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Summary of investigation – Tulchan Communications LLP (‘Tulchan’)

Wednesday 25th November 2020

November 2020

Organisation or Person Investigated

Tulchan Communications LLP (‘Tulchan’)

Matter(s) Investigated

Whether Tulchan submitted an inaccurate Quarterly Information
Return under the terms of the Transparency of Lobbying, Non-Party Campaigning and Trade
Union Administration Act 2014 (‘the Act’), in particular whether they omitted a client from their
return for the period April to June 2020.

Registrar’s Decision

Based on the information provided, and no evidence to the contrary,
Tulchan did not conduct undeclared consultant lobbying as defined by the Act in the period
under enquiry.

Summary of Rationale for Decision

Tulchan provided a timeline of the activities of its
Managing Partner, Lord Feldman, in relation to Tulchan, the Department for Health & Social
Care (‘DHSC’) and Oxford Nanopore Technologies Limited (‘Oxford Nanopore’) from March
2020 to June 2020. Irrespective of Lord Feldman’s status with Tulchan in this period, the
Registrar has no evidence of activity that constituted consultant lobbying within the definition
in section 2 of the Act (i.e. communication by the consultant with a Minister, Permanent
Secretary or equivalent, on behalf of a paying client).
Oxford Nanopore was not a client of Tulchan in the period of Lord Feldman’s association
with DHSC. They subsequently became a client of Tulchan and the Registrar has received a
comprehensive assurance dated 18 November 2020 that no consultant lobbying had been
conducted by Tulchan on behalf of Oxford Nanopore as at that date.

Chronology

DateAction
16 November 2020

Query from a journalist to ORCL following reports that Lord
Feldman, Tulchan Managing Partner, met with ministers and
Oxford Nanopore on 1 April and on 13 May 2020. The
journalist asked why Oxford Nanopore was not listed as a
Tulchan client in their Quarterly Information Return.
16 November 2020 Formal letter from Registrar to Tulchan to enquire whether
an inaccurate Quarterly Information Return had been
submitted.
18 November 2020 Response from Tulchan providing a comprehensive
assurance about the accuracy of its Quarterly Information
Returns and setting out a timeline of the activities of Lord
Feldman in relation to Tulchan, the Department for Health &
Social Care (‘DHSC’) and Oxford Nanopore from March 2020
to June 2020.

25 November 2020

Office of the Registrar of Consultant Lobbyists

office@orcl.gov.uk