Political and Constitutional Reform CommitteeWritten evidence submitted by Ed Williams, Chief Executive Officer, Edelman UK
1. Please accept this letter as Edelman’s response to the Political & Constitutional Reform Committee’s inquiry into the proposed Statutory Register of Lobbyists.
2. Edelman is the world’s largest independent public relations company, with 4,000 consultants in 60 offices globally. In the UK, we have nearly 400 consultants offering the full range of public relations services including corporate communications, marketing communications and digital communications, as well as public affairs or lobbying. Our public affairs division represents less than 20% of our total UK business, although it should be noted that a large number of public affairs clients also receive other communications services from Edelman as part of an integrated offer. We have been a member of the APPC (Association of Professional Political Consultants) since 2003 and as such our list of public affairs clients, and those consultants that work on those clients, is already freely available at
3. Edelman supports the proposal for a statutory register of lobbyists. We agree with the Government’s assertion that lobbying makes an important contribution to public policy-making, but believe a Register is required to improve transparency and build public confidence.
4. There are, however, a number of issues that the Committee and the Government need to consider carefully as they scrutinise and develop the proposals. The remainder of this letter sets out these issues.
5. It is important to recognise that multi-client public affairs agencies represent only a small part of the lobbying industry. It is vital that the Government clarifies that all those who do lobbying (an act defined in the consultation paper as communications with government or Parliament in an effort to influence decision-making) on behalf of others are covered by their registration proposals. An illustrative but not exhaustive list of the types of organisation which also carry out lobbying on behalf of others are law firms, accountancy firms, management consultants, planning consultancies, think tanks, trade associations, NGOs, trade unions and charities. There are also a very large number of individual consultants and freelancers in the sector, who offer public affairs services to clients. At present, we believe the Government’s proposals are ambiguous as to whether the above organisations would be covered by the proposals as they stand. Should they not be included we believe the proposal would fail to meet the objectives of improved transparency and public confidence.
6. We believe that the present definition of lobbying in the consultation paper requires further clarification. The vast majority of the work of public affairs agencies involves advising clients on dealings with the Government, rather than in communicating directly with government on clients behalf. The definition of lobbying as proposed includes only direct communications with government and Parliament. It is unclear whether the act of advising others on such communications would be a registerable activity. It is vital that the Government clarify their intent in this regard.
7. It is also important to recognise that for agencies such as Edelman, public affairs is just one of many public relations services we provide to clients. The boundaries between, for example, activity which influences the political environment and activity which influences a broader media and stakeholder environment is increasingly blurred. The advent and growing primacy of digital communications complicates this matter still further. Other markets with similar registration requirements such as Washington DC and Brussels do not have this complication in that they are PR markets in which public affairs is dominant, unlike London where public affairs is only a small proportion of a sophisticated and complex PR marketplace.
8. The remainder of this submission briefly considers a number of other points raised by the Government consultation.
9. We support the proposed level of information to be included in the register, the quarterly reporting requirement, and the proposed level of penalties for non-compliance. We also accept that the costs of registration should be met by the companies who register. However, we do suggest the Government look at the very modest cost of running the APPC register and use that as a benchmark for overall costs.
10. We do not believe that the inclusion of financial data would be practical. For the majority of Edelman clients, public affairs is offered as part of an integrated service to clients. It would be very difficult or impossible to try and define how much of a budget was allocated for “lobbying” as defined by the legislation.
11. I hope this submission has been useful for the Committee. Should the Committee have any further questions or clarifications about our evidence, we would be happy to respond to them.
February 2012