(APG0015)
Written evidence submitted by All-Party Parliamentary Group for Animal Welfare
Submitted on behalf of the APPG Animal Welfare by Marisa Heath (Secretariat)
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.
As one of the oldest APPGs in existence, started in 1986 we believe we coordinate the Group to a very high standard following the guidance provided by the Commissioner for Standards. Over that time the Group has evolved to meet the needs of the political members.
All-Party Parliamentary Groups (APPGs) can provide useful information and resources for MPs and Lords on a wide range of issues however we also acknowledge that the plethora of APPGs has grown exponentially over the years and there is no consistent approach to the running of such groups or to which standards are adhered.
One of the main problems at the moment is some APPGs do little to nothing, others do substantial work and there is no distinction between good or bad practice. Some Groups are simply set up because of a piece of legislation or topical debate and are largely inactive. APGAW holds regular meetings, a minimum of 6 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.
The APGAW believes that well-run APPGs can be 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. This can be especially valuable on specialist topics. They act as a good way of creating a leadership body to bring key parties together to work out both policy and self-regulatory measures to improve matters under their subject area.
Many issues start within APPGs which then work their way up to Government departments, for example the work the APGAW has done recently on animal welfare in abattoirs and livestock worrying is currently being considered by Defra. They can contribute effectively to the functioning of our democratic system. From large corporations to single members of the public they enable access to talk about serious issues, that there may not be sufficient time to discuss within the wider Westminster agendas, with decision makers.
● Transparency and appropriateness of funding of APPG activities and secretarial support
The APGAW believes that the current and recently introduced method of reporting all funding on APPGs and having that published is a much more transparent way of working. Funding should, where possible, be done by a collective rather than one organisation holding all of the power even if that one organisation contributes significantly more (for example with APGAW, although the RSPCA provides the majority of the funding for the Group and the secretariat, the Group receives funding from several other organisations including Petfood Manufacturers Association, British Veterinary Association, National Farmers Union, World Horse Welfare and Pet Industry Federation. APPGs should continue to ensure all funding is listed on their websites as well as the Parliamentary register and 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 in a clear way. Funding should also be balanced e.g., for APGAW it is a combination of charities and industry.
APPGs need funding and secretarial support and as they offer a good way to raise issues of concerns within the relevant sectors it is acceptable that they are funded by outside bodies as long as the Group is well managed by the political Officers to ensure there is balanced representation and funding does not mean control of the Group. For example, although the RSPCA provides the majority of the funding for APGAW, the Group has a board made up of political Officers of the Group and other major funders where work strategies are discussed and agreed with no one organisation having greater influence over another. The secretariat answers to the political officers of the Group and they have final sign off on all work.
● The role of external secretariats to APPGs
As mentioned above, secretariats are vital to the good working and delivery of work of APPGs if they want to hold inquiries, write reports and hold events. There is a way to manage the role of external secretariats effectively via the Group’s political Officers to ensure they do not control the Group to the benefit of one organisation and that they work across membership interests well.
There should be a written contract or memorandum of understanding between the provider of any secretariat and the Officers of the Group which includes the agreement that the secretariat answers to the Officers of that Group and takes direction from them and that the secretariat is in effect seconded over to them for that purpose (although the terms of employment and resulting protections rest with the organisation providing that role). This is the case with the RSPCA and the APGAW. There also needs to be a mechanism that clearly enables full transparent access to the secretariat by other political (and associate) members and the ability to raise concerns if that is not happening.
● 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.
The APGAW believes that the political Officers of the 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. Understanding the resource restraints, it would assist if the Parliamentary Standards team do some ‘spot checks’ on the APPGs to ensure they are not being used in the wrong manner by those who are running them in particular.
Any external parties providing staff must be able to show through job descriptions that the individual is not a lobbyist and has the job role of APPG secretariat. Those who work as full-time as lobbyists should not be running APPGs, i.e., providing the secretariat role is simply part of their job description. The RSPCA employs an individual for providing the secretariat for APGAW as a stand-alone job and although their role sits within the Public Affairs team, they are not required to carry out any lobbying activities.
● Use of Parliamentary passes by staff exclusively supporting APPGs
In order to run an APPG effectively having a pass can be very helpful to meet Officers, set up meetings and access resources, although we recognise this can be abused. If such a pass is provided then the individual should only use it to assist them in their role as secretariat, i.e., meetings with Officers, setting up meetings, etc. Like anyone that person should fill out the conflict-of-interest forms which are accessible for anyone to see and if it is felt they are not using the pass appropriately it should be removed from them. The secretariat for APGAW has known many APPG staff, and on the whole they are responsible and use their passes in the correct manner. One thing that may assist in this area is further consideration of whether they should log their use of passes as part of the annual reporting to the AGM as good practice.
Again, if an APPG is being run properly and holding regular meetings and workstreams a pass assists the staff in doing this work. If the APPG is not really doing anything significant and cannot demonstrate its value, it could be questioned why the staff have a pass as it may be being used for alternative reasons.
It should be noted that many APPGs will now hold meetings virtually going forward so access to the Estate will not be as frequent anyway.
● Financial governance and controls
The APGAW believes this should be the responsibility of the elected Political Officers of the Group to ensure regular reporting and budget information comes to them. APGAW also uses its independent Advisory Board which is made up of political officers and carefully chosen associate members to help monitor this as well. 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 information with a budget breakdown annually.
To further assist with controlling spend the Political Officers should set limits on authorisation for spend. For example, the APGAW secretariat can authorise spend of funds of up to £100 without seeking further authorisation from the Political Officers.
● Other governance and compliance issues, including assurance that APPGs are meeting relevant employment law and data protection laws
If the staff are employed by an MP or Lord, they will fall under Parliamentary estate employment terms and conditions. If they are funded by an external provider, they will be covered by the terms and conditions of that employer. While this may see differing terms, conditions and protections we are not aware that this has caused significant problems to date.
Every APPG should have its own GDPR agreement which it holds on its website and shares with all members. Simple good practice should include, for example, emails to multiple recipients should be bcc except where agreed otherwise. Membership information should be kept on a secure platform and regularly updated. All of this information should be in a written document to be sent to those who becomes members of the APPG.
● Status of APPGs within the House, including the risk of confusion with select committees, and branding of APPG activities and publications
The APGAW believes there is little real confusion about whether an APPG is a Select Committee, certainly within Westminster. A simple google of ‘Select Committee’ reveals they are much more formalised and significant entities within Parliament. That said APPGS can be a useful resource for Select Committees as they can identify issues or topics that Select Committees may wish to consider in more detail at a later date.
To enable APPGs to take leadership, have authority and bring people together the Portcullis logo is significant and brings credibility to the Groups, however it might be useful to consider whether there should be criteria in order to obtain use of the Portcullis branding e.g., a Group should have certain membership numbers, should have a certain number of meetings, engagements and produce significant work. One of the main problems at the moment is some APPGs do little to nothing, others do substantial work and there is no distinction between good or bad practice. Some Groups are simply set up because of a piece of legislation or topical debate and are largely inactive. It is these types of Groups that the focus of any inquiry should be on. It would be unfair to bring the good APPGs down by removing their strong connection to Parliament because of the poorer performing and questionable APPGs and instead thought should be given to the criteria to use branding and association.
As part of the standards for APPGs it could be a rule that all make clear at the top of any report or publication that an APPG is not a Select Committee.
● Who should be accountable for ensuring an APPG complies with the rules
The APGAW believes that firstly this should lie with the political Officers, in particular the Chair and Vice Chair/s, followed by the Parliamentary Standards checking and perhaps doing random ‘spot checks’ on APPGs to check they have everything in place. Any external providers of secretariat services should obviously also ensure they are complying with all rules.
● How APPGs can be better supported to comply with the rules
All those employed to provide the secretariats for APPGs should be required to undertake a virtual induction and overview of the rules and requirements provided by the Parliamentary standards. This would help raise awareness and understanding as well as hopefully improve standards over the long-term.
In addition, perhaps an annual or bi-annual workshop on TEAMS/ZOOM to talk to those running them to ensure they understand what is required/expected as well as sharing of good practice and ideas.
Swift 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.
● The proportionality and effectiveness of current requirements on holding of AGMs and formal meetings, and election of officers
In the opinion of the APGAW this seems to work well, and we ensure we comply with the requirements in a timely manner. That said, for those APPGs mentioned above who do little there seems no compulsion for them to comply with the requirements and some are often late with submitting their annual returns on a regular basis. We believe there should be some sort of criteria set that an APPG must meet to continue operating and being able to use the branding, etc. For example, they must have an AGM and at least 3 other meetings a year with a quorate of 5, they must have 20 political members or more, they must be able to provide an annual report setting out work and outcomes achieved. All of which, for a well-run Group would be simple to comply with and something the APGAW does each year.
The key objective should be to weed out the poorly performing and questionable APPGs and lift the standards of performance so that APPGs are more professionalised and therefore understand they need to comply more strictly with the rules and transparency. The majority of the good ones already do this so it would be a real pity to bring down the ability of APPGs to do good work and to be seen as leading that work by preventing their ability to use Parliament through the logo, the meeting rooms and the status just because some are performing very poorly and are not complying.
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. For many years APGAW was the only APPG connected with animal welfare yet over the years we have seen an increasing number of sometimes quite specific animal related APPGs set up. Now it may be that there is a need for this, and competition can be healthy, but where politicians’ time and resources are limited it would make sense for ensuring a lack of duplication of Groups covering the same or similar topics. We are sure there must be similar examples in other sectors. These groups often start with some enthusiasm because of the topic issue but then officers lose interest and they are left to run themselves by outside members who may take advantage of having control over such a body. They then cause conflict and confusion with those groups who are doing good work and maintaining good standards.
As mentioned, there should be some sort of criteria set to demonstrate the value of the APPG e.g., number of meetings held, political participation (demonstrate cross party input and attendance), reports or briefings produced and engagement with key stakeholders to show it is not just a small group of certain organisations controlling the group. An annual report setting all of this out could be required under the rules and published on websites so that there is complete transparency, and this could provide a more robust way in which to keep APPGs in check.
There perhaps needs to be more penalties for failure to comply with the rules and a stricter approach taken to enforcement, such as the striking off the formal list and not being able to start a new one within a certain time period. A broader, formal support from a myriad MPs and Lords along with organisations should be required so we are clear it is not just the whim of one organisation seeking to lobby.
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