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Summary of Investigation – Public Policy Projects Ltd

Friday 26th February 2021

February 2021

Organisation or Person Investigated

Public Policy Projects Limited (“PPP”)

Matter(s) Investigated

Following a query from a journalist, this investigation was to
determine if PPP is an unregistered consultant lobbyist and in particular whether a meeting
on 21 August 2020 (“the meeting”) constituted consultant lobbying.

Registrar’s Decision

Based on the information provided and assurances given, PPP’s
activities do not currently constitute consultant lobbying.

Summary of Rationale for Decision

My formal guidance covers a number of issues to be
considered by think tanks in relation to registration, including: “If funding is provided for a
specific project, but the funder cannot exercise control over the outcome of the project, the
activity is unlikely to be registrable. This is because any resulting communication would be
expressing the think tank’s views, rather than being on behalf of a client.”
PPP provided details of how they operate and comprehensive assurances that the views
they communicate are those of PPP, not those of clients or funders. In particular, clients
cannot influence the outcome of research projects. PPP also provided details of the meeting
which was in fact a PPP webinar co-chaired by a Deputy Chair of PPP, Baroness
Blackwood, and addressed by Lord Bethell, a minister at the Department of Health and
Social Care.
Based on the assurances from PPP about how they work and details of the meeting, I am
satisfied that PPP’s current activities do not constitute consultant lobbying.

Chronology

DateAction
16 February 2021

Email received from a journalist, asking if ORCL received any returns on
Public Policy Projects Ltd (PPP) that have not yet been published. The query
stemmed from published evidence of a meeting between PPP, Baroness
Blackwood and Lord Bethell, Parliamentary Under Secretary of State at the
Department of Health and Social Care.
17 february 2021Formal letter from the Registrar to PPP giving an overview of the
Transparency of Lobbying, Non-Party Campaigning and Trade Union
Administration Act 2014 (the Act); asking PPP to consider whether they
undertake communications that fall within the scope of the Act; and about the
meeting between Baroness Blackwood, PPP and Lord Bethell on 21 August
2020 to discuss clinical trials.
24 February 2021Response from PPP stating they define their own projects, accepting funding
but not briefs from clients; they keep editorial control of their publications; and
they speak with public officials to promote discussion on PPP policy
proposals, not on behalf of clients. Regarding the meeting of 21 August, PPP
stated it was a webinar co-chaired by Baroness Blackwood and Dr Jonathan
Sheffield and addressed by Lord Bethell. It was held as part of the work of
the Clinical Research Coalition, initiated by PPP, in May 2020 through a
public call for evidence from those interested in the implications of the Covid
pandemic for clinical research in the UK. This call led to written contributions
and a series of webinars in which speakers were drawn from a broad
spectrum of thought leaders in the sector.

26 February 2021

Office of the Registrar of Consultant Lobbyists

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