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Frequently Asked Questions
Members’ FAQs on the APPC Code of Conduct
Members occasionally ask the Management Committee for advice on interpretation and application of the Code of Conduct in particular circumstances. These FAQs are based on members’ questions, adapted to be of a more general application. Members with other questions are invited to contact the Management Committee for advice.
Q. We have an unpaid intern who has now been offered a job as a researcher for an MP. All parties wish to phase-in his new job over two weeks and before he will have received his parliamentary pass. Is this acceptable?
Yes, provided the intern has in mind clause 12 of the Code (separation of duties) and provided that, if his pass is issued while still working for you, it is retained by the MP and not given to him.
Q. I have recently been elected to my local Council in the area where my consultancy is based. I understand that the Code allows this provided I do not act for a client in respect of the Council. However, I am concerned about
a) acting for clients in respect of organisations in which the Council is a stakeholder or subscriber, eg the airport and authorities such as fire and police, and
b) working for clients that may operate within the Council’s geographic area, particularly in my own ward.
In answer to the first part of the question, it would be a breach of the Code if, as a councillor, you (directly or through the Council) have influence over the decisions of the organisation in question. The second part of the question is more a matter of judgement, bearing in mind Clause 1 of the Code; for example if a client was a large national organisation that happened to have a branch in your ward, that would be acceptable provided the client wasn’t directly seeking, say, planning permission from the Council. It would be more difficult to act for a client that was a local firm tendering for Council contracts.
Q. We contracted a market research company to carry out anonymous research with Assembly Members. We learned later that the market research company had paid £50 to each Assembly Member who had responded. Have we breached the Code?
No, as the payments were made by a third party without your knowledge and without the Assembly Members knowing who you were, so there was no question of trying to influence their views on behalf of a client.
Q. We wish to use a freelancer on a fairly regular basis. However, he has a part-time job as a Parliamentary researcher and thus has a pass to the House of Commons. Can we contract with him? Would it make a difference if he undertook not to use the pass whilst on our business?
The Management Committee would advise against it, even with his assurances about not using the pass. Your decision must take account of all the circumstances – for example, what proportion of his time would be with the MP? Would he work for the MP from The House or from his own office?
Q. We have both PR and PA clients. How do we decide which clients to declare on the APPC Register?
If possible, err on the side of caution and declare clients. If a consultancy is not carrying out any PA functions whatsoever for a PR client, there is no need to include them on the APPC register; however, if ANY work involving interaction with the institutions of government or the political world more generally is subsequently carried out, then APPC considers that client to be a PA client which should be listed on the APPC register in the normal way.
Q. How do we deal with conference passes?
If you obtain a pass from your local Party, you should ensure that, if there is any possibility that you will be acting on behalf of clients, your pass shows the name of your firm. Otherwise, it is better to obtain a commercial pass.
Disclaimer
These FAQs are for general guidance only and cannot be relied upon in the event of a complaint against a member for breach of the APPC Code of Conduct.