This is a House of Commons Committee report.
Date Published: 14 September 2023
1. This report arises from an investigation by the Parliamentary Commissioner for Standards into whether the Rt Hon. Rishi Sunak MP had breached paragraph 13 of the 2023 Code of Conduct for Members, relating to the confidentiality of the Commissioner’s investigations. This arose in the context of an earlier investigation by the Commissioner into whether Mr Sunak had breached paragraph 6 of the 2023 Code of Conduct for Members, relating to declaration of interests. That investigation was concluded through the rectification process, by agreement with Mr Sunak.1
2. This report relates solely to the issue of the confidentiality of the Commissioner’s investigation; however, we note that both the issue of declaration of interests, which was subject to rectification, and the statements made by No. 10 in this case, indicate a confusion between the obligations under the Ministerial Code and the obligations on Members (including those who are Ministers) under the House’s Code. This is a matter to which we intend to return as part of our review of the House of Commons standards landscape.
3. The Commissioner has supplied us with a memorandum relating to the issue of confidentiality, which we publish as an Appendix to this report.2 Mr Sunak has provided further written evidence which we have also published as an Appendix to this report.3 Written evidence relating to the Commissioner’s inquiry is published on our webpages.
4. Full details of the Commissioner’s inquiry and his opinion are set out in his memorandum. We summarise the Commissioner’s opinion briefly before setting out our decision.
5. The Commissioner opened his original investigation into Mr Sunak on 28 March 2023 after a complaint was made that, during an oral evidence session held before the Liaison Committee on 28 March 2023, he failed to declare a relevant interest.
6. Mr Sunak wrote to the Chair of the Liaison Committee on 4 April 2023 concerning his declaration of interest. This letter was published by that Committee on 5 April 2023.4 Mr Sunak subsequently deposited a copy of the letter in the House of Commons Library.
7. On the afternoon of 14 April, the Guardian newspaper published an article stating that:
No 10 has confirmed [the Commissioner’s investigation] relates to his links to a childcare firm in which his wife is an investor. Akshata Murty is listed as a shareholder in Koru Kids, which is among the private childcare providers likely to benefit from a pilot scheme proposed in last month’s budget to train new childminders.5
8. This was followed by articles from various media outlets including the BBC, Politico, Reuters and the Independent which referred to similar information that was confirmed either by No. 10 or by Mr Sunak’s spokesperson. In addition, some articles included a quote from a No. 10 spokesperson stating “We are happy to assist the Commissioner to clarify how this has been transparently declared as a ministerial interest”.6
9. On 20 April 2023, the Commissioner wrote to Mr Sunak to inform him that he would be extending his inquiry to consider a breach of confidentiality under paragraph 13 of the Code of Conduct.
10. Paragraph 13 of the Code states:
Members must not disclose details in relation to: (i) any investigation by the Parliamentary Commissioner for Standards except when required by law to do so, or authorised by the Commissioner.
11. Chapter 7 of the Procedural Protocol sets out the requirements relating to confidentiality during a Code of Conduct case. In particular, the Protocol states that:
From the point that the Commissioner opens an investigation, the Member may only share details of the investigation with:
(a) a very limited number of friends or family members; and/or
(b) a specific whip who can advise and support them during an investigation; and/or
(c) a legal or medical adviser; and/or
(d) a Member’s own staff.7
12. On 23 August 2023, the matter concerning Mr Sunak’s failure to declare an interest during an oral evidence session before the Liaison Committee was rectified.8
13. The Commissioner has given his opinion that, based on the evidence he received, Mr Sunak’s team gave a statement to media outlets which contained details of the ongoing investigation and therefore breached Rule 13 of the Code of Conduct.
14. In his analysis, the Commissioner stated that:
I accept Mr Sunak’s assertion that information about the Liaison Committee meeting of 28 March 2023, Ms McKinnell’s question and his response was in the public domain. However, at no point did I publicise or confirm that these matters were the subject of my inquiry. Whilst it was open to the media to speculate, when Mr Sunak’s spokesman confirmed to the media that the inquiry related to Mr Sunak’s “links to a childcare firm in which his wife is an investor” he disclosed details about my inquiry, including details of the intended response to my inquiry i.e. that the interest had been correctly declared as a ministerial interest [ … ]9
15. The Commissioner has also drawn our attention to:
a) The fact that the Commissioner’s letter to Members, and the Procedural Protocol which is provided to Members at the outset of an investigation, make clear the requirements of confidentiality.
b) The fact that the Code places an obligation on Members to “not disclose details in relation to: (i) any investigation by the Parliamentary Commissioner for Standards except when required by law to do so, or authorised by the Commissioner.”10
c) Mr Sunak’s indication that “with hindsight he would have made arrangements to restrict the disclosure of information by his office on his behalf.”11
d) His opinion that Mr Sunak has co-operated fully with the Commissioner throughout his investigation.
e) His opinion that the breach of confidentiality did not materially affect his investigation into the matter of the declaration of interest.12
f) His opinion that he has no reason to disbelieve Mr Sunak’s assertion that the disclosures to the media were an inadvertent breach of the Code.13
16. Mr Sunak stated in his initial response to the Commissioner, on the issue of confidentiality, that “there is a distinction between the disclosure of details of a Commissioner’s investigation, and the mere confirmation, in the response to questions of information already in the public domain”,14 and that his office had only confirmed matters already in the public domain, including statements made during the Liaison Committee hearing and his letter to the Chair of the Liaison Committee.
17. However, in his letter to the Commissioner of 27 July 2023, Mr Sunak asked the Commissioner to include the breach of confidentiality within the rectification process. Rectification is only available where a Member accepts the Commissioner’s opinion that they have breached the Code: in doing so, Mr Sunak implicitly accepted that he had breached the Code in respect of the confidentiality requirements.
18. In his written evidence to us, Mr Sunak repeated his initial statement that there is a distinction between the confirmation of information already in the public domain and the disclosure of confidential information relating to an investigation, implying that the information provided by his team was not a “clear cut” breach of paragraph 13.15 Mr Sunak reflects at the end of his written evidence that “with hindsight, I would also have informed my office not to confirm the subject matter of the inquiry in response to questioning”, but does not state that he agrees that he has breached the Code.16
19. We note Mr Sunak’s argument that there is a distinction between confirming information already in the public domain, and the disclosure of further details. It was a matter of public record only that the Commissioner was investigating a possible breach of the rule on declaration of interests. The No. 10 spokesperson confirmed publicly that the subject matter of this inquiry related to a childcare firm in which Mr Sunak’s wife was an investor—although we appreciate that this could reasonably have been inferred from other material in the public domain at the time. As the Commissioner observes, however, the No. 10 spokesperson also indicated how Mr Sunak intended initially to respond to the allegations, namely, by holding that declaration in the House was unnecessary because the interest had been declared as a Ministerial interest. This should properly have remained confidential.
20. We appreciate that Members holding senior Government office will not personally authorise all the communications that go out in their name. They are nonetheless responsible for actions done in their name, and for ensuring that those with whom they properly share details of an investigation are also aware of the confidentiality requirements. Mr Sunak has rightly taken responsibility for the statements to the media by the No. 10 spokesperson.
21. The statements to the press by the No. 10 spokesperson went beyond what could already be inferred from information properly in the public domain, by indicating how Mr Sunak intended initially to respond to the Commissioner. Mr Sunak has rightly taken responsibility for this disclosure, which breached paragraph 13 of the Code, on confidentiality of investigations. We consider this, however, to be a minor and inadvertent breach of the Code.
22. In accordance with our usual practice, we have considered whether there are any aggravating or mitigating factors in relation to this breach.
23. We consider the following to be an aggravating factor:
a) Mr Sunak holds the most senior Government office as Prime Minister, and should have ensured he was aware of the House’s rules.
24. We consider the following to be mitigating factors:
a) Mr Sunak did not intend to breach the Code.
b) Mr Sunak has acknowledged that, with hindsight, he would have followed a different course of action.
c) Mr Sunak has co-operated fully with the Commissioner’s investigation.
25. This was a minor and inadvertent breach of the Code. Mr Sunak’s staff should not have issued any statement about the details of the case under investigation, without the approval of the Parliamentary Commissioner for Standards. The Commissioner has made clear that it had no impact on his inquiry. Nevertheless, it constitutes a breach that should not have occurred. However, Mr Sunak acknowledges that with hindsight he would have followed a different course of action. We would remind the Prime Minister, and all Ministers, like all other MPs, that it is their responsibility, as individuals, to ensure that such breaches do not occur.
This memorandum reports on an inquiry that I commenced on 20 April 2023 in the course of investigating an allegation that The Rt Hon. Rishi Sunak MP had breached rule 6 of the 2023 Code of Conduct for Members (declaration of interests). I extended that inquiry on my own initiative following statements in the media attributed to Mr Sunak’s office, in order to consider whether Mr Sunak had breached the confidentiality requirement set out in rule 13 of the Code by disclosing details of an ongoing inquiry.
During my inquiry I contacted Mr Sunak and he provided a written submission outlining his actions and rationale.
I am of the view that Mr Sunak breached rule 13 of the Code of Conduct when he shared information about my ongoing confidential inquiry with the media. As a breach of rule 13 of the Code cannot be concluded by rectification, I am referring this memorandum to the Committee on Standards.
Daniel Greenberg CB
Parliamentary Commissioner for Standards
23 August 2023
26. On 13 April 2023 I wrote to The Rt Hon. Rishi Sunak MP stating that I had received a complaint that, during a session of the Liaison Committee on 28 March 2023, he failed to declare a relevant interest. I informed Mr Sunak of my decision to start an investigation.
27. On 17 April 2023 reports in the media about this investigation referred to statements provided by Mr Sunak’s spokesperson, which appeared to provide details of my investigation.
28. On 20 April 2023, I extended my original inquiry on my own initiative to include whether Mr Sunak had breached paragraph 13 of the Code of Conduct for Members:
“13. Members must not disclose details in relation to: (i) any investigation by the Parliamentary Commissioner for Standards except when required by law to do so, or authorised by the Commissioner;”
29. The standard of proof that I have applied in reaching my conclusion below is the balance of probabilities.
30. During my inquiry, in response to questions from me, I received a written submission from Mr Sunak on 27 April 2023.
31. The substantive declaration issue has been resolved by way of rectification and accordingly is not addressed in this memorandum. In his letter of 5 July 2023 accepting my offer of rectification regarding declaration, Mr Sunak included comments regarding the alleged breach of confidentiality. I did not conclude the inquiry on confidentiality until the declaration matter had been rectified, to avoid having to duplicate matters relating to the same Member to the Committee, should Mr Sunak not agree to rectification.
32. A timeline of my investigation is attached at Appendix 1.
33. My letter to Mr Sunak on 13 April 2023 initiating the inquiry into rule 6 of the Code states that my inquiries are conducted in private and should be kept confidential.17 The letter refers to the Procedural Protocol in respect of the Code18 which sets out the limited circumstances in which a Member may share details of an investigation.19 This does not include providing media statements.
34. I published the decision to start the inquiry on my website at 11.30am on 17 April 2023.20 The information on my webpage is limited to the name of the Member, the date the inquiry started, the relevant paragraph of the Code, and which edition of the Code is relevant. In accordance with usual practice, the website records that the investigation relates to the declaration of an interest but gives no details of the subject of the declaration.
35. At 12.39pm on 17 April 2023 there was a tweet by Harry Cole, Political Editor at the Sun newspaper stating:
“NEW: Sunak has written to Liaison Committee to say he did declare Koru Kids link to Cabinet Office”
36. The tweet included a letter that Mr Sunak wrote to Sir Bernard Jenkin MP on 4 April 2023.21 The letter was reproduced both in full and an extract referring to Mr Sunak’s declaration of interest. This letter was published by Mr Cole one day before it was published on Parliament’s website.22 It is noted that Mr Sunak deposited his letter to Sir Bernard with the House of Commons Library on 14 April 2023, and the Library confirmed it was accessible by the public from that date.
37. At 3.01pm an article was published by the Guardian newspaper stating:
“However, No 10 has confirmed it relates to his links to a childcare firm in which his wife is an investor. Akshata Murty, is listed as a shareholder in Koru Kids, which is among the private childcare providers likely to benefit from a pilot scheme proposed in last month’s budget to train new childminders.”23
38. There were numerous articles published the same day by other media outlets including the BBC, Politico, Reuters and the Independent. These media outlets also report similar information confirmed by No. 10 or by “Sunak’s spokesperson”.
39. The media continued to report and speculate on this matter for a number of days, with many articles referring to the subject of the declaration under inquiry, these included:
“A Downing Street spokesperson said: ‘We are happy to assist the commissioner to clarify how this has been transparently declared as a ministerial interest’.
…
The prime minister’s spokesman said that the commissioner was investigating whether Mr Sunak was not clear that he had dual obligations to declare the connection as a ministerial interest and also to declare it when speaking to MPs about the issue.
‘The prime minister has set out in his response to the Liaison Committee that he is confident the appropriate process has been followed to avoid or mitigate any potential conflict of interest, and that the interest of ministers’ spouses or partners is not something that would influence their actions either as ministers or as members of parliament,’ he said.”24
40. On 20 April 2023, I wrote to Mr Sunak outlining my concern that there had been a breach of confidentiality and informing him of my intention to extend my inquiry to consider this matter. I asked Mr Sunak to provide full details of any information he had disclosed to the media, and a full explanation as to why he had disclosed details of my inquiry to the media.
41. Mr Sunak responded on 27 April 2023. In his response Mr Sunak disputed a breach of confidentiality had occurred as the information was in the public domain. Specifically:
42. Mr Sunak said that there had been no proactive briefing from No. 10 and that his office had only responded to media inquiries. Mr Sunak said that his office had only confirmed matters that were already in the public domain and did not include confidential or privileged information. Rather his office stated that he was “happy to assist the Commissioner to clarify how this has been transparently declared as a ministerial interest.” Mr Sunak said that to comment further would have been inappropriate.
43. Mr Sunak said that the reference to a spokesperson from No 10 was supposition by a journalist not a direct quote.
44. In his letter to me of 5 July 2023 Mr Sunak helpfully acknowledged that “[w]ith hindsight, I would also have informed my office not to confirm the subject matter of the inquiry in response to questioning” and apologised for the error which he stated was “inadvertent”.
45. Breaches of confidentiality, no matter how minor, risk prejudicing an investigation. Mr Sunak had a duty under paragraph 13 of the Code of Conduct to maintain confidentiality during the investigation process. This requirement was expressly addressed in the initiation letter sent to Mr Sunak on 13 April 2023 and referenced in the Procedural Protocol appended to the letter.
46. I accept Mr Sunak’s assertion that information about the Liaison Committee meeting of 28 March 2023, Ms McKinnell’s question and his response was in the public domain. However, at no point did I publicise or confirm that these matters were the subject of my inquiry. Whilst it was open to the media to speculate, when Mr Sunak’s spokesman confirmed to the media that the inquiry related to Mr Sunak’s “links to a childcare firm in which his wife is an investor”25 he disclosed details about my inquiry, including details of the intended response to my inquiry i.e. that the interest had been correctly declared as a ministerial interest which is a breach of the Code to the media.
47. I note that these statements were made not by Mr Sunak but on his behalf. Footnote 1 to the Guide to the Rules relating to the Conduct of Members, however, provides that “Members are personally responsible for their adherence to the Code including when breaches have been made caused by the actions of a member of staff”. I note that Mr Sunak in his letter of 5 July helpfully confirms that with hindsight he would have made arrangements to restrict the disclosure of information by his office on his behalf.
48. Having considered the information available to me, I am satisfied that Mr Sunak breached rule 13 of the Code by statements made on his behalf on 17 April 2023 as described above.
49. I am of the opinion that Mr Sunak’s breach of confidentiality falls at the less serious end of the spectrum on the basis that:
a) although the subject of the declaration had not been publicised by my office, information about the matter was in the public domain; and
b) on this occasion, the breach of confidentiality did not materially affect the inquiry.
50. I also note, and have no reason to disbelieve, Mr Sunak’s assertion that the disclosures to the media were an inadvertent breach of the Code.
51. In considering this matter the Committee may also wish to take account of the fact that in his letter to me of 5 July, Mr Sunak in effect acknowledges the breach and apologises for it.
52. Unlike the substantive declaration element of the investigation, a breach of rule 13 of the Code cannot be concluded by rectification. Standing Order No. 150(4) makes a clear distinction between breaches that can and cannot be rectified. The Standing Order states that rectification may only be used:
a) in any case where the Member concerned has agreed that he has failed to register or declare an interest, if it is the Commissioner’s opinion that the interest involved is minor, or the failure was inadvertent […]
b) in any case involving parliamentary allowances, or the use of facilities or services […].
53. I therefore refer this matter to the Committee on Standards.
Daniel Greenberg CB
Parliamentary Commissioner for Standards
23 August 2023
|
Date |
Action |
|
13/04/2023 |
I wrote to The Rt Hon. Rishi Sunak MP to inform him of my decision to start an investigation into a complaint that he had failed to declare an interest during the Liaison Committee meeting dated 28 March 2023. |
|
17/04/2023 |
I published my decision to start an investigation |
|
17/04/2023 |
Media reports about the investigation, including details of the declaration under investigation. |
|
20/04/2023 |
I wrote to The Rt Hon. Rishi Sunak MP informing him of my decision to extend the investigation and consider the breach of confidentiality. |
|
27/04/2023 |
The Rt Hon. Rishi Sunak MP provides a written response to my questions. |
|
05/07/2023 |
The Rt Hon. Rishi Sunak MP accepted the offer to rectify the failure to declare an interest and included observations about this investigation. |
|
24/07/2023 |
The Rt Hon. Rishi Sunak MP is sent a draft copy of my memorandum to the Committee for his comments |
|
27/07/2023 |
I received The Rt Hon. Rishi Sunak MP’s comments on my draft memorandum |
|
07/08/2023 |
The Rt Hon. Rishi Sunak MP is sent an amended draft copy of my memorandum to the Committee for his comments |
|
18/08/2023 |
I received The Rt Hon. Rishi Sunak MP’s comments on my draft memorandum |
|
23/08/2023 |
I conclude my memorandum and pass it to the Committee for their decision-making |
Thank you for the letter from Mr James of 24 August 2023. I am grateful for the opportunity to respond.
This matter arises out of the Commissioner’s inquiry into whether I correctly declared my wife’s minority interest in Koru Kids Limited. I am pleased that the declaration inquiry has been concluded by way of rectification, in recognition that this was a minor and inadvertent breach.
The question now before you is whether my office’s confirmation of the subject matter of the Commissioner’s declaration inquiry, in response to media questioning, breached rule 13 of the Code. The Commissioner’s position was that Standing Order No. 150(4) did not allow him to resolve this ancillary matter by way of rectification, and he had no choice but to refer the matter to the Standards Committee. This is notwithstanding the Commissioner’s recognition, for which I am grateful, that any breach of confidentiality was minor, “at the lower end of the spectrum”, inadvertent and did not materially affect his inquiry.
My position on the confidentiality issue is set out in detail in my letter to the Commissioner of 24 July 2023. In particular, I draw your attention to the sheer volume of information about the declaration matter that was already in the public domain, as also recognised by the Commissioner at paragraph 16 of his Report to you. For example, my letter to the Chair of the Liaison Committee. noting the media coverage relating to my wife’s interest in Koru Kids Limited, and confirming that this interest had been registered, was in the public domain from 14 April 2023. Similarly, the complainant had published tweets on the matter, including retweets which directly linked the interest in Koru Kids Limited with a potential breach of the Code. Against this backdrop, when asked by the media on 17 April 2023 whether the Commissioner’s inquiry on declaration related to Koru Kids Limited, the only thing my office did was to confirm that it did, and simply repeated the content of my public letter to the Liaison Committee. No further detail was provided; there was no proactive briefing.
I continue to hold the view that there is a distinction between the disclosure of confidential, privileged details of a Commissioner’s investigation, and the mere confirmation of information already in the public domain. The former would be a breach of Rule 13, whilst the latter is not clear cut. Notwithstanding, with hindsight I would have informed my office not even to confirm the subject matter of the declaration inquiry when asked by the media.
I trust this written response, together with the Commissioner’s Memorandum and supporting evidence is sufficient for the Committee to reach its decision.
Please do not hesitate to contact me if I can be of any further assistance.
Sir Bernard Jenkin, in the Chair
Andy Carter
Alberto Costa
Allan Dorans
Yvonne Fovargue
Mehmuda Mian
Dr Rose Marie Parr
Victoria Smith
Dr David Stirling
Draft report (Rishi Sunak), proposed by the Chair, brought up and read.
Ordered, That the draft Report be read a second time, paragraph by paragraph.
Paragraphs 1 to 25 read and agreed to.
Two papers were appended to the Report.
Resolved, That the Report be the Fourteenth Report of the Committee to the House.
None of the lay members present wished to submit an opinion on the Report (Standing Order No. 149(8)).
Ordered, That the Chair make the Report to the House.
The following written evidence was ordered to be reported to the House for publication:
Written evidence bundle from the Parliamentary Commissioner for Standards
The Committee adjourned.
All publications from the Committee are available on the publications page of the Committee’s website.
|
Number |
Title |
Reference |
|
1st |
New Code of Conduct and Guide to the Rules: promoting appropriate values, attitudes and behaviour in Parliament |
HC 227 |
|
2nd |
Code of Conduct: Procedural Protocol |
HC 378 |
|
3rd |
New Guide to the Rules: final proposals |
HC 544 |
|
4th |
Andrew Bridgen |
HC 855 |
|
5th |
Precautionary exclusion: response to the House of Commons Commission’s consultation |
HC 1049 |
|
6th |
Alex Davies-Jones |
HC 1048 |
|
7th |
Rules for the use of House of Commons stationery |
HC 1263 |
|
8th |
All-Party Parliamentary Groups: final proposals |
HC 228 |
|
9th |
Margaret Ferrier |
HC 1276 |
|
10th |
Matt Hancock |
HC 1417 |
|
11th |
Jess Phillips |
HC 1439 |
|
12th |
Christopher Pincher |
HC 1653 |
|
13th |
Mr Marcus Fysh |
HC 1811 |
|
1st Special |
Government Response to the Committee’s First, Second and Third Reports |
HC 709 |
|
2nd Special |
All-Party Parliamentary Groups: final proposals: Government Response to the Committee’s Eighth Report |
HC 1706 |
|
Number |
Title |
Reference |
|
1st |
Boris Johnson |
HC 549 |
|
2nd |
Mrs Natalie Elphicke, Sir Roger Gale, Adam Holloway, Bob Stewart, Theresa Villiers |
HC 582 |
|
3rd |
Mr Owen Paterson |
HC 797 |
|
4th |
Review of the Code of Conduct: proposals for consultation |
HC 270 |
|
5th |
Daniel Kawczynski |
HC 1036 |
|
6th |
Review of fairness and natural justice in the House’s standards system |
HC 1183 |
|
7th |
All-Party Parliamentary Groups: improving governance and regulation |
HC 717 |
|
Number |
Title |
Reference |
|
1st |
Kate Osamor |
HC 210 |
|
2nd |
Stephen Pound |
HC 209 |
|
3rd |
Greg Hands |
HC 211 |
|
4th |
Conor Burns |
HC 212 |
|
5th |
Mr Marcus Fysh |
HC 213 |
|
6th |
Confidentiality in the House’s standards system |
HC 474 |
|
7th |
Sanctions in respect of the conduct of Members |
HC 241 |
|
8th |
David Morris |
HC 771 |
|
9th |
Dr Rosena Allin-Khan |
HC 904 |
|
10th |
The House of Commons and the criminal law: protocols between the police and the Parliamentary Commissioner for Standards and the Committee on Standards |
HC 883 |
|
11th |
ICGS investigations: Commons-Lords agreement |
HC 988 |
|
12th |
Sanctions and confidentiality in the House’s standards system: revised proposals |
HC 1340 |
1 Rectification published on 23 August 2023
2 Appendix 1
3 Appendix 2
4 Letter from the Prime Minister relating to the declaration of relevant non-registerable interests, dated 4 July 2023
5 The Guardian, Rishi Sunak’s alleged breach of MPs’ rules: what we know so far, 14 April 2023
6 E.g. https://www.reuters.com/world/uk/uk-parliaments-standards-commissioner-investigating-pm-sunak-2023–04–17/
7 Procedural Protocol in respect of the Code of Conduct (HC 1084), para 117
8 Rectification - Rt Hon Rishi Sunak MP
9 Appendix 1, para 22
10 The Code of Conduct, together with the Guide to the Rules relating to the conduct of Members (HC 1083)
11 Appendix 1, para 22
12 Appendix 1, para 12
13 Appendix 1, para 25
14 Written evidence 3
15 Appendix 2
16 Appendix 2
17 The full text is set out in the Written Evidence Pack - item 1.
18 Procedural Protocol in respect of the Code of Conduct
19 The full guidance in the procedural protocol regarding confidentiality is set out in Written Evidence Pack - item 2.
20 Allegations currently under investigation by the Commissioner - UK Parliament
21 Harry Cole (@MrHarryCole) / Twitter
22 Liaison Committee (Commons) - Correspondence - Committees - UK Parliament
23 Rishi Sunak’s alleged breach of MPs’ rules: what we know so far
24 Rishi Sunak investigated over declaration of interest - BBC News 18 April 2023
25 Rishi Sunak’s alleged breach of MPs’ rules: what we know so far