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Code of conduct
This Code of Conduct covers the activities of regulated political consultants (defined as APPC member companies, their staff and non-executive consultants) in relation to all United Kingdom, English, Welsh, Scottish and Northern Ireland central, regional and local government bodies and agencies, public bodies and political parties (hereinafter “institutions of Government”). This Code applies equally to all clients, whether or not fee-paying.It is a condition of membership of APPC that the member firm, its staff and non-executive consultants should accept and agree to abide by this Code for itself and that members will be jointly and severally liable for the actions of their staff in relation to the Code. Regulated political consultants are required to endorse the Code and to adopt and observe the principles and duties set out in it in relation to their business dealings with clients and with institutions of government.
Other conditions of membership of APPC include:
• Undertaking an annual compliance procedure in respect of the Code
• Being bound by the terms of the APPC Complaints & Disciplinary Procedure
• Providing twice a year to APPC the names of all clients and consultancy staff during the previous six months for publication in the APPC Register
The Code of Conduct applies the principles that political consultants should be open and transparent in their dealings with parliamentarians or representatives of institutions of government; and that there should be no financial relationship between them. APPC members are determined to act at all times with the highest standards of integrity and in a professional and ethical manner reflecting the principles applied by this Code. In the view of APPC, it is inappropriate for a person to be both a legislator and a political consultant.
THE CODE OF CONDUCT
1. In pursuance of the principles in this Code, political consultants are required not to act or engage in any practice or conduct in any manner detrimental to the reputation of the Association or the profession of political consultancy in general.
2. Political consultants must act with honesty towards clients and the institutions of government.
3. Political consultants must use reasonable endeavours to satisfy themselves of the truth and accuracy of all statements made or information provided to clients or by or on behalf of clients to institutions of government.
4. In making representations to the institutions of government, political consultants must be open in disclosing the identity of their clients and must not misrepresent their interests.
5. Political consultants must advise clients where their lobbying activities may be illegal, unethical or contrary to professional practice, and to refuse to act for a client in pursuance of any such activity.
6. Political consultants must not make misleading, exaggerated or extravagant claims to clients about, or otherwise misrepresent, the nature or extent of their access to institutions of government or to political parties or to persons in those institutions.
7. Save for entertainment and token business mementoes, political consultants must not offer or give, or cause a client to offer or give, any financial or other incentive to any person in public life, whether elected, appointed or co-opted, that could be construed in any way as a bribe or solicitation of favour. Political consultants must not accept any financial or other incentive, from whatever source, that could be construed in any way as a bribe or solicitation of favour.
8. Political consultants must not:
• Employ any MP, MEP, sitting Peer or any member of the Scottish Parliament or the National Assembly of Wales or the Northern Ireland Assembly or the Greater London Assembly;
• Make any award or payment in money or in kind (including equity in a member firm) to any MP, MEP, sitting Peer or to any member of the Scottish Parliament or the National Assembly of Wales or the Northern Ireland Assembly or the Greater London Assembly, or to connected persons or persons acting on their account directly or through third parties.
9. Political consultants must ensure that they do not benefit unreasonably by actions of any third party that, if undertaken by the consultant, would be considered a breach of the Code.
10. Political consultants must comply with any statute, Westminster or Scottish parliamentary or National Assembly of Wales or Northern Ireland Assembly or Greater London Assembly resolution and with the adopted recommendation of the Committee on Standards in Public Life in relation to payments to a political party in any part of the United Kingdom.
11. Political consultants who are also local authority councillors are prohibited from working on a client assignment of which the objective is to influence a decision of the local authority on which they serve. This restriction also applies to political consultants who are members of Regional Assemblies, Regional Development Agencies or other public bodies.
12. Political consultants must keep strictly separate from their duties and activities as political consultants any personal activity or involvement on behalf of a political party.
13. Political consultants must abide by the rules and conventions for the obtaining, distribution and release of parliamentary and governmental documents.
14. Political consultants must not hold, or permit any staff member to hold, any pass conferring entitlement to access to the Palace of Westminster, to the premises of the Scottish Parliament or the National Assembly of Wales or the Northern Ireland Assembly or the Greater London Assembly or any department or agency of government. The only exceptions are:
• where the relevant institution is a client of the political consultant and requires the political consultant to hold a pass to enter their premises.
• where the political consultant holds a pass as a spouse of a member or as a former member of the relevant institution, in which case the pass must never be used whilst the consultant is acting in a professional capacity.
15. Political consultants must conduct themselves in accordance with the rules of the Palace of Westminster, Scottish Parliament, National Assembly of Wales, Northern Ireland Assembly or Greater London Assembly or any department or agency of government while within their precincts, and with the rules and procedures of all institutions of government.
16. Political consultants must always abide by the internal rules on declaration and handling of interests laid down by any public body on which they serve.
17. Political consultants must not exploit public servants or abuse the facilities or institutions of central, regional or local government within the UK.
In all their activities and dealings, political consultants must be at all times aware of the importance of their observance of the principles and duties set out in this Code for the protection and maintenance of their own reputation, the good name and success of their company, and the standing of the profession as a whole.
Revised January 2006