Lessons from Greensill Capital Contents


Outline of events

102.In early 2020, the UK was beginning to face the potential consequences of the coronavirus pandemic. In response to the health emergency, on 3 March 2020, the Department of Health and Social Care released the Coronavirus (COVID-19) Action Plan.165 In his appointment hearing with us the following day (4 March 2020), Andrew Bailey, then CEO of the Financial Conduct Authority, and now Governor of the Bank of England, told us that:

I think it is quite reasonable to expect that we will have to provide collectively some form of supply chain finance in the not-very-distant future, to ensure that the effects of this shock from the virus are not damaging to many forms of activity, particularly to small and medium-sized firms. We will have to move very quickly to do that. It stands to reason that to do that, you must move very quickly.166

This reference by Mr Bailey to the potential role for supply chain finance appears to have prompted representatives of Greensill Capital to begin making the approaches to the Government which led to the events underlying this Report.

103.On 5 March 2020, the Rt Hon David Cameron asked Sir Tom Scholar, Permanent Secretary at the Treasury, for the contact details for Sir Jon Cunliffe, Deputy Governor of the Bank of England.167 Mr Cameron then emailed Sir Jon as follows: “a quick question for you, concerning what the Governor meant in his remarks about Supply Chain Finance”.168

104.The initial aim of the lobbying by representatives of Greensill was the reactivation of the Bank of England’s 2009 Secured Commercial Paper Facility (SCP) (part of the Asset Purchase Facility (APF)).169 The SCP was a facility announced in July 2009 that would “offer to buy securities backed by assets such as trade receivables consistent with the APF’s aim to purchase high-quality assets of broadly investment grade”.170 At the time, the Bank explained that “The purpose of the Facility [SCP] is to help improve the function of the private market by standing ready to make primary market purchases and by acting as a backstop for secondary market investors”.171

105.On 17 March 2020, in a letter to the Chancellor, Mr Greensill explained that re-activating the SCP with £10–20 billion would “give confidence to the capital market investors who underpin this market. As you would expect, that confidence is currently in question.” He argued that “This action would not only allow the continuing flow of capital into supply chains which would benefit the UK economy at a critical time, but would also assist HMG specifically in ensuring that funding flows quickly and cost effectively to its suppliers”.172

106.However, the lobbying from Greensill was to change focus, as the Government announced a new support mechanism: the Covid Corporate Financing Facility (CCFF). The CCFF was announced on 17 March 2020.173 The Bank described the CCFF as follows:

The CCFF was designed to support liquidity among larger businesses, helping them to bridge disruption to their cash flows as a result of the Covid shock, through the purchase of short-term debt in the form of CP [Commercial paper]. The CCFF purchased CP of up to one-year maturity, issued by non-financial firms making a material contribution to the UK economy. This helped businesses across a range of sectors to pay wages and suppliers, even while experiencing severe disruption to cash flows. By lending to large companies directly, the CCFF protected the space for banks to lend to the wider population of households and businesses, complementing other Bank and Government schemes such as the Term Funding Scheme with additional incentives for SMEs (TFSME), the Coronavirus Large Business Interruption Loan Scheme (CLBILS), the Coronavirus Business Interruption Loan Scheme (CBILS) and the Bounce Back Loan Scheme (BBLS).174

107.The Bank provided the following description of how responsibility for the operation of the CCFF was apportioned:

The Bank operated the CCFF as agent for HM Treasury. HM Treasury set the parameters of the scheme, including the terms and eligibility criteria for participation, which were detailed in the Market Notice published by the Bank and the CCFF legal documentation on 18 March 2020. HM Treasury was the risk-owner of the scheme and fully indemnified the Bank from any losses that might arise under the CCFF.175

108.Following the release of the market notice, Greensill made an application to join the CCFF. From the outset, Greensill knew that it did not meet the criteria for acceptance to the CCFF. It therefore proposed changes to the CCFF to allow them to gain access.176 These included, according to the Bank, “allowing assets from securitisation vehicles in the EEA to be accepted; accepting the credit rating of insurers in place of the rating of the individual borrower; and to accept assets in other G7 currencies”.177 On 22 March 2020, the Bank referred Greensill’s application and its suggested criteria changes to the CCFF to the Treasury. The Treasury responded to the Bank on 30 March 2020, to say that the Chancellor did not intend to change the criteria. That same day, the Bank informed Greensill that its application did not meet the eligibility criteria, and that the Treasury were not going to change the criteria.178

109.The Bank told us that Greensill then approached the Treasury again, with further proposals for changes to the terms of the CCFF and their application. The Bank added that Mr Cameron approached it on 3 April 2020 “asking for clarity on why HM Treasury had considered that the amended Greensill proposals did not qualify”.179 He was told that that was a matter for the Treasury and was pointed to the fact that the CCFF was aimed at non-financial corporates.180

3–4 April 2020

110.The continued denial of access to the CCFF for Greensill led to an increase in activity from Mr Cameron. On 3 April 2020, he sent the following text to Sir Tom Scholar:

Again Greensill have got a “no”. Am genuinely baffled. Letter says CCFF is there to provide liquidity for “non financial corporates”. That is what we do. The fact the notes are issued by a financial entity is irrelevant. The recipients of the money are all non financials and mostly SMEs! Can I have 5 minutes for a call? This seems bonkers. Am now calling CX, Gove, everyone. Best wishes. Dc.181

111.From 3 to 7 April 2020, Mr Cameron then contacted:

112.This flurry of activity was to culminate in a call between Charles Roxburgh (Second Permanent Secretary at the Treasury), Sir Tom Scholar and David Cameron on 7 April 2020.183 In the lead-up to that call, Mr Cameron sent the following text to the Chancellor:

Really grateful for your engagement on this. As agreed, I think one more conversation—Tom S, Charles R and Lex Greensill—is what’s required. Let’s try and do it today or tomorrow. As I said if there is anything else I can help with, just let me know. [Redacted] Best wishes. Dc.184

113.Mr Cameron appeared particularly keen for Sir Tom to be part of the 7 April 2020 call. He texted Sir Tom on 7 April 2020 as follows:

V much hoping—as agreed with CX [The Chancellor]—that you will be on the call. There is a very specific, contained and restricted proposal that would fulfil the desire to get something done in this space, but it may require your real world, practical and can-do approach. Best, dc185

114.Following the 7 April 2020 call, Mr Cameron texted the Chancellor: “Excellent call with Tom S and Charles R. Many thanks. Dc”.186

115.On 7 April, the Treasury proposed an option to Greensill that was compatible with the terms of the CCFF.187 The Bank told us that “Greensill, however, indicated that it did not wish to pursue this option”.188


116.On 14 April, the Treasury sent the Bank a revised proposal from Greensill for access to the CCFF. The Bank’s analysis was that Greensill’s revised proposal did not meet the CCFF’s existing eligibility criteria.189

117.On 20 April, the Treasury contacted the Bank “regarding options to extend the CCFF to support SCF to SMEs, suggesting HM Treasury and the Bank should discuss further.”190 Within a fortnight, the Treasury would issue a confidential Call for Evidence.191

118.On 23 April 2020, the Chancellor of the Exchequer sent the following text to Mr Cameron:

Hi David, apologies for the delay. I think the proposals in the end did require a change to the Market Notice but I have pushed the team to explore an alternative with the Bank that might work. No guarantees, but the Bank are currently looking at it and Charles should be in touch. Best, Rishi192

119.Lord Macpherson, a former Permanent Secretary to the Treasury, told us that “There are two interpretations to that text. The classic one is that you are trying to get someone off your back, so you say that you are pushing it when actually you are doing nothing. Since further meetings followed, it suggests that something else happened”.193

120.However, Sir Tom Scholar, the current Treasury Permanent Secretary, rejected the notion that he had been “pushed”. He told us that “I have to say that I was not aware of any push at all at the time”.194 The Chancellor argued that:

I really would not personally read too much into that word. It is just a turn of phrase synonymous with “asked”. It is a reasonably common phrase that I would use on an almost daily or weekly basis when talking about work that is being worked on in the Department. It is nothing more than a turn of phrase. The substance of that message was, almost verbatim, the same message that Charles and the team were delivering to Greensill at exactly the same time. In that sense, there is no new information of substance contained in it. As I said, the word is just a turn of phrase.195

The call for evidence and a final effort

121.On 1 May 2020, the Treasury issued a confidential call for evidence. The Treasury told us that this contained “potential targeted changes to the terms of the CCFF which, if implemented, would promote quicker payments of invoices by CCFF-eligible corporates to their UK SME suppliers”. It described its proposals as follows:

• CCFF-eligible corporates would be able to assign their CCFF allowance to an SCF provider who would then issue commercial paper on their behalf, with strict conditions on the use of funds benefiting UK SMEs. Eligible corporates would transfer payment obligations owed to UK SMEs into a SPV [Special Purpose Vehicle] established by the provider. The CCFF would buy the commercial paper issued by the SPV secured by these payment obligations (so its credit risk would ultimately closely mirror that of the underlying investment-grade corporate).

• The proceeds from the sale of the commercial paper to the CCFF would be used solely for the purpose of paying corporates’ UK SME suppliers early. Additional conditions proposed included that UK SME supplier invoices that were outstanding at the time of the corporate’s initial drawing under the new scheme must be paid within 14 days and that corporate participants must sign up to the Government’s Prompt Payment Code.196

122.On 5 and 11 May, the Treasury led two phone calls with Greensill regarding “Greensill’s views on the call for evidence, Greensill’s business model and the SCF market.”197 The Treasury held further calls with Greensill on 13, 14, and 15 May to discuss how to ensure that the scheme extension should benefit, in the main, UK SMEs.198

123.The Treasury explained to us that “while respondents [to the Call for Evidence] supported the objectives of the proposal to support UK SMEs via SCF providers drawing on CCFF, on balance, they did not think the proposed changes would make for an effective intervention”.199 The Treasury described Greensill as the “the most enthusiastic respondent to the consultation”.200 On 18 May, the Treasury told the Bank that the Chancellor had decided not to proceed with an extension to the CCFF.201

124.Sir Jon Cunliffe, following the call for evidence, noted that the Bank had identified that “the majority of this sort of finance is still done by banks, not players that securitise the assets in the market. It turned out that Greensill was very much in favour, but there was not really general support for it”.202 He also told us that “By the time we came to the response to the call for evidence, I do not know whether “surprise” is the right word, but it reconfirmed that there was not a general problem here.”203

125.Also on 18 May, a revised proposal from Greensill was sent to the Bank by the Treasury. On 27 and 28 May 2020, Treasury officials held calls with Greensill representatives about Greensill’s new proposals. The call on the 28 May was also joined by Bank of England officials. On 4 June 2020, the Bank shared a note with the Treasury on Greensill’s proposals.204

126.On 26 June 2020, the Treasury told Greensill for the final time that it would not be eligible for the CCFF. To impart this news, Charles Roxburgh, alongside junior officials, held a conference call with Mr Greensill and Bill Crothers. A letter was also sent by John Glen MP, Economic Secretary to the Treasury, to Mr Greensill reiterating the points made by Charles Roxburgh. Finally, John Glen MP texted David Cameron to tell him the news.205

127.Despite the efforts of its representatives, Greensill never gained access to the CCFF. The lobbying of the Bank of England and the Treasury was therefore unsuccessful.

Rt Hon David Cameron’s lobbying


128.The majority of the lobbying on behalf of Greensill was undertaken by the following three Greensill representatives:

We focus on the role Mr Cameron played in that lobbying, given that he was an ex-Prime Minister and, as seen in the outline of events above, it was often his messages, in whatever form, that would precede meetings with the Treasury. In the period being considered in this Report, he (or his office) engaged in 56 different contacts with the Government on behalf of Greensill.206

His role at Greensill

129.Mr Cameron was employed as an adviser at Greensill, but Mr Cameron told us that lobbying was not intended to be part of the role:

[…] I was not employed at Greensill as a lobbyist, and lobbying the UK Government was never intended to be part of my role. However, in the economic turmoil caused by Covid, the Government quite rightly introduced several schemes to help ensure that credit would continue to be expanded to business. The Greensill proposal was to make this even more effective, and I believed that it should be considered by Government.207

130.Mr Cameron, by his own admission, had a strong economic interest in the performance of Greensill. Although Mr Cameron told us that the exact amount of his renumeration at Greensill was a “private matter”, he did tell the Committee that:

I was paid a generous annual amount—far more than what I earned as Prime Minister. I had shares—not share options—in the business, which vested over the period of time of my contract. It is important for the Committee to know that I absolutely had a big economic investment in the future of Greensill. I wanted the business to succeed. I wanted it to grow.208

131.The economic benefits from Mr Cameron’s relationship with Greensill were clearly very significant. They were also represented by his use of Greensill’s private jets, both for business purposes and a handful of times on “other visits”, which Mr Cameron later confirmed to the Committee were “all for short haul flights, and tax was paid appropriately for any benefit received”.209

132.In his oral evidence to us, Mr Cameron further highlighted the level of engagement he had at Greensill, explaining that he had attended Board meetings:

I would take part in the board meetings and listen to the arguments and make contributions, sometimes particularly on geopolitical matters and suchlike. So, yes, I was a regular attender and would contribute, but of course there are a lot of board issues that are director-only. I did not sit on the credit committee. I did not sit on the risk committee. I did not sit on the audit committee or any of those sorts of functions, so I wasn’t involved, as it were, in the day-to-day running of the business or credit decisions, but, yes, of course I would listen to the discussions and make contributions.210

133.However, in a follow-up letter to us, Mr Cameron emphasised the limits to his role at the Board:

[…] while I was invited to attend most routine Greensill Board meetings as an Adviser, I was not a Director of Greensill Capital and did not sit on any of the Board committees. I had no executive responsibility whatsoever, no voting rights, and no ability to direct the Board, Greensill executives or employees. When there were key Board meetings in the run up to Greensill filing for administration, for example, I was not invited and did not attend. The last Board meeting I attended was on 10 November 2020.211

134.Lord Macpherson set this lobbying by Mr Cameron in the context of his experience as a Permanent Secretary of the Treasury:

I suppose you can question his judgment in working for Lex Greensill, but let us put that to one side. There is nothing wrong with people getting in touch with the Treasury, and generally, if a former Prime Minister rings you up, as Tom Scholar pointed out, you tend to take the call. Normally when a former Prime Minister rings you up, they are talking about some broader issue of policy and it is worth listening to that. In this case, it seems clear that Mr Cameron was focusing on something that directly related to his interest in Greensill. He was clear about that. I do not see anything wrong with engaging on that basis, provided that you write it down and record what the individual said, and provided that, once they have made their point, you do not give them special treatment.212

135.Sir Tom told us that “I did not know that he was working for Greensill until that point [when Mr Cameron approached Sir Tom], so that was news to me. Obviously he is a former Prime Minister, but it was equally clear to me that the issue he was raising related to the company he was working for.”213 Sir Tom denied that Greensill got more attention because it had an ex-Prime Minister lobbying for it.214 The Chancellor was also adamant that Mr Cameron’s involvement, despite him being an ex-Prime Minister, had had no effect on the Treasury’s work. He told us

We look at the issue and I looked at the issue on the merits of it, and so the identity of the person talking about it was not relevant to the amount of attention and proper diligence that the issue got and required. That was driven by the circumstances we were facing at the time with acute financing needs for small and medium-sized companies. Therefore, it was entirely right that we diligenced ideas.

This was one of many strands of work, and in fact probably the one we spent the least time on, over this period. Nevertheless, it was an avenue that was worth exploring, given the context. It was worth doing the work and ultimately concluding that it was not one that we should take forward, whereas we did take forward various other proposals.215

136.Mr Cameron was acting as a representative of Greensill, with a very significant personal economic interest in the firm. As soon as that had been identified by the Treasury, the fact that he was an ex-Prime Minister should have been irrelevant to the Treasury’s treatment of his approach. That is what the Treasury has told us happened. We consider that view later in this report.


137.Some of those who Mr Cameron lobbied on behalf of Greensill were known to Mr Cameron from his time as Prime Minister. Sir Jon Cunliffe, for whom Mr Cameron specifically requested contact details at the Bank, was from July 2007 to December 2011 the Prime Minister’s Advisor on Europe and Global Issues, a period which in part had coincided with Mr Cameron’s tenure.216 Sir Tom Scholar was also the Prime Minister’s adviser on European and Global Issues, sherpa for the EU, G7 and G20, and Head of the European and Global Issues Secretariat during Mr Cameron’s period in office.217 Sheridan Westlake had been a Special Adviser to the Prime Minister, when Mr Cameron was in office.218

138.The texts from Mr Cameron at times express a familiarity with those he was lobbying. For example, he exchanged the following texts with Sir Tom Scholar, beginning on 5 March 2020:

[9.35] Hope you are still alive and well. [REDACTED] Three questions: is Sir Jon C still at the bank? Do you have a number? Can I give you lunch once the budget is done? Love Dc.219

Sir Tom responded:

[10:36] Great to hear from you. Here’s the Cunliffe number. +44 203 461 [REDACTED] Can also supply emails, mobile numbers, you name it.

[10.37] Lunch would be great. Quite a lot to talk about! I’ll also see you [at the leaving event for Mark Carney] chez Rishi in a fortnight. Unless it gets Covid cancelled, which seems quite likely, since the world’s central bankers are in [REDACTED] [crisis] mode.220

Mr Cameron responded on 6 March:

Thanks. Will fix for after that. Never quite understood how rate cuts help a pandemic. [REDACTED] I am riding to the rescue with Supply Chain Finance with my friend Lex Greensill—my new job [REDACTED] See you with [sic] Rishi’s for an elbow bump or foot tap. Love Dc221

139.However, when questioned on his “Love Dc” sign off, and the strength of his relationship with Sir Tom, Mr Cameron said:

I think I have seen him perhaps once or twice since leaving office. Anyone I know even at all well I tend to sign text messages with “Love Dc”. I don’t know why. I just do. My children tell me that you don’t need to sign off text messages at all and that it is very old-fashioned and odd to do so. Anyway, that’s what I do.222

140.Sir Tom described one of his meetings with Mr Cameron as follows:

We met somewhere in Whitehall in the early evening, at the end of the day, but just for an hour or so. He was, at that time, telling me about work that he was doing on failed states, which drew on some of the work that he had done as Prime Minister and that I had supported him on in the G7 and the G20. That was what he wanted to talk about.223

141.Another expression of the familiarity of Mr Cameron with those he was contacting was some of the communication methods he used: notably texts and whatsapp. Mr Cameron appeared to express regret about that:

Lobbying itself is a necessary and healthy part of our democratic process, but I accept there is a strong argument that having a former Prime Minister engage on behalf of any commercial interest, no matter how laudable the motives and cause, can be open to misinterpretation. Perhaps that is especially so when the communication systems we all use, particularly in the heat of responding to a crisis, are text, phone and app, rather than the more formal approach of writing. I hope it is accepted that nothing I did was in breach of the rules, but on the wider test of what is appropriate, as I have said previously, it would be better only to use the most formal means of contact, via a letter.224

142.Mr Cameron’s use of less formal means to lobby Government showed a significant lack of judgement, especially given that his ability to use an informal approach was aided by his previous position of Prime Minister. Mr Cameron appears to accept that, at least to some degree, his judgement was lacking.

143.Though they have been downplayed in evidence to the Committee, there were obvious personal links between Mr Cameron and those he lobbied in Government on Greensill’s behalf. Yet we have not seen evidence of a time or process when and by which the potential risks of those connections were considered by the Treasury, and potential mitigations put in place. The Treasury should have encouraged Mr Cameron at the initial stage of his lobbying into more formal methods of communication, and there should have been a discussion as to whether Mr Cameron’s ongoing contact posed any reputational risks to the Treasury, and whether, as a consequence, mitigation was required. In the light of these events we expect the Treasury to put in place more formal processes to deal with any such lobbying attempts by ex-Prime Ministers or Ministers in the future and to publish the process which they will follow should similar circumstances recur. We would expect any such processes to be consistent with any reforms which might be introduced as a result of the lobbying undertaken on behalf of Greensill.


144.When the lobbying by Mr Cameron described in this Report became public, there was disquiet that a former Prime Minister had used such informal means and prior connections to approach people still in public life with a consequence of which being the promotion of his own economic interest. One media report noted that “He appears to have used personal contacts to seek preferential treatment for a company in which he had a financial stake”.225 Another referred to it as “the biggest UK lobbying scandal in a generation”.226 Hannah White, Deputy Director for the Institute of Government, however provided the following commentary on why Mr Cameron had not breached the rules at the time:

It is correct that nothing Cameron has been criticised for is against the UK’s rules on lobbying. Once he had left office, he was no longer bound by the rules on disclosure of financial interests that govern MPs, or by the Ministerial Code, which precludes ministers from conflicts between their official position and their personal financial interests. As more than two years expired between his resignation as PM and starting work for Greensill, he was not required to bring the role to the attention of the Advisory Committee on Business Appointments (ACOBA)—the body tasked with advising ministers and senior civil servants on whether appointments they take on after leaving government might give rise to any justified public concern, criticism or misinterpretation.

Because Cameron was employed by Greensill, rather than contracted as a consultant, he was not required to register his lobbying activity with the Office of the Registrar of Consultant Lobbyists (ORCL), the body established in 2014 during his first term as prime minister.227

145.Given the concern that had been expressed about his lobbying on behalf of Greensill, Mr Cameron provided us with suggestions for potential reforms:

If lobbying registration can be extended to in-house operatives, without excessive bureaucracy or damaging the interests of charities, there is a case for making that change. The body that vets jobs for former Ministers and civil servants—ACOBA—is well established and, in my view, works, but its examination of appointments should be mandatory and comprehensive, and its decisions should be enforceable. As I said at the outset, former Prime Ministers are in a different category, and I have read the arguments for different, special arrangements. A longer period before any contact with Government over any commercial issue could be appropriate, and a new special committee, over and above ACOBA, to advise on post-office appointments might help with choices that need to be made.228

146.The Committee on Standards in Public Life reached conclusions in its recent report on the effectiveness of standards regulation in England similar to the suggestions made by Mr Cameron to us. Its recommendations included:

147.We accept that Mr Cameron did not break the rules governing lobbying by former Ministers, but that reflects on the insufficient strength of the rules, and there is a strong case for strengthening them. Oversight of policy in this area does not fall within our remit or the terms of reference of this inquiry. We note the ongoing inquiry into the propriety of governance in light of Greensill by the Public Administration and Constitutional Affairs Committee.

Intelligence on Greensill

148.In the face of the lobbying by representatives of Greensill, outlined above, we explored reasons why the Treasury, and the Bank, could have been cautious in their dealings with Greensill. These included the extent to which Greensill’s proposals would help UK SMEs, its description of itself as a fintech, and other matters relating to its financial health and reputation. We consider these matters below.

Greensill and SMEs

149.One of the main reasons presented by Greensill representatives for it to be included in the CCFF was that it would support UK SMEs. In his evidence to us, Mr Cameron emphasised that supporting SMEs was his motivation for his contacts with the Treasury. He said:

[…] I can tell you that the motivation for contacting the Government was that I thought we had a really good idea for how to help extend credit to thousands of businesses, and I would quite like to explain why I thought it was such a great idea. I have sat on the other side of the fence, in Government, where you have a credit crunch and you have difficulties in the credit market, and you are desperate to get banks lending and you are desperate to get credit to businesses. I well remember standing at the Dispatch Box and being asked, “This scheme that you announced six months ago—how many companies are taking part? How many banks are taking part?” and often having to give very disappointing answers. So I was very keen for us to put forward our scheme, because I thought it was absolutely in the public interest to try and get money into small businesses.230

150.The potential for the provision of support for SMEs was also presented by the Treasury as the reason for its engagement with Greensill’s representatives. The Treasury explained that at the time of Greensill’s initial engagement “… UK SMEs were facing extraordinary challenges. HMT was receiving feedback from businesses that they needed more support”.231

151.The desire to help SMEs was also cited by the Treasury as their reason for proceeding with the call for evidence in May 2020. Charles Roxburgh, Second Permanent Secretary at the Treasury, told us that:

It was perfectly reasonable to look at whether we could find a way to use CCFF moneys, for people who already had access to it, to support their small businesses. It did not work but it was a reasonable idea to invest a very small amount of time in exploring.232

152.Yet, throughout the period, questions were asked as to whether Greensill’s proposals would actually meet the needs of UK-based SMEs. A 21 March 2020 email to Charles Roxburgh, apparently from a Treasury official, offering thoughts on a call with Greensill, noted that the Treasury ought to press on the geographical spread of suppliers, since Greensill’s “pitch” was that this was an opportunity to bail out important parts of the UK real economy.233

153.In analysing Greensill’s request for an extension to the CCFF in April 2020, the Bank’s view was “that Greensill did not play a sufficiently large role in providing funding in scale to UK SMEs to warrant a specific extension.”234 The Bank also told us that intelligence from its network of Agents around the country did not find evidence that Greensill played a major role in credit provision to SMEs.235 In fact, the Bank’s view at that time was that “since investment grade larger companies had access to alternative sources of finance (including the CCFF), any lending by Greensill would probably be focussed on allowing sub investment grade larger companies to increase leverage.”236

154.This concern that Greensill’s proposals would not meet the needs of UK-based SMEs was also seen in the evidence from the Treasury. It gave as its reason for refusing Greensill’s request to alter the CCFF in April 2020 the following:

HMT concluded that Greensill’s proposal (allowing their Luxembourg-based Special Purpose Vehicle to issue notes to the CCFF and use the funds for SCF purposes) was unlikely to bring sufficient benefits for UK SMEs to justify such a significant change to the CCFF for one particular financing model, at a time when many other businesses were requesting support.237

155.The central argument of Greensill’s attempt to gain access to the CCFF was that it would substantially benefit a very significant number of UK SMEs. Neither the Treasury nor the Bank of England believed there was merit in the claim that supporting Greensill would substantially benefit the SME sector in the UK. It seems that this was more of a sales pitch than a reality.

Greensill as a fintech

156.Another point emphasised by Mr Cameron in his lobbying was that Greensill was a Financial Technology (fintech) firm. The Financial Stability Board238 defines fintech as “technologically enabled innovation in financial services that could result in new business models, applications, processes or products with an associated material effect on financial markets and institutions and the provision of financial services”.239

157.In an email sent to the Financial Secretary to the Treasury, Rt Hon Jesse Norman MP, on 3 April 2020, Mr Cameron argued that “Greensill is a significant UK employer and its most valuable Fin Tech [firm], and we are keen to use our technology to help in this time of national crisis.” Later in the same email he suggested that “Surely HMG should be seen to be supporting UK fintechs—who are creating employment, driving innovation and already delivering billions in ultra low-cost liquidity to British SMEs—particularly when it has been proven that banks are struggling to do so.”240

158.Mr Cameron may have been hoping to tap into an ongoing interest of the Government in supporting fintech. In 2014, George Osborne, then Chancellor of the Exchequer, stated at the launch of a new trade body for fintech that “I’m here today because I want the UK the lead the world in developing Fin Tech.”241 Lord Macpherson told us that “Every Government likes to be associated with success stories, such as the dotcom boom. Fintech is definitely the flavour of the month.”242

159.However, there has been scepticism about whether Greensill was a fintech firm. Lord Myners argued that “We have very few fintech companies. Even though the former Prime Minister has described it as a fintech, Greensill was simply not a fintech. It had 700 employees; it was a paper-based company. It was not in the world of technology at all.”243 Lord Macpherson was also clear: “this simply was not fintechery.”244

160.When we asked Mr Cameron about this, he told us:

I certainly wouldn’t pretend to be an expert in this, but it seemed to me that what Greensill were doing with partners such as Oracle or Taulia, or Textura in the past, was using the information in a company’s ERP245 to make sure you could extend credit to suppliers, and indeed to employees, faster, and I think that does qualify as fintech, because the fin is the access to the deep capital markets and the tech is using the ERP to make credit decisions better and faster. I know that all sounds very techy, but ultimately what it can be about is trying to make the cost of your mobile phone lower, making sure you can access your pay on a daily basis rather than waiting until the end of the month. I think these are quite powerful changes. So whether you want to call it tech-enabled or fintech is a matter of choice, but it is certainly using technology in capital markets to make people’s lives better.246

161.Regardless of its status, both Charles Roxburgh and the Chancellor argued that they had not been influenced by the description of Greensill as a fintech when they were lobbied. The Chancellor told us:

I would like to think that we are able to diligence things on their actual merits, rather than what the marketing spin of them or the branding might be. You have heard me talk about this for an hour and whatever. I probably have not mentioned the word “fintech”. This was about providing credit to small and medium-sized companies and supply chain finance. That is really all there is to it.247

162.The use of the term fintech by Mr Cameron highlights wider questions about the risks being run by the Government’s support for innovation in this area. Professor Aikman told us:

The Chancellor writes an annual letter to the Bank, listing what [the Government’s economic] objectives are. In the most recent letter, it lists promoting fintech and its contribution to […] productive finance and economic growth. The Bank has this delicate balance between making sure the system is resilient and sound, which is its core objective, and being asked to look at where it can take actions to promote businesses like fintech. There are questions about whether that balance is exactly right. It involves trade-offs.248

163.Charles Roxburgh, while noting that “fintech is actually a great success story in this country, and we should be very proud of the innovation, competition and better customer outcomes that this has brought”, acknowledged that there were also risks.249 He argued that “We have encouraged and the regulators have taken the lead in learning how to regulate innovation in a way that maintains innovation and competition, but protects consumers and market integrity. It is a difficult balance, but to date our regulators have done a good job.”250 He echoed Professor Aikman’s point about there being a balance in supporting fintech firms, telling us that:

[…] we need to maintain that balance of innovation, competition and good regulation. It would be a mistake to lurch too far to one extreme, either to have too much innovation with too much risk, or conversely to shut down the innovation and have a less competitive, less innovative, higher-cost market that delivers worse for customers. We need to get the balance right.251

164.The description of Greensill as a fintech firm has been questioned in the course of our inquiry. But in the lobbying by Mr Cameron this description was used with obvious intent, given the Government’s desire to promote fintech. In our view, the claim that Greensill Capital was a fintech appears doubtful. Witnesses have acknowledged that the Government has to be careful when balancing the risks around regulation and innovation. Despite the fact that the Treasury does not appear to have been influenced by the claim that Greensill was a fintech business, care does need to be taken with so called fintech businesses as to whether they are what they claim to be and whether claims about the ‘tech’ are not hiding a ‘fin’ problem.

Assessing the financial health of Greensill

165.As seen in Chapter 2, a material portion of Greensill’s funding was provided by investors in certain funds. Yet the onset of the pandemic saw those markets come under strain. On 15 March 2020, Mr Greensill emailed Sir Jon Cunliffe with the following commentary:

The disruption to supply chains and the financing of them is real. In the last week we have seen a great many fixed income investors who support the asset class step back—meaning liquidity could well become a major issue in the coming days.252

Alongside this risk to its funding, we have also seen in Chapter 2 that Greensill had a particular ‘concentration risk’ to the GFG Alliance.

166.Given that Greensill had been placed in administration by the time of our inquiry, we explored whether, in the period of lobbying considered by this report, the Treasury and Bank should have been more aware of any risks to Greensill at the time of the lobbying.

167.The position of the Treasury was that it had no reason to undertake due diligence in respect of Greensill, since it had never intended to lend to it. Mr Roxburgh explained this point to the Public Accounts Committee as follows:

It would be completely disproportionate to conduct in-depth financial due diligence on a company simply before having a conversation with them. Had we extended credit to the company—which we did not, and would not have done—through the CCFF, that would have been the time to do due diligence.253

168.However, there was information flowing into the Bank of England that could have suggested that something might have been amiss at Greensill, or with the customer towards which Greensill had a concentration risk, the GFG Alliance:

169.Given potential weaknesses in its business model, we queried whether Greensill’s desire to access the CCFF was to support its business, potentially through lending to firms to which it had a concentration risk. Mr Greensill told us, however, that his approach to the CCFF was for the following reason:

I think a correct characterisation is that we did not know what was going to happen next. We felt that having, for want of a better expression, a liquidity insurance policy, which the CCFF provided to many businesses in the country who were making a material contribution to the country, was a prudent thing for us as a business to do, simply because nobody knew what was going to happen next.262

170.Mr Greensill told us that his first concerns about Greensill as a company were in December 2020, following interactions with the German regulator.263 Mr Cameron also cited December 2020 as the time when he was first concerned about Greensill’s viability. He told us:

The first time I became concerned that the company might be in serious financial difficulty was in December 2020 following a call I received from Lex Greensill, during which I was told that the company’s planned capital raising was not going as well as had been hoped.

Up until that point, I firmly believed that Greensill was in good financial health. In the autumn of 2020, I understood Greensill was on track for a relatively strong year financially and it had embarked upon what looked likely to be a successful capital raising.264

171.When we pushed Mr Cameron on whether there was more to his lobbying than just supporting SMEs, he told us:

That is not what I felt at the time and it is not what motivated me. I think there is a huge difference between constrained capacity in the credit markets and the risk of a business failing. I think that when Lex Greensill was in front of you he also said that he did not believe that there was a danger of the business failing at that time. He did not think the business faced failure until—as I did—December 2020. If you look at what went on and happened in the rest of that year, the business actually had quite a successful year, extending a similar amount of credit in 2020 to what it did in 2019.

On the issue of defaults, like any financial institution, you have clients that occasionally default, but the insurance effectively covered that, as far as I understand. Lex Greensill gave the example of NMC, which did fail, for all sorts of reasons, but Greensill was able to recover the money for its clients because of the insurance situation. I can absolutely say to you that I really believed in the solution that we had and were putting to Government. I thought it would make a difference—that was my motivation for doing so. I have spent most of my adult life in public service. I believe in it deeply. I would never put forward something that I didn’t think was absolutely in the interests of the public good. That is what I thought I was doing on Greensill’s behalf.265

172.Mr Cameron also provided the following factors as to what had encouraged him in his work for Greensill:

One point I would make is that when you are an adviser to a company but not a director, one of the things you ask yourself is, does this company have an effective legal function? Does it have an effective credit committee, risk committee, audit committee? Is it a strong board? And the answer to all those questions seemed to me to be pretty positive, and of course as an adviser, not a director, you take comfort from that.266

173.Mr Woods told us that from December 2019, the PRA “were sharing information pretty fully and fairly regularly with the Treasury about what we were up to with Wyelands Bank. Of course, to a limited extent, because of the opacity of the GFG Alliance, that did throw some light on the GFG Alliance as well”.267 However, the Treasury did not appear to have linked this information to Greensill. Charles Roxburgh told us that:

They were separate entities. Wyelands Bank was owned by the GFG Alliance. Greensill was a provider of finance to the GFG Alliance but not part of it. We were aware, because, as the Governor told you, they [the Bank of England] had shared with us information that they had raised concerns with the NCA about the GFG banks—Commonwealth Trade Bank and Wyelands—in December [2019].

In May [2020], the Bank wrote to us formally indicating the issues and, as the Secretary of State for Business said yesterday, we shared that information with BEIS, because it was relevant to its consideration of an approach that it had had from Liberty for finance. We were aware and we passed the information on. It was about Wyelands and the Gupta Family Group Alliance. It was not information about Greensill.268

174.The Chancellor also told us that there was nothing about Greensill at the time, other than the squeeze on credit markets, that had given the Treasury cause for worry about its future. He told us:

We were not aware of any specific concerns with Greensill at that time from the Bank and others, other than what they had told us, which was a particular financing issue in the commercial paper market that financed the supply chain side of it, but no particular issues around their own business at all.269

Reputational issues

175.Prior to the period of lobbying covered by this report, there had been issues raised in press reporting that concerned both Greensill and the GFG Alliance. A Financial Times article in March 2019 reported on concerns around links between Mr Greensill, Mr Gupta and Tim Haywood, from GAM Holdings, an investment firm, one of whose funds provided finance to Greensill. It is reported that Mr Haywood was fired from GAM for “gross misconduct”.270

176.In June 2019, Lord Myners tabled a Parliamentary Question about whether the Government was “investigating, or intend to investigate, the (1) management of, (2) investment valuations used by, and (3) relationships between managers and businesses invested in, the GAM Greensill Supply Chain Finance Fund”.271 A Reuters article from around the same time quoted Lord Myners as saying that “The FCA needs to be looking at the processes followed by GAM and the appropriateness of the investments for a fund that was marketed as low risk”.272

177.However, despite these “reputational issues”, Mr Roxburgh said that it was appropriate for the Treasury to hold meetings with Greensill. He told us that:

There were reputational issues around Greensill. You could read the newspapers at the time. There were issues around the reputational side of Greensill, but we have to talk to companies, even if they have bad press. The specific proposal from Greensill was the one that we considered and rejected in two weeks. From 4 April onwards, we were thinking about a broad, industry-wide scheme to see whether we could support small businesses through a broad, industry-wide supply chain finance scheme. It did not work, but, had it been open, it would have been open to any non-bank provider of supply chain finance.273

178.The National Audit Office’s recent report on its Investigation into the British Business Bank’s accreditation of Greensill Capital also notes that other agencies of the Government were paying attention to the reputational issues around Greensill. For example, the NAO reports that UK Export Finance (UKEF) refused applications for Export Development Guarantees for lending to Greensill in June and September 2020. The NAO states that “UKEF’s due diligence, which included reviewing publicly available sources and media reports, identified concerns relating to Greensill’s governance and how exposed Greensill might have been to some of its customers. UKEF considered that these potentially raised the risk profile of Greensill”.274

Time spent on Greensill’s proposals

179.In its evidence, the Treasury noted that the period of lobbying by Greensill and its representatives was also a time when the Treasury was “extraordinarily busy” on other policy matters related to the pandemic.275 The Chancellor noted the significant array of other support programmes that were being developed:

If you think about it, over this timeframe we introduced the CBILS loan scheme in March; in April, we essentially had CBILS 2.0, where we revised lots of conditions and the way the CBILS scheme worked in order to make it work better; we also introduced the CLBILS scheme in April. Then in May we upsized the CLBILS scheme; we introduced the bounce back loan scheme and the future fund. In June, we introduced the trade credit insurance fund. On top of that, we did three calls for evidence regarding financing for small and medium-sized companies looking at other things, which we ultimately did not take forward.

That was just on the providing of finance to businesses, let alone the half a dozen other policies we had to support businesses, whether that was furlough, VAT cuts, business rates cuts, VAT referrals and the like. There was an enormous amount of work going on, rightly, to support businesses. In the area of providing finance to them, this was really a very small part of that. Ultimately, we decided not to take this forward, but it was absolutely right to diligence the options in this space, not least because it had been alerted to us that this particular segment of the market may be one that required attention.276

180.In their evidence to us, officials and ministers dealing with the lobbying by Greensill’s representatives were keen to highlight that this lobbying was not a significant burden on them. Sir Jon Cunliffe noted that “It was not taking up a very large part of my day.”277 Charles Roxburgh argued that:

There is a disproportionate focus on the transparency return. That is not an accurate reflection of how I spent my time at this time. I just disclosed all my meetings and short phone calls. That is not an accurate reflection of how I spent my time during these months. This was a very small part of my time, when I was working on much more pressing, more important issues throughout this period.278

181.The Chancellor also argued that “This was one of many strands of work, and in fact probably the one we spent the least time on, over this period.”279

182.On more junior staff, the Bank indicated that the resource in evaluating Greensill’s proposals, including the potential extensions to the CCFF, and supporting the call for evidence:

…was approximately 2.5 FTE for a period of approximately six to eight weeks. This was resourced by reprioritising the work of existing Bank staff and no external expenses were incurred. A similar level of resource was involved in performing analysis supporting evaluation and development of other lending schemes at the time.280

Charles Roxburgh indicated to the Committee that the Treasury used a similar amount of resource as the Bank in its work on Greensill in the period from 20 March to 26 June.281

183.When we pressed the Chancellor of the Exchequer on whether there had been too much time spent by the Treasury on this matter, he noted:

I did not know, and nor did Charles [Roxburgh] or anyone else, at the beginning of that process where the policymaking process would end up. It is right that we do the work on these things and that we get to the right answer. In this particular case, the right answer was not to take this proposal forward. The other interventions that we put in place did work, but, again, we did not know that at the beginning.282

184.When we asked the Chancellor why he wouldn’t accept the proposition that the proposals as pressed by Mr Cameron would have received at least some degree of special attention given that Mr Cameron was a former Prime Minister, he replied “Because I do not believe it is right.”283

Coronavirus Large Business Interruption Loan Scheme (CLBILS)

185.Greensill, in the end, never accessed the CCFF. However, it did become an accredited lender in the Coronavirus Large Business Interruption Loan Scheme (CLBILS) in June 2020.284 CLBILS was administered by the British Business Bank, which is a government-owned business development bank whose shareholder is BEIS.285286

186.In a letter to the Shadow Chancellor of the Exchequer on 20 April 2021, the British Business Bank (BBB) emphasised that the CCFF and CLBILS were two very different schemes:

The two schemes, and their eligibility criteria, are very different. The Bank of England administers the Covid Corporate Financing Facility (CCFF) whereas the BBB administers CLBILS. CCFF is aimed at providing COVID-19 financial support to investment grade rated businesses whereas CLBILS aimed at providing COVID-19 financial support to UK mid-cap and larger enterprises with a turnover of over £45 million. The CCFF supported companies directly (and excluded financial services firms) whereas CLBILS was a delegated guarantee scheme which operated through a wide variety of lenders. Given the separate nature and purpose of these schemes and the entirely different eligibility criteria, it is not possible to compare accreditation decisions. Applicants that were suitable for one scheme may not be suitable for the other.287

187.Mr Greensill told us that Greensill had lent £400 million (the National Audit Office has reported that this was through eight loans, seven of which were to firms connected to the GFG Alliance288) under CLBILS, and £18.5 million under CBILS.289 Given that the guarantees from the British Business Bank cover 80% of the amount lent, Mr Greensill therefore placed the exposure under the schemes at £334,800,000.290

188.The CLBILS limit for guarantees on lending by an accredited lender to an individual firm could be raised above £50 million. However, the British Business Bank was required to consult with the Treasury for such approval.291 Some of the final contacts by Mr Cameron in the period under review in this Report were related to seeing whether that limit could be lifted. In mid-June, Mr Cameron sent messages to Nadhim Zahawi MP, who was at the time Parliamentary Under-Secretary of State for Business and Industry, and to Richard Sharp (who is reported to have been an adviser to the Chancellor on the pandemic).292

189.In the end, no such approval for enhanced accreditation was provided. The Treasury told us that:

HMT’s only role in the CLBILS process for large loans is, if the BBB are prepared to accredit lenders at this level, they would consult with HMT on providing that lender with enhanced accreditation. The BBB did not approach HMT with a proposal to approve enhanced lending accreditation for Greensill, and as a matter of public record Greensill’s individual loan limit remained at £50m for the scheme.293

190.In April 2021, the Financial Times reported that GFG Alliance had split companies to allow greater funding to the Alliance by Greensill under the CLBILS scheme, while keeping within the £50 million cap for each transaction.294 Mr Greensill was not willing to discuss individual customers,295 but he told us that:

Greensill Capital was selected by the British Business Bank as being eligible to operate the scheme. The credit that we extended to our customers complied with our ordinary credit rules and procedures, which were scrutinised by the British Business Bank. Each facility that we provided was reviewed by a top-tier London law firm, and where there was any question about the interpretation of the British Business Bank rules, we actually had that leading law firm directly discuss the matter with the British Business Bank to ensure compliance with the rules. So, it is my opinion that every facility that we provided complied with the British Business Bank rules.296

191.However, the July 2021 Report by the National Audit Office states that:

The [British Business] Bank was concerned that Greensill’s activity may have contravened the scheme rules on lending to groups. Greensill was not accredited to the Larger Scheme Facility. Given that, if the GFG Alliance borrowers were to be treated as a single group, Greensill’s lending was £300 million above the lending limits applicable to it.297

192.The Treasury has said that it had no role in the accreditation decision made by the British Business Bank to allow Greensill to take part in the CLBILS scheme.298 However, given the flow of information to the Treasury and the Bank of England about both Greensill, and GFG alliance, we questioned the Treasury on what information it had passed on to the BBB.

193.Charles Roxburgh provided the following information as to what the Treasury passed on to BEIS:

We were aware, because, as the Governor told you, they had shared with us information that they had raised concerns with the NCA about the GFG banks—Commonwealth Trade Bank and Wyelands—in December. In May, the Bank wrote to us formally indicating the issues and, as the Secretary of State for Business said yesterday, we shared that information with BEIS, because it was relevant to its consideration of an approach that it had had from Liberty [Steel] for finance. We were aware and we passed the information on. It was about Wyelands and the Gupta Family Group Alliance. It was not information about Greensill.299

194.Patrick Magee, Chief Commercial Officer of the British Business Bank, speaking to the Business, Energy and Industrial Strategy Committee, noted though that “There was no information passed to the British Business Bank about Wyelands Bank, but, as I was saying earlier, we were accrediting Greensill, not GFG, and certainly not Wyelands Bank.”300

195.Charles Roxburgh also refuted any suggestion that there was more the Treasury could have done in relation to the BBB’s acceptance of Greensill as an accredited lender. He told us “We shared the relevant information at the relevant time.”301

196.For the Bank’s part, Andrew Bailey noted that “We have no gateway under statute either to the British Business Bank or to BEIS. We have no gateway to provide information. As I said earlier, we kept the Treasury fully informed, but we have no gateway to the British Business Bank or to BEIS”.302 Mr Woods, Deputy Governor of the Bank of England for Prudential Regulation, also noted that:

[…] we have a gateway to the Treasury. It is quite a full gateway; we can share with it confidential information. We have no such gateway with the British Business Bank, nor indeed with the Secretary of State for Business in his role as the Minister for CLBILS. The only gateways that exist to BEIS are very narrow ones in cases where the Secretary of State has appointed individuals to undertake Companies Act investigations.303

197.However, on the potential for reform of the gateways, Mr Woods noted that:

You may well be thinking—I am not sure—that those gateways should be much broader. I am not sure about that, because, if I look at it—perhaps this is too narrow a view—from the point of view of our responsibilities, if firms felt that information passed to us would be passed in a generalised way into Government, it could quite seriously impede what we do. Parliament is being quite wise in putting quite tight constraints on this. Whether they are in exactly the right place, one can debate. Tight constraints are quite sensible for what we do.304

198.In its work on the Greensill’s CLBILS application, the NAO found that:

Our review shows that the [British Business] Bank followed a streamlined version of its established process for accrediting lenders for CLBILS when assessing Greensill’s application. That accreditation process was streamlined in response to the policy need to deliver money to businesses at pace during the pandemic. In the case of Greensill, applying a less streamlined and more sceptical accreditation process might have led the Bank to further question several of Greensill’s statements, including on: loan default rates; exposure to specific borrowers and product types; and its business model and ethical standards. Each were the subject of press reports prior to accreditation.

It is to the Bank’s credit that it quickly picked up the loans allegedly in breach of the scheme rules, and shows that the post-accreditation monitoring process was, in this case, effective. But had the Bank done more due diligence, including on the loans Greensill claimed it intended to make, it is possible that this situation could have been avoided.305

199.The guarantees offered by the Government under the Coronavirus Large Business Interruption Loan Scheme, which are currently suspended, were not direct exposures to Greensill itself but were contingent liabilities relating to the companies to which it lent. But Greensill’s symbiotic relationship with the GFG Alliance meant that there was always a risk that Greensill would funnel money towards the GFG Alliance. The Bank had shared with the Treasury information concerning the GFG Alliance through the regulation of Wyelands Bank. While information does appear to have been passed through to BEIS, it appears that the information was not passed on by BEIS to the British Business Bank. There remains an open question as to whether the Treasury, BEIS and the British Business Bank missed an opportunity to prevent these guarantees being extended. We welcome the examination by the BEIS Committee of this issue. We also note the finding by the National Audit Office that a more sceptical process might have prevented the acceptance of Greensill as an accredited lender.

200.The Treasury should use the events concerning Wyelands Bank, the GFG Alliance and Greensill to review the information gateways under the Financial Services and Markets Act 2000, and specifically whether there is scope to provide better information, in a more timely fashion.

Overall conclusions

201.Despite the lobbying of Greensill representatives, the Treasury did not amend the rules of the CCFF or allow its participation. But this appropriate decision does not necessarily mean that the Treasury handled this situation perfectly. Dealing with the lobbying of Greensill, and Mr Cameron, required Government resources and such lobbying would always run the danger that he would be perceived to be detrimental to the appearance of propriety at the Treasury.

202.We question Mr Cameron’s judgement in relation to his lobbying on behalf of Greensill. Mr Cameron appears to have relied heavily on the Board of Greensill as a guarantee of its propriety and financial health, when arguably he should have taken a broader and more enquiring assessment of the business. There were signals available to Mr Cameron at the time when he was lobbying the Treasury and others which might have led him to a more restrained approach.

203.We accept that at the start of the engagement with Mr Cameron, and therefore Greensill, it was right, given the considerable need to provide support to businesses at the start of the pandemic, for the Treasury and others to consider seriously the proposals presented by Greensill for its inclusion in the CCFF.

204.We note the firm conviction of the Treasury that the fact that Mr Cameron had previously been Prime Minister and was personally well connected to those he was lobbying had no meaningful effect on how Greensill’s application for access to the Covid Corporate Financing Facility was dealt with, including the time spent on it by those at a senior level. Or, put another way, that if the approach had come from someone else less prominent or connected to the Treasury, then overall it would have been given a similar quality and level of attention and engagement. We are very surprised about this, given that Mr Cameron was an ex-Prime Minister, who had worked with those he was lobbying, had access to their mobile phone numbers, and appears to have been able to negotiate who should attend meetings. The Treasury’s unwillingness to accept that it could have made any better choices at all in how it engaged in this case is a missed opportunity for reflection. That said, we accept that Treasury officials and Ministers behaved with complete and absolute integrity in their handling of Mr Cameron’s lobbying. The Treasury also took the right decision in preventing Greensill from accessing the CCFF.

166 Oral evidence taken on 4 March 2020, HC (2020–21) 122, Q2

170 “Asset Purchase Facility: Secured Commercial Paper”, Bank of England News Release, 30 July 2009

171 “Asset Purchase Facility: Secured Commercial Paper”, Bank of England News Release, 30 July 2009

172 HM Treasury, Information in Scope of FOI request, 26 May 2021

173 Bank of England, Covid Corporate Financing Facility (CCFF), accessed 29 June 2021

216 Gov.uk, ‘Sir Jon Cunliffe,’ accessed 07 July 2021

217 Gov.uk, ‘New Permanent Secretary to the Treasury announced,’ accessed 07 July 2021

218 Cabinet Office, “Special advisers in post, 17 December 2015”, 17 December 2015

227 Institute for Government, Cameron’s role with Greensill Capital has called the UK’s lobbying regulations into question (1 April 2021), accessed 28 June 2021; See also the outcome of the investigation by the Office of the Registrar of Consultant Lobbyists.

229 Committee on Standards in Public Life, Standards Matter 2 - Committee Findings, June 2021

233 HM Treasury, Information in Scope of FOI request, 26 May 2021

238 The Financial Stability Board (FSB) is an international body that monitors and makes recommendations about the global financial system. The FSB promotes international financial stability; it does so by coordinating national financial authorities and international standard-setting bodies as they work toward developing strong regulatory, supervisory and other financial sector policies. (https://www.fsb.org/about/)

241 HM Treasury, Speech: Chancellor on developing FinTech, 6 August 2014

245 Enterprise Resource Planning. An ERP system integrates all the processes needed to run a company, such as finance, HR, manufacturing into a single system. SAP, ‘What is ERP?’, accessed 07 July 2021

270 “Asset management: inside the scandal that rocked GAM”, Financial Times, 18 March 2019

271 PQ HL16211, 10 June 2019

272 “Britain’s Lord Myners urges UK to investigate GAM-Greensill fund”, Reuters, 19 June 2019

274 Comptroller and Auditor General’s Report, Investigation into the British Business Bank’s accreditation of Greensill Capital, Session 2021–22, HC 301, 7 July 2021, p 11

277 Oral evidence taken on 24 May 2021, HC(2021–22) 142, Q144

288 Comptroller and Auditor General’s Report, Investigation into the British Business Bank’s accreditation of Greensill Capital, Session 2021–22, HC 301, 7 July 2021, p 9–10

297 Comptroller and Auditor General’s Report, Investigation into the British Business Bank’s accreditation of Greensill Capital, Session 2021–22, HC 301, 7 July 2021, p 36

305 Comptroller and Auditor General’s Report, Investigation into the British Business Bank’s accreditation of Greensill Capital, Session 2021–22, HC 301, 7 July 2021, p 12

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