CONSULTATION QUESTIONS

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1 CONSULTATION QUESTIONS Question 1 Do you agree that the Government s three core principles are appropriate to inform the delivery of an effective and proportionate lobbying registration regime in Scotland? We agree in part with the core principles outlined by the government. 1) The introduction of lobbying transparency regulations are essential to, and will only strengthen, Parliament s principles of openness, ease-of-access and accountability. Without sufficient transparency and openness in the policy-making process there can be little accountability. There is also no reason to believe that a lobbying register would present a barrier to participation, even for the smallest and most resource poor groups. Evidence from the longestablished register in North America suggests that information presented by a lobbying register can, in fact, stimulate participation in politics. We suggest, therefore, that this principle be redrafted to recognise that effective regulation of lobbying i.e. a register that puts sufficient information in the public domain to allow meaningful public scrutiny of lobbying activity (detailing objectives, beneficiaries, funding sources and targets) is now essential to good public governance. As the OECD states in its Principles for Transparency and Integrity in Lobbying : Lobbying can provide decision-makers with valuable insights... However, lobbying can also lead to undue influence, unfair competition and regulatory capture to the detriment of the public interest and effective public policies. A sound framework for transparency in lobbying is therefore crucial to safeguard the integrity of the public decision-making process. 2) A register of lobbyists should be designed from the outset to complement and where appropriate join up with existing transparency and ethics measures. For example, information should be logged and presented in a format that it can be cross-referenced with the public registers of ministerial meetings. 3) The register must be proportionate to the scale of lobbying in Scotland. We believe, however, that the government is potentially underplaying the issue. We agree that the register must be straightforward for both registrants and for the public to access. For this reason, it should be available online and in hard copy, and be published in an open format and designed to be fully searchable, sortable and downloadable. 1

2 Question 2 Do you agree that a publicly available register of lobbyists should be introduced in Scotland? Yes. We believe now is the time to introduce mandatory transparency regulations for lobbyists in Scotland. We agree with the government s conclusion that as the powers and responsibilities of the Scottish Parliament increase, so lobbying in Scotland will grow in intensity and volume, thus increasing the need for public scrutiny. As a leading, global commercial lobbying firm with a strong presence in Scotland recently confirmed: As more powers are devolved to Scotland, the need for business to engage with the Parliament and Scottish Government will increase. Another commercial agency described the post-referendum period as an incredibly exciting time for Scottish politics and public affairs, adding that it wanted to capitalise on the increased legislative powers the Scottish Government will receive. As Scotland and the SNP have moved centre stage in UK politics, we are also witnessing an increase in the number of people passing through the so-called revolving door from politics to commercial lobbying. In recent months we have seen, for instance, moves by both the SNP's strategic communications director and the chief of staff of the SNP Westminster Group to commercial lobbying agencies, and the hiring of an aide to the Scottish Labour party by another. This movement feeds public concerns about the cosy relationships between government, officials and the lobbying industry, which can damage public trust. A statutory register of lobbyists is the simplest way to provide public scrutiny of who is seeking to influence decisions in Holyrood. This will only be achieved by requiring lobbyists to provide basic, but meaningful information on their activities. To alternatively require Ministers, MSPs and officials on the receiving end of lobbying, to publish diaries of meetings with lobbyists, as some in the industry have proposed, would be to place the burden entirely on decision-makers. It would also provide only a very partial view of lobbying, which extends far beyond individual, face-to-face meetings. Question 3 Do you agree that no fee should be payable by lobbyists for registering or updating the register? Yes. We support the principle that the register should be publicly funded, principally for the reason set out by the government. Lobbying is an essential part of a healthy democracy, when it is open to public scrutiny. There must be no barrier, financial or otherwise, to anyone wanting to engage with decision-makers in a transparent way. In addition, we believe that for a system to attract public confidence it must be entirely independent of lobbyists, which would not be the case were it be industry-funded. 2

3 Question 4 What are your views on whether the onus to register should lie with individuals who lobby as part of their work, or organisations who lobby? In line with the principle that the system of registration should be proportionate and simple in its operation, we believe that organisations should be required to register, not individuals, (with the exception of sole-trader, third party lobbyists). This is in line with the Committee s recommendation. This would require organisations that trigger registration to list any employees engaged in lobbying activity; or in the case of third party agencies engaged in lobbying, to register a client and any employees engaged in lobbying activity on behalf of that client. Question 5 Should both consultant lobbyists and in-house lobbyists be required to register? Yes. We strongly agree with the government that both consultant and in-house lobbyists should be required to register. This is a significant improvement on the register introduced in Westminster earlier this year, which includes only consultant lobbyists. As both ALT and the commercial lobbying industry have consistently stated, the narrow approach taken by the UK government is mistaken. According to industry estimates, 80 per cent of all lobbying is undertaken by in-house lobbyists. There is no difference between the activities of a lobbyist employed directly for an organisation and an agency lobbyist. A system of regulation that excludes in-house lobbyists is incapable of delivering meaningful lobbying transparency. We believe that a credible system of registration must include all in-house lobbyists, whether representing the interests of business, trade unions or charities. It must also include all third party lobbyists, including those working in law firms, management consultancies, accountancy firms and think tanks. This requires a robust definition of lobbying activity. Consequently, we do not support the consultation s definition of a lobbyist, whether in-house or consultant, as an individual engaged to lobby MSPs or Scottish Ministers. It is both too narrow and vague to be workable. As the OECD states: Experience suggests that effective regulation depends on... a clear and unambiguous definition of lobbyist and lobbying activities targeted by regulation. We urge that the Scottish government follows the approach common to countries that have successfully introduced lobbying transparency measures. This has been to produce a robust definition of the acti vi ty of l obbyi ng. A lobbyist is then anyone paid to conduct such activities, regardless of where, or for whom, they work. Defining who constitutes a lobbyist, what is considered lobbying activity, and who might be a target of lobbying are critical components of effective lobbying transparency rules. As well as the principles outlined by the OECD, a set of best practice guidelines has recently been drafted by the international transparency community, led by the Sunlight Foundation in the US, to help policymakers in this respect. 3

4 Question 6 Should any types of in-house lobbyist be exempt from registration? ALT believes that all organisations that pay people to undertake lobbying activity should be required to register, regardless of the type of organisation. Trade unions and charities, for example, undertake significant lobbying activity, which if excluded, would distort public perceptions of who is seeking to influence Scottish politics. Any approach that attempts to exclude lobbying by non-profit or charitable organisations, for example, should be rejected. Besides creating a loophole for those who may wish to hide their lobbying activity, such a distinction could suggest that there is bad lobbying, which needs to be registered, and good lobbying that can safely be exempted. A register of lobbyists is a transparency measure that opens up government. It should not pass judgement. We do, however, support measures to exempt less well resourced organisations. A register is designed to record all significant lobbying activity. As such, there should be a threshold possibly based on lobbying expenditure below which organisations would not have to register. This would exempt small businesses and small charities. The level of the threshold should be widely consulted on. Question 7 Do you agree that the register should cover the lobbying of MSPs and Ministers? Lobbying of MSPs and Ministers should trigger registration, but we strongly believe that lobbying of most other public officials should also be included if the register is to provide a more accurate picture of lobbying in Scotland. This is in line with other countries, such as Canada. The justification for extending the definition of who constitutes a lobbying target, is that the majority of lobbying activity is not directed at Ministers, or MSPs. Civil servants, including junior government staff, and special advisers are more common targets for lobbyists. As many in the industry pointed out during the passage of the Westminster Lobbying Bill, to exclude their interactions with these groups would be to fundamentally misinterpret how lobbyists operate. Rather than seek to single out specific lobbying targets, we believe an easier and more accurate means of determining who and what should be registered is to focus on the lobbying activity and its purpose. In broad terms: anyone who is paid to communicate with any member of the Scottish Government (or its agencies, advisors or officials), or member of the Scottish Parliament (or their advisors, or staff); for the purpose of influencing legislation, regulation, policy or government contract, or grant; should register their lobbying activity. 4

5 Question 8 What types of communication do you think should be covered by a statutory register? ALT believes that any contact with public officials, whether written or oral communication, electronic or otherwise, should trigger registration. To try and captur e this information on the register, however, would be disproportionate. We support the proposal that face-to-face meetings with Ministers and very senior civil servants should be recorded on the register. We do not support, however, the proposal that only meetings with Ministers or MSP should trigger registration. As a principle, lobbyists should be required to register as close to real time as possible after they have engaged in lobbying activity, regardless of the mode of communication. Certain communications should be exempt, and not trigger registration, including: an oral or written submission to Parliament, or its Committees, that is a matter of public record; a public response to an invitation by government for information or evidence, or a formal response to a public invitation to tender; or administrative requests made by lobbyists, where no attempt is made to influence. This answers the Committee s question: how do you identify the point at which information sharing becomes lobbying? Question 9 Do you agree with the Government s view that paid lobbyists should be required to register? We agree that only paid lobbyists should be required to register. This should include those whose job is not as a lobbyist, but who engage in lobbying occasionally, such as company CEOs. It is possible, with a robust definition, to capture lobbying by these key staff, whose interaction with officials may be sporadic, but whose influence may be significant. Question 10 Do you agree that the register should also allow for voluntary registration by lobbyists not required to register? We agree with the Committee and the government that voluntary registration should be allowed. We also support the idea of allowing organisations to update their register more frequently and with more detailed information than is required. 5

6 Question 11 What are your views on what kind of information each lobbyist should be required to provide on registration? We agree with the Scottish government s position that lobbyists provide regular returns detailing their lobbying activity, and not merely who is lobbying (as required under the new Westminster system). In order for a register of lobbyists to allow meaningful public scrutiny of lobbying it must include details of lobbyists interactions with public officials. In other words, not just who is lobbying, but whom is being lobbied and what issues they are lobbying on. We believe lobbyists should be required to disclose the following on registration: * the name, address and contact information of the organisation, or the client lobbying; * the name of all active lobbyists working on behalf of the organisation or client; plus information on any public office held by the lobbyist in the past five years (capturing the revolving-door ); * Information to identify the subject-matter of the lobbying activity, including any relevant legislative proposal, Bill, resolution, regulation, policy, program, grant, or contract; * the name of any department or other governmental institution at whom the lobbying activity is directed; * Information to identify any communication technique that the registrant uses or expects to use in connection with its communication with public officials: this could include any appeals to the general public, planned events, or funding of secondary organisations, such as a think tank. Lobbyists should provide the above information on a quarterly basis, along with the following: * A good faith estimate of the financial cost of the lobbying activity during the preceding quarter. It is important to be able to see how much money is being invested in lobbying (lobbying is seen as a tactical investment by business, with an anticipated rate of return). It provides an indication of the scale of an organisation s lobbying activity; reveals the spending gap between, for example, business and civil society groups, or multi-nationals and non-profits lobbying for government contracts; as well as trends in lobbying activity. Question 12 How often should lobbyists be required to provide a return detailing their lobbying activity? We support the principle that lobbying reports should be filed as close to real time as possible. Delays in disclosure create the risk that the public would not be aware of lobbying activities until after any legislative or government action has taken place. Registration, we believe, should occur: in the case of consultant lobbyists, within 14 days of the start of a client s contract; and for in-house registrants, within 30 days of the lobbying activity beginning. We propose that a proportionate system for Scotland would require lobbyists to file quarterly returns, in line with many registers around the world, including Westminster. 6

7 Question 13 Do you agree that the Parliament should introduce a Code of Practice for lobbyists setting out guidance on the registration regime and expected standards of behaviour? We support the introduction of a Code of Practice for lobbyists. It should set minimum standards of behaviour and should include, for example, a ban on paying Parliamentarians. Question 14 Do you agree that a register should include the facility for lobbyists to indicate if they already subscribe to any industry Codes of Conduct? We do not oppose a provision for lobbyists to indicate that they subscribe to industry codes of conduct, although this should be additional to, and not a replacement for, the Code of Practice linked to the register. Question 15 Do you have any views on the Committee s proposals for who should be responsible for upkeep and oversight of the Register? The Registrar should be independent of industry and government, as proposed by the Committee. We believe the role of the Registrar should be to: administer the register; provide a public registry of all disclosed lobbying information; and ensure compliance with the law and Code of Practice. They should have the resources to regularly audit the data for accuracy and the power to conduct investigations into potential non-compliance. Registration systems in countries show that this can be done without significant cost to the public purse. Question 16 Do you have any views on what enforcement mechanisms and sanctions should be available in connection with the registration regime? We agree that the registration regime should be focused on helping lobbyists comply with registration requirements. We also support stronger sanctions, including possible criminal charges, for the most serious breaches. Reputation is important to professional lobbyists. The introduction of a sanction requiring the Registrar to inform officials of a clear breach would be an additional means of ensuring compliance. 7

8 Question 17 Do you have any views on whether Parliament, by resolution, should be able to adjust the scope and operation of the registration regime once established? We agree that Parliament should be able to make improvements to the registration system in response to any notable administrative burdens, loopholes, or to respond to changes in the lobbying industry. Question 18 Do you have any views on whether there could be impacts on equalities groups as a result of the proposals outlined? Please draw on specific evidence and/or wider knowledge, experience and expertise. We do not foresee any impact from the proposals on equalities groups. Question 19 Do you have any views on whether there could be any additional costs or other implications for businesses as a result of the proposals outlined? Please draw on specific evidence and/or wider knowledge, experience and expertise. In our experience, which since 2007 has primarily been focused on lobbying for a statutory register in Westminster, proposals for a register of lobbyists are often accompanied by protests from lobbyists that transparency regulations will place an unacceptable burden on their businesses. It is notable, however, that these views are not in evidence in countries where lobbyists are required to register their activities. We believe that if sensible exemptions for small organisations are put in place, and with a straightforward online filing system, the cost to registrants of submitting a quarterly return will not be unduly burdensome. Question 20 Do you have any other comments on the general operation of a register of lobbyists, or on any of the proposals put forward by the Committee or the Government? The Scottish government is right in recognising that the time is right to consider introducing greater transparency in lobbying in Scotland. 8

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