Appendix 4: Letter dated 16 July 2018 from Ian Paisley MP to the Clerk of the Committee
Dear Dr James,
Thank you for your letter and attached note from the registrar. The Commissioner kindly sent me a copy also. Once again, I reiterate to you and the committee my profuse apology for failing to register two overseas visits in 2013. There was no ulterior motive on my part, and no gain for me in any way. It was an unintentional mistake that I take full responsibility for.
I have read the memorandum from the registrar. I took the opportunity to meet with the registrar on Thursday in order to clarify its meaning. I have not sought to argue with either the Commissioner or Registrar about the matter. I respect them and their integrity. On these matters I have been treated with courtesy and professionally throughout this inquiry.
Upon studying the note and subsequently the rules 99(7) and 100(d), that both applied simultaneously in 2013/14, it is clear to see that the rules totally contradict each other on the matter of declaration and paid advocacy. I was not, at any time a paid advocate for any person or organisation or government. I have always been my own person. 1 know that by falling to make a registration in 2013 I created this problem. The visits arranged by the Sri Lankan government were embarked upon in good faith by myself. I was never asked to lobby on any issue to do with this at the time or subsequently.
I did sign a joint letter to the PM making my observations clear about Sri Lanka and I believe the letter made a general request not one seeking exclusive benefit for Sri Lanka but for the mutual benefit of both nations’ integrity. I made my observations in the context of my own knowledge of post-conflict society, of which I have some practical knowledge.
Rule 99(7) is specific and clear and comes before rule 100(d). It says and means that overseas visits are “not to be taken into account for the purposes of the rule”; meaning MPs would be permitted to lobby and would not be considered to be engaging in paid advocacy.
I believe that under the appropriate application of this rule it would be unjust to find that I was engaged in paid advocacy. The sequence of events is clear;
In March and July 2013 I and my family made visits to Sri Lanka. I failed to register these visits by mistake.
In November 2013 l made and properly registered a visit to Sri Lanka. The following year (four or so months after the November visit and eleven & nine months respectively after the unregistered visits) I put my name to a general letter to the PM. Through the eyes of the time, and being obedient to the rule 99(7), I could not have breached the rule on paid advocacy as overseas visits are not to be taken into account.
Rule 100(d) appears to concern itself with the issue of “exclusive benefit”. When I met the registrar I asked had any consideration or interpretation been given, at the time or subsequently, of what was meant by exclusive benefit. I understand no such consideration was made of its extent or meaning. On face value, I suggest, it would not mean something that was of mutual benefit.
The rules are contradictory and confusing and I understand why they have subsequently been revised. However, I was told I would be considered through the lens of the time. On that basis, I believe, it would be unfair to conclude that I breached the rule on paid advocacy.
Finally, in the report to the committee the Commissioner states that it was not appropriate for me to accept these visits for myself and my family. I have no quarrel with this. There is a saying that we should abstain from all appearances that suggest something not intended to be and I fully accept that it was foolish, at the time, not to recognise how these visits could appear. I reiterate I had no direct or indirect financial gain or benefit, no commerclal interest, and no expectation from me as a result of the visits.
I apologise for my registration failing and believe the process has been invaluable and challenging to me. I leave this in the hands of the committee and submit to your dellberations on these matters.
Yours sincerely,
Mr Ian Paisley MP
Published: 18 July 2018