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You are here: Publications and Records > Commons Publications > Select Committees > Standards and Privileges > Standards and Privileges
Select Committee on Standards and Privileges Third Report

Written evidence received by the Parliamentary Commissioner for Standards

NOTE: Any enclosures mentioned in the documents listed are not appended.

1.  Letter to the Commissioner from Mr John Mann and Mr Kevan Jones, 23 November 2006

Please find enclosed a file on the actual and possible misuses of Parliamentary facilities for party political fundraising. You will note this has been raised by oral and written question and we are aware of the existence of at least two current journalistic investigations.

It is clear that there is a systematic use of 'patrons clubs' to dine in the Commons and Lords explicitly to fundraise for the Conservative Party.

We have so many examples and individual complaints that we enclose them as one file.

Our analysis of room bookings is that this is only the tip of the iceberg and that there are perhaps hundreds of such fundraising events.

We have had great difficulty in finding proof, but we enclose what appears to us to be categorical proof of misuse.

You will note that this matches precisely the system explained in the academic analysis of the Political Quarterly article of 1991 (enclosed).

In our view the money raised, inadvertently or deliberately outside the rules, must be paid over to charity in full. Clearly there needs to be an immediate cessation of this activity and a full analysis of all dining room bookings.

We are of course happy to co-operate fully with any inquiry.

23 November 2006

2.  Article from the Political Quarterly, April 1991

Patrons' Clubs in the Conservative Party: a special kind of membership

Membership of the Conservative Party is by individual subscription to local Conservative Associations. There is no central party membership register nor is there a set subscription, although £5 per annum is the recommended Central Office subscription target. However, Central Office emphasises that £5 should be taken as a constituency average so as not to discourage those who can only afford to pay a little. This subscription target is achieved in a substantial number of constituencies although the average subscription figure in seats in urban and inner-city areas can be as low as £1.50 or thereabouts.

The Houghton Committee estimated the party's average constituency membership to be 2,400 which yields a national membership figure of 1.5 million. This figure is currently claimed by the party. However, a survey of forty-eight Conservative Associations carried out by the author—plus interviews with Central Office officials and constituency agents and workers—suggests that the actual national membership figure is nearer 1 million. A major feature of the membership levels in the Associations surveyed is the wide variation according to electoral environment. In safe seats (held by the Conservative Party with majorities of 10 per cent or more of the total 1987 General Election poll) average membership was found to be 1,877. In marginal seats (held by the Conservative Party or other parties with majorities of 5 per cent or less of the total poll) the average membership level fell to 903. Finally, membership in 'unwinnable' seats (held by other parties with majorities of 10 per cent or more of the 1987 poll) amounted to only 277.

However, in addition to yielding information on membership levels and variations by electoral environment, the survey revealed the existence of a special category of member found in a number of safe seats and some marginal constituencies. These are the members of Patrons' Clubs. Members of such Clubs are offered a privileged position within Associations in return for a substantial annual subscription. Patrons' Clubs are specifically designed to attract and involve local 'notables', and as such their members constitute an elite inside some Conservative Associations. They seek to enlist the financial support of local notables for whom ordinary membership may have little attraction or who have no time to become more actively involved. The literature of a Patrons' Club in the South West makes this point clearly.

There are many who strongly agree with the aims and policies of the Conservative Party but who, because of business, professional, or other commitments do not have the time to become actively involved in the Conservative organisation. With this in mind, the Patrons' Club was formed as a means of channelling this support.

Patrons' Clubs are organised by Association officers and/or constituency agents and subscribers are entirely separate from other members. Names and subscription details are kept private and confidential and will not be found in the Association's 'public' membership records.

The basic recommended subscription is £100 per annum for a single person and £150 per annum for a member and spouse. However, there are considerable variations between and within Patrons' Clubs. In the North, the reported annual subscription is £80 for a single person and £120 for a couple. Subscription income from Patrons' Clubs can be considerable. One Patrons' Club in the South East, founded in 1984, has a target of one hundred members subscribing a total of £33,000 per annum. This is broken down into sixty members subscribing £150, twenty members subscribing £250, ten members subscribing £500, three members subscribing £1,500, one member subscribing £2,000 and finally, one member subscribing £2,500. It has almost achieved this target. A Patrons' Club in a Yorkshire constituency included in the survey has a member who subscribed £1,000 per annum. In the run up to the 1987 General Election, a Patrons' Club in the South West declared that its aim was to raise £10,000 per year to fund the coming campaign.

Three important features of all Patrons' Clubs are (i) the social programme, (ii) special links with their Conservative Member and government figures and (iii) the provision of financial assistance to other constituencies. An annual dinner and reception are two events which figure in all Club programmes and they are a source of additional income. The dinner is usually held at the House of Commons. Clubs which do not have a Conservative Member will usually be hosted by a Peer. Members take it in turn to host the local reception and it is, perhaps, not surprising that the membership of wives is reckoned to be an important factor in any Club's success. One of the main purposes of Patrons' Clubs is to raise large sums of money to fund major initiatives and campaigns at the local level and, most importantly, to channel vital financial support to less fortunate constituencies, especially marginals. One Patrons' Club calls itself 'The Mutuals' in recognition of this important aim. This Club already pays for a trained agent in a neighbouring marginal constituency and hopes to do more. Almost without exception, Patrons' Clubs are pledged to raise money to support the party's efforts in other seats. Finally, Patrons' Clubs emphasise that their members will have privileged and direct contact with their MP and/or other senior members of a Conservative government. Most provide subscribers with a regular newsletter or bulletin from their Member.

There are currently about one hundred Patrons' Clubs which, by their very nature, are overwhelmingly concentrated in safe Conservative seats. Their total membership is unlikely to be much more than 5,000 but, with an average subscription of £100, members of Patrons' Clubs probably generate something in the region of £500,000 annually for the party. The total figure may well be considerably more, especially in General Election years when fund-raising and appeals are stepped up. They function as an important channel along which resources can be moved to areas of greater need.

In many ways, Patrons' Clubs are reminiscent of the first Conservative Associations formed in the 1830s. Lacking a mass electorate—and hence any need for a mass membership—these Associations were essentially groupings of local 'notables' whose social activities maintained the party's presence in the constituencies. They provided funds which were employed to get supporters onto the new post-1832 electoral register. They also provided the finance to support contests in the associated Registration Courts which dealt with disputed claims. Patrons' Clubs house a special kind of party member. They raise what are clearly large sums of money, thus enabling others to carry on the electoral struggle. They have a very strong social dimension. Indeed, several Patrons' Clubs actually have the label 'Dining Club' in their title. Electoral times have changed but, in the Conservative Party at least, something of the original melody lingers on.

April 1991

3.  House of Commons Banqueting Regulations in force currently

1.  Eligibility

1.1  A Member of Parliament, an Officer of the House of Commons, or Member of the House of Lords who was formerly a Member of Parliament, must sponsor all functions, except as noted in 1.2 below.

1.2  Accredited, authorised all-party and House of Commons Committees are permitted to book the private dining rooms in their own right. Further details are available from the banqueting office.

2.  Duties of Sponsor

2.1  The Sponsor is responsible for the good conduct of the function and for ensuring that the terms and conditions of booking are complied with.

2.2  No Sponsor may hold more than 6 bookings are any time.

2.3  The Sponsor must be present throughout the function, except when required to vote in the House.

2.4  It is the duty of the Sponsor to find a suitable replacement in the event that he/she is unable to attend. The banqueting office must be notified of any change.

2.5  The Sponsor is responsible for ensuring the bona fides of any organisation on whose behalf they sponsor a function.

2.6  The Sponsor is responsible for ensuring that the Private Dining Confirmation Form is completed and signed.

2.7  The Sponsor may delegate the responsibility of co-ordinating a function to an Organiser, in which case a Sponsorship Agreement Form must be completed and signed. These are available from the banqueting office.

2.8  The Sponsor is liable for all costs associated with an event.

3.  Duties of the Organiser

3.1  Organisers to whom the co-ordination of a function has been properly agreed and authorised may deal directly with the banqueting office in making all arrangements for the function.

3.2  Organisers are responsible for all liaison with their Sponsor to ensure that the terms and conditions of the booking are met.

3.3  Organisers of sponsored events shall have the status of GUEST only.

4.  Declaration of Interest

4.1  The Sponsor is directly and personally responsible for the declaration of any relevant interest relating to their sponsorship of a function.

4.2  The Sponsor must complete the relevant section of the Private Dining Confirmation Form to indicate whether or not there is a relevant interest.

4.3  In the event that there is any relevant interest, invitations must clearly state "relevant interest declared".

4.4  Any Sponsor in doubt about the requirements to declare any interest should consult the Parliamentary Commissioner for Standards.

5.  Use of Private Dining Rooms

5.1  Subject to the exclusions in 5.2, the private dining rooms are not to be used for direct financial or material gain by a Sponsor, political party, or any other person or outside organisation.

5.2  Use of the private dining rooms for direct financial or material gain by all-party Parliamentary groups or by registered charities is acceptable.

5.3  The private dining rooms may not be used as an inducement to recruit new members of outside organisations or non-parliamentary associations.

5.4  No commercial presentation, promotion or demonstration is permitted.

5.5  Subject to the rules on the declaration of interest and 5.1 above, it is appropriate for the private dining rooms to be used for political functions or for "lobbying purposes".

5.6  All functions must be brought to a close by 10.30pm and guests should leave the Parliamentary Estate by 11.00pm. The Refreshment Department reserves the right to recover additional costs incurred in the event of a late vacation of the premises.

5.7  With the exception of Wedding/Special Event cakes, no food or drink, other than that supplied by the House of Commons Refreshment Department, may be consumed on the premises.

5.8  No betting or gaming may be carried out on the premises.

5.9  Concerts, loud music or other activities likely to cause a noise nuisance are NOT permitted. Background music may be permitted by prior agreement at times when neither House is sitting and adjacent rooms are not in use for other events. The Sponsor should apply in writing to the Chairman of the Administration Committee who will advise the Speaker.

6.  Publicity, Photography & Media

6.1  Any publicity, invitation, circular, literature or announcement in connection with the function must bear prominently the name of the sponsoring Member or Officer of the House of Commons, or Member of the House of Lords and must be submitted to the banqueting office for approval prior to publication.

6.2  Any media interest must be notified in writing to the banqueting office and copied to the Sponsor.

6.3  All representatives of the media must possess a formal invitation.

6.4  Television cameras must be hand-held and any filming or photography is restricted to the confines of the function room.

6.5  Photographers, television crews and radio crews authorised by the Sponsor must obtain a permit from the Director of Catering Services via the banqueting office.

7.  Booking

7.1  Provisional bookings will be held for a maximum of ten working days. If the banqueting office does not receive the signed confirmation of Booking within this time, the reservation will be automatically cancelled without further notice.

7.2  Reservations can be made for a maximum period of 18 months in advance of the function date.

8.  Cancellation by the Sponsor

8.1  Cancellation must be confirmed in writing to the banqueting office.

8.2  Cancellation of a confirmed booking will incur the following charges, unless the banqueting office is able to subsequently re-let the room:

9.  Cancellation by the House of Commons

9.1  In the event of the dissolution of Parliament, all functions during this period will be cancelled without any liability to the Sponsor or Organiser.

9.2  The House of Commons Refreshment Department may also cancel a function without liability to the Sponsor or Organiser if:

  • The House is unexpectedly recalled during a recess.
  • The House of Commons premises or any part of them are closed for reasons beyond the control of the House authorities.
  • The Sponsor ceases to hold a position eligible to host a function.
  • The Sponsor or Organiser is in breach of the terms and conditions of the booking.

10.  Charges

10.1  An estimate of number of persons attending functions must be provided by Sponsors or Organisers when completing the booking form.

10.2  Charges will be based on the final attendance numbers confirmed. Final numbers must be confirmed to the banqueting office not less than 3 working days before the date of the function.

10.3  Where catering is less than the required minimum food spend or the minimum required number of guests per room, the advertised Room Hire charge will be levied. Room Hire is applied to each time slot throughout the day.

10.4  All functions taking place on Friday evenings and Saturdays will incur a weekend supplement. Details are set out in this brochure.

10.5  If numbers attending fall below the minimum required for the room booked, the Refreshment Department reserves the right to relocate the function to a smaller room. Should no such room be available, the advertised minimum numbers for the booked room will be charged.

10.6  All charges will be based upon the banqueting tariff current on the date of the event, not the date of booking. Organisers are therefore advised to allow a contingency for any such price increases when allocating budgets to a function.

10.7  As a general rule, banqueting tariffs are reviewed annually in April.

10.8  Prior to departure at the end of their function, Organisers and Sponsors are advised to agree and sign for all drinks consumed. The Refreshment Department cannot be held responsible for a discrepancy after the event.

10.9  The final account charged to the Sponsor's Refreshment Department Account will remain as an outstanding debt until it has been paid by either the Sponsor or Organiser.

10.10  All queries relating to the invoice should be addressed to the banqueting office.

10.11  Cheques must be crossed and payable to the House of Commons Refreshment Department.

10.12  All menu and wine/bar prices are quoted inclusive of service charge @ 12.5% and VAT @ 17.5%.

11.  Access

11.1  Entrance to the Palace of Westminster is via St Stephen's Entrance for all guests, or at 1 Parliament Street for the Astor Suite or Bellamy's Clubroom.

11.2  All guests attending an event must be in possession of an official invitation, to be shown on demand to the House of Commons Security. This invitation card is to be produced by the event organiser and verified by the Banqueting Office before going to print. See below for an example of the approved wording.

An enlarged example of the above can be found under Banqueting Additional Services

11.3  A typed list of attendees' names must be supplied to the banqueting office a minimum of 24 hours in advance of the function.

11.4  The banqueting office will be pleased to advise on access arrangements for disabled guests.

11.5  No car parking facilities are available. Coaches and cars may set down and pick up guests at St Stephen's entrance or outside the entrance to 1 Parliament Street.

12.  General

12.1  No display of any sort is permitted outside the room hired for the function.

12.2  Sponsors or Organisers must ensure that all stage sets, stands, materials and decorations are non-flammable and comply with all relevant safety regulations.

12.3  No flammable, noxious or dangerous items may be brought into the Parliamentary premises.

12.4  All fire exists, stairways, gangways and doors must be kept clear and free from obstruction at all times.

12.5  The House of Commons accepts no responsibility for any errors or omissions appertaining to function details not confirmed in writing to the banqueting office.

12.6  The Director of Catering Services has the authority to accept, refuse or re-schedule bookings at any time. Such authority will not be exercised unreasonably.

12.7  The banqueting office is happy to advise Organisers about catering for special dietary needs. Organisers should enquire whether their guests have any special dietary requirements or food intolerances and should communicate this information to the banqueting office before the function.

12.8  All menus must state 'Guests who have food allergies, should ask the supervisor for assistance'.

12.9  A no smoking policy operates in all House of Commons Banqueting areas.

12.10  The Refreshment Department is unable to offer storage facilities either prior to an event or after an event has taken place. The Refreshment Department will not take responsibility for any items left on the Parliamentary Estate.

4.  House of Commons Banqueting Regulations in force prior to 13 December 2000

1.  Eligibility

1.1  A Member of Parliament, an Officer of the House of Commons, or Peer who was formerly a Member of Parliament, must sponsor all functions, except as noted in 1.2 below.

1.2  Accredited, authorised all-party parliamentary organisations are permitted to book the private dining rooms in their own right. Further details are available from the banqueting office.

2.  Duties of Sponsor

2.1  The Sponsor is responsible for the cost and good conduct of the function and for ensuring that the terms and conditions of booking are complied with.

2.2  No Sponsor may hold more than three bookings at any time.

2.3  The Sponsor must be present throughout the function, except when required to vote in the House.

2.4  It is the duty of the Sponsor to find a suitable replacement in the event that he/she is unable to attend. The banqueting office must be notified immediately of any change.

2.5  The Sponsor is responsible for ensuring the bona fides of any organisation on whose behalf they sponsor a function.

2.7  The Sponsor may delegate the responsibility of co-ordinating a function to an Organiser, in which case a Sponsorship Agreement Form must be completed and signed. These are available from the banqueting office.

3.  Duties of the Organiser

3.1  Organisers to whom the co-ordination of a function has been properly agreed and authorised may deal directly with the banqueting office in making all arrangements for the function.

3.2  Organisers are responsible for all liaison with their Sponsor to ensure that the terms and conditions of the booking are met.

3.3  Organisers of sponsored events shall have the status of GUEST only.

4.  Declaration of Interest

4.1  The Sponsor is directly and personally responsible for the declaration of any relevant registered interest relating to their sponsorship of a function.

4.2  The Sponsor must complete the relevant section of the Private Dining Confirmation Form to indicate whether or not there is a relevant registered interest.

4.3  In the event that there is any relevant interest, invitations must clearly state "relevant registered interest declared".

4.4  Any Sponsor in doubt about the requirement to register any interest should consult the Parliamentary Commissioner for Standards.

5.  Use of Private Dining Rooms

5.1  The private dining rooms may NOT be used for any purpose involving direct commercial gain, or as an inducement to recruit new members of outside organisations or non-parliamentary associations.

5.2  No commercial presentation, promotion or demonstration is permitted.

5.3  Subject to the rules on the declaration of interest, it is appropriate for the private dining rooms to be used for political functions or for "lobbying purposes".

5.4  All functions must be brought to a close by 10.30pm and guests should leave the Parliamentary Estate by 11.00pm.

5.5  With the exception of Wedding/Special Event Cakes, no food or drink, other than that supplied by the House of Commons Refreshment Department, may be consumed on the premises.

5.6  No betting, gaming or auction activity may be carried out on the premises. Raffles may only be drawn on the premises.

5.9  Concerts, loud music or other activities likely to cause a noise nuisance are NOT permitted. Background music may be permitted by prior agreement at times when neither House is sitting and adjacent rooms are not in use for other events.

6.  Publicity, Photography & Media

6.1  Any publicity, invitation, circular, literature or announcement in connection with the function must bear prominently the name of the sponsoring Member/Officer/Peer and must be submitted to the banqueting office for approval prior to publication.

6.2  Any media interest must be notified in writing to the banqueting office and to the Sponsor.

6.3  Television and radio crews, and representatives of the media must possess a formal invitation.

6.4  Television cameras must be hand-held, and any filming or photography is restricted to the confines of the function room.

6.5  Photographers authorised by the Sponsor must obtain a permit from the banqueting office.

7.  Booking

7.1  Provisional bookings will be held for a maximum of ten working days. If the banqueting office does not receive the signed Confirmation of Booking within this time, the reservation will be automatically cancelled without further notice.

7.2  Reservations can be made for a maximum period of 18 months in advance of the function date.

7.3  No event may be provisionally booked for more than two dates.

8.  Cancellation by the Sponsor

8.1  Cancellation must be confirmed in writing to the banqueting office.

8.2  Cancellation of a confirmed booking will incur the following charges, unless the banqueting office is able to subsequently re-let the room:

9.  Cancellation by the House of Commons

9.1  In the event of the dissolution of Parliament, all functions during this period will be cancelled without any liability to the Sponsor or Organiser.

9.2  The House of Commons Refreshment Department may also cancel a function without liability to the Sponsor or Organiser if:

  • The House is unexpectedly recalled during a recess.
  • The House of Commons premises or any part of them are closed for reasons beyond the control of the House authorities.
  • The Sponsor ceases to hold a position eligible to host a function.
  • The Sponsor or Organiser is in breach of the terms and conditions of the booking.

10.  Charges

10.1  At the time of booking, the Sponsor or Organiser must provide an estimate of the number of persons attending the function.

10.2  Charges for food and beverage will be based on the final attendance numbers confirmed. Final numbers must be confirmed to the banqueting office not less than 3 working days before the date of the function.

10.3  Where catering is less than the required minimum food spend, the advertised Room Hire charge will be levied.

10.4  All functions taking place on Friday evenings and Saturdays will incur a weekend supplement. Details are set out in this brochure.

10.5  Should numbers attending fall below the minimum required for the room booked, the Refreshment Department reserves the right to relocate the function to a smaller room. Should no such room be available, the advertised minimum numbers for the booked room will be charged.

10.6  All charges will be based upon the banqueting tariff current on the date of the event, not the date of booking. Organisers are therefore advised to allow a contingency for any such price increases when allocating budgets to a function.

10.7  As a general rule, banqueting tariffs are reviewed annually at the beginning of September.

10.8  Prior to departure at the end of their function, Organisers and Sponsors are advised to agree and sign for all drinks consumed.

10.9  The final account for the function will be invoiced to the Sponsor or Organiser, and is payable upon receipt.

10.10  All queries relating to the invoice should be addressed to the banqueting office.

10.11  Cheques must be crossed and payable to the "House of Commons Refreshment Department".

10.12  All menu and wine/bar prices are quoted inclusive of service charge @ 12.5% and VAT @ 17.5%.

11.  Access

11.1  Entrance to the Palace of Westminster is via St Stephen's Entrance for all guests, or at 1 Parliament Street for the Astor Suite or Bellamy's Club Room.

11.2  A typed list of attendees' names must be supplied to the banqueting office a minimum of 24 hours in advance of the function.

11.3  All guests attending an event must be in possession of an official invitation, to be shown on demand to the House of Commons Security.

11.4  The banqueting office will be pleased to advise on access arrangements for disabled guests.

11.5  No car parking facilities are available. Coaches and cars may set down and pick up guests at St Stephen's entrance or outside the entrance to 1 Parliament Street.

12.  General

12.1  No display of any sort is permitted outside the room hired for the function.

12.2  Sponsors or Organisers must ensure that all stage sets, stands, materials and decorations are non-flammable and comply with all relevant regulations.

12.3  No flammable, noxious or dangerous items may be brought into the Parliamentary premises.

12.4  All fire exists, stairways, gangways, passages and doors must be kept clear and free from obstruction at all times.

12.5  The House of Commons accepts no responsibility for any errors or omissions appertaining to function details not confirmed in writing to the banqueting office.

12.6  The Director of Catering Services has the authority to accept, refuse or re-schedule bookings at any time. Such authority will not be exercised unreasonably.

5.  Letter to Rt Hon Michael Ancram from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of your constituency association's list of forthcoming events, which includes a Patrons' Club luncheon at the House of Commons on 29 November 2006, to be hosted by your and your wife.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that your Patrons' Club is a fund-raising device for your constituency association; that the luncheon on 29 November was not charged at cost; and that therefore in hosting it you breached paragraph 5.1 of the Banqueting Regulations which provides that the House's private dining rooms (and by implication, its other catering facilities) are not to be used for "direct financial or material gain by a ….political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

6.  Letter to the Commissioner from Rt Hon Michael Ancram, 19 December 2006

Thank you for your letter of 7 December. I am most surprised by the complaint from Mr Mann and Mr Jones.

For background, my constituency Patrons' Club, which is composed of people who have paid an enhanced subscription, has for many years attended a number of functions which I have hosted or at which I have been present.

In a typical year these would include a drinks party with my wife and myself at our home in the constituency, an evening somewhere in the constituency at which politics is seriously discussed and a meal in London which sometimes has been at the House of Commons and sometimes at clubs in London and at which there is normally a prominent political speaker.

I had never considered that on the occasions when this took place in the House of Commons this offended against paragraph 5.1 to which you refer. I had always taken the view that this prohibition referred to a Member making available the use of a private dining room in direct exchange for money or some other material gain rather than what I had always assumed in the case of my Patrons' Club was a social/political event.

As you will see from the foregoing there is no question of tickets being sold or any other form of direct financial or material gain as set out in paragraph 5.1. The attraction of such events for the members of the Patrons' Club is to hear a prominent speaker whether that event takes place in the House of Commons or elsewhere.

If there remain any questions in your mind about this I would be more than happy to come and speak to you about them.

19 December 2006

7.  Letter to Mr Richard Bacon from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of two pages from the web-site of the South Norfolk Conservative Association, on the second of which is reference to a Westminster Group dinner at the House on 27 November 2006 at which the Rt Hon David Cameron MP was expected to be present. Mr Mann and Mr Jones assert that there is a fee (which they believe to be £15) to join the Group.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the Westminster Group is a fund-raising device for your constituency association; that there is a membership fee to join it; and that your sponsorship of the dinner at the House of Commons is a breach of paragraph 5.1 of the Banqueting Regulations, which says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

Mr Cameron is named with you in the complaint I have received, and I am therefore writing separately to him about this matter. I am also copying this letter to him so that he is aware of the nature of the complaint. I should make clear, however, that responsibility for ensuring that the terms of the Banqueting Regulations are met rests with the sponsor of, not any speaker at, the event (paragraph 2.1 of the Regulations refers).

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

8.  Letter to the Commissioner from Mr Richard Bacon, 18 December 2006

Thank you for your letter of 7 December concerning the complaint by John Mann MP and Kevan Jones MP.

From your letter and enclosures, I understand that Mr Mann and Mr Jones are claiming that certain dining clubs run by a number of Conservative constituency associations raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription, and that the Westminster Group run by South Norfolk Conservative Association is such a dining club.

Please allow me to explain why I do not believe these claims are justified.

The Westminster Group offers its members the opportunity to attend three dinners each year (two dinners in South Norfolk and one dinner in Westminster) and to hear interesting speakers on current topics.

Recent speakers in South Norfolk have included the chief executive of the local Norfolk and Norwich University Hospital, and the manufacturing director of Group Lotus, which is a large employer in my constituency.

Speakers in Westminster are usually leading figures in the Conservative Party In recent years they have included Liam Fox MP, John Bercow MP and Rt Hon David Davis MP. On Monday 27 November we were due to have had Rt Hon David Cameron MP as the speaker but he was unable to attend due to a visit to Iraq, and instead we had Oliver Letwin MP.

Membership costs £150. This is designed to cover the cost without further charge of participation at three separate 3-or 4-course dinners, including the cost of all food and wine. The Westminster Group is not a fund-raising device for my constituency association. It is designed to cover its costs while enabling those who wish to join to hear interesting speakers.

Membership of the Westminster Group does not confer membership of South Norfolk Conservative Association and there is no requirement for Westminster Group members to join the Conservative Party, locally or nationally.

I hope this helps. If you would like any further assistance, please do not hesitate to let me know.

18 December 2006

9.  Letter to Mr Tony Baldry from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from these two Members relating to your Patrons' Club.

The complaint is linked to a wider series of complaints made by Mr Mann and Mr Jones against a number of Conservative Members, about the alleged use of the House of Commons dining facilities for fundraising by the Conservative Party.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

As you will see the letter dated 1 February, which I received from Mr Mann and Mr Jones at the end of last week, was accompanied by a copy of the report and accounts of the North Oxfordshire Conservative Association for the year ended 31 December 2005. These include a number of references to the Patrons' Club run by the Association, which also appears to be known as the Quorum Club. Page 8 of the report indicates that the Club, with 71 members, "held an excellent Dinner at the House of Commons in November [2005] when Alan Duncan MP came and spoke". Pages 3 and 4 of the Accounts report income from the Club in 2005 of £17,462, as against expenditure of £1,712. The budget for 2006 on the final page shows anticipated income of £16,000 from the Club.

The complaint which Mr Jones and Mr Mann appear to be making is, in essence, that your Patrons' Club is a fundraising device for the Conservative Party, and that the dinner it held at the House in November 2005 breached paragraph 5.1 (and possibly 5.3) of the Banqueting Regulations. This was so in that either an inflated membership subscription was charged for the Club (out of which the expenses of the dinner were met) or that, while the event was charged for separately, membership of the Club was a pre-condition of attendance at the dinner.

I should be grateful if, in accordance with the enclosed procedural note, you would let me have your response to the complaint. It would be helpful if that could include information on:

1.  The membership, activities and aims of your Patrons' Club.

2.  How its activities are funded, including any subscription paid by Members.

3.  How it raises any funds it donates to your Constituency Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years, when, and how these have been funded (whether charged for directly or funded from subscriptions, and if the former whether or not the events have been charged for at cost or have made a profit).

5.  How much it has donated to the Association in each of the last 5 years.

If you would like a word about the matter, please do not hesitate to ring me on the number above. An early reply to my letter would be helpful as I am keen to report on the matter to the Committee on Standards and Privileges reasonably speedily.

I am copying this letter and enclosures to the Director of Catering Services, with whom I am in contact about the interpretation of the Banqueting Regulations and whom I shall consult as necessary on your reply.

6 February 2007

10.  Letter to the Commissioner from Mr Tony Baldry, 7 February 2007

Thank you for your letter of 6 February.

It is not my Patrons' Club. It is the Patrons' Club of the North Oxfordshire Conservative Association.

The membership fees of the Patrons' Club include the cost of one free dinner per year in London, and that is held either in the House of Commons or the House of Lords, or in the Carlton Club.

No fundraising takes place at these dinners. They are simply an opportunity for members of the Club to hear a political speaker and ask questions.

I am aware of the rules, and am confident that they have not been broken.

7 February 2007

11.  Letter to Mr Tony Baldry from the Commissioner, 12 February 2007

Thank you for your letter of 7 February in reply to mine of 6 February about this complaint.

I appreciate the speed of your reply, and note your confidence that the Rules of the House have not been broken. It would help me to understand the manner in which the Patrons' Club of the North Oxfordshire Conservative Association operates if you could supplement your letter by responding to the five questions listed on page 2 of my letter. I am keen to know in particular:

1.  How many members the Association's Patrons' Club has.

2.  What is the subscription charged to members.

3.  How the Club raises any funds it donates to the Constituency Association.

4.  How many events the Club has held at the Houses of Parliament (including how many in the House of Commons) in the past 5 years, and when.

5.  How much the Club has donated to the Association in each of the last 5 years.

It is clear to me from my contacts with other Members named by Mr Mann and Mr Jones that the manner in which such Clubs operate varies considerably and so therefore does the manner in which they are affected by the House's rules. Hence my request for clarification on these points.

12 February 2007

12.  Letter to the Commissioner from the Agent of the North Oxfordshire Conservative Association, 6 March 2007

I have been asked by Tony Baldry MP to supply you with the information you have requested regarding our association Patrons' Club.

1.  The Association had 66 Patrons in 2006, this number can vary from year to year but would be between 50-75 members.

2.  The subscription is £350+.

3.  The Club income is membership subscriptions, which includes membership of the Constituency Conservative Association.

4.  The Club has held 24 events since 1st Jan 2001, of which two were held at the House of Commons and one at the House of Lords. Members are circulated with details of events and are free to choose which they would like to attend.

5.  From January 2001 to 31st December 2006 the Patrons Club has raised £50,430 after expenses for Association funds.

I hope this information is useful to you.

6 March 2007

13.  Letter to Rt Hon David Cameron from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a copy of two pages from the web-site of the South Norfolk Conservative Association, on the second of which is reference to a Westminster Group dinner at the House on 27 November 2006 at which you were due to be present.

Mr Mann and Mr Jones assert that there is a fee (which they believe to be £15) to join this Group and therefore that both you and the Member for South Norfolk, Mr Richard Bacon, have, in effect, broken paragraph 5.1 of the Banqueting Regulations which says that the House's private dining rooms (and, by implication, its dining facilities) should not be used for "direct financial or material gain by a . . . political party." I enclose a copy of the letter I have sent Mr Bacon putting this matter to him.

You will see from this letter that responsibility for ensuring that the Banqueting Regulations are adhered to rests with the sponsor of an event, not any speaker at it, and on that ground I do not see that the particular complaint made against you by Mr Mann and Mr Jones can stand. However, there may be other relevant matters you wish to draw to my notice—hence this letter to you.

You will also see that the precise point put to me by Mr Mann and Mr Jones is considerably narrower than the allegations made in the enclosed article from the "Sunday Times" of 3 December. The article alleges that your own constituency association in Witney runs a Patrons' Club with a membership fee of £480 a year, which offers members up to two lunches hosted by you at the House of Commons a year. It also says that you are "alleged to have booked dining rooms and hosted lunches and dinners for fellow Tory MPs." I should welcome your comments on these allegations also.

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

14.  Article from the Sunday Times, 3 December 2006

Cameron faces inquiry on lucrative lunches

David Cameron, the Conservative party leader, is facing an official investigation for hosting a series of fundraising events in the House of Commons.

He and other senior Tories have hosted 32 fundraising lunches or dinners in private parliamentary rooms in the past two months. They are thought to have raised more than £100,000.

Last week, two backbench Labour MPs filed a formal complaint with Sir Philip Mawer, the parliamentary commissioner for standards.

Parliamentary rules ban the use of Commons dining facilities for fundraising. They state: "The private dining rooms are not to be used for direct financial or material gain by a sponsor, political party or any other person or outside organisation."

The money raised by Cameron's events, via his "patrons' club", is thought to be used to fund his Witney constituency. Cameron is also alleged to have booked dining rooms and hosted lunches and dinners for fellow Tory MPs.

Last Thursday, Nick Gibb, shadow minister for schools, held a Commons lunch for his patrons' club, which was also attended by Theresa May, shadow Leader of the House.

The Commons charges about £35 a head for a three-course meal in the private dining rooms, enabling the Tories to make a profit from a higher fee. Most functions are thought to be attended by about 50 patron club members.

Kevan Jones, Labour MP for North Durham, who lodged the complaint, said: "The misuse of the parliamentary facilities is blatant and disgraceful. These rooms are being block-booked by the Tories months in advance for fundraising functions.

"We have presented enough evidence to the parliamentary commissioner to justify a detailed investigation. Cameron should have to repay every penny his party has raised through these illicit events." John Mann, Labour MP for Bassetlaw, also made the complaint.

A copy of the letter sent to potential members of patrons' clubs, circulated between Tory MPs, advises them to write to potential members saying: "The club holds dinners in the House of Commons twice a year as well as a reception in the constituency. The membership fee is £225 which includes the cost of one dinner for yourself and a guest. The second dinner and further guest tickets costs £35 to include wine and a three-course dinner."

Last week, an undercover reporter approached eight constituency parties and was offered the chance to attend parliamentary dinners or lunches by six.

At Cameron's association the reporter was told £480 would buy access to up to two parliamentary lunches hosted by the leader, plus two dinners at the homes of wealthy local members—who cover the cost and do not charge the party. Cameron's constituency is thus able to profit from the parliamentary functions.

"The Principal Patrons (club)…. have lunches in London and they are at the House of Commons," said a local official.

In Tunbridge Wells, the constituency of Greg Clark, shadow minister for charities, the patrons' club costs £160 per person or £265 for a couple for "a dinner in the Houses of Parliament or the Carlton Club."

An official told the report. "It's quite expensive because—to be honest—you pay a lot to dine in the House and sit in those horribly uncomfortable green leather chairs."

The official went on to describe how the donors could also have tea on the parliamentary terrace reserved for MPs. "If it's a nice afternoon, the doors are always open and you can go and stroll up and down and wave at the tourists," she said.

The Wycombe Conservative Association's website explains that its patrons' club is "for those who wish to support the party but do not have the time to be fully involved in all its activities".

As association official added that the club was for their "more wealthy donors" and that the last event was attended by George Osborne, the shadow chancellor. Paul Goodman is the local MP.

The sale of dinners in the Commons is the latest fundraising controversy to hit Cameron. Last week the Tories disclosed they had taken substantial loans running into millions of pounds from several offshore trusts and companies at rates below those offered by conventional banks.

This week, Cameron will mark his first anniversary as party leader. Yesterday, he laid down the gauntlet to Tory activists and warned they must support his modernising drive or risk losing a fourth election.

A Conservative spokesman said they would be writing to the parliamentary commissioner to "clarify" the rules. He accepted that the patrons' club and their dinners may be used to raise funds for local constituencies.

A party statement said: "The rules state that rooms at the House of Commons can be used for party political purposes and MPs may hire out the rooms for a charge. This appears to be an issue which affects all the political parties."

3 December 2006

15.  Article from the Sunday Times, 31 December 2006

David Cameron has raised more than £100,000 from a private club which offers fundraising lunches at the House of Commons.

Oxfordshire residents are charged £480 a year for membership of the club, of which the main perk is two private lunches in the parliamentary dining rooms. The membership fees have netted Cameron's constituency up to £29,954 a year since his election in 2001.

Earlier this month The Sunday Times revealed that Tory constituencies—including Cameron's—were effectively selling invitations to parliamentary dinners with shadow ministers for hundreds of pounds each.

Last week it emerged that Sir Philip Mawer, the parliamentary standards commissioner, has launched a formal investigation into the Conservative dining clubs. It is against parliamentary rules to use the dining rooms for fundraising.

This weekend the scale of the activities—revealed in the accounts filed by local constituencies—can be disclosed for the first time.

According to the accounts of Cameron's Witney constituency party, his Principal Patrons club brought in £29,954 last year and £25,167 the year before.

The outgoings for the club were just £3,226 last year, so it made a profit of £26,728.

The club is described as a "major income contributor" and is the largest source of funds for the constituency, even outstripping money raised from membership fees.

Other shadow cabinet members are also reliant on the thousands of pounds raised from their patrons' clubs. Tatton, the Cheshire constituency of George Osborne, the shadow chancellor, has made more than £40,000 from his patrons' club since he was elected in 2001.

The patrons' club of Alan Duncan, the shadow trade and industry secretary, has raised more than £20,000 in the past two years for his Rutland and Melton constituency.

The party accounts for last year also refer to a Christmas lunch that was held at the Commons with Cameron as the guest speaker.

The Tory MPs are alleged to have broken parliament's banqueting rules which state: "The private dining rooms are not to be used for direct financial or material gain by a sponsor, political party or any other person or outside organisation."

The Conservatives have denied that the membership fees were a direct payment for the dinners. A spokesman said: "The rules state the rooms may be used for party political purposes and MPs can hire out the rooms for a charge. We have asked Sir Philip to clarify the rules. We believe we have broken no rules."

31 December 2006

16.  Letter to the Commissioner from Rt Hon David Cameron, 9 January 2007

Thank you for your letter of 7th December 2006, regarding the complaint by John Mann MP and Kevan Jones MP into the use of House of Commons facilities. I am very grateful to you for allowing me to reply after the Christmas break.

I have looked carefully at the current rules governing the use of dining facilities at the House of Commons. They seem to contain considerable ambiguity. I do not think that I have broken any rules relating to the use of private dining rooms or other House of Commons facilities, although I will of course be guided entirely by what you conclude.

Let me deal first with the specific complaint made by John Mann MP and Kevan Jones MP in relation to the dinner of the Westminster Group hosted by Richard Bacon on 27 November 2006, at which I was due to speak. As you acknowledge in your letter to me, I see no reason to suppose that my presence—or that of any other Member—as a speaker to a Patrons Club could be held to contravene either paragraph 14 of the Code of Conduct for Members or the Banqueting Regulations. As a speaker, the Member in question is not using 'expenses, allowances, facilities and services provided from the public purse' (as set out in paragraph 14 of the Code of Conduct), and does not—as you point out—carry the responsibility for ensuring that the Banqueting Regulations are adhered to.

Turning to the broader allegations contained in the article in The Sunday Times on 3 December 2006, the West Oxfordshire Conservative Association has a Principal Patrons Club. This was established in 2000, when I was the Parliamentary Candidate for Witney. I attach a copy of the letter inviting recipients to join as a founder member and subsequent correspondence. The Club meets several times a year at various locations in the Witney constituency and at other London venues. It has held two lunches at the House of Commons since I have been the Member for Witney—one on 7th April 2004, addressed by Lord Saatchi, and the other on 16th June 2005, at which the journalist Melanie Phillips was the guest speaker. No activity designed to generate 'direct financial or material gain''(paragraph 5.1 of the Banqueting Regulations) took place at them. I would, of course, be happy to supply any other details of the operation of my Patrons Club since I have been a Member of Parliament, if that would be helpful.

Paragraph 5.5 of the Banqueting Regulations states that 'Subject to the rules on the declaration of interest and 5.1 above, it is appropriate for the private dining rooms to be used for political functions'. My Patrons Club is a 'political function' and is therefore clearly covered by paragraph 5.5. Paragraph 5.1, to which paragraph 5.5 refers, prevents use of private dining rooms by Patrons Clubs for 'direct financial or material gain'. Since funds were not raised at, or in direct connection with, the meals held by the Patrons Club in the House of Commons, I do not believe that my Patrons Club contravenes paragraph 5.1.

Some have argued that the fact there are meals held in the House of Commons as part of the normal round of Patrons Club events could be 'an inducement to recruit new members' as outlined in paragraph 5 3, and could therefore contravene this regulation. However, as you can see from the original letter sent out to potential members, my Patrons Club did not recruit members with the inducement of dinner in the House of Commons. As you can see from the enclosed material, a wide range of functions have been offered to members of the Patrons Club. I attach a list of the breakfasts, lunches and dinners which have been held by my Patrons Club since its inception: only two of the twenty-three events have taken place at the House of Commons.

These Clubs have been custom and practice for many years and, as the complaint against me states, have even been the subject of academic research. In interpreting what are—as you have noted—somewhat ambiguous Banqueting Rules, I would hope that you will be ready to take this into account.

If you require any more information I would be happy to assist in any way I can

9 January 2007

17.  Letter to Mr Jonathan Djanogly from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of a list of events held recently in the House. The list includes a reference to an event you hosted for Huntingdon Conservative Association on 18 October, which Mr Mann and Mr Jones say was a meal. They have asked why this event was not posted on Huntingdon Conservatives web-site (a page from which is enclosed) and whether the failure to post it indicates that you charged for the event at more than cost and were aware that you should not have done so.

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that the event on 18 October was used as a means of raising funds for your constituency association, contrary to paragraph 5.1 of the Banqueting Regulations which says that the House's private dining rooms may not be used for "direct financial or material gain by a . . . political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

18.  Letter to the Commissioner from Mr Jonathan Djanogly, 11 December 2006

Thank you for your letter of 7 December 2006 concerning the complaint by John Mann MP and Kevan Jones MP.

My first point would be that the entry in the list of events, which you provided for 18 October 2006, is incorrect. The entry is wrongly stated as being the "Huntingdon Conservative Association" whilst it should be the "Huntingdon Industrial Advisory Council" (HIAC).

HIAC is an organisation, founded over 25 years ago, which exists for business people living in or connected with Huntingdonshire. There is no need for members of HIAC to be members of the Conservative Party and HIAC itself is not part of the national or local Conservative Party.

My understanding is that members of HIAC pay an annual subscription which entitles them to attend a number of events each year. This includes dinners at the House of Commons or House of Lords, some of which have been booked in my name. Members are entitled to invite guests to HIAC functions and the main purpose of such functions is as a local social networking group with speeches given by notable people, including Members of Parliament.

Accordingly I do not believe that this activity is in breach of section 5.1 of the Banqueting Regulations.

11 December 2006

19.  Letter to the Commissioner from Mr Jonathan Djanogly, 21 December 2006

Thank you for your letter of 14 December.

With regard to your final paragraph, I am not sure how my letter of 11 December could be interpreted to say that the Huntingdon Industrial Advisory Council (HIAC) does not contribute funds to the Conservative Party.

My understanding of the position is that HIAC has its own bank account which is used to receive membership subscriptions and then to pay the money received to fund events. If at the end of the year there is money left over, in the past HIAC has decided to make payments to the Huntingdon Conservative Constituency Association (HCCA).

However, I would make the points that the giving of such money by HIAC to HCCA is:

(a) ancillary to the primary purpose of HIAC, which is to promote the linking of local business to other local stakeholders, including other businesses and politicians; and

(b) to a significant extent, used by HCCA to cover the administrative expenses of HIAC—on the basis that HCCA provides administration services for HIAC.

I hope that this clarifies the position for you.

21 December 2006

20.  Letter to the Commissioner from Mr Jonathan Djanogly, 11 January 2007

Thank you for your letter of 5th January. I have now discussed this with the Secretary of HIAC and can report back as follows:

In confirmation of my previous letter, HIAC was set up some 25 years ago as a forum for business in and connected with the Huntingdon Constituency to meet with the Member of Parliament to discuss and deal with matters of political and economic interest to the business community. It is not seen as a vehicle for raising funds for the Conservative Party.

The annual membership of HIAC has been £300 for the past three years. In the light of increasing catering costs they have decided to increase this to £400 for 2007.

HIAC normally hosts two dinners each year, the majority of which are held in the House of Commons. Occasionally, other venues have been used and other events have also been held. The payment of the membership subscription entitles each member to two tickets at each of the events.

The contributions to the Huntingdon Constituency Conservative Association (HCCA) vary in each year. I should make the point that the administration of HIAC is undertaken within the HCCA office by its staff. Therefore the contributions made should be treated in the most part for payment of administration costs and services.

The annual sums for the past four years paid by HIAC to HCCA are:

2003 £3470

2004 £5810

2005 £4000

2006 £3900

Out of these sums must be taken the administration costs. Detailed figures are not readily available. However, this would annually include several mailings, postage costs, stationery costs, secretarial and event organiser staff expenses, telephone, table decoration and printing of menu cards, as well as payment for alcoholic refreshment consumed during dinners.

Accordingly, I am informed that the net profit element going to HCCA is minimal in all years and sometimes loss making.

Please let me know if I can be of further assistance.

11 January 2007

21.  Letter to Mr James Duddridge from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This consists of an extract from the Register of Members' Interests showing that your constituency party received a donation from the United and Cecil Club.

According to Mr Mann and Mr Jones, the United and Cecil Club holds monthly dinners at the House of Commons. It is "an old, established Conservative Dining Club". In 2001, it was among the top 50 donors to the Conservative Party.

The essence of the complaint which Mr Mann and Mr Jones appear to be making against you is therefore that your constituency party has received money from a club which they believe to be making improper use of the House's dining facilities to raise money for the Conservative Party. Paragraph 5.1 of the Banqueting Regulations says that the House's private dining rooms (and, by implication, its other dining facilities) are not to be used for "direct financial or material gain by a . . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to this complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

22.  Letter to Mr Alan Duncan from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from the above two Members relating to your Patrons' Club and its alleged use of House of Commons dining facilities for fundraising purposes.

The complaint is part of a wider series of complaints of a similar nature which I have received from Mr Jones and Mr Mann against a number of Conservative Members. You will see that two other Members are named alongside you in the enclosed letter.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

With their letter dated 31 January, Mr Mann and Mr Jones sent me a copy of the Annual Report and Accounts of the Rutland and Melton Conservative Association for the year ended 31 December 2005. I enclose a copy for your convenience. Page 6 of these includes a section on the Patrons' Club, which indicates that the Club's 2005 Christmas Lunch was held at the House of Commons. The report continues: "The Patrons' Club provide a significant part of the income needed to finance our organisation …". Page 10 of the accounts show an overall income from fundraising in 2005 of £48,628.

Other material sent to me by the complainants indicates that your Association's Patrons' Club held another event at the House on 15 November 2006. You may also have seen the reference to the Club in the Sunday Times on 31 December 2006: I enclose a copy of the relevant article.

In the light of this material, the complaint which Mr Mann and Mr Jones make is, in essence, that your Association's Patrons' Club is a fundraising device for the Conservative Party. By offering events at the House in return for a membership fee, (the 'profit' on which goes to Party funds) and/or by charging directly for those events it is using the rooms in breach of paragraph 5.1, and probably also of paragraph 5.3, of the Banqueting Regulations.

I should be grateful if, in accordance with the procedures set out in the enclosed note, you will let me have your response to the complaint. It would be helpful if this could include information on:

1.  The membership, aims and activities of your Patrons' Club.

2.   How these activities are funded, including any subscription paid by members.

3.  How the Club raises any funds it donates to your local Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit).

5.  What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years.

If you would like a word about this matter, please do not hesitate to ring me on the number above. I am keen, in the interests of the House, to report reasonably speedily to the Committee on Standards and Privileges on all these related complaints if I can, and a reply by Monday, 19 February, when the House returns from the half-term recess, would therefore be helpful if at all possible.

I am copying this letter and enclosures to the House's Director of Catering Services, with whom I am in touch about these matters and whom I shall consult as necessary on your reply.

6 February 2007

23.  Letter to the Commissioner from Mr Alan Duncan, 19 February 2007

Thank you for your letter of 6th February about the Rutland & Melton Patrons' Club.

My association employs a fully-qualified professional agent who is responsible for all the political organisation in my constituency. In everything we do we endeavour to meet the highest standards, and pride ourselves in trying to be a model constituency in the way we behave. I firmly believe that the organisation of our Patrons' Club fully meets these standards.

To assist you in your investigations I asked my agent for all the information he can muster from the last few years, and I have included in full here with my own letter the report he has sent to me.

In essence, the Patrons' Club is a higher category of local party membership which secures a larger annual subscription from a group who happen to be willing both to pay a little more and who also want to engage, through social events, a bit more in politics.

What we say to them (and there is no promotional literature associated with the Club) is that in return for their annual fee of £250 they will enjoy party membership and in addition can, at no further charge, attend a summer champagne drinks party in the constituency, and a winter lunch in London, each with a guest speaker.

At no stage, nor in any way whatsoever, is there ever any mention or promise of a meal in, or visit to, the House of Commons. In the course of the last 10 or so years, I believe it is true to say that the majority of the lunches have been outside the Commons We are just as happy to go to the Army & Navy, the Carlton or the St Stephen's Club, and some members actually prefer the variety that stems from going to different places.

In the event additional guests attend the lunch, no profit is sought from the booking; the primary purpose of the lunch is so that Patrons can listen to a speaker; and in no respect whatsoever is it true to assert that we have offered anything to do with the House in return either for membership or for profit. At the last review of the Club's finances it was, if anything, marginally more expensive to dine in the Commons, and so it was more of a cost than a benefit for us.

The complainants assert that the Patrons' Club has contributed as much as £48,628 to my association's funds. I wish it were so! This figure, and similar such figures in any other year, are a total from all fund-raising activity in that year, and have no connection with the Patrons' Club. The income from the Patrons falls under the heading 'subscriptions', and the total annual contribution from the balance left after costs is about £7,000.

I feel very strongly that the conduct of my Patrons' Club both adheres to the rules of the House, and also appears to do so in all respects.

I hope this letter and the accompanying documents satisfactorily address all and any concerns. Please do not hesitate to contact me if I can clarify anything further.

19 February 2007

24.  Agent's report on Rutland and Melton Patrons' Club

Patrons' Club Report

Question 1

The Membership of the Patrons' Club as at 31 December 2006 is 69 paying an average membership of £155.14.

Aims and objectives:—to enable members to engage in political discussion at social occasions.

Question 2

Annual membership is currently £250 per person, £300 per couple.

This includes membership to the Party of £25 per person.

Also included are invitations to two social events during the year.

Summer Event—typically a Champagne Reception or Cocktail/Pimms Party at a private house in the constituency.

Autumn Event—Lunch in London including Champagne Reception, wine and three course meal with coffee. As you can see from my answer to Question 4 the House of Commons is sometimes used as a venue: however no promises are made to new or existing members that the House of Commons will be the preferred venue. Patrons may bring a limited number of guests to the lunches. Patrons are charged at cost for these guests; charge calculated on per capita basis and includes administration cost.

Question 3

At the summer event raffles and auctions may be organised and any monies raised are donated to the Association. Funds left after costs of membership, events and administration are absorbed into the Association.

Question 4

Autumn events organised by R&MCA Patrons' Club

Wed 15 November 2006  House of Commons  Guest Speaker  Jonathan Djanogly MP

Mon 28 November 2005  House of Commons  Guest Speaker  David Cameron MP

Fri 26 November 2004  Army & Navy Club  Guest speaker  Mark Field MP

Thu 6 November 2003  St Stephen's Club    Guest Speaker  Theresa May MP

Fri 22 November 2002  Carlton Club    Guest Speaker   Michael Brown

Mon 17 December 2001  House of Commons  Guest Speaker  Rt Hon David Davis MP

Tues 19 December 2000  House of Commons  Guest Speaker  Boris Johnson MP

Thu 2 December 1999  St Stephen's Club    Guest Speaker   Matthew Parris

Question 5

The Patrons' Club, as with the Association's 200 Club and Women's Lunch Club, is fully integrated into the Association (see membership report attached) and all administration is undertaken by the constituency office and its staff. All subscription collection and events are administered by association staff.

Income from the Patrons' Club's Subscriptions is reported in the Annual Accounts as a gross figure as with all membership. However common sense tells you that if you take the average subscription from the attached report of £155.14 per member and then deduct membership to the Party £25 (formally £15) along with the cost of the Autumn Champagne Reception and lunch as well as the cost of the Summer Cocktail/Pimms/Champagne Party, there are little funds available for administration.

Patrons' Club's real benefit to the Association is by way of Raffles, Fighting funds and specific appeals.

25.  Letter to Mr Michael Gove from the Commissioner, 7 December 2006

I have received a complaint from the above two Members in which you are named (along with several other Members). I am writing to inform you of the complaint and the evidence which has been given to me, and to invite your response.

A copy of the letter of complaint from Mr Mann and Mr Jones (dated 23 November) is enclosed. You will see that the complaint focusses on the alleged misuse of House of Commons dining facilities to raise money for the Conservative Party. In particular it is claimed that certain dining clubs, including Patrons' Clubs run by a number of Conservative constituency associations, raise money for Party funds by offering their members the opportunity to dine in the House, in the case of Patrons' Clubs in return for an inflated membership subscription.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5.

The letter of complaint from Mr Mann and Mr Jones was accompanied by a substantial file of supporting material. I am enclosing a copy of the material from the file which particularly relates to you. This includes:

1.  a copy of some pages from the Surrey Heath Conservatives web-site, which include at the end a reference to 'Strangers Gallery', a Parliamentary Luncheon Club which holds "luncheon meetings four times a year at the House of Commons and an annual dinner."

2.  your entry in the Register of Members' Interests showing that "Contributions to Surrey Heath Conservative Association are received from: Strangers Gallery Lunch Club."

Based on this material, the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that Strangers Gallery Lunch Club is a means of raising funds for your constituency association and that it is improperly using Parliamentary dining facilities for this purpose, in so far as paragraph 5.1 of the Banqueting Regulations provides that the House's private dining rooms (and, by implication, its other dining facilities) should not be used for "direct financial or material gain by a. . .political party."

In accordance with the procedures set out in the enclosed note, I now invite your response to the complaint. As the outcome of the complaints I have received is likely to turn in part on the interpretation of the Banqueting Regulations to which I have already referred, I am seeking advice from the House's Director of Catering Services and the Clerk of the Administration Committee on the issues raised.

I shall consider your response and their advice carefully before deciding how to proceed.

If you would like a word about the complaint, please do not hesitate to ring me on the number above.

7 December 2006

26.  Letter to the Commissioner from Mr Michael Gove, 4 January 2007

Thank you very much for your letter of the 7th very kindly informing me of the complaint which has been made by John Mann MP and Kevan Jones MP. I am grateful to you for the trouble you have taken to provide me with the fullest possible background and guidance.

You were kind enough to indicate that "the essence of the complaint which Mr Mann and Mr Jones appear to be making against you is that Strangers Gallery Lunch Club is a means of raising funds for your constituency association and that it is improperly using Parliamentary dining facilities for this purpose, in so far as paragraph 5.1 of the Banqueting Regulations provides that the House's private dining rooms should not be used for 'Direct financial or material gain by a … political party'."

Let me try to deal with each of the questions raised.

HISTORY OF THE CLUB

By way of background, I should explain that Strangers Gallery has been in existence as an executive lunch club for business and professional men and women who work or reside in the Surrey Heath area since 1974, when Surrey Heath Borough Council came into existence. It provides a networking facility for local business people and one of its principal functions is the opportunity it provides for discussion on matters of shared interest.

As I am sure you are aware, Surrey Heath Conservative Association had a spotlight shone on its activities following the decision to deselect my predecessor in 2004. During, and after, that period no suggestion was made that there was anything untoward about Strangers Gallery.

Given the Club's existence for over 30 years, its regular pattern of operations over that time, the fact that no-one troubled to complain beforehand, and the fact that no complaint was made about the Club, even during a time when there was detailed media and political scrutiny of the Association—all this inclined me to believe, as a new Member, that the Club was a highly respected organisation in good standing with the Commons authorities.

THE CLUB'S OPERATIONS—IS WESTMINSTER DINING AN INDUCEMENT TO JOIN?

The Club has played a valuable role in keeping me as a Member of Parliament, and my predecessors, informed about the views and concerns of my constituents and those who employ them. To make it easier for me to stay regularly in touch, the Club meets four times a year in Westminster, on a weekday, for lunch. Given the constraints on my timetable, and theirs, a lunch meeting in Westminster during the week is the most time-efficient way of keeping in touch.

It should be noted, however, that the Club organises a range of events outside Westminster to allow members to socialise and network. Events have included a trip to Leeds Castle, a boat trip down the Thames and a dinner on HMS Belfast. The Club also organises regular informal dinners in the homes of Committee members which create a further opportunity for networking.

Club members also enjoy first refusal for tickets to major SHCA events such as our Summer and Winter Balls, Burns Supper and other major speaker meetings.

It is, I believe, un-knowable to what extent the fact that when I meet with Club members it is in Westminster acts as an incentive to join.

To my mind there are other factors which are the prime motivating reasons in persuading members to become involved—the chance to network with other members, the chance to meet their Member of Parliament, the chance to hear entertaining and informative speakers and the opportunity to enjoy a wide range of social occasions with like-minded people.

Dining in Westminster certainly suits my busy diary, and very often it suits the guest speaker, but I have no doubt that another congenial central London location with high standards of service and cuisine would be equally attractive to the membership. The only losers would be me, in terms of time lost in travel which I could devote to my other parliamentary duties, and the House's Catering Department which would lose valuable custom.

DIRECT FUND-RAISING?

Monies raised at events in the constituency organised by Strangers Gallery members do contribute to party funds. But the Club is not run in such a way as to maximise the amount of money which could be raised for the party. It is run to provide members with a congenial social forum. The Club is allowed, by the terms of its founding constitution, to have up to 100 members, but it currently has just 74. That is a consequence of decisions taken by the Committee who wish to preserve the Club on terms which suit their interests. Needless to say, if the Club were being run primarily as a Conservative Party fund-raising exercise, a much more pro-active approach would have been taken to growing membership and gathering in funds.

The lunches which take place in the House of Commons are priced in such a way as to barely cover the costs of all those involved. Each lunch—including wine and three courses—costs £55. Club accounts show that the regular operating surplus on each lunch is between £5 and £8 head. The last lunch had 58 people dining and made an operating surplus of just £404. Organising each lunch is a major administrative task for the Club Secretary, who operates from his own accountancy practice, not from any Conservative premises. The operating surplus from each lunch, at around £400, barely covers the effective cost of the time he commits to each event.

It would appear to me, on that basis, that these lunches do not constitute the use of Commons facilities for "direct financial or material gain" by a political party. No fund-raising activity takes place during lunches. And given the net worth of many of the individuals present, the decision to charge only slightly above cost reflects a commitment to respect the rules of the House.

4 January 2007

27.  Letter to Rt Hon John Gummer from the Commissioner, 6 February 2007

I enclose a copy of a letter of complaint I have received from the above two Members relating to your Westminster Club and its alleged use of House of Commons dining facilities for fundraising purposes.

The complaint is part of a wider series of complaints of a similar nature which I have received from Mr Jones and Mr Mann against a number of Conservative Members. You will see that two other Members are named alongside you in the enclosed letter.

Paragraph 14 of the Code of Conduct for Members provides that:

"Members shall at all times ensure that their use of expenses, allowances, facilities and services provided from the public purse is strictly in accordance with the rules laid down on these matters, and that they observe any limits placed by the House on the use of such expenses, allowances, facilities and services."

The relevant rules relating to the use of private dining rooms at the House are to be found in the Banqueting Regulations. I have enclosed a copy for your convenience. I draw your attention in particular to Section 5, especially paragraphs 5.1, 5.3 and 5.5. Paragraph 5.1 provides that the House's private dining rooms (and by extension, its other catering facilities) may not be used for "direct financial or material gain by a … political party" and paragraph 5.3 that they may not be used "as an inducement to recruit new members of outside organisations or non-parliamentary associations".

With their letter dated 31 January, Mr Mann and Mr Jones sent me a copy of the Annual Report and Accounts of the Suffolk Coastal Conservative Association for the year ended 31 December 2005. I enclose a copy for your ease of reference. On page 3 of the report, there is a reference to a Westminster Club as one of the money-raising activities of the Association. Page 5 reports total income from fundraising in 2005 of £19,486. Information supplied separately to me by the complainants indicates that your Association's Westminster Club held an event at the House on 6 November 2006.

In the light of this material, the complaint which Mr Mann and Mr Jones make is, in essence, that your Association's Westminster Club is a fundraising device for the Conservative Party. By offering events at the House in return for a membership fee, (the 'profit' on which goes to Party funds) and/or by charging directly for those events it is using the rooms in breach of paragraph 5.1, and probably also of paragraph 5.3, of the Banqueting Regulations.

I should be grateful if, in accordance with the procedures set out in the enclosed note, you will let me have your response to the complaint. It would be helpful if this could include information on:

1.  The membership, aims and activities of your Westminster Club.

2.   How these activities are funded, including any subscription paid by members.

3.  How the Club raises any funds it donates to your local Association.

4.  How many events it has held at the Houses of Parliament in the course of the last 5 years; when; and how these have been funded (whether paid for out of subscriptions or paid for directly by members and if the latter, whether or not the events have been charged for at cost or have made a profit).

5.  What is the Club's organisational relationship with your Association and how much it has donated to the Association in each of the last 5 years.

If you would like a word about this matter, please do not hesitate to ring me on the number above. I am keen, in the interests of the House, to report reasonably speedily to the Committee on Standards and Privileges on all these related complaints if I can, and a reply by Monday, 19 February, when the House returns from the half-term recess, would therefore be helpful if at all possible.

I am copying this letter and enclosures to the House's Director of Catering Services, with whom I am in touch about these matters and whom I shall consult as necessary on your reply.

6 February 2007

28.  Letter to the Commissioner from Rt Hon John Gummer, 19 February 2007

Thank you very much for your letter. Clearly I needed to get the information required from the Chairman of the Suffolk Coastal Conservative Association as I have nothing to do with the financial arrangements of the Association and, indeed, it would be severely frowned on were I to attempt any such thing. He has written back to me with the enclosed letter, detailing the circumstances of the Westminster Club. You will see that the reason for holding these meetings in the House of Commons is primarily because of the ability to attract notable speakers, who are clearly more able to attend when the event does not require any travel.

You will see that the new Honorary Treasurer of the Association changed the format in which the accounts were presented and put all incoming money, including my own payment for office facilities and services under "Fund-raising". Clearly this was not a suitable appellation for the items included and in future he will present the accounts in a way which is less liable to misinterpretation. This problem would not have occurred if the Registered Treasurer of the Association had not been incapacitated for much of last year when the accounts were being prepared.

I have to say that it had never occurred to me that anyone might believe that there might be something improper at a political club holding a lunch in the House of Commons. Even now one would have to say that it would be odd if such a lunch were available for members of organisations in my constituency, for whom I am always happy to sponsor such an occasion, but not specifically to those who have an interest in politics. There has therefore never been an intention either by me or by my Association, to do other than obey the rules of the House.

There is a difficulty that arises from budgeting to ensure that a loss is not made at such lunches and if your view is that it would be better were we to offer to return any money over and above the sums required for the lunches at the end of the year, I am sure that offer could certainly be made. I am anxious that we should offend neither the spirit nor the letter of the law, but at the same time clearly I would not like to lose the real advantage of enabling people to meet senior politicians and to exchange views with them.

I ought also to say that, to my knowledge, I have never refused to sponsor a function in the House of Commons for any of my constituents, irrespective of their party political allegiance or interests and that continues to be true.

If I can be of any further assistance, please let me know.

I am told that the figures I include have had to be extracted from the records as the breakdown has not hitherto been made. I fear that there are no similar breakdowns for earlier years. Obviously—if you wanted—I could ask for some attempt to be made to make similar figures available for previous years. They would be likely to show smaller surpluses and would take some time to obtain. Nevertheless, if you need them, I shall ask for someone to try to abstract them in this form.

19 February 2007

29.  Note by the Chairman of the Suffolk Coastal Conservative Association

You have asked for clarification of the role of our Westminster Club following an enquiry from the Office of the Parliamentary Commissioner for Standards.

The Westminster Club was created and exists to connect with Suffolk's Business and Professional Communities, for the benefit of all parties involved. It has a diverse membership which includes farmers, estate agents, motor dealers, local manufacturers and retailers, and those involved in tourism. It provides an opportunity to hear the views, question and debate key issues with senior members of the Party, and sometimes with local notables whose position is wholly apolitical.

The Club has its own Chairman who is not a member of the Association's Executive, and its own Officers. A lot of work goes into organising the three events and this is effected by the Secretary hiring the necessary support from the Woodbridge office. Those who join are automatically made a Member of the Conservative Association and a subscription of £15—the minimum figure required by the Party Organisation—is taken.

Three events are held each year—one Breakfast Meeting at a hotel in Suffolk to discuss local matters—often with a non-party political speaker—and two in London, currently at the House of Commons, where national and international issues are discussed. It would be totally inappropriate for any money raising activity to take place at these events.

The Palace of Westminster has been used as it provides ready access to the top speakers. As with all our events, it is clear that it is the speaker and not the location that generates the demand for places and additional guests. Given the growing popularity of the Club, due to the quality and relevance of the speakers—David Cameron, William Hague, George Osborne—we are having to consider returning to other nearby venues which can accommodate a larger attendance than that available at the Palace of Westminster.

Our membership numbers over the past five years are:

2002

15 Full Members

1 Part Year Member

7 Guests

2003

17 Full Members

2 Part Year Members

15 Guests

2004

25 Full Members

5 Part Year Members

11 Guests

2005

27 Full Members

2 Part Year Members

35 Guests

When establishing the annual subscription (which covers all costs for the year) we have to take account of a number of variables outside our control, notably the demand for membership, the number of guests, the number of "no shows" by members and guests at the three events and the level of imbibing! There are of course meals at events which are paid for but not taken and, if we have adequate notice, these may not have to be paid for by us. Details are shown on the attached sheets. Needless to say, we budget to break even.

Up to 2005, any surplus was rightfully identified as "Donation from Association Bodies" along with the sums received from the MP for support and services rendered by the Association's office here.

A re-examination of the 2005 accounts prompted by this enquiry reveals however that the new Honorary Treasurer made a number of changes and incorrect allocations of which fund raising was one. This is confirmed by the marked difference between Donations and Fundraising in 2004 and 2005.

As you will see from the two financial statements enclosed, there was a surplus of £502 in 2005, up from previous years, largely because of David Cameron's attendance in November 2005 during the leadership race, which realised a sell out. This was a lucky break for us as we could not predict this when planning our events far in advance. I fear that we have no detailed accounts for those earlier years.

Money raising may be difficult but I can assure you that there are many easier ways of generating funds than by operating a separate club within this organisation but our Westminster Club is highly valued by both the business and professional communities locally, this Association, and those Members of Parliament who address these meetings, in fulfilling the objective set out previously.

Please let me know if any more information is required.

30.  Letter to Mr Charles Hendry from the Commissioner, 31 January 2007

Further to our telephone conversation earlier today, I enclose a copy of the letter I have received from the above 2 Members dated 30 January (my e-mail of today to you also refers).

When I spoke to Mr Jones this morning, he referred me to a list of events in the House in October and November 2006, a copy of which I also enclose. You will see that this includes reference to a dinner which you are said to have hosted at the House on 29 November 2006 for the "Sir Winston Churchill 50 Dining Club".

An earlier version of this list was included in the material which Mr Mann and Mr Jones sent me with their original complaint about dining clubs on 23 November last year. However, the last entry on the version I received then was dated 15 November and so the entry relating to you was not included in the material I received at that point. Nor had I, indeed, seen the enclosed version of the list until this morning.

In view of the letter Mr Mann and Mr Jones have now sent me, I feel obliged to put their complaint to you in order that you may have the opportunity to respond to it. As I understand it, the allegation they are making is in essence, that the "Sir Winston Churchill 50 Dining Club" is a fund raising device for the Conservative Party akin to the Patrons' Clubs to be found in other constituencies. These Clubs typically offer their members the opportunity to dine at the House (as well as other social events) in return for an inflated annual membership subscription. The surplus of the funds raised is paid out to the Conservative Party. Mr Mann and Mr Jones argue that the use of the House's dining facilities in this way is contrary to:

I should welcome your response to this complaint, in accordance with the procedure set out in the enclosed note. It will be helpful if this includes information on:

1.  the nature, objectives and membership of the Club

2.  its funding

3.  in particular, how the dinner at the House on 29 November was funded, and

4.  whether the Club has made donations to your constituency association and, if so, of how much and when.

I hope this makes the position clear but if you are left with any queries, please do not hesitate to ring me on the number above.

I look forward to receiving your reply.

31 January 2007

31.  Letter to the Commissioner from Mr Charles Hendry, 9 March 2007

Thank you for your letter regarding the dinner I hosted in Dining Room A for the Sir Winston Churchill Fifty Dining Club on 29 November.

The Club has no links whatsoever either to me or to my constituency association. I understand it was founded in the 1960s for people living or working in, or having an interest in, the Parliamentary constituencies of Brighton Kemptown, Brighton Pavilion and Hove. It is limited to 50 members, who are not necessarily members of a political Party, who pay a joining fee of £100 and an annual membership of £200.

The Club is administered by Hove Conservative Association. Members receive three dinners a year, usually held in the House of Commons, with a Conservative spokesman as the guest speaker. The costs of these dinners are covered by the members' annual subscription. Additional guests can be invited at a cost of £45/head. There is no fund-raising at the dinners nor does the Club take part in more general fund-raising activities although it has made occasional donations to the Conservative Party where surplus funds have made this possible.

The dinners are hosted in Westminster/near Westminster for the convenience of the guest speaker and to ensure that the speaker would not need to cancel because of parliamentary business. My impression is that the guests attend to hear the speaker rather than because the dinner is in the House of Commons.

As there is currently no Conservative MP in Hove, neighbouring MPs have been asked to host the dinners and I was asked to host the one which took place on 29 November. It is the first such dinner I have been asked to host and I derived no financial or other benefit either for myself or for my own constituency association.

With regard to the specific complaint:

The Club made the room booking through my office and they secured the Guest Speaker themselves.

I understand that the membership fee covers the full costs of the meal, together with the wine, pre-meal drinks, dinner menu, associated printing and administrative costs, as well as the meal costs of the Guest Speaker.

I understand that the list of benefits of membership does refer to the dinners being held in Westminster. Given the name of the club and its purpose—giving Brighton & Hove-based businesses the chance to network with each other and with senior Conservative Party spokesmen—the listing of the event at Westminster is intended to be factual and is not intended as an undue inducement. Indeed, not to mention the dinner at Westminster would seem perverse.

I hope this enables you to complete your investigation and I hope this helps to reassure you about this particular one-off event. For the sake of completeness, I should add that my own constituency Patrons' Club does not use House of Commons facilities.

9 March 2007

32.  Further letter to the Commissioner from Mr Charles Hendry, 9 March 2007

I am attaching my formal reply to your letter regarding the complaint which has been made against me by Kevan Jones MP and John Mann MP.

In addition to your investigation into this issue, I would also be grateful if you would look into the way this complaint has been handled and to clarify the guidelines on the appropriate way for such things to be done.

As you will be aware, I was notified of this complaint by a journalist from the Brighton Argus. I told him that I was not aware of a complaint being made and had not been notified as such either by the two MPs involved or by yourself. Nevertheless, this led to two damaging stories in the local papers, one under the headline: 'MP is under investigation'. As you will recall, I then contacted you and you advised me that no such complaint had been received.

I relayed this to the journalist who then contacted Kevan Jones, who informed him that my name had not been included in the initial complaint, but that he would now lodge a complaint about the dinner I hosted in November.

On legal advice, I have written to the paper to say that the articles they wrote were clearly libellous, as no such complaint had been made, but we have decided to wait until the completion of your investigation before taking matters forward. They fully recognise the inaccuracy of the story.

I would be grateful if you could express an opinion on whether this is an acceptable way for Members to behave—to notify the press of a complaint before they have had the courtesy of advising the Member concerned or before even making a complaint to your office? Surely Members should hear from you first, before hearing from the media?

Perhaps it might be a useful opportunity to remind all colleagues of appropriate procedure in making a complaint?

The local newspapers are concerned to correct what they accept was a seriously incorrect story, but should it result in legal action, then it would lead to the very unfortunate situation of another Member having to be named in that action. Had proper procedures been followed, that situation would not have arisen.

I am copying this letter to Kevan Jones, John Mann, Sir George Young, Patrick McLoughlin and Tommy McAvoy.

9 March 2007

33.  Letter to Mr Charles Hendry from the Commissioner, 12 March 2007

Thank you for your two letters of 9 March.

First, may I acknowledge your letter in formal reply to this complaint? In accordance with the procedures set out in the note I sent you on 31 January, I will let you have shortly the draft of the factual sections of my report relating to the complaint against you. I shall be grateful if you will let me have any comments on this as soon as possible, so that I may complete the report and submit it for the Committee on Standards and Privileges to consider.

Secondly, in your letter covering your formal reply, you ask me to look into the way the complaint by Mr Mann and Mr Jones has been handled and to clarify the guidelines on the appropriate way for such things to be done. You particularly have in mind the failure of Mr Mann and Mr Jones to inform you or me that they had made the complaint against you before they informed the press of it.

The House's expectations on this matter are very clear. Paragraph 85 of the Guide to the Rules relating to the Conduct of Members says:

"It is a basic courtesy that a Member making a complaint to the Commissioner should at the same time send a copy of the letter of complaint to the Member concerned."

It is, of course, implicit in this that the Member complaining will inform me at the same time as telling the Member concerned, and before informing any third party.

I set out in my letter to you of 31 January what I know of the circumstances surrounding the communication to you and to me of the complaint against you. Only Mr Jones and Mr Mann can provide an explanation from their point of view.

I shall, as you request, draw this aspect of the matter to the attention of the Committee when submitting my report on the linked series of complaints by Mr Mann and Mr Jones. It will be for the Committee to decide, but it may well be that it will wish to reiterate the importance of Members complying with the House's expectations on this point when it in turn reports to the House on these complaints.

I am copying this letter to the recipients of yours.

12 March 2007

34.  Letter to the Commissioner from Mr John Mann and Mr Kevan Jones, 14 March 2007

Thank you for your letter of 12th March enclosing your letter to Charles Hendry.

We are pleased to be able to confirm what was explained on the telephone on the morning of 30th January: that we had always believed that Charles Hendry's name had been included in the dossier of evidence submitted to you before Christmas 2006.

That is why when a journalist from the Brighton Argus contacted the office of Kevan Jones in January the office stated that Charles Hendry's name was amongst those submitted to you.

It was always our intention that Charles Hendry's dinner be investigated; that is why when it became apparent that you did not have this information we submitted it to you in the letter of 30th January. In addition, we enclose copies of his constituency accounts which detail the income received from the Patrons' Club as well as a Patrons' Club event that was hosted by Lord Saatchi at the House of Lords.

14 March 2007

35.  Letter to Mr John Mann and Mr Kevan Jones from the Commissioner, 15 March 2007

Thank you for your letter of 14 March responding to mine of 12 March. I have noted your explanation of the circumstances in which you did not inform Mr Hendry in advance of your complaint against him and I will include a summary of the position in my report.

Thank you also for the copies of Mr Hendry's constituency accounts you sent me. I note that in 2004 his Association's Patrons' Club held a dinner addressed by Lord Saatchi in the House of Lords but as you know I do not have jurisdiction in respect of the Upper House. Mr Hendry has separately informed me that his constituency Patrons' Club does not use House of Commons facilities.

I will let you know when I have submitted my report to the Committee on Standards and Privileges.

15 March 2007

36.  E-mail containing sample letter of invitation to prospective members of the Fareham Patrons' Club

I am writing to you as President of the Fareham Patrons' Club, an informal group that supports my work and that of the Fareham Conservative Association.

The Club holds two dinners in the House of Commons twice a year as well as a reception in the constituency. At our dinners in London, the aim is to provide the opportunity for people to listen to a k