Members occasionally ask the Management Committee for advice on interpretation and application of the Code of Conduct and on membership obligations.  Members with other questions are invited to contact the Management Committee for advice at mail@appc.org.uk

How do we deal with conference passes?

If you obtain a pass from your local Party, you should ensure that you behave with the utmost transparency if acting as a political practitioner during the conference. Even if attending in a purely personal capacity, without undertaking client work, you are recommended to disclose the nature of your work.  In any event, those attending in a personal capacity cannot subsequently use information gained at conference in the course of post-conference work for clients.

If I do use a Party pass, how do I ensure the utmost transparency?

Set out below are some guidelines on behaviour that may be adopted by PA practitioners using a Party pass.

  • When meeting an elected representative (or an advisor to one) in any context, you must make clear that you work for a named consultancy as a PA practitioner. If you intend to or do act on behalf of a specific client, then that too must be made clear.
  • If you appear on panels at conference in any capacity, you must declare that you work for a named consultancy as a PA practitioner even if you go on to state that, on the panel, you are appearing primarily in a personal political capacity.
  • If you hold elected office, or are seeking to hold office, you can undertake activity relating to that office or election to that office. However, you must not use that office or platform to get undue access to ex officio party members on behalf of clients.  If a matter of interest to a client does come up in the course of discussions of your (prospective) office, you must declare that you represent that client.
  • When engaging with anyone else at conference, you must not misrepresent your connection to a particular party nor your employment by a consultancy.  Deliberately concealing or omitting to mention your employment status as a PA practitioner is not acceptable where such disclosure is reasonably likely to have an impact on the course of the conversation.
  • If you wish to engage in the internal democratic functions of a Party at conference, you must have the correct pass.
  • All disclosures need to be made as early as reasonably practicable in any exchange and must be sufficiently clear to be heard by anyone in the group.

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.

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. 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

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.

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.

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 contract with any freelancer should stipulate that he/she abides by the APPC Code of Conduct.

We have both PR and PA clients. How do we decide which clients to declare on the APPC Register?

You need to declare only those clients for whom PA services (as defined in the Code of Conduct) have been provided in the relevant quarter (and hence the PA practitioners providing those services).  You need to declare on the Register which part of your organisation (eg PA division) is actually in membership of APPC and thus bound by the Code of Conduct.

If in doubt, you should seek guidance from the APPC.

What are the requirements for declaring work for an All Party Parliamentary Group?

There are two requirements – one for the APPC Register and one for the Parliamentary Register of All Party Groups. The APPC Code of Conduct requires that any APPC member providing secretariat or other services to an APPG must list the APPG as a client in the APPC Register, indicating the name of any organisation(s) funding or otherwise supporting the APPG.  If any such organisation is also a separate client of the member, then they should be declared separately in the normal way.

Where the APPC member provides the services pro bono, any funders must still be declared or, if there are no funders, a note should be added to that effect.

APPGs need to be registered with the Parliamentary authorities and to comply with the Parliamentary rules.  APPC members must be bound by and comply with the rules of the Parliamentary authorities.  The rules require that – amongst all other financial support and material benefits given to an APPG – the Register of All Party Groups should record both the name of a consultancy providing secretariat services and, where applicable, the source of the funding for that service.  The rules published by Parliament are at:

http://www.parliament.uk/documents/pcfs/pcfsgroupsrules.pdf

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.

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