Effective Self Regulation in Lobbying

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UKPAC positively encourages effective self-regulation in the lobbying industry. This document sets out what UKPAC considers to be the essential requirements for such a self-regulatory system. It is not intended to be a comprehensive blueprint: each association, organisation or body which commits to effective self-regulation will no doubt wish to incorporate additional elements appropriate to its own particular circumstances. It is also the responsibility of each association, organisation or body to put in place appropriate induction and training arrangements to ensure awareness and observance of its Code of Conduct, and to commit adequate resources to secure the enforcement of the Code.


1. Code of Conduct


In its response to the Government's consultation on a statutory register of lobbyists, the Committee on Standards in Public Life advocated a single code of conduct, backed if necessary by statute. UKPAC recognises that the range of membership bodies, trade associations, companies and other organisations involved to a greater or lesser extent in lobbying makes a single self-regulatory code unattainable for the foreseeable future. But effective self-regulation can nonetheless be achieved if everyone in a business or employed in a capacity which involves lobbying subscribes to an appropriate Code of Conduct. That code may be administered by a professional association or membership body, or by a particular organisation or company.  


The code must, as a minimum, require observance of UKPAC's Guiding Principles http://www.citizenpower.co.uk/en/resources/ relating to -


        Transparency and Openness


        Accuracy and Honesty






The code must also require those who subscribe to it to cooperate in full with the Complaints Procedure (see next section) in the event of a complaint of non-compliance being made against them. Cooperation entails timely responses to communications from the adjudicating body and timely submission of any evidence or documentation that may be requested. 


The code should also set out clearly the range of sanctions which may be applied in the event of a breach of its provisions (eg. suspension of membership in the case of a professional institute or association, published reprimand, or dismissal or financial penalty in the case of an employing body).


2. Complaints Procedure


It must be possible for anybody, whether a Minister, politician or official or a member of the public, to make a complaint alleging that a named individual, agency or organisation has failed to comply with the applicable Code of Conduct. The code itself, together with details of how and to whom a complaint may be made, must therefore be published and clearly displayed on the website of the body administering the code.


The complaint investigation and adjudication procedure should be clear to all and should be based on the principles of natural justice. Both the initial assessment of a complaint and any investigation and adjudication which may follow must be conducted by or with the involvement of at least one independent person. "Independent" for this purpose means a person who is not, and has not been in the previous 10 years, employed or in business as a lobbyist; in a case where the administering body is a professional institute or association, is not a member of that institute or association; and in a case where the administering body is a company or organisation, is not employed by or on the managing board of that company or organisation.


Codes should have transparency at the heart of the adjudication process. There should be publicly available criteria on the publication of judgements, and the outcome should be communicated to the complainant and to the party under investigation.


An initial assessment of any complaint received should be made within not more than one month of receipt; and complaints should normally be determined within not more than six months of receipt.




30 April 2013