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Summary of Investigation – Portland PR Limited

Monday 11th January 2021

November 2020 to January 2021

Organisation or Person Investigated

Portland PR Limited

Matter(s) Investigated

Whether Portland PR Limited submitted accurate QIRs, particularly
non-inclusion of Boston Consulting Group (BCG) in their QIR for April to June 2020; and
whether George Pascoe-Watson’s discussions with Lord Bethell included undeclared
lobbying. This investigation followed a Sunday Times article on 15 November 2020.

Registrar’s Decision

The QIR for April to June 2020 is accurate, based on assurances
from Portland PR Limited and further enquiries with the Department of Health and Social
Care (DHSC). However, in reviewing all QIR data, Portland PR Limited discovered that
clients were omitted from their July to September 2020 QIR, for which I will issue a Notice of
Intention to impose a civil penalty.

Summary of Rationale for Decision

On the two specific questions, assurances have been
given by Portland PR: that they had no involvement in the meeting with Lord
O’Shaughnessy, DHSC and BCG; nor were they connected with Mr Pascoe’s-Watson’s role
at DHSC. I accept the evidence and assurances given, that both were acting in an
independent capacity. As part of Portland PR Limited’s full review, they have declared
omitted clients from their July to September 2020 QIR. A civil penalty is appropriate for this
omission.

Chronology

DateAction
15 November 2020Sunday Times article regarding potential undeclared lobbying.
16 November 2020 Formal letter from Registrar to Portland PR Limited regarding
accuracy of QIRs, particularly non-inclusion of Boston
Consulting Group (BCG) in their QIR for April to June 2020;
and whether George Pascoe-Watson’s discussions with Lord
Bethell included undeclared lobbying. Response required by 17:00 on 23 November.
23 November 2020Letter from Portland PR Limited, stating they need more time
to review all QIRs for comprehensive assurance.
24 November 2020Letter from Registrar to Portland PR Limited extending
deadline for full response to 1 December 17:00.
1 December 2020


Letter from Portland PR Limited requesting further time
to complete the process of QIR verification for
comprehensive assurance.
4 December 2020Email from ORCL office requiring response to the two
specific issues raised in the Registrar’s letter of 16
November by 17:00; and the fuller response by 17:00 on
15 December.
4 December 2020Call and email from Portland PR Limited apologising for
delay; confirming discrepancies in their QIR July to
September 2020; confirming no consultant lobbying for
BCG in April to June 2020; and Mr Pascoe’s-Watson’s
role at DHSC was in a personal capacity and did not
involve lobbying for Portland PR Limited clients.
7 December 2020Email from ORCL office for further clarification on dates
of meetings with Lord O’Shaughnessy, DHSC and BCG
and who initiated.
8 December 2020

Email from Portland PR Limited confirming no
involvement with the meeting and suggesting follow up
with DHSC.
14 December 2020Formal letter from Registrar to DHSC, requesting further
information about meetings with Lord O’Shaughnessy,
DHSC and BCG and who initiated.
15 December 2020Full response from Portland PR Limited, confirming
response of 4 December; identifying and apologising for
three omitted clients from the July to September 2020
return, following a full review; and providing assurance
that this was not as a result of a systems issue.
16 December 2020

Email from ORCL office requesting further information
on reason for omissions and basis for assurance that it’s
not systematic.
18 December 2020Email from Portland PR Limited, giving further
information on reporting systems and omission.
23 December 2020Email from DHSC, confirming no involvement from
Portland PR Limited in meeting with Lord
O’Shaughnessy, DHSC and BCG.

11 January 2021

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk