(APG0012)

 

 

 

 

RSPCA response to the Committee of Standards call for evidence on

All-Party Parliamentary Groups

 

The RSPCA, as the provider of the secretariat for the All-Party Parliamentary Group for Animal Welfare (APGAW), welcomes the opportunity to respond to this call for evidence and hopes that the information provided is of assistance to the Committee for Standards.

 

APGAW is one of the oldest APPGs in existence, started in 1986, and the RSPCA has provided a secretariat for 34 years.  We believe we have done so to a very high standard following the guidance provided by the Commissioner for Standards.  We have enabled the Group to evolve to meet the needs of the political members and have given professional support which has led to some excellent outcomes for the APPG and animal welfare more widely.

 

The RSPCA recognises the need for APGAW to act as a resource for MPs and Lords on a wide range of issues and it is well placed to offer evidence and a clear view of the issues, however we also enable a wide range of other stakeholders to use the Group to further the case of animal welfare.  We are very aware of the importance of APGAW being, and being seen to be, independent and active.  A problem we have seen with some APPGs is that they are not very active whilst others do substantial work and there is no distinction between good or bad practice.  With the resources provided by the RSPCA, APGAW is able to hold regular meetings, a minimum of six a year but generally much more, and usually has an inquiry running annually producing a substantial report or policy outline.  It also acts as an information point so that any parliamentarian who receives constituent correspondence or wishes to speak in an animal-related debate can obtain up to date information or a draft response from the secretariat.

 

  1. The value and benefits of APPGs to the House

1.1              The RSPCA holds the view that well-run APPGs are hugely valuable to both Houses of Parliament as a way of raising key issues and bringing together politicians with external stakeholders to share knowledge and solutions.  They act as a good means of creating a leadership body to bring key parties together to work out not only policy but just as importantly self-regulatory measures to improve matters under their subject area.

 

1.2              We have seen many issues start within APGAW which then work their way up to Government departments.  For example, the RSPCA has worked with APGAW on greyhound welfare, dog breeding, animal welfare in abattoirs and livestock worrying all of which either have or are currently being considered by Defra.  All of these issues have involved cross-party politicians and a range of stakeholders from large corporations to single members of the public which can be evidenced in the resulting reports and briefings.  See the APGAW website for more information[1].

 

1.3              When an APPG is well run, is inclusive and transparent, it brings real benefits including better outcomes in many important areas of the subject they cover.  For example the work APGAW has done on dogs has fed into the work of the EFRA Select Committee, Defra and the Canine and Feline Sector Group over the years.

 

  1. Transparency and appropriateness of funding of APPG activities and secretarial support

2.1              The transparency of funding has improved greatly since the RSPCA first became involved in APGAW.  We have always been transparent about the fact that the RSPCA funds the secretariat and publishes that on the website as well as ensuring all members of the Group are aware.  The current requirement to report and publish all funding for APPGs is a step forward in transparency, which we welcome. 

 

2.2              APGAW requires associate members, i.e. those who are not political to pay an annual membership fee depending on the size of their organisation to contribute towards the running of the Group.  In addition, in the last few years a group of key stakeholders[2] now contribute a small sum for the running of the Group.  The RSPCA still provides the majority of the funding for the secretariat.  One benefit of this has been to ensure there is no perception of control or influence by one organisation.

 

2.3              The RSPCA believes that APPGs should continue to ensure all funding is listed on their websites as well as the parliamentary Register[3].  In particular it should be clear as to why that organisation is funding the work e.g. it needs to be for the benefit of the subject area not just for the organisation concerned.  Funding should also be balanced e.g. for APGAW it is from a range of organisations.

 

2.4              The RSPCA is very proud of the work APGAW has been able to do largely due to the funding of a professional secretariat who is able to carry out the work at the direction of the political Officers.  Without the provision of this funding, the Group would not have been able to do the substantial work it has done and Parliamentarians would have struggled to take their issues forward in a constructive manner.  It is very appropriate for interested parties to facilitate the running of APPGs through secretariat support as long as all the funding is transparent, there is a wider benefit of the funding and it can be clearly demonstrated that funding is not giving control of the Group to one individual or organisation.

 

  1. The role of external secretariats to APPGs

3.1              As mentioned above, secretariats are vital to the good working of APPGs if they want to hold inquiries, write reports and hold events.  The RSPCA employs an individual in a stand alone capacity to provide the secretariat so there is no confusion between that individual’s work and the wider work of the team they are based in.  That person obviously benefits from the provisions of employment by the RSPCA and as an organisation we work closely with the political Officers to ensure the strategy and work of the Group is delivered effectively.

 

3.2              The RSPCA has found it helpful for a written memorandum of understanding between APGAW and the political Officers of the Group.  This includes the agreement that the work of the secretariat is set by the Officers but that the duties as an employer rest with the RSPCA.  While we recognise that there can be grey areas this on the whole works quite well and certainly provides a format if there are any concerns from either side.

 

3.3              The RSPCA believes that problems may occur where the person employed to carry out the duties of the secretariat also has a wider job role within the organisation and it may be more difficult to separate the two roles  We recognise this may be due to perception rather than reality however this is why the RSPCA keeps the secretariat role standalone.

 

  1. The risk of APPGs being used for access by lobbyists, other organisations or by foreign governments, and how any conflicts of interests arising can be managed.

4.1              The RSPCA believes this can be avoided by secretariats being employed directly and only for the role of running the APPG.  To put it simply, those who work full-time as ‘lobbyists’ should not be running APPGs, i.e. providing the secretariat role should not be simply part of their job description.

 

4.2              The RSPCA believes that the political Officers of APPGs have a responsibility to ensure this does not happen and must be regularly reminded that they have a duty to ensure they have control and understanding of who is using the APPG and accessing its resource.  This is something APGAW does formally at least once a year through the AGM but also more informally through Officer meetings and updates.  It would assist if the Parliamentary Standards team carried out ‘spot checks’ on APPGs to ensure they are not being used in the wrong manner by those who are running them.

 

  1. Use of Parliamentary passes by staff exclusively supporting APPGs

5.1              The secretariat running APGAW is employed on a part-time basis and has other part-time work such as short-term work for MPs which require a parliamentary pass.  The RSPCA has discussed this with her and notes that she is careful in using the pass and does not use it for informal meetings or bringing outside parties onto the Parliamentary estate.  We have agreed with her that it should only be used to meet political members of the Group and set up meetings and for that purpose it has been very helpful in saving political Officers  and their staff’s time.  We very much believe that if a secretariat has a pass they should fill out a conflict of interest form which, we understand, are accessible for anyone to view and if that person is not using the pass appropriately it should be removed from them.  To assist with this, the RSPCA believes that further consideration could be given to whether secretariats should log their use of passes as part of the annual reporting to the AGM as good practice.

 

5.2              The RSPCA recognises this is a grey area and different people have different views on this.  However, if an APPG is being run properly and holding regular meetings and workstreams a pass assists the secretariat in doing this work.  If the APPG is not really doing anything significant and cannot demonstrate its value, it could be questioned why the individual has a pass.  The RSPCA believes that it is therefore important to have clear standards for running an APPG and be able to demonstrate the value that APPG is bringing to the work of Parliament.  With this in place then, the RSPCA believes that the use of passes should be acceptable.

 

  1. Financial governance and controls

6.1              The RSPCA believes it should be the responsibility of the elected political Officers of the Group to ensure regular reporting and budgetary information comes to them.  The RSPCA has always ensured this is the case, through reports to the Officers for the AGM and a benefit of this is that it helps to protect our reputation as well.  We feel that an organisation supporting the running of an APPG should ensure all of the governance and controls are in place as any issues will reflect on them as well as officers of the Group.

 

6.2              The RSPCA believes that every AGM, at least, should have a financial report and one Officer should be Treasurer who has more regular reporting.  This should all be made public with a budget breakdown annually.  To further assist with controlling spend the political Officers could set limits on authorisation for spend, clearly this may be more appropriate for some Groups rather than others. 

 

  1. Other governance and compliance issues, including assurance that APPGs are meeting relevant employment law and data protection laws

7.1              By being an employee of the RSPCA the secretariat for APGAW has the protection of the terms and conditions of general employment with us.  Within that framework the RSPCA has a duty to ensure matters relating to employment and data protection are all met.  Obviously where there are disputes over performance, etc then this is something the RSPCA discusses with the political Officers and the secretariat jointly.  We note that if the secretariat of an APPG is employed by an MP or Lord they will fall under Parliamentary estate employment terms and conditions.  The RSPCA is not in a position to comment on that.

 

7.2              The RSPCA believes that as with APGAW, all APPGs should have their own GDPR agreement which they hold on their website and share with all members.  Simple good practice should include, for example, emails to multiple recipients should be blind copied except where agreed otherwise.  Membership information should be kept on a secure platform and regularly updated.

 

  1. Status of APPGs within the House, including the risk of confusion with select committees, and branding of APPG activities and publications

8.1              The RSPCA does not see this as an issue.  There is little real confusion about whether an APPG is a Select Committee, certainly within Westminster.  A simple internet search of ‘Select Committee’ reveals they are much more formalised and significant entities within Parliament.

 

8.2              The use of branding is slightly more complex and the RSPCA believes more could be done in this area.  Without the Parliamentary branding APPGs would lose a great deal of credibility and it would be a real loss for some excellent work which comes out of some of the Groups.  We recognise, however, that some Groups who deliver very little may take advantage of the branding to give themselves credibility.  The RSPCA believes a way forward could be criteria in order for an APPG to be able to use Parliamentary branding.  For example,  the Group should have minimum membership numbers, should have a certain number of meetings, engagements and produce significant work outputs.  Some APPGs may not have much political engagement at all, the Officers stand for election because, at the time, it is a topical issue and then do not attend meetings and do not engage.  In this case the Group should not be allowed to use the branding (and it is questionable whether they should be registered at all).  APPGs should be required to provide evidence of Officer engagement throughout the year and only use the branding on documents or outputs which are supported by those political members.

 

8.3              It would be a real loss to remove the branding from the well-run APPGs and we would urge careful thought around any consideration of this through more robust rules on how APPGs are run to prove they are acting on behalf of those representing Parliament.

 

  1. Who should be accountable for ensuring an APPG complies with the rules

9.1              The RSPCA believes that firstly this should lie with the political Officers, in particular the Chair and Vice Chair/s, followed by the Parliamentary Standards team.  The latter could conduct random ‘spot checks’ on APPGs to ensure they are.

 

9.2              Any external providers of secretariat services should obviously also ensure they are complying with all rules and as mentioned above the RSPCA ensures this through regular employee meetings to review workloads and updates on developments.

 

  1. How APPGs can be better supported to comply with the rules

10.1              All those employed to provide the secretariats for APPGs should be required to undertake an induction to understand the rules and requirements provided by the Parliamentary Commissioner for Standards.  This would help raise awareness and understanding as well as hopefully improve standards over the long-term.  In addition we believe there is benefit in an annual or bi-annual workshop to talk to secretariats to update them on developments/changes to the rules as well as sharing of good practice and ideas.

 

10.2              The RSPCA believes swifter action to strike off those Groups from the registered list should be taken if those in breach of the rules do not comply with a warning notice.  In addition to this Officers of Groups, in particular the Chair/s should be regularly reminded to satisfy themselves their Group is being run appropriately.

 

10.3              Any third party providing support should also be notified about the rules on an annual basis and asked to check they comply and sign off on it.  Such checks could provide some form of auditing on an annual basis.

 

  1. The proportionality and effectiveness of current requirements on holding of AGMs and formal meetings, and election of officers

11.1              On the whole, the RSPCA feels this works well, although there should be set requirements for holding meetings and work of the Officers.  For example; one AGM and at least three other meetings must be held a year with a quorum of four or five political attendees, they must have 20 political members or more, they must be able to provide an annual report setting out work and outcomes achieved.  We have seen examples where a meeting is held, no political members attend, the meeting closes with no outcomes but the box is ticked for having held a meeting.  This gives authority to those APPGs running in this manner to continue when actually it is not adding anything to the Parliamentary process and may actually be damaging it.

 

11.2              The RSPCA would like to see the Parliamentary Commissioner for Standards weed out the poorly performing APPGs and lift the standards of performance so that APPGs are more professionalised.  We recognise this is not an easy task but through more effective criteria for setting up Groups and reporting - especially focusing on outcomes of APPGs work then we feel this can be started. 

 

11.3              Further consideration could be given to the rationale for setting up some APPGs to ensure they are really needed and not duplicating the work of others already in existence.  There are a number of Groups (across a range of issues) that have been started, often with good intentions, but their purpose has changed, political members have lost interest or the agenda has simply moved on.  These Groups remain on the registered list yet may be largely inactive.  One solution would be to regularly review the status of APPGs and withdraw accreditation from those no longer operating to the standards set.  Interestingly, in the European Parliament such Groups have to show their value each Parliament as there is a limit on the number of Groups that can be registered - this might be worth considering in the UK Parliament.

 

11.4              The RSPCA would also suggest that APPGs  should be required to produce an annual report setting out how the work they have carried out,  who attended meetings, reports published, etc.  We feel this would help focus the minds of APPGs and provide transparency as well as a mechanism for the Parliamentary Standards Commissioner to monitor the Groups.

 

11.5              We acknowledge that it is relatively easy for APPGs to hold meetings, AGMs and elect figurehead Officers, however the true value of all of that needs to be demonstrated through outcomes.  As a charity we are required to justify our work and, in particular, spend to the Charity Commission, we do not believe it is unreasonable to require an APPG to do similar to the parliamentary authorities. Surely, it is in the interests of both Parliament and stakeholders to ask for evidence of the value of each APPG and to ask those running APPGs to recognise when the value is no longer there to close the Group.

 

11.6              Finally,  the RSPCA believes there could be more consideration around the penalties for failing to comply with the rules and a more strict approach taken to enforcement.  It feels very ‘light touch’ at present and we believe more could be done to see Groups struck off the Registered list and external organisations not being allowed to approach politicians to start a new one within a certain time period.

 

19 November 2020

 


[1] https://apgaw.org/

[2] The Petfood Manufacturers Association, British Veterinary Association, National Farmers Union, World Horse Welfare and Pet Industry Federation.

[3] https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-interests/parliamentary-commissioner-for-standards/registers-of-interests/register-of-all-party-party-parliamentary-groups/