Written Evidence submitted by Policy Connect

 

Introduction

Policy Connect is a social enterprise, not-for-profit cross-party think tank. The organisation was set up in 1995 by a group of cross-party MPs, including its current chair Barry Sheerman MP, in order to provide All-Party Parliamentary Groups with the administrative support and staff resources to be an effective conduit for debate between Parliamentarians, industry, academia and the third sector. Policy Connect assists with the administration and programme of ten All-Party Parliamentary Groups (see appendix) and provides further support through a number of research commissions and forums. Policy Connect’s aim in doing so is to support APPG to contribute to the development of new policy ideas and improve public policy through evidence and collaboration.

Policy Connect welcomes the opportunity to provide written evidence to the Committee to its inquiry into All-Party Parliamentary Groups. We detail below our response to Committee’s call for evidence and would like to highlight three key aspects that we would suggest for the Committee to explore further;

 

 

The value and benefits of APPGs to the House

Policy Connect recognises a strong desire from many politicians from different parties to promote working together on areas of common interest. It is the “other face “of Parliament, where political foes find common cause and indeed friendships. APPGs provide an important channel for this type of discourse and as informal groups for knowledge exchange they are enriched by external parties who can bring expertise and /or personal experience to deliberations in advance of parliamentary debate. The potential for what a well-run APPG can achieve is huge: Parliamentarians working together can be an effective force in bringing forward new ideas for changing our way of life for the better. Parliament is seen at its very best when politicians from different parties work together; APPGs foster this behaviour through their programmes of events and research.

Transparency and appropriateness of funding of APPG activities and secretarial support

Based on Policy Connect’s long-standing experience in assisting APPG activities and secretarial support, funding can provide APPGs with the staff and operational resources needed to be able to undertake high-quality work and provide effective support for the work of Parliamentarians.

Policy Connect thinks that the visibility of APPG funding has become more transparent over the recent past with registration forms now requiring the breakdown of funding provided to secretariats by third parties who provide secretariat services to an APPG in kind. Further, those APPGs with an income of £12,500 in cash or in kind are required to complete an income and expenditure statement, which must be approved by the officers at the AGM and published online.

The role of external secretariats to APPGs

Policy Connect long term experience suggests external organisations to play an important role in providing secretariat services to APPGs. The additional staff and operational resource that they bring to a group provides effective support to its officers in developing and delivering a frequent and varied programme of events, outreach and research in order to meet the ambitions. ..

External secretariats also fulfil an important gatekeeper role and can act as trusted and independent arbiter between its officers and any external funders, ensuring that its parliamentary officers maintain an appropriate distance and independence from financial contributors to the group. In Policy Connect’s case we have codified this gatekeeper role within our code of governance and funding agreements, which sets out that control over each groups and their outputs resides solely with the respective officers and its secretariat.

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

There is a risk that the, previously referred to, gatekeeper role of external organisations providing secretariat services to APPGs is used for access by parties with an interest in unduly influencing debate and outputs, particularly where there are no codes of governance in place and funding agreements are not guided by a strict separation of control and money.

The APPG rules currently state that “Each group’s Chair and Registered Contact is responsible for ensuring if any person or organisation provides a secretariat or support services, that person or organisation is aware of and complies with the rules of the House”. Further, recent changes to the financial reporting regime to the effect that money from third parties received with the intention to support a secretariat’s in-kind support of an APPG has improved transparency in this regard.

One possible way forward to further safeguard APPGs against illegitimate access could be to require APPGs to adopt a strict code of governance and provide templates for contractual funding agreements.

As a further financial safeguard Policy Connect’s due diligence procedure uses a screening programme (CSI WatchDOG) to ensure that prospective funders of APPGs are fully compliant with UK laws. We would recommend the Committee consider such a due diligence process being required of all APPG external secretariats receiving income from third parties.

As a side note, Policy Connect would like to draw the Committee’s attention to the fact that the term “lobbyist” encompasses a wide spectrum of actors and in common parlance carries a negative connotation, which should be reserved to a particular type of activity on this spectrum. Despite being a social enterprise and a cross-party not-for-profit think tank, Policy Connect itself is currently classed as a “consultant lobbyist” under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014. This is by simple virtue of the fact that we communicate with ministers and permanent secretaries on behalf of APPGs, research commissions and forums to invite them to attend parliamentary events, discuss policy ideas and take note of our research report.

Use of Parliamentary passes by staff exclusively supporting APPGs

Parliamentary passes could help with the organisation of APPG events through easier access to rooms on the parliamentary estate. However, Policy Connect does not consider Parliamentary passes a necessity for the effective support of APPGs. We have been operating our APPGs without them successfully for the last years and therefore see no need for a change.

Financial governance and controls

Policy Connect deems the current financial governance and control arrangements for APPGs suitable. According to these, APPGs with an income of £12,500 in cash or in kind are required to complete an income and expenditure statement, which must be approved by the officers at the AGM and published online. Each APPG secretariat is therefore accountable to is respective chair and officers.

To support chair and officers in scrutinising these statements more effectively, the APPG registrar could develop further guidance on “red flags”, e.g. a large proportion income and/or expenditure listed in the category “Other” and not sufficiently explained.

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

Policy Connect recommends that APPG registration paperwork could include the requirement to provide evidence of secretariat providers’ companies house registration, employers’ liability insurance as well as data controller and processor due diligence arrangements.

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

Policy Connect considers the current requirements on APPGs sufficient to avoid the risk of confusion with select committees and ensure that the activities of APPGs are clearly attributable to them. These requirements include that

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

Policy Connect finds the current requirement for each group’s Chair and Registered Contact to be responsible for ensuring compliance with the rules appropriate. This could, however, be further complemented by an explicit statement in the rules that any external organisation providing secretariat services for an APPG must be aware of the rules and ensure compliance with them and support the Chair and Registered Contact.

How APPGs can be better supported to comply with the rules

Policy Connect suggests that the confidence of the registrar as well as the Chairs and Officers of APPGs in their secretariats and support staff could be increased through mandatory training sessions to build capacity and competency.

We suggest that the training sessions and available support /advice currently provided by the registrar is supplemented with an online training course that provides accreditation for the named contact person providing secretariat support to an APPG. This could further be made an APPG registration requirement.

The online course should cover all aspects of finance, compliance and unacceptable lobbying behaviour. The course could also include guidance for ensuring the smooth running of an APPG event and writing reports. These type of accreditations are common place across many sectors.

We further to suggest that that to cover the costs that a fee be incurred based on turn over or status i.e. not for profit, charity or corporate.

An alternative would be to make the accreditation optional and it could exist as a quality kite mark to better inform parliamentarians about the secretariat choices they make.

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

Policy Connect has found the current requirements around AGMs, formal meetings and the election of officers to work well and the timelines around the reporting year to provide sufficient flexibility to account for the fast-paced Parliamentary environment.

 

 

Barry Sheerman MP                                                                                                  Jonathan Shaw

Chair                                                                                                                              CEO

 

20 November 2020

 

 

Appendix 1

Policy Connect provides secretariat support to the following APPGs