a consultant for them?
AI	00:09:37	It's not, you know, as well as, so I'm having to do that, as well as being an MP, and that, it's all about time management.
CW		Yeah.
AI		And I'm doing all that myself, there's no problem. I'm kind of moving out from being an MP.
CW		Yeah.
AI	00:09:50	I'm a drop dead (...INAUDIBLE...) because of the general election, so I'm only weeks away from it.
CW		Yeah.
AI	00:09:53	And, ah, so I've got a breadth of experience, I think I've good knowledge, I've run big departments and, and I may be of use to you.
CW		Yeah, well it does sound like you've got an amazing breadth of experience actually.
AI		How did you come across my name?
CW	00:10:07	Erm, I got one of my researchers to basically draw up a list of people, ah, that may be interested in this kind of work. I think, ah, he looked at people who had other consultancy jobs and also just spoke to people. And I would say, I don't know exactly where he got all the names from, I just ended up with a list.
AI		Okay, okay.
CW	00:10:22	So I'm pleased to say he's obviously, um, hit up on the right person, so that's always good news. In terms of your time commitment, presumably when you stand down as an MP, you'll have a little more time.
AI		Oh, (...INAUDIBLE...) that's right (?)
CW		Will you be looking to take on other, a few consultancy positions, do you think?
AI	00:10:40 00:11:13	Yeah I will be, but in the sense that, um, as I say, there are two other companies that have come to me, people who I know well, and they're two quite big projects, ah, ah, and the, but that will not happen until after, after I'm no longer an MP, because I said I'm not going to touch it till that time. Ah, one's in the energy sector, ah, ah, the other, the other one is really, ah, was going to happen to Government anyway. A lot of departments in defence, one of them will have to be going to outsource, they'll have to look where their core business is, and what their non-core business is. And they've done a lot of that anyway, so if it's not core business, it shouldn't be sitting in Government, somebody else can do that for them.
CW		So what would that be, for example?
AI	00:11:24	Well, ah, well it, it's a project that's not surfaced yet.
CW		Oh right.
AI		And the, and the main consortium is now just being put together. So it would take a big chunk of, of what a lot of civil servants do, and they've been doing it for donkeys of years in defence, but it's not really core defence business, it's just, it's in the logistics sector, you know, the detail of it. And, ah, the reality is that defence will have, will have, cos that's how they, that's how they get down their costs.
CW		Yeah, so you can save money.
AI	00:11:56 00:12:28	You can save money, but let someone else take on the risk. Ah, and then it's based upon, you're really contracting for availability. So if I want something, you're a private company, you deliver. And (...INAUDIBLE...) that's what they did is doing it the transformation in the defence logistics sector, that was a case of, ah, aircraft maintenance, it was a classic example that, why should you have all that trained people doing this, when surely you've built that aircraft, so you should maintain it. And we tell you we want, whatever it is, twenty fast jets at any point in time, your job to deliver. If you don't deliver, you take the penalty.
CW		Yeah.
AI	00:12:36	And, em, ah, we need, we need aircraft, so, so there's a mutual relationship between all of that, you've got to make sure that they've capable to deliver. But that's what cut a lot of the cost out because they're saying you've got (...INAUDIBLE...) two and a half thousand people that you no longer need.
CW		No.
AI	00:12:52	It's cruel, but necessary, because in my view the public purse is not there to keep people in employment, they serve to do best value for money.
CW		Yeah.
AI	00:13:04	So that's, that's kind of where I'm (...INAUDIBLE...) other, other than as an energy idea of people looking at, and I guess, it's to do with defence estates, the land, the defence laws and how we best utilise that, so there's a mutual benefit between the energy sector, and you've got access to large areas, large tracts of land, which you could then properly exploit, defence gets a payback and it doesn't interfere with their, with their training anywhere else.
CW		No.
AI	00:13:32	So there (...INAUDIBLE...) there's a project, I'm looking at that.
CW		That's quite interesting.
AI		(...INAUDIBLE...) just an advisor, it hasn't all been worked out yet (?)
CW		Okay.
AI		But I can handle all of that.
CW	00:13:43	Yeah good. Erm, I think for our advisory board, I think we'll probably need to assess it after six months to kind of, see how it's going. But I would envisage that for the first six months there would be a meeting maybe every other month, they may want to increase that to every month, me, so, and then of course there would be preparation to do.
AI	00:14:01	And who would, who would be, first of all, you'll be deciding on the makeup of the advisory board?
CW		Well I will be in conjunction with people in the States, so over the next week or two I'll be drawing up a shortlist of people.
AI		Okay.
CW		And then, ah, some of the directors will fly over from the states, they would like to meet with them.
AI		Yeah sure.
CW	00:14:16	And then, of course, we can, um, bring some of the clients over, or fly, um, you know.
AI		(...INAUDIBLE...)
CW	00:14:22	Yes, exactly. Well I think it's just quite nice for anyone who's on the advisory board to be meeting our clients and, you know vice versa I think that's just how it should be.
AI	00:14:29	But the job wouldn't be advising the clients necessarily?
CW		No, well a bit of both actually. I think the advisory board would be advising us, Anderson Perry, and when issues come up with particular clients, advising the clients.
AI		Going out there, yeah.
CW		Yeah, exactly. Though I think, I don't know if this is something you would be interested in, we'll certainly be looking for consultants to advise specific clients at specific times, that we would pay a retainer, um, and then they would have a daily rate, erm that we could, you know, then they would bill us and say, well actually this month, I've done five days, for this particular firm, or three, or you know, whatever.
AI	00:15:03	Okay.
CW		Just depending on the workload, and that might work for you, if you were interested in a um specific client and felt that you could help.
AI	00:15:12	Yeah, cos that's, okay, yeah ...
CW		Yeah, I think that's the best idea.
AI	00:15:15	And how, how big would the board be?
CW		I think four or six people.
AI		Four to six, yeah.
CW		Yeah, I don't think you want it to be too big.
AI		You don't want it to be too big. And who, who, you said maybe I had interest in the chairmanship. Is someone else being considered for that?
CW	00:15:28	Yes, ah, another person is, um, it's someone with a kind of finance background, me, a kind of banking background really. I think what's important across, in the board is to get quite a broad section of people, so someone from, you know, who has a very legal background, someone from a finance background, someone from a political background.
AI		Okay.
CW	00:15:46	And then we'll just kind of mix and match. I think you kind of decide on say three and then you.
AI		Any ex-civil servants in there?
CW	00:15:51	No, but no, no, that's quite a good thought. Erm I don't know, maybe you might be able to suggest some, I don't know.
AI		Well, not off the top of my head, but there are, there are some people of real good quality that, that are likely to pop out if there's a change of administration, you know, people will say, you know, I've been ten years or so with this, this administration. Although they are ostensibly neutral, ah, it, sometimes it's not a comfortable environment for them.
CW		Yeah.
AI	00:16:16	Cos, cos their new masters don't trust them basically, and wrongly, that's, that, you know always a bit of suspicion, suspicion of what you . (...INAUDIBLE...) And, and,...ah, so there are very good people, um, I could talk to people (...INAUDIBLE...)
CW	00:16:30	Do you think at permanent secretary level, or below that?
AI	00:16:33	I certainly think we'll get permanent secretary level, unless there, there are one or two potentially in there. I, I would tend to go maybe second or third tier, you know, because they tend to deliver it (?).
CW		Yes.
AI	00:16:44	It's an issue I have with general secretaries, I have crossed swords with them a few times, that I've always, it was the whole permanent secretary...when I went to Northern Ireland, took me aside and said, "Let's just understand what the working relationship is, I'm the Minister, he's the permanent secretary."
CW		Thanks.
AI	00:16:58	I says, you're the chairman and I'm the chief executive. I said well that's all very well, but I'll decide what the relationship is, I'm not going to be the chief executive, because it's not the job. Ah, we were, we were very good friends after this, but it was, don't tell me what we're going to do.
CW	00:17:15	Yeah.
AI	00:17:17	Let's just get the ground rules right. But it was good advice. I, I, I've had one or two words with permanent secretaries, just remember you're the chief executive, and what's happening in the way this department is now in defence, I'm now the chief executive, I'm dealing with all the executive decisions, I'm dealing with too many decisions, ah, and having to do all that, ah, I'm not against it, ah, in one sense, but really that's your job.
CW		Yeah.
AI	00:17:41	Your job is to manage, and my job is to sit as a chairman and...
CW		And do other things.
AI		And do other things, and drive it in particular ways. Ah, and of course, sometimes the secretaries don't see themselves as chief executives, they've come to the, come to the point in their life, where they do something else.
CW		Yeah.
AI	00:17:58	Ah, having said that, there are some very good ones. I mean I would tend to go for the lower level, you know the directorate (?) level, who really.
CW		So a director of something?
AI	00:18:08	Yeah, you know, whether it's director of policy, the, the other thing is they do tend to move around, and they, every department will move people around into different directorates, sometimes they're good at it, sometimes they're not. But they, they, they gain a big breadth of experience as they move towards becoming a permanent secretary, so the, the senior (...INAUDIBLE...) is almost the depth of the (...INAUDIBLE...) So the err I know there are some very good people about.
CW		Oh well I'd appreciate your thoughts on that, if you come across anybody that you think would be worth us approaching. But it can be a bit tricky approaching people when they're still in their job.
AI	00:18:43	Yeah, that's what I'm saying, you would, you would maybe watch people popping out of the system.
CW		Yeah.
AI	00:18:47	I don't know how much knowledge...necessarily, but, ah, me, you know, ah, it, I I just suspect it will happen. I'll also a generation thing people get to an age where they're saying, you know, I've no longer much of a career here, it's getting pretty crowded, ah, there's a thinning down at the top of the, you know, civil service and you thin down anyway, so I've come to the end of my potential era, and then they move out, because they're pension's right and they're, they're of the right age to do it. And the other the other, and other people to look at, if you've not done it, ah, some of the sea and military people.
CW		Yes.
AI	00:19:21	And, and the reason I say this is because if they're the right type of, I could put a side (...INAUDIBLE...) think I know all of them and, ah, some of them are very good strategic planners, good thinkers, and well trained in command and control, ah, and just think logically.... (...INAUDIBLE...)
CW		No, that's a very good thought.
AI	00:19:40	And also work on the basis that, ah, no, no problems too big. A problem could be, could stump you, you may fail, but you still have to win, you still have to get to the objective.
CW		Have to keep going.
AI	00:19:51	...just keep going at least I got, and these guys, these guys are of a particular mindset.
CW		Oh yes, well I'd appreciate any names in that sense as well because similarly it's not um a world I'm that familiar with, but I could probably get someone to do some research, I think, to try to (...INAUDIBLE...)
AI	00:20:04	Yeah, but it's again who's, who's coming out and there's a lot, there's a lot duffers in there but I've got some there in mind...but there's some very...Yeah, so.
CW		Yeah, well that's it, from the outside you're not necessarily sure who to go to.
AI	00:20:13	Well, you could say the man was very good (...INAUDIBLE...) very good as a manager. The best person to ask is a Serjeant Major (...INAUDIBLE...)
CW		Yes, exactly, then you can check. One thing I think we'll be looking to do it—, or how to support our clients with, would be expanding in the UK. So, for instance, err the health company or a defence company in the States, they have, or both have contracts, actually, with the relevant department in America.
AI	00:20:44	Yeah.
CW		That they'd be looking to try to speak to the various Government departments here um and just build a closer relationship with them, I suppose with the end game on hopefully winning some contracts. Is that something that you're familiar with, with your other consultant work?
AI	00:21:00	Yeah. As a Member of Parliament I can't lobby, they're very strict on that, so you can't go lobby for a company err which as non-MP you can.
CW		Yeah.
AI	00:21:13	And it's a very firm rule, and remember, you've got to sign a lot of agreements (...INAUDIBLE...)
CW		Oh do you?
AI	00:21:21	First of all, as an ex-Minister you've got to get approval, to take on a directorship, and there's a—, anything up to a two year period. So for instance, if I had been making a decision about a particular company and then I'm no longer a Minister, said I'm now I'm going to be a director of that company, only I'm not, you know, because I (...INAUDIBLE...) working for that company ... So there's usually a gap and in my case it was because I'm (...INAUDIBLE...) necessarily doing some stuff with that, and none of it abutted across, against err the or the companies I knew as a Minister , so it was like a six month period. But it could be anything up to a year, and then you have to make it very clear that you're not going to lobby, then I said, "Well, define lobby."
CW		Yeah.
AI	00:22:10	And the statement was, "You'll know it when you're doing it." ..., you know, so. Which is the...
CW		Yeah.
AI	00:22:15	And so I just don't do it, you know this, and the freedom of information question (...INAUDIBLE...), trust me about, you know, the company you're now engaged with, did they do any business with the Ministry of Defence, were contracts placed? Did any meetings take place with a Minister, and of course that's the part I know (...INAUDIBLE...), and I don't answer that, that's a department question against a lot of MPs who are—, who have business interests. So I've always played a very clean um approach, but having said that the point of contact can be quite wide and then it's just like if you are respected, people take a judgement, and set it against their own judgement, but nonetheless that's a, I value that judgement, so. And I, and I can facilitate as best I can, but there's bits of Government I know nothing about.
CW		No, of course, yeah.
AI	00:23:13	You sit within one bit of Government but you don't necessarily know all the people.
CW		Yeah.
AI	00:23:20	And it's all about personal points of contact. But the thing about that is, and this is one for the very big reality at the election, (...INAUDIBLE...) a lot of ex-ministers, many of whom are leaving Parliament entirely, some are going to lose their seats and they're become a point a contact in the political network you know, who do you know in that department, who can you, who can you suggest I talk to, and that becomes a point, that becomes a point of contact, so. So all of that can be, all of that can be established. ... it can take a bit of time to build those blocks but you begin to look beyond the, who, who's important in that...
CW		And that would be your point of contact, whoever was important, yeah.
AI	00:24:01	Go and ask their advice then and again I could...who I can trust and who I couldn't trust.
CW		Yeah, and that's something you'd be able to do once you've stood down as a MP, is it?
AI	00:24:09	Yeah.
CW		Okay. Yeah, that's useful to know.
AI	00:24:12	But I wouldn't do anything before I went, yeah, before the election. I just couldn't take anything on.
CW		Yeah. No, well that's what you said on the phone.
AI	00:24:17	But I will ...
CW		Yeah.
AI	00:24:18	I mean to have to register it err and I'm quite—, quite happy with that.
CW		Yes.
AI	00:24:22	...and probably (...INAUDIBLE...)
CW		Yeah, okay, well that's good to know. And in terms of, I kind of heard from someone here who works in public affairs that actually the people you should be speaking to are the civil servants. Is that, do you agree with that point of view?
AI	00:24:35	Definitely.
CW		Yeah.
AI	00:24:38	Ministers, Ministers are very, it's worth it, sometimes cultivating a Minister, but it depends how they react how amenable they are err but decision-makers really, well, in one big sense are, is the civil service structure, because they do all the definition of how you're going to deliver on a particular project, they draw up the invitation to tender, they then make all the recommendations, which (...INAUDIBLE...) Ministers may accept/go across a Minister's desk.
CW		Yeah.
AI	00:25:05	And Ministers can say, "I'm not happy with this," but ministers will not the (...INAUDIBLE...) and won't do the selection. They will have a recommendation and it has to be made clean, because if a Minister says, "I'm, you know, I'm not accepting this, I'm going for that company," well, you really can't because you don't, you're not carrying the, you're not carrying risk, (...INAUDIBLE...) carrying risk here. And, and, and so therefore it's exactly, that's what I'm saying (...INAUDIBLE...) that civil servants are very important as a second and third, third layer.
CW		And presumably you have good contacts with them from when you were a Minister.
AI	00:25:38	Oh yeah.
CW		And how does it work? Is the best thing to do, you know, you just kind of—, you call them up and just say, "Oh I'd like to see you about something," or, I don't know, the best way to um contact the civil service.
AI	00:25:50	Well, the reason the reason, because I've not been doing this as an MP err I've not want to state err I've not, I've not really been doing that, for obvious reasons, because really, if you do that they should record it.
CW		Oh right.
AI	00:26:05	And then, if you have therefore for my request (...INAUDIBLE...) suffers (...INAUDIBLE...) with me as a Member of Parliament that I have a business that I'm engaged in, and that's who you will be.
CW		Right, okay.
AI	00:26:15	I so, I don't know. And I know shouldn't lobby, but, yes, that's what you would do, you would, you would find a way to network and then just say, "Look, I wouldn't mind having a chat with you. Come for lunch, come for dinner." But, you know,...
CW		But would that be, if that's such an issue for you, once you've stepped down as a MP,
AI	00:26:34	No, no it's (...INAUDIBLE...)
CW		Okay.
AI	00:26:36	'Cause you're a private citizen, you're no longer, all you're doing is raising your, your, your street cred err and your points of contact. And err just trying to, you know, working for particular clients ... could be useful if—, maybe if you met, talked about things. The problem is, if there is a invitation to tender and there's a err, you know, a contract in place or whatever, they then will meet, and ministers will never meet ... companies applying for a contract. A Minister should never meet just one on one.
CW		Right.
AI	00:27:14	Definitely...
CW		So in actual fact you want to be meeting them way before bidding for contracts?
AI	00:27:20	Actually you can have, you can look at what is coming up, you know, once the, once the guys are doing a chassis for a particular type of vehicle , you know that we're finding the procurement scheme for replacement for all our vehicles, (...INAUDIBLE...) say, "You know, this is coming out." So that's the point at which you then start to get, the point of view across. And it's not impossible about (?) the meeting Ministers if you do it early enough, but Ministers are not necessarily decision-makers.
CW		Yeah.
AI	00:27:55	The other key to anything like that is where the jobs are. If you're bringing, if you're trying to bid for a major contract, how many jobs you are bringing to the UK. So if you're off-shoring, even if you're the cheapest, it will be set against the onshore, It's the jobs and there is that.
CW		Yeah, it's a useful thing to think about, isn't it, so.
AI	00:28:16	...all this.
CW		You might want to partner up with someone in the UK.
AI	00:28:19	That's what I say you, you can partner up for joint ventures or something else, you know, you risk sharing all that (....(...INAUDIBLE...)...) anyway, you know. So it's a, you know, it's an American chassis, but it's somebody else's (...INAUDIBLE...) somebody you know, so. But it's getting the best product that fits, at the end of the day. It seems to me that the jobs are important, but what is the best product, especially, especially if you're providing them for the armed forces. They need the best equipment for armed forces. It needs to work all the time.
CW		Yes, yes exactly, it can't be breaking.
AI	00:28:52	And, you know, if it's body armour, whatever else, yeah if they stop the bullets a best they can, there's no point seeing this as a new technology, yeah.
CW		No, exactly.
AI	00:29:00	It should stop the bullets.
CW		Yeah, does it work?
AI	00:29:02	...
CW		Yeah, I think that is the most important thing. Okay great, so you would be able to help us develop our relationship with the ministers and civil servants, 'cause that's—,
AI	00:29:10	I could work at that yeah.
CW		Great, because it's quite hard for me, as Claire Webster to call up as Anderson Perry because of course they've never heard of me.
AI	00:29:17	No.
CW		And that's something that I think the American board would be quite pleased to see, that we can help with on the UK board.
AI	00:29:26	Yeah.
CW		Because it's helping us kind of fill in a skill shortage, if you like, I suppose.
AI	00:29:31	Yeah.
CW		Well that's really um a positive thought. And also, just your understanding of the way a department works I imagine will be incredibly useful.
AI	00:29:39	Yeah, and in fact what you can ask someone, kind of how this works, "Can you give me the wind-down?" The best thing is just to get a wind-down, you know, who is, because every, every department tends to do it differently in its procurement structures.
CW		Oh right.
AI	00:29:55	There's an increasing tendency, for Government to try a standard approach, but again, best cross-fertilisation so if you are buying an IT system, don't reinvent the wheel.
CW		No.
AI	00:30:07	Yeah. Or you're buying whatever it is, you know, don't, don't start trying to (...INAUDIBLE...) communication systems. First of all (...INAUDIBLE...) is it compatible with anyone else's foreign system.
CW		Yes, exactly. Is it going to work in practice?
AI	00:30:23	When there was err one big department was going to procure the comms system, that was incompatible to the emergency responder, they nearly bought it. And people kept going, yeah but they can't, maybe you can. May be you can knit them together.
Audio file M2U00152
AI		It was just not compatible because it was set different standards and that was abandoned to the point of signing in the contract.
CW	00:00:05	Oh really.
AI		And, and then it was, it, and I sat at the table the planning table thing and it wasn't, (...INAUDIBLE...) cross corresponding err, and some of us were putting their bets/backs(?) up, if it doesn't talk, then don't buy.
CW		Yeah, don't spend more.
AI	00:00:19	It's too far down the road, don't spend hundreds of millions of pounds on something that doesn't work.
CW		Don't spend more.
AI	00:00:25	Because of course it will cost a £100 million to fix it.
CW		Yeah.
AI		You are either going to have to abandon it and you'll have to go out and (...INAUDIBLE...) the official as well (...INAUDIBLE...) and of course industry, industry was a bit disreputable because it was quick to sell anything. Err, now, now there is more open accounting between companies and Government, so it's, there tends to be more honesty.
CW		Yeah.
AI	00:00:47	Err, and more transparency and yeah you can't do this, and you can't do that then the gain share, profit share that type of thing. You know so if you actually may start to be making a lot of money, then the department should get a share of that, simple thing so that that, that...
CW		It seems quite fair doesn't it.
AI	00:01:06	And best practice is now beginning to prevail across governments, the Government of, err, what is it...the department (...INAUDIBLE...) of Government commerce (...INAUDIBLE...) um, the problem is a new incoming Government may just change all this (...INAUDIBLE...)
CW		Yeah that's one thing I was going to ask you actually, how much effect do you think it will have if the...?
AI	00:01:27 00:01:51	Well you don't know until they start doing it, you know because what ministers like to do and what you also have is people within the system who've got set ideas, and err, you're just hoping for a new Minister (...INAUDIBLE...) I'm going to try this, (...INAUDIBLE...) who's (...INAUDIBLE...) by another civil servant and this is really my idea, and I think you get that Minister saying this is a great idea, let's go down that route. And see if you can find changes that maybe for the better, may not be err, but, but any, any new Minister who comes in, wants to make his mark, and he's not going to settle for saying we'll just take anything.
CW		No of course yeah.
AI	00:02:03 00:02:23	Got to look for new ideas and initiatives and um, but really the sort of sector you're in is really at that you know, if the top health care provision the you know, private sector. Well if the Tories win, they're going to go more for this and there's no question at all the health budget, it's a bloated budget, it's not an official budget. I've never worked in health err, and it's a monumentally difficult area to work in because it's just, it just consumes money err, it just eats money um, just because of medical science and what we do and so on. And err, so again it's a bit like Defence, if you can, if you can strip away things which really you shouldn't be doing, err, so you're making the best use of the money that is available to you.
CW		With the money you have got.
AI	00:02:50 00:03:16	Increasingly, increasingly (...INAUDIBLE...) is the name of the game. I'm hoping that labour no question about that, but it maybe (...INAUDIBLE...) the door, (...INAUDIBLE...) and then the other issue which you can put into that is the public service unions (?)who are, who again have become very big and affected by public expenditure (...INAUDIBLE...) to downsize they say you can't really (...INAUDIBLE...) oh yes you can, but then it goes...
CW		Yes they'll be very resistant to it won't they yeah?
AI		Yeah because, because I mean I've trade union background I was a trade unionist for ten years, to officials (...INAUDIBLE...) negotiating (...INAUDIBLE...) public sector, err, and all of the unions have just tried to put their membership up because your job depends on the size of the membership.
CW		Yeah of course.
AI	00:03:40	So if you're (...INAUDIBLE...)
CW		You don't need so many of you, yeah.
AI		(...INAUDIBLE...) bad news. Good to go err, and so but, but the civil servant unions tend to (...INAUDIBLE...), they are noisy in one sense but in terms of delivering on the street, they don't really deliver. It's all noise, noises off.
CW		Yeah.
AI	00:04:06	But anyway, anyway there's a whole range of issues that you then have to attend to as change takes place. Change is the one thing people don't like and then when they get to it, they get to the new plateau they say right this is great. And don't change this again.
CW		No exactly, never go back.
AI	00:04:25	Don't go back there. So um, and I think, I think there is a difference in American culture, this country and again so because we're so much tied to the European regulations and all this, we have increasing problems because of (...INAUDIBLE...) changes, European relationship but some of the employment laws and so on, will change you know the consultation before you do things.
CW		Yes.
AI	00:04:48	Err, but that's, that's a way down the (...INAUDIBLE...)
CW		Do you think um, a Conservative Government will change your role on the advisory board at all, do you think it will affect you or the things you can deliver?
AI	00:04:58	No my guess is that I have enough credibility because the territory I was in, defence have in fact, there is, there's one person who's likely to become the defence Minister in the Tory administration, says once you (?) become Minister wants to come and talk to me because I'll give him good advice.
CW		Oh really.
AI	00:05:25	I said yes I'll do that err, breaking all the rules but I want to see the department well run, I don't care who's running it, as long as it's well run, I feel so much for the guys. Um, so, and I, and I tend to talk to people and I talk to Tory opposition members to say "let's think about that"
CW		Yeah.
AI	00:05:32	(...INAUDIBLE...) good governance. I want to see my money spent properly.
CW		I know so do we all.
AI	00:05:42	So I don't know if that's of interest to you.
CW		Yeah it is of interest, one thing that we need to discuss is always tricky, is I don't know what you're thinking in terms of err, remuneration for...
AI	00:05:50	I haven't been thinking of anything, cos I don't know what you've asked me to do yet.
CW		Well if we just look at the um, idea of being on the advisory board and doing a meeting every other err, month for the first instance, um, do you have a, a figure in mind, I don't know whether it's a kind of day rate figure or a yearly figure.
AI	00:06:06 00:06:31	Well it kind of varies between err, I tend to focus it on the type of company it is err and err, in actual fact what, what I do is public property anyway so I'm not, so, one of my directorships, it's a thousand pounds for a meeting, and another it's fifteen hundred pounds a day, and you know that's what consultancy (...INAUDIBLE...) charge (...INAUDIBLE...) difference (?) setting up a board meeting. Err, and you do a variety of things and you then have to think about more complex issues um, so you, round about that sort of territory (...INAUDIBLE...) two thousand pounds, so I have two/three (?) companies associated with Libya, and they're each two thousand pounds.
CW		A day?
AI	00:06:51	That's, that's a month, that's a month. But um, err, but we just have an arrangement, something I don't even do a day, and I just...
CW		But that's a retainer presumably then yeah?
AI	00:07:06	And I (...INAUDIBLE...) non executive Chairman. Directors all come together (...INAUDIBLE...) I'm non-executive. They are all executive. They pay me over the period, two thousand pounds (...INAUDIBLE...) but also using me to meet some of the client base, also, err, points of contact.
CW	00:07:27	Well that sounds quite similar, same kind of thing, so maybe um, that would be err, the right amount if you would be happy with that. The only reason I'm asking you
AI		Plus VAT.
CW		Of course and your expenses. The reason I'm asking now is because when I feed back to the States, of course that's one of the things I will bear in mind err, what the different err, levels of um.
AI	00:07:46	I'm negotiable with that.
CW		Yes and as are we actually um, I think for us it's about getting the right kind of people um, and as you say you have very good err, points of contact within Government and I think that's something that would appeal. And the board...
AI	00:07:59	You can't have different members getting different rates as well, that becomes, I think that becomes an issue.
CW		Yes I...
AI	00:08:05	(...INAUDIBLE...) legal knowledge and...
CW	00:08:31	Yes though I think, I think it's better, apart from obviously the chair, I think the chair would expect to get um, more um, for all the board members to be on the same but if they were doing extra err, work so it wasn't for the board the you would have err, a pro rata rate, like a daily rate essentially that you would um, supplement if they were doing, you know if they did five days a month, rather than the standard two. then obviously you'd want to err, reflect that. And I would imagine there would be some err, trips every now and again to the States to meet clients and what they do, and meeting every so often there. Um, but does it sound broadly the kind of thing you'd be interested in doing?
AI	00:08:44	Yeah it does and I like the idea of the six month review I would be happy with that because I'm of the basis that I'm not going to take money for nothing (...INAUDIBLE...) make sure I put something back in, and err, (...INAUDIBLE...) my own personal integrity, if I am not adding value I am not doing my job.
CW		Yeah what are you doing?
AI	00:09:02	And err, so you're right, the six month, it's not too short, it's a start up.... (...INAUDIBLE...).... but err, you know you think start up is maybe not the best thing to join it's maybe...
CW		No I know and I think you just have to kind of see how it's going don't you and just have conversations err, in order to assess it, you don't have to kind of have a formal review, how are things?
AI	00:09:22	And then of course recruiting the board together (...INAUDIBLE...) if there are people who don't know each other they...
CW		Yes they've got time to gel yeah.
AI		(...INAUDIBLE...)
CW		Yes.
AI		(...INAUDIBLE...) objective of the request is (?)
CW	00:09:38	No I think that's right err, and that may well take a little while to kind of warm up and to see what everyone's strengths are really you know.
AI		Okay.
CW		It takes time.
	00:09:46	And in terms of um, how quickly you could err, start, so it sounds like the beginning of May for you after the election.
AI	00:09:53	Well immediately after the election, any time, you know any time from well the election date is the 6th of May, and I'll be busy, I'll be campaigning up to then err, and (...INAUDIBLE...) my successor and err, so that's, putting my intense effort in there um, and (...INAUDIBLE...) It'll go so very quickly but the election period has happened too soon.
CW		Yeah.
AI	00:10:13	Now that that...
CW		Yeah how do you feel about standing down?
AI	00:10:16	Ah well, I, I made my mind up at the last election, I only told, my wife knew and err, my election agent who, who I wanted to be my successor (...INAUDIBLE...) getting, having been prepared to be the fall man and err, but I didn't announce it till a year ago err, you know so I'm, I kind of made my mental adjustment I was going to go.
CW	00:10:37	Yeah you had some time to get your head around it
AI	00:11:03	And err, and but I was still two years, I was still two years as a Minister doing (...INAUDIBLE...) so there's no way of announcing (...INAUDIBLE...) at the beginning of 2007 I thought well just because I was (...INAUDIBLE...) ending the study err, I thought mm, I'm not going to announce it now, and I kind of waited till the study was out, (...INAUDIBLE...) and that then gave a clear indication. my successor was only appointed two or three weeks ago.
CW		Oh right.
AI		There's a lot going on in the Parliamentary state, that's a big thing (...INAUDIBLE...)
CW		Yeah I imagine.
AI	00:11:29	Because you have six hundred and fifty people, and out of sixty million, and you have a status even with all the stuff as an MP, I'm you know, (...INAUDIBLE...) as you know but um, you know I've been very angry with my colleagues because they're ripped the system off and I was warning a lot of the time this will come back and bite you, you should not be doing this err, and it was a bit of a let down, I was kind of Presbyterian creature, all fire and damnation err, but I didn't know the extent, I thought it was, and very few of us did, and then we saw it I thought this is absolutely outrageous.
	00:11:50	We are all damaged by it.
CW		Yeah that's what the shame is really isn't it?
AI	00:11:54	And so you've got the bulk is, probably half of MPs have are, are just operating the system properly err, and, and you know not to the limit but just properly applied it, some of them have been forced to pay back money (...INAUDIBLE...) the rules. I wasn't asked to do any of that stuff and err, and I run a very tight ship in terms of the money I spend, so I'm always um, a user of all the allowances, not just your personal allowance but all the overall in terms of staff and ...
CW		All the extra things you're allowed yeah.
AI	00:12:42	(...INAUDIBLE...). all over the country, and, and 2008, 2009 period. so you know I tried to, I tried to run it in a pretty tight way, and um, but we are damaged by the whole thing.
CW		Well I think it's such a shame actually cos unfortunately the public just remember the bad cases.
AI		Yeah.
CW	00:12:53	Err, and I think that's quite sad.
AI	00:13:09	And I expect so you'll go back to the impression that you sort of (...INAUDIBLE...) I'm pretty sickened by their conduct and I've watched people who are in denial. Some of them say oh the system's all wrong, I've been caught by the system you know and I've said well, you've created the problem. We all created it by not being, not sitting on not getting a hold on the problem.
CW		Yeah.
AI	00:13:18	Some of us, some of them knew more than others, everyone you knew it was not done properly and no one said "fix this" and there was a big cover up err, and because people who knew the excesses that were going on err did not want that to surface because it was people who were next in line who were going to be judged.
CW		Yeah.
AI	00:13:41	Err, and then of course it was (...INAUDIBLE...) much lower than that.
CW		Yeah.
AI	00:13:50	So I mean I've, I'm coming (...INAUDIBLE...)
CW		Well that's good. I'm sure your own constituents are rather happy with you?
AI	00:13:58	Yeah they are, and the press come on the news and they say things you know, I've rented property ever since I've been in London (...INAUDIBLE...) I did it when (...INAUDIBLE...) public money and err, and then you buy things for the flat you know, and it was (...INAUDIBLE...) I mean you've got to have knives and forks.
CW		Yes exactly.
AI	00:14:20	I haven't bought anything for ten years (...INAUDIBLE...) given us, cos that is our second home, we need, and it's not luxury.
CW		No exactly especially I think that you're renting, that I would imagine your constituents must be quite happy with that.
AI	00:14:32	Very happy yes.
CW		Cos it's not like you're making money on property.
AI	00:14:35	And I'd have felt terribly guilty if I been, if I had got twenty three years on my mortgage.
CW		Exactly.
AI		I would have been in a million pound house, you know and err and you think "maybe I should..."(...INAUDIBLE...) I just, I just didn't want to do it.
CW		Yeah.
AI	00:14:51	I was just not comfortable with it.
CW		Yeah.
AI		And there was a lot of (...INAUDIBLE...) there was a you know, I will never forget this, trying to buy the leases of long term residence and I was offered forty two thousand pounds for my lease and I said no I'm not doing it. And there's other colleagues (...INAUDIBLE...) take the money.
CW		I know.
AI	00:15:10	I said "you're not entitled to that money" because it's not best, it, it's it's not yours, the rent is someone else, and then you take that as a windfall. It's not right. And err, (...INAUDIBLE...)
CW		It probably is the best policy really isn't it.
AI	00:15:29	It's just personal integrity.
		Yeah I think so it's been tricky and a shame.
AI		But they're not A paragon of virtue.
CW		No they're definitely not.
AI		I'm not sitting on the board (?)...
CW	00:15:39	Once you stand down um, as an MP, I think you said that you wouldn't need to get any um, future kind of consultancy stuff cleared, is that right?
AI	00:15:47	That's correct.
CW		I don't really know how it works.
AI		I've been long enough away from being a Minister now so I don't need to seek approval.
CW		Right.
AI	00:15:53	Err, you know so there's no, there's no conflict of interest and so all that, and I'm a private citizen. I mean if I was a Minister now, leaving in May, then there would be a gap, but you (...INAUDIBLE...)
CW	00:16:07	Okay well that's good to know, it's useful just in case, I don't think they, the people in the US will ask, but just in case they do.
AI		Well they have very tough laws on that as well as you probably know.
CW	00:16:15	Yes, yeah.
AI		So and you usually have to sign documents, because the HD err, EDS had to sign that law, the disclaimers about (...INAUDIBLE...) corruption and bribery and all that sort of stuff.
CW		It was amazing actually, I always find it surprising that so many documents that we need to sign sometimes.
AI	00:16:33	Well it's about saying you, you're operating proper standards.
CW		Yeah.
AI		In fact there was, there was a bill passed today, that the (...INAUDIBLE...) passed my detail over (...INAUDIBLE...) in the UK parliament um, err, the Bribery Act.
CW		Oh really.
AI	00:16:46	Yeah and that's, I think.
CW		That must be quite interesting.
AI		(...INAUDIBLE...)
CW		Some good bedtime reading.
AI		(...INAUDIBLE...) I would say, (...INAUDIBLE...) pick up the description of the Bill but I think that's on the same territory, it's all about err, how people, how individuals should operate and how companies should operate.
CW		Oh that's interesting.
AI	00:17:07	And providing standards
CW		Yeah, yeah I think that's right. Well over the next err, week and a half I imagine, I'll be talking to err, the people in the states and I'll be drawing up a short list so I'll probably give you a call in the next week and a bit or so, um, and just let you know when people are coming over from the states and just keep you informed.
AI		Okay.
CW	00:17:24	Um, and maybe you know hopefully we can meet again and talk about how to, the best things um, best. Um, we've got each other's um, e-mail address I think, so um, yeah just drop me an e-mail um, if you have any further thoughts or whatever.
AI	00:17:38	Okay I will. You, you contact me when it's comfortable again, if they want to speak to me.
CW		Yeah, yeah I will. I really appreciate you coming here, I'm sorry about the slight change in err, time, I thought it would much nicer for you to be able to come here a bit earlier.
AI		No I was quite happy to do that yeah.
CW	00:17:52	Okay really nice to meet you.
AI		What did you do before you came here?
CW	00:17:56	I just worked in PR actually for an agency
AI		Just
CW	00:18:15	I know just, um, for an agency um, on Great Titchfield street, so not very far away. We kind of had um, it was a, oh a number of clients actually which is quite nice when you work for quite a big agency, because then you get to do lots of varied stuff which is good. did you put your coat in the cupboard, alright, really nice to meet you, take care I'll be in touch shortly, soon, okay bye.
AI		(...INAUDIBLE...)
BACKGROUND NOISE
CW	00:24:14	Yeah, yeah fine.
		Great
CW		Do you want me to help you?
End of interview.

142.  Letter to the Commissioner from Rt Hon Adam Ingram, 28 June 2010

I refer to your letter of 31 March 2010 enclosing a copy of the complaint you had received from Greg Hands MP, dated 28 March 2010, and to your subsequent letter of 2 June enclosing a copy of the certified transcripts of the telephone conversation of 1 March 2010 and the subsequent interview I had with the undercover reporter from the Sunday Times.

You set out Mr Hands' complaint as follows:

"In essence, the complaint is that you may have been engaged in lobbying activities in a way which is contrary to the rules of the House; that your conduct during an interview with a person who subsequently revealed herself as a journalist was contrary to the rules; that your conduct was not such as to maintain or strengthen the public's trust in the integrity of Parliament; and that it brought the House of Commons into disrepute".

In his letter, Mr Hands stated:

"The Rt Hon Member for East Kilbride, Strathaven and Lesmahagow, Adam Ingram, admitted that he had used his contacts and experience to help a construction company he worked for carry out a defence project in Libya: "Gadafi wanted a defence academy built, and people I'm with have got very good points of contact with the Libyan regime. Also, responding to a question posed by the undercover reporter about whether he could use his experience to develop relationships with ministers and civil servants, he said: "I'd do that".

Let me now deal with these points before responding to the specific questions in your letters of 31 March and 2 June.

(1) It is clearly stated in the Guidelines of Business Appointments System for Former Ministers, under Annex A, that:

"It is in the public interest that former Ministers with experience in Government should be able to move into business....".

I would maintain that all of my actions and activities, since leaving Ministerial office in 2007, are wholly consistent with that guidance. Furthermore, I have fully complied with the requirement to seek advice and to properly register my business interests with the appropriate House authorities, at all times.

(2) It was made clear to the undercover reporter that I did not believe it appropriate to carry out lobbying activities while I remained a Member of Parliament nor have I ever done so since leaving Ministerial office in 2007. The Sunday Times article accepted this in their report.

In the run-up to the interview, a Freedom of Information (F01) request was submitted to the Ministry of Defence in relation to the companies with which I have a registered relationship. I assume the FOI request had been submitted by the undercover Sunday Times reporter or someone acting on her behalf.

I attach a copy of the FOI request and the MOD's response, at Appendix 1..

The record is clear on this point. For the avoidance of doubt, I did not lobby on behalf of any companies I was considering working with after I left Parliament.

(3) I do not accept that my "conduct" during the interview was contrary to the rules. I expand on this later in this submission.

(4) If the public had been made aware by the Sunday Times that it is perfectly acceptable, indeed, in the public interest, for former Ministers to "move into business" that may have helped their readership better understand the nature of my engagement in seeking employment after I left Parliament. In working within the spirit and meaning of that guideline, I do not accept that I brought the House of Commons "into disrepute".

Mr Hands claims that I "admitted" to using my "contacts and experience" to help a construction company I worked for "carry out a defence project in Libya". You also ask a specific question on this point.

Libya is a country of strategic and economic importance to the UK. There are many UK companies which have major business interests in Libya. While Mr Hands may have chosen to word his statement in a particular way for his own political purposes, I am at a loss to understand what he is insinuating.

It is in the UK's national interest to engage with Libya. My work for these companies, which are part of a consortium bringing valuable business to the UK, was fully and properly registered. The efforts of these companies were fully supported by the UK Embassy in Libya.

The transcript shows that I did not "admit" to what Mr Hands alleges.

For the avoidance of doubt, I have no points of contact in Libya gained through my time as a Minister or as a Member of Parliament. I never visited the country nor met with any representatives of the country during my time as a Minister or as a Member of Parliament. The point I was making, as set out in the transcript, was that people in the companies with which I was associated had good points of contact in Libya.

Mr Hands quotes a statement I allegedly made to the undercover reporter, viz. "I'd do that" in relation to using my "experience to develop relationships with Ministers and civil servants". I did not make that statement, as the transcript shows. I deal further with this point later in my submission.

I now turn to your letter of 31 March and set out my response to the five questions you raise.

(Al) My researcher in my office in Portcullis House was contacted by Claire Webster purporting to be acting on behalf of a company which wanted to discuss with me the prospect of my taking on a paid role as a member of an Advisory Board which was being set up. I did not initially return the call.

A further call was made to my researcher in my Portcullis House office and this was relayed to my secretary in my constituency office. She passed the information to me and I did a preliminary check on the internet and with Companies House on the company's name—"Anderson Perry". On the face of it, the company appeared to be a bona fide organisation. Claire Webster was subsequently advised to call me which she did on I March. The transcript sets out the arrangements which were made for me to meet with her.

(A2a) To the best of my recollection, I confirm the statement made, This is confirmed in page 40 of the transcript.

Given the fact that under the guidelines of the Appointments System for Former Ministers it is in the public interest that "former Ministers with experience in Government should be able to move into business...", it would not be unusual for former Ministerial colleagues to maintain points of contact if they had mutual interests to pursue.

This statement was made in the context of my being asked to possibly give advice outside of my knowledge base. Again, I do not think there is anything remiss in contacting former Ministerial colleagues for advice on personalities and structures within a particular Department.

I do not accept that I was in any way suggesting that a formal network be set up to be used "to arrange contacts".

(A2b) I set out later in this submission the extent of my contacts with civil servants after leaving Ministerial office in 2007. In the words I used, I was expressing a statement of fact that it is the civil service structure which brings together particular procurement decisions. It is therefore desirable for companies to make themselves known to civil servants and to Ministers. This is normal practice and one adopted by companies involved in a procurement process. Many of those who do this on behalf of companies may indeed be former civil servants or Ministers.

I did not have contact with civil servants on behalf of clients and did not lobby on their behalf. If I had done so I would have declared an interest as appropriate.

(A2c) I did not claim that I was helping to put together a consortium to bid for work which the MOD outsources to private companies.

The transcript merely confirms my knowledge of what was being put together, not that I was at that stage actively part of it or instrumental in it.

The background is that I had been contacted by a business acquaintance outlining what he was putting together and enquiring as to whether I would be interested in becoming involved after I left Parliament.

I have done no work for this project and I have no knowledge of its maturity.

I have received no payment and have had no contact with Ministers or civil servants about the project. It was a short discussion about a possible future appointment after I left Parliament.

(A2d) I have two registered interests with companies which have been successful, as part of a wider UK consortium, in winning a contract for the design and planning phase of an Engineering/Defence Academy for the Libyan Government. I provided advice on the range of activities undertaken in the UK in this area. The payments I received were properly registered.

I was never involved in meetings with Ministers or civil servants on behalf of the clients. If I had been, these would have been registered, as appropriate.

(A2e) The "Academy" has not been built and it therefore has not been populated by the students or instructors/teachers. There is a future prospect that another company with which I am involved and in which my interest has been registered, is likely to have an interest in obtaining contracts in this area.

I have never been involved in meetings with Ministers or civil servants on behalf of my clients in this regard.

(A2f) I registered all companies with which I have been involved. All potential earnings were also properly registered as required.

I enclose a copy of the letter sent by my solicitors to the Sunday Times, at Appendix 2.

I maintain that I have, at all times, properly registered all companies with which I have a financial interest. I have not undertaken any other registerable work, paid or unpaid, outside of those companies listed in my Register of Interests.

I have said nothing untrue, therefore the question is not relevant. I now turn to your letter of 2 June and the six questions raised.

(Al) The list of the companies I worked for in 2009-10 are as per those listed in Appendix 1. They were fully registered in the Register of Members' Financial Interests.

I wish to make it clear that I was working with EDS as a consultant, not in my capacity as a Member of Parliament.

I had agreed with the company that the best mutual date to review my on-going contract was when I was standing down as a Member of Parliament. It was a natural review date because I was looking at my retirement options in terms of the amount of time I would be in London.

EDS was acquired by Hewlett Packard during this time. I continued to provide consultancy advice to EDS. New senior executives had been appointed with whom I met almost immediately prior to the Dissolution of Parliament. I continue to be available to give advice to the company when requested to do so.

Following my standing down as a Minister in June 2007, I was asked by the Prime Minister to head-up a study into Defence's Contribution to Counter-Terrorism and Resilience. This was in an unpaid capacity. During that time, I had extensive contact with civil servants across Whitehall.

I presented my Report to the Prime Minister in the autumn of 2008. From October 2009, I undertook an Audit of my Report which, again, brought me into contact with civil servants. I reported to the Prime Minister in March 2010.

I also undertook a range of unpaid activities at the request of the Royal United Services Institute (RUSI), the Royal College of Defence Studies (RCDS) and the Defence Academy at Shrivenham. Civil servants would have been involved in those events.

In addition, I spoke to PhD students at Kings College, London, on my role and time as a Defence Minister.

I have not maintained any other relationships, formal or informal, with senior civil servants, and certainly not in order to recommend them for future employment opportunities once they had left the civil service.

I have provided references, on a limited number of occasions, at the request of individuals who were seeking employment after leaving Government service.

(A4) The interview had been set up to discuss my possible engagement as a member of an advisory board. Despite having no experience of doing what I was being asked to do on a paid basis, I could envisage seeking to speak to ministers or civil servants or to participate in meetings about a client's interests. My failure to elaborate further, as the transcript bears out, was probably because I was considering the practicalities of such an approach.

I do not accept the emphasis put on it by the undercover journalist or by Greg Hands, and, in any event, it would have been undertaken after I left Parliament. The words I used—"I could work at that"—have a very different meaning to the fabricated quote by the undercover journalist—"I'd do that". The subsequent exchange with the undercover journalist involved my making non-committal responses to her leading suggestions.

(A5) The discussion on this point was about providing advice, on request, on my experience as a Defence Minister. I would have been prepared to do so because I care about good governance and about the Ministry of Defence. I was not suggesting that such a contact would be used in the way phrased in your question. For the record, the individual concerned was not appointed as a Coalition Government Minister.

(A6) I cannot confirm the exact date of the interview.

In conclusion, I reiterate the points made earlier that I have complied with the rules and regulations laid down by the House authorities, in relation to my business appointments. I always erred on the side of caution in all of my dealings. The evidence of the FOI request clearly shows that I did not breach the rules and regulations relating to lobbying.

I participated in the interview on the basis that I was being considered as a member of an advisory board although clearly there was an underlying agenda of entrapment. I do not believe I offered to do anything as a Member of Parliament which would have required me to register an interest. There was no formal follow-up to the initial interview and no formal offer made of employment in any capacity relating to my time as a Member of Parliament.

As a consequence, I believe that the complaint made by Greg Hands is unfounded and should be dismissed.

28 June 2010

143.  Extract from response from Ministry of Defence to Freedom of Information Request, 26 February 2010

26 February 2010

Dear [name]

Thank you for your e-mail dated 25 January which is being treated as a request for information under the Freedom of Information (F01) Act 2000. You asked:

1) From the 1st May 2001 until 29 June 2007 please can you provide details of all meetings (including dates, agendas and minutes) and correspondence including letters, e-mails, notes of telephone conversations and memos) between Adam Ingram MP (and/or his political advisors, secretaries) and:

a)  Signpoint Secure LTD

b)  International School for Security and Explosives Education (ISSEE) Argus Scotland Ltd

d)  Argus Libya UK LLP

e)  Electronic Data Systems (EDS)

2) Details of any communication and/or meetings between the Department and Adam Ingram MP since the 29th June 2007 specifically in regards to:

a)  Signpoint Secure LTD

b)  International School for Security and Explosives Education (ISSEE)

c)  Argus Scotland Ltd

d)  Argus Libya UK LLP

e)  Electronic Data Systems (EDS)

1)  Ingram Advisory LTD

3) Details of any communication and/or meetings since 29 June 2007 between the Ministry of Defence Department and:

a)  Signpoint Secure LTD

b)  International School for Security and Explosives Education (ISSEE)

c)  Argus Scotland Ltd

d)  Argus Libya UK LLP

e)  Electronic Data Systems (EDS)

f)  Ingram Advisory Ltd

4) Details of any contracts made since 29th June 2007 between the Department and:

a)  Signpoint Secure LTD

h)  International School for Security and Explosives Education (ISSEE)

c  Argus Scotland Ltd

d)  Argus Libya UK LLP

e)  Electronic Data Systems (EDS)

f)  Ingram Advisory Ltd

...

ln response to your first question, the records relating to meetings and correspondence are only held from 2004 onwards. Between 1 January 2004 and 29 June 2007 there were no meetings or correspondence between Adam Ingram MP or his office.

In response to questions 2 and 3, there has been no communications or meetings between Adam Ingram MP and Departmental Ministers since 29 June 2007 regarding any of these companies. Any communications between the Ministry of Defence (MOD) and those companies not involving Ministers could only be identified at disproportionate cost. This is because while Ministerial diaries and correspondence can readily be searched, it is not possible to do this on a Departmental wide basis. It has been assessed that the costs for which we are permitted to charge in providing this information will exceed the appropriate limit. This limit is specified in FOI regulations and for central government is set at £600. This represents the estimated cost of one person spending three and a half working days in determining whether the Department holds the information, and locating, retrieving and extracting it. The MOD does not maintain a central record of all meetings (including dates, agendas and minutes) and correspondence including letters, e-mails, notes of telephone conversations and memos) and the effort required obtaining this information and then assessing whether any of the resulting information can be released or falls within the remit of any exemptions under the FOI Act, would exceed the limit as explained above. Under the terms of the FOI Act, this means that we are not obliged to comply with this aspect of your request.

In response to your final question, since 29 June 2007 one contract has been placed with ISSEE. The value of the contract was less than £10,000. I am withholding further details of the contract under s.43 of the FOI Act (Commercial interests). As this is a qualified exemption I am required to carry out a public interest test. There is a general public interest in not releasing specific contract values, as to do so could inhibit our ability to deliver best value for money for the taxpayer; it could also compromise individual companies' commercial position. On the other hand, there are public interest arguments in favour of transparency in MOD's commercial dealings. I judge that these considerations can be satisfactorily balanced by releasing the general contract information set out above.

26 February 2010

144.  Letter to Rt Hon Adam Ingram from the Commissioner, 1 July 2010

Thank you for your letter of 28 June responding to my letters of 31 March and 2 June about this complaint in respect of the interview which you gave to an undercover reporter earlier this year.

I was most grateful for this response. There are some points which it raises and on which I would be grateful for your further help. They are:

1.  You say at point 1 of your letter that you have "fully complied with the requirement to seek advice and to properly register my business interests with the appropriate House authorities, at all times." Could you let me know what advice you have sought, from whom, and whether that advice related to the nature of your outside employment when you were a Member of Parliament?

2.  In relation to the alleged network of former Ministers, could you let me know whether you have used your contacts with Ministers, former Ministers or civil servants in order to advise any of your clients about structures and people in a government department?

3.  On the same point, you say that you do not accept that you were in any way suggesting that a formal network be set up. In the light of that, I am having some difficulty in interpreting the point you made on page 40 of the transcript: "some are going to lose their seats and they're become a point of contact in the political network … so all of that … can be established … it can take a bit of time to build those blocks …" Can you help me on why it should not be inferred from this that you were suggesting a network of contacts of former MPs (and in particular ex-Ministers) which you would build over time?

4.  In A2b you say that you "did not have contact with civil servants on behalf of clients". I see that the FOI request did not identify any contact you had with Ministers. My original question was about contacts with Ministers as well as civil servants, so I would be grateful if you could let me know whether you had any contact with Ministers from 2007 on behalf of any of your clients or on matters which might be of assistance to those clients.

5.  In A2d you say that the payments you received from the company in a contract for the engineering/defence academy for the Libyan Government were properly registered. Could you confirm which of your Register entries this statement related to? Am I right in thinking it was Argus Libya UK?

6.  Similarly, under A2e you note that your interest in the company providing instructors/teachers for the Libyan engineering/defence academy had been registered. Could you help me by identifying the Register entry in respect of that company?

7.  You say in answer to point 2 of my letter of 2 June that you were working with EDS as a consultant and not in your capacity as an MP. I have consulted the Registrar of Members' Financial Interests about this. She tells me that you registered a salary band and deposited an agreement for the provision of services for EDS. I enclose a copy of the relevant Register entry and agreement. These fulfill the requirements of the rules for those undertaking work in the capacity of an MP. (I enclose a copy of the relevant extract from the Guide to the Rules.) Could you explain how you reconcile this with your statement that you were not working in your capacity as an MP? And could you give me a little more detail about the work you carried out for EDS? The agreement you deposited contains only the information required by the rules of the House: did you also have a contract with EDS, and if so may I see it? Finally could you let me know whether you are currently paid a retainer by EDS so that they can draw on your services, and whether you continue to have a contract with them?

8.  In answer to point 3 in my letter of 2 June, you say that you have not maintained any other relationships, formal or informal, with senior civil servants, and certainly not in order to recommend them for future employment. Could you help me in reconciling that statement with what you say at pages 35 and 36 of the transcript, where you say, during a discussion on civil servants who might be approached for the fictional advisory board: "I think I know all of them and … some of them are very good strategic planners, good thinkers, and well-trained in command and control … and just think logically." And on page 36: "There's a lot duffers in there but I've got some there in mind". Does that not suggest that you were offering to identify possible members for the advisory board from recently retired civil servants whom you knew in a Government department, which I take to be the Ministry of Defence?

9.  In relation to the answer on point 4 in my letter of 2 June about your discussion in respect of developing relationships with Ministers and civil servants, would it be reasonable for me to draw from your answer that, now that you have left Parliament, you would be ready to use the contacts you have built up as a Member of Parliament and former Minister to contact and maintain relations with current Ministers and civil servants on behalf of your clients?

10.  In response to point 5 in my letter of 2 June, you state that you were "not suggesting that such a contact would be used in the way phrased in your question". My question had been whether you were offering to the company as a contact the Member who might become a Conservative Defence Minister (but in the event has not). I have some difficulty in otherwise interpreting what you said in the conversation at pages 54 and 55 of the transcript. The question was whether a Conservative Government would affect you or the things you could deliver. In your answer, you refer to the person who you thought then was likely to become a Defence Minister who, once he became a Minister, wanted to come and talk to you because "I'll give him good advice". You said then that you tended to talk to people and that you talked to "Tory Opposition Members". You concluded this section by saying "So I don't know if that's of interest to you." Would it not be a reasonable inference from those exchanges that you thought that your contacts with Conservative Members, in particular the individual you identified, might be of interest to the company (Anderson Perry) and that that interest would stem from the contact you might create between that company and the putative Conservative Defence Minister?

11.  Finally, I note that you do not have the exact date of the interview. Could you let me know whether you have been able to check your diary for earlier this year and, if so, whether an entry was made in your diary for this interview, and, if not, why no entry was made for this appointment?

I apologise for the length of these additional questions, but I hope that your response will enable me to take forward this inquiry to its conclusion. I am most grateful for your help.

1 July 2010

145.  Letter to the Commissioner from Rt Hon Adam Ingram, 7 July 2010

RESPONSE TO LETTER OF 1 JULY 2010

(1)  I sought advice from the appropriate House authorities about the procedures and rules applicable to obtaining clearance to take up outside employment and the way in which those interests should be registered.

(2)  I have not used any contacts with Ministers, former Ministers or civil servants to advise my clients about structures and people in a Government Department. I used my own knowledge in this regard to provide such advice.

(3)  In your original question (Q2a) to me in your letter of 31 March, you asked me to explain my comments about the possible establishment of a network of former Ministers who could be used to "arrange contacts".

I explained that I could see nothing wrong in contacting former colleagues to obtain advice on personalities and structures within a particular Department. That would take place only after I had left Parliament and would not contradict advice in the Appointments System for former Ministers which states that:

"former Ministers with experience in Government should be able to move into business".

I reiterate my view that as a private citizen, I am at liberty to contact whomsoever I think necessary to provide me with such advice within the bounds of propriety. Political and business networking is perfectly legitimate and a common feature of business interface with Government.

(4)  In response to your question about my having any contact with Ministers from 2007,

the response to the Freedom of Information (F01) request from the Ministry of Defence makes it clear that there was "no communications or meetings between Adam Ingram MP and Departmental Ministers since 29 June 2007 regarding any of those companies".

(5)  I confirm that the company in question is Argus Libya UK.

(6)  I explained in my earlier response (A2e) that the academy had not been built and therefore there is no company with which I am currently involved which is "providing instructors/teachers" to the academy. I explained in (A2e) that the academy was a future business prospect.

The company to which I referred is the International School for Security and Explosives Education (ISSEE).

(7)  You ask how I can reconcile my entry in the Register of Members' Financial Interests in relation to EDS with my statement that I was not providing services to the company in my capacity as a Member of Parliament.

In my response of 28 June, I advised you that I always erred on the side of caution in all my outside employment dealings. My understanding of the rules is that service in the capacity of a Member of Parliament is usually taken to mean advice on any Parliamentary matter or services connected with any Parliamentary proceedings or otherwise, related to the House.

I did not provide such services to EDS although the registered entry would have allowed me to do so. The registered entry also states that EDS expected me to provide advisory services and certain other project work as directed by the contract with the company. I enclose a copy of that contract as requested.

You will note that the contract is between EDS and "Adam Ingram, Director, Adam Ingram Advisory Ltd".

The contract states that payment will be made for a minimum of two days each month. By mutual agreement, that part of the contract was not implemented and I billed only for days actually worked.

My full entry in the Register of Remunerated Directorships states that the payments to be made to me would be paid through Adam Ingram Advisory Ltd.

In response to your request for a little more detail about the work I carried out for EDS, initially I was engaged with familiarising myself with the company's structures and key project managers. I provided them with analysis on the structure of Government and the role of Ministers; the interface between Ministers and senior civil servants and my assessment of developments in Government thinking based on my political analysis. In the main, those meetings were of a strategic nature.

I was not paid a retainer by EDS during that time, nor do I receive such payment now.

The contract has not been formally terminated and I believe I would continue to be bound by it if asked to provide future services to the company.

(8)  You refer to comments I made on pages 35/36 of the transcript in relation to my thoughts on civil servants who could be suitable for future employment.

I would suggest that those comments should be taken in conjunction with the comments made on Page 31 of the transcript where I respond to a request for suggested names of former civil servants by stating that I could not provide such names "off the top of my head".

I believe this clearly indicates that I did not maintain a checklist of individuals whom I would be prepared to recommend for future employment.

(9)  In response to Q4 of your letter of 2 June, I replied that I could envisage seeking to speak to Ministers or civil servants about a client's interest. That remains my position which I believe to be wholly consistent with the view of the House authorities that it is in the public interest for former Ministers to move into business.

I have not maintained such a contact list and instead would use publicly-available information if I was trying to establish contact for a particular purpose.

(10)  My interpretation of the exchange on Pages 54/55 of the transcript differs from yours. The interview was taking place in the context of my suitability to become a member of an advisory board of a company. It is hardly surprising that I tried to show my breadth of experience, the respect in which I was held across the political spectrum and the willingness of others to trust my objective advice and judgement. My use of the phrase "so I don't know if that's of interest to you", falls withing the category of setting out my wider attributes and in the context of my outline wish to see good governance irrespective of which party is in office.

(11)  The reason I cannot give you the exact date of the interview is simply because I have not kept the diary details. The arrangements for the interview were made with me and not through my constituency office. From memory, it was held on either 9 or 10 March.

7 July 2010

146.  Letter to Rt Hon Adam Ingram from the Commissioner, 15 July 2010

Thank you for your letter of 7 July responding to mine of 1 July with some follow-up questions about this complaint. I was most grateful for such a prompt response.

I have carefully considered your response. There are a number of points which I do need to clear up with you. I think that it might be most convenient if we did that in writing, although, subject to your response, it may be that we will need to meet for an interview on any outstanding matters after that.

The points I need to ask you about are as follows (and are numbered as yours):

1.  I have noted that you consulted "the appropriate House authorities" about rules for clearance and registration. Could you identify for me who you consulted and when, so that I can consider approaching those officials? I do not know who you might have consulted about clearing your employment offers. As you know, I have already obtained from the Registrar of Members' Financial Interests details of your Register entry and agreement for services with EDS. To save time, I am now writing to ask her about any consultations you had with her on the registration entries for your remunerated employment.

2.  I note that you used your own knowledge to advise your clients about structures and people in Government Departments. But would I be right in assuming that that knowledge drew on your experience as a Minister and your continuing contacts as an MP with Ministers and civil servants? If that is not so, could you let me know on what your knowledge was based and how it was kept up to date?

3.  I assume from your response that you do intend to use your network of contacts which you built up as a Member and Minister to assist your current and any future clients now that you have left Parliament. I note, however, that you do not have a specific (and, I assume, separate) list of such contacts and that you did not intend to imply in the discussion with the undercover reporter that you would be setting up a formal network to arrange contacts. I should emphasise that I have not myself formed a view on the propriety of your contacting former colleagues to get advice for your clients on personalities and structures in Departments, and note that you see nothing wrong in this. At this stage I am simply asking you to confirm my understanding of your intentions.

4-6.  I have no further matters to raise with you on your response to these points.

7a.  Could you let me know whether you specifically took advice from the Registrar of Members' Financial Interests about your Register entry in relation to EDS, and, in particular, your decision to register your salary band and the agreement for services? To save time, I am now consulting the Registrar about this also and will let you have her response.

7b.  I have noted the terms of your contract, including that you were paid a daily rate of £1,500 and that paragraph 19 includes the provision about advocacy which you submitted to the Registrar.

7c.   I note that "in the main" the meetings you had with EDS were of a "strategic nature". Was the advice you provided all oral advice at meetings, or did you prepare papers for them? To whom was the advice given? And did you provide more specific and less strategic advice at any time, and if so, what did it cover?

8.  I have noted that you did not maintain a "checklist" of people to recommend for appointments to boards. The question I asked in my letter of 1 July was whether you were offering to identify possible members for the advisory board from recently retired civil servants whom you knew in a Government Department, which I took to be the Ministry of Defence. I have noted that you did not give names at that meeting. But you appeared to suggest that you had names in mind. In any event, could you confirm that you were indeed offering to identify such people? I should make clear that at this stage I am not suggesting that there was an impropriety in your doing so. That would be a matter for me to consider once my inquiries are concluded.

9.  I note that you could envisage speaking to Ministers or civil servants about a client's interest and that you would use publicly available information as you do not have a "contact list". I am finding this argument a little difficult to follow. It would be unusual for someone in public life not to keep the names and numbers of their contacts in an address book or its electronic equivalent. Are you suggesting that you do not keep details of such contacts? And are you suggesting that, even if you had kept such a contact list, you would not consult it if you wished to contact a Government Minister or a senior civil servant? Again, I am not suggesting at this stage any impropriety in such actions. That would be a matter for me to consider once my inquiries are completed.

10.  I note your point about setting out your wider attributes and the references to good governance which you made at this point in the interview (page 55 of the transcript). But in that part of the interview which was specifically about whether a Conservative Government would change your role on the advisory board, it appears that you were making clear that you had good contacts with Conservative Members, including the particular Member whom you thought at that stage might become a Defence Minister, and that, in the interests of good governance, you expected to give advice to that Minister. As a result, it may seem that you were suggesting that you would be able to bring to the advisory board your contacts with Conservatives, on the assumption that there would be a Conservative Government. Again, I am not suggesting at this stage any impropriety, which I will need to consider at the conclusion of my inquiries. I simply want to be clear on the implications of what you were saying in the discussion. If I am wrong to draw these inferences from what you appear to have been saying, please let me know, and why.

11.  I have no further points on the interview date. Thank you for your explanation.

I appreciate that you will not be able to let me have a response to this letter until after the middle of August. But it would be very helpful if you could let me have a response, however, by the end of August.

15 July 2010

147.  Letter to the Commissioner from Rt Hon Adam Ingram, 27 August 2010

Thank you for your letter of 15 July 2010.

You raise a number of additional points and my response set out below is as per your numbered paragraphs.

1)  You ask whom I consulted about clearance and registration of my various business appointments.

Prior to taking up a role with the companies concerned, I sought clearance from the Office of the Advisory Committee on Business Appointments.

I received clearance from Lord Mayhew, the Committee Chairman, in a letter dated 14 January 2008, advising me that "it would be proper" for me to take appointments with three companies about which I had enquired, namely, Signpoint Secure Ltd, Argus Scotland Ltd and Argus Libya UK Ltd.

I received a further letter from the Committee, dated 27 March 2008, signed by the Secretary to the Committee, [name], that they could "see no reason" why I should not take up appointments with EDS Inc. and the International School for Security and Explosives Education (ISSEE).

Following receipt of those letters and after consultation with the Registrar for Members Interests about the most appropriate listing for those appointments, I duly registered my interests and notified the Secretary to the Advisory Committee on Business Appointments that I had taken up the appointments.

2)  You ask whether I drew upon my experience as a Minister in providing advice to the companies with which I was involved.

I confirm I did so and believe that to be consistent with the guidelines for former Ministers which state that "it is in the public interest" for former Ministers with experience in Government to move into business.

You ask if I used my continuing contacts as a Member of Parliament with Ministers and civil servants in the interests of those companies.

I believe it has been established that I did not lobby on behalf of those companies despite having clearance from the Advisory Committee on Business Appointments to do so, if I wished, any time after one year of leaving office.

You ask how I kept my "knowledge" up to date.

You will note that, with the exception of my appointment with EDS, I had taken on the role of director with the other companies. That required a range of skills and attributes not necessarily connected to my previous role as a Minister. It would be of assistance to me if you could clarify what you mean by my "knowledge".

3)  I could envisage using contacts made during my time as a Minister. Many companies engage former Ministers and civil servants for that very purpose. The capacity to ask people for advice is not unique to me and is recognised as part of the guidelines for former Ministers that it is in the public interest for them to move into business.

It would be a strange turn of events if former Ministers, or indeed former Members of Parliament, were prohibited from making contact with anyone they had known as a Ministerial colleague or civil servant after they had left Parliament.

4-6).../

4-6) I note you have no further matters to raise with me in relation to these points.

7a)  I took advice from the Registrar of Members Interests about my Register entry in relation to EDS.

As I previously advised you, I also sought approval from the Advisory Committee on Business Interests before taking up my appointment with EDS.

7b)  Noted.

7c)  All advice given to EDS was oral. I did not make any written submissions to them. The advice was given to a range of account executives and their senior staff. I had regular meetings with the senior personnel responsible for the company's public affairs.

The only non-strategic advice I would have given would have been about the role and responsibilities of a Member of Parliament, stressing the importance of keeping good relations between company representatives and local Members of Parliament in the areas where the company had a presence.

8) As I explained in my earlier response on this point, I stated in my interview with the bogus company representative that I could not think of the names of former civil servants suitable for outside employment "off the top of my head".

You ask if I would be prepared to suggest such names.

For the avoidance of doubt, I was not offering myself as a head-hunter, for payment or otherwise. I would be prepared, however, to offer my best advice on the qualities of people I knew in Government.

As a Minister, I made a number of appointments to various bodies on the basis of recommendations made to me by civil servants about their former colleagues. Public service is replete with former civil servants who take on other public roles after they retire, which, in many instances, will be done on the basis of a personal recommendation. In the main, I think this works to the advantage of service delivery.

Similarly,.../

Similarly, industry and commerce can benefit from the transfer of such a skill base from the public sector to the private sector.

9)  As I previously advised you, I do not have a "contact list", in either address book or electronic form, of Ministers or civil servants. Your hypothetical question is therefore not relevant.

10)  You say that I appear to be suggesting that I would be able to bring to the bogus advisory board my contacts with Conservatives on the assumption that there would be a change of Government. I made no such offer.

What I said in response to the direct question posed to me by the bogus company representative (page 54) was that I had credibility as a Defence Minister which I believed could transcend a change of Government. I believe that my credibility and knowledge was recognised across the political spectrum, based on my service as a Defence Minister for over six years. There can be no question that this would allow me to talk to Members of Parliament of parties other than my own, in Government or not, from a position of strength, an attribute which would have been available to the bogus advisory board.

You will no doubt be aware that two former Labour Cabinet Ministers and one former Minister have been appointed as advisors to the current Government. Likewise, if I was to be asked to give advice on Defence matters, I would do so, motivated by the desire for good governance as expressed in my comments to the bogus company representative.

11)  Noted.

I look forward to hearing from you.

27 August 2010

148.  Letter to Rt Hon Adam Ingram from the Commissioner, 2 September 2010

Thank you for your letter of 27 August responding to mine of 15 July about this complaint.

I was most grateful for this response which I will take fully into account when I come to consider my conclusions on this matter.

There were a number of matters which I should briefly follow up, namely:

1.  You address the question at point 2 in my letter to you of 15 July about the basis for the knowledge you use to advise your clients on the structures and people in government departments. I was not suggesting that you lobbied such people. I was simply seeking to clarify whether you used your continuing contacts with Ministers and with civil servants to advise your clients about structures and people in government departments. I was assuming that you did so. If you rejected that assumption, then I was asking how you managed to keep up to date the advice you gave to your clients about structures and people in government departments. I was not asking how you kept up to date your knowledge on wider issues. Could you, therefore, confirm whether you used your continuing contacts with Ministers and civil servants to keep up to date the advice you gave your clients about structures and people in government departments? This would be consistent with the more general account you gave in point 3 that you would envisage using contacts made during your time as a Minister. Again, I will need to come to my own view on what you have said about this, and you should not draw from this that I am suggesting there is any impropriety in the way you advised your clients on these matters.

2.  I have noted in response to point 9 in my letter of 15 July that you do not have a "contact list" of Ministers or civil servants, either in address book or electronic form. But what I was asking was whether you kept the details of Ministers and civil servants in some form, either in hard copy or electronically, and whether you would refer to it if you wished to identify or contact such people? I am not sure whether you wish me to take from your reply that you do not have any names, addresses, or contact numbers of Ministers, former Ministers or civil servants in any list of personal contacts kept by you and, if you wish to contact such people, rely only on public records.

It would be very helpful if you could let me have a response to these final points within the next two weeks. Meanwhile, I will pass the relevant parts of your letter to the Registrar of Members' Financial Interests so that she can take them into account in preparing the response which, as you will know from my letter of 15 July, I have asked of her.

2 September 2010

149.  Letter to the Registrar of Members' Financial Interests from the Commissioner, 15 July 2010

I would welcome your help on a complaint I have received against the Rt Hon Adam Ingram when he was the Member for East Kilbride, Strathaven and Lesmahagow.

The complaint relates to a meeting which Mr Ingram had with an undercover reporter in March 2010 which was recorded without his knowledge, and which was reported in the Sunday Times of 28 Match 2010. The matter on which I need your help relates to contacts which Mr Ingram may have had with you in relation to his registration entries in respect of his remunerated directorships.

Mr Ingram has told me that he consulted the "appropriate House authorities" about the way in which his outside employment interests should be registered. He has told me that he has "always erred on the side of caution" in all his "outside employment dealings" in respect of the rules and regulations laid down by the House authorities in relation to business appointments.

At my request, you have provided me with a copy of Mr Ingram's Register entry for EDS and the related agreement for services. Mr Ingram had told me that he wished to make it clear that he was working with EDS as a consultant, and not in his capacity as a Member of Parliament. He has told me that his "understanding of the rules is that service in the capacity of a Member of Parliament is usually taken to mean advice on any parliamentary matter or services connected with any parliamentary proceedings or otherwise, related to the House". He has told me that he did not provide such services to EDS, although he recognises that the Register entry would have allowed him to do so. He says that the Register entry also stated that EDS expected him to provide advisory services and certain other project work as directed by the contract with the company.

Mr Ingram has also provided me with some information about the work he carried out for EDS as follows:

"… initially I was engaged with familiarising myself with the company's structures and key project managers. I provided them with analysis on the structure of Government and the role of Ministers; the interface between Ministers and senior civil servants and my assessment of developments in Government thinking based on my political analysis. In the main, those meetings were of a strategic nature."

For completeness, I enclose a copy of the agreement for consulting services which Mr Ingram sent to me.

In the light of this, I would be grateful to know:

1.  whether Mr Ingram at any time consulted you about his registration entries for his remunerated employment and, if so, when and what those discussions were about;

2.  in respect of Mr Ingram's employment with EDS, your view in the light of the information provided to me by Mr Ingram as to whether he was required within the provisions of the Guide to the Rules to register his payment band and lodge with you his agreement for services.

I have today written to Mr Ingram to ask him for more information about the advice he gave to EDS. When I receive his reply, which is unlikely to be before mid-August, I will let you see it.

If you could let me have a response to this letter by the end of the first week in September, that would be most helpful.

15 July 2010

150.  Letter to Registrar of Members' Financial Interests from the Commissioner, 2 September 2010

I wrote to you on 15 July asking for your help with a complaint I had received against the Rt Hon Adam Ingram. I said in that letter that I had written to Mr Ingram to ask him for more information about the advice he gave to EDS.

I have now heard back from Mr Ingram with further information about his contacts with you. He has written as follows:

"Prior to taking up a role with the companies concerned, I sought clearance from the Office of the Advisory Committee on Business Appointments.

I received clearance from Lord Mayhew, the Committee Chairman, in a letter dated 14 January 2008, advising me that 'it would be proper' for me to take appointments with three companies about which I had enquired, namely, Signpoint Secure Ltd, Argus Scotland Ltd and Argus Libya UK Ltd.

I received a further letter from the Committee, dated 27 March 2008, signed by the Secretary to the Committee, [name], that they could 'see no reason' why I should not take up appointments with EDS Inc. and the International School for Security and Explosives Education (ISSEE).

Following receipt of those letters and after consultation with the Registrar for Members Interests about the most appropriate listing for those appointments, I duly registered my interests and notified the Secretary to the Advisory Committee on Business Appointments that I had taken up the appointments."

Mr Ingram also advised me:

"I took advice from the Registrar of Members' Interests about my Register entry in relation to EDS.

As I previously advised you, I also sought approval from the Advisory Committee on Business Interests before taking up my appointment with EDS."

Finally, in relation to the advice he gave EDS, Mr Ingram has informed me as follows:

"All advice given to EDS was oral. I did not make any written submissions to them. The advice was given to a range of account executives and their senior staff. I had regular meetings with the senior personnel responsible for the company's public affairs.

The only non-strategic advice I would have given would have been about the role and responsibilities of a Member of Parliament, stressing the importance of keeping good relations between company representatives and local Members of Parliament in the areas where the company had a presence."

I would be grateful if you could take this into account in preparing your response to my letter of 15 July. I appreciate that you may need a little more time to consider the additional information that Mr Ingram has provided, but I hope that you could let me have a response within the next two weeks. I look forward to hearing from you.

2 September 2010

151.  Letter to the Commissioner from the Registrar of Members' Financial Interests, 9 September 2010

Thank you for your letter of 15 July and for the follow-up letter of 2 September.

Your first question is whether at any time Mr Ingram consulted me about his registration entries for his remunerated employment and if so when and what those discussions were about.

I have gone back in Mr Ingram's file to the point at which he ceased to be a Minister in July 2007. The sequence of events is as follows, and relevant correspondence is appended.[608]

On 12 July 2007 I wrote to Mr Ingram noting that he no longer held ministerial office, saying that it might be that he was now thinking of taking up outside employment, pointing out that the rules might have changed since he was last in a position to do this and offering advice should he require it. I indicated that general guidance was available in the Code of Conduct and in the procedural and advice notes.

On 10 March 2008 Mr Ingram sent the office a copy of an agreement with a company called SignPoint and asking for the employment to be registered. The file contains a draft e-mail from the Executive Officer including a draft entry.

On 27 June 2008 Mr Ingram wrote again with copies of agreements with Argus Libya and Argus Scotland asking for them to be registered. He must have telephoned the Executive Assistant on 9 July, as her draft e-mail suggests she e-mailed back "Further to our conversation earlier I attach below your revised entry for the Register. I would be grateful if you could also let me know what the business of the two companies is; I am afraid I forgot to ask you that when we spoke".

Mr Ingram must have telephoned again, as there is a draft e-mail in the file from the Executive Assistant dated 22 July and saying "Thank you for your call letting me know the description of the two companies. I attach below a revised entry for the next updated internet version of the Register".

The first mention of EDS occurs on 21 August 2008 when Mr Ingram wrote enclosing an agreement with the company and asked for it to be registered. This time he told us what the company did. Mr Ingram having supplied an agreement with a salary band we assumed that he was providing services in the capacity of an MP (since it is only when this is the case that a band and agreement are required) and inserted that salary band in the Register entries.

A draft e-mail from the Executive Assistant to Mr Ingram, dated 2 September 2008 reads "Thank you for your call. I attach your entry for the next updated edition of the Register, which will be produced later this week". Mr Ingram's secretary replied the same day saying "Thank you [name]. The entry is OK".

I have referred above to "draft e-mails" from the Executive Assistant. This is because it was her practice to print off e-mails for filing before she actually sent them. Evidence (for instance responses) suggests that they were indeed sent.

The file does not suggest discussions of any length between this office and Mr Ingram. Had there been any such, the Executive Assistant or I would have recorded them, either in a file note or in an e-mail response to Mr Ingram. It appears that on each occasion including the one relating to EDS we simply complied with his request to make an entry: we did not give him any substantive advice and none was requested.

Secondly, you ask my view, in the light of the information provided by Mr Ingram, as to whether he was required within the provisions of the rules, to register a salary band and lodge an agreement for the provision of services.

The rules of the House require that Members undertaking to provide services in the capacity of a Member of Parliament shall obtain a written agreement to that effect, including a standard clause stating that the Member will not be asked to engage in advocacy, and deposit it with the Parliamentary Commissioner for Standards, and register their payment by £5,000 bands. By giving a salary band and providing an agreement, Mr Ingram was informing the reader that he was providing services in the capacity of a Member of Parliament.

I note that Mr Ingram says that he did not provide services in the capacity of a Member of Parliament but that his Register entry would have allowed him to do so. He also says that the entry stated that EDS expected him to provide advisory services and certain other work as directed by the contract with the company (in fact it is the agreement not the Register entry which refers to project work). He says that his understanding of the rules is that 'services in the capacity of a Member of Parliament is usually taken to be advice on any parliamentary matter or services connected with any parliamentary proceeding or otherwise related to the House'. These words are a quotation from the 2009 edition of the Guide to the Rules'.

The Guide to the Rules in force at the time Mr Ingram took up the appointment made no attempt to define or describe 'services in the capacity of an MP', though the foreword to the Register of 2005 makes illustrative reference to 'making representations to a government department, providing advice on parliamentary or public affairs or sponsoring functions in a parliamentary building'. Had Mr Ingram consulted me in 2008 I would have given him the then-current advice; this was codified in the 2009 edition of the rules from which Mr Ingram quotes, which was then in preparation.

Neither the agreement deposited by Mr Ingram nor the longer contract with which he supplied you and which you have sent me give sufficient detail as of the actual work Mr Ingram was carrying out for EDS to me to be able to say that he was indeed providing services in the capacity of an MP. In your first letter to me, however, you tell me that he told you that 'he provided them with an analysis of the structure of government and the role of Ministers; the interface between Ministers and senior civil servants and [his] assessment of developments in Government thinking based on his political analysis'. In your second letter you tell me he wrote to you that 'the only non-strategic advice I would have given would have been about the role and responsibilities of a Member of Parliament, stressing the importance of keeping good relations between company representatives and local Members Parliament in the areas where the company had a presence'. These two statements, and particularly the second, lead me to the conclusion that it was indeed right that Mr Ingram should give a salary band and provide an agreement because he was providing what I would regard as services in the capacity of a Member of Parliament.

I should like to make two further observations. First, Mr Ingram says he wished to make it clear that he worked for EDS as a consultant and not as an MP. I should say that the two are not mutually exclusive and the form of his Register entry gave the opposite impression. Secondly there is no relationship between the Advisory Committee on Business Appointments and the work of this office, though I would always ask an ex-Minister registering an appointment if s/he had checked with that Committee.

9 September 2010

152.  Letter to Rt Hon Adam Ingram from the Commissioner, 9 September 2010

When I wrote to you on 15 July I said that I would be consulting the Registrar of Members' Financial Interests about your Register entry in relation to EDS and, in particular, your decision to register your salary band and the agreement for services. You kindly provided me with some further information about this in your letter of 27 August and I noted in my letter to you of 2 September that I would pass those points on to the Registrar.

I have now heard back from the Registrar. I enclose a copy of my letters to her of 15 July and 2 September; and her response of 9 September, together with its enclosures.

As you will see, the Registrar notes the contacts you had with her office about your EDS and other Register entries since 2007, although she notes that it appears from her files that there were no discussions of any length between her office and yourself: it appears that on each occasion the office complied with your request to make an entry—they did not give you any substantive advice and none was requested. Having considered your evidence on the advice you gave EDS, the Registrar has also concluded that it was right for you to have given a salary band and provided an agreement because you were providing what she would regard as services in the capacity of a Member of Parliament.

I would welcome any comments you may wish to make on the Registrar's advice. I may need to note that you had registered that you were providing services in the capacity of a Member of Parliament in the context of what you told the interviewer (pages 21 and 22 of the transcript)—including: "I have been doing advisory work, done a lot initially, not so much recently, with the EDS, which is now part of HP, and actually just talking to them about, really just about Government relations and what to look for in Government…There's a kind of standard way in which Governments tend to operate…my arrangement with them is that I would only do work on an MP and then…it would probably come to the end of the arrangement..".

Subject to any comments you may wish to make on the Registrar's letter, and your response to my letter to you of 2 September, I consider that I am now close to the conclusion of this inquiry. I should say that I am planning to prepare a memorandum to the Committee on Standards and Privileges on my inquiries, although you should draw no inferences from that. You are one of a number of Members who have been subject to a complaint in respect of this matter. Once I have concluded my inquiries on each of these complaints, I will be preparing a draft memorandum for the Committee. I will show you the relevant sections of the factual sections of that memorandum so that you can check on their accuracy. I will then prepare my conclusions and submit the full memorandum to the Committee. The Clerk of the Committee will send you a copy of that full memorandum so that you can comment on it if you so wish before the Committee come to consider the matter.

If you could let me have any response you may wish to make to the Registrar's letter within the next two weeks, I would be most grateful.

Thank you for your help.

9 September 2010

153.  Letter to the Commissioner from Rt Hon Adam Ingram, 14 September 2010

Thank you for your letter of 2 September 2010.

You raise a number of additional points and my response is as follows.

1)  You ask if I used "continuing contacts with Ministers and with civil servants to advise ... clients about structures and people in government departments".

Throughout our correspondence, you have consistently referred to "clients". With the exception of EDS and Argus Libya(UK) LLP, I have no other "clients". I trust this clarifies the situation.

I did not maintain a continuing contact with Ministers and with civil servants in order to advise "clients".

The point I was making in paragraph 3 of my letter of 27 August was that I could envisage making contact with people I knew in government after I left Parliament.

I further expressed the view that any prohibition on contact between a former Minister or a Member of Parliament, after leaving Parliament, and Ministers and civil servants would be an unusual development.

I responded in the future tense since that was the context in which you had sought my response in your letter of 15 July.

I have made no such contact since leaving Parliament.

2)  You ask if I "kept the details of Ministers and civil servants in some form, either hard copy of electronically" and whether (I) would refer to it if (1) wished to identify or contact such people".

I advised you in earlier correspondence that I do not have a comprehensive list of Ministers, past or present, or civil servants.

I have a small circle of friends, built up over my twenty-three years in Parliament and in government. I maintain contact details of those friends whom I occasionally meet socially. I do not view them as contacts in the context of your enquiry.

I look forward to hearing from you.

With best wishes.

14 September 2010

154.  Further letter to the Commissioner from Rt Hon Adam Ingram, 14 September 2010

Thank you for your letter and enclosures of 9 September 2010.

I do not have details of when I contacted the Registrar's office or any notes relating to the advice I received.

My recollection is that I sought general advice on what was required in the registration of outside financial interests. I also recollect being advised to look at how others had registered their interests as that could prove a useful template. I addition, I drew upon the Code of Conduct and the supporting procedural and advice notes.

The first company I registered was Signpoint Secure Ltd which provided the framework for subsequent entries. When it came to registering subsequent interests, I recollect telephone discussions about the categorisation of the registered interest. I believe that applied to the action I took on the registration of EDS.

You will note that I provided an agreement for services and a salary band for each of the registered interests.

I have noted the comments of the Registrar and respect her version of events.

With regard to the consultancy services I provided to EDS, I maintain that I did not provide advice as a Member of Parliament, either in terms of the pre- or post-2009 guidance as set out in the Registrar's letter to you of 9 September. My earlier letters describe the services I provided and I stand by those comments.

I appreciate that both you and the Registrar take a different view, although, as I understand it, you accept that I had properly complied with the relevant registration requirements to allow me to give advice in my capacity as a Member of Parliament.

I now turn to your interpretation of the comments made in pages 21/22 of the transcript.

I set out in my letter of 28 June my interpretation of the meaning of the comments I made. I am clear in my own mind that the point I was making was that the understanding I had with EDS was that I would provide services to them while a Member of Parliament and not as a Member of Parliament. For the reasons set out in my letter of 28 June, the natural review of my continuing relationship with the company was at the point of my standing down as a Member of Parliament. The relationship has also changed in part because of the new company structure and new senior executives at EDS.

I look forward to hearing from you.

With best wishes.

14 September 2010

155.  Letter to Rt Hon Adam Ingram from the Commissioner, 20 September 2010

Thank you for your two letters of 14 September responding first to my letter to you of 2 September and secondly to my letter to you of 9 September.

In respect of your response to my letter of 2 September, I was not intending for you to answer whether you maintained your contacts in order to advise your clients—in other words those whose employment by you you had registered—but whether you used those continuing contacts (of course among other things) to keep up to date the advice you gave to those who employed you. In your letter, you told me that you have made no such contact since leaving Parliament, but you made no comment on the position while you were still a Member. Unless you wished to clarify the situation, I will simply record that you have not given me an answer about whether, while you were a Member of Parliament, you drew on your continuing contacts with Ministers, former Ministers and civil servants when you gave advice to those who employed you during that time. I will then come to my own conclusions on that matter.

Similarly, I will note that, in the context of my inquiry, you maintain contact details only of those whom you regard as your friends, built up over 23 years in Parliament and in government. You have not told me if any of those are Ministers, former Ministers or civil servants. You have also not told me whether you would use that list if you wished to contact any of them on behalf of those who employed you now that you have left Parliament. Again, subject to any points of clarification you wish to make, I will need to come to my own conclusions on this.

Finally, in respect of the registration question, I should make clear that I sent you the advice of the Registrar. I have not yet come to my own conclusion on this and would not wish to do so until I have given you an opportunity to comment on the Registrar's advice. I see from your comment that you respect her version of events about the advice you sought from her office. I assume that the use of the word "respect" means that you fall short of accepting fully that version. If I am wrong on this, or you would like to set out any points where you take a different view, please let me know. I see that despite registering your work for EDS as if you were providing services in your capacity as a Member of Parliament, you do not accept that you were in fact doing so—arguing that you were providing services while a Member but not as a Member. I will of course note the distinction you have drawn and will need to come to my own conclusions on that.

I think I have now probably taken this as far as I can. Subject, therefore, to any points of clarification you wish to make in response to this letter—and if you do I would be most grateful if you could let me have a response within the next two weeks—I consider that this inquiry is closed. I will now concentrate on preparing the draft factual sections of the memorandum which, as you will know from my letter of 9 September, I will let you have so that you can comment if necessary on their factual accuracy.

Thank you for your help.

20 September 2010

156.  Letter to the Commissioner from Rt Hon Adam Ingram, 28 September 2010

Thank you for your letter of 20 September 2010.

In your letter of 2 September you asked me to "clarify" whether I used my "continuing contacts with Ministers and with civil servants to advise" clients. In my response of 14 September, I confirmed that I did not maintain a continuing contact with Ministers and civil servants for that purpose. I believed I had answered your enquiry as I understood it.

I can confirm that I did not draw upon any contacts I may have had with Ministers, former Ministers or civil servants to give advice to those who employed me while I was a Member of Parliament.

With regard to the second point of clarification you seek in your letter of 20 September, I believe it was implicit in my response set out in paragraph 2 of my letter of 14 September that amongst my "circle of friends"—which I defined as "small"—would have been Ministers, former Ministers and civil servants. I further stated that I did not view them as "contacts" in the context of your enquiry.

You now ask whether I would use that list to contact them on behalf of those who now employ me. I have not done so and I cannot envisage any circumstances in which I would.

Finally, in respect of the registration question, I sought to explain my recollection of the contact I had with the Registrar's office. I am satisfied that I received sufficient information from that office to assist me in properly registering my various interests in terms of the rules and regulations applicable at that time.

I trust this answers your request for further points of clarification. I look forward to hearing from you.

28 September 2010

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606   WE 10 Back

607   WE 9 Back

608   Not included in the written evidence.  Back

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Prepared 9 December 2010