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Summary of Investigation – Lord Hammond of Runnymede (‘Lord Hammond’) and Matrix Partners Limited (‘Matrix’)

Friday 10th September 2021

August and September 2021

Organisation or Person Investigated

Lord Hammond of Runnymede (‘Lord Hammond’) and Matrix Partners Limited (‘Matrix’).

Matter(s) Investigated

Whether Lord Hammond is an unregistered consultant lobbyist, with particular reference to OakNorth Bank PLC (‘OakNorth’).

Registrar’s Decision

Based on detailed information that Lord Hammond provided about his business activities
and on substantive assurances from him, I conclude that he has not been engaged in
consultant lobbying activity, either independently or through Matrix.

Summary of Rationale for Decision

Lord Hammond and Matrix demonstrated that his email of 24 July 2020 to Charles
Roxburgh, Second Permanent Secretary at HMT, in relation to OakNorth fell within the
exception in schedule 1, part 1 of the Transparency of Lobbying, Non-Party Campaigning
and Trade Union Administration Act 2014 (‘the Act’) (‘the incidental exception’) which
provides (in part):
A person does not, by reason of making a communication, carry on the business of
consultant lobbying if (a) the person carries on a business which consists mainly of
non-lobbying activities, and (b) the making of the communication is incidental to the
carrying on of those activities.
Had the incidental exception not applied, the email of 24 July 2020 would have been an act
of consultant lobbying and therefore a registrable communication.

Chronology

DateAction
8 August
Media report regarding Lord Hammond emailing the second permanent
secretary of the Treasury on behalf of OakNorth.
10 AugustFormal letter from the Registrar to Lord Hammond giving background on
the requirement for registering; asking if his activities in general fall within
the criteria to be registered; and in particular with reference to OakNorth.
10 August
Email from Lord Hammond assuring the Registrar that his business
activity does not include consultant lobbying.
11 AugustLetter from Registrar asking for further information.
17 August
Email from Lord Hammond responding to the further information request
on 11 August and giving rationale for the communication to fall within the
incidental exception.
18 AugustEmail from Registrar requesting Lord Hammond’s letter of agreement with
OakNorth.
19 August
Email from Lord Hammond attaching letter of appointment from OakNorth.
23 August Email from Registrar asking in what terms Lord Hammond’s intention not
to lobby on behalf of OakNorth was made clear.
23 August
Email from Lord Hammond providing further information in response to the
Registrar’s email earlier the same day.
8 September Letter from Registrar requesting further information regarding the volume
and value of OakNorth work in relation to his and Matrix’s activities.
8 September

Email from Lord Hammond providing further information in response to the
Registrar’s email earlier the same day.
10
September
Letter from Registrar to conclude the investigation and to advise that, had
the incidental exception not applied, Lord Hammond’s email to Charles
Roxburgh would have been consultant lobbying under the definitions
provided in the Act. This is irrespective of the terms of the agreement with
the client and whether or not the offer contained in the email was probono. The Registrar drew Lord Hammond’s attention to the difference
between the requirements of the Act and those of ACOBA, in particular in
respect of what constitutes ‘consultant lobbying’ and ‘lobbying’.

10 September 2021
Office of the Registrar of Consultant Lobbyists
office@orcl.gov.uk