Political and Constitutional Reform CommitteeWritten evidence submitted by Rob Mckinnon

Introduction

1. The Who’s Lobbying project is an experiment to collate publicly available data on lobbying and public affairs.

2. Since Sept 2010 the Who’s Lobbying project has run a publicly available website, containing information derived from government and Parliament reports, and other publicly available sources.

3. The Who’s Lobbying website url is: http://whoslobbying.com/

4. Motivations for the Who’s Lobbying project include:

Public Transparency—to give us easy access on the Web to information about who is trying to influence government and public affairs.

Government Policy—to inform the UK Government as to what information is and is not available, at a time when they are proposing to create a statutory register of lobbying activity.

Government Implementation—to show government how to put this type of information on the web in an easy to browse, consistent format.

Sustainability—to find a way to make the site financially sustainable (it survives on donated time and resources at present).

Currently the website has separate pages on 8,458 entities that have been reported to either have met a minister, been a lobbying firm client, or given oral evidence to Parliament.

5. More information on the history and public data service offered by Who’s Lobbying is contained in Annex A: Who’s Lobbying background.

Departments in Breach of Ministerial Code

6. Who’s Lobbying is extremely disappointed that departments have not released the last eight months worth of ministerial meeting reports.

7. Departments last published meeting reports for the period Apr-Jun 2011.

8. It is now 29 Feb 2012. Where are the last eight months worth of ministerial meeting reports?

9. To put this in perspective, it is now several months after the Liam Fox/Adam Werritty scandal. Yet the Ministry of Defence has still not published the complete ministerial meeting reports of who Liam Fox met in his last few months before resignation.

10. All ministers are in breach of the Ministerial Code May 2010’s requirement that “Departments will publish, at least quarterly, details of Ministers’ external meetings”. http://www..gov.uk/sites/default/files/resources/ministerial-code-may-2010.pdf

Question 1. Does the Government’s consultation paper represent a balanced approach to the idea of a statutory register? Does the paper present the evidence in a balanced way? Are you confident that the issues covered are ones on which the Government has an open mind? Is the Government clear wherever it has a preference for a particular option, and is this preference in each case a reasonable one?

11. Very little “evidence” has been included in the Government’s consultation entitled “Introducing a Statutory Register of Lobbyists”.

PRCA withdrew from UKPAC

12. In the consultation’s Annex A, the Government presents the UKPAC’s combined voluntary register as if it was a successfully working register that is endorsed by the so-called “lobbying industry”. This impression is a false one.

13. In December 2010, one of the three main lobbying industry bodies, PRCA, withdrew from the UKPAC stating:

“For the past 18 months, we have worked hard alongside our partners within UKPAC to find the best route forward for the public affairs industry. It is with regret that we have reluctantly concluded that UKPAC will not be able to deliver the statutory register that the Government has decided to introduce. Thanks to repeated delays and inaccuracies in its work, UKPAC simply lacks the credibility and competence to meet the Government’s objectives.” http://www.prca.org.uk/UKPACresignation

14. The UKPAC register website itself is flawed by design in that it does not have a history of registrations beyond the current period being reported.

15. In Nov 2011, the UKPAC register still only contained data covering the period Sep-Nov 2010. The data was a year out-of-date. Did the Cabinet Office delay the consultation in order to give UKPAC time to get more up-to-date data on its register before the consultation was released?

Justification for not proposing more rigorous disclosure requirements

16. In the consultation the Government fails to satisfactorily justify why it doesn’t propose the more rigorous disclosure requirements of other jurisdictions.

17. There should have been at least consideration of requirements similar to that of USA law which requires all lobbyists to submit reports on their company (both for in-house and agency lobbyists), how much was spent, and what issues were being lobbied on for whom, including exactly which bills are being lobbied on, which public agencies were contacted, and whether the lobbyist had previous employment as a senior government official.

To reiterate statements from another submitter’s evidence:

18. “Disclosure of ministerial meetings provides very little transparency and cannot be used as justification for limiting the scope of the register.”

19. First, it is far from clear from the descriptions given in the ministerial meeting logs what issues are being discussed: of the 5,144 ministerial meetings recorded, over 1100 of these meetings are reported simply as “introductory meeting/introduction”, general “catch-up” or “discussion”. [Who’s Lobbying performed this analysis in January 2011.]

20. Second, while the consultation underlines the requirement in the ministerial code to publish, at least quarterly, details of external meetings, disclosure is often delayed. For example, the last ministerial meetings logged by the Treasury, BIS, and Mark Harper’s own department, Cabinet Office, are April-June 2011. [No departments have published a report for a period past Apr-Jun 2011.]

21. Third, it is not the case that all meetings between ministers and agencies are recorded. For example, it was recently revealed that Communities Secretary, Eric Pickles had accepted a dinner with lobbying group Bell Pottinger. Pickles said he was not required to register the dinner because he had attended in a “private” and not a “ministerial” capacity. http :// www . thebureauinvestigates . com /2011/10/22/ gaping - hole - in - rules - lets - eric - pickles - keep - business - dinner - private /

22. Finally, the focus on face-to-face meetings with ministers shows a misunderstanding of the nature of lobbying. It excludes approaches made to countless other public officials, such as regulators, special advisers and civil servants.

23. Disclosure of ministerial meetings does nothing to address the lack of transparency in lobbying of other public officials.”—http://www.publications.parliament.uk/pa/cm201012/cmselect/cmpolcon/writev/1809/mem
01.htm

Question 2. Does the consultation paper contain the right questions? Is each of the questions asked in a balanced way? Are there any important questions that are not asked?

24. In the “How a register might work” section of the consultation the Government states: “A lobbying firm would be required to update the register quarterly”.

25. Why do we have the concept of quarterly registry reports in the first place? Why do quarterly reports exist? They exist because before the Web it was easiest to collate information periodically for publication on paper.

26. The Web is not paper. When you have a new medium you need to rethink these things.

27. You need to think: how can this medium allow us more immediate connection with the world around us?

28. How can this medium allow us to work in a way that we can share what we’re doing in a way that is transparent to the public?

Publish ministerial meetings weekly on register website

29. Most departments use the new medium of the Web to share frequent updates with the public via the photo website Flickr, and the social texting website Twitter.

30. At least 15 department’s are paying staff to keep photostreams up-to-date on a weekly basis on the Flickr website (Annex B). The photos published include photos of some ministers’ meetings.

31. At least 19 departments pay staff to provide daily updates on the Twitter social texting website (Annex C). The “tweets” published include mentions of some ministers’ meetings.

32. Why not have these same staff keep a register website up-to-date with ministerial meetings with the same frequency as they post to Flickr and Twitter?

Publish lobbyists’ employment histories on register website

33. About 500 out of the 1,000 lobbying agency staff list on APPC’s public affairs register were found to have public LinkedIn profiles, based on research conducted by Who’s Lobbying in 2010.

34. These public LinkedIn profiles contain employment histories, as well as the name, current title, and employer of each lobbyist.

35. It’s likely that a large number of in-house lobbyists also have public LinkedIn profiles. Analysis of the LinkedIn profiles found being to current agency lobbyists, showed that there is a revolving door between employment at lobbying firms, thinktanks, and in-house public affairs positions.

36. Why not leverage this publicly available information when constructing a register?

37. Why not require all lobbyists on the register to provide details of their public LinkedIn profile if they have one? And give them the option to keep their employment details up-to-date there?

38. Software could be written to automatically keep this in sync with the register website. It may reduce the burden of compliance on the lobbyists, and ensure the register is kept more frequently up-to-date.

Public usability

39. There was no analysis of how a register should work for a member of the public.

40. Given we are in the 21st century, a register website that allows online updating, search, browsing, filtering by client organisation, by issue, by category of organisation would be a reasonable expectation by a member of the public.

Lobbying spend and lobbying issues and in-house lobbyists

41. Research by Who’s Lobbying has identified 167 organisations with disclosed lobbying activity in both the UK and USA.

42. In the USA these 167 organisations have a combined disclosure of $3,499,731,804 total amount spent on lobbying and lobbying firms hired.

43. Annex D lists organisations that have a declared US amount spent on lobbying of $10 million or more.

44. In the USA there is also disclosure of the issues and bills organisations have lobbied on. Some of this is shown in Annex D.

45. Through UK department ministerial meeting reports we know these 167 organisations have had at least 343 meetings with government.

46. However due to the vague meeting descriptions supplied by departments, there’s inadequate information to determine the exact issues being lobbied on.

47. US data was taken from InfluenceExplorer.com. Figures are based on lobbying activity reported to the Senate Office of Public Records. Reported dollar amounts are required to be accurate to the nearest $20,000.

48. Given the amount of money disclosed by these organisations in the US, there is justification for legitimate public interest in requiring disclosure of the same information through legislation for a UK register of lobbyists.

49. The Government should have asked in the consultation whether the public want disclosure of financial spend, lobbying issues, bills being lobbied on, and those details for in-house in addition to agency lobbyists.

Question 3. Which lobbying contacts are of greatest legitimate public interest? Does the consultation paper envisage the capture of appropriate information about these contacts, as opposed to other kinds of contact?

50. The public are interested in the timely disclosure of who is lobbying government on what issues, on behalf of who, and how much is spent to do so.

51. Why not define the activity that has the greatest legitimate public interest, and ensure that is appropriately disclosed in a timely fashion?

52. Activity where there is a legitimate public interest includes the drafting of legislation, the drafting of procurement tenders, and the drafting of policy.

53. Any contacts involved in drafting or influencing the text written by drafters, should have their meetings, including phone conversations, with government disclosed, ideally within a week of them occurring.

54. Legislation and policy should not be drafted behind closed doors under the potential influence of external parties with privileged access to government.

Question 4. How should the Government deal in policy and practice with how it might be lobbied on the issue of a statutory register of lobbyists? How open should the Government be about such lobbying contacts?

55. Government departments have not disclosed who ministers have meet for the last 8 months. This is despite a promise in the Ministerial Code May 2010 that departments will publish at least quarterly ministers meetings with external interests.

56. The last period the Cabinet Office reported meetings for is Apr-May 2011.

57. In practice the Government should ensure it complies with the Ministerial Code and publish each quarter’s meetings at the end of the quarter.

Question 5. How should the Government analyse the consultation responses, and seek to balance the weight of opposing argument?

58. That is for the Government to decide. But the Government should ensure the staff involved are reviewed for their impartiality.

59. It was of concern that civil servant Walsh Atkins, reportedly in charge of drafting the Government’s register plans, tweeted on 22 December 2011: “I wish Unlock Democracy would die. I am prepared to help it along.”

60. Hopefully after her resignation a more impartial civil servant was put into the role of Head of Constitutional Policy Branch at the Cabinet Office.

61. If the Cabinet Office meets organisations representing professional lobbyists, it also has a duty to meet organisations that are campaigning for greater transparency.

Question 6. Do you have any comments on how any proposals emerging from the consultation should be implemented?

62. The register should be a website operated on the Web, updated via the Web, with a separate page for the activity for each entity engaged in lobbying or public affairs activity. There should also be a separate page for each entity with in-house lobbyists.

63. “Free-text” organisation names are not unique enough for accurate reporting and onward analysis.

64. In collating data, Who’s Lobbying has found at least 1,560 entities listed in different public documents under more than one variant of their name (eg under an acronym, name mis-spelling, trading name, previous name, or name variation or contraction).

65. Company numbers must be provided for every company mentioned, both clients and lobbying firms. This is similar to the manner in which company numbers are reported for companies declaring political donations via the Electoral Commission.

66. If an organisation is not registered in the UK, then its jurisdiction of registration should be supplied as well as its registration number in that jurisdiction.

67. Charity numbers should be provided for every charity mentioned, in addition to their company number if they have one.

68. The full text name of an organisation should be supplied separately from its acronym.

69. For example, the Ministry of Justice reported Kenneth Clarke, Lord Chancellor and Secretary of State for Justice, had a meeting with ICC in January 2011. This acronym is too ambiguous to match to a specific entity—is it the International Criminal Court, or International Chamber of Commerce, or one of the other scores of organisations with this acronym?

70. No umbrella names should be provided to obscure the actual identity of participants.

71. For example, in that same meeting reported by MOJ with Kenneth Clarke, there was a participant referred to as “MNCG”. Research suggests that this is the so-called “Multinational Chairman’s Group”, an umbrella name to cover the identity of an unreported group of influential individuals. If they are representing themselves then they should be required to disclose their own names on a register, else to disclose the legal entities that they represent.

72. Conclusion

73. Who’s Lobbying is available to provide further evidence to the Committee, or to generate reports from the data it has collated related to ministerial reports and other public affairs activity.

February 2012

Annex A

WHO’S LOBBYING BACKGROUND

The Who’s Lobbying project was conceived after the release of the Public Administration Select Committee report on “Lobbying: Access and influence in Whitehall” in Dec 2008. http://www.publications.parliament.uk/pa/cm200809/cmselect/cmpubadm/36/3602.htm

Software code for a website was started at the end of October 2009, after the Labour Government’s promise to publish quarterly ministerial meeting reports. Under the Labour Government no reports were forthcoming until after I sent an FOI request to each department in March 2010 requesting the meeting information.

Most departments refused disclosure, stating the Section 21 future publication exemption. Only some departments actually published reports before the election.

In the Ministerial Code May 2010 the coalition Government’s ministers committed departments will publish at least quarterly ministerial meetings. Once again no reports were forthcoming until after I sent an FOI request to each department in July 2010 asking for reports for the Q1 and Q2 2010. Again, most departments refused disclosure, stating the Section 21 future publication exemption, and they also refused to give a date for when that publication was planned.

Since Sept 2010 the Who’s Lobbying project has run a publicly available website: http://whoslobbying.com/

Currently the website has separate pages on 8,458 entities. Some summary statistics for those entities:

Department ministerial meeting disclosures May 2010-June 2011 mention 5,543 entities.

The 93 lobbying firms registered with APPC or PRCA in 2010–11 list 2,627 organisations as clients.

At least 52 UK public authorities were listed as clients of lobbying firms in Jun-Aug 2011.

More than 1,400 organisations had people providing oral evidence to parliament committees 2010–12.

At least 1,560 entities were listed in different public documents under more than one variant of their name (eg under an acronym, name mis-spelling, trading name, previous name, or name variation or contraction).

On the Who’s Lobbying website each entity is listed on its own page, alongside all its activity across ministerial meetings, lobbying firms hired, oral evidence given, and other information such as related Lords staff passes, and lobbying spend in the USA (where lobbying spend has been declared in the USA).

For example, BAE System’s page is here: http://whoslobbying.com/uk/bae_systems—I welcome committee members to explore the website for themselves.

To find the same information without Who’s Lobbying, you’d have to poke around through dense, difficult-to-navigate websites and hard to find PDF documents.

Ministerial meetings alone have been reported by departments in over 130 different files across 24 different department websites.

Annex B

DEPARTMENT PHOTOSTREAMS ON FLICKR

Department’s have not released the last eight months worth of ministerial meeting reports, in breach of the Ministerial Code. The last reports were published for the period Apr-Jun 2011.

Yet at least 15 department’s are paying staff to keep photostreams update on a weekly basis on the Flickr website. The photos published include photos of some ministers’ meetings.

Government Flickr accounts include:

Prime Minister’s Office photostream: http://www.flickr.com/photos/number10gov

Cabinet Office photostream: http://www.flickr.com/photos/cabinetoffice

Department for Business, Innovation and Skills photostream: http://www.flickr.com/photos/bisgovuk

Department for Communities and Local Government photostream: http://www.flickr.com/photos/communitiesuk

Department for Culture, Media and Sport photostream: http://www.flickr.com/photos/thedcms

Department for Education photostream: http://www.flickr.com/photos/educationgovuk

Department for International Development photostream: http://www.flickr.com/photos/dfid

Department for Transport photostream: http://www.flickr.com/photos/transportgovuk

Department of Energy and Climate Change photostream: http://www.flickr.com/photos/deccgovuk

Department of Health photostream: http://www.flickr.com/photos/departmentofhealth

Foreign and Commonwealth Office photostream: http://www.flickr.com/photos/foreignoffice

HM Treasury photostream: http://www.flickr.com/photos/hmtreasury

Home Office photostream: http://www.flickr.com/photos/49956354@N04

Ministry of Defence photostream: http://www.flickr.com/photos/defenceimages

Ministry of Justice photostream: http://www.flickr.com/photos/ministryofjustice

Annex C

DEPARTMENT TWITTER ACCOUNTS

Department’s have not released the last eight months worth of ministerial meeting reports, in breach of the Ministerial Code. The last reports were published for the period Apr-Jun 2011.

Yet at least 19 departments pay staff to provide daily updates on the Twitter social texting website. The “tweets” published include mentions of some ministers’ meetings.

Government Twitter accounts include:

http://twitter.com/Number10gov

http://twitter.com/DECCgovuk

http://twitter.com/DefenceHQ

http://twitter.com/Directgov

http://twitter.com/foreignoffice

http://twitter.com/DFID_UK

http://twitter.com/DHgovuk

http://twitter.com/CommunitiesUK

http://twitter.com/transportgovuk

http://twitter.com/cabinetofficeuk

http://twitter.com/educationgovuk

http://twitter.com/UKTI

http://twitter.com/DCMS

http://twitter.com/MoJGovUK

http://twitter.com/DefraGovUK

http://twitter.com/hmtreasury

http://twitter.com/COIgovuk

http://twitter.com/ukhomeoffice

http://twitter.com/bisgovuk

Annex D

USA LOBBYING DISCLOSURE BY ORGANISATIONS LOBBYING IN THE UK

The table below shows organisations with disclosed US lobbying spend over $10,000,000 that have also had disclosed UK based lobbying or public affairs activity in the UK.

US data is from InfluenceExplorer.com. Figures are based on lobbying activity reported to the Senate Office of Public Records. Reported dollar amounts are required to be accurate only to the nearest $20,000. For organizations that are not primarily lobbying firms, we display total amount spent on lobbying.

Organisation	US lobbying spend covers through to end of Q3 2011	US Most Frequently Disclosed Lobbying Issues	UK lobbying spend	UK Most Frequently Disclosed Lobbying Issues
US Chamber of Commerce	$544,505,445	Immigration, Taxes, Fed Budget & Appropriations, Law Enforcement & Crime, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 3 meetings with UK govt since May 2010.
Northrop Grumman	$163,518,093	Transportation, Trade, Government Issues, Energy & Nuclear Power, Aviation, Airlines & Airports	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 6 meetings with UK govt since May 2010 .
Exxon Mobil	$160,946,942	Fed Budget & Appropriations, Natural Resources, Government Issues, Consumer Product Safety, Chemical Industry	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 6 meetings with UK govt since May 2010 .
Boeing Co	$151,144,310	Taxes, Homeland Security, Foreign Relations, Labor, Antitrust & Workplace, Transportation	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 6 meetings with UK govt since May 2010 .
Lockheed Martin	$125,580,880	Homeland Security, Science & Technology, Energy & Nuclear Power, Taxes, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 8 meetings with UK govt since May 2010 .
General Motors	$117,371,000	Fed Budget & Appropriations, Trade, Finance, Transportation, Radio & TV Broadcasting	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 5 meetings with UK govt since May 2010 .
Pfizer Inc	$112,520,000	Pharmacy, Consumer Product Safety, Fed Budget & Appropriations, Agriculture, Torts	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 12 meetings with UK govt since May 2010 .
Microsoft Corp	$100,585,000	Copyright, Patent & Trademark, Consumer Product Safety, Science & Technology, Labor, Antitrust & Workplace, Health Issues	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 16 meetings with UK govt since May 2010 .
ConocoPhillips	$78,182,717	Natural Resources, Foreign Relations, Clean Air & Water, Transportation, Marine, Boats & Fisheries	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 4 meetings with UK govt since May 2010 .
Royal Dutch Shell	$71,508,339	Natural Resources, Clean Air & Water, Trade, Chemical Industry, Foreign Relations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 31 meetings with UK govt since May 2010 .
BP	$65,520,584	Foreign Relations, Clean Air & Water, Natural Resources, Transportation, Chemical Industry	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 21 meetings with UK govt since May 2010 .
JPMorgan Chase & Co	$62,759,775	Environment & Superfund, Copyright, Patent & Trademark, Education, Government Issues, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 11 meetings with UK govt since May 2010 .
Raytheon Co	$60,844,188	Science & Technology, Trade, Foreign Relations, Transportation, Aerospace	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Bristol-Myers Squibb	$60,776,355	Pharmacy, Trade, Agriculture, Consumer Product Safety, Clean Air & Water	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Abbott Laboratories	$53,296,000	Fed Budget & Appropriations, Agriculture, Food Industry, Pharmacy, Medical Research & Clin Labs	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Intel Corp	$52,530,779	Environment & Superfund, Telecommunications, Science & Technology, Immigration, Fed Budget & Appropriations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
United Parcel Service	$45,311,216	Trade, Energy & Nuclear Power, Trucking & Shipping, Retirement, Fed Budget & Appropriations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
MasterCard Inc	$44,185,000	Labor, Antitrust & Workplace, Computers & Information Tech, Copyright, Patent & Trademark, Gaming, Gambling & Casinos, Science & Technology	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Qualcomm Inc	$43,632,100	Taxes, Transportation, Trucking & Shipping, Fed Budget & Appropriations, Education	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Time Warner	$43,380,000	Trade, Postal, Consumer Product Safety, Computers & Information Tech, Advertising	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 2 meetings with UK govt since May 2010 .
DaimlerChrysler	$41,638,707	Defense, Health Issues, Transportation, Bankruptcy, Environment & Superfund	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Bayer Corp	$41,517,686	Fed Budget & Appropriations, Environment & Superfund, Energy & Nuclear Power, Pharmacy, Railroads	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Visa Inc	$37,113,333	Taxes, Labor, Antitrust & Workplace, Government Issues, Gaming, Gambling & Casinos, Education	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Siemens Corp	$36,190,223	Trade, Medicare & Medicaid, Telecommunications, Environment & Superfund, Copyright, Patent & Trademark	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 10 meetings with UK govt since May 2010 .
BAE Systems	$34,527,000	Taxes, Trade, Homeland Security, Aerospace, Law Enforcement & Crime	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 32 meetings with UK govt since May 2010 .
Blackstone Group	$34,032,314	Advertising, Finance, Trade, Automotive Industry, Health Issues	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Accenture	$32,996,358	Homeland Security, Education, Finance, Veterans Affairs, Health Issues	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 6 meetings with UK govt since May 2010 .
Sony Corp	$32,972,000	Consumer Product Safety, Computers & Information Tech, Education, Science & Technology, Environment & Superfund	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 5 meetings with UK govt since May 2010 .
Coca-Cola Co	$32,721,775	Environment & Superfund, Agriculture, Labor, Antitrust & Workplace, Government Issues, Energy & Nuclear Power	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
United Airlines	$32,305,732	Retirement, Taxes, Homeland Security, Environment & Superfund, Government Issues	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Anheuser-Busch InBev	$31,870,406	Transportation, Agriculture, Alcohol & Drug Abuse, Fed Budget & Appropriations, Environment & Superfund	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Baxter Healthcare	$31,140,209	Copyright, Patent & Trademark, Disaster & Emergency Planning, Agriculture, Medical Research & Clin Labs, Retirement	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
L-3 Communications	$31,050,356	Foreign Relations, Law Enforcement & Crime, Trade, Radio & TV Broadcasting, Labor, Antitrust & Workplace	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
American Express	$29,020,000	Bankruptcy, Copyright, Patent & Trademark, Labor, Antitrust & Workplace, Torts, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Bank of America	$29,011,040	Housing, Trade, Consumer Product Safety, Education, Retirement	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 2 meetings with UK govt since May 2010 .
3M Co	$27,756,196	Environment & Superfund, Trade, Energy & Nuclear Power, Copyright, Patent & Trademark, Disaster & Emergency Planning	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 7 meetings with UK govt since May 2010 .
Genworth Financial	$27,280,000	Banking, Retirement, Medicare & Medicaid, Fed Budget & Appropriations, Medical Research & Clin Labs	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Nissan North America	$27,056,000	Finance, Labor, Antitrust & Workplace, Economics & Econ Development, Homeland Security, Consumer Product Safety	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 11 meetings with UK govt since May 2010 .
Clear Channel Communications	$27,019,576	Fed Budget & Appropriations, Law Enforcement & Crime, Arts & Entertainment, Media Information & Publishing, Finance	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Goldman Sachs	$25,587,000	Trade, Retirement, Commodities, Copyright, Patent & Trademark, Agriculture	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 14 meetings with UK govt since May 2010 .
Genzyme Corp	$24,622,403	Medical Research & Clin Labs, Fed Budget & Appropriations, Insurance, Science & Technology, Food Industry	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Hewlett-Packard	$24,396,727	Telecommunications, Immigration, Copyright, Patent & Trademark, Defense, Education	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 9 meetings with UK govt since May 2010 .
Amazon.com	$22,556,000	Labor, Antitrust & Workplace, Law Enforcement & Crime, Transportation, Banking, Computers & Information Tech	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 5 meetings with UK govt since May 2010 .
Google Inc	$20,790,000	Advertising, Computers & Information Tech, Science & Technology, Consumer Product Safety, Small Business	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 19 meetings with UK govt since May 2010 .
Motion Picture Assn of America	$20,499,220	Telecommunications, Education, Law Enforcement & Crime, Computers & Information Tech, Fed Budget & Appropriations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 3 meetings with UK govt since May 2010 .
SABMiller	$19,095,676	Clean Air & Water, Trucking & Shipping, Advertising, Food Industry, Immigration	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
ChevronTexaco	$17,459,296	Taxes, Environment & Superfund, Law Enforcement & Crime, Government Issues, Retirement	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 3 meetings with UK govt since May 2010 .
Universal Music Group	$16,880,000	Government Issues, Education, Homeland Security, Travel & Tourism, Computers & Information Tech	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 3 meetings with UK govt since May 2010 .
Diageo PLC	$16,854,000	Food Industry, Labor, Antitrust & Workplace, Small Business, Health Issues, Fed Budget & Appropriations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 12 meetings with UK govt since May 2010 .
Emergent BioSolutions	$16,193,000	Medical Research & Clin Labs, Fed Budget & Appropriations, Government Issues, Pharmacy, Science & Technology	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Continental Airlines	$15,878,895	Immigration, Postal, Trade, Bankruptcy, Insurance	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
eBay Inc	$15,205,700	Law Enforcement & Crime, Banking, Finance, Small Business, Immigration	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Credit Suisse Group	$15,170,000	Housing, Health Issues, Fed Budget & Appropriations, Foreign Relations, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Barclays	$15,020,000	Housing, Energy & Nuclear Power, Trade, Commodities, Bankruptcy	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 41 meetings with UK govt since May 2010 .
Unisys Corp	$14,583,982	Taxes, Trade, Agriculture, Health Issues, Immigration	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Boehringer Ingelheim Corp	$14,256,546	Trade, Environment & Superfund, Fed Budget & Appropriations, Agriculture, Animals	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Syngenta Corp	$14,150,000	Trade, Government Issues, Taxes, Foreign Relations, Tariffs	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Boston Scientific Corp	$13,690,000	Trade, Fed Budget & Appropriations, Science & Technology, Labor, Antitrust & Workplace, Finance	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 2 meetings with UK govt since May 2010 .
Sony Music Entertainment	$13,235,000	Arts & Entertainment, Labor, Antitrust & Workplace, Manufacturing, Media Information & Publishing, Science & Technology	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 2 meetings with UK govt since May 2010 .
Apple Inc	$12,703,008	Education, Environment & Superfund, Consumer Product Safety, Finance, Fed Budget & Appropriations	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 5 meetings with UK govt since May 2010 .
Capital One Financial	$12,428,000	Consumer Product Safety, Advertising, Labor, Antitrust & Workplace, Computers & Information Tech, Radio & TV Broadcasting	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Toshiba Corp	$12,085,000	Copyright, Patent & Trademark, Computers & Information Tech, Science & Technology, Utilities, Finance	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 1 meeting with UK govt since May 2010 .
Unilever	$10,530,000	Fed Budget & Appropriations, Consumer Product Safety, Health Issues, Energy & Nuclear Power, Government Issues	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 3 meetings with UK govt since May 2010 .
ING Group	$10,176,866	Banking, Torts, Government Issues, Environment & Superfund, Telecommunications	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues.
Rolls-Royce PLC	$10,132,386	Aerospace, Taxes, Transportation, Manufacturing, Trade	No UK requirement to disclose lobbying spend.	No UK requirement to disclose lobbying issues. Had at least 18 meetings with UK govt since May 2010 .