1.  We applaud the Prime Minister's decision to revise the Ministerial Code and to focus it on questions of general principle rather than detailed guidance on procedure. Procedural guidance is necessary, but the Ministerial Code is not the place for it. A principle-based Code should be simpler for ministers to use and simpler for Parliament and the public to judge them by. (Paragraph 9)

2.  We welcome the Prime Minister's decision to publish a list of ministerial interests. The list will be an important safeguard against impropriety. (Paragraph 10)

3.  We do not believe the public is greatly exercised by how ministers obtain advice on avoiding conflicts of interest. The primary concern around the Code has never been its content. Nor has it been a lack of advice for ministers on compliance. The major issue remains what happens when it appears that the Code has been breached. (Paragraph 11)

4.  We welcome the assurance that the Independent Adviser is no longer to be limited to investigating only breaches of certain parts of the Ministerial Code. (Paragraph 13)

5.   It is right that the Independent Adviser should investigate the facts of allegations, and not determine the penalty if ministers are found to have breached the Code. Prime Ministers must ultimately be accountable for who serves in their governments. (Paragraph 14)

6.  We welcome Sir Philip Mawer's understanding that the facts uncovered in his investigations will be made public. Like him, we believe that public confidence requires it. However, he acknowledges that the Prime Minister retains a discretion, and it is easily foreseeable that some investigations might uncover information which is potentially embarrassing or even damaging to the government, and which therefore the Prime Minister might not want to publish. For the avoidance of doubt, therefore, we invite the Prime Minister to state unambiguously that he will make public any relevant findings of fact. (Paragraph 16)

7.  It is hard to see how the Independent Adviser can command public confidence if the Prime Minister can decide that prima facie breaches of the Code will not be investigated. (Paragraph 17)

8.  the Government has confirmed that Sir John Bourn was not asked to conduct any investigations while he was Independent Adviser. Put simply, there is no point in having an investigator in post if he is not given discretion to investigate very public allegations that the Code has been breached. (Paragraph 17)

9.  We welcome Sir Philip Mawer's assurance that he would make his views clear to the Prime Minister if he felt that a particular allegation required investigation. It is encouraging that he has already had a number of meetings with the Prime Minister, and that his views will be heard. Nonetheless, the decision to instigate an investigation still lies with the Prime Minister. The Prime Minister is clearly not an impartial figure when it comes to deciding whether or not to instigate an investigation. If the regulatory system is to have credibility, that decision must be taken out of political hands. (Paragraph 20)

10.  The post of Independent Adviser should become a permanent part of the regulatory framework for conduct in public life. If the post is to become permanent, however, it is important not just that the postholder's personal independence is unimpeachable, but also that there are institutional safeguards to guarantee that independence of action. (Paragraph 21)

11.  Effective regulators ought to be at a healthy distance from those they regulate. While the Independent Adviser is accommodated in the Cabinet Office, staffed by the Cabinet Office and funded by the Cabinet Office, it is hard to see how that distance will be maintained. (Paragraph 27)

12.  Having appointed Sir John Bourn to the job as recently as 2006, we do not understand how the Government can argue it is not appropriate for a serving Officer of Parliament to be the Independent Adviser on Ministerial Interests. (Paragraph 28)

13.  The Independent Adviser should be appointed, if not by Parliament, then at least through a transparent open competition, regulated by the Commissioner for Public Appointments. This would still allow the Prime Minister the final say, but only after a rigorous, safeguarded process. The appointment should then be made on a fixed term, and it should be subject to a pre-appointment hearing. (Paragraph 29)

14.  We welcome the fact that an annual report will be published, but more active pursuit of publicity will be needed. At the very least, as Sir Philip acknowledged, his post should have a dedicated website. (Paragraph 30)

15.  We are also attracted to the notion that dismissal should not be the only punishment available for a breach of the Code. (Paragraph 32)

16.  Sir Philip Mawer told us that he supported some "equivalent of a yellow card" for ministers whose offence did not warrant their removal from office. It is, as Sir Philip acknowledged, difficult to imagine what that "yellow card" might be, but this does not mean it is not an idea worth pursuing. Expecting ministers to come to the House and make a formal statement of apology is one option; simple naming and shaming is another. We recommend that the Government considers whether there are any suitable penalties for breaching the Ministerial Code that fall short of dismissal. Whatever penalty is preferred, however, it will only be credible if the investigation which preceded it is also credible. (Paragraph 33)

17.  This report sets out the steps needed to give credibility to the investigation of alleged breaches of the Ministerial Code. By appointing an investigator, the Prime Minister has shown that he understands the need for fair, impartial investigation. It is a significant step towards fair, defined accountability for ministerial conduct. The potential benefits of such a post, however, will not be felt unless the investigator is widely seen to be entirely independent and impartial. Current arrangements do not provide for that independence. Until the changes we outline have taken place, it is inappropriate to refer to the new investigator as an Independent Adviser. We therefore urge the Prime Minister to adopt the Committee's recommendations for change, and in so doing to build upon the significant improvements already made to the machinery for investigating the conduct of ministers. (Paragraph 34)